ML20136G052
| ML20136G052 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna, 05000000 |
| Issue date: | 05/22/1985 |
| From: | Campagnone M Office of Nuclear Reactor Regulation |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20136E841 | List: |
| References | |
| FOIA-85-668 NUDOCS 8506050101 | |
| Download: ML20136G052 (10) | |
Text
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Docket No. 50-387/388' MAY 2 21985
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MEMORANDUM FOR:
Richard Starostecki, Director Division of Reactor Projects Region I THRU:
Walter R. Butler, Chief Licensing Branch No. 2 Division of Licensing FROM:
M. Campagnone, Project Manager Licensing Branch No. 2 Division of Licensing
SUBJECT:
.SALP - PENNSYLVANIA POWER AND LIGHT COMPANY l
SUSQUEHANNA STEAM ELECTRIC STATION Enclosed is the NRR evaluation of the licensee's performance for the licensing' activities portion of the SALP review for the Susquehanna Steam Electric Station during the period February 1,1984 through April,30,1985.
Meleel eigned bre ll. Campagnone, Preject Manager Licensing Branch No. 2 Division of Licensing
Enclosure:
As stated CONTACT:
H. J. Campagnone, X-27235 DISTRIBUTION Docket File LBf2 Reading
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s Encicsure Docket No. 50-387/388 FACILITY:
Suscuehanna Steam Electric Station LICERSEE:
Pennsylvania Power and Light Company EVALUATIO:: PERIOD:
February 1, 1984 to April 30, 1985 PROJECT MANAGER:
Mari-Josette Campagnone I.
SUMMARY
This report contains NRR's input to the SALP review for the Susquehanna Steam Electric Station (SSES). The assessment of the licensee's performance was conducted according to NRR Office Letter No. 44, NRR inputs to SALP Process, dated January 3,1984. This Office Letter incorporates NRC Manual Chapter 0561, Systematic Assessment of Liseasee Performa'nce.
NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned a performance category (Category 1, 2 or 3) based on a composite of a number of attributes. The performance of the Pennsylvania Power and Light Company in the functional area of Licensing Activities is rated Category i II. CRITERIA The evaluation criterik used in the assessment are given-in NRC l'ir.ual Chapter 0516 Appendix, Table 1, Evaluation Criteria.with Attributes for Assessment of Licensee Performance.
L III.- BETHODOLOGY
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This evaluation represents the integrated inputs of the Operating Reactor 4
Project Manager-(ORPM) and the technical review groups who expended signifi-j cant' efforts on SSES' licensing actions during-the current ~ rating period.
Using 2
the guidelines of HRC Manual Chapter 0516, the ORPM and the revieu groups applied specific evaluation criteria to the relevant licinila performance attributes, as delineated in Chapter 0516, and assigneo ch crerall rating
. category (1, 2 or 3) to each attribute.
The review groups inciuded this information_as part of Safety Evaluation Reports transmitted to the Division of Licensing. The ORPM, after reviewing.these inputs, combined this infor-mation with his own assessment of licensee performance and using a;propriate weighting factors, arrived at a composite rating for the licensee. The rating also reflected the comments of the NRC Senior Executive essigned to the SSES
'SALP assessment.
A written evaluation which was then prepared by the ORPM and circulated to NRR management for comments which were incorporated in the L final draf t.
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, The basis for the appraisal was the licensee's performance in support of licensing actions that were either comnleted or had a significant level of acti'vity during the current rating period.
IV. ASSESSMENT OF PERFORitANCE' ATTRIBUTES The licensee's performance evaluations were based on consideration of the seven attributes as given in the NRC Manual Chapter.
For most of the licensing actions considered in these evaluations, only three of the' attributes.were.of significance.
Therefore, the composite ratings were heavily based on the following attributes:
-- lianagement. involvement in assuring safety
-- Approach ;to resolution of technical issues from a safety standpoint
-- Responsiveness to NRC initiatives The remaining attributes of Staffing, Enforcement History,. Reportable
- Events and Training were judged to apply to relatively fewer licensing actions.-
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Susquehanna, Unit 1-Plant:
(Operating Phase Reactor)
Intrccuction During the assesscent period from February 1,19FA to April 30.19S5, Unit 1 operated commercially.
In this peric..i the staff issued 22 amendments to.the Unit T license.
These changes included administrative char.;es to reflect plant modifications and new information based on operating experience.
4 Additionally, changes to the Unit I licer.se were made to provide consistency between the Unit I and Unit 2 Technical Specifications. Two amendrents were processed under emergency circumstances.
In each case, the sta'ff concluded that circumstances leading to the emergency conditicns could not be avoided.
Unit I tient down for its first refueling cutage in February of 1985 and plans to remain down until June of 1985. During the Unit I first refueling outage 1
the licensee has had to schedule one major repair on a steam dryer support bracket. Additionally during this period Susquehanna underwent its first Fire Protection Auoit which diverted licensee staff manpower as a result of some HRR/ plant specific problems.. Also during this period the Unit 2 low power and full power licenses were issued, the Unit 2 start-up testing and pre-operational j
testing was completed, and Unit 2 went commercial in February of 1985.
Functional Areas:
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1.
Manacement Invc1vement and Control in Assuring Ouality
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. Pennsylvania Power and Light Company (PPLL) has demonstrated a good degree of management control and involvement.
PP&L management has participated in site reviews and audits with a positive attitude
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and a willingness to cooperate. Most licensing amendment requests j
reflect adequate evidence of prior planning necessary to support i
licensing activity schedules. Additionally PP&L management staff level review has always been adequate. When necessary PP&L has'provided the WRC with additional support necessary to expedite reviews of proposed ame,ndments. During the first refueling outage management support seemed ~
slightly strained. -The licensee needs_to evaluate more closely the necessity of and scheduling of amendment requests; Rating: Category 2.
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2.
Aporoach to Resolution of Technical Issues from a Sefetv Star.c6cint The licensee has demonstrated a clear understanding of issues applicable to licensing activities. The licensee has in some instances submitted information that is not as complete as expected, but upon recuest has adequately supplemented this information.
The need to reques additionai information does not reflect a lack of knowledge of the issue but a lack of-complete documentation of information.
FP&L should strive to improve the completeness of the information submitted to the staff so as to avoid l
unnecessary time and effort expended on obtaining additional information.
The licensee has proven to be responsible and ' competent in resolving tecnnical issues from a safety stanopoint.
PP&L's licensing staff is technically.knowledgable and exceptionally sensitive to safet;. concerns.
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. - -- Rating: Category 1 3.
Resoonsiveness to NRC Initiative In response to NRC initiatives, the licensee has generally provided
-timely responses, with adequate resolutions proposed.
The licensee has had some difficulty responding to some informal requests for i
additional information necessary to complete safety reviews of license amendment requests. This difficulty has not been experienced throughout the SALP period but has become evident during.the Unit 1 first refueling outage as a large portion of plant personnel resources have baen dedicated to the outage making their availability to discuss technical issues with
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the NRC staff limited.
Rating: Category 2 4.
Enforcement History During this SALP period PP&L has been cited for some violations. These violations were not indicative of a programmatic breakdown.
In all instances the licensee took prompt effective corrective action. This was evidenced by PP&L's attention to the problems experienced with the Scram Pilot Solenoid Valves (SPSV) during individual rod scram testing.
PP&L showed good initiative by persuing both the immediate problem and the root cause.
Overall PP&L has shown good initiative in reporting and resolving any difficulties which may result in enforcement action.
Rating: Category 1 5.
Reoortico and Analysis of Reportable Events Corpo' rate and plant management are aware of the deficiencies and events tha,t are reportable to the NRC. The licensee reports events completely and accurately. When requested to provide follow-up information the licensee has been responsive in a timely manner to NRC follow-up requests.
In most cases the corrective action has been effective.
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Rating: Category 1 6.
Staffine (includinc l'anacement)
Personnel involved in licensing activities are knowledgeable and professional.
The licensing staff has sound technical knowledge of licensing activities and has dealt with the staff in a straight forward manner. Appropriate personnel are in attendance at meetings with the NRC staff to make the meetings productive.
Rating: Category 1
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Trainina and Oualification Effectiveness
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J The licensee has maintained an adequate number of licensed personnel at Susquehanna Unit 1 for'which most are qualified to also operate Susqueha,nna Unit 2.
Rating Category 1 90 9 D
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Plant: Susquehanna, Unit 2 (Precperational/ Operating Phase Reactor)
Introduction During this assessment period from February 1,1984 to April 30, 1985, the URC staff along with PP&L was involved with several phases of the licensing process.
During this period Supplements 6 and 7 to the Safety Evaluation Report were issued. They addressed the remaining open items on Susquehanna Unit 2 requiring resolution prior to low power / full power operating license issuance. Addition-ally Unit 2 completed start-up testing, low power testing, power ascension testing and initial commercial operation within this SALP period.
During this SALP period the staff issued 10 amendments to the Unit 2 license.-
Functional Areas:
1..
Manacement Involvement and Control in Assurino Quality The licensee has demonstrated a high degree of involvement resolving licensing issues. The licensee's management has participated in site reviews and audits with a positive attitude and willingness to cooperate.
From a licensing activity standpoint the licensee has developed some knowledge and experience through the operation of Unit I which is reflected in improved scheduling and planning for Unit 2.
Additionally the licensee profitted from the experienci gained from Unit I and was able to play a more meaningful role in the licensing process prior to and following Unit 2 licensing.
Rating: Category 1 2.
Acoroach to Resolution of Technical Issues from a-Safety Standooint The licensee has routinely exhibited conservatism in areas of safety significance. The licensee has proposed technically sound and thorough app, roaches in most cases and overall the licensee has shown a clear
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understanding of licensing issues.
This has been evidenced by their depth of knowledge relating to the impact of 2 Unit operation on Technical Specification requirements, as well as, proposals submitted in
'an effort to make Unit I and 2 more independent of one another (i.e.
125-volt battery common load transfer capability). Although the licensee shows a clear understanding of the impact of 2 unit oper.ation with common Unit 1/ Unit 2 systems their attempt to resolve these issues could have been pursued in a more timely manner.
Rating:
Category 1 3.
Responsiveness to NRC Initiatives PP&L is generally aware of the staff's needs in order to perform its i
review function with adequate lead time. The licensee is responsive to meeting with the HRC staff in order to resolve critical path issues.
The licensee needs to more effectively determine its priorities relating to licensing issues.
By prioritizing the need for licensing actions the licensee can more effectively respond to those NRC reques s of greater importance in a more timely manner.
l Rating: Category 2 l
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Enforcement ^ History The licensee has received some violations during' this SALP period. These violations were not indicative of a programmatic breakdown. One specific incident which required enforcerent action took place in July ~of 1984
'when Unit 2 expsrienced a loss of all AC power. Events leading to this incident included several operational errors. Although the staff does not find that this incident indicates a programmatic breakdown we feel that several consecutive operational errors is a cause for some concern.
In all instances the licensee took effective corrective action.
Rating: Categ[ry2 5..
Reporting and Analysis of Reportable Events
' Corporate and plant management are aware of the deficiencies and events that are reportable to the NRC. The licensee reports events completely and accurately. When the licensee has been requested to provide more detailed information this has been accomplished in a reasonable time period. The licensee needs to be more responsive to NRC follow-up i
requests.
In most cases the corrective action has been effective.
Rating: Category 1 6.
Staffing (Including Management)
Personnel involved in licensing activities are knowledgeable and professional. The licensing staff has sound technical knowledge of licensing activities and has dealt with the staff in a straight forward Appropriate personnel are in attendance at meetings with the manner.
NRC staff to make the meetings productive.
Ratingi ' Category 1 l
7.
Tr:aining and Qualification Effectiveness.
1 The licensee has maintained an adequate number of licensed personnel at i
Susquehanna Unit 2 for which most are qualified to also operate Susquehanna Unit 1.
Rating: ~ Category 1 l
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t INFORMATION TO BE ADDED TO SECTION V 0F SAtP REPORT SUPPORT DATA AND
SUMMARY
1.
HRR Site Visits 11/13/84 - Site.Walkdown
. 03/18/05 - Fire Protection NRR Audit 04/08/85 - Refueling Outage Repairs Review 2.
Comission Briefings ilay22,1984 PP&L and the staff attended the full power license Comission briefing for Unit 2..
3.
Schedular Extensions Granted Environmental Qualification Extension granted allowing until Hovember 30, 1985 for environmental qualification of equipment for both units 1 and 2.
4.
Reliefs Granted December 24, 1984, granted relief from certain requirements (hydrostatic pressure test following repair) of ASME CODE Section IX Inservice (Testing) Requirements for Susquehanna '
Unit 2.
5.
Exemotions Granted December 19, 1984 Exemption from requirements of'-10 CFR 50.44 (containment inerting) Paragraph (c)(3)(1) to Facility Operating 3
License No. NPF-22 6..
License Amendments Issued 32 amendments issued.
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Emeroency Technical Specifications Issued i
2 emergency changes.
8.
-Orders Issued June 14, 1984 Order confirming licensee commitment of Emergency Response Capability for NPF-14, Unit 1.
July 27, 1984 Order confirming the actions that were the subject of a Confirmatory Action Letter dated July 26, 1984, relating to fiPF-22, Unit 2, loss of all AC power incident experienced during Unit 2 te' sting.
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NRR/ Licensee Management C'onferences On February 26, 1985 and April 18, 1985, NRR met with the licensee to discuss the Susquehanna Fire Protection Program.
- 10. 'Housekee' ping-During the visits by NRR to the Susquehanna site it was noted that the housekeeping and cleanliness practices at Susquehanna were markedly good.
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