ML20136J365
| ML20136J365 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 03/14/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17158B998 | List: |
| References | |
| 50-387-97-01, 50-387-97-1, 50-388-97-01, 50-388-97-1, NUDOCS 9703200093 | |
| Download: ML20136J365 (8) | |
Text
.a NOTICE OF VIOLATION .,
Pennsylvania Power and Light Company (PP&L) Docket Nos. 50-387, 50-388 Susquehanna Unit 1 and Unit 2 License Nos. NPF-14, NPF-22 During an NRC inspection conducted from January 14,1997, through February 24,1997, three violations of NRC requirements were identified in accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the violations are listed below;
- a. Technical Specification (TS) 6.8.1 requires that written procedures shall be established and implemented for applicable procedures recommended in Appendix
'A' of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Appendix 'A', item 5, requires procedures for abnormal, offnormal, and alarm conditions. Item 5 further states that procedures for annunciators should contain the immediate action that is to occur automatically and the immediate operator action.
Alarm response procedure AR-231-001 for the " Unit 2 Recomb Discharge H2 Conc Hi- Hi" annunciator lists the automatic action for a 2% hydrogen concentration as an Offgas System Isolation. Further, AR-231-001 Operator action 2.2.1 requires operators to ensure automatic actions occur.
Contrary to the above, on December 19,1996, operators failed to ensure the automatic actions occurred after the " Unit 2 Recomb Discharge H2 Conc Hi- Hi" annunciator alarmed and after a grab sample show a hydrogen concentration of 8%.
Specifically, the offgas system did not automatically isolate and operators did not take immediate manual action to isolate it.
l This is a Severity Level IV violation (Supplement 1).
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- b. 10 CFR Part 50, Section 50.55a, " Codes and Standards," requires that protection systems meet the requirements of the institute of Electrical and Electronic Engineers (IEEE) " Criteria for Nuclear Power Plant protection systems," Std 279-1971. IEEE 279, Section 4.13, requires that, if the protective action of some part of the l protection system has been bypassed, or deliberately rendered inoperative for any j purpose, this fact shall be continuously indicated in the control room.
Regulatory Guide (RG) 1.47, May 1973, describes an acceptable method of complying with the requirements of IEEE Std 279. RG 1.47 states that an acceptable system will automatically indicate at the system level the bypass or deliberately induced inoperability of the protection system.
Contrary to the above, since initial operation, the bypass indication system (BIS) at Susquehanna has not provided the continuous control room indication required by lEEE 279, and 10 CFR 50.55a, when a portion of the residual heat removal system is bypassed. The BIS does not automatically indicate at the system level when an RHR pump is rendered inoperable by a trip circuit that is enabled when the pump's suction valve is not full open. As a result, the RHR system is inoperable during
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9703200093 970314 PDR ADOCK 05000387 G PDR
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2 quarterly RHR suction valve testing and no automatic indication of this condition is provided at the system level.
This is a Severity LevelIV violation (Supplement 1). l 1
- c. 10 CFR 50, Appendix B, Criterion XVI, requires that licensees establish measures to i assure that conditions adverse to quality such as f ailures, malfunctions, deficiencies, defective material and equipment and nonconformances are promptly identified and corrected.
Contrary to the above, two examples were identified where the licensee failed to ;
control maintenance activities such that conditions adverse to quality were created j and not promptly identified and corrected. )
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- 1. In 1991, the licensee failed to implement adequate corrective actions in response to a vendor letter that identified a deficiency on the contact surfaces of the 'E' emergency diesel generator bridge transfer switch. As a result of the licensee's failure to implement corrective actions to preclude the condition identified by the vendor, the transfer switch f ailed to perform ,
its function on December 10,1997, during an 'E' emergency diesel l surveillance test. l
- 2. In December 1996, the licensee's corrective actions in response to the f ailed
'E' diesel generator transfer switch included the development of a trouble shooting plan. As a result of inadequate control and review of the trouble i shooting plan, a failure was induced in safety related equipment and the 'E' emergency diesel generator f ailed a second surveillance test.
This is a Severity Level IV violation (Supplement 1). :
Pursuant to the provisions of 10 CFR 2.201, Pennsylvania Power and Light Company is l hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a l copy to the Regional Administrator, Region I, and a copy to the NRC Resident inspector at the f acility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a
" Reply to a Notice of Violation" and should include for each violation: (1) the reason for j the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps !
that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not j received within the time specified in this Notice, an order or a Demand for information may 1 be issued as to why the license should not be modified, suspended, or revoked, or why such other action as mey
- i proper should not be taken. Where good cause is shown, consideration will be gm -) extending the response time.
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i 3 t Because your response will be placed in the NRC Public Document Room (PDR), to the f extent possible, it should not include any personal privacy, proprietary, or safeguards i information so that it can be placed in the PDR without redaction. If personal privacy or '
proprietary information is necessary to provide an acceptable response, then please provide i a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request I withholding of such material, you EWi.1 specifically identify the portions of your response :
that you seek to have withheld and provide in detail the bases for your claim of withhold-ing (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a [
request for withholding confidential commercial or financial information). If safeguards )
information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
Dated at King of Prussia, PA i this 14th day of March 1997 !
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- q$* M%q)g UNITED STATES
[ 3 .,., 'g NUCLEAR REGULATORY COMMISSION 5 'j REGloN l
.* % 4 475 ALLENDALE ROAD b
%...,+o KING oF PRUsstA, PENNSYLVANIA 19406-1415 March 14,1997 Mr. Robert G. Byram Senior Vice President - Nuclear Pennsylvania Power & Light Company 2 North Ninth Street -
Allentown, Pennsylvania 18101
SUBJECT:
NRC INTEGRATED INSPECTION REPORT 50-387/97-01, 50-388/97-01 AND NOTICE OF VIOLATION.
Dear Mr. Byram- -
This refers to the inspections conducted between January 14,1997 and February 24, i 1997, at the Susquehanna Steam Electric Station. The inspections covered routine I activities by the resident inspectors and announced inspections by Region I specialist inspectors for radiological effluent control and emergency preparedness. The enclosed report presents the results of these inspections.
Overall, your conduct of operations at the Susquehanna facility during this period was characterized by safe operation and conservative decision making. The NRC specialist inspections found that PP&L continues to maintain a very good radioactive liquid and gaseous effluent control program, and a good emergency preparedness program.
However, based on the results of this inspection the NRC has also determined that three violations of NRC requirements occurred. These violations are cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding them are described in detailin the subject inspection report. One violation involves the failure of operators to respond in ,
accordance with procedures when an accumulation of hydrogen gas occurred in the offgas l recombiner system. The second violation concerns the design of the bypass indication )
system. The NRC determined that it does not meet a requirement referenced by 10 CFR 50.55a. The third violation involves two examples where corrective action in the maintenance area was not effective. These violations are of concern because they were either identified by the NRC or resulted in the degradation of safety related components.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, we request that you discuss the extent to which the bypass indication system installed at Susquehanna differs from guidance of Regulatcry Guide 1.47 and the system's design specification. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
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Mr. Robert G. Byram 2 ,
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in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosures, and your response will be placed in the NRC Public Document Room (PDR).
Sincerely, l Otb k ' }c~, en f. i Walter J. Pasciak, Chief ,
Reactor Projects Branch No. 4 Division of Reactor Projects b
Docket Nos.: 50-387;50-388 License Nos: NPF-14, NPF-22
Enclosures:
- 1. Inspection Report 50-387/97-01, 50-388/97-01
- 2. Notice of Violation t cc w/ encl: .
G. T. Jones, Vice President - Nuclear Operations !
G. Kuczynski, Plant Manager '
J. M. Kenny, Supervisor, Nuclear Licensing i G. D. Miller, Manager - Nuclear Engineering ;
R. R. Wehry, Nuclear Licensing l M. M. Urioste, Nuclear Services Manager, General Electric ,
C. D. Lopes, Manager - Nuclear Security i W. Burchill, Manager, Nuclear Safety Assessment H. D. Woodeshick, Special Office of the President J. C. Tilton, Ill, Allegheny Electric Cooperative, Inc. ;
Commonwealth of Pennsylvania L
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_ _ _ . e .- - - . - - -
NOTICE OF VIOLATION Pennsylvania Power and Light Company (PP&L) Docket Nos. 50-387, 50-388 Susquehanna Unit 1 and Unit 2 License Nos. NPF-14, NPF-22 During an NRC inspection conducted from January 14,1997, through February 24,1997, three violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
- a. Technical Specification (TS) 6.8.1 requires that written procedures shall be established and implemented for applicable procedures recommended in Appendix
'A' of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Appendix 'A', item 5, requires procedures for abnormal, offnormal, and alarm conditions. Item 5 further states that procedures for annunciators should contain the immediate action that is to occur automatically and the immediate operator action.
Alarm response procedure AR-231-001 for the " Unit 2 Recomb Discharge H2 Conc Hi- Hi" annunciator lists the automatic action for a 2% hydrogen concentration as an Offgas System isolation. Further, AR-231-001 Operator action 2.2.1 requires operators to ensure automatic actions occur.
Contrary to the above, on December 19,1996, operators failed to ensu.i the automatic actions occurred after the " Unit 2 Recomb Discharge H2 Conc Hi- Hi" annunciator alarmed and after a grab sample show a hydrogen concentration of 8%.
Specifically, the offgas system did not autom6tically isolate and operators did not take immediate manual action to isolate it.
l This is a Severity Level IV violation (Supplement 1).
- b. 10 CFR Part 50, Section 50.55a, " Codes and Standards," requires that protection systems meet the requirements of the Institute of Electrical and Electronic Engineers (IEEE) " Criteria for Nuclear Power Plant protection systems," Std 279-1971. IEEE 279, Section 4.13, requires that, if the protective action of some part of the protection system has been bypassed, or deliberately rendered inoperative for any purpose, this fact shall be continuously indicated in the control room.
Regulatory Guide (RG) 1.47, May 1973, describes an acceptable method of complying with the requirements of IEEE Std 279. RG 1.47 states that an i acceptable system will automatically indicate at the system level the bypass or j deliberately induced inoperability of the protection system.
Contrary to the above, since initial operation, the bypass indication system (BIS) at i Susquehanna has not provided the continuous control room indication required by l IEEE 279, and 10 CFR 50.55a, when a portion of the residual heat removal system '
is bypassed. The BIS does not automatically indicate at the system level when an RHR pump is rendered inoperable by a trip circuit that is enabled when the pump's !
suction valve is not full open. As a result, the RHR system is inoperable during i
2 ,
quarterly RHR suction valve testing and no automatic indication of this condition is provided at the system level.
This is a Severity Level IV violation (Supplement 1).
- c. 10 CFR 50, Appendix B, Criterion XVI, requires that licensees establish measures to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, defective material and equipment and nonconformances are promptly identified and corrected. ,
Contrary to the above, two examples were identified where the licensee f ailed to control maintenance activities such that conditions adverse to quality were created and not promptly identified and corrected.
- 1. In 1991, the licensee failed to implement adequate corrective actions in ;
response to a vendor letter that identified a deficiency on the contact surfaces of the 'E' emergency diesel generator bridge transfer switch. As a result of the licensee's failure to implement corrective actions to preclude ,
the condition identified by the vendor, the transfer switch failed to perform j its function on December 10,1997, during an 'E' emergency diesel i surveillance test. )
- 2. In December 1996, the licensee's corrective actions in response to the failed
'E' diesel generator transfer switch included the development of a trouble shooting plan. As a result of inadequate control and review of the trouble shooting plan, a failure was induced in safety related equipment and the 'E' emergency diesel generator failed a second surveillance test.
This is a Severity Level IV violation (Supplement 1). ;
Pursuant to the provisions of 10 CFR 2.201, Pennsylvania Power and Light Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident inspector at i the f acility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a
" Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response, if an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
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Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction, if personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request l withholding of such material, you must specifically identify the portions of your response ,
that you seek to have withheld and provide in detail the bases for your claim of withhold- j ing (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
Dated at King of Prussia, PA this 14th day of March 1997 i
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