IR 05000277/2005006

IR 05000277-05-006, 05000278-05-006; 07/11/2005 - 07/29/2005; Peach Bottom Atomic Power Station; Biennial Baseline Inspection of the Identification and Resolution of Problems

ML052550395
Person / Time
Site:	Peach Bottom
Issue date:	09/12/2005
From:	Shanbaky M Reactor Projects Region 1 Branch 4
To:	Crane C Exelon Generation Co, Exelon Nuclear
References
IR-05-006
Download: ML052550395 (22)

Text

ber 12, 2005

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION NRC INSPECTION REPORT 05000277/2005006 AND 05000278/2005006

Dear Mr. Crane:

On July 29, 2005, the US Nuclear Regulatory Commission (NRC) completed a team inspection at your Peach Bottom Atomic Power Station, Units 2 and 3. The enclosed inspection report documents the inspection findings, which were discussed at an exit meeting on July 29, 2005,

with Mr. Joseph Grimes, Peach Bottom Plant Manager, and other members of your staff.

This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and the conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

On the basis of the sample selected for review, there were no findings of significance identified during this inspection. The team concluded that problems were properly identified, evaluated and resolved within the problem identification and resolution programs (PI&R). However, during the inspection, several examples of minor problems were identified, including causal evaluations for human performance issues that were not sufficiently thorough to identify the base root cause.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document

Mr. Christopher Crane 2 Room or from the Publically Available Records (PARS) component of the NRCs document 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/ James Trapp signing for Mohamed M. Shanbaky, Chief Projects Branch 4 Division of Reactor Projects Docket No. 50-277, 278 License No. DPR-44, 56

Enclosure:

Inspection Report Nos. 05000277/2005006 & 05000278/2005006 w/Attachment: Supplemental Information

REGION I==

Docket Nos: 50-277, 278 License Nos: DPR-44, 56 Report Nos: 05000277/2005006 & 05000278/2005006 Licensee: Exelon Generation Company, LLC Correspondence Control Desk P.O. Box 160 Kennett Square, PA 19348 Facility: Peach Bottom Atomic Power Station (PBAPS) - Units 2 and 3 Location: 1848 Lay Road Delta, Pennsylvania Dates: July 11 - 29, 2005 Team Leader: B. S. Norris, Senior Project Engineer, Division of Reactor Projects Inspectors: A. L. Burritt, Senior Project Engineer, Division of Reactor Projects R. E. Cureton, Reactor Engineer, Division of Reactor Projects D. C. Johnson, Reactor Engineer, Division of Reactor Projects Observer: J. R. Bream, Summer Co-Op, Division of Reactor Projects Approved by: Mohamed M. Shanbaky, Chief Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000277/2005-006, 05000278/2005-006; 07/11/2005 - 07/29/2005; Peach Bottom Atomic

Power Station; Biennial Baseline Inspection of the Identification and Resolution of Problems The inspection was conducted by four regional inspectors. No findings of significance were identified.

Identification and Resolution of Problems The team determined that the corrective action program at Peach Bottom was adequate. The team determined that Exelon was effective at identifying problems and entering them in the corrective action program (CAP). Once entered into the system, the items were generally screened and prioritized in a timely manner using established criteria. Items entered into the CAP were properly evaluated commensurate with their safety significance. The causal evaluations for equipment issues and events reasonably identified the causes of the problem and developed appropriate corrective actions. However, for some of the issues affecting human performance, the evaluations were not of sufficient depth to identify the base root cause; therefore, the corrective actions did not prevent further human performance errors of a similar nature. In two cases, operability determinations did not consider all the applicable information to support the final conclusion that the equipment was operable. Corrective actions were typically implemented in a timely manner, but the team found that in one case, corrective actions were not adequate to correct the problem, and did not prevent recurrence. Many of the problems the team reviewed were long standing and had been previously identified by internal and external organizations.

a.

NRC Identified and Self-Revealing Findings

None.

b.

Licensee-Identified Violations

None.

ii

REPORT DETAILS

4OA2 Problem Identification and Resolution

Effectiveness of Problem Identification

a. Inspection Scope

The inspection team reviewed the procedures describing the corrective action program (CAP) at Exelons Peach Bottom Atomic Power Station (PBAPS). Exelon identifies problems by initiating Issue Reports for conditions adverse to quality, plant equipment deficiencies, industrial or radiological safety concerns, or other significant issues. The Issue Reports are subsequently screened for operability, categorized by priority (1 to 5)and significance (A through D), and assigned for evaluation and resolution; after the Issue Reports are screened, they become Action Requests. The Issue Reports and Action Requests are referred to as Condition Reports (CRs).

The team reviewed CRs selected across the seven cornerstones of safety in the NRCs Reactor Oversight Program to determine if problems were being properly identified, characterized, and entered into the CAP for evaluation and resolution. The team selected items from the maintenance, operations, engineering, emergency planning, security, radiological control, and oversight programs to ensure that Exelon was appropriately considering problems identified in each functional area. The team used this information to select a risk-informed sample of CRs that had been issued since the last NRC PI&R inspection, which was completed in June 2003.

In addition to CRs, the team selected items from other processes at Peach Bottom to verify that they appropriately considered problems identified in these areas for entry into the corrective action program. Specifically, the team reviewed a sample of work orders, engineering change requests, operator log entries, control room deficiency and work-around lists, operability determinations, engineering system health reports, completed surveillance tests, and current temporary configuration change packages.

The documents were reviewed to ensure that underlying problems associated with each issue were appropriately considered for resolution via the corrective action process. In addition, the team interviewed plant staff and management to determine their understanding of and involvement with the CAP. The CRs and other documents reviewed, and a list of key personnel contacted, are listed in the Attachment to this report.

The team reviewed a sample of Exelons Nuclear Oversight audits and quarterly reports, the departmental self-assessments, and the most recent audit of the CAP. This review was performed to determine if problems identified through these evaluations were entered into the CAP, and whether the corrective actions were properly completed to resolve the deficiencies. The effectiveness of the audits and self-assessments was evaluated by comparing audit and self-assessment results against self-revealing and NRC-identified findings, and current observations during the inspection.

The team considered insights from risk analyses to focus the sample selection and system walkdowns on risk-significant components; the team determined that the five highest risk-significance systems were residual heat removal, emergency diesel generators, high pressure service water, high pressure coolant injection, and reactor core isolation cooling systems. For the selected risk-significant systems, the team reviewed the applicable system health reports, and a sample of work requests, engineering documents, plant log entries, and results from surveillance tests and maintenance tasks. For these selected systems, the team also interviewed cognizant station personnel and completed system walkdowns to assess material condition and system performance.

b. Observations and Findings

No findings of significance were identified.

The team concluded that Exelon was generally effective at problem identification at the Peach Bottom station. The station staff generally had appropriate knowledge of the CAP, and identified problems and entered them into the program at an appropriate threshold. There were approximately 10,000 CRs initiated per year. Station staff promptly initiated CRs, as appropriate, in response to deficiencies or issues raised by the inspection team. Several of the fourteen departmental Functional Area Self Assessments (FASAs) that the team reviewed were not self-critical and identified only minor issues. The majority of the significant issues identified in the CRs that the team reviewed were as a result of an event or an equipment failure. The team noted few significant issues that were the result of a proactive effort, such as trending or system walkdowns.

The team did identify a minor deficiency that Exelon did not recognize. During a 2003 inspection, the NRC identified that Senior Reactor Operators Limited to Fuel Handling (LSROs) were being reactivated without the direct supervision of an active license holder, as required by 10CFR55.53(f)(2), and a non-cited violation (NCV) was issued.

As part of this inspection, the team reviewed Exelons corrective actions for the NCV, as documented in CR A1295039, and found them acceptable. However, during the review of the CR, the team identified a new concern; specifically, that the practice was to have multiple LSROs reactivate their licenses simultaneously with one active SRO. Code of Federal Regulations 10CFR55.53(f)(2) states that the Part 55 licensee must complete the under instruction period ... in the position to which the individual will be assigned.

Specifically, that there is a one-to-one relationship between the active and inactive license holders. For the last two refueling outages at Peach Bottom, the reactivation of the LSROs was not completed on a one-to-one basis. The failure to comply with 10CFR55.53(f)(2) constitutes a violation of minor significance that is not subject to enforcement action in accordance with the NRCs enforcement policy.

2. Prioritization and Evaluation of Issues

a. Inspection Scope

The inspection team reviewed the CRs listed in the attachment to the inspection report to assess whether Exelon adequately evaluated and prioritized the identified problems.

The team selected the CRs to cover the seven cornerstones of safety identified in the NRCs Reactor Oversight Program. The team also considered risk insights from the Peach Bottom Probabilistic Risk Analysis to focus the CR sample. The CRs reviewed encompassed the full range of Exelon evaluations, including root cause analysis, apparent cause evaluations, and common cause analysis. The review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of the resolutions. For significant conditions adverse to quality, the team reviewed Exelons assessment of the extent-of-condition and the determination of corrective actions to preclude recurrence. The team observed the Station Oversight Committee (SOC) and Management Review Committee (MRC)meetings, in which Exelon managers reviewed incoming CRs and evaluated preliminary corrective action assignments, analyses, and plans.

The team reviewed Exelons evaluation of industry operating experience information for applicability to their facility, this review was expanded to five years. The team also reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems. The team assessed the backlog of corrective actions to determine, individually or collectively, if any represented an increased risk due to delays in implementation. The team further reviewed equipment performance results and assessments documented in completed surveillance procedures, operator log entries, and trend data to determine whether the equipment performance evaluations were technically adequate to identify degrading or non-conforming equipment.

b. Observations and Findings

No findings of significance were identified.

The team concluded that Exelon generally screened the CRs appropriately and properly classified them for significance. The items in the engineering and maintenance backlogs had been evaluated for risk, individually and collectively. The team noted that significant conditions adverse to quality received a formal root cause analysis (RCA) and an extent-of-condition review. Less significant conditions typically received an apparent cause evaluation (ACE). A common cause analysis (CCA) was performed to identify common failure modes for selected issues. The majority, approximately 96 percent, of the CRs written were for less significant issues. Additionally, the team determined that the SOC and MRC were effective in reviewing and prioritizing CRs. However, the team noted that the SOC sometimes held a CR for clarification of the issue or additional information before it was passed to the MRC; some of the CRs were delayed by as much as 14 days.

The quality of the RCAs, ACEs, and CCAs was inconsistent. The causal analysis for equipment issues and events were generally good; however, the investigations for the human performance issues reviewed were not as thorough or in-depth. For example: a CR was written for a control rod that was not withdrawn in the proper sequence. The root cause was determined to be ... personnel were not being accountable. The RCA was not thorough in that it did not address the potential underlying causes such as procedure adherence, trainee oversight and supervision, and operator self-checking.

Since the RCA was not in-depth enough, the corrective actions to preclude recurrence were very general and failed to re-enforce the human performance fundamentals.

The quality of certain extent-of-condition reviews were also inconsistent. An example of a narrowly focused extent-of-condition review was for the use of an abrasive cleaning pad to refurbish the brushes on the non-safety related turbine generator exciter. The root cause determined that the copy of the vendor manual did not contain the information that the vendor recommended that abrasive pads not be used. This information was contained in a separate proprietary document. The extent-of-condition was narrowly focused in that the review of vendor manuals was limited to non-safety related generators instead of an extent-of-condition review that included a sampling of all of the non-safety related vendor manuals. The vendor manual group is proactive in getting updates for manuals only for safety-related equipment. The inspectors were told that the reason for the limited scope was because the exciter is not safety-related.

However, Exelon did not consider that the loss of the turbine generator would also cause an initiating event.

The lack of thorough documentation in some of the CRs reviewed made it difficult to understand the issue and resolution. In particular, the level of detail was insufficient in some of the causal analysis to support the conclusions and subsequent corrective actions. In those cases, the inspectors required additional information (verbally and/or additional documentation) from the individual(s) that performed the analysis before they understood the analysis. The inspectors noted that some of the recent RCAs did appear more complete.

In addition, the inspectors identified two examples in which Exelon did not provide sufficient bases to support the operability determinations for degraded or non-conforming conditions.

C The first example involved three safety relief valves (SRVs) that appeared to have lifted below the Technical Specification (TS) required pressure band during the Unit 2 turbine trip and reactor scram transient on July 10, 2005. Exelon identified the premature lifting of the SRVs during their post-trip review. Exelon subsequently determined that the reactor pressure data did not accurately reflect the actual pressure transient, and that the SRVs functioned within the TS required pressure tolerance. The inspectors found that Exelons assessment did not consider all available information, specifically:

(1) the wide range pressure indication during the transient, recorded on a strip chart;

(2) the as-found test history of previous apparent premature SRV lifts during similar transients; and

(3) the delayed closure of the E SRV with two subsequent short duration opening cycles, as shown on the sequence of events printout. After review of the above additional information, the inspectors determined that Exelons conclusion concerning SRV operability was reasonable.

Exelon initiated CR 357841 to address the problems with the thoroughness of this operability review.

C The second example involved the scram solenoid pilot valves for two control rod drive mechanisms. The exhaust diaphragms in the pilot valves had exceeded the recommended service life. The inspectors found that a written operability determination was not prepared until after one of the control rods exhibited an abnormal scram rate. The operability determination only addressed the control rod with the non-conforming time. The operability determination did not address the potential effects of the aged diaphragms. Specifically, the operability determination did not consider:

(1) the manufacturing batch number information provided by the vendor;

(2) related industry operating experience in which diaphragms beyond their recommended service life had hardened and cracked, and caused the failure of the associated control rod to scram; or

(3) environmental factors which could significantly affect the diaphragm degradation rate. Based on a review of the additional information and recent plant scram data, the inspectors determined that the conclusion in the operability determination was reasonable. Exelon initiated CR 357831 to address the level of detail problems with the operability determination.

3. Effectiveness of Corrective Actions

a. Inspection Scope

The team reviewed the corrective actions associated with selected CRs to determine whether the actions addressed the identified causes of the problems. The team reviewed CRs for repetitive problems to determine whether previous corrective actions were effective. The team also reviewed Exelons timeliness in implementing corrective actions and their effectiveness in precluding recurrence of significant conditions adverse to quality. The team reviewed the CRs associated with selected non-cited violations and findings to determine whether Exelon properly evaluated and resolved these issues.

b. Observations and Findings

No findings of significance were identified.

The team concluded that Exelon generally determined corrective actions that were appropriate, effective, and completed in a timely manner. Nonetheless, the team identified an instance where Exelon failed to take adequate corrective actions for a Unit 2 drywell pressure switch (PS-2-05-016) that has repeatedly been found out-of-calibration since October 2000. The function of the pressure switch is to provide an alarm in the control room alerting the operators of changing drywell pressure conditions. The alarm (20C205L F-2, Drywell Hi-Lo Press) response procedure directs the operators to implement the appropriate response procedure for increasing or decreasing drywell pressure. In July 2003, Unit 2 received the drywell pressure alarm at a pressure lower than the expected setpoint of 0.25 psig. The alarm was considered to be functioning in a conservative direction and no action was taken. The alarm subsequently re-occurred seven more times; each time, nitrogen was added to the drywell to raise pressure and clear the alarm. On September 21, 2003, CR 176754 was written to document the repetitive problem, an Equipment Apparent Cause Evaluation was performed. During the teams review of the CR, the inspectors learned that the switch had been calibrated on February 3, 2003, five months before the first alarm, and that the calibration frequency was every two years. The CR noted that the switch was found out-of-tolerance during the last two calibrations. The inspectors reviewed the calibration records of the pressure switch for the last eight years. In August 1998, the switch was within tolerance; in October 2000, February 2003, and September 2003, the pressure switch was found out-of-tolerance during each calibration. During the February 2003 calibration, that the technicians attributed the drift to instrument aging; no corrective actions were taken. The inspectors observed the calibration of the pressure switch on July 27, 2005; both the low and high alarms were found out-of-calibration, CR 357222 was written.

The pressure switch is in the Peach Bottom Maintenance Rule (10CFR50.65) program and classified as risk significant. Exelon procedure ER-AA-520, Instrument Performance Trending, was developed to monitor the results of calibrations of plant instrumentation to identify poor performance, as evidenced by the failure to meet setting tolerances for repeated calibrations. The procedure states that all instruments in the Maintenance Rule are included in the trend program. The results of the drywell pressure switch calibrations were not reviewed or trended by the responsible system engineer. The procedure lists possible corrective actions, including revision of the acceptance criteria, increased calibration frequency, and replacement of the instrument.

Since pressure switch PS-2-05-016 was associated with an alarm function did not provide any protection or control functions, and all automatic systems remained fully operable, the inspectors determined that the repetitive out-of-calibration condition of the drywell pressure switch had no actual safety impact. The issue was determined to constitute a finding of minor significance that is not subject to enforcement action.

4. Assessment of Safety Conscious Work Environment

a. Inspection Scope

During the interviews with station personnel, the team assessed the safety conscious work environment (SCWE) at the Peach Bottom station. Specifically, the team assessed whether people were hesitant to raise safety concerns to their management and/or the NRC. The team also reviewed Exelons Employee Concerns Program (ECP)to determine if employees were aware of the program and had used it to raise concerns.

The team also reviewed a sample of the ECP files to ensure that issues were entered into the corrective action program.

b. Observations and Findings

No findings of significance were identified.

The team determined that the plant staff were aware of the importance of having a strong SCWE and expressed a willingness to raise safety issues. The staff interviewed stated they had never experienced retaliation for safety issues raised, and had an adequate knowledge of the CAP and ECP. Based on these limited interviews, the team concluded that there was no evidence of an unacceptable SCWE.

4OA6 Meetings, including Exit

On July 29, 2005, the team presented the inspection results to Mr. Joseph Grimes, Peach Bottom Plant Manager, and other members of the Peach Bottom staff, who acknowledged the findings. The inspectors confirmed that no proprietary information reviewed during inspection was retained.

ATTACHMENT: Supplemental Information In addition to the documentation that the inspectors reviewed (listed in the Attachment), copies of information requests given to the licensee and email correspondence between the NRC and licensee personnel are in ADAMS, under accession numbers ML052210419 and ML052210429, respectively.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

S. Beck, Corrective Action Program Manager

J. Berg, HPSW System Engineer

R. Braun, Site Vice President

S. Breeding, Manager, Operations Support - Limerick

J. Brozonis, Site ECP Representative

J. Cockroft, Maintenance Rule Coordinator

S. Craig, Acting Security Manager

P. Davison, Director, Engineering

G. Easterday, CAPCo, Work Management

D. Foss, Regulator Assurance Engineer

D. Garcia, CAPCo, Engineering

C. Heimbach, CAPCo, Security

D. Henry, Manager, Engineering Business Support

G. Jardel, Manager, Emergency Preparedness

J. Kovalchick, Operations Support manager

C. Lautenbach, Electrical Maintenance Supervisor

J. Lyter, EOP Program Manager

M. Magness, CAPCo, Chemistry

J. Mallon, Manager, Regulatory Assurance

J. McDaniel, Acting Reactor Engineer Manager

J. McLaughlin, EDG System Engineer

W. Nelle, Regulatory Assurance Engineer

C. Perino, Manager, Nuclear Oversight

J. Popielarski, Manager, Operations Training

C. Rich, Manager, Operations Training - Limerick

G. Rombold, Performance Assessor

G. Stathes, Maintenance Director

T. Van Wyen, CAPCo, Operations

J. Volz, CAPCo, Radiation Protection

J. Wagner, Manager, Maintenance Programs

C. Wiedersum, Manager, Operations Support

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

None