IR 05000387/2012004

IR 05000387-12-004 and 05000388-12-004; 07-01-12 - 09-30-12; Susquehanna Steam Electric Station - NRC Integrated Inspection Report and NRC Office of Investigations Report 1-2012-017

ML12319A022
Person / Time
Site:	Susquehanna
Issue date:	11/13/2012
From:	Paul Krohn Reactor Projects Region 1 Branch 4
To:	Rausch T Susquehanna
krohn, pg
References
1-2012-017 IR-12-004
Download: ML12319A022 (43)

Text

{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION ber 13, 2012

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION - NRC INTEGRATED INSPECTION REPORT 05000387/2012004 AND 05000388/2012004 AND NRC OFFICE OF INVESTIGATIONS REPORT 1-2012-017

Dear Mr. Rausch:

On September 30, 2012, 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 October 16, 2012, with you 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 NRC-identified findings and one self-revealing finding of very low safety significance (Green). Two of these findings were determined to involve violations of NRC requirements. Additionally, one licensee-identified violation, which was determined to be of very low safety significance, is listed in this report. However, because of the very low safety significance and because they are entered into your correction 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 NCVs 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, U. S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspectors at 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 Resident Inspectors at SSES.

This inspection also reviewed actions regarding the failure of the C emergency diesel generator (EDG) identified by NRC inspectors in December 2011. In response, the Region I Field Office, NRC Office of Investigations (OI), initiated an investigation on January 2, 2012, to determine whether maintenance technicians and a Quality Control (QC) inspector, employed by PPL, deliberately failed to properly assemble delivery valves on 15 fuel pumps. Based on testimonial and documentary evidence gathered during the investigation, the investigators concluded that while a violation of Technical Specification (TS) requirements had occurred, improper planning and implementation of work instructions was identified as the cause and that the technicians and QC inspector did not deliberately fail to perform the maintenance. The safety significance of this violation was previously evaluated by the NRC and documented in NRC Inspection Report 05000387;388/2011005 as a Green finding. The enforcement aspects of the Green finding were held open pending the completion of the NRC OI Investigation. The NRC is dispositioning this violation of NRC requirements as an NCV in accordance with the Enforcement Policy since it was of very low safety significance, PPL has entered this issue into their CAP, it was not repetitive or willful, and compliance was restored in a reasonable period of time. The finding and associated violation will be counted as one input into the plant assessment process.

Please note that final NRC documents, such as the OI report described above, may be made available to the public under the Freedom of Information Act (FOIA) subject to redaction of information appropriate under FOIA. Requests under FOIA should be made in accordance with 10 CFR 9.23, Request for Records.

In accordance with 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/ Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 50-387, 50-388 License Nos. NPF-14, NPF-22 cc w/encl: Distribution via ListServ

ML12319A022 Non-Sensitive Publicly Available SUNSI Review Sensitive Non-Publicly Available OFFICE mmt RI/DRP RI/DRP RI/ORA RI/DRP NAME PFinney/AAR for ARosebrook/ AAR MMcLaughlin/ MMM PKrohn/ PGK DATE 11/ 06 /12 11/06 /12 11/06 /12 11/07 /12 Distribution w/encl: (via e-mail) W. Dean, RA D. Lew, DRA D. Roberts, DRP J. Clifford, DRP C. Miller, DRS P. Wilson, DRS P. Krohn, DRP A. Rosebrook, DRP S. Ibarrola, DRP P. Finney, DRP, SRI J. Greives, DRP, RI S. Farrell, DRP, AA C. Santos, RI OEDO RidsNrrPMSusquehanna Resource RidsNrrDorlLpl1-2 Resource ROPreports Resource

U.S NUCLEAR REGULATORY COMMISSION

REGION I

Docket No: 50-387, 50-388 License No: NPF-14, NPF-22 Report No: 05000387/2012004 and 05000388/2012004 Licensee: PPL Susquehanna, LLC (PPL) Facility: Susquehanna Steam Electric Station, Units 1 and 2 Location: Berwick, Pennsylvania Dates: July 1, 2012 through September 30, 2012 Inspectors: P. Finney, Senior Resident Inspector J. Greives, Resident Inspector R. Edwards, Acting Resident Inspector F. Arner, Senior Reactor Inspector S. Ibarrola, Acting Resident Inspector P. Kaufman, Senior Reactor Inspector J. Caruso, Senior Operations Engineer R. Rolph, Health Physicist S. Hammann, Senior Health Physicist Approved By: Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000387/2012004, 05000388/2012004; 07/01/2012 - 09/30/2012; Susquehanna Steam

Electric Station, Units 1 and 2; Adverse Weather Protection, Maintenance Effectiveness, Maintenance Risk Assessments and Emergent Work Control The report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified two non-cited violations (NCVs) and one self-revealing finding of very low safety significance (Green). 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 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, dated December 2006.

Cornerstone: Initiating Events

Green.

The inspectors identified a Green NCV of TS 5.4.1, Procedures, when PPL did not maintain adequate procedures to respond proactively to acts of nature. Specifically, PPLs adverse weather procedure did not ensure timely risk management activities for imminent adverse weather were completed despite a National Weather Service (NWS) declaration of a high wind watch, high wind advisory, and a tornado watch. PPL entered this item in their Corrective Action Program (CAP) as condition report (CR) 1628452.

The issue was evaluated in accordance with IMC 0612 and determined to be more than minor since it affected the procedure quality attribute of the Initiating Events cornerstone and its objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the inadequate procedure prevented PPL from taking proactive steps to limit the likelihood of high wind or tornado-related missile hazards upsetting plant electrical power systems.

The finding screened to Green in accordance with IMC 0609, Attachment 4, and Appendix A, Exhibit 1, since it did not cause a reactor trip, involve the complete or partial loss of mitigation or support equipment, or impact the frequency of a fire or internal flooding event.

The finding was determined to have a cross-cutting aspect in the area of Problem Identification and Resolution - CAP because PPL did not identify issues completely, accurately, and in a timely manner commensurate with their safety significance.

Specifically, PPL did not identify that the Off Normal procedure was inadequate both during the 2011 periodic procedural review and during documentation of inspector observations in May 2012 as part of CR 1579977. [P.1(a)] (Section 1R01)

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green NCV of 10 CFR 50.65(a)(4) when PPL did not implement risk management actions (RMAs) during maintenance as required by station procedures. The inspectors identified multiple examples of PPL non-compliance with 10 CFR 50.65(a)(4); PPLs implementing procedures NDAP-QA-0340, Protected Equipment Program; and NDAP-QA-1902, Integrated Risk Management. PPL entered the issue in their CAP as CRs 1611044, 1604007, 1601929, 1602495, and 1611876.

The finding was more than minor because it was similar to IMC 0612, Appendix E, examples 7.e and 7.f. Specifically, elevated plant risk required RMAs or additional RMAs that were not implemented as required by plant procedures. The finding also affected the equipment performance attribute of the Mitigating Systems Cornerstone and its objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. In accordance with IMC 0609, Attachment 4, the issues were determined to involve PPLs assessment and management of risk associated with performing maintenance activities and was further assessed under IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management SDP. The issue was evaluated by a Senior Reactor Analyst utilizing flowchart 2, and the finding was determined to be of very low safety significance (Green) since it did not result in an increase to either the incremental core damage probability (ICDP) or to the incremental large early release probability (ILERP).

The finding was determined to have a cross-cutting aspect in the area of Human Performance, Work Control, in that PPL did not plan work activities, consistent with nuclear safety, by incorporating risk insights. Specifically, PPL did not incorporate RMAs into its work activities despite recognition of increased risk. [H.3(a)] (Section 1R13)

Cornerstone: Barrier Integrity

Green.

A self-revealing Green finding against PPL procedure NDAP-QA-0510, Troubleshooting Plant Equipment, was identified when inadequate troubleshooting caused repeated inoperability of secondary containment, an associated unplanned Unit 2 entry into a 4-hour limiting condition for operation (LCO) action statement, and a loss of the 1C fuel pool cooling (FPC) pump during equipment restoration. The FPC pump had been designated as protected equipment as a risk management action. The failure to perform adequate troubleshooting activities to identify and correct equipment problems prior to restoration was a performance deficiency that was within PPLs ability to foresee and prevent. PPL entered this issue into their CAP as CR 1628250.

The inspectors determined that the finding was more than minor because it was associated with the configuration control attribute of the Barrier Integrity cornerstone and adversely affected its objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the event resulted in the inoperability of secondary containment and loss of a FPC pump. The finding was evaluated in accordance with IMC 0609, Attachment 4, and Appendix A - Exhibit 3, and was determined to be of very low safety significance (Green) because the finding did not only represent a degradation of the radiological barrier function provided for the standby gas treatment system and it did not: a) cause the spent fuel pool to exceed a maximum temperature limit; b) cause mechanical fuel damage and detectable release of radio-nuclides; c) result in the loss of spent fuel pool water inventory; or d) affect spent fuel shutdown margin. This finding is related to the cross-cutting area of Human Performance - Decision-Making because PPL did not make safety-significant or risk-significant decisions using a systematic process, especially when faced with uncertain or unexpected plant conditions, to ensure safety is maintained. Specifically, PPL failed to restore equipment in a systematic manner, given the intermittent nature of heater faults, to preclude a repeated loss of protected equipment and secondary containment. [H.1(a)] (Section 1R12)

Other Findings

A violation of very low safety significance that was identified by PPL was reviewed by the inspectors. Corrective actions taken or planned by PPL have been entered into PPLs CAP. This violation 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 in Mode 2 starting up from a forced outage. The unit reached 100 percent rated thermal power (RTP) on July 6. On July 7, the unit was reduced to 68 percent over 32 hours for a control rod pattern adjustment. On July 17, the unit was reduced to 83 percent power over 17 hours for indications of a main generator oil exciter leak. On August 18, the unit was reduced to 65 percent power over 33 hours for a control rod sequence exchange. The unit remained at or near 100 percent power for the remainder of the inspection period.

Unit 2 began the inspection period at or near 100 percent power. On July 28, the unit was reduced to 83 percent power over 18 hours for a condenser waterbox planned isolation activity.

On August 3, the unit was reduced to 59 percent power over 66 hours for condenser waterbox cleaning. On August 24, Unit 2 was reduced to 66 percent power over 34 hours for a control rod sequence exchange. The unit remained at or near 100 percent power for the remainder of the inspection period.

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, 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. Documents reviewed for each section of this inspection report are listed in the Attachment.

Common, hot weather alert for July 5 - 7, 2012 Common, high wind watch for afternoon of September 18, 2012

b. Findings

Introduction.

The inspectors identified a Green NCV of TS 5.4.1, Procedures, when PPL did not maintain adequate procedures to respond proactively to acts of nature.

Specifically, PPLs adverse weather procedure did not ensure timely risk management activities for imminent adverse weather were completed despite a National Weather Service (NWS) declaration of a high wind watch, high wind advisory, and a tornado watch.

Description.

On May 25, 2012, inspectors informed Operations staff of a concern regarding debris in the vicinity of the supplemental decay heat removal piping that could become a missile hazard based on the amount of debris in the area if high winds were encountered. The items noted included hoses, buckets, stanchions, and loose piping.

The inspectors based this concern, in part, on forecasted inclement weather. PPL entered this observation in their CAP as CR 1579977, closed the CR without action, and documented that should inclement weather occur prior to clean up, the appropriate off normal procedure would be entered and the area secured. Regulatory Guide (RG) 1.33 identifies Acts of Nature as one type of procedure for combating emergencies and other significant events that is part of the list of safety-related activities that should be covered by written procedures.

On September 17, 2012, the NWS issued a High Wind Watch for Luzerne County in effect from the morning through the evening of September 18. The NWS issues a High Wind Watch when there is a potential for high wind speeds developing that may pose a hazard or is life threatening. At 4:04 a.m. on September 19, the NWS issued a High Wind Advisory to be in effect from 11:00 a.m. to 6:00 p.m. expecting sustained winds of 20 to 30 miles per hour (mph) with gusts of 40 to 50 mph and localized gusts of 50 mph or greater possible. Downed trees and power lines were anticipated. Based on the High Wind Watch and Advisory, the resident inspectors selected an Imminent Weather inspection sample and completed walkdowns of the 500KV and 230KV offsite power switchyards, the primary and backup meteorological towers, offsite power transformers T10 and T20, Unit 1 and 2 main transformers, the station blackout EDG, and the Engineered Safeguards System transformers. The inspectors noted a number of items that could be potential missile hazards that included loose pieces of wood, loose wood blocks, wooden pallets, a wooden cable spool, stanchions, piping, piping flanges, a metal-frame door, and pieces of sheet metal. Some of the loose wood, pallets, and cable spool were located inside the 500KV switchyard. The remaining items were located in the vicinity of the ESS transformers and station blackout (SBO) EDG.

The inspectors reviewed the station procedures concerning adverse weather. At approximately 12:00 p.m., one of the inspectors went to the control room and asked the Shift Manager what procedure(s) had been entered for the High Wind Advisory. During the conversation, the control room received a phone call informing the site that the NWS had declared a Tornado Watch for Luzerne County. The NWS issues a Tornado Watch when conditions are favorable for the development of tornadoes in and close to the watch area. The Shift Manager updated station leadership on the new information and a log entry was made that: a) onsite work groups were notified of weather conditions; b)outside work was prepared for high winds; and c) a walkdown of site areas for missile hazards was commenced. The subsequent PPL walkdown identified items in the vicinity of the main transformers and ESS transformers to include a gas cylinder, tools, ladders, tarps, and pipe flanges. The inspectors observed that not all of the items the inspectors had observed were noted by PPL nor were they all removed during the PPL walkdown.

An Independent Spent Fuel Storage Installation (ISFSI) campaign was also in progress that day and the inspectors noted that a loaded dry fuel cask had been moved from the spent fuel pool to the reactor vessel head washdown area at 11:15 am, despite the High Wind Advisory in effect at that time.

The inspectors reviewed ON-000-002, Natural Phenomena, Revision 28, to determine whether the site met entry conditions for that off-normal procedure. Procedural entry condition 1.1 is a receipt of warning of impending hurricane or tornado with probable impact on station confirmed from Transmission Control Center or Generation Power Dispatcher. The NWS issues a Tornado Warning when a tornado is indicated by radar or sighted by spotters. Step 3.3.3 states, If hurricane/tornado approaching, perform section 3.4. Section 3.4 states, If impending hurricane or tornado impact probable and wind velocity < 50 mph 10 meters above ground, perform following: Call in appropriate personnel to support imminent emergency efforts as required; initiate a walk down of outside areas for loose material/debris such as wood planks, plywood, sheet metal, scaffold planks or material in dumpsters that can be potential missiles; contact PPL Electric Utilities and request a walk down of the 500KV and 230KV switchyards for potential missiles; and notify maintenance to install locking pins on the Unit 1 and Unit 2 Reactor Building Cranes. PPL did not enter this ON procedure during the forecast period of inclement weather when the NWS warnings and advisories were in effect.

The inspectors concluded that, procedurally, PPL would not take anticipatory actions until there is a confirmed tornado and that tornado has probable impact on the station.

This approach was determined to be inadequate given that the touchdown of a tornado with probable impact on the station did not allot sufficient time to take preventive measures or mitigating actions and that a proactive approach to acts of nature was warranted. Additionally, proactive entry into this procedure would have enabled PPL to consider the increased risk of relocating a dry fuel cask from the spent fuel pool to the refueling floor under these conditions since ON-000-002 directs the installation and engagement of locking pins on the reactor building cranes. Finally, the inspectors determined that the procedure had received its periodic review in 2011 and that PPL had missed an opportunity to identify the inadequacy at that time. Specifically, PPL did not identify that the Off Normal procedure was inadequate either during the 2011 periodic procedural review or during documentation of inspector observations in May 2012 as part of 1579977. PPL entered this item in their CAP as CR 1628452.

Analysis.

An inadequate procedure for addressing acts of nature was a performance deficiency within PPLs ability to foresee and correct. The issue was evaluated in accordance with IMC 0612 and determined to be more than minor since it affected the procedure quality attribute of the Initiating Events cornerstone and its objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the inadequate procedure prevented PPL from taking proactive steps to limit the likelihood of high wind or tornado-related missile hazards upsetting plant electrical power systems. The finding screened to Green in accordance with IMC 0609, Attachment 4 and Appendix A, Exhibit 1, since it did not cause a reactor trip, involve the complete or partial loss of mitigation or support equipment, or impact the frequency of a fire or internal flooding event.

The finding was determined to have a cross-cutting aspect in the area of Problem Identification and Resolution - CAP because PPL did not identify issues completely, accurately, and in a timely manner commensurate with their safety significance.

Specifically, PPL did not identify that the Off Normal procedure was inadequate either during the 2011 periodic procedural review or during documentation of inspector observations in May 2012. [P.1(a)]

Enforcement.

TS 5.4.1.a, Procedures, requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in RG 1.33, Revision 2, Appendix A. RG 1.33, Appendix A lists safety-related activities that should be covered by written procedures. Section 6 identifies procedures for combating emergencies and other significant events among which is 6.w Acts of Nature (e.g. tornado, flood, dam failure, earthquakes). Contrary to the above, prior to September 2012, PPL did not maintain an adequate procedure to respond proactively to acts of nature, specifically high winds and tornadoes. Since this issue was entered into PPLs CAP as CR 1628452, it is being treated as an NCV in accordance with Section 2.3.2 of the NRCs Enforcement Policy. (NCV 05000387;388/2012004-01, Inadequate Procedure for Acts of Nature)

==1R04 Equipment Alignment

.1 Partial System Walkdowns

==

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems: Unit 1, 125 VDC batteries during B emergency service water (ESW) pump unavailability Common, E EDG aligned for B EDG during overhaul Common, A control structure (CS) chiller during B CS chiller maintenance 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), 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.

.2 Full System Walkdown

a. Inspection Scope

On July 18 and 19, 2012, the inspectors performed a complete system walkdown of accessible portions of the Unit 2 reactor core isolation cooling (RCIC) system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication, equipment cooling, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related CRs and WOs to ensure PPL appropriately evaluated and resolved any deficiencies.

b. Findings

No findings were identified. ==1R05 Fire Protection