IR 05000387/2011004
| ML113120409 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/08/2011 |
| From: | Paul Krohn Reactor Projects Region 1 Branch 4 |
| To: | Rausch T Susquehanna |
| Krohn P | |
| References | |
| EA-11-244 IR-11-004 | |
| Download: ML113120409 (57) | |
Text
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD
SUBJECT:
SUSQUEHANNA STEAM ELECTRIC STATION _ NRC INTEGRATED I N SpECTt ON REPORT 05000387/201 1 004 AN D 050003881201 1 004 AND NOTICE OF VIOLATION
Dear Mr. Rausch:
On September 30, 2011, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Susquehanna Steam Electric Station Units 1 and 2. The enclosed integrated inspection report presents the inspection results, which were discussed on October 13,2011, with you and other members of your staff.
This inspection examined activities completed 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.
Based on the results of this inspection, the NRC has determined that a Severity Level (SL) lV violation of NRC requirements occurred. The violation was evaluated in accordance with the NRC Enforcement Policy included on the NRC's Web site at www.nrc.qov. Select About NRC, How We Regulate, Enforcement, then Enforcement Policy.
The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The inspectors identified a SL lV Violation of 10 CFR 55.25, "lncapacitation Because of Disability or lllness," for PPL failing to notify the NRC of a known permanent change in medical status of a licensed operator, and 10 CFR 55.3, "License Requirements," for failing to ensure that an individual license holder, in the capacity of a reactor operator (RO), met the medical prerequisites prior to performing licensed operator duties. Specifically, biennial medical examinations conducted on April 16, 2009 and April 19,2011 identified that an RO did not meet the health requirements stated in ANSI/ANS 3.4-1983, Section 5.4.5, "Eyes." However, PPL did not inform the NRC or request an amended license for the RO until August 2011. Therefore, the RO performed licensed duties without an NRC-approved, amended license from April 2009 through August 2011, until the NRC identified this issue. Upon notification PPL submitted, and the NRC approved, a conditional license to address the disqualifying medical condition. See Section 1R1 1 of the attached report for additional details. Violations of operator licensing requirements are of particular concern to the NRC, and may be considered for escalated enforcement under certain circumstances. However, in this case, the NRC has classified this violation at SL lV, after considering that the operator was wearing corrective lenses since the first failed test in April 2009 and that an amended license for a condition of "Corrected Lenses Required" likely would have been approved. Thus, the basis for the RO's license was not impacted since his actual corrected vision while performing his duties was within the standards.
This violation is being cited in the enclosed Notice in accordance with NRC Enforcement Manual Section 3.1.2, because the violation was determined to be repetitive of NRC Enforcement Action (EA) 09-248 dated January 28,2010, an SL lll Notice of Violation related to a Senior Reactor Operator (SRO) standing watch without meeting a medical qualification requirement. The medical conditions in both the former and current cases were similar; therefore, it was reasonable that an adequate extent of condition review for EA-09-248 should have identified the additional discrepancy.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. Please discuss the corrective actions taken to restore compliance, corrective actions to preclude recurrence of similar issues in the future, and a discussion why actions for EA-09-248 were not effective in identifying this issue. Also, if you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
This report also documents two NRC-identified findings and one self-revealing finding, all of very low safety significance (Green), and one NRC-identified SL lV NCV. Two of these findings were determined to involve violations of NRC requirements. Additionally, two licensee-identified violations, which were determined to be of very low safety significance, are listed in this report.
However, because of the very low safety significance and because they are entered into your correction action program (CAP), the NRC is treating these findings as non-cited violations (NCVs) consistent with Section 2.3.2 of the NRC's Enforcement Policy. lf 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 RegionalAdministrator Region l; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC 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 RegionalAdministrator, Region l, and the NRC Resident lnspector at the Susquehanna Steam Electric Station.
ln 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 document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.qov/readino-rm/adams.html (the Public Electronic Reading Room). To the extent possible, your response should not include any personal privacy or proprietary, information so that it can be made available to the Public without redaction. lf personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that deletes such information. lf you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.9., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). lf safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
tuL-4u Paul G. Krohn, Chief Projects Branch 4 Division of Reactor Projects DocketNos. 50-387;50-388 License Nos. NPF-14, NPF-22
Enclosures:
1. Notice of Violation 2. lnspection Report 05000387/2011004 and 05000388/201 1004 wl Attachment: Supplemental Information Mencl: Distribution via ListServ copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. lf you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.9., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). lf safeguards information is necessary to provide an a
REGION I Docket Nos: 50-387, 50-388 License Nos: NPF-14, NPF-22 Report No: 05000387/201 1 004 and 050003881 201 1 004 Licensee: PPL Susquehanna, LLC Facility: Susquehanna Steam Electric Station, Units 1 and 2 Location: Benruick, Pennsylvania Dates: July 1 ,2011through September 30,2011 Inspectors: P. Finney, Senior Resident lnspector J. Greives, Resident Inspector A. Rosebrook, Senior Project Engineer S. Pindale, Senior Reactor Inspector E. Burket, Reactor Inspector M. Orr, Reactor Inspector Approved By: Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure 2
TABLE OF CONTENTS 1R01 Adverse Weather Protection ...............7 1R04 Equipment Alignment. ........8 1 R05 Fire Protection........... ....,...8 1R06 Flood Protection Measures .................9 1R07 Heat Sink Performance............... ........9 1R11 Licensed Operator Requalification Program ............. ..........10 1R12 Maintenance Effectiveness ........ ......13 1R13 Maintenance Risk Assessments and Emergent Work Control ............13 1R15 Operability Evaluations and Functionality Assessments .....................17 1R18 Plant Modifications.... .......19 1R19 Post-Maintenance Testing (PMT) ...............,.....20 1 R20 Refueling and Other Outage Activities ........,.....21 1R22 Surveillance Testing .,....-21 1EP6 Drill Evaluation .......... ......24 4041 Performance lndicator (Pl) Verification ........ .....25 4C.42 fdentification and Resolution of Problems .............. ............27 4043 Event Followup ...............30 4045 Other Activities ..............,.31 4046 Meetings, lncluding Exit........... .........34 4QA7 Licensee-ldentified Violations ...........34 ATTACHMENT: SUPPLEMENTAL INFORMATION .............35 SUPPLEMENTARY INFORMATION.......,.. .,...,..A-1 KEY POTNTS OF CONTACT ............. A-1 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED .... A-1 LIST OF DOCUMENTS REVIEWED ,.......... ..,....A-2 LtsT oF ACRONYMS............... ....... A-13 Enclosure 2
SUMMARY OF FINDINGS
lR 05000387 1201 1004, 05000388i20 1 1 A04; 07 101 1201 1 - 091301201 1 ; Susquehanna Steam
Electric Station, Units 1 and 2; Licensed Operator Requalification Program, Maintenance Risk Assessments and Emergent Work Control, Operability Evaluations and Functionality Assessments, surveillance Testing, Performance lndicator Verification.
This report covered a three-month period of inspection by resident inspectors and announced inspections by regional inspectors. One Severity Level (SL) lV Notice of Violation (NOV), two Green non-cited violations (NCV), one SL lV NCV, and one Green finding were identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter (lMC) 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," Revision 4, dated December 2006.
Cornerstone: Mitigating Systems
. Severitv Level lV. The inspectors identified a SL lV NOV of 10 CFR 55.25, "lncapacitation Because of Disability or lllness," for PPL failing to notify the NRC of a known permanent change in medical status of a licensed operator, and 10 CFR 55.3, "License Requirements," for failing to ensure that an individual license holder, in the capacity of a reactor operator (RO), met the medical prerequisites prior to performing licensed operator duties.
Specifically, an RO failed a medical examination in both 2009 and 2011 which identified a disqualifying condition and performed licensed duties without an NRC-approved, amended license. He performed the function of an RO while on watch from April 2009 through August 2011, when the NRC identified this issue. However, the operator did wear corrective lenses while standing watch since April 2009. Upon notification PPL submitted, and the NRC approved, a conditional license to address the disqualifying medical condition. PPL entered this issue into their corrective action program (CAP) as condition report (CR)1 4501 38.
The inspectors determined that PPL's failure to notify the NRC of a known permanent change in a licensed operator's medical status and request an amended license in order to assume licensed duties was a performance deficiency. This finding was evaluated using the traditional enforcement process because the issue had the potential to impact or impede the regulatory process. Specifically, there was a potentialfor license termination or the issuance of a conditional license to accommodate for a medical condition. The RO performed licensed duties from April 2009 through August 2011 with a disqualifying condition that required his license to be amended. Using the NRC Enforcement Policy, this violation was characterized at SL lV, in accordance with Section 6.4.
This violation is being cited in the enclosed Notice in accordance with NRC Enforcement Manual Section 3.1.2, because the violation was determined to be repetitive of NRC Enforcement Action (EA) 09-248 dated January 28,2Q1Q, an SLlll Notice of Violation related to a Senior Reactor Operator (SRO) standing watch without meeting a medical qualification requirement. The medical conditions in both the former and current cases were similar:
therefore, it was reasonable that an adequate extent of condition review for EA-09-24g should have identified the additional discrepancy.
This significance of the associated performance deficiency was screened against the Reactor oversight Process (Rop) per the guidance of tMC 0612, Appendix B. No associated ROP finding was identified and no cross-cutting aspect was assigned. (Section 1R1 1)o Green' An NRC-identified Green NCV of 10 CFR 50, Appendix B, Criterion V, "lnstructions, Procedures, and Drawings," was identified when PPL did not perform an adequate operability assessment in accordance with procedure NDAP-QA-0703, "Operability Assessments and Requests for Enforcement Discretion," Revision 15, to ensure the continued operability of the 'M' safety relief valve (SRV). Upon identification, operators initiated an Operability Follow-up Request which ultimately resulted in the'M' SRV being declared inoperable.
The finding was more than minor because it was similar to example 3.j in IMC 0612 Appendix E, "Examples of Minor lssues" in that an error in a calculation is not minor if the error results in reasonable doubt on the operability of the system or component. In this case, the error made in evaluating the operability of the SRV resulted in reasonable doubt of operability. The finding was evaluated for significance using IMC 0609, Attachment 4,
"Phase 1 - lnitial Screening and Characterization of Findingl." Since the finding was not a design or qualification deficiency, did not result in a loss of system safety function, did not result in loss of a single train for greater than its allowed outage time, and was not potentially risk significant due to external events, the finding was determined to be of very low safety significance (Green). This finding was related to the cross-cutting area of Problem ldentification and Resolution (Pl&R) - CAP because PPL did not thbroughly evaluate problems such that the resolutions address the causes and extent of co-nditions, to include properly classifying, prioritizing and evaluating for operability. Specifically, ppl failed to consider the effect that seat leakage had on the lift point oftne ;M' SRV bnd failed to correctly assess the sRV for operabitity. [p.1 .(c)] (section 1R15)
Cornerstone: Barrier Integrity
o
- Green.
A self-revealing Green finding of NDAP-QA-0340, "Protected Equipment program," Revision 10, was identified when the 2A fuel pool cooling (FPC) pump tripped during maintenance on the 2AFPC heat exchanger (HX). The pump and HX had been deiignated as protected equipment. The unavailability and loss of pump functionality resulted in in off-normal procedure entry. PPL entered this issue into their CAP as CR 1438904 and completed an apparent cause evaluation (ACE).
The finding was more than minor due to its adverse effect on the Barrier lntegrity cornerstone attribute of system, structure, and component performance to maintain spent fuel pool cooling (SFPC) system functionality and its objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The finding was screened in accordance with IMC 0609 Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," and was determined to be of very low safety significance, Green, due to its not being associated with the loss of cooling to the spent fuel pool (SFP) that would have precluded restoration prior to boiling, a fuel handling error, or loss of SFP inventory. The finding had a cross-cutting aspect in the area of Human Performance, Work Practices, in that PPL did not use human error prevention techniques commensurate with the risk of the assigned task nor did personnel stop work in the face of uncertainty. [H.4.(a)] (Section 1R13)
- Green.
An NRC-identified Green NCV of Susquehanna Unit 1 and 2 TS 5,4.1,
"Procedures," was identified for an inadequate surveillance procedure for implementing Technical Specifications (TS) Surveillance Requirement (SR) 3.6.4.1.4 and 3.6.4.1.5.
Specifically, the implementing procedure was revised allowing the SR to be missed and subsequently required entry into SR 3.0.3. PPL entered this issue in their CAP as CR 1460362.
The finding is more than minor because it was similar to example 3.d in IMC 0612 Appendix E, "Examples of Minor lssues" in that the failure to implement the TS SR as required is not minor if the surveillance had not been conducted. In this case, the SR had not been completed for all configurations of secondary containment and required both Unit 1 and Unit to enter SR 3.0.3 for a missed surveillance. Additionally, it is associated with the procedure quality attribute to maintain functionality of containment and the Barrier Integrity cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the inadequate surveillance procedure resulted in missed surveillances, SRs 3.6.4.1.4 and 3.6.4.1 .5 and entry into SR 3.0.3 for missed surveillances, The finding was evaluated for significance using IMC 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings." Since the finding only represented a degradation of the radiological barrier function provided for the reactor building (RB) (i.e. secondary containment), the finding was determined to be of very low safety significance (Green). This finding is related to the cross-cutting arca of Human Performance - Resources because PPL did not ensure that personnel, equipment, procedures, and other resources were available and adequate to assure nuclear safety. Specifically, the procedures did not ensure surveillance requirements (SRs) required by TS 3.6.4.1 were implemented. [H.2(c)] (Section 1R22\ Severitv Level lV. An NRC-identified SL-IV NCV of 10 CFR 50.9(a), "Completeness and Accuracy of Information," occurred when PPL inaccurately reported reactor coolant system (RCS) leakage values under the RCS leakage performance indicator (Pl)for both units since inception of the Pl in April 2000. PPL entered the issue in their CAP as CR 1441824, completed an apparent cause evaluation, and plans to revise Pl data previously submitted.
No performance indicator crossed the GreenMhite threshold once the values were updated.
Because violations of 10 CFR 50.9 are considered to potentially impede or impact the regulatory process, they are dispositioned using the traditional enforcement process. The inspectors concluded that PPL had reasonable opportunity to foresee and correct the inaccurate information prior to the information being submitted to the NRC. PPL's failure to identify and correct the recurring errors over this period of time indicated the existence of a programmatic issue. Additionally, verification of the corrected Pl data in a subsequent inspection will have more than an insignificant regulatory impact on the NRC. Accordingly, although none of the affected Pls in this case would have crossed the threshold, the NRC has determined that the violation is of more than minor significance. The finding was not considered to be more significant since had this information been accurately reported, it would not have likely caused the NRC to reconsider a regulatory position or undertake a substantial further inquiry. The significance of the associated performance deficiency was screened against the ROP per the guidance of Manual Chapter 0612, Appendix B. No associated ROP finding was identified and no cross-cutting aspect was assigned. (Section 4OA1)
Other Findings
Violations of very low safety significance or severity level lV, identified by PPL, were reviewed by the inspectors. Corrective actions taken or planned by PPL have been entered into PPL's CAP. These violations and corrective action tracking numbers are listed in Section 4OA7 of this report.
REPORT DETAILS
Summarv of Plant Status Susquehanna Steam Electric Station (SSES) Unit 1 began the inspection period at 92 percent rated thermal power (RTP) in a control rod pattern adjustment and power ascension from a reactor startup. The unit reached 100 percent RTP on July 1. On July 6, the unit was reduced to 72 percent RTP in response to a condensate conductivity excursion. On July 22, the unit was reduced to 85 percent RTP due to condenser backpressure associated with a hot weather limit.
On August 23, a seismic event registered in the area and as a result, Unit 1 entered a Notice of Unusual Event at2:05 p.m. and exited it at 9:10 p.m. On September 9, the unit was reduced to 69 percent RTP for a control rod sequence exchange. Unit 1 operated at full RTP for the remainder of the inspection period.
Unit 2 began the inspection period at 16 percent RTP in a power ascension. Unit 2 reached its former licensed power level of 94.4 percent RTP on July 15. The unit reached 97
.5 percent and
its extended power uprate (EPU) licensed power limit of 100 percent RTP on July 17 and26, respectively. The unit reduced power to 63 percent RTP on August 13 for a control rod pattern adjustment and sequence exchange. On August 19, the Unit 2 reactor tripped from a main turbine trip that was actuated during integrated control system (lCS) leveltesting. A reactor startup was commenced on August 21. On August 23, a seismic event registered in the area and as a result, Unit 2 entered a Notice of Unusual Event at 2:05 p.m. and exited it at 9:10 p.m.
100 percent RTP was attained on August 26. Unit 2 operated at full RTP for the remainder of the inspection period.
Note: The licensed RTP for both units is 3952 megawatts thermal. The authorized power level for both units is 100 percent of the EPU licensed power limit. For the purposes of this report and the remainder of current operating cycle, the authorized power level for Unit 2 is 100 percent of the EPU licensed power limit.
1. REACTORSAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier lntegrity
1R01 Adverse Weather Protection Readiness for lmminent Adverse Weather Conditions (71111.01
- 1 sample)
a. Inspection Scope
During the weeks of August 29 and September 5,2011, the inspectors evaluated implementation of imminent weather preparation to include procedures and compensatory measures as they relate to high winds and heavy rain. The inspectors toured susceptible plant areas and reviewed associated issues in the CAP for appropriate evaluation and resolution. Documents reviewed for each section of this inspection report are listed in the Attachment
.
Common. station readiness for severe weather associated with Hurricane lrene and Tropical Storm Lee
b. Findinqs No findings were identified. ==1R04 EquipmentAlionment
.1 Partial Walkdown (71111.04Q
- 3 samples)
a. Inspection Scope
== The inspectors performed partial walkdowns of the following systems: r Unit 1, Division ll residual heat removal (RHR) during Division I RHR work window o Unit 1,'1A' Standby Liquid Control (SBLC) train during 1B SBLC train outage
.
Common, 'A' CS chiller while 'B' CS chiller out of service (OOS) 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, technical specifications, work orders, condition reports, 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 (Licensee) staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.
b. Findinqs No findings were identified. ==1R05 Fire Protection