IR 05000387/2012002

IR 05000387-12-002, 05000388-12-002, on 01/01/2012 03/31/2012, Susquehanna Steam Electric Station, Units 1 and 2, Maintenance Effectiveness, Drill Evaluation, Problem Identification and Resolution

ML12123A026
Person / Time
Site:	Susquehanna
Issue date:	05/02/2012
From:	Paul Krohn Reactor Projects Region 1 Branch 4
To:	Rausch T Susquehanna
KROHN, PG
References
IR-12-002
Download: ML12123A026 (46)

Text

{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION May 2, 2012

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION - NRC INTEGRATED INSPECTION REPORT 05000387/2012002 AND 05000388/2012002

Dear Mr. Rausch:

On March 31, 2012 the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Susquehanna Steam Electric Station (SSES) Units 1 and 2. The enclosed integrated inspection report (IR) presents the inspection results, which were discussed on April 17, 2012, with you and other members of your staff.

This inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents three NRC-identified findings and one self-revealing finding of very low safety significance (Green). These findings were determined to involve violations of NRC requirements. Additionally, two licensee-identified violations, which were determined to be of very low safety significance, are listed in this report. However, because of their very low safety significance and because they are entered into your correction action program (CAP), the NRC is treating these findings as non-cited violations (NCVs) consistent with Section 2.3.2 of the NRCs 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 Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at the Susquehanna Steam Electric Station. In addition, if you disagree with the cross-cutting aspect of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at the SSES. In accordance with 10 CFR 2.390 of the NRCs "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 NRCs 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, /RA/ Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 50-387; 50-388 License Nos. NPF-14, NPF-22

Enclosures:

Inspection Report 05000387/2012002 and 05000388/2012002 w/Attachment: Supplemental Information

REGION I== Docket No: 50-387, 50-388 License No: NPF-14, NPF-22 Report No: 05000387/2012002 and 05000388/2012002 Licensee: PPL Susquehanna, LLC (PPL) Facility: Susquehanna Steam Electric Station, Units 1 and 2 Location: Berwick, Pennsylvania Dates: January 1, 2012 through March 31, 2012 Inspectors: P. Finney, Senior Resident Inspector J. Greives, Resident Inspector T. OHara, Reactor Inspector R. Rolph, Health Physicist A. Bolger, Reactor Engineer Approved By: Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000387/2012002, 05000388/2012002 01/01/2012 - 03/31/2012; Susquehanna Steam

Electric Station, Units 1 and 2; Maintenance Effectiveness, Drill Evaluation, Problem Identification and Resolution.

The report covered a 3-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified three NCVs and one self-revealing NCV of very low safety significance (Green). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC)0609, Significance Determination Process (SDP). The cross-cutting aspects for the findings were determined using IMC 0310, Components Within The Cross-Cutting Areas. Findings for which the SDP does not apply may be Green, or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process (ROP), Revision 4, dated December 2006.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green NCV of 10 CFR Part 50 Appendix B, Criterion V, Instructions, Procedures, and Drawings, regarding PPLs safety-related motor operated valve (MOV) program. Specifically, the program lacked a procedure, qualification, and prescribed acceptance criteria for actuator grease analysis and PPL improperly implemented maintenance instructions for lubricating valve stems. PPLs QA organization conducted a separate investigation and entered this issue in their CAP via CRs 1545581 and 1544737.

This finding was considered more than minor because it was similar to IMC 0612, Appendix E, examples 3.j and 3.k, in that significant programmatic deficiencies existed that could lead to worse errors if uncorrected. The lack of a procedure, repeatable acceptance criteria, qualification, and multiple cycles without stem lubrication could result in untimely actuator overhauls and ultimately MOV degraded performance. Further, the performance deficiency affected the equipment performance attribute of the Mitigating Systems cornerstone and its objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, inadequate MOV program implementation affects MOV reliability. The issue screened to Green via IMC 0609 Attachment 4 since it was not a design or qualification deficiency or loss of safety function and did not screen as potentially risk significant due to external events. The issue was determined to have a cross-cutting aspect in the area of Problem Identification and Resolution. In this case, PPL was aware of the lack of procedural guidance and qualification for MOV grease analysis as well as non-compliance with stem lubrication instructions but had not entered the concerns in its CAP. [P.1(a)] (Section 1R12)

Cornerstone: Emergency Preparedness

Green.

The inspectors identified a Green NCV of 10 CFR Part 50.54 q and 50.47(b)(4)because PPL did not have adequate instrumentation to assess and determine if an abnormal radiological effluent release was in progress such that the EAL classification process would declare an Alert accurately and in a timely manner. Specifically, the maximum range for the liquid radwaste discharge radiation monitor was inadequate to ensure the meter was onscale when the threshold value of 200 times the alarm setpoint established by the discharge permit was reached.

The finding was more than minor because it is associated with the Emergency Preparedness (EP) cornerstone attribute of Facilities and Equipment, and affected the cornerstone objective of ensuring that a licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the effective range for the liquid radwaste discharge monitor was insufficient to ensure a timely and accurate EAL classification could be made. Using IMC 0609, Appendix B, Section 5.4, the finding is of very low safety significance because the finding was determined to be an example of an ineffective EAL, such that an Alert would be declared in a degraded manner. This finding is related to the cross-cutting area of Pl&R - CAP because PPL did not thoroughly evaluate problems such that the resolutions address the causes and extent of conditions, to include properly classifying, prioritizing and evaluating for operability. Specifically, PPL failed to appropriately evaluate the extent of condition from similar NCVs issued in November 2008 and 2010 regarding inadequate instrumentation to support EAL declarations. [P.1(c)] (Section 1EP6)

Cornerstone: Radiation Safety

Green.

A self-revealing, Green NCV of Technical Specification (TS) 5.7.1 was identified when a worker did not comply with a radiological barrier and protective measures for high radiation area (HRA) entry. Specifically, the worker entered a HRA but was not on the proper radiation work permit (RWP) and had not been briefed for HRA entrance. Upon identification, PPL conducted a Susquehanna Error Prevention Team Assessment (SEPTA), entered this issue into their CAP as Condition Report (CR) 1546827, and issued both an Effluents department clock reset and a Radiological Safety Note to station personnel.

The finding was determined to be more than minor based on similarity to IMC 0612, Appendix E, Example 6.h, which describes an improper entry into an HRA. Specifically, the individual was not authorized entry into a HRA. It was also more than minor based on association with the human performance attribute of the Occupational Radiation Safety cornerstone and its objective to ensure the adequate protection of worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. The finding was evaluated in accordance with IMC 0609, Appendix C, where it was determined to be Green since PPLs three year average collective dose is less than 240 person-rem/unit. The inspectors determined that this issue had a cross-cutting aspect in Human Performance - Work Practices. Human error prevention techniques, such as pre-job briefings and self-checking are expected to be used commensurate with the risk of the assigned task, such that work activities are performed safely. Personnel also do not proceed in the face of uncertainty or unexpected circumstances. In this case, the worker did not adhere to the pre-job briefings associated with the assigned RWP that prohibited HRA entry and the workers health physics (HP) briefing that did the same. Further, the individual proceeded in the face of uncertainty by breaching the HRA boundary. [H.4(a)] (Section 4OA2.1)

Green.

The inspectors identified a Green NCV of TS 5.4.1.a, which requires that written procedures be implemented covering the activities in the applicable procedures recommended by Regulatory Guide (RG) 1.33, including procedures for RWPs. On December 5, 2011, a work crew identified that dose rates exceeded the Alert levels specified on their RWPs used to transfer an 1100 Curie Cesium 137 source from a shipping cask to a calibration irradiator. Procedure NDAP-QA-0626, Radiological Controlled Area (RCA) Access and RWP System, Appendix X, provides specific actions that the radiation protection technician providing job coverage must take when Alert levels are exceeded.

All of the actions were not completed prior to restarting the work on December 5, 2011.

Specifically, higher levels of supervision were not notified, the RWP was not changed, and no additional actions or precautions were documented in the RWP remarks log as required by NDAP-QA-0626, Appendix X. PPL subsequently entered the issue into their CAP as CR 1521467.

The finding is more than minor because it is associated with the Radiation Safety - Occupational Radiation Safety cornerstone attribute of program and process and affected the cornerstone objective of protecting worker health and safety from exposure to radiation.

Specifically, PPL did not take the appropriate actions defined in the procedure to evaluate actions to prevent recurrence prior to restarting work when RWP alert levels had been exceeded. Using the IMC 0609, Appendix C, Occupational Radiation Safety SDP, the inspector determined that the finding was of very low safety significance (Green) because it did not involve: (1) an as low as is reasonably achievable (ALARA) planning and controls deficiency, (2) an overexposure, (3) a substantial potential for overexposure, or (4) an impaired ability to assess dose. This finding was caused by inadequate procedure compliance. Consequently, the cause of this deficiency had a cross-cutting aspect in the area of Human Performance. Specifically, PPL did not follow procedures. [H.4(b)] (Section 4OA2)

Other Findings

Violations of very low safety significance or Severity Level IV, which were identified by PPL, were reviewed by the inspectors. Corrective actions taken or planned by PPL have been entered into PPLs CAP. These violations and corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at 100 percent power. Unit 1 was reduced to 68, 77, 75, and 70 percent power on January 13, February 17, March 2, and March 16 respectively for control rod pattern adjustments. On March 22, Unit 1 commenced a coastdown to a scheduled refueling outage. Unit 1 was shutdown on March 31.

Unit 2 began the inspection period at 100 percent power. Unit 2 was reduced to 73 percent power for a control rod pattern adjustment on January 28. Unit 2 was reduced to 84 percent power for two days for condenser waterbox cleaning on March 17. Unit 2 was reduced to 76 percent power on March 23 for a control rod sequence exchange. Unit 2 remained at or about 100 percent power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

==1R04 Equipment Alignment

.1 Partial System Walkdowns

a.

==

Inspection Scope The inspectors performed partial walkdowns of the following systems:

• Unit 1, Division II residual heat removal (RHR) during Division I RHR maintenance
• Units 1 and 2, residual heat removal service water (RHRSW)
• Common, B control structure (CS) chiller while A out-of-service (OOS)

The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), Technical Specifications (TSs), work orders (WOs), condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether PPL staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings

No findings were identified. ==1R05 Fire Protection