PLA-4851, Provides Info That Was Requested by Cj Anderson on 980213 Re Former Util Employee Concern on Radwaste Control Room Offgas Panel Alarm Testing
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Robert G. Byram PP &L. Inc. I Semor Vice Pres 4ent Generation and Chief Nuclear orncer Tei 610.774 7502 Fax 610 774 5019 Two North Ninth street Allentown. PA 18101-1179 Tel 610.774 5151 I l E-mail rgeyram@paol com htto uwww caol com/
cEB 1 e 1996 1
NOTE: THIS DOCUMENT CONTAINS '
l Mr. Charles W. Hehl INFORMATION TO BE WITHHELD IN I 475 Allendale Road King of Prussia. A 19406 ACCORDANCE WITH 10CFR2.790 1
l SUSQUEHANNA STEAM ELECTRIC STATION Docket Nos. 50-387 RESPONSE FOR REQUESTED INFORMATION FILE R41-2 and 50-388 '
PLA4851 1 Dear Mr. Hehh .
The purpose of this letter is to provide information that was requested by Mr. Clifford J. Anderson of your staff on Friday February 13,1998.
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Former PP&L Emolovee Concern An employee concem on radwaste control room offgas panel alarm testing was brought to PP&L's Corporate Audit Services Department by a former NPO.
The individual (s) conducting the investination were indeoendent of the organization affected bv the concern and were oroficient in the soecified functional area.
Members of the Corporate Audit Services investigative team are independent of the Nuclear Department. Additionally, the individuals who performed the investigation are knowledgeable of Nuclear Department procedures and processes and were sufficiently l
proficient to perform the investigation. l The evaluation was of sufficient death and scoce.
reviewing pertinent documentation associated with The investigative team's efforts included:
the concern identified, conducting interviews with appropriate personnel, and analyzingl l
results and developing conclusions.
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Investination Results The investigative team reviewed the circumstances of the issue and concluded th employee's concern was substantiated.
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- p FILE R41-2 PLA-4851 Nir. Charles W. Hehl This conclusion was based upon a detetTnination that the required testing, for the time period identified in the employee concern was, at times, not always performed. This determination was based upon personnel interviews and an analysis of computer point testing data. The detailed analysis of computer point testing data veritied that the testing was. at times. not always performed.
Corrective Actions The lack of testing, as identified in the employee concern, occurred prior to the "E" Emergency Diesel Generator (EDG) event that occurred in July 1996. Since corrective actions associated with the "E" EDG event addressed the necessity to perform required procedural activities, the corrective actions associated with the "E" EDG also applied to this concern. The investigative team confirmed that the applicable corrective actions from the "E" EDG were also effective for this issue.
Additional specific corrective actions were also taken to address this issue. These included:
- Suclear Operations personnel reinforced the necessity to completely and concisely document operations activities, and
- Procedural revisions were made which relocates the radwaste control room offgas panel alarm testing requirements to a procedure which contains other equipment checks.
As a result of the above noted investigation. and associated corrective actions PP&L considers this concern closed.
Attached is the redacted version of PP&L. Inc.'s Corporate Auditing Report C39459-2-98. dated February 10.1998. The necessary affidavit pursuant to 10 CFR 2.790 justifying that the redacted portions be withheld from public disclosure is also attached.
We trust that you will find th'is submittal responsive. If you have any questions please contact Mr. J. M. Kenny at (610) 774-7535.
Sincerely,
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Mr. Charles W. Hehl bc: J. V. Edwards - NUCSA4 G. T. Jones NUCSA4 J. . M. Kenny GENA 61 B. ' A. Snapp . GENTW3-M. F. Urban 'GENTW9
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AFFIDAVIT OF ROBERT G. BYRAM I, Robert G. Byram, Sr. Vice President-Generation / Chief Nuclear Officer of PP&L, Inc. ("PP&L"), do hereby affirm and state:
- behalf. I am further authorized.to review information submitted to the Nuclear Regulatory Commission and apply for the withholding of information from disclosure.
- 2. PP&L requests that certain portions of the document attached hereto ("PP&L Response") be withheld from public disclosure under the provisions of 10 C.F.R. 2.790(a)(4) and (a)(6). This document indicates the portions sought to be withheld.
- 3. The PP&L Response contains the results of intemal investigative activities that constitute confidential commercial information that should be withheld -
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'under 10 C.F.R. 2.790(a).
- 4. This information has been held in confidence by PP&L. To the extent that PP&L has shared this information with others, it has done so on a need to know basis. !
- 5. There is a rational basis for holding this information in confidence.
Confidential treatment of such information encourages franic and open intemal )
investigations.
- 6. Disclosure of the complete document would result in the details of I this internal investigation being revealed. Such disclosure would adversely affect the future effectiveness of the Company's ability to investigate potential wrongdoing by its employees.
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- 7. The employees interviewed did not expect publication of the results of their interviews to the public.
- 8. Individual employees would be reluctant to candidly discuss matters ]
with the Auditing Department and other individuals conducting investigation which '
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would in turn undermine the employees' trust in PP&L's internal auditors and other investigators. The credibility of the Company's investigative process would also be diminished. As a result, the government's ability to obtain similar information in the i future would be impaired. Such disclosure would have a chilling effect on future investigations. )
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- 9. The PP&L Response also involves personal and privacy issues, the disclosure of which could unreasonably harm individual employees.
- 10. This information is being transmitted and received in confidence, it is not available from public sources and could not be gathered readily from other publicly available information.
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- 11. Public disclosure of this information would cause substantial harm to the competitive position of PP&L, because such information could be used by others to harm it and thereby gain a competitive advantage over it.
l PP&L, INC.
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Robe G. ram , _
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Subscribed and sworn before me, a Notary Public in and for the Commonwealth of Pennsylvania this it day of %,1998.
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NOTARIAL SEAL JANICE M. REESE, Notsty Public City of Alleramn, Lehigh County, PA My Commission Expres June 11. 2001
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that there was no review of the remaining EDGs in the operability determination.
The inspectors determined there were no current operability concerns with the remaining EDGs based on a review of completed and ongoing maintenance activities.
However, the lack of any generic considerations for the other EDGs in the root cause of the operability determination existed, until questioned by the NRC.
CR 98-0491 identified a degraded condition of the "E" EDG day tank. The day tank level slowly decreases, requiring make-up fuel oil addition. The operability j determination characterized the leak as " minor" and within the capability of the fuel oil transfer pumps. The inspectors questioned why the engineers did not quantify the l leak or discuss the basis for the TS minimum day tank volume (e.g., how long the i diesel must be able to run on the day tank alone without makeup). This short l coming was discussed with operations management, and the operability l determination was revised. The inspectors reviewed the revised operability i determination and found that it adequately addressed the TS and design basis for the EDG day tank.
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- c. Ennch minns i Seventeen initial operability determinations (ODs) were reviewed and were determined to be adequate. The inspectors questioned two of the ODs. An emergency diesel generator (EDG) OD did not address the operability of the other EDGs, although they could have been subject to the same degraded condition (worn EDG drive chain). The other OD did not consider the affect of a leaking EDG day tank check valve on an associated Technical Specification requirement for EDG day tank volume. Subsequent revisions of the two ODs, questioned by the NRC, provided adequate bases for operability.
04.2 Nnn-I icanmad Onarntnr Parfnrrnanca
- a. Inanactinn knea (71707 4?901)
The licensee's corrective actions associated with non-licensed operator performance problems identified in conjunction with the "E" EDG mis-alignment in June 1996 were reviewed. This review specifically examined corrective actions associated with escalated enforcement action VIO 50-387,388/96-270-01022 Items B.2.a, c, and d.
- b. Ohnarvatinns and Findings On July 4,1996, operators identified that the "E" EDG auxiliary equipment supply breaker, at panel OA510, was not installed. Subsequently, it was discovered that a circuit breaker was mis-positioned on June 14,1996, when an NPO aligned the "E" EDG for service. A number of procedural violations were cited in escalated enforcement actions, issued on June 20,1997.
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6 Item 8.2.a of VIO 96-270-01022 identified that an NPO failed to self check during alignment of the "E" EDG breakers at OA510 and consequently did not align the equipment as specified in the applicable procedure.
Item B.2.c of VIO 96-270-01022 identified that an NPO failed to notify the control room operators after discovering a potential problem with the breaker alignment at panel OA510, on July 3,1996.
Item B.2.d of VIO 96-270-01022 identified that NPCs failed to perform panel alarm tests for "E" EDG panel OC577E on numerous occasions, between January 1996 and June 1996.
v The inspectors reviewed licensee corrective actions for issuesjinv Iving procedure compliance, which included operator training,{ersonnel actions) and first line leadership training. In addition, PP&L established a number of general corrective actions. The inspectors concluded that the licensee's corrective actions for the specific cited violations were acceptable. Several additional issues? with implications regarding personnel performance, were also reviewed and are discussed below.
Nase ia in February 1997, questions regarding the validi of the computer records, for the panel alarm tests at panel OC577E, were?;::W:t;d by PP&L and subsequentiy reviewed by the NRC. The NFC mom and inspection activities were documented in NRC Inspection Report (IR) 50 387.388/97-09. The NRC's review concluded that a failed-reflash unit had preverited the control room alarm from reflashing on February 13,199Qespite the control room annunciator not alarming, computer records were avaTi able to show the panel alarm test had been performed.
In response to the June 1997 escalated enforcement action, PP&L committed to a number of reviews and assessments. PP&L's reviews ultimately included audits of other routine activities required of Nuclear Plant Operators (NPCs), Auxiliary System Operators (ASOs) and Plant Control Operators (PCOs). Three reviews examined routine panel alarm tests required for the engineered safeguard systems (ESS) transformers,7radwaste control room panels, and main control room panels. NRC review of these alarm test issues and PP&L's investigations are documented in sections E2.2, E2.3, and E2.4 of this report. The NRC inspection included reviews of y,
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PP&L's audit reports, computer repcrts and PP&L's conclusions regarding personnel
, R' ' performance. The inspectors concluded the licensee's audits were acceptable and
, ;.;.'~ l y , ' that appropriate actions had been taken to validate and verify the quality of
,) s ecmputer data used to assess personnel performance.
The inspectors concluded that PP&L has implemented appropriate corrective actions j J, to address personnel performance related violations identified in items B.2.a, c, and d i- of VIO 50-387,388/96-270-01022. Subsequent Ilcensee's audits and self
. [. .[ J assessments reflect improvements which have occurred in the operations
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7 department.' NRC obs rvations of current operator performance do mented in NRC !
IR 50-387,388/97-10 oncluded that operator performance was ' ood. Based !'
on these findings,-Items B.2.a, c, and d of violation VIO 50-387,388/96-270-01022 are closed. }
- c. Conclusions l PP&L's corrective actions for three procedure violations, associated with the June i 1996 "E" emergency diesel generator circuit breaker misalignment, were acceptable. Corrective actions focused on improving operator performance, management oversight, and independent assessment. Subsequent licensee audits of operator performance were acceptable and appropriate actions were taken to I validate and verify the quality of computer data used to assess operator i performance.
05 Operator Training and Qualification i
, .i 05.1 Licensed Ooerator Re-aualification Trainina Procram l i
- a. Insoection Scoce (71001)
The inspector evaluated the Susquehanna licensed operator re-qualification training (LORT) program using NRC Inspection Procedure 71001, Licensed Operator Re- i qualification Program Evaluation, during the week of January 12,1998. The inspector evaluated the adequacy of the annual operating test and biennial written examinations, and the administration of the examinations to one operating crew and ]
several staff licenses using NUREG 1021, Operator Licensing Examination J
Standards for Power Reactors. In addition, the inspector reviewed the procedures for maintenance and activation of operator licenses and verified that the requirements were met to reactivate inactive licenses. Administrative procedures and documents associated with the training program and its implementation were also reviewed.
- b. - Qbservations and Findincs Examination Materials l
The inspector reviewed six written annual re-qualification examinations (i.e.,3 reactor operator and 3 senior reactor operator) prepared and administered by PP&L ;
this examination cycle. Overall, the written examinations were adequate but l sections on " limits and controls" for five of six written examinations had questions j that were weak at testing higher cognitive levels of knowledge. This portion of j
'these examinations contained a number (i.e., 30-40%) of direct lookup or memory j level questions. The use of direct lookup or memory level questions on the written
, examinations will be an inspector followup item. (IFl 50-387,388/98-01-01) i b:
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On February 17,1998, on Unit 1 during a planned increase in recirculation flow, to )
maintain 100% reactor power, a momentary reduction in "B" recirculation drive flow I l (e.g., a reduction in pump speed) was noted, followed by a slower than expected '
l increase in the "B" drive flow. A 3 rpm speed decrease over a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> period was observed for the "B" recirculation pump. As before, there was no change in the "A" ,
recirculation pump speed during this period. The licensee initiated CR 98-0498 and CR 98-0518 to evaluate this problem.
Since February 14, the PCO's have been closely monitoring recirculation speed and flow, however, no speed or flow drift has been observed since February 17. The !
recirculation pumps operate at about 1500 rpm, therefore, the observed speed drift ;
problem represents a change of approximately 0.1% per hour. SSES engineering and instrument and controls personnel analyzed the system performance data for these two events, based on a computer history review, and concluded that this was probably caused by a drift in the control signal. SSES engineering has further concluded, based on the information available, that a rapid speed change or failure of _
the control system is not likely. A temporary data recorder was installed in the '
recirculation flow control system to obtain additional diagnostic information not available from the plant computer system. SSES engineering response was adequate.
Operators responded well, to control reactor power and monitor plant parameters, on two occasions when the recirculation pump speed drift resulted in unanticipated reactivity additions. The inspectors reviewed the CR and supporting data, and discussed recirculation speed control, reactivity addition, and the resulting effects on reactor power with operations supervision, system engineering supervision, and PCOs. The operability determination was found to be adequate. The licensee's initial actions appeared to be reasonable and conservative.
- c. Ennelmainna I The Unit 1 "B" reactor recirculation pump speed was observed to be slowly changing without any operator action, on two separate occasions, resulting in unanticipated reactivity additions. The inspectors reviewed the operability determination and the
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licensee's initial corrective actions, and found them to be adequate.
1 E2.2 Enginaarad Maf aguarda svetam Trannfnrmar Local Panal Alarm Tante (37551, p - x71707)L
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} i Nuclear Plant Operators (NPCs) perform a local panel alarm test for several
- f engineered safeguards system (ESS) transformers as part of their routine round activities. The inspectors reviewed two computer reports, for ESS transformer local panel alarm actuation data, and a PP&L corporate audit report, dated October 15, 1997, for ESS transformer local panel alarm test performance.
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e ie 30 The inspectors concluded the computer reports showed data recording deficiencies for some Unit 1 ESS transformer local panel alarms. A comparison of the Unit 1 and 2 computer reports with in-plant maintenance records, and system configurations, provided evidence that PP&L's conclusions were reasonable with respect to NPO local panel alarm test performance. The inspectors concluded that the licensee's corrective actions, with respect to NPO performance, were acceptable based on direct inspection of NPO activities, discussions with NPOs, and additional record reviews. After accounting for the computer data recording deficiencies, computer records covering the periods of January to July 1996, August to December 1996, and January to March 1997, all indicate NPCs were consistently performing the required ESS transformer local panel alarm tests.
Although some deficiencies were identified with the recorded computer data, the inspectors found that PP&L accounted for the computer data deficiencies and reached reasonable conclusions regarding the data. PP&L'r conclusions and corrective actions to improve NPO performance, oversight, and independent assessment were found to be acceptable. Bend ca T!u. c:> -,,dt/ revb 1mac G4 Tha n.n s. u c n l.s a p t r , c.s s r n g , ,,',.
E2.3 Radwnsta Enntrni Rnnm Panel Alarm Tmta (37551, 71707) hc / c le < 3 fe d tae.c c.3as 4 fly y tu r . a 6 h, o ,se ,,
f Auxiliary System Operators (ASOs) perform radwaste control room panel alarm tests as part of their routine shift activities. The inspectors reviewed computer reports
- and PP&L audit datafor radwaste panel alarm tests for selected periods in 1996 and 1997. % d.:tel fd ;,,4 y /0, / 991, The inspectors concluded the computer reports showed data recording deficiencies for some radwaste control room panel alarms. A comparison of the Unit 1 and Unit 2 computer reports with in-plant maintenance related conditions, and system configurations, provided evidence that PP&L's conclusions were reasonaole, with respect to ASO radwaste control room panel alarm test performance. PP&L's audit determined that their management expectations were not clear and had not been consistently implemented throughout all operation shifts.
Records for the period January to July 1996, indicate the ASOs were not consistently performing the radwaste control room panel alarm tests. This issue is considered part of personnel performance problems which existed prior to July 1996.
Licensee corrective actions associated with VIO 50-387,388/96-270 are considered applicable to this issue.
NRC reviews of the records covering the periods August to December 1996, and January to March 1997, indicate ASOs were consistently performing the required radwaste control room panel alarm tests. The inspectors concluded that the licensee's corrective actions, with respect to ASO performance, were acceptable based on direct inspection of ASO performance, interviews of ASOs, and additional record reviews.
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. Although some' deficiencies were identified with the recorded computer data, the
?inspectora found that PP&L accounted for the computer data deficiencies and reached reasonable conclusions regarding the data. PP&L's conclusions and oversi f corrective assessmentactions to improve were found ASO performance,\ . .:ght, to be acceptable. and
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E2.4 u in c' antral Annm Annunt intnr Alarm Tant * (37551, 71707)
Plant Control Operators (PCOs) perform main control room annunciator alarm tests as :
part of their routine shift activities. 7Aa ,,,a6.4e e e . ., s.A th( c,4.fJ., k d.I.J '
b s u. s u . I I M1 -ih ' Per $. ' .h c.Je. l es a . r..b o ch!~ k'A .
The inspectors determined that there was no computer data which would indir a*= ar u m.1.
whether specifi in control room annunciator alarm tests were'j!iierformed, ans
( Q,h a . ' also determin method used to accomplish the annunciator alarm tests varied from shift to shift. The licensee also concluded, that there was no computer data to support a performance review for specific main co tro{rgrg annunciator alarm tests. ~
Therefore, the licensee trt
- cegure -ditina L .,,.. a review of main' control .
room annunciator alarm tests using PCO interviews, Unit Supervisor (US) interviewn . Pcc
' and control room log reviep The licensee determined there were ~ performance L issues,ralmaaw </The inspectors concluded thatQL's initial actions to evaluate the PCO%performanceNere conservative, in generai, ma inw.c;cr; _ fL: co wc/,,
concluded the corrective actions, for varied PCO alarm test practices, were C.'h .'. g ,*j reasonable and overall PCO performance was good, based on direct inspection, L. A ,g interviews of PCOs, and additional record reviews.
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(- D. l The inspectors found that PP&L accounted for the absence of supporting computer %, A l data and reached reasonable conclusions. PP&L's conclusions and corrective A7 i
- actions, to improve PCO performance, oversight, and independent assessment, were l found to be acceptable. \ me sije a t ,f ) '
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E8' Miscellaneous Engineering issues E8.1: Fnlinwnn nf Onan Itamn (37551, 92903) y L '
f' It'!nearn URI cio-3R7 'tRR/97-07-09 ,
' Reactor Building Truck Bay Hatch !
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i During a routine tour of SSES reactor buildings, the inspectors observed that a large f . floor hatch, on elevation 749 of the Unit 2 reactor building, was open and appeared to have been that way for many years. A subsequent review by PP&L found that the j hatch was assumed to be closed in the tornado analysis for the reactor building. CR
[ 97 1950 was' opened to document this discrepancy and two calculations were performed to evaluate the as-found condition (EC-012-2207 and EC-012-2209). ;
,L l g. PP&L concluded that the open hatch is an acceptable configuration. )
cf As discussed in NRC IR 50-387,388/97-07, the licensee had not performed FR 50.59 safety evaluation prior to placing the hatch in a position contrary to the !
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. original tornado analysis. The inspectors reviewed the results of PP&L's recent t i j's .d, --
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32 calculations and determined the tomado analysis was not adversely affected by having the truck bay hatch in the open position. No unreviewed safety question was identified. No safety impact was identified, this finding does not represent a programmatic problem, and this finding was not considered a precursor to a more significant event. This failure constitutes a violation of minor rignificance and is being treated as a non-cited violation, consistent with Section IV of the NRC Enforcement Policy. (NCV 50-387,388/98-01-10)
Iv_ mne sunnnre R1 Radiological Protection and Chemistry Controls R1.1 As-L nw- As-Ran=nnnhlv- Ar hiavnhia (ALAR A)
- a. Insnactinn hnna (R'17MO)
A review was performed of the controls to maintain radiation expo'sures as-low-as- "
reasonably-achievable (ALARA). Information was gathered by reviews of ALARA evaluations written for radiation work permit 1997-0061, " Application of paint and epoxy" in the emergency core cooling system rooms on the lower elevation of the unit 1 and unit 2 reactor buildings, through discussions with cognizant personnel, and tours through the plant.
- b. Ohnarvatinns and Andings ALARA reviews were well detailed and included person-rem estimates, work planning information, external and internal exposure controls, health physics operational concerns, dosimetry and radiological monitoring, anticipated de::e retes, additional comments, a work flow synopsis, and lessons learned from previous jobs. Examples of ALARA measures implemented for painting of the residual heat removal (RHR) rooms included use of temporary shielding, system flushes, use of long handled tools, radiation source postings, and use of pictures for briefings. "ALARA (work) in-progress reviews were performed as the project evolved, and one notable lesson learned was that a preplanned flush of the unit 2 RHR shut down cooling (SDC) line was canceled without consultation of the cognizant ALARA specialist. The ALARA in-progress review highlighted the need for improved communications between operations and health physics to ensure the success of future RHR SDC system flushes.
During tours of the plant, the inspector examined temporary shielding installed in the t RHR rooms. Lead blankets were suspended from the upper grating and were hung l
beneath the RHR shut down cooling lines in the overhead of the RHR room. Licensee records showed that the shielding reduced general area dose rates by approximately 25-35 percent. Although the shielding was installed to reduce dose rates for the painting project, approval had been obtained to allow the shielding to remain in-place until the end of the next outage on each unit, thereby increasing the effectiveness of the shielding. Shielding packages were neat and orderly, showed evidence of detailed planning. and were noted as excellent by the inspector.