IR 05000387/2013002

IR 05000387-13-002 and 05000388-13-002; (01-01-13 - 03-31-13), Susquehanna Steam Electric Station - NRC Integrated Inspection Report

ML13134A117
Person / Time
Site:	Susquehanna
Issue date:	05/14/2013
From:	Mel Gray Reactor Projects Region 1 Branch 4
To:	Rausch T Susquehanna
GRAY, MEL
References
IR-13-002
Download: ML13134A117 (50)

Text

{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION May 14, 2013

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION - NRC INTEGRATED INSPECTION REPORT 05000387/2013002 AND 05000388/2013002

Dear Mr. Rausch:

On March 31, 2013, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Susquehanna Steam Electric Station (SSES) Units 1 and 2. The enclosed inspection report (IR) presents the inspection results, which were discussed on April 26, 2013, with Jon Franke, Site Vice President, and other members of your staff.

This inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents two self-revealing and two NRC-identified findings of very low safety significance (Green). Three of these findings were determined to involve violations of NRC requirements. Additionally, the NRC has determined that two traditional enforcement Severity Level IV violations occurred. One of these traditional enforcement violations was associated with one of the findings contained in this report. Further, one licensee-identified violation which was determined to be of very low safety significance and one licensee-identified violation which was determined to be Severity Level IV are listed in this report. However, because of the very low safety significance and because they are entered into your corrective action program (CAP), the NRC is treating these findings as non-cited violations (NCVs) consistent with Section 2.3.2 of the NRCs Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, D.C.

20555-0001; with copies to the Regional Administrator Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Senior Resident Inspector at the SSES. In addition, if you disagree with the cross-cutting aspect of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Senior Resident Inspector at the SSES. In accordance with the Code of Federal Regulations (10 CFR) 2.390 of the NRCs "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely, /RA/ Mel Gray, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 50-387; 50-388 License Nos. NPF-14, NPF-22

Enclosures:

Inspection Report 05000387/2013002 and 05000388/2013002 w/Attachment: Supplemental Information

REGION I== Docket No: 50-387, 50-388 License No: NPF-14, NPF-22 Report No: 05000387/2013002 and 05000388/2013002 Licensee: PPL Susquehanna, LLC (PPL) Facility: Susquehanna Steam Electric Station, Units 1 and 2 Location: Berwick, Pennsylvania Dates: January 1, 2013 through March 31, 2013 Inspectors: P. Finney, Senior Resident Inspector J. Greives, Resident Inspector F. Arner, Senior Reactor Inspector P. Kaufman, Senior Reactor Engineer C. Lally, Operations Engineer J. Ayala, Project Engineer Approved By: Mel Gray, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

Inspection Report (IR) 05000387/2013002 05000388/2013002 01/01/2013 - 03/31/2013;

Susquehanna Steam Electric Station (SSES), Units 1 and 2; Fire Protection, Maintenance Risk Assessments and Emergent Work Control, Plant Modifications, Performance Indicator (PI) Verification, Followup of Events and Notices of Enforcement Discretion The report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified four findings of very low safety significance (Green), three of which were also NCVs, and two Severity Level IV non-cited violations (NCVs), one of which was associated with one of the findings. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). The cross-cutting aspects for the findings were determined using IMC 0310, Components Within The Cross-Cutting Areas.

Findings for which the SDP does not apply may be Green, or be assigned a severity level after Nuclear Regulatory Commission (NRC) management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process (ROP), Revision 4.

Cornerstone: Initiating Events

Green.

A self-revealing NCV of very low safety significance (Green) was identified when PPL incorrectly implemented the clearance order process while returning the common offgas recombiner to service after maintenance. NDAP-QA-0322, Energy Control Process, Revision 42, requires that upon completion of the [clearance order] restoration plan, the system should be restored to the design operating condition (e.g. running, automatic standby, etc.). Additionally, it requires the System Operating Representative (SOR) and Operations Supervision to ensure restoration of the clearance order prevents introduction of system or plant transients. Contrary to these requirements, on December 12, 2012, when restoring from a clearance order, a manual isolation valve for the common recombiner was incorrectly left in the closed position. This resulted in a degradation of main condenser vacuum when the common recombiner was subsequently placed in service on February 5, 2013, requiring operator action to decrease reactor power to maintain main condenser vacuum within limits. PPL entered the issue into the CAP as CR 1668013.

The performance deficiency is more than minor because it was associated with the Configuration Control attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during power operations. Specifically, when PPL operators attempted to place the common recombiner in service on February 5, 2013, the closed manual isolation valve caused a loss of process flow to the recombiner and ultimately a degradation of main condenser vacuum. In responding to the reduction in vacuum, a recirculation pump runback was initiated and thermal power was rapidly reduced by approximately 32 percent. Additionally, the performance deficiency was similar to example 4.b in IMC 0612, Appendix E, Examples of Minor Issues, which states that a procedural error is more than minor if it caused a reactor trip or other transient. The inspectors evaluated the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, and determined the finding did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. Consequently, the finding is of very low safety significance (Green). The finding is related to the cross-cutting area of Human Performance, Work Practices in that PPL did not communicate human error prevention techniques such as self and peer checking to ensure work activities are performed safely. Specifically, both the SOR and Operations Supervision reviews were insufficient to ensure the manual steam isolation valve for the common recombiner was restored to the correct position during clearance order removal. [H.4(a)] (1R13)

Green.

The inspectors identified a Green Finding related to implementation of NDAP-QA-0737, Reactor Oversight Process (ROP) Performance Indicators, Revision 9, and associated severity level (SL) IV NCV of 10 CFR 50.9(a), Completeness and Accuracy of Information because PPL staff did not accurately report the Unplanned Scrams with Complications (USwC) performance indicator (PI) for the period of October 2012 through December 2012. Specifically, PPL did not report the Unit 2 reactor scram, which occurred on December 16, 2012, in this PI. PPL entered the issue in their CAP as CR 1688235 and corrected the data on March 20, 2013.This scram, when combined with a second complicated scram, which was accurately reported in the same quarter, caused the PI to cross the Green-White threshold. This was discussed in an NRC follow-up assessment letter dated April 1, 2013 (ML13092A011).

The finding was evaluated in accordance with IMC 0612 Appendix B, Issue Screening, which states, in part, that a performance deficiency is more than minor if it is related to a performance indicator and caused the performance indicator to exceed a threshold. In this case, when the December 16 scram was re-classified under the USwC PI, the performance indicator crossed the Green-White threshold. The inspectors evaluated the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power and determined the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available.

Consequently, the finding is of very low safety significance (Green). Additionally, the issue was evaluated in the traditional enforcement process because it had the potential to impact the NRCs ability to perform its regulatory function. The inspectors determined the finding was a Severity Level IV violation using the examples of the NRC Enforcement Policy.

Specifically, example 6.9.d.11 states a 10 CFR Part 50 licensee submits inaccurate or incomplete PI data to the NRC that would have caused a PI to change from green to white is an example of a SL IV violation. This finding has a cross-cutting aspect in the area of Human Performance, Decision-Making because PPL personnel did not communicate decisions and the basis for decisions to personnel who have a need to know the information in order to perform work safely, in a timely manner. Specifically, PPL did not adequately document the basis for determining the scram, which occurred on December 16, 2012, should be classified under the USwC PI to enable reviewers to adequately challenge the decision to ensure the appropriate classification was made. [H.1.(c)] (4OA1)

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green NCV of Unit 2 Operating License Condition 2.C.(3), regarding its fire protection program, when PPL stored transient combustibles in restricted areas without evaluations by the site fire protection group. PPL procedure NDAP-QA-0440, Control of Transient Combustible/Hazardous Materials, Revision 10, section 6.2.4 states that, for restricted areas, transient combustibles or hazardous materials shall not be stored in these areas without specific instructions to do so. It continues that specific approvals for storage in Restricted Areas must be from the Site Fire Protection Group. PPL removed transient combustibles from the restricted areas, established hourly fire watches as appropriate, revised procedures, conducted walkdowns for the extent of the condition, and entered the issues in their CAP.

The inspectors evaluated this finding using IMC 0612 Appendix B and determined it to be more than minor based on affecting the Protection against External Factors attribute of the Mitigating Systems cornerstone and its objective to ensure the availability, reliability, and capability of systems that respond to initiating events, in this case fire, to prevent undesirable consequences. Additionally, it was similar to IMC 0612 Appendix E example 4.k in that in all of the observations, transient combustibles were in a combustible free zone required for separation of independent trains and, in one case, the fire loading was not within fire hazard analysis limits. The finding was qualitatively screened in accordance with IMC 0609 Appendix F where the finding was categorized under Fire Prevention and Administrative Controls. The degradation was assigned a Low rating and screened to Green based on the Low degradation rating. The finding was determined to have a cross-cutting aspect in the area of Human Performance, Work Practices, for the need to ensure supervisory and management oversight of work activities such that nuclear safety is supported. Specifically, PPL supervisory and management oversight had not sufficiently coached and reinforced the knowledge of station and procedural standards regarding restricted area requirements. [H.4(c)] (1R05) SLIV. The 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. (1R18)

Green.

A self-revealing NCV of 10 CFR 50 Appendix B, Criteria V Instructions, Procedures, and Drawings, was identified because PPL did not ensure alarm response procedures (ARPs) for control room cooling fan train failures were adequate, which resulted in the subsequent loss of both trains of cooling during clearance order (CO) application for fan repair work. Specifically, the ARP actions were deficient in allowing an abnormal system control switch configuration that led to the inadvertent shutdown of the in-service B train fans during the application of the CO process to perform work on the failed A control room cooling fan train. PPL entered the issue into their CAP to repair the failed damper and also evaluate the extent-of-condition to ensure the adequacy of other applicable ventilation procedures.

The inspectors determined the deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating System Cornerstone. The inadequate procedure resulted in the loss of control room cooling fans, which affects the objective to ensure the availability and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined through a review of IMC 0609 Appendix A, Exhibit 2, Mitigating Systems Screening Questions, that the finding was of very low safety significance (Green) because the finding was not related to a design or qualification deficiency, did not represent a loss of a credited mitigating system safety function because cooling was restored in a timely manner, and did not screen as potentially risk significant due to external initiating events. The control room operators immediately recognized the loss of cooling and took manual action to restart the B cooling train within 15 minutes to ensure control room temperatures were not adversely affected. The finding did not have a cross-cutting aspect because the inadequate ARP was an historical issue not indicative of current performance. Specifically, the procedures had not been adequately identified and revised in 2003 and this occurred outside of the nominal three-year period for evaluating present performance as defined in IMC 0612, section 03.15. Additionally, PPL has instituted procedure and CAP improvements since that time which would have prevented the performance deficiency. (4OA3)

Other Findings

Violations of very low safety significance or Severity Level IV that were identified by PPL staff were reviewed by the inspectors. Corrective actions taken or planned by PPL staff have been entered into PPLs CAP. These violations and corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at or near 100 percent power. On February 15, Unit 1 was reduced to approximately 68 percent over 13 hours for a control rod pattern adjustment. Unit 1 ended the inspection period at or near 100 percent power.

Unit 2 began the inspection period at 84 percent power with operators increasing reactor power from a reactor startup on December 26. Unit 2 reached full power later on January 1.

Operators reduced Unit 2 power to 64 percent on February 5 due to a problem with an offgas recombiner that degraded main condenser vacuum. Operators returned Unit 2 to full power on February 6. On February 8, operators reduced Unit 2 power to 74 percent over 15 hours for a control rod sequence exchange. Operators similarly reduced Unit 2 power on February 16 to 89 percent over 8 hours for a control rod pattern adjustment. Finally, on March 2, operators decreased Unit 2 power to 77 percent over 15 hours for a control rod pattern adjustment and control rod scram testing. Unit 2 ended the inspection period at or near 100 percent power.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Readiness for Imminent Adverse Weather Conditions

a. Inspection Scope

The inspectors reviewed PPLs preparations in advance of and during warnings and advisories issued by the National Weather Service. The inspectors performed walkdowns of areas that could be potentially impacted by the weather conditions, such as the emergency and station black out diesel generators (DGs), station transformers, and switchyards, and verified that station personnel secured loose materials staged for outside work prior to the forecasted weather. The inspectors verified that PPL monitored the approach of adverse weather according to applicable procedures and took appropriate actions as required. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), Technical Specifications (TSs), control room logs, and the CAP to determine what temperatures or other seasonal weather could challenge these systems and to ensure PPL personnel had adequately prepared for these challenges.

The inspectors reviewed station procedures, including PPLs seasonal weather preparation procedure and applicable operating procedures. Documents reviewed for each section of this inspection report are listed in the Attachment.

Common, cold weather alert for January 24, 2013

b. Findings

No findings were identified. ==1R04 Equipment Alignment

.1 Partial System Walkdowns

==

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems: Unit 2, turbine building closed cooling water (TBCCW) on February 5, 2013 Unit 2, RCIC during high pressure coolant injection (HPCI) unavailability, March 7, 2013 Unit 2, HPCI during RCIC unavailability, March 14, 2013 Common, B emergency diesel generator (EDG) during A EDG inoperability for a damper failure The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, TSs, work orders (WOs), condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether PPL staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings

No findings were identified. ==1R05 Fire Protection