ML093170375
| ML093170375 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/13/2009 |
| From: | David Lew Division Reactor Projects I |
| To: | Rausch T Susquehanna |
| KROHN P, RI/DRP/PB4/610-337-5120 | |
| References | |
| EA-09-248 IR-09-004 | |
| Download: ML093170375 (47) | |
See also: IR 05000387/2009004
Text
UNITED NUCLEAR REGULATORY
REGION 475 ALLENDALE KING OF PRUSSIA, PA
November 13, 2009 EA-09-248
Mr. Timothy S. Rausch Senior Vice President
and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Boulevard, NUCSB3 Berwick, PA 18603
SUSQUEHANNA
STEAM ELECTRIC STATION -NRC INTEGRATED
INSPECTION
REPORT 05000387/2009004
AND 05000388/2009004
Dear Mr. Rausch: On SeptElmber
30, 2009, the U. S. Nuclear Regulatory
Commission (NRC) completed
an inspection
at your Susquehanna
Steam Electric Station Units 1 and 2. The enclosed integrated
inspection
report presents the inspection
results, which were discussed
with you and other members of your staff during a preliminary
exit meeting on October 9, 2009. This inspection
examined activities
completed
under your license as they relate to safety and compliance
with the Commission's
rules and regulations
and with the conditions
of your license. The inspectors
reviewed selected procedures
and records, observed activities, and interviewed
personnel.
Based on the results of this inspection, two examples of an apparent violation (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).
T. Rausch 2 Upon discovery, PPL removed both individuals
from watchstanding
duties pending follow-up
medical evaluations
and, in the August 2009 example involving
the SRO who failed his vision examination
resulting
in a disqualifying
condition, PPL requested
a conditional
NRC license to address the disqualifying
medical condition.
For the July 2009 example, the SRO passed his biennial medical examination
when administered.
Both issues have been entered into PPL's corrective
action program. See Section 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 the
T. Rausch 3 Susquehanna
Steam Electric Station. The information
you provide will be considered
in accordance
with Inspection
Manual Chapter 0305. In accordance
with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be available
electronically
for public inspection
in the !\IRC Public Document Room or from the Publicly Available
Records (PARS) component
of the NRC's document system (ADAMS). ADAMS is accessible
from the NRC Web site at http://www.nrc.qov/reading-rm/adams.html(the
Public Electronic
Reading Room). Sincerely, IRA! David C. Lew, Director Division of Reactor Projects Docket Nos. 50-387; 50-388 License Nos. NPF-14, NPF-22 Enclosures:
Inspection
Report 05000387/2009004
and 05000388/2009004
Attachment:
Supplemental
Information
cc w/encl: Distribution
via ListServ
T. 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
Attachment:
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 .........................................................................................................REPORT DETAILS .....................................................................................................................1. REA,CTOR SAFETy ...........................................................................................................1 R04 Equipment
Alignment
..............................................................................................1 R05 Fire Protection
.........................................................................................................1 R06 Flood Protection
Measures ......................................................................................1 R07 Heat Sink Performance
...........................................................................................1 R11 Licensed Operator Requalification
Program .......................................................... 1R12 Maintenance
Effectiveness
.................................................................................... 1 R 13 Maintenance
Risk Assessments
and Emergent Work Control ............................... 1 R 15 Operability
Evaluations
.......................................................................................... 1 R 18 Plant Modifications
................................................................................................ 1 R 19 Post-Maintenance
Testing .....................................................................................1 R22 Surveillance
Testing ..............................................................................................1 EP6 Drill Evaluation
......................................................................................................2. RADIATION
SAFETY .......................................................................................................20S 1 Access Control to Radiologically
Significant
Areas ................................................ 20S2 ALARA Planning and Controls ...............................................................................20S3 Radiation
Monitoring
Instrumentation
.................................................................... 4. OTHER ACTiViTIES
.........................................................................................................40A 1 Performance
Indicator
Verification
.........................................................................40A2 Identification
and Resolution
of Problems .............................................................. 40A5 Other Activities
......................................................................................................40A6 Meetings, Including
Exit. ........................................................................................40A7 Licensee-Identified
Violations
................................................................................ ATTACHMENT:
SUPPLEMENTAL
INFORMATION
................................................................ SUPPLE.MENTAL
INFORMATION
......................................................................................... KEY POINTS OF CONTACT .................................................................................................. LIST OF ITEMS OPENED, CLOSED, AND DiSCUSSED
....................................................... LIST OF DOCUMENTS
REVIEWED ...................................................................................... LIST OF ACRONYMS .......................................................................................................... Enclosure
SUMMARY 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
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
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 (lWIIISI)
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 IWIlISI activity resulted in the additional
collective
exposure to perform this routine task. This finding was entered into PPL's Correction
Action Program for resolution.
This finding is more than minor because it resulted in unplanned, unintended
collective
exposure that was greater than 50 percent above the intended collective
exposure and greater than 5 person-rem.
Additionally, the performance
deficiency
adversely
affected the radiation
protection
cornerstone
objective.
The inspectors
assessed the finding in accordance
with IMC 0609, Appendix C, "Occupational
Radiation
Safety Significance
Determination
Process," and determined
that the finding was of very low safety significance (Green) because the finding was due to ALARA work control planning and the 3-year rolling average collective
exposure at Susquehanna
was less than 240 person-rem
(107 person-rem
for 2005-2007).
This finding was determined
to have a cross-cutting
aspect in the area of Human Performance, Resources, because PPL did not utilize sufficiently
qualified
personnel
to assure occupational
radiation
safety requirements
were met H.2{b).
Specifically, PPL's use of inexperienced
contract workers resulted in additional
collective
exposure that could have been avoided. (Section 20S2) B. Licensee Identified
Violations
A violation
of very low safety significance.
which was identified
by PPL. has been reviewed by the inspectors.
Corrective
actions taken or planned by PPL have been entered into PPL's CAP. This violation
and corrective
action tracking numbers are listed in Section 40A7 of this report. Enclosure
.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 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> in support of a control rod sequence exchangEl
and pattern adjustment.
Unit 1 remained at 94.4 percent RTP for the remainder
of the inspection
period. SSES Unit 2 began the inspection
period at the authorized
licensed power level of 94.4 percent RTP. On September
12,2009, Unit 2 was reduced to 58 percent over 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> in support of a control rod sequence exchange and pattern adjustment.
Unit 2 remained at 94.4 percent RTP for the remainder
of the inspection
period. Note: The licensed RTP for both units is 3952 megawatts
thermal. The Extended Power Uprate (EPU) License Amendment
for SSES was approved in January 30,2008, and was implemented
for both units in accordance
with the issued license conditions.
For the current inspection
period, the authorized
power level for both units is 94.4 percent of the EPU licensed power limit. REACTOR 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 (EDGs) 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
VA006, VA007, VA011, and VA012. 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
10 '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
without scram, reactor pressure vessel power and level control, and event declaration.
b. Findings No findings of significance
were identified . . 2 Licensed Operator Medical Review (1 sample) a.. Inspection
Scope The inspectors
reviewed two instances
in July 2009 and August 2009 where PPL had identified
issues with the medical qualification
records for two separate Senior Reactor Operators.
The inspectors
reviewed the medical certification
forms, reviewed the PPL's formal correspondence
with the NRC upon discovery
of the issue to ensure timeliness
requirements
were met, PPL conditional
license request submittal
and reviewed PPL's corrective
actions. b. Findings Introduction:
The licensee identified
two examples of an AVof 10 CFR 55.3, Licensed Requirements, for two cases in which PPL licensed operators
failed to have valid medical examinations
consistent
with their position.
Specifically, one licensed operator performed
duties with an expired biennial medical examination
while another licensed operator performed
duties with a failed visual examination.
In both cases, operators
performed
the function of a senior reactor operator without meeting the medical
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
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
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 10CFR55.3, 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 SSCs and assessed PPL's extent of condition
determinations
for these issues with potential
common cause or generic implications
to evaluate the adequacy of PPL's corrective
actions. The inspectors
reviewed PPL's problem identification
and resolution
actions for these issues to evaluate whether PPL had appropriately
monitored.
evaluated.
and dispositioned
the issues in accordance
with PPL procedures
and the requirements
of 10 CFR 50.65, "Requirements
for Monitoring
the Effectiveness
of Maintenance." In addition, the inspectors
reviewed selected SSC classification, performance
criteria and goals, and PPL's corrective
actions that were taken or planned. to verify whether the actions were reasonable
and appropriate.
Documents
reviewed are listed in the Attachment.
The following
issues were reviewed: Unit 1, HPCI turbine stop valve failure and previous corrective
actions for inadequate
preventative
maintenance; 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 NCVof 10 CFR Part 50, Appendix B. Criterion
XVI. "Corrective
Action," in that, PPL did not implement
timely corrective
actions to preclude repetition
of a significant
condition
adverse to quality. Specifically, the actions taken to address the causes of the Unit 1 HPCI stop valve failure to close in 2006 did not prevent the same Unit 1 HPCI stop valve from failing to close on August 18, 2009. In both cases, the failure of the stop valve to close rendered this single train high pressure injection
system inoperable
as it was unable to meet the 30 second injection
response time as described
in the design basis. Discussion:
On August 18, 2009, the Unit 1 HPCI stop valve (FV-15612)
indicated
dual position after performance
of the weekly lubricating
oil functional
check. FV-15612 did not go full closed as expected and was verified to be approximately
one inch from full closed. Operations
cycled the valve with maintenance
personnel
present in the field and found that the valve did not operate smoothly when closing. Based on previous history with FV-15612, engineering
recommended
that the HPCI system be declared inoperable.
Unit 1 HPCr was declared inoperable
and the FV15612 valve was disassembled
and repaired.
The failure of FV-15612 Significantly
impacts HCpr operation
because the HPCI ramp generator
resets to idle when the lower limit switch opens (at the full closed indication
on Enclosure
FV-15612).
Thus, FV-15612's
closure is necessary
to prepare the governor to restart the turbine and if FV-15612 does not fully close, the generator
can not reset, and the governor would demand full open when the turbine restarts.
This condition
greatly increases
the probability
of an overspeed
trip upon turbine start. Historical
data from the original HPCI speed control design reveals that it would be expected to have at least 1 or 2 overspeed
trips before the HPCI governor would be able to control turbine speed. In this condition
the HPCI 30 second design basis response time would not be met. (Ref: TS 3.5.1.13).
Therefore, HPCI was not able to perform its safety function with design limits and was inoperable.
In addition, this degraded component
also challenges
the system protective
features {overspeed
trip function}
which reduces the reliability
of the system to function.
The safety system remained unavailable
for several days as extensive
effort was required to repair the component
for this type of degradation.
Inspectors
witnessed
some of the maintenance
work and observed that there were many physical similarities
to the conditions
found when this valve was disassembled
and repaired following
the failure to close in August of 2006. One documented
cause for the 2006 FV-15612 failure was an observed seal area that is periodically
wetted by HPCI operation
and a material which is susceptible
to general corrosion
and requires periodic replacement
to maintain proper operation.
In 2006, PPL took the action to replace the rod bushing. However, there were no actions to address the cause and reduce moisture exposure, change or evaluate materials
to reduce the susceptibility
to corrosion, and no actions to increase component
monitoring
for moisture or corrosion.
The second documented
apparent cause for the 2006 FV-15612 failure was inadequate
preventive
maintenance (PM). An administrative
error had caused this component
to go past the PM expiration
date. PPL performed
the inspections
as part of the 2006 repair and recalculated
a new due date for the PM task. PPL did not change the 10 year interval for maintenance
and inspection
and did not increase the PM frequency
for this component
to more appropriately
address this identified
apparent cause (inadequate
PM). The inspectors
determined
that the limited corrective
actions taken following
the apparent cause evaluation
in 2006 contained
in CR 806988 were a primary contributor
to the repeat failure of the FV-15612 in 2009. In both cases, valve FV15612 failed in the same manner and would not travel to the full closed position.
In both cases, the actuator stem to bushing interface
was very tight and required the use of pullers and/or hammers during actuator disassembly.
For both failures the most likely cause was due to increased
friction between the actuator shaft and the rod bushing as a result of corrosion.
The inspectors
also identified
that the corrective
action report CR 806988 did not have an effectiveness
review plan. The CR stated that given the long duration of the PM interval, it would be unreasonable
to hold an effectiveness
review open for several years. The inspectors
reviewed PPL's cause evaluation
for the August 2009 valve failure, as documented
in CR 1172997. This evaluation
described
how the leakage through the seat of the Unit 1 HPCI Steam Admission
Valve (HV-155F001)
was a contributing
cause to the 2009 component
failure. The HV-155F001
had chronic through seat leakage for the last decade. Inspectors
concluded
that this leakage and moisture source was also a contributing
factor from 2006, and that more aggressive
action to fix the seat leakage which contributed
to the corrosive
environment
would have reduced the probability
and/or frequency
of the experienced
component
failure. Enclosure
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
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
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
for scheduled
maintenance;
dual unit 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> shutdown limiting condition
for operation (LCO); Orange equipment
out-of-service
risk for both Unit 1 and Unit 2 during "A" EDG outage and emergent "E" EDG inoperability, CR 1165553; Replace recirculation/standby
gas treatment
system (SGTS) damper actuator;
dual unit 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> shutdown LCO; Emergent wiring repairs on ESS transformer
OX203 in 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO; and T20 startup transformer (T20) high voltage bushing replacement
and Bus 20 clean and inspect. b. Findings No findings of significance
were identified.
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 TSs. In addition, the inspectors
reviewed the selected operability
determinations
to evaluate whether the determinations
were performed
in accordance
with NDAP-QA-0703, "Operability
Assessments." The inspectors
used the TSs, Technical
Requirements
Manual, Final Safety Analysis Report (FSAR), and associated
DeSign Basis Documents
as references
during these reviews. Documents
reviewed are listed in the Attachment.
The issues reviewed included: Unit 1, RHR Oivision I, gas entrainment
issue; Unit 1, repeat failure of 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
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, TSs, and assessed the adequacy of the safety determination
screening
and evaluation.
The inspectors
also assessed configuration
control of the change by reviewing
selected drawings and procedures
to verify whether appropriate
updates had been made. The inspectors
compared the actual installation
to the temporary
modification
documents
to determine
whether the implemented
change was consistent
with the approved documents.
The inspectors
reviewed selected post-installation
test results to determine
whether the actual impact of the change had been adequately
demonstrated
by the test. Documents
reviewed are listed in the Attachment.
The following
modification
and document was included in the review: Unit 1, Temporary
Engineering
Change 1136133, bypass gas discharge
temperature
trip on 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, HV152F0005A
and F015A after breaker swaps; Unit 2, reactor core isolation
cooling (RCIC) pump and flow testing and overspeed
trip test following
resolution
of turbine trip tappet nut alignment, CR 1146099; Unit 2, PMT of PSV 251 F087 after maintenance
to eliminate
emergency
core cooling system keepfill leakage past valve; and T20 high bushing replacement, tap charger inspection
and bus 20 cleaning and inspection.
b. Findings No findings of significance
were identified. 1 Surveillance
Testing (71111.22
-4 Routine Surveillance
and 1 1ST Samples) a. Inspection
Scope The inspectors
observed portions of selected surveillance
test activities
in the control room and in the field and reviewed test data results. The inspectors
compared the test results to the established
acceptance
criteria and the applicable
TS or Technical
Requirements
Manual operability
and surveillance
requirements
to evaluate whether the systems were capable of performing
their intended safety functions.
Documents
Enclosure
21 reviewed are listed in the Attachment.
The observed or reviewed surveillance
tests included: Unit 1, quarterly
functional
test of reactor vessel water level channels LlS-B21-IN031A, 3B, C, D, SI-180-203; Unit 2, 1ST testing of RCIC pump flow indication
from remote shutdown panel; "A" SGTS filter and absorber leak tests; "D" EDG full load rejection
test, SE-024-D01;
and Monthly operation
of SGTS train "A", SO-070-001.
b. Findings No findings of significance
were identified.
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. RADIATION
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-vesseIISIIIVVI
and EPU alternate
decay heat removal modification).
The inspectors
reviewed PPL's method for adjusting
exposure estimates, or re-planning
work, when unexpected
changes in scope or emergent work are encountered.
The inspectors
evaluated
whether adjustments
to estimated
exposure (intended
dose) were based on sound radiation
protection
and ALARA principles
or just adjusted to account for failures to control the work. The inspectors
evaluated
PPL's performance
against the requirements
contained
in 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 IWIIISI tasks, including:
inspection;
camera placement
and repair; and, pressure washing/surface
preparation, were inexperienced
in performing
these tasks. The work hours to perform these tasks then expanded to include an additional
294 hours0.0034 days <br />0.0817 hours <br />4.861111e-4 weeks <br />1.11867e-4 months <br /> for inspection;
207 hours0.0024 days <br />0.0575 hours <br />3.422619e-4 weeks <br />7.87635e-5 months <br /> for camera placement
and repair; and, 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> for pressure washing/surface
preparation.
These examples of additional
high radiation
work resulted in additional
collective
exposure that could have been avoided had sufficient
pre-job training been provided.
Pre-task training for workers, as described
in the pre-outage
work plan, was inadequate
for the tasks to be performed, based on the use of inexperienced
workers. Outage planning for this work was based upon past performance
in earlier outages with experienced
work crews, and estimated
to require less than 3000 hours0.0347 days <br />0.833 hours <br />0.00496 weeks <br />0.00114 months <br />. Actual hours to perform these tasks with the inexperienced
workers were over 5000 hours0.0579 days <br />1.389 hours <br />0.00827 weeks <br />0.0019 months <br />. The original exposure estimate was 5.00 person-rem.
When compared to the actual work activity exposure of 11.04 person-rem, the results were 120 percent greater
than the exposure estimate.
Analysis:
Inadequate
work planning that resulted in significant
unplanned
collective
exposure was a performance
deficiency
which was reasonably
within PPL's ability to foresee and correct and which should have been prevented.
Specifically, the original exposure estimate was 5.00 person-rem.
When compared to the actual work activity exposure of 11.04 person-rem, the results were 120 percent greater than the exposure estimate.
The finding is more than minor because the issue involved actual collective
exposure greater than 5 person-rem
that was greater than 50 percent above the estimated
or intended exposure and the dose overrun was due to activities
within PPL's control. This issue is similar to the greater than minor examples provided in Appendix E of Manual Chapter 0612. Further, the performance
deficiency
is associated
with the radiation
safety cornerstone
attribute
of the program (ALARA planning)
and adversely
affected the cornerstone
objective
to ensure adequate protection
of worker health and safety from exposure to radiation.
The finding was evaluated
in accordance
with IMC 0609, Appendix C, "Occupational
Radiation
Safety Significance
Determination
Process." The inspectors
determined
that the finding was of very low safety significance (Green) because: (1) it involved an ALARA planning issue, and (2) the 3-year rolling average collective
dose history was less than 240 person-rem
(107 person-rem
annual exposure for 2005-2007).
This finding was entered into PPL's CAP (CR 1140623 and 1137835).
This finding was determined
to have a cross-cutting
aspect in the area of Human Performance, Resources, because PPL did not utilize sufficiently
qualified
personnel
to assure occupational
radiation
safety requirements
were met H.2(b).
Specifically, PPL's use of inexperienced
contract workers resulted in additional
collective
exposure that could have been avoided. Enclosure
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
-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
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 ACTIVITIES 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
PIs were included in this review: Units 1 and 2 unplanned
scrams per 7000 critical hours (IE01); Units 1 and 2 unplanned
power changes per 7000 critical hours (IE03); Units 1 and 2 unplanned
scrams with complications (IE04); Common Occupational
Exposure Control Effectiveness (OR01); and Common RETS/ODCM
Radiological
Effluents (PR01)
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
26 Program (ECP), QA documents, and selected reference
RCA documents.
The inspectors
also reviewed the corrective
action schedules
and reviewed completed
corrective
actions such as revised procedures, training material, and records. The inspectors
also conducted
interviews
with site ECP and QA personnel, and several focus groups consisting
of workers and supervisors
from the Security, Work Management, Health Physics, and Operations
Departments.
These interviews
were performed
in order to assess how the staff viewed the effectiveness
of the corrective
actions to date in addressing
the general work environment.
The inspectors
also assessed PPL's longer term action plan items by verifying
action item entries in the CAP as well as through interviews
of responsible
personnel.
b. Findings and Observations
No findings of significance
were identified.
Background:
On January 28, 2009, the NRC issued a PCE letter advising PPL of concerns related to the safety conscious
work environment (SCWE) at SSES and requested
PPL provide: (1) a description
of PPL's current action plans to address existing SCWE concerns to preclude a chilled work environment
at SSES; (2) PPL plans for further evaluating
the health of the SCWE at SSES; and (3) the metrics PPL intended to monitor to determine
the effectiveness
of their actions and ensure a SCWE at SSES (ML090280115).
Also, on January 28, 2009, the NRC issued SSES -NRC Integrated
Inspection
Report 05000387/2008005
and 05000388/2008005 (ML090230434)
which described
the SCWE concerns at PPL and provided additional
background.
PPL completed
their formal RCA of the work environment
issues in May 2009. The NRC's review of that RCA is documented
in NRC Integrated
Inspection
Report 05000387/2009003
and 05000388/2009003 (ML092230158).
Root Cause Analysis Corrective
Actions The inspectors
determined
that the corrective
actions developed
by the RCA team to address the root cause and causal factors were being appropriately
scheduled
and that the actions were being completed
in accordance
with that schedule.
The time frame for completion
of these scheduled
actions was also determined
to be appropriate.
Any changes to the schedule required a review by the Management
Review Committee
and approval by senior management.
Corrective
actions completed
to date included the roll out of the RCA through formal site presentations
and small group discussions, the establishment
of two methods
for workers to raise an anonymous
concern (Safety Hotline and anonymous generated
CRs), developing
training materials
and case studies related to work environment
issues and conducting
this training with all first line supervisors
and positions
above, and revising several procedures.
The training was well received by plant personnel
and the new anonymous
concern processes
was being utilized by plant personnel.
In addition, several organizational
changes were made including
the arrival of the new eNO in July 2009, the establishment
of a plant manager position, restructuring
to have QA, ECP, and Regulatory
Affairs directly reporting
to the CNO, and the selection
of several new personnel
for key management
positions.
The inspectors
observed that these changes were well communicated
to the site and generally
have been well Enclosure
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 3 rd 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 TSs were met and equipment
operated properly.
The inspectors
reviewed documents
and records associated
with the operation
of the SSES independent
spent fuel storage installation (ISFSI), including
training records for personnel
involved with loading of a dry cask canister.
A list of the documents
reviewed is provided in the Supplemental
Information
section. The inspectors
met with reactor engineering
personnel
to review the fuel selection
process and associated
documentation.
The inspectors
discussed
how the cask loading computer program is created for each cask loading. The video recording
of the fuel bundles placed into the canister was reviewed to ensure that each bundle was placed into the proper location.
The inspectors
observed work activities
on the refuel floor associated
with the fuel selection, loading of fuel into the cask, vacuum drying, welding, and moving of the loaded canister to the truck bay. b. Findings No findings of significance
were identified.
However, the inspectors
did identify an issue regarding
compliance
with procedure
MT-GM-014, "Rigging and Lifting Equipment
Inspection." This procedure
references
ASME code 830.9-2003, "Slings." Both documents
require that slings are to be inspected
annually.
While the licensee also performs an inspection
of each sling prior to use in accordance
with the same procedure, the pre-job inspection
does not meet the annual inspection
requirement.
Inspectors
noted that when synthetic
slings used in dry cask storage are inspected
by PPL they receive an August 5 th 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). A IT ACHMENT: SUPPLEMENTAL
INFORMATION
Enclosure
SUPPLEMENTAL
INFORMATION
KEY POINTS OF CONTACT Licensee Personnel
N. D'Angelo, Manager, Station Engineering
R. Doty, Radiation
Protection
Manager T Iliadis, GM -Nuclear Operations
S. Ingram, Dosimetry
Supervisor
R. Kessler, Health Physicist -
ALARA A. Klopp, Heat Exchanger
Program Engineer D. Leimbach, Eddy Current Level III, In-service
Inspection
R. Pagodin, GM -Nuclear Engineering
G. Ruppert, GM -Work Management
S. Davis, Fire Protection
Program Engineer LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened 05000387;
388/200900402 Violation
of 10CFR55.3, Senior Reactor Operators
Performing
Licensed Duties While Not Qualified
Due to Medical Examination
Issues (1 R11.2) Opened/Closed
05000388/200900401 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
A-2 BASELINE INSPECTION
PROCEDURE
PERFORMED
LIST OF DOCUMENTS
REVIEWED (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
A-3 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, 1 st period -Jan 1 -May 2008, 1 51 period -Jan 1 -Apr. 2 nd period -May 1-Aug. 3 rd period -Sept 1 -Dec. 2007, 1 sl period -Jan 1 -Apr 2 nd period -May 1 Aug 3rd period Sept 1-Dec Eddy Current Testing Final Reports 1E205B** 1B RHR Hx, 2E205A -1A RHR Hx, OE505 -Ai, A2, E1, E2, OE505, OE506 A, E, OE526 E, OE507 A, E ESSW Spray Pond Dive Inspection
Report Ecology III, Inc. report dated 3 August 2009 SO-054-A03, Quarterly
ESW flow verification
-Loop A, February 23, 2005 and November 24, 2004 SO-054-803, Quarterly
ESW flow verification
-Loop B, February 16, 2005 and November 17, 2004 TP-054-076, ESW flow balance, September
24, 2004 Chemistry
Matrix Ch-054-001 (ESW), Revision 23, March 05, 2008 Design Calculations
CALC EC-CHEM-1018, Justification
for the Assurance
of Adequate Heat Removal Capabilities, Revision 5 CALC EC-054-0537, ESW System Heat Load and Flow Rate Requirements
for Updated Power Conditions, Revision 5 CALC-049-1001, RHR Heat Exchanger
Performance
at 8000 gpm RHR Flow, Revision 5 Section 1R11: Operator Re-qualification
Program Condition
Report: 1159194,1173155,1173182,622658,625137,389555,1166686
Procedures:
ON-164-002, Loss of Reactor Recirculation
Flow, Revision 28 ON-178-002, Core Flux Oscillations, Revision 14 Attachment
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: OP002-09-06-01, Simulator
Scenario, Revision 0 Section 11R12: Maintenance
Effectiveness
Condition
Report: 1172458,1173175,1173454,1173859,1174337
Procedure:
ES-002-001, Supplying
125 VDC Loads with Portable Diesel Generator, Revision 12 Work Orders: 1172466,1172530
Section 1R13: Maintenance
Risk Assessments
and Emergent Work Control Condition 1162039,1172088,1171760,1171814, 1171764,and
MT-GE-030, ITT Damper Hydramotor
Model NH91 NH93 Overhaul, Revision OI-AD-029, Emergency
Load Control, Revision MT-GE-030, ITT Damper Hydramotor
Model NH91 and NH93 Overhaul, Revision
E-102, Sheet 17, ESS Transformer
101R201 Isolating
Relay Control, Revision 13 E-102, Sheet 17 Circuit Breaker DA10406 Control, Revision 11 M-144, Sheet 2, Reactor Water Clean-Up, Revision 11 M-144, Sheet 1, Reactor Water Clean-Up, Revision 41 E6-8, sheet 1, ESS Trans EX201 and OX203, Revision 8 VC-175, Heating, Ventilation
and Air-Conditioning
Control Diagram SBGT System, Revision 31 M-145, Sheet 1, Clean-up Filter Demineralizer, Revision 21 Work Order: 1162052 and 828214 Other: Attachment
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
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 (OA104)fr20
Outage and restoration, Revision 1 Drawing 9220248, Connection
Diagram Hydraulic
Control Unit, Revision 3 10505411, Box and Cables Hydraulic
Control Unit, Revision 3 105D5634, Connection
Diagram Hydraulic
Control Unit, Revision 2 922D234, Assembly Electrical
box, Revision 3 E-157, Sheet 3, Trip Signals to hydraulic
control unit Unit 1, Revision 7
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, HV143F023B, 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 EP6 Drill Evaluation
Condition
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
SSES 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 FACCTAS 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 ACRONYMS ADAMS Agencywide
Document and Access Management
System ALARA As Low As Is Reasonably
Achievable
AV Apparent Violation
CAP Corrective
Action Program CFR Code of Federal Regulations
CR Condition
Report DG Diesel Generator
ECP Employee Concerns Program EDG Emergency
Diesel Generator
EPU Extended Power Uprate ESW Emergency
Service Water FIN Finding FPE Fire Protection
Engineer FPPR Fire Protection
Program Report FSAR [SSES] Final Safety Analysis Report HPCI High Pressure Coolant Injection
HV High Voltage IN Information
Notice IMC Inspection
Manual Chapter ISFSI Independent
Spent Fuel Storage Installation
lSI Inservice
Inspection
IWIIISI In Vessel Visual 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
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