IR 05000387/2016001

IR 05000387/2016001; 05000388/2016001; Susquehanna Steam Electric Station, Integrated Inspection Report (Jan 1, 2016 - Mar 31, 2016)

ML16132A421
Person / Time
Site:	Susquehanna
Issue date:	05/12/2016
From:	Daniel Schroeder Reactor Projects Region 1 Branch 4
To:	Rausch T Susquehanna
SCHROEDER, DL
References
IR 2016001
Download: ML16132A421 (40)

Text

{{#Wiki_filter:May 12, 2016

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION - INTEGRATED INSPECTION REPORT 05000387/2016001 AND 05000388/2016001

Dear Mr. Rausch:

On March 31, 2016, 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 April 22, 2016 with you and other members of your staff.

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

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

The inspectors documented two findings of very low safety significance (Green) in this report.

Both of these findings involved violations of NRC requirements. Additionally, NRC inspectors documented one Severity Level IV violation with no associated finding. Further, inspectors documented two licensee-identified violations which were determined to be of very low safety significance in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the 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, or a finding not associated with a regulatory requirement 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 Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access and 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 05000387/2016001 and 05000388/2016001 w/Attachment: Supplementary Information

REGION I== Docket Nos.: 50-387 and 50-388 License Nos.: NPF-14 and NPF-22 Report No.: 05000387/2016001 and 05000388/2016001 Licensee: Susquehanna Nuclear, LLC (Susquehanna) Facility: Susquehanna Steam Electric Station, Units 1 and 2 Location: Berwick, Pennsylvania Dates: January 1, 2016 through March 31, 2016 Inspectors: J. Greives, Senior Resident Inspector T. Daun, Resident Inspector P. Meier, Project Engineer N. Floyd, Reactor Inspector Approved By: Daniel L. Schroeder, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY

IR 05000387/2016001, 05000388/2016001; January 1, 2016 to March 31, 2016; Susquehanna

Steam Electric Station, Units 1 and 2; Follow-Up of Events and Notices of Enforcement Discretion, Maintenance Risk Assessments and Emergent Work Control, and Problem Identification and Resolution.

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 (NCVs), all of which were of very low safety significance (Green and/or Severity Level IV). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within Cross-Cutting Areas, dated December 4, 2014.

All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated February 4, 2015. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

Cornerstone: Initiating Events

Green.

A self-revealing finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was identified for Susquehannas failure to establish measures to assure a condition adverse to quality was corrected. Specifically, vibration induced fatigue cracking on the Unit 1 B reactor recirculation pump (RRP) lower seal cavity vent piping was not corrected in December 2014 after a reactor coolant pressure boundary leak had occurred. This resulted in another reactor coolant pressure boundary leakage at the same location with Unit 1 operating in Mode 1, a condition prohibited by technical specifications (TS) LCO 3.4.4. Susquehannas entered the issue into the corrective action program (CAP) as CR-2015-30901 and replaced and modified the union that included the weld.

The finding was more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors evaluated the finding in accordance with Exhibit 1 of IMC 0609, Appendix A, The significance determination process (SDP) for Findings At-Power, and determined the finding was of very low safety significance (Green) because the leakage would not have exceeded the reactor coolant system (RCS) leak rate for a small loss of coolant accident (LOCA) and it did not affect other systems used to mitigate a LOCA. This finding had a cross-cutting aspect in the area of Human Performance, Work Management, because Susquehanna did not implement a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority, in that Susquehanna did not adequately coordinate the work activities with different groups [H.5]. Specifically, welding engineers were not engaged in the decision making process during the December 2014 repair and consequently the repair was inadequate to ensure the entire crack had been removed. [4OA3]

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green NCV of 10 CFR 50.65(a)(4) because Susquehanna did not adequately assess the risk of performing maintenance in accordance with station procedures. Specifically, Susquehanna did not assess the risk of performing a standby liquid control (SLC) system flow surveillance in conjunction with having the D emergency diesel generator (EDG) unavailable and therefore did not specify appropriate risk management actions (RMAs). Susquehanna entered the issue into the CAP as CR-2016-04137.

The inspectors determined that this performance deficiency is more than minor because it was associated with the Human Performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).

Additionally, the finding is similar to example 7.e. in NRC IMC 0612 Appendix E, Examples of Minor Issues. This example states, in part, that failure to perform an adequate risk assessment when required by 10 CFR 50.65 (a)(4) is not minor if the overall elevated plant risk would put the plant into a higher licensee-established risk category or would require, under plant procedures, RMAs or additional RMAs. In this case, the combination of the D EDG maintenance and SLC flow surveillance resulted in changing risk to Yellow which required additional RMAs in accordance with station procedures. The inspectors evaluated the finding using IMC 0609 Appendix K, Maintenance Risk Assessment and Risk Management SDP. The inspectors and the Region I senior resident analyst used Appendix K, Flowchart 1, Assessment of Risk Deficit, and determined that the inadequate risk assessment was of very low safety significance (Green). The basis for this determination was that the short duration of the actual planned maintenance activities (3.5 hours)associated with the SLC unavailability results in less than E-9 calculated incremental core damage probability deficit (ICDPD) using Susquehannas risk model. Since the resultant ICDPD is below 1 E-8 threshold, the finding was determined to be

Green.

This finding was determined to have a cross-cutting aspect in the area of Human Performance, Work Management in that Susquehanna did not appropriately incorporate insights from probabilistic risk assessments into the daily work activities [H.5]. Specifically, Susquehanna did not appropriately assess the risk of performing maintenance activities as specified in station procedures. [1R13]

Cornerstone: Other

SLIV. Inspectors identified a Severity Level IV NCV of 10 CFR Part 50.73 (a)(2)(v) when Susquehanna did not submit a licensee event report (LER) within 60 days of identifying that both trains of the control room emergency outside air supply system (CREOASS) were rendered inoperable during surveillance testing, a condition that could have prevented fulfillment of a safety function. Susquehanna entered the issue into the CAP as CR-2016-03713 and reported the condition on May 5, 2016 in LER 50-388(387)/2015-015.

Since the issue had the potential to affect the NRCs ability to perform its regulatory function, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process. Using example 6.9.d.9 from the NRC Enforcement Policy, the inspectors determined that it was a Severity Level IV violation. The significance of the associated performance deficiency was also screened against the reactor oversight process (ROP) per the guidance of IMC 0612, Appendix B, "lssue Screening. Because this violation involves the traditional enforcement process and does not have an associated finding under the ROP, inspectors did not assign a cross-cutting aspect to this violation. [4OA2]

Other Findings

Violations of very low safety significance that were identified by Susquehanna were reviewed by the inspectors. Corrective actions taken or planned by Susquehanna have been entered into Susquehannas CAP. These violations and corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at 100 percent rated thermal power (RTP). On January 8, 2016, operators reduced reactor power to approximately 75 percent RTP to perform a rod pattern adjustment and power was restored to 100 percent the following day. On January 16, 2016, operators reduced power to 85 percent to perform a planned rod pattern adjustment and power was restored to 100 percent on January 17, 2016. On January 24, 2016, operators reduced power to 80 percent to perform a planned rod pattern adjustment and power was restored to 100 percent on January 25, 2016. On January 30, 2016, operators commenced an end of cycle coast down for a planned refueling outage. During the coast down, operators reduced power from 89 percent to 67 percent to perform a planned rod pattern adjustment.

Power was restored to approximately 87 percent and the coast down was resumed on March 3, 2016. On March 11, 2016, operators performed a shutdown for a planned refueling outage.

Unit 1 remained shutdown in Mode 5 for the remainder of the inspection period.

Unit 2 began the inspection period at 100 percent power and operated at full power until January 15, 2016, when operators reduced reactor power to 71 percent RTP for a planned rod sequence exchange. Power was restored to 100 percent on January 16, 2016 and remained at or near 100 percent power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

==1R04 Equipment Alignment

.1 Partial System Walkdowns

==

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems: Unit 1, A core spray (CS) during B CS system outage window (SOW) on January 13, 2016 Common, restoration of E EDG following mid-cycle overhaul on February 1, 2016 (vertical inspection) Unit 1, division II residual heat removal (RHR) during division I RHR SOW on February 10, 2016 Unit 1, division I shutdown cooling on March 13, 2016 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, TS, work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted the systems performance of its intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Susquehanna staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings

No findings were identified. ==1R05 Fire Protection