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:	Krohn P G Reactor Projects Region 1 Branch 4
To:	Rausch T S Susquehanna
krohn, pg
References
1-2012-017 IR-12-004
Download: ML12319A022 (43)

Text

November 13, 2012

Mr. Timothy S. Rausch Senior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Boulevard, NUCSB3

Berwick, PA 18603

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 Commission's 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 findi ngs 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 r eport. 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 NRC's 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 cro ss-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 NRC's "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 NRC's 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

SUNSI Review Non-Sensitive Sensitive Publicly Available 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

1 Enclosure 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 2

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 NRC's 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, PPL's 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); PPL's 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.

4The 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 PPL's 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 PPL's 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 PPL's CAP. This violation and corrective action tracking numbers are listed in Section 4OA7 of this report.

5

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 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> for a control rod pattern adjustment. On July 17, the unit was reduced to 83 percent power over 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> for indications of a main generator oil exciter leak. On August 18, the unit was reduced to 65 percent power over 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> 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 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> for a condenser waterbox planned isolation activity. On August 3, the unit was reduced to 59 percent power over 66 hours7.638889e-4 days <br />0.0183 hours <br />1.09127e-4 weeks <br />2.5113e-5 months <br /> for condenser waterbox cleaning. On August 24, Unit 2 was reduced to 66 percent power over 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> 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

(71111.01 - 2 samples)

Readiness for Imminent Adverse Weather Conditions

a. Inspection Scope

The inspectors reviewed PPL's 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, PPL's 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.

6

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 7or 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 PPL's 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, 8prior 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 PPL's CAP as CR 1628452, it is being treated as an NCV in accordance with Section 2.3.2 of the NRC's 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 parameter s 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 system s to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operati ng parameters of equipment to verify 9that 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

.1 Resident Inspector Quarterly Walkdowns

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that PPL controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out-of-service (OOS),

degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

Unit 1, remote shutdown panel room (I-109), Fire Zone 1-2D Unit 2, residual heat removal (RHR) pump room 'A' (II-14), Fire Zone 2-1F Unit 2, high pressure coolant injection (HPCI) Fire Zone 2-1C Common, emergency safeguards service water (ESSW) pump house loops A and B, Fire Zones 0-51 and 0-52 Common, heating and ventilation equipment rooms (Fire Zones 0-29A through 0-29D),

b. Findings

No findings were identified.

1R06 Flood Protection Measures

.2 Annual Review of Cables Located in Underground Bunkers/Manholes

a. Inspection Scope

The inspectors conducted an inspection of underground bunkers/manholes subject to flooding that contain cables whose failure could disable risk-significant equipment. The inspectors performed walkdowns of risk-significant areas, including electrical vaults VA011 and VA006, and manhole MH032 containing power cables, to verify that the cables were not submerged in water, that cables and/or splices appeared intact, and to observe the condition of cable support structures. When applicable, the inspectors verified proper sump pump operation and verified level alarm circuits were set in accordance with station procedures and calculations to ensure that the cables will not be submerged. The inspectors also ensured that drainage was provided and functioning properly in areas where dewatering devices were not installed.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

Heat Sink Annual Review (71111.07A - 1 sample)

a. Inspection Scope

The inspectors reviewed documents associated with maintenance for the Unit 1, 'A' HPCI room cooler to determine its readiness and availability to perform its safety functions. This review was performed to ensure the performance capability for the HPCI room cooler was consistent with design assumptions. The inspectors verified that PPL initiated appropriate corrective actions for identified deficiencies. Additionally, the inspectors reviewed the WOs associated with the latest as-found maintenance inspection for the HPCI room cooler to evaluate whether maintenance procedures were adequate to ensure the minimum assumed design heat removal capability.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed licensed operator simulator training on August 14 and 21, 2012, which included a loss of startup bus 20, loss of the '1D' Engineering Safeguard System (ESS) bus, and an auxiliary bus undervoltage load shed. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, includi ng the use of abnormal and emergency operating procedures (EOPs). The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the TS action statements entered by the shift technical advisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify

and document crew performance problems.

b. Findings

No findings were identified.

.2 Quarterly Review of Licensed Operator Performance in the Main Control Room

a. Inspection Scope

The inspectors observed control room operators during a substitution of the 'B' EDG for the 'E' EDG that placed both units in Orange risk on September 15, 2012, a period of heightened activity and risk. The inspectors observed the crew during the evolution to 11verify that procedure use, crew communications, and coordination of activities in the control room met established expectations and standards.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structures, systems, and components (SSCs) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance WOs, and maintenance rule basis documents to ensure that PPL was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by PPL staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that PPL staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.

Common, breaker failure during 'E' EDG swap for 'B' EDG Common, ground fault causes loss of reactor Load Centers 1B270/280

b. Findings

Introduction.

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' FPC pump during equipment restoration. The FPC pump had been designated as protected equipment by station procedures as a risk management action.

Description.

On April 13, 2012, Load Center (LC) feeder breaker 1B27012 tripped twice on a ground fault while LCs 1B270 and 1B280 were cross-tied. The 480VAC LCs were cross-tied to support plant modifications during Unit 1's refueling outage. The first trip occurred approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the LCs were cross-tied and the second trip occurred approximately 20 minutes after attempts to re-energize the LCs.

The loss of both LCs impacted secondary containment in that both reactor building (RB)heating, ventilation, and air conditioning (HVAC) Zone I equipment compartment exhaust fans tripped due to the loss of power. This in turn caused the supply and exhaust fans for Zone I to trip and Zone I secondary containment differential pressure to drop below the required negative differential pressure of 0.25" water. This rendered Unit 2 secondary containment inoperable and necessitated entry into Unit 2 TS 3.6.4.1 since Zone I was not isolated from the recirculation plenum. Additionally, the power loss impacted Unit 1 Zone III supply fans and unfiltered exhaust fans which caused Zone III differential pressure to drop below its own 0.25" water requirement. Unit 1 was in Mode 5, not performing core alterations, nor any operations with a potential for draining the 12reactor vessel (OPDRV). Therefore, TS 3.6.4.1 was not applicable for Unit 1. Finally, the loss of the LCs also caused the '1C' FPC to trip.

Operators responded by aligning Unit 2 Zone III ventilation to carry the zone for both units, shutting down Unit 1 Zone III filtered exhaust fans, and isolating Zone I from the recirculation plenum since Unit 1 secondary containment was not required for the given plant conditions.

Engineering developed a troubleshooting plan in accordance with procedure NDAP-QA-0510, "Troubleshooting Plant Equipment," Revision 6. Electrical maintenance inspected the LC feeder breaker, the Zone III '1A' supply fan breaker, and the 1C277 A through D heaters. Electrical maintenance completed their troubleshooting activities on April 15, 2012. Faulty Unit 1 Zone III ventilation heaters were identified and electrically isolated by pulling their respective fuses.

On April 23, 2012, operators attempted to restore non-faulted Zone III ventilation heaters due to concerns that Zone III air temperatures were approaching the lower limits.

Restoration of the load center was conducted outside of the troubleshooting plan with the load centers cross-tied. During the restoration, breaker 1B27012 tripped again on ground fault and the loss of the LC caused Unit 1 and Unit 2 Zone III differential pressure to drop below the required 0.25" water requirement. Unit 2 secondary containment was again declared inoperable and TS 3.6.4.1 was entered, placing Unit 2 in a 4-hour shutdown LCO due to loss of LC-fed HVAC loads. The loss of the LCs also caused a repeat trip of the '1C' FPC pump except that the pump had now been designated as protected equipment as a risk management action since the spent fuel pool (SFP) time to 200 degrees Fahrenheit was less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Given the previous two trips on April 13 th and the troubleshooting conclusion that this was an intermittent fault, it was reasonable to expect that PPL staff take actions to place ventilation and spent fuel pool cooling in an alternate line up to protect that equipment in case the bus was lost again.

However, the operators did not consider this and it resulted in an additional loss of secondary containment ventilation, '1C' FPC pump, and another unplanned LCO entry.

The inspectors reviewed two apparent cause evaluations (ACEs) that were completed for the April 15 and April 23 trips. The second ACE determined that the troubleshooting plan was limited in scope due to the desire to limit interruption to refueling floor work and pose minimal risk to the operating unit's Zone III HVAC. The troubleshooting plan did not identify the individual LC supply breakers as a possible cause and only their downstream loads were suspected. NDAP-QA-0510, "Troubleshooting Plant Equipment," Revision 6, Section 2 states, in part, that "troubleshooting is a structured process to systematically identify equipment and system problems, their causes, and the necessary actions to resolve the problem." NDAP-QA-0510, Attachment A states, in part, that "recurring faults may be either complete, partial, or intermittent." While the troubleshooting plan classified the heater fault as intermittent in nature, the troubleshooting did not identify all of the faulted heaters and PPL did not account for this by ensuring that system configuration at the time of the equipment's restoration would not result in the subsequent loss of secondary containment or protected equipment.

Additionally, the inspectors identified that the second ACE did not identify and consider the impact of the FPC pump's protected status during the assessment of the event's actual consequences. PPL entered this issue into their CAP as condition report CR

1628250.

Analysis.

The failure to perform adequate troubleshooting activities per NDAP-QA-0510 to identify and correct equipment problems prior to restoration was a performance deficiency that was within PPL's ability to foresee and prevent. The inspectors 13determined 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 events resulted in the inoperability of secondary containment and the 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 radionuclides; 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)

Enforcement.

This finding does not involve enforcement action because no violation of regulatory requirements was identified. Because this finding does not involve a violation and is of very low safety significance, it is identified as a FIN. (FIN 05000387;388/2011004-02, Inadequate Troubleshooting Results in Loss of Secondary Containment and Protected Equipment)

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that PPL performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that PPL personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When PPL performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk.

The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the station's probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

Common, swap 'E' EDG for 'D' EDG and failure of breaker to close Common, yellow risk during Division I ESW pump testing Common, orange risk during swap of 'E' EDG for 'B' EDG Common, Division II ESW OOS with 'E' EDG unavailable for substitution

b. Findings

Introduction.

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 14station procedures. The inspectors identified multiple examples of PPL non-compliance with 10 CFR 50.65(a)(4) and PPL's implementing procedures NDAP-QA-0340, "Protected Equipment Program," Revision 17, and NDAP-QA-1902, "Integrated Risk Management," Revision 9.

Description.

First, on July 24, 2012, PPL performed TP-054-065, "Pump Curve for Division I ESW Pumps," Revision 12. PPL's equipment out-of-service (EOOS) risk assessment of the procedure yielded Yellow risk on both Units. However, because the duration was less than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, no equipment was required to be protected per NDAP-QA-0340, step 6.2.1 as a RMA. When inspectors requested to review the NDAP-QA-1902, Integrated Risk Assessment for this work activity, PPL could not provide it since it had not been performed. When PPL subsequently performed that assessment, the risk

was determined to be Medium Operational risk. Where assessed risk is Medium or High, NDAP-QA-1902, step 6.4.1 requires the staff to consider those RMAs listed in Appendix D, Section 1; determine the RMAs to be used; and document the RMAs selected on Attachment E. The inspectors additionally identified that NDAP-QA-0340, G, step 5, requires protection of the available ESW loop when the other ESW loop is unavailable. This requirement is active when the calculated heatup rate associated with the SFP reaching 200 degrees F is less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The inspectors inquired as to whether the other ESW loop had been protected during completion of TP-054-065 and PPL confirmed that it had not. PPL entered these issues in their CAP as CRs 1601929, 1602495, and 1611876. PPL's short term corrective actions included protecting an ESW loop during the same test on the opposite division of ESW during procedure TP-054-066, on August 25.

Second, on August 13, 2012, the Unit 2 Division I RHR loop was taken OOS for maintenance. That maintenance included work on the breaker associated with the loop's minimum flow valve. The inspectors noted that NDAP-QA-0340, Attachment G, step 4, requires that when the SFPs are cross-tied, their time to reach 200 degrees F is

less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and the 'A' loop of RHR on ei ther unit is unavailable, then the other unit's 'A' loop of RHR must be protected. Under that condition, the procedure also requires that the supporting residual heat removal service water (RHRSW) and ESW loops be protected. The inspectors inquired as to whether those systems had been protected in accordance with the procedure and PPL confirmed that they had not. PPL entered this issue into their CAP as CR 1611044.

Finally, on July 30, 2012, five vent monitoring system particulate, iodine, and noble gas (SPING) sample pumps were being taken OOS sequentially for maintenance. The vent monitoring systems are used to identify unplanned or uncontrolled releases to the environment. At the time of the schedule review, the standby gas treatment system (SGTS) SPING had already been taken OOS. On the schedule, only the Unit 1 RB SPING was annotated as an Emergency Preparedness (EP) risk item. The inspectors inquired as to why only one SPING met this criterion. A subsequent review by PPL determined that the other four SPING WOs had been improperly reviewed for risk in accordance with NDAP-QA-1902, Attachment C. PPL re-performed the risk screenings for all five SPINGS, determined them all to be Medium EP risk and implemented RMAs from NDAP-QA-1902, Attachment D that included consulting the EP manager to determine additional actions to manage risk, evaluating redundant components required to support the activity, providing field supervi sory monitoring of the activity, and verifying pre-planned alternate measures are available. PPL entered this issue into their CAP as

CR 1604007.

Analysis.

Not performing RMAs for maintenance activities in accordance with station procedures was a performance deficiency within PPL's ability to foresee and correct.

15The finding was more than minor since 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 issue was determined to involve PPL's 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) because it did not result in an increase to either the ICDP or to the 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)

Enforcement.

10 CFR 50.65(a)(4) states, in part, that "before performing maintenance activities, the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities." PPL procedures NDAP-QA-1902, "Maintenance Rule Risk Assessment and Management Program," Revision 2, and NDAP-QA-0340, "Protected Equipment Program," Revision 8, implement the requirements of 10 CFR 50.65(a)(4) at the station. Contrary to the above, during the months of July and August 2012, there were multiple instances of inadequate implementation of RMAs while maintenance was conducted. Because of the very low safety significance of this finding and because the finding was entered into PPL's CAP as CRs 1611044, 1604007, 1601929, 1602495, and 1611876, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000387;388/2012004-03, Failure to Implement Risk Management Actions)

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:

Unit 1, anomalies of 'A' steam pressure regulator and 1, 2, and 3 bypass valves Unit 2, reactor recirculation loop decontamination connections Unit 2, HPCI water hammer during comprehensive flow verification Common, passive fire barrier qualification Common, settlement monitoring of the ESSW pump house The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to PPL's evaluations to determine

whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by PPL. The 16inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

b. Findings

No findings were identified.

1R18 Plant Modifications

.1 Permanent Modifications

a. Inspection Scope

The inspectors evaluated a modification to the Zone III exhaust system on Units 1 and 2 implemented by engineering change 1495468, "Close and Block Dampers HD17534C and HD27534C." The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification.

In addition, the inspectors reviewed modification documents associated with the upgrade and design change. The inspectors also reviewed revisions to station documents and interviewed engineering personnel.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the post-maintenance tests (PMTs) for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.

Unit 1, B control rod drive (CRD) pump motor after modification to breaker controls Unit 2, RHR 'B' loop Division II after pressure safety valve (PSV) replacement and electrical maintenance Unit 2, RHR 'D' loop after socket weld leak on suction piping Common, motor-driven fire pump after discharge check valve maintenance Common, 'E' EDG intercooler PSV01126E replacement Common, 'B' EDG 5 year inspection and overhaul Common, 'B' CS chiller following piping and valve work Common, 'A' control room emergency outside air supply system (CREOAS) following hydramotor replacement (HDM07811A)

b. Findings

No findings were identified.

17

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TS, the UFSAR, and PPL procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:

Unit 1, SO-151-A02, quarterly core spray Division II flow verification Unit 1, SO-100-010, monthly Zone I integrity verification Unit 2, SO-249-B02, RHR Division II quarterly flow verification Common, SO-024-014, monthly EDG 'E' operability test Common, SO-070-001, monthly standby gas treatment

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstone:

Public Radiation Safety and Occupational Radiation Safety

2RS1 Radiological Hazard Assessment and Exposure Controls

This area was inspected to: (1) review and assess PPL's performance in assessing the radiological hazards in the workplace associated with licensed activities and the implementation of appropriate radiation monitoring (RM) and exposure control measures for both individual and collective exposures, (2) verify PPL is properly identifying and reporting Occupational Radiation Safety cornerstone performance indicators (PIs), and (3) identify those performance deficiencies that were reportable as a PI and which may have represented a substantial potential for overexposure of the worker.

During August 20 to 24, 2012, the inspectors interviewed the radiation protection manager (RPM), performed walkdowns of various portions of the plant, and reviewed PPL documents. The inspectors used the requirements in 10 CFR Part 20 and guidance in RG 8.38 Control of Access to High and Very High Radiation Areas (VHRAs) for Nuclear Plants, the TSs, and PPL's procedures required by TSs as criteria for determining compliance.

a. Inspection Scope

Instructions to Workers The inspectors selected five containers containing non-exempt licensed radioactive materials that may cause unplanned or inadvertent exposure of workers. The inspectors 18assessed whether the containers were labeled and controlled in accordance with 10 CFR Part 20 requirements.

Contamination and Radioactive Material Control The inspectors reviewed PPL's procedures and records to verify that the radiation detection instrumentation was used at its typical sensitivity level based on appropriate counting parameters.

Risk-Significant High Radiation Area (HRA) and Very High Radiation Area Controls The inspectors evaluated PPL controls for VHRAs and areas with the potential to become a VHRA to ensure that an individual was not able to gain unauthorized access to these areas.

Problem Identification and Resolution The inspectors reviewed CRs associated with RM and exposure control and verified SSES's problems were identified at an appropriate threshold and were properly addressed for resolution. The inspectors specifically evaluated the investigation and resolution for the contaminated transfer trailer issue and the associated CR 1606682.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

(71124.02)

This area was inspected August 20 to 24, 2012

, to ensure occupational dose is appropriately monitored and assessed. The inspectors used the requirements in 10 CFR Part 20, the guidance in RG 8.13 - Instructions Concerning Prenatal Radiation Exposures, RG 8.36 - Radiation Dose to Embryo Fetus, RG 8.40 - Methods for Measuring Effective Dose Equivalent from External Exposure, TSs, and PPL's procedures required by TSs as criteria for determining compliance.

a. Inspection Scope

Inspection Planning

The inspectors reviewed the results of SSES radiation protection program audits related to internal and external dosimetry. The inspectors reviewed the most recent National Voluntary Laboratory Accreditation Program (NVLAP) accreditation report on PPL and PPL's vendor's most recent results to determine the status of the accreditation. A review was conducted of PPL's procedures associated with dosimetry operations, including issuance/use of external dosimetry, assessment of internal dose, and evaluation of dose assessments for radiological incidents. The inspectors evaluated whether PPL had established procedural requirements for determining when external dosimetry and internal dose assessments are required.

External Dosimetry The inspectors evaluated whether PPL and PPL's dosimetry vendor is NVLAP accredited and if the approved irradiation test categories for each type of personnel 19dosimeter used are consistent with the types and energies of the radiation present and the way the dosimeter is being used.

The inspectors evaluated the onsite storage of dosimeters before issuance, during use, and before processing/reading. The inspectors also reviewed the guidance provided to radiation workers with respect to care and storage of dosimeters.

PPL does not use non-NVLAP accredited passive dosimeters.

The inspectors assessed the use of electronic personal dosimeters to determine if PPL uses a "correction factor" to address the response of the electronic personal dosimeter as compared to the dosimeter of legal record for situations when the electronic personal dosimeter is used to assign dose and whether the correction factor is based on sound technical principles.

The inspectors reviewed four dosimetry occurrence reports or CAP documents for adverse trends related to electronic personal dosimeters. The inspectors assessed whether PPL had identified any adverse trends and implemented appropriate corrective actions. Internal Dosimetry

Routine Bioassay (In Vivo)

The inspectors reviewed procedures used to assess the dose from internally deposited radionuclides using whole body counting equi pment. The inspectors evaluated whether the procedures addressed methods for differentiating between internal and external contamination, the release of contaminated individuals, determining the route of intake

and the assignment of dose.

The inspectors reviewed the whole body count (WBC) process to determine if the frequency of measurements was consistent with the biological half-life of the radionuclides available for intake.

The inspectors reviewed PPL's evaluation for use of its portal radiation monitors as a passive monitoring system. The inspectors assessed if instrument minimum detectable activities were adequate to determine the potential for internally deposited radionuclides sufficient to prompt an investigation.

The inspectors selected three WBCs and evaluated whether the counting system used had sufficient counting time/low background to ensure appropriate sensitivity for the potential radionuclides of interest. The inspectors reviewed the radionuclide library used for the count system to determine if it included the gamma-emitting radionuclides that exist at the site. The inspectors evaluated how PPL accounts for hard-to-detect radionuclides in their internal dose assessments, if applicable.

Special Bioassay (In Vitro)

The inspectors selected two internal dose assessments obtained using whole body counting. The inspectors reviewed and assessed the adequacy of PPL's program for urinalysis of radionuclides including collection and storage of samples.

The inspectors reviewed the vendor laboratory quality assurance program and assessed whether the laboratory participated in an industry recognized cross-check program 20including whether out-of-tolerance results were reviewed, evaluated, and resolved appropriately.

Internal Dose Assessment - Airborne Monitoring PPL had not performed any internal dose assessments using airborne/derived air concentration monitoring during the period reviewed.

Internal Dose Assessment - Whole Body Count Analyses The inspectors reviewed several dose assessments performed by PPL using the results of WBC analyses. The inspectors determined whether affected personnel were properly monitored with calibrated equipment and that internal exposures were assessed consistent with PPL's procedures.

Special Dosimetric Situations

Declared Pregnant Workers The inspectors assessed whether PPL informs radiation workers of the risks of radiation exposure to the embryo/fetus, the regulatory aspects of declaring a pregnancy, and the specific process to be used for (voluntarily) declaring a pregnancy.

The inspectors reviewed the records for two individuals who had declared pregnancy

during the current assessment period and evaluated whether PPL's radiological monitoring program (internal and external) for declared pregnant workers is technically adequate to assess the dose to the embryo/fetus. The inspectors reviewed exposure results and monitoring controls that were implemented.

Dosimeter Placement and Assessment of Effective Dose Equivalent for External Exposures The inspectors reviewed PPL's methodology for monitoring external dose in non-uniform radiation fields or where large dose gradients exist. The inspectors evaluated PPL's criteria for determining when alternate monitoring, such as use of multi-badging, is to be implemented.

The inspectors reviewed selected dose assessments performed using multi-badging to evaluate whether the assessment was performed consistent with PPL procedures and dosimetric standards.

Shallow Dose Equivalent The inspectors reviewed two dose assessments of shallow dose equivalent for adequacy. The inspectors evaluated PPL's method (e.g., VARSKIN or similar code) for calculating shallow dose equivalent from distributed skin contamination or discrete radioactive particles.

Assigning Dose of Record For the special dosimetric situations reviewed in this section, the inspectors assessed how PPL assigns dose of record for total effective dose equivalent (TEDE), shallow dose equivalent, and lens dose equivalent (LDE). This included an assessment of external 21and internal monitoring results, supplementary information on individual exposures, and radiation surveys when dose assignment was based on these techniques.

Problem Identification and Resolution

The inspectors assessed whether problems associated with occupational dose assessment are being identified by PPL at an appropriate threshold and are properly addressed for resolution in PPL's CAP. The inspectors assessed the appropriateness of the corrective actions for a selected sample of problems documented by PPL involving occupational dose assessment.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

.1 Safety System Functional Failure (2 samples)

a. Inspection Scope

The inspectors sampled PPL's submittals for the Safety System Functional Failures performance indicator for both Unit 1 and Unit 2 for the period of January 2011 through June 2012. To determine the accuracy of the performance indicator data reported during those periods, inspectors used definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, and NUREG-1022, "Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73." The inspectors reviewed PPL's operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, condition reports, event reports and NRC integrated inspection re ports to validate the accuracy of the submittals.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index (MSPI) (2 samples)

a. Inspection Scope

The inspectors reviewed PPL's submittal of the MSPI for the following systems for the period of October 2011 through May 2012:

Units 1 and 2, Heat Removal System To determine the accuracy of the PI data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment PI Guideline," Revision 6. The inspectors also reviewed PPL's operator narrative logs, CRs, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findings

No findings were identified.

.3 Reactor Coolant System (RCS) Specific Activity (2 samples)

a. Inspection Scope

The inspectors reviewed PPL's submittal fo r the RCS specific activity performance indicator for both Unit 1 and Unit 2 for the period of April 2011 through March 2012. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6.

b. Findings

No findings were identified.

.4 Occupational Exposure Control Effectiveness (1 sample)

a. Inspection Scope

The inspectors reviewed implementation of PPL's Occupational Exposure Control

Effectiveness PI Program. Specifically, the inspectors reviewed recent condition reports, and associated documents, for occurrences involving locked HRAs, VHRAs, and unplanned exposures against the criteria specified in NEI 99-02, Regulatory Assessment PI Guideline, to verify that all occurrences that met the NEI criteria were identified and reported as PIs. This inspection activity represents the completion of one (1) sample relative to this inspection area; completing the annual inspection requirement.

b Findings No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of PI&R Activities

a. Inspection Scope

As required by Inspection Procedure 71152, "PI&R," the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that PPL entered issues into the CAP at an appropriate threshold, gave adequate attention to

timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended CR screening meetings.

b. Findings

No findings were identified.

23.2 Annual Sample: Review of the Operator Workaround Program

a. Inspection Scope

The inspectors reviewed the cumulative effects of the existing operator workarounds, operator burdens, existing operator aids and disabled alarms, and open main control room deficiencies to identify any effect on emergency operating procedure operator actions, and any impact on possible initiating events and mitigating systems. The inspectors evaluated whether station personnel had identified, assessed, and reviewed operator workarounds as specified in PPL procedure OI-AD-096, "Operator Burdens,"

Revision 8.

The inspectors reviewed PPL's process to identify, prioritize, and resolve main control room distractions to minimize operator burdens. The inspectors reviewed the system used to track these operator workarounds and recent PPL self assessments of the program. The inspectors also toured the control room and discussed the current operator workarounds with the operators to ensure the items were being addressed on a schedule consistent with their relative safety significance.

b. Findings and Observations

No findings were identified.

The inspectors determined that the issues reviewed did not adversely affect the capability of the operators to implement abnormal or emergency operating procedures. The inspectors also verified that PPL entered operator workarounds and burdens into the CAP at an appropriate threshold and planned or implemented corrective actions commensurate with their safety significance.

4OA3 Followup of Events and Notices of Enforcement Discretion

.1 (Closed) Licensee Event Report (LER) 05000387/2011-004-00

'C' Emergency Diesel Generator Inoperable

a. Inspection Scope

On December 6, 2011, PPL declared the 'C' EDG inoperable due to loss of firing from cylinder 8R during surveillance testing. TS 3.8.1 was entered until the 'E' EDG was substituted for the 'C' EDG. A review of past maintenance on the 'C' EDG determined that it was inoperable from the time maintenance was performed on September 21, 2011 until it was shutdown on December 6, 2011, because it could not have fulfilled its mission time. The cause of the loss of firing was incorrect installation of the delivery valve spring that resulted in interruption of the spray pattern in the fuel injection nozzle and partial blockage. As a consequence of the inoperability, a condition prohibited by TS 3.8.1 occurred. PPL identified the root causes of this event to be that: 1) the work package to install delivery valve springs was insufficient, 2) the work crew proceeded using an inadequate work package, and 3) QC activities were insufficient to prevent the incorrect reassembly of the fuel injector pump components. The inspectors reviewed this LER, and the root cause analysis (RCA) and corrective actions associated with this event. This LER is closed.

b. Findings

An NRC-identified Green FIN (FIN 05000387;388/2011005-01; Failure to Properly Implement Work Instructions Results in 'C' EDG Inoperability) associated with this LER was documented in IR 05000387;388/2011-005. Section

4OA5 of this report provides

additional information on the status of that finding and subsequent enforcement.

4OA5 Other Activities

.1 NRC Office of Investigations Report 1-2012-017

In December 2011, NRC inspectors identified a failure to meet TS requirements for properly planning and implementing work instructions on the 'C' EDG and the potential existed that this may have been a deliberate act.

In response, the Region I Field Office, NRC Office of Investigations (OI), initiated an investigation on January 6, 2012, to determine whether maintenance technicians and a Quality Control (QC) inspector, employed by PPL at Susquehanna, deliberately failed to implement those work instructions during the assembly of delivery valves on 15 fuel pumps. Based on testimonial and documentary evidence gathered during the investigation the investigators concluded that while violations of 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 the violation was previously evaluated by the NRC and

documented in NRC Inspection Report 05000387;388/2011005 as a Green finding (FIN 05000387;388/2011005-01; Failure to Properly Implement Work Instructions Results in 'C' EDG Inoperability). The enforcement aspects of that finding were held open pending the completion of the NRC OI Investigation. While this finding involved a violation of NRC requirements, the NRC has determined that this issue is 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, although dispositioned separately, only count as one input into the plant assessment process.

The enforcement section of the original finding is amended as follows.

Enforcement.

Susquehanna Units 1 and 2 TS Section 5.4.1, requires, in part, that procedures be established, implemented, and maintained for those recommended in Regulatory Guide 1.33. RG 1.33, Appendix A, section 9, states, in part, "Maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances." Contrary to the above, on September 21, 2011, PPL did not properly plan and implement work instructions and QC hold point inspections on the 'C' EDG. This also resulted in violations of 10 CFR 50, Appendix B, Criterion X, "Inspection" and TS 3.8.1, "AC Sources - Operating," since the

'C' EDG exceeded the TS allowed outage time. Because of the very low safety significance of this finding and because the finding was entered into PPL's CAP (ARs:

1226969, 1226202, 1299543, 1299476, 1302720, and 1303308), it is being treated as an NCV in accordance with Section 2.3.2 of the NRC's Enforcement Policy. (NCV 05000387;388/2011005-01;05000278/2011005-02; Failure to Properly Implement Work Instructions Results in 'C' EDG Inoperability)25

.2 Temporary Instruction 2515/187 - Inspection of Near-Term Task Force Recommendation 2.3 - Flooding Walkdowns

On August 6, 2012, inspectors commenced activities to independently verify that PPL conducted external flood protection walkdown activities using an NRC-endorsed walkdown methodology. These flooding walkdowns are being performed at all sites in response to Enclosure 4 of a letter from the NRC to licensees entitled, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated March 12, 2012 (ADAMS Accession No.

ML12053A340). The results of this temporary instruction will be documented in a future inspection report.

.3 Temporary Instruction 2515/188 - Inspection of Near-Term Task Force Recommendation 2.3 - Seismic Walkdowns

On July 19, 2012, inspectors commenced activities to independently verify that PPL conducted seismic walkdown activities using an NRC-endorsed seismic walkdown methodology. These seismic walkdowns are being performed at all sites in response to Enclosure 3 of a letter from the NRC to licensees entitled, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated March 12, 2012 (ADAMS Accession No.

ML12053A340). When complete, the results of this temporary instruction will be documented in a future inspection report.

.4 Operation of an ISFSI at Operating Plants (IP 60855 and 60855.1)

a. Inspection Scope

The inspectors observed and evaluated the licensee's loading of the third canister associated with PPL's current ISFSI dry cask campaign. The inspectors verified compliance with the Certificate of Compliance (CoC), TS, regulations, and licensee procedures. The inspectors also reviewed PPL's activities related to long-term operation and monitoring of the ISFSI.

The inspectors observed the heavy load movement of the transfer cask and loaded dry shielded canister (DSC) from the spent fuel pool to the cask washdown area next to the spent fuel pool. The inspectors also observed DSC processing operations including: decontamination and surveying, welding, non-destructive weld examinations, DSC draining, and vacuum drying. During performance of the activities, the inspectors evaluated PPL's familiarity with procedures, supervisory oversight, and communication and coordination between the personnel involved. The inspectors also reviewed loading and monitoring procedures and evaluated PPL's adherence to these procedures.

The inspectors performed a walk-down of the heavy haul path and toured the ISFSI pad to assess the material condition of the pad and the loaded horizontal storage modules. The inspectors also reviewed the as low as is reasonably achievable (ALARA) goal for the loading of the cask to determine the adequacy of PPL's radiological controls and to ensure that radiation worker doses were ALARA and that project dose goals could be

achieved.

26 The inspectors attended PPL briefings to assess their ability to identify critical steps of the evolution, potential failure scenarios, and human performance tools to prevent

errors.

The inspectors reviewed PPL's program associated with fuel characterization and selection for storage. The inspectors reviewed cask fuel selection packages and the video recording of the canister to verify that PPL was loading fuel in accordance with the CoC and TS. PPL did not plan to load any damaged fuel assemblies during this

campaign.

The inspectors reviewed corrective action reports and the associated follow-up actions that were generated since the last ISFSI inspection to ensure that issues were entered into the corrective action program, prioritized, and evaluated commensurate with their safety significance. The inspectors also reviewed PPL's 10 CFR 72.48 screenings.

b Findings No findings were identified.

4OA6 Meetings, Including Exit

On August 24, 2012, the inspectors presented the inspection results to Mr. J. Helsel, Plant Manager and Acting Site Vice President, and other members of the staff.

On September 21, 2012, the inspectors presented the inspection results to Mr. J. Helsel, Plant Manager and Acting Site Vice President, and other members of the staff.

On October 16, 2012, the inspectors presented the inspection results to Mr. T. Rausch, Chief Nuclear Officer (CNO) and other members of the PPL staff. PPL acknowledged the findings. No proprietary information is contained in this report.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by PPL and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV.

On September 27, 2011, PPL declared the 10-meter wind direction instrument on the primary meteorological tower inoperable when indications showed, as confirmed by the vendor; the wind direction data was inconsistent with known weather responses.

EP-TP-007, "Equipment Important for Emergency Plan Implementation," states compensatory measures for an out of service Meteorological Tower include notifying the control room of potential Emergency Notification System (ENS) notifications, ensuring the availability of the backup and/or Nescopeck towers, using onsite observations by personnel and obtaining external meteorological information. The control room verified and notified the Nuclear Emergency Response Organization (NERO) Duty Planner that the compensatory measures identified in EP-TP-007 were available. However, the NERO was not notified of the meteorological tower 10-meter wind direction indication being inoperable. In addition, the wind direction indication on the plant computer system continued to display a yellow status color indicating valid data was available for use. Because the NERO was unaware the 10-meter wind direction indication on the primary meteorological tower was erroneous, the inaccurate meteorological information on the plant computer system could have been used by the NERO to make emergency classifications, perform dose projections, and 27make protective action recommendations (PAR). Although the data from the backup meteorological tower would have been available there were no stimuli that would have caused the NERO to use that data instead. PPL's RCA determined the cause of not notifying the NERO was due to the lack of specific procedural guidance defining the conditions for which the duty NERO personnel should be notified when equipment important to EP was out of service or inoperable.

This issue was determined to be a violation of 10 CFR 50.54(q)(2), which requires licensees follow and maintain the effectiveness of an emergency plan that meets the planning standards in 50.47(b). 10 CFR 50.47(b)(9) requires the use of adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition. Contrary to the above, from September 27 through September 30, 2011, PPL did not maintain an adequate method for accurately calculating dose projections and issuing PARS to offsite agencies. In accordance with IMC 0609, Appendix B, Attachment 2, and the examples contained in Table 5.9-1, the inspectors determined the finding was Green since the meteorological tower was not functional for longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the time of discovery without adequate compensatory measures. The finding was not greater than Green since the capability for immediate dose projection existed via alternate meteorological towers. The issue was entered in PPL's CAP as CR 1541932.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Boika, Nuclear Operations

M. Christopher, Nuclear Operations Support

S. DiPalma, Nuclear Field Services

L. Fuller, Design Engineer

C. Goff, Nuclear Training Director

J. Goodbred Jr., Nuclear Operations Manager

K. Griffith- Nuclear Training

M. Hanover, Senior Engineer

J. Helsel, Plant General Manager and Acting Site Vice President

J. Hirt, Supervisor, Reactor Engineering

T. Hess, Journeyman Electrician

F. Hickey, Chemistry Support Senior Health Physicist

D. Karchner, Refuel Floor Manager

A. Klopp, Senior Engineer

J. Knorr, Maintenance Foreman

J. Lada, System Engineer

J. Lear, Nuclear Field Services

D. Lock, Manager, Nuclear Maintenance

T. Magrone, Chemistry

C. Manchester, Electrical Maintenance Supervisor

D. Marinos, Nuclear Operations

G. Merenich, Radiation Protection Instrument Foreman

J. Mirilovich, Reactor Engineering

S. Muntzenberger, Supervising Engineer

B. O'Rourke, Senior Engineer, Licensing

E. Ortuba, Health Physicist

S. Peterkin, Radiation Protection Manager

R. Rodriguez-Gillroy, Radiation Operations Supervisor

D. Smethers, Nuclear Field Services

W. Snyder, Electrician Leader

R. Takacs, Chemistry

D. Wright, Dry Fuel Storage Project Manager

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None.

Attachment

Opened/Closed

05000387;388/2012004-01 NCV Inadequate Procedure for Acts of Nature (Section 1R01)

05000387;388/2012004-02 FIN Inadequate Troubleshooting Results in Loss

of Secondary Containment and Protected

Equipment (Section 1R12)

05000387;388/2012004-03 NCV Failure to Implement Risk Management Actions (Section 1R13)

Closed

05000387;388/2011005-01 NCV Failure to Properly Implement Work Instructions Results in 'C' EDG Inoperability

(Section 4OA5)

05000387/LER-2011-004-00 LER 'C' Emergency Diesel Generator Inoperable (Section 4OA3.1)

LIST OF DOCUMENTS REVIEWED

(Not Referenced in the Report)

Section 1R01: Adverse Weather Protection

Procedures

OI-AD-029, Emergency Load Control, Revision 15

NDAP-00-0030, Severe Weather Preparations (Winter Storm, Hurricane)

GO-1(2)00-010, Hot Weather Operation, Revision 6(3)

ON-000-002, Natural Phenomenon, Revision 28

EP-TP-001, Emergency Classification Levels Manual, Revision 6

NDAP-QA-1902, Integrated Risk Management, Revision 9

Condition Reports

1457059,

1598613

Miscellaneous

Final Safety Analysis Report (FSAR) 3.3, 3.5

Section 1R04: Equipment Alignment

Procedures

OP-024-004, Transfer and Test Mode Operations of DG E, Revision 31

LA-0521-002, DG B 0C521B, Revision 16

CL-030-0023, Common Control Structure Heating and Ventilation, Revision 5

CL-030-0011, Control Structure Chilled Water System A, Revision 7

CL-030-0021, Common Control Room Floor Cooling, Revision 3

CL-030-0012, Control Structure Chilled Water System A, Revision 13

Attachment

CL-030-0022, Common Computer Room Floor Cooling, Revision 4

CL-030-0015, Control Structure Chilled Water System, Revision 5

Condition Reports

(* NRC identified)

1610577*,

1610610,

1549568,

1617975,

Drawing: M-149, Unit 1, RCIC, Revision 47

Section 1R05: Fire Protection

Procedures

FP-013-200, ESW Pump House LOOP A Pump Room, Fire Zone 0-51, Revision 4

FP-013-201, ESSW Pump House LOOP B Pump Room Fire Zone 0-52, Revision 4

FP-013-086, H&V Equipment Rooms (C-700 through C-706) Fire Zones 0-29A through 0-29D, Elevation .783'-0", Revision 6

ON-013-001, Response to Fire, Revision 31

FP-213-241, RHR Pump Room 'A' (II-14), Fire Zone 2-1F, Elevation 645'-0", Revision 6

NDAP-QA-0443, Firewatch Procedure, Revision 10

FP-113-109, Remote Shutdown Panel Room (I-109), Fire Zone 1-2D, Elevation 670'-0", Revision 5

FP-213-238, HPCI Pump Room (II-11), Fire Zone 2-1C, Elevation 645'-0", Revision 5

SO-213-023, 18 Month Functional Test and Visual Inspect-DS-215and 216

Condition Reports

(*NRC identified)

1606649,

1606652,

1606656,

1595016

Work Orders

1376682,

1436253

Miscellaneous

ESW Pump House LOOP A and B Pump Rooms, Fire Zones 0-51 and 0-52, Revision 685'6"

FPRR, Section 4.5, Deluge Systems, Revision 11

TRS 3.7.3.2 and TRSB 3.7.3.2

Compensatory Actions Firewatch Log, August 17, 2012, August 18, 2012, and August 19, 2012

Section 1R06: Flood Protection Measures

Condition Reports

(* NRC identified)

1601756,

1601764,

1601780,

1618248*

Drawings: E-413, Sheet 1, Manholes and Duct Banks, Revision 36

E-52, Sheet 54, Manhole Schedule Notes and Details, Revision 9

E-52, Sheet 55, Manhole Schedule Notes and Details, Revision 10

Section 1R07:

Heat Sink Performance

Procedure:

NDAP-QA-0504, Heat Exchanger (HX) Program, Revision 4

Attachment

Condition Reports

1443053,

1603636*,

1604543

Work Orders

1324446,

1538214,

1538996,

1364291,

1596094,

1538992,

1521415

Drawings: M-1557, HX Gasket Materials, Revision 1

M-111, Sheet 2, ESW 'A' Loop, Revision 52

Miscellaneous

H-1004, TS for HX/Condenser Inspection and Condition Assessment

Generic Letter (GL) 89-13

MT-GM-025, HX Cleaning and Inspection, Revision 4 EPRI

NP-7552, HX Performance Monitoring Guidelines, December, 1992

Section 1R11: Licensed Operator Requalification Program

Procedures

ON-100-101, Scram, Scram imminent, Revision 27

OP-142-001, Circulating Water (CW) System and Cooling Tower Operation, Revision 53

ON-004-002, Energizing Dead 4kV ESS Bus, Revision 22

ON-104-204, Loss of 4kV ESS Bus 1D (1A204), Revision 12

ON-003-002, Loss of Startup Bus 20, Revision 26

AR-106-001, Main Turbine Generator, Computer HVAC, Instrument AC 2 4VDC, 125VDC, 250 VBC, Panel 1C651, Revision 52

OP-AD-001, Operations Standards for System and Equipment Operation, Revision 48

OP-AD-004, Operations Standards for Error and Event Prevention, Revision 24

OP-024-004, Transfer and Test Mode Operations of DG E, Revision 31

OP-AD-002, Standards for Shift Operations, Revision 39

NDAP-QA-0300, Conduct of Operations, Revision 32

NDAP-QA-0302, System Status and Equipment Control, Revision 25

Condition Reports

(* NRC identified)

1594232,

1597808,

1349898,

1413175,

1494142,

1610926*,

1611014*,

1620382

Miscellaneous

OP002-12-05-02, Loss of Sub 20, Loss of 1D ESS Bus, Re-Energize 1D ESS Bus, Auxiliary Bus UV Load Shed, Revision 0

CFR 55.59, 10 CFR 55.53

Section 1R12: Maintenance Effectiveness

Procedures

NDAP-00-0752, Cause Analysis, Revision 16

NDAP-QA-0510, Troubleshooting Plant Equipment, Revision 6

NDAP-QA-0413, Maintenance Rule Program, Revision 10

Condition Reports

1600373,

1619873*,

1619286*,

1619356*,

1557253,

1563533,

1562913,

1562381,

1557360,

1561813

Attachment Calculation

EC-SOPC-0516, Relay Setting for Coordination of 1E LCs and Motor Control Centers, Revision 0

Work Orders

160420,

1601472,

1601477,

890695,

880117,

890762

Drawing: E-8, Common Single Line Meter and Relay Diagram 480V LCs 1B270, 1B280, 1B810, 1B820, Revision 30

Miscellaneous

Maintenance Rule Basis Document - System 24

IOM 779, Class 1E 4.16kV Switchgear DGs 0A501 A (B-D) for DG 'E' EPRI

TR 1000013, Guidance on Overhaul of ABB K-Line Circuit Breakers EPRI

TR 109001-1, ABB Breaker Lubrication Testing Report, Revision 0

EPRI

TR 1003087, Evaluation and Testing of ABB Breakers with Mobil Grease 28

EPRI Technical Evaluation 100 0014, Circuit Breaker maintenance Programmatic Considerations Unit 1 Operations Logs for July 19 and 26, 2012

Anderol Product Data Sheet

EC-RISK-1054, Performance Criteria for Maintenance Rule, Revision 5

IN 95-22, Hardened or Contaminated Lubricants Cause Metal- Clad Circuit Breaker Failures

IR 05000354/2007006

IR 05000285/2009007 ML11238A234, ML11238A242, and ML11238A241

EPRI

NP-7410-V1P1

Routine Preventive Maintenance Guidance for ABB K-Line Circuit Breakers

ABB MV 1E Circuit Breaker Refurbishment, dated July 30, 2007

Maintenance Rule Basis Document - System 05, 480V LCs Unit 2 Operations Log For April 13 and 23, 2012

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures

OP-024-004, Transfer and Test Mode Operations of DG E EOOS Risk Profile for August 17, 2012, Units 1 and 2 Protected Equipment Tracking form Dated August 15, 2012 for System 024, Revision 30

OP-024-001, DGs, Revision 63

NDAP-QA-1902, Integrated Risk Management, Revision 9

PSP-26, Online and Shutdown Nuclear Risk Assessment Program, Revision 11

Condition Reports

1616224,

1616220,

1616211,

1616738*

Action Request

1600373

Miscellaneous

EOOS for Units 1 and 2 for Thursday, July 19, 2012

Attachment

Section 1R15: Operability Evaluations

Procedures

TM-OP-193L-ST, Electrohydraulic Control (EHC) Pressure Control and Logic, Revision 7

ON-200-005, Excess Drywell Leakage Identification, Revision 15

GO-200-012, Power Maneuvers, Revision 40

GO-200-009, Single Recirculation Loop Operation, Revision 25

NDAP-QA-0703, Operability Assessments and Requests for Enforcement Discretion, Revision 20

TP-000-015 Settlement Monitoring of the ESSW Pump House, Completed September 11, 2012, Revision 1

ON-000-002, Natural Phenomena, Revision 28

SO-252-006, HPCI Comprehensive Flow Verification, Revision 11

Condition Reports

(* NRC-identified)

1594228,

1594473,

1594323,

1594346,

1593886,

1597021*,

1590555,

1590704,

1588212,

1591543,

1612302,

1612304,

1611225,

1612311,

1612330,

1526133,

1612342,

1613346*,

1616228,

1616050,

1620168,

1616723

Action Requests

1602927,

1618916

Calculations

EC-058-1001, Turbine Valve Closure SCRAM Bypass Setpoint, Revision 4

EC-058-1016, Turbine First Stage Pressure versus Reactor Power For Siemens Turbine, Revision 8

EC-STRU-2031, Structural Monitoring Inspection Calculation, Revision 1

EC-PUPC-2070, Extended Power Uprate (EPU) Flow Inducted Vibration Testing and Walkdown Criteria, Revision 1

Work Orders

1594244,

1602927

Drawing: M-2155, Sheet 1, Unit 2 P&ID HPCI, Revision 43

Miscellaneous

Operations Logs Unit 1, July 2, 2012 - July 3, 2012

TS and TSB for 3.7.6, 3.7.8, 3.3.4.1, and 3.3.1.1

Hot Box 12-31

Audit Number

1343693, Fire Protection Quality Assurance Internal Audit Report Specification C 1026, TS for Settlement Monitoring of ESSW Pump House, Revision C FSAR Section 2.5.4.10.2 and 2.5.4.13.2

EPRI

TR-106438, May 1996, Water Hammer Handbook for Nuclear Plant Engineers and Operators

TRS 3.7.8.5

Section 1R18: Permanent Plant Modifications

Condition Reports

(* NRC identified)

1495489,

1334937,

1356828,

1239036,

1239037,

1234032,

1234060

Attachment

Work Orders

1503115,

1503108,

1501186,

1501190

Drawings: M-175, Unit 1 P&ID RB, Air Flow Diagram Zone III, Revision 32

M-2175, Unit 1 P&ID RB, Air Flow Diagram Zone III, Revision 19

Miscellaneous

EC 1495468, Close and Block Dampers HD17534C and HD27534C, Revision 0

50.59 SD 01164

Section 1R19: Post-Maintenance Testing

Procedures

MT-GM-003, Valve Disassembly, Reassembly, and Rework, Revision 22

SO-013-001, Monthly Diesel and Motor Driven Fire Pump Run, Revision 6

TP-013-035, Annual motor Driven Fire Pump OP512 Performance Test, Revision 6

SO-024-014, Monthly EDG E Operability Test, Revision 33

MT-GM-005, Safety Relief Valve (SRV) Setting, Revision 24

NDAP-QA-0480, ASME XI System and Component Pressure Testing, Revision 7

NDAP-QA-0482, Post-Maintenance Testing, Revision 6

PSP-29, Post-Maintenance Test Matrix, Revision 12

NDE-LP-001, Color Contrast Liquid Penetrant Examination, Revision 4

SO-249-B02, Quarterly RHR System Flow Verification, Division II, Revision 17

OP-155-001, CRD Hydraulic System, Revision 50

TP-155-019, CRD Pump B Test of EC1305834 4kV Breaker, Revision 0

SM-024-002, 24 Month ED Engine Inspection, Revision 15

SO-024-013, Offsite Power Source and Onsite Class 1E Operability Test, Revision 17

SO-024-001B, Monthly DG 'B' Operability Test, Revision 10

SO-030-B03, Quarterly Control Structure Chilled Water Flow Verification Loop B, Revision 21

SE-030-202, CSCW System Emergency Condenser Pu mp Check Valve Exercising, Revision 1

SE-130-102, 24 Month Division II Control Structure Chiller DC Control Automatic Transfer Logic, Revision 4

MT-GE-051, Initial Inspection Testing and Installation of

NLI 480 VAC MCC Cubicles, Revision 13

Condition Reports

(*NRC-identified)

1421627,

1421795,

1480537,

1596673,

1595302,

1595297,

1477405,

1529893,

1527414,

1600956*,

1607435*,

1607434*,

1607913,

1607636,

1606802,

1607636*,

1609371*,

1609213*,

1606271,

1604956,

1610519,

1610875,

1610747,

1610427,

1612545,

1612544,

1612769,

1614134,

1615498,

1617575,

1619755,

1620648,

471256,

1615959,

1623141,

1548540,

1537511,

1625096,

1621437

Work Orders

1585115,

1339086,

892555,

1606843,

1481648,

1475404,

1509420,

1601815,

1596948,

1067855,

1239107,

1115159,

1301270,

1499158,

1499957,

1263262,

1447131,

1304896,

1616019,

1091530,

1613920

Attachment Drawings: M-122, Sheet 1, Fire Pump House North and South, Revision 52

FF110230, Sheet 301, Outline Drawing and Bill of Material 2" to 14" Cast Iron Swing Check Valve

ISIM-100-1, Sheet 1, Legends and Symbols Inservice Inspection (ISI) Classification Boundary Drawing, Revision 7 M-2151, Sheet 3, RHR, Revision 24

D107318, Susquehanna Unit 1, Schematic Diagram CRD Pump 1P132B, Revision 24

Miscellaneous

TS 3.5.3, TRO 3.6.4

'B' CS Chiller Maintenance

Section 1R22: Surveillance Testing

Procedures

SO-000-010, Monthly Zone III Integrity, Revision 31

SO-151-A02, Quarterly Core Spray Flow Verification Division II, Revision 14

SO-024-014, Monthly DG 'E' Operability Test

OP-024-001, Diesel Generator, Revision 63

SO-070-001, Monthly Standby Gas Treatment, Revision 17

SO-249-B02, Quarterly RHR System Flow Verification, Division II, Revision 17

Calculations

EC-037-1006, Determination of Minimum Pressure Requirement to Assure Emergency Core Cooling System (ECCS) and RCIC Pump Discharge Lines Filled with Water, Revision 2

EC-051-0004, Core Spray TS Test Pressure, Revision 7

Drawings: M-152, Unit 1 P&ID Core Spray, Revision 39 M-134, Sheet 5, E Diesel Auxiliaries (Starting Air and Jacket Water System), Revision 17 M-134, Sheet 7, E Diesel Auxiliaries, (Fuel Oil System, Lube Oil System, and Air Intake and Exhaust System), Revision 18 M-175, Unit 1 P&ID RB Air Flow Diagram - Zone III, Revision 8

Miscellaneous

Operability Assessment Form, Corrective Action Document

548841, System 070, Year 2004, Revision 0

EC-037-1006, Determination of Minimum Pressure Requirement to Assume ECCS and RCIC Pump Discharge Lines are Filled with Water, Revision 2

EC-051-0004, Core Spray TS Test Pressure, Revision 7

Section 2RS1: Radiological Hazard Assessment and Exposure Controls

Procedure:

HP-TP-310, Barricading, Posting, and Labeling, Revision 40

Condition Reports

1428275,

1459847,

1493300,

1500283,

1601902

Attachment Miscellaneous

QA Internal Audit

1340786, March 2011 Radiation Protection/Solid Radwaste

Section 2RS4: Occupational Dose Assessment

Procedures

HP-TP-201, Operation of the Whole Body Counting System using

APEX-INVIVO Software, Revision 2

HP-TP-205, Dosimeter Handling and Control, Revision 16

HP-TP-208, Performance Verification and Calibration of the Whole Body Counting System, Revision 13

HP-TP-209, Dose Tracking and the Dose Extension Process, Revision 13

HP-TP-215, Issuance and Replacement of the Permanent Whole Body Thermoluminescence Dosimeter (TLD), Revision 28

HP-TP-220, Indirect Bioassay, Revision 10

HP-TP-221, External Dose Investigations & Evaluations, Revision 23

HP-TP-222, Special Dosimetry Issuance and Criteria, Revision 19

HP-TP-223, Internal Dose Investigations and Evaluations, Revision 13

NDAP-QA-0625, Personnel Radiation Exposure Monitoring Program, Revision 11

Condition Reports

1430729,

1454093,

1473474,

1510774,

1558759,

1606258,

1609774

Exposure Evaluations

PCE #

CR#

Date

1391012

158010

4/20/2011

1574834

5/16/2012

1387290

4/18/2011

1574854

4/16/2012

1384690

4/10/2011

Internal Dose Evaluations

RH-7150-1, April 23, 2011

SH-1733, May 4, 2012

Miscellaneous

2011 Teledyne Brown Engineering Environmental Services Quality Assurance Report 2011 PPL NVLAP Proficiency Testing Report Landauer NVLAP Accreditation Report for 2012

HP009, Prenatal Radiation Exposure Briefing, Revision 3

Health Physics (HP) Technical Basis #00-022 "Use of the Eberline

PM-7 Monitors as Passive Internal Exposure Monitors"

Section 4OA1: Performance Indicator Verification

Procedures

SC-176-102, Unit 1 Primary Coolant Specific Activity Equivalent I-131, Revision 12

SO-000-010, Monthly Zone III Integrity, Revision 30

Condition Reports

(* NRC identified)

1527190,

1357370,

1574550,

1566734

Attachment Work Order

1574595

Miscellaneous

PI Summary Report, Susquehanna Unit 1 and 2, RCS Activity, April, 2011 - March, 2012

Performance Analysis Form Units 1 & 2, April, 2011 - March, 2012

Operability Assessment Form, Corrective Action Document No.

548841, System 070, Year

2004, Revision 0 MSPI Derivation Reports for Susquehanna Unit 1 and Unit 2 for Heat Removal System Unavailability and Unreliability Index MS05, Maintenance Rule Database, August 16, 2012

Consolidated Data Entry 4.0 MSPI Derivation Report, July 17, 2012

NDAP-QA-0737, ROP PIs, Revision 9

PL-NF-06-002, SSES Mitigating System Performance Index Basis Document, Revision 7 SSES Mitigating System Performance Basis Document, Revision 6

NEI-99-02, Regulatory Assessment PI Guideline, Revision 6

Section 4OA2: Identification and Resolution of Problems

Procedures

OI-AD-096, Operator Burdens, Revision 8

OI-AD-034, Annunciator Deficiency Tracking, Revision 11

Condition Reports

(* NRC identified)

1595576*,

1596902*,

1596912*,

1602765*,

1602931*,

1600927*,

1602505*,

1601935*,

1601934*,

1606239*,

1602933,

1606933*,

1607320*,

1607617*,

1609459*,

1070595,

1033487,

148491,

1333186,

1516027,

1600773,

1370249,

1451345,

1583544,

1264068,

28315,

1365728,

1401848,

1572905,

1605167,

1589035,

1350759,

1263813,

1461789,

1489410,

1580548,

1571254,

1297085,

1575433,

1160117,

1519268,

1345589,

1436313,

1609417,

1609405,

1609402,

1609395,

1609387,

1609377,

1609375,

1612969*,

1613395*,

1617148,

1614352*,

1617148,

1618337,

1618341

Work Orders

1487388,

1334219,

1517210,

1386973,

829233,

1252589,

1574231,

1515988,

1527235,

1614352*

Miscellaneous

SL5 - Unit 1/GWE (General Work Environment) 27 - U1 for July, 2012

SL5 - Unit 2/GWE 27 - U2 for July, 2012

SL6 - for July, 2012

SL7 - for July, 2012

Section 4OA3: Event Followup

Procedures

NS-SSP-003, Tests, Checks, and Inspections of Security Systems and Equipment, Revision 22

HP-TP-320, Radiological Work Permits, Revision 24

MI-PS-001, Work Package Standard, Revision 35

Attachment

Condition Reports

156105,

1532037,

1532038,

1532042,

1532049,

1532050,

1532052,

1532057,

1532059,

1538240, 1616131

Section 4OA5: Other Activities

Procedures

ME-ORF-023, "Dry Fuel Storage-61BT DSC," Revision 20

ME-ORF-152, "Dry Fuel Storage - Response to Crane/Rigging/Transfer Equipment Malfunction and CoC TS Requirements," Revision 3

ME-ORF-179, "Dry Fuel Storage Equipment List and Reference Information," Revision 10

MT-EO-045, "Guidance and Use of Nutech Horizontal Modular Storage Automated Welding System for Welding Operation," Revision 2

MT-EO-058, "E1000 Series Vacuum Drying System Operation," Revision 20

MT-199-001, "Reactor Building Crane Operating Procedure", Revision 22

NDAP-QA-0507, "Conduct of Refuel Floor," Revision 21

RE-081-043, "Selection and Monitoring of Fuel for Dry Storage," Revision 7

Condition Reports

1611028*,

1611254*,

1613395*,

1611312*,

1616212*,

1618248*,

1619745,

1624965*,

1625702*,

1623008*,

1623018*,

1623022*,

1625645,

1297621,

1327056,

1602791,

1317006,

1498388,

1612923

Work Orders

M8663-01 OS559, "Assist Vendor with E1000 Vacuum Drying System (DFS) Mechanical Preparations" M8663-01,

1480449, "Preventative Maintenance on the Vacuum Drying Skid"

Miscellaneous

2012 Dry Fuel Storage Program Implementation Readiness Check 72.48 Screen, 72.48

SD 00046, "ISFSI Temperature Monitoring And Lightning Protection System Row D & E" 72.48 Screen, 72.48

SD 00059, "Dry Fuel Storage Horizontal Modules Installation at ISFSI"

"Annual Preventative Maintenance Plan for Unit 1 Reactor Building Crane," Rev. 2, 2011

Form

RE-081-042-4, "Components/Storage Locations with Special Requirements," Revision 5

NFE-1-17-014, "Appendix E, Bundle DH Storage for Dry Fuel Storage," Revision 1 QA Audit

1225786, "Fuel Management Audit Report," March 10, 2011 Receipt Inspection Report No.

179523, "Dry Shielded Canister S/N SSE61B-044-A"

RWP 2012-0200, "Dry Fuel Storage Activities on The Refuel Floor," Revision 000

RWP 2012-0201, "Dry Fuel Storage Activities in 101 Truck Bay and ISFSI," Revision 002

RWP 2012-0202, "Setup and Demobilization of Dry Fuel Storage Equipment," Revision 000 "SSES, Spent Fuel Storage Project, 10CFR72.212 Evaluation," Revision 4

Training Material Number HP272, "Dry Fuel Storage Refresher for HP," Revision 1

Training Material Number MM132, "Dry Fuel Storage - Maintenance Workers" Weld Record, Weld Document No.

090410, "Work Order WPQT350"

Attachment

LIST OF ACRONYMS

AC Alternating Current

ACE Apparent Cause Evaluation

ADAMS Agencywide Document and Access Management System

ALARA As Low As Is Reasonably Achievable

ANS Alert and Notification System

AR Action Report

ASME American Society of Mechanical Engineers

CAP Corrective Action Program

CFR Code of Federal Regulations

CNO Chief Nuclear Officer

CoC Certificate of Compliance

CR Condition Report

CRD Control Rod Drive

CREOAS Control Room Emergency Outside Air Supply

CS Control Structure

CW Circulating Water

DG Diesel Generator

DP Differential Pressure

DSC Dry Shielded Canister

EAL Emergency Action Level

ECCS Emergency Core Cooling System

EDG Emergency Diesel Generator

EHC Electrohydraulic Control

ENS Emergency Notification System

EOOS Equipment Out-of-Service

EOP Emergency Operating Procedure

EP Emergency Preparedness

EPU Extended Power Uprate

ERO Emergency Response Organization

ESS Engineering Safeguard System

ESSW Emergency Safeguards Service Water

ESW Emergency Service Water

FEMA Federal Emergency Management Agency

FIN Finding

FOIA Freedom of Information Act

FPC Fuel Pool Cooling

FSAR [[[SSES] Final Safety Analysis Report]]

GE General Electric

GL Generic Letter

GWE General Work Environment

HP Health Physics

HPCI High Pressure Coolant Injection

HRA High Radiation Area

HVAC Heating, Ventilation and Air-Conditioning

HX Heat Exchanger

IMC Inspection Manual Chapter

ICDP Incremental Core Damage Probability

ILERP Incremental Large Early Release Probability

IP Inspection Procedure

Attachment

IR [[]]

NRC Inspection Report

ISFSI Independent Spent Fuel Storage Installation

ISI Inservice Inspection kV Kilovolts

LC Load Center

LCO Limiting Condition for Operation

LDE Lens Dose Equivalent

LER Licensee Event Report

LOOP Loss of Offsite Power mph Mile Per Hour

MT Magnetic Particle Testing

NCV Non-Cited Violation

NDAP Nuclear Department Administrative Procedure

NEI Nuclear Energy Institute

NERO Nuclear Emergency Response Organization

NRC Nuclear Regulatory Commission

NVLAP National Voluntary Laboratory Accreditation Program

NWS National Weather Service

OA Other Activities

ODCM Offsite Dose Calculation Manual

OI [[]]

NRC Office of Investigations

OOS Out-of-Service

PAR Protective Action Recommendation

PARS Publicly Available Records

PCE Potential Chilling Effect

PI [[[NRC] Performance Indicator]]

PI&R Problem Identification and Resolution

PMT Post-Maintenance Test

PPL [[]]

PPL Susquehanna,

LLC [[]]

PS Planning Standard

PSV Pressure Safety Valve

QA Quality Assurance

QC Quality Control

RB Reactor Building

RCA Root Cause Analysis

RCIC Reactor Core Isolation Cooling

RCS Reactor Coolant System

REMP Radiological Environmental Monitoring Program

RG [[[]]

NRC [[] Regulatory Guide]]

RHR Residual Heat Removal

RHRSW Residual heat Removal Service Water

RMA Risk Management Actions

RM Radiation Monitoring

ROP Reactor Oversight Process

RPM Radiation Protection Manager

RTP Rated Thermal Power

SBO Station Blackout

SDP Significance Determination Process

SE Safety Evaluation

SFP Spent Fuel Pool

SFPC Spent Fuel Pool Cooling

Attachment

SGTS Standby Gas Treatment System

SPING System Particulate Iodine and Noble Gas

SRV Safety Relief Valve

SSC Structures, Systems and Components

SSES Susquehanna Steam Electric Station

TEDE Total Effective Dose Equivalent

TLD Thermoluminescence Dosimeter

TS Technical Specifications

UFSAR Updated Final Safety Analysis Report

VHRA Very High Radiation Areas

WBC Whole Body Count

WO Work Order