IR 05000387/2011004

IR 05000387-11-004, 05000388-11-004; on 07-01-11 - 9-30-11; Susquehanna Steam Electric Station - NRC Integrated Inspection Report and Notice of Violation

ML113120409
Person / Time
Site:	Susquehanna
Issue date:	11/08/2011
From:	Krohn P G Reactor Projects Region 1 Branch 4
To:	Rausch T S Susquehanna
Krohn P G
References
EA-11-244 IR-11-004
Download: ML113120409 (57)

Text

November B, 2011EA-11-244Mr. Timothy S. RauschSenior Vice President and Chief Nuclear OfficerPPL Susquehanna, LLC769 Salem Boulevard. NUCSB3Berwick, PA 18603

SUBJECT: SUSQUEHANNA STEAM ELECTRIC STATION _ NRC INTEGRATEDI N SpECTt ON REPORT 05000387/201 1 004 AN D 050003881201 1 004AND NOTICE OF VIOLATION

Dear Mr. Rausch:

On September 30, 2011, the U. S. Nuclear Regulatory Commission (NRC) completed aninspection at your Susquehanna Steam Electric Station Units 1 and 2. The enclosed integratedinspection report presents the inspection results, which were discussed on October 13,2011,with you and other members of your staff.This inspection examined activities completed 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 interviewedpersonnel.Based on the results of this inspection, the NRC has determined that a Severity Level (SL) lVviolation of NRC requirements occurred. The violation was evaluated in accordance with theNRC Enforcement Policy included on the NRC's Web site at www.nrc.qov. Select About NRC,How We Regulate, Enforcement, then Enforcement Policy.The violation is cited in the enclosed Notice of Violation (Notice) and the circumstancessurrounding it are described in detail in the subject inspection report. The inspectors identified aSL lV Violation of 10 CFR 55.25, "lncapacitation Because of Disability or lllness," for PPL failingto notify the NRC of a known permanent change in medical status of a licensed operator, and 10CFR 55.3, "License Requirements," for failing to ensure that an individual license holder, in thecapacity of a reactor operator (RO), met the medical prerequisites prior to performing licensedoperator duties. Specifically, biennial medical examinations conducted on April 16, 2009 andApril 19,2011 identified that an RO did not meet the health requirements stated in ANSI/ANS3.4-1983, Section 5.4.5, "Eyes." However, PPL did not inform the NRC or request an amendedlicense for the RO until August 2011. Therefore, the RO performed licensed duties without anNRC-approved, amended license from April 2009 through August 2011, until the NRC identifiedthis issue. Upon notification PPL submitted, and the NRC approved, a conditional license toaddress the disqualifying medical condition. See Section 1R1 1 of the attached report foradditional details.

T. RauschViolations of operator licensing requirements are of particular concern to the NRC, and may beconsidered for escalated enforcement under certain circumstances. However, in this case, theNRC has classified this violation at SL lV, after considering that the operator was wearingcorrective lenses since the first failed test in April 2009 and that an amended license for acondition of "Corrected Lenses Required" likely would have been approved. Thus, the basis forthe RO's license was not impacted since his actual corrected vision while performing his dutieswas within the standards.This violation is being cited in the enclosed Notice in accordance with NRC Enforcement ManualSection 3.1.2, because the violation was determined to be repetitive of NRC Enforcement Action(EA)09-248 dated January 28,2010, an SL lll Notice of Violation related to a Senior ReactorOperator (SRO) standing watch without meeting a medical qualification requirement. Themedical conditions in both the former and current cases were similar; therefore, it wasreasonable that an adequate extent of condition review for EA-09-248 should have identified theadditional discrepancy.You are required to respond to this letter and should follow the instructions specified in theenclosed Notice when preparing your response. Please discuss the corrective actions taken torestore compliance, corrective actions to preclude recurrence of similar issues in the future, anda discussion why actions for EA-09-248 were not effective in identifying this issue. Also, if youhave additional information that you believe the NRC should consider, you may provide it in yourresponse to the Notice. The NRC will use your response, in part, to determine whether furtherenforcement action is necessary to ensure compliance with regulatory requirements.This report also documents two NRC-identified findings and one self-revealing finding, all of verylow safety significance (Green), and one NRC-identified SL lV NCV. Two of these findings weredetermined to involve violations of NRC requirements. Additionally, two licensee-identifiedviolations, which were determined to be of very low safety significance, are listed in this report.However, because of the very low safety significance and because they are entered into yourcorrection action program (CAP), the NRC is treating these findings as non-cited violations(NCVs) consistent with Section 2.3.2 of the NRC's Enforcement Policy. lf you contest any NCVin 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 ControlDesk, Washington, D.C. 20555-0001;with copies to the RegionalAdministrator Region l; theDirector, Office of Enforcement, United States Nuclear Regulatory Commission, Washington,D.C. 20555-0001; and the NRC Resident Inspector at the Susquehanna Steam Electric Station.In addition, if you disagree with the cross-cutting aspect of any finding in this report, you shouldprovide a response within 30 days of the date of this inspection report, with the basis for yourdisagreement, to the RegionalAdministrator, Region l, and the NRC Resident lnspector at theSusquehanna Steam Electric Station.ln 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 theNRC Public Document Room or from the Publicly Available Records (PARS) component of theNRC's document system (ADAMS). ADAMS is accessible from the NRC Web site athttp://www.nrc.qov/readino-rm/adams.html (the Public Electronic Reading Room). To the extentpossible, your response should not include any personal privacy or proprietary, information sothat it can be made available to the Public without redaction. lf personal privacy or proprietaryinformation is necessary to provide an acceptable response, then please provide a bracketed T. Rauschcopy of your response that deletes such information. lf you request withholding of suchmaterial, you must specifically identify the portions of your response that you seek to havewithheld and provide in detail the bases for your claim of withholding (e.9., explain why thedisclosure of information will create an unwarranted invasion of personal privacy or provide theinformation required by 10 CFR 2.390(b) to support a request for withholding confidentialcommercial or financial information). lf safeguards information is necessary to provide anacceptable response, please provide the level of protection described in 10 CFR 73.21.tuL-4uPaul G. Krohn, ChiefProjects Branch 4Division of Reactor ProjectsDocketNos. 50-387;50-388License Nos. NPF-14, NPF-22

Enclosures:

1. Notice of Violation2. lnspection Report 05000387/2011004 and 05000388/201 1004 wl

Attachment:

Supplemental InformationMencl: Distribution via ListServ T. Rauschcopy of your response that identifies the information that should be protected and a redactedcopy of your response that deletes such information. lf you request withholding of suchmaterial, you must specifically identify the portions of your response that you seek to havewithheld and provide in detail the bases for your claim of withholding (e.9., explain why thedisclosure of information will create an unwarranted invasion of personal privacy or provide theinformation required by 10 CFR 2.390(b) to support a request for withholding confidentialcommercial or financial information). lf safeguards information is necessary to provide anacceptable response, please provide the level of protection described in 10 CFR 73.21.

Sincerely,/RA'PaulG. Krohn, ChiefProjects Branch 4Division of Reactor ProjectsDocketNos. 50-387;50-388License Nos. NPF-14. NPF-22

Enclosures:

1. Notice of Violation2. lnspection Report 05000387/2011004 and 0500038812011404 wl

Attachment:

Supplemental Informationcc Mencl: Distribution via ListServDistribution Wencl: (via e-mail)W. Dean, RAD. Lew. DRAD. Roberts. DRPJ. Clifford, DRPC. Miller, DRSP. Wilson. DRSP. Krohn, DRPA. Rosebrook. DRPE. Miller, DRPS. lbarrola. DRPP. Finney, DRP, SRIJ. Greives, DRP, RlS. Farrell, DRP, OAJ. McHale. RIOEDORidsNrrPMSusquehanna ResourceRidsNrrDorlLpll -1 ResourceROPreports ResourceSUNSI Review Complete: AAR (Reviewer's Initials)MLl13120409DOCUMENT NAME: GIDRP\BRANCH4\INSPECTION REPORTS\SUSQUEHANNA\2011\3RD QUARTER201 1 \SUS201 1_004fi nal.DOCXAfter declaring this document "An Official Agency Record" it will be released to the Public.To receirre a coov of this document, indicate in the box: 'C' = Copy without attachmenUenclosure "E" = Copy with'N'= NoOFFICE mmtRI/DRPRI/DRPRI/ORARI/DRSRI/DRPNAMEPFinney/ MR forARosebrook/ AARADeFrancisco/AEDDJackson/ DEJPKrohn/ PGKDATE11t07 t1111t07 t1111t08 t1111t 07 1111108 t11OFFICIAL RECORD COPY NOTICE OF VIOLATIONPPL Susquehanna, LLC (PPL)Susquehanna Steam Electric StationDocket No. 50-387; 50-388License No. NPF-14: NPF-22EA-11-244During an NRC inspection, conducted during the third quarter of 2011, for which an exit meetingwas held on October 13,2011, a violation of NRC requirements was identified. ln accordancewith the NRC Enforcement Policy, the violation is listed below:10 CFR 55.3, states that a person must be authorized by a license issued by theCommission to perform the functions of an operator or senior operator as defined in thispart.10 CFR 55.21 requires, in part, that a licensee shall have a medical examination by aphysician every two years. The physician shall determine that the applicant or licenseemeets the requirements of 10 CFR 55.33(a)(1). 10 CFR 55.33(a)(1)states, in part, thatthe applicant's medical condition and general health will not adversely affect theperformance of assigned job duties or cause operational errors endangering publichealth and safety. 10 CFR 55.33(b) states, in part, if an applicant's general medicalcondition does not meet the minimum standards under 10 CFR 55.33(aX1) theCommission may approve the application and include conditions in the license toaccommodate the medical defect.10 CFR 55.23 requires, in part, that to certify the medical fitness of the applicant, anauthorized representative of the facility licensee shall complete and sign NRC Form 396.On the Form 396, PPL certified that it used the guidance in ANSI/ANS 3.4-1983,"Medical Certification and Monitoring of Personnel Requiring Operator Licenses forNuclear Power Plants."10 CFR 55.23(b) states that when the certification requests a conditional license basedon medical evidence, the medical evidence must be submitted on NRC Form 396 to theCommission and the Commission then makes a determination in accordance with10 cFR 55.33.ANSI/ANS 3.4-1983, section 3 states, in part, that the primary responsibility for assuringthat qualified personnelare on duty rests with the facility operator. The healthrequirements set forth herein are considered the minimum necessary to determine thatthe physical condition and general health of the individual are not such as might causeoperational errors endangering public health and safety. The specific healthrequirements and disqualifying conditions are described in Section 5.3, "DisqualifyingConditions," and Section 5.4, "Specific Minimum Capacities Required for MedicalQualification," of the ANSI standard.10 CFR 55.25 states, in part, that if during the term of the license, the licensee developsa permanent physical or mental condition that causes the licensee to fail to meet therequirements of 10 CFR 55.21, the facility licensee shall notify the Commission, within30 days of learning of the diagnosis. For conditions for which a conditional license (asdescribed in 10 CFR 55.33(b) of this part) is requested, the facility licensee shall providemedical certification on Form NRC 396 to the Commission.Enclosure 1 2Contrary to the above, PPL failed to notify the NRC within 30 days of a knownpermanent change in medical condition of a licensed operator and ensure that anindividual license holder, in the capacity of an RO, met the conditions of his license priorto performing licensed operator duties. Specifically, biennial medical examinationsconducted on April 16, 2009 and April 19, 2011 identified that an RO did not meet thehealth requirements stated in ANSI/ANS 3.4-1983, Section 5.4.5, "Eyes." Despitemedical reviews on May 12,2009 and May 9,2011, PPL did not report this change inpermanent medical condition to the NRC within 30 days nor did PPL request anamended license with a condition requiring corrective lenses until identified by the NRCduring a review of the RO's license renewal application package submitted to the NRCon August 9,2011. This resulted in the RO performing licensed operator duties fromApril 2009 through August 2011 without a properly restricted license. lt was noted thatthe RO had worn his corrective lenses since his medical examination in April 2009.This is an example of a Severity Level lV violation (Enforcement Policy Section 6.4).Pursuant to the provisions of 10 CFR 2.201, PPL Susquehanna, LLC is hereby required tosubmit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:Document Control Desk, Washington, DC 20555-0001 with a copy to the RegionalAdministrator, Region l, and a copy to the NRC Resident Inspectors, within 30 days of the dateof the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked asa "Reply to a Notice of Violation; EA-1 1-244" and should include for the violation: (1) the reasonfor the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps thathave been taken and the results achieved, (3) the corrective steps that will be taken to avoidfurther violations, (4) the date when full compliance will be achieved, and (5) why correctiveactions for EA-09-248 were not effective in identifying this violation at an earlier date. Yourresponse may reference or include previous docketed correspondence, if the correspondenceadequately addresses the required response. lf an adequate reply is not received within thetime specified in this Notice, an order or a Demand for lnformation may be issued as to why thelicense should not be modified, suspended, or revoked, or why such other action as may beproper should not be taken. Where good cause is shown, consideration will be given toextending the response time.lf you contest this enforcement action, you should also provide a copy of your response, withthe basis for your denial, to the Director, Office of Enforcement, United States NuclearRegulatory Commission, Washington, DC 20555-0001.Because your response will be made available electronically for public inspection in the NRCPublic Document Room or from the NRG's document system (ADAMS), accessible from theNRC Web site at http://www.nrc.qov/readinq-rm/adams.html, to the extent possible, it should notinclude any personal privacy, proprietary, or safeguards information so that it can be madeavailable to the public without redaction. lf personal privacy or proprietary information isnecessary to provide an acceptable response, then please provide a bracketed copy of yourresponse that identifies the information that should be protected and a redacted copy of yourresponse that deletes such information. lf you request withholding of such material, you mustspecifically identify the portions of your response that you seek to have withheld and provide indetail the bases for your claim of withholding (e.9., explain why the disclosure of information willcreate an unwarranted invasion of personal privacy or provide the information required by10 CFR 2.390(b) to support a request for withholding confidential commercial or financialinformation). lf safeguards information is necessary to provide an acceptable response, pleaseprovide the level of protection described in 10 CFR 73.21.Enclosure 1 In accordance with 10 CFR 19.11, you may be required to post this Notice within two workingdays of receipt.Dated this 8th day of November 2011Enclosure 1 Docket Nos:License Nos:Report No:Licensee:Facility:Location:Dates:Inspectors:Approved By:U.S NUCLEAR REGULATORY COMMISSIONREGION I50-387, 50-388NPF-14, NPF-2205000387/201 1 004 and 050003881 201 1 004PPL Susquehanna, LLCSusquehanna Steam Electric Station, Units 1 and 2Benruick, PennsylvaniaJuly 1 ,2011through September 30,2011P. Finney, Senior Resident lnspectorJ. Greives, Resident InspectorA. Rosebrook, Senior Project EngineerS. Pindale, Senior Reactor InspectorE. Burket, Reactor InspectorM. Orr, Reactor InspectorPaul G. Krohn, ChiefReactor Projects Branch 4Division of Reactor ProjectsEnclosure 2 2TABLE OF CONTENTSAdverse Weather Protection ...............7Equipment Alignment. ........8Fire Protection........... ....,...8Flood Protection Measures .................9Heat Sink Performance............... ........9Licensed Operator Requalification Program ............. ..........10Maintenance Effectiveness ........ ......13Maintenance Risk Assessments and Emergent Work Control ............13Operability Evaluations and Functionality Assessments .....................17Plant Modifications.... .......19Post-Maintenance Testing (PMT) ...............,.....20Refueling and Other Outage Activities ........,.....21Surveillance Testing .,....-21Drill Evaluation .......... ......24Performance lndicator (Pl) Verification ........ .....25fdentification and Resolution of Problems .............. ............27Event Followup ...............30Other Activities ..............,.31Meetings, lncluding Exit........... .........34Licensee-ldentified Violations ...........341R011R041 R051R061R071R111R121R131R151R181R191 R201R221EP640414C.424043404540464QA7ATTACHMENT: SUPPLEMENTAL INFORMATION .............35SUPPLEMENTARY INFORMATION.......,.. .,...,..A-1KEY POTNTS OF CONTACT ............. A-1LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED .... A-1LIST OF DOCUMENTS REVIEWED ,.......... ..,....A-2LtsT oF ACRONYMS............... ....... A-13Enclosure 2 3

SUMMARY OF FINDINGS

lR 05000387 1201 1004, 05000388i20 1 1 A04; 07 101 1201 1 - 091301201 1 ; Susquehanna SteamElectric Station, Units 1 and 2; Licensed Operator Requalification Program, Maintenance RiskAssessments and Emergent Work Control, Operability Evaluations and FunctionalityAssessments, surveillance Testing, Performance lndicator Verification.This report covered a three-month period of inspection by resident inspectors and announcedinspections by regional inspectors. One Severity Level (SL) lV Notice of Violation (NOV), twoGreen non-cited violations (NCV), one SL lV NCV, and one Green finding were identified. Thesignificance of most findings is indicated by their color (Green, White, Yellow, or Red) usingInspection Manual Chapter (lMC) 0609, "Significance Determination Process" (SDP). Thecross-cutting aspects for the findings were determined using IMC 0310, "Components WithinThe Cross-Cutting Areas." Findings for which the SDP does not apply may be Green or beassigned a severity level after NRC management review. The NRC's program for overseeingthe safe operation of commercial nuclear power reactors is described in NUREG-1649, "ReactorOversight Process," Revision 4, dated December 2006.

Cornerstone: Mitigating Systems. Severitv Level lV. The inspectors identified a SL lV NOV of 10 CFR 55.25, "lncapacitationBecause of Disability or lllness," for PPL failing to notify the NRC of a known permanentchange in medical status of a licensed operator, and 10 CFR 55.3, "License Requirements,"for failing to ensure that an individual license holder, in the capacity of a reactor operator(RO), met the medical prerequisites prior to performing licensed operator duties.Specifically, an RO failed a medical examination in both 2009 and 2011 which identified adisqualifying condition and performed licensed duties without an NRC-approved, amendedlicense. He performed the function of an RO while on watch from April 2009 through August2011, when the NRC identified this issue. However, the operator did wear corrective lenseswhile standing watch since April 2009. Upon notification PPL submitted, and the NRCapproved, a conditional license to address the disqualifying medical condition. PPLentered this issue into their corrective action program (CAP) as condition report (CR)1 4501 38.The inspectors determined that PPL's failure to notify the NRC of a known permanentchange in a licensed operator's medical status and request an amended license in order toassume licensed duties was a performance deficiency. This finding was evaluated using thetraditional enforcement process because the issue had the potential to impact or impede theregulatory process. Specifically, there was a potentialfor license termination or theissuance of a conditional license to accommodate for a medical condition. The ROperformed licensed duties from April 2009 through August 2011 with a disqualifyingcondition that required his license to be amended. Using the NRC Enforcement Policy, thisviolation was characterized at SL lV, in accordance with Section 6.4.This violation is being cited in the enclosed Notice in accordance with NRC EnforcementManual Section 3.1.2, because the violation was determined to be repetitive of NRCEnforcement Action (EA)09-248 dated January 28,2Q1Q, an SLlll Notice of Violation relatedto a Senior Reactor Operator (SRO) standing watch without meeting a medical qualificationrequirement. The medical conditions in both the former and current cases were similar:Enclosure 2

therefore, it was reasonable that an adequate extent of condition review for EA-09-24gshould have identified the additional discrepancy.This significance of the associated performance deficiency was screened against theReactor oversight Process (Rop) per the guidance of tMC 0612, Appendix B. Noassociated ROP finding was identified and no cross-cutting aspect was assigned. (Section1R1 1)o Green' An NRC-identified Green NCV of 10 CFR 50, Appendix B, Criterion V, "lnstructions,Procedures, and Drawings," was identified when PPL did not perform an adequateoperability assessment in accordance with procedure NDAP-QA-0703, "OperabilityAssessments and Requests for Enforcement Discretion," Revision 15, to ensure thecontinued operability of the 'M' safety relief valve (SRV). Upon identification, operatorsinitiated an Operability Follow-up Request which ultimately resulted in the'M' SRV beingdeclared inoperable.The finding was more than minor because it was similar to example 3.j in IMC 0612Appendix E, "Examples of Minor lssues" in that an error in a calculation is not minor if theerror results in reasonable doubt on the operability of the system or component. In thiscase, the error made in evaluating the operability of the SRV resulted in reasonable doubt ofoperability. The finding was evaluated for significance using IMC 0609, Attachment 4,"Phase 1 - lnitial Screening and Characterization of Findingl." Since the finding was not adesign or qualification deficiency, did not result in a loss of system safety function, did notresult in loss of a single train for greater than its allowed outage time, and was notpotentially risk significant due to external events, the finding was determined to be of verylow safety significance (Green). This finding was related to the cross-cutting area ofProblem ldentification and Resolution (Pl&R) - CAP because PPL did not thbroughlyevaluate problems such that the resolutions address the causes and extent of co-nditions, toinclude properly classifying, prioritizing and evaluating for operability. Specifically, pplfailed to consider the effect that seat leakage had on the lift point oftne ;M' SRV bnd failedto correctly assess the sRV for operabitity. [p.1 .(c)] (section 1R15)

Cornerstone: Barrier Integrityo

Green.

A self-revealing Green finding of NDAP-QA-0340, "Protected Equipment program,"Revision 10, was identified when the 2A fuel pool cooling (FPC) pump tripped duringmaintenance on the 2AFPC heat exchanger (HX). The pump and HX had been deiignatedas protected equipment. The unavailability and loss of pump functionality resulted in inoff-normal procedure entry. PPL entered this issue into their CAP as CR 1438904 andcompleted an apparent cause evaluation (ACE).The finding was more than minor due to its adverse effect on the Barrier lntegritycornerstone attribute of system, structure, and component performance to maintain spentfuel pool cooling (SFPC) system functionality and its objective to provide reasonableassurance that physical design barriers protect the public from radionuclide releases causedby accidents or events. The finding was screened in accordance with IMC 0609 Attachment4, "Phase 1 - Initial Screening and Characterization of Findings," and was determined to beof very low safety significance, Green, due to its not being associated with the loss ofcooling to the spent fuel pool (SFP) that would have precluded restoration prior to boiling, afuel handling error, or loss of SFP inventory. The finding had a cross-cutting aspect in thearea of Human Performance, Work Practices, in that PPL did not use human errorEnclosure 2 prevention techniques commensurate with the risk of the assigned task nor did personnelstop work in the face of uncertainty. [H.4.(a)] (Section 1R13)Green. An NRC-identified Green NCV of Susquehanna Unit 1 and 2 TS 5,4.1,"Procedures," was identified for an inadequate surveillance procedure for implementingTechnical Specifications (TS) Surveillance Requirement (SR) 3.6.4.1.4 and 3.6.4.1.5.Specifically, the implementing procedure was revised allowing the SR to be missed andsubsequently required entry into SR 3.0.3. PPL entered this issue in their CAP as CR1460362.The finding is more than minor because it was similar to example 3.d in IMC 0612 AppendixE, "Examples of Minor lssues" in that the failure to implement the TS SR as required is notminor if the surveillance had not been conducted. In this case, the SR had not beencompleted for all configurations of secondary containment and required both Unit 1 and Unit2 to enter SR 3.0.3 for a missed surveillance. Additionally, it is associated with theprocedure quality attribute to maintain functionality of containment and the Barrier Integritycornerstone objective to provide reasonable assurance that physical design barriers protectthe public from radionuclide releases caused by accidents or events. Specifically, theinadequate surveillance procedure resulted in missed surveillances, SRs 3.6.4.1.4 and3.6.4.1 .5 and entry into SR 3.0.3 for missed surveillances, The finding was evaluated forsignificance using IMC 0609, Attachment 4, "Phase 1 - Initial Screening andCharacterization of Findings." Since the finding only represented a degradation of theradiological barrier function provided for the reactor building (RB) (i.e. secondarycontainment), the finding was determined to be of very low safety significance (Green). Thisfinding is related to the cross-cutting arca of Human Performance - Resources becausePPL did not ensure that personnel, equipment, procedures, and other resources wereavailable and adequate to assure nuclear safety. Specifically, the procedures did notensure surveillance requirements (SRs) required by TS 3.6.4.1 were implemented. H.2(c)(Section 1R22\Severitv Level lV. An NRC-identified SL-IV NCV of 10 CFR 50.9(a), "Completeness andAccuracy of Information," occurred when PPL inaccurately reported reactor coolant system(RCS) leakage values under the RCS leakage performance indicator (Pl)for both unitssince inception of the Pl in April 2000. PPL entered the issue in their CAP as CR 1441824,completed an apparent cause evaluation, and plans to revise Pl data previously submitted.No performance indicator crossed the GreenMhite threshold once the values were updated.Because violations of 10 CFR 50.9 are considered to potentially impede or impact theregulatory process, they are dispositioned using the traditional enforcement process. Theinspectors concluded that PPL had reasonable opportunity to foresee and correct theinaccurate information prior to the information being submitted to the NRC. PPL's failure toidentify and correct the recurring errors over this period of time indicated the existence of aprogrammatic issue. Additionally, verification of the corrected Pl data in a subsequentinspection will have more than an insignificant regulatory impact on the NRC. Accordingly,although none of the affected Pls in this case would have crossed the threshold, the NRChas determined that the violation is of more than minor significance. The finding was notconsidered to be more significant since had this information been accurately reported, itwould not have likely caused the NRC to reconsider a regulatory position or undertake asubstantial further inquiry. The significance of the associated performance deficiency wasscreened against the ROP per the guidance of Manual Chapter 0612, Appendix B. NoEnclosure 2 6associated ROP finding was identified and no cross-cutting aspect was assigned. (Section4OA1)

Other Findings

Violations of very low safety significance or severity level lV, identified by PPL, werereviewed by the inspectors. Corrective actions taken or planned by PPL have been enteredinto PPL's CAP. These violations and corrective action tracking numbers are listed inSection 4OA7 of this report.Enclosure 2 7

REPORT DETAILS

Summarv of Plant StatusSusquehanna Steam Electric Station (SSES) Unit 1 began the inspection period at 92 percentrated thermal power (RTP) in a control rod pattern adjustment and power ascension from areactor startup. The unit reached 100 percent RTP on July 1. On July 6, the unit was reducedto 72 percent RTP in response to a condensate conductivity excursion. On July 22, the unit wasreduced to 85 percent RTP due to condenser backpressure associated with a hot weather limit.On August 23, a seismic event registered in the area and as a result, Unit 1 entered a Notice ofUnusual Event at2:05 p.m. and exited it at 9:10 p.m. On September 9, the unit was reduced to69 percent RTP for a control rod sequence exchange. Unit 1 operated at full RTP for theremainder of the inspection period.Unit 2 began the inspection period at 16 percent RTP in a power ascension. Unit 2 reached itsformer licensed power level of 94.4 percent RTP on July 15. The unit reached 97

.5 percent andits extended power uprate (EPU) licensed power limit of 100 percent RTP on July 17 and26,respectively. The unit reduced power to 63 percent RTP on August 13 for a control rod patternadjustment and sequence exchange. On August 19, the Unit 2 reactor tripped from a mainturbine trip that was actuated during integrated control system (lCS) leveltesting. A reactorstartup was commenced on August 21. On August 23, a seismic event registered in the areaand as a result, Unit 2 entered a Notice of Unusual Event at 2:05 p.m. and exited it at 9:10 p.m.100 percent RTP was attained on August 26. Unit 2 operated at full RTP for the remainder ofthe inspection period.Note: The licensed RTP for both units is 3952 megawatts thermal. The authorized power levelfor both units is 100 percent of the EPU licensed power limit. For the purposes of this reportand the remainder of current operating cycle, the authorized power level for Unit 2 is 100percent of the EPU licensed power limit.1. REACTORSAFETYCornerstones: Initiating Events, Mitigating Systems, and Barrier lntegrity1R01 Adverse Weather ProtectionReadiness for lmminent Adverse Weather Conditions (71111.01 - 1 sample)a. Inspection ScopeDuring the weeks of August 29 and September 5,2011, the inspectors evaluatedimplementation of imminent weather preparation to include procedures andcompensatory measures as they relate to high winds and heavy rain. The inspectorstoured susceptible plant areas and reviewed associated issues in the CAP forappropriate evaluation and resolution. Documents reviewed for each section of thisinspection report are listed in the Attachment. Common. station readiness for severe weather associated with Hurricane lrene andTropical Storm LeeEnclosure 2

b. FindinqsNo findings were identified.

1R04 EquipmentAlionment

.1 Partial Walkdown (71111.04Q - 3 samples)a. Inspection ScopeThe inspectors performed partial walkdowns of the following systems:r Unit 1, Division ll residual heat removal (RHR) during Division I RHR work windowo Unit 1,'1A' Standby Liquid Control (SBLC) train during 1B SBLC train outage. Common, 'A' CS chiller while 'B' CS chiller out of service (OOS)The inspectors selected these systems based on their risk-significance relative to thereactor safety cornerstones at the time they were inspected. The inspectors reviewedapplicable operating procedures, system diagrams, the UFSAR, technical specifications,work orders, condition reports, and the impact of ongoing work activities on redundanttrains of equipment in order to identify conditions that could have impacted systemperformance of their intended safety functions. The inspectors also performed fieldwalkdowns of accessible portions of the systems to verify system components andsupport equipment were aligned correctly and were operable. The inspectors examinedthe material condition of the components and observed operating parameters ofequipment to verify that there were no deficiencies. The inspectors also reviewedwhether (Licensee) staff had properly identified equipment issues and entered them intothe corrective action program for resolution with the appropriate significancecharacterization.b. FindinqsNo findings were identified.

1R05 Fire Protection

.1 Resident Inspector Quarterly Walkdowns (71111.05Q - 5 samples)a. Inspection ScopeThe inspectors conducted tours of the areas listed below to assess the materialcondition and operational status of fire protection features. The inspectors verified thatPPL controlled combustible materials and ignition sources in accordance withadministrative procedures. The inspectors verified that fire protection and suppressionequipment was available for use as specified in the area pre-fire plan, and passive firebarriers were maintained in good material condition. The inspectors also verified thatstation personnel implemented compensatory measures for out of service, degraded, orinoperable fire protection equipment, as applicable, in accordance with procedures.Enclosure 2

. Unit 1, RB 749'(Fire Zones l-sA-N, 1-5A-S, 1-sAW, 1-58, 1-5E, 1-5G, 1-5H). Unit 2, access and remote shutdown panel areas (Fire Zones 2-2A,2-2C). Common, A-D DG bays (Fire Zones 0-41A,0-418, 0-41C, 0-41D). Common, main control room (Fire Zones 0-26H, 0-26N, 0-26P). Common, circulating water pump house basement (Fire Zones 0-71A and 0-71B)b. FindinqsNo findings were identified.

1R06 Flood Protection Measures

.1 Annual Review of Cables Located in Underqround Bunkers/Manholes (71111.06 - 1sample)a. lnsoection ScopeThe inspectors conducted an inspection of underground bunkers/manholes subject toflooding that contain cables whose failure could disable risk-significant equipment. Theinspectors performed walkdowns of risk-significant areas to verify that the cables werenot submerged in water, that cables and/or splices appeared intact, and to observe thecondition of cable support structures. When applicable, the inspectors verified propersump pump operation and verified level alarm circuits were set in accordance withstation procedures and calculations to ensure that the cables will not be submerged.The inspectors also ensured that drainage was provided and functioning properly inareas where dewatering devices were not installed. The following area was reviewed:. Common, underground manhole inspection (MH22, MH23, MH27, and MH28)b. FindinosNo findings were identified.

1R07 Heat Sink PerformanceHeat Sink Annual Review (71111.07A - 1 sample)a. Inspection ScopeThe inspectors reviewed the Unit 2, 'A' FPC HX to determine its readiness andavailability to perform its safety functions. The inspectors reviewed the design basis forthe component and verified (Licensee's) commitments to NRC Generic Letter 89-13.The inspectors reviewed documents associated with maintenance for the HX to ensurethe performance capability for the HX was consistent with design assumptions. Theinspectors reviewed the results of previous inspections of the Unit 2, 'A' FPC HX andsimilar heat exchangers. The inspectors discussed the results of the most recentinspection with engineering staff and reviewed pictures of the as-found and as-leftconditions. The inspectors verified that PPL initiated appropriate corrective actions forEnclosure 2

10identified deficiencies. The inspectors also verified that the number of tubes pluggedwithin the heat exchanger did not exceed the maximum amount allowed.b. FindinqsNo findings of significance were identified.1R1 1 Licensed Operator Requalification Proqram.1 Resident Inspector Quarterlv Review (71111 . 1 1Q - 1 sample)a. lnspection ScopeThe inspectors observed licensed operator simulator training on September 13, 2011,which included a stuck radiation source, anticipated transient without scram (ATWS),and an unisolable reactor core isolation cooling (RCIC) steam leak. The inspectorsevaluated operator performance during the simulated event and verified completion ofrisk significant operator actions, including the use of abnormal and emergency operatingprocedures. The inspectors assessed the clarity and effectiveness of communications,implementation of actions in response to alarms and degrading plant conditions, and theoversight and direction provided by the control room supervisor. The inspectors verifiedthe accuracy and timeliness of the emergency classification made by the shift managerand the technical specification action statements entered by the shift technical advisor.Additionally, the inspectors assessed the ability of the crew and training staff to identifyand document crew performance problems.Additionally, the inspectors reviewed an instance in August 2011 where an NRCoperator licensing assistant identified an issue with the medical qualification records foran RO during a review of the RO's License Renewal Application form. The inspectorsreviewed the medical certification forms, reviewed PPL's formal correspondence with theNRC upon discovery of the issue, PPL's conditional license request submittals, andreviewed PPL's corrective actions for a similar NOV issued by the NRC on January 28,2010 (EA-09-248). Documents reviewed are listed in the Attachment.b. Findinqslntroduction. The inspectors identified a SL lV NOV of 10 CFR 55.25, "lncapacitationBecause of Disability or lllness," for PPL failing to notify the NRC of a known permanentchange in medical status of a licensed operator, and 10 CFR 55'3, "LicenseRequirements," for failing to ensure that an individual license holder, in the capacity of areactor operator (RO), met the medical prerequisites prior to performing licensedoperator duties. Specifically, an RO failed a medical examination in both 2009 and 2011which identified a disqualifying condition and performed licensed duties without an NRC-approved, amended license.Discussion. On August 9, 2011, during a Licensed Operator License RenewalApplication review, an NRC Operator Licensing Assistant identified that an RO's currentlicense had a condition of "shall take medication." The application included a Form 396,Certification of Medical Examination by Facility Licensee, dated May 9, 2011. The formrecommended the conditions of "shall take medication" and "corrective lenses must beworn" based on a documented biennial medical examination on April 19,2011. This wasEnclosure 2 11a change from the previous Form 396 submittal, so the box for "restriction change fromprevious submittal" should have been checked. The Operator Licensing Assistant alsoidentified that since this was a change that PPL was aware of on May 9,2011, they hadmissed the requirement to notify the NRC by June 8,2011, 30 days from PPL becomingaware of this permanent change in medical condition.The Operator Licensing Assistant informed PPL of the issue and requested thesupporting medical documentation for processing the requested license conditionchanges. PPL discovered that a medical examination conducted on April 16, 2009, firstidentified that the RO's vision did not meet the health requirements stated in ANSI/ANS3.4-1983, Section 5.4.5, "Eyes." Specifically, the RO did not meet the standard foruncorrected near vision. The medical review for this examination was completed onMay 12,2009. On April 19,2011, the RO's biennial medical examination confirmed thesame results. The medical review for this examination had been completed on May 9,2011. PPL had been aware of this condition since 2009, but did not report this changeto the NRC or request a change to the RO's license.The RO wore corrective lenses upon his return to licensed duties in April 2009, whichbrought his corrected near vision into compliance with the requirements of ANSI/ANS3.4-1983. He stood watch on both units and participated in refuelfloor operations withno evidence of impacted performance. Had PPL submitted a request for a conditionallicense, a condition would likely have been added to require corrective lenses. Followingthe identification of this issue in August 2011, a conditional license was requested onAugust 16,2011, and the NRC issued an amended license adding the condition"corrective lenses required" on September 9, 2011. PPL entered this issue into theirCAP as CR 1451039 and is conducting an evaluation. Interim corrective actionsincluded a review of allforms submitted from November 2009 to August 2011 in order toverify that all medical changes documented and/or submitted to the NRC were correct.No discrepancies were found from this interim action.10 CFR 55.3 requires a person to be authorized by a Commission-issued license toperform the function of an operator. 10 CFR 55.25 requires the facility licensee to notifythe Commission within 30 days if a licensee develops a permanent physical or mentalcondition which causes the licensee to failto meet the requirements of 10 CFR 55.21and to submit an NRC Form 396 for a conditional license. With respect to theseregulations, PPL had previous opportunities to identify that a report and conditionallicense were required during their extent of condition review for EA-09-248, datedJanuary 28,2010. This Enforcement Action was a SL lll NOV related to a senior reactoroperator (SRO) standing watch without meeting the same medical qualificationrequirements for vision in August 2009. The inspectors concluded that an adequateextent of condition review would have identified the additional discrepancy that existed in2009 and that corrective actions for the previous violation were ineffective given theyfailed to identify this issue when it recurred in 2Q11.Analvsis. The inspectors determined that PPL's failure to notify the NRC of a knownpermanent change in a licensed operator's medical status and request an amendedlicense in order to assume licensed duties was a performance deficiency. This findingwas evaluated using the traditional enforcement process because the issue had thepotential to impact or impede the regulatory process. Specifically, there was a potentialfor license termination or the issuance of a conditional license to accommodate themedical condition. The RO performed licensed duties from April 2009 through AugustEnclosure 2 122011 with a disqualifying condition that required his license to be amended. lt is notedthat the RO's job performance was satisfactory during this period'Using the NRC Enforcement Policy, this violation was assessed using Section 6.4.The NRC also considered that the underlying medical basis for the RO's license was notaffected since appropriate corrective lens had been worn since April 2009 while he wasperforming licensed operator duties. As a result, the violation was characterized as SLtv.This significance of the associated performance deficiency was screened against theROP per the guidance of IMC 0612, Appendix B. No associated ROP finding wasidentified and no cross-cutting aspect was assigned.Enforcement. 10 CFR 55.3 states that a person must be authorized by a license issuedby the Commission to perform the function of an operator or senior operator as definedin this part.10 CFR 55.21 requires, in part, that a licensee shall have a medical examination by aphysician every two years. The physician shall determine that the applicant or licenseemeets the requirements of 10 CFR 55.33(aX1). 10 CFR 55.33(a)(1) states, in part, thatthe applicant's medical condition and general health will not adversely affect theperformance of assigned operator job duties or cause operational errors endangeringpublic health and safety. 10 CFR 55.33(b) states, in part, that if an applicant's generalmedical condition does not meet the minimum standards under 10 CFR 55.33(aX1) ofthis part, the Commission may approve the application and include conditions in thelicense to accommodate the medical defect.10 CFR 55.23 requires, in part, that to certify the medical fitness of the applicant, anauthorized representative of the facility licensee shall complete and sign NRC Form 396.On the Form 396, PPL certified that it used the guidance in ANSI/ANS 3.4-1983,"Medical Certification and Monitoring of Personnel Requiring Operator Licenses forNuclear Power Plants."10 CFR 55.23(b) states that when the certification requests a conditional license basedon medical evidence, the medical evidence must be submitted on NRC Form 396 to theCommission and the Commission then makes a determination in accordance with10 cFR 55.33.ANSI/ANS 3.4-1983, section 3 states, in part, that the primary responsibility for assuringthat qualified personnel are on duty rests with the facility operator. The healthrequirements set forth herein are considered the minimum necessary to determine thatthe physical condition and general health of the individual are not such as might causeoperational errors endangering public health and safety. The specific healthrequirements and disqualifying conditions are described in Section 5.3, "DisqualifyingConditions," and Section 5.4, "specific Minimum Capacities Required for MedicalQualification," of the ANSI standard.10 CFR 55.25 states, in part, that if during the term of the license, the licensee developsa permanent physical or mental condition that causes the licensee to fail to meet therequirements of 10 CFR 55.21, the facility licensee shall notify the Commission, within30 days of learning of the diagnosis. For conditions for which a conditional license (asEnclosure 2 13described in 10 CFR 55.33(b) of this part) is requested, the facility licensee shall providemedical certification on Form NRC 396 to the Commission.Contrary to these requirements, PPL failed to notify the NRC within 30 days of a knownpermanent change in medical condition of a licensed operator and ensure that anindividual license holder, in the capacity of an RO, met the conditions of his license priorto performing licensed operator duties. Specifically, biennial medical examinationsconducted on April 16, 2009 and April 19, 201't identified that an RO did not meet thehealth requirements stated in ANSI/ANS 3.4-1983, Section 5.4.5, "Eyes." Despitemedical reviews on May 12, 2009 and May 9, 2011, PPL did not report this change inpermanent medical condition to the NRC within 30 days nor did PPL request anamended license with a condition requiring corrective lenses until identified by the NRCduring a review of the RO's license renewal application package submitted to the NRCon August 9,2011. This resulted in the RO performing licensed operator duties fromApril 2009 through August 2011 without a properly restricted license. lt was noted thatthe RO had worn his corrective lenses since his medical examination in April 2009.Since this violation is considered to be repetitive, based on EA-09-248 and itsoccurrence within two years, and it was NRC-identified, the NRC is issuing an NOV inaccordance with the guidance in NRC Enforcement Manual Section 3.1.2.3. PPL hasentered this issue into their CAP as CR 1450138. (NOV 05000387;38812011004'01,Violation of 10GFR55.25, Failure to Notify NRC of a Change in Medical Status andRequest a Conditional License)1R12 Maintenance Effectiveness (71111.12- 3 samples)a. lnspection ScopeThe inspectors reviewed the samples listed below to assess the effectiveness ofmaintenance activities on SSC performance and reliability. The inspectors reviewedsystem health reports, corrective action program documents, maintenance work orders,and maintenance rule basis documents to ensure that PPL was identifying and properlyevaluating performance problems within the scope of the maintenance rule. For eachsample selected, the inspectors verified that the SSC was properly scoped into themaintenance rule in accordance with 10 CFR 50.65 and verified that the (aX2)performance criteria established by PPL staff was reasonable. As applicable, for SSCsclassified as (aX1), the inspectors assessed the adequacy of goals and correctiveactions to return these SSCs to (a)(2). Additionally, the inspectors ensured that PPLstaff was identifying and addressing common cause failures that occurred within andacross maintenance rule system boundaries.. Unit 1 , RHR Loop 'A' suppression pool cooling/test control valve, HV151 F0244,failed to closeo Unit 1, main steam line (MSL) flow indicating switches. Common, review of 50.65(a)(3) Assessment, dated June 2,2011b. FindinosNo findings were identified.1 R13 Maintenance Risk Assessments and Emerqent Work Control (71111

.13 - 4 samples)Enclosure 2

a.14Inspection ScopeThe inspectors reviewed station evaluation and management of plant risk for themaintenance and emergent work activities listed below to verify that PPL performed theappropriate risk assessments prior to removing equipment for work. The inspectorsselected these activities based on potential risk significance relative to the reactor safetycornerstones. As applicable for each activity, the inspectors verified that PPL personnelperformed risk assessments as required by 10 CFR 50.65(a)(4) and that theassessments were accurate and complete. When PPL performed emergent work, theinspectors verified that operations personnel promptly assessed and managed plant risk.The inspectors reviewed the scope of maintenance work and discussed the results ofthe assessment with the station's probabilistic risk analyst to verify plant conditions wereconsistent with the risk assessment. The inspectors also reviewed the technicalspecification requirements and inspected portions of redundant safety systems, whenapplicable, to verify risk analysis assumptions were valid and applicable requirementswere met.The inspectors reviewed scheduled and emergent work activities with licensed operatorsand work-coordination personnel to evaluate whether risk management action thresholdlevels were correctly identified. ln addition, the inspectors compared the assessed riskconfiguration to the actual plant conditions and any in-progress evolutions or externalevents to evaluate whether the assessment was accurate, complete, and appropriate forthe emergent work activities. The inspectors performed control room and fieldwalkdowns to evaluate whether the compensatory measures identified by the riskassessments were appropriately performed. Documents reviewed are listed in theAttachment. The selected maintenance activities included:r Unit 1, red online risk for a 'B' emergency diesel generator (EDG) damper failure andstation portable diesel generator OOSo Unit 1, RCIC discharge check valve failure results in high suction pressurer Unit 2, trip of 2A FPC pump during 2A FPC HX cleaning. Common, dual-unit yellow risk during Unit 1 Division ll RHR work and 'B' EDGheating, ventilation and air-conditioning (HVAC) workFindinqslntroduction. A self-revealing Green finding of NDAP-QA-0340, "Protected EquipmentProgram," Revision 10, was identified when the 2A FPC pump tripped duringmaintenance on the 2AFPC HX. The pump and HX had been designated as protectedequipment.Descriotion. On July 14,2011, PPL was performing preventive maintenance on the24 FPC HX. This maintenance included cleaning, inspection, and eddy current testing.During the tube cleaning via pneumatic hose, air pressure pushed what was noted asexcessive mud past a plastic cover installed on the opposite end of the heat exchangerand impacted the operating 2A and 28 FPC pumps. At 10:00 p.m. on the same day, the2A FPC pump supply breaker tripped. The control room received a fuel pool paneltrouble alarm and a fire alarm for the FPC pump room. The diesel-driven fire pump andmotor-driven fire pump started. Operators responded by entering ON-235-001, "Loss ofFPC/Coolant Inventory," Revision 32, evaluating ON-O13-001, "Response to Fire,"Enclosure 2 15Revision 30, for entry, and restoring FPC by starting the 2C FPC pump. PPL'sinvestigation confirmed that 0.25" of mud had covered the 2A FPC pump and motorincluding the motor casing and vents. The thermal overloads were not tripped and motorwinding insulation was charred. PPL concluded that the motor shorted to ground andthat the adjacent heat exchanger work was the source of the mud and the direct causeof the pump trip.At the time of this event, all three FPC HXs and all three FPC pumps on each unit werebeing protected under PPL's Protected Equipment Program since the SFP time to 200degrees Fahrenheit was less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The program is implemented underNDAP-QA-0340, "Protected Equipment Program," Revision 10. Section 3.1 definesprotected equipment as "active or passive systems or components essential to ensuringsafety functions or unit generation are maintained for given plant conditions." Step 6.7.3of the procedure directs that if work is on or near protected equipment, the protectedequipment work approvalform will be completed, approvalwill come from the shiftmanager, and the shift manager will be briefed on critical steps and human performancetools or actions in place to minimize potential impact to protected equipment. lt alsodirects that continuous or periodic supervisory oversight of the activity will be provided ifworking on or near the protected equipment respectively, operations supervision willprovide periodic oversight once per shift or more frequently if directed by the shiftmanager, and that the work approval form will be kept with the work package.lnspectors reviewed contributors to this event and noted the following insights.. There was a misunderstanding between maintenance and operations personnelregarding whether HX work was considered on or near protected equipment whichchanged the expectations for supervisory oversight. During inspector interviews withoperations management, it appeared clear that the work was on protected equipmentand operations is procedurally responsible for implementation of the program.. An initial shift briefing was held between an assistant operations manager (AOM)and the maintenance crew on July 11,2011, when the work began but subsequentshift briefings either did not occur or at a minimum did not repeat the protectedequipment discussions required. This was a missed opportunity for clarification ofthe work category.. No protected equipment work approval forms were retained with the work packageas required. Since the shift manager and AOM are required signatures for work atleast near protected equipment, it was expected that one or more forms would beavailable considering the work lasted multiple shifts.. Lighting and inadequate housekeeping before and after the maintenance werefactors. The as-found room lighting and area cleanliness did not meet stationstandards despite a work package prerequisite step to inspect the area prior tobeginning work for housekeeping and foreign material exclusion (FME) issues. Theas-left area cleanliness also did not meet station standards. A work package step toclean the work area was annotated as in-progress but not complete despite a signedand initialed subsequent step that the jobsite met station housekeeping expectations.Workers observed mud on the floor of the room but did not question the extent of thecondition nor raise a concern with operations.. The room was a high radiation area (HRA). Radiological Protection staff restrictedaccess to the room to maintain dose as low as is reasonable achievable (ALARA)and required the two workers to be on the same side of the HX at all times. TheEnclosure 2 16dose concern also limited the time that supervisory oversight could be present in theroom and also mandated the side of the HX viewed. The effects of ALARA concernswere not addressed in briefings and staff did not challenge or raise concerns withmanagement.. The historic method of cleaning an FPC HX was to leave the opposite endbellpartially installed to capture water and debris as it leaves the HX. Due to thecondition of the endbell coating, it was removed and a plastic sheet was taped overthe HX open end. This change to the normalwork method was not challenged foradequacy and ultimately proved inadequate in that the plastic sheet was not a robustenough barrier to prevent mud and debris from the HX cleaning from impacting theother FPC pumps in the room.While this issue had many aspects, the inspectors determined that all of the contributorshad a common characteristic of human error prevention techniques in that they are to beused commensurate with the risk of the assigned task to perform it safely and thatpersonnel do not proceed in the face of uncertainty or unexpected circumstances.Inspectors determined that use of human error prevention techniques would haveeliminated issues associated with communications, briefings, housekeeping, oversight,and work activity changes.Failing to protect equipment under the protected equipment program was a performancedeficiency that was within PPL's ability to foresee and prevent. PPL entered this issueinto their CAP as CR 1438904.Analvsis. Failure to protect equipment under the protected equipment program is aperformance deficiency within PPL's ability to foresee and correct. The inspectorsdetermined that the finding was more than minor because it was associated with theBarrier Integrity cornerstone attribute of system, structure, and component performanceto maintain FPC system functionality and its objective to provide reasonable assurancethat physical design barriers protect the public from radionuclide releases caused byaccidents or events. Specifically, the finding resulted in the unavailability and associatedloss of functionality of a FPC system pump.The finding was screened in accordance with IMC 0609 Attachment 4, "Phase 1 - InitialScreening and Characterization of Findings," and was determined to be of very lowsafety significance, Green, due to its not being associated with the loss of cooling to theSFP that would have precluded restoration prior to boiling, a fuel handling error, or lossof SFP inventory. Specifically, other FPC pumps and heat exchangers were availableon both units and the spent fuel pools were cross-connected.The inspectors determined that the finding has a cross-cutting aspect in the area ofHuman Performance, Work Practices, in that PPL did not use human error preventiontechniques commensurate with the risk of the assigned task nor did personnel stop workin the face o'f uncertainty or unexpected circumstances. Specifically, PPL did notimplement human error prevention techniques commensurate with the potential to affectprotected equipment and did not stop work when confronted with the uncertaintyassociated with communications, briefings, and work activity changes nor theunexpected circumstances associated with housekeeping and oversight. [H.a.(a)]Enforcement. This finding does not involve enforcement action because no regulatoryrequirement violation was identified. Because this finding does not involve a violationEnclosure 2 I17and has very low safety significance, it is identified as a FlN. (FlN 0500038812011004-02, Inadequate Maintenance Practices Result in Trip of Protected EquipmentSpent Fuel PoolCooling Pump)1R15 Operabilitv Evaluations and FunctionalitvAssessments (71111.15 - 7 samples)a. Inspection ScopeThe inspectors reviewed operability determinations for the following degraded or non-conforming conditions:. Unit 1, 1D660 float voltage high out of specification. Unit 2, RCIC post-refueloutage. Unit 2, suppression pool-drywell vacuum breakers dual open/close indicationo Unit 2,'M'SRV seat leakageo Unit 2, HV252 F0318 failed first acceptance criteria. Common, startup bus 10 after lightning strikes. Common, SRV ASME testing (Second Quarter sample - see 4OA5.4)The inspectors selected these issues based on the risk significance of the associatedcomponents and systems. The inspectors evaluated the technical adequacy of theoperability determinations to assess whether technical specification operability wasproperly justified and the subject component or system remained available such that nounrecognized increase in risk occurred. ln addition, the inspectors reviewed theselected operability determinations to evaluate whether the determinations wereperformed in accordance with NDAP-QA-0703, "Operability Assessments." Theinspectors compared the operability and design criteria in the appropriate sections of thetechnical specifications and UFSAR to PPL evaluations to determine whether thecomponents or systems were operable. Where compensatory measures were requiredto maintain operability, the inspectors determined whether the measures in place wouldfunction as intended and were properly controlled by PPL. The inspectors determined,where appropriate, compliance with bounding limitations associated with the evaluations.b. Findinqs1.

Introduction.

An unresolved item (URl) was opened concerning Unit 2 RCIC followingrefuel outage maintenance to allow completion of the licensee's cause evaluation anddetermine if a performance deficiency exists.Description. On June 29, 2011, Unit 2 RCIC was declared inoperable after it tripped onoverspeed in automatic flow control when initiated for SR 3.5.3.3 between 920 and 1060psig reactor pressure. RCIC had previously been operated in manual flow controlfor SR3.5.3.4 with reactor pressure less than 165 psig reactor pressure. The failure wasattributed to the ramp generator signal converter (RGSC) prior to the end of the refuelingoutage. The completion of SR 3.5.3.4 did not identify the issue with the RGSC. PPLentered this issue into their CAP as CR 1430270. At the end of this inspection period,PPL was conducting an apparent cause evaluation, a root cause analysis (RCA), andpost-mortem investigation of the RGSC. This issue will be tracked as an URI pendinginspection and review of PPL's completed ACE, RCA, and RGSC investigation.(URl 0500038812011004-03, RCIC Failure During Surveillance)Enclosure 2 182.

Introduction.

An NRC-identified Green NCV of 10 CFR 50, Appendix B, Criterion V,"lnstructions, Procedures, and Drawings," was identified when PPL did not perform anadequate operability assessment in accordance with procedure NDAP-QA-0703,"Operability Assessments and Requests for Enforcement Discretion," to ensure thecontinued operability of the 'M' Safety Relief Valve (SRV).Description. On August24,2011, operations personnel identified a step change in thetail pipe temperature for the 'M' SRV from 166F to 212F. Condition Report (CR)1456166 was initiated to document the condition and evaluate operability. The promptoperability determination performed by the on-shift SRO stated that "at the temperaturesindicated, the 'M' SRV is leaking." Additionally, it stated that "the SRV remains operableas leakage will not have an adverse effect on lift point."On August 29, after reviewing the CR and operability determination, inspectorsquestioned the validity of the statement that leakage will not have an adverse effect onlift point. The basis of the question was CR 1399810 which evaluated three SRVs thatfailed to meet the TS 3.4.3 setpoint criteria of +/-3 percent in May 2011. In this case, allthree valves failed to meet the criteria below -3 percent, indicating they would have liftedprior to their design setting. The apparent cause attributed to one of the failed valveswas setpoint variance caused by seat leakage. This was reported to the NRC inLicensee Event Report (LER) 50-388/201 1-001. Upon review of the ACE associatedwith CR 1399610, the inspectors determined that PPL failed to consider the effect thatseat leakage could have on future operability determinations.In response to inspectors'questions, Operability Follow-up Request (OFR) 1459248 waswritten to validate the operability determination. The OFR stated that at a tail pipetemperature in excess of 22QF, the valve would be declared inoperable. This was basedon the fact that, since 2006, four valves had experienced this magnitude of seat leakageand all four failed to meet the TS setpoint criteria in the low (>-3 percent) direction duringthe subsequent testing. However, for temperatures below 220F PPL concluded in theOFR that the valve would be considered operable. PPL based this on historical datasince 2006 in which, of three leaking SRVs with tail pipe temperatures below 220F,"only one failed its as-found setpoint test." Upon review of test data, the inspectorsdetermined that, of the three leaking SRVs below 220F, though one had failed its as-found testing, only one had passed its as-found setpoint test, since one of the valveshad yet to be tested per the In-service Testing Program. The conclusion of the OFRstated that, since tail pipe temperature for the 'M' SRV was only 212F, the valve wasoperable. lnspectors evaluated the OFR against the requirements of Part 9900Technical Guidance "Operability Determinations & Functionality Assessment forResolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety," anddetermined that the use of such a limited data set to support operability, withouttechnicaljustification, was insufficient and did not provide reasonable assurance that the'M' SRV was operable.PPL generated CR 1479436 to address the inspectors' concerns regarding the OFR.Though the written response to the CR had not been completed at the time of this report,additional follow-up conversations with PPL staff identified that the OFR adopted aphilosophy of using test data to prove the SRV was operable, vice one of providingreasonable assurance of operability. In this case, since there was evidence that a valvewith low levels of leakage (i.e. tail pipe temperature between 200F and 220F) could failEnclosure 2 19its subsequent test and no technicaljustification for why the condition would only occurat higher levels of leakage, there was reasonable doubt on the operability of the 'M'SRV.On September 4, operators identified another step change in 'M' SRV tail pipetemperature to 226F and initiated CR 1460990 to evaluate the condition for operability.Upon review and evaluation against the OFR criteria, operators declared the 'M' SRVinoperable. This determination was the direct result of inspectors'questioning and theOFR generated following the first step change in tail pipe temperature.Analvsis. Failure to adequately assess component operability by incorporating results ofprevious failure modes analysis is a performance deficiency which was reasonablywithin PPL's ability to foresee and correct. The finding is more than minor because itwas similar to example 3.j in IMC 0612 Appendix E, "Examples of Minor lssues," in thatan error in a calculation is not minor if the error results in reasonable doubt on theoperability of the system or component. ln this case, the error made in evaluating theoperability of the'M' SRV resulted in reasonable doubt of operability. The finding wasevaluated for significance using IMC 0609, Attachment 4, "Phase 1 - Initial Screeningand Characterization of Findings." Since the finding was not a design or qualificationdeficiency, did not result in a loss of system safety function, did not result in loss of asingle train for greater than its allowed outage time, and was not potentially risksignificant due to external events, the finding was determined to be of very low safetysignificance (Green).This finding was related to the cross-cutting area of Pl&R - CAP because PPL did notthoroughly evaluate problems such that the resolutions address the causes and extent ofconditions, to include properly classifying, prioritizing and evaluating for operability.Specifically, PPL failed to consider the effect that seat leakage had on the lift point of the'M' SRV and failed to correctly assess the SRV for operability. [P.1.(c)]Enforcement. 10 CFR Part 50, Appendix B, Criterion V, "lnstructions, Procedures, andDrawings," states, in part, that "activities affecting quality shall be prescribed byinstructions, procedures, or drawings... and shall be accomplished in accordance withthese instructions, procedures, or drawings." NDAP-QA-0703, "Operability Assessmentsand Requests for Enforcement Discretion," Revision 15, states, in part, that an initialoperability screening should be documented such that it provides a basis for operability.Contrary to the above, the prompt operability determination performed on August 24,2011, following identification that the 'M' SRV was experiencing seat leakage wasinadequate since it failed to identify that seat leakage had resulted in previousoccurrences of setpoint variance outside of acceptable as-found tolerances. Becausethis finding is of very low safety significance and has been entered into PPL's correctiveaction program (CR 1459230 and 1465729), this violation is being treated as an NCVconsistent with section 2.3.2 of the NRC Enforcement Policy. (NCV 05000388/2011004-04, Inadequate Operability Assessment of Safety Relief Valve Seat Leakage)1R18 Plant Modifications.1 Temporarv Plant Modifications (71111.18 - 1 sample)a. Inspection ScopeEnclosure 2 20The inspectors reviewed the temporary modification listed below to determine whetherthe modification affected the safety functions of systems that are important to safety.The inspectors reviewed 10 CFR 50.59 documentation and post-modification testingresults, and conducted field walkdowns of the modifications to verify that the temporarymodifications did not degrade the design bases, licensing bases, and performancecapability of the affected systems. The inspectors also assessed configuration control ofthe changes by reviewing selected drawings and procedures to verify that appropriateupdates had been made.o Unit 2, RCIC steam trap on-line leak sealingb. FindinqsNo findings were identified.

1R19 Post-Maintenance Testinq (PMT) (71111.19 - 6 samples)a. Inspection ScopeThe inspectors reviewed the post-maintenance tests for the maintenance activities listedbelow to verify that procedures and test activities ensured system operability andfunctional capability. The inspectors reviewed the test procedure to verify that theprocedure adequately tested the safety functions that may have been affected by themaintenance activity, that the acceptance criteria in the procedure was consistent withthe information in the applicable licensing basis andlor design basis documents, and thatthe procedure had been properly reviewed and approved. The inspectors alsowitnessed the test or reviewed test data to verify that the test results adequatelydemonstrated restoration of the affected safety functions.The inspectors reviewed PMT activities relating to EPU design changes for the reactorfeed pump turbine speed control unit. Specifically, the review included auto-flow controlmode testing.o Unit 1, 1B residual heat removal service water (RHRSW) pump following liftadjustmente Unit 2, two reactor feed pumps (RFPs) in auto-flow control mode testing (EPU)r Unit 2, rod worth minimize inoperable during reactor startup. Common, 'B' EDG exhaust damper following repairs. Common, 'D'ESW motor replacemento Common, 'C' EDG after 5 year inspectionb. FindinqsNo findings were identified.Enclosure 2

211R20 Refuelinq and Other Outaqe Activities (71111

.20 - 1 sample).1 Unit 2 Refuel Outaqe (RFO)a. lnspection ScopeUnit 2 began the inspection period in a power ascension from 16 percent RTP after anRFO. Through power ascension, inspectors performed the activities below:o Monitoring of startup and heatup activitiesr lmplementation of the EPU testing planr ldentification and Resolution Problems - reviewed CAP entries to verify an adequatethreshold for issues and appropriate corrective actionsDuring the inspection activities, the inspectors reviewed the associated documentation toensure that the tasks were performed safely and in accordance with plant TSrequirements and operating proceduresb.FindinqsNo findings were identified.Surveillance Testinq (71111.22 - 5 samples)1R22a. lnspection ScopeThe inspectors observed performance of surveillance tests and/or reviewed test data ofselected risk-significant SSCs to assess whether test results satisfied technicalspecifications, the UFSAR, and PPL procedure requirements. The inspectors verifiedthat test acceptance criteria were clear, tests demonstrated operational readiness andwere consistent with design documentation, test instrumentation had current calibrationsand the range and accuracy for the application, tests were performed as written, andapplicable test prerequisites were satisfied. Upon test completion, the inspectorsconsidered whether the test results supported that equipment was capable of performingthe required safety functions. The inspectors reviewed the following surveillance tests:o Unit 1, Division I core spray (CS) quarterly flow surveillance and inservice testing(rsr). Unit 2, Division ll RHRSW comprehensive flow surveillance (lST). Unit 2, drywell floor drain in-leakage calculation (RCS Leak Detection)r Unit 2, SE-204-103,24 month 2A auxiliary bus degraded grid testing. Common, SE-070-01 1 and SE-170-01 1, 24 month secondary containmentdrawdown and in-leakage surveillance testb. Findinqslntroduction. The inspectors identified a Green NCV of Susquehanna Unit 1 and 2 TS5.4.1, "Procedures" for an inadequate implementing procedure for TS SR 3.6.4.1 .4 and3.6.4.1.5. Specifically, the implementing procedures were revised to allow missing theSR and subsequently required entry into SR 3.0.3.Enclosure 2

2

Description.

On October 10, 2Q04, PPL identified that TS SRs 3.6.4.1

.4 and 3.6.4.1 .5 aswritten were non-conservative and CR 610828 was generated to initiate the necessarycorrective actions. Specifically, the SRs test the leak-tightness of secondarycontainment by assuring in-leakage into secondary containment is within limits (SR3.6.4.1.5) and that secondary containment drawdown times are within limits (SR3.6.4.1.4). The SRs are required to be performed on a 24 month staggered test basisfor each ventilation subsystem. The TS SRs modified the frequency with a note thatrequired that the three zone configuration of secondary containment be tested every 60months. This note assumed that the three-zone configuration was the most limitingconfiguration of secondary containment based on being the largest air volume. Uponreview of historicaltest data, PPL determined that, due to differences in the damperpositions for the three different configurations of secondary containment (i,e. Zones 113,Zones 213, or Zones 11213), the three-zone configuration was not necessarily the mostlimiting configuration. Thus, as written, the TS SRs did not ensure the most limitingconfiguration was tested every 60 months. Despite this, PPL had been testing allconfigurations every 24 months on a staggered test basis such that all configurationswere tested every 48 months. This was controlled by the implementing procedures in-place at the time and controlled via their work scheduling process.As part of corrective actions for the non-conservative TS, a licensing document changewas requested via PLA-5857 on February 7,2005. Additionally, the TS Bases weremodified on March 1, 2005, to reflect the testing requirements. Due to the change in theTS Bases, System Engineering updated the surveillance frequency in the workscheduling process such that the required frequency for each of the two-zoneconfigurations was changed from 24 months to 48 months. This change was madewithout performing an impact review. Additionally, the surveillance implementingprocedures, SE-170-011, "Secondary Containment Drawdown and In-leakage TestZones I and lll" and SE-270-01 1, "Secondary Containment Drawdown and In-leakageTest Zones ll and lll," were modified on May 14, 2007, to describe the tests as 60 monthtests and ensure that, for human performance concerns, the two-zone test wasperformed on the same ventilation train on which the three-zone test was beingperformed. A note was added to the surveillance procedures to describe the change:"Note: SE-070-011 will be performed every 2 years with the A/B divisions staggered.SE-170-01 1 and SE-270-01 1 will be performed on a 2 year staggered basis.SE-170-01 1 and SE-270-01 1 should be performed with the same division thatwas tested during surveillance of SE-070-011 in order to minimize humanperformance errors."This procedure change was processed as an administrative correction, and as such, didnot require a Surveillance Procedure Review per NDAP-QA-0722, "Surveillance Testing"and allowed a lower level approval authority than would be required for a technicalchange. The testing methodology was changed as follows:Enclosure 2

23Time(months)Testing Methodology(Prior to 2005)Testing Methodology(After 2005)ConfigurationsTestedVentilation TrainTestedConfigurationsTestedVentilation TrainTested01t2t3&1t3&213A1t2t3 &2t3A241t2t3 & 1t3 &2t3B1t2t3 & 1t3B48112t3 & 1t3 &213A1t2t3 &2t3A72112t3 & 1t3 &213B1t2t3 & 1t3BThese two changes resulted in the Zone 113 configuration, which is tested viaSE-170-01 1, and the Zone 2i3 configuration, which is tested via SE-270-01 1, were onlytested with the'B' and'A' ventilation trains, respectively.On August 19,2011, after observing performance of SE-070-011, Revision 11,"Secondary Containment Drawdown and lnleakage Test Zones l, ll and lll" andSO-170-01 1 , Revision 1 1, "Secondary Containment Drawdown and lnleakage TestZones I and lll," inspectors questioned how the implementing procedures and testingmethodology met the TS SR requirement of 24 month staggered tests basis, as modifiedby a note that states "test each configuration at least one time every 60 months."Specifically, after reviewing previous test data, inspectors noted that the SE-170-01 1,which tests the Zone 113 configuration, had not been performed with the'A'train ofventilation since June 15, 2001 and SE-270-011, which tests the Zone 213 configuration,had not been performed with the 'B' train of ventilation since April 18, 2003.PPL entered the issue into their CAP as CR 1460362. Upon review, PPL determinedthat the failure to perform the TS SR on all configurations as required by plant TSsconstituted a missed surveillance and complied with the requirements of TS SR 3.0.3 forboth Unit 1 and Unit 2. As required by SR 3.0.3, a risk assessment determined that theimpact of delaying completion of the surveillance would be negligible and an additional 6month delay was determined to be reasonable to schedule and perform the SR perexisting plant processes.Analvsis. Failure to have an adequate procedure to implement TS SRs is a performancedeficiency which was reasonably within PPL's ability to foresee and correct. The findingis more than minor because it was similar to example 3.d in IMC 0612 Appendix E,"Examples of Minor lssues," in that the failure to implement the TS SR as required is notminor if the surveillance had not been conducted. ln this case, the SR had not beencompleted for all configurations of secondary containment and required both Unit 1 andUnit 2 to enter SR 3.0.3 for a missed surveillance. Additionally, it is associated with theprocedure quality attribute to maintain functionality of containment and the BarrierIntegrity cornerstone objective to provide reasonable assurance that physical designbarriers protect the public from radionuclide releases caused by accidents or events.Specifically, the inadequate surveillance procedure resulted in missed surveillances,SRs 3.6.4.1

.4 and 3.6.4.1.5, and entry into SR 3.0.3 for missed surveillances. Thefinding was evaluated for significance using IMC 0609, Attachment 4, "Phase 1 - InitialEnclosure 2

24Screening and Characterization of Findings." Since the finding only represented adegradation of the radiological barrier function provided for the reactor building (i.e.,secondary containment), the finding was determined to be of very low safety significance(Green).This finding is related to the cross-cutting area of Human Performance - Resourcesbecause PPL did not ensure that personnel, equipment, procedures, and otherresources were available and adequate to assure nuclear safety. Specifically, thesurveillance procedures SE-170-011 , Revision 1 1, "Secondary Containment Drawdownand In-leakage Test Zones I and lll," and SO-270-011, Revision 11, "SecondaryContainment Drawdown and ln-leakage Test Zones ll and lll," did not ensure SRsrequired by TS 3.6.4.1were implemented. Since these procedures were lastimplemented in 2011 and 2009 respectively, the inspectors determined it was reflectiveof current performance. [H.2.(c)]Enforcement. Susquehanna Unit 1 and 2 TS 5.4.1, "Procedures," requires that writtenprocedures be established, implemented and maintained as recommended in RegulatoryGuide 1

4OA1 Performance Indicator (Pl) Verification

(8 samples).1Mitiqatino Svstems Performance Index (MSPI) (4 samples)Inspection ScopeThe inspectors reviewed PPL's submittal of the MSPI for the following systems andtimeframes. To determine the accuracy of the performance indicator data reportedduring those periods, the inspectors used definitions and guidance contained in NEIDocument 99-02, "Regulatory Assessment Performance lndicator Guideline," Revision6. The inspectors also reviewed PPL's operator narrative logs, condition reports, andMSPI derivation reports to validate the accuracy of the submittals. The review alsoincluded revisions of the MSPIs for January through September 2010, as correctiveactions for NCV 2010005-06 in lR 05000387;38812011005.Units 1 and2, MS07, High Pressure Injection Systems, April2010 through June2011Units 1 and 2, MS10, Cooling Water Systems, August 2010 through June 201 1FindinosNo findings were identified.Reactor Coolant Svstem (RCS) Specific Activitv and RCS Leak Rate (4 samples)lnspection ScopeThe inspectors reviewed PPL's submittal for the RCS specific activity and RCS leak ratePls for both Unit 1 and Unit 2 for the period of June 2010 through April 2011. Todetermine the accuracy of the performance indicator data reported during those periods,the inspectors used definitions and guidance contained in NEI Document 99-02,"Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectorsalsoreviewed RCS sample analysis and control room logs of daily measurements forRCS leakage, and compared that information to the data reported by the Pl.Additionally, the inspectors observed surveillance activities that determined the RCSidentified leakage rate, and chemistry personneltaking and analyzing an RCS sample.Findinoslntroduction. The inspectors identified a severity level lV NCV of 10 CFR 50.9(a),"Completeness and Accuracy of lnformation," when PPL inaccurately reported RCSleakage values under the RCS leakage Pl, 8102, since inception of the Pl in April 2000through June 201 1. PPL entered the issue in their CAP as CR 1448124, conducted anACE, and plans to revise Pl data previously submitted.Description. During a review of the RCS Leakage Pls for Units 1 and 2, the inspectorsidentified that PPL was not reporting leakage data in accordance with NEI 99-02,"Regulatory Assessment Performance lndicator Guideline," Revision 6. InspectionProcedure (lP) 71 151 , 'Pl Verification," dated June 28, 2007 , provides guidance to verify.2b.Enclosure 2 26Pl data submitted by licensees. lP 71 151 , section 3 states, "lnspectors should refer toNEI 99-02 for more in-depth definitions and descriptions of Pl inputs" since it providesthe guidelines for collection and submittal of Pl data for review by the NRC. NEI 99-02,section 2.3 describes the RCS leakage Pl, 8102, and defines the indicator as, "Themaximum RCS identified leakage in gallons per minute each month per the TSs andexpressed as a percentage of the TS limit." Under the data reporting elementssubsection, it states "The following data are required to be reported each quarter:o The maximum RCS identified leakage calculation for each month of the previousquarter (three values). The TS limit"NEI 99-02, section 2.3 defines the monthly Pl value as a calculation using the maximummonthly value of identified leakage divided by the TS limit for identified leakage,multiplied by 100 to obtain a percentage. There is a clarifying note in the section thatstates, "For those plants that do not have a TS limit on identified leakage, substituteRCS total leakage in the data reporting elements." Total leakage is considered the sumof both identified and unidentified leakage and both items listed above are consideredthe data reporting elements. This NEI 99-02 guidance remains unchanged in all itsrevisions. Since Susquehanna Units 1 and 2 do not have a TS for identified leakage,PPL should use their maximum RCS total leakage calculation for each month and theirTS limit for total leakage which is 25 gallons per minute. While PPL was correctly usingthe TS limit for total leakage in the Pl, inspectors determined that PPL was incorrectlyusing their maximum identified leakage value resulting in a non-conservative Pl value forboth units. An inspector review of historical data showed that the largest error on Unit 1occurred in February 2011 when the reported value was 6.44 percent versus the correctvalue of 9.20 percent. This was due to the HPCI inboard isolation valve steam leak inthe drywell. The largest error on Unit 2 occurred in September 1997 when the reportedvalue was 6.48 percent versus a correct value of 14.88 percent. PPL entered this issueinto their CAP as CR 1448124, conducted an Apparent Cause evaluation, and plans torevise the Pl data previously submitted. Upon review of all historical RCS Pl data forUnits 1 and 2, PPL noted slight reductions in margin, but no data crossed theGreenMhite threshold.Analvsis. The performance deficiency involved PPL's failure to submit complete andaccurate Pl data for RCS leakage for both Unit 1 and Unit 2 since inception of the Plprogram in April 2000. Because violations of 10 CFR 50.9 are considered to potentiallyimpede or impact the regulatory process, they are dispositioned using the traditionalenforcement process.PPL submitted inaccurate data for the affected Pl for Units 1 and 2 every quarter fromApril 2000 through its current submittal of June 2011. PPL's failure to identify andcorrect the recurring errors over this period of time indicated the existence of aprogrammatic issue. Additionally, verification of the corrected Pl data in a subsequentinspection will have more than an insignificant regulatory impact on the NRC.Accordingly, although none of the affected Pls in this case would have crossed thethreshold, the NRC has determined that the violation is of more than minor significance.The inspectors concluded that PPL had reasonable opportunity to foresee and correctthe inaccurate information prior to the information being submitted to the NRC. Thefinding was not considered to be more significant since had this information beenEnclosure 2 4c.A2.1a.27accurately reported, it would not have likely caused the NRC to reconsider a regulatoryposition or undertake a substantial further inquiry.The significance of the associated performance deficiency was also screened againstthe ROP per the guidance of IMC 0612, Appendix B, "lssue Screening." No associatedROP finding was identified and no cross-cutting aspect was assigned.Enforcement. 10 CFR 50.9(a) requires, in part, that information provided to the NRC bya licensee be complete and accurate in all material respects. NEI 99-02, "RegulatoryAssessment Pl Guideline," Revisions 0 through 6, provided guidance to the industry forsubmittal of Pl data to the NRC. Per NEI 99-02, licensees without a TS limit forldentified Leakage are to report RCS leakage using Total Leakage values. Contrary tothis, since inception of the Pls in April 2000 through June 2011, PPL did not report theRCS leakage Pl correctly. Specifically, PPL incorrectly calculated the Pl using maximumidentified leakage vice total leakage (sum of identified and unidentified leakage). Thisresulted in inaccurate Pl values being calculated and submitted for both units since April2000. This violation is characterized as an SL-IV NCV consistent with sections 2.2.1.cand 6.9 of the NRC Enforcement Policy. Because this violation was of very low safetysignificance, was not repetitive or willful, and was entered into PPL's CAP as CR1448124, this violation is being treated as an NCV, consistent with section 2.3.2.a of theNRC Enforcement Policy. (NCV 05000387;388/2011004-06, Inaccurate RCS Pl DataSubmittal)ldentification and Resolution of Problems (71152)Routine Review of Problem ldentification and Resolution ActivitiesInspection ScopeAs specified by lP 71152, "Problems ldentification and Resolution," the inspectorsroutinely reviewed issues during baseline inspection activities and plant status reviews toverify that PPL entered issues into the corrective action program at an appropriatethreshold, gave adequate attention to timely corrective actions, and identified andaddressed adverse trends. ln order to assist with the identification of repetitiveequipment failures and specific human performance issues for follow-up, the inspectorsperformed a daily screening of items entered into the CAP and periodically attendedscreening meetings.FindinqsNo findings were identified.Annual Sample: Review of CAP Evaluation Products (1 sample)Inspection ScopeThe NRC's 2010 Annual Assessment Letter dated March 4, 2011 (ML1 10620317) andthe NRC's 2011 Mid-Cycle Assessment Letter dated September 1,2011(ML1 1 2430469), documented weaknesses in the area of Problem ldentification andResolution - Problem Evaluation, IMC 0310, P.1(c). Both letters documented a cross-Enclosure 2b.a..2 28cutting theme in this area and the 2011 Mid-Cycle Assessment letter assigned aSubstantive Cross-Cutting lssue in this area.The inspectors reviewed a sample of PPL's root cause, apparent cause, and commoncause evaluations completed in 2011 prior to the inspection. The inspectors alsoreviewed selected effectiveness reviews, quality assurance (QA) reviews and programaudits, and attended corrective action review board (CARB) meetings to assess PPL'sprogress in addressing the cross-cutting theme in Pl&R, Problem Evaluation. Theinspectors also reviewed a sample of CAP documents, reviewed self-assessments andCAP training plans, observed station operation committee (SOC) and managementreview committee (MRC) meetings, and conducted interviews to assess the level ofprogress PPL had made in addressing the identified weaknesses. The majority of theevaluation products selected were issues identified during the Unit 2 refueling outage.Findinqs and ObservationsNo findings of significance were identified.The quality of the PPL's problem evaluation products for the sample reviewed wasadequate, with some noted weaknesses. Also, between the 4tn quarter o'f 2010 and theend of June 201 1, there appears to have been limited improvement in the overall qualityof PPL's evaluation products related to apparent cause evaluations. PPL had planned anumber of corrective actions to improve the quality of evaluations including ACE teamleader training and qualifications, increased focus on CAP by senior management, andthe implementation of Department-level Corrective Action Review Board (DCARB)reviews. However, some planned corrective actions to address weaknesses in problemevaluation were deferred from the originally intended dates thereby delaying theimplementation of effective corrective actions. For example:. The procedure for DCARB reviews was issued on May 27,2Q11 with theexpectation of implementation within 30 days. The original procedure due date wasFebruary 25,2011. Extensions were based on additional time needed to resolve theextensive nature of the comments to the initial draft, resource limitations prior to theUnit 2 refueling outage, and implementation of a change management plan.. The lesson plan for ACE training was not completed until late-May 2011. Theoriginal due date for the lesson plan was extended three times from February,25 toJune 30, 2Q11. The extensions were based on clarification of the assignment,reassigning the work, and training committee reviews.. ACE training began in mid-June and was completed in mid-August 2011. Theoriginal intent had been to complete ACE training for all personnel by June 17,2011.Regarding the Unit 1 and 2 outages, much of the workforce was involved in Unit 2refueling outage activities from early April to early May 2011. Once turbine bladereplacement began on both Units (mid-May 2011), however, substantially less of theworkforce was involved in supporting the outages, thereby creating another opportunityto move fonrvard in addressing evaluation weaknesses. In summary, several actionscould have been completed, substantially or in part, before the Unit 2 Spring 2011refueling outage or during the period of the dual-unit outage (mid-May to late June2011); thereby increasing the quality and effectiveness of many of the problemevaluations conducted during this time frame.Enclosure 2 29For some of the CAP evaluation products reviewed, the inspectors noted weaknesses inthe timeliness of evaluations, corrective actions, and in the level of rigor/ documentationfor supporting the basis for the conclusions. The inspectors also noted that a PPL QAaudit identified similar weakness. Specific examples include:r AR 1438453 identified that the guidance in NDAP-00-0753, Revision 0, was notconsistent with industry practice for conducting common cause/common issueanalysis and created a potential for the evaluator to stop short of determining thecommon cause. Corrective actions were developed under AR1438452 in July 2011;however, at the end of September 2011, PPL QA made a similar observation for thecommon cause analysis performed for the White Pl which stopped short ofidentifying a common cause for these operational events.o The ACE and RCA (CR1430270 and CR1450534 respectively) for a RCIC issuewhich resulted in a functional failure of the system and an LER (50-388-11-002-00)did not appear to be timely. The event occurred on June 29,2011. As of the closeof the quarterly inspection period, the ACE and RCA were not complete for thismatter. Further, the post-mortem analysis of the RGSC had not been completed tosupport the ACE.. For CR 1396005 for a configuration control event, the conclusion was not supportedwith data. Specifically, the evaluation took credit for actions previously taken bymanagement to reinforce the use of human performance tools and therebydetermined that no further action was required. However, no basis was provided forthis decision.Finally, the inspectors evaluated selected effectiveness reviews of CAs and attendedCARB reviews for RCAs performed in 2009 and 2010. In general, the reviews wereobjective and thorough, and the conclusions were reasonable and well supported. Foreffectiveness reviews that were determined to be ineffective. CRs were written andevaluations were assigned as appropriate.However, in one case, the CR and Level 3 evaluation (CR 1 445763) performed for anunsatisfactory effectiveness review of CR 1194033 related to CAP programmaticweaknesses did not appear to address the underlying problems identified by theeffectiveness review. The Level 3 evaluation challenged the effectiveness review'sconclusion and suggested alternate acceptance criteria such that the review would havebeen judged effective. Notwithstanding, the level 3 evaluation did not address why theCARB approved acceptance criteria were not met and the effectiveness review had todetermine the review was ineffective.From observations of DCARBs and CARBs during the quarter, the inspectors concludedthat these meetings are providing value to reviewed CAP products. The CARB rejectionrate in June and July averaged approximately 39 percent. PPL raised the performancethresholds for CARB grades in July based on the expectation that DCARBS will improvethe products that are subsequently reviewed by CARB. However, challenges to theability to execute these processes exist. Examples include:. Increased number of RCAs and ACEs requiring DCARB and CARB review;o Documents frequently not provided to DCARB or CARB members within the programspecified guidelines for minimum time for review;Enclosure 2 4043.1a.30. One meeting was observed where the presenter (i.e. ACE evaluator) was notpresent (CR 1a56182);o Numerous DCARB and CARB meetings cancelled due to inability to establish ameeting quorum;r Feedback from CARB members being provided to evaluators with insufficient time toresolve comments prior to the meetings, resulting in several cancelled CARBmeeting (1a87536);. Numerous CARBS are being scheduled as "Special CARB meetings." Thoughallowed by process, the frequency of this occurrence seemed inconsistent with theprocedure that states these are occasional occurrences; and. Several DCARB and CARB meetings were observed to take in excess of severalhours, leading to more troubleshooting and evaluation during the meeting, viceassessment of the product.Each of the specific examples discussed above were screen for risk significance usingIMC 0609 Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings,"IMC 0612, Appendix B, "lssue Screening," and IMC 0612, Appendix E, "Examples ofMinor lssues." They were determined to be of minor risk significance.Event Followup (71153 - 2 samples)Unit 2 Reactor Trip from Main Turbine Trip Durinq ICS Level TestinqInspection ScopeOn August 19,2011, the Unit 2 reactor scrammed on a Level 8 main turbine trip during aquarterly functional test of the feedwater/main turbine trip system associated with reactorvessel water level channels, The main turbine tripped but reactor feedwater pumpsremained in service. No automatic emergency core cooling system (ECCS) initiationsoccurred and RCIC did not initiate. Six SRVs lifted and both reactor recirculation pumpstripped. A resident inspector responded to the control room and observed the plant'sresponse to the transient and associated operator actions during the response.Additionally, inspectors reviewed the transient response post-event as well as reviewedimmediate corrective actions. The event was entered into PPL's CAP as 1453671.FindinqsNo Findings were identified.Notice of Unusual Event (NOUE) for Seismic Activitv at Units 1 and 2Inspection ScopeOn August 23,2011, central Virginia experienced a 5.8 earthquake on the Richter scalewith the epicenter in Mineral, Virginia. The seismic event was felt by personnel onsite atSusquehanna at 1:55 p.m. and was recorded by the seismic monitoring system. Theseismic monitoring system classified the event as less than an Operating BasisEarthquake (OBE) and less than a Safe Shutdown Earthquake (SSE). At 2:05 p.m.SSES declared a Notice of Unusual Event, OUS, for both units after confirmation byoutside agencies that an actual seismic event had occurred and reports from numerousb..2a.Enclosure 2 b.31personnel that they had detected ground motion. There was no indication of equipmentdamage or personnel injuries and no automatic initiations of any ECCS, emergencysafety feature (ESF) systems, or RPS actuations. A resident inspector, who was onsiteat the time, felt the seismic event and responded to the control room. Inspectorsobserved and assessed plant and control room operator responses to the event toinclude emergency response staffing, event classification, and event notification. Anindependent walkdown of ECCS equipment and exterior sections of the drywells for bothunits was completed. Inspectors also established and maintained communications withNRC Region I and Headquarters to ensure awareness of specific site impacts and PPL'sevent response.FindinqsNo findings were identified.Other ActivitiesEPU and Mitioatinq Svstem Startup Testinq (71004 and71111.19)lnspection ScopeThe inspectors observed portions and reviewed the following major plant test. Thedetails of this inspection sample are described in section 1 R19 of this report. The testwas considered an inspection sample that meets the requirements of lP 71004, 02.03.c:. Unit 2, RFPs in auto-flow control mode testingFindinqs and ObservationsNo findings were identified.EPU Power Ascension (lnteqrated Plant Evolutions) (lP 71004 and 71 1 1 1

.20 )Inspection Scopelnspectors witnessed power ascension following the Unit 2 refueling outage. Inspectorswitnessed portions of all reactivity changes made to achieve specific EPU testconditions. lnspectors also reviewed operator actions, procedure adherence, and plantresponse during these integrated plant maneuvers. This was a required inspectionsample that meets the requirements of lP 71004, 02.03.d.FindinqsNo findings of significance were identified.(Closed) NRC Temporarv Instruction 2515/177 - Manaqinq Gas Accumulation inEmeroencv Core Coolinq. Decav Heat Removal and Containment Sprav SvstemsInspection Scope40A5.1a.b..2b..3a.Enclosure 2

32The inspectors performed the inspection at Units 1 and 2 in accordance with Temporarylnstruction (Tl) 251 51177, "Managing Gas Accumulation in Emergency Core Cooling,Decay Heat Removal and Containment Spray Systems." The NRC staff developedT125151177 to support the NRC's confirmatory review of licensee responses to NRCGeneric Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling,Decay Heat Removal and Containment Spray Systems." Based on a review of PPL'sGL 2008-01 response letters, the NRC Office of Nuclear Reactor Regulation (NRR) staffprovided additional plant specific guidance on inspection scope to the regionalinspectors. The inspectors used this inspection guidance along with the Tl to verify thatPPL implemented or was in the process of acceptably implementing the commitments,modifications, and programmatically controlled actions described in their GL 2008-01response. The inspectors verified that the plant-specific information (including licensingbasis documents and design information) was consistent with the information that PPLsubmitted to the NRC in response to GL 2008-01.The inspectors reviewed a sample of isometric drawings, and piping and instrumentdiagrams, and conducted selected system piping walkdowns to verify that PPL'sdrawings reflected the subject system configurations and Updated Final Safety AnalysisReport (UFSAR) descriptions. Specifically, the inspectors verified the following relatedto a sample of isometric drawings for the high pressure coolant injection (HPCI), CS, andresidual heat removal (RHR) systems:o High point vents were identifiedr High points that did not have vents were recognized and evaluated with respect totheir potential for gas buildup. Other areas where gas could accumulate and potentially impact subject systemoperability, such as orifices in horizontal pipes, isolated branch lines, heatexchangers, improperly sloped piping, and under closed valves, were acceptablyevaluated in engineering reviews or had ultrasonic test (UT) points which wouldreasonably detect void formationo For piping segments reviewed, branch lines and fittings were clearly shownThe inspectors conducted walkdowns of portions of the above systems to evaluate theacceptability of PPL's drawings utilized during their review of GL 2008-01. Theinspectors verified that PPL conducted walkdowns of the applicable systems to confirmthat the combination of system orientation, vents, instructions and procedures, tests, andtraining, would ensure that each system was sufficiently full of water to ensureoperability. The inspectors reviewed PPL's methodology used to determine systempiping high points, identification of negative sloped piping, and calculations of void sizesbased on UT equipment readings, to ensure the methods were reasonable. Theinspectors also reviewed engineering analyses associated with the development ofacceptance criteria for as-found voids. The review included engineering assumptions forvoid transport and acceptability of void fractions at the suction and discharge piping ofthe applicable system pumps. In addition, the inspectors verified that PPL included allemergency core cooling systems, along with supporting systems, within the scope of theGL.The inspectors reviewed a sample of PPL's procedures used for filling and venting thesystems associated with GL 2008-01 to verify that the procedures were effective inventing or reducing voiding to acceptable levels. The inspectors verified that PPL'sEnclosure 2

.4 a.33venting surveillance frequencies were consistent with TSs and associated bases, andthe UFSAR. The inspectors reviewed a sample of system venting surveillance results toensure proper implementation of the surveillance program.The inspectors reviewed CAP documents to verify that selected actions described inPPL's nine-month and supplemental submittals were acceptably documented includingcompleted actions, and implementation schedule for incomplete actions. The inspectorsalso verified that the NRC commitments in PPL's submittals were included in the CAP.The inspectors specifically verified the installation of hardware vents, located in theHPCI, CS, and RHR discharge piping, as committed to in PPL's GL response.Additionally, the inspectors reviewed evaluations and corrective actions for variousissues PPL identified during their GL 2008-01 review. The inspectors performed thisreview to ensure PPL appropriately evaluated and adequately addressed any gasvoiding concerns including the evaluation of operability for gas voids discovered in thefield. Finally, the inspectors reviewed PPL's training associated with gas accumulationto assess if appropriate training had been provided to the operations and engineeringsupport staff to ensure appropriate awareness of the effects of gas voiding. Documentsreviewed are listed in the Attachment.FindinqsNo findings were identified. This completes the inspection requirements for Tl 25151177at Units 1 and 2.Omission of Operabilitv Evaluation Inspection Sample in lR 05000387:388/2011-003lnspection ScopeDuring a review of samples conducted during previous quarters, the resident inspectorsidentified that a completed Operability Evaluation sample was not documented in theassociated inspection report. lt is listed here as well as section 1R15 so as to providedocumented evidence of its completion.r Common, SRV ASME testingFindinoqNo findings were identified.URI 05000387/201 0003-05 UpdateInspection ScopeA URI regarding configuration control and operation of ICS was opened in lR05000387;38812010003 pending the review of a root cause analysis (RCA) associatedwith a Unit 1 reactor scram to determine if a performance deficiency exists. Subsequentto completion of this RCA, Unit 1 was issued a White FIN for a condenser bay floodingevent and its Pl for Unplanned Scrams turned White. This placed Unit 1 in theDegraded Cornerstone column of the NRC's action matrix. In preparation for theassociated 95002 inspection for a Degraded Cornerstone, PPL re-performed the RCAfor the scram associated with this URl. Since the results of this new RCA may differb..5a.Enclosure 2

34from the original, this URI is intended to be inspected coincident with the review of theRCAs during the 95002, currently scheduled for February 2012.b. FindinqsNo findings were identified.4OAO Meetinos. Includinq ExitOn September 1 , 2011, the inspectors presented the inspection results to Mr. J. Petrilla,Acting Manager, Nuclear Regulatory Affairs, and other members of PPL staff. Theinspectors verified that no proprietary information is documented in this report.On October 13,2011, the inspectors presented inspection results to Mr. T. Rausch,Chief Nuclear Officer (CNO) and other members of his staff. PPL acknowledged thefindings. The inspectors verified that no proprietary information is documented in thisreport.4CA7 Licensee-ldentified ViolationsThe following violations of very low safety significance (Green) or severity level lV wereidentified by PPL and are violations of NRC requirements which meet the criteria of theNRC Enforcement Policy, for being dispositioned as non-cited violations:o On July 29, 2011, the Unit 1 RCIC system was declared inoperable when the pumpdischarge check valve failed to fully shut and consequentially failed the surveillanceacceptance criteria. PPL declared the system inoperable and took several days ofunplanned unavailability to troubleshoot and repair the check valve. The apparentcause of the check valve failure was sticking or binding as the result of the righthinge pin having excessive axial clearance. The maintenance procedures fordisassembly of the check valve, last performed in July 2QQ7, did not specify atolerance for sideto-side hinge pin clearance. This issue was determined to be aviolation of Susquehanna Unit 1 TS 5.4.1, "Procedures," which requires that writtenprocedures be established, implemented and maintained as recommended inRegulatory Guide 1

.33 , Revision 2, Appendix A, February 1978. Regulatory Guide1.33, Appendix A, requires procedures to perform maintenance on the RCIC system.The performance deficiency was determined to be more than minor because thefinding was associated with the Mitigating Systems cornerstone attribute ofEquipment Performance, and affected the cornerstone objective to ensure theavailability, reliability, and capability of systems that respond to initiating events toprevent undesirable consequences. The inspectors evaluated the finding using IMC0609, Attachment 4, "lnitial Screening and Characterization of Findings," anddetermined the finding was of very low safety significance (Green) because it wasnot a design or qualification deficiency, did not iesult in a loss of safety function orthe loss of a train for greater than its TS allowed outage time, and was not potentiallyrisk significant due to external event initiators. The issue was entered into PPL'sCAP as CR 1444679.. On May 23, 2011, PPL identified that effluents decontamination workers entered theUnit 2 equipment pit on RB elevation 818'without a survey performed to assessradiological conditions, or escorted by healthy physics personnel in violation of TSEnclosure 2

355.7.1.e. TS 5.7.1.e requires that entry by individuals, other than those qualified in orescorted by those qualified in radiation protection procedures, into a High RadiationArea only be made after dose rates in the area have been evaluated and entrypersonnel are knowledgeable of them. The issue was more than minor because itwas determined to be similar to example 6.h of IMC 0612, Appendix E, in that asurvey was not actually performed. Additionally, the finding affected the programand process attribute, as measured by procedures, of the Occupational RadiationSafety cornerstone and its objective to ensure the adequate protection of the workerhealth and safety from exposure to radiation from radioactive material during routinecivilian nuclear reactor operation. The issue was evaluated in accordance with IMC0609, Appendix C, "Occupational Radiation Safety Significance DeterminationProcess," and inspectors determined that the finding was of very low safetysignificance (Green) because the finding was due to ALARA work control and the3-year rolling average collective exposure was less than 240 person-rem/unit (99.7person-remiunit for 2008-2010). PPL entered the issue into their CAP as CR1412115.ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Rausch, Chief Nuclear Officer

C. Coddington, Senior Engineer

J. Eisenhauer, Nuclear Plant Operator

R. Centenaro, Design Engineer

S. Muntzenberger, System Engineer

T. Walters, System Engineer

J. Petrilla, Acting Manager Regulatory Affairs

J. Goodbred Jr, Manager Nuclear Operations

G. Maertz, Manager Engineering

J. Waclawski, Senior Engineer

D. Lock, Manager Nuclear Maintenance

M. Potter, Assistant Operations Manager

D. Wright, Maintenance CAP Coordinator

J. Felock, Supervising Engineer

M. Murphy, Supervising Engineer

J. Siroka, Senior Engineer

M. Rochester, Regulatory Affairs

L. West, CAP Manager

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened05000388/201 1 004-03URI05000387;38812011004-01 NOVOpened/Closed05000388/2011004-02 FrN05000388/2011004-04 NCV05000387:38812011004-05 NCVRCIC Failure During Surveillance (1R15.1)Violation of 10CFR55.25, Failure to NotifyNRC of a Change in Medical Status andRequest a Conditional License (1R1 1)Inadequate Maintenance Practices Result inTrip of Protected Equipment Spent FuelPool Cooling Pump (1R13)Inadequate Operability Assessment ofSafety Relief Valve Seat Leakage (1R15.2)Inadequate Surveillance Procedure Resultsin Missed Technical SpecificationSurveillance Req uirements for SecondaryContainment (1R22)Inaccurate RCS Pl Data Submittal (4OA1.2)05000387;38812011004-06 NCVAttachment

A-2

Discussed

05000387/201 0003-05URIConfiguration Control and Operation of ICS(4OA5.5)

LIST OF DOCUMENTS REVIEWED

(Not Referenced in the Report)

==Section 1R01: Adverse Weather ProtectionProcedures:ON-000-002, "Natural Phenomenon," Revision 25NDAP-00-0030, "Severe Weather Preparations", Revision 3Condition Reports:1457059*,

1457528,

1457529,

1457530,

1457551, 1457578Miscellaneous:FSAR Figure 2.4-9, Flood Profiles on the Susquehanna River at the SiteSection 1R04: Equipment AlisnmentProcedures:EO-000-113, Level/Power Control, Revision 9CL-153-001 1, Unit 1 Standby Liquid Control System - Electrical, Revision 7CL-153-0012,Unit 1 Standby Liquid Control System - Mechanical, Revision 12Condition Reports (*==

NRC identified):1

449439*, 1

449436*, 1

449433*, 1

470458*, 1 47 0468.Drawinqs:M-151, Sheet 1, Unit 1 Residual Heat Removal, Revision 64M-151, Sheet 2, Unit 1 Residual Heat Removal, Revision 53Miscellaneous:EC-RISK-1063, Evaluation of Operator Actions for Application in Susquehanna lPE, Revision 1

Section 1R05: Fire ProtectionProcedures:FP-213-243, Access Area (11-105) Remote Shutdown Panel Area (11-09), Truck Airlock(11-100), Fire Zones

2-2A,2-2Q, Elevation 670'-", Revision 7ON-013-001, Response to Fire, Revision 29OP-283-001 , Automatic Depressurization System and Safety Relief Valves, Revision 15FP-013-155, Control Room (C-409) and Soffits Fire Zones 0-26H,0-26N, and 0-26P, Elevation729', Revision 7FP-01 3-202, Fire Service and Circulating Water Pump Areas (Basement) Fire Zone 0-71B,0-71A, Elevation 661'-0", Revision 3EC-PIPE-16310, Develop Maximum WallThickness Values for Fire Protection (KBF) Piping,Revision 0Attachment

A-3FP-113-119, "Pre-Fire Plan - Circulation Space (1-500) and Adjacent Rooms (1-511 ,517,514,508, 513), Fire Zones 1-5A-N, S, W; 1-5H Elevation 749'-1"," Revision 5FP-113-123, "Pre-Fire Plan - Load Center Room (1-507), Load Center Room (1-510) Fire Zone1-5F, 1-5G Elevation 749'-1"," Revision 4FP-013-189, Diesel Generator Bay A Fire Zone 0-41A Elevations 677', 660', and 610', Revision4FP-013-192, Diesel Generator Bay B Fire Zone 0-418 Elevations 677', 660', and 610', Revision4FP-013-195, Diesel Generator Bay C Fire Zone 0-41C Elevations 677', 660', and 610', Revision4FP-013-198, Diesel Generator Bay D Fire Zone 0-41 D Elevations 677' , 660' , and 610', Revision4Condition Reports (*NRC identified):1

440693*, I

454649*, 1 469231.Action Requests (*NRC ldentified):97817 4, 1 051 738, 9791 39Work Order:978949Drawinq:KBF-1-4,lsometric Pump House Fire Protection, Revision 7E205953, Sheet 2, 'RB Fire Doors and Fire Dampers, Elevation 749'-1"," Revision 9E205953, Sheet 1, "RB Fire Zone Plan, Elevation 749'-1"," Revision 11

Section 1R06: Flood Protection MeasuresCondition Reports (*

NRC identified):1 2907 22, 1 2247 61, 1 2247 60Drawinqs:4107201, Sheet 48, "Manhole Schedule Notes and Details," Revision 9A107201, Sheet 49, "Manhole Schedule Notes and Details," Revision

54107201, Sheet 50, "Manhole Schedule Notes and Details," Revision 9A107201, Sheet 51, "Manhole Schedule Notes and Details," Revision

64107201, Sheet 40, "Manhole Schedule Notes and Details," Revision

84107201, Sheet 41, "Manhole Schedule Notes and Details," Revision

64107201, Sheet 42, "Manhole Schedule Notes and Details," Revision

84107201, Sheet 43, "Manhole Schedule Notes and Details," Revision 5Miscellaneous:PLA-6206 and

PLA-6307, "SSES Response to

GL 2007-01, Inaccessible Underground PowerCable Failures that Disable Accident Mitigation Systems or Cause Plant TransientsSection 1R7: Heat Sink Performance:Procedures:EC-035-1026. Tables 1 and 2. Revision 0Attachment

A-4Condition Reports:1404495,1437021Miscellaneous:Assist Ops Manager Turnover Log, July 12 through July 1 4,2011Evaluation for SFP Time to 200 F less than 200F and Compensatory ActionsHP Survey Maps for SFP Heat Exchanger Spaces, July 12 through July 14, 2011

Section 1R11: Licensed Operator Requalification ProqramCondition Reports (*

NRC identified):1459843Section 1 R12: Maintenance EffectivenessProcedures:SO-149-A05, "Quarterly RHR LOOP A Valve Exercising," Revision 12SO-149-015, "RHR Two year RPI Checks," Revision 14Condition Reports:1449694,1449695,

1449423,1451020,1451096,

1450646,1450316,1465702*,

1465698*1 30827 6, 1 47 37 66., I 47 377 1*, 1 47 3133*Drawinqs:E-153, Sheet 23, "RHR Test Return Valve Unit 1," Revision 10Miscellaneous:Maintenance Rule Basis Document - System 49, "RHR"EC-049-1010, "RHR System - Suppression Pool Cooling (SPC) Design and Licensing BasisEvaluation," Revision 1EC-VALV-0569, "Design Basis Development for Priority 1 MOVs," Revision 21EC-049-0549, "NOV Data Detail Calculation for

HV 151 F024A, Revision 6MREP Meeting Minutes for Meeting #2011-0307, dated March 7,2011MREP Meeting Minutes for Meeting #2011-0328, dated March 28,2011Susquehanna LLG Eighth Maintenance Rule Periodic Assessment, dated June 1 ,2011NEI-93-01, "lndustry Guideline for Monitoring the Effectiveness of Maintenance at NuclearPower Plants," Revision 2Station Health Report for January 1,2011 - May 31,2011, dated August 22, 2011, Revision 1

Section 1Rl3: Maintenance Risk Assessments and Emerqent Work ControlProcedures:NDAP-QA-1902, Maintenance Rule Risk Assessment and Management Program, Revision 3NDAP-QA-0340, Protected Equipment Program, Revision 10MT-AD-504, Scaffold Erection Review and Inspection, Revision 17TP-250-004,

RCIC Turbine Overspeed Trip Testing with Auxiliary Steam50-250-005, 24 Month RCIC Flow Verification, Revision 17Condition Reports:1

436836,

1436841,

1446094*,

1447030*, 1447Q28*,

1447027*,

1448335*,

1448335*, 145A534,1430270Attachment

A-5Work Orders:1

073966, 1

436402, 1040467Drawinqs:E-193, Sheet 28VC-182, Sheet 1M-2153, FPC and Clean-Up, Revision 32Miscellaneous:EOOS Risk Model Units 1 and 2 for July 13,2011Risk Profiles for Unit 1 and Unit 2 for Wednesday, Augusl3,2011Protected Equipment Program Electronic Tracking Forms for Systems 149, 116, 126, Fuel RodCooling, and 234FSAR 14.2 - 53154,704-7 ,7.7-35, 14.3-11, Section 5.4.6

Section 1Rl5: Operabilitv EvaluationsProcedures:30-259-002, "Monthly Operability Check of Suppression Chamber Drywell Vacuum ReliefBreaker Valves, Revision 12SM-188-001, "250VDC Station Batteries Weekly/Monthly/Quarterly Electrical ParameterChecks," Revision 15NDAP-00-0341, "Adverse Condition Monitoring and Contingency Planning," Revision 0NDAP-QA-0703, "Operability Assessments and Requests for Enforcement Discretion,"Revision 15SO-251-1304, "Quarterly Core Spray Valve Exercising Division ll," Revision 9Condition Reports (*

NRC'identified):1435119,

1435319,

1435138,1449979,1449419,1449979*,1243388,

1456166,

1399810,1

459230*,

1459248* ,

1465729*,

1459230*,

1456166*,

1459248*,

1460385*, 1

460990,1 461 088,

146129, 1

398255,

1398276, 1 3981 91 6, 1 4067 11 ,

1405543,

1406724,1 47 1320*, 1 47 1350*, 1

470497, 1 47 0498,Drawinqs:E-22, Sheet 2, 13.9 kV Startup Bus 0A103 and 0A105, Revision 30E-102, Sheet 7 , 13.8 kV Bus 10 Incoming Circuit Breaker Control, Revision 15Miscellaneous:IOM'166, "Operation and Maintenance Manual for Vacuum Relief Valve, Type CV 1-2,24-inchand Auxiliaries, Revision 6IEEE 450-1995, "IEEE Recommended Practice for Maintenance Testing and Replacement forVented Lead-Acid Batteries for Stationary Applications"EPRI topical Report

TR-100248, "Stationary Battery Guide: Design Application andMaintenance"POC J. Smith, Nuclear Plant OperatorUnit 1 Operating Log, September 27,2Q11

Section 1R19: Permanent Plant ModificationsProcedures:NDAP-QA-1218, "Temporary Changes," Revision 1 0Attachment

A-6NDAP-QA-1220, "Engineering Change Process," Revision 7MT-GM-033, "Online Leak Repairs," Revision 12Condition Reports (* NRC identified):1452575, 1

454903,

1442911, 1442554Miscellaneous:Team Incorporated PO 86187E

Section 1Rl9: Post-Maintenance TestinqProcedures:SO-231-001,

RWM Operability Demonstration Startup following System Failure, Revision 10TP-054-104, "lnitial Start and Run-ln of New or Repaired 'D' ESW Pump Motor," Revision 0MT-054-001, "ESW Pump (OP504 A-D) Disassembly and Reassembly, Revision 1250-054-803, "Quarterly ESW Flow Verification LOOP B," Revision 10SO-024-001C, "Monthly Diesel Generator 'C' Operability Test," Revision 8NDAP-QA-0423, Station Pump and Valve Testing Program, Revision 20Condition Reports (*NRC-identified):1 455433.,

1454488,

1241419, 1 81 241,

1238355,

1404136,

1176615, 1

453601 , 1

460501 ,1

460502, 1 46A5A4, 1

460505, 1

460651, 1 46651 3, 1 4643Q3, 1 45777 4, 1

460655,1459252, 1

466654, 1

460390,

1467307* ,

1391024,

1375964, 1 430964Action Requests:231359,1399103Work Orders:1278385,

1295230,

131243,231 359,

1454821,

1438764, 1 3391 60,

1364823, 9951 93,

1446364,1391024, 137 8426, 1 431345Drawinqs:E-193, Sheet28VC-182, Sheet 1Miscellaneous:PSP-29, "Damper and Ducting Component Testing," performed July 11,2Q11TRO 3.1.4ASME OM Code 1998NUREG-1482, Guidelines for IST at NPPs, Revision 1MT-016-001, RHRSW Pump Disassembly and Reassembly, Revision 15

Section 1R20: Refuelinq and Other Outaqe ActivitiesProcedures:GO-200-002, Plant Startup, Heatup, and Power Ascension, Revision 60SR-200-008, In-Sequence, Critical and Shutdown Margin Demonstration, Revision 11Miscellaneous:Unit 2, Cycle 16 Sequence A2 Startup Control Rod SequenceAttachment

A-7

Section 1R22: Surveillance TestinqProcedures:SO-151-A02, "Quarterly Core Spray Flow Verification - Division l, Revision 18SE-070-01 1, "24-Month Secondary Containment Drawdown and Inleakage Surveillance Test,Zones l, ll, and lll," Revision 11SE-170-01 1, "Z4-Month Secondary Containment Drawdown and Inleakage Surveillance Test,Zone I and lll," Revision 11SE-204-103,"24 Month '2A' Auxiliary Bus Degraded Grid Test," Revision 4SO-216-804, "RHRSW System Comprehensive Flow Verification Division ll," Revision 4NDAP-QA-0002, "Procedure Program and Procedure Change Process," Revision 20Condition Reports (*

NRC identified):1434442,1383361,1453805,1453806,1453807.1466147,754927,1460362*,1460503.,1068342, 1

169576,

610828,

1453805,

1453806,

1453807, 1453593Work Orders:20925-01,20547-01,Miscellaneous:EC-051-A02, "Quarterly Core Spray Flow Verification - Division l, Revision '18EC-070-1001, "Secondary Containment and Control Structure Pressure Boundary - EquipmentLeakage Through Penetrations," Revision 14PCAFs 2007 -1 1 53, 2007 -1 1 51Letter to B. McKinney dated February 2,2006 Regarding Licensee Amendment No. 229 toNPF-14 and No. 205 to

NPF-22PLA-5857, Proposed Licensee Amendment for Change to TS 3.6.4.1.4 and 3.6.4.1.5NRC Administrative Letter 90-10, "Dispositioning of TSs That Are Insufficient to Assure PlantSafety"EC-RADN-1125, "CHRE and Offsite Post LOGA Doses - AST," Revision 3EC-070-1001, "Secondary Containment and Control Structure Pressure Boundary - EquivalentLeakage Through Penetrations," Revision 13

==Section 1EP6: Drill EvaluationProcedures:Condition Reports:1455585,

1455606,

1455574,1456031 ,1456181,1456183,

1460402,

1461860, 1

464751,1464872,

1464773,

1464842,

1464872, 1

464889, 1

464865, 1

464868, 1 465730.Section 4OAl : Performance lndicator VerificationProcedures:NDAP-QA-0737, Reactor Oversight Process (ROP) Performance Indicators, Revision 7Tl-CH-106, Preparation of Monthly==

NRC Pl - Reactor Coolant Specific Activity, Revision 4NDAP-QA-0630, Conduct of Chemistry, Revision 8NDAP-QA-1195, Chemistry Program, Revision 5CH-AD-001, Chemistry Sampling Analysis and Work Schedule, Revision 6NDAP-QA-0737, ROP Performance Indicators, Revision 7Attachment

A-8Condition Reports (* NRC identified):1290594,

1301429,

1309267 ,

1320299,

1329465,

1277180, 1

338689,1365457, 1 41 6635, 1

399698, 1 43427 3, I

448124*, 1 457 945*,1

328563, 1

328561, 1 357 297, 1 357 37 3, 1

463504*, 1 46347 5.Miscellaneous:TS 3.4.7 and TS 3.4.4SC-276-102, Unit 2 Primary Coolant Specific Activity Base EquivalentNEI-99-02, Regulatory Assessment Performance I nd icator Gu idel i ne,Dose Equivalent l-131 Samples 11-7634, 11-7641MSPI Derivation Reports for Unavailability and Unreliability for Units 1to March, 2011for HPCI1350858,

1382094,1357572, 1

356823,2-131Revision 6and2from January,2010PL-NF-06-002, MSPI Basis Document, Revision 6MSPI Derivation Reports for Units 1 and 2 from January,2010 to June, 2011System Journals for RHRSW, ESW, and

HPCITM-OP-016-5T, "RHRSW," Revision 8

Section 4OA2: ldentification and Resolution of ProblemsProcgdures:NDAP-00-753, Revision 0MT-GE-30, Revision 19Condition Reports (*

NRC identified):1430912*, 143Q914*,

1430917*,

1433437*,

1433522*,

1433453*,

1439649*,

1438805*,1442992. , 1 448088., 1 459843.,1 438452',

1438453, 1

396005,

1354847 ,

1445763,1 1 94033, 1

385601,

1356822, 1

356830, 14197 12,

1381475, 1 39981 0, 1

389069,1

409053, 1 1 48924, 1 1 858 1 4, 12217 1 0, 12217 1 4, 12217 I 6, 1 27 8385, 12777 61,1

365706, 1

359335, 1278385Work Ordel:6812288

Section 4OA3: Event FollowupProcedures:GO-200-002, Plant Startup, Heatup, and Power Operation, Revision 60ON-000-002, Natural Phenomena, Revision 25TP-000-015, Settlement Monitoring of the

ESSW Pump House, Revision 0SO-231-001, "RWM Operability Demonstration Startup/Following System Failure," Revision 10GO-200-002,"Plant Startup, Heatup, and Power Operation, Revision 60ON-200-101, "Scram/Scram lmminent," Revision 22ON-000-002, "Natural Phenomenon," Revision 25EP-TP-O01, "EAL Classification Levels," Revision 4OP-099-002, Seismic Monitoring System, Revision 16ENS 47186Condition Reports:1454628*,

1455547 ,

1455562,

1455592,

1455613, 1

455595 ,

1455604*, 1

455603* ,

1455602*,1455496*,

1454249,

1454488,

1453763,

1453725,

1453671,

1453766,

1453796,Attachment

1453797,1 455581.A-91453799, 1

454008,

1454093,

1454081,

1454488, 1

455602*, 1

455603*,1455992*, 1

455604, 1

455604*,

1455992*, 1

455581 , 1

455039*Drawinqs:E-120, Sheet 8, "Unit 1 Schematic Diagram Turbine EHC," Revision 11Miscellaneous:Unit 2, Cycle 16, Startup Control Rod Sequence A-1 at Exposure 01050PORC Package dated August 21,2011

Section 4OA5: Other ActivitiesProcedures:TP-245-028,

SAT-ICS Initial Operation of FWLC, Reactor Recirculation Speed Control andRFPT Speed Control, Completed June 23, 2011, Revision 1TP-245-036, Unit 2 ICS Test Plan (EC 864462), Revision 1TP-245-029, Feedwater Master Water Level Controller (MWLC) Tune-up, Revision 1TP-245-031, Sat - ICS Startup and Tune Up in Condition 1 and 2 Less Than 40 Percent RTP,Revision 0TP-245-034, ICS Startup and Flow Control Tuning Equal to or Greater Than 60 Percent RTP,Revision 1TP-299-010, EPU Master Test Procedure, Revision 3TP-293-041, EPU Phase 2EHC Pressure RegulatorTesting, Revision 1TP-200-013, EPU Data Collection and Extrapolation, Revision 1DP-151-001, Core Spray'A'&'C'Drain Procedure While at Power, Revision 10DP-152-002, HPCI - Drain Procedure While at Power, Revision 7DP-152-005, HPCI Turbine and Pump Drain Procedure While Unit Shutdown, Revision 5NDE-UT-O14, Ultrasonic Thickness Examination, Revision 7OP-149-001, RHR System, Revision 40OP-151-001, Core Spray System, Revision 33OP-152-001, HPCI System, Revision 45SO-149-001, RHR Monthly Alignment Check, Revision 22SO-149-A02, Quarterly RHR System Flow Verification Division l, Revision 17SO-149-802, Quarterly RHR System Flow Verification Division ll, Revision 19SO-151-001, Monthly CS System Discharge Line Filled and Valve Alignment Check, Revision 9SO-152-004, Quarterly HPCI Valve Exercising, Revision 29SO-152-005, 24 Month HPCI Flow Verification, Revision 19SO-152-006, High Pressure Coolant Injection Comprehensive Flow Verification, Revision 11SO-249-001, RHR Monthly Alignment Check, Revision 22Condition Reports:1434495,1434748,1434848,1435127,1435130,1435472,143Q721,

1438450,

1440148,1440515,

1434748,

137848, 1

384849,

1443101*, 14431Q9. ,

1443129,

1443146,1444599.,

1444591*,

1445286,

1433456,

1430716,

1378105,

1416836,

1448096*,0987202, 1

033823,

1033824, 1

033835,

1046092, 10464Q2, 1

046403, 1Q69732,1069733,

069734,

1069735,

1072122,1077922,1Q79149,

1079350,1113537,

1168769,1178658,1249122,1352000,1372643,1458550*,1458672*,1459114*,1459143",1 459833., 1 459980.Calculations and Evaluations:EC-049-1073, RHR System Acceptance Criteria for Gas lntrusion, Revision 0Attachment

A-10EC-049-1075, Summary of Evaluations and Actions Completed in Response to Generic Letter2008-01, Revision 0EC-052-1056, HPCI System Acceptance Criteria for Gas Intrusion, Revision 0EC-052-1057, Establish Gas Void Acceptance Criteria for HPCI, Core Spray and RHR SuctionPiping in Support of Generic Letter 2008-01, Revision 0Com pleted Tests/Procedures/Exami nations:NDE-lSl-09-004, Unit 2 Core Spray 'B'

GBB-201-4 Gas Intrusion Inspection, January 27, 2009NDE-lSl-0g-177, Unit 2 HPCI Suction Line

HBB-209-1, November 23, 2009NDE-lSf-10-031, Unit 1 HPCI Line

DBB-120-1at HV2F006, March 3,2010 and April 10,2010NDE-lSl-10-050, Unit 1 RHR Loop 'A'Air Intrusion Inspection, March 10,2010NDE-lSl-10-051, Unit 1 RHR Loop 'B'Air lntrusion Inspection, March 10,201QNDE-MISC-2009-001, Unit 2 HPCI Line

DBB-220-2 at HV2F006, April 9,2009SO-149-001, RHR Monthly Alignment Check, Vent Time Results from April 2005 - August 201 1SO-149-A02, Quarterly RHR System Flow Verification Div l, Vent Time Results from August2008 to August 2011SO-149-802, Quarterly RHR System Flow Verification Div ll, Vent Time Results from August2008 to August 2011SO-151-001, Monthly CS System Discharge Line Filled and Valve Alignment Check, Resultsfrom August 2008 to August 2011SO-152-001, Unit 1 Monthly HPCI Pump Discharge Line Filled and Alignment Verification, VentTime Results from June 2008 to July 201150-249-001, RHR Monthly Alignment Check, Vent Time Results from April 2005 - August 201 1SO-251-001, Monthly CS System Discharge Line Filled and Valve Alignment Check, Resultsfrom August 2008 to July 2011SO-252-001, Unit 2 Monthly HPCI Pump Discharge Line Filled and Alignment Verification, VentTime Results from June 2008 to August 2011TP-249-087, Measuring Vent Times of RHR Piping for Known Gas Volumes, June 27 ,zQQgWork Orders:1079351,

1079390,

1079423,

1079644,

1079645,

1079646,1079648,

1079649,1

149635,1253209Drawinqs:DBB-107-1, lsometric - RB RHR - Unit 1 , Revision 5DBB-107-2, lsometric - RB RHR - Unit 1, Revision 5DBB-1 13-1, lsometric - RB Core Spray - Unit 1, Revision 3DBB-113-2, lsometric - RB Core Spray - Unit 1, Revision 4DBB-1 17-1 , lsometric - RB HPCI - Unit 1, Revision 8DBB-1 19-1, lsometric - RB Feedwater - Unit 1, Revision 8DBB-120-1, lsometric - RB HPCI - Unit 1, Revision 9DBB-120-2, lsometric - RB HPCI - Unit 1, Revision 5DBB-207-1, lsometric - RB RHR - Unit 2, Revision 4DBB-213-1, lsometric - RB Core Spray - Unit 2, Revision 3DBB-217-1, lsometric - RB HPCI - Unit 2, Revision 4DBB-219-1, lsometric - RB Feedwater - Unit 2, Revision 5DBB-220-1, lsometric - RB HPCI - Unit 2, Revision 5DBB-220-2. lsometric - RB HPCI - Unit 2, Revision 3DCA-108-1, lsometric - RB RHR - Unit 1, Revision 7DCA-109-1, lsometric - RB Core Spray - Unit 1, Revision 53DCA-109-2, lsometric - RB Core Spray - Unit 1, Revision 6Attachment

A-11DCA-1 10-1 , lsometric - RB RHR - Unit 1, Revision 12DCA-1 10-2, lsometric - RB RHR - Unit 1 , Revision 12DCA-209-2, lsometric - RB Core Spray - Unit 2, Revision 4DCA-210-2, lsometric - RB RHR - Unit 2, Revision 5E105951, P&lD - Residual Heat Removal - Unit 2, Sheet 1, Revision 56E105951, P&lD - Residual Heat Removal - Unit 2, Sheet 2, Revision 45E105951, P&lD - Residual Heat Removal - Unit 2, Sheet 3, Revision 23E105952, P&lD - Core Spray - Unit 2, Revision 27E105955, P&lD - High Pressure Coolant Injection - Unit 2, Sheet 1, Revision 42E105956, P&lD - HPCI Turbine/Pump - Unit 2, Sheet 1, Revision 27E106213, P&lD - Condensate & Refueling Water Storage - Unit 1, Sheet 1, Revision 52E106213, P&lD - Condensate & Refueling Water Storage - Unit 1, Sheet 2, Revision '14E106256, P&lD - Residual Heat Removal - Unit 1 , Sheet 1, Revision 64E106256, P&lD - Residual Heat Removal - Unit 1, Sheet 2, Revision 53E106256, P&lD - Residual Heat Removal - Unit 1, Sheet 3, Revision 26E106256, P&lD - Residual Heat Removal - Unit 1, Sheet 4, Revision 19E106257, P&lD - Core Spray - Unit 1, Revision 39E106260, P&lD - High Pressure Coolant Injection - Unit 1, Sheet 1, Revision 54E106261 , P&lD - HPCI Turbine/Pump - Unit 1, Sheet 1 , Revision 36EBB-102-1, lsometric - RB HPCI - Unit 1, Revision 3EBB-102-2, lsometric - RB HPCI - Unit 1, Revision 6EBB-202-1, lsometric - RB HPCI - Unit 2, Revision 4EBB-202-2, lsometric - RB HPCI - Unit 2, Revision 5GBB-101-2, lsometric - RB Core Spray - Unit 1, Revision 4GBB-101-4, lsometric - RB Core Spray - Unit 1 , Sheet 1 , Revision 9GBB-102-1, lsometric - RB Core Spray - Unit 1, Revision 9GBB-102-3, lsometric - RB Core Spray - Unit 1, Revision 7GBB-103-1, lsometric - RB Core Spray - Unit 1, Revision 2GBB-104-1, lsometric - RB RHR - Unit 1, Revision 7GBB-104-2, lsometric - RB RHR - Unit 1, Revision 4GBB-104-3, lsometric - RB RHR - Unit 1, Sheet 1, Revision 8GBB-104-4, lsometric - RB RHR - Unit 1, Revision 5GBB-105-1, lsometric - RB RHR - Unit 1, Revision 6GBB-105-2, lsometric - RB RHR - Unit 1, Revision 6GBB-106-1, lsometric - RB RHR - Unit 1 , Revision 9GBB-109-1, lsometric - RB RHR - Unit 1 , Revision 7GBB-109-2, lsometric - RB RHR - Unit 1, Revision 9GBB-1 15-1, lsometric - RB RHR - Unit 1, Sheet 1, Revision 7GBB-1 16-1, lsometric - RB RHR - Unit 1, Revision 6GBB-1 18-1, lsometric - RB RHR - Unit 1, Revision 7GBB-201-1, lsometric - RB Core Spray - Unit 2, Revision 2GBB-201-3, lsometric - RB Core Spray - Unit 2, Revision 3GBB-201-4, lsometric - RB Core Spray - Unit 2, Revision 4GBB-204-1, lsometric - RB RHR - Unit 2, Sh. 1, Revision 6GBB-204-2, lsometric - RB RHR - Unit 2, Revision 5GBB-206-1, lsometric - RB RHR - Unit 2, Revision 6GBB-212-1, lsometric - RB RHR - Unit 2, Revision 4GBB-217-1, lsometric - RB RHR - Unit 2, Revision 3HBB-104-1, lsometric - RB Core Spray - Unit 1, Revision 10HBB-104-2, lsometric - RB Core Spray - Unit 1, Revision 9HBB-107-1, lsometric - RB HPCI - Unit 1, Revision 3Attachment

2HBB-109-1 , lsometric - RB HPCI - Unit 1, Revision 8HBB-1 10-1 , lsometric - RB RHR - Unit 1 , Revision 10HBB-1 10-2, lsometric - RB RHR - Unit 1, Revision 10HBB-1 10-3, lsometric - RB RHR - Unit 1 , Sheet 1, Revision 8HBB-110-4, lsometric - RB RHR - Unit 1, Sheet 1, Revision 8HBB-111-1, lsometric - RB RHR - Unit 1, Revision 6HBB-1 1 1-2, lsometric - RB RHR - Unit 1, Revision 4HBB-204-2, lsometric - RB Core Spray - Unit 2, Sheet 1, Revision 6HBB-207-1, lsometric - RB HPCI - Unit 1, Revision 2HBB-209-1, lsometric - RB HPCI - Unit 2, Sheet 1, Revision 5HBB-210-1, lsometric - RB RHR - Unit 2, Revision 7HBB-210-3, lsometric - RB RHR - Unit 2, Revision 6HCB-101-1 , lsometric - RB Cond. & Refuel Water Storage - Unit 1 , Revision 4HCB-102-1, lsometric - RB Core Spray - Unit 1, Revision 2HCB-103-1 , lsometric - RB HPCI - Unit 1, Revision 2HCB-1-1, lsometric - Condensate Storage and Refuel Water Storage - Unit 1 & 2, Revision 4HCB-1-2,lsometric - Condensate Storage and Refuel Water Storage - Unit 1 & 2, Revision 4HCB-201-1, lsometric - RB Cond. and Refuel Water Storage - Unit 2, Revision 7HCB-203-1, lsometric - RB Cond. and Refuel Water Storage - Unit 2, Sheet 1, Revision 7SP-HCB-203-1, lsometric - 1" Drains and Vent on 16"

HCB-203-1 Condensate & RefuelingWater Storage System, Revision 6Miscellaneous:TM-OP-045 l-ST, Rector Feedwater Level Control System, Revision 1Letter from B. T. McKinney (PPL Susquehanna, LLC) to USNRC, "Three Month Response toGeneric Letter 2008-01," dated May 27,2OQBLetter from B. T. McKinney (PPL Susquehanna, LLC) to USNRC, "Nine-Month Response toGL 2008-01," dated October 14,2008Letter from T. S. Rausch (PPL Susquehanna, LLC) to USNRC, "Unit 2 Supplemental Responseto Generic Letter 2008-01," dated August 10,2009Letter from T. S. Rausch (PPL Susquehanna, LLC) to USNRC, "Unit 1 Supplemental Responseto Generic Letter 2008-01," dated July 14, 201QLetter from T. S. Rausch (PPL Susquehanna, LLC) to USNRC, "Response to Request forAdditional Information Regarding Generic Letter 2008-01," dated January 6,2011Susquehanna Steam Electric Station - TSs, Unit 1, Amendment2S4Susquehanna Steam Electric Station - TSs, Unit 2, Amendment 234Susquehanna Steam Electric Station Updated Final Safety Analysis Report, Unit 1 & 2,Revision 64EG303, Managing Gas Accumulation in Plant Systems (Engineering Training), August 30, 2010NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, DecayHeat Removal and Containment Spray Systems, January 11, 2OOBOperations Bulletin (Operations Hotbox Training), October 27, 2008Station Health Report, January 1,2011 - May 31, 2011

Section 4OA7: Licensee-ldentified ViolationsCondition Reports:1444679,1412115Attachment

ACEADAMSALARAAOMARASMEATWSCAPccACFRcNoCRCSCSECCSEDGEHCEOOSEPEPUEROESFESSESWFINFPCGLHPCIHRAHVHVACHXtcst&cIEEEINtMcIPIRISTKVLCOLERLOCALOOPMGMRCMSLA-13

LIST OF ACRONYMS

Apparent Cause EvaluationAgencyruide Document and Access Management SystemAs Low As ls Reasonably AchievableAssistant Operations ManagerAction ReportAmerican Society of Mechanical EngineersAnticipated Transient Without ScramCorrective Action ProgramCommon Cause AnalysisCode of Federal RegulationsChief Nuclear OfficerCondition ReportCore SprayControl StructureEmergency Core Cooling SystemEmergency Diesel GeneratorElectrohydraulic ControlEq uipment Out-of-ServiceEmergency PreparednessExtended Power UprateEmergency Response OrganizationEmergency Safety FeatureEngineering Safeguard SystemEmergency Service WaterFindingFuel Pool CoolingGeneric LetterHigh Pressure Coolant lnjectionHigh Radiation AreaHigh VoltageHeating, Ventilation and Air-ConditioningHeat ExchangerIntegrated Control SystemInstrumentation and Controlslnstitute of Electrical and Electronics EngineersInformation NoticeInspection Manual ChapterInspection ProcedureNRC Inspection ReportInservice TestingKilovoltsLimiting Condition for OperationLicensee Event ReportLoss of Coolant AccidentLoss of Offsite PowerMotor GeneratorManagement Review CommitteeMain Steam LineAttachment

MSPINCVNDAPNEINRCNRROAOBEOFRo&MoosPARSPIPI&RPMTPPLQARBRCARCARCtCRCSRFORFPRGRHRRHRSWRMARMSROROPRPSRTPRWMURWPRWSTSBLCSBOSCWESDESDPSESFPSFPCsocSOWSRVSSCSSESSESSWA-14Mitigating Systems Performance IndexNon-Cited ViolationNuclear Department Administrative ProcedureNuclear Energy InstituteNuclear Regulatory CommissionOffice of Nuclear Reactor RegulationOther ActivitiesOperating Basis EarthquakeOperability Followup RequestOperation and MaintenanceOut-of-ServicePublicly Available Records[NRC] Performance IndicatorProblem ldentification and ResolutionPost-Maintenance TestPPL Susquehanna, LLCQuality AssuranceReactor BuildingRadiologically Controlled AreaRoot Cause AnalysisReactor Core lsolation CoolingReactor Coolant SystemRefuel OutageReactor Feed PumpINRC] Regulatory GuideResidual Heat RemovalResidual heat Removal Service WaterRisk Management ActionsRadiation Monitoring SystemReactor OperatorReactor Oversight ProcessReactor Protection SystemRated Thermal PowerRiver Water Make-UpRadiation Work PermitRefueling Water Storage TankStandby Liquid ControlStation BlackoutSafety Conscious Work EnvironmentSkin Dose EquivalentSignificance Determination ProcessSafety EvaluationSpent Fuel PoolSpent Fuel Pool CoolingStation Operation CommitteeSystem Outage WindowSafety Relief ValveStructures, Systems and ComponentsSafe Shutdown EarthquakeSusquehanna Steam Electric StationService WaterAttachment

A-15Tl Temporary lnstructionTRM Technical Requirements ManualTS Technical SpecificationsUFSAR Updated Final Safety Analysis ReportUT Ultrasonic TestWO Work OrderAttachment