EA-01-087 - Susquehanna 1 & 2 (PPL Susquehanna, LLC)

September 13, 2001


Mr. Robert G. Byram
Senior Vice President and
Chief Nuclear Officer
PPL Susquehanna, LLC
Susquehanna Steam Electric Station
2 North Ninth Street
Allentown, Pennsylvania 18101


Dear Mr. Byram:

The purpose of this letter is to provide you with the final results of our significance determination of the preliminary White finding identified during an NRC inspection conducted between May 13 to June 30, 2001. The results of the inspection were discussed with members of your staff at an exit meeting on July 5, 2001. The inspection finding was assessed using the significance determination process and was preliminarily characterized as White, an issue with low to moderate increased importance to safety that may require additional NRC inspections. This preliminary White finding, which was described in the subject NRC inspection report dated August 10, 2001, concerned several occasions when your on-shift staffing was below the minimum on-shift staffing requirements as defined in your Emergency Plan. We have concluded that a white finding is appropriate because at the reduced on-shift staffing levels, certain emergency preparedness functions for an emergency at the site would not be met. These functions were emergency communication, monitoring the unaffected unit for safety, and operations support center coordination duties.

The NRC letter transmitting the inspection report provided you an opportunity to either request a regulatory conference to discuss this issue or to explain your position in a written response. In a phone conversation between Mr. Richard Conte of my staff and Mr. Terry Harpster of your staff on August 17, 2001, PPL Susquehanna, LLC did not contest the characterization of the risk significance of this finding as White and did not wish to provide a written response. After consideration of the information developed during the inspection, the NRC has concluded that the inspection finding is appropriately characterized as White. You have 10 business days from the date of this letter to appeal the staff's determination of significance for the identified White finding. Such appeals will be considered to have merit only if they meet the criteria given in NRC Inspection Manual Chapter (IMC) 0609, Attachment 2.

Per the Action Matrix associated with the NRC's Assessment Process (IMC 0305), any single White issue, such as this finding, places Susquehanna Steam Electric Station in the Regulatory Response Band. Therefore, we will use the NRC Action Matrix to determine the most appropriate NRC response. We will notify you by separate correspondence of that determination, including any adjustments to the NRC inspection plan. The NRC has also determined that PPL Susquehanna, LLC violated the requirements of 10 CFR 50.54(q), 50.47(b)(2) and Appendix E, Section IV.E.9, as cited in the enclosed Notice of Violation (Notice), by having an inadequate procedure that allowed on-shift staffing to fall below the minimum on-shift staffing requirements as defined in your Emergency Plan, which occurred on several occasions. Details regarding the circumstances surrounding this violation were discussed in the subject inspection report. In accordance with the NRC Enforcement Policy, NUREG-1600, the Notice is considered escalated enforcement action because it is associated with a White finding.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. We recognize that one of your immediate corrective actions consisted of revising the procedure in question. However, our ongoing inspections indicate that some Emergency Plan staffing problems have recurred on a few occasions since our May/June inspection. Therefore, your response should address not only the specific changes made to that procedure, but also any other immediate and long term corrective actions. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosures will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at the Public NRC Library.

Hubert J. Miller
Regional Administrator

Docket Nos. 50-387, 50-388
License Nos. NPF-14, NPF-22

Enclosure: Notice of Violation

cc w/encl:
B. L. Shriver, Vice President - Nuclear Site Operations
G. T. Jones, Vice President - Nuclear Engineering and Support
R. Anderson, General Manager - SSES Operations
R. L. Ceravolo, General Manager - SSES Maintenance
G. A. Williams, General Manager - Nuclear Assurance
G. D. Miller, Manager - Nuclear Plant Services
R. R. Sgarro, Supervisor, Nuclear Licensing - SSES
M. M. Golden, Manager - Nuclear Security
P. Nederostek, Nuclear Services Manager, General Electric
A. M. Male, Manager, Quality Assurance
H. D. Woodeshick, Special Assistant to the President
G. DallaPalu, PP&L Nuclear Records
R. W. Osborne, Vice President, Supply & Engineering
Allegheny Electric Cooperative, Inc.
Commonwealth of Pennsylvania
R. A. Calvan, Regional Director, FEMA, Region III
C. Markley, Pennsylvania Power & Light Company


PPL Susquehanna, LLC
Susquehanna Units 1 and 2
  Docket Nos. 50-387, 50-388
License Nos. NPF-14, NPF-22

During an NRC inspection conducted between May 13 and June 30, 2001, for which an exit meeting was held on July 5, 2001, 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 50.54(q) specifies, in part, that a licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the standards in 10 CFR 50.47(b).

10 CFR 50.47(b)(2) states, in part, that on-shift facility licensee responsibilities for emergency response are unambiguously defined, and adequate staffing to provide initial facility accident response in key functional areas is maintained at all times.

The Susquehanna Emergency Plan (E-Plan), dated February 2000, Section 6.1, specifies that the minimum shift response during off-hours to respond to an emergency event includes, in part, two plant control operators (PCOs - reactor operators) per unit, for a total of four PCOs, and one Assistant Unit Supervisor (AUS - senior reactor operator or reactor operator).

Contrary to the above, the licensee did not ensure that procedures were adequate and staffing levels were maintained to meet E-Plan requirements. Specific deficiencies included:

  (1) Nuclear Department Administrative Procedure (NDAP), NDAP-QA-0300, "Conduct of Operations," Revision 11, permitted the use of three PCOs and no AUS when approved by operations management.
(2) On nine occasions in 2000 (May 21, June 4, June 14, June 26, June 28, June 30, July 25, December 15, and December 16), and four occasions in 2001 (January 21, February 11, March 2, and April 4), the licensee did not maintain at least four PCOs on-shift for all or a significant part of those 12 hour shifts.
(3) On one occasion in 1999 (October 1), three occasions in 2000 (May 25, June 10, and June 11), and one occasion in 2001 (January 7), the licensee did not maintain the AUS position for all or a significant part of those 12 hour shifts.
This violation is associated with a WHITE Significance Determination Process finding.

Pursuant to the provisions of 10 CFR 2.201, PPL Susquehanna, LLC is hereby required to submit a written statement or explanation 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). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for the violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or its significance, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

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.

Because your response will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. ADAMS is accessible from the NRC Web site at the Public NRC Library. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If 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.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days.

Dated this 13th day of September 2001

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