Susquehanna Steam Electric Station
May 3, 2011:
Three Mile Island Alert
NRC’s Annual Assessment March 21, 2012
Eagle Building, Berwick, PA
May 3, 2011:
NRC to Mr. Timothy S. Rausch Senior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC,
“...Subsequent to the issuance of our March 4 letter, the NRC's review of Susquehanna Unit 1 determined that the Unplanned Scrams per 7000 Critical Hours performance indicator (Pl) has crossed the Green-to-white threshold (i.e., greater than three unplanned scram per 7000-critical hours) Specifically, Unit 1 had unplanned scrams on April 22,May 14, and July 16, 2010 as well as January 25, 2011. The first quarter of 2011 PPL was reported to the NRC on April 21, 2011.”
Therefore, beginning in the first quarter of 2011, the NRC has assessed the performance of Susquehanna Unit 1-to be in the Degraded Cornerstone column of the NRC's Action Matrix based on two White [findings] in the Initiating Events cornerstone. Consistent with the graded approach in the NRC's ROP, this results. In a corresponding increase in the NRC's inspection and assessment oversight of Susquehanna Unit 1. Specifically, we plan to schedule and perform a supplemental inspection
... [the] inspection will be conducted to provide assurance that the root causes and contributing causes of individual and collective risk-significant performance issues are understood, independently assess the extent of condition and extent of cause of individual and collective risk significant performance issues, and provide assurance that licensee corrective actions for risk significant performance issues are sufficient to address the root causes and contributing causes and prevent recurrence.
May 24, 2011
NRC to Mr. Timothy S. Rausch Senior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC
Dear Mr. Rausch:
By letter dated March 31,2011, PPL Susquehanna LLC, Inc. (PPL) submitted "NRC Decommissioning Funding Status Report, December 31, 2010" for the Susquehanna Steam Electric Station, Units 1 and 2.
The Nuclear Regulatory Commission staff has been reviewing the submittal and has determined that additional information is needed to complete its review.
RAI #1: Citation for real rate of returns: Provide the citation (e.g., an Order by the rate-regulatory authority) by the regulatory entity that allows for the for the assumptions used regarding rates of escalation in decommissioning costs, rate of earnings on decommissioning funds and rates of other assumed in your DFS report.
“PPL Susquehanna LLC is no longer under the jurisdiction of a rate making authority...” (PPL, June 22, 2011)
RAI #2: After-tax decommissioning funds as of December 31, 2010: Indicate if the amount of decommissioning funds identified within the DFS Report is the after-tax amount of funds accumulated through December 31, 2010. If not, provide the after-tax amount of decommissioning funds accumulated through December 31,2010.
“PPL paid all applicable federal, sate, and local taxes on trust fund activities directly front he fund balance including assets held as of December 31, 2010.” (PPL, June 22, 2011)
Sept. 1, 2011 The NRC completed its mid-cycle performance of Susquehanna Units 1 and 2
The NRC determined that the performance of Unit 1 during the most recent quarter ending June 30, 2011, was within the “degraded cornerstone column” of its oversight process. This was due to one finding having low to moderate safety significance and one performance indicator having low to moderate safety significance.
The one finding related to an internal flooding event on July 16, 2010, that required a plant shutdown. The performance indicator involved unplanned shutdowns occurring in 2010 on April 22, May 14, and July 16, and on Jan. 25, 2011.
The NRC found that the performance of Unit 2 was within the licensee response column of the oversight process.
Sept. 6, 2011
HARRISBURG, Pa. (AP) - Pennsylvania's Susquehanna nuclear power plant faces tougher scrutiny from federal regulators following a national review of plant safety.
The Nuclear Regulatory Commission said Tuesday all of the nation's 104 plants are operating safely, but that problems at Unit 1 of the Susquehanna plant in Luzerne County made it 1 of 5 with the worst recent safety performance. No serious problems were detected at Pennsylvania's four other nuclear plants in the latest assessment.
The low grades reflect four unplanned shutdowns at Susquehanna Unit 1 between April 2010 and January 2011, including one necessitated by a faulty gasket that caused 1 million gallons of river water to leak into the turbine building.
Copyright 2011 The Associated Press. All rights reserved. This material may not be published, broadcast, rewritten or redistributed
November 1, 2011
NRC to Mr. Timothy S. Rausch Senior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC,
“...once every 3 years, the NRC staff will audit a licensee's commitment management program.
On September 26-29, 2011, an audit of the commitment management program for PPL Susquehanna, LLC (PPL, the licensee) was performed onsite and in the NRC office. Based on the audit, the NRC staff finds that:
(1) While PPL had implemented most of the Regulatory Commitments on a timely basis; in the case of one commitment in the audit sample, item #3, in Table 1, the licensee neither entered the commitment in the system, nor did it track the implementation, and
(2) While PPL's program for managing NRC commitments, including the changes, is generally consistent with NEI 99-04, only the revised version of some regulatory commitments, related to license renewal, were entered in the system. The original commitments were not entered and subsequently revised, as described in its procedure NDAP-QA-0750, Revision 8, "Regulatory Commitment Management."
Also, as described in the enclosed audit report, the NRC audit team noted that the implementation of PPL's Commitment Management Program procedure varies depending on the user resulting in lack of consistent and uniform implementation. Therefore, the licensee's program document NDAP-QA-0750, needs considerable improvements, because it lacks specificity, clarity, consistency, and uniformity.”
Nov. 8, 2011, The NRC issued a severity level IV violation against the plant operator for failure to notify the NRC of the change in medical status of a licensed reactor operator. It was determined that the operator needed to wear eyeglasses as early as April 2009, but plant licensee PPL “did not inform the NRC or request an amended license” for the operator until August 2011.
“Therefore,” the NRC said, “the reactor operator performed license duties without an NRC-approved, amended license from April 2009 through August 2011, until the NRC identified the issue.”
The NRC noted that this is a “repetitive” issue. (See report dated Jan. 28, 2010, in which a senior reactor operator continued to conduct NRC-license activities after not meeting a specific medical prerequisite and there was no notification to NRC to ensure the person’s license was conditioned to require corrective lenses.) In that Jan. 28, 2010, report, the NRC noted that a civil penalty would not be proposed, but “significant violations in the future could result in a civil penalty.”
The latest NRC report does not mention any possible civil penalty.
The violation was found during an examination for the third quarter from July through September 2011. In the report, the NRC also found a non- cited security level IV issue and two NRC-identified and one self-revealing finding, all of very low safety significance. Additionally, the report said two PPL identified violations were determined to be of very low safety significance and were treated as non-cited violations.
The other level IV violation involved the recording of reactor coolant system leakage values under the performance indicators for Units 1 and 2.
“”PPL submitted inaccurate data for the affected performance indicators for Units 1 and 2 every quarter from April 2000 through its current submittal of June 2011,” the report said. “PPL’s failure to identify and correct the recurring errors over this period of time indicate the existence of a programmatic issue.”
Even though the data didn’t cross certain thresholds, “the inspectors concluded that PPL had reasonable opportunity to foresee and correct the inaccurate information prior to the information being submitted to the NRC,” the NRC report said. “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 matter has been placed into PPL’s corrective action program.
On Dec. 6, 2011, personnel ascertained that a cylinder was not firing for the generator. It was determined that the loss of firing was likely the result of a diesel overhaul completed in September 2011, the NRC report said. The overhaul included disassembly of the fuel pumps to upgrade the o-rings to a material that was more compatible with ultra-low sulfur diesel fuel oil, the report said.
As part of the repair work, the cylinder was disassembled to inspect the delivery valve. The purpose was to verify that the delivery valve spring and stop had been installed correctly. When disassembled, the spring was found broken into several pieces. On Dec. 13, 2011, PPL decided to inspect the other fuel pumps to verify whether the springs were properly installed. It was determined that 11 of the remaining 15 delivery valves had their springs and stops inverted (installed incorrectly), and they were all broken into multiple pieces. Adding in the problem with the initial cylinder, 12 of 16 valve springs and stops were installed incorrectly,
The NRC said a root cause analysis determined that “work instructions to perform the modification were inadequate; workers proceeded with the work using the inadequate work instructions; and quality control hold point inspections were insufficient in both quality and performance to identify the error.
The finding was determined to be of very low safety significance. The NRC said a violation related to the finding is “currently under review.”
A second, self-revealing, finding of very low safety significance was identified when PPL personnel did not have adequate procedures to perform post-modification testing on the Unit 2 digital integrated control system (ICS). This led to a failure to identify an improperly terminated jumper that ultimately created a main turbine trip and automatic reactor scram (shutdown) during subsequent surveillance testing, the NRC report said.
PPL’s root cause analysis determined the direct cause of the main turbine trip on Aug. 19, 2011, “to be the improperly terminated connection in the ICS feed-water control panel,” the NRC report said. “This termination was installed in March 2009 as part of the ICS upgrade; however, the installation was not complete, to include post-modification testing, until May 2011. Despite review of documents and interviews with personnel performing the initial field installation, PPL was unable to positively determine that the improper termination was made during the 2009 initial field installation...Since the list of terminations that were required to be visually verified was not included in the work package, the visual check was not performed and the improper termination of the jumper that caused the event was not discovered”
“The wiring error ultimately led to a main turbine trip and automatic reactor scram during surveillance testing,” the NRC added. Inspectors evaluated the finding and determined that it “did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment of functions would not be available.” Consequently, the NRC issued a finding of very low safety significance.
An additional finding, a non-cited violation, occurred when the Unit 2 reactor core isolation cooling ramp generator signal converter failed during maintenance, but post-maintenance testing did not identify the failure. The failure went unrecognized for a three day period, from June 26, 2011 (when PPL commenced a reactor startup and transitioned to plant conditions when the reactor core isolation cooling was required to be operable) until June 29, 2011. The signal converter was replaced on July 1, 2011, and the isolation cooling unit was declared operable on July 2, 2011. (The reactor core isolation cooling provides makeup water to the reactor when normal supply is lost.)
Another non-cited violation occurred when PPL did not perform an adequate operability assessment for a failed suppression pool spray flow indicator, the NRC report said.
The NRC said one subsystem of the suppression pool was inoperable for 62.5 hours. “Since the finding was not a degradation of the barrier function of the control room against smoke or toxic gas, did not represent an actual open pathway of the physical integrity of containment, and did not involve an actual reduction in function of hydrogen igniters in the reactor containment, the finding was determined to be of very low safety significance,” the NRC said.
The three findings by PPL, the licensee, were all considered to be of very low safety significance. They are:
1) On Sept. 17, 2011,a worker in the Unit 1 recombiner room received a dose rate alarm of 683 millirem/hour, but the room was not posted and controlled as a high radiation area. “The issue was of very low significance because it was not an As Low as Reasonably Achievable issue, did not involve an actual or substantial potential for an overexposure, and the ability to assess the actual dose received was not compromised,” the NRC said.
2) PPL identified that a reactor operator was removed from the requalification program for a period of six months, and then was returned to licensed duties after three months of makeup training without obtaining NRC review.
3) On Nov. 2, 2011, PPL determined that the full scope of a control room emergency outside air supply system surveillance requirement was not being met due to procedural deficiencies.
The NRC also said it had opened an unresolved item relating to NRC requirements during a Dec. 5, 2011, transfer of a 1,100 curie Cs-137 sealed source and a source transfer into a Hopewell Design survey instrument calibrator. During the transfer, electronic dosimeters worn by the Hopewell Design contractor and the effluent technician immediately alarmed, indicating unexpected high dose rates. “The NRC had a number of issues related to this event, including adherence to radiological work practices in conducing the evolution and proceeding after the initial event, the adequacy of the radiological monitoring used, design control and vendor knowledge concerns related to the configuration of the source transfer assembly, and whether appropriate procedures were issued and followed for the evolution,” the report said.
The NRC also conducted a semi-annual review to identify trends that could indicate the existence of other safety issues. In the general work environment, the NRC noted that “actions taken to date to address the Safety Conscious Work Environment appeared to have had a positive impact” since the issuance of a chilling effect letter in January 2009. “Based on these results, the NRC will no longer formally document its assessments” of the safety work environment on a semi-annual basis, the NRC said.
Regarding human performance, the NRC observed that it had issued green, low-level, findings in each of the four quarters from July 1, 2010, through June 30, 2011 “pertaining to inadequate plant procedures.” It also noted that the plant’s human performance program “is not valued as a prevention method to reduce performance deficiencies. Numerous corrective actions were assigned to address the weaknesses, but had not been implemented at the time of this review.”
In addition, the NRC said, “Inspectors identified what appeared to be a potential trend in violations that were subject to traditional enforcement. Though many were of minor safety significance, the number of violations may be indicative of a trend requiring additional analysis and corrective action.”
It also listed concerns involving postings at radiation and high radiation areas, “as well as less than adequate radiation worker behaviors.” The report noted that PPL had developed a radiation protection recovery program “to track progress of numerous corrective action program products and manage corrective actions aimed at addressing the continuing trend.”
Jan. 6, 2012 – The NRC issued a notice of violation to a senior reactor operator who failed to notify officials of the Susquehanna Steam Electric facility of a criminal violation filed against him by Indiana State Police prior to his return to work in July 2010.
The NRC said the senior operator had been issued a citation on July 10, 2010. The citation was for public indecency/indecent exposure, according to NRC records.
The senior operator did not report the legal action to his superior or any other PPL related official when he returned to work at the Berwick plant on July 18, 2010. He subsequently reported the legal action on July 21, 2010.
The senior reactor operator had unescorted access at the plant and was required by NRC regulations to promptly report legal actions issued to him by law enforcement agencies. The senior reactor operator was on vacation on July 10, 2010, and was scheduled to return to work on July 21, 2010. However, he reported back three days earlier to assist in a plant-flooding event, the NRC said.
The operator is no longer employed by PPL, the owner of the plant. He was issued a notice of violation, but no enforcement action is being taken against PPL, the NRC said.
Feb. 14, 2012 - The NRC issued its quarterly report for Units 1 and 2. The report covers the period from October through December, although it discusses and issues findings for events that happened prior to the quarter.
In the report, the NRC had four findings, two of them determined to be violations of NRC requirements. The plant’s licensee, PPL, also identified three violations that were determined to be of very low safety significance.
The NRC report also discussed some troubling trends regarding plant performance and procedures.
One finding involved PPL’s failure to properly plan and implement work instructions associated with a modification of an emergency diesel generator fuel pump assembly. The error resulted in the failure of the generator to continue running during surveillance testing on Dec. 6, 2011. It was subsequently determined that the generator had been inoperable from Sept. 19, 2011 following restoration from its maintenance outage.
NRC to Mr. Timothy S. Rausch Senior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC,
March 1, 2012
Dear Mr. Rausch:
On February 13, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed its end-of-cycle performance review of Susquehanna Steam Electric Station (Susquehanna) Units 1 and 2. The NRC reviewed the most recent quarterly performance indicators (PIs) in addition to inspection results and enforcement actions from January 1, 2011, through December 31, 2011. This letter informs you of the NRC’s assessment of your facility during this period and its plans for future inspections at your facility. This performance review and enclosed inspection plan do not include security information. A separate letter will include the NRC’s assessment of your performance in the Security Cornerstone and its security-related inspection plan.
The NRC determined that the performance at Susquehanna Unit 1 during the most recent quarter was within the Degraded Cornerstone Column of the NRC’s Reactor Oversight Process (ROP) Action Matrix because of one finding having low to moderate safety significance (i.e., white) and one PI having low to moderate safety significance (i.e., white), both associated with the Initiating Events Cornerstone. The White finding was related to an internal flooding event on July 16, 2010, which required the operators to insert a manual scram and isolate the normal heat sink. The White PI was related to the 1st quarter 2011 Unplanned Scrams per 7000 Critical Hours PI. Specifically, Unit 1 crossed the
green-to-white PI threshold following unplanned scrams on April 22, May 14, and July 16, 2010, and January 25, 2011. Although the 2nd quarter 2011 Unplanned Scrams PI returned to Green from White, Susquehanna Unit 1 will remain in the Degraded Cornerstone Column of the NRC Action Matrix until the associated supplemental inspection is completed satisfactorily.
...Therefore, the NRC plans to conduct ROP baseline inspections at Unit 2. The NRC evaluates cross-cutting themes to determine whether a substantive cross-cutting issue (SCCI) exists in a particular area and to encourage licensees to take appropriate actions before more significant performance issues emerge. Regarding Susquehanna, the NRC sustained an SCCI in the Corrective Action Program (CAP) component of the Problem Identification and Resolution (Pl&R) cross-cutting area. Specifically, there were six findings with a PI&R cross- cutting aspect of P.1(c) - Evaluation of Identified Problems - during this assessment period, one of which included the July 16, 2010 flooding event which has been held open since the associated supplemental inspection was not completed at the end of the assessment period. The P.1(c) theme was originally identified in the 2010 Annual Assessment letter (ML110620317), and an SCCI was assigned in the 2011 Mid-Cycle Assessment letter (ML112430469).
For the current assessment period, the NRC has determined that the exit criteria defined in the 2011 Mid-Cycle Assessment letter have not been met. Specifically, there has not been a notable reduction in the number of findings with a P.1(c) cross- cutting aspect and PPL has not demonstrated sustainable performance improvement in this area (ML111330523, 112220409, 113120409, and 12045A383).
Therefore, the P.1(c) SCCI will remain open until PPL has demonstrated sustainable performance improvement as evidenced by effective implementation of an appropriate corrective action plan that results in a notable reduction in the overall number of inspection findings with the same cross- cutting aspect, as well as no safety significant findings.
Because this letter is the second consecutive letter documenting an SCCI with the same cross-cutting aspect, in accordance with NRC Inspection Manual Chapter 0305, section 14.04.c, the NRC requests your staff provide a verbal response discussing your progress and future plans in addressing this SCCI during the 2011 annual public meeting. The NRC will continue to monitor your staff’s efforts and progress in addressing this SCCI through the baseline inspection program, the 95002 supplemental inspection, and the July 2012 biennial PI&R inspection.
The NRC also identified an SCCI in the Resources component of the Human Performance cross- cutting area. Specifically, PPL had four findings with a Human Performance cross-cutting aspect of H.2(c) - Documentation, Procedures, and Component Labeling, which included a green finding in each of the four quarters of the assessment period. This was originally identified as a cross cutting theme in the 2011 Mid-Cycle Assessment letter. For the current assessment period, the NRC has a concern with your progress in addressing and substantially mitigating this issue given that a reasonable duration of time has passed, findings with the same cross-cutting aspect continue to be identified as demonstrated by six consecutive quarters with an H.2(c) finding, and the delayed completion of a root cause analysis which resulted in limited implementation of corrective actions by the end of the assessment period. The PI&R H.2(c) SCCI will remain open until PPL has demonstrated sustainable performance improvement as evidenced by effective implementation of an appropriate corrective action plan that results in a notable reduction in the overall number of inspection findings with the same cross-cutting aspect, as well as no safety significant findings.
The NRC will monitor your staff’s efforts and progress in addressing this SCCI through the baseline inspection program, the 95002 supplemental inspection, and the July 2012 biennial PI&R inspection.
The NRC also identified a cross-cutting theme in the Work Practices component of the Human Performance cross-cutting area. Specifically, PPL had five findings with a Human Performance cross-cutting aspect of H.4 (a) -human error prevention techniques, which included two green findings and a greater-than-green finding issued in the 1st quarter(ML110871605 and ML111180742), and one green finding in each of the 3rd and 4th quarters of the assessment period (ML113120409 and ML12045A383). The NRC determined that an H.4 (a) SCCI does not exist because the NRC does not, at this time, have a concern with your staff’s scope of effort and progress in addressing the cross-cutting theme. Specifically, PPL recognized the H.4 (a) theme in the 3rd quarter 2011 and conducted analyses, including a root cause investigation, which were completed near the end of the assessment period.
Thus, the NRC concluded that more time is necessary for PPL to demonstrate the effectiveness of their corrective actions regarding human error prevention techniques in order for the NRC to evaluate the effectiveness and sustainability of these activities. The NRC will continue to monitor your staff’s efforts and progress in addressing the theme until the theme criteria are no longer met.
The enclosed inspection plan lists the inspections scheduled through June 30, 2013....The NRC will schedule and conduct IP 92723 when your staff has notified us of your readiness for this inspection. The NRC will contact you as soon as possible to discuss changes to the inspection plan should circumstances warrant any changes.
William M. Dean Regional Administrator 14
Three Mile Island
July 20 – The NRC granted requests from TMI operator Exelon for relief and allowed it to use alternative procedures to certain requirements for in-service examination of components and steam pressure tests conducted during 10-year intervals. The requests were part of the fourth 10-year inspection that began on April 20, 2011 and ends no later than April 19, 2022.
August 28, 2009
No safety issues found to prevent reactors from running another 20 years.
By Rory Sweeney
Times Leader Staff Writer
The U.S. Nuclear Regulatory Commission concluded that there are no safety issues that would stop PPL Corp. from relicensing its Susquehanna nuclear station for another 20 years, according to a report released by the agency on Thursday.
Three Mile Island-Alert News Report
By Marlene Lang
Three Mile Island Alert's Questions on the
NRC’s Annual Assessment of the
Susquehanna Steam Electric Station
May 19, 2009
1) PPL sought to publicly hide the extent of their decommissioning losses in
an affidavit the Company submitted to the NRC on March 26, 2009. PPL’s
one year decommissioning losses are staggering by any standard. “The fair
value of investments that are legally restricted due the decommissioning of
the Susquehanna Nuclear plant was $446 million and $555 million in at
December 31, 2008 and 2007...” (PPL 2008 Annual Report, Nuclear
Decommissioning, p. 191)
PPL lost $109 million from the fund in one year and now has$446
million out of projected $936 million (2002 dollars) needed to
decommission it operating nuclear units.
How will PPL recoup the losses after 12/31/2009?
The Susquehanna Steam Electric Station (SSES) contains the nation’s
19th and 20th largest nuclear reactors. The plant currently generates 60
metric tons of nuclear waste annually. The SSES is a limited liability
corporation (“LLC”), and out of the rate base. A license extension, uprate or
by Eric Joseph Epstein
Nuclear Trash On The River
March 16, 2009
The Nuclear Regulatory Commission staff has completed its final environmental impact statement (EIS) for the Susquehanna Steam Electric Station, Units 1 and 2, and concluded that there are no environmental impacts that would preclude license renewal for an additional 20 years of operation. The staff has also issued a safety evaluation report (SER) that documents the interim results of the NRC staff’s review of the license renewal application and site audits of Susquehanna’s aging management programs to address the safety of plant operations during the period of extended operations. Overall, the interim results show that PPL has identified actions that have been or will be taken to manage the effects of aging in the appropriate safety systems, structures and components of the plant and that their functions will be maintained during the period of extended operation.
TMI Alert Chairman Eric Epstein presented testimony in a civil lawsuit pertaining to the relicensing of PPL's Susquehanna Steam Electric Station. Epstein asked that action toward relicensing the plant be put on hold until unresolved water use issues are resolved.
To read the full complaint, and other related documents and articles, open PDF attachments: