IR 05000387/2015004

IR 05000387/2015004 & 05000388/2015004 - Susquehanna Steam Electric Station Integrated Inspection Report, October 1, 2015 - December 31, 2015

ML16040A197
Person / Time
Site:	Susquehanna
Issue date:	02/09/2016
From:	Schroeder D L Reactor Projects Region 1 Branch 4
To:	Rausch T S Susquehanna
schroeder, dl
References
IR 2015004
Download: ML16040A197 (49)

Text

February 9, 2016

Mr. Timothy President and Chief Nuclear Officer Susquehanna Nuclear, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603

SUBJECT: SUSQUEHANNA STEAM ELECTRIC STATION INTEGRATED INSPECTION REPORT 05000387/2015004 AND 05000388/2015004

Dear Mr. Rausch:

On December 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Susquehanna Steam Electric Station (SSES), Units 1 and 2. The enclosed report documents the inspection results, which were discussed on January 19, 2016 with you and other members of your staff. NRC Inspectors examined activities conducted under your license as they relate to safety and The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. This report documents four NRC-identified or self-revealing findings of very low safety significance (Green). Three of these findings were determined to involve violations of NRC requirements. Additionally, a licensee-identified violation, which was determined to be of very low safety significance, is listed in this report. However, because of the very low safety significance, and because they are entered into your corrective action program (CAP), the NRC is treating these findings as non-cited violations (NCVs), consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest any NCVs in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at SSES. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at SSES. In accordance with 10 CFR 2.390 of the NRCenclosure, and your response (if any) will be available electronically for public inspection in the Agencywide Documents Access Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.htmL (the Public Electronic Reading Room).

Sincerely,

/RA/ Daniel L. Schroeder, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 50-387 and 50-388 License Nos. NPF-14 and, NPF-22 Enclosure: Inspection Report 05000387/2015004 and 05000388/2015004 w/Attachment: Supplementary Information cc w/encl: Distribution via ListServ

ML16040A197 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE RI/DRP RI/DRP R1/DRP NAME JGreives/per telecon ATurilin/ AT DSchroeder/ DLS DATE 02/09 /16 02/ 09 /16 02/09/15 1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION I Docket Nos.: 50-387, 50-388 License Nos.: NPF-14, NPF-22 Report No.: 05000387/2015004 and 05000388/2015004 Licensee: Susquehanna Nuclear, LLC (Susquehanna) Facility: Susquehanna Steam Electric Station, Units 1 and 2 Location: Berwick, Pennsylvania Dates: October 1, 2015 through December 31, 2015 Inspectors: J. Greives, Senior Resident Inspector T. Daun, Resident Inspector T. Fish, Senior Operations Engineer C. Graves, Health Physicist E. H. Gray, Senior Reactor Inspector J. DeBoer, Emergency Preparedness Inspector N. Embert, Operations Engineer P. Meier, Project Engineer S. Barr, Senior Emergency Preparedness Inspector Approved By: Daniel L. Schroeder, Chief Reactor Projects Branch 4 Division of Reactor Projects 2

SUMMARY

IR 05000387/2015004, 05000388/2015004; October 1, 2015 to December 31, 2015; Susquehanna Steam Electric Station, Units 1 and 2; Maintenance Effectiveness, Operability Determinations and Functionality Assessments, , and Follow-Up of Events and Notices of Enforcement Discretion. This report covered a three-month period of inspection by resident inspectors and announced baseline inspections performed by regional inspectors. The inspectors identified three non-cited violations, all of which were of very low safety significance (Green and/or Severity Level IV). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual cDetermination Process,ted April 29, 2015. Cross-cutting aspects are determined using IMC -Cu. All violations of NRC February 4, 2015power reactors is described in NUREG-5.

Cornerstone: Initiating Events

Green.

A self-revealing finding of very low safety significance (Green) was identified when Susquehanna did not correctly validate a deficient condition associated with the Unit 1 inboard main steam isolation valve (MSIV) direct current (DC) solenoid valve as an actual valve issue, vice indication-only, through the use of specific acceptance criteria as required by MT-AD-. By incorrectly concluding the issue was indication only, testing was allowed to be performed which inserted a half-isolation by de-energizing the alternating MSIV. When this maintenance was performed, the BMSIV closed unexpectedly, resulting in a reactor scram. The cause of the closure was the failure of the DC solenoid valve MSIV. Susquehanna entered the issue into the CAP as CR-2015-30721 and replaced the DC The finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during power operations. Specifically, the maintenance activity performed to validate the DC solenoid valve continuity was inadequate and as a result the testing was allowed to be performed which relied on DC solenoid valve continuity to prevent an MSIV closure. The inadvertent inboard MSIV resulted in a high pressure scram. The inspectors evaluated the finding in accordance with IMC 0609, Appendix Significance Determination Process (SDP) for Findings At-, for the Initiating Events cornerstone. The inspectors determined the finding was of very low safety significance (Green) because it did not cause the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. Specifically, the condenser was maintained for decay heat removal via the bypass valves through the other three main steam lines following the trip. This finding had a cross-cutting aspect in the area of Human Performance, Challenge the Unknown, because Susquehanna did not stop when faced uncertain conditions and instead rationalized unanticipated test results. Specifically, the investigation of the extinguished continuity monitor focused on the possibility that it was an indication-only issue and failed to question the acceptability of the current values obtained during troubleshooting [H.11]. (Section 40A3)

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Cornerstone: Barrier Integrity

Green.

A self-revealing finding of very low safety significance (Green) and associated violations Technical Specification (TS) not take adequate corrective action to address the inoperability of the reactor recirculation sample line outboard PCIV when it failed during surveillance testing on July 1, 2015. The valve failed its subsequent surveillance test on September 30, 2015 due to the same degraded condition, which rendered the valve inoperable for longer than the allowed outage time specified in TS 3.6.1.3. The repeat failure was entered into the CAP as CR-2015-26590 and restored the valve to an operable condition by replacing its associated solenoid valve. The finding was determined to be more than minor because it was associated with the structure, system and component (SSC) and Barrier Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers (containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the failure to correct the degraded condition of solenoid valve sticking resulted in a PCIV being rendered inoperable for longer than the TS allowed outage time. Inspector evaluated the finding In accordance with IMC 0609.04, -Powesafety significance (Green) because the performance deficiency did not result in an actual open pathway in the physical integrity of reactor containment, because the inboard valve remained operable for the duration of the inoperability, and it did not involve the hydrogen recombiners. This finding had a cross-cutting aspect in the area of Human Performance, Challenge the Unknown, because Susquehanna did not stop when faced with uncertain conditions and ensure the risks were evaluated and managed before proceeding. Specifically, Susquehanna did not challenge the unanticipated test results and did not ensure that the condition adverse to quality, associated with the faulty solenoid valve, was resolved prior to considering the valve operable [H.11]. (Section 1R12)

Green.

An NRC-identified finding of very low safety significance (Green) and associated violations and TS 3.7.3, was identified when Susquehanna performed maintenance on redundant trains of the standby gas treatment (SBGT) system and control room emergency outside air supply system (CREOASS) concurrently. When performing these actions, operators did not apply NDAP-QA-technical requirement for operations (TROs) the unrecognized loss of safety function of SBGT and CREOASS. Susquehanna entered the issue into the CAP as CR-2015-26475 and restored one of the subsystems to service, restoring the safety function. This finding is more than minor because it is associated with the Human Performance (Routine OPS/Maintenance Performance) attribute of the Barrier Integrity cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers (Secondary Containment and Control Room Ventilation) protect the public from radionuclide releases caused by accidents or events. Specifically, allowing work to be performed on redundant trains of SBGT and CREOASS concurrently, while not applying plant TSs correctly, resulted in a loss of safety function of both systems. In accordance with IMC 0609.04 5 3 -both dated June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency was only associated with the radiological barrier function of the Control Room and Secondary Containment. This finding had a cross-cutting aspect in the area of Human Performance, Avoid Complacency because Susquehanna did not recognize and plan for the possibility of mistakes, latent problems, or inherent risk, even while expecting successful outcomes. Specifically, Susquehanna did not perform a thorough review of the planned activities every time work was performed to ensure compliance with plant TSs, rather than relying on past successes and assumed conditions [H12]. (Section 1R15)

Cornerstone: Emergency Preparedness

Green.

Specifically, Susquehanna emergency plan implementing procedures did not provide the guidance for the dose assessment staff in the Technical Support Center (TSC) to determine the magnitude of, and continually assess the impact of, the release of radioactive materials. The TSC staff was procedurally limited to performing forward and back dose calculations, but not blowout panel calculations. Blowout panel release calculations were only to be performed by the Emergency Operations Facility (EOF) staff. Susquehanna entered this issue into their corrective action program as CR-2015-04701, which led to the revision of the applicable procedures to allow the TSC dose assessment staff to perform the full scope of dose calculations available to the EOF staff. The inspectors determined that the failure to have the same scope of dose assessment capabilities available to the full emergency response organization (ERO) was a performance deficiency that was within Susquehannaility to foresee and correct. The performance deficiency is more than minor because it is associated with the ERO Readiness and ERO Performance attributes of the emergency preparedness cornerstone, and adversely affected the cornerstone objective of ensuring that a licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Using IMC 0609, Appendix B, Section 5.9, the finding is of very low safety significance (Green) because the finding was determined to not be an example of the overall dose projection process being incapable of providing technically adequate estimates of radioactive material releases; the deficiency was limited to the TSC staff which in fact had the capability of performing dose projections and was only limited by the lack of procedural guidance. The cause of this finding has a cross-cutting aspect in the area of Documentation, because Susquehanna did not ensure that their organization creates and maintains complete, accurate and up-to-date documentation. Specifically, Susquehanna did not provide emergency plan implementing procedures to enable the TSC dose assessment staff to perform dose projections for all required radioactive material releases [H.7]. (Section 1EP6)

Other Findings

A violation of very low safety significance that was identified by Susquehanna was reviewed by the inspectors. Corrective actions taken or planned by Susquehanna have been entered into CAP. This violation and corrective action tracking number are listed in Section 4OA7 of this report.

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REPORT DETAILS

Summary of Plant Status Unit 1 began the inspection period at 100 percent power. On November 10, 2015, operators reduced reactor power to approximately 30 percent(RRP) from service and entered single loop operation. This planned activity was conducted so that the RRP motor-generator set tachometer, which was identified previously as being degraded, could be replaced. Following replacement of the tachometer, operators commenced power restoration. On November 12, 2015 power restoration had reached approximately 98 percent when a reactor scram occurred. The scram was caused by high reactor pressure when MSIV unexpectedly closed during testing. Following the completion of the maintenance activities, operators commenced a reactor startup on November 18, 2015. During startup, with power at approximately 85 percent, operators inserted a RRP runback to 62 percent due to rapidly lowering reactor feed pump suction pressure. Power was stabilized and the cause of the pressure transient was identified and corrected. Power was restored to 100 percent on November 22, 2015. On December 4, 2015, operators reduced power to approximately 75 percent to perform a rod pattern adjustment and power was restored to 100 percent on December 5, 2015. On December 11, 2015, operators reduced power to 62 percent to perform a planned rod sequence exchange and power was restored to 100 percent on December 13, 2015. On December 22 and 27, 2015, operators reduced power to 74 and 80 percent, respectively, to perform planned rod pattern adjustments and power was restored to 100 percent the same days. The unit remained at or near 100 percent power for the remainder of the inspection period.

Unit 2 began the inspection period at 100 percent power and operated at full power until October 28, 2015, when operators reduced reactor power to 62 percent at the request of the grid operator for stability concerns due to the loss of the Sunbury 230 kV line. Power was restored to 100 percent on October 30, 2015. On October 30, 2015, operators reduced power to approximately 84 percent to perform a rod pattern adjustment and power was restored to 100 percent on October 31, 2015.

Unit 2 remained at or near 100 percent power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

seasonal extreme low temperatures from October 31 - December 21, 2015. The review focused on the engineered safeguards service water pump house, exposed portions of the condensate and refueling water storage system, the circulating water pump house and the station portable diesel generator (Blue Max). The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), TS, control room logs, and the CAP to determine what temperatures or other seasonal weather could challenge these systems, and to ensure Susquehanna personnel had adequately prepared for these challenges.

preparation procedure and applicable operating procedures. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during cold weather conditions. Documents reviewed for each section of this inspection report are listed in the Attachment A.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems: Unit 1, division II core spray (CS) during division I system outage window (SOW) on October 6, 2015 Unit 1, high-pressure coolant injection (HPCI) during reactor core isolation cooling (RCIC) SOW on October 26, 2015 Unit 1, RCIC and automatic depressurization system (ADS) during HPCI SOW on December 1, 2015 Unit 1, division I residual heat removal (RHR) during division II SOW on December 1, 2015 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, TSs, work orders, CRs, and the impact of ongoing work activities on redundant trains of equipment in order to safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Susquehanna staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

.2 Full System Walkdown

a. Inspection Scope

On October 15-16 and 21-23, the inspectors performed a complete system walkdown of accessible portions of the Unit 1 reactor protection system (RPS) and alternate rod insertion (ARI) system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hanger and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify as-built system configuration matched plant documentation, and that system components and support equipment remained operable. The inspectors confirmed that systems and components were aligned correctly, free from interference from temporary services or isolation boundaries, environmentally qualified, and protected from external threats. The inspectors also examined the material condition of the components for degradation and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related condition reports (CRs) and work orders to ensure Susquehanna appropriately evaluated and resolved any deficiencies.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Resident Inspector Quarterly Walkdowns

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Susquehanna controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

Unit 2, RCIC room (fire zone 2-1D) on November 5, 2015 Units 1 and 2, division II CS (fire zone 1-1B and 2-1B) on November 30, 2015 Unit 1, HPCI room (fire zone 1-1C) on December 1, 2015 Unit 1, Win 1-4G) on December 16, 2015

b. Findings

No finding were identified.

.2 Fire Protection - Drill Observation

a. Inspection Scope

The inspectors observed a fire brigade drill scenario conducted on December 14, 2015, el Generator (EDG). The inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that Susquehanna personnel identified deficiencies, openly discussed them in a self-critical manner during the debrief, and took appropriate corrective actions as required. The inspectors evaluated the following specific attributes of the drill: Proper wearing of turnout gear and self-contained breathing apparatus Proper use and layout of fire hoses Employment of appropriate fire-fighting techniques Sufficient fire-fighting equipment brought to the scene Effectiveness of command and control Search for victims and propagation of the fire into other plant areas Smoke removal operations Utilization of pre-planned strategies Adherence to the pre-planned drill scenario Drill objectives met The inspectors also -fighting strategies.

c. Findings

No findings were identified.

1R06 Flood Protection Measures

.1 Internal Flooding Review

a. Inspection Scope

The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to identify internal flooding susceptibilities for the site. The inspectors review focused on the elevation of 683which includes both loops of low pressure coolant injection, HPCI and RCIC steam lines and both CS test lines. It verified the adequacy of equipment seals located below the flood line, floor and water penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and temporary or removable flood barriers. It assessed the adequacy of operator actions that Susquehanna had identified as necessary to cope with flooding in this area and also reviewed the CAP to determine if Susquehanna was identifying and correcting problems associated with both flood mitigation features and site procedures for responding to flooding.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed licensed operator simulator training on December 8, 2015, which included loss of offsite power with a fire in an EDG and subsequent steam leak in the HPCI system. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the TS action statements entered by the unit supervisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

b. Findings

No findings were identified.

.2 Quarterly Review of Licensed Operator Performance in the Main Control Room

a. Inspection Scope

On October 28, 2015, inspectors observed the control room operators respond to plant alarms and conduct an unplanned emergent power reduction on Unit 2 in response to a loss of one line into the 500 kV switchyard. The inspectors observed the reactivity control briefing to verify that it met the criteria specified in OP-AD--AD-and OP-AD-activity Manipulations Standards and Communication The inspectors observed the crew during the evolution to verify that procedure use, crew communications, control board component manipulations, and coordination of activities in the control room met established standards.

b. Findings

No findings were identified.

a. Inspection Scope

The following inspection activities were performed using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 10, and Inspection Examination Results Requalification exam results (operating test, only) for year 2015 were reviewed to determine if pass/fail rates were consistent with the guidance of NRC IMC 0609, SDPthat the failure rate (individual or crew) did not exceed 20%.

The overall individual failure rate was 7.8%. The crew failure rate was 8.3% Written Examination Quality The inspectors reviewed three comprehensive written exams previously administered to the operators in October and November 2014.

Operating Test Quality The inspectors reviewed annual operating tests, scenarios and job performance measures (JPMs), associated with the on-site inspection week.

Licensee Administration of Operating Tests The inspectors observed facility training staff administer dynamic simulator exams and JPMs. These observations included facility evaluations of crew and individual operator performance during the simulator exams and individual performance of JPMs. Exam Security The inspectors assessed whether facility staff properly safeguarded exam material, and whether test item repetition was excessive. Remedial Training Program The inspectors reviewed two remediation packages, including re-tests, associated with operators who failed their 2014 biennial written exam. Conformance with License Conditions License reactivation and license proficiency records were reviewed to ensure that 10 CFR 55.53 license conditions and applicable program requirements were met. The inspectors also reviewed a sample of records for requalification training attendance, and a sample of medical examinations for compliance with license conditions and NRC regulations.

Simulator Performance Simulator performance and fidelity were reviewed for conformance to the reference plant control room. A sample of simulator deficiency reports was also reviewed to ensure facility staff addressed identified modeling problems. Problem Identification and Resolution The inspectors reviewed recent operating history documentation found in inspection CAP, NRC End-of-Cycle and Mid-Cycle reports, and the most recent NRC plant issues matrix. The resident staff was also consulted for insights regarding licensed opfocused on events associated with operator errors that may have occurred due to possible training deficiencies.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, and component performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance work orders, and maintenance rule basis documents to ensure that Susquehanna was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the structure, system, or component was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by Susquehanna staff was reasonable. As applicable, for structures, systems, and components classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these structures, systems, and components to (a)(2). Additionally, the inspectors ensured that Susquehanna staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.

Unit 2, repeat failure of reactor sample outboard isolation valve (HV243F020) from November 10, 2015 through November 16, 2015 Unit 1 and Unit 2, RPS electrical power monitoring assembly breaker failures on December 18, 2015

b. Findings

Introduction.

A self-revealing Green finding and associated violation of 10 CFR 50, PCIVsed when Susquehanna did not take adequate corrective action to address the inoperability of the reactor recirculation sample line outboard PCIV when it failed during surveillance testing on July 1, 2015. The valve failed its subsequent surveillance test on September 30, 2015 due to the same degraded condition, which rendered the valve inoperable for longer than the allowed outage time specified in TS 3.6.1.3.

Description.

HV-243F020 is the outboard PCIV for the sample line from the reactor recirculation system. The valve is normally open to allow for continuous sampling of the reactor coolant system. SV-24320 is a normally energized solenoid valve which de-energizes on a primary containment isolation signal to vent air from HV-243F020, allowing it to spring close. TS -243F020 to be operable in Modes 1, 2 and 3 and requires action to isolate the line with a closed, deactivated valve within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> if it is determined to be inoperable. To be considered operable, TSs require, in part, that the valve be capable of closing within 2 seconds of receiving an isolation signal.

On July 1, 2015, HV-243F020, failed its TS surveillance test in that it did not close within the acceptance criteria of 2 seconds. In response to the failure, Susquehanna lubricated the external limit switch arms and stroked the valve three additional times. Based on the stroke times meeting the acceptance criteria of closing within 2 seconds, Operations personnel determined the valve was operable. Subsequent to restoring the valve to an operable condition, a failure mode analysis was performed which identified three potential causes of the failure: limit switch sticking, solenoid valve sticking due to internal degradation and solenoid valve sticking due to exhaust line blockage. Despite the corrective action taken having only addressed one of the failure modes, no additional action was taken to address the other two potential causes. CR-2015-21156 was generated to evaluate the failure. The equipment apparent cause evaluation was completed on August 26, 2015 and identified that the failure was most likely caused which was unrelated to the limit switches. Despite this, no additional action was taken to investigate the solenoid valve and no action was taken to address the identified cause. On September 30, 2015 during the subsequent quarterly test, HV-243F020 failed to stroke closed within the acceptance criteria again, rendering the valve inoperable. The repeat failure was entered into the CAP as CR-2015-26590. Susquehanna identified the direct cause of the failure was due to solenoid valve sticking and attributed it to the same mechanism that occurred on July 1st. Additionally, Susquehanna identified an apparent cause of solenoid valve sticking as less than adequate corrective actions following the July failure. Susquehanna determined the condition was reportable as a condition prohibited by plant TSs in accordance with 10 CFR 50.73(a)(2)(i)(B) because the valve was inoperable for longer than the TS allowed outage time. Then inspectors determined that Susquehanna had identified a condition adverse to quality on July 1, 2015 associated with solenoid valve sticking, which rendered HV-243F020 inoperable, however, did not take sufficient corrective actions to restore the valve to an operable condition as was revealed in a subsequent failure on September 30, 2015.

Analysis.

The failure to take adequate corrective actions to address an inoperable PCIV was reasonabbeen prevented. Specifically, despite identifying solenoid valve malfunction as the likely cause of a PCIV failure, Susquehanna did not take any action to address the condition adverse to quality. The finding was determined to be more than minor because it was associated with the SSC and Barrier Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers (containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the failure to correct the degraded condition of solenoid valve sticking resulted in a PCIV being rendered inoperable for longer than the TS allowed outage time. Inspector evaluated the finding -June 19, 2012, and determined it is of very low safety significance (Green) because the performance deficiency did not result in an actual open pathway in the physical integrity of reactor containment, because the inboard valve remained operable for the duration of the inoperability, and it did not involve the hydrogen recombiners. This finding had a cross-cutting aspect in the area of Human Performance, Challenge the Unknown, because Susquehanna did not stop when faced with uncertain conditions and ensure the risks were evaluated and managed before proceeding [H.11]. Specifically, Susquehanna did not challenge the unanticipated test results and did not ensure that ensure that the condition adverse to quality, associated with the faulty solenoid valve, was resolved prior to considering the valve operable Enforcementmeasures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. Contrary to this, despite identifying a condition adverse to quality on July 1, 2015 associated with solenoid valve malfunction, implementation of CAP did not assure that the condition adverse to quality was promptly corrected. Additionally, TS 3.6.1.3 requires HV-243F020, the reactor recirculation sample line outboard PCIV to be operable in Mode 1 and requires action be taken within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to isolate the line if it is determined to be inoperable. Contrary to this, HV-243F020 was inoperable from July 1, 2015 through September 30, 2015 without the line being isolated with a closed, deactivated valve. Following the September 30 failure, Susquehanna closed and deactivated the inboard PCIV to establish compliance with TSs and replaced the solenoid valve, restoring operability of the outboard PCIV. Because it was of very low safety significance (Green) and has been entered into the CAP as CR-2015-26590, this finding is being treated as a NCV in accordance with (NCV 05000388/2015004-01, Failure to Correct a Condition Adverse to Quality Associated with an Inoperable Primary Containment Isolation Valve)

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Susquehanna performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Susquehanna personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Susquehanna performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

Unit 1, yellow risk during division 2 RHR SOW on November 3, 2015 et tachometer on November 10, 2015 Unit 1, emergent repair of HPCI following identification of significant amounts of water in the oil system on December 4, 2015 Common, yellow risk during startup transformer 10 SOW during the week of October 19, 2015

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-conforming conditions based on the risk significance of the associated components and systems: Unit 1, water identified in HPCI lube oil on December 4, 2015 RRP discharge bypass valve dual indication on November 9, 2015 Common, application of plant TSs during nuclear steam supply shutoff system instrumentation surveillance testing on November 23, 2015 Common, hiller failed capacity test on December 14, 2015 The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to evaluations to determine whether the components or systems were operable. The inspectors confirmed, where appropriate, compliance with bounding limitations associated with the evaluations. Where compensatory measures were required to maintain operability, such as in the case of operator workarounds (OWAs), the inspectors determined whether the measures in place would function as intended and were properly controlled by Susquehanna. The inspectors verified that Susquehanna identified OWAs at an appropriate threshold and addressed them in a manner that effectively managed OWA-related adverse effects on operators and SSCs.

b. Findings

Introduction.

An NRC-identified Green finding and associated violation of TS 5.4.1, identified when Susquehanna performed maintenance on redundant trains of the SBGT system and CREOASS concurrently. When performing these activities, operators did not apply NDAP-QA-correctly which resulted in the unrecognized loss of safety function of SBGT and CREOASS.

Description.

On September 29, 2015, Susquehanna authorized performing SI-180-306, 24-Month Calibration- Rx Vessel Water Level 1 & 2 Isolation Channels A & C. Each channel provides an input to one division of the nuclear steam supply shutoff system, in part, for initiation of the primary containment isolation system (PCIS), secondary containment isolation system (SCIS) and CREOASS. This surveillance test calibrates level switches and satisfies surveillance requirements of the following TSs: TS 3.3.6.1, Primary Containment Isolation Instrumentation; TS 3.3.6.2, Secondary Containment Isolation; and TS 3.3.7.1, CREOASS System Instrumentation. Performance of the surveillance renders each of the channels inoperable when they are isolated from the process stream so that external test equipment can be used to calibrate the level instruments. A note in the surveillance requirement allows a 6-hour delay prior to taking the required action of the TS LCO if the inoperability is due solely to testing as long as isolation/initiation function is maintained. Each of these functions is arranged in two, two-out-of-two logic subsystems. For exampleTherefore, with the A instrument isolated for testing, one division of the PCIS, SCIS, and CREOASS would not have isolated/initiated because one of the two instruments would not have tripped. Additionally, because the SBGT system receives an initiation signal from the SCIS, one division of the SBGT system would not have initiated. However, because this test only impacted the ability of one division to function, operators were not required to take the actions of TS LCO 3.3.6.1, 3.3.6.2 or 3.3.7.1. During performance of SI-180-306, operators commenced SE-030-002B, 24 Month Control Structure Ventilati the approved plant schedule, which rendered s of the SBGT system and CREOASS inoperable. Subsequently, maintenance technicians notified the control room operators that -180-306, was found outside of TS acceptance criteria. Operators determined that the 6-hour delay was no longer applicable and that the LCO action statements required, in part, performance of SE-030-002B, operators entered the action statement of TS 3.6.4.1 for both trains of SBGT inoperable and reported the loss of safety function to the NRC in event notification 51432.

Susquehanna entered the issues into CAP as CRs 2015-26442, 2015-26455 and 2015-as failed, -030-002B. Therefore, Susquehanna identified the cause of the event was that the risk was not considered when scheduling surveillance tests because personnel were accustomed to successful outcomes and therefore had allowed surveillances from multiple divisions to be performed concurrently. Inspectors reviewed the apparent cause evaluation and associated corrective actions and determined that Susquehanna had not identified the appropriate cause of the event and therefore had not identified reasonable corrective actions. Specifically, Susquehanna did not recognize that they had inappropriately applied the note in the TS SR which allows delaying entry into the action statement if an inoperability is solely due to testing. Susquehanna had considered that this note allowed considering the instrument operable for the delay period. By interpreting the TS in this manner, operators did not correctly apply all TS LCOs correctly and therefore, in this instance, identified as failed. Inspectors determined that the instrument was inoperable the entire time and therefore a loss of safety function had occurred for the duration of the two activities.

To assess whether this was a one-time error or potentially more programmatic, inspectors reviewed past performance of the level instrument calibration on both units. Inspectors identified that on October 3, 2014, Susquehanna performed SI-280-306, which is the Unit 2 equivalent to the surveillance, concurrent with a surveillance on the determined that this also constituted a loss of safety function of CREOASS, similar to the event that occurred on September 29. Inspectors reviewed NDAP-QA-apply the safety function determination process when a TS system or component is -divisional checks to ensure a loss of capability to perform the safety function assumed in the accident analysis not go undetected. Additionally, it states that a loss of safety function exists if a required system redundant to a system supported by the inoperable support system is also inoperable. Attachment B of NDAP-QA-0312 lists SCIS instrumentation as a support system of the SBGT system and CREOASS. Inspectors determined that Susquehanna had not implemented this procedure correctly in multiple instances when 1) the appropriate LCOs were not entered when rendering systems inoperable and 2) a loss of safety function determination was not made when rendering were rendered inoperable when a support system for the redundant train was inoperable, a loss of safety function had occurred.

Inspectors considered whether this violation was licensee-identified because the loss of safety function was identified by Susquehanna during a surveillance test, but determined that inspectors added significant valve because of the identified weaknesses in evaluation and correction of the issue and therefore determined it should be characterized as NRC-identified.

Analysis.

Inspectors determined that failing to apply plant TSs appropriately was a and should have been prevented. Specifically, on multiple occasions operators did not apply a note in plant TSs correctly and allowed work on redundant trains to be performed concurrently, resulting in a loss of safety function of the SBGT system and CREOASS. This finding is more than minor because it is associated with the Human Performance (Routine OPS/Maintenance Performance) attribute of the Barrier Integrity cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers (Secondary Containment and Control Room Ventilation) protect the public from radionuclide releases caused by accidents or events. Specifically, allowing work to be performed on redundant trains of the SBGT system and CREOASS concurrently, while not applying plant TSs correctly, resulted in a loss of safety function of both systems. 3 Findings At-both dated June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency was only associated with the radiological barrier function of the Control Room and Secondary Containment. This finding had a cross-cutting aspect in the area of Human Performance, Avoid Complacency because Susquehanna did not recognize and plan for the possibility of mistakes, latent problems, or inherent risk, even while expecting successful outcomes [H12]. Specifically, Susquehanna did not perform a thorough review of the planned activities every time work was performed to ensure compliance with plant TSs, rather than relying on past successes and assumed conditions.

Enforcement.

be established, implemented, and maintained covering the applicable procedures recommended in RG 1.33. RG 1.33, Appendix A, requires administrative procedures control of maintenance, including a method for obtaining permission to work. requirements for the program required to implement the requirements of TS LCO 3.0.6. NDAP-QA-is one of the administrative procedures which is intended to meet these requirements. This procedure requires operators to enter the appropriate LCOs and apply the safety function determination process when a TS system or component is declared inoperable. Contrary to the above, on October 3, 2014 and September 29, 2015, work which affected both trains of SBGT and/or CREOASS was scheduled and executed, which resulted in a loss of safety function of both systems. On both occasions, operators did not enter the appropriate TS LCO action statements and did not perform a safety function determination prior to rendering systems inoperable. Additionally, with both inoperable. TS LCO 3.0.3 requires action be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to shutdown both units. Contrary to this, both trains of CREOASS were inoperable from 10:20 a.m. to 12:28 p.m. on September 29, 2015 and no action was initiated as required by TS LCO 3.0.3. Upon identification of the issue, operators restored one of the divisions of SBGT and CREOASS, restoring the safety function of both systems. Because it was of very low safety significance (Green) and has been entered into the CAP as CR-2015-26475, this finding is being treated as a NCV Enforcement Policy. (NCV 05000387/2015004-02, Loss of Safety Function of SBGT and CREOASS due to Concurrently Performing Maintenance on Redundant Trains)

1R18 Plant Modifications

===.1 Permanent Modifications

a. Inspection Scope

The inspectors evaluated significant changes to the emergency operating procedures and severe accident guidelines which were implemented by actions 1733969 and 1731628. The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the procedure changes. In addition, the inspectors reviewed modification documents associated with the change.

b. Findings

No findings were identified.

=

a. Inspection Scope

The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure were consistent with the information in the applicable licensing basis and/or design basis documents, and that the test results were properly reviewed and accepted and problems were appropriately documented. The inspectors also walked down the affected job site, observed the pre-job brief and post-job critique where possible, confirmed work site cleanliness was maintained, and witnessed the test or reviewed test data to verify quality control hold point were performed and checked, and that results adequately demonstrated restoration of the affected safety functions.

Unit 1, division I CS following SOW on October 8, 2015 Unit 1, RCIC testing following SOW on October 28, 2015 Unit 1, A and B inboard MSIVs following solenoid valve replacement on November 16, 2015 Unit 1, HPCI following SOW on December 3, 2015

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

The inspectors reviewed forced outage, which was conducted November 12 through 19, 2015. The inspectors schedules to verify that risk, industry experience, previous site-specific problems, and defense-in-depth were considered. During the outage, the inspectors observed portions of the shutdown and cooldown processes and monitored controls associated with the following outage activities: Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable TSs when taking equipment out of service Implementation of clearance activities and confirmation that tags were properly hung and equipment was appropriately configured to safely support the associated work or testing Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication and instrument error accounting Status and configuration of electrical systems and switchyard activities to ensure that TSs were met Monitoring of decay heat removal operations Reactor water inventory controls, including flow paths, configurations, alternative means for inventory additions, and controls to prevent inventory loss Activities that could affect reactivity Maintenance of secondary containment as required by TSs Fatigue management Tracking of startup prerequisites, walkdown of the drywell (primary containment) to verify that debris had not been left which could block the emergency core cooling system suction strainers, and startup and ascension to full power operation Identification and resolution of problems related to refueling outage activities

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant structures, systems, and components to assess whether test results satisfied TSs, the UFSAR, and Susquehanna procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests: Unit 1, HPCI quarterly flow surveillance on December 3, 2015

b. Findings

No findings were identified. Cornerstone: Emergency Preparedness a.

b.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

Susquehanna implemented various changes to the Susquehanna Emergency Action Levels (EALs), Emergency Plan, and Implementing Procedures. Susquehanna had determined that, in accordance with 10 CFR 50.54(q)(3), any change made to the EALs, Emergency Plan, and its lower-tier implementing procedures, had not resulted in any reduction in effectiveness of the Plan, and that the revised Plan continued to meet the standards in 50.47(b) and the requirements of 10 CFR 50 Appendix E.

The inspectors performed an in-office review of all EAL and Emergency Plan changes submitted by Susquehanna as required by 10 CFR 50.54(q)(5), including the changes to lower-tier emergency plan implementing procedures, to evaluate for any potential reductions in effectiveness of the Emergency Plan. This review by the inspectors was not documented in an NRC Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The requirements in 10 CFR 50.54(q) were used as reference criteria. The specific documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings were identified.

RADIATION SAFETY

===Cornerstone: Occupational and Public Radiation Safety

2RS1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

During October 13-15, 2015, the inspectors reviewed the Susquehanna performance in assessing and controlling radiological hazards in the workplace. The inspectors used the requirements contained in 10 CFR 20, TSs, applicable Regulatory Guides (RGs), and the procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspectors reviewed the performance indicators for the occupational exposure cornerstone, radiation protection (RP) program audits, and reports of operational occurrences in occupational radiation safety since the last inspection. Radiological Hazard Assessment The inspectors reviewed recent plant radiation surveys and any changes to plant operations since the last inspection to identify any new radiological hazards for onsite workers or members of the public.===

Instructions to Workers The inspectors observed several containers of radioactive materials and assessed whether the containers were labeled and controlled in accordance with requirements.

The inspectors reviewed several dosimeter alarmed. The inspectors reviewed the Susquehannaevaluation of the incidents, documentation in the CAP, and whether compensatory dose evaluations were conducted when appropriate.

Contamination and Radioactive Material Control The inspectors observed themonitoring of potentially contaminated material leaving the radiological control area and inspected the methods and radiation monitoring instrumentation used for control, survey, and release of that material.

Problem Identification and Resolution The inspectors evaluated whether problems associated with radiation monitoring and exposure control were identified at an appropriate threshold and properly addressed in the CAP. Findings

2RS2 Occupational ALARA Planning and Controls

a. Inspection Scope

During October 13-15, 2015, the inspectors assessed the Susquehannaperformance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspectors used the requirements contained in 10 CFR 20, applicable RGs, TSs, and procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspectors conducted a review of collective dose history and trends; ongoing and planned radiological work activities; radiological source term history and trends; and ALARA dose estimating and tracking procedures. Radiological Work Planning The inspectors selected the following radiological work activities based on exposure significance for review: RWP 20152118 noble metals injection modifications in the radiological controlled area RWP 20152120 reactor water cleanup complex and back wash receiving tank room general work and inspections RWP 20152324 recirculation pump 2P401B motor replacement RWP 20152336 recirculation pump work For each of these activities, the inspectors reviewed: ALARA work activity evaluations; exposure estimates; exposure reduction requirements; results achieved (dose rate reductions, actual dose); person-hour estimates and results achieved; and post-job reviews that were conducted to identify lessons learned. Verification of Dose Estimates and Exposure Tracking Systems The inspectors reviewed the current annual collective dose estimate; basis methodology; and measures to track, trend, and reduce occupational doses for ongoing work activities. Source Term Reduction and Control The inspectors reviewed the current plant radiological source term and historical trend, plans for plant source term reduction, and contingency plans for changes in the source term as the result of changes in plant fuel performance or changes in plant primary chemistry.

4OA1 Performance Indicator Verification

.1 Safety System Functional Failures (2 samples)

a. Inspection Scope

Failures performance indicator for both Unit 1 and Unit 2 for the period of July 1, 2014, through June 30, 2015. To determine the accuracy of the performance indicator data reported during those periods, inspectors used definitions and guidance contained in NEI Document 99-Revision 7, and NUREG-50.73." The inassessments, maintenance rule records, maintenance work orders, CRs, event reports and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index (4 samples)

a. Inspection Scope

Performance Index for the following systems for the period of October 1, 2014, through September 30, 2015: Unit 1, RHR System Unit 2, RHR System Unit 1, Cooling Water System Unit 2, Cooling Water System To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, alCRs, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findings

No findings were identified.

===.3 Emergency Preparedness (3 samples)

=

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that PPL entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended management review committee meetings.

b. Findings

No findings were identified.

.2 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a semi-annual review of site issues, as required by Inspection indicate the existence of more significant safety issues. In this review, the inspectors included repetitive or closely-related issues that may have been documented by Susquehanna outside of the corrective action program, such as trend reports, performance indicators, system health reports, maintenance rule assessments, and maintenance or corrective action program backlogs. The inspectors also reviewed 2015 to assess CRs written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily CR review (Section 4OA2.1). The inspectors reviewed the Susquehanna quarterly performance assessment report for the second and third quarter of 2015, conducted under LS-125-1, to verify that Susquehanna personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures.

b. Findings and Observations

No findings were identified.

Adequacy of Corrective Actions. Inspectors noted a potential trend in the adequacy of corrective actions. Specifically, inspectors noted that from July through December, 2015 there were several events that that were either caused by or exacerbated by inadequate or untimely corrective actions. Specific examples include: On September 29, 2015, Susquehanna identified that a loss of safety function occurred when a division 1 reactor vessel level instrument failed during TS testing, which was being performed concurrently with testing of division 2 of the SBGT system and CREOASS. Susquehanna entered the issue into the CAP as CRs 2015-26442, 2015-26455 and 2015-26475. As documented in section 1R15 of this report, inspectors reviewed the evaluation and associated corrective actions and determined that Susquehanna had not identified the appropriate cause of the event and therefore had not identified reasonable corrective actions. As documented in section 1R12 of this report, Susquehanna did not take adequate corrective actions to address a failure of a PCIV to close within the limits specified in TSs. This resulted in a repeat failure during the subsequent surveillance test. (CR-2015-26590) As documented in

4OA3 section of thiinvestigate and address an extinguished light that provided indication of MSIV solenoid valve continuity were inadequate to ensure that the solenoid remained energized while testing the redundant solenoid.

(CR-2015-30092) Preparation for and Execution of Maintenance. Inspectors noted several examples since the last semi-annual review in which planned preventative or corrective maintenance was not able to be executed due to inadequate preparation, noting that this was indicative of a possible adverse trend. Specific examples include:

On September 15, 2015, division 2 of the ultimate heat sink was rendered inoperable for performance of spray array nozzle inspections. After hanging the clearance order and releasing the maintenance item, the work group identified that the boat that was required to perform the inspection was non-functional and the evolution had to be aborted. This resulted in 11.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of unnecessary unavailability of a high safety significant system. (CR-2015-25208) On October 21, 2015, fuel oil was drained from Blue Max, as part of a modification to install a fuel oil heater. The following day, maintenance determined that the temperature switch associated with the thermostat could not be calibrated and that the modification had to be aborted. This resulted in approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of unnecessary unavailability of a high safety significant system. (CR-2015-28612) In August and October, 2015, the maintenance rule unavailability criteria was exceeded for both the diesel driven and backup diesel driven fire pumps. Though inspectors recognize that much of the accrued unavailability was due to piping and pump replacement, which were identified as corrective actions to address previous unavailability exceeding the performance criteria established under the maintenance rule, inspectors noted considerable unnecessary unavailability during both projects due to deficiencies in preparation or execution of the work windows. (CR 2015-28486, 2015-28232 and 2015-23100) On January 6, 2016, several maintenance items that were scheduled during the 12- to either lack of parts or lack of test equipment. These will require additional unavailability of the safety-related chillers to complete once rescheduled. (CR-2016-00551, CR-2016-00564) Readiness for Seasonal Weather. Inspectors documented a potential adverse trend (CR-1638800). In part, this trend was identified because the station had not completed preparations for the winter season by November 1 of each year from 2008 through 2012 as required by NDAP-00-was able to meet the requirement for 2013 based on management intervention in response to the documented trend. However, inspectors noted that the station did not meet the procedural requirements in 2014 as documented in CR-2014-33693. Additionally, inspectors noted that not all procedural actions were completed as required in 2015. Specifically, 1) a modification to install a fuel tank heater in Blue Max was not completed by December 1 due to issues with parts (CR-2015-28612), 2) compensatory measures were necessary to maintain the functionality or the liquid radwaste sample tank line to the Unit 1 condensate storage tank due to non-functional heat trace (CR-2015-31811), and 3) compensatory measures were required to maintain functionality of Blue Max in temperatures below 14F due to the lack of cold weather qualification of the electrical cables (CR-2015-19827). These three potential trends were entered into the CAP as CRs 2015-32988, 2016-01868, and 2016-01870, respectively.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

.1 Plant Events

a. Inspection Scope

For the plant events listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional activities. As applicable, the inspectors verified that Susquehanna made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed follow-up actions related to the events to assure that Susquehanna implemented appropriate corrective actions commensurate with their safety significance.

Unit 1 Reactor scram during MSIV testing on November 12, 2015

b. Findings

Introduction.

A self-revealing Green finding was identified for not correctly validating a deficient condition associated with the Unit 1 as an actual valve issue, vice indication-only, through the use of specific acceptance criteria as required by MT-AD-concluding the issue was indication only, testing was allowed to be performed which inserted a half-isolation by de-MSIV. When this maintenance was performed, the BMSIV closed unexpectedly, due to the failure of the DC solenoid, resulting in a reactor scram.

Description.

The main steam system consists of four steam lines that are isolated by two redundant MSIVs. The MSIVs are pneumatic opening, spring and/or pneumatic closing valves. Each of the MSIVs are controlled by two solenoid operated pilot valves. For reliability one of the solenoids are powered by an AC source and the other by a DC source. When both pilots are de-energized the associated MSIV will close. An inadvertent closure of one MSIV with the reactor at-power will result in a rapid increase in reactor pressure, which in turn will result in a rapid increase in reactor power due to the positive reactivity added by the rapid collapse of steam voids in the core. Depending on initial reactor power level, the reactor protection system may generate either a high reactor pressure or high power scram to prevent exceeding safety limits during the power transient. On November 6, 2015, operators identified the continuity light for the DC solenoid verified the bulb was functional by changing with a known good bulb and generated CR-2015-30092.

CR-2015-30092 directed an investigation to determine if the current transformer or the actual solenoid was bad.

On November 9, 2015, electrical maintenance performed an investigation utilizing MT-AD-509, Control of Minor Maintenance Activities, and observed a current of approximately 40 ma across the DC solenoid. Maintenance concluded that the continuity monitor needed to be replaced and calibrated but did not assess the acceptability of the DC solenoid. The minor maintenance work checklist did not provide acceptance criteria associated with the DC solenoid, troubleshooting guidance, or technical information for the continuity monitor. On November 11, 2015, technicians commenced a routine quarterly surveillance of the -183-207). I&C technicians noted the DC solenoid continuity light was not lit as required by SI-183-207, step 5.2.14, so the technicians utilized the alternate method identified in step 5.2.14 to verify current at the field side terminal wiring was approximately 50maDC through the use of a clamp-on ammeter. I&C continued with the surveillance testing per SI-183-207. When the test pressure for the trip associated with the AC solenoid was reachclosed resulting in an automatic scram. Follow-on troubleshooting revealed that the current values associated with the DC solenoid circuit were erratic and the DC solenoid was experiencing intermittent performance before failing. evaluation of the scram identified that the measured currents were insufficient to ensure the continuity of the DC solenoid and separately concluded that the minor maintenance work document, which was performed on November 9, did not provide sufficient detail to ensure the degraded condition was appropriately evaluated. MT-AD-509 requires the initial apparent cause be identified sufficiently to enable the formal work planning process. Since Susquehanna did not utilize any formal acceptance criteria for the validation, they incorrectly validated the cause of the problem as a material failure of the continuity monitor.

Analysis.

troubleshoot and diagnose the deficient condition of an extinguished continuity monitor for a DC solenoid as valve degradation, vice an indication-only issue, was a performance deficiency. This performance deficiency was more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and affected the objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during power operations. Specifically, the maintenance activity performed to validate the DC solenoid continuity was inadequate and did not identify that the solenoid valve was degraded. Testing of the redundant AC solenoid was allowed to be resultant high pressure reactor scram. The inspectors evaluated the finding in -, for the Initiating Events cornerstone. The inspectors determined the finding was of very low safety significance (Green) because it did not cause the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. Specifically, the condenser was maintained for decay heat removal via the bypass valves through the other three main steam lines following the transient.

This finding had a cross-cutting aspect in the area of Human Performance, Challenge the Unknown, because Susquehanna did not stop when faced uncertain conditions and instead rationalized unanticipated test results. Specifically, the investigation of the extinguished continuity monitor focused on the possibility that it was an indication-only issue and failed to question the acceptability of the current values obtained during troubleshooting [H.11].

Enforcement.

This finding does not involve any enforcement action since no violation of regulatory requirements was identified. Specifically, the failure of the DC solenoid does not impact the safety-related function of the MSIV. Because the finding does not involve a violation of regulatory requirements and has very low safety significance, it is identified as a FIN. (FIN 05000387/2015004-04, Inadvertent Closure )

4OA6 Meetings, Including Exit

On January 19, 2016, the inspectors presented the inspection results to Mr. T. Rausch, Senior Vice President and Chief Nuclear Officer, and other members of the Susquehannaretained by the inspectors or documented in this report.

4OA7 Licensee-Identified Violations

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Franke, Site Vice President

B. Franssen, Plant Manager

D. Adams, Licensed Operator Requalification Training Supervisor

B. Bridge, Radiation Protection Manager

K. Cimorelli, General Manager- Operations

T. Creasy, Assistant Operations Manager

M. Dziedzic, Site Level III and IWE/IWL Program Owner

N. Giusto, System Engineer

J. Gorman, Emergency Preparedness Manager

B. Hyduk, Support Engineer

T. French, Operations Training Supervisor

J. Jennings, Regulatory Assurance Manager

D. Jones, Operations Manager

A. Kuklis, System Engineer

C. Manges, Regulatory Assurance

A. May-Allen, System Engineer

T. Mogavero, Corrective Action Program Coordinator/Performance Improvement Coordinator

S. Muntzenberger, Engineering Branch Manager

R. Rodrigues-Gilroy, Radiation Operations Supervisor

T. Roth, Supervisor- Operations Engineering

P. Scanlan, Station Engineer Manager

H. Strahley, Assistant Operations Manager

T. Terryah, ISI Programs Manager

J. Waclawski, Engineering Branch Manager

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

05000388/2015004-01 NCV Failure to Correct a Condition Adverse to Quality Associated with an Inoperable Primary Containment Isolation Valve (Section 1R12)

05000387/2015004-02 NCV Loss of Safety Function of SBGT and CREOASS due to Concurrently Performing Maintenance on Redundant Trains (Section 1R15)

05000387;388/2015004-03 NCV Dose Assessment Capabilities in the Technical Support Center(Section 1EP6)

05000387/2015004-04 FIN (Section 40A3)

Closed

05000387; 388/2015001-04 URI Effectiveness of Declaration Capability of Abnormal Radiation Level EAL (Section 1EP6)

Section 1R01: Adverse Weather Protection

Procedures

NDAP-00-1913, Seasonal Readiness, Revision 3

MT-085-001, Freeze Protection, Process Heat Trace Testing and Maintenance, Revision 24

Condition Reports

(*NRC identified)

CR-2015-28670

CR-2015-28662

CR-2015-27014

CR-2014-31063

CR-2014-26667

CR-2015-25485

Maintenance Orders/Work Orders

1841063

1855366

1762768

Miscellaneous

EC 1634054, Fuse Block for Turbine Building HVAC

Section 1R04: Equipment Alignment

Procedures

OP-152-001, HPCI System, Revision 59

OP-258-001, RPS System, Revision 57

OP-150-001, RCIC System, Revision 46

OP-183-001, Automatic Depressurization System and Safety Relief Valves, Revision 18

DP-151-001, Unit 1 Core Spray A & C Drain Procedure While at Power, Revision 18

CL-151-0015, Unit 1 Core Spray System Division 2 Mechanical, Revision 13

CL-151-0014, Unit 1 Core Spray System Division 2 Electrical, Revision 9

Maintenance Orders/Work Orders

1119887

1119886

Drawings

M-155, Unit 1 P&ID High Pressure Coolant Injection, Sheet 1, Revision 58 M-156, Unit 1 P&ID HPCI Turbine-Pump, Sheet 1, Revision 38 M-146, Unit 1 P&ID Control Rod Drive Part A, Sheet 1, Revision 42 M-147, Unit 1 P&ID Control Rod Drive Part B, Sheet 1, Revision 38 M-152, Unit 1 P&ID Core Spray, Revision 40

Miscellaneous

Maintenance Rule Basis Document-System 55, CRD Control Rod Drive Hydraulics Maintenance Rule Basis Document-System 58, RPS Reactor Protection System

TM-OP-058-ST, Reactor Protection System, Revision 09

CL-183-0011, Unit 1 Safety Relief Valve System, Revision 6

CL-150-0012, Unit 1 Reactor Core Isolation Cooling System, Revision 25

CL-150-0011, Unit 1 RX Core Isolation Cooling System, Revision 11

Section 1R05: Fire Protection

Procedures

FP-113-103, HPCI Pump Room (I-II) Fire Zone 1-1C -

FP-213--17) Fire Zone 2--

FP-113--10) Fire Zone 1--

Miscellaneous

SSES FPRR, Revision 18

Section 1R06: Flood Protection Measures

Maintenance Orders/Work Orders

1235117

520929

Drawings

C--Revision 2

Engineering Calculations

EC-RISK-0539, Internal Flooding Analysis for PRA, Revision 3

Section 1R11: Licensed Operator Requalification Program

Procedures

LS-1012, Reportable Action Levels for Loss of Emergency Response Capabilities, Revision 0

OP-AD-002, Standards for Shift Operations, Revision 57

OP-AD-338, Reactivity Manipulations Standards and Communications Requirements,

Revision 31 ANSI/ANS-3.5-2009, Nuclear Power Plant Simulators for Use in Operator Training and Examination 2015 LOR Annual Operating Exam Sample Plan

OI-AD-044, Return to Shift Duty/Job Promotion (Operator Qualification)

TQ-106, LOR Program Implementation

TQ-201, Examination Security and Administration

Condition Reports

(*NRC identified)

CR-2015-29146

CR-2015-29141

CR-2015-29164

CR-2015-29150

CR-2014-10388

CR-2015-25851

CR-2015-25889

CR-2015-23700

CR-2015-32652

CR-2015-32787

CR-2015-32816

CR-2015-32786

CR-2015-32788

CR-2015-32652

CR-2015-32670

CR-2015-32702

CR-2015-32940

CR-2015-32922

CR-2015-32721

CR-2015-32725

CR-2015-32706

CR-2015-32710

CR-2015-32889

CR-2015-32866

CR-2015-32648

CR-2015-32782

CR-2015-32784

CR-2015-32838

CR-2015-32650

CR-2015-32654

CR-2015-32650

CR-2015-32831

CR-2015-32649

CR-2015-32924

CR-2015-32733

CR-2015-32781

CR-2015-32776

Job Performance Measures

00.AD.037.052 04.ON.1203.251 45.OP.4677.152 49.OP.008.101 58.OP.006.201 24.OP.1443.051 49.OP.1877.201 79.OP.006.102 00.AD.3274.103 00.AD.1033.101 50.OP.004.152

Comprehensive Written Exams (Previously administered in Aug/Sep 2014)

14-06-S2C 14-06-S2A 14-06-S1A

Simulator Scenarios

OP002-503 OP002-205 OP002-514 OP002-610

Simulator Testing

TQ-302 Simulator Testing and Documentation 2014 Simulator Physical Fidelity Audit 2015 Simulator Physical Fidelity Audit

Section 1R12: Maintenance Effectiveness

Procedures

NDAP-QA-0413, Implementation of the Maintenance Rule, Revision 14

NSEP-AD-0413D, Maintenance Rule- Performance Monitoring, Revision 3

NSEP-AD-0413E, Maintenance Rule-Dispositioning Between (A)(1) and (A)(2), Revision 2

Condition Reports

(*NRC identified)

CR-2015-26590

CR-1733145

CR-2014-26599

CR-2015-21156

CR-2015-18650

CR-2015-30133

CR-2015-27360

CR-2015-25881

CR-2015-25539

CR-2015-25428

CR-2015-25426

CR-2015-24221

CR-2015-27220

CR-2015-27222

CR-2015-27224

CR-2015-27225

CR-2015-27226

CR-2015-27227

CR-2015-27228

CR-2015-27229

CR-2015-27230

CR-2015-27231

CR-2015-27232

CR-2014-28492

CR-2015-25539

CR-2015-25881

Action Requests

AR-1571694

AR-2015-03484

Miscellaneous

Maintenance Rule Basis Document- System 64, November 18, 2015

SM-158-001, RPS M-and Functional Test, Revision 15

SM-158-001, RPS M-and Functional Test, Revision 14

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures

MT-052-002, Unit 1 and Unit 2 HPCI Turbine Maintenance, Revision 14

OP-152-001, HPCI System, Revision 59

PSP-26, Online and Shutdown Nuclear Risk Assessment Program, Revision 15

NDAP-QA-1902, Integrated Risk Management, Revision 20

OP-164-001, Reactor Recirculation System, Revision 81

OP-164-002, Reactor Recirculation System HIMI Operations, Revision 9

Condition Reports

(*NRC identified)

CR-1093815

CR-1259874

CR-293289

CR-55991

CR-583298

CR-693556

CR-783341

CR-830292

CR-955607

CR-2015-32134

CR-2015-30101

CR-2015-29858

CR-2015-30215

Maintenance Orders/Work Orders

1779634

Drawings

M-155, Unit 1 P&ID High Pressure Coolant Injection, Sheet 1, Revision 58 M-156, Unit 1 P&ID HPCI Turbine Pump, Sheet 1, Revision 38 M-156, Unit 1 HPCI Lubricating and Control Oil P&ID, Sheet 2, Revision 10

Miscellaneous

IOM-13, HPCI Vendor Manually, Revision 37

Section 1R15: Operability Determinations and Functionality Assessments

Procedures

TP-164-045, Local System Leakage Test of Reactor Recirculation Loops A & B, Revision 5

MT-052-002, Unit 1 and Unit 2 HPCI Turbine Maintenance, Revision 14

OP-152-001, HPCI System, Revision 59

NDAP-QA-and Safety Function Determination Program, Revision 18

PSP-30, SSES Tactics for Excellence through Accountable Management (Team), Revision 16

SE-030-002B, 24 Month Control Structure Ventilation System Operability Test, Div II, Revision 3

SI-180-306, 24 Month Calibration of RWCU, PCIS, Secondary Containment Isolation, and CREOASS Initiation on Reactor Vessel Water Level 2 and MSIV Isolation on Reactor Vessel Water Level 1 for Channels

LITS-B21-1N026A&C

Condition Reports

(*NRC identified)

CR-1093815

CR-1259874

CR-293289

CR-55991

CR-583298

CR-693556

CR-783341

CR-830292

CR-955607

CR-2015-32134

CR-2015-29412

CR-2015-33033

CR-2015-26455

CR-2015-31181

CR-2015-26475

CR-2015-25476

CR-2015-26442

CR-2015-31802*

Maintenance Orders/Work Orders

1913719

1630684

1823252

1762531

775211

1755925

Drawings

M-143, Unit 1 P&ID Reactor Recirculation, Sheet 1, Revision 49 M-143, Unit 1 P&ID Reactor Recirculation, Sheet 2, Revision 14 M-143, Unit 1 P&ID Reactor Recirculation, Sheet 3, Revision 4 M-143, Unit 1 P&ID Reactor Recirculation, Sheet 4, Revision 1 M-144, Unit 1 P&ID Reactor Water Clean-Up, Sheet 1, Revision 45 E-151, Unit 2 Schematic Diagram Reactor Recirculation Pump Discharge Bypass Valve,

Sheet 29, Revision 24 M-155, Unit 1 P&ID High Pressure Coolant Injection, Sheet 1, Revision 58 M-156, Unit 1 P&ID HPCI Turbine Pump, Sheet 1, Revision 38 M-156, Unit 1 HPCI Lubricating and Control Oil P&ID, Sheet 2, Revision 10

Miscellaneous

IOM-13, HPCI Vendor Manually, Revision 37 0-TS-14-INOP for

SO-030-B03 Flow Verification Plan of the day meeting, September 29, 2015 04:42 Plan of the day meeting, September 30, 2015 04:42

Section 1R18: Plant Modifications

Procedures

EO-000-102, RPV Control, Revision 13

EP-DS-002, RPV and Primary Containment Flooding

SAG-2, Revision 8

EO-000-102, RPV Control, Revision 12

EP-DS-002, RPV and Primary Containment Flooding, Revision 7

SC-173-101, Unit 1 Primary Containment Activity Prior to Each Purge, Revision 10

EP-RM-004, EAL Classification Bases, Revision 3

EO-000-103, Primary Containment Control, Revision 13

Condition Reports

(*NRC identified)

CR-2015-15757

CR-2015-29968

Engineering Calculations

EC-RADN-0525, Estimation of Containment High Range Radiation Monitor Response to a Loss of Coolant Accident for Emergency Planning Purposes, Revision 2

Miscellaneous

S2015-04-15-02, 10CFR50.54q Screening Form EPFAQ Number 2015-005 50.59

SD 01666, EOP Upgrade to EPG/SAG, Revision 3 S2015-05-08-01, 10CFR50.54q Screening Form Regulatory Guide 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors

Section 1R19: Post-Maintenance Testing

Procedures

SO-150-002, Quarterly RCIC Flow Verification, Revision 52

SO-150-004, Quarterly RCIC Valve Exercising, Revision 34

SO-150-015, Two Year RCIC RPI Checks, Revision 12

PSP-29, Post Maintenance Testing Matrix, Revision 20

SO-184-006, MSIV Stroke Timing, Revision 8

SO-151-A02, Core Spray Flow Verification A Loop

DP-151-001, Core Spray A & C Drain Procedure While at Power, Revision 18

SE-159-400, RHR/Core Spray/HPCI/RCIC Component Post-Maintenance Closed System Testing, Revision 5

SO-151-A02, Quarterly Core Spray Flow Verification Division 1, Revision 24 24 Month Core Spray Division 1 System Remote Position Indicator (RPI) Checks, Revision 0 Monthly Core Spray A Loop Discharge Line Filled & Valve Alignment Verification, Revision 1

Condition Reports

(*NRC identified)

CR-2015-30958

CR-2015-31072

CR-2015-31012

CR-2015-27216

Maintenance Orders/Work Orders

1789416

1789469

1648924

1852049

1759028

1895241

1891623

1738013

1928363

1930693

1922010

Engineering Calculations

1946985

Miscellaneous

BOP-PT-15-349, Liquid Penetrant Examination

BOP-PT-15-345, Liquid Penetrant Examination

BOP-PT-15-348, Liquid Penetrant Examination

BOP-PT-15-346, Liquid Penetrant Examination

BOP-PT-15-347, Liquid Penetrant Examination

BOP-UT-15-129, UT Thickness Examination Clearance Order 51-001-1806756-0

Section 1R20: Refueling and Other Outage Activities

Procedures

GO-100-02, Plant Startup, Heatup and Power Operation, Revision 101

NDAP-QA-0309, Primary Containment Access and Control, Revision 33

SO-159-008, 24 Month Personnel Airlock Door Interlocks, Revision 9

OP-149-002, RHR Shutdown Cooling, Revision 69

GO-100-005, Plant Shutdown to Hot/Cold Shutdown, Revision 66

SO-100-011, Reactor Vessel Temperature and Pressure Recording, Revision 26

Condition Reports

(*NRC identified)

CR-2015-31207*

CR-2014-37999

CR-2015-31208*

CR-2015-30910

CR-2015-30474

CR-2015-30830

CR-2015-30924 CR-2015-30901

Section 1R22: Surveillance Testing

Procedures

SO-152-002, Quarterly HPCI Flow Verification, Revision 68

Maintenance Orders/Work Orders

1604740

1758057

1789469

1806752

1824718 1865806

Section 1EP2: Alert and Notification System Evaluation

Procedures

EP-108, Alert Notification SystemAmerican Signal Corporation Sirens, Revision 2

EP-109, Alert Notification System Annual TestAmerican Signal Corporation Sirens, Revision 1

EP-110, ANS Problem Solving, Revision 1

Miscellaneous

Susquehanna Steam Electric Station Emergency Plan, Revision 58 Susquehanna Nuclear Power Station, Siren Alert Notification System Design Evaluation, Final Report, dated September 2008 Letter from FEMA Region III Susquehanna Steam Electric Station, dated November 7, 2008 ANS Maintenance Records, November 2013

June 2015 ANS Testing Records, January 2014

October 2015

Section 1EP3: Emergency Response Organization Staffing and Augmentation System

Procedures

EP-008, Off-Site Agency Emergency Plan, Revision 0

EP-00-007, Testing of Emergency Communications Equipment, Revision 2

TQ-210-0310, Emergency Plan Overview (EP-100), Revision 2

Miscellaneous

Susquehanna Steam Electric Station Emergency Plan, Revision 58 Susquehanna Steam Electric Station On-Shift Staffing Analysis Report, Revision 0

Section 1EP4: Emergency Action Level and Emergency Plan Changes

Procedures

Susquehanna Emergency Plan, Revision 56 Susquehanna Emergency Plan, Revision 57 Susquehanna Emergency Plan, Revision 58

EP-PS-001, Emergency Planning Forms and Supplementary Instructions, Revision 5

EP-PS-101, TSC Emergency Director, Revision 31

EP-PS-104, Radiation Protection Coordinator, Revision 30

EP-PS-101, TSC Dose Calculator, Revision 23

EP-PS-200, Recovery Manager, Revision 31

EP-PS-244, EOF Dose Assessment Staffer, Revision 16

Section 1EP5: Maintenance of Emergency Preparedness

Procedures

EP-00-007, Testing of Emergency Communications Equipment, Revision 2

EP-00-006, Inventory Inspection and Operational Testing of Emergency Equipment and Supplies, Revision 5

EP-115, Equipment Important to Emergency Response (EITER), Revision 4

EP-102, Review, Revision and Distribution of the SSES Emergency Plan and 50.54(Q) Evaluations, Revision 5

NDAP-QA-0726, 10CFR 50.59 and10CFR 72.48 Implementation, Revision 17

LS-125, Corrective Action Program, Revision 3

Miscellaneous

ETE Annual Assessment, 2013 and 2014 Letters of Agreement/Memoranda of Understanding 2014, 2015 Susquehanna Steam Electric Station Emergency Plan, Revision 58 Audit

1689863, Audit Area 18; Emergency Preparedness, March 28, 2014 Audit 2015-01394, Emergency Preparedness, March 6, 2015

Section 1EP6: Drill Evaluation

Procedures

EP-PS-105, TSC Dose Calculator, Revision 24

EP-RM-004, MIDAS-

EP-PS-001-22, EOF Dose Assessment Flowchart, Revision 3

EP-PS-001-25, TSC Dose Assessment Flowchart, Revision 3

Condition Reports

(*NRC identified)

CR-2015-03695

CR-2015-04701

Miscellaneous

Susquehanna Steam Electric Station Emergency Plan, Revision 58

Section 2RS1: Access Control to Radiologically Significant Areas

Procedures

NDAP-QA-0623, Radiation Protection Standards and Responsibilities, Revision 1

NDAP-QA-0626, Radiologically Controlled Area Access and Radiation Work Permit (RWP) System, Revision 39

RP-122, Radiation Protection Stop Work Authority, Revision 0

HP-TP-500, Health Physics Radiological Survey Program, Revision 49

Condition Reports

(*NRC identified) 2015-25852

Section 2RS2: Occupational

ALARA Planning and Controls

Procedures

HP-AL-400, RWP ALARA Reviews and Evaluations, Revision 19

NDAP-QA-1191, ALARA Program and Policy, Revision 22

HP-TP-103, Plant Radiation Profile, Revision 4

Condition Reports

(*NRC identified) 2015-26927 2015-11899 2015-23961

Documents

RWP 20152118 Noble Metals Injection Mods in the RCA, Revision 0

RWP 20152120 RWCU Complex and BWRT Room General Work and Inspections, Revision 0

RWP 20152324 Recirculation Pump 2P401B Motor Replacement, Revision 0

RWP 20152336 Recirculation Pump Work, Revision 0 Water Chemistry Data from 2010-2015 Health Physics Technical Basis

AR-2015-03613 Unit 2 16th Outage Report Unit 2 17th Outage Report

Section 4OA1: Performance Indicator Verification

Procedures

SO-100-07, Daily Surveillance Operating Log, Revision 71

NDAP-QA-0737, Reactor Oversight Process (ROP) Performance Indicators, Revision 15

Condition Reports

(*NRC identified)

CR-2015-14721*

CR-2014-34399

CR-2015-19740

CR-2015-20925

CR-2014-07058

CR-2014-10288

CR-2014-12078

CR-2014-20248

CR-2014-32605

CR-2014-32851

CR-2014-32988

CR-2014-37227

CR-2015-05805

CR-2015-06976

CR-2015-07251

CR-2015-07254

CR-2015-17999

CR-2015-18919

CR-2015-19164

CR-2015-19189

CR-2015-20653

Action Requests

AR-2014-21608

AR-2014-21496

AR-2015-14740

AR-2015-19415

AR-2015-19415

Drawings

V-178, Logic Diagram Control Structure HVAC Isolation Signals, Sheet 14, Revision 7 V-178, Logic Diagram Control Structure HVAC Emer OA Supply Fans

OV-101A&B, Sheet 2, Revision 7 E-214, Common Schematic Diagram Control Structure HVAC Chilled Wtr Sys Chilled Wtr Circ PPS, Sheet 4, Revision 28 M-178, Unit 1 P&ID Control Structure Air Flow Diagram, Sheet 1, Revision 35

Engineering Calculations

EC-RADN-1125, CRHE and Off Site Post LOCA Doses, Revision 6

EC-RISK-1165, MSPI Basis Document JUL12R1 Model Data Input, Revision 0

Miscellaneous

NEI-99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7

EWR-2015-22825

TM-OP-030-ST, Control Structure HVAC, Revision 11 SSES Unit 1&2 Issuance of Amendment Re: Implementation of Alternative Radiological Source Term (TAC Nos. MC8730 and MC8731), Mr. Britt T. McKinney, January 31, 2007 SSES Proposed Amendment No. 281 to License

NPF-14 and Proposed Amendment No. 251 to License

NPF-22: Application for License Amendment and Related TS Changes to Implement Full-Scope Alternative Source Term in Accordance with 10

CFR 50.67

PLA-5963, October 13, 2005 SSES Response to Generic Letter 2003-01 Control Room Habitability

PLA-5659, August 11, 2003 MSPI Cooling Water System, MSPI Derivation Report, Susquehanna Unit 1, September 2015 MSPI Cooling Water System, MSPI Derivation Report, Susquehanna Unit 2, September 2015 MSPI Residual Heat Removal System, MSPI Derivation Report, Susquehanna Unit 2, September 2015 MSPI Residual Heat Removal System, MSPI Derivation Report, Susquehanna Unit 1, September 2015

NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7 MSPI Basis Document, Revision 8 DEP PI data, October 2014

September 2015 ERO Drill Participation PI data, October 2014

September 2015 ANS Reliability PI data, October 2014

September 2015

Section 4OA2: Problem Identification and Resolution

Condition Reports

(*NRC identified)

CR-2015-27105

CR-2015-23100

CR-2015-28486

CR-2015-28232

CR-2015-25208

CR-2015-28612

CR-2016-00564

CR-2016-00551

CR-2015-32988

CR-2015-34009

CR-2015-31976

CR-2015-33482

CR-2015-33553

CR-2015-28017

CR-2015-26200

CR-2015-32988*

Miscellaneous

3Q15 Performance Assessment Report, November 10, 2015, Revision 1 2Q15 Performance Assessment Report, July 29, 2015 SSES Nuclear Oversight Station Summary Report May 2015 through August 2015,

October 1, 2015

Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion

Procedures

SI-183-207, Quarterly Test of Main Steam Line C Flow Channels

FIS-B21-IN008A&B and

Main Steam Line D Flow Channels

FIS-B21-1N009A&B. Revision 14

MT-AD-509, Control of Minor Maintenance Activities, Revision 19

OP-AD-327, Post Reactor Transient/Scram/Shutdown Evaluation, Revision 31

Condition Reports

(*NRC identified)

CR-2015-30974

CR-2015-30975

CR-2015-30973

CR-2015-30971

CR-2015-30984

CR-2015-30759

CR-2015-30706

CR-2015-30711

CR-2015-30721

CR-2015-30728

CR-2015-30745

CR-2015-30746

CR-2015-30748

CR-2015-30753

CR-2015-30754

CR-2015-30756

CR-2015-30762

CR-2015-30764

CR-2015-30928

CR-2015-31290

CR-2015-31219

CR-2015-31293

CR-2015-31081

CR-2015-31069

CR-2015-31063

CR-2015-30983

CR-2015-30721

CR-2015-30092

Action Requests

AR-2015-30786

Maintenance Orders/Work Orders

1641281

1945473

1923252

1809437

Drawings

E-151, Unit 1 Schematic Diagram Reactor Recirculation Pump Trip Anticipated Transient without Scram, Sheet 35, Revision 7

Engineering Calculations

EC-INST-1333, I&C Maintenance Calculation for LISB211N025A, Revision 0

LIST OF ACRONYMS

ADAMS Agencywide Documents Access and Management System

AC alternating current

ADS automatic depressurization system

ALARA as low as is reasonably achievable

ANS alert and notification system

ARI alternate rod insertion Blue Max station portable diesel generator

CAP corrective action program

CFR Code of Federal Regulations

CR condition report

CREOAS S control room emergency outside air supply system

DC direct current

EAL emergency action level

EOF emergency operations facility

EOP emergency operating procedure

EP emergency preparedness

ERF emergency response facility

ERO emergency response organization

ESW emergency service water

FEMA Federal Emergency Management Agency

FSAR final safety analysis report

HPCI high-pressure coolant injection

HRA high radiation area

I&C instrument and controls

IMC Inspection Manual chapter

LCO limiting condition for operation

MSIV main steam isolation valve

NCV non-cited violation

NEI Nuclear Energy Institute

NRC Nuclear Regulatory Commission

NSIR Office of Nuclear Security and Incident Response

NVLAP National Voluntary Laboratory Accreditation Program

ODCM offsite dose calculation manual

OWA operator workarounds

PCIV primary containment isolation valve

PI performance indicator

PMT post maintenance testing

RB reactor building

RCIC reactor core isolation cooling

RCS reactor coolant system

RG regulatory guide

RHR residual heat removal

RHRSW residual heat removal service water

RP radiation protection

RPM radiation protection manager

RPS reactor protection system

RRP reactor recirculation pump

RTP rated thermal power

RWP radiation work permit

SBGT standby gas treatment

SCIS secondary containment isolation system

SDP significance determination process

SOW system outage window

SSC structure, system and component

SSES Susquehanna Steam Electric Station

TRO technical requirement for operation

TS technical specification

TSC technical support center

UFSAR Updated Final Safety Analysis Report VHRA very high radiation area