IR 05000387/2013003
| ML13226A023 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 08/14/2013 |
| From: | Darrell Roberts Division Reactor Projects I |
| To: | Rausch T Susquehanna |
| GRAY, MEL | |
| References | |
| EA-13-122 IR-13-003 | |
| Download: ML13226A023 (61) | |
Text
{{#Wiki_filter:UNITED STATES August 14, 2013
SUBJECT:
SUSQUEHANNA STEAM ELECTRIC STATION - NRC INTEGRATED INSPECTION REPORT 05000387/2013003 AND 05000388/2013003 AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Mr. Rausch:
On June 30, 2013 the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Susquehanna Steam Electric Station (SSES) Units 1 and 2. The enclosed inspection report (IR) presents the inspection results, which were discussed on July 12, 2013, with you and other members of your staff.
This inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents three NRC-identified findings of very low safety significance (Green). All of these findings were determined to involve violations of NRC requirements. However, because of the very low safety significance and because they are entered into your correction action program (CAP), the NRC is treating these findings as non-cited violations (NCVs) consistent with Section 2.3.2 of the NRCs Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, D.C. 20555-0001; with copies to the Regional Administrator Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Senior Resident Inspector at the Susquehanna Steam Electric Station. In addition, if you disagree with the cross-cutting aspect of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Senior Resident Inspector at the SSES.
Separately, a violation involving a failure to set secondary containment during operations with the potential to drain the reactor vessel (OPDRVs) was identified during the Unit 2 refueling outage.
Specifically, from April 17, 2013 to May 7, 2013 and May 10, 2013 to May 17, 2013, while all other Technical Specifications were met, PPL conducted several OPDRVs without establishing secondary containment operability, which is a violation of Technical Specification (TS) 3.6.4.1, Secondary Containment. NRC issued EGM 11- 003, Enforcement Guidance Memorandum on Dispositioning Boiling Water Reactor (BWR) Licensee Noncompliance with TS Containment Requirements During Operations with a Potential for Draining the Reactor Vessel, on October 4, 2011, allowing for the exercise of enforcement discretion for such OPDRV-related TS violations, when certain criteria are met. The EGM, which was revised on December 20, 2012, also requires that, to be eligible for discretion, a licensee must submit a license amendment request (LAR) to accept the NRCs generic change to the Standard Technical Specifications (STS) that will allow a graded approach to OPDRV requirements. The LAR must be submitted within four months of NRC publication of the STS in the Federal Register.
The NRC concluded that, for the specified periods, PPL met the EGM criteria and has committed to submit the LAR, as required. Therefore, I have been authorized, after consultation with the Director, Office of Enforcement, and the Regional Administrator, to exercise enforcement discretion and refrain from issuing enforcement for the violation, subject to a timely LAR being submitted.
In accordance with the Code of Federal Regulations (10 CFR) 2.390 of the NRCs "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely, /RA/ Darrell J. Roberts, Director Division of Reactor Projects Docket Nos. 50-387; 50-388 License Nos. NPF-14, NPF-22
Enclosures:
Inspection Report 05000387/2013003 and 05000388/2013003 w/Attachment: Supplemental Information
REGION I== Docket No: 50-387, 50-388 License No: NPF-14, NPF-22 Report No: 05000387/2013003 and 05000388/2013003 Licensee: PPL Susquehanna, LLC (PPL) Facility: Susquehanna Steam Electric Station, Units 1 and 2 Location: Berwick, Pennsylvania Dates: April 1, 2013 through June 30, 2013 Inspectors: P. Finney, Senior Resident Inspector J. Greives, Resident Inspector F. Arner, Senior Reactor Inspector S. Barber, Senior Project Engineer R. Rolph, Health Physicist D. Orr, Senior Reactor Engineer D. Dodson, Resident Inspector T. OHara, Reactor Inspector A. Bolger, Reactor Engineer J. Laughlin, Emergency Preparedness Specialist Approved By: Mel Gray, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
Inspection Report (IR) 05000387/2013003 05000388/2013003, 04/01/2013 - 06/30/2013;
Susquehanna Steam Electric Station, Units 1 and 2; Operability Determinations and Functionality Assessments, Surveillance Testing.
The report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified three NCVs 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 Nuclear Regulatory Commission (NRC)management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process (ROP), Revision 4, dated December 2006.
Cornerstone: Mitigating Systems
- Green.
Inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when PPL performed an inadequate operability determination for a synchroscope switch failure that rendered offsite power and the four emergency diesel generators (EDGs) inoperable. This resulted in PPL being in violation of Unit 1 TSs 3.8.1, 3.8.2, and 3.0.3, and Unit 2 TSs 3.6.4.1 and 3.8.2. PPL entered the issue in their CAP as CR 1703293, re-evaluated past operability and submitted a licensee event report (LER) for the associated condition prohibited by plant Technical Specifications (TS)on July 8, 2013 (ADAMS Accession No. ML13190A104).
The performance deficiency was determined to be more than minor since it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected its objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was evaluated using the SDP of IMC 0609.04. The finding was evaluated under both the Mitigating Systems Exhibit of IMC 0609 Appendix A when Unit 1 was at power and Appendix G for the times when one or both units were in a shutdown condition. Under IMC 0609, Appendix A, the finding screened to Green since it was not a design or qualification deficiency and was not a potential or actual loss of system or safety function. Under IMC 0609, Appendix G, Attachment 1, Checklists 5 through 7, the inspectors screened the issue to Green since it affected the requirement for operable DGs under TS 3.8.1 and TS 3.8.2.
The inspectors determined that a Phase 2 analysis was not warranted since it did not match those criteria listed for further analysis in these checklists. Specifically, since all automatic transfer functions of off-site power and the EDGs remained functional, inspectors determined that none of the functions evaluated under the SDPs were affected. The finding had a cross-cutting aspect in Problem Identification and Resolution (PI&R), corrective action program (CAP), because PPL staff did not thoroughly evaluate problems such that the resolutions address the causes and extent of conditions, to include properly classifying, prioritizing and evaluating for operability. Specifically, PPL staff did not appropriately evaluate the effect that the synchroscope switch failure had on offsite power and emergency diesel generator operability. [P.1(c)] (1R15)
- Green.
Inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XI, Test Control, because PPL staff performed unacceptable preconditioning by performing corrective maintenance prior to recording the as-found time response of the reactor protection system (RPS) and end-of-cycle recirculation pump trip (EOC-RPT) for the turbine control valve (TCV) fast closure function. Specifically, corrective maintenance was performed with the potential to improve the time response of the system without verifying that the as-found condition was within the acceptance criteria assumed in the accident analysis. PPL entered the issue into their CAP as CR 1712564 and verified as-left data was verified to be within acceptance criteria which provided reasonable assurance that the SSC would perform satisfactorily during the subsequent operational period.
Inspectors determined the performance deficiency is more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).
Specifically, the failure to collect as-found data could result in the inability to verify the operability of structures, systems, and components (SSC). Additionally, in this case, the test had exhibited low margin and unreliable performance during its previous surveillance test.
The inspectors determined, through a review of IMC 0609, Appendix A, Exhibit 2, that the finding was Green because the finding was not related to a design or qualification deficiency, did not represent a loss of a mitigating system safety function, and did not screen as potentially risk significant due to external initiating events. The finding is related to the cross-cutting area of PI&R, CAP, in that PPL did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity. Specifically, though degraded performance was identified during previous testing, PPL staff did not take timely and effective corrective actions to ensure the required maintenance did not unacceptably precondition the following 24-month surveillance test. [P.1(d)] (1R15)
Cornerstone: Barrier Integrity
- Green.
Inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because PPL did not adequately incorporate the acceptance criteria for heatup rate specified in the plant TSs, as amplified in its basis, into the surveillance test implementing procedure for monitoring adherence to pressure and temperature requirements during plant heatup and cooldown. Based on this procedure inadequacy, operators exceeded the TS limit during a plant startup on May 28, 2013. PPL entered the issue into their CAP as CR 1709058 and revised plant procedures to appropriately incorporate the acceptance criteria.
This performance deficiency is more than minor because it was associated with the human performance and procedure quality attribute of the Barrier Integrity cornerstone and affected the objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system (RCS), and containment) protect the public from radionuclide releases caused by accidents or events. Using IMC 0609, Significance Determination Process, Appendix A, Exhibit 3, Barrier Integrity Screening Questions, the inspectors determined that this issue required a detailed risk evaluation. In consultation with a Region I Senior Reactor Analyst, the inspectors completed a qualitative risk assessment and determined this issue is of very low safety significance (Green). Specifically, there was no impact on the integrity of the reactor vessel due to the short duration temperature gradient imposed by exceeding the TS heatup rate. Consistent with PPLs evaluation, the observed heatup rate minimally exceeded the specified limit during plant startup and remained within the acceptable bounds of the current plant pressure and temperature analysis. The finding is related to the cross-cutting area of PI&R, Corrective Actions, in that PPL did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity. Specifically, PPL did not take effective corrective actions to correct an inadequate procedure for monitoring adherence to pressure/temperature (P/T) limits after it was identified by inspectors.
[P.1(d)] (1R22)
REPORT DETAILS
Summary of Plant Status
Unit 1 began the inspection period at or near 100 percent power. On May 9, Unit 1 was shutdown for a main turbine outage to inspect and replace turbine blades. Unit 1 commenced a reactor startup on June 1. Unit 1 was shutdown on June 4 from 15 percent power for main turbine balance adjustments. Unit 1 commenced a reactor startup on June 6. On June 7, operators manually scrammed Unit 1 due to a failure in the EHC system. Unit 1 commenced a reactor startup on June 8. Unit 1 was shutdown on June 10 from 16 percent power for main turbine balance adjustments. Unit 1 commenced a reactor startup on June 11 and reached 100 percent power on June 19. Unit 1 ended the inspection period at or near 100 percent power.
Unit 2 began the inspection period at or near 100 percent power. On April 13, Unit 2 was shutdown for a refueling outage. Unit 2 commenced a reactor startup on May 28 and reached 100 percent power on June 12. Unit 2 ended the inspection period at or near 100 percent power.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
Summer Readiness of Offsite and Alternating Current (AC) Power Systems
a. Inspection Scope
The inspectors performed a review of plant features and procedures for the operation and continued availability of the offsite and alternate AC power system to evaluate readiness of the systems prior to seasonal high grid loading. The inspectors reviewed PPLs procedures affecting these areas and the communications protocols between the transmission system operator and PPL. This review focused on changes to the established program and material condition of the offsite and alternate AC power equipment. The inspectors assessed whether PPL established and implemented appropriate procedures and protocols to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system. The inspectors evaluated the material condition of the associated equipment by interviewing the responsible system manager, reviewing condition reports (CRs) and open work orders, and walking down portions of the onsite and offsite AC power systems including the diesel generators, transformers, and the 500 kilovolt (kV) and 230 kV switchyards.
b. Findings
No findings were identified. ==1R04 Equipment Alignment
.1 Partial System Walkdowns
a.== Inspection Scope The inspectors performed partial walkdowns of the following systems: Unit 1, 1A residual heat removal service water (RHRSW) during Division II RHRSW inoperability Unit 2, Division II, core spray (CS) Unit 2, Division II A residual heat removal (RHR) following low pressure coolant injection (LPCI) alignment 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 Updated Final Safety Analysis Report (UFSAR), TSs, work orders (WOs), CRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether PPL staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
On April 24, 2013, the inspectors performed a complete system walkdown of accessible portions of the Unit 1 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 to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the RCIC components while in the standby condition to ensure no deficiencies existed. The inspectors also reviewed the latest surveillance test results to ensure operating parameters were in accordance with the design requirements of the system.
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