05000387/LER-2005-001

LER-2005-001, R. A. Saccone PPL Susquehanna, LLC
Vice President - Nuclear Operations 769 Salem Boulevard
Berwick, PA 18603
Tel. 570.542.3959 Fax 570.542-1504
rasaccone@pplweb.com PP
SEP 2 0 2005
U. S. Nuclear Regulatory Commission
Attn: Document Control Desk
Mail Station OP1-17
Washington, DC 20555
SUSQUEHANNA STEAM ELECTRIC STATION
LICENSEE EVENT REPORT 50-387/2005-001-01
PLA-5938 Docket 50-387
Reference:� Susquehanna Steam Electric Station — Licensee Event Report 50-387/2005-001-00,
dated, Januar), 20, 2005
Susquehanna Steam Electric Station — NRC Integrated Inspection Report
05000387/2004005 and 05000388/2004005, dated, January 28, 2005
Attached is Licensee Event Report 50-387/2005-001-01. This report supplements the
referenced Licensee Event Report which identified that primary containment instrument
lines found penetrating the Unit 1 Reactor Building's Railroad Bay (an area not normally
maintained within Secondary Containment) could prevent structures or systems needed to
control the release of radioactive material from fulfilling their safety function.
Accordingly, this event was reported in accordance with 10 CFR 50.73(a)(2)(v)(C).
By virtue of Susquehanna's ventilation system design, PPL was able to eliminate the
non-conforming condition by reconfiguring Secondary Containment in a manner that
encompassed the Railroad Bay. On four occasions, however, as noted in the Inspection
Report referenced above, PPL temporarily returned the Railroad Bay to its normal
configuration (e.g., ventilation outside of secondary containment) to support plant
maintenance activities. A misinterpretation of Generic Letter 91-18 guidance, and PPL's
belief that the Secondary Containment function was not affected by returning the plant to
its normal and customary ventilation alignment, caused PPL to complete the
reconfiguration without entering the Secondary Containment LCO 3.6.4.1. Because the
Secondary Containment was not restored within LCO Required Action completion times,
this situation also constitutes an operation prohibited by the plant's Technical
Specifications and is reportable per 10 CFR 50.73(a)(2)(i)(B).
.!;;C-a'at>
2- Document Control Desk
PLA-5938
or
There were no actual consequences to the health and safety of the public as a result of
this event.
No new regulatory commitments have been created through issuance of this report.
Robe A. Saccone
Vice President - Nuclear Operations
Attachment
cc:-Mr. S. J. Collins
Regional Administrator
U. S. Nuclear Regulatory Commission
475 Allendale Road
King of Prussia, PA 19408
Mr. F. W. Jaxheimer
Sr. Resident Inspector
U. S. Nuclear Regulatory Commission
P.O. Box 35
Berwick, PA 18603-0035
Mr. R. Osborne
Allegheny Electric Cooperative
P. 0. Box 1266
Harrisburg, PA 17108-1266
Mr. R. R. Janati
Bureau of Radiation Protection
Rachel Carson State Office Building
P. 0. Box 8469
Harrisburg, PA 17105-8469
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1. FACILITY NAME Susquehanna Steam Electric Station - Unit 1 2. DOCKET NUMBER 3. PAGE
05000387 1 OF 3
4. Tm.E Primary Containment Instrument Lines Located Outside Secondary Containment

Susquehanna Steam Electric Station - Unit 1
Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(v)(C), Loss of Safety Function - Release of Radioactive Material 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
3872005001R01 - NRC Website

Reactor Building's Railroad Bay (EIIS Code: NG). Two of the instrument lines are associated with the Unit 1 Reactor Recirculation system (EIIS Code: AD) while the remaining four are associated with the Unit 1 Residual Heat Removal system (EIIS Code: BO). These instrument lines have been located in the Railroad Bay since plant startup. Although the area can be aligned to Secondary Containment (EllS Code: NH), it has not normally been configured as such since 1995.

The original Safety Analysis Report (SAR) did not rely upon instrument lines being located within Secondary Containment.

The SAR was, however, changed in 1998 to credit Secondary Containment in the SAR accident analysis. The instrument lines that are located in the Railroad Bay, and thus, have been typically located outside Secondary Containment, are not then consistent with assumptions currently found in station licensing documents. This non-compliance was reported in accordance with 10 CFR 50.73(a)(2)(v)(C) as a condition that could have prevented structures or systems needed to control the release of radioactive material from fulfilling their safety function.

By virtue of Susquehanna's ventilation system design, PPL was able to eliminate the non-conforming condition by reconfiguring Secondary Containment in a manner that encompassed the Railroad Bay. On four occasions, however, as noted in the referenced NRC Integrated Inspection Report, PPL temporarily returned the Railroad Bay to its normal configuration (e.g., ventilation outside of secondary containment) to support plant maintenance activities. Although this action was supported by an assessment that concluded the Secondary Containment function remained operable in its normal configuration even with the identified non-conformance, it later became apparent that 10 CFR 50.59 should have been applied before ventilation of the Unit 1 Railroad Bay was changed from an area within the Secondary Containment, as described in the SAR, to an area outside the Secondary Containment. PPL believed that, until final resolution of the non-conformance could be established via the corrective action process, Railroad Bay alignment to the normal configuration was consistent with, and solely governed by, the NRC Generic Letter 91-18 process for addressing non- conforming but operable conditions. This misinterpretation of Generic Letter 91-18 guidance, and PPL's belief that the Secondary Containment function was not affected by returning the plant to its normal and customary ventilation alignment, caused PPL to complete the reconfiguration without entering the Secondary Containment LCO 3.6.4.1. Because the Railroad Bay was not restored to the Secondary Containment configuration within LCO Required Action completion times, this situation also constitutes an operation prohibited by the plant's Technical Specifications and is reportable per 10 CFR 50.73(a)(2)(i)(B).

CAUSE OF EVENT

The principal causes for the non-compliance with the licensing basis were the changes made to the accident analysis that credited Secondary Containment and the change in 1995 that established normal alignment of the Railroad Bay outside Secondary Containment.

A misinterpretation of Generic Letter 91-18 guidance led to the operation prohibited by the plant's Technical Specifications. PPL failed to recognize the potential 10 CFR 50.59 implications created by the unique ability, through plant ventilation design, to restore a non-conforming condition to a configuration consistent with the plant's SAR accident analysis. In the absence of a 10 CFR 50.59 evaluation addressing a change to the facility as described in the SAR, the station's Technical Specifications should have been applied to any action that re-established the non-conformance.

ANALYSIS / SAFETY SIGNIFICANCE

Analysis of Secondary Containment bypass leakage has concluded that the postulated leakage from these lines is within the margin available in the LOCA dose analysis for Secondary Containment Bypass Leakage. Further, the analysis indicates that the instrument lines, if cracked or broken, will not introduce radiological consequences that exceed those presented in the SAR for a break outside of Secondary Containment.

CORRECTIVE ACTIONS

The following corrective actions have been completed:

• Administrative controls have been enacted to align the Railroad Bay to the Secondary Containment Zone III when the Railroad Bay door is not open. PPL is controlling and limiting the time that the Railroad Bay ventilation is aligned outside of Secondary Containment by entering and adhering to the Technical Specification LCO that governs Secondary Containment operability when the Railroad Bay door must be opened.

• A review of the Technical Specification and Technical Requirement Bases documents did not identify other situations where restoration of a non-conforming condition would likely cause a misinterpretation similar to the one described in this report.

The following corrective actions are planned:

• A plant modification will be implemented which will locate the subject instrument lines to within Secondary Containment.

• The SAR accident analysis of potential instrument lines breaks will be evaluated and modified as appropriate.

ADDITIONAL INFORMATION

None