IR 05000277/2008002
| ML081270699 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/06/2008 |
| From: | Paul Krohn Reactor Projects Region 1 Branch 4 |
| To: | Pardee C AmerGen Energy Co, Exelon Generation Co |
| KROHN, PG | |
| References | |
| IR-08-002 | |
| Download: ML081270699 (27) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION May 6, 2008
SUBJECT:
PEACH BOTTOM ATOMIC POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000277/2008002 and 05000278/2008002
Dear Mr. Pardee:
On March 31, 2008, the United States Nuclear Regulatory Commission (NRC) completed an inspection at your Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The enclosed integrated inspection report documents the inspection results, which were discussed on April 18, 2008, with Mr. M. Massaro and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
The report documents one NRC-identified finding of very low safety significance (Green). This finding was determined to involve a violation of NRC requirements. However, because of the very low safety significance and because it is entered into your corrective action program (CAP),
the NRC is treating the finding as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the 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 NRC, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the PBAPS.
In accordance with Title 10 of the Code of Federal Regulations (CFR), 2.390 of the NRC's
"Rules of Practice," a copy of this letter, its enclosures, 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.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56
Enclosures:
Inspection Report 05000277/2008002 and 05000278/2008002 w/Attachment: Supplemental Information
REGION I==
Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56 Report No.: 05000277/2008002 and 05000278/2008002 Licensee: Exelon Generation Company, LLC Facility: Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 Location: Delta, Pennsylvania Dates: January 1, 2008 through March 31, 2008 Inspectors: F. Bower, Senior Resident Inspector M. Brown, Resident Inspector F. Arner, Senior Reactor Inspector J. Commiskey, Health Physicist R. Fuhrmeister, Senior Project Engineer R. Nimitz, Senior Health Physicist R. Rolph, Health Physicist Approved by: Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000277/2008-002, 05000278/2008-002; 01/01/2008 - 03/31/2008; Peach Bottom Atomic
Power Station (PBAPS), Units 2 and 3; Fire Protection.
The report covered a 3-month period of inspection by resident inspectors and announced inspections by regional health physicists, a senior reactor inspector, and a senior project engineer. One Green non-cited violation (NCV) was identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review.
The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a non-cited violation (NCV) of Technical Specification (TS) 5.4.1, which requires that written procedures be implemented covering the Fire Protection Program. The Fire Drill Performance procedure was inadequately implemented because numerous fire brigade deficiencies were not discussed at the post-drill critique or documented in the fire drill record. The licensee has entered this problem into their CAP for action.
This finding is more than minor because it affects the impairment or degradation of a fire protection feature, specifically, on the ability of the fire brigade to effectively carry out the defense-in-depth attribute of manual fire fighting and is associated with the Mitigating Systems Cornerstone and its respective attribute of human performance. This finding is of very low safety significance because the observed crew was only one of five crews of the site fire brigade team, the other crews had no known problems, and the overall condition of the fire detection and suppression systems had been satisfactory. The finding has a cross-cutting aspect in the area of Problem Identification and Resolution because Peach Bottom Atomic Power Station personnel did not properly identify and assess deficiencies with the fire brigades performance. (IMC 0305, aspect P.3 (a))
(Section 1R05.2).
Licensee-Identified Violations
None.
REPORT DETAILS
Summary of Plant Status
Unit 2 began the inspection period at 100 percent rated thermal power (RTP) until January 4, 2008, when power was reduced to 55 percent for planned waterbox cleaning, control rod testing, and other planned maintenance and testing. On January 6, 2008, the unit was returned to full power where it remained until the end of the inspection period, except for brief periods to support planned testing and rod pattern adjustments.
Unit 3 began the inspection period at 100 percent RTP. On February 1, 2008, the unit was reduced to 57 percent for planned control rod sequence exchange, control rod testing, and other planned maintenance and testing. On February 2, 2008, the 3 D main steam safety relief valve (SRV) temperature unexpectedly increased indicating leakage. The unit was shutdown for an unplanned maintenance outage on February 5, 2008 to replace the SRV. On February 8, 2008, the unit was returned to full power where it remained until the end of the inspection period, except for brief periods to support planned testing and rod pattern adjustments.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R04 Equipment Alignment (71111.04Q - 3 Partial Walkdown Samples)
.1 Partial Walkdown
a. Inspection Scope
The inspectors performed a partial walkdown of three systems to verify the operability of redundant or diverse trains and components when safety-related equipment was inoperable. The inspectors performed walkdowns to identify any discrepancies that could impact the function of the system and potentially increase risk. The inspectors reviewed applicable operating procedures, walked down system components, and verified that selected breakers, valves, and support equipment were in the correct position to support system operation. The three systems reviewed were:
- Unit 3 High Pressure Coolant Injection (HPCI) with the Unit 3 Reactor Core Isolation Cooling (RCIC) Out-of-Service;
- E-4 Emergency Diesel Generator (EDG) with E-2 Out-of-Service.
b. Findings
No findings of significance were identified.
.2 Complete System Walkdown (71111.04S - 1 Sample)
a. Inspection Scope
The inspectors performed a complete system walkdown of the accessible portions of the Unit 3 HPCI system, verifying that accessible breakers, valves and support equipment were properly aligned to support system operation. The inspectors reviewed system operating procedures, piping and instrumentation drawings, walked down control system components and verified that circuit breakers and valves were in the appropriate positions.
b. Findings
No findings of significance were identified
1R05 Fire Protection (71111.05 - 5 Samples)
.1 Fire Protection - Tours
a. Inspection Scope
The inspectors reviewed PBAPSs Fire Protection Plan, Technical Requirements Manual (TRM), and the respective pre-fire action plan procedures to determine the required fire protection design features, fire area boundaries, and combustible loading requirements for the areas examined during this inspection. The fire risk analysis was reviewed to gain risk insights regarding the areas selected for inspection. The inspectors performed walkdowns of five areas to assess the material condition of active and passive fire protection systems and features. The inspection was also performed to verify the adequacy of the control of transient combustible material and ignition sources, the condition of manual firefighting equipment, fire barriers, and the status of any related compensatory measures. The following five fire areas were reviewed for impaired fire protection features:
- Unit 3 HPCI Room, 88 Elevation (Fire Zone 62);
- Unit 3 3 B/3 D Core Spray (CS) Rooms, 916 Elevation (Fire Zone 13A & 13B);
- Unit 2 D CS Instrument Room, 116 Elevation (Fire Zone 5G);
- Unit 2 2 A/2 C CS Rooms, 916 Elevation (Fire Zone 5B); and
- Unit 3 Reactor Recirculation Pump Motor Generator Set Room, 135 Elevation (Fire Zone 12C).
b. Findings
No findings of significance were identified.
.2 Fire Protection - Drill Observation (71111.05A - 1 Sample)
a. Inspection Scope
During a fire protection drill on March 6, 2008, associated with the Unit 3 C reactor feed pump turbine lubricating oil storage room, the inspectors assessed the timeliness of the fire brigade in arriving at the scene, the fire fighting equipment brought to the scene, the donning of fire protective clothing, the effectiveness of communications, and the exercise of command and control by the fire brigade leader (FBL). The inspectors also assessed the acceptance criteria for the drill objectives; the rigor and thoroughness of the post-drill critique; and reviewed the licensees CAP for recent fire protection issues.
b. Findings
Introduction:
A Green NCV of TS 5.4.1 was identified by the NRC regarding the failure to identify and properly document performance deficiencies during a fire post-drill critique, contrary to the Fire Protection Program requirements.
Description:
On March 6, 2008, the inspectors observed a fire drill and the post-drill critique to evaluate the fire brigades performance and the ability of the licensees evaluation team to identify performance deficiencies. The inspectors determined that, while the evaluation team identified some deficiencies, several significant deficiencies were not identified and/or properly documented. The inspector-identified deficiencies included:
- The FBL repeatedly opened the hot door to the fire area with no protective equipment on, contrary to training requirements and drill scenario guidance, creating the possibility of a flashback, subsequent explosion, and personnel injury. The other team members and evaluators failed to identify this during the drill. The inspectors noted that during the critique, the fire brigade, drill coordinator, and drill assistant were given the opportunity to critique the FBLs performance and this deficiency was not identified. Rather than note the deficiency as a weakness, the item was not noted by the evaluators on the fire drill record after it was identified by the inspectors.
- The floor supervisor, who holds a senior reactor operator license and is normally the FBLs supervisor, gave the FBL guidance to swap the lubricating oil pumps in the room with the fire instead of shutting down all lubricating oil pumps in the affected room, which was the more conservative action. The other team members and evaluators failed to identify this during the drill. When the inspectors made this observation, the evaluators concurred and the item was documented as a weakness in the fire drill record.
- The FBL was not aware of the status of the sprinkler system in the fire area, did not attempt to manually actuate it, and was not sure how to check the status of the sprinkler system to ensure it had actuated. This deficiency was not addressed by the drill controller during the critique or recorded on the fire drill record.
- The FBL failed to set the ventilation system to remove the smoke from the room until prompted by the drill coordinator. Since the ventilation system was set to remove smoke from the room, the fire drill record listed this as a strength and failed to mention that the FBL needed prompting to direct this action.
PBAPSs TS 5.4.1 requires, in part, that written procedures be established, implemented, and maintained covering Fire Protection Program implementation. The inspectors reviewed OP-AA-201-003, Fire Drill Performance, and determined that the procedure was not properly implemented, in that, performance deficiencies of the fire brigade were not addressed in the critique as required by Section 4.2.5, Fire Drill Evaluation, Step 1, and that identified deficiencies were not documented in the fire drill record as required by Step 5.
The inspectors determined that the failure to identify and document deficiencies in the post-drill critique was a performance deficiency because the requirements of the Fire Protection Program were not met.
Analysis:
This finding is not suitable for SDP evaluation but has been reviewed by NRC management. As described below, this finding is determined to be of very low safety significance (Green). The assumptions and limitations of the Fire Protection Significance Determination Process (SDP), IMC 0609, Appendix F, specifically exclude fire brigade issues. As such, IMC 0609, Appendix M, Significance Determination Process using Qualitative Criteria, required NRC management review to determine the significance of this finding.
The inspectors determined that this finding was more than minor due to the impairment or degradation of a fire protection feature, specifically, on the ability of the fire brigade to effectively carry out the defense-in-depth attribute of manual fire fighting and suppression. This was based on weaknesses associated with the FBL and floor supervisors performance that were not identified and properly documented during the post-drill critique. In addition, the inspectors determined that the finding was associated with the Mitigating Systems Cornerstone and its respective attribute of human performance. NRC management and the inspectors determined that the finding was of very low safety significance (Green) because the defense-in-depth attribute of the fire brigade was minimally affected, in that, the observed crew was only one of five crews of the site fire brigade team, the other crews had no known problems, and that the overall condition of the fire detection and suppression systems has been satisfactory.
The inspectors determined that this finding has a cross-cutting aspect in the area of PI&R (self and independent assessment because Peach Bottom Atomic Power Station personnel did not properly identify and assess deficiencies with the fire brigades performance.) (IMC 0305, aspect P.3 (a)
Enforcement:
TS 5.4.1 requires that procedures be implemented covering the Fire Protection Program. Procedure OP-AA-201-003, Fire Drill Performance, Section 4.2.5, Fire Drill Evaluation, Step 1, requires that deficiencies of the fire brigade be addressed in the critique and Step 5 requires identified deficiencies be documented on the fire drill record. Contrary to this, on March 6, 2008, the licensee failed to implement the Fire Protection Program when the fire brigades performance deficiencies were not identified during the post-drill critique and several identified deficiencies were not documented on the fire drill record. Because the finding is of very low safety significance and has been entered into PBAPSs CAP (Issue Report (IR) 759361), this violation is being treated as a Green NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy: NCV 05000277/2008002-01; 05000278/2008002-01, Failure to Identify and Document Fire Brigade Deficiencies.
1R06 Flood Protection Measures (71111.06 - 1 Sample)
a. Inspection Scope
The inspectors reviewed selected risk-important plant design features intended to protect the plant and its safety-related equipment from internal flooding events. The inspectors reviewed the flood analysis and Updated Final Safety Analysis Report (UFSAR). The inspectors walked down the Unit 3 reactor building closed cooling water pump and heat exchanger (HX) room to evaluate the condition of penetration seals, watertight doors, and other internal design features to verify that they were as described in the Individual Plant Examination.
b. Findings
No findings of significance were identified
1R07 Heat Sink Performance (71111.07 - 1 Sample)
a. Inspection Scope
Based on a plant specific risk assessment and past inspection results, the inspectors reviewed Exelons program for maintenance and testing of risk-important HXs for the EDGs. Specifically, the review included the program for testing and analysis of the E-4 EDG HXs over three cycles of cleaning and inspection. The inspectors reviewed test results and compared them with acceptance criteria contained within the procedure to verify that all acceptance criteria had been satisfied. The inspectors also reviewed the UFSAR to ensure that HX inspection results were consistent with the design basis.
b. Findings
No findings of significance were identified
1R11 Licensed Operator Requalification Program (71111.11Q - 1 Sample)
Resident Inspector Quarterly Review
a. Inspection Scope
On January 29, 2008, the inspectors observed operators in PBAPSs simulator during licensed operator requalification training to verify that operator performance was adequate, and that evaluators were identifying and documenting crew performance issues. The inspectors verified that performance issues were discussed in the crews post-scenario critiques. The inspectors discussed the training, simulator scenarios, and critiques with the operators, shift supervision, and the training instructors. The evaluated scenario observed for this one sample involved the event listed below:
- 1105 EOP 1, Loss-of-Coolant Accident Requiring Emergency Blowdown, Simulator Evaluation Scenario.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness (71111.12 - 3 Samples)
a. Inspection Scope
The inspectors reviewed three samples of PBAPS=s evaluation of degraded conditions involving safety-related significant structures, systems and components (SSCs) for maintenance effectiveness during this inspection period. The inspectors reviewed PBAPS=s implementation of the Maintenance Rule (MR), and verified that the conditions associated with the referenced condition reports (CRs) were evaluated against applicable MR functional failure criteria as found in the licensee=s scoping documents and procedures. The inspectors also discussed these issues with PBAPS personnel to verify that they were tracked against performance criteria, and that the systems were classified in accordance with MR implementation guidance. Documents reviewed during the inspection are listed in the Attachment. The following conditions were reviewed:
- IR 678935, 3 A Residual Heat Removal (RHR) Pump Trip While in Shutdown Cooling;
- IR 741386, Reactor Water Cleanup System Relief Valves Maintenance History; and
- IR 722535, Unit 2 A & B Vent Stack High/Trouble Alarms - MR Functional Failure.
The inspectors also verified that issues of minor significance were entered in the CAP to address an incorrect maintenance preventable functional failure (MPFF) determination (IR 726973), and a procedure error (IR 726903) that led to the incorrect MPFF determination.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 5 Samples)
a. Inspection Scope
The inspectors evaluated PBAPS=s implementation of their maintenance risk program with respect to the effectiveness of risk assessments performed for maintenance activities that were conducted on SSCs, and verified that the licensee managed the risk in accordance with 10 CFR Part 50.65(a)(4) and procedure WC-AA-101, AOn-line Work Control Process. The inspectors evaluated whether PBAPS had taken the necessary steps to plan and control emergent work activities and to manage overall plant risk. The inspectors selectively reviewed PBAPSs use of the online risk monitoring software, and daily work schedules. The activities selected were based on plant maintenance schedules and systems that contributed to risk. The inspectors completed five evaluations of maintenance activities on the following:
- Rework Support and Resecure Valve for Instrument Nitrogen B Header Supply to Drywell, AO-3969B (Work Order (WO) C0223676);
- Loss of Station Blackout Capability at Peach Bottom (IR 736060);
- Unexpected Voltage Measured During Primary Containment Isolation Valve Group II Logic System Functional Test (IR 741321);
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations (71111.15 - 6 Samples)
a. Inspection Scope
The inspectors reviewed six issues to assess the technical adequacy of the evaluations, the use and control of compensatory measures, and compliance with the licensing and design bases. Associated adverse condition monitoring plans, engineering technical evaluations, and operational and technical decision making documents were also reviewed. The inspectors used TS, TRM, UFSAR, and associated Design Basis Documents (DBDs) as references during these reviews. The issues reviewed included:
- Evaluation of Part 21 Report on Basler Electric Auto Voltage Regulator Card Solder Joints (IR 675297);
- Lowering Speed on 3 A Reactor Recirculation Pump (IR 723484);
- SRV 71 D Elevated Tailpipe Temperature Post-P3R16 (IR 705250);
b. Findings
No findings of significance were identified.
1R18 Plant Modifications (71111.18 - 1 Sample)
a. Inspection Scope
The inspectors reviewed one temporary modification to verify that implementation of the modification did not place the plant in an unsafe condition. The review was also conducted to verify that the design bases, licensing bases, and performance capability of risk significant SSCs had not been degraded as a result of these modifications. The inspectors verified the modified equipment alignment through control room instrumentation observations, UFSAR, drawings, procedures, WO reviews, and plant walkdowns of accessible equipment. The following temporary modification was reviewed:
- Engineering Change Request (ECR) 08-00064, Temporarily Disables the Alarm Functions for Turbine Bearing #6.
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing (71111.19 - 7 Samples)
a. Inspection Scope
The inspectors observed selected portions of post-maintenance testing (PMT) activities and reviewed completed test records. The inspectors determined whether the tests were performed in accordance with the approved procedures and assessed the adequacy of the test methodology based on the scope of maintenance work performed.
In addition, the inspectors assessed the test acceptance criteria to evaluate whether the test demonstrated that the tested components satisfied the applicable design and licensing bases and the TS requirements. The inspectors reviewed the recorded test data to verify that the acceptance criteria were satisfied. The inspectors reviewed seven PMTs performed in conjunction with the following maintenance activities:
- Passport WO 0633733501, Peach Bottom 65 CB, Station Could Not Close Breaker;
- R1029073, Inspect/Rework Unit 3 Service Water Strainer BS-3897;
- WO C0220220, Replace Emergency Service Water (ESW) Piping;
- WO A1650073, AP-3-16-3969B Failed to Stroke Closed;
- WO A1646094, Degraded Sealing Surface on One High-Efficiency Particulate Air (HEPA) Filter Gasket; and
b. Findings
No findings of significance were identified.
1R20 Refueling and Other Outage Activities (71111.20 - 1 Sample)
Unit 3 Maintenance Outage
a. Inspection Scope
An unplanned Unit 3 maintenance outage began on February 5, 2008. The inspectors observed selected portions of the plant shutdown and planned reactor scram. Following the shutdown, the inspectors accompanied plant personnel on the initial walkdown of containment to verify that no significant leaks or adverse material condition issues existed. Following completion of work to replace the 71 D SRV, the inspectors performed a walkdown of containment on February 6, 2008, in preparation for containment closure prior to plant startup. Particular attention was given to the areas where work was completed. The inspection was conducted to verify no evidence of leakage and to verify that debris had not been left which could affect performance of the emergency core cooling (ECCS) system strainers. Observed issues were identified to accompanying plant personnel for resolution. On February 7 and 8, 2008, the inspectors observed selected portions of the Unit 3 startup and power ascension following the maintenance outage.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing (71111.22 - 8 Samples)
a. Inspection Scope
The inspectors reviewed and observed selected portions of selected surveillance tests (STs), and compared test data with established acceptance criteria to verify the systems demonstrated the capability of performing the intended safety functions. The inspectors also verified that the systems and components maintained operational readiness, met applicable TS requirements, and were capable of performing the design basis functions.
The eight STs reviewed and observed included:
- ST-M-40D-910-2, Control Room Emergency Ventilation Filter Train B Test;
- ST-O-010-301-3, A RHR Loop Pump, Valve, Flow and Unit Cooler Functional and Inservice Test [IST Sample];
- ST-O-020-560-2/3, Reactor Coolant Leakage Test [Leakage Sample];
- SI2L-2-72-B1FQ, Functional Test of ECCS B Compensated Trip System;
- SI3L-2-72-A1FQ, Functional Test of ECCS A Compensated Trip System;
- SI2R-63E-2979-A1CE, Vent Stack Radiation Monitor RY-2979A Electronic Calibration Check;
- ST-O-052-202-2, E-2 Diesel Generator Slow Start and Full Load Test; and
- ST-O-37D-340-2, Diesel-Driven Fire Pump Runs.
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation (71114.06 - 1 Sample)
a. Inspection Scope
The inspectors evaluated the conduct of a PBAPS emergency drill on March 25, 2008, to identify any weaknesses and deficiencies in classification, notification and protective action recommendation development activities. The inspectors observed emergency response operations in the simulated control room to verify that event classification and notifications were performed in accordance with the emergency plan.
The inspectors attended the pre-drill briefing of exercise controllers and evaluators, and the post-drill critique to compare any inspector-identified weakness with those identified by PBAPS in order to verify that the licensee was properly identifying failures and areas for improvement.
b. Findings
No findings of significance were identified.
RADIATION SAFETY
Cornerstone: Public Radiation Safety
2PS2 Radioactive Material Processing and Transportation (71122.02 - 1 Sample) Shipment Preparation
a. Inspection Scope
On February 21, 2008, the inspectors observed a non-exempt radioactive material shipment (#0208-13600) in preparation. The inspectors observed shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifests, shipping papers provided to the driver, and licensee verification of shipment readiness. The inspectors verified that the receiving licensee was authorized to receive the shipment packages.
The inspectors performed a review to verify that the licensees procedures for cask loading and closure were consistent with the vendors current approved procedures, Safety Analysis Report (SAR) and Certificate of Compliance (C of C).
The inspectors selectively reviewed the training of personnel conducting the package loading, closure, survey, and shipping activities relative to the training specified in NRC Bulletin 79-19 and 49 CFR 172, Subpart H.
The review was performed against criteria contained in 10 CFR 20, 10 CFR 61, 10 CFR 71, Department of Transportation requirements as contained in 49 CFR 170-189, station procedures, applicable disposal facility licenses, and applicable C of C of vendor procedures for various shipping casks.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification (71151 - 6 Samples)
Cornerstone: Initiating Events
a. Inspection Scope
The inspectors sampled PBAPSs submittals for the PIs listed below for Units 2 and 3 for the fourth quarter of 2007. PI definitions and guidance contained in Nuclear Energy Institute 99-02, Regulatory Assessment Indicator Guideline, Revision 5, were used to verify the basis in reporting for each data element.
- Unplanned Scrams;
- Unplanned Scrams with Complications; and
- Unplanned Power Changes.
The inspectors reviewed portions of the operating logs and raw PI data developed from plant recorder traces. The inspectors compared graphical representations from the most recent PI report to the raw data to verify that the data were correctly reflected in the report.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems (PI&R) (71152 - 1 Sample)
.1 Routine Review of Items Entered into the CAP
a. Inspection Scope
As required by Inspection Procedure (IP) 71152, Identification and Resolution of Problems, and in order to help identify repetitive equipment failures and human performance issues for follow-up, the inspectors performed routine screening of issues entered into PBAPSs CAP. The review was accomplished by selectively reviewing copies of IRs and accessing PBAPSs computerized database.
b. Findings
No findings of significance were identified.
.2 Annual Sample - Unit 3 Torus Corrosion Products (1 Sample)
a. Inspection Scope
The inspectors reviewed Exelons actions regarding higher than expected amounts of sludge and rust that were identified on the downcomers of the Unit 3 torus during the October 2007 refueling outage. Specifically, the inspectors reviewed Exelons evaluation of the issue, with particular focus on the potential impact to design bases assumptions for debris loading on the ECCS pump suction strainers. The inspectors reviewed Exelons technical evaluations for both past operability and future operability considering the amount of sludge accumulation initially discovered, and the amount which remained on the downcomers at the end of the refueling outage. The inspectors reviewed Exelons conclusions relative to the impact on Core Spray and RHR pump net positive suction head analyses considering the amount of corrosion product debris loading. Additionally, the inspectors reviewed Exelons apparent cause report (CR 682042) which was initiated to investigate the adequacy and implementation of process controls given the amount of residual semi-solid sludge encountered in the Unit 3 torus.
This review was performed to ensure Exelons proposed and completed corrective actions were adequate.
b. Findings and Observations
No findings of significance were identified. The inspectors determined that Exelon had used a nonconservative assumption in their initial technical evaluation of the acceptability of the amount of sludge remaining in the Unit 3 torus at the end of the refueling outage. The inspectors determined that a sludge density factor used to estimate how much sludge remained on the downcomers was not valid because the area of each bay within the torus had been overestimated. Exelon initiated action request (AR) 683747 to revise the evaluation and eliminate the use of the density factor.
The inspectors determined this error to be of minor significance as the corrosion product estimate for the next cycle of operation remained within the ECCS suction strainer design basis analysis assumptions. With respect to a past operability determination, the inspectors agreed with Exelons conclusion that the ECCS pumps had not been affected by the estimated amount of sludge debris found in the Unit 3 torus.
The inspectors found the apparent cause report to be thorough and self critical in that Exelon identified that ineffective cleaning and weak evaluations of sludge accumulation had occurred over the years. The inspectors determined that the proposed corrective actions were reasonable with respect to preventing excessive accumulation of debris going forward. Additionally, Exelon effectively used operating experience during their review of the issue.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On April 18, 2008, the resident inspectors presented the inspection results to Mr. M. Massaro and other PBAPS staff, who acknowledged the findings. The inspectors asked the licensee whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.
4OA7 Licensee-Identified Violations
None.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Exelon Generation Company Personnel
- J. Grimes, Site Vice President
- M. Massaro, Plant Manager
- J. Armstrong, Regulatory Assurance Manager
- C. Behrend, Engineering Director
- L. Bunner, Work Management Director
- C. Jordan, Chemistry Manager
- R. Franssen, Shift Operations Superintendent
- G. Stathes, Operations Director
- S. Taylor, Radiation Protection Manager
- W. Trump, Security Manager
- T. Wasong, Training Director
- J. Chizever, Mechanical Design Engineer
- S. Stahl, Programs Engineer
- H. McCrory, Radiation Protection Technical Support Manager
- C. Tubman, Shipping Specialist
- H. Miller, Shipping Specialist (Limerick Generating Station)
- R. Smith, Senior Regulatory Assurance Engineer
- M. Ross, Radwaste, Environmental Supervisor
NRC Personnel
- F. Bower, Senior Resident Inspector
- M. Brown, Resident Inspector
- F. Arner, Reactor Inspector
- J. Commiskey, Health Physicist
- R. Fuhrmeister, Senior Project Engineer
- R. Nimitz, Senior Health Physicist
- R. Rolph, Health Physicist
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Opened/Closed
- 05000277/278/2008002-01 NCV Failure to Identify and Document Fire Brigade Deficiencies (Section 1R05.2)
Closed
None
Discussed
None