IR 05000387/2015004
| ML16040A197 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 02/09/2016 |
| From: | Daniel Schroeder Reactor Projects Region 1 Branch 4 |
| To: | Rausch T Susquehanna |
| schroeder, dl | |
| References | |
| IR 2015004 | |
| Download: ML16040A197 (49) | |
Text
{{#Wiki_filter:ary 9, 2016
SUBJECT:
SUSQUEHANNA STEAM ELECTRIC STATION - INTEGRATED INSPECTION REPORT 05000387/2015004 AND 05000388/2015004
Dear Mr. Rausch:
On December 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Susquehanna Steam Electric Station (SSES), Units 1 and 2. The enclosed report documents the inspection results, which were discussed on January 19, 2016 with you and other members of your staff.
NRC Inspectors 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 four NRC-identified or self-revealing findings of very low safety significance (Green). Three of these findings were determined to involve violations of NRC requirements. Additionally, a 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 2.3.2 of the NRC Enforcement Policy. If you contest any NCVs 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, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at SSES. In addition, if you disagree with the cross-cutting aspect assigned to 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 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 NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.htmL (the Public Electronic Reading Room).
Sincerely, /RA/ Daniel L. Schroeder, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 50-387 and 50-388 License Nos. NPF-14 and, NPF-22
Enclosure:
Inspection Report 05000387/2015004 and 05000388/2015004 w/Attachment: Supplementary Information
REGION I== Docket Nos.: 50-387, 50-388 License Nos.: NPF-14, NPF-22 Report No.: 05000387/2015004 and 05000388/2015004 Licensee: Susquehanna Nuclear, LLC (Susquehanna) Facility: Susquehanna Steam Electric Station, Units 1 and 2 Location: Berwick, Pennsylvania Dates: October 1, 2015 through December 31, 2015 Inspectors: J. Greives, Senior Resident Inspector T. Daun, Resident Inspector T. Fish, Senior Operations Engineer C. Graves, Health Physicist E. H. Gray, Senior Reactor Inspector J. DeBoer, Emergency Preparedness Inspector N. Embert, Operations Engineer P. Meier, Project Engineer S. Barr, Senior Emergency Preparedness Inspector Approved By: Daniel L. Schroeder, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY
IR 05000387/2015004, 05000388/2015004; October 1, 2015 to December 31, 2015;
Susquehanna Steam Electric Station, Units 1 and 2; Maintenance Effectiveness, Operability Determinations and Functionality Assessments, Drill Evaluation, and Follow-Up of Events and Notices of Enforcement Discretion.
This report covered a three-month period of inspection by resident inspectors and announced baseline inspections performed by regional inspectors. The inspectors identified three non-cited violations, all of which were of very low safety significance (Green and/or Severity Level IV).
The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual chapter (IMC) 0609, Significance Determination Process, dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within Cross-Cutting Areas, dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated February 4, 2015. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
Cornerstone: Initiating Events
- Green.
A self-revealing finding of very low safety significance (Green) was identified when Susquehanna did not correctly validate a deficient condition associated with the Unit 1 B inboard main steam isolation valve (MSIV) direct current (DC) solenoid valve as an actual valve issue, vice indication-only, through the use of specific acceptance criteria as required by MT-AD-509, Control of Minor Maintenance Activities. By incorrectly concluding the issue was indication only, testing was allowed to be performed which inserted a half-isolation by de-energizing the alternating current (AC) solenoid valve on the B inboard MSIV. When this maintenance was performed, the B inboard MSIV closed unexpectedly, resulting in a reactor scram. The cause of the closure was the failure of the DC solenoid valve on the B inboard MSIV. Susquehanna entered the issue into the CAP as CR-2015-30721 and replaced the DC solenoid for the B MSIV.
The finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during power operations. Specifically, the maintenance activity performed to validate the DC solenoid valve continuity was inadequate and as a result the testing was allowed to be performed which relied on DC solenoid valve continuity to prevent an MSIV closure. The inadvertent closure of the B inboard MSIV resulted in a high pressure scram. The inspectors evaluated the finding in accordance with IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 1, for the Initiating Events cornerstone. The inspectors determined the finding was of very low safety significance (Green) because it did not cause the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. Specifically, the condenser was maintained for decay heat removal via the bypass valves through the other three main steam lines following the trip. This finding had a cross-cutting aspect in the area of Human Performance, Challenge the Unknown, because Susquehanna did not stop when faced uncertain conditions and instead rationalized unanticipated test results. Specifically, the investigation of the extinguished continuity monitor focused on the possibility that it was an indication-only issue and failed to question the acceptability of the current values obtained during troubleshooting [H.11]. (Section 40A3)
Cornerstone: Barrier Integrity
- Green.
A self-revealing finding of very low safety significance (Green) and associated violations of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, and Technical Specification (TS)3.6.1.3, Primary Containment Isolation Valves (PCIVs), was identified when Susquehanna did not take adequate corrective action to address the inoperability of the reactor recirculation sample line outboard PCIV when it failed during surveillance testing on July 1, 2015. The valve failed its subsequent surveillance test on September 30, 2015 due to the same degraded condition, which rendered the valve inoperable for longer than the allowed outage time specified in TS 3.6.1.3. The repeat failure was entered into the CAP as CR-2015-26590 and restored the valve to an operable condition by replacing its associated solenoid valve.
The finding was determined to be more than minor because it was associated with the structure, system and component (SSC) and Barrier Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers (containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the failure to correct the degraded condition of solenoid valve sticking resulted in a PCIV being rendered inoperable for longer than the TS allowed outage time. Inspector evaluated the finding In accordance with IMC 0609.04, Initial Characterization of Findings, dated June 19, 2012, and Exhibit 2 of IMC 0609, Appendix A, The SDP for Findings At-Power, dated June 19, 2012, and determined it is of very low safety significance (Green) because the performance deficiency did not result in an actual open pathway in the physical integrity of reactor containment, because the inboard valve remained operable for the duration of the inoperability, and it did not involve the hydrogen recombiners.
This finding had a cross-cutting aspect in the area of Human Performance, Challenge the Unknown, because Susquehanna did not stop when faced with uncertain conditions and ensure the risks were evaluated and managed before proceeding. Specifically, Susquehanna did not challenge the unanticipated test results and did not ensure that the condition adverse to quality, associated with the faulty solenoid valve, was resolved prior to considering the valve operable [H.11]. (Section 1R12)
- Green.
An NRC-identified finding of very low safety significance (Green) and associated violations of TS 5.4.1, Procedures, TS 5.5.11, Safety Function Determination, and TS 3.7.3, Control Room Emergency Outside Air Supply System was identified when Susquehanna performed maintenance on redundant trains of the standby gas treatment (SBGT) system and control room emergency outside air supply system (CREOASS) concurrently. When performing these actions, operators did not apply NDAP-QA-0312, Control of LCOs, technical requirement for operations (TROs) and Safety Function Determination Program, correctly which resulted in the unrecognized loss of safety function of SBGT and CREOASS. Susquehanna entered the issue into the CAP as CR-2015-26475 and restored one of the subsystems to service, restoring the safety function.
This finding is more than minor because it is associated with the Human Performance (Routine OPS/Maintenance Performance) attribute of the Barrier Integrity cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers (Secondary Containment and Control Room Ventilation) protect the public from radionuclide releases caused by accidents or events. Specifically, allowing work to be performed on redundant trains of SBGT and CREOASS concurrently, while not applying plant TSs correctly, resulted in a loss of safety function of both systems. In accordance with IMC 0609.04, Initial
Characterization of Findings, and Exhibit 3 of IMC 0609, Appendix A, The SDP for Findings At-Power, both dated June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency was only associated with the radiological barrier function of the Control Room and Secondary Containment. This finding had a cross-cutting aspect in the area of Human Performance, Avoid Complacency because Susquehanna did not recognize and plan for the possibility of mistakes, latent problems, or inherent risk, even while expecting successful outcomes. Specifically, Susquehanna did not perform a thorough review of the planned activities every time work was performed to ensure compliance with plant TSs, rather than relying on past successes and assumed conditions [H12]. (Section 1R15)
Cornerstone: Emergency Preparedness
- Green.
The inspectors identified a finding of very low safety significance (Green) and a NCV of 10 CFR 50, Appendix E, Section IV.B.1. Specifically, Susquehanna emergency plan implementing procedures did not provide the guidance for the dose assessment staff in the Technical Support Center (TSC) to determine the magnitude of, and continually assess the impact of, the release of radioactive materials. The TSC staff was procedurally limited to performing forward and back dose calculations, but not blowout panel calculations. Blowout panel release calculations were only to be performed by the Emergency Operations Facility (EOF) staff. Susquehanna entered this issue into their corrective action program as CR-2015-04701, which led to the revision of the applicable procedures to allow the TSC dose assessment staff to perform the full scope of dose calculations available to the EOF staff.
The inspectors determined that the failure to have the same scope of dose assessment capabilities available to the full emergency response organization (ERO) was a performance deficiency that was within Susquehannas ability to foresee and correct. The performance deficiency is more than minor because it is associated with the ERO Readiness and ERO Performance attributes of the emergency preparedness cornerstone, and adversely 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.
Using IMC 0609, Appendix B, Section 5.9, the finding is of very low safety significance (Green)because the finding was determined to not be an example of the overall dose projection process being incapable of providing technically adequate estimates of radioactive material releases; the deficiency was limited to the TSC staff which in fact had the capability of performing dose projections and was only limited by the lack of procedural guidance. The cause of this finding has a cross-cutting aspect in the area of Documentation, because Susquehanna did not ensure that their organization creates and maintains complete, accurate and up-to-date documentation.
Specifically, Susquehanna did not provide emergency plan implementing procedures to enable the TSC dose assessment staff to perform dose projections for all required radioactive material releases [H.7]. (Section 1EP6)
Other Findings
A violation of very low safety significance that was identified by Susquehanna was reviewed by the inspectors. Corrective actions taken or planned by Susquehanna have been entered into Susquehannas CAP. This violation and corrective action tracking number are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Unit 1 began the inspection period at 100 percent power. On November 10, 2015, operators reduced reactor power to approximately 30 percent, removed the B reactor recirculation pump (RRP) from service and entered single loop operation. This planned activity was conducted so that the RRP motor-generator set tachometer, which was identified previously as being degraded, could be replaced. Following replacement of the tachometer, operators commenced power restoration. On November 12, 2015 power restoration had reached approximately 98 percent when a reactor scram occurred. The scram was caused by high reactor pressure when the B MSIV unexpectedly closed during testing. Following the completion of the maintenance activities, operators commenced a reactor startup on November 18, 2015. During startup, with power at approximately 85 percent, operators inserted a RRP runback to 62 percent due to rapidly lowering reactor feed pump suction pressure. Power was stabilized and the cause of the pressure transient was identified and corrected. Power was restored to 100 percent on November 22, 2015. On December 4, 2015, operators reduced power to approximately 75 percent to perform a rod pattern adjustment and power was restored to 100 percent on December 5, 2015. On December 11, 2015, operators reduced power to 62 percent to perform a planned rod sequence exchange and power was restored to 100 percent on December 13, 2015. On December 22 and 27, 2015, operators reduced power to 74 and 80 percent, respectively, to perform planned rod pattern adjustments and power was restored to 100 percent the same days. The unit remained at or near 100 percent power for the remainder of the inspection period.
Unit 2 began the inspection period at 100 percent power and operated at full power until October 28, 2015, when operators reduced reactor power to 62 percent at the request of the grid operator for stability concerns due to the loss of the Sunbury 230 kV line. Power was restored to 100 percent on October 30, 2015. On October 30, 2015, operators reduced power to approximately 84 percent to perform a rod pattern adjustment and power was restored to 100 percent on October 31, 2015. Unit 2 remained at or near 100 percent power for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
The inspectors performed a review of Susquehannas readiness for the onset of seasonal extreme low temperatures from October 31 - December 21, 2015. The review focused on the engineered safeguards service water pump house, exposed portions of the condensate and refueling water storage system, the circulating water pump house and the station portable diesel generator (Blue Max). The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), TS, control room logs, and the CAP to determine what temperatures or other seasonal weather could challenge these systems, and to ensure Susquehanna personnel had adequately prepared for these challenges.
The inspectors reviewed station procedures, including Susquehannas seasonal weather preparation procedure and applicable operating procedures. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during cold weather conditions.
Documents reviewed for each section of this inspection report are listed in the A.
b. Findings
No findings were identified. ==1R04 Equipment Alignment
.1 Partial System Walkdowns
==
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems: Unit 1, division II core spray (CS) during division I system outage window (SOW) on October 6, 2015 Unit 1, high-pressure coolant injection (HPCI) during reactor core isolation cooling (RCIC) SOW on October 26, 2015 Unit 1, RCIC and automatic depressurization system (ADS) during HPCI SOW on December 1, 2015 Unit 1, division I residual heat removal (RHR) during division II SOW on December 1, 2015 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 UFSAR, TSs, work orders, CRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted the systems performance of its 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 Susquehanna 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.
.2 Full System Walkdown
a. Inspection Scope
On October 15-16 and 21-23, the inspectors performed a complete system walkdown of accessible portions of the Unit 1 reactor protection system (RPS) and alternate rod insertion (ARI) system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hanger and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify as-built system configuration matched plant documentation, and that system components and support equipment remained operable. The inspectors confirmed that systems and components were aligned correctly, free from interference from temporary services or isolation boundaries, environmentally qualified, and protected from external threats. The inspectors also examined the material condition of the components for degradation and observed operating parameters of equipment to verify that there were no deficiencies.
Additionally, the inspectors reviewed a sample of related condition reports (CRs) and work orders to ensure Susquehanna appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified. ==1R05 Fire Protection