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05000387/FIN-2016001-0231 March 2016 23:59:59SusquehannaNRC identifiedFailure to Report Loss of Safety Function as Required by 10 CFR 50.73(a)(2)(v)Inspectors identified a Severity Level IV NCV of 10 CFR Part 50.73 (a)(2)(v) when Susquehanna did not submit a licensee event report (LER) within 60 days of identifying that both trains of the control room emergency outside air supply system (CREOASS) were rendered inoperable during surveillance testing, a condition that could have prevented fulfillment of a safety function. Susquehanna entered the issue into the CAP as CR-2016-03713 and reported the condition on May 5, 2016 in LER 50-388(387)/2015-015. Since the issue had the potential to affect the NRCs ability to perform its regulatory function, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process. Using example 6.9.d.9 from the NRC Enforcement Policy, the inspectors determined that it was a Severity Level IV violation. The significance of the associated performance deficiency was also screened against the reactor oversight process (ROP) per the guidance of IMC 0612, Appendix B, "lssue Screening. Because this violation involves the traditional enforcement process and does not have an associated finding under the ROP, inspectors did not assign a cross-cutting aspect to this violation.
05000387/FIN-2016404-0131 December 2015 23:59:59SusquehannaNRC identifiedSecurity
05000387/FIN-2014005-0331 December 2014 23:59:59SusquehannaNRC identifiedFailure to Submit an LERInspectors identified a Severity Level IV NCV of 10 CFR 50.73 (a)(2)(v) for PPL staff not submitting an Licensee Event Report (LER) within 60 days of discovery of a condition that could have prevented the fulfilment of the safety function of the RPS Electrical Power Monitoring System. PPL submitted an LER for the subject condition and entered the issue into their CAP under CR-2014-17112. The finding was evaluated using the traditional enforcement process because not accurately reporting events has the potential to impact or impede the regulatory process. The finding was determined to be a Severity Level IV violation of 10 CFR 50.73 (a)(2)(v) based on example 6.9.d.9 of the NRC Enforcement Policy. This example states that a licensee failing to make a report required by 10 CFR 50.73 is an example of a Severity Level IV violation. Because this violation involves the traditional enforcement process and does not have an underlying technical violation that would be considered more-than-minor, inspectors did not assign a cross-cutting aspect to this violation in accordance with IMC 0612, Appendix B.
05000387/FIN-2013005-0531 December 2013 23:59:59SusquehannaLicensee-identifiedLicensee-Identified Violation10 CFR 55.53(e) requires, in part, that to maintain active status, a licensee shall actively perform the functions of an operator or senior operator on a minimum of seven 8-hour shifts or five 12-hour shifts per calendar quarter and that if a licensee has not been actively performing the functions of an operator or senior operator, the licensee may not resume activities authorized by a license issued except as permitted by 10 CFR 55.53(f). 10 CFR 55.53(f) requires, in part, that before resumption of licensed functions, an authorized representative of the facility licensee shall certify that: 1) the licensees qualification and status of the licensee are current and valid; and 2) that the licensee has completed a minimum of 40 hours of shift functions under the direction of an operator or senior operator as appropriate and in the position to which the individual will be assigned. Contrary to the above, between April 1, 2010, and December 31, 2012, prior to allowing 8 licensed SRO and 2 licensed Reactor Operators (RO) to conduct licensed activities, SSES did not properly ensure that the qualifications and status of the SRO or RO licenses were current and valid, regarding each individual meeting the minimum of seven 8-hour or five 12-hour shifts per calendar quarter. Specifically, the operators stood watch as members of a reactivity management team, which is not a credited shift crew position. These watches were incorrectly credited towards meeting their minimum required quarterly proficiency requirements. The facility has properly reactivated those individuals who still have licenses as required by 10 CFR 55.53 (f). This issue was entered in the facility CAP as CR 1658590. Additionally, SSES promptly removed the licensed operators from shift duties and entered the issue into its Corrective Action Program (CR 1658590). To prevent reoccurrence, SSES revised its procedure to identify the shift positions that are creditable for proficiency. The Operators were recertified to stand shift in accordance with 10 CFR 55.53(f). SSES also communicated lessons learned from this issue to the SSES operations department staff. This issue was subject to traditional enforcement because it involves operator license conditions and impacts the regulatory process of operator licensing. This issue matches a severity level III example in the NRC enforcement policy. However, after review of the responsibilities of the reactivity management team positions and that none of the operators were responsible for operational errors as a result of not standing the required number of proficiency watches and there were no other factors impacting their ability to hold a shift position, NRC management has determined this issue to be more appropriately evaluated as a severity level IV.
05000387/FIN-2013013-0230 June 2013 23:59:59SusquehannaNRC identifiedFailure to Follow RCA Egress RequirementsThe contractors actions caused PPL to violate the SSES operating license. Specifically, SSES License Condition 2.C(2) requires that PPL will operate SSES in accordance with the TS. SSES TS 5.4.1, in part, requires that written procedures shall be implemented covering the procedures recommended in RG 1.33, Rev 2, App A, February 1978. RG 1.33, Rev 2, App A, recommends the establishment of radiation protection procedures for access control to radiation areas and for contamination control. Pertaining to the second OI Investigation (1-2012-043), PPL implementing procedure NDAP-QA-0626, Radiologically Controlled Area Access and Radiation Work Permit System states that individuals are not allowed to move radiological postings, barricades, and barriers and to contact HP if there is a need to have any of these items moved or modified. Contrary to the above, on March 30, 2012, a contract carpenter did not contact the SSES HP department and, instead, moved an HRA posting on his own. Pertaining to the third OI Investigation (1-2011-030), PPL implementing procedure NDAP-QA- 0623, Radiation Protection Standards and Responsibilities requires individuals to not leave the RCA until they can successfully pass through a PCM and a PM. Contrary to the above, on April 6 and April 7, 2011, contract employees left the SSES RCA without successfully passing through both a PCM and a PM. Because the violations associated with the second and third OI investigations were caused by the willful actions of contract employees, they were evaluated under the NRCs traditional enforcement process using the factors set forth in Section 2.3.2 of the NRC Enforcement Policy. After careful consideration of these factors, the NRC concluded that these violations should be classified at Severity Level IV. In reaching this decision, the NRC considered that the significance of the underlying violations was minor because: (1) pertaining to OI investigation 1-2012-043, the HRA was conservatively posted and physical access into the actual HRA overhead did not occur; and, (2) pertaining to OI investigation 1-2011-030, both individuals successfully cleared other contamination monitors and the issue did not involve the spread of radioactive contamination into an uncontrolled area. However, the NRC decided to increase the significance of the violations since they were willful and the NRC regulatory program is based, in part, on licensees and their contractors acting with integrity.
05000387/FIN-2013013-0130 June 2013 23:59:59SusquehannaNRC identifiedUnauthorized Movement of a High Radiation Area BoundaryThe first OI investigation (1-2012-012), which was completed on August 23, 2012, examined whether a contract roofer at SSES deliberately failed to follow an SSES procedure pertaining to personnel contamination monitoring. Based on the evidence gathered during the OI investigation, the NRC concluded that on October 11, 2011, the contract roofer willfully, with careless disregard, failed to contact the SSES Health Physics (HP) department after receiving two radiation portal monitor (PM) alarms when exiting the SSES protected area (PA). Specifically, on the specified occasion, after the contract roofer received a second alarm on a PM at the SSES PA exit, one of the NRC resident inspector staff, while exiting the SSES PA, observed the contractor and reminded him of the requirement to contact HP. Because the contract roofer could not locate a telephone in the area, his coworker (who had successfully passed the PM and exited the PA) approached a SSES security officer stationed at the security control point, purportedly to request assistance with contacting the HP department. As a result of a likely miscommunication, the HP department was not contacted and the contract roofer used a different PM and exited the PA after not receiving an alarm, even though, in accordance with his testimony to OI, the contract roofer knew he was supposed to contact the HP department and wait for assistance. Although the contract roofers coworker testified to OI that a security officer at the security control point had told him to have the contract roofer try another PM, OI, through its investigation, was unable to corroborate that any security officer provided such direction. The contract roofers actions caused PPL to violate the SSES operating license. The violation is described in the enclosed Notice of Violation (Notice).
05000387/FIN-2013002-0331 March 2013 23:59:59SusquehannaNRC identifiedInadequate 10 CFR 50.59 Screening of TS Bases ChangeThe inspectors identified a Severity Level IV (SL-IV) NCV of 10 CFR 50.59, Changes, Tests, and Experiments, when PPL made changes that affected Unit 1 and Unit 2 TS 3.8.3 without obtaining a license amendment pursuant to 10 CFR 50.90. Specifically, PPL changed the TS 3.8.3 bases to support raising the American Petroleum Institute (API) gravity of acceptable diesel fuel oil by crediting the fuel oil day tank capacity to meet the onsite fuel requirements. This change altered the intent of TS 3.8.3. PPL entered this item in their CAP as CR 1678266, made urgent changes to surveillance procedures, evaluated the issue, and ultimately agreed with this conclusion. The inspectors determined that the failure to implement the requirements of 10 CFR 50.59 for changes to the TSBs was a performance deficiency within PPLs ability to foresee and correct. The inspectors evaluated the finding in accordance with IMC 0612 Appendix B. The inspectors determined that this issue impacted the regulatory function by failing to receive prior NRC approval for changes in licensed activities. Therefore, the violation was compared to examples in Enforcement Policy section 6. The violation was determined to be more than minor based on similarity to SLIV example 6.1.d.2, a 10 CFR 50.59 violation that resulted in conditions evaluated as having very low safety significance. The inspectors also evaluated the performance deficiency under the ROP and determined that the associated ROP finding was minor since PPL had not accepted fuel oil deliveries with a higher gravity. As such, no cross-cutting aspect was assigned to this finding.
05000387/FIN-2013002-0731 March 2013 23:59:59SusquehannaLicensee-identifiedLicensee-Identified ViolationOn March 27, 2012, PPL determined, during a CAP follow-up review into the failure of the B CS chiller compressor guide vane linkage, that it had likely occurred on February 16, 2012, while the A CS chiller was OOS for maintenance. The result was that both CS chillers had been inoperable simultaneously for a total of 49 hours. PPL determined that this had resulted in a condition prohibited by TS. Specifically, TS 3.7.4 action D.1 requires the immediate entry into LCO 3.0.3 during the time the two control room floor cooling subsystems were inoperable. Contrary to the above, PPL had not recognized the failure of the in-service B chiller and, therefore, had not taken the appropriate action. Traditional enforcement applies in accordance with IMC 0612, sections 0612-09 and 0612-13 and Enforcement Policy section 2.2.4.d, because the inspectors did not identify an associated performance deficiency. A review of historical equipment performance had not shown the ball-joint connector to be a notable failure mode for the chillers and there were no prior trends of failures of the CS chiller compressor ball joint connectors. Additionally, the inspectors determined that the failure of the chiller compressor guide vanes with the chiller in operation would not have been readily apparent due to minimal changes in chiller demand required at the time of the failure. This issue was considered to be an SLIV violation of TS 3.7.4 in accordance with Enforcement Policy section 6.1.d. In addition, IMC 0612, Appendix B, Figures 1 and 2, Issue Screening, were referenced in documenting this SLIV licensee-identified NCV. There was no actual safety consequence as the B CS chiller was able to support its cooling load to maintain the CS room temperatures within normal operating bands in the position where the vanes had failed. Additionally, although not considered operable for design conditions, the B chiller was able to provide some minimal cooling to its respective loads during the limited exposure time where both trains were considered inoperable. This severity level IV licensee-identified NCV was entered into PPLs CAP as CR1548540.
05000387/FIN-2012005-0231 December 2012 23:59:59SusquehannaNRC identifiedFailure to Report COMMON-CAUSE Inoperability of Independent TrainsInspectors identified a SL IV NCV of 10 CFR 50.73 (a)(2)(vii) for PPLs failure to submit a licensee event report (LER) of a common cause inoperability of two independent trains of reactor protection system (RPS) electrical power monitoring associated with several Unit 1 RPS breakers on May 8, 2012. PPL staff entered the issue into the CAP as CR 1663785 and took action to issue the required LER. This finding was evaluated using the traditional enforcement process because the failure to accurately report events has the potential to impact or impede the regulatory process. The finding was determined to be a Severity Level IV violation based on example 6.9.d.9 of the NRC Enforcement Policy. This example states that a licensee failing to make a report required by 10 CFR 50.72 or 10 CFR 50.73 is an example of a Severity Level IV violation. Because this violation involves the traditional enforcement process and does not have an underlying technical violation that would be considered more-than-minor, inspectors did not assign a cross-cutting aspect to this violation in accordance with IMC 0612, Appendix B.
05000387/FIN-2012005-0631 December 2012 23:59:59SusquehannaNRC identifiedFailure to Make a Timely Report for a Valid Actuation of RPSThe inspectors identified a SL IV NCV of 10 CFR 50.72(b)(3)(iv)(A) and (B) when PPL operators did not report a valid actuation of the Unit 2 RPS on November 9, 2012 within eight hours of occurrence as required. The concern was entered into PPLs CAP as CR 1643096 and an Emergency Notification System (ENS) report was submitted restoring compliance. This finding was evaluated using the traditional enforcement process because the failure to accurately report events has the potential to impact or impede the regulatory process. The finding was determined to be a Severity Level IV violation based on example 6.9.d.9 of the NRC Enforcement Policy. This example states that a licensee failing to make a report required by 10 CFR 50.72 or 10 CFR 50.73 is an example of a Severity Level IV violation. Because this violation involves the traditional enforcement process and does not have an underlying technical violation that would be considered more-than-minor, inspectors did not assign a cross-cutting aspect to this violation in accordance with IMC 0612, Appendix B.
05000387/FIN-2012003-0330 June 2012 23:59:59SusquehannaNRC identifiedVIOLATION OF 10 CFR 50.73(a)(2)(i)(B), FAILURE TO REPORT CONDITION PROHIBITED BY TSsInspectors identified a Severity Level (SL) IV NCV of 10 CFR Part 50.73 (a)(2(i)(B) for PPLs failure to submit a Licensee Event Report (LER) of a condition prohibited by plant TS associated with seat leakage from the Unit 1 D outboard main steam isolation valve (MSIV). On April 8, 2012, the D outboard MSIV failed to pressurize during its LLRT indicating that leakage was in excess of its TS limit. The same MSIV had failed to pressurize during its LLRT in 2010. The inspectors determined there was firm evidence to indicate that seat leakage from the MSIV was in excess of the TS limits during the previous two operating cycles for greater than the allowed outage time of 20 hours, which constitutes a condition prohibited by TS 3.6.1.3. PPL entered the issue into the CAP as CR 1590506. This finding was evaluated using the traditional enforcement process because the failure to accurately report events has the potential to impact or impede the regulatory process. The finding was determined to be a Severity Level (SL) IV NCV based on example 6.9.d.9 of the NRC Enforcement Policy. The significance of the associated performance deficiency was also screened against the ROP per the guidance of IMC 0612, Appendix B, lssue Screening. No associated ROP finding was identified and no cross-cutting aspect was assigned.
05000387/FIN-2011004-0130 September 2011 23:59:59SusquehannaNRC identifiedViolation of 10CFR55.25, Failure to Notify NRC of a Change in Medical Status and Request a Conditional LicenseThe inspectors identified a SL lV NOV of 10 CFR 55.25, lncapacitation Because of Disability or lllness, for PPL failing to notify the NRC of a known permanent change 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 a disqualifying condition and performed licensed duties without an NRC-approved, amended license. He performed the function of an RO while on watch from April 2009 through August 2011, when the NRC identified this issue. However, the operator did wear corrective lenses while standing watch since April 2009. Upon notification PPL submitted, and the NRC approved, a conditional license to address the disqualifying medical condition. PPL entered 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 permanent change in a licensed operator\\\'s medical status and request an amended license in order to assume licensed duties was a performance deficiency. This finding was evaluated using the traditional enforcement process because the issue had the potential to impact or impede the regulatory process. Specifically, there was a potentialfor license termination or the issuance of a conditional license to accommodate for a medical condition. The RO performed licensed duties from April 2009 through August 2011 with a disqualifying condition that required his license to be amended. Using the NRC Enforcement Policy, this violation was characterized at SL lV, in accordance with Section 6.4. This violation is being cited in the enclosed Notice in accordance with NRC Enforcement Manual Section 3.1.2, because the violation was determined to be repetitive of NRC Enforcement Action (EA) 09-248 dated January 28,2Q1Q, an SLlll Notice of Violation related to a Senior Reactor Operator (SRO) standing watch without meeting a medical qualification requirement. The medical conditions in both the former and current cases were similar: therefore, it was reasonable that an adequate extent of condition review for EA-09-24g should have identified the additional discrepancy. This significance of the associated performance deficiency was screened against the Reactor oversight Process (Rop) per the guidance of tMC 0612, Appendix B. No associated ROP finding was identified and no cross-cutting aspect was assigned
05000387/FIN-2011004-0630 September 2011 23:59:59SusquehannaNRC identifiedInaccurate RCS Pl Data SubmittalAn NRC-identified SL-IV NCV of 10 CFR 50.9(a), Completeness and Accuracy of Information, occurred when PPL inaccurately reported reactor coolant system (RCS) leakage values under the RCS leakage performance indicator (Pl)for both units since 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 Green/white threshold once the values were updated. Because violations of 10 CFR 50.9 are considered to potentially impede or impact the regulatory process, they are dispositioned using the traditional enforcement process. The inspectors concluded that PPL had reasonable opportunity to foresee and correct the inaccurate information prior to the information being submitted to the NRC. PPL\'s failure to identify and correct the recurring errors over this period of time indicated the existence of a programmatic issue. Additionally, verification of the corrected Pl data in a subsequent inspection 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 NRC has determined that the violation is of more than minor significance. The finding was not considered to be more significant since had this information been accurately reported, it would not have likely caused the NRC to reconsider a regulatory position or undertake a substantial further inquiry. The significance of the associated performance deficiency was screened against the ROP per the guidance of Manual Chapter 0612, Appendix B. No associated ROP finding was identified and no cross-cutting aspect was assigned
05000387/FIN-2010005-0631 December 2010 23:59:59SusquehannaNRC identifiedInaccurate MSPI Data SubmittalAn NRC-identified NCV of 10 CFR 50.9(a), Completeness and Accuracy of Information, occurred when PPL failed to update the Mitigating Systems Performance Index (MSPIs) to reflect a change in PPLs MSPI basis document. The change to the basis document affected all five MSPIs on each unit and resulted in inaccurate values for three consecutive quarters during 2010. PPL evaluated the MSPIs for needed changes and updated over 100 values used in calculating the PIs and entered the issues in their CAP as CRs 1328561 and 1328563. No performance indicator crossed the Green/White threshold once the values were updated. Because violations of 10 CFR 50.9 are considered to potentially impede or impact the regulatory process, they are dispositioned using the traditional enforcement process. The inspectors concluded that PPL had reasonable opportunity to foresee and correct the inaccurate information prior to the information being submitted to the NRC. This violation is characterized as a SLIV violation because it is similar to example 6.9.d.1 of the NRC Enforcement Policy, and is consistent with Section 2.2.1.c in that the violation impacted the regulatory process. Because this finding was of very low safety significance, was not repetitive or willful, and was entered into PPLs CAP, this violation is being treated as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy. The significance of the associated performance deficiency was screened against the ROP per the guidance of Manual Chapter 0612, Appendix B and the inspectors determined it to be minor because it did not result in any of the PIs exceeding the Green-White threshold. As such, no ROP finding was identified and no cross-cutting aspect was assigned.
05000387/FIN-2010002-0131 March 2010 23:59:59SusquehannaLicensee-identifiedLicensee-Identified ViolationIn June 2007, PPL Susquehanna management informed NRC resident inspectors that they had identified an issue where an individual had falsified entries in a weld rod oven temperature log. The NRC Office of Investigations (01) Investigation (Report 1-2008- 031) initiated on March 7, 2008, at PPL\'s Susquehanna Steam Electric Station (SSES). The purpose of the investigation was to determine if a SSES Operations Support Clerk (OSC) deliberately falsified weld rod oven temperature verification logs between June 8, 2007, and February 1, 2008. Based on evidence developed during the 01 investigation, the NRC concluded that the SSES OSC deliberately falsified the Weld Rod Oven Temperature Logs for four dates, specifically, January 29, 2008, through February 1, 2008. The creation of a false record material to the NRC constituted a violation of 10 CFR 50.9. Because the licensee is responsible for the actions of its employees, and because the violation was willful, the violation of 10 CFR 50.9 was evaluated under the NRC traditional enforcement process as set forth in Section IV.AA of the NRC Enforcement Policy. The NRC considered that the violation, absent willfulness, would be of minor safety significance because subsequent evaluation by PPL of the oven temperature recorders (separate from the logs) determined that the temperatures for this time frame were all satisfactory for the issuance of weld rods. However, the NRC increased the significance of the violation to Severity Level IV because the violation involved a deliberate act. The NRC considered issuance of a Notice of Violation for this issue. However, after considering the factors set forth in Section VI.A.1 of the Enforcement Policy, the NRC determined that although the violation was willful, a non-cited violation (NCV) was appropriate in this case because: (1) PPL identified the violation; (2) the violation inVOlved the acts of a non-supervisory individual who was not a licensee official in the context of the NRC Enforcement Policy; (3) the violation resulted from the isolated actions of a single individual without management involvement; and, (4) PPL took significant remedial action. The NRC also recognized that PPL did identify this issue on January 28, 2008, during a QA audit of the SSES Tool Room. As such, this violation was characterized as a licensee-identified, SLiV NCV of 10 CFR 50.9. Because it is a licensee-identified issue, it will not be entered into the Plant Issues Matrix; and in accordance with NRC Inspection Manual Chapter 0305, \"Plant Assessment\" was not directly considered in the plant assessment process. (EA-09-006
05000387/FIN-2009003-0230 June 2009 23:59:59SusquehannaNRC identifiedVIOLATION OF 10 CFR 50.73(A)(2)(VII), Report Common Cause of Failures of Independent ChannelsThe inspectors identified a non-cited violation of 10 CFR 50.73(a)(2)(vii), because PPL did not submit a Licensee Event Report (LER) for the common cause failure and consequent inoperability of two or more SRVs in 2005, 2008, and 2009. The inspectors determined that SRV failures of set pressure testing per the 1998 ASME O&M Code were attributed to setpoint drift resulting in two or more independent channels (two or more SRVs) to become inoperable. As an immediate corrective action, the licensee entered this NCV into their corrective action process (CR 1161398). This finding was evaluated using the traditional enforcement process because the failure to accurately report events has the potential to impact or impede the regulatory process. The finding was determined to be a Severity Level IV violation based on Supplement I, Example D.4 of the NRC Enforcement Policy. However, because this violation was of very low safety significance, was not repetitive or willful, and was entered into PPLs corrective action program, this violation is being treated as an NCV consistent with the NRC Enforcement Policy. This finding is related to the Problem Identification and Resolution cross-cutting area (Operating Experience (OE)) because PPL did not thoroughly incorporate Information Notice (IN) 2006-24 to include SRV set point drift as a reportable common cause failure method. (P.2(b))
05000387/FIN-2008302-0130 September 2008 23:59:59SusquehannaNRC identifiedFailure to Provide Complete and Accurate NRC License ApplicationThe NRC identified a Level IV non-cited violation of 10 CFR 50.9, Completeness and Accuracy of Information because PPL submitted a license application for a reactor operator to take an initial NRC license examination that incorrectly stated that the applicant was medically qualified with restrictions. The performance was reviewed for any cross cutting aspects and none were identified. This finding was more than minor because it impacted the NRCs ability to perform its regulatory function and was therefore evaluated using the traditional enforcement process. Specifically, PPL submitted a license application for a reactor operator to take an NRC license examination that incorrectly stated that the applicant was medically qualified with restrictions. This information could have resulted in an operator being licensed that was not medically qualified. The finding is of very low significance because it did not result in the NRC making an incorrect licensing decision and PPL took adequate corrective actions and on July 14, 2008 requested withdrawal of this reactor operator license application. (Section 4OA5
05000387/FIN-2004005-0231 December 2004 23:59:59SusquehannaNRC identifiedFailure to Complete 10 CFR 50.59 AnalysisThe inspectors identified a Severity Level IV violation of 10 CFR 50.59 requirements for the failure to evaluate a change in plant system configuration that was known to be inconsistent with accident analysis and the final safety analysis report (FSAR) description. On December 16, 20, 23 2004, and on January 4, 2005, PPL aligned the ventilation of the Unit 1 Reactor Building railroad bay to be outside of secondary containment which was inconsistent with the assumptions of a previously analyzed accident described in FSAR Chapter 15.6.2. PPL did not perform an evaluation in accordance with the requirements of 10 CFR 50.59 to determine if the change required a license amendment prior to implementation of this change in plant configuration This finding was addressed using traditional enforcement since it potentially impacts or impedes the regulatory process in that a required 10 CFR 50.59 evaluation was not performed and documented. A SDP Phase-1 screening was performed and determined that the condition resulting from the violation of 10CFR 50.59 was of very low safety significance because the finding only represents a degradation of the radiological barrier function provided by secondary containment and the standby gas treatment system. This is a Severity Level IV Violation of NRC requirements in accordance with Section VI.A of the NRC Enforcement Policy (Supplement I - Reactor Operations; Example D.5). This violation is being cited in a Notice of Violation under Section VI of the NRC Enforcement Policy since PPL did not restore compliance within a reasonable time after the violation was identified nor did they enter the violation into a corrective action program to address recurrence.