IR 05000387/2006004
Download: ML063040665
Text
October 31, 2006
Mr. Britt T. McKinneySenior Vice President, and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Boulevard - NUCSB3 Berwick, PA 18603-0467
SUBJECT: SUSQUEHANNA STEAM ELECTRIC STATION - NRC INTEGRATEDINSPECTION REPORT 05000387/2006004 AND 05000388/2006004
Dear Mr. McKinney:
On September 30, 2006, the US Nuclear Regulatory Commission (NRC) completed aninspection at your Susquehanna Steam Electric Station Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on October 6, 2006, with you and other members of your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.The report documents one NRC-identified finding of very low safety significance (Green). The finding was determined to involve a violation of NRC requirements. However, because of thevery low safety significance and because it is entered into your corrective action program, the NRC is treating the finding as a non-cited violation (NCV), consistent with Section VI.A.1 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 Resident Inspector at the Susquehanna Steam Electric Station.
B. McKinney2In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publically Available Records (PARS) component of the NRC's document 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/James M. Trapp, ChiefProjects Branch 4 Division of Reactor ProjectsDocket Nos.50-387, 50-388License Nos.NPF-14, NPF-22
Enclosures:
Inspection Report 05000387/2006004 and 05000388/2006004
w/Attachment:
Supplemental Informationcc w/encls:R. A. Saccone, Vice President - Nuclear Operations T. L. Harpster, General Manager - Plant Support R. D. Pagodin, General Manager - Nuclear Engineering R. R. Sgarro, Manager - Nuclear Regulatory Affairs W. E. Morrissey, Supervisor, Nuclear Regulatory Affairs M. H. Crowthers, Supervising Engineer, Nuclear Regulatory Affairs S. Cook, Manager - Quality Assurance L. A. Ramos, Community Relations Manager, Susquehanna B. A. Snapp, Esquire, Associate General Counsel, PPL Services Corporation Supervisor - Document Control Services R. W. Osborne, Allegheny Electric Cooperative, Inc.
Director - Bureau of Radiation Protection, PA Department of Environmental Protection Board of Supervisors, Salem Township J. Johnsrud, National Energy Committee B. McKinney3Distribution w/encls:(via E-mail)S. Collins, RAM. Dapas, DRA J. Trapp, DRP C. Khan, DRP A. Blamey, DRP - SRI Susquehanna F. Jaxheimer, DRP - RI Susquehanna S. Farrell, DRP - Susquehanna OA B. Sosa, RI OEDO R. Laufer, NRR R. Guzman, PM, NRR T. Colburn, PM (backup), NRR Region I Docket Room (with concurrences)ROPreports@nrc.gov SUNSI Review Complete: JMT (Reviewer's Initials)DOCUMENT NAME: C:\FileNet\ML063040665.wpdAfter declaring this document "An Official Agency Record" it will be released to the Public.To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copyOFFICERI/DRPRI/DRPRI/DPRENAMEABlamey/JMTFORCkhan/JMT FORJTrapp/DATE10/ 31 /0610/ 31 /0610/ 31 /06OFFICIAL RECORD COPY EnclosureiU.S. NUCLEAR REGULATORY COMMISSIONREGION IDocket Nos.:50-387, 50-388 License Nos.:NPF-14, NPF-22 Report No.:05000387/20060004 and 05000388/2006004 Licensee:PPL Susquehanna, LLC (PPL)
Facility:Susquehanna Steam Electric Station, Units 1 and 2 Location:Berwick, Pennsylvania Dates:July 1, 2006 through September 30, 2006 Inspectors:A. Blamey, Senior Resident InspectorF. Jaxheimer, Resident Inspector J. Furia, Senior Health Physicist C. Bickett, Resident InspectorApproved by:James M. Trapp, ChiefReactor Projects Branch 4 Division of Reactor Projects Enclosureii
SUMMARY OF FINDINGS
IR 05000387/2006-004, 05000388/2006-004; 07/01/2006 - 09/30/2006; Susquehanna SteamElectric Station, Units 1 and 2; Maintenance Risk Assessments and Emergent Work Control.The report covered a 3-month period of inspection by resident inspectors and announcedinspections by a regional senior health physicist. One Green finding, which was a non-citedviolation (NCV) was identified. The significance of most findings is indicated by their color(Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance
Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649,
"Reactor Oversight Process," Revision 3, dated July 2000.A.NRC Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a non-cited violation (NCV) of 10 CFR 50.65(a)(4), for an inadequate risk assessment. PPL did not correctly assess the risk associated with planned maintenance activities on the 'A' emergency service water pump and the diesel fire pump on August 25, 2006. PPL entered this deficiency into their corrective action program and revised the risk assessment to correctly assess plant risk. The finding is greater than minor because it was similar to Example 7.e in IMC0612, Appendix E, "Examples of Minor Issues," and because PPL underestimated the cumulative increase in core damage probability for ongoing planned maintenance which when correctly assessed placed Unit 2 into a higher risk category. The finding was determined to be of very low safety significance (Green) using Appendix K of Inspection Manual Chapter 0609, "Maintenance
Risk Assessment and Risk Management Significance Determination Process, "
using Flowchart 1, because the incremental core damage probability deficit was determined to be less than 1.0 E-6 and the incremental large early release probability deficit was determined to be less than 1.0 E-7. The finding has a cross-cutting aspect in the area of human performance because PPL's planned work activities did not effectively incorporate risk insights. (Section 1R13)
B. Licensee-Identified Violations
.None.
Enclosure
REPORT DETAILS
Summary of Plant StatusSusquehanna Steam Electric Station (SSES) Unit 1 started the inspection period with a powerreduction to approximately 20 percent rated thermal power (RTP) to replace a main turbine electrohydraulic control system card. Unit 1 returned to 100 percent RTP on July 2, 2006 and remained at 100 percent RTP for the remainder of the inspection period with the exception of two weekend power reductions to 75 percent RTP, in September to perform a control rod sequence exchange, turbine valve testing and control rod maintenance.
Unit 2 began the inspection period with a power ascension from 70 percent RTP to 100 percentRTP following a control rod sequence exchange on July 1, 2006. Unit 2 remained at 100 percent RTP power from July 2, 2006, until power was reduced to 75 percent RTP on July 16, 2006 to support scheduled transmission and distribution work. Unit 2 returned to 100 percent RTP on July 17, 2006 and remained at full RTP until a downpower for control rod sequence exchange on August 26, 2006. This power reduction was extended, due to a stuck control rod. Reactor power returned to 100 percent RTP on August 29, 2006. Unit 2 ended the inspection period with a reactor shutdown on September 29, 2006 for a scheduled outage to perform fuel channel replacement and a fuel shuffle to address the ongoing control cell friction issue.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity1R01Adverse Weather Protection (71111.01- 1 Sample)
a. Inspection Scope
During the week of July 17, 2006, the inspectors reviewed PPL's preparations forextreme hot weather. Plant walkdowns for selected structures, systems and components (SSCs) were performed to determine the adequacy of PPL's weather protection activities. The inspectors also reviewed and evaluated plant conditions during extreme hot weather which occurred the week of July 31, 2006. Inspectors reviewed related considerations in PPL's Maintenance Rule (MR) station risk assessment and maintenance work scheduling. The readiness of the following systems was reviewed.Emergency service water (ESW), residual heat removal service water (RHRSW),and the ultimate heat sink with outside air temperatures greater than 95F.
b. Findings
No findings of significance were identified.
R04 Equipment Alignment
(71111.04Q - 3 Samples).1Partial Walkdown
a. Inspection Scope
The inspectors performed partial walkdowns to verify system and component alignmentand to note any discrepancies that would impact system operability. The inspectors verified selected portions of redundant or backup systems or trains were available while certain system components were out-of-service (OOS). The inspectors reviewed selected valve positions, electrical power availability, and the general condition of major system components. The equipment configuration was then compared to plant drawings, operating procedures and design documents to verify the operability of the systems. The walkdowns included the following systems:Units 1 and 2, compressed instrument gas systems including 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> air bottleson Unit 1Units 1 and 2, EWS to emergency diesel generators (EDGs) and cross connectsbetween 'A' and 'B' flow loopsUnit 2 Division I residual heat removal (RHR)
b. Findings
No findings of significance were identified.1R05Fire Protection (71111.05 - 10 Samples)
.1 Fire Protection - Tours
a. Inspection Scope
The inspectors reviewed PPL's fire protection program to determine the required fireprotection design features, fire area boundaries, and combustible loading requirements for selected areas. The inspectors walked down those areas to assess PPL's control of transient combustible material and ignition sources, fire detection and suppression capabilities, fire barriers, and any related compensatory measures to assess PPL's fire protection program in those areas. The inspected areas included:Common, 'E' - EDG Building, fire zone 0-41E.Common, Security Control Center, fire zone 0-83, FP-013-360Common, Low Level Radwaste Building - offsite responder fire drillCommon, 'D'- EDG Building, fire zone 0-41D Units 1 and 2, Battery and Battery Charger Rooms, fire zones 0-28A, B, F, K,& L Unit 1 Switchgear Rooms, fire zones 1-4C, 1-4D (reactor building elevation 719')FP-113-115
Unit 1 reactor recirculation motor generator set area, fire zone 1-35C,FP-113-234Unit 1 turbine building basement, fire zone 1-31FUnit 2 Switchgear Rooms fire zone 2-4C, 2-4D (reactor building elevation 719')FP-213-250Unit 2 Reactor Building elevation 683 foot fire zone 2-3B-N,S; FP-213-245, 246
b. Findings
No findings of significance were identified.1R11Licensed Operator Requalification Program (71111.11Q - 1 Sample).1Resident Inspector Quarterly Review
a. Inspection Scope
On September 6, 2006, the inspectors observed licensed operator performance in thesimulator during operator requalification training. The inspectors compared the operators' actions to Technical Specification requirements, emergency plan procedures, and emergency operating procedures. The inspectors also evaluated PPL's critique of the operators' performance to identify discrepancies and deficiencies in operator training. The following training scenario was observed:Licensed operator requalification simulator exam scenarios onSeptember 6, 2006, which included the failure of an automatic scram and other equipment malfunctions.
b. Findings
No findings of significance were identified.1R12Maintenance Effectiveness (71111.12Q - 1 Sample)
a. Inspection Scope
The inspectors evaluated PPL's work practices and follow-up corrective actions forselected SSC issues to assess the effectiveness of PPL's maintenance activities. The inspectors reviewed the performance history of those SSCs and assessed PPL's extent of condition determinations for these issues with potential common cause or generic implications to evaluate the adequacy of PPL's corrective actions. The inspectors reviewed PPL's problem identification and resolution actions for these issues to evaluate whether PPL had appropriately monitored, evaluated, and dispositioned the issues in accordance with PPL procedures and the requirements of 10 CFR 50.65,
"Requirements for Monitoring the Effectiveness of Maintenance." In addition, the inspectors reviewed selected SSC classification, performance criteria and goals, and
PPL's corrective actions that were taken or planned, to verify whether the actions werereasonable and appropriate. The following issues were reviewed:Units 1 and 2 electrolytic capacitor components following MR functional failureand missed preventive maintenance (PMs), Condition Report 753990
b. Findings
No findings of significance were identified.1R13Maintenance Risk Assessments and Emergent Work Control (71111.13 - 6 Samples)
a. Inspection Scope
The inspectors reviewed the assessment and management of selected maintenanceactivities to evaluate the effectiveness of PPL's risk management for planned and emergent work. The inspectors compared the risk assessments and risk management actions to the requirements of 10 CFR 50.65(a)(4) and the recommendations of NUMARC 93-01, Section 11, "Assessment of Risk Resulting from Performance of Maintenance Activities." The inspectors evaluated the selected activities to determine whether risk assessments were performed when required and appropriate risk management actions were identified.The inspectors reviewed scheduled and emergent work activities with licensed operatorsand work-coordination personnel to verify whether risk management action threshold levels were correctly identified. In addition, the inspectors compared the assessed risk configuration to the actual plant conditions and any in-progress evolutions or external events to evaluate whether the assessment was accurate, complete, and appropriate for the emergent work activities. The inspectors reviewed PPLs on-line risk monitor
"Equipment Out of Service" (EOOS) inputs and results to gain insights into the risk associated with these plant configurations when appropriate. The inspectors performed control room and field walkdowns to verify whether the compensatory measures identified by the risk assessments were appropriately performed. The selected maintenance activities included:Units 1 and 2, 'D' EDG 80 pound air header regulator failure, CR 794122Units 1 and 2, 'E" EDG turbocharger overspeed engine trip and maintenanceoutage, CR 794697 Units 1 and 2, Reschedule of PM and surveillances during grid warnings and hotweather period, July 31 - August 3, 2006Units 1 and 2, Reschedule of station backout diesel PMs and 'C' EDGmodification due to emergent work on 'A' EDG (ESW leak and slow start), CR 804028 and 804034Unit 1 and 2, ESW check valve failure and repair, CR 806572Unit 2, refueling floor wall exhaust radiation monitor failure, CR 807670 and808572
b. Findings
Introduction.
The inspectors identified a Green NCV of 10CFR 50.65(a)(4) becausePPL performed an inadequate risk assessment for planned maintenance activities on the 'A' ESW pump and station diesel fire pump, which resulted in underestimating the risk associated with performing the associated maintenance activities on August 25, 2006.Description. On August 25, at 4:09 a.m., PPL removed the 'A' ESW pump from servicefor scheduled maintenance. Approximately two hours later, the inspectors observed that the station diesel fire pump remained out-of-service. Earlier in the week, when inspecting the rescheduling of station backout diesel PMs due to emergent work, the inspectors observed that the diesel fire pump was not included in the EOOS risk model calculation inputs after August 24, 2006. The Inspectors questioned if the risk calculation was updated and correct for the ongoing maintenance activities. PPL recalculated the risk for the ongoing maintenance activities in accordance with station procedure PSP-26, "ORAM-EOOS Program," and logged the results as being in the Green Risk category at 7:50 a.m.. When a peer check of the corrected calculation was performed several hours later it was determined that the calculation results were misinterpreted and that the actual results placed Unit 2 in the Yellow Risk category. The correct results were logged, reported to the control room and the inspectors by 12:40 p.m. on August 25, 2006.The inspectors noted that the risk inputs programmed into EOOS were recalculatedeach day based on a dynamic schedule which had changed significantly for the work week. Inspectors observed that the EOOS calculations were not properly updated for the diesel fire pump outage length. Station procedure, NDAP-QA-1902, "Maintenance Rule Risk Assessment and Management Program," requires (1) a risk assessment of scheduled maintenance be performed before maintenance is begun and (2) Risk Management Actions (RMAs) be considered for plant equipment configurations which result in plant risk exceeding risk management thresholds. RMAs were not properly considered or implemented for the maintenance activities on August 25, 2006, since the evaluation of plant risk was incorrect. PPL did not restore the diesel fire pump as scheduled due to lack of resources and then removed the 'A' ESW pump from service without a current risk evaluation. The 'A' ESW pump was restored to functional status approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> later. PPL initiated CR 805396 to document and correct this Maintenance Rule performance deficiency.
Analysis.
The inspectors determined that not performing an adequate risk assessmentprior to conducting online maintenance on the 'A' ESW pump while the diesel fire pump was in a system maintenance outage on August 25, 2006 constituted a performance deficiency and a finding. The finding, which was associated with the Mitigating Systems cornerstone, was more than minor because it was similar to Example 7.e in IMC 0612, Appendix E, "Examples of Minor Issues," and because PPL underestimated the cumulative increase in core damage probability for ongoing planned maintenance which, when correctly assessed, placed Unit 2 into a higher risk category. The finding was evaluated in accordance with Appendix K of Inspection Manual Chapter 0609,
"Maintenance Risk Assessment and Risk Management Significance DeterminationProcess," and determined to be of very low safety significance (Green), using Flowchart
1. This determination was based on the incremental core damage probability (ICDP) of
1E-09 and the incremental large early release probability (ILERP) of 1.3E-10 for the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> duration of the maintenance configuration ('A' ESW pump and the diesel fire pump both out of service) which are significantly less than 1E-06 (ICDP) and 1E-07 (ILERP).The finding has a cross-cutting aspect in the area of human performance becausePPL's planned work activities did not effectively incorporate risk insights.
Enforcement.
10 CFR 50.65 (a)(4), "Requirements for Monitoring the Effectiveness ofMaintenance at Nuclear Power Plants," requires, in part, that before performing maintenance activities (including, but not limited to surveillances, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities.
Contrary to the above, PPL did not perform an adequate risk assessment for maintenance on August 25, 2006. Specifically, PPL did not assess the total increase in core damage probability due to the unavailability of the 'A' ESW pump and the diesel fire pump. Because the finding was of very low safety significance and has been entered into the corrective action program (CR # 805396), this violation is being treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy:
NCV 05000388/2006004-01, Inadequate Risk Assessment.1R15Operability Evaluations (71111.15 - 6 Samples)
a. Inspection Scope
The inspectors reviewed operability determinations that were selected based on riskinsights, to assess the adequacy of the evaluations, the use and control of compensatory measures, and compliance with the Technical Specifications.
In addition, the inspectors reviewed the selected operability determinations to verify whether the determinations were performed in accordance with NDAP-QA-0703,
"Operability Assessments." The inspectors used the Technical Specifications, Technical Requirements Manual, Final Safety Analysis Report (FSAR), and associated DesignBasis Documents as references during these reviews. The issues reviewed included:Units 1 and 2, 'C' EDG fuel oil leak on July 3 and July 5, CR 749560Units 1 and 2, 'B' EDG air manifold crack on 2L cylinder, CR 798523Units 1 and 2, Static pressure in recirculation plenum, CR 801261Units 1 and 2, Low sulfur diesel fuel oil - EDGs, CR 809691Units 1 and 2, "A" loop ESW pressurized to 70 psig during "B" loop surveillance,SO-054-B03, CR 810518Unit 1, 1 'C' 4KV bus breaker 09 truck operated cell (TOC) switch failureEngineering Work Request (EWR) 811738 and Action Request (AR) 811196
b. Findings
No findings of significance were identified.1R19Post-Maintenance Testing (71111.19 - 6 Samples)
a. Inspection Scope
The inspectors observed portions of post-maintenance testing activities in the field todetermine whether the tests were performed in accordance with the approved procedures. The inspectors assessed the test's adequacy by comparing the test methodology to the scope of maintenance work performed. In addition, the inspectors evaluated the test acceptance criteria to verify whether the test demonstrated that the tested components satisfied the applicable design and licensing bases and the Technical Specification requirements. The inspectors reviewed the recorded test data to determine whether the acceptance criteria were satisfied. The post-maintenance testing activities reviewed included:Units 1 and 2, 'D' EDG governor modification and overhaul, TP-024-148Units 1 and 2, repair the 'E' EDG transfer switch OATS556, PCWO 749616Unit 1, replacement of control rod drive flow controller and instrument powersupply, plant component work order (PCWO) 7929750Unit 1, replace TOC switch in the 'C' 4Kv bus cubical 09, PCWO 811203Unit 2, dynamic motor operated valve (MOV) testing following HV251F027Bstem nut replacement, PCWO 778694Unit 2, dynamic MOV testing following HV251F047A, PCWO 778696
b. Findings
No findings of significance were identified.1R22Surveillance Testing (71111.22 - 5 Samples)
a. Inspection Scope
The inspectors observed portions of selected surveillance test activities in the controlroom and in the field and reviewed the test data results. The inspectors compared the test result to the established acceptance criteria and the applicable Technical Specification or Technical Requirements Manual operability and surveillance requirements to evaluate whether the systems were capable of performing their intended safety functions. The observed or reviewed surveillance tests included:Units 1 and 2, 'B' emergency diesel generator loading as compared to the FSAR design loads on July 31, 2006Unit 1, revision to drywell floor drain inleakage calculation SO-100-006Unit 2, reactor core isolation cooling pump valve and flow surveillance, onJuly 26, 2006
Unit 2, semi-annual calibration of average power range monitor (APRM) channelB, August 9, 2006, SI-278-319BUnit 2, SI-278-333D2, oscillation power range monitor (OPRM) D2 calibration onAugust 9, 2006
b. Findings
No findings of significance were identified.1R23Temporary Plant Modifications (71111.23 - 1 Sample)
a. Inspection Scope
The inspectors reviewed temporary plant modifications to determine whether thetemporary changes adversely affected system or support system availability, or adversely affected a function important to plant safety. The inspectors reviewed the associated system design bases, including the FSAR, Technical Specifications, and assessed the adequacy of the safety determination screenings and evaluations. The inspectors also assessed configuration control of the temporary changes by reviewing selected drawings and procedures to verify whether appropriate updates had been made. The inspectors compared the actual installations to the temporary modification documents to determine whether the implemented changes were consistent with the approved documents. The inspectors reviewed selected post installation test results to verify whether the actual impact of the temporary changes had been adequately demonstrated by the test. The following temporary modification and documents were included in the review:Add support to reactor recirculation lube oil cooler lines, EC 8024-5
b. Findings
No findings of significance were identified.2.RADIATION SAFETYCornerstone: Occupational Radiation Safety2OS1Access Control to Radiologically Significant Areas (71121.01 - 8 Samples)
a. Inspection Scope
The inspectors reviewed all Susquehanna performance indicators (PIs) for theOccupational Exposure Cornerstone for followup from January 1 through August 17, 2006.
The inspectors reviewed radiation work permits for airborne radioactivity areas with thepotential for individual worker internal exposures of >50 mrem committed effective dose equivalent [CEDE] (20 derived air concentration-hrs). The inspectors reviewed and assessed the adequacy of PPL's internal dose assessment for any actual internal exposure greater than 50 mrem CEDE. No internal exposures of this magnitude were reported by PPL during the period from January 1 through August 17, 2006.The inspectors verified barrier integrity and engineering control performance(e.g., high efficiency particulate air ventilation system operation). The inspectors examined PPL's physical and programmatic controls for highly activated or contaminated materials (non-fuel) stored within spent fuel and other storage pools. For high radiation work areas with significant dose rate gradients (factor of 5 or more), the inspectors reviewed the application of dosimetry to effectively monitor exposure to personnel, and verified the adequacy of PPL controls.The inspectors discussed, with the radiation protection manager, high dose rate-highradiation area, and very high radiation area (VHRA) controls and procedures. The inspectors verified that any changes to PPL procedures did not substantially reduce the effectiveness and level of worker protection.The inspectors discussed, with first-line health physics (HP) supervisors, the controls inplace for special areas that have the potential to become VHRA during certain plant operations. The inspectors verified that these plant operations require communication beforehand with the HP group, so as to allow corresponding timely actions to properly post and control the radiation hazards.The inspectors conducted direct observation of activities taking place in the fuel poolarea involving the processing of irradiated components in preparation for shipment for disposal. Additionally, the inspectors observed the removal and repair of the advanced crusher shear from the fuel pool. The activities observed involved hot particle control, significant dose rate gradients, locked high and potentially VHRA controls, and as low as is reasonably achievable (ALARA) planning.
b. Findings
No findings of significance were identified.2OS2ALARA Planning and Controls (71121.02 - 2 Samples)
a. Inspection Scope
The inspectors reviewed PPL's method for adjusting exposure estimates, or re-planningwork, when unexpected changes in scope or emergent work are encountered. Utilizing PPL records, the inspectors reviewed the historical trends and current status oftracked plant source terms. The inspectors verified that PPL was making allowances or developing contingency plans for expected changes in the source term due to changes
in plant fuel performance issues or changes in plant primary chemistry. The inspectorsalso attended the August 14, 2006 meeting of the station ALARA committee.
b. Findings
No findings of significance were identified.2OS3Radiation Monitoring Instrumentation and Protective Equipment (7112103 - 1 Sample)
a. Inspection Scope
The inspectors reviewed the types of portable radiation detection instrumentation usedfor job coverage of high radiation area work, other temporary area radiation monitors currently used in the plant, and continuous air monitors associated with jobs with the potential for workers to receive 50 mrem CEDE.
b. Findings
No findings of significance were identified.4.OTHER ACTIVITIES4OA1Performance Indicator Verification (71151 - 2 Samples)
a. Inspection Scope
Cornerstone: Occupational Radiation SafetyOccupational Exposure Control EffectivenessThe inspectors reviewed all Susquehanna PIs for the Occupational ExposureCornerstone for follow-up. The inspectors reviewed a listing of PPL action reports for the period from January 1 through August 17, 2006 for issues related to the occupational radiation safety performance indicator, which measures non-conformances with high radiation areas greater than 1R/hr and unplanned personnel exposures greater than 100 mrem total effective dose equivalent (TEDE), 5 rem skin dose equivalent (SDE), 1.5 rem lens dose equivalent (LDE), or 100 mrem to the unborn child. The inspectors determined if any of these PI events involved dose rates >25 R/hr at30 centimeters or >500 R/hr at 1 meter. If so, the inspectors determined what barriers had failed and if there were any barriers left to prevent personnel access. For unintended exposures >100 mrem TEDE (or >5 rem SDE or >1.5 rem LDE), the inspector determined if there were any overexposures or substantial potential for overexposure. The inspectors determined that PPL had no occurrences during the period specified which met these criteria.
Cornerstone:
Public Radiation SafetyRETS/ODCM Radiological Effluents Occurrence The inspectors reviewed a listing of PPL action reports for the period fromJanuary 1 through August 17, 2006 for issues related to the public radiation safety performance indicator, which measures radiological effluent release occurrences per site that exceed 1.5 mrem/qtr whole body or 5 mrem/qtr organ dose for liquid effluents; or 5 mrads/qtr gamma air dose, 10 mrads/qtr beta air dose; or 7.5 mrems/qtr organ doses from I-131, I-133, H-3 and particulates for gaseous effluents. The inspectors determined that PPL had no occurrences during the period specified which met these criteria.
b. Findings
No findings of significance were identified.4OA2Identification and Resolution of Problems (71152 - 1 Annual Sample).1 Review of Items Entered into the Corrective Action ProgramAs required by Inspection Procedure (IP) 71152, Identification and Resolution ofProblems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed screening of all items entered into PPL's corrective action program. This was accomplished by reviewing the description of each new action request / condition report and attending daily management meetings..2Annual Sample: Review of Operator Work-Arounds
a. Inspection Scope
The inspectors performed walkdowns in the control room and remote shutdown panels,as well as reviewed action requests to identify deficient conditions that could challenge the operator's ability to correctly operate plant equipment. The "Risk Significant Operator Actions" list was also reviewed to determine if any of the deficient conditions impacted highly important and time critical actions. The deficient conditions were compared to off-normal and emergency operating procedures to determine if the deficient condition would prevent the proper operation of the equipment and / or implementation of the procedures. The inspectors also assessed the operational impact by evaluating if the condition would (1) change a longstanding operating practice, (2)require operation in a manner dissimilar from similar components or systems, (3) impair access to required indications, (4) increase required operator actions, and (5) require operation of equipment under conditions it was not designed to operate. In addition, the inspectors assessed the complexity of the task to determine if the operator's training was adequate to correctly operate the deficient equipment. Finally, the inspectors evaluated the cumulative effects of the deficient conditions on the ability of the operators
to respond in a correct and timely manner. Typical examples of deficient conditionsreviewed included, but was not limited to:Unit 1, 'A' control rod drive flow control valve oscillating, AR 768744Unit 1, 'C' condensate pump motor thrust bearing temperature point is spiking,AR 402320Unit 1 refueling water pump discharge pressure is reading low in the controlroom, AR 756989Unit 1, 'K' safety relief valve discharge pipe temperature is greater than 200F,AR 771547Unit 2, service water isolation valve to the 'B' turbine building closed coolingwater heat exchanger did not fully close, AR 791428Unit 2, 'A' reactor feedwater pump unable to respond to a demand signal,Operational Decision Making (ODM) 810625Unit 2, core flow restrictions, ODM 659894Unit 2, feedwater heater 'B' string, ODM 808801
b. Findings
No findings of significance were identified.4OA3Event Follow-up (71153 - 2 Samples).1Control Rod 42-51 Stuck, August 27, 2006
a. Inspection Scope
On August 27, 2006, Unit 2 was at 75 percent RTP to perform control rod testing. Control rod 42-51 was being manually inserted from the fully withdrawn position (48) to the fully inserted position (00) when it stopped at position 46. PPL increased drive water pressure in accordance with station procedure ON-255-001, "Control Rod Problems."
After raising drive water pressure the control rod was inserted to position 36 before it stopped. The control rod could not be inserted past position 36 using existing station procedures and PPL declared the control rod inoperable at position 36. The control rod was hydraulically isolated at 6:01 a.m., in accordance with TS 3.1.3 Control Rod Operability. Technical Specifications also require PPL to verify shutdown margin was maintained within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of disabling a control rod. At 3:55 p.m., PPL determined that the Unit 2 Technical Specification 3.1.1 shutdown margin was not met, due to control rod 42-51 being hydraulically isolated at position 36. Shutdown Margin was reestablished by fully inserting the four control rods around control rod 42-51 at 4:51 p.m.. Control rod 42-51 was fully inserted by increasing the drive water flow to the control rod at 6:22 p.m.. The inspectors responded to the site to monitor activities associated with the stuckcontrol rod on August 27, 2006. The inspectors assessed plant conditions, the status of the other Unit 2 control rods, PPL's immediate corrective actions and the action plan to fully insert control rod 42-51. The inspectors also verified that Unit 2 met the technical
specification requirements for control rod operability, shutdown margin and that thereactor protection system was still operable and would have been able to rapidly shutdown Unit 2 if required. The inspectors discussed the results of the troubleshooting with the control rod drive system engineers, reactor engineers, and plant operating staff.
The results of the troubleshooting indicated that the control rod had degraded drive seals, coupled with control cell friction, which prevented the drive from being inserted until the drive water flow was increased to compensate for the degraded seals. PPL's initial corrective actions included modifying station procedure TP-055-005, "LeakyHydraulic Control Unit Valve Troubleshooting Testing," which increased the drive water flow to the seals and allowed the control rod to be fully inserted. However, on September 13, 2006, during preparation for additional control rod testing on Unit 1, the inspectors interviewed engineers to determine what actions were taken to prevent recurrence during the control rod drive testing scheduled for September 16, 2006. The inspectors determined that no changes had been made to allow increasing drive water flow during testing, to compensate for degraded seals and prevent recurrence. After the discussion, and before Unit 1 control rod testing, PPL changed ODM 676754 to allow increasing drive water flow to fully insert control rods with significantly degraded seals.
PPL's has since made permanent changes to station procedure ON-255-001, "Control Rod Problems," which allows increasing drive water flow to compensate for degraded seals.
b. Findings
No findings of significance were identified..2(Closed) LER 05000388/2006-001-00 Technical Specifications Not Met for InoperableADS Pressure SwitchesOn January 25, 2006, PPL investigated the potential for interaction between an installedscaffold and tubing that supplied two automatic depressurization system (ADS) pressure switches. These switches provide an ADS initiation permissive signal when the 2D RHR pump is running. PPLs analysis concluded that scaffolding movement during a dynamic event could have challenged the function of the ADS pressure switches. As a result, they declared the pressure switches inoperable from the time of scaffold installation on February 1, 2005 to scaffold removal on January 27, 2006. This exceeds Technical Specification 3.3.5.1 allowable completion times for inoperable emergency core cooling system (ECCS) instrumentation. The scaffold installation did not compromise the function of ADS since the pump running permissive for ADS initiation has numerous alternative sources. A finding regarding this issue is documented in NRC Inspection Report 05000387, 388/2006-006PPL completed a site-wide inspection of accessible scaffolds and did not identify anyadditional adverse impacts to other safety-related equipment. PPL also revised their scaffolding control program to incorporate lessons learned from their root cause evaluation. The inspectors identified no additional findings in their review. PPL
documented this issue and associated corrective actions in condition reports 745248and 745462. This LER is closed.4OA6Meetings, Including ExitExit Meeting SummaryOn October 6, 2006, the resident inspectors presented the inspection results toMr. B. McKinney, Senior Vice President, and Chief Nuclear Officer, and other members of his staff, who acknowledged the findings. Susquehanna management stated that none of the information reviewed by the inspectors was considered proprietary.ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- M. Baughman, Manager Nuclear Training
- D. Brophy, Senior Engineer, Nuclear Regulatory Affairs
- L. Casella, System Engineer
- A. Fitch, Shift Operations Supervisor
- J. Fritzen, Radiological Operations Supervisor
- J. Grisewood, Manager Corrective Action and Assessment
- R. Kessler, Senior Health Physicist - ALARA
- B. McKinney, Senior Vice President and CNO
- E. Miller, Senior Engineer, Nuclear Regulatory Affairs
- J. Paciotti, Security Operations Supervisor
- R. Saccone, Vice President - Nuclear Operations
- V. Schuman, Radiological Protection Manager
- R. Sheranko, Senior Component Engineer
- D. Shane, Radiation Protection Technical Training
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
OpenedNONE
Opened and Closed
- 05000388/2006004-01 NCVInadequate Risk Assessment
Closed
- 05000388/LER-2006-001-00 LERTechnical Specifications Not Met for Inoperable ADSPressure Switches
LIST OF DOCUMENTS REVIEWED
(Not Referenced in the Report)Section 1R04: Equipment AlignmentOP-125-001, Unit 1 Containment Instrument Gas System Operating ProcedureOP-225-001, Unit 2 Containment Instrument Gas System Operating Procedure Containment Instrument Gas System P&ID, E106231
- OP-054-001, Emergency Service Water System Operating Procedure Emergency Service Water System P&ID, E106216
- A-2Attachment
Section 1R05: Fire ProtectionFP-013-198, "Pre-Fire Plan: Diesel Generator Bay "D", Fire Zone
- 0-41D," Revision 4Section 1R12: Maintenance EffectivenessMaintenance Rule Expert Panel Meeting Minutes, Meeting # 2006-0420
- Section 2OS: Occupational Radiation SafetyCondition Reports:733098;
- 732539;
- 750309;
- 755414;
- 755362;
- 756718;
- 756780;
- 756786;
- 756788; 756791;
- 757080;
- 757729;
- 757709;
- 757605;
- 758330;
- 758999;
- 759216;
- 751697;
- 755883; 755600;
- 755780;
- 756406;
- 756517;
- 756628;
- 756635;
- 756690;
- 756690;
- 756718;
- 756759; 756780;
- 756786;
- 756788;
- 756791;
- 757080;
- 757085;
- 757213;
- 757247;
- 757250;
- 757251; 757605;
- 757613;
- 757673;
- 757709;
- 757729;
- 757775;
- 757777;
- 758054;
- 758093;
- 758500; 758828;
- 758999;
- 759116;
- 759214;
- 759216;
- 759230;
- 759303;
- 759628;
- 759686;
- 759753; 759806;
- 760395;
- 760549;
- 760948;
- 761254;
- 761319;
- 761662;
- 761846;
- 762692;
- 762950; 763150;
- 763767;
- 763857;
- 764171;
- 764366;
- 764685;
- 764872;
- 765305;
- 765409;
- 765869; 766279;
- 766600;
- 767275;
- 767952;
- 768199;
- 768352;
- 768461;
- 768724;
- 769166;
- 769179; 769248;
- 769836;
- 769876;
- 769869;
- 770300;
- 771209;
- 771218;
- 771471;
- 771549;
- 771781; 772657;
- 2991;
- 773035;
- 773147;
- 773236;
- 774740;
- 775932;
- 775990;
- 776014;
- 776328; 776637;
- 776901;
- 778177;
- 778191;
- 778690;
- 778842;
- 780782;
- 784409;
- 784456;
- 784675; 799879;
- 799316;
- 797595;
- 791044;
- 800148;
- 768213;
- 774539;
- 745180;
- 732189; 732572"Removal of Advanced Crusher Shear (AC/S) from Cask Storage Pit (CSP) Work Plan"PPL Susquehanna, LLC., "Unit 1 14th Refuel and Inspection Outage Radiological PerformanceReport," July 12, 2006
- Collective Radiation Exposure Reduction Plan, updated August 14, 2006
- NDAP-QA-0626, Rev 7, Radiologically Controlled Area Access and Radiation Work Permit(RWP) System
- HP-240, Rev 0, Main Steam for HP Techs
- TM-OP-083-ST, Rev 2, Systems Training: Main Steam Station ALARA Committee Meeting Agenda, August 14, 2006
==Section 4OA2: Identification and Resolution of ProblemsAR
- AR 761286761286: Control Room Deficiency Tags, Unit 1, Unit 2 and Common, dated 9/1/06Annunciator Issues database Unit 1, Unit 2, and Common, dated 9/8/06
- Operator Monthly Performance Indicator, Operator Aggregate Impact Index dated 8/17/06
- Operator Workaround List, dated 8/28/06
- OI-AD-096, "Operator Work-Around / Challenges," Rev. 5
- A-3AttachmentON-000-001, "Security Event," Rev. 13EO-000-113, "Level / Power Control," Rev. 2
==Section 4OA3: Event FollowupAR
- 756711, "Walkdown, Inspect, and Tag All==
- U-1 Long Term Scaffolds Prior to Startup"CR
- 745248, "Scaffolding at the 2D RHR Pump (2P202D) Could Impact RHR Operation"
- CR 745462, "Apparent Trend - Recent Incidents Identifying Discrepancies With Scaffold" Root Cause Analysis for
- CR 745248 and CR 745462
LIST OF ACRONYMS
ADAMSAgencywide Document and Access Management SystemADSAutomatic Depressurization System
- ALAR [[]]
- APR [[]]
- CED [[]]
- CF [[]]
RCode of Federal Regulations
- CR [[]]
- ECC [[]]
- ED [[]]
- EOO [[]]
- ES [[]]
- EW [[]]
REngineering Work Request
Fdegrees FahrenheitFSARFinal Safety Analysis Report
- ICD [[]]
- ILER [[]]
- IM [[]]
CInspection Manual Chapter
- LD [[]]
- LE [[]]
- MO [[]]
VMotor-Operated Valve
- NC [[]]
- NDA [[]]
- NR [[]]
- OD [[]]
- OO [[]]
- OPR [[]]
- PAR [[]]
- PCW [[]]
- PI [[[]]
NRC] Performance Indicator
PMPreventive Maintenance
A-4AttachmentPPLPPL Susquehanna,
- ODCMR adiological Effluents Technical Specifications/Off-Site Dose Calculation ManualRHRResidual Heat Removal
- RHRS [[]]
WResidual Heat Removal Service Water
- RT [[]]
- SD [[]]
- SD [[]]
- SS [[]]
- SSE [[]]
- TED [[]]
- TO [[]]
CTruck Operated Cell
- VHR [[]]