PLA-5870, Reply to a Notice of Violation (05000387-04-005-02) PLA-5870
| ML050670471 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 02/28/2005 |
| From: | Mckinney B Susquehanna |
| To: | Document Control Desk, NRC Region 1 |
| References | |
| PLA-5870 IR-04-005 | |
| Download: ML050670471 (5) | |
Text
Britt T. McKlnney Vice President-Nuclear Site Operations PPL Susquehanna, LLC 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3149 Fax 570.542.1504 btmckinney@pplweb.com I
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TPR ? 9 720S U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop OP1-17 Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION REPLY TO A NOTICE OF VIOLATION (05000387/2004005-02)
PLA-5870 Docket 50-387
Reference:
Sutsqutehanna Steam Electric Station - NRC Integrated Inspection Report 05000387/2004005 and 05000388/2004005 This letter provides the PPL Susquehanna, LLC (PPL) response to the NRC Notice of Violation (NOV 05000387/2004005-02) contained in Susquehanna Steam Electric Station - NRC Integrated Inspection Report 05000387/2004005 and 05000388/2004005, dated January 28, 2005. The attachment to this communication provides the formal PPL response to the violation.
PPL does not contest the violation or its significance level as characterized by the NRC.
As is recognized in the Integrated Inspection Report referenced above, PPL has restored compliance by controlling and limiting the time that the railroad bay ventilation is aligned outside secondary containment in a manner that is consistent with the Technical Specification (3.6.4.1) requirements for an inoperable secondary containment.
If you have any questions concerning the response, please contact Mr. R. R. Sgarro, Manager-Nuclear Regulatory Affairs, at (610) 774-7552.
Sincerely, B. T. McKinney
Attachment:
Reply to a Notice of Violation jcEo
Document Control Desk PLA-5870 Copy: Regional Administrator - Region I Mr. A. J. Blarney, NRC Sr. Resident Inspector Mr. R. V. Guzman, NRC Project Manager Mr. R. Janati, DEP/BRP to PLA-5870 Page 1 of 3 REPLY TO A NOTICE OF VIOLATION NRC Statement of Violation 05000387/2004005-02 Paragraph (c)(1) of 10 CFR 50.59 states, in part, that a licensee may make changes in the facility and procedures as described in the Final Safety Analysis Report (FSAR) and conduct tests or experiments not described in the FSAR without obtaining a license amendment only if the change, test or experiment does not meet any of the criteria in paragraph (c)(2) of this section.
Paragraph (d)(l) of 10 CFR 50.59 states, in part, that the licensee shall maintain records of changes to the facility, procedures, conduct of tests and experiments made pursuant to paragraph (c) of this section. These records must include a written evaluation which provides the bases for determination that the change does not require a license amendment pursuant to paragraph (c)(2) of this section.
Contrary to the above, PPL made a change to the facility, i.e., the method for performing or controlling a function, different from that described in the FSAR and did not perform and maintain records of a written evaluation which provided the basis for determination that the change does not require a license amendment. Specifically, on December 16, 20, 23, 2004, and on January 4, 2005, PPL changed the ventilation of the Unit 1 railroad bay from an area within the secondary containment, as described in the FSAR, to an area outside the secondary containment without a written evaluation pursuant to 10 CFR 50.59.
PPL Response Reason for the Violation It has been determined that misinterpretation of Generic Letter 91-18 guidance was the cause of this event. 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 FSAR accident analysis. Through implementation of a plant procedure, PPL was able to align the Unit 1 Railroad Bay as a secondary containment ventilation zone. This action established a secondary containment configuration that completely encompassed primary coolant instrument lines that were found outside of the plant's normal and customary secondary containment boundary.
PPL subsequently used an established procedure to temporarily return the railroad bay to its normal configuration (e.g., ventilation outside of secondary containment) to facilitate new fuel receipt. This action was supported by an approved Operability assessment that to PLA-5870 Page 2 of 3 reviewed the situation from a radiological dose consequence and a secondary containment bypass leakage standpoint. The assessment concluded that the secondary containment function remained operable in its normal configuration even with the identified non-conformance.
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 the NRC Generic Letter 91-18 process for addressing non-conforming but operable conditions. Despite an alternative view expressed by the NRC, PPL maintained a confidence that this non-conformance was solely governed by Generic Letter 91-18.
This confidence was based upon independent reviews that supported PPL's interpretation of Generic Letter 91-18 and evolving analysis which demonstrated that the non-conformance did not violate relevant Standard Review Plan (SRP) acceptance criteria.
PPL failed to recognize the applicability of 10 CFR 50.59 to the situation. The initial action of aligning the railroad bay to secondary containment established conformance with the licensing basis. Therefore, any action that re-established the non-conformance should have been considered a plant change subject to 10 CFR 50.59 evaluation. The misinterpretation of Generic Letter 91-18 guidance has been identified as the cause of this event. The plant design, which maintained an ability to restore FSAR conformance through the implementation of preexisting procedures, provided the unique circumstances necessary for creating this misinterpretation.
Corrective Steps That Have Been Taken and the Results Achieved PPL has aligned the railroad bay to secondary containment. 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 (TS 3.6.4.1). These actions restore compliance by controlling and limiting the time that the railroad bay ventilation is aligned outside of secondary containment.
PPL has also performed a review of Corrective Action Program data to confirm the unique nature of the event in question. This review identified no past problems with interpretation of Generic Letter 91-18 guidance.
Corrective Steps That Will Be Taken to Avoid Further Violations Prior to startup after the Spring 2006 Unit 1 Refueling Outage, PPL will implement a final resolution to the identified instrument line non-conformances that led to the violation. This action will eliminate the potential for further violations related to the specific circumstances of this event. Until this action is complete, Technical to PLA-5870 Page 3 of 3 Specification LCO 3.6.4.1 will continue to be utilized to control and limit the time that the railroad bay ventilation is aligned outside of secondary containment.
An additional review is being performed to determine if other similar situations exist where restoration of conformance to the licensing basis accident analysis could create the possibility for a similar misinterpretation. Preliminary results have identified no similar circumstances. This review will be finalized by March 31, 2005; if generic implications are identified, actions will be taken to reduce the potential for future misinterpretation.
Date When Full Compliance Will Be Achieved As is recognized in Integrated Inspection Report 05000387/2004005 and 05000388/2004005, PPL restored compliance on January 15, 2005 by controlling and limiting the time that the railroad bay ventilation is aligned outside secondary containment in a manner that is consistent with the Technical Specification (3.6.4.1) requirements for an inoperable secondary containment.