IR 05000387/2009004: Difference between revisions

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{{Adams|number = ML093170375}}
{{Adams
| number = ML100280714
| issue date = 01/28/2010
| title = EA-09-248, Susquehanna, Notice of Violation (NRC Inspection Report Nos. 05000387/2009004 and 05000388/2009004)
| author name = Collins S J
| author affiliation = NRC/RGN-I/ORA
| addressee name = Rausch T S
| addressee affiliation = PPL Susquehanna, LLC
| docket = 05000387, 05000388
| license number = NPF-014, NPF-022
| contact person = McLaughlin M
| case reference number = EA-09-248, IR-09-004
| document report number = EA-09-248
| document type = Enforcement Action, Letter, Notice of Violation
| page count = 8
}}


{{IR-Nav| site = 05000387 | year = 2009 | report number = 004 }}
{{IR-Nav| site = 05000387 | year = 2009 | report number = 004 }}


=Text=
=Text=
{{#Wiki_filter:UNITED NUCLEAR REGULATORY REGION 475 ALLENDALE KING OF PRUSSIA, PA November 13, 2009 EA-09-248 Mr. TimothySenior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Boulevard, NUCSB3 Berwick, PA 18603 SUSQUEHANNA STEAM ELECTRIC STATION -NRC INTEGRATED INSPECTION REPORT 05000387/2009004 AND 05000388/2009004
{{#Wiki_filter:
[[Issue date::January 28, 2010]]
 
EA-09-248 Mr. Timothy Senior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Boulevard, NUCSB3 Berwick, PA 18603
 
SUBJECT: SUSQUEHANNA STEAM ELECTRIC STATION - NOTICE OF VIOLATION NRC Inspection Report Nos. 05000387/2009004 and 05000388/2009004


==Dear Mr. Rausch:==
==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 [[Exit meeting date::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 (A V) 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).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 1 R11 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 theSusquehanna 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).
This refers to the inspection completed on September 30, 2009, at Susquehanna Steam Electric Station Units 1 and 2 (Susquehanna). The purpose of the inspection was to examine 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. During the inspection, the NRC reviewed two instances of a failure by PPL Susquehanna, LLC (PPL) to obtain NRC approval for two senior reactor operators (SROs) to continue to conduct NRC-licensed activities after each SRO did not meet a specific medical prerequisite for performing the duties of a licensed operator, as required by 10 CFR 55.3. These failures, which were identified by your staff, were discussed during an exit meeting that Mr. Paul Krohn and the Susquehanna resident inspectors held with your staff on October 9, 2009. The apparent violation was described in detail in the subject NRC inspection report dated November 13, 2009 (Inspection Report Nos. 05000387/2009004, 05000388-2009004; ADAMS Accession Number ML093170375).
 
With respect to the first instance, during August 2009, a medical examination for an SRO identified a disqualifying condition, namely, that the SRO's vision did not meet the health requirements stated in ANSI/ANS 3.4-1983, Section 5.4.5, "Eyes." Nonetheless, the SRO continued to perform licensed watchstanding duties on three different occasions following the examination, without the NRC first being informed to ensure that the individual's license was conditioned to require corrective lenses. With respect to the second instance, another SRO had not received the required biennial medical examination, which was due by April 1, 2009, until July 22, 2009. During that time, the SRO performed licensed operator duties 52 times.
 
The NRC recognizes that PPL discovered both of these instances, and upon discovery of the issues, notified the NRC and removed both individuals from watchstanding duties pending follow-up medical evaluations. PPL requested a conditional NRC license for the first SRO, and administered the biennial examination to the second SRO, which he passed. Both issues were also entered into PPL's corrective action program.
 
On November 9, 2009, Mr. David Lew and Mr. Krohn of my staff spoke with Mr. Jeff Helsel, Plant Manager, and other members of your staff, and provided them the opportunity to address the apparent violation by either attending a predecisional enforcement conference or by providing a written response before we made our final enforcement decision. On November 10, , Mr. Michael Crowthers, Manager, Nuclear Regulatory Affairs, responded that PPL planned to submit a written response. The NRC received the PPL response on December 10, 2009 (ML100150702).
 
In its response, PPL acknowledged that both SROs did not fully meet the prerequisite medical requirements in each case. PPL also noted that it promptly identified the conditions, developed root causes, and corrected the conditions with no consequence to safe operation of the plant. PPL contended that the safety significance of both instances was very low and represented Severity Level (SL) IV violations that should be dispositioned as non-cited violations. PPL indicated that: 1) neither SRO was ever the only SRO credited to meet minimum Technical Specification staffing requirements; and, 2) there were no actual consequences during the times that the SROs were on-shift without having met the appropriate licensing requirements. PPL also stated that the situations did not impact the NRC's initial licensing decisions in the time period prior to these incidents, in that both NRC Forms (Form 396) on-record were complete and accurate as of the time of the last successfully completed medical examinations, and, in the case of the second example, the SRO subsequently passed the 2009 biennial examination.
 
The NRC evaluated the information developed during the inspection, as well as the information PPL provided in its response, and has concluded that each instance constituted a violation of NRC requirements, one of which has been classified at SL III and the other of which has been classified at SL IV. The violations are cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding them are described in detail in the subject inspection report.
 
In determining the significance of the violations, the NRC recognizes that although both SROs did not meet their medical prerequisites, they were never in a solo-status and no operational errors were identified while on shift. In addition, in the second instance, the SRO for whom the medical physical was not completed in a timely manner was later found to meet all medical fitness requirements when the physical was subsequently completed. This violation has been categorized at SL IV because the failure to receive the physical in a timely manner did not invalidate the licensing basis for this individual since the SRO was subsequently determined to be medically fit. However, the first instance, involving the SRO for whom vision problems were identified, did impact the licensing basis for that individual because the SRO was required to have his license conditioned to wear corrective lenses while performing licensed activities. This violation has been categorized in accordance with the NRC Enforcement Policy at SL III.
 
In accordance with the NRC Enforcement Policy, a base civil penalty in the amount of $70,000 is considered for a SL III violation. Because your facility has been the subject of escalated enforcement actions within the last 2 years 1, the NRC considered whether credit was warranted for Identification and Corrective Action in accordance with the civil penalty assessment process in Section VI.C.2 of the Enforcement Policy. The NRC has concluded that credit for Identification is warranted because PPL discovered the issue through internal reviews and informed the NRC in a timely manner upon discovery. Additionally, the NRC has concluded that credit for Corrective Action is warranted because PPL's actions in response to the issue were prompt and comprehensive. The immediate actions included: (1) disqualifying the SRO with the vision issue from the licensed position and removing him from standing watch until receipt of a revised NRC license which added a condition that corrective lenses be worn; and, (2) immediately revoking the second SRO's qualifications until administering the physical examination to him on July 24, 2009. In addition, specific actions were taken and/or are 1 A "Greater-than Green" finding with a related Notice of Violation was issued on August 11, 2009 (EA-09-108) for a security-related issue. planned by PPL to prevent recurrence, including: (1) developing and implementing use of a form, to be completed at the conclusion of the visual and audiometric testing for any employee receiving a Licensed Operator Medical Examination, which states that any negative response be immediately reported to the PPL senior staff specialist of Health Services; (2) issuing two operations bulletins, to inform operators of the new form that will be used by the attending physician to provide immediate feedback on test results for eye and hearing testing, and to reinforce the ANSI standards regarding the passing criteria for eye and hearing tests; (3) checking the site database to ensure that all biennial examination expiration dates were correct; (4) ensuring that no manual overrides are permitted in the site database system without two levels of approval; (5) establishing a performance indicator to track medical certification expirations; and, (6) conducting an effectiveness review of all medical transactions six months after the last corrective action is complete to verify that no processing errors have occurred.
 
Therefore, to encourage prompt and comprehensive correction of violations, I have been authorized, after consultation with the Director, Office of Enforcement, not to propose a civil penalty in this case. However, significant violations in the future could result in a civil penalty.
 
The NRC has also concluded that information regarding the reason for the violations, the corrective actions taken and planned to correct the violations and prevent recurrence and the date when full compliance was, or will be, achieved is already adequately addressed on the docket in Inspection Report Nos. 05000387/2009004, 05000388/2009004, in the PPL letter received December 10, 2009, and in this NRC letter. Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.
 
In addition, in its December 10, 2009, response, PPL disputed the statement in the NRC inspection report that the finding related to these violations 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 [Inspection Manual Chapter 0305, Appendix A, "Components within the Cross-Cutting Areas," Item P.2(a)]. The NRC inspection report noted that PPL failed to evaluate NRC Information Notice (IN) 2004-20, "Recent Issues Associated with NRC Medical Requirements for Licensed Operators," in accordance with their operating experience review program, as evidenced by a 2008 SL IV non-cited violation (NRC Inspection Report Nos. 05000387/2008302, 05000388-2008302; ML081340746) for an initial licensed operator application submitted to the NRC with a disqualifying medical condition (and the two events described in the NRC inspection report and this letter). In support of its position, PPL stated that upon receipt of the IN, PPL had evaluated its operator medical information and found that no corrective actions were required. PPL further stated that none of the examples cited in the IN would have led to actions that, five years later, would have precluded the issues associated with the two events described in the NRC inspection report and in this letter. In addition, PPL stated that with respect to the first instance, involving the SRO who failed his vision examination, the Form 396 was submitted within the required 30 days; and that with respect to the second instance, involving the SRO who missed his biennial examination, no Form 396 was required; therefore, the IN examples were not comparable to these violations.
 
The NRC considered the position presented by PPL and the fact that these instances represent separate violations. Regarding the first instance, the NRC concluded that the cross-cutting aspect as described in NRC Inspection Report Nos 05000387/2009004 and 05000388/2009004 is correct, as stated. IN 2004-20 states, in part, "licensed operators should understand that they are responsible for meeting all the conditions of their license and for promptly informing their employer if they develop any medical condition, such as needing to wear glasses - that could affect their fitness to safely operate the facility." The IN also states that the, "NRC depends on facility licensees to ensure that the personnel who perform and evaluate licensed operator medical examinations understand the regulatory requirements, the applicable medical standards, . . ., thereby ensuring that the examinations are performed correctly and any medical defects are accommodated." As of August 2009, this operating experience had not been properly incorporated at Susquehanna. Specifically, regarding the SRO with vision problems, PPL did not have a requirement to ensure the examining physician, a PPL contractor, immediately informed PPL after the exam, that the SRO needed corrective lenses. As a result, PPL did not administratively limit the SRO's licensed operator duties until the NRC had been informed and a license condition was processed to require corrective lenses. Consequently, the SRO stood watch three times after the exam without a license condition to require corrective lenses. Regarding the second instance, the NRC agreed with PPL's position that actions to prevent the IN examples would not have precluded the missed biennial medical evaluation. Therefore, no cross-cutting aspect will be assigned to the violation involving the SRO who missed the biennial medical examination.
 
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response, if you choose to provide one, should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such information, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). The NRC also includes significant enforcement actions on its Web site at www.nrc.gov; select What We Do , Enforcement, then Significant Enforcement Actions.
 
Sincerely,/RA/
Samuel J. Collins Regional Administrator Docket No. 50-387; 50-388 License No. NPF-14; NPF-22
 
===Enclosure:===
Notice of Violation cc w/encl: Distribution via ListServ
 
ML100280714
" C" = Copy without attachment/enclosure " E" = Copy with attachment/enclosure " N" = No Copy OFFICE RI/ORA RI/DRP RI/DRS RI/DRP RI/DRS NAME ADeFrancisco via emai PKrohn* SHansell* DLew*
P Wilson for DRoberts*
 
DATE 12/18/09 12/23/09 12/24/09 12/30/09 12/31/09 OFFICE RI/ORA RI/ORA OE NRR RI/ORA NAME KFarrar* DHolody* GGulla via email JMcHale via email SCollins DATE 1/08/10 1/25/10 1/21/10 1/21/10
* See concurrence on previous page Distribution w/encl:
(via e-mail)
ADAMS (PARS)
SECY CA OEMAIL OEWEB W Borchardt, EDO B Mallett, DEDR L Trocine, OEDO R Zimmerman, OE B Sosa, OE N Hilton, OE L Lopez,OE N Hasan, OE M Crutchley, OE G Gulla, OE E Leeds, NRR Enforcement Coordinators RII, RIII, RIV C Scott, OGC E Hayden, OPA H Bell, OIG C McCrary, OI S Titherington-Buda, OCFO M Williams, OCFO D Screnci/N Sheehan, RI K Farrar, RI D Holody, RI A DeFrancisco, RI/M McLaughlin, RI C O'Daniell, RI Region I OE Files (with concurrences) RI ORA Mail Resource RI DRP Mail Resource S Collins, RA M Dapas, DRA D Roberts, DRS P Wilson, DRS S Hansell, DRS J Clifford, DRP D Lew, DRP P Krohn, DRP A Rosebrook, DRP/R Fuhrmeister, DRP P Finney, DRP, SRI S Ferrel, DRP, OA RidsNrrODMail Resource RidsNrrPMSusquehanna Resource RidsNrrDorpl1-2 Resource H Chernoff, NRR R Nelson, NRR D Egan, NRR, PM ROPreports@nrc.gov Region I Docket Room (with concurrences)
NOTICE OF VIOLATION PPL Susquehanna, LLC (PPL) Docket No. 50-387; 50-388 Susquehanna Steam Electric Station License No. NPF-14; NPF-22 EA-09-248
 
During an NRC inspection, conducted during the third quarter of 2009, for which an exit meeting was held on October 9, 2009, violations of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violations are listed below:
10 CFR 55.21 requires, in part, that a reactor or senior reactor operator 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, 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.


Sincerely,IRA! David C. Lew, Director Division of Reactor Projects Docket Nos. 50-387; 50-388 License Nos. NPF-14, NPF-22
10 CFR 55.3 requires, in part, 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.


===Enclosures:===
10 CFR 55.23 requires, in part, that a facility licensee shall certify the medical fitness of an applicant by completing and signing a Form 396, "Certification of Medical Examination by Facility Licensee. On its Form 396s, licensees must certify, in part, what guidance was used to determine the medical fitness of its applicants. PPL certified that it used the guidance in ANSI/ANS 3.4-1983, "Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants."
Inspection Report 05000387/2009004 and 05000388/2009004


===Attachment:===
ANSI/ANS 3.4-1983 states, in part, that the primary responsibility for assuring that qualified personnel are on duty rests with the facility licensee. In addition, the health requirements set forth within the standard provide the minimum necessary to determine that the physical condition and general health of the operators are not such as might cause operational errors endangering public health and safety. The specific health requirements and disqualifying conditions are described in Section 5.3, "Disqualifying Conditions," and Section 5.4, "Specific Minimum Capacities Required for Medical Qualifications," of the ANSI standard.
Supplemental Information cc w/encl: Distribution via ListServ T. 4 Susquehanna Steam Electric Station. The information you provide will be considered accordance with Inspection Manual Chapter 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 Inspection Report 05000387/2009004 and 05000388/2009004
1. Contrary to the above, in 2009, a PPL Senior Reactor Operator (SRO) did not meet a certain medical prerequisite for performing NRC-licensed operator activities, and the SRO continued to perform NRC-licensed activities without PPL first submitting a Form 396 to obtain NRC approval. Specifically, on three occasions between August 10, 2009, and August 18, 2009, the PPL SRO (although possessing an NRC license) performed SRO duties even though, on August 10, 2009, a change in his licensed condition existed as found by a medical examination. 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," and PPL did not obtain NRC approval for the change in licensed activities Notice of Violation 2 by requesting a conditional license indicating that corrective lenses be worn prior to performing licensed duties.


===Attachment:===
This is a Severity Level III violation (Supplement VII).
Supplemental Information cc Distribution via ListServ Distribution w/encl: (via E-mail) S. Collins, (R10RAMAIL Resource) M. Dapas, (R10RAMAIL Resource) D. Lew, (R1 DRPMAIL Resource) J. Clifford, (R1 DRPAMAIL Resource) P. Krohn, DRP D. Holody OE (R10RAMAIL Resource) R Fuhrmeister, DRP A. Rosebrook, DRP E. Torres, DRP J. Bream, DRP F. Jaxheimer, DRP, SRI P. Finney, DRP, RI S. Farrell, DRP, OA L. Trocine, RI OEDO RidsNrrPMPeachBottom Resource RidsNrrDorlLpl1-2 Resource ML093170375 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 Docket No: License No: Report No: Licensee: Facility: Location: Dates: Inspectors: Reviewed By: Approved By: U.S NUCLEAR REGULATORY COMMISSION REGION I 50-387, 50-388 NPF-14, NPF-22 05000387/2009004 and 05000388/2009004 PPL Susquehanna, LLC Susquehanna Steam Electric Station, Units 1 and 2 Berwick, Pennsylvania July 1, 2009 through September 30, 2009 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 Paul G. Krohn, Chief Projects Branch 4 David C. Lew, Director Division of Reactor Projects Enclosure TABLE OF


=SUMMARY OF FINDINGS=
2. Contrary to the above, in 2009, a second PPL SRO did not meet a certain medical prerequisite for performing NRC-licensed operator activities, and the SRO continued to perform NRC-licensed activities without PPL first submitting a Form 396 to obtain NRC approval. Specifically, on 52 occasions between April 1, 2009, and July 22, 2009, the second PPL SRO (although possessing an NRC license) continued to perform NRC-licensed activities even though on April 1, 2009, a change in his licensed condition existed in that the SRO failed to have the required biennial medical examination by a physician, and PPL did not obtain prior NRC approval for the SRO to continue to perform NRC-licensed activities without meeting the biennial examination requirement of his license.
.........................................................................................................


=REPORT DETAILS=
This is a Severity Level IV violation (Supplement VII).
.....................................................................................................................1. REA,CTOR SAFETy ...........................................................................................................1R04 Equipment Alignment ..............................................................................................1R05 Fire Protection .........................................................................................................1R06 Flood Protection Measures ......................................................................................1R07 Heat Sink Performance ...........................................................................................1R11 Licensed Operator Requalification Program .......................................................... 1R12 Maintenance Effectiveness .................................................................................... 1R13 Maintenance Risk Assessments and Emergent Work Control ............................... 1R 15 Operability Evaluations .......................................................................................... 1R 18 Plant Modifications ................................................................................................ 1R19 Post-Maintenance Testing .....................................................................................1R22 Surveillance Testing ..............................................................................................1EP6 Drill Evaluation


==RADIATION SAFETY==
The NRC has concluded that information regarding the reason for the violations, the corrective actions taken and planned to correct the violations and prevent recurrence and the date when full compliance was achieved is already adequately addressed on the docket in Inspection Report Nos. 05000387/2009004 and 05000388/2009004, in the PPL letter received December 10, 2009, and in the NRC letter transmitting this Notice of Violation (Notice). However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a "Reply to a Notice of Violation; EA-09-248" and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident Inspector at Susquehanna Steam Electric Station, within 30 days of the date of the letter transmitting this Notice.
.......................................................................................................20S1 Access Control to Radiologically Significant Areas ................................................ 20S2 ALARA Planning and Controls ...............................................................................20S3 Radiation Monitoring Instrumentation .................................................................... 4. OTHER ACTiViTIES .........................................................................................................40A1 Performance Indicator Verification .........................................................................40A2 Identification and Resolution of Problems .............................................................. 40A5 Other Activities ......................................................................................................40A6 Meetings, Including Exit. ........................................................................................40A7 Licensee-Identified Violations ................................................................................ ATTACHMENT:


=SUPPLEMENTAL INFORMATION=
If you choose to respond, your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS),
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.


==KEY POINTS OF CONTACT==
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days. Dated this 28 th day of January 2010.
..................................................................................................
==LIST OF ITEMS==
OPENED, CLOSED, AND DiSCUSSED .......................................................
==LIST OF DOCUMENTS REVIEWED==
......................................................................................
==LIST OF ACRONYMS==
: [[......]] [[.................................................................................................... Enclosure]]
: [[SUMMAR]] [[Y]]
: [[OF]] [[]]
: [[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 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]]
: [[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 1 R11.2) 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
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 1 R12) 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 (l]]
: [[WIIISI]] [[) of the reactor vessel that resulted in additional unplanned collective exposure contrary to low-as-is-reasonably-achievable (ALARA) controls. Specifically, the utilization of inexperienced workers to perform the various tasks involved in the]]
: [[IWI]] [[l]]
: [[ISI]] [[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 
.1
: [[REPORT]] [[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 hours 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 hours 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.]]
: [[REACTO]] [[R]]
: [[SAFETY]] [[Cornerstones: Initiating Events, Mitigating Systems, and 8arrier Integrity 1 Equipment Alignment 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 (]]
: [[EDG]] [[s) when "En]]
: [[EDG]] [[substituted for "8"]]
EDG. b. Findings No findings of significance were identified. Enclosure 
.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. 1 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', 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
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 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 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
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 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 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) 1 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]]
: [[VA]] [[006,]]
: [[VA]] [[007,]]
: [[VA]] [[011, and]]
: [[VA]] [[012. b. Findings No findings of significance were identified. 1 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 
'A' Emergency diesel generator heat 1) Intercooler heat 2) Jacket water cooler; 3) Lubricating oil 'E' Emergency diesel generator heat 1) Intercooler heat 2) Jacket water cooler; 3) Lubricating oil 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 
.1 1Licensed Operator Requalification Program (71111.11 Q -2 Sample) 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]]
: [[AV]] [[of 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 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
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 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
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
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 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
will not adversely affect operator duties or performance. (AV 05000387; 02, Violation of
: [[10CFR]] [[55.3, Senior Reactor Operators Performing Licensed Duties While Not Qualified Due to Medical Examination Issues) 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]]
: [[SSC]] [[s 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; Multiple failures of]]
: [[EDG]] [[air start system relief valves which caused "A"]]
: [[EDG]] [[unavailability; and Station blackout (]]
: [[SBO]] [[) diesel generator (DG) unavailability due to radiator coolant leakage. b. Findings Introduction: 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, 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]]
: [[HPC]] [[r was declared inoperable and the]]
: [[FV]] [[15612 valve was disassembled and repaired. The failure of]]
: [[FV]] [[-15612 Significantly impacts]]
: [[HC]] [[pr operation because the]]
: [[HPCI]] [[ramp generator resets to idle when the lower limit switch opens (at the full closed indication on Enclosure]]
: [[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]]
: [[FV]] [[15612 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
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). 1 R 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
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, Yellow Risk during corrective maintenance on]]
: [[SBO]] [[]]
: [[DG]] [[concurrent with 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 hour 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; Replace recirculation/standby gas treatment system (]]
: [[SGTS]] [[) damper actuator; dual unit 4 hour shutdown]]
: [[LCO]] [[; Emergent wiring repairs on]]
: [[ESS]] [[transformer]]
: [[OX]] [[203 in 72 hour]]
: [[LCO]] [[; and T20 startup transformer (T20) high voltage bushing replacement and Bus 20 clean and inspect. b. Findings No findings of significance were identified. 1 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]]
: [[TS]] [[s. 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]]
: [[TS]] [[s, 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 1 B]]
RHRSW pump 1ST; Unit 2, '0' main steam line radiation monitor on multiple alarms and work orders; Enclosure 
.1 Unit 2,
: [[HPCI]] [[operators disabled auxiliary oil pump during surveillance restoration steps on May 16, 2009; Common cause analysis after "C"]]
: [[EDG]] [[trip on overspeed; <IE"]]
: [[EDG]] [[with failed turbocharger overspeed speed trip circuit,]]
: [[OFR]] [[1166085; and "0"]]
: [[EDG]] [[,]]
: [[ESW]] [[piping clamp support on floor,]]
: [[CR]] [[1181216. b. Findings No findings of significance were identified 1 Plant Modifications (71111.18 -2 Samples) 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]] [[,]]
: [[TS]] [[s, 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 1 K206B. b. Fr:ndings No findings of significance were identified . . 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
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. 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,]]
: [[HPCI]] [[]]
: [[PMT]] [[after stop valve repair; Unit 1, single control rod scram during scram switch functional check; Unit 1, core spray valve exercising,]]
: [[HV]] [[152F0005A 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. 1 Surveillance Testing (71111.22 -4 Routine Surveillance and 1 1]]
ST 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
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, 1]]
: [[ST]] [[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. 1 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.]]
: [[RADIAT]] [[ION]]
: [[SAFETY]] [[Cornerstone: Occupational Radiation Safety (]]
: [[OS]] [[) 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
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-vesse]]
: [[IISIII]] [[VVI 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 10 CFR 20.1101. Documents reviewed are listed in the Attachment. Enclosure
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]]
: [[IWIIIS]] [[I 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 hours for inspection; 207 hours for camera placement and repair; and, 1000 hours for pressure washing/surface preparation. These examples of additional 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 hours. Actual hours to perform these tasks with the inexperienced workers were over 5000 hours. 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
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 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 
.1
: [[OTHER]] [[]]
: [[ACTIVI]] [[TIES Performance Indicator Verification (71151 -8 Samples) Injtiating Events 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]]
: [[PI]] [[s were included in this review: Units 1 and 2 unplanned scrams per 7000 critical hours (]]
: [[IE]] [[01); 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) No findings of significance were Identification and Resolution of Problems (71152 -1 Sample) Review of Items Entered into the Corrective Action Program 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. No findings of significance were identified . Annual Sample: Review of]]
: [[PPL]] [['s Progress in Implementing Corrective Actions to Address General Work Environment and Potential Chilling Effect Concerns 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
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]] [[(]]
: [[ML]] [[090280115). 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 (]]
: [[ML]] [[092230158). 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 generated]]
: [[CR]] [[s), 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 e]]
: [[NO]] [[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
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 
.1 40A5 Other Activities 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
: [[TS]] [[s 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 
.3 illustrate a weakness in
: [[PPL]] [['s Corrective Action Program because it did not identify a non compliance with a regulatory requirement. 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
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).]]
: [[AITACH]] [[MENT:]]
: [[SUPPLE]] [[]]
: [[MENTAL]] [[]]
: [[INFORM]] [[]]
: [[ATION]] [[Enclosure]]
: [[SUPPLE]] [[]]
: [[MENTAL]] [[]]
: [[INFORM]] [[]]
: [[ATION]] [[]]
: [[KEY]] [[]]
: [[POINTS]] [[]]
: [[OF]] [[]]
: [[CONTAC]] [[T 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]] [[]]
: [[DISCUS]] [[SED Opened 05000387; 388/200900402 Violation of]]
: [[10CFR]] [[55.3, Senior Reactor Operators Performing Licensed Duties While Not Qualified Due to Medical Examination Issues (1 R11.2) Opened/Closed 05000388/200900401 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 Inadequate Corrective Actions Result in a Repeat Failure of Unit 1]]
: [[HPCI]] [[Turbine Stop Valve (1R12) 05000388/200900404 Failure to Maintain Occupational Radiation Exposure As Low As Reasonably Achievable during the Unit 2 Refueling Outage (20S2) Attachment]]
: [[BASELI]] [[]]
: [[NE]] [[]]
: [[INSPEC]] [[]]
: [[TION]] [[]]
: [[PROCED]] [[]]
: [[URE]] [[]]
: [[PERFOR]] [[]]
: [[MED]] [[]]
: [[LIST]] [[]]
: [[OF]] [[]]
: [[DOCUME]] [[]]
: [[NTS]] [[]]
: [[REVIEW]] [[]]
: [[ED]] [[(Not Referenced in the Report) Section 1 R04: Equipment Alignment Condition 1168300, 1175048, 1176331,]]
: [[OP]] [[-225-001, Containment Instrument Gas System. Revision]]
: [[CL]] [[-225-0012, Unit 2 Containment Instrument Gas Mechanical, Revision M-2126, Unit 2 Containment Instrument Gas Sheets 1 and 2, Revision 33 and 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
Section 1 R06: Flood Protection Measures Condition Reports: 1121942,1171337,1172365,and606589 Work Order: 606837 Section 1 R07: 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
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 Generic Letter 89-13 and Supplement 1, Service Water System Problems 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) 1 D-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
Evaluation of lube oil cooler fouling factor increases in winter, October 1, Commitment Change Evaluation
: [[ECR]] [[]]
: [[LG]] [[96-02349, Undersized Lube Oil]]
: [[ECR]] [[]]
: [[LG]] [[01-01096,]]
: [[GL]] [[98-13 Program Recommendation Heat Exchanger]]
: [[ECR]] [[]]
: [[LG]] [[01-00968, Final Report on]]
: [[DG]] [[Heat Exchanger Performance Tests]]
: [[GL]] [[]]
: [[ECR]] [[]]
: [[LG]] [[04-00433, Licensing Basis of]]
: [[RHRSW]] [[Summary of]]
: [[RHRSW]] [[/]]
: [[ESW]] [[Valve Pit Other: Station Health Reports for]]
: [[RHR]] [[and]]
: [[EDG]] [[Systems: 2009, 1st period -Jan 1 -May 2008, 151 period -Jan 1 -Apr. 2nd period -May 1-Aug. 3rd period -Sept 1 -Dec. 2007, 1sl period -Jan 1 -Apr 2ndperiod -May 1 Aug 3rd period Sept 1-Dec Eddy Current Testing Final Reports 1E205B** 1B]]
: [[RHR]] [[Hx, 2E205A -1A]]
: [[RHR]] [[Hx,]]
: [[OE]] [[505 -Ai, A2, E1, E2,]]
: [[OE]] [[505,]]
: [[OE]] [[506 A, E,]]
: [[OE]] [[526 E,]]
: [[OE]] [[507 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]]
: [[ON]] [[-100-101,]]
: [[SCRAM]] [[,]]
: [[SCRAM]] [[Imminent, Revision]]
: [[EO]] [[-000-113, Level/Power Control, Revision]]
: [[EO]] [[-000-102,]]
: [[RPV]] [[Control, Revision]]
: [[NDAP]] [[-]]
: [[QA]] [[-0725, Operating Experience Review Program, Revision Other:]]
: [[OP]] [[002-09-06-01, 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 1162039,1172088,1171760,1171814, 1171764,and]]
: [[MT]] [[-GE-030,]]
: [[ITT]] [[Damper Hydramotor Model]]
: [[NH]] [[91]]
: [[NH]] [[93 Overhaul, Revision]]
: [[OI]] [[-AD-029, Emergency Load Control, Revision]]
: [[MT]] [[-]]
: [[GE]] [[-030,]]
: [[ITT]] [[Damper Hydramotor Model]]
: [[NH]] [[91 and]]
: [[NH]] [[93 Overhaul, Revision E-102, Sheet 17,]]
: [[ESS]] [[Transformer 101R201 Isolating Relay Control, Revision 13 E-102, Sheet 17 Circuit Breaker]]
: [[DA]] [[10406 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]]
: [[EX]] [[201 and]]
: [[OX]] [[203, 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]]
: [[2009 RFM]] [[Daily Status Report August 3-4,2009 -Cask 53 Section 1 R15: Operability Evaluations Condition Reports: 1159448,1159214,1159461,478425,794697,478350, 1160418, 1160653, 1112465, 1147886,1145418,1152053,1152076,1161825, 1162050, 1172110, and]]
: [[FSAR]] [[]]
: [[TRO]] [[J-412, Sheet 6,]]
: [[RHR]] [[]]
: [[SW]] [[Pump Discharge Pressure, Revision M-134, Sheet 3, A -D Diesel Auxiliaries Starting Air System, Revision Work Engineering Work]]
: [[EWR]] [[10M 183-2,]]
: [[KSV]] [[Diesel Generator Instruction Manual, Revision Section 1 R18: Permanent Plant Modifications Condition 1179204,1179788,1179777,1178870,1136097, 1136107, 1136188,]]
: [[FSAR]] [[9.4.2.2,9.2.12.3, Table]]
: [[TRO]] [[3.8.6 and]]
LA-1K206B-001, 1K206B Reactor Building Chiller B Safety Indicator Panel, Revision M310-245, Sheet 2, Chiller 1K206B, Revision Work Attachment
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 (]]
: [[OA]] [[104)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 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]]
: [[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]]
: [[SE]] [[-150-004,]]
: [[RCIC]] [[Functional Test at 1C2014, January 21,2008, Revision]]
: [[SE]] [[-100-008,]]
: [[RCIC]] [[Functional test at Remote Shutdown Panel, Revision]]
: [[SE]] [[-200-008,]]
: [[RCIC]] [[Functional test at Remote Shutdown Panel, January 21, 2009, Revision]]
: [[SE]] [[-100-011,]]
: [[HV]] [[143F023B, Functional Test at 1C2014, March 5, 2008, Revision 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 1]]
: [[EP]] [[6 Drill Evaluation Condition]]
: [[EP]] [[-]]
: [[TP]] [[-001,]]
: [[EAL]] [[Classification Levels, Revision August 25,2009 Drill Results Section 20S1: Access Control to Radiologically Significant Areas Condition 1168353; 1167515; 1167427; 1162310; and Section 20S2:]]
ALARA Planning and Controls Condition 1155780; 1153396; and Section 20S3: Radiation Monitoring Instrumentation Attachment
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]]
: [[NDAP]] [[-]]
: [[QA]] [[-0737, Reactor Oversight Process Performance Indicators, Revision Operator Logs, Unit 1 and Unit 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]]
: [[SS]] [[]]
ES Concerns Hotline flyer Attachment
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,]]
: [[SSES]] [[Work Environment Performance Indicators for July 2009 and August Proposed Draft General Work Environment Performance Indicator data September 23,]]
: [[PPL]] [[Performance Planning and Review Process-Personnel Goals and Observation sheet dated April 21, Nuclear culture review survey provided to Operations Department on 8/19/09 and 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
Other:
: [[2008 PPL]] [[]]
: [[SSES]] [[]]
: [[LLC]] [[Dry Fuel Storage Project Completion Review Self 2009 Dry Fuel Storage Readiness Annual Synthetic Round Sling Inspection 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]] [[Final safety Analysis Report (]]
: [[FSAR]] [[), November 9, Decay Heat Calculation,]]
: [[EC]] [[-Fuel-1185, Revision]]
: [[FACCTA]] [[S for]]
: [[DSC]] [[#53, July 31,2009, Revision]]
: [[ISFSI]] [[Temperature Monitoring System Software Requirement Specification, July 2, Revision Annual Preventative Maintenance Plan for Unit 1 Reactor Building Crane,]]
: [[WO]] [[completed December 5,]]
: [[SSES]] [[Area Survey Map,]]
: [[ISFSI]] [[Facility, dated: January 28, 2008; April 22, 2008; 25, 2008; October 24, 2008; January 22, 2009; April 25, 2009; May 1,]]
: [[LIST]] [[]]
: [[OF]] [[]]
: [[ACRONY]] [[MS]]
: [[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 l]]
: [[SI]] [[Inservice Inspection]]
: [[IWIIIS]] [[I In Vessel Visual I nspectionll 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]]
: [[PMT]] [[]]
: [[PPL]] [[]]
: [[QA]] [[]]
: [[RCA]] [[]]
: [[RCIC]] [[]]
: [[RHR]] [[]]
: [[RHR]] [[]]
: [[SW]] [[]]
: [[RTP]] [[]]
: [[SBO]] [[]]
: [[SCWE]] [[]]
: [[SOP]] [[]]
: [[SG]] [[]]
: [[TS]] [[]]
: [[SRO]] [[]]
: [[SSC]] [[]]
: [[SSES]] [[]]
: [[TS]] [[T20 Post-Maintenance Test]]
: [[PPL]] [[Susquehanna,]]
: [[LLC]] [[Quality Assurance Root Cause Analysis Reactor Core Isolation Cooling Residual Heat Removal Residual Heat Removal Service Water Rated Thermal Power Station Blackout Safety Conscious Work Environment Significance Determination Process Standby Gas Treatment System Senior Reactor Operator Structures, Systems and Components Susquehanna Steam Electric Station Technical Specifications T20 Startup Transformer Attachment]]
}}
}}

Revision as of 06:05, 24 August 2018

EA-09-248, Susquehanna, Notice of Violation (NRC Inspection Report Nos. 05000387/2009004 and 05000388/2009004)
ML100280714
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 01/28/2010
From: Collins S J
Region 1 Administrator
To: Rausch T S
Susquehanna
McLaughlin M
References
EA-09-248, IR-09-004 EA-09-248
Download: ML100280714 (8)
v • d • e


Text

January 28, 2010

EA-09-248 Mr. Timothy Senior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Boulevard, NUCSB3 Berwick, PA 18603

SUBJECT: SUSQUEHANNA STEAM ELECTRIC STATION - NOTICE OF VIOLATION NRC Inspection Report Nos. 05000387/2009004 and 05000388/2009004

Dear Mr. Rausch:

This refers to the inspection completed on September 30, 2009, at Susquehanna Steam Electric Station Units 1 and 2 (Susquehanna). The purpose of the inspection was to examine 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. During the inspection, the NRC reviewed two instances of a failure by PPL Susquehanna, LLC (PPL) to obtain NRC approval for two senior reactor operators (SROs) to continue to conduct NRC-licensed activities after each SRO did not meet a specific medical prerequisite for performing the duties of a licensed operator, as required by 10 CFR 55.3. These failures, which were identified by your staff, were discussed during an exit meeting that Mr. Paul Krohn and the Susquehanna resident inspectors held with your staff on October 9, 2009. The apparent violation was described in detail in the subject NRC inspection report dated November 13, 2009 (Inspection Report Nos. 05000387/2009004, 05000388-2009004; ADAMS Accession Number ML093170375).

With respect to the first instance, during August 2009, a medical examination for an SRO identified a disqualifying condition, namely, that the SRO's vision did not meet the health requirements stated in ANSI/ANS 3.4-1983, Section 5.4.5, "Eyes." Nonetheless, the SRO continued to perform licensed watchstanding duties on three different occasions following the examination, without the NRC first being informed to ensure that the individual's license was conditioned to require corrective lenses. With respect to the second instance, another SRO had not received the required biennial medical examination, which was due by April 1, 2009, until July 22, 2009. During that time, the SRO performed licensed operator duties 52 times.

The NRC recognizes that PPL discovered both of these instances, and upon discovery of the issues, notified the NRC and removed both individuals from watchstanding duties pending follow-up medical evaluations. PPL requested a conditional NRC license for the first SRO, and administered the biennial examination to the second SRO, which he passed. Both issues were also entered into PPL's corrective action program.

On November 9, 2009, Mr. David Lew and Mr. Krohn of my staff spoke with Mr. Jeff Helsel, Plant Manager, and other members of your staff, and provided them the opportunity to address the apparent violation by either attending a predecisional enforcement conference or by providing a written response before we made our final enforcement decision. On November 10, , Mr. Michael Crowthers, Manager, Nuclear Regulatory Affairs, responded that PPL planned to submit a written response. The NRC received the PPL response on December 10, 2009 (ML100150702).

In its response, PPL acknowledged that both SROs did not fully meet the prerequisite medical requirements in each case. PPL also noted that it promptly identified the conditions, developed root causes, and corrected the conditions with no consequence to safe operation of the plant. PPL contended that the safety significance of both instances was very low and represented Severity Level (SL) IV violations that should be dispositioned as non-cited violations. PPL indicated that: 1) neither SRO was ever the only SRO credited to meet minimum Technical Specification staffing requirements; and, 2) there were no actual consequences during the times that the SROs were on-shift without having met the appropriate licensing requirements. PPL also stated that the situations did not impact the NRC's initial licensing decisions in the time period prior to these incidents, in that both NRC Forms (Form 396) on-record were complete and accurate as of the time of the last successfully completed medical examinations, and, in the case of the second example, the SRO subsequently passed the 2009 biennial examination.

The NRC evaluated the information developed during the inspection, as well as the information PPL provided in its response, and has concluded that each instance constituted a violation of NRC requirements, one of which has been classified at SL III and the other of which has been classified at SL IV. The violations are cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding them are described in detail in the subject inspection report.

In determining the significance of the violations, the NRC recognizes that although both SROs did not meet their medical prerequisites, they were never in a solo-status and no operational errors were identified while on shift. In addition, in the second instance, the SRO for whom the medical physical was not completed in a timely manner was later found to meet all medical fitness requirements when the physical was subsequently completed. This violation has been categorized at SL IV because the failure to receive the physical in a timely manner did not invalidate the licensing basis for this individual since the SRO was subsequently determined to be medically fit. However, the first instance, involving the SRO for whom vision problems were identified, did impact the licensing basis for that individual because the SRO was required to have his license conditioned to wear corrective lenses while performing licensed activities. This violation has been categorized in accordance with the NRC Enforcement Policy at SL III.

In accordance with the NRC Enforcement Policy, a base civil penalty in the amount of $70,000 is considered for a SL III violation. Because your facility has been the subject of escalated enforcement actions within the last 2 years 1, the NRC considered whether credit was warranted for Identification and Corrective Action in accordance with the civil penalty assessment process in Section VI.C.2 of the Enforcement Policy. The NRC has concluded that credit for Identification is warranted because PPL discovered the issue through internal reviews and informed the NRC in a timely manner upon discovery. Additionally, the NRC has concluded that credit for Corrective Action is warranted because PPL's actions in response to the issue were prompt and comprehensive. The immediate actions included: (1) disqualifying the SRO with the vision issue from the licensed position and removing him from standing watch until receipt of a revised NRC license which added a condition that corrective lenses be worn; and, (2) immediately revoking the second SRO's qualifications until administering the physical examination to him on July 24, 2009. In addition, specific actions were taken and/or are 1 A "Greater-than Green" finding with a related Notice of Violation was issued on August 11, 2009 (EA-09-108) for a security-related issue. planned by PPL to prevent recurrence, including: (1) developing and implementing use of a form, to be completed at the conclusion of the visual and audiometric testing for any employee receiving a Licensed Operator Medical Examination, which states that any negative response be immediately reported to the PPL senior staff specialist of Health Services; (2) issuing two operations bulletins, to inform operators of the new form that will be used by the attending physician to provide immediate feedback on test results for eye and hearing testing, and to reinforce the ANSI standards regarding the passing criteria for eye and hearing tests; (3) checking the site database to ensure that all biennial examination expiration dates were correct; (4) ensuring that no manual overrides are permitted in the site database system without two levels of approval; (5) establishing a performance indicator to track medical certification expirations; and, (6) conducting an effectiveness review of all medical transactions six months after the last corrective action is complete to verify that no processing errors have occurred.

Therefore, to encourage prompt and comprehensive correction of violations, I have been authorized, after consultation with the Director, Office of Enforcement, not to propose a civil penalty in this case. However, significant violations in the future could result in a civil penalty.

The NRC has also concluded that information regarding the reason for the violations, the corrective actions taken and planned to correct the violations and prevent recurrence and the date when full compliance was, or will be, achieved is already adequately addressed on the docket in Inspection Report Nos. 05000387/2009004, 05000388/2009004, in the PPL letter received December 10, 2009, and in this NRC letter. Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.

In addition, in its December 10, 2009, response, PPL disputed the statement in the NRC inspection report that the finding related to these violations 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 [Inspection Manual Chapter 0305, Appendix A, "Components within the Cross-Cutting Areas," Item P.2(a). The NRC inspection report noted that PPL failed to evaluate NRC Information Notice (IN) 2004-20, "Recent Issues Associated with NRC Medical Requirements for Licensed Operators," in accordance with their operating experience review program, as evidenced by a 2008 SL IV non-cited violation (NRC Inspection Report Nos. 05000387/2008302, 05000388-2008302; ML081340746) for an initial licensed operator application submitted to the NRC with a disqualifying medical condition (and the two events described in the NRC inspection report and this letter). In support of its position, PPL stated that upon receipt of the IN, PPL had evaluated its operator medical information and found that no corrective actions were required. PPL further stated that none of the examples cited in the IN would have led to actions that, five years later, would have precluded the issues associated with the two events described in the NRC inspection report and in this letter. In addition, PPL stated that with respect to the first instance, involving the SRO who failed his vision examination, the Form 396 was submitted within the required 30 days; and that with respect to the second instance, involving the SRO who missed his biennial examination, no Form 396 was required; therefore, the IN examples were not comparable to these violations.

The NRC considered the position presented by PPL and the fact that these instances represent separate violations. Regarding the first instance, the NRC concluded that the cross-cutting aspect as described in NRC Inspection Report Nos 05000387/2009004 and 05000388/2009004 is correct, as stated. IN 2004-20 states, in part, "licensed operators should understand that they are responsible for meeting all the conditions of their license and for promptly informing their employer if they develop any medical condition, such as needing to wear glasses - that could affect their fitness to safely operate the facility." The IN also states that the, "NRC depends on facility licensees to ensure that the personnel who perform and evaluate licensed operator medical examinations understand the regulatory requirements, the applicable medical standards, . . ., thereby ensuring that the examinations are performed correctly and any medical defects are accommodated." As of August 2009, this operating experience had not been properly incorporated at Susquehanna. Specifically, regarding the SRO with vision problems, PPL did not have a requirement to ensure the examining physician, a PPL contractor, immediately informed PPL after the exam, that the SRO needed corrective lenses. As a result, PPL did not administratively limit the SRO's licensed operator duties until the NRC had been informed and a license condition was processed to require corrective lenses. Consequently, the SRO stood watch three times after the exam without a license condition to require corrective lenses. Regarding the second instance, the NRC agreed with PPL's position that actions to prevent the IN examples would not have precluded the missed biennial medical evaluation. Therefore, no cross-cutting aspect will be assigned to the violation involving the SRO who missed the biennial medical examination.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response, if you choose to provide one, should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such information, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). The NRC also includes significant enforcement actions on its Web site at www.nrc.gov; select What We Do , Enforcement, then Significant Enforcement Actions.

Sincerely,/RA/

Samuel J. Collins Regional Administrator Docket No. 50-387; 50-388 License No. NPF-14; NPF-22

Enclosure:

Notice of Violation cc w/encl: Distribution via ListServ

ML100280714

" C" = Copy without attachment/enclosure " E" = Copy with attachment/enclosure " N" = No Copy OFFICE RI/ORA RI/DRP RI/DRS RI/DRP RI/DRS NAME ADeFrancisco via emai PKrohn* SHansell* DLew*

P Wilson for DRoberts*

DATE 12/18/09 12/23/09 12/24/09 12/30/09 12/31/09 OFFICE RI/ORA RI/ORA OE NRR RI/ORA NAME KFarrar* DHolody* GGulla via email JMcHale via email SCollins DATE 1/08/10 1/25/10 1/21/10 1/21/10

  • See concurrence on previous page Distribution w/encl:

(via e-mail)

ADAMS (PARS)

SECY CA OEMAIL OEWEB W Borchardt, EDO B Mallett, DEDR L Trocine, OEDO R Zimmerman, OE B Sosa, OE N Hilton, OE L Lopez,OE N Hasan, OE M Crutchley, OE G Gulla, OE E Leeds, NRR Enforcement Coordinators RII, RIII, RIV C Scott, OGC E Hayden, OPA H Bell, OIG C McCrary, OI S Titherington-Buda, OCFO M Williams, OCFO D Screnci/N Sheehan, RI K Farrar, RI D Holody, RI A DeFrancisco, RI/M McLaughlin, RI C O'Daniell, RI Region I OE Files (with concurrences) RI ORA Mail Resource RI DRP Mail Resource S Collins, RA M Dapas, DRA D Roberts, DRS P Wilson, DRS S Hansell, DRS J Clifford, DRP D Lew, DRP P Krohn, DRP A Rosebrook, DRP/R Fuhrmeister, DRP P Finney, DRP, SRI S Ferrel, DRP, OA RidsNrrODMail Resource RidsNrrPMSusquehanna Resource RidsNrrDorpl1-2 Resource H Chernoff, NRR R Nelson, NRR D Egan, NRR, PM ROPreports@nrc.gov Region I Docket Room (with concurrences)

NOTICE OF VIOLATION PPL Susquehanna, LLC (PPL) Docket No. 50-387; 50-388 Susquehanna Steam Electric Station License No. NPF-14; NPF-22 EA-09-248

During an NRC inspection, conducted during the third quarter of 2009, for which an exit meeting was held on October 9, 2009, violations of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violations are listed below:

10 CFR 55.21 requires, in part, that a reactor or senior reactor operator 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, 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 55.3 requires, in part, 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.

10 CFR 55.23 requires, in part, that a facility licensee shall certify the medical fitness of an applicant by completing and signing a Form 396, "Certification of Medical Examination by Facility Licensee. On its Form 396s, licensees must certify, in part, what guidance was used to determine the medical fitness of its applicants. PPL certified that it used the guidance in ANSI/ANS 3.4-1983, "Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants."

ANSI/ANS 3.4-1983 states, in part, that the primary responsibility for assuring that qualified personnel are on duty rests with the facility licensee. In addition, the health requirements set forth within the standard provide the minimum necessary to determine that the physical condition and general health of the operators are not such as might cause operational errors endangering public health and safety. The specific health requirements and disqualifying conditions are described in Section 5.3, "Disqualifying Conditions," and Section 5.4, "Specific Minimum Capacities Required for Medical Qualifications," of the ANSI standard.

1. Contrary to the above, in 2009, a PPL Senior Reactor Operator (SRO) did not meet a certain medical prerequisite for performing NRC-licensed operator activities, and the SRO continued to perform NRC-licensed activities without PPL first submitting a Form 396 to obtain NRC approval. Specifically, on three occasions between August 10, 2009, and August 18, 2009, the PPL SRO (although possessing an NRC license) performed SRO duties even though, on August 10, 2009, a change in his licensed condition existed as found by a medical examination. 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," and PPL did not obtain NRC approval for the change in licensed activities Notice of Violation 2 by requesting a conditional license indicating that corrective lenses be worn prior to performing licensed duties.

This is a Severity Level III violation (Supplement VII).

2. Contrary to the above, in 2009, a second PPL SRO did not meet a certain medical prerequisite for performing NRC-licensed operator activities, and the SRO continued to perform NRC-licensed activities without PPL first submitting a Form 396 to obtain NRC approval. Specifically, on 52 occasions between April 1, 2009, and July 22, 2009, the second PPL SRO (although possessing an NRC license) continued to perform NRC-licensed activities even though on April 1, 2009, a change in his licensed condition existed in that the SRO failed to have the required biennial medical examination by a physician, and PPL did not obtain prior NRC approval for the SRO to continue to perform NRC-licensed activities without meeting the biennial examination requirement of his license.

This is a Severity Level IV violation (Supplement VII).

The NRC has concluded that information regarding the reason for the violations, the corrective actions taken and planned to correct the violations and prevent recurrence and the date when full compliance was achieved is already adequately addressed on the docket in Inspection Report Nos. 05000387/2009004 and 05000388/2009004, in the PPL letter received December 10, 2009, and in the NRC letter transmitting this Notice of Violation (Notice). However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a "Reply to a Notice of Violation; EA-09-248" and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident Inspector at Susquehanna Steam Electric Station, within 30 days of the date of the letter transmitting this Notice.

If you choose to respond, your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS),

accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days. Dated this 28 th day of January 2010.

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