IR 05000277/2010003
| ML102170163 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/05/2010 |
| From: | Paul Krohn Reactor Projects Region 1 Branch 4 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| KROHN P, RI/DRP/PB4/610-337-5120 | |
| References | |
| IR-10-003 | |
| Download: ML102170163 (35) | |
Text
SUBJECT:
PEACH BOTTOM ATOMIC POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000277/2010003 AND 05000278/2010003
Dear Mr. Pacilio:
On June 30,2010, the U. S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Peach Boltom Atomic Power Station (PBAPS), Units 2 and 3.
The enclosed integrated inspection report documents the inspection results, which were discussed on July 16, 2010, with Mr. Thomas Dougherty and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of this inspection, no findings of significance were identified. However, a licensee* identified violation which was determined to be of very low safety significance is listed in this report. Due to the very low safety significance of the finding, and because the finding has been 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 Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U. S. NRC, Washington, DC 20555-0001; and the NRC Senior 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 enclosure, 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 Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Docket Nos.: 50-277,50-278 License Nos.: DPR-44, DPR-56
Sincerely, Paul G. Krohn, Chief Projects Branch 4 Division of Reactor Projects
Enclosure:
Inspection Report 05000277/2010003 and 05000278/2010003 w/AUachment: Supplemental Information
REGION I==
50-277, 50-278 DPR-44, DPR-56 05000277/2010003 and 05000278/2010003 Exelon Generation Company, LLC Peach Bottom Atomic Power Station, Units 2 and 3 Delta, Pennsylvania April 1, 2010 through June 30, 2010 F. Bower, Senior Resident Inspector A. Ziedonis, Resident Inspector F. Arner, Senior Reactor Inspector S. Pindale, Senior Reactor Inspector L. Scholl, Senior Reactor Inspector J. Schoppy, Senior Reactor Inspector K. Young, Senior Reactor Inspector Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000277/2010003,05000278/2010003; 04/01/2010 - 06/30/2010; Peach Bottom Atomic
Power Station (PBAPS), Units 2 and 3; Integrated Inspection.
The report covered a three-month period of inspection by resident inspectors and announced inspections by five senior regional reactor inspectors. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity None.
Other Findings
A violation of very low safety significance, which was identified by the licensee, has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's CAP. This violation and the licensee's corrective action tracking numbers are listed in Section 40A7 of this report.
Summary of Plant Status
REPORT DETAILS
Unit 2 began the inspection period at 100 percent rated thermal power (RTP) where it generally remained until May 21, 2010, when a planned power reduction to 40 percent was conducted to support summer readiness maintenance and testing that included control cell friction testing and single loop operations to replace the 2 'B' reactor recirculation pump breaker. On May 25, 2010, the unit was returned to 100 percent RTP 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 where it generally remained until May 14, 2010, when power was reduced to approximately 60 percent to support summer readiness maintenance and testing. On May 16, the unit was returned to 100 percent RTP where it remained until the end of the inspection period, except for brief periods to support planned testing, rod pattern adjustments, and planned hydraulic control unit (HCU)maintenance.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1 R01 Adverse Weather Protection (71111.01 - 3 Samples)
.1 Grid Reliability (1 Sample)
a. Inspection Scope
The inspectors reviewed plant features and procedures for operation and continued availability of offsite and backup power systems during adverse weather (summer conditions). The inspectors reviewed communication protocols between the control room personnel and electrical system operations, as well as measures prescribed and taken to maintain the availability and reliability of these alternating current systems.
Documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
. 2 External Flooding (1 External Flooding Sample)
a. Inspection Scope
The inspectors reviewed selected risk-important plant design features intended to protect the plant and its safety-related equipment from external flooding events. On May 24, 2010, the inspectors reviewed the Unit 3 external flood barrier breach during planned chemical maintenance treatment (clamtrol) injection into the Unit 3 service water (SW) system. The inspectors walked down the pump structure during the barrier breach condition, reviewed the barrier breach permit, reviewed the station guidance in CC-PB-201, "Hazard Barrier Control Program," and discussed the field condition with operators to verify that the station had appropriate controls in place to mitigate an external flood event during the barrier breach condition. The inspectors reviewed the external flood analyses in Design Bases Document (DBD) P-T-07, "External Hazards,"
selected sections of the Updated Final Safety Analysis Report (UFSAR), and Special Event Procedure, SE-4, "Flood Procedure," to verify that the barrier breach controls were maintained in accordance with the licensing basis. Documents reviewed are listed in the
.
b. Findings
No findings of significance were identified.
. 3 Summer Seasonal Readiness Preparations (1 Seasonal Readiness Sample)
a. Inspection Scope
The inspectors conducted a review of PBAPS's preparations for the 2010 summer conditions to verify selected features of the plant's design were sufficient to protect mitigating systems from the effects of adverse weather. The inspectors reviewed PBAPS's implementation of procedure WC-AA-1 07, "Seasonal Readiness," in preparation for summer season readiness. Documentation for selected risk-significant systems was reviewed to ensure that these systems would remain functional when challenged by inclement weather. During the inspection, the inspectors focused on plant specific design features and the licensee's procedures used to mitigate or respond to adverse weather conditions. The inspectors reviewed the UFSAR and performance requirements for systems selected for inspection. The inspectors reviewed CAP records to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their CAP. In addition, the inspectors reviewed the "Certification of 2010 Summer Readiness" memorandum dated May 14, 2010.
Documents reviewed during this inspection are listed in the Attachment. The inspectors walked down the following systems and equipment:
- High Pressure Service Water (HPSW) Pump Room;
- Emergency Service Water (ESW) Pump Room;
- Emergency Booster Pump Room; and
- Emergency Diesel Generator (EDG) Rooms.
1 R04 Eguipment Alignment (71111.040 - 3 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 selected applicable operations procedures, walked down system components, and verified that selected breakers, valves, and support equipment were in the correct position to support system operation. Documents reviewed are listed in the Attachment.
The three systems reviewed were:
'B' Standby Gas Treatment System (SGTS) Train during 'A' SGTS Maintenance Outage;
- 2 'A' Residual Heat Removal (RHR) Train during 2 'B' RHR Train Outage; and
b. Findings
No findings of significance were identified.
1 R05 Fire Protection (71111.05Q - 6 Samples)
.1 Fire Protection - Tours
a. Inspection Scope
The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment. The inspectors reviewed areas to assess whether PBAPS had implemented the Peach Bottom Fire Protection Plan (FPP) and adequately: controlled combustibles and ignition sources within the plant; maintained fire detection and suppression capability; and maintained the material condition of passive fire protection features. For the areas inspected, the inspectors also verified that PBAPS had followed the Technical Requirements Manual (TRM) and the FPP when compensatory measures were implemented for OOS, degraded or inoperable fire protection equipment, systems, or features. The inspectors verified: that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient combustible materials were managed in accordance with plant procedures; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. Documents reviewed during the inspection are listed in the Attachment. The inspectors toured the following areas:
- Unit 2 Turbine Building, Lubricating Oil Tank Room (Fire Zone 88);
- Unit 2 Reactor Building, Reactor Core Isolation Coolant (RCIC) Room (Fire Zone 60);
- Turbine Building Common, Radiation Chemical Area (Fire Area 78C);
- Unit 2 Turbine Building, Emergency Battery Switchgear Room (Fire Area 127);
- Unit 3 Turbine Building, Emergency Battery Switchgear Room (Fire Area 117); and
- Radwaste Building, Unit 3 Recirculation Pump Motor Generator (MIG) Set Room (Fire Area 12C).
b. Findings
No findings of significance were identified.
1 R06 Flood Protection Measures (71111.06 - 1 Sample)
.1 Internal Flood Protection
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 UFSAR. The inspectors walked down the Unit 3 High Pressure Coolant Injection (HPCI) pump 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. The inspectors also reviewed Exelon's monitoring and control of HPCI pump mechanical seal leakage in this area to ensure the leakage would not adversely impact the operability of the system.
Documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
1 R07 Heat Sink Performance (71111.07T - 2 Samples)
a. Inspection Scope
Based on a plant specific risk assessment, previous inspections, recent operational experience, and resident inspector input, the inspectors selected the following heat sink samples:
- Operation and Performance Testing of the HPSW system; and
- Performance of the Ultimate Heat Sink, which Included HPSW Piping Integrity and Intake Structure Functionality.
The Conowingo Pond, supplied directly from the Susquehanna River, functions as the normal heat sink for both Peach Bottom units. The ESW and HPSW pumps take suction from the Conowingo Pond through the SW pump bays. The ESW pumps are common to both units and supply cooling to the EDG coolers. In addition, ESW also supplies cooling to the emergency core cooling system (ECCS) room coolers, core spray pump motor oil coolers, and RHR pump seal coolers. The HPSW system for each unit provides cooling water for the RHR heat exchangers (HXs) under post-accident conditions. The emergency cooling tower (ECT) provides the heat sink for the safety-related pump bays in the unlikely event that the Conowingo Dam fails or the Conowingo pond floods.
The inspectors reviewed the ESW, HPSW, and intake design to evaluate the adequacy of system monitoring and performance testing. The inspectors reviewed a sample of ESW and HPSW pump and valve performance tests, system health and Generic Letter (GL) 89-13 Program reports, and in-service test (1ST) vibration monitoring results for adverse trends and to verify that the systems functioned as designed. The inspectors verified that Exelon performed the pump and valve ISTs in accordance with American Society of Mechanical Engineers Code requirements. In addition, the inspectors reviewed Exelon's monitoring, maintenance, and testing of interface valves between safety-related SW and non-safety related or non-seismic piping systems to ensure that adequate SW flow is available post-accident consistent with design basis assumptions.
The inspectors reviewed Exelon's buried pipe inspection and monitoring program to independently assess the condition and structural integrity of the HPSW piping. The inspectors reviewed a sample of HPSW pipe nondestructive examination records and intake structure inspections to ensure that Exelon appropriately identified and dispositioned any HPSW piping or intake structure degradation. The inspectors performed an above ground walkdown of accessible areas containing buried HPSW and ESW piping to look for soil subsidence or other indications of piping leakage and/or degradation. The inspectors also directly observed the condition of HPSW and ESW piping in the accessible portions of the SW pump bays, valve pits, and EDG rooms.
The inspectors reviewed Exelon's procedures and processes to control macrofouling of the ESW and HPSW systems. The inspectors also observed the condition of several zebra mussel monitoring locations. The inspectors reviewed Exelon's procedures for ESW, HPSW, and intake structure operation; abnormal SW operations; intake flooding; and for a loss of the Conowingo Pond. The inspectors verified that Exelon maintained these procedures consistent with their design and licensing basis, and that plant operators could reasonably implement the procedures as written. The inspectors independently verified that the HPSW pump bay and intake level instrumentation, which operators rely upon for decision making, was available and functional. The inspectors also reviewed the most recent third party structural inspection of the Conowingo Dam to assess the integrity and availability of the Conowingo Pond heat sink.
The inspectors walked down control room instrument panels, accessible portions of HPSW piping in the turbine and reactor buildings (including the RHR HXs), the ECT, the ESW and HPSW pumps, and the intake area (including the trash racks, outer traveling water screen room, and SW traveling water screens) to assess the material condition and configuration control of these structures, systems and components (SSCs). The inspectors also reviewed a sample of corrective action issue reports (IRs) related to the HPSW and ESW isolation valves, pumps, and piping integrity to ensure that Exelon appropriately identified, characterized, and corrected problems related to these essential SSCs. Documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
==1R11 Licensed Operator Regualification Program (71111.11Q -1 Sample)
==
.1 Resident Inspector Quarterly Review
a. Inspection Scope
On May 3, 2010, the inspectors observed operators in PBAPS's 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 crew's post-scenario critiques. The inspectors discussed the training, simulator scenarios, and critiques with the operators, shift supervision, and the training instructors. The inspectors observed the following scenario:
- PSEG-1109R: Evaluation Scenario.
b. Findings
No findings of significance were identified.
==1R12 Maintenance Effectiveness (71111.12Q - 2 Samples)
a. Inspection Scope
==
The inspectors evaluated PBAPS's work practices and follow-up corrective actions for safety-related SSCs and identified issues to assess the effectiveness of PBAPS's maintenance activities. The inspectors reviewed the performance history of SSCs and assessed PBAPS's extent-of-condition (EOC) determinations for those issues with potential common cause or generic implications to evaluate the adequacy of the PBAPS's corrective actions. The inspectors assessed PBAPS's problem identification and resolution (PI&R) actions for these issues to evaluate whether PBAPS had appropriately monitored, evaluated, and dispositioned the issues in accordance with Exelon procedures, including ER-AA-310, "Implementation of the Maintenance Rule (MR)," and the requirements of 1 0 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance." In addition, the inspectors reviewed selected SSC classifications, performance criteria and goals, and PBAPS's corrective actions that were taken or planned, to evaluate whether the actions were reasonable and appropriate.
Documents reviewed are listed in the Attachment. The inspectors performed the following two samples:
- 2 'C' RHR (System 10) Exceeded MR (a)(1) Unavailability Limit (IR 1084973); and
- Maintenance Activities Associated with Failure Mode Causal Tree (FMCT) for Tritium Leakage Mitigation Efforts (IR 1046838, Activity 6).
b. Findings
No findings of significance were identified.
1 R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 6 Samples)
a. Inspection Scope
The inspectors evaluated PBAPS's implementation of the Maintenance Risk Program with respect to the effectiveness of risk assessments performed for maintenance activities that were conducted on SSCs. The inspectors also verified that the licensee managed the risk in accordance with 10 CFR Part 50.65(a)(4) and procedure.
WC-AA-101, "On-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 PBAPS's 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. Documents reviewed are listed in the Attachment. The inspectors completed six evaluations of maintenance activities on the following:
- Control of Work and Management of Plant Risk, between April 6-7, 2010, during Partial Loss of 3 'A' Main Power Transformer Cooling (IR 1053261);
- Control of Work and Management of Plant Risk, between April 26-30, during Week 1 of 5 of the 11th Annual Independent Spent Fuel Storage Installation Campaign (SF-221);
- Control of Work and Management of Plant Risk, on May 20, 2010, during Troubleshooting and Repair of Backup Nitrogen Supply to the Automatic Depressurization System (ADS) valves (Action Request (AR) A1730354 and ST-M-016-400-3);
- Control of Work and Management of Plant Risk, between May 10-28, 2010, during Transfer of Reactor Protection System Power Supplies for Cooper Substation Tie-In to Off-Site Source 220-08 (Clearance 10000772);
- Control of Work and Management of Plant Risk, between April 4-5, 2010, during on-line steam leak injection repairs to CV-2-08-4018: Main Steam Supply to Recombiner System Control Valve (Operational Technical Decision Making (OTDM)associated with IR 1045319); and
- Control of Work and Management of Plant Risk during and following Identification of a Leak in the Unit 2 'C' RHR HX on June 16 (RT-O-010-630-2).
b. Findings
No findings of significance were identified.
1 R15 Operability Evaluations (71111.15 - 6 Samples)
a. Inspection Scope
The inspectors reviewed six issues to assess the technical adequacy of the operability evaluations, the use and control of compensatory measures, and compliance with the licensing and design bases. Associated adverse condition monitoring plans (ACMPs),engineering technical evaluations, and OTDM documents were also reviewed. The inspectors verified these processes were performed in accordance with the applicable administrative procedures and were consistent with NRC guidance. Specifically, the inspectors referenced procedure OP-AA-108-115, "Operability Determinations," and NRC IMC Part 9900, "Operability Determinations & Functionality Assessments for Resolutions of Degraded or Nonconforming Conditions Adverse to Quality or Safety."
The inspectors also used Technical Specifications (TSs), TRM, UFSAR, and associated DBDs as references during these reviews. Documents reviewed are listed in the
. The following degraded equipment issues were reviewed:
- Operability Evaluation Number 10-002, Engineer Evaluation of Submerged Cable Issue (IR 1048012);
- Operability Evaluation Number 10-003, Unit 3 HPCI 30P038 Inboard and Outboard Seal Leak After Run (IR 1048641);
- Evaluate Utilization of the 2AE018 Reactor Building Closed Cooling Water (RBCCW)
HX with River Water Temperature Greater than 60 Degrees Fahrenheit (AR A1552281 Evaluation 21);
- Unit 2 Control Rod Drive 38-15 Double Notch (IR 1072280);
- GNF-II Quality Update 2010-001: GNF Bent Spacer Flow Vanes; and
- ACMP for Monitoring of 3 'B' Phase Main Power Transformer Combustible Gases (IR 1082693).
b. Findings
No findings of significance were identified.
==1R18 Plant Modifications (71111.18 -1 Sample)
==
.1 Permanent Modifications
a. Inspection Scope
The inspectors reviewed one permanent modification to verify that modification implementation 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, and work order ryvO)reviews; staff interviews; and plant walkdowns of accessible equipment. Documents reviewed are listed in the Attachment. The following engineering change request (ECR)for a permanent modification was reviewed:
b. Findings
No findings of significance were identified.
==1R19 Post-Maintenance Testing (71111.19 - 5 Samples)
a. Inspection Scope
==
The inspectors observed and reviewed completed test records for selected post-maintenance testing (PMT) activities. The inspectors observed whether the tests were performed in accordance with the approved procedures or instructions 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 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. Documents reviewed are listed in the Attachment. The inspectors reviewed five PMTs performed in conjunction with the following maintenance activities:
- E-2 EDG Engine Inspection ryvO R1108074);
- Unit 2 End-of-Cycle Recirculation Pump 'B' Trip Breaker Replacement ryvO C0299083-07);
- Unit 3 HPCI Turbine Trip Level Adjustment (IR 1060963); and
- Unit 3 'B' Core Spray Pump, Valve, Flow and Cooler Functional and 1ST following Planned 'B' Loop Maintenance Outage (ST-O-014-305-3 performed on May 19, 2010).
b. Findings
No findings of significance were identified.
==1R22 Surveillance Testing (71111.22-5 Samples) a.
==
Inspection Scope (3 Routine Surveillances; 1 RCS; and 1 1ST Sample)
The inspectors reviewed and observed selected portions of the following 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 design basis functions. Documents reviewed are listed in the Attachment. The five STs reviewed or observed included:
- ST-O-032-301-3, HPSW Pump, Valve and Flow Functional and 1ST [1 1ST Sample];
- ST-O-020-560-2/3, Units 2 & 3 - Reactor Coolant Leakage Test [1 Reactor Coolant System (RCS) Leakage sample];
- ST-O-010-306-3, 'B' RHR Loop Pump, Valve, Flow, and Unit Cooler Functional and 1ST [1 1ST sample];
- ST-M-071-602-2, Independent Spent Fuel Storage Installation (lSFSI) Casks TN-68-48 through TN-68-64 Drying, Backfilling, and Leak Tests; and
- RT-O-023-302-2, HPCI Turbine Overspeed Trip Reset Time Check / Adjustment and HPCI Auxiliary Oil Pump and Manual Trip Lever Tension Test, performed on May 22,2010.
The inspectors noted that IR 1068090 was entered into the corrective action system to address a question related to the acceptance criteria contained in RT-O-023-302-2, and verified that appropriate corrective actions were taken by PBAPS.
b. Findings
No findings of significance were identified.
1EP6 Drill Evaluation (71114.06 -1 Sample)
a. Inspection Scope
The inspectors evaluated the conduct of a PBAPS emergency drill on May 10, 2010, to identify any weaknesses and deficiencies in classification and notification activities. The drill was conducted, in part, to provide drill and exercise performance (DEP)opportunities for the DEP performance indicator (PI). The inspectors observed operators respond to events in the simulator control room through the declaration and notification of an alert. The inspectors observed the operations shift manager transition emergency response command and control responsibilities to the site emergency director in the technical support center (TSC). The inspectors relocated to the TSC to observe command and control of the emergency response organization and dose assessment as the event escalated to the declaration and notification of a site area emergency, followed by further escalation to a general emergency. The inspectors verified that the event classification and notifications were done in accordance with EP-AA-1007, "Exelon Nuclear Radiological Emergency Plan Annex for PBAPS." The inspectors verified that the drill evaluators correctly counted the drill's contribution in the calculation of the DEP PI. The inspectors also verified that operations personnel in the simulator control room identified weaknesses or deficiencies during the critique of the drill. The following simulated events were classified during this training exercise:
- FG1 - General Emergency, Fission Product Barrier Degradation: Fuel Cladding;
- FS1 - Site Area Emergency, Fission Product Barrier Degradation: Primary Containment; and
- FA 1 - Alert, Fission Product Barrier Degradation: Reactor Coolant System (RCS).
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES (OA)
40A1 Performance Indicator (PI) Verification (71151 - 4 Samples)
Cornerstone: Barrier Integrity
.1 Barrier Integrity Pis (71151 - 4 Samples)
a. Inspection Scope
The inspectors reviewed a sample of PBAPS's submittals for the four Barrier Integrity Pis listed below to verify the accuracy of the data reported. The PI definitions and the guidance contained in Nuclear Energy Institute (NEI) 99-02, "Regulatory Assessment Indicator Guideline," Revision 6, and Exelon procedure LS-AA-2001, "Collecting and Reporting of NRC PI Data," were used to verify that the reporting requirements were met. The inspectors reviewed PI data collected from January 2009 to April 2010. The inspectors compared the graphical representations from the most recent PI report available from the NRC public website to the raw PI data to verify the data was properly included in the report. The Pis reviewed were:
- Unit 2 and Unit 3 RCS Specific Activity (BI01); and
- Unit 2 and Unit 3 RCS Leakage (BI02).
b. Findings
No findings of significance were identified.
40A2 Identification and Resolution of Problems (PI&R) (71152 - 1 Semi-annual Trend Sample; 1 OWA Sample)
.1 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 or specific human performance issues for fOllOW-Up, the inspectors performed screening of all items entered into the licensee's CAP. This was accomplished by reviewing the description of each new AR / IR and attending daily management review committee meetings.
b. Findings
No findings of significance were identified.
. 2 Semi-Annual Review to Identify Trends (1 Semi-annual Resident Inspector Sample)
a. Inspection Scope
The inspectors reviewed lists of CAP items to identify trends (either NRC or licensee identified) that might indicate the existence of a safety issue requiring more detailed inspection follow-up. The inspectors reviewed a list of approximately 6,700 IRs that PBAPS initiated and entered into the CAP action tracking system (Passport) from December 1, 2009 through June 1, 2010. The inspectors also reviewed a list of approximately 3,200 IRs for which corrective actions remained open. The lists were reviewed and screened to complete the required semi-annual PI&R trend review. A sample of 54 Passport IRs (listed in the Attachment) were selected from the list and reviewed in more detail to verify whether the issues were adequately identified and evaluated, and that corrective actions were either closed or planned appropriately. The inspectors evaluated the IRs against the requirements of Exelon procedure, LS-AA-125, and 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action."
b.
Assessments and Observations No findings of significance were identified.
The inspectors noted that during this trend review period, two significant unplanned transients occurred. One involved the trip of the 2 'A'reactor recirculation pump (IR 1026936) and the other involved a Unit 2 load reduction that was performed in response to a loss of isophase bus duct cooling (IR 1008530). The inspectors observed that the PBAPS appropriately performed root cause analyses for these two events. The inspectors also noted that PBAPS performed a root cause analysis of an event involving multiple control rods that had slow scram times during the initial portions of their insertion (IR 1023827). A common cause analysiS was performed to review multiple equipment related reactivity events. The inspectors observed that the licensee appropriately used the CAP and associated analYSis tools to evaluate reactivity management events.
The inspectors observed that PBAPS took appropriate action to perform common cause analyses of two additional areas. The first involved an adverse trend of problem identification and resolution cross-cutting aspects associated with NRC findings (IR 1060396). The second involved security department training and qualification failures that required remediation (IR 1061573). The inspectors also noted that maintenance personnel identified (IR 1059363) a list of historical deficiencies that supported their conclusion that poor operating reliability existed for the glycol chillers in the offgas system and contributed to adverse environmental impacts.
The inspectors noted additional trends related to the following subject areas: tritium (IR 1044318, IR 1024952, IR 1032576, IR 1030952), motor control center (MCC)voltages (IR 1002703, IR 1081198, IR 1081472, IR 1081490, IR 1081496), main turbine master trip solenoid valves (IR1042832, IR 1070301, IR 1076001), submerged cable issues (IR 1030481, IR 1081636, IR 1048012, IR 1022206) and fire induced multiple spurious operations (MSOs) related issues (IR 1053615, IR 985851, IR 106316, IR 1047196). The inspectors also observed a trend of aged issues that remained open during the inspection period that included engineering issues identified during or in preparation for NRC inspections (IR 707459, IR 479833, IR 453385, IR 452577, IR 451634, and IR 762371). The inspectors had discussed these issues and trends with PBAPS personnel.
However, based on the overall review of the selected sample, the inspectors concluded that PBAPS was: appropriately identifying and entering issues into the CAP, adequately evaluating the identified issues, and acceptably identifying adverse trends before they became more safety significant problems.
. 3 Review of Operator Work Arounds (1 OWA Sample)
a. Inspection Scope
As required by IP 71152, "Identification and Resolution of Problems," the inspectors conducted a review of the OWA program to verify that PBAPS was identifying OWAs problems at an appropriate threshold, have entered them in the CAP, and proposed or implemented appropriate corrective actions. The inspectors reviewed the list of OW As and Operator Challenges (OCs) identified and managed in accordance with Exelon Procedure, OP-AA-1 02-103, "OWA Program." Specifically, the review was conducted to determine if any OWAs for mitigating systems affected the mitigating system's safety functions or affected the operators' ability to implement abnormal and emergency operating procedures. The inspectors reviewed the following open OWAs being tracked by PBAPS:
- Unit 3 - HPCI Pump Inboard and Outboard Seal Leakage (AR A1752639).
The inspectors also reviewed the lists of open OCs (deficiencies that are obstacles to normal plant operations), periodically walked down the panels in the main control room, and have reviewed control room deficiencies to identify and be cognizant of:
- Require operations contrary to past training or require more detailed knowledge than routinely provided;
- Require a change from longstanding operational practices;
- Require operation of a system or component in a manner different from similar systems or components;
- Create the potential for the compensatory action to be performed on equipment or under conditions for which it is not appropriate;
- Impair access to required indications, increase dependence on oral communications, or require actions under adverse environmental conditions; and
- Require the use of equipment and interfaces that have not been designed with consideration of the task being performed.
The inspectors accompanied the Unit 2 turbine building equipment operator during dayshift rounds on June 3, 2010, and the Unit 3 reactor building nuclear equipment operator during day shift rounds on June 24, 2010, to observe any potential work around challenges. The inspectors also interviewed operators to determine if any compensatory actions they routinely take are (or should be) categorized as workarounds/challenges. Finally, the inspectors reviewed current operator turnover documentation to determine if there are documented compensatory actions that should be categorized as workarounds!challenges.
b. Findings
No findings of significance were identified.
40A6 Meetings, Including Exit
.1 Commissioner Site Visit and Meeting
On June 2, 2010, Commissioner W. Magwood and members of his staff visited PBAPS, toured the site and met with senior Exelon management. Commissioner Magwood was accompanied by Mr. S. Collins, Regional Administrator, Region I and Mr. P. Krohn, Branch Chief, Region I, Division of Reactor Projects.
. 2 Quarterly Resident
Exit Meeting Summary
On July 16,2010, the resident inspectors presented the inspection results to Mr. Thomas Dougherty and other PBAPS staff, who acknowledged the findings.
Mr. P. Krohn, Chief, USNRC, Region 1, Division of Reactor Projects, Branch 4, attended this quarterly inspection exit meeting. The inspectors asked the licensee whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.
. 3 Triennial Heat Sink Performance
Exit Meeting Summary
On May 21, 2010, the inspectors presented the inspection results to Mr. Thomas Dougherty, Site Vice President, and other members of the Exelon staff. The inspectors verified that no proprietary information was documented.
40A7 Licensee-Identified Violations The following violation of very low significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Policy for being dispositioned as a NCV:
- License Condition 2.C.(11).(b) requires, in part, that PBAPS shall develop and maintain strategies for addressing large fires and explosions. On May 11, 2010, the licensee discovered that equipment used for a single mitigation strategy, described in TSG-4.1, Attachment 15, had been removed from its designated location. The finding was assessed in accordance with IMC 0609, Appendix L, Table 2, and determined to be of very low (Green) safety significance because the finding only impacted an individual mitigation strategy. The licensee restored the equipment and entered the issue into their CAP as IR 01068128.
ATIACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Exelon Generation Company Personnel
- T. Dougherty, Site Vice President
- G. Stathes, Plant Manager
- J. Armstrong, Regulatory Assurance Manager
- M. Weidman, Acting Engineering Director
- R. Franssen, Work Management Director
- J. Kovalchick, Security Manager
- L. Lucas, Chemistry Manager
- P. Navin, Operations Director
- R. Holmes, Radiation Protection Manager
- T. Wasong, Training Director
- C. Esham, System Engineer (Traveling Water Screens)
NRC Personnel
- P. Krohn, Branch Chief
- F. Bower, Senior Resident Inspector
- A. Ziedonis, Resident Inspector
- F. Arner, Senior Reactor Inspector
- S. Pindale, Senior Reactor Inspector
- L. Scholl, Senior Reactor Inspector
- J. Schoppy, Senior Reactor Inspector
- K. Young, Senior Reactor Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Opened/Closed
None
Closed
None
Discussed
None