ML18026A595

Responds to NRC Ltr Re Violations Noted in Insp Repts 50-387/94-06 & 50-388/94-06 on 940510.Corrective Actions: Maint Mgt Developed Briefing Package Detailing Mgt Expectations for First Line Supervisors

ML18026A595
Person / Time
Site:	Susquehanna
Issue date:	06/09/1994
From:	Byram R PENNSYLVANIA POWER & LIGHT CO.
To:	Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
PLA-4149, NUDOCS 9406140029
Download: ML18026A595 (9)

Text

ACCELERATED DOCUMENT DISTRIBUTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9406140029 DOC.DATE: 94/06/09 NOTARIZED: NO DOCKET I FACIL:50-387 Susquehanna Steam Electric Station, Unit 1, Pennsylva 05000387 50-388 Susquehanna Steam Electric Station, Unit 2, Pennsylva 05000388 R AUTH. NAME AUTHOR AFFILIATION BYRAM,R.G. Pennsylvania Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION WENZINGER,E.C. Region 1 (Post 820201)

D

SUBJECT:

Responds to 50-387/94-06.&

NRC ltr re violations noted in insp repts 50-388/94-06 on 940510.Corrective actions:

maint mgt developed briefing package detailing mgt expectations for first line supervz.sors.

DISTRIBUTION CODE: IE01D TITLE: General COPIES RECEIVED:LTR (50 Dkt) -Insp Rept/Notice ENCL of Vio ation JResponse SIZE:

NOTES:

D RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-2 PD 1 1 POSLUSNY,C 1 1 D INTERNAL: ACRS 2 2 AEOD/DEIB 1 1 AEOD/DSP/ROAB 1 1 AEOD/DSP/TPAB 1 1 AEOD/TTC 1 1 DEDRO 1 1 NRR/DORS/OEAB 1 1 NRR/DRCH/HHFB 1 1 NRR/DRSS/PEPB 1 1 NRR/PMAS/ILPB1 1 1 NRR/PMAS/IRCB-E 1 1 NUDOCS-ABSTRACT 1 1 OE~DZR 1 1 OGC/HDS2 1 1 CRE~G~LE 02 1 1 RES/HFB 1 '1 RGN1 FILE 01 1 1 EXTERNAL EG&G/BRYCE i J H ~ 1 1 NRC PDR 1 1 NSIC 1 1 D

D D

NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEI CONTACI'HE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDl TOTAL NUMBER OF COPIES REQUIRED: LTTR 23 ENCL 23

'; ': ""'ennsylvania Power & Light Company Two North Ninth Street ~ Allentown, PA 18101.1179 ~ 610/774-5151 Robert G. Byram Senior Vice President-Nuclear 610/774-7502 Fax: 610/774-5019 JUV 09 1994 Mr. Edward C. Wenzinger, Chief Division of Reactor Projects Reactor Projects Branch 2 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 SUSQUEHANNA STEAM ELECTRIC STATION REPLY TO NOTICE OF VIOLATION (387/944641 AND 387/94-06-02) Docket Nos. 50-387 P LA<149 FILE R41-2 50-388

Dear Mr. Wenzinger:

This letter provides Pennsylvania Power & Light Company's response to the Notice of Violation for NRC Combined Inspection Report 50-387/94-06 and 50-388/94-06 dated May l 0, l 994.

PP&L recognizes the significance of procedural compliance. We take seriously thc concern NRC has identified with respect to the failure to folloiv procedures. Thercforc, in addition to the specific corrective actions identified in the violation response we are in thc process of forming a Nuclear Department Continuous Performance Improvement Process Team that will evaluate and recommend enhaiicemcnts to the in-plant work processes utilized at Susquehanna. This Work Process lniprovcment Teani will, in part, evaluate concerns similar to those identified in the Notice of Violation. We ivill inform you of the results of this teams conclusions.

The notice required submittal of a written reply within thirty (30) days of the date of the letter transmitting the Notice of Violation. We trust that the commission will find the attached response acceptable.

Very truly yours, R G y Attachm t 9406140029 940609 PDR ADQCK 05000387 G,l PDR

' FILE R41-2 PLA-4149 Mr. E. C. Wenzinger CC: NRC Document Control Desk (original)

Regional Administrator - Region I Mr. G. S. Barber, NRC Sr. Resident Inspector Mr. C. Poslusny, Jr., NRC Sr. Project Manager

ATTACHMENTTO PLA-4 49 1 FILE R41-2 PAGE I OFS REPLY TO A 1VOTICE OF VIOLTION Technical Specification 6.8.1 requires that written procedures be established, implemented and maintained covering activities referenced in Regulatory Guide 1.33. Regulatory Guide 1.33 requires licensees to establish and implement administrative procedures for safety-related activities.

Violation (387/94-06-01)

The following four examples describe circumstances where maintenance was not performed in accordance with licensee procedures:

1. Maintenance Procedure MT-AD-504, Scaffold Erection, Review and Inspection, Section 4.7 requires that the installer verify that the scaffolding does not interfere with plant operations or endanger the safe operability of plant systems. Specifically, the scaffold shall not obstruct manual or automatic movement of equipment.

Contrary to the above, on April 7, 1994, the 'B'oop of Residual Heat Removal (RHR) system was drained back to the suppression pool when scaffolding prevented the 'B'HR pump discharge check valve from properly seating aAer the 'B'HR pump was shutdown.

2. Nuclear Department Administrative Procedure, NDAP-QA-502, Work Authorization System, requires a Work Authorization to perform work on plant equipment.

Contrary to the above, on March 22, 1994, the scram pilot solenoid valves for hydraulic control units (HCUs) 02-35 and 06-39 were removed without an approved Work Authorization.

3. NDAP-QA-506, Foreign Material Exclusion, requires temporary covers be, installed on system openings during maintenance when the system is unattended.

S Contrary to the above, on March 22, 1994, the inspector observed numerous openings on scram pilot solenoid valve air piping that did not have temporary covers installed.

On March 24, 1994, the inspector observed an opening on HCU 18-51 did not have a temporary cover installed.

4. NDAP-QA-422, Control of Ignition Sources; Cutting, Welding, and Hot Work Permits, form NDAP-QA-422-1, requires movable combustible material be removed from below and within a 35 foot radius of the work area.

Contrary to the above, on March 25, 1994, the inspector observed combustible material ignite and burn below the work area in direct observation of the fire watch.

ATTACHMENTTO PLA-4149 FILE R41-2 PAGE 2 OF 5

~Res ense

1. Reason for the Violation This violation identified examples where the performance of maintenance activities did not meet Susquehanna's standards as set forth in our procedures. Based on our review of these examples, and other self-identified outage work incidents we determined that the expectations of Maintenance management has not been effectively communicated to First Line Supervisors, namely:

1. The importance of First Line Supervision presence in the field;

2. The importance of effective field observations;

3. The importance of adherence to procedures and work plans; and

4. The importance of identifying work activity problems and promptly correcting them.

Consequently, the importance of adherence to procedures and work plans was not consistently being reinforced by the First Line Supervisors with the individuals performing work activities in the field.

2. Corrective Ste s Which Have Been Taken and the Results Achieved Maintenance management has developed a briefing package detailing management's expectations for First Line Supervisors. This briefing package stresses the importance of the presence of First Line Supervisors in the field; the importance of effective field observation for work activities under their jurisdiction; the importance of adherence to procedures and work plans; and the importance of identifying work activity problems (e.g., industrial safety issues, deviations from work plans, etc.) and taking prompt corrective actions. This briefing package has been reviewed by Maintenance Section functional unit supervisors.

3. Corrective Ste s Which Will Be Taken to Avoid Further Violations

a. Training on management's expectations for First Line Supervisors detailed in (2) above will be conducted for First Line Supervisors under Nuclear Maintenance's jurisdiction for work performed at Susquehanna. This training will be completed by August 1, 1994.

b. Training to emphasize the importance of adherence to procedures and work plans and the importance of identifying work activity problems so that they can be promptly corrected will be conducted by First Line Supervisors under Nuclear

ATTACHMENTTO PLA-4 I 49 FILE R4)-2 PAGE 3 OF 5 Maintenance's jurisdiction for their work crews. Initial training and incorporation of this training into a standard pre-outage briefing package, to be included as maintenance pre-outage training prior to each refueling outage, will be completed by October 1, 1994.

c. Upgrades to self assessment processes will be made by Nuclear Maintenance to validate and enforce the above expectations for First Line Supervisors; to measure the effectiveness of the First Line Supervisors'resence and monitoring activities on the workers'erformance; and to make these assessment processes more effective and less cumbersome. Upgrades to the self assessment processes are targeted for completion by December 1, 1994. Evaluations to determine the.

effectiveness of First Line Supervisors'xpectations will be completed by July 1, 1995.

4. Date of Full Com liance PPAL will be in full compliance by July 1, 1995, following the evaluations to determine the effectiveness of the self assessment process upgrades detailed in (3.c) above.

0 ATTACHMENTTO PLA-4149 FILE R41-2 PAGE4OF5 Violation (387/94-06-02)

The following example describes a circumstance where a nonconforming condition on Unit 1 was not evaluated and dispositioned by the NCR procedure.

NDAP-QA-0754, Nonconformance Reports - Control and Processing, requires, in part, that nonconforming conditions with generic implications be evaluated and dispositioned via the NCR process.

Contrary to the above, during the fall 1993 Unit 1 refueling outage, on October 14, 1993, overheated MSIV cables were discovered (while-performing.

Work Authorizations C30165 and C30168) and replaced without documenting this nonconforming condition in an NCR.

~Res ense

1. Reason for the Violation This violation identified a case in which a Nonconformance Report (NCR) was not generated. During the Unit 1 7th Refueling and Inspection Outage station personnel discovered that two inboard MSIV control/indication cables showed signs of overheating. The cables were replaced as part of cable modification work activities in progress at that time; however, the condition was not documented on an NCR as required in NDAP-QA-0754. Although NDAP-QA-0754 allows deficiencies to be corrected during in-progress work without an NCR being generated, heat damage to cables associated with a safety system inside primary containment would not be expected under normal operating conditions. The effects of that condition should have been assessed at that time. Susquehanna's standards for identifying discrepancies and assessing them were not met in this case.

2. Corrective Ste s Which Have Been Taken and the Results Achieved

a. The Unit 1 cables found damaged during the Unit 1 7th Refueling and Inspection Outage were replaced.

b. Following identification of the damaged Unit 2 cables an NCR was generated.

The Unit 2 NCR also contains an assessment of the Unit MSIV system. This 1

assessment concluded that the condition of the Unit cables did not affect the 1

ability of the cables to provide power to the associated components.

Additionally, if electric power was interrupted, the associated components would actuate to their fail safe position.

ATTACHMENTTO PLA-4149 FILE R41-2 PAGE 5 OF 5

c. The cause of the Unit 2 cable damage was determined to be from thermal losses from an uninsulated main steam line hanger. The Unit 2 pipe hanger and other similar hangers have been subsequently insulated.

d. The generic implications of heat damaged cables were investigated during a walk down of the Unit 2 primary containment. Any safety related cables that could potentially be affected by heat from uninsulated pipe hangers were evaluated and rerouted and/or replaced ifnecessary.

3. Corrective Ste s Which Will Be Taken to Avoid Further Violations

a. Inspection of the applicable Unit 1 MSIV cables and other cables in the area, will be conducted during the Unit 1 8th Refueling and Inspection Outage. The applicable main steam line hangers will be insulated and cable repairs/reroutes will be made based on the results of the inspections. These work activities will be completed by July 1, 1995.

b. The Specification governing the installation of cables and raceways (C-1035) will be revised to reflect the necessary separation needed for heat source considerations. These revisions will be completed by June 30, 1994.

c. Training on this event, with emphasis on evaluating/reporting potentially nonconforming conditions will be included in the site Continuing Engineering Training curriculum. This training is scheduled to begin on July 11, 1994.

d. The need to generate an NCR to identify potential discrepancies with significant implications will be reviewed with the Modifications Installation Group personnel. This review will be completed by July 1,1994.

4. Date of Full Com liance PP8cL will be in full compliance by July 1, 1995, with the completion of the Unit 1 work outage activities.