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{{#Wiki_filter:UNITED STATES | |||
NUCLEAR REGULATORY COMMISSION | |||
REGION I | |||
475 ALLENDALE ROAD | |||
KING OF PRUSSIA, PA 19406-1415 | |||
November 13, 2009 | |||
EA-09-248 | |||
Mr. Timothy S. Rausch | |||
Senior Vice President and Chief Nuclear Officer | |||
PPL Susquehanna, LLC | |||
769 Salem Boulevard, NUCSB3 | |||
Berwick, PA 18603 | |||
SUBJECT: SUSQUEHANNA STEAM ELECTRIC STATION - NRC INTEGRATED | |||
INSPECTION REPORT 05000387/2009004 AND 05000388/2009004 | |||
Dear Mr. Rausch: | |||
On SeptElmber 30, 2009, the U. S. Nuclear Regulatory Commission (NRC) completed an | |||
inspection at your Susquehanna Steam Electric Station Units 1 and 2. The enclosed integrated | |||
inspection report presents the inspection results, which were discussed with you and other | |||
members of your staff during a preliminary exit meeting on October 9, 2009. | |||
This inspection examined activities completed under your license as they relate to safety and | |||
compliance with the Commission's rules and regulations and with the conditions of your license. | |||
The inspectors reviewed selected procedures and records, observed activities, and interviewed | |||
personnel. | |||
Based on the results of this inspection, two examples of an apparent violation (AV) were | |||
identified, involving PPL Susquehanna, LLC (PPL) failing to ensure that individual license | |||
holders, on shift in the capacity of senior reactor operators (SROs), met the medical | |||
prereqUisites required for holding a license prior to performing the duties of a licensed operator | |||
as required by 10 CFR 55.3. In one occasion in August 2009, an SRO failed a medical | |||
examination which identified a disqualifying condition, in that, the examination identified that the | |||
SRO's vision did not meet the health requirements stated in ANSI/ANS 3.4-1983, Section 5.4.5, | |||
"Eyes." However, he performed the function of an SRO during three watches with a license | |||
that was not appropriately conditioned to require that corrective lenses be worn. In the second | |||
occasion, a different SRO performed licensed operator duties 52 times between April 1, 2009, | |||
and July 22, 2009, after the deadline for his biennial medical examination had passed. The | |||
medical examination may have identified an issue with the SRO's medical condition and general | |||
health that would have disqualified him from being authorized by a license. | |||
This app,arent violation is being considered for escalated enforcement action in accordance with | |||
the NRC Enforcement Policy. The current Enforcement Policy is included on the NRC's Web | |||
site at (http://www.nre.gov/about-nrciregulatorv/enforcementienforce-pol.html). | |||
T. Rausch 2 | |||
Upon discovery, PPL removed both individuals from watchstanding duties pending follow-up | |||
medical evaluations and, in the August 2009 example involving the SRO who failed his vision | |||
examination resulting in a disqualifying condition, PPL requested a conditional NRC license to | |||
address the disqualifying medical condition. For the July 2009 example, the SRO passed his | |||
biennial medical examination when administered. Both issues have been entered into PPL's | |||
corrective action program. See Section 1R11 of the attached report for additional details. In | |||
addition, since you identified the violation, and based on our understanding of your corrective | |||
actions, a civil penalty may not be warranted in accordance with Section VI.C.2 of the | |||
Enforcement Policy. | |||
The NRC believes we have enough information to make a final decision on the matter. Before | |||
the NRC makes its enforcement decision, we provided you an opportunity to either: (1) respond | |||
to the apparent violation addressed in this inspection report within 30 days of the date of this | |||
letter or, (2) request a predecisional enforcement conference. On November 9, 2009, I | |||
contacted Mr. Jeff Helsel, Susquehanna Plant Manager, and members of your staff and | |||
informed them of this opportunity. | |||
On November 10, 2009, Michael Crowthers, Susquehanna Regulatory Assurance Manager, | |||
informed my staff that you elected to provide a written response. Your written response should | |||
be clearly marked as a "Response to an Apparent Violation in Inspection Report | |||
0500038"712009004 AND 05000388/2009004; EA-09-248" and should include for each example | |||
of the AV: (1) the reason for the AV, or, if contested, the basis for disputing the AV; (2) the | |||
corrective steps that have been taken and the results achieved; (3) the corrective steps that will | |||
be taken to avoid further violations; and (4) the date when full compliance will be achieved. | |||
Your response may reference or include previously docketed correspondence, if the | |||
correspondence adequately addresses the required response. If an adequate response is not | |||
received within the time specified or an extension of time has not been granted by the NRC, the | |||
NRC will proceed with its enforcement decision. | |||
In addition, please be advised that the number of violations and characterization of the AV | |||
described in the enclosed inspection report may change as a result of further NRC review. You | |||
will be advised by separate correspondence of the results of our deliberations on this matter. | |||
In addition, this report documents two NRC-identified findings and one self-revealing finding of | |||
very low safety significance (Green). Two of these findings were determined to involve a | |||
violation of NRC requirements. Additionally, one licensee-identified violation, which was | |||
determined to be of very low safety significance, is listed in this report. However, because of | |||
the very low safety significance and because they are entered into your corrective action | |||
program (CAP), the NRC is treating these findings as non-cited violations (NCVs), consistent | |||
with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV in this report, you | |||
should provide a response within 30 days of the date of this inspection report, with the basis for | |||
your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, | |||
Washington, D.C. 20555-0001; with copies to the Regional Administrator Region I; the Director, | |||
Office of Enforcement, United States NRC, Washington, D.C. 20555-0001; and the NRC | |||
Resident Inspector at the Susquehanna Steam Electric Station. In addition, if you disagree with | |||
the characterization of the cross cutting aspect of any finding in this report, you should provide a | |||
response within 30 days of the date of this inspection report, with the basis for your | |||
disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at the | |||
T. Rausch 3 | |||
Susquehanna Steam Electric Station. The information you provide will be considered in | |||
accordance with Inspection Manual Chapter 0305. | |||
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its | |||
enclosure, and your response (if any), will be available electronically for public inspection in the | |||
!\IRC Public Document Room or from the Publicly Available Records (PARS) component of the | |||
NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at | |||
http://www.nrc.qov/reading-rm/adams.html(the Public Electronic Reading Room). | |||
Sincerely, | |||
IRA! | |||
David C. Lew, Director | |||
Division of Reactor Projects | |||
Docket Nos. 50-387; 50-388 | |||
License Nos. NPF-14, NPF-22 | |||
Enclosures: Inspection Report 05000387/2009004 and 05000388/2009004 | |||
Attachment: Supplemental Information | |||
cc w/encl: Distribution via ListServ | |||
T. Rausch 4 | |||
Susquehanna Steam Electric Station. The information you provide will be considered in | |||
accordance with Inspection Manual Chapter 0305. | |||
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its | |||
enclosure, and your response (if any), will be available electronically for public inspection in the | |||
NRC Public Document Room or from the Publicly Available Records (PARS) component of the | |||
NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at | |||
http://www.nrc.gov/reading-rm/adams.html(the Public Electronic Reading Room). | |||
Sincerely, | |||
IRA! | |||
David C. Lew, Director | |||
Division of Reactor Projects | |||
Docket Nos. 50-387; 50-388 | |||
License Nos. NPF-14, NPF-22 | |||
Enclosures: Inspection Report 05000387/2009004 and 05000388/2009004 | |||
Attachment: Supplemental Information | |||
cc w/encl: Distribution via ListServ | |||
Distribution w/encl: (via E-mail) | |||
S. Collins, RA (R10RAMAIL Resource) | |||
M. Dapas, DRA (R10RAMAIL Resource) | |||
D. Lew, DRP (R1 DRPMAIL Resource) | |||
J. Clifford, DRP (R1 DRPAMAIL Resource) | |||
P. Krohn, DRP | |||
D. Holody I~I OE (R10RAMAIL Resource) | |||
R Fuhrmeister, DRP | |||
A. Rosebrook, DRP | |||
}} | }} |
Latest revision as of 01:31, 14 November 2019
ML093170375 | |
Person / Time | |
---|---|
Site: | Susquehanna ![]() |
Issue date: | 11/13/2009 |
From: | David Lew Division Reactor Projects I |
To: | Rausch T Susquehanna |
KROHN P, RI/DRP/PB4/610-337-5120 | |
References | |
EA-09-248 IR-09-004 | |
Download: ML093170375 (47) | |
See also: IR 05000387/2009004
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD
KING OF PRUSSIA, PA 19406-1415
November 13, 2009
Mr. Timothy S. Rausch
Senior Vice President and Chief Nuclear Officer
769 Salem Boulevard, NUCSB3
Berwick, PA 18603
SUBJECT: SUSQUEHANNA STEAM ELECTRIC STATION - NRC INTEGRATED
INSPECTION REPORT 05000387/2009004 AND 05000388/2009004
Dear Mr. Rausch:
On SeptElmber 30, 2009, the U. S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Susquehanna Steam Electric Station Units 1 and 2. The enclosed integrated
inspection report presents the inspection results, which were discussed with you and other
members of your staff during a preliminary exit meeting on October 9, 2009.
This inspection examined activities completed under your license as they relate to safety and
compliance with the Commission's rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
Based on the results of this inspection, two examples of an apparent violation (AV) were
identified, involving PPL Susquehanna, LLC (PPL) failing to ensure that individual license
holders, on shift in the capacity of senior reactor operators (SROs), met the medical
prereqUisites required for holding a license prior to performing the duties of a licensed operator
as required by 10 CFR 55.3. In one occasion in August 2009, an SRO failed a medical
examination which identified a disqualifying condition, in that, the examination identified that the
SRO's vision did not meet the health requirements stated in ANSI/ANS 3.4-1983, Section 5.4.5,
"Eyes." However, he performed the function of an SRO during three watches with a license
that was not appropriately conditioned to require that corrective lenses be worn. In the second
occasion, a different SRO performed licensed operator duties 52 times between April 1, 2009,
and July 22, 2009, after the deadline for his biennial medical examination had passed. The
medical examination may have identified an issue with the SRO's medical condition and general
health that would have disqualified him from being authorized by a license.
This app,arent violation is being considered for escalated enforcement action in accordance with
the NRC Enforcement Policy. The current Enforcement Policy is included on the NRC's Web
site at (http://www.nre.gov/about-nrciregulatorv/enforcementienforce-pol.html).
T. Rausch 2
Upon discovery, PPL removed both individuals from watchstanding duties pending follow-up
medical evaluations and, in the August 2009 example involving the SRO who failed his vision
examination resulting in a disqualifying condition, PPL requested a conditional NRC license to
address the disqualifying medical condition. For the July 2009 example, the SRO passed his
biennial medical examination when administered. Both issues have been entered into PPL's
corrective action program. See Section 1R11 of the attached report for additional details. In
addition, since you identified the violation, and based on our understanding of your corrective
actions, a civil penalty may not be warranted in accordance with Section VI.C.2 of the
The NRC believes we have enough information to make a final decision on the matter. Before
the NRC makes its enforcement decision, we provided you an opportunity to either: (1) respond
to the apparent violation addressed in this inspection report within 30 days of the date of this
letter or, (2) request a predecisional enforcement conference. On November 9, 2009, I
contacted Mr. Jeff Helsel, Susquehanna Plant Manager, and members of your staff and
informed them of this opportunity.
On November 10, 2009, Michael Crowthers, Susquehanna Regulatory Assurance Manager,
informed my staff that you elected to provide a written response. Your written response should
be clearly marked as a "Response to an Apparent Violation in Inspection Report
0500038"712009004 AND 05000388/2009004; EA-09-248" and should include for each example
of the AV: (1) the reason for the AV, or, if contested, the basis for disputing the AV; (2) the
corrective steps that have been taken and the results achieved; (3) the corrective steps that will
be taken to avoid further violations; and (4) the date when full compliance will be achieved.
Your response may reference or include previously docketed correspondence, if the
correspondence adequately addresses the required response. If an adequate response is not
received within the time specified or an extension of time has not been granted by the NRC, the
NRC will proceed with its enforcement decision.
In addition, please be advised that the number of violations and characterization of the AV
described in the enclosed inspection report may change as a result of further NRC review. You
will be advised by separate correspondence of the results of our deliberations on this matter.
In addition, this report documents two NRC-identified findings and one self-revealing finding of
very low safety significance (Green). Two of these findings were determined to involve a
violation of NRC requirements. Additionally, one licensee-identified violation, which was
determined to be of very low safety significance, is listed in this report. However, because of
the very low safety significance and because they are entered into your corrective action
program (CAP), the NRC is treating these findings as non-cited violations (NCVs), consistent
with Section VI.A.1 of the NRC Enforcement Policy. If you contest any NCV in this report, you
should provide a response within 30 days of the date of this inspection report, with the basis for
your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk,
Washington, D.C. 20555-0001; with copies to the Regional Administrator Region I; the Director,
Office of Enforcement, United States NRC, Washington, D.C. 20555-0001; and the NRC
Resident Inspector at the Susquehanna Steam Electric Station. In addition, if you disagree with
the characterization of the cross cutting aspect of any finding in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at the
T. Rausch 3
Susquehanna Steam Electric Station. The information you provide will be considered in
accordance with Inspection Manual Chapter 0305.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any), will be available electronically for public inspection in the
!\IRC Public Document Room or from the Publicly Available Records (PARS) component of the
NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.qov/reading-rm/adams.html(the Public Electronic Reading Room).
Sincerely,
IRA!
David C. Lew, Director
Division of Reactor Projects
Docket Nos. 50-387; 50-388
Enclosures: Inspection Report 05000387/2009004 and 05000388/2009004
Attachment: Supplemental Information
cc w/encl: Distribution via ListServ
T. Rausch 4
Susquehanna Steam Electric Station. The information you provide will be considered in
accordance with Inspection Manual Chapter 0305.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any), will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of the
NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html(the Public Electronic Reading Room).
Sincerely,
IRA!
David C. Lew, Director
Division of Reactor Projects
Docket Nos. 50-387; 50-388
Enclosures: Inspection Report 05000387/2009004 and 05000388/2009004
Attachment: Supplemental Information
cc w/encl: Distribution via ListServ
Distribution w/encl: (via E-mail)
S. Collins, RA (R10RAMAIL Resource)
M. Dapas, DRA (R10RAMAIL Resource)
D. Lew, DRP (R1 DRPMAIL Resource)
J. Clifford, DRP (R1 DRPAMAIL Resource)
P. Krohn, DRP
D. Holody I~I OE (R10RAMAIL Resource)
R Fuhrmeister, DRP
A. Rosebrook, DRP
E. Torres, DRP
J. Bream, DRP
P. Finney, DRP, RI
S. Farrell, DRP, OA
L. Trocine, RI OEDO
RidsNrrPMPeachBottom Resource
RidsNrrDorlLpl1-2 Resource
SUNSI Review Complete: AAR (Reviewer's Initials)
DOCUMENT NAME: G:\DRP\BRANCH4\lnspection Reports\Susquehanna\SQ 3rd Qtr
2009\SUS2009_004_g.doc
After declaring this document "An Official Agency Record" it will be released to the Public.
To receive a copy of this document. indicate in the box: "C":: Copy without attachment/enclosure "E";; Copy with attachmenUenciosure liN" No copy
OFFICE RIIDRP I RI/DRP I R1/0E I R1/DRP I
NAME ARosebrookl PKrohnl DHoiody/AED for DLew
lOATE 11/12/09 11/12/09 11112109 11/12/09
OFFICIAL RECORD COPY
U.S NUCLEAR REGULATORY COMMISSION
REGION I
Docket No: 50-387, 50-388
Report No: 05000387/2009004 and 05000388/2009004
Licensee: PPL Susquehanna, LLC
Facility: Susquehanna Steam Electric Station, Units 1 and 2
Location: Berwick, Pennsylvania
Dates: July 1, 2009 through September 30, 2009
Inspectors: F. Jaxheimer, Senior Resident Inspector
P. Finney, Resident Inspector
G. Meyer, Senior Reactor Inspector
S. Chaudhary, Reactor Inspector
J. Furia, Senior Health Physicist
A. Rosebrook, Senior Project Engineer
O. Masnyk-Bailey, Health Physicist
S. Hammann, Health Physicist
J. Nicholson, Health Physicist
Reviewed By: Paul G. Krohn, Chief
Projects Branch 4
Approved By: David C. Lew, Director
Division of Reactor Projects
Enclosure
2
TABLE OF CONTENTS
SUMMARY OF FINDINGS ......................................................................................................... 3
REPORT DETAILS .....................................................................................................................6
1. REA,CTOR SAFETy ...........................................................................................................6
1R04 Equipment Alignment ..............................................................................................6
1R05 Fire Protection .........................................................................................................7
1R06 Flood Protection Measures ...................................................................................... 9
1R07 Heat Sink Performance ........................................................................................... 9
1R11 Licensed Operator Requalification Program .......................................................... 11
1R12 Maintenance Effectiveness .................................................................................... 15
1R13 Maintenance Risk Assessments and Emergent Work Control ............................... 17
1R15 Operability Evaluations .......................................................................................... 18
1R18 Plant Modifications ................................................................................................ 19
1R19 Post-Maintenance Testing .....................................................................................20
1R22 Surveillance Testing .............................................................................................. 20
1EP6 Drill Evaluation ......................................................................................................21
2. RADIATION SAFETY .......................................................................................................21
20S1 Access Control to Radiologically Significant Areas ................................................ 21
20S2 ALARA Planning and Controls ...............................................................................22
20S3 Radiation Monitoring Instrumentation .................................................................... 24
4. OTHER ACTiViTIES ......................................................................................................... 25
40A1 Performance Indicator Verification ......................................................................... 25
40A2 Identification and Resolution of Problems .............................................................. 25
40A5 Other Activities ......................................................................................................28
40A6 Meetings, Including Exit. ........................................................................................ 29
40A7 Licensee-Identified Violations ................................................................................ 29
ATTACHMENT: SUPPLEMENTAL INFORMATION ................................................................ 30
SUPPLE.MENTAL INFORMATION ......................................................................................... A-1
KEY POINTS OF CONTACT .................................................................................................. A-1
LIST OF ITEMS OPENED, CLOSED, AND DiSCUSSED ....................................................... A-1
LIST OF DOCUMENTS REVIEWED ...................................................................................... A-2
LIST OF ACRONYMS .......................................................................................................... A-12
Enclosure
3
SUMMARY OF FINDINGS
IR 05000387/2009004,05000388/2009004,07/01/2009 - 09/30/2009; Susquehanna Steam
Electric Station, Units 1 and 2; Fire Protection, Licensed Operator Requalification Program,
Maintenance Effectiveness, ALARA Planning and Controls.
The report covered a 3-month period of inspection by resident inspectors and announced
inspections by regional reactor inspectors. Two Green non-cited violations (NCVs), and one
Green finding were identified. In addition, one apparent violation (AV) item being considered for
escalated enforcement action in accordance with the NRC Enforcement Policy. The current
Enforcement Policy is included on the NRC's Web site at
(http://wvvw.nrc.gov/about-nrc!regulatory/enforcementlenforce-pol.html). The significance of
most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual
Chapter (IMC) 0609, "Significance Determination Process" (SOP). Cross-cutting aspects
associated with findings are determined using IMC 0305, "Operating Reactor Assessment
Program," dated August 2009. Findings for which the SOP does not apply may be Green or be
assigned a severity level after NRC management review. The NRC's program for overseeing
the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor
Oversight Process," Revision 4, dated December 2006.
A. NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green. The inspectors identified a Green NCV of the Susquehanna, Unit 2 Operating
License Condition 2.C.(3), Fire Protection for failure to administratively control
combustible loading in an area on the 686' elevation of the control structure. As a result,
a normally locked storage area was discovered to contain numerous combustibles
without deSignated detection, suppression, or a pre-fire plan. This issue was placed in
PPL's corrective action program (CAP) and immediate corrective actions included the
removal of some of the combustible materials and the assignment of hourly fire watches.
The finding was more than minor because it was associated with the external factors
attribute (fire) of the Mitigating Systems cornerstone objective to ensure the availability,
reliability, and capability of systems that respond to initiating events to prevent
undesirable consequences. Specifically, PPL did not ensure that plant procedures
controlled the use and storage of combustible materials and that a combustible loading
analysis was maintained for a locked storage area fire zone in the control structure. The
inspectors assessed this finding in accordance with IMC 0609, Appendix F, "Fire
Protection Significance Determination Process", and determined the finding to be of very
low safety significance (Green) because the fire barrier between the safety-related
equipment in the lower relay room and this storage area was being properly maintained
and found in good physical condition. The finding was determined to have a cross
cutting aspect in the area of Problem Identification and Resolution, Corrective Action
Program, because PPL did not implement a CAP with a low threshold for identifying
issues P.1(a). Specifically, PPL had reasonable opportunities to identify the
combustible loading issue on multiple occasions during access of the storage room.
(Section 'I R05)
Enclosure
4
AV... PPL identified two examples of an apparent violation (AV), involving PPL
Susquehanna, LLC (PPL) failing to ensure that individual license holders, on shift in the
capacity of senior reactor operators (SROs), met the medical prerequisites required for
holding a license prior to performing the duties of a licensed operator as required by 10
CFR 55.3. In one occasion in August 2009, an SRO failed a medical examination which
identified a disqualifying condition, in that, the examination identified that the SRO's
vision did not meet the health requirements stated in ANSI/ANS 3.4-1983, Section 5.4.5,
"Eyes." However, he performed the function of an SRO during three watches with a
license that was not appropriately conditioned to require that corrective lenses be worn.
In the second occasion, a different SRO performed licensed operator duties 52 times
between April 1, 2009, and July 22, 2009, after the deadline for his biennial medical
examination had passed. The medical examination may have identified an issue with
the SRO's medical condition and general health that would have disqualified him from
being authorized by a license. Upon discovery, PPL removed both individuals from
watchstanding duties pending follow-up medical evaluations and, in the case involving
the SRO whose failed medical examination resulted in a disqualifying condition, PPL
requested a conditional NRC license to address the disqualifying medical condition.
Both issues have been entered into PPL's corrective action program.
Each example was evaluated independently using the traditional enforcement process
bf:lcause the failure to determine an operator's medical condition and general health has
the potential to impact or impede the regulatory process. Specifically, medical
certification and conditional licensing are used by the NRC to ensure health conditions
wi" not adversely affect operator duties or performance. The finding was determined to
have a cross-cutting aspect in the area of Problem Identification and Resolution,
Operating Experience, because PPL did not systematically collect, evaluate, and
communicate relevant external operating experience P.2(a). Specifically, PPL failed to
evaluate NRC Information Notice 2004-20 for medical examination issue applicability in
accordance with their operating experience review program as evidenced by the 2008
SL-IV NCV (NRC IR 50-387 & 50-388 2008302-01), for an initial licensed operator
application submitted to the NRC with a disqualifying medical condition, as well as these
two events in July and August of 2009. (Section 1R11.2)
- Green. The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion
XVI, "Corrective Action," in that PPL did not implement timely corrective actions to
preclude repetition of a significant condition adverse to quality. Specifically, actions
taken to address causes of the Unit 1 high pressure coolant injection (HPCI) stop valve
failure to close in 2006 did not prevent the same HPCI stop valve from failing to close on
August 18, 2009. In both cases, the stop valve failure to close rendered this single train
HPCI system inoperable as it was unable to meet the 30 second injection response time
as described in the design basis. Corrective maintenance was performed on the valve
and the issue was entered into PPL's CAP.
The finding is more than minor because it adversely affected the performance attribute
of the Mitigating Systems cornerstone objective, to ensure the availability, reliability, and
capability of equipment that respond to initiating events to prevent undesirable
consequences. Specifically, a full closed stop valve indication resets the HPCI ramp
generator via a lower limit switch. Without this reset, the governor is unprepared to
restart the turbine from an idle state during a designed basis event. The inspectors
assessed this finding in accordance with IMC 0609, Attachment 4, "Phase 1 Initial
Screening and Characterization of Findings" and determined the finding to be of very low
Enclosure
5
safety significance because it did not result in an actual loss of safety function for greater
than the Technical Specification allowed outage time. The finding was determined to
have a cross-cutting aspect in the area of Problem Identification and Resolution,
Corrective Action Program, because PPL did not take appropriate corrective actions to
address safety issues in a timely manner, commensurate with their safety significance
and complexity [P .1 (d)]. Specifically, PPL did not appropriately implement corrective
actions following the 2006 failure of the HPCI stop valve. (Section 1R12)
Cornerstone: Occupational Radiation Safety
- Green. A self-revealing, Green finding was identified that involved inadequate work
planning relative to the in-vessel visual inspection! inservice inspection (lWIIISI) of the
reactor vessel that resulted in additional unplanned collective exposure contrary to as
low-as-is-reasonably-achievable (ALARA) controls. Specifically, the utilization of
inexperienced workers to perform the various tasks involved in the IWIlISI activity
resulted in the additional collective exposure to perform this routine task. This finding
was entered into PPL's Correction Action Program for resolution.
This finding is more than minor because it resulted in unplanned, unintended collective
exposure that was greater than 50 percent above the intended collective exposure and
greater than 5 person-rem. Additionally, the performance deficiency adversely affected
the radiation protection cornerstone objective. The inspectors assessed the finding in
accordance with IMC 0609, Appendix C, "Occupational Radiation Safety Significance
Determination Process," and determined that the finding was of very low safety
significance (Green) because the finding was due to ALARA work control planning and
the 3-year rolling average collective exposure at Susquehanna was less than 240
person-rem (107 person-rem for 2005-2007). This finding was determined to have a
cross-cutting aspect in the area of Human Performance, Resources, because PPL did
not utilize sufficiently qualified personnel to assure occupational radiation safety
requirements were met H.2{b). Specifically, PPL's use of inexperienced contract
workers resulted in additional collective exposure that could have been avoided.
(Section 20S2)
B. Licensee Identified Violations
A violation of very low safety significance. which was identified by PPL. has been
reviewed by the inspectors. Corrective actions taken or planned by PPL have been
entered into PPL's CAP. This violation and corrective action tracking numbers are listed
in Section 40A7 of this report.
Enclosure
6
REPORT DETAILS
Summary of Plant Status
Susquehanna Steam Electric Station (SSES) Unit 1 began the inspection period at the
authorized licensed power level of 94.4 percent rated thermal power (RTP). On September 4,
2009, Unit 1 was reduced to 70 percent over 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> in support of a control rod sequence
exchangEl and pattern adjustment. Unit 1 remained at 94.4 percent RTP for the remainder of
the inspection period.
SSES Unit 2 began the inspection period at the authorized licensed power level of 94.4 percent
RTP. On September 12,2009, Unit 2 was reduced to 58 percent over 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> in support of a
control rod sequence exchange and pattern adjustment. Unit 2 remained at 94.4 percent RTP
for the remainder of the inspection period.
Note: The licensed RTP for both units is 3952 megawatts thermal. The Extended Power
Uprate (EPU) License Amendment for SSES was approved in January 30,2008, and was
implemented for both units in accordance with the issued license conditions. For the current
inspection period, the authorized power level for both units is 94.4 percent of the EPU licensed
power limit.
1. REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and 8arrier Integrity
1R04 Equipment Alignment
.1 Partial Walkdown (71111.04 - 3 Samples)
a. Inspection Scope
The inspectors performed partial walkdowns to verify system and component alignment
and to identify any discrepancies that would impact system operability. The inspectors
verified that selected portions of redundant or backup systems or trains were available
while certain system components were out-of-service. The inspectors reviewed
selected valve positions, electrical power availability, and the general condition of major
system components. Documents reviewed are listed in the Attachment. The
walkdowns included the following systems:
- Unit 1, 18 residual heat removal (RHR) components and instrumentation with
focus on behavior during pressurization and venting;
- Plant discharge line (blow down) and river water make-up system parameters
and lineup during investigation of groundwater issue described by CR 1167146;
and
- "An and "En emergency diesel generators (EDGs) when "En EDG substituted for
"8" EDG.
b. Findings
No findings of significance were identified.
Enclosure
7
.2 Complete Walkdown (71111.04S - 1 Sample)
a. Inspection Scope
The inspectors performed a detailed review of the alignment and condition of the station
nitrogen system and the Unit 2 containment instrument gas system. The inspectors
reviewed operating procedures, checkoff lists, and system piping and instrumentation
drawings. Walkdowns of accessible portions of the systems were performed to verify
components were in their correct positions and to assess the material condition of
systems and components. The inspectors evaluated ongoing maintenance and
outstanding Condition Reports (CR) associated with both systems to determine the
effect on system health and reliability. The inspectors verified proper system alignment
and looked at system operating parameters. Documents reviewed are listed in the
Attachment. The walkdown included the following system and its interconnection:
- Unit 2, Nitrogen and Primary Containment Instrument Gas.
b Findings
No findings of significance were identified.
1R05 Fire Protection (71111.050 - 5 Samples)
Fire Protection - Tours
a. Inspection Scope
The inspectors reviewed PPL's fire protection program to evaluate the specified fire
protection deSign features, fire area boundaries, and combustible loading requirements
for selected areas. The inspectors walked down those areas to assess PPL's control of
transient combustible material and ignition sources, fire detection and suppression
capabilities, fire barriers, and any related compensatory measures to assess PPL's fire
protection program in those areas. Documents reviewed are listed in the Attachment.
The inspected areas included:
- Unit 1, battery rooms, fire zones 0-28 B-1 (11) and 0-28 I thru N;
- Unit 1, containment access area (1-401);
- Security control center, fire zone 0-83, FP-013-360;
- Control structure charcoal filter area and operations storage area on elevation
687', FP-013-135; and
- Central access control area and chemistry laboratory, elevation 676', FP-013
134.
b. Findings
Introduction: The inspectors identified that PPL was not administratively controlling
combustible loading in an area on the 686' elevation of the control structure as
specifically required by the Susquehanna Fire Protection Program and specifically
described as a provision of the Fire Protection Program Report (FPPR). This finding
Enclosure
8
was determined to be of very low safety significance (Green) and an NCV of the SSES
Unit 2 Operating License Condition 2.C(3), Fire Protection.
Description: During a fire walkdown inspection in the control structure, the resident
inspectors identified that an operations department space, a normally locked storage
area on 686' elevation, contained numerous combustibles. Most items stored in the
area were found on open shelves or stacked on the floor. The accumulation of
combustibles included (but was not limited to) wood, plastic, cardboard boxes, old paper
records, rubber drain hoses, radio equipment, refueling support furniture, and labeling
supplies. Inspectors immediately asked operations staff if this room was part of any fire
pre-plan (fire fighting guideline/procedure). The room was not incorporated in any of the
site fire pre-plans and inspectors did not locate any combustible storage permits. When
inspectors could not verify the area was being controlled by the design control process
as a combustible storage area and could not verify that PPL was procedurally controlling
the use and storage of combustible materials in this area, the issue was brought to PPL
management's attention. PPL took immediate action to dispatch the fire protection
engineer (FPE) and field unit supervisor to the area. An hourly fire watch was started for
the area and some of the combustibles were promptly removed from the room. The
operations shift manager determined that the area was overcrowded with materials that
were no longer needed. Longer term correction actions are planned and the issue is
bl~ing tracked by CR 1179995.
As part of the evaluation of this performance issue, inspectors also completed additional
walkdowns and drawing reviews which revealed that the operations department storage
area was actually located directly below the following rooms on the 698' elevation of the
control structure: the computer maintenance room, the uninterrupted power supply
computer room, Corridor C-200, and the Unit-2 lower relay room. Inspectors reviewed
d~9sign drawings, the FPPR and held a discussion with the site FPE, to verify that there
was no automatic detection, no automatic suppression, and no fire pre-plan for this
storage area.
Analysis: The inspectors determined that this finding was more than minor because it
was associated with the external factors attribute (fire) of the mitigating systems
cornerstone objective to ensure the availability, reliability, and capability of systems that
respond to initiating events to prevent undesirable consequences (Le., core damage).
Specifically, PPL did not ensure that fire combustible storage was procedurally
controlled in the control structure. Fire combustibles accumulated in an area directly
b,elow the Unit 2 relay room and three other separated rooms. This storage area did not
have any fire suppression or detection capability.
The inspectors assessed this finding in accordance with IMC 0609, Appendix F, "Fire
Protection Significance Determination Process." This finding was determined to be of
very low safety significance (Green) in Phase 1 of the SDP because it was assigned a
low degradation rating. A low degradation rating was assigned because the fire barrier
between the safety-related equipment in the lower relay room and this storage area was
being properly maintained and found in good physical condition.
The finding was determined have a cross-cutting aspect in the area of Problem
Identification and Resolution, Corrective Action Program, because PPL did not
implement a CAP with a low threshold for identifying issues [P.1 (a)]. Specifically, PPL
Enclosure
9
had reasonable opportunities to identify the combustible loading issue on multiple
occasions during access of the storage room.
Enforcement: The Susquehanna Unit 2 Operating License Condition 2.C.(3), requires
that PPL implement and maintain in effect all provisions of the Fire Protection Program
as described in the FPPR. FPPR section 1.4 requires that plant procedures control the
use and storage of combustible materials and section 6.0 also requires that the
combustible loading analysis was maintained through the design control process.
Contrary to these requirements, prior to September 2009 PPL did not procedurally
control the use and storage of combustible materials on the 686' elevation of the control
structure and did not evaluate changes to combustible storage in this area through the
dE~sign control process. Because the finding is of very low safety significance and has
been entered into PPL's CAP (CR 1179995), this violation is being treated as a Non
Cited Violation (NCV), consistent with Section VI.A of the NRC Enforcement Policy.
(NCV 05000388/2009004-01, Failure to Implement and Maintain the Fire Protection
Program with Respect to the Use and Storage of Combustibles in the Control
Structure)
1R06 Fiood Protection Measures (71111.06 - 1 Sample)
Underground Cables
a. Inspection Scope
The inspectors reviewed documents, interviewed plant personnel, and entered four
underground vaults to evaluate the conditions of risk-significant cables. The inspection
focus included a visual inspection of cable integrity. Additionally, the material condition
o'f support structures and credited components such as watertight plugs, floor drains,
flood detection equipment, and alarms were also assessed to determine whether the
components were capable of performing their intended function. Some dewatering
devices were observed in operation. Documents reviewed are listed in the Attachment.
The following risk significant area was reviewed:
- Engineered Safeguards Service Water pump house and spray pond vault
inspections VA006, VA007, VA011, and VA012.
b. Findings
No findings of significance were identified.
1R07 Heat Sink Performance (71111.07T - 3 Samples)
Triennial Heat Sink
a. Inspection Scope
Based on safety significance and prior inspection history, the inspectors selected the
following heat exchangers to evaluate PPL's means (inspection, cleaning, maintenance,
and performance monitoring) of ensuring adequate heat sink performance.
- Unit 1 A RHR heat exchanger;
Enclosure
10
- 'A' Emergency diesel generator heat exchangers:
1) Intercooler heat exchanger;
2) Jacket water cooler; and
3) Lubricating oil cooler.
- 'E' Emergency diesel generator heat exchangers:
1) Intercooler heat exchanger;
2) Jacket water cooler; and
3) Lubricating oil cooler.
The inspectors assessed the external condition of the above heat exchangers in the
field, reviewed the eddy current, surveillance test and inspection results, and reviewed
the applicable system health reports since the last inspection to confirm that results were
acceptable and that design basis assumptions for flow rate, plugged tube percentage,
and heat transfer capability had been met. The inspectors discussed piping corrosion,
and heat exchanger practices, including the specifications and procedures for heat
exchanger maintenance, and consistency with the Generic Letter 89-13 requirements
with cognizant, system engineers, and chemistry personnel. The inspectors reviewed
applicable corrective action program documents to confirm that identified problems and
d,egraded conditions had been resolved properly.
In addition to the inspections of heat exchangers in the RHR and EDG systems, the
inspectors visually examined equipment, slope protection and water level in the spray
pond, and the apparent condition of primary and support equipment in the intake
structure.
The inspectors assessed the condition of the spray pond (ultimate heat sink) and the
pump house, and reviewed the August 2009 inspection/evaluation of spray pond
sediment depth. The review included discussions with the RHR service water system
engineer, a walk-down of the spray pond and pump house, and discussions with
cl1emistry personnel and the emergency service water (ESW) system engineer.
The chemical treatment programs for the spray pond (ESW ultimate heat sink) and the
cooling tower basin (service water heat sink) were reviewed to verify that potential
bio-fouling mechanisms were being addressed, including on-going treatment and
monitoring as specified in the chemistry manual. The inspectors noted that the SSES
results were aided by the ability to chemically control their ultimate heat sink, the
extensive use of stainless steel AL-6XN in tubing, and the experience of involved
engineering, testing, and chemistry personnel.
Documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
Enclosure
11
1R11 Licensed Operator Requalification Program (71111.11 Q - 2 Sample)
.1 Resident Inspector Quarterly Review
a. Inspection Scope
On August 10, 2009, the inspectors observed as-found licensed operator simulator
performance. The inspectors compared their observations to Technical Specifications
(TSs), emergency plan implementation, and the use of system operating procedures.
Tlhe inspectors also evaluated PPL's critique of the operators' performance to identify
discrepancies and deficiencies in operator training. Documents reviewed are listed in
the Attachment. The following training was observed:
- Anticipated transient without scram, reactor pressure vessel power and level
control, and event declaration.
b. Findings
No findings of significance were identified .
.2 Licensed Operator Medical Review (1 sample)
a.. Inspection Scope
The inspectors reviewed two instances in July 2009 and August 2009 where PPL had
identified issues with the medical qualification records for two separate Senior Reactor
Operators. The inspectors reviewed the medical certification forms, reviewed the PPL's
formal correspondence with the NRC upon discovery of the issue to ensure timeliness
requirements were met, PPL conditional license request submittal and reviewed PPL's
corrective actions.
b. Findings
Introduction: The licensee identified two examples of an AVof 10 CFR 55.3, Licensed
Requirements, for two cases in which PPL licensed operators failed to have valid
medical examinations consistent with their position. Specifically, one licensed operator
performed duties with an expired biennial medical examination while another licensed
operator performed duties with a failed visual examination. In both cases, operators
performed the function of a senior reactor operator without meeting the medical
rE~quirements for requalification specified in 10 CFR 55.21, 10 CFR 55.23 and
10 CFR 55.33. As such both operators were not qualified while being assigned to and
performing licensed duties as required by 10 CFR 55.3.
Discussion: During July and August 2009, two instances were identified where SSES
licensed operators failed to meet the medical requirements to maintain their license, and
these operators subsequently performed licensed operator duties.
,!;,vent 1: On October 13, 2008, a senior reactor operator (SRO) self-identified a medical
issue that resulted in his disqualification, a medical restriction entered into a corporate
database and an automatic update of TMX, (the site's training and qualification
database) was completed from the corporate source. The operator subsequently
Enclosure
12
completed a medical follow-up and was reinstated on December 12, 2008. While the
corporate database entry could have been deleted upon reinstatement, manual
corrections to TMX were made. When the restriction was manually updated with a
December 12, 2008 date, TMX automatically and incorrectly changed the medical
examination due date to October 31, 2010, to reflect a biennial requirement from the
date of the SRO's self-identified medical issue.
In 2004, the NRC issued NUREG-1021, Revision 9, which clarified the periodicity of
medical examinations. Appendix F of the NUREG defines biennial as 730 days and
allows for an extension to include the remaining days in the anniversary month. For
example, the subject SRO had a biennial medical examination due on March 9, 2009,
exactly two years from the previous examination but the permitted extension carried the
due date to March 31,2009.
During a medical record review on July 22, 2009, PPL discovered that the SRO had not
received a biennial licensed medical examination by March 31, 2009. The SRO
qualifications for the individual were immediately revoked and a physical was scheduled
for July 24, 2009. The operator passed the physical examination and was subsequently
reinstated on July 30,2009. Upon review, it was determined that the SRO stood a total
of 52 watches in a TS licensed position without a certifying medical examination as
outlined in ANSI/ANS-3.4-1983, "Medical Certification and Monitoring of Personnel
Requiring Operator Licenses for Nuclear Power Plants." Upon discovery, PPL placed
this issue in their corrective action program under CR 1166686.
Event 2: On August 18, 2009, a PPL health services specialist determined that an on
shift SRO did not pass the corrected or uncorrected visual examination which had been
performed during the previous week. Upon discovery, the SRO was disqualified for the
licensed position and the operator was removed from standing watch. PPL operations
staff promptly initiated Condition Report 1173182, which described the non-compliance
and established corrective actions to implement measures to mitigate the recurrence of
similar conditions. PPL also implemented actions to request a conditional license for this
SRO adding a condition to the operator's license requiring corrective lenses be worn.
It was determined that the licensed operator performed licensed duties during three
scheduled work shifts which included assuming the role of the refueling SRO during fuel
moves for a dry fuel storage campaign. This SRO performed licensed duties even
though he had not met the medical condition and general health prescribed for licensed
operators at the facility as outlined on NRC Form 396 and required by 10 CFR 55.21.
Information Notice (IN) 2004-20, "Recent Issues Associated with NRC Medical
Requirements for Licensed Operators," states, "Given the importance of the operators'
role in maintaining reactor safety, the NRC staff becomes concerned whenever
inspection results, facility audits, and other indicators suggest that facility medical
programs may not be receiving sufficient management oversight to ensure that the
fitness of licensed operators is being maintained at the required level." Despite the fact
that PPL entered IN 2004-20 into their corrective action program for operating
experience evaluation (CRs 625137 and 622658), that evaluation did not occur.
Enclosure
13
Analysis:
Event 1: The inspectors determined that PPL's failure to ensure that the licensed
operator received a biennial medical examination was a performance deficiency. This
finding was evaluated using the traditional enforcement process because the failure to
determine an operator's medical condition and general health has the potential to impact
or impede the regulatory process. Specifically, there was potential for license
termination or the issuance of a conditional license to accommodate the medical
problems.
This operator performed licensed duties during 52 scheduled work shifts as an SRO.
Tile NRC notes that the operator was actually qualified the entire time (his follow-up
medical examination results were satisfactory), he had not developed any condition that
required a license condition and there was no actual impact to his requalification; the fact
that the SRO was never the only SRO being credited to met minimum TS manning
requirement; and the fact that the SRO's job performance was satisfactory during the
period of the expired physical examination, and these factors will be considered prior to
a final severity level determination.
Event 2: The inspectors determined that PPL's failure to ensure that the licensed
operator received the required vision examination and passed the required visual before
assuming licensed reactor operator duties was a performance deficiency. This finding
was evaluated using the traditional enforcement process because the failure to
determine an operator's medical condition and general health has the potential to impact
or impede the regulatory process. Specifically, there was a potential for license
termination or the issuance of a conditional license to accommodate for medical
problems.
This operator perform licensed duties during three scheduled work shifts, which included
assuming the role of the refueling SRO during fuel moves for the ongoing dry fuel
storage campaign, but he did so with a disqualifying condition that would have required
his license to be amended. The NRC notes that the Fuel Handling SRO position is a
procedurally required position which was performed by a qualified individual; the SRO
had an actual disqualifying medical condition which required an amended license; and
the SRO's job performance was satisfactory during three watches he stood with this
identified condition, and these factors will be considered prior to a final severity level
determination.
Each of the two events would be considered violations of the same regulatory standard
(10 CFR 55.3) and share a common root cause of programmatic issues within PPL's
licensed operator medical reviews.
The finding was determined to have a cross-cutting aspect in the area of Problem
Identification and Resolution, Operating Experience, because PPL did not systematically
collect, evaluate, and communicate relevant external operating experience P.2(a).
Specifically, PPL failed to properly evaluate IN 2004-20 for medical examination issue
applicability in accordance with their operating experience review program as evidenced
by the 2008 SL-IV NCV (NRC IR 50-387 & 50-388 2008302-01), for an initial licensed
operator application submitted to the NRC with a disqualifying medical condition, as well
as these two events in July and August of 2009.
Enclosure
14
Enforcement:
Event 1: 10 CFR 55.21 requires, in part, that "a licensee shall have a medical
examination by a physician every two years. The physician shall determine that the
applicant or licensee meets the requirements of 10 CFR 55.33(a)(1).
10 CFR 55.33(a)(1) states, in part, that the applicants medical condition and general
health will not adversely affect the performance of assigned job duties or cause
operational errors endangering public health and safety. 10 CFR 55.3 states that, "A
person must be authorized by a license issued by the Commission to perform the
function of an operator or a senior operator as defined in this part".
Contrary to the above, between April 1, 2009, and July 22, 2009, PPL failed to ensure
that the individual licensee, an SRO, while on shift, was authorized by a license to
perform the function of an SRO, after he failed to have the required two-year medical
examination. Specifically, the SRO performed licensed operator duties 52 times
between April 1, 2009, and July 22, 2009, after the deadline for his medical examination
had passed. The medical examination may have identified an issue with the SRO's
medical condition and general health that would have disqualified him from being
authorized by a license.
Event 2: 10 CFR 55.21 requires, in part, that a licensee shall have a medical
examination by a physician every two years. The physician shall determine that the
applicant or licensee meets the requirements of 10 CFR 55.33{a)(1).
10 CFR 55.33(a){1) states, in part, that the applicant's medical condition and general
health will not adversely affect the performance of assigned job duties or cause
operational errors endangering public health and safety. 10 CFR 55.33(b) states, in
part, if an applicant's general medical condition does not meet the minimum standards
under 10 CFR 55.33(a)(1) the Commission may approve the application and include
conditions in the license to accommodate the medical defect.
10 CFR 55.23(b) states in part, when the certification requests a conditional license
based on medical evidence, the medical evidence must be submitted to the Commission
and the Commission then makes a determination in accordance with 10 CFR 55.33.
10 CFR 55.3 states that a person must be authorized by a license issued by the
Commission to perform the function of an operator or a senior operator as defined in this
part.
Contrary to the above, between August 10,2009, and August 18, 2009, PPL failed to
ensure that the individual licensee, an SRO, while on-shift, was authorized by a license
to perform the function of an SRO, after he failed a medical examination which identified
a disqualifying condition. Specifically, a medical examination conducted on August 10,
2009, identified that the SRO's vision did not meet the health requirements stated in
ANSI/ANS 3.4-1983, Section 5.4.5, "Eyes." However, he performed the function of an
SRO during three watches with a license that was not appropriately conditioned to
rE~quire that corrective lenses be worn.
Each example was evaluated independently using the traditional enforcement process
because the failure to determine an operator's medical condition and general health has
the potential to impact or impede the regulatory process. Specifically, medical
certification and conditional licensing are used by the NRC to ensure health conditions
Enclosure
15
will not adversely affect operator duties or performance. (AV 05000387; 388/2009004
02, Violation of 10CFR55.3, Senior Reactor Operators Performing Licensed Duties
While Not Qualified Due to Medical Examination Issues)
1R12 Maintenance Effectiveness (71111.120 - 3 Samples)
a. Inspection Scope
Tile inspectors evaluated PPL's work practices and follow-up corrective actions for
selected structures, systems and components (SSC) issues to assess the effectiveness
of PPL's maintenance activities. The inspectors reviewed the performance history of
those SSCs and assessed PPL's extent of condition determinations for these issues with
potential common cause or generic implications to evaluate the adequacy of PPL's
corrective actions. The inspectors reviewed PPL's problem identification and resolution
actions for these issues to evaluate whether PPL had appropriately monitored.
evaluated. and dispositioned the issues in accordance with PPL procedures and the
requirements of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of
Maintenance." In addition, the inspectors reviewed selected SSC classification,
performance criteria and goals, and PPL's corrective actions that were taken or planned.
to verify whether the actions were reasonable and appropriate. Documents reviewed
are listed in the Attachment. The following issues were reviewed:
- Unit 1, HPCI turbine stop valve failure and previous corrective actions for
inadequate preventative maintenance;
unavailability; and
coolant leakage.
b. Findings
Introduction: The inspectors identified a Green NCVof 10 CFR Part 50, Appendix B.
Criterion XVI. "Corrective Action," in that, PPL did not implement timely corrective
actions to preclude repetition of a significant condition adverse to quality. Specifically,
the actions taken to address the causes of the Unit 1 HPCI stop valve failure to close in
2006 did not prevent the same Unit 1 HPCI stop valve from failing to close on August 18,
2009. In both cases, the failure of the stop valve to close rendered this single train high
pressure injection system inoperable as it was unable to meet the 30 second injection
response time as described in the design basis.
Discussion: On August 18, 2009, the Unit 1 HPCI stop valve (FV-15612) indicated dual
position after performance of the weekly lubricating oil functional check. FV-15612 did
not go full closed as expected and was verified to be approximately one inch from full
closed. Operations cycled the valve with maintenance personnel present in the field and
found that the valve did not operate smoothly when closing. Based on previous history
with FV-15612, engineering recommended that the HPCI system be declared
inoperable. Unit 1 HPCr was declared inoperable and the FV15612 valve was
disassembled and repaired.
The failure of FV-15612 Significantly impacts HCpr operation because the HPCI ramp
generator resets to idle when the lower limit switch opens (at the full closed indication on
Enclosure
16
FV-15612). Thus, FV-15612's closure is necessary to prepare the governor to restart
the turbine and if FV-15612 does not fully close, the generator can not reset, and the
governor would demand full open when the turbine restarts. This condition greatly
increases the probability of an overspeed trip upon turbine start. Historical data from the
original HPCI speed control design reveals that it would be expected to have at least 1
or 2 overspeed trips before the HPCI governor would be able to control turbine speed.
In this condition the HPCI 30 second design basis response time would not be met.
(Ref: TS 3.5.1.13). Therefore, HPCI was not able to perform its safety function with
design limits and was inoperable. In addition, this degraded component also challenges
the system protective features {overspeed trip function} which reduces the reliability of
the system to function.
The safety system remained unavailable for several days as extensive effort was
required to repair the component for this type of degradation. Inspectors witnessed
some of the maintenance work and observed that there were many physical similarities
to the conditions found when this valve was disassembled and repaired following the
failure to close in August of 2006.
One documented cause for the 2006 FV-15612 failure was an observed seal area that is
periodically wetted by HPCI operation and a material which is susceptible to general
corrosion and requires periodic replacement to maintain proper operation. In 2006, PPL
took the action to replace the rod bushing. However, there were no actions to address
the cause and reduce moisture exposure, change or evaluate materials to reduce the
susceptibility to corrosion, and no actions to increase component monitoring for moisture
or corrosion. The second documented apparent cause for the 2006 FV-15612 failure
was inadequate preventive maintenance (PM). An administrative error had caused this
component to go past the PM expiration date. PPL performed the inspections as part of
the 2006 repair and recalculated a new due date for the PM task. PPL did not change
the 10 year interval for maintenance and inspection and did not increase the PM
frequency for this component to more appropriately address this identified apparent
cause (inadequate PM). The inspectors determined that the limited corrective actions
taken following the apparent cause evaluation in 2006 contained in CR 806988 were a
primary contributor to the repeat failure of the FV-15612 in 2009. In both cases, valve
FV15612 failed in the same manner and would not travel to the full closed position. In
both cases, the actuator stem to bushing interface was very tight and required the use of
pullers and/or hammers during actuator disassembly. For both failures the most likely
cause was due to increased friction between the actuator shaft and the rod bushing as a
result of corrosion. The inspectors also identified that the corrective action report CR
806988 did not have an effectiveness review plan. The CR stated that given the long
duration of the PM interval, it would be unreasonable to hold an effectiveness review
open for several years.
The inspectors reviewed PPL's cause evaluation for the August 2009 valve failure, as
documented in CR 1172997. This evaluation described how the leakage through the
seat of the Unit 1 HPCI Steam Admission Valve (HV-155F001) was a contributing cause
to the 2009 component failure. The HV-155F001 had chronic through seat leakage for
the last decade. Inspectors concluded that this leakage and moisture source was also a
contributing factor from 2006, and that more aggressive action to fix the seat leakage
which contributed to the corrosive environment would have reduced the probability
and/or frequency of the experienced component failure.
Enclosure
17
Analysis: The finding is more than minor because it adversely affected the equipment
pE:lrformance attribute of the Mitigating Systems cornerstone objective, to ensure the
availability, reliability and capability of equipment that respond to initiating events to
prevent undesirable consequences. Specifically, with FV-15612 unable to fully close,
the HPCI 30 second design basis response time would not be met. Not only did this
dE3graded component make the HPCI system inoperable; it also challenged the system
protective features (overspeed trip function) which reduced the reliability of the system to
function. In addition, the repairs necessary to restore the system required extensive
effort and resulted in several days of unplanned unavailability for a single train safety
system.
The inspectors assessed this finding in accordance with IMC 0609 Attachment 4, "Phase
1 - Initial Screening and Characterization of Findings" and determined the finding to be
of very low safety significance (Green) because it did not result in an actual loss of
safety function for greater than the TS allowed outage time. The finding was not
potentially risk Significant due to seismic, flood, or severe weather initiating events.
This finding was determined to have a cross-cutting aspect in the area of Problem
Identification and Resolution, Corrective Action Program, because PPL did not take
appropriate corrective actions to address safety issues in a timely manner,
commensurate with their safety Significance and complexity [P.1 (d)]. Specifically, PPL
did not take appropriate corrective actions for a significant condition adverse to quality
from the 2006 failure of the HPCI stop valve to prevent the 2009 failure of the same
valve.
Enforcement: 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires,
in-part, for significant conditions adverse to quality, measures shall assure that the
cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, PPL did appropriately identify several causes but corrective
actions following the 2006 valve failure did not prevent repetition of the same HPCI stop
valve failure on August 18, 2009. In both cases, the failure of the stop valve to close
rendered this single train high pressure injection system inoperable as it was unable to
meet the 30 second injection response time as described in the design basis. In 2009
this particular failure also caused several days of unplanned unavailability due to the
extensive effort to repair the component. Because the finding is of very low safety
significance and has been entered into PPL's CAP (CR 710737), this violation is being
treated as a Non-Cited Violation (NCV), consistent with Section VI.A of the NRC
Enforcement Policy. (NCV 05000387/2009004-03, Inadequate Corrective Actions
Result in a Repeat Failure of Unit 1 HPCI Turbine Stop Valve).
1R 13 Maintenance Risk Assessments and Emergent Work Control (71111.13 7 Samples)
a. Inspection Scope
The inspectors reviewed the assessment and management of selected maintenance
activities to evaluate the effectiveness of PPL's risk management for planned and
emergent work. The inspectors compared the risk assessments and risk management
actions to the requirements of 10 CFR Part 50.65(a)(4) and the recommendations of
NUMARC 93-01, Section 11, "Assessment of Risk Resulting from Performance of
Maintenance Activities." The inspectors evaluated the selected activities to determine
Enclosure
18
whether risk assessments were performed when specified and appropriate risk
management actions were identified.
The inspectors reviewed scheduled and emergent work activities with licensed operators
and work-coordination personnel to evaluate whether risk management action threshold
levels were correctly identified. In addition, the inspectors compared the assessed risk
configuration to the actual plant conditions and any in-progress evolutions or external
events to evaluate whether the assessment was accurate, complete, and appropriate for
the emergent work activities. The inspectors performed control room and field
walkdowns to evaluate whether the compensatory measures identified by the risk
assessments were appropriately performed. Documents reviewed are listed in the
Attachment. The selected maintenance activities included:
- Unit 1, 2-4 GPM leak on RWCU filter demineralizer outlet isolation valve
emergent work control;
Unit 1 HPCI stop valve and "B" EDG jacket water heater failures on August 21;
- Units 1 and 2, 2A residual heat removal service water (RHRSW) pump
inoperable due to loose electrical junction box supports concurrent with Unit 1
RHRSW subsystem inoperable for scheduled maintenance; dual unit 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />
shutdown limiting condition for operation (LCO);
- Orange equipment out-of-service risk for both Unit 1 and Unit 2 during "A" EDG
outage and emergent "E" EDG inoperability, CR 1165553;
dual unit 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> shutdown LCO;
- Emergent wiring repairs on ESS transformer OX203 in 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO; and
- T20 startup transformer (T20) high voltage bushing replacement and Bus 20
clean and inspect.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations (71111.15 - 7 Samples)
a. Inspection Scope
The inspectors reviewed operability determinations that were selected based on risk
insights, to assess the adequacy of the evaluations, the use and control of
compensatory measures, and compliance with TSs. In addition, the inspectors reviewed
the selected operability determinations to evaluate whether the determinations were
performed in accordance with NDAP-QA-0703, "Operability Assessments." The
inspectors used the TSs, Technical Requirements Manual, Final Safety Analysis Report
(FSAR), and associated DeSign Basis Documents as references during these reviews.
Documents reviewed are listed in the Attachment. The issues reviewed included:
- Unit 1, RHR Oivision I, gas entrainment issue;
- Unit 1, repeat failure of 1B RHRSW pump 1ST;
- Unit 2, '0' main steam line radiation monitor on multiple alarms and work orders;
Enclosure
19
- Unit 2, HPCI operators disabled auxiliary oil pump during surveillance restoration
steps on May 16, 2009;
- <IE" EDG with failed turbocharger overspeed speed trip circuit, OFR 1166085;
and
b. Findings
No findings of significance were identified
1R18 Plant Modifications (71111.18 - 2 Samples)
.1 T,emporary Plant Modifications (1 Sample)
a. Inspection Scope
The inspectors reviewed a temporary plant modification to determine whether the
change adversely affected system or support system availability, or adversely affected a
function important to plant safety. The inspectors reviewed the associated system
design bases, including the FSAR, TSs, and assessed the adequacy of the safety
determination screening and evaluation. The inspectors also assessed configuration
control of the change by reviewing selected drawings and procedures to verify whether
appropriate updates had been made. The inspectors compared the actual installation to
the temporary modification documents to determine whether the implemented change
was consistent with the approved documents. The inspectors reviewed selected
post-installation test results to determine whether the actual impact of the change had
been adequately demonstrated by the test. Documents reviewed are listed in the
Attachment. The following modification and document was included in the review:
- Unit 1, Temporary Engineering Change 1136133, bypass gas discharge
temperature trip on 1K206B.
b. Fr:ndings
No findings of significance were identified .
.2 Permanent Plant Modifications (1 Sample)
a. Inspection Scope
The inspectors reviewed a permanent plant modification to determine whether the
change adversely affected system or support system availability, or adversely affected a
function important to plant safety. The inspectors reviewed the associated system
design bases, including the FSAR, TSs, and assessed the adequacy of the safety
determination screening and evaluation. The inspectors also assessed configuration
control of the change by reviewing selected drawings and procedures to verify whether
appropriate updates had been made. The inspectors compared the actual installation to
the permanent modification documents to determine whether the implemented change
was consistent with the approved documents. The inspectors reviewed selected
Enclosure
20
post-installation test results to verify whether the actual impact of the change had been
adequately demonstrated by the test. Documents reviewed are listed in the Attachment.
The following modification and document was included in the review:
- Engineering Work Request 1086364, T20 H1 bushing replacement.
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing (71111.19- 6 Samples)
a. Inspection Scope
The inspectors observed portions of post-maintenance test (PMT) activities in the field to
determine whether the tests were performed in accordance with the approved
procedures. The inspectors assessed the test adequacy by comparing the test
methodology to the scope of maintenance work performed. In addition, the inspectors
evaluated acceptance criteria to determine whether the test demonstrated that
components satisfied the applicable design and licensing bases and TS requirements.
The inspectors reviewed the recorded test data to determine whether the acceptance
criteria were satisfied. Documents reviewed are listed in the Attachment. The PMT
activities reviewed included:
- Unit 1, single control rod scram during scram switch functional check;
- Unit 1, core spray valve exercising, HV152F0005A and F015A after breaker
swaps;
- Unit 2, reactor core isolation cooling (RCIC) pump and flow testing and
overspeed trip test following resolution of turbine trip tappet nut alignment,
CR 1146099;
- Unit 2, PMT of PSV 251 F087 after maintenance to eliminate emergency core
cooling system keepfill leakage past valve; and
- T20 high bushing replacement, tap charger inspection and bus 20 cleaning and
inspection.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing (71111.22 - 4 Routine Surveillance and 1 1ST Samples)
a. Inspection Scope
The inspectors observed portions of selected surveillance test activities in the control
room and in the field and reviewed test data results. The inspectors compared the test
results to the established acceptance criteria and the applicable TS or Technical
Requirements Manual operability and surveillance requirements to evaluate whether the
systems were capable of performing their intended safety functions. Documents
Enclosure
21
reviewed are listed in the Attachment. The observed or reviewed surveillance tests
included:
- Unit 1, quarterly functional test of reactor vessel water level channels
LlS-B21-IN031A, 3B, C, D, SI-180-203;
- Unit 2, 1ST testing of RCIC pump flow indication from remote shutdown panel;
- "A" SGTS filter and absorber leak tests;
- "D" EDG full load rejection test, SE-024-D01; and
- Monthly operation of SGTS train "A", SO-070-001.
b. Findings
No findings of significance were identified.
1EP6 Drill Evaluation (71114.06 - 1 Sample)
a. Inspection Scope
Tlhe inspectors reviewed the combined functional drill scenario (2009 Gold Team
Emergency Drill) that was conducted on August 25, 2009, and observed selected
portions of the drill in the simulator control room and technical support center. The
inspection focused on PPL's ability to properly conduct emergency action level
classification, notification, and protective action recommendation activities and on the
evaluators' ability to identify observed weaknesses and/or deficiencies within these
areas. Ten performance indicator (PI) opportunities were included in the scenario.
The inspectors attended the evaluators' post-drill critique and compared identified
weaknesses and deficiencies including missed PI opportunities against those identified
by PPL to determine whether PPL was properly identifying weaknesses and failures in
tbese areas. Documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
2. RADIATION SAFETY
Cornerstone: Occupational Radiation Safety (OS)
20S1 Access Control to Radiologically Significant Areas (71121.01 6 Samples)
a. Inspection Scope
The inspectors reviewed and assessed the adequacy of PPL's internal dose assessment
for any actual internal exposure greater than 50 mrem committed effective dose
equivalent.
The inspectors examined PPL's physical and programmatic controls for highly activated
or contaminated materials (non-fuel) stored within spent fuel and other storage pools.
Enclosure
22
For high radiation work areas with significant dose rate gradients (factor of 5 or more),
the inspectors reviewed the application of dosimetry to effectively monitor exposure to
pE!rSOnnel.
The inspectors discussed with the radiation protection manager high dose rate-high
radiation area, and very high radiation area controls and procedures. The inspectors
focused on any procedural changes since the last inspection. The inspectors verified
that any changes to PPL's procedures did not substantially reduce the effectiveness and
level of worker protection.
The inspectors discussed with health physics supervisors the controls in place for
special areas that have the potential to become very high radiation areas during certain
plant operations. The inspectors determined that these plant operations required
communication beforehand with the health physics group, so as to allow corresponding
timely actions to properly post and control the radiation hazards.
The inspectors verified adequate posting and locking of entrances to high dose rate-high
radiation areas, and very high radiation areas.
The inspectors evaluated PPL's performance against the requirements contained in
10 CFR 20 and Plant Technical Specification 5.7.
Documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
20S2 ALARA Planning and Controls (71121.02 - 3 Samples)
a. Inspection Scope
The inspectors obtained from PPL a list of work activities ranked by actual/estimated
exposure that are in progress or that have been completed during the last outage and
select the 2 work activities of highest exposure significance (in-vesseIISIIIVVI and EPU
alternate decay heat removal modification).
The inspectors reviewed PPL's method for adjusting exposure estimates, or re-planning
work, when unexpected changes in scope or emergent work are encountered. The
inspectors evaluated whether adjustments to estimated exposure (intended dose) were
based on sound radiation protection and ALARA principles or just adjusted to account
for failures to control the work.
The inspectors evaluated PPL's performance against the requirements contained in
Documents reviewed are listed in the Attachment.
Enclosure
23
b. Findings
Introduction: A self-revealing Green finding was identified due to a deficiency in the area
of maintaining occupational radiation exposures ALARA. Work performance involving
the IWI/ISI during the Unit 2 14th Refuel and Inspection Outage was less than adequate
resulting in collective exposure for the work to expand from 5.00 person-rem to 11.04
person-rem.
Description: The IWI/ISI dose overrun was primarily due to the utilization of
inexperienced contract workers to perform the task. The contractor selected by PPL
utilized workers for major IWIIISI tasks, including: inspection; camera placement and
repair; and, pressure washing/surface preparation, were inexperienced in performing
these tasks. The work hours to perform these tasks then expanded to include an
additional 294 hours0.0034 days <br />0.0817 hours <br />4.861111e-4 weeks <br />1.11867e-4 months <br /> for inspection; 207 hours0.0024 days <br />0.0575 hours <br />3.422619e-4 weeks <br />7.87635e-5 months <br /> for camera placement and repair; and,
1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> for pressure washing/surface preparation. These examples of additional in
fiE~ld high radiation work resulted in additional collective exposure that could have been
avoided had sufficient pre-job training been provided. Pre-task training for workers, as
described in the pre-outage work plan, was inadequate for the tasks to be performed,
based on the use of inexperienced workers. Outage planning for this work was based
upon past performance in earlier outages with experienced work crews, and estimated to
require less than 3000 hours0.0347 days <br />0.833 hours <br />0.00496 weeks <br />0.00114 months <br />. Actual hours to perform these tasks with the
inexperienced workers were over 5000 hours0.0579 days <br />1.389 hours <br />0.00827 weeks <br />0.0019 months <br />. The original exposure estimate was 5.00
person-rem. When compared to the actual work activity exposure of 11.04 person-rem,
the results were 120 percent greater than the exposure estimate.
Analysis: Inadequate work planning that resulted in significant unplanned collective
exposure was a performance deficiency which was reasonably within PPL's ability to
foresee and correct and which should have been prevented. Specifically, the original
exposure estimate was 5.00 person-rem. When compared to the actual work activity
exposure of 11.04 person-rem, the results were 120 percent greater than the exposure
estimate.
The finding is more than minor because the issue involved actual collective exposure
greater than 5 person-rem that was greater than 50 percent above the estimated or
intended exposure and the dose overrun was due to activities within PPL's control. This
issue is similar to the greater than minor examples provided in Appendix E of Manual
Chapter 0612. Further, the performance deficiency is associated with the radiation
safety cornerstone attribute of the program (ALARA planning) and adversely affected the
cornerstone objective to ensure adequate protection of worker health and safety from
exposure to radiation. The finding was evaluated in accordance with IMC 0609,
Appendix C, "Occupational Radiation Safety Significance Determination Process." The
inspectors determined that the finding was of very low safety significance (Green)
because: (1) it involved an ALARA planning issue, and (2) the 3-year rolling average
collective dose history was less than 240 person-rem (107 person-rem annual exposure
for 2005-2007). This finding was entered into PPL's CAP (CR 1140623 and 1137835).
This finding was determined to have a cross-cutting aspect in the area of Human
Performance, Resources, because PPL did not utilize sufficiently qualified personnel to
assure occupational radiation safety requirements were met H.2(b). Specifically, PPL's
use of inexperienced contract workers resulted in additional collective exposure that
could have been avoided.
Enclosure
24
Enforcement: Enforcement action does not apply because the performance deficiency
did not involve a violation of regulatory requirement. The ALARA rule contained in
1(I CFR 20.1101 (b) Statements of Consideration indicates that compliance with the
ALARA requirement will be judged on whether the licensee has incorporated measures
to track and, if necessary, to reduce exposures and not whether exposures and doses
represent an absolute minimum or whether the licensee has used all possible methods
to reduce exposures. The overall exposure performance of the nuclear power plant is
used to determine compliance with the ALARA rule. Since SSES is below the three
year-rolling-average of 240 person-rem and PPL has an established ALARA program to
reduce exposure consistent with the statements of consideration for 10 CFR 20.1101, no
violation of regulatory requirements [10 CFR 20.11 01 (b)] is considered. Because this
finding does not involve a violation of regulatory requirements and has very low safety
significance, it is identified as (FIN 05000388/2009004-04, Failure to Maintain
Occupational Radiation Exposure as Low as Reasonably Achievable during the
Unit 2 Refueling Outage)
20S3 Radiation Monitoring Instrumentation (71121.03 -1 Sample)
a. Inspection Scope
The inspectors verified the calibration, operability, and alarm setpoints of several types
of instruments and equipment. Verification methods included: review of calibration
documentation and observation of PPL's source check or calibrator exposed readings.
The inspectors reviewed the detector measurement geometry, calibration method and
appropriate selection of calibration sources to closely represent the actual measurement
conditions in the plant. The inspectors observed electronic and radiation calibration of
these. The inspectors reviewed the alarm set point determinations and observed in-field
source checks. The inspectors determined what actions were taken when, during
calibration or source checks, an instrument was found significantly out of calibration (>50
percent). The inspectors determined the possible consequences of instrument use since
last successful calibration or source check. The inspectors determined if the out of
calibration result was entered into the CAP.
During an on-site visit, the inspectors reviewed calibration data, quality assurance (QA)
data and National Voluntary Laboratory Accreditation Program audits and
intercomparison test data for PPL's personnel dosimetry laboratory located in Allentown.
The inspectors evaluated PPL's performance against the requirements contained in
10 CFR 20.1501,10 CFR 20.1703 and 10 CFR 20.1704.
Documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
Enclosure
25
4. OTHER ACTIVITIES
40A1 Performance Indicator Verification (71151 - 8 Samples)
Injtiating Events
a. Inspection Scope
The inspectors reviewed PPL's PI data for the period of August 2008 through August
2009 to verify whether the PI data was accurate and complete. The inspectors
examined selected samples of PI data, PI data summary reports, and plant records. The
inspectors compared the PI data against the guidance contained in Nuclear Energy
Institute 99-02, "Regulatory Assessment Performance Indicator Guideline." Documents
reviewed are listed in the Attachment. The following PIs were included in this review:
- Units 1 and 2 unplanned scrams per 7000 critical hours (IE01);
- Units 1 and 2 unplanned power changes per 7000 critical hours (IE03);
- Units 1 and 2 unplanned scrams with complications (IE04);
- Common Occupational Exposure Control Effectiveness (OR01); and
- Common RETS/ODCM Radiological Effluents (PR01)
b. Findings
No findings of significance were identified.
40A2 Identification and Resolution of Problems (71152 - 1 Sample)
.1 Review of Items Entered into the Corrective Action Program
a. Inspection Scope
As specified by Inspection Procedure 71152, Problem Identification and Resolution, and
in order to help identify repetitive equipment failures or specific human performance
issues for follow-up, the inspectors performed screening of all items entered into PPL's
CAP. This was accomplished by reviewing the description of each new action
requesUcondition report and attending daily management meetings.
b. Findings
No findings of significance were identified .
.2 Annual Sample: Review of PPL's Progress in Implementing Corrective Actions to
Address General Work Environment and Potential Chilling Effect Concerns
a. Inspection Scope
The inspectors performed a detailed review of PPL's corrective actions associated with
the Root Cause Analysis (RCA) conducted in response to the NRC's Potential Chilling
Effect (PCE) letter of January 28, 2009 and the associated action plan. The inspectors
reviewed the RCA, the general work environment action plan, Employees Concern
Enclosure
26
Program (ECP), QA documents, and selected reference RCA documents. The
inspectors also reviewed the corrective action schedules and reviewed completed
corrective actions such as revised procedures, training material, and records. The
inspectors also conducted interviews with site ECP and QA personnel, and several focus
groups consisting of workers and supervisors from the Security, Work Management,
Health Physics, and Operations Departments. These interviews were performed in
order to assess how the staff viewed the effectiveness of the corrective actions to date in
addressing the general work environment. The inspectors also assessed PPL's longer
term action plan items by verifying action item entries in the CAP as well as through
interviews of responsible personnel.
b. Findings and Observations
No findings of significance were identified.
Background: On January 28, 2009, the NRC issued a PCE letter advising PPL of
concerns related to the safety conscious work environment (SCWE) at SSES and
requested PPL provide: (1) a description of PPL's current action plans to address
existing SCWE concerns to preclude a chilled work environment at SSES; (2) PPL plans
for further evaluating the health of the SCWE at SSES; and (3) the metrics PPL intended
to monitor to determine the effectiveness of their actions and ensure a SCWE at SSES
(ML090280115). Also, on January 28, 2009, the NRC issued SSES - NRC Integrated
Inspection Report 05000387/2008005 and 05000388/2008005 (ML090230434) which
described the SCWE concerns at PPL and provided additional background. PPL
completed their formal RCA of the work environment issues in May 2009. The NRC's
review of that RCA is documented in NRC Integrated Inspection Report
05000387/2009003 and 05000388/2009003 (ML092230158).
Root Cause Analysis Corrective Actions
The inspectors determined that the corrective actions developed by the RCA team to
address the root cause and causal factors were being appropriately scheduled and that
the actions were being completed in accordance with that schedule. The time frame for
completion of these scheduled actions was also determined to be appropriate. Any
changes to the schedule required a review by the Management Review Committee and
approval by senior management.
Corrective actions completed to date included the roll out of the RCA through formal site
presentations and small group discussions, the establishment of two methods for
workers to raise an anonymous concern (Safety Hotline and anonymous computer
generated CRs), developing training materials and case studies related to work
environment issues and conducting this training with all first line supervisors and
positions above, and revising several procedures. The training was well received by
plant personnel and the new anonymous concern processes was being utilized by plant
personnel.
In addition, several organizational changes were made including the arrival of the new
eNO in July 2009, the establishment of a plant manager position, restructuring to have
QA, ECP, and Regulatory Affairs directly reporting to the CNO, and the selection of
several new personnel for key management positions. The inspectors observed that
these changes were well communicated to the site and generally have been well
Enclosure
27
received. Most personnel interviewed felt the organizational changes were appropriate
and the personnel selected were a good fit for their new positions. These changes have
allowed progress to be made in re-establishing trust between the workers and upper
management and improving the general work environment.
Employee Concerns Program
Another corrective action from the RCA was to evaluate and make changes to the ECP.
A strong ECP is a pillar of a successful safety culture. However, in the past at SSES,
the ECP was not seen by many plant employees as a viable and effective program.
During the third quarter 2009, PPL restructured the ECP program by eliminating the
Ombudsman position and hiring an additional ECP representative who was full time
on-site at SSES. The inspectors interviewed ECP representatives and discussed the
ECP program re-organizations with each of the focus groups. The inspectors concluded
that PPL did a good job communicating the changes in the ECP program to the site. All
groups interviewed knew who the new ECP representative was and were aware that the
Ombudsman position had been eliminated. Most had a positive impression and an
inherent level of trust for the new on-site ECP representative selected. In addition,
corrective actions were completed changing the organizational reporting requirements,
taking the ECP program out to the line organization and making it a direct report to the
CNO.
However, additional organizational changes in the ECP Oversight Team remain to
ensure that the ECP process is viewed by the workforce as a viable alternative for
issues. See NRC Integrated Inspection Report 05000387/2009003 and
05000388/2009003 (ML092230158) for further details on this concern.
Challenges: The inspectors identified two upcoming challenges which have the potential
to impact the general work environment. The first challenge will be the implementation
of the NRC Fatigue Rule (10 CFR 26 Subpart I) which went into effect October 1,2009.
The inspectors observed that the plant had done a good job communicating the new
rule, and had done a good job working with the departments most heavily impacted
(Operations and Security); however, several workers and supervisors interviewed
expressed uncertainty as to how the rule will be implemented and what will be the true
impact. PPL acknowledged it was slow in engaging the bargaining unit regarding
potential shift rotation adjustments in the Health Physics Department, which was a
concern to the mc:ijority of the Health Physics personnel interviewed. In a similar note,
the upcoming collective bargaining unit negotiations have the potential to impact the
general work environment.
Assessment
During the 3rd quarter of 2009, PPL made reasonable process in implementing their
action plan and RCA corrective actions to address the general work environment at
SSES. Based on interviews with a sample population of site employees, the actions to
date have been well received and are making a positive impact on the general work
environment at SSES. Overall, the workers stated they were cautiously optimistic that
changes were being implemented; however, they acknowledged that significant work
remained to be done and several Significant challenges still need to be addressed. The
NRC plans to continue monitoring PPL's progress in this area.
Enclosure
28
40A5 Other Activities
.1 Quarterly Resident Inspector Observations of Security Personnel and Activities
a. Inspection Scope
During the inspection period, the inspectors conducted observations of security force
personnel and activities to ensure that the activities were consistent with licensee
security procedures and regulatory requirements relating to nuclear plant security.
These observations took place during both normal and off-normal plant working hours.
b. Findings
No findings of Significance were identified .
.2 Independent Spent Fuel Storage Installation (60855 and 60855.1)
a. Inspection Scope
The inspectors observed selected activities associated with loading of a dry cask
canister to ensure that TSs were met and equipment operated properly. The inspectors
reviewed documents and records associated with the operation of the SSES
independent spent fuel storage installation (ISFSI), including training records for
personnel involved with loading of a dry cask canister. A list of the documents reviewed
is provided in the Supplemental Information section. The inspectors met with reactor
engineering personnel to review the fuel selection process and associated
documentation. The inspectors discussed how the cask loading computer program is
created for each cask loading. The video recording of the fuel bundles placed into the
canister was reviewed to ensure that each bundle was placed into the proper location.
The inspectors observed work activities on the refuel floor associated with the fuel
selection, loading of fuel into the cask, vacuum drying, welding, and moving of the
loaded canister to the truck bay.
b. Findings
No findings of significance were identified. However, the inspectors did identify an issue
regarding compliance with procedure MT-GM-014, "Rigging and Lifting Equipment
Inspection." This procedure references ASME code 830.9-2003, "Slings." Both
documents require that slings are to be inspected annually. While the licensee also
performs an inspection of each sling prior to use in accordance with the same
procedure, the pre-job inspection does not meet the annual inspection requirement.
Inspectors noted that when synthetic slings used in dry cask storage are inspected by
PPL they receive an August 5th due date sticker for the following year, regardless of
when they are inspected in the current year. This presented a potential for a sling to
exceed its annual inspection based on the annotated date. PPL entered this issue into
their corrective action program under CR 1173698, "SSES Rigging Committee review of
procedural guidance." The licensee's extent of condition review did not identify any
slings used in safety related activities which had actually exceeded the annual inspection
criteria. As a result, this issue was determined to be of minor significance and a violation
of minor significance that is not subject to enforcement action in accordance with the
NRC's Enforcement Policy. However, for assessment purposes, this issue does
Enclosure
29
illustrate a weakness in PPL's Corrective Action Program because it did not identify a
non compliance with a regulatory requirement.
.3 Operation of an ISFSI at Operating Plants (60855)
a. Inspection Scope
The inspectors verified by direct observation and independent evaluation that PPL had
performed loading activities at the ISFSI in a safe manner and in compliance with
applicable procedures. This included observing the loading of one canister of spent fuel
into the ISFSI on August 10, 2009. The inspectors verified by direct observation that
radiation dose and contamination levels were within prescribed limits after a dry cask
storage system container had been installed at the ISFSI.
b. Findings
No findings of significance were identified.
40A6 Meetings, Including Exit
On August 14, 2009, the health physics inspector presented inspection results to Mr. C.
Gannon and other members of his staff, who acknowledged the findings. The inspector
confirmed that proprietary information was not provided or examined during the
inspection.
On August 21,2009, the health physics inspectors presented inspection results to Mr. C.
Gannon and other members of his staff, who acknowledged the findings. The inspectors
confirmed that proprietary information was not provided or examined during the
inspection.
On October 9,2009, the resident inspectors presented their findings to Mr. T. Rausch,
and other members of his staff, who acknowledged the findings. The inspectors
confirmed that proprietary information was not provided or examined during the
inspection.
40A7 Licensee-Identified Violations
The following violation of very low safety significance (Green) was identified by PPL and
is a violation of NRC requirements which meets the criteria of Section VI of the NRC
Enforcement Policy, NUREG-1600, for being dispositioned as an NCV:
- On 25 August 2009, while performing pre-start checks to place Unit 2 RHR in
suppression pool cooling, a field operator identified the ESW cooling water
valves 211193 and 211194 to be unlocked and closed. These valves are
required to be locked open to assure supply of cooling to a Unit 2 RHR room
cooler and 2C RHR pump motor oil cooler. This was an identified violation of
TS 5.4.1, and a violation of those procedures that must be implemented for
operation of the unit and for the performance of maintenance as delineated in
Regulatory Guide 1.33. Contrary to NDAP-QA-0302, "System Status and
Enclosure
30
Equipment Control," PPL did not use a proceduralized method to maintain
status control of these valves and contrary to NDAP-QA-502, "Work Control
Process," these valves were not returned to the original design configuration
following maintenance. PPL determined that the status control of these
valves was most likely lost during the post-modification testing performed in
late April 2009. Upon discovery, the valves were promptly aligned to provide
cooling flow and the performance issue was captured in CR 1174837. Using
a Phase III risk evaluation model, the region staff determined this finding to
be of very low safety significance (Green).
AITACHMENT: SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
N. D'Angelo, Manager, Station Engineering
R. Doty, Radiation Protection Manager
T Iliadis, GM - Nuclear Operations
S. Ingram, Dosimetry Supervisor
R. Kessler, Health Physicist - ALARA
A. Klopp, Heat Exchanger Program Engineer
D. Leimbach, Eddy Current Level III, In-service Inspection
R. Pagodin, GM - Nuclear Engineering
G. Ruppert, GM - Work Management
S. Davis, Fire Protection Program Engineer
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000387; 388/200900402 AV Violation of 10CFR55.3, Senior Reactor
Operators Performing Licensed Duties
While Not Qualified Due to Medical
Examination Issues (1 R11.2)
Opened/Closed
05000388/200900401 NCV Failure to Implement and Maintain the Fire
Protection Program with Respect to the Use
and Storage of Combustibles in the Control
Structure (1 R05)
05000387/200900403 NCV Inadequate Corrective Actions Result in a
Repeat Failure of Unit 1 HPCI Turbine Stop
Valve (1R12)
05000388/200900404 FIN Failure to Maintain Occupational Radiation
Exposure As Low As Reasonably
Achievable during the Unit 2 Refueling
Outage (20S2)
Attachment
A-2
BASELINE INSPECTION PROCEDURE PERFORMED
LIST OF DOCUMENTS REVIEWED
(Not Referenced in the Report)
Section 1R04: Equipment Alignment
Condition Reports:
1168300, 1175048, 1176331, 1174964
Procedures:
OP-225-001, Containment Instrument Gas System. Revision 30
CL-225-0012, Unit 2 Containment Instrument Gas Mechanical, Revision 13
Drawings:
M-2126, Unit 2 Containment Instrument Gas Sheets 1 and 2, Revision 33 and 13
M-157, Unit 1 Containment Atmosphere Control, Revision 47
M-134, A-D Diesel Auxiliaries Fuel Oil, Lube Oil. Air Intake and Exhaust and Jacket Water
Cooling System. Revision 45
Engineering Work Request:
EWR 1168578
Other:
Chemistry Analysis and Sample Results Attached to CR 1167146
Drainage Contour Map, Potentiometric Surface Contours Overburden Monitoring Wells
August/September 2008
Section 1 R05: Fire Protection
Condition Reports:
1172702
Procedures:
FP-113-113, Containment Access Area (1-401, 1-404, 1-405) Fire Zones 1-4A-N, S, W,
Elevation 719'-0", Revision 6
FP-013-168, Equipment and Battery Rooms Unit 1 West Side (C-605, 606, 600,601,607) Fire
Zones 0-28B-11, 0-28K, 0-28L, 0-281, Elevation 771'-0", Revision 5
FP-013-169, Equipment and Battery Rooms Unit 1 East Side (C-604, 602, 603, 608) Fire Zones
0-28B1, 0-28M, 0-28N, 0-28J, Elevation 771'-0", Revision 4
Attachment
A-3
Section 1R06: Flood Protection Measures
Condition Reports:
1121942,1171337,1172365,and606589
Work Order:
606837
Section 1R07: Heat Exchanger Performance
Condition Reports and Action Requests:
1003096,915409,984635,1136415,1153052, 1178867, 1095358, 1109759, 1172704,892305,
1095358,1109759,1162322,1084289, 1162414, 1108376, and 1044430
Procedures:
H-1001, Heat exchanger tube cleaning, Revision 5
H-1004, Heat exchanger inspection and condition assessment, Revision 6
H-1005, Eddy Current Examination Services, Revision 6
NDAP-QA-0504, Heat Exchanger Program, Revision 4
TP-149-079, RHR Heat Exchanger Performance Test, Revision1
ER-AA-340, GL 89-13 Program Implementing Procedure, Revision 4
ER-AA-340-1001, GL 89-13 Program Implementation Instructional Guide, Revision 6
ER-AA-5400, Buried Pipe and Raw Water Corrosion Program Guide, Revision 1
ER-AA-5400-1001, Raw Water Corrosion Program Guide, Revision 0
ER-AA-5400-1002, Buried Piping Examination Guide, Revision 1
Limerick GL 89-13 Program Basis Document, Revision 0
CY-LG-120-828, Clam Control Activities, Revision 5
CY-LG-120-1102, Outside Chemistry/NPDES related Sampling and analysis schedule,
R:evision 18
CY-LG-120-1117, Spray Pond Chemistry Guide, Revision 2
ST-2-011-390-0, ESW/Diesel Generator Heat Transfer Test, Revision 4
M-011-001, LGS Preventive Maintenance Procedure for Diesel Generator Heat Exchanger
Cleaning and Examination, Revision12
Standing work order R0920468-01, EDG heat exchangers
Drawings
Drawing # M-109/E106214, Service Water System, Revision 50,
Drawing # M-111/E106216, Emergency Service Water System, Revision 48
Drawing # M-112/E106217, RHR Service Water System, Revision 47
Drawing # M-120/E106225, Diesel Oil Transfer System, Revision 32
SIM-M-12, Emergency Service Water! RHR Service Water Overview, Revision 9
8031-M-11, Sh. 1-5, Emergency Service Water, Revision 68, 81,53,50,48, respectively
8031-M-12, Sh. 1-2, Residual Heat Removal Service Water, Revision 62,6, respectively
8031-E-1045, Cathodic Protection Plan Spray Pond & Cooling Towers Area, Revision 14
8031-E-'1046, Cathodic Protection Plan - PCMU, RHR & ESW Piping, Units 1 & 2, Revision 14
Unit 2 RHR Heat Exchanger Assembly & Cross Section Drawings, April 1972
Attachment
A-4
Work Orders:
796290, 796291,2E205A,889724,888029,OE505A1&2, 1078542,808322,OE505E1&2,
889732,889516,OE506A, 1111425, 1067871,OE506E,916733,889717,OE507A, 1111426,
1067872,OE507E,941280,889240
Miscellaneous Documents
Regulatory Guide 1.27, Ultimate Heat Sink for Nuclear Power Plants, dated January 1976
Generic Letter 89-13 and Supplement 1, Service Water System Problems Affecting
Safety-Related Equipment, Dated July 1989
PPL responses to GL 89-13, dated Feb. 23,1990, through Feb. 12, 1997, et al
Spray Pond Inspection Report, November 13, 2007
Zebra Mussel & Asiatic Clam Survey, November 6, 2007
ECT Test Report for Heat Exchanger 2A-E205, March 2005
WO R0966553, Clean and eddy current test 2A-E205, performed May 19, 2005
IC-C-11-02021, Testing of Cathodic Protection System, performed September 4, 2007
RT-1-012-390-0, RHR Heat Exchanger Heat Transfer Performance Computation Test,
performed Feb. 15, 2005
RT-2-011-251-0, ESW Loop A Flow Balance, Rev. 15, performed April 26, 2008
RT-6-012-390-2, 2A-E205 Heat Exchanger Heat Transfer Test, performed Feb. 9, 2005
RT-6-109-001-0, Cathodic Protection Monthly Inspection, performed September 4, 2007
ST-1-012-901-0, Spray Pond Structural Inspection, performed September 5,2002,
August 10, 2003, August 10, 2005, and July 27,2007
ST-6-011-231-0, A Loop ESW Pump, Valve, and Flow Test, performed May 9,2008, and
August 8, 2008
ST-6-012-232-0, A Loop RHRSW Pump, Valve, and Flow Test, performed May 16, 2008,
elnd August 7,2008
Structural Integrity Associates, Inc., Limerick ESW/RHRSW Pre-Outage Support, May 7,2008
Nuclear Event Report NC-07-044, Essential Service Water Piping Degradation, Rev. 0 & 1
Operational Event Review - Degradation of Essential Service Water Piping, January 15, 2008
Technical Evaluation - Cumulative Leakage from the ESW System (CR 714581-02)
Technical Evaluation EDG Permissible Fouling Factors as a Function of ESW Flow and
Plugged Tubes (IR 691841)
Apparent Cause Evaluation -Internal Corrosion of RHRSW System Piping (CR 731389)
Apparent Cause Evaluation -Increased Frequency of ESW Throttle Valve Silting (11/14/05)
Apparent Cause Evaluation - Diesel Heat Exchanger GL 89-13 Heat Transfer Test Performed
Too Soon After Cleaning (CR 174574)
RHRSW Pipe Minimum Wall Thickness Action Plan (IR 693495-32)
1D-G501, EDG Heat Exchanger Inspection Report, June 23, 2008
2D-G501, EDG Heat Exchanger Inspection Report, December 10,2007
LG 96-02349-000, Undersized Lube Oil Cooler
LG 01-0'1096-000, LGS Unit 1 & 2 GL 98-13 Program Recommendation - Heat Exchanger
Cleaning
LG 01-00968-000, Final Report on DG Heat Exchanger Performance Tests GL 89-13
Calculation LM-0225, Performance Curve for EDG Heat Exchanger for GL 89-13
Engineering Analysis LEAM-0007, Emergency Diesel Heat Exchanger Performance Tests
GL 89-13, September 10, 2001.
Evaluation of 0-22 EDG Heat Exchanger Performance Test of August 26, 2003
Evaluation of 0-22 EDG Heat Exchanger Performance Test of July 24,2004
Attachment
A-5
Evaluation of lube oil cooler fouling factor increases in winter, October 1, 2008
Commitment Change Evaluation 2006-002
ECR LG 96-02349, Undersized Lube Oil Cooler
ECR LG 01-01096, GL 98-13 Program Recommendation Heat Exchanger Cleaning
ECR LG 01-00968, Final Report on DG Heat Exchanger Performance Tests GL 89-13
ECR LG 04-00433, Licensing Basis of RHRSW Flow
Summary of RHRSW/ESW Valve Pit Inspections
Other:
Station Health Reports for RHR and EDG Systems:
2009, 1st period - Jan 1 - May 31
2008, 151 period - Jan 1 - Apr. 30
2 nd period - May 1- Aug. 31
3 rd period - Sept 1 - Dec. 31
2007, 1sl period - Jan 1 - Apr 30
2 nd period - May 1 Aug 31
3rd period Sept 1- Dec 31
Eddy Current Testing Final Reports
1E205B** 1B RHR Hx, 2E205A -1A RHR Hx, OE505 - Ai, A2, E1, E2, OE505, OE506 A, E,
OE526 E, OE507 A, E
ESSW Spray Pond Dive Inspection Report
Ecology III, Inc. report dated 3 August 2009
SO-054-A03, Quarterly ESW flow verification - Loop A, February 23, 2005 and
November 24, 2004
SO-054-803, Quarterly ESW flow verification - Loop B, February 16, 2005 and
November 17, 2004
TP-054-076, ESW flow balance, September 24, 2004
Chemistry Matrix Ch-054-001 (ESW), Revision 23, March 05, 2008
Design Calculations
CALC EC-CHEM-1018, Justification for the Assurance of Adequate Heat Removal Capabilities,
Revision 5
CALC EC-054-0537, ESW System Heat Load and Flow Rate Requirements for Updated Power
Conditions, Revision 5
CALC-049-1001, RHR Heat Exchanger Performance at 8000 gpm RHR Flow, Revision 5
Section 1R11: Operator Re-qualification Program
Condition Report:
1159194,1173155,1173182,622658,625137,389555,1166686
Procedures:
ON-164-002, Loss of Reactor Recirculation Flow, Revision 28
ON-178-002, Core Flux Oscillations, Revision 14
Attachment
A-6
ON-100-101, SCRAM, SCRAM Imminent, Revision 22
EO-000-113, Level/Power Control, Revision 6
EO-000-102, RPV Control, Revision 7
NDAP-QA-0725, Operating Experience Review Program, Revision 7
Other:
OP002-09-06-01, Simulator Scenario, Revision 0
Section 11R12: Maintenance Effectiveness
Condition Report:
1172458,1173175,1173454,1173859,1174337
Procedure:
ES-002-001, Supplying 125 VDC Loads with Portable Diesel Generator, Revision 12
Work Orders:
1172466,1172530
Section 1R13: Maintenance Risk Assessments and Emergent Work Control
Condition Report:
1162039,1172088,1171760,1171814, 1171764,and 1137572
Procedure:
MT-GE-030, ITT Damper Hydramotor Model NH91 NH93 Overhaul, Revision 17
OI-AD-029, Emergency Load Control, Revision 13
MT-GE-030, ITT Damper Hydramotor Model NH91 and NH93 Overhaul, Revision 17
DrawingS'~:
E-102, Sheet 17, ESS Transformer 101R201 Isolating Relay Control, Revision 13
E-102, Sheet 17 Circuit Breaker DA10406 Control, Revision 11
M-144, Sheet 2, Reactor Water Clean-Up, Revision 11
M-144, Sheet 1, Reactor Water Clean-Up, Revision 41
E6-8, sheet 1, ESS Trans EX201 and OX203, Revision 8
VC-175, Heating, Ventilation and Air-Conditioning Control Diagram SBGT System, Revision 31
M-145, Sheet 1, Clean-up Filter Demineralizer, Revision 21
Work Order:
1162052 and 828214
Other:
Attachment
A-7
2009 RFM Daily Status Report August 3-4,2009 - Cask 53
Section 1R15: Operability Evaluations
Condition Reports:
1159448,1159214,1159461,478425,794697,478350, 1160418, 1160653, 1112465, 1119661,
1147886,1145418,1152053,1152076,1161825, 1162050, 1172110, and 1172113
Procedures:
FSAR 7.:3.1
TRO 3.3.6
Drawings:
J-412, Sheet 6, RHR SW Pump Discharge Pressure, Revision 6
M-134, Sheet 3, A - D Diesel Auxiliaries Starting Air System, Revision 15
Work Order:
1159273
Engineering Work Request:
EWR 110707
Other:
10M 183-2, KSV Diesel Generator Instruction Manual, Revision 89
Section 1R18: Permanent Plant Modifications
Condition Reports:
1179204,1179788,1179777,1178870,1136097, 1136107, 1136188, 1141687,1136189,
1135663
Procedures:
FSAR 9.4.2.2,9.2.12.3, Table 9.4-4,5
TRO 3.8.6 and bases
LA-1K206B-001, 1K206B Reactor Building Chiller B Safety Indicator Panel, Revision 2
Drawingq:
M310-245, Sheet 2, Chiller 1K206B, Revision 2
Work Order:
1180017,1104170.1082776,1136153,1136156,1136013
Attachment
A-8
Engineering Work Request:
EWR 1086364
TEC 1136133, Bypass Gas Discharge Temperature Trip on -IK206B
Other:
10M 694, Type SL Core Form Substation Transformer Type UTT-B Load Tap Changer Spare
Startup Transformer, Revision 2
Section '1 R19: Post-Maintenance Testing
Condition Reports:
1079703" 1161553, 1174414, 1174403, 1177692, 1177906, 1183410
Procedures:
SO-151-014, Core Spray System Cold Shutdown Valve Exercising, September 28,2009,
Revision 16
SO-151-A04, Quarterly Core Spray Valve Exercising Division I, September 28,2009, Revision 9
SO-152-006, High Pressure Coolant Injection Comprehensive Flow Verification, Revision 8
SO-158-001, "Weekly Manual Scram Control Switch Functional Check," Revision 12
OP-003-003, Startup Bus 20 (OA104)fr20 Outage and restoration, Revision 1
Drawing
9220248, Connection Diagram Hydraulic Control Unit, Revision 3
10505411, Box and Cables Hydraulic Control Unit, Revision 3
105D5634, Connection Diagram Hydraulic Control Unit, Revision 2
922D234, Assembly Electrical box, Revision 3
E-157, Sheet 3, Trip Signals to hydraulic control unit Unit 1, Revision 7
MI-C72-~~2, Sheet 12, Elementary Diagram Reactor Protection System, Revision 13
Work Orders:
1046829., 1177693, 1012176
Engineering Work Reguest:
EC 1100766, Generic ECO 480V MCC Bucket Replacement
Section'1R22: Surveillance Testing
Condition Reports:
10419999,1159516, 1159518,1159520,1176579,917309,1041999, 1176718,1176719
Procedures:
Attachment
A-9
SE-070-A09, "A" SGTS HEPA Filter and Charcoal Adsorber in-Place Leak Test, Revision 5
MT-GM-076, Operations of the Aerosol Detector and Aerosol Generator for Testing HEPA
Filters, Revision 3
MT-GM-077, Operation of the Halide Detector and Halide Generator for Testing Charcoal
Filters, Revision 4
SI-250-312, 24 Month calibration of RCIC System Pump Flow Channel FT-E51-2N003 Remote
Shutdown Monitor
SE-150-004, RCIC Functional Test at 1C2014, January 21,2008, Revision 0
SE-100-008, RCIC Functional test at Remote Shutdown Panel, Revision 4
SE-200-008, RCIC Functional test at Remote Shutdown Panel, January 21, 2009, Revision 2
SE-100-011, HV143F023B, Functional Test at 1C2014, March 5, 2008, Revision 0
Work Orders:
875249,1130776
Drawing:
VC-175, Sheet 3, HVAC Control Diagram RB SGTS, Revision 31
E-201, Sheet 9, SGTS Dampers HD-0755A & B, Revision 17
E-154, Sheet 3, RCIC Outboard Steam Line Isolation Valve Unit 1, Revision 18
E-154, Sheet 22, RCIC Outboard Steam Line Isolation Valve Unit 2, Revision 5
E-149, Sheet 6, Remote Shutdown Panel 2C201, transfer Switches Unit 2, Revision 9
Section 1EP6 Drill Evaluation
Condition Reports:
1174697,1174731
Procedures:
EP-TP-001, EAL Classification Levels, Revision 2
Other:
August 25,2009 Drill Results Summary
Section 20S1: Access Control to Radiologically Significant Areas
Condition Reports:
1168353; 1167515; 1167427; 1162310; and 1165207
Section 20S2: ALARA Planning and Controls
Condition Reports:
1155780; 1153396; and 1140623
Section 20S3: Radiation Monitoring Instrumentation
Attachment
A-10
Quality Assurance Internal Audit Reports:
665555; 819260; and 1093653
NIST NVLAP On-Site Assessment Report, March 13,2009
Personnel Dosimetry Performance Testing Quarterly Report, 4th Quarter 2007
Section 40A1: Performance Indicator Verification
Procedures:
NDAP-QA-0737, Reactor Oversight Process Performance Indicators, Revision 5
Operator Logs, Unit 1 and Unit 2
Section 40A2: Identification and Resolution of Problems
Condition Reports:
1159518, 1159523, 1160653, 1161370, 1161398, 1162307, 1168487, 1168500, 1172365,
1173445,1173454,1174011,1174052,1174964,1175030, 1175048, 1175140, 1175332,
1175332, 1176331,1176959,1177165,1177499,1177965,1178870, 1179656, 1179995,
1027040,1044490,1073866,1114121,1128499, 1147908, 1148761,1148762,1148765,
1148790,1148824,1148828,1148834,1148851, 1148852, 1148853, 1148854, 1148859,
1148862,1148879,1148884,1148887,1148891, 1148895, 1148900,1157872,1158039,
1162998,.1173604,1173611,1173614, 1173619,1173697, 1181243
Engineering Work Request:
1161370
Procedures:
NDAP-00-0109, "Employee Concerns Program", Revision 13
NDAP-QA-0702, "Action Request and Condition Report Process", Revision 23
NRC Letter-EA-09-003, Work environment Issues at SSES-PCE, dated January 28, 2009
PPL Lettt:3r PLA-6486, SSES NRC Request to Address Work Environment Issues at SSES,
dated February 27, 2009
PPL Letter PLA-6489 SSES NRC Request to Address Work Environment Issues at SSES,
dated March 13, 2009
PPL Letter PLA-6528 SSES PPL Susquehanna LLC Work Environment Improvement Plan,
dated June 23, 2009
SSES Organization chart dated 9/10/2009
SSES Concerns Hotline flyer
Attachment
A-11
Safety Conscious Work Environment Trending Survey November 2008, Revision 0
General Work Environment-PCE Power Point Presentation, dated June 15, 2009
Communication Plan for Work Environment Root Cause Analysis report, dated June 3, 2009
USNRC Allegation Website allegation data from January 2005 - August 2009
SSES Organizational Effectiveness Oversight Panel, Employee Focus Group Meeting May 5-7,
2009 summary report
SSES Focus (Internal Communications newsletter) dated July 16, 2009; July 21,2009; July 29,
2009; July 31, 2009:;August 7, 2009 (2); August 14, 2009, August 17,2009, August 20,
2009, August 24,2009, August 26,2009, August 31,2009; September 1,2009,
September 4, 2009; September 11, 2009; September 14, 2009 (2); September 15, 2009;
September 22, 2009; and September 23, 2009
SSES Grapevine dated August 28, 2009; September 2, 2009; and September 8, 2009
SSES Work Environment Performance Indicators for July 2009 and August 2009
Proposed Draft General Work Environment Performance Indicator data dated
September 23, 2009
PPL Performance Planning and Review Process- Personnel Goals and Observation planning
sheet dated April 21, 2009
Nuclear culture review survey provided to Operations Department on 8/19/09 and preliminary
evaluation of the data
Memorandum of Agreement between PPL and IBEW Local 1600 dated may 9,2002
SSES RCA rollout Presentation and feedback forms
Section 40A5: Other
Condition Reports:
1173698
ISFSI related Condition Reports since July 12, 2006
Procedures:
ME-ORF-023, Dry Fuel Storage 61 BT Dry Shielded Canister, Revision 14
MT -EO-045, Guidance and Use of NUHOMS Automated Welding System for Welding
Operation, Revision 1
ME-ORF*,179, Dry Fuel Storage EqUipment List and Reference Information, Revision 8
NDAP-QA-0658, Dry Fuel Storage Program, Revision 6
IVIE-ORF-152, Dry Fuel Storage Response to Crane/RigginglTransfer Equipment, Malfunction
and Certificate of Compliance Technical Specification Requirements, Revision 2
MT-EO-058, E1000 Series Vacuum Drying System Operation, Revision 8
ME-ORF*,150, Dry Fuel Storage Dry Shielded Canister Unloading, Revision 1
RE-081-43, Selection and Monitoring of Fuel for Dry Storage, Revision 5
ON-089-001, Dry Fuel Storage Temperature Anomaly, Revision 6
MT-199-001, Reactor Building Crane Operating Procedure, Revision 18
MT-199-002, Reactor Building Crane Main & Auxiliary Hoist Limit Switch Testing, Revision 6
MT-GM-014, Rigging and Lifting Equipment Inspection, Revision 16
Work Orders:
ERPM 937419, Inspect 1H213 Crane for Proper Operation
ERPM 1065158, 1H213 Perform 4 year Weld Inspections, completed May 30,2009
Attachment
A-12
Other:
2008 PPL SSES LLC Dry Fuel Storage Project Completion Review Self Assessment
2009 Dry Fuel Storage Readiness Review
Annual Synthetic Round Sling Inspection Checklist
72.48 Screens, SO 00041, SO 00035, SO 00038, SO 00033, SO 00035, SO 00028, SO 00027,
SO 00024, SO 00000022, SO 00016, SO 00015, SO 00006
Final safety Analysis Report (FSAR), November 9, 2007
Decay Heat Calculation, EC-Fuel-1185, Revision 26
FACCTAS for DSC #53, July 31,2009, Revision 0
ISFSI Temperature Monitoring System Software Requirement Specification, July 2, 1999,
Revision 1.1
Annual Preventative Maintenance Plan for Unit 1 Reactor Building Crane, WO 19018,
completed December 5, 2008
SSES Area Survey Map, ISFSI Facility, dated: January 28, 2008; April 22, 2008; July
25, 2008; October 24, 2008; January 22, 2009; April 25, 2009; May 1, 2009
LIST OF ACRONYMS
ADAMS Agencywide Document and Access Management System
ALARA As Low As Is Reasonably Achievable
AV Apparent Violation
CAP Corrective Action Program
CFR Code of Federal Regulations
CR Condition Report
DG Diesel Generator
ECP Employee Concerns Program
EDG Emergency Diesel Generator
EPU Extended Power Uprate
ESW Emergency Service Water
FIN Finding
FPE Fire Protection Engineer
FPPR Fire Protection Program Report
FSAR [SSES] Final Safety Analysis Report
HPCI High Pressure Coolant Injection
HV High Voltage
IN Information Notice
IMC Inspection Manual Chapter
ISFSI Independent Spent Fuel Storage Installation
lSI Inservice Inspection
IWIIISI In Vessel Visual Inspectionll nservice Inspection
LCO Limiting Condition for Operation
NCV Non-Cited Violation
NDAP Nuclear Department Administrative Procedure
NRC Nuclear Regulatory Commission
PARS Publicly Available Records
PCE Potential Chilling Effect
PI [NRC] Performance Indicator
PM Preventive Maintenance
Attachment
A-13
PMT Post-Maintenance Test
QA Quality Assurance
RCA Root Cause Analysis
RCIC Reactor Core Isolation Cooling
RHRSW Residual Heat Removal Service Water
RTP Rated Thermal Power
SBO Station Blackout
SCWE Safety Conscious Work Environment
SOP Significance Determination Process
SGTS Standby Gas Treatment System
SRO Senior Reactor Operator
SSC Structures, Systems and Components
SSES Susquehanna Steam Electric Station
TS Technical Specifications
T20 T20 Startup Transformer
Attachment