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EA-02-216 - Susquehanna 1 & 2 (PPL Susquehanna, LLC)January 13, 2003 EA 02-216 Mr. Bryce L. Shriver
Dear Mr. Shriver: This letter refers to the inspection conducted between June 30 and September 28, 2002, at PPL's Susquehanna Steam Electric Station. The results of this inspection were discussed with you and other members of your staff on October 7, 2002. Our letter dated November 12, 2002, transmitted the inspection report and described an apparent violation involving the backfilling of a Dry Shielded Canister (DSC) with argon, rather than helium, as required by Certificate of Compliance (CoC) No. 1004. The letter which transmitted the subject inspection report provided you the opportunity to address the apparent violation identified in the report by either attending a predecisional enforcement conference or by providing a written response before we made our final enforcement decision. In a letter dated December 12, 2002, you provided a response to the apparent violation. Based on the information developed during the inspection and the information that you provided in your response to the inspection report, the NRC has determined that a violation of NRC requirements occurred. The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it were described in detail in the subject inspection report. Specifically, on July 26, 2002, a DSC containing 52 spent fuel bundles, was filled with a mixture of argon and helium, rather that pure helium, as required by CoC No. 1004 for the NUHOMS-52B dry spent fuel storage system used at Susquehanna. NRC regulations require PPL to comply with the Certificate of Compliance (CoC). The condition existed until August 11, 2002, when the DSC was filled with pure helium and sealed, at which time the DSC was effectively restored to its design condition as specified by CoC No. 1004 . In your response, you stated that PPL did not contest that a violation of regulatory requirements occurred. However, you contend that three prior NRC enforcement actions related to dry fuel storage activities at other facilities supports issuance of a Severity Level IV violation, and a Severity Level IV violation is also warranted because: (1) the event was isolated; (2) the event was licensee-identified; (3) there were no immediate or long-term threats to workers, the safe storage of the spent fuel, station operation, or the health and safety of the public; and (4) this event has been thoroughly evaluated and comprehensive corrective actions have been implemented. The NRC has reviewed the three prior NRC enforcement actions issued to Point Beach, Trojan and Oconee, and we disagree with your contention. With respect to the first two cases, you asserted that a Severity Level III violation issued to Point Beach, which involved the detonation of combustible gases during the transfer of spent fuel, and a Severity Level III violation issued to Trojan, which involved the generation of organic compounds and flammable gases during spent fuel loading operations, were more significant than the Susquehanna event. The NRC considered the Point Beach and Trojan events to be significant, and as a result, they were classified at Severity Level III. The Susquehanna event was also considered significant, warranting a Severity Level III classification, because the NRC found that a system designed to prevent or mitigate a serious safety event, namely the DSC, was degraded to the extent that a detailed evaluation was necessary to demonstrate that there would not have been any long-term threats to workers, the safe storage of the spent fuel, station operation, or to the health and safety of the public or environment. The civil penalty assessment process was followed for each case, which resulted in the issuance of a civil penalty to Point Beach. With respect to the third case, you asserted that the Susquehanna event was similar in significance to the Severity Level IV violation issued to Oconee, which involved sampling the boron concentration in a DSC 20 hours before fuel assembly insertion rather than the required 4 hours. The NRC maintains that the Severity Level IV classification was appropriate at Oconee because a sample was taken (just not at the right time period) and the boron concentration was within specifications. The NRC agrees that the event did not represent an immediate safety concern and appears to be isolated. However, the DSC provides confinement and criticality control for the transfer and storage of highly irradiated nuclear fuel. Helium fill gas ensures a non-corrosive atmosphere and adequate heat removal. Argon gas is about ten times less effective in removing heat as compared to helium gas. As a result, a mixture of both helium and argon gases placed the DSC in an unanalyzed condition. Therefore, because a detailed analysis was necessary as explained above, this violation has been categorized in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, at Severity Level III. In accordance with the Enforcement Policy, a base civil penalty in the amount of $15,000 is considered for a Severity Level III violation for independent spent fuel storage installations. Because your facility has been the subject of escalated enforcement actions within the last 2 years (EA-00-012 and EA-01-187), the NRC considered whether credit was warranted for Identification and Corrective Action in accordance with the civil penalty assessment process in Section VI.C.2 of the Enforcement Policy. Credit for identification is warranted because your staff, namely a maintenance mechanic, identified that the helium regulator was improperly connected to an argon gas cylinder. Credit for corrective action is also warranted. After discovery of the event, work was stopped and an event investigation team was formed. Fuel cladding temperatures were monitored and maintained at appropriate levels until the DSC was restored to CoC requirements. Other corrective actions included: (1) providing briefings, turnovers, and training to appropriate personnel; (2) separating argon and helium cylinders and clearly marking them for identification; (3) reviewing and revising procedures; and (4) apprising the industry about this event. Corrective actions that will also be taken in the future include bench marking your dry fuel storage process to industry leaders in this area and conducting an effectiveness review of completed actions. Therefore, to encourage prompt identification and comprehensive correction of violations, I have been authorized, after consultation with the Director, Office of Enforcement, not to propose a civil penalty in this case. However, significant violations in the future could result in a civil penalty. The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance was achieved is already adequately addressed on the docket in NRC Integrated Inspection Report 50-387/02-05, 50-388/02-05; 72-28/02-01, LER 50-387/2002-005-00, and your letter dated December 12, 2002. Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice. In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. The NRC also includes significant enforcement actions on its Web site at www.nrc.gov; select What We Do, Enforcement, then Significant Enforcement Actions.
Docket Nos.: 50-387; 50-388; 72-28 Enclosure: Notice of Violation cc w/encl:
NOTICE OF VIOLATION
During an NRC inspection conducted between June 30 and September 28, 2002, for which an exit meeting was held on October 7, 2002, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions, NUREG-1600, the violation is listed below: 10 CFR 72.212(b)(7) requires, in part, that the licensee maintain a copy of the Certificate of Compliance and shall comply with its terms and conditions. Certificate of Compliance No. 1004 governs the NUHOMS-52B Dry Cask Fuel Storage System in use at the facility. Certificate of Compliance No. 1004, Technical Specification 1.2.3, requires, in part, that Dry Shielded Canisters have a helium backfill pressure of 2.5 pounds per square inch, plus or minus 2.5 pounds per square inch. Contrary to the above, between July 26 and August 11, 2002, Dry Shielded Canister #18 containing 52 spent fuel bundles, which was vacuum dried and seal welded, was backfilled with a mixture of argon and helium rather than helium alone. This is a Severity Level III violation (Supplement VI ). The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance was achieved is already adequately addressed on the docket in NRC Integrated Inspection Report 50-387/02-05, 50-388/02-05; 72-28/02-01, LER 50-387/2002-005-00, and your letter dated December 12, 2002. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a "Reply to a Notice of Violation," include the EA number, and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). If you choose to respond, your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction. If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001. In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days. Dated this 13th day of January 2003 |
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