IR 05000387/2013005
| ML14045A295 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 02/14/2014 |
| From: | Fred Bower Reactor Projects Region 1 Branch 4 |
| To: | Rausch T Susquehanna |
| References | |
| EA-13-187 IR-13-001, IR-13-005 | |
| Download: ML14045A295 (58) | |
Text
{{#Wiki_filter:ary 14, 2014
SUBJECT:
SUSQUEHANNA STEAM ELECTRIC STATION - NRC INTEGRATED INSPECTION REPORT 05000387/2013005 AND 05000388/2013005, AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION REPORT NO.
07200028/2013001
Dear Mr. Rausch:
On December 31, 2013 the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Susquehanna Steam Electric Station (SSES) Units 1 and 2. The enclosed integrated inspection report documents the inspection results, which were discussed on January 24, 2014, with Jeff Helsel, Plant Manager, and other members of your staff.
This inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents three NRC-identified findings of very low safety significance (Green).
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 the 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, D.C. 20555-0001; with copies to the Regional Administrator Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Senior 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 Senior Resident Inspector at SSES.
As a result of the Safety Culture Common Language Initiative, the terminology and coding of cross-cutting aspects were revised beginning in calendar year (CY) 2014. New cross-cutting aspects identified in CY 2014 will be coded under the latest revision to IMC 0310. Cross-cutting aspects identified in the last six months of 2013 using the previous terminology will be converted to the latest revision in accordance with the cross-reference in IMC 0310. The revised cross-cutting aspects will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the CY 2014 mid-cycle assessment review.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRCs "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely, /RA/ Fred L. Bower, III, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 50-387; 50-388 License Nos. NPF-14, NPF-22
Enclosures:
Inspection Report 05000387/2013005, 05000388/2013005 and 07200028/2013001 w/Attachment: Supplemental Information
REGION I== Docket No: 50-387, 50-388, 72-28 License No: NPF-14, NPF-22 Report No: 05000387/2013005, 05000388/2013005 and 07200028/2013001 Licensee: PPL Susquehanna, LLC (PPL) Facility: Susquehanna Steam Electric Station, Units 1 and 2 Location: Berwick, Pennsylvania Dates: October 1, 2013 through December 31, 2013 Inspectors: J. Greives, Senior Resident Inspector T. Daun, Resident Inspector A. Turilin, Acting Resident Inspector S. Barr, Senior Emergency Preparedness Inspector R. Rolph, Health Physicist D. Kern, Senior Reactor Inspector J. Nicholson, Health Physicist J. DAntonio, Senior Operations Engineer T. Hedigan, Operations Engineer Approved By: Fred L. Bower, III, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY
IR 05000387/2013005, 05000388/2013005, 07200028/2013001, 10/01/2013 - 12/31/2013;
Susquehanna Steam Electric Station, Units 1 and 2; Flood Protection Measures, Surveillance Testing, and Drill Evaluation.
The report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified three findings of very low safety significance (Green), which were NCVs. 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 (SDP), dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Components Within The Cross-Cutting Areas, dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated January 28, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4.
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a Green NCV of Technical Specifications (TS) 5.4.1, Procedures, because PPLs procedures EO-000-104, Secondary Containment Control and ON-169-002, Flooding in the Reactor Building were inadequate in that actions directed in the procedures could complicate an internal flooding event and may adversely affect aspects of PPLs flood design. Specifically, the procedures directed operators to enter a flooded room to assess the extent and source of the flooding; an action which could render multiple trains of emergency core cooling system (ECCS) inoperable due to communicating two watertight rooms. In addition to entering the issue into the CAP as Condition Reports (CRs)-2013-02099 and 2013-06417, PPL issued Operations Directive 13-07 which provided guidance to ensure that operators sent to investigate a room flooded alarm will do so in a manner that will not affect redundant trains.
The performance deficiency is more than minor because it was associated with the procedure quality attribute of the Mitigating Systems cornerstone and affected the objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the procedure to respond to a room flooded alarm was insufficient to ensure operator response would not potentially render multiple trains of ECCS inoperable. The finding was evaluated in accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibits 2 and 4 of IMC 0609, Appendix A, The SDP for Findings At-Power. Since opening the watertight door with excessive flooding could bypass the flood protection feature and potentially degrade two or more trains of a multi-train system or function, a detailed risk assessment was performed. The condition was modeled using the Susquehanna standardized plant analysis risk (SPAR) model version 8.19 along with SAPHIRE version 8.09. As a bounding analysis, the condition was assumed to exist for greater than one year and the flooding was assumed to require a reactor shutdown which results in a plant transient with failure of high pressure coolant injection (HPCI) and core spray (CS) due to flood impacts. The flooding initiating event frequency was estimated to be about 1 in 10,000 years. The resulting change in core damage frequency was substantially less than 1E-7. The dominant sequences included a transient with a loss of all direct current (DC) power and a transient with failures to depressurize and reactor core isolation cooling (RCIC) failures. Since the change in core damage frequency was sufficiently low no further evaluation for large early release was required. The finding is related to the cross-cutting area of PI&R, Self and Independent Assessments, in that PPL did not conduct assessments to identify areas for improvement. In particular, the self-assessments were not of sufficient depth, comprehensive, appropriately objective, or self-critical. Specifically, despite PPLs process requiring periodic verification that event driven procedures are technically and functionally correct, the periodic review completed in April 2013 failed to identify that actions specified in the procedure could invalidate the flood design. [P.3(a)]. (Section 1R06)
Cornerstone: Barrier Integrity
- Green.
The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XI, Test Control, because PPL did not ensure all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service was identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Specifically, PPLs procedure used to implement the requirements of TS Surveillance Requirements (SR)3.6.4.1.4 and 3.6.4.1.5 did not ensure that secondary containment integrity was tested in all required configurations. PPLs immediate corrective actions included entering the issue into their CAP as CR-2013-03891 and applied a status control tag to the railroad access bay door-101 as an administrative control until corrective actions can be completed and the configuration tested satisfactorily.
The finding is more than minor because it is associated with the procedure quality attribute of the Barrier Integrity cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events.
Specifically, the inadequate surveillance procedure resulted in missed surveillances for SRs 3.6.4.1.4 and 3.6.4.1.5. Additionally, it was similar to example 3.d in IMC 0612 Appendix E, Examples of Minor Issues, in that the failure to implement the TS SR as required is not minor if the surveillance had not been conducted. In this case, the surveillance requirement had not been completed for all configurations of secondary containment. In accordance with IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, The SDP for Findings At-Power, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency only represented a degradation of the radiological barrier function provided for the Standby Gas Treatment system. This finding was determined to have a cross-cutting aspect in the area of Human Performance Resources area because the licensee failed to ensure that personnel, equipment, procedures, and other resources are available and adequate to assure nuclear safety.
Specifically, those necessary for: complete, accurate and up-to-date design documentation, procedures, and work packages, and correct labeling of components [H.2(c)]. (Section 1R22)
Cornerstone: Emergency Preparedness
- Green.
The inspectors identified a Green NCV of 10 CFR 50.54, Conditions of Licenses, paragraph (q), because PPL did not maintain the Emergency Plan to adequately meet the standards of 50.47(b). Specifically, PPL did not have temperature indication installed in some areas of the reactor building that are required to support assessment and determination of entry conditions into the fission product barrier emergency action levels (EALs). PPL entered this issue into their CAP as CR 1727229.
The inspectors determined that the failure to have temperature indication installed in certain areas of the reactor building was a performance deficiency that was within PPLs ability to foresee and correct. The performance deficiency is more than minor because it is associated with the Facilities and Equipment attribute 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. Specifically, the lack of installed temperature instrumentation and the reliance on local temperature indications were insufficient to ensure a timely and accurate EAL classification could be made. Using IMC 0609, Appendix B, section 5.4, the finding is of very low safety significance (Green) because the finding was determined to be an example of an ineffective EAL initiating condition, such that a Site Area Emergency would be declared in a degraded manner. The cause of this finding has a cross-cutting aspect in the area of Human Performance Resources because PPL did not ensure that facilities and equipment were adequate and available, including emergency facilities and equipment. Specifically, PPL did not provide temperature instrumentation to operators to ensure a timely and accurate declaration of an emergency for an un-isolable reactor coolant leak in the reactor building. [H.2.d]. (Section 1EP6)
Other Findings
One Severity Level IV violation that was identified by PPL was reviewed by the inspectors.
Corrective actions taken or planned by the licensee have been entered into the licensees CAP. This violation and corrective action tracking number are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Unit 1 began the inspection period at or near 100 percent rated thermal power (RTP). On November 1, 2013, operators lowered power on Unit 1 to 64 percent for a planned rod sequence exchange. Power was returned to 100 percent on November 3, 2013. On November 10, 2013, Unit 1 performed an unplanned power reduction to 57 percent due to a trip of the running turbine building chiller. Power was restored to 98 percent on November 12, 2013. On November 29, 2013, Unit 1 power was reduced to 90 percent to perform unplanned emergent cleaning of the cooling tower screens. Power was restored to 100 percent the same day and Unit 1 ended the inspection period at or near 100 percent power.
Unit 2 began the inspection period at or near 100 percent RTP. On October 24, 2013, power was reduced to 60 percent on Unit 2 for grid-related maintenance. Power was restored to 100 percent on October 25, 2013. On November 22, 2013, power was reduced on Unit 2 to 67 percent for a planned rod sequence exchange. Unit 2 was restored to 100 percent on November 23, 2013. On November 29, 2013, Unit 2 power was reduced to 90 percent to perform unplanned emergent cleaning of the cooling tower screens. Power was restored to 100 percent the same day and Unit 2 ended the inspection period at or near 100 percent power.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
The inspectors performed a review of PPLs readiness for the onset of seasonal extreme low temperatures on October 31 - November 22, 2013. The review focused on the engineered safeguards service water (ESSW) pump house, exposed portions of the condensate and refueling water storage system and the circulating water pump house.
The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), technical specifications, control room logs, and the CAP to determine what temperatures or other seasonal weather could challenge these systems, and to ensure PPL personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including PPLs seasonal weather preparation procedure and applicable operating procedures. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during cold weather conditions. Documents reviewed for each section of this inspection report are listed in the Attachment.
b. Findings
No findings were identified.
.2 Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
The inspectors reviewed PPLs preparations in advance of and during warnings and advisories issued by the National Weather Service for a tornado watch and high winds on October 7, 2013. The inspectors performed walkdowns of areas that could be potentially impacted by the weather conditions, such as station blackout and emergency diesel generators (EDGs), station transformers, switchyards, and verified that station personnel secured loose materials staged for outside work prior to the forecasted weather. The inspectors verified that PPL staff monitored the approach of adverse weather according to applicable procedures and took appropriate actions as required.
The inspectors reviewed the UFSAR, Technical Specifications (TSs), control room logs, and the CAP to determine what temperatures or other seasonal weather could challenge these systems, and to ensure PPL personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including PPLs seasonal weather preparation procedure and applicable operating procedures.
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 I residual heat removal (RHR) during Division II RHR work window on November 6, 2013
- Unit 1, RCIC during HPCI work window on December 2, 2013
- Unit 2, Division II 125V DC distribution, December 30, 2013
- Common, D EDG during T-10 unavailability on October 21, 2013 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 (WOs), CRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether PPL staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
From October 18 - 23, 2013, the inspectors performed a complete system walkdown of accessible portions of the Unit 2 HPCI 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, equipment cooling, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the system to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the HPCI system components while in the standby condition to ensure no deficiencies existed. The inspectors also reviewed the latest surveillance test results to ensure operating parameters were in accordance with the design requirements of the system.
Additionally, the inspectors reviewed a sample of related CRs and WOs to ensure PPL appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified. ==1R05 Fire Protection