IR 05000277/2011005
| ML12041A323 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/10/2012 |
| From: | Paul Krohn Reactor Projects Region 1 Branch 4 |
| To: | Pacilio M Exelon Nuclear, Exelon Generation Co |
| krohn, pg | |
| References | |
| IR-11-005 | |
| Download: ML12041A323 (59) | |
Text
UNITED STATES N UCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD KING OF PRUSSIA. PA 19406-1415
SUBJECT:
PEACH BOTTOM ATOMIC POWER STATION - NRC INTEGRATED I NSPECTlON REPORT O5}OO277 t20 1 1 005 AND 0500 027 81201 I 005
Dear Mr. Pacilio:
(NRQ)-co.lnpleted an On December 31 ,201'1, the U. S. Nuclear Regulatory Commission -
Units 2 and 3'
integrated inspection at'your Peach Bottom Atomic Power Station (PBAPS),
were Thelnclosed integrated inspection report documents the inspection results, which Peach Bottom Site Vice President'
discussed on January 2,0t,2b12, with Mr. Thomas Dougherty, and other members of Your staff.
relate to safety and The inspection examined activities conducted under your license as they conditions of your license.
compliance with the Commission's rules and regulations and with the and interviewed The inspectors reviewed selected procedures aid records, observed activities, personnel.
finding of very low This report documents one self-revealing finding and one inspector-identified safety significance (Green). One finding was d_etermined to involve a violation of NRC to be of iequiiem-ents. Additionallf, two license6-identified violations, which were determined of the very low safety very low safety significanie, are listed in this report. However, because your corrective action program (CAP), the NRC significance and because they are entered into non-"ited violations (NCVs;, consistent with Section2'3'2 of the ir-tr".ting the findings NRC's Enforcemenieoti"y.
"
"" lf you contest any NCVs in this report, you should provide a.
for your denial, tct within go iavs of tn"'d"t" of this inspection rep_ort, with the basis -
20555-Nuclear Regutatory Commission, ATTN: bocument'Control Desk, Washingtorr,-DC
'"rponr" the Otfice of Enforcement, 0001; with copi6s to the Regional Administrator, Region l; the Director, Resident lnspector at the U. S. NRC, Washington, Di 20555-0001, and the NRC Senior pBApS. tn additiori ii Vb, disagree with ihe cross-cutting aspects assigned.to the findings in date of this inspection, with the this report, you should provide a response within 30 dayJ of the the NRC Resident nasis ior your disagieement, to the Regional Administrator, Region 1, and lnspector at 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).
f,*/zM
Sincerely, Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Prolects Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56
Enclosure:
Inspection Report 0500027712011005 and 0500027812011005 w/Attachment: Supplementary lnformation
REGION I Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56 Report No.: 05000277 120 1 1 005 and 0500027 81201 1005 Licensee: Exelon Generation ComPanY, LLC Facility: Peach Bottom Atomic Power Station, Units 2 and 3 Location: Delta, Pennsylvania Dates: October 1,2011 through December 31,2011 Inspectors: S. Hansell Senior Resident Inspector A. Ziedonis, Resident InsPector S. Barr, Senior Emergency Preparedness lnspector E. Miller, Region 1 Project Engineer R. Nimitz, Senior Health PhYsicist J. Tomlinson, Operations Engineer K. Young, Senior Reactor lnsPector Approved by: Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
tR 05000227t2011005, 0500027812011005; 1010112011 - 1213112011; Peach Bottom Atomic
Power Station (PBAPS), Units 2 and 3; Maintenance Effectiveness and Radioactive Gaseous and Liquid Effluent Treatment.
The report covered a three-month period of inspection by resident inspectors and announced inspeciions performed by regional inspectors. One self-revealing (Green) finding and one inspector-identified finding were identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter (lMC) 0609, "Significance Determination Process" (SDP). The cross-cutting aspect associated with the findings was determined using IMC 0310, "Components Within the Cross-Cutting Areas." Findings forwhich the SDP does not apply may be Green, or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is describeO inNUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
Cornerstones: Initiating Events, Mitigating Systems, and Barrier lntegrity
- Green.
The inspectors determined that Exelon's failure to promptly correct a condition aOverse to quality associated with a safety-related motor-operated valve (MOV)constituted a Green, self-revealing NCV of 10 CFR Part 50, Appendix B, Criterion XVl,
"Corrective Action." Specifically, corrective actions to prevent recurrence of MOV program testing failures due to degraded stem lubrication in 2009 were not performed in a timely manner to prevent the inoperability of a safety-related MOV due to degraded lubricaiion, as identified on September 22,2011. PBAPS entered this issue into the CAP via issue reports (lRs) 1266600 and 1266604'
This finding was more than minor because it was associated with the configuration control attribute of the Barrier Integrity (Bl) cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the pu-Oti" from iadionuciide releases caused by accidents or events. Specifically, the Unit 3 reactor water cleanup (RWCU) outboard isolation valve MO-3-12-018 did not develop sufficient thrust at the torque switch trip setpoint during diagnostic testing on September 22, 2011. The RWCU MOV would not have been able to perform its safety function to close during the most limiting design condition. Using the Phase worksheet in
'1 Appendix a of IMC 0609, "SDP," the finding affected the Bl cornerstone and was of very low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of containment.
This finding had a cross-cutting aspect in the area of Problem ldentification & Resolution (pl&R), CAP, because Exelon did not take appropriate corrective actions to address the adverse trend of degraded stem lubrication on a safety-related MOV in a timely manner (Section 1 R12) IP.1(d)1.
Cornerstone: Public Radiation Safety
- Green.
The inspectors identified a Green finding associated with the failure to establish, imptement, and maintain adequate quality assurance (QA) program elements in the area of effluent and environmental monitoring as required by Peach Bottom, Units 2 and 3 Technical Specification (TS), Section 5.4.1. Specifically, Exelon's QA program for effluent and environmental monitoring was not sufficient to ensure: 1) that both adequate and timely evaluation and assessment of changes described in the Public Land Use Census were conducted for purposes of dose validation and sampling program modification; 2) that changes in meteorological parameters, used for public dose projections and assessment, were promptly and adequately evaluated; and 3) that laboratory QA programs for effluent and environmental sample analysis measurement systems were adequate and implemented properly. Exelon placed thes_e issues in its inp as Action Requests (ARs): 1226969, 1226202,1299543, 1299476,1302720, and 1303308.
The finding is more than minor because it is associated with the Public Radiation Safety cornerstone attribute of programs and processes and adversely affected the associated cornerstone objective in that failure to establish, implement, and maintain an adequate QA program in the effluents and environmental monitoring program area adversely affected the licensee's ability to ensure adequate protection of public health and safety.
The finding was assessed for significance using IMC 0609, Appendix D, and determined to be of very tow safety significance (Green) because: the issue was contrary to TSs and is a radioactive effluent release program deficiency; there was no indication of a spill or release of radioactive material on the licensee's site or to the offsite environs that would impact public dose assessment, and there was no substantialfailure to implement the radioactive effluent release program. The licensee re-assessed the dose to members of the public from routine releases and determined that projected doses did not, nor were likely to, exceed applicable limits, including as low as is reasonably achievable (ALARA) design specifications of 10 CFR Part 50, Appendix l; or 10 CFR 20.1301(e). The cause of this finding is related to the cross-cutting area of Human Performance, Work Practices, Aspect H.4(b) because the licensee did not ensure personnelfollowed procedure compliance requirements activities for effluent and environmental monitoring program. (Section 2RS06) tH.4(b)1.
Other Findings
Two violations of very low safety significance, which were identified by the licensee, have been reviewed by the inspectors.' CoireCtive actions taken or planned by Exelon have been entered into the CAp. Tnese violations and the corrective action tracking numbers are listed in Section 4OA7 of this report.
REPORT DETAILS
Summarv of Plant Status Unit 2 began the inspection period at 100 percent rated thermal power(RTP)- On November power to approximatelyS0 percent to perform main turbine valve 19, 2011,-operators reduced'
'C' reactoi feed pump (RFP).
The unit was returned to testing, and'planned maintenance on the the end of the inspection 100 p-ercent RTp the next day. The unit remained at RTP through period, except for brief periodi to support planned testing and rod pattern adjustments.
(RFO) (P3R18) Ol Unit 3 began the inspection period shutdown for the 18th refueling outage october i3, the reactor mod'e switch was placed in start-up and the unit was synchronized to the grid on October 14. On October 17, the unit was returned to 100 percent RTP.
On October 26' in unplanned downpower was performed to approximately 79 percent to remove the 'B' RFP The from service to repair an oil leak in the feed pump turbine speed control hydraulic system.
unit was returned to 100 percent RTP later that same day following successful repairs' On performed to swap the November 30, an emergent downpower to approximately 94 percent was
'B' recirculation pump motor generator (MG) set due to in-service lubricating oiipump for trre elevated noise and iibrations associated with the 'E' lube oil pump.
After placing the 'F' lubricating oil pump in-seryice, the unit was returned to 100 percent power later that same day.
periods to support Unit 3 reriained at RTp until the end of the inspection period, except for brief planned testing and rod pattern adjustments'
REACTOR SAFETY
Gornerstones: lnitiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection (71111'01 - 1 sample)
Readiness for Seasonal Extreme Weather Conditions a.
lnspection ScoPe cold The inspectors performed a review of PBAPS's readiness for the onset of seasonal steam supply, temperatur"s. The review focused on the auxiliary boiler system heallng emergency diesel generators (EDGs), emergency service water (ESW) and high pressure service wlter (HPSW) pump rooms, the outer intake cooling water pump structure building, and the innei intake cooling water screen structure' The inspectors reviewed tfre UplO'ated Final Safety Analysis Report (UFSAR), Technical Specifications (TSs), control room logs, and the CAP to determine what temperatures or other personnel had seasonal weather could challenge these systems, and to ensure PBAPS procedures, adequately prepared for these challenges. The inspectors reviewed station including pgnpS's seasonal weather preparation procedure and applicable operating procedures. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems verify that during cold weather conditions. The inspectors also reviewed CAP items to pBApS was identifying adverse weather issues at an appropriate threshold and entering procedures.
Documents them into their CAP iriaccordance with station corrective action reviewed for each section of this inspection report are listed in the Attachment.
b. Findinqs No findings were identified.
1R04 Equipment Aliqnment
Partial Svstem Walkdowns a. lnspection ScoPe The inspectors performed partial walkdowns of the following three systems:
o Unit 3, alternate reactor pressure vessel injection with residual heat removal (RHR), on October 11,2011
.
Unit 3, standby liquid control (SLC) during Unit 2 SLC unavailability on November 15,2011
.
E-4 EDG availability during E-3 fuel oil transfer pump suction problem on December 14,2011 The inspectors selected these systems based on their risk-significance relative to the Reactor Safety cornerstones at the time they were inspected. The_inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, TSs, work orders (WOs), condition reports (CRs), and the impact of ongoing work a.ctivities on redundant irains'of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether PBAPS siaff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.
b. Findinqs No findings were identified.
1R05 Fire Protection
Resident nspector Quarterlv Walkdq\,Vns I
a.
lnspection ScoPe The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that pBAPS controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out-of-service, degraded or inopera'ble fire protection equipment, as applicable, in accordance with procedures' Unit 3, reactor building (RB) north and south control rod drive equipment areas, elevation 135'-0 inches on November 9 (Fire Zones PF-13H and 13P)a Unit 3, refuel floor, elevation 234'-0 inches on November 9 (Fire Zone PF-55)
Unit 2, RB closed loop cooling water room, elevation 1 16'-0 inches on November o
(Fire Zone PF-5F)
.
Unit 2 reaclor recirculation MG and alternate shutdown area on November 10 (Fire Zone PF-4C)o HPSW and ESW intake structure on November 14 (Fire Zone 144)b.
Findinqs No findings were identified.
1R1 1 Licensed operator Requalification Proqram (71111.11)
.1 Resident Inspector Quarterlv Review
a.
Inspection ScoPe The inspectors observed licensed operator simulator training on November 7, which included a loss of offsite electrical power with a failure of one emergency bus to load-,
failure of the reactor core isolation cooling (RCIC) system to operate, and a failure of high pressure coolant injection (HPCI) system to automatically start. The inspectors ev:aluated operator performance during ihe simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed tfre clarity and effectiveness of communications, the implementation of aciions in response to alarms and degrading plant conditions, and verified oversight and direction provided by the control room supervisor. The inspectors the accuracy and timeliness of the emergency classification made by the shift manager (SM), the SM's identification of TS action statements, and the shift technical advisor's of the verification of the SM's decisions. Additionally, the inspectors assessed the ability crew performance problems.
crew and training staff to identify and document b.
Findinos No findings were identified.
and
.2 actor Operators (71111'11B - 1 sample)
Inspection Scope review On Decem ber 21,20j1, one NRC region-based inspector conducted an in-office exam of the licensee-administered annual operating tests and comprehensive w_ritten peach Bottom Limited Refueling Senior Reactor Operators for results for Limerick and pass rates were consistent with the guidance of 2.011. The inspection assessed whether NRC Manual Chapter 0609, Appendix l, "Operator Requalification Human Performance SDP." The insPector verified that:
o Individual pass rates on the written exam were greater than 80 percent' (Pass rate was 100 Percent)
.
Individual pass rates on the job performance measures of the operating exam were greater than 80 percent. (Pass rate was 91 percent)
.
lndividual pass rates on the simulator operating exam were greater than 80 percent.
(Pass rate was 100 Percent)
.
Overall pass rate among individuals for all portions of the exam was greater than or equal to 75 percent. (Overall pass rate was 91 percent)b. Findinqs No findings were identified.
1R12 Maintenance Effectiveness (71111'12Q - 2 samples)
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structures, systems, and components (SSCs) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance WOs, and maintenance rule (MR) basis documents to ensure that PBAPS was identifying and properly evaluating performance problems ryitJ,f the scope of the MR. For seletted, the inspectors verified that the SSC was properly scoped into"".lirarple the MR in accordance with 10 CFR 50.65 and verified that the (aX2)performance criteria established by PBAPS staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return tnese'SSCs to (a)(2). Additionally, the inspectors ensured that PBAPS staff was identifying and addressing common cause failures that occurred within and across MR system boundaries.
o Unit 3 RWCU system leaks on October 16 and 22,2011 o Unit 3 RWCU outboard isolation MOV diagnostic testing failure and degraded lubrication on November 14, 15, and 21 , 2011 b. Findinqs
Introduction.
The inspectors determined that Exelon's failure to promptly correct a condition adverse to quality
'tO associated with a safety-related MOV constituted a Green, self-revealing NCV of ifn 50, Appendix B, Criterion XVl, "Corrective Action."
Speci1cally, iorrective actions to prevent recurrence of MOV program testing failures due to degraded stem lubrication in 2009 were not performed in a timely manner to prevent thL inoperability of a safety-related MOV due to degraded lubrication, as identified on SePtember 22.
Description.
During as-found diagnostic testing performed by Exelon on September 22, the unit 3 RWCU o-utboard Mov Mo-3-12-018 did not develop sufficient thrust at the torque switch trip setpoint to ensure that the valve would close under the most limiting design basis differeniial pressure scenario. Subsequent inspeclionby Exelon maintenance personnel determined that the MOV stem lubrication, Exxon Nebula EP-1' was dry and caked on the valve stem with no functioning lubricant on the stem threads.
pBApS determined that the cause of the underthrust condition was attributed to degraded stem lubrication and the resultant increased coefficient of friction on the valve stem. lmmediate corrective actions included cleaning and removing the Nebula EP-1 grease, applying MOV Long-Life grease to the valve stem, and performing successful Is-left diagnostic testing. PBAPS-'s extent-of-condition (EOC) efforts are summarized in the last paragraph of the "Description" section of this finding' pBApS root cause evaluation report 892191-08 determined that degraded MOV stem lubrication resulted in four safety-related MOV program test failures in March and April of 2009. pBAPS performed multiple corrective actions to address the 2009 MOV program testing failures, as well as an EOC scoping that included inspection, diagnostic testing, and/oi corrective maintenance on 45 safety-related MOVs in March and April of 2009.
Additional corrective actions included revising MOV program procedures and preventive maintenance (PM) frequencies. PBAPS also identified degraded Nebula EP-1 grease on MOV program valves in 2006, 2007, and 2008, as discussed in root cause evaluation ieport Agbt g-1-Oe, Attachment 1 . The root cause evaluation identified that PBAPS had the longest allowable MOV PM lubrication intervals (10 years) in the United States nuclear-industry. Another factor related to MOV stem lubrication, the vendor cancelled production of lriebula EP-1 in 2001, stating a one-ye_ar limited shelf life. Additionally, Lxelon internal operating experience identified a MOV test failure due to degraded stem lubrication at Braidwood on June 21 ,2010. As a result of the PBAPS and Braidwood degraded MOV grease events, Exelon has initiated corporate actions to transition all sites from Nebula EP-1 to MOV Long-Life by the end of 2014' Root cause evaluation report 892191-08 required changing the MOV stem lubricant program to MOV Long-Life grease as a corrective action to prevent recurrence of MOV testing failures Oue to degraded stem lubrication. PBAPS implemented a risk-informed susceptibility to if ign,heOium and tow riif) corrective action plan based on the level of was included OelraOeO stem lubrication. RWCU outboard isolation valve MO-3-12-018 in iire ',medium," risk population of MOV program valves that had not yet been converted grease at the time of the diagnostic test_failure on September 22.
to MOV Long-Life MO-3-1 Z-}1-Bwas scheduled for PM and conversion to MOV Long-Life following as-found diagnostic testing, which constituted a six-year PM interval. PBAPS identified that the MOV program scofing for MO-3-12-018 did not include the correct high temperature stem factor, wnicn would have reduced the PM frequency to four years' At the close of the inspection period, PBAPS had transitioned 128 of the 182 MOV program valves to MdV Long-111" grease. In addition to the previously discussed coriective actions in responsl to thl Mo-3-12-018 degraded grease, PBAPS.performed grease, an EOC review of all MOVs that have not yet been converted to MOV Long-Life including MOV program calculations to identify additional errors such as the were aforeme-ntioneO nign temperature stem factor on MO-3-12-018. Field walkdowns also performed onlll Unit g MOVs with NebulaEP-1grease, as well as all accessible Unit 2 MOVs with Nebula EP-1 grease. Based on the EOC review, 14 MOVs had their grease conversion dates moved fonrvard. Additionally, PBAPS has expedited corrective Ictions to complete the MOV Long-Life conversion on all MOV program valves from December 2O14to December 2013. The NRC inspectors reviewed the final EOC scoping and determination performed by PBAPS, and found that it was appropriate to the circumstances.
Analvsis. The inspectors determined that Exelon's failure to promptly correct a condition lEffito quality associated with a safety-related MOV constitutes a performance
'speiiticatty, J"ti"i"n.y.
degraded Exxon Nebula EP-1 stem lubricant caused RWCU outboard isolation valve MO-3-12-018 to fail diagnostic testing on September 22,2011, after a root cause evaluation required changing the stem lubricant to MOV Long-Life grease to prevent recurrence of multiple safety-related MOV diagnostic testing failures in March and April of 2009. This finding was more than minor because it was associated with the containment configuration control attribute of the Barrier Integrity cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the RWCU outboard isolation valve MO-3-12-018 did not develop sufficient thrust at the torque switch trip setpoint during diagnostic testing on September 22,2011, and therefore would not have been able to perform its safety function to close during the most limiting design condition. Using the Phase 1 worksheet in Attachment 4 of IMC 0609, "SDP," the inspectors determined that this finding was of very low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of reactor containment.
This finding had a cross-cutting aspect in the area of Pl&R, CAP, because Exelon did not take appropriate corrective actions to address a safety issue in a timely manner lP.1(d)]. Specifically, Exelon failed to address the adverse trend of degraded MOV stem lubricant in a timely manner, which resulted in loss of the RWCU outboard isolation valve closing safety function for the most limiting design condition.
Enforcement.
10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," states, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Contrary to the above, Exelon failed to promptly correct a condition adverse to quality associated with degraded stem lubrication on RWCU outboard isolation valve MO-3-12-018. Specifically, root cause evaluation 892191-08 required Exelon to change MOV stem lubrication from Nebula EP-1 to MOV Long-Life, as a corrective action to prevent recurrence of multiple MOV program testing failures due to degraded stem lubrication identified in 2009. As a consequence of Exelon's failure to promptly correct this condition adverse to quality, MO-3-12-018 failed diagnostic testing due to degraded Nebula EP-1 stem lubrication on September 22, 2011. Because this finding is of very low safety significance and has been entered into the CAP via lRs 1266600 and 1266604, this violation is being treated as a Green NCV consistent with the NRC Enforcement Policy. (NCV 05000278/201{005-01, Untimely Gorrective Action to Correct MOV Degraded Stem Lubrication)
1R13 MaintenanceRiskAssessmentsandEmeroentWorkControl
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that PBAPS performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the Reactor Safety cornerstone. As applicable for each activity, the inspectors verified that PBAPS personnel performed risk assessments as required by 10 CFR 50.65(aX4) and that the assessments were accurate and complete. When PBAPS performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the station's probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the l1 TS requirements and inspected portions of redundant safety systems, when applicable, to veriiy risk analysis assumptions were valid and applicable requirements were met.
.
Unit 3 average power range monitor (APRM) 2-out-of-4 voter failure on November 4, 2011
.
E-2 EDG emergent work on November I and 10,2011
.
E-2 EDG declared inoperable due to voltage regulator malfunction and emergent work on December 5,2011 b. Findinqs No findings were identified.
1R.lS Operabilitv Determinations and Functionalitv Assessments (71111'15 - 5 samples)a. Inspection ScoPe The inspectors reviewed five operability determinations for the following degraded or non-conforming conditions:
o Operability Evaluation 11-003: Control rod seismic impact from fuel channel friction on October 6,2011 o Technical Evaluation 1268076-02: Past operability review of Unit 3 automatic depressurization system valve 718 on November 3,2011
.
Unit 2 reaclor feedwater pump control station loss of power on November 10,2Q11
.
Unit 3 SLC tank temperature control degraded equipment on November 15,2Q11 o primary containment overpressure credit for emergency core cooling pumps on November 23 and 29,2011 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the justified and operability determihations to assess whether TS operability was properly the subject component or system remained available such that no unrecognized in increase in risk occurred. The inspectors compared the operability and design criteria the appropriate sections of the TSs and UFSAR to PBAPS's evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by PBAPS' The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.
b.
Findinqs No findings were identified.
R18 Plant Modifications
Permanent Mod ifications a. Inspection ScoPe The inspectors evaluated the permanent modification to the Multiple Spurious Operation Motor Control Center Breaker implemented by Engineering Change Request (ECR) 10-OO44g, "Multiple Spurious Operation Motor Control Center Breaker Rework" on November 1d and 17. The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification. In addition, the inspectors reviewed modification documents associated with the upgrade and design change, which included 10 CFR Part 50.59 documentation and post-mbdification testing resulis. The inspectors also conducted field walkdowns of the modifications to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance capability of the affected systems.
b. Findinqs No findings were identified.
1R19 Post-Maintenance Testinq
a. Inspection Scope
The inspectors reviewed the post-maintenance tests (PMTs) for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify tnai tne procedure adequately tested the safety functions that may have been affeited by the maintenance activity, that the acceptance criteria in the procedure was consistenfwith the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.
.
Unit 3 main steam isolation valve (MSIV) stroke timing on October 3,2011, following P3R1 I maintenance activities
.
Unit 3 E-23 vital bus loss of coolant accident (LOCA) / loss of offsite power (LOOP)testing on October 5,2011, following planned maintenance
.
Unit 3 low pressure turbine acceptance testing during start-up between October 14 and 1 7 ,2011 , following P3R18 retrofit modification
.
Unit 3 'B' reactor protection system (RPS) MG set between October 23 to 24,2011, following flywheel inboard bearing replacement
.
Unit 2MO-2-10-1548 last performed diagnostic test on May 18,2011, following planned maintenance o Unit 3 APRM 3 voter card replacement and partial surveillance test (ST) Sl3N-60A-APRM-31FS on November 4,2011 r Unit 3 M-004-400 reactor vessel head bolt tensioning verification in response to industry operating experience on November 29,2011
.
E-1 EDG inspection post-maintenance functional test on November 28 and 29,2011 following two-year maintenance overhaul b. Findinos No findings were identified.
1R20 Refuelinq and Other Outaoe Activities (71111'20 - 1 sample)
Peach Bottom Unit 3 Outaqe - Refuelinq (P3R18)a. Inspection ScoPe The inspectors reviewed the station's work schedule and outage risk plan for the Unit 3 maintenance and refueling outage (3R18), which was conducted September 1 1 through October 14,2011. This simple completes the inspection activity begun in the PBAPS 3'd quarter 201 1 inspection report ,2011005. The inspectors reviewed PBAPS's development and implementation of outage plans and schedules to verify that risk, industry experience, previous site-specific problems, and defense-in-depth were considered. During the outage, the inspectors observed portions of the shutdown and cooldown processes and monitored controls associated with the following outage activities:
.
Refueling Activities - verified that PBAPS was using adequate controls to ensure the location of tne fuel assemblies were properly tracked and verified that procedures for foreign material control and retrievalwere implemented on the refueling floor
.
Core Verification - independently reviewed selected portions of other core verification activities o Torus Closure - conducted a thorough walkdown of accessible torus areas above the suppression pool water line prior to reactor startup to verify that all debris, tools, and diving gear were removed
.
Oryw-elt Closure - conducted a thorough inspection and walkdown of containment pribr to reactor startup to identify any remaining debris, tools, and equipment were removed prior to reactor startuP
.
Reactor Startup Preparations - reviewed the tracking of startup prerequisites and observed selected Plant Operations Review Committee meetings where outstanding outage issues and startup reviews were discussed o Startup and Ascension to Full Power Operation - observed selected activities including: reactor criticality; portions of the plant heat-up, main generator synchronization to the grid; portions of the power ascension to full power operation o Licensee ldentification and Resolution of Problems - reviewed corrective action reports related to RFO and startup activities to verify that PBAPS was identifying issues at the appropriate level and taking adequate corrective action b.
Findinqs No findings were identified.
1R22 Surveillance Testinq (71111'22 - 3 samples)
a. Inspection Scope
(2 routine surveillances; 1 in-service test (lST))
test The inspectors observed performance of surveillance tests (STs) and/or reviewed whether test results satisfied TSs, the data of selected risk-signiiicant SSCs to assess verified that test UFSnn, and pBApS piocedure requirements. The inspectors and were acceptance criteria were clear, tests demonstrated operational readiness calibrations and consistent with desijn documentation, test instrumentation had current written, and the range and accur-acy for the application, tests were performed as satisfied.
Upon test completion, the inspectors applica6le test prerequisites were that equipment was capable of performing considered whether the test results supported the following STs:
the required safety functions. The inspectors reviewed on RT-O-01 0-304-3, RHRyHPSW system valves alternate controltesting November 14and15 IST on ST-0-023-301 -2, Unit 2 HPCI Pump, Valve, Flow, and Unit Cooler December 12
.
sT-o-0 52-154-2, E-4 EDG Simulated Unit 2 Emergency core cooling system (ECCS) Signat Auto Start with Offsite Power Available on December 21 b. Findinqs No findings were identified.
EmergencY PreParedness (EP)lEPO Drill Evaluation (71114'06 - 1 sample)lnspection ScoPe drill on December The inspectors evaluated the conduct of a routine PBAPS emergency notification, and 5 to identify any weaknesses and deficiencies in the classification, observed protective iction recommendation development activities. The inspectors in the simulator, and technical support center to emergency response operations notifications, and protective action deteririne-wheiher the event classification, recommendations were performed in accordance with procedures' The inspectors and discussed the results of tfre station drill critique with the lead drill controller, with those reviewed the items entered into the CAP, to compare inspector observations whether the iJ"nliti"J by pBAps staff in order to evaluate PBAPS's critique and to verify PBAPS staff was properly identifying weaknesses in the cAP.
Findinos No findings were identified.
2. RADIATION SAFEry
Cornerstone: Occupationat Radiation Safety (OS)
2RS01 Access Control to Radioloqicallv Siqnificant Areas (71124.01- 1 sample)
a. Inspection Scope
The inspectors reviewed selected activities, and associated documentation, in the below listed areas. The evaluation of Exelon's performance was against criteria contained in Title 10 of the CFR Part 20, applicable TSs, and applicable station procedures.
Inspection Plannins The inspectors reviewed Performance Indicators (Pls) for the Occupational Exposure cornerstone.
Radiolooical Hazard Assessment The inspectors conducted walkdowns of the facility, including the dry-active waste collection location and the low-level waste storage facility, including associated yard area, to evaluate material and radiological conditions. The inspectors made independent radiation measurements to verify conditions. During the walk-downs the inspectors selectively reviewed survey data, as available.
The inspectors selectively reviewed radiologically risk-significant work activities that involve exposure to radiation. The inspectors verified that appropriate pre-work surveys were performed. The inspectors evaluated the radiological survey program to determine if hazards were properly identified (e.9., discrete particles, hard-to-detect radionuclides, transient radiation dose rates and dose rate gradients).
Instructions to Workers The inspectors selectively reviewed occurrences where a worker's electronic dosimeter noticeably malfunctioned or alarmed to verify appropriate worker response and inclusion of issues in CAP, as applicable. The inspectors evaluated licensee dose evaluations as applicable for these occurrences.
Contamination and Radioactive Material Control The inspectors observed locations where the licensee monitors potentially contaminated material leaving the Radiological Controlled Area (RCA), and inspected the methods used for control, survey, and release from these areas. The inspectors selectively evaluated the radiation monitoring instrumentation sensitivity for the type(s) of radiation present.
Radiolooical Hazards Control and Work Coveraqe The inspectors toured the facility and evaluated ambient radiological conditions (e.9., radiation levels or potential radiation levels).
The inspectors conducted selective inspection of posting and physical controls for high radiation areas (HRAs) and very high radiation areas (VHRAs), to verify conformance with the Occupational Pl.
Rad iation Worker Performance The inspectors selectively reviewed radiological problem reports since the last inspection to identify human performance errors and to determine if there were any observable patterns. The inspectors discussed corrective actions for identified concerns with licensee Personnel.
Radiation Protection Technician Proficiencv The inspectors selectively reviewed outage radiological problem reports to identify those to that indicate the cause oi tne event to be radiation protection technician error and evaluate corrective action approach taken by the licensee to resolve the reported problems. The inspectors discussed corrective actions for identified concerns with licensee Personnel.
Problem ldentification and Resolution The inspectors determined if problems associated with radiation monitoring and and exposure controlwere being identified by the licensee at an appropriate threshold were properly addressed foi resolution in the licensee CAP. The inspectors discussed corrective actions for identified concerns with Exelon personnel' b.
Findinqs No findings were identified' 2RSO2 and (71124.02- 1 sample)samPle)a.
lnspection ScoPe Inspection Planninq The inspectors selectively reviewed pertinent information regarding plant collective order to exposuie history, .urreni"*posure tiends, and ongoing or planned activities in ura"r, current performance and exposure challenges. The inspectors reviewed as low as is reasonably achievable (ALARA) results associated with the 2011 Unit 3 outage' of The inspectors'selectively reviewed conformance with the ALARA program aspects 10 cFR 20j101.
Radiolooical Work Planninq The inspectors selectively compared accrued results achieved (dose rate reductions, person-rem used), ar auiil"ble, with the intended dose established in the licensee's person-hour nf_nnn planning ior selected work activities (Unit 3 2O1.1.outage) including estimates. The-inspectors focused on work activities with an accrued dose of five person-rem. The inspectors determined, as applicable, and where analyses were Lompleted at the time of the inspection, the reasons for inconsistencies between intended and actualwork activity doses.
The inspectors determined if post-job (work activity) reviews were conducted and if identified problems were entered into the CAP including lessons learned.
The inspectors selectively reviewed 2011 Station ALARA Committee meeting minutes.
The inspectors selectively reviewed outage report information collected and assembled as of the date of the insPection' Verification of Dose Estimates and Exposure Tracking The inspectors selectively verified work activities that Exelon had established measures to track, trend, and if necessary to reduce, occupational doses for ongoing work activities. The inspectors reviewed control rod drive work, recirculation pump work, in-vessel work, scaffolding, Unit 3 main condenser work, and reactor disassembly and re-assembly Source Term Reduction and Control The inspectors discussed source term mitigation effectiveness with licensee staff associated with the Unit 3 outage' Problem ldentification and Resolution The inspectors determined if problems associated with ALARA planning and controls were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensee CAP. The inspectors discussed corrective actions for identified ALARA concerns rruith Exelon personnel.
b.
Findinqs No findings were identified' 2RS03 ln-Plant Airborne Radioactivitv Control and Mitiqation (71124.03 - 1 sample)a.
Inspection ScoPe lnspection Planninq The inspectors reviewed the reported Pls to identify any related to unintended dose resulting from intakes of radioactive materials.
Problem ldentification and Resolution The inspectors reviewed and discussed problems associated with the control and mitigation of in-plant airborne radioactivity to evaluate the licensee's identification and resolution of issues in the CAP.
b.
Findinqs No findings were identified.
2RS04 Occupational Dose Assessment (71124.04 - 1 sample)
Inspection Scope Inspection Planninq The inspectors selectively reviewed licensee procedures associated with dosimetry operations. The inspectors evaluated procedure guidance for personnel monitoring.
External Dosimetrv The inspectors evaluated the use of the licensee's personnel dosimeters that require processing were National Voluntary Laboratory Accreditation Program (NVLAP)accredited-. The inspectors determined if the licensee used a "correction factod'to address the response of the electronic dosimeter (ED) as compared to its thermoluminescent dosimeter (TLD) for situations when the ED must be used to assign dose.
lnternal Dosimetrv The inspectors selectively reviewed routine bioassay (in vivo) procedures and whole body count results used to assess dose from potentially internally deposited nuclides using whole body counting equipment.
Special Dosimetrv Situations The inspectors selectively reviewed exposure results, and monitoring controls employed, associaied with declared pregnant individuals during the current assessment period.
The inspectors selectively reviewed the licensee's implementation of monitoring for externai dose for the Unii 3 outage in situations in which non-uniform fields are expected or large dose rate gradients (i.e., use of multi-badging or determination of effective dose equivilent for exteinal exposures (EDEXs) using an NRC approved method).
Neutron Dose Assessment The inspectors selectively evaluated the licensee's neutron dosimetry program, including dosi meter type(s) and/or survey instrumentation.
Shallow Dose Equivalent The inspectors selectively reviewed personnel contamination instances to evaluate frequency, causes, and dose assessment, as appropriate. The inspectors also discussei identification and logging of personnel contamination occurrences during the Unit 3 outage including actions taken to identify and limit personnel contamination events. The inspectors reviewed a common cause analysis associated with personnel contamination events (AR 1 268194).
Dose Assiqnment The inspectors evaluated assignment of dose of record for total effective dose equivalent, shallow dose equivalent, and lens dose equivalent.
Problem ldentification and Resolution problems The inspectors selectively reviewed corrective action documents to verify that at associated with occupational dose assessment were being identified by the licensee an appropriate threshold and were properly addressed for resolution in the licensee's CAp. The inspectors discussed corrective actions for identified concerns with Exelon personnel.
b.
Findinqs No findings were identified.
2RS0 5 Radiation Monitorinq lnstrumentation
a.
Inspection ScoPe Inspection Planninq The inspectors reviewed the plant updated final safety analysis lepgrt (UFSAR)'as applicable, to identify radiation instruments associated with monitoring area radiological conditions, includingairborne radioactivity, process streams, effluents, materials/articles, and workers.
Walkdowns and Observations and The inspectors selected portable survey instruments in use or available for issuance checked calibration and source check stickers for currency, and to assess instrument material condition and operability.
Calibration and Testino Proqram range The inspectors selectively reviewed calibration of Units 2 and Unit 3 drywell high monitors. The inspectors selectively verified electronic calibration and source calibration.
collect The inspectors selectively reviewed and discussed the licensee's capability to high range, post-accident iodine effluent samples' The inspectors selectively reviewed and discussed high-range effluent monitor calibrations.
Problem ldentification and Resolution The inspectors selectively reviewed corrective action documents associated with at an radiation monitoring instrumentation to determine if the licensee identified issues the appropriate tfrreshdtd and placed the issues in the CAP for resolution' In addition, inspectors evaluated the appropriateness of the corrective actions for a selected sample of problems documented by the licensee that involve radiation monitoring instrumentation. The inspectors discussed corrective actions for identified concerns with Exelon personnel.
b.
Findinqs No findings were identified.
Gornerstone: Public Radiation Safety (PS)2RS06 Radioactive Gaseous and Liquid Effluent Treatment (71124'06 - 1 sample)a.
lnspection ScoPe The inspectors selectively reviewed UFSAR descriptions of the radioactive effluent monitoring systems, treatment systems, and effluent flow paths.
The inspectors selectively reviewed changes to the ODCM made by the licensee since the last inspection to identify differences.
any The inspectors discussed, and selectively determined, if the licensee had identified an non-rad'ioactive systems that have become contaminated as disclosed either through event report or are documented in the ODCM since the last inspection. The inspectors effluent selectively determined if any newly contaminated systems had an unmonitored discharge path to the environment.
Walk downs and Observations The inspectors selectively walked down components of the gaseous and liquid discharge systems to verify equipm-ent configuration, flow paths, and material conditions' The inspectors selectively reviewed liquid waste discharge permits' Samplinq and Analvses The inspectors selectively reviewed, as available, effluent discharges made with inopera'ble (declared outbf-service) effluent radiation monitors to verify that controls weie in-place to ensure compensatory sampling was performed consistent with the Rad iolog ical Effl uents Tech nical specification (RETS)/ODCM.
The inspectors selectively determined if the facility was relying on the use of compensatory sampling in lieu of adequate system maintenance.
The inspectors selectively reviewed the results of the inter-laboratory and intra-laboratory comparison p.gr"r to verify the quality of the radioactive effluent sample analyses.
Dose Calculations The inspectors selectively reviewed liquid and gaseous waste discharges to verify that the projected doses to members of the public were accurate and based on representative samples of the discharge path.
The inspectors selectively evaluated the methods used to determine the isotopes that were included in the source term to ensure all applicable radionuclides were included, within detection standards.
The inspectors selectively reviewed changes in the licensee's offsite dose calculations since the last inspection io verify changes were consistent with the ODCM and Regulatory Guide (RG) 1
.109 . The inspectors also reviewed meteorological dispersion
anO Oepoiition factors used in the ODCM and effluent dose calculations to ensure appropriate factors were being used for public dose calculations.
The inspectors reviewed the latest Public Land Use Census to verify that changes had been factored into the dose calculations and to verify calculated doses were within the 10 CFR Part 50, Appendix I and TS dose criteria.
The inspectors selectively reviewed, as available, abnormal gaseous or liquid tank discharges and associated dose calculations, evaluations, and corrective actions.
Ground Water Protection lnitiative lmplementation The inspectors selectively reviewed implementation of the ground water monitoring program. The inspectors reviewed monitoring results of the Ground Water Protection initi-ative (Gpl) to determine if the licensee had implemented its program as intended and to identify any anomalous or missed results and to determine if the licensee had identified and addressed deficiencies through its CAP' Problem ldentification and Resolution The inspectors verified that problems associated with the effluent monitoring and control program were being identified by the licensee at an appropriate threshold and were corrective fro[erty addressed'for resolution in the CAP. The inspectors discussed actions-for identified concerns with Exelon personnel' b. Findinos lntroduction. The inspectors identified a Green Finding associated with failure to establ'Sh, and maintain adequate QA program elements in the area of effluent and environmental monitoring as required by Peach Bottom Units 2 and 3
'rnplement, TSs Sectio n 5.4.1.c, "Quality assurance for effluent and environmental monitoring."
Specifically, Exelonjs QA program for effluent and environmental monitoring was not sufficient to ensure: 1) that Ootfr adequate and timely evaluation and assessment of
.h"ngur described in ifre 2010 Public Land Use Census were conducted for purposes of dose validation and sampling program modification; 2) that changes in meteorological were promptly and farameters, used for public Oose prolections and assessment, adequately evaluated; and 3) that laboratory quality assurance programs for effluent and enviionmental sample analysis measurement systems were adequate and implemented properly.
Description.
Peach Bottom Units 2 and 3 TSs require in Section 5.4.1.c, among other requtrements, that QA procedures for effluent and environmental monitoring be established, implemented, and maintained' Exelon established various effluent and environmental monitoring QA program procedures to provide QA for important elements of the effluent and environmental monitoring program that could collectively and individually impact public dose projections attributable to effluent releases from the Peach Bottom Station. These QA elements covered such matters as: 1) evaluation of public land use around the station to ensure dose pathway analyses were conducted taking into consideration current land use around the facility; 2) evaluation of changes to important meteorological parameters used for public dose'projection; and 3) various laboratory QA program elements to provide assurance that onsite and vendor laboratories were providing acceptable analytical results. The inspectors identified six examples where the effluent and environmental QA program was ineffective as follows:
.
Exelon did not conduct an evaluation of its 2010 Land Use Census results in accordance with Procedure CY-AA-1 70-1 000, Revision 5, "Radiological Environmental Monitoring Program and Meteorological Program lmplementation."
The evaluation supports tfre Oetermination, from a QA perspective, of the need for additional new monitoring stations (compensatory measures) based on changes in the land use and calculaied dose or dose commitment. Procedure CY-AA-170-1000 required in section 4.5, that the census be reviewed against the requirements listed in ine station's ODCM, and the ODCM required that compensatory measures be taken to add new environmental monitoring locations, within 31 days, if needed' Exelon had completed its 2010 Land Use Census (dated January 4, 2011) for Peach Bottom and provided a summary of the census to the NRC in its May 31,2011' Annual Radiological Operating Report (No. 63). Exelon subsequently conducted an evaluation of the 2010 Land Use Census in July 2011, which included new information, and concluded no change in monitoring was required. Exelon placed this issue into its CAP (AR 1226969)'
.
Exelon did not conduct an assessment of its long term meteorological data to compare the 2010 annual meteorology values of )UQ (dispersion factor) and D/Q (deposition factor) against long term averages to determine if non-conservative "Radiological irends existed. Exel6n Procedure CY-AA-170-1000, Revision 5, Environmental Monitoring Program and Meteorological Program lmplementation,"
required in Section +.0.+ltnatihe annual meteorologicalXQ (dispersion) and D/Q (deposition) values be compared to the long term historical X/Q and D/Q values for significant changes in a non-conservative direction. The procedure required that if the values were-found to be trending non-conservatively higher over a period of time, then action was to be initiated, including initiating the corrective action process, if there was a gap between ODCM requirements and sample locations. Exelon (AR subsequently compared the data in June 2011 and placed this issue in the CAP 1226202).
. The inspectors identified that Exelon's QA program for meteorological data evaluation failed to detect that the existing ground-level meteorological )UQ value, for the Units 2 and 3 vent stacks, used in the ODCM for purposes of dose projection, was non-conservative relative to the latest calculated long term meteorological average values resulting in potential incorrect dose calculations. Exelon subsequently evaluated this new data in December 2011 and concluded there was no significant change in critical sector dose projections and that public dose projections continued to be well within 10 CFR Part 50, Appendix l, ALAM design values and 10 CFR 20.1301(e). Exelon placed this issue into its CAP (AR 1299543).
.
The inspectors identified that Exelon did not conduct an evaluation of its first, second, and third quarter 2011 inter-laboratory cross-check samples to determine if sample analyses met applicable QA requirements, as required by Procedure CY-AA-130-201, Revision 1, "Radiochemistry Quality Control," Section 4.3. The cross-check samples that were not evaluated included: tritium; gross alpha; Sr-89/90; and filter gas and solid samples. The inter and intra laboratory samples were subsequently evaluated in December 2011 using the criteria within Procedure CY-AA-130-201, Attachment F. Exelon placed this issue into its CAP (AR1299476).
.
The inspectors identified that Exelon's QA program did not ensure that actual QA sample analysis results, obtained from a vendor laboratory for analysis, were subsequently critically evaluated against applicable criteria specified in procedures.
Exelon did not conduct its onsite biennial evaluation for liquid tritium analysis during second quarter 2011 sampling activity, in that a traceable standard was not analyzed onsite in accordance with the QA program requirements specified in CY-AA-130-201 Revision 1. Exelon subsequently placed this issue into its CAP (AR 1302720), and successfully performed the analysis in December 2011.
o The inspectors identified that Exelon's QA cross-check procedure, RT-C-095-861-2, "Radiochemistry Intra-laboratory Cross-Check Analysis Program," did not contain sufficient guidance to ensure appropriate analytical data was used for sample inter-comparison resolution. Exelon subsequently identified similar concerns in other cross-check procedures. ln addition, incorrect sample inter-comparison analysis resultswere identified (e.9., November 14,2011 tritium sample analysis). Exelon placed this issue into its CAP (AR 1303308) to correct the procedural deficiencies and re-perform the cross-check using appropriate analytical methods.
Given the identified issues, Exelon conducted extensive re-analysis of projected offsite doses taking into consideration new Land Use Census data as well as the identified changes in meteorological parameters. Exelon concluded there was no significant impact on public doses and public dose projections remained well within 10 CFR Part 50 Appendix I ALARA design specifications. Exelon also reviewed environmental sample data and did not identify any anomalous results. Exelon also evaluated those samples results (as well as inter-comparison results) that had not been critically evaluated (or incorrectly evaluated) and concluded, based on data review, that the sample results met comparison criteria once evaluated properly. Exelon was continuing its data review.
Further, Exelon conducted a liquid tritium analysis and concluded that the analysis results were within acceptance criteria. The inspectors discussed and selectively reviewed Exelon's analyses and did not identify any significant dose consequence.
Analvsis. Exelon did not establish, implement, and maintain an adequate QA program in the area of etfluent and environmental monitoring as required by Peach Bottom Units 2 and 3 TSs, Section 5.4.1.c, for elements of its effluent and environmental monitoring program. Specifically, Exelon's QA program for effluent and environmental monitoring waJnot sufficiently robust to ensure: 1) that both adequate and timely evaluation and assessment of chinges described in the 2010 Public Land Use Census were conducted for purposes of dose validation and sampling program modification; 2) that changes in meteorological parameters, used for public dose projections and assessment, were promptly a-nd adequately evaluated; and 3) that laboratory QA programs, for effluent and environmental sample analysis measurement systems were both adequate and implemented. The failures to establish, implement, and maintain such a QA program was reasonably within the Exelon's ability to foresee and should have been prevented.
The finding is more than minor because it is associated with the Public Radiation Safety cornerstone attribute of programs and processes and adversely affected the associated cornerstone objective in thai failure to establish, implement, and maintain an adequate eA program inine effluents and environmental monitoring program area adversely affeiteO the licensee's ability to ensure adequate protection of public health and safety' Specifically, Exelon's QA program for effluent and environmental monitoring, was not sufficienly robust to ensuie: i; tnat adequate and timely evaluations and assessment of changes described in the 2010 Public Land Use Census were conducted for purposes of dose validation and sampling program modification; 2) that changes in meteorological parameters, used for public dose projections and assessment, were evaluated in an adequate and timely manner; and 3) that laboratory QA programs for effluent and enviionmental sample analysis measurement systems were adequate and properly implemented.
This finding was assessed using IMC 0609, Appendix D, and determined to be of very low safetyiignificance (Green) because: the issue was contrary to the licensee's TSs; there wai no indication of a spill or release of radioactive material on the licensee's site or to the offsite environs that would impact public dose assessment; and there was no substantial failure to implement the radioactive effluent release program. The licensee was able to re-assess the dose to members of the public from routine releases and determined that projected doses did not nor were likely to exceed applicable limits including ALARA design specifications of 10 CFR Part 50, Appendix l, or ..
10 CFR20.1301(e). There was no effluent monitor calibration issue and the licensee had data by which io assess dose to a member of the public. Exelon plans to provide updated efiluent release and dose reports, as necessary, to reflect revised analyses.
The cause of this finding is related to the crosscutting area of Human Performance, Work Practices, Aspect H.+(O) because the licensee did not ensure personnelfollowed procedure compliance requirements activities for the effluent and environmental monitoring programs.
Enforcement.
The violation related to this finding is currently under review by the NRC.
When that review is completed, the decision relative to any violation will be transmitted to Exelon via separate correspondence. In accordance with NRC IMC 0612, since the significance determination of ihe underlying finding has been completed and does not inlerfere with the NRC's current review of the violation, the finding can be issued at this time. The finding and associated violation, although dispositioned separately, only count aS one input into the plant assessment process. However, the number and characterization of violations is subject to change pending the NRC's final review.
Exelon entered this matter into its CAP (ARs: 1226969,12262Q2,1299543,1299476, 13O272O,and 1303308), (FtN 0500027712011005-02;0500027812011005'02; Failure to Establish, lmplement,'and Maintain Adequate QA for Effluent and Environmental Monitoring)
2RS0 7 Radioloqical Environmental Monitorinq Proqram
a.
Inspection ScoPe Inspection Planninq fne reviewed the annual radiological environmental and effluent
'nWectoffictively operating reports (2009, 2O1O), and the results of licensee assessments since the last inspection, to verify that the Radiological Environmental Monitoring Program (REYll ODCM' was implemented in accordance with the Peach Bottom Units 2 and 3 TSs and The inspectors reviewed the report for changes to the ODCM with respect to environmental monitoring, commitments in terms of sampling locations, monitoring program' and measurement frequencies, Land Use Census, inter-laboratory comparison program exceptions, and analysis of data' The inspectors selectively reviewed the ODCM to identify locations of environmental monitoring stations.
The inspectors selectively reviewed the Peach Bottom Units 2 and 3 Updated Final monitoring Safety Analysis Report (UfSnn) for information regarding the environmental program and meteorological monitoring instrumentation' Site InsPection to The inspectors selectively reviewed any significant changes made by the licensee the ODCM as the result of changes to the Public Land Use Census, long-term year meteorological conditions (e.g., average), or modifications to the sampler stations since the last inspection. itre inspectors reviewed technicaljustifications for any changed samPling locations.
for The inspectors evaluated detection sensitivities with respect to TS/ODCM used counting samples (i.e., the samples meet the TS/ODCM required lower limits of detection (LLD).
ldentification and Resolution of Problems The inspectors determined if problems associated with the REMP were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in of the the CAp. In addition to the above, the inspectors verified the appropriateness licensee that corrective actions for a selected sample oi problems documented by the discussed corrective actions for identified concerns involve the REMp. The inspectors with Exelon Personnel' b.
Findinqs No findings were identified.
Transportation (7 1 124.08 - 1 sample)
Inspection ScoPe Inspection Planninq in the The inspectors selectively reviewed the solid radioactive waste system des,cription recent radiological effluent release UFSAR, the process conirol program (PCP), and the waste reports ior iniormation on the types, amounts, and processing of radioactive disposed.
Radioactive Material Storaqe waste were The inspectors selectively reviewed areas where containers of radioactive stored, io verify that the containers were labeled in accordance with 10 CFR 20'1904'
,;t"O"ling Coniainers," or controlled in accordance with 10 CFR 20.1905, "Exemptions to Labeling Req uirements," as appropriate.
The inspectors selectively toured the facility to verify that the radioactive materials of storage areas were controlled and posted in accordance with the requirements 10 CFR part20, "standards for Protection against Radiation."
Radioactive Waste Svstem Walkdown processing The inspectors reviewed and discussed liquid and solid radioactive waste various photographs, live camera systems. The inspectors also selectively reviewed conditions of rooms and tanks.
The uL*r, and radiological surveys to access material and systems.
inspectors reviewed area staius logs for radioactive waste areas Shipment PreParation marking' The inspectors selectively observed shipment packaging, surveying, labeling.'
shipping papers placarding, vehicle checks, emergency instructions, disposal manifest, readiness irovided [o tn" driver, and licensee verification of shipment pM-1 1-1si ;. rne inspectors observed radiation workers during the conduct
[srripment if the of tne radioactive material shipment preparation. The inspectors determined and whether shipping shippers were knowledgeable of the shipping regulations peisonnel demonstratei adequate skills to accomplish the package preparation provided iequirements. The inspectors verified that the licensee's training program processing and training to personnel responsible for the conduct of radioactive waste radioactive material shipment preparation activities' ldentification and Resolution of Problems processing, The inspectors determined if problems associated with radioactive waste at.an handling, storage, and transportation, were being identified by the licensee and are properly addressed for thr6shold, ur" piop"rly characterized, "ppropii"t" resolution in the licensee CAp. The inspectors discussed corrective actions for identified concerns with Exelon Personnel' b. Findinqs No findings were identified.
OTHER ACTIVITIES
4OA1 Performance lndicator Verification
Cornerstone: Mitigating SYstems
.1 Mitioatinq Svstems Performance lndex (10 samples)
a. Inspection ScoPe The inspectors sampled PBAPS's submittals of the Mitigating Systelg Performance lndex ifrrfSef l for the following systems for the period of October 1,2010 through September 30,2Q11:
o Unit 2 and Unit 3 Emergency Alternating Current Power System (MS06)o Unit 2 and Unit 3 HPCI System (MS07)r Unit 2 and Unit 3 RCIC System (MS08)o Unit 2 and Unit 3 RHR SYstem (MS09)o Unit 2 and Unit 3 Support Cooling Water System (MS10)
To determine the accuracy of the Pl data reported during this period,lhe inspectors used in Nuclear Energy lnstitute (NEl) Document 99-02, definitions and guidance iontained
,,Regulatory AsJessment Pl Guideline," Revision 6. The inspectors also reviewed pBApS operator narrative logs, condition reports (CRs), MSPI derivation reports, event the reports, and NRC integrated inspection reports to validate the accuracy of submittals.
b.
Findinqs No findings were identified.
.2 Safetv Svstem Functional Failures (2 samples)
a.
lnspection ScoPe failure The inspectors sampled PBAPS's submittals for the safety system functional pl for both Unit 2 and Unit 3 for the period of October 1,2010, through September 30, period, inspectors 2011. To determine the accuracy of the Pl data reported during this "Regulatory used definitions and guidance contained in the NEI Document 99-02, "Event Reporting Guidelines Assessment pl GuidJline," Revision 6, and NUREG-1o22, 10 cFR 5}.72and 10 cFR 50.73." The inspectors reviewed PBAPS's operator narrative logs, operability assessments, MR records, maintenance WOs, condition reports, event reports, anO l..tRC integrated inspection reports to validate the accuracy of the submittals.
b. Findinqs No findings were identified.
.3 Occupational Exposure Control Effectiveness (71151- 1 Sample)
a.
lnspection Scope The implementation of the Occupational Exposure Control Effectiveness Pl Program was reviewed. The inspectors selectively reviewed CAP records for occurrences involving HRAs, VHRAs, and unplanned personnel radiation exposures since the last inspection in this area and the previous four complete quarters. The review was against the applicable criteria specified in NEI 99-02, "Regulatory Assessment Pl Guideline,"
Revision 6. The purpose of this review was to verify that occurrences that met NEI criteria were recognized and identified as Pls.
Findinos No findings were identified.
.4 RETS/ODCM Radiolosical Effluent Occurrences (71151- 1 Sample)
lnspection Scope The implementation of the RETS/ODCM Pl was reviewed. The inspectors selectively reviewed CAP records and projected monthly and quarterly dose assessment results due to radioactive liquid and gaseous effluent releases; for the past four complete quarters. The review was against the applicable criteria specified in NEI 99-02, "Regulatory Assessment Pl Guideline," Revision 6. The purpose of this review was to verify that occurrences that met NEI criteria were recognized and identified as Pls.
As part of this review, the inspectors also reviewed Exelon's evaluations and public dose assessments, as necessary, associated with identification of localized onsite ground water contamination within the restricted area.
b.
Findinos No findings were identified.
40.p.2 ldentification and Resolution of Problems (71152 - 4 samples)
.1 Routine Review of Pl&R Activities
a.
lnsoection Scope As required by Inspection Procedure71152, "Problem ldentification and Resolution,"
the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that PBAPS entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended CR screening meetings.
b. Findinqs and Observations No findings were identified.
.2 (71152 - 1 annual
sample)
Inspection Scope The inspectors reviewed the CRs and the corresponding corrective actions from the last RFO on Units 2 and 3. The inspectors interviewed key site personnel regarding the incidents and changes to the refueling process. The inspectors evaluated effectiveness of the corrective actions, EOC, and station personnel knowledge of the process changes. The inspectors reviewed Peach Bottom procedures related to FH and the recenl training provided to the FH personnel. The inspectors assessed Exelon's problem ident-ification threshold, cause analyses, EOC reviews, compensatory actions, and the prioritization and timeliness of corrective actions to determine whether Exelon person nel were appropriately identifyi ng, characterizi ng, and correcti ng problems associated with this issue, ahd whether the planned or completed corrective actions were effective. The inspectors compared the actions taken to the requirements of Exelon's CAp and 10 iFR Part 50, Appendix B, "QA Criteria for Nuclear Power Pants and Fuel Reprocessing Plant." In addition, the inspectors performed in plant walkdowns and interviewed site p6rsonnel to assess the effectiveness of the implemented corrective actions.
The inspectors reviewed Peach Bottom's process to identify, prioritize-, and resolve refuel floor distractions in an attempt to minimize operator burdens. The inspectors observed Exelon personnel conducting fuel movement in the reactor vessel during the September 2011 Unit 3 RFO.
b. Findinos and Observations No findings were identified.
The inspectors determined that the Exelon corrective actions were comprehensive and implemented in a timely fashion. Specifically, the just-intime training of the FH crews was performed at the sjte prior to the Unit 3 outage. The inspectors observed. good communications between the FH crew members during fuel movement' The inspectors observed a constant management presence during FH activities. The inspectors observed that plant personnel involved with the FH activities were knowledgeable regarding the previous FH events and associated corrective actions. The inspectors observed a strong commitment toward zero FH events.
The inspectors observed that the revised Potential Obstruction Compensatory Plan' compleied the day before the FH and core verification, would have provided more benefit to refueling personnel if it had been updated at the start of the Unit 3 RFO.
The revision to the plan'was a corrective action determined from the FH events during the 2010 Unit 2 RFO.
.3 Review of the Units 2 and 3 Spent Fuel Pool (SFP) Boraflex Deqradation Corrective
Actions (71152 - 1 annual sample)a. lnspection Scope The inspectors assessed Peach Bottom's historical SFP shutdown margin. The inspectors compared Exelon's SFP Boraflex CAP documentation and 10 CFR Part 50, Appendix B, 'QA Criteria for Nuclear Power Plants." The SFP criticality calculations listed in lR 1225840-13 were evaluated to determine the significance of the Boraflex degradation. The Exelon SFP Boraflex technical evaluation was reviewed to determine if the SFP TS sub-criticality margin remained less than
.95 Keff. The inspectors also
interviewed site personnel to assess the effectiveness of the implemented corrective actions.
b. Findinos and Observations The inspectors identified one observation related to Exelon's implementation of the corrective actions associated with the SFP Boraflex degradation issue. The issue is currently under review by the NRC as an Unresolved ltem discussed in inspection report 2010004. When that review is completed, the final decision will be transmitted to Exelon via a separate correspondence or in the resident inspector quarterly report. The inspectors also determined that once the TIA response was provided by Nuclear Reactor Regulation (NRR), PBAPS's corrective actions were adequate.
The inspectors reviewed Exelon's Technical Evaluation written to support continued operation of the SFP storage racks provided by Peach Bottom. The Technical Evaluation applied additional margins to account for the changes in fuel designs, code deficiencies, and estimated boron degradation in the SFP racks. The inspectors also reviewed the TIA provided by Nuclear Reactor Regulation (NRR) in response to a TS Amendment request. Exelon subsequently revised the calculation contained in the Technical Evaluation, applying some additional conservatisms raised by the NRR review. Actual conditions in the SFPs did not appear to exceed the TS K"tr < 0.95 limit.
Based on the information provided by Exelon, the inspectors considered that TS 4.3.1.1.b., "Fuel Storage Criticality," was not exceeded.
.4 Semi-Annual Review to ldentifv Trends (1 semi-annual Resident Inspector sample)
a. Inspection Scope
The inspectors performed a detailed review of items entered into the CAP to identify trends (either NRC or licensee-identified), and develop insights into PBAPS's progress in identifying and addressing themes. The inspectors reviewed a list of approximately 8,844lRs that PBAPS initiated and entered into the CAP action tracking system (Passport) from June 1,2011 through December 1,2011. The list was reviewed and screened to complete the required semi-annual Pl&R trend review. The inspectors evaluated the lRs against the requirements of Exelon CAP procedure, LS-AA-125, and 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action."
b. Findinos and Observations No findings were identified.
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 properly identifying a.dverse trends before they the three became riore safety significant problems. However, the inspectors did note adverse trends discussed below' Human performance and configuration control continued to be focus areas for PBAPS from during the second half of 2011. PBAPS identified four configuration control events June-1 through December 1, 2A11, (lRs 1234874 (two events), 1245157, a1! 1271883);seven total in 2011, and five configuration control events were identified in 2010' A
common cause analysis (ccA) was performed in June of 201 1 (lR 1203953.), and a
the Configuration Control Recovery Team was implemented to focus on correcting adverle trend. Since July 1, two additional configuration control events were noted.
None of the configuration control events in 2011 resulted in significant consequences.
lndustrial safety issues continue to challenge PBAPS. There were three Occupational (lRs Safety and Heilt6 Administration recordable injuries in September of 2011 12616gg,1264502, and1265372). Additionally, there were 45 first aid events during'the September and October 2011Unit 3 RFO (P3R18). PBAPS identified this negative trend, and has performed a CCA to address the adverse trend in industrial safety performance during P3R18 (\R1277414). The inspecto_rs noted that PBAPS has of industrial safety performance:
ferformed additionil causal investigations in the area safety a CCA was completed in April of ZOtl to address an inadequate trend in industrial performance between January 1 and April 25 of 20]l (lR 1203002): and an Apparent Cause Evaluation was completeO in November of 2011 in response to Nuclear Oversight pBAPS's failure to complete actions to address unsatisfactory truOSl identifying performance from 2010 in the area of industrial safety' During The inspectors identified an adverse trend in the area of equipment reliability.
the review period from June 't to December 1, 2011, PBAPS submitted five licensee sixth event reports (LERs) related to degraded or failed equipment, and also noted a equipment reliabilitY issue:
o Failed Relay Results in Unplanned EDG Actuation during Surveillance Testing (LER 0500 0277 l2O1 1 -003-00)o EDG Oil Leak (LER 0500027712011-004-00)o Hardened Grease in a Safety-Related MOV (LER 05000278/2011-001, this finding was documented in Section 1R12 of this report)o Leaking Relief Valve in the RHR System (LER 0500027812011-002-00)
. Actuator Diaphragm Thread Seal Leakage in an Automatic Depressurization System Safety Relief Valve (SRV) (LER 05000278i2011-003-00)
.
Repeiitive Leaks on the Unit 3'B'RWCU System (lR 1281888)
The inspectors verified that all of the equipment issues identified above have been entered into the PBAPS's CAP.
.5 Actions
(71152- 1 annual samPle)
a. Inspection Scope
The i"spectors licensee actions to resolve vital bus degraded voltage protectibn issues. The inspectors selected lR 01 119440 as a Pl&R sample for a detailed
'eviewed iollow-up review because it tracked the analysis and disposition of the issue' There were numerous lRs associated with the vital bus degraded voltage protection issue.
As an documented in NRC Inspection Report 0500027712008007 and 0500027812008007, licensing unresolved item (URl) was opened to determine whether the approved PBAPS basis included the use of automatic load tap changers (LTCs) to protect the vital buses from unacceptable low voltage co1d!!i91s during a design basis "r"tg"n.y LOCA. As documented in inspection report 0500027712010004 and 0500027812010004, 2009-the NRC, Region l, requested that a formal review (task interface agreement (TlA)007) be cond-ucted Oy tfre NRC, Nuclear Reactor Regulation to resolve the issue' The lnaf ttn response determined that PBAPS license basis for degraded voltage relay protect the iettings did not include credit for the LTCs on the startup transformers to class"l-E safety-related equipment during a design basis LocA.
The inspection report also closed the URI and enforcement action was documented.
The licensee subsequently issued LER 2010004-00 which was reviewed by the Nfp and closed as documentedin inspection report 0500027712010005 and 0500027812010005 with no additional enforcement action.
The inspectors assessed Exelon's problem identification threshold, EOC reviews, operabiiity evaluations, technical evaluations, modification packages, a1d interim prioritization and compensatory measures. The inspectors also assessed Exelon's timeiiness of corrective actions to determine whether Exelon was appropriately issue identifying, characterizing, and correcting problems associated with the identified planned c-orrective actions were appropriate to prevent and whether the compleieO or portions of recurrence. Additionally, the inspectors performed walkdowns of accessible to assess if abnormal conditions affected motor control ienters (lrrtCCs) and components gain insights regarding the existed. The inspectors also interviewed plant personnel to identified issues and implemented or planned corrective actions' b. Findinqs and Observations No findings were identified.
the The inspectors determined that Exelon properly implemented their CAP regarding initial discovery of the reviewed issue. The lR package was complete and included' EOC operability evaiuations, technical evaluations, interim compensatory measures, the reviews, and contained implemented and planned corrective actions. Additionally, and operability evaluations were detailed and elements of the lR, technical evaluations, appeared appropriate to thorough. lmplemented and planned corrective actions actions minimiie the potential of recurrence. The inspectors determined that corrective calculations that included performing an operability evaluation, which included electrical identifying used the most limiiing uoitrg" level allowed by the TS (excluding the LTC),identified components that wou"ld not-have adequate voltage to operate under the
.ondition, implementing interim compensatory measures (revising operations procedures and operaior training) to operate equipment that would not have adequate voltage to operate in the design basis LOCA, and creating and implementing modification packages for MOVs and MCCs to allow equipment to operate under the analyzed condition. The inspectors found the operability evaluation and interim compensatory measures reasonable. Exelon had completed all modifications associated *itn ftlOvr and MCCs that would not have adequate voltage during a design basis LOCA.
Additional corrective actions included performing an evaluation of vital buses at a lower This voltage (3737 volts) than the TS lower limit for the function four LOCA relay setting.
analysis'was perfoimed to identify equipment needing margil impro.vement, but remiined operable for the TS function four relay setting band. The inspectors determined that Exelon had completed modifications on some of the equipment identified in the analysis and had scheduled modifications on the remaining equipment identified.
.6 ldentification and Resolution of Problems (71124.01,71124'Q2,71124'03,71124'04,
71124.05,71124.06)a. lnspection ScoPe The inspectors selectively reviewed corrective action documents for occupational radiation safety program and effluent and environmental monitoring program' See documents reviewed.
The review was against criteria contained in 10 CFR ParI20, TSs, ODCM, and applicable station audit and surveillance procedures' b. Findinqs No findings were identified.
40A3 (71153 - 4 samples)
.1 (closed) LER 05000277/2011003-00: Delayed Relay operation Results in E-3 EDG
Actuation during Surveillance Testing of the On Septem ber 21, 2011, during the P3R18 RFO, an unplanned, valid actuation E-3 EDG occurred during surveillance (functional) testing of the E-33 4 kV emergency bus undervoltage relays.- The E-3 EDG started unexpectedly when time delay relay 3-54-1g3-1708 did noi operate properly, resulting in a delayed E-33 bus fast-transfer between the TS off-site sources. This delay resulted in the operation of an additional voltage' undervoltage relay and thereby caused a valid actuation of the E-3 EDG on low Because the E-33 bus delayed fast transfer occurred prior to the EDG reaching full speed and voltage, the EDG output breaker was not required to close.
to The cause of the event was due to the failure of the 3-54-183-1708 time delay relay pioperty tunction. The relay was replaced and tested satisfactorily.
There was no actual the CAP safety consequences assoiiated with this event. PBAPS entered this item into was no for additional evaluation and investigation. The inspectors determined that there performance deficiency associated with the failed relay. This LER is closed.
.2 (Ctosed) LER 05000277/2011004-00: Oil Leak Resulting in E-1 EDG lnoperability
On September 23,2011, during the P3R18 RFO, an oil leak was discovered on the E-1 EDG when the engine was being shutdown during 4kV emergency bus lesting. The leak was determined to be from a crack on the lube oil drain line for the combustion air intake blower (supercharger). Analysis determined that the leak previously existed and the EDG would not have been able to perform its safety function to successfully run for a 24-hour mission time.
pBApS determined that the cause of the event was ineffective maintenance practices, and the drain line should have previously been replaced during maintenance activities.
The leaking drain line was replaced on September 23,2011, and the E-1 EDG was tested suciessfully with no leaks in the drain line. PBAPS entered this issue into the CAp, performed EOC inspections, and took corrective action to revise the associated maintenance procedure. The enforcement aspects of this LER are discussed in Section 4OA7. This LER is closed.
.3 (Ctosed) LER 05000278/2011001-00: Containment lsolation Valve Inability to Close for
a Design Basis Event due to Degraded Lubricant On Septem ber 22, 2011 , during the P3R18 RFO, it was identified that the ability of the Unit 3 RWCU outboard isolation valve (MO-3-12-018) to close was degraded due to a motor-operator greasing deficiency. This deficiency was identified during performance of routine MOV maintenance and diagnostic testing. lt was determined that this condition was prohibited by TSs since this primary containment isolation valve was determined to be inoperable for containment isolation purposes during the previous operating cycle for a time period longer than allowed by TS. The cause of the greasing deficienjy was due to inadequate lubrication. The valve was repaired on September 23, 2011. There was no actual safety consequences associated with this event. The enforcement aspects of this LER are discussed in Section 1Rl2' This LER is closed.
.4 (Ctosed) LER 05000278/201 1002-00: RHR Leaking Relief Valve Results in Condition
Prohibited by TS On September 19, 2011, during the P3R18 RFO, Engineering personneldetermined that a leak on the inlet connection to the'D' RHR suction piping thermal relief valve was due to cracking of the relief valve body and not due to a mechanicaljoint leak as originally
-uring identified cycle 18 operations on April 27 , 2010. On April27 , 2010, PBAPS identified the leik to be one drop per two minutes, and incorrectly determined that the leak was from a threaded connection. Subsequent non-destructive evaluation following the September 19, 201 1 determination confirmed the leak to be through the relief valve body. Based on analysis, PBAPS determined the relief valve could have become detjched from the piping during the worst case design basis seismic event' This condition would resuit in tfre 'D; RHR pump being inoperable, thereby affecting the RHR low pressure coolant injection function.
pBApS determined the cause of the delay in identifying the inoperable condition was due to inadequate technical rigor when evaluating the operability of the relief _valve on April 27, 2010. The leaking relief valve was replaced on October 2,2011. EOC reviews were performed for similar components in Unit 2 and Unit 3. Operations has instituted additionaltraining and procedure revisions to drive improved performance regarding this operability evaluitions. There were no actual safety consequences as result of safety event. This event was considered as a condition prohibited by TSs and loss of function. The enforcement aspects of this LER are discussed in Section 4OA7. This LER is closed.
4OA5 Other Activities
.1 NRC Review of Exelon's Response to NCV EA-11-128
a. Inspection Scope
Exelon On Septem ber 12, 2011, the NRC transmitted a NCV and a Green finding to for EAL related to a change Exelon made to the emergency action level (EAL) basis Plan HU6, which introduced a decrease in effectiveness to Peach Bottom's Emergency (Ep)'and resutted in a violation of the requirements ltipulated in 10 CFR 50.5a(q).
5pecifically, the licensee modified the EAL Basis in EAL HU6, Revision 16, which extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm.
This change decreased the effectiveness of the EP by reducing the capability to perform a risk sign'ificant planning function in a timely mannef.- The_NCV and finding were describJd in detail in NRb Inspection Report Nos. 0500027712011502 and 0500027812011502.
In response to the NCV and finding, Exelon entered the issue into their CAP as lR 01184333 and subsequently implemented Revision 21 of the Peach Bottom EP, the which restored the EAL HUO Aasis to the Revision 15 guidance, thereby removing decrease in effectiveness. The inspectors reviewed lR 01 184333 and the revised Bottom version of the HU6 Basis, and discussed the corrective actions with the Peach Emergency PreParedness staff' Findinqs and Observations No findings were identified. The inspectors determined that Exelon's response and finding, and corrective actions were reasonable and appropriate to address the NCV and to be closed' their underlying performance deficiency. The NRC considers the issue
.2 lndependent Spent Fuel Storaqe lnstallation
a. lnspection ScoPe The inspectors selectively reviewed routine operational surveillance data, including (lSFSl)radiological surveillance,ior the Independent Spent Fuel Storage Installation facility. The inspectors toured the facility and made independent radiation re"rur"rents of the facility. The data was evaluated against 10 CFR Part 20 and applicable Exelon Procedures.
Findinqs No findings were identified.
4046 Meetinqs. lncludinq Exit Quarterlv Resident Exit Meetinq Summarv On January 20,2012, the resident inspectors presented the inspection results to Mr. Thomas Dougherty and other PBAPS staff, who acknowledged the findings.
Mr. P. Krohn, Cniet, U-SrunC, Region 1, Division of Reactor Projects, Branch 4,
attended this quarterly inspection exit meeting. The inspectors verified. that no proprietary informatioh was retained by the inspectors nor documented in this report' 4C,A7 Licensee-ldentified Violations by the The following violations of very low safety significance (Green) were identified licensee violations of runC requirem-ents which meet the criteria of the NRC "nd-rr" Enforcement Policy for being dispositioned as NCVs'
.
TS b.4.1 states, in part, that written procedures shall be implemented a1d maintained A'
as recommended ln nC 1.33, Appendix A, November 1972. RG 1'33, Appendix Section l, "procedures for Performing Maintenance," subsection 1, states the following: "Maintenance which can affect the performance of safety-related written equipm6nt should be properly preplanned and performed in accordance with procedures, documenied insiructions, or drawings appropriate to the circumstances' bkill, nottally possessed by qualified maintenance personnel may not require detailed step--by-step delineition in a procedure." Contrary to the aboye,. PBAPS did not properly preplan and perform maintenance which affected the E-1 EDG' have Specifically, pAApd determined that a damaged lubricating oil drain line should planned maintenance activities prior to the been identified and replaced during the occurrence of leakage. As a consequence of not identifying and replacing was unable to perform its damaged drain line,-pBAPS determined that the E-1 EDG period of time 24-hour mission time, and therefore was inoperable, during the between April27 , 2011, and September 23, 2011' Peach The finding was determined to be of very low safety significance, for both A, "Delgrlnining the Bottom Units 2 and 3, in accordance wit-h lMc 0609, Appendix Situations" (lMC 06094)
Significance of Reactor Inspection Findings for At-Pow-er uslng SDp phase s 1,2 and 3. Phase 1 screened the finding to Phase 2 because it reiresented a loss of the E-1 EDG safety function, between April27 and Sepiember 23,2011 (149 days), longer thln the TS limiting condition for operation (Lco) of 14 dayi. A ilegion i senioi Reactor Analyst (SRA) conducted a Phase 3 the Peach analysis because the Phlse 2 analysis, conducted by.the inspectors using-indicated that the finding Bottom pre-solved Risk-lnformed lnspection Notebook, could be more than very low significance' (SPAR) model, The SRA used the peach Bottom Standardized Plant Analysis Risk 8 to conduct Revision 8.19 and 8.17, for units 2 and 3 respectively and SAPHIRE phase 3 analysis, with the conservative assumption that the E-1 EDG would not the time over the 149 day exposure period' have operated at all for its 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> mission have operated for over two This analysis was conservative given the EDG could potential that operators could have hours assuming that the drain line broke and the temporarily limiied the leakage from the supercharge lube oil drain line.
This analysis indicated an increase in core damage frequency (ACDf) forinternal initiaiing events in the range of one core damage accident in 2,500,000 years of reactor operation, in the low E-7 range per year for each unit. The dominate core damage sequences included losses of offsite power with the failure of all EDGs resulting in a station blackout (SBO), followed by the failure of operators to reduce direct current loading to allow extended operation of the RCIC system alq -
depressurize the realtor, and with inability to recover offsite power, the SBO source of power from the Conowingo Dam or an EDG in two hours. In accordance with IMC OObgR, for a finding with an internal events ACDF above 1E-7, the SRA assessed the impact of the tinOing on: 1) External events such as fire, seismic and flooding, determining, using the external events portion of the Peach Bottom Unit 2 and 3 SpAR modlls, tfrit tne total ACDF (internal plus external) would not be above the 1 E-6 threshold; and 2) the increase in large early release frequency (ALERF)'determining that given the operators ability, following core damage, to recover offsite power and depressurize and inject water to the reactor from low pressure sources and to flood the containment that the ALERF was in the low E-8 per year range' Because this finding is of very low safety significance and has been entered into Exelon's CAp under lR 1266b37, this violation is being treated as a Green, licensee-identified NCV consistent with the NRC Enforcement Policy.
. TS LCO 3.5.1, Condition A, requires that one inoperable low pressure ECCS injection subsystem should be iestored to an OPERABLE status within seven days during operatibnal modes 1 and 2, or requires action to place the unit in operational mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Contrary to the above, the 'D' LPCI pump was inoperable during a period of time between April27,2O1O, and October2,2011. Specifically' pBApS determined that the leaking relief valve body, as identified on April 27,2010, could have become detached from the 'D' RHR suction piping during the worst case
'D' RHR pump being design basis seismic event. This condition would result in the inop6rable, thereby affecting the RHR LPCI function.
Because the 'B' RHR pump was unaffected by this even-t, there was no total loss of the 'B' LPCI train safety function. The inspectors determined that this event screens to Green using the Table 4b seismic screening criteria in Attachment 4 of IMC 0609, "SDP." Because CAP this finding is of very low sifety significance and has been entered into Exelon's as a Green, licensee-identified NCV under lR i264g09, ihis violation iJbeing treated consistent with the NRC Enforcement Policy' ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Exelon Generation Companv Personnel
- T. Dougherty, Site Vice President
- G. Stathes, Plant Manager
- J. Armstrong, Regulatory Assurance Manager
- T. Moore, Site Engineering Director
- P. Navin, Operations Director
- J. Kovalchick, SecuritY Manager
- P. Cowan, Work Management Director
- B. Reiner, ChemistrY Manager
- R. Holmes, Radiation Protection Manager
- J. Bower, Training Director
- B. Hennigan, Operations Training Manager
- R. Shortes, Radiological Engineering Manager
- J. Stenclik, Chemistry SuPervisor
- H. McCrory, Technical Support Manager
- R. Reiner, Manager, Chemistry, Environmental and Radwaste
- C. Crabtree, Senior Environmental Chemist
- D. Dullum, RegulatorY Assurance
- N. Burkins, lnstrument SuPervisor
- M. Pawlowski, Radwaste ShiPPer
- M. Ballew, Radiation Protection Supervisor
- E. Schwartz, Chemist
- R. Ridge, Instrument PhYsicist
- D. Hornberger, Radwaste Chemist
NRC Personnel
- P. Krohn, Branch Chief
- S. Hansell, Senior Resident Inspector
- A. Ziedonis, Resident InsPector
- S. Barr, Sr. Emergency Preparedness Inspector
- E. Miller, Project Engineer
- R. Nimitz, Senior Health PhYsicist
- J. Tomlinson, OPerations Engineer
- K. Young, Senior Reactor Engineer
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened/Closed
- 05000278/201 1 005-01 NCV Untimely Corrective Action to Correct MOV Degraded Stem Lubrication (Section 1R12)
Opened
- 0500027712011005-02 FIN Failure to Establish, lmplement, and
- 05000278/2011005-02 Maintain Adequate QA for Effluent and Environmental Monitoring (Section 2RS06)
Closed
- 050002771201 1003-00 LER Delayed Relay Operation Results in E-3 EDG Actuation during Surveillance Testing (Section 4OA3.1)
- 050002771201 1004-00 LER Oil Leak Resulting in E-1 EDG Inoperability (Section 4OA3.2)
- 05000278/201 1 001 -00 LER Containment lsolation Valve lnability to Close for a Design Basis Event due to Degraded Lubricant (Section 4OA.3)
- 05000278/2011002-00 LER RHR Leaking Relief Valve Results in Condition Prohibited bY TS (Section 4OA3.4)
- 0500027712011502-01 NCV (Traditional Enforcement) Changes to
- 0500027812011502-01 fRt gasis Decreased the Effectiveness of the Plan without Prior NRC Approval (Section 4OA5)
- 0500027712011502-02 FIN Changes to EAL Basis Decreased the
- 05000278/2011502-02 Effectiveness of the Plan without Prior NRC Approval (Section 4OA5)
Discussed
- 0500027712010004-01 URI Non-conservative TS and Potential Non-
Compliance Associated with Degraded SFP Boraflex Panels (Section 40A2'3)