IR 05000277/2013004

IR 05000277-13-004 & 05000278-13-004; 07/01/2013 - 09/30/2013; Peach Bottom Atomic Power Station (Pbaps), Units 2 and 3; Surveillance Testing and Other Activities

ML13319A907
Person / Time
Site:	Peach Bottom
Issue date:	11/15/2013
From:	Fred Bower Reactor Projects Region 1 Branch 4
To:	Pacilio M Exelon Generation Co
Bower F
References
IR 13-004
Download: ML13319A907 (46)

Text

UNITED STATES ber 15, 2013

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000277/2013004 AND 05000278/2013004

Dear Mr. Pacilio:

On September 30, 2013, the U. S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The enclosed inspection report documents the inspection results, which were discussed on October 28, 2013, with Pat Navin, Peach Bottom Plant Manager, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, this report documents two NRC-identified findings of very low safety significance. Both of these findings were determined to involve violations of NRC requirements. However, because of the very low safety significance, and because they are entered into your corrective action program (CAP), the NRC is treating these findings as non-cited violations (NCVs), consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest any NCVs in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the PBAPS. In addition, if you disagree with the cross-cutting aspect assigned to the findings in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at the PBAPS. In accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 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 NRCs Public Document Room or from the Publicly Available Records component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.htmL (the Public Electronic Reading Room).

Sincerely,

/RA/

Fred L. Bower III, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos: 50-277, 50-278 License Nos: DPR-44, DPR-56

Enclosure:

Inspection Report 05000277/2013004 and 05000278/2013004 w/Attachment: Supplementary Information

REGION I==

Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56 Report No.: 05000277/2013004 and 05000278/2013004 Licensee: Exelon Generation Company, LLC Facility: Peach Bottom Atomic Power Station, Units 2 and 3 Location: Delta, Pennsylvania Dates: July 1, 2013 through September 30, 2013 Inspectors: S. Hansell, Senior Resident Inspector A. Ziedonis, Resident Inspector E. Burket, EP Inspector J. Furia, Senior Health Physicist H. Gray, Senior Reactor Inspector J. Laughlin, EP Inspector, NSIR T. OHara, Reactor Inspector R. Rolph, Acting Resident Inspector J. Tomlison, Operations Engineer Approved by: Fred Bower, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000277/2013004, 05000278/2013004; 07/01/2013 - 09/30/2013; Peach Bottom Atomic

Power Station (PBAPS), Units 2 and 3; Surveillance Testing and Other Activities.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The inspectors identified two findings of very low safety significance (Green). The significance of most findings is indicated by their color (i.e.,

greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Components Within Cross-Cutting Areas, dated October 28, 2011. All violations of Nuclear Regulatory Commission (NRC) requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated January 28, 2013.

The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Cornerstones: Emergency Preparedness

Green.

The inspectors identified a Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulation (CFR) 50.54(q)(2) associated with 50.47(b)(4) because PBAPS failed to control emergency planning (EP) procedure changes in a manner that would ensure timely emergency action level (EAL) classification for effluent parameters. On June 27, 2013, PBAPS issued Revision 27 to EP-AA-1007, Exelon Nuclear Radiological Emergency Plan Annex for PBAPS. One of the plan changes involved removal of the 'A' ventilation and main stack radiation monitors from radiological effluent EAL matrix Table 3-1, and thereby rendered the B ventilation and main stack radiation monitors as the only means of EAL classification for effluent releases. On July 24, 2013, the inspectors questioned shift operations on whether the ability to make timely and accurate EAL classifications was impacted with the B reactor building (RB) ventilation stack radiation monitor inoperable.

Shift operations did not have an immediate response, but later in the same shift provided a response to the inspectors that compensatory measures were required for degraded EP equipment, and the 'A' ventilation stack radiation monitor was established as a compensatory measure for the inoperable 'B' monitor in response to questions by the inspectors. Following the inspectors questions, PBAPS initiated issue report (IR) 1539674 to capture programmatic deficiencies that were revealed as a result of the inspectors questions. PBAPS corrective actions included a revision to the PBAPS Emergency Plan, a revision to the EP compensatory measure procedure, issuance of Operations Information Update (OIU) 13-10 to the shift managers (SMs) to clarify the purpose of the compensatory measure procedure, and an assignment to incorporate the latest revision of the compensatory measure procedure into licensed operator training program curriculum review committee (CRC).

This finding was more than minor because it was associated with the procedure quality attribute of the Emergency Preparedness cornerstone, and adversely affected the associated cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the public health and safety in the event of a radiological emergency. Using IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, and IMC 0609, Appendix B, Emergency Preparedness SDP, the inspectors determined that this finding was of very low safety significance (Green) using Table 5.4.1. Specifically, this finding rendered an EAL ineffective such that an unusual event (UE) declaration could be delayed. The inspectors determined that this finding had a cross-cutting aspect in the area of Human Performance, Work Control, because PBAPS did not appropriately coordinate work activities by incorporating actions to address the impact of work on different job activities, and the need for work groups to communicate, coordinate, and cooperate with each other during activities in which interdepartmental coordination is necessary to assure plant and human performance H.3(b). Specifically, the impact of a PBAPS Emergency Plan Annex revision was not communicated properly or coordinated between the EP department and operations department, to assure that shift operations could implement compensatory measures as necessary for degraded EP equipment

[H.3.(b)]. (Section 1R22)

Cornerstone: Occupational Radiation Safety

Green.

The inspectors identified a NCV of very low safety significance of Technical Specification (TS) 5.7.2 because Exelon did not control the access point to a Locked High Radiation Area (LHRA). The performance deficiency (PD) was related to not controlling access to a Unit 3 LHRA. The LHRA became accessible when temporary scaffold was built on the south shield wall between the electrical generator and the main turbine. On August 19, the inspectors identified a permanent ladder from the top of the north side of the shield wall to the turbine deck floor that could allow access to the LHRA. Radiation Protection (RP) procedure RP-AA-460, Controls for High and LHRA, Revision 24, provides guidance for the control of high radiation areas (HRAs). By the procedure definition of accessible area, the area was accessible after the scaffold was built, and no tools or other exceptional measures were needed to gain access. The violation was entered into Exelons corrective action program (CAP) as action request (AR) 01548397.

The PD was more than minor because it is associated with the cornerstone attribute of Program and Process (RP controls), and negatively affected the Occupational Radiation Safety cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear power operation. There was also an example of this PD in example 6.g. of IMC 0612,

Appendix E, Examples of Minor Issues. This example concludes that the issue is more than minor because actual dose rates in excess of the posting requirements existed in the area. LHRAs are required to be posted and controlled properly to avoid unnecessary worker exposure. The finding was evaluated using the Occupational Radiation Safety SDP and was determined to be of very low safety significance (Green) because it was not related to As Low As is Reasonably Achievable (ALARA) planning, it did not involve an overexposure, did not constitute a substantial potential for overexposure, and the ability to access dose was not compromised. The finding included a cross-cutting aspect in the area of Work Controls, Human Performance component, because Exelon did not appropriately plan the work activities and identify the potential job site conditions (radiological hazards)associated with building scaffold next to a LHRA wall [H.3.(a)]. (Section 4OA5)

Other Findings

None.

REPORT DETAILS

Summary of Plant Status

Unit 2 began the inspection period at 100 percent power. On August 30, 2013, operators reduced power to approximately 80 percent to perform planned activities that included control rod testing, main turbine valve testing, main steam isolation valve (MSIV) testing, and reactor feed pump testing. On August 30, 2013, the Unit 2 B reactor recirculation (RR) pump tripped during the planned power reduction. Reactor power dropped to 40 percent unexpectedly when the B pump tripped due to a RR motor generator (MG) high lube oil (LO) temperature condition. The LO temperature setpoint input drifted below the operating temperature value.

The B MG high LO trip setpoint actuated at 175 degrees F versus the expected 210 degree F value. Unit 2 transitioned to single loop operation on August 31, 2013. After the installation and calibration of a new MG LO temperature switch, the B RR MG was placed in operation on September 1, 2013. Reactor power was increased from 40 percent to 100 percent on September 2, 2013. The unit remained at rated thermal power through the end of the inspection period.

Unit 3 began the inspection period at 100 percent power. On July 5, 2013, operators reduced power to approximately 82 percent to remove the 5A and 5C fifth stage feedwater (FW) heat exchangers (HXs) from service, prior to EOC coastdown, as a planned activity to reduce moisture carryover during the EOC coastdown. On July 31, 2013, the unit began its end-of-cycle (EOC) coast down period. Planned power reductions of approximately five percent rated thermal power were performed on July 26, 2013, to remove the 5B fifth stage FW HX and August 2, 2013, to remove the 4C fourth stage FW HX from service during the EOC coast down. On September 8, 2013, a planned shutdown from approximately 80 percent power was commenced, and the main generator breaker was opened to start the units 19th refueling outage (RFO) P3R19. During the shutdown, operators inserted a planned manual scram from approximately five percent reactor power. The unit remained shutdown in P3R19 through the end of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment (71111.04 - 3 Samples)

.1 Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

Unit 3 reactor core isolation cooling (RCIC) system with the high pressure coolant injection system (HPCI) out of service (OOS) for planned maintenance on August 5, 2013 Unit 2 and Unit 3 recirculation MGs on September 3, 2013 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 Updated Final Safety Analysis Report (UFSAR), TSs, work orders (WOs), condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also 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 Exelon staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

.2 Full System Walkdown

a. Inspection Scope

On August 11, 2013, the inspectors performed a complete system walkdown of accessible portions of the E-3 and E-4 emergency diesel generators (EDGs) to verify the existing equipment lineup was correct. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related CRs and WOs to ensure Exelon appropriately evaluated and resolved any deficiencies.

b. Findings

No findings were identified.

1R05 Fire Protection

Resident Inspector Quarterly Walkdowns (71111.05Q - 5 samples)

a. Inspection 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 were controlled 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 OOS, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

Unit 2 HPCI room on July 19, 2013 Unit 2 RB, elevation 135 on July 19, 2013 Unit 3 RB, elevation 234 on July 19, 2013 Unit 2 RCIC room on August 6, 2013 Unit 3 D residual heat removal (RHR) pump and HX room on August 6, 2013

b. Findings

No findings were identified.

1R08 Inservice Inspection Activities

a. Inspection Scope

From September 16, 2013 to September 20, 2013, the inspectors conducted a review of Exelons implementation of in-service inspection (ISI) program activities for monitoring degradation of the reactor coolant system (RCS) pressure boundary, risk significant piping and components, and containment systems for Unit 3. The sample selection for this inspection was based on the inspection procedure objectives and risk priority of those pressure retaining components in these systems where degradation would result in a significant increase in risk. The inspectors observed in-process non-destructive examinations (NDE), reviewed documentation, and interviewed inspection personnel to verify that the NDE activities performed as part of Interval 4, Period 2 of the Unit 3 ISI program during the PBAPS Unit 3 19th Refueling and Inspection Outage were conducted in accordance with the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI, 2001 Edition, 2003 Addenda.

Nondestructive Examination and Welding Activities The inspector performed direct observations of NDE activities in process and reviewed records of NDEs listed below:

ASME Code Required Examinations The inspectors performed a field observation of the ultrasonic examination (UT) of weld ISI-14-B-3 in the core spray (CS) system. The inspectors observed the calibration of the testing equipment, reviewed the results of previous inspection of the weld and reviewed the testing procedure being used. After observing the technicians performing the inspection the inspectors reviewed the completed data sheets.

The inspectors performed a field observation of the UT of FW nozzle N4D nozzle to reactor vessel weld. The inspectors observed the calibration of the testing equipment, reviewed the results of a previous inspection of the weld and reviewed the testing procedure. The inspectors observed the technicians performing the inspection and reviewed the completed data sheets.

The inspectors observed the calibration of the phased array UT equipment used to examine dissimilar metal weld 14-A-46DM, nozzle N5A safe end to nozzle weld. The inspectors also reviewed the completed Examination Summary Sheet, Report No. 169694 for the completed dissimilar metal weld examination.

The inspectors reviewed a sample of certifications for NDE technicians performing ASME Code examinations and verified the inspections were performed in accordance with approved procedures and that the results were reviewed and evaluated by certified Level III NDE personnel.

Other Augmented or Industry Initiative Examinations The inspectors reviewed inspection records of visual examinations conducted on reactor vessel internals components during the prior (U3-18th) RFO. These inspections were carried out in accordance with the industry initiative under the Boiling Water Reactor Vessel and Internals Project , In-Vessel Visual Inspection (IVVI) Program. These inspections monitor and record the condition of the reactor vessel internal components.

Specifically, the inspectors reviewed visual testing (VT) examination data records and reviewed the disposition of indications noted by the inspectors. The inspectors verified that the activities were performed in accordance with applicable examination procedures and industry guidance. All recorded indications were recorded and dispositioned by the NDE examiner and the licensee as acceptable for further service.

Review of Originally Rejectable Indications Accepted by Evaluation The inspectors reviewed several ARs which documented, recordable, rejectable non-conforming conditions discovered during visual inspection of piping system supports.

For the ARs reviewed, Exelons staff conducted appropriate repairs or completed technical evaluations justifying continued operation of the systems without repairs.

Repair/Replacement Activities Including Welding Activities The inspectors reviewed WO C0245643, which added main steam (MS) snubber supports to the Unit 3 MS relief valve piping.

The inspectors reviewed an Extended Power Uprate (EPU) project modification (Engineering Change Request (ECR)-PB 11-00496 003), which made changes and additions to the RHR system piping to provide for simultaneous use of two RHR HXs for plant cooldown at the proposed EPU power level. (License Amendment request currently under NRC review). This project was not completed during the R19 outage. The new piping to the #1 RHR HX has been installed and tested satisfactorily. The future connections to the #2 RHR HX have been closed with blank flanges for completion during a future outage. The inspectors reviewed the surveillance test used to verify the repair and reviewed the completion of the ECR VT of the new piping.

The inspectors reviewed the ECR for the replacement of the CS system piping internal to the reactor vessel. The inspectors reviewed the design specification for the new piping assembly, the 10 CFR 50.59 screening of the piping modification and reviewed evaluations performed to verify that the new piping maintained the original CS design basis. The inspectors reviewed the CS surveillance test which verified the ability to add sufficient water to the reactor vessel.

The inspectors reviewed WO C0245643 which installed MS line A/B snubber supports inside the Unit 3 drywell during outage R19. The inspectors reviewed the WO instructions, the completed work order document, the specified welding material records and material list, and the welder qualification tests.

Identification and Resolution of Problems (71152)

The inspectors reviewed a sample of Exelon corrective action reports, which identified NDE indications, deficiencies and other nonconforming conditions since the previous U3-18th refueling outage (RFO). The inspectors verified that nonconforming conditions were, in general, properly identified, entered into the CAP, characterized, evaluated, and corrective actions identified and completed.

b. Finding No findings were identified.

1R11 Licensed Operator Requalification Program

Quarterly Review of Licensed Operator Performance in the Main Control Room

a. Inspection Scope

The inspectors observed licensed operator performance in the Unit 2 main control room (MCR) during downpower on August 30, 2013, and during power escalation on September 1, 2013. The inspectors observed maintenance and test performance to verify that procedure use, crew communications, and coordination of activities between work groups met established expectations and standards. Additionally, the inspectors observed reactivity manipulations to verify that they were performed in a safe and controlled manner, and included the appropriate level of peer verification and supervisory oversight.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the sample 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 within the scope of the MR. For each sample selected, the inspectors verified that the SSC was properly scoped into the MR in accordance with Title 10 CFR 50.65 and that the (a)(2)performance criteria established by the Exelon staff were reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2) status. Additionally, the inspectors ensured that PBAPS staff was identifying and addressing common cause failures that occurred within and across MR system boundaries.

Unit 3 RHR shutdown cooling pressure switches on September 12, 2013

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

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 cornerstones. As applicable for each activity, the inspectors verified that PBAPS personnel performed risk assessments as required by 10 CFR 50.65(a)(4) 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 stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

Elevated risk on Units 2 and 3 during planned maintenance on E-4 EDG on July 1, 2013 Elevated Unit 3 risk following D inboard MSIV direct-current solenoid valve failure on July 31, 2013 Elevated Unit 2 risk during planned maintenance on the HPCI system on August 5, 2013 Elevated Unit 2 risk during troubleshoot, rework test (TRT) 13-0009 to re-seat HPCI turbine steam supply valve MO-2-23-014 on August 8, 2013 Unit 3 MG rotor lift to the main turbine deck on August 26, 2013

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed seven operability determinations (ODs) for the following degraded or non-conforming conditions:

Unit 2 and 3 vent stack degraded flow instrumentation on July 8, 2013 Unit 3 elevated moisture carryover impact on downstream components on July 8, 9, and 10, 2013 E-1 EDG operability on July 15, 2013 Unit 3 elevated maximum fraction of limiting power density (MFLPD) thermal limit on August 1, 2013 MCR radiation monitors on August 23, 2013 Unit 2 HPCI on September 10, 2013 Unit 2 Appendix R calculation on September 29, 2013 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the ODs to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to PBAPSs 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. Findings

No findings were identified.

1R19 Post-Maintenance Testing

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 that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with 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 A high-pressure service water (HPSW) discharge check valve planned preventive maintenance on July 3 and 5, 2013 B control room emergency ventilation damper flow controller troubleshooting, minor corrective maintenance, and calibration on August 2, 2013 Unit 2 HPCI corrective maintenance to repair steam line drain valve packing leakage on August 6, 2013 Unit 2 restart of B recirculation pump on September 1, 2013 Unit 3 CS pump breaker on September 26, 2013 Unit 3 safety relief valve thread seal replacement on September 30, 2013

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

Peach Bottom Unit 3 Outage - Refueling (P3R19)

a. Inspection Scope

The inspectors reviewed the stations work schedule and outage risk plan for the Unit 3 maintenance and refueling outage (P3R19) which began on September 8, 2013, and continued through the end of the inspection period. The inspectors reviewed Exelons development and implementation of outage plans and schedules to verify that risk, industry experience, previous site-specific problems, and defense-in-depth were considered. Inspection of the design, preparations and work scope for the replacement of the Unit 3 CS piping, planned for the fall 2013 RFO, was performed. The replacement scope is two loops of the CS piping from the vessel nozzles to the CS spargers. The inspectors reviewed ECR PB-10-00279 for the Unit 3 CS in-vessel piping replacement, discussed the replacement scope with plant and contractor staff, observed the staged pipe components, and evaluated the 10 CFR 50.59 applicability to the change analysis.

The replacement configuration represents an equivalent change as defined in Procedure CC-AA-10, Revision 6, Configuration Control Process Description" and, therefore, did not require a 10 CFR 50.59 review. During the outage, the inspectors observed portions of the shutdown and cooldown processes and monitored controls associated with the following outage activities:

Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable TSs when taking equipment OOS Implementation of clearance activities and confirmation that tags were properly hung and that equipment was appropriately configured to safely support the associated work or testing Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication and instrument error accounting Status and configuration of electrical systems and switchyard activities to ensure that TSs were met Monitoring of decay heat removal operations Impact of outage work on the ability of the operators to operate the spent fuel pool cooling system Reactor water inventory controls, including flow paths, configurations, alternative means for inventory additions, and controls to prevent inventory loss Activities that could affect reactivity Maintenance of secondary containment as required by TSs Fatigue management Refueling activities, including fuel handling and fuel receipt inspections Control of heatup and startup activities

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

(3 routine surveillances; 1 RCS sample; 1 IST sample; 1 ISO)

The inspectors observed performance of surveillance tests (STs) and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TSs, the UFSAR, and PBAPS procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following STs:

ST-O-020-560-2, Reactor Coolant Leakage Test, Revision 13, on July 25, 2013 (RCS)

SI3R-63E-3979-B1CE, Vent Stack Radiation Monitor RY-3979B Electronic Calibration Check, on July 25 and 26, 2013 E-3 EDG / RHR Pump Reject after ST on August 12, 2013 (IST)

Unit 2 HPCI Pump, Valve, and Flow on September 9, 2013 ST-O-052-190-3, Simultaneous Start of All EDGs, Revision 11 on September 24, 2013 Containment ST, Unit 3 MSIV Surveillance on September 11, 2013 (ISO)

b. Findings

Introduction.

The inspectors identified a Green NCV of 10 CFR 50.54(q)(2) associated with 50.47(b)(4) because PBAPS failed to control EP procedure changes in a manner that ensured timely EAL classification for effluent parameters.

Description.

On June 27, 2013, PBAPS issued Revision 27 to EP-AA-1007, Exelon Nuclear Radiological Emergency Plan Annex for PBAPS. One of the plan changes involved removal of the 'A' ventilation and main stack radiation monitors from radiological effluent EAL Matrix Table 3-1, and thereby rendered the B ventilation and main stack radiation monitors as the only means of EAL classification for effluent releases from the RB ventilation stacks and main stack. Revision 27 was reviewed and approved by PBAPS Plant Operations Review Committee (PORC), as required by EP-AA-121, Emergency Plan Administration, on May 28, 2013. The release rate channels of both the 'A' and 'B' RB ventilation and main stack radiation monitors had historically been relied upon for EAL classification of effluent releases at the UE, Alert, station area emergency (SAE), and the general emergency (GE) levels. The instrument range of the B wide range monitors were designed to support EAL classification for the UE, Alert, SAE, and GE levels. However, the A narrow range monitors were only designed to support UE EAL classification. Following May 28, 2013, approval of the Emergency Plan Annex, PORC action item 1013944-40 required the EP Department to ensure adequate guidance existed to operating crews clarifying the backup function of the A main stack radiation monitor was limited to UEs, but did not include action to ensure adequate guidance existed for the A ventilation stack radiation monitor. The inspectors noted that the guidance issued by the EP department only included an email to SMs and station emergency directors. An action to provide information related to the specific changes during licensed operator requalification training was scheduled after the change implementation date.

On July 24, 2013, during the performance of Unit 3 SI3R-63E-3979-B1CE, Vent Stack Rad Monitor Electronic Calibration Check, the flow transmitter associated with the B ventilation stack wide range radiation monitor failed, thereby rendering the instrument inoperable for EAL classification. Instrument and control technicians generated IR 1539484 to capture the failure and immediately contacted operations. Operations entered Technical Requirements Manual (TRM) statement 3.6 and declared the B RB ventilation stack radiation monitor inoperable. Following the TRM entry, the inspectors questioned the control room supervisor (CRS) about the ability to make timely and accurate EAL classifications with the B RB ventilation stack radiation monitor inoperable. The inspectors also questioned whether the A monitor could be used as an adequate back-up to compensate for the 'B' monitor. The CRS did not have an immediate answer, and subsequently engaged the SM. The SM immediately referenced the PBAPS Emergency Plan Annex. The SM noted that the current revision only allowed use of the B RB ventilation stack radiation monitor for effluent release EAL classifications, and no longer allowed use of the 'A' monitor as contained in previous revisions. Shift operations were unable to provide an immediate answer to questions from the inspectors, but understood the questions and pursued a response with the appropriate level of prioritization.

Later on the same shift, the SM provided a response to the inspector regarding the EAL classification impact associated with the B ventilation stack radiation monitor failure.

The SM stated that compensatory measures were required for degraded EP equipment under EP-AA-121, "Emergency Response Facilities and Equipment Readiness," and the

'A' ventilation stack radiation monitor was established as a compensatory measure for the inoperable 'B' monitor in response to questions by the inspectors. The SM further stated that the range of the 'A' monitor supported effluent release thresholds through the UE, and partially into the Alert threshold. On July 30, the 'B' ventilation stack radiation monitor was restored to an operable condition.

Following the inspectors questions on July 24, 2013, Operations Management initiated IR 1539674 to capture the programmatic deficiencies that were revealed as a result of the inspectors questions. Specifically, no formal written guidance was provided to operations following the issuance of Revision 27 to the PBAPS Emergency Plan Annex.

Additionally, EP-AA-121, Attachment F-07, "Peach Bottom Equipment Matrix," Revision 2, was not updated to provide compensatory measures for an inoperable B ventilation stack radiation monitor following issuance of Revision 27 to the PBAPS Emergency Plan Annex I, EP-AA-121, Attachment F-07, improperly classified the ventilation stack radiation monitors as Category 2 emergency preparedness equipment, which do not require compensatory measures when OOS. As a result of questions by the inspectors, Revision 3 to EP-AA-121, Attachment F-07, was issued on July 29, 2013, to change the ventilation stack radiation monitors to Category 1 equipment, thereby requiring compensatory measures when OOS. On September 5, 2013, Revision 28 to the PBAPS Emergency Plan Annex was issued, which appropriately reincorporated the A ventilation and main stack radiation monitors into radiological effluent EAL matrix Table 3-1 for use only in UE classifications.

Additionally, the questions posed by the inspectors identified a knowledge gap between the operations and EP departments on the use and application of procedural guidance for compensatory measures of degraded EP equipment. As a result of this knowledge gap, PBAPS issued OIU 13-10 to the SMs on September 9, 2013, to clarify the purpose of EP-AA-121 and EP-AA-121, Attachment F-07, as captured under assignment 3 to IR 1539674. Additionally, Assignment 4 to IR 1539674 was created for the PBAPS chair of the licensed operator requalification training (LORT) CRC to review inclusion of EP-AA-121, Attachment F-07, in LORT CRC. Despite the procedural knowledge gaps, the inspectors noted that licensed operators were knowledgeable and proficient in the design differences associated with the narrow range A and wide range B ventilation stack radiation monitors.

Analysis.

The inspectors determined that PBAPSs inadequate control of EP procedure changes resulted in the potential for an untimely EAL classification by shift operations.

This constituted a PD. Specifically, PBAPS did not ensure approved written guidance existed to operating crews clarifying the backup function of the A RB ventilation stack radiation monitor for assessment capability of UEs. This finding was more than minor because it was associated with the procedure quality attribute of the Emergency Preparedness cornerstone, and adversely affected the associated cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the public health and safety in the event of a radiological emergency. Additionally, this PD was similar to example 3.k of IMC 0612, Appendix E, because there was a programmatic deficiency that could lead to more significant errors if left uncorrected.

Using IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, and IMC 0609, Appendix B, Emergency Preparedness SDP, the inspectors determined that this finding was of very low safety significance (Green) using Table 5.4.1. Specifically, this finding rendered an EAL ineffective such that a UE declaration could be delayed. Additionally, the inspectors determined that an appropriate GE or SAE declaration could have been made in an accurate and timely manner because of the plant design and other overlapping EALs. Specifically, secondary containment isolates from the ventilation stack, prior to the Alert threshold, and is directed to a monitored release point at the main stack. Therefore, the main stack effluent thresholds would provide timely and accurate compensation for radioactive releases inside secondary containment. For events with RB ventilation stack effluent releases due to elevated radioactive releases inside the turbine building, low RPV water level and high drywell radiation levels would be precursors to core damage and could adequately compensate for an ineffective effluent monitor because the declaration could be performed, as required.

The inspectors determined that this finding had a cross-cutting aspect in the area of Human Performance, Work Control, because PBAPS did not appropriately coordinate work activities by incorporating actions to address the impact of work on different job activities, and the need for work groups to communicate, coordinate, and cooperate with each other during activities in which interdepartmental coordination is necessary to assure plant and human performance H.3(b). Specifically, the impact of Revision 27 to the PBAPS Emergency Plan Annex on EP-AA-121, "Emergency Response Facilities and Equipment Readiness," Attachment F-07, "Peach Bottom Equipment Matrix," was not communicated properly or coordinated between the EP department and operations department, to assure that shift operations could implement compensatory measures as necessary for degraded EP equipment.

Enforcement.

10 CFR 50.54(q)(2) requires that the facility licensee follow and maintain in effect emergency plans which meet the standards in 10 CFR 50.47(b). 10 CFR 50.47(b)(4) requires, in part, that emergency response plans include a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters. Contrary to the above, PBAPS did not maintain in effect the Emergency Plan to meet the standard in 10 CFR 50.47(b)(4) that requires the EAL scheme bases include facility system and effluent parameters. Specifically, revision 27 to the PBAPS Emergency Plan Annex was issued on June 25, 2013, without adequate guidance to ensure operations could make timely and accurate UE classification with a degraded or inoperable B ventilation stack radiation monitor.

On July 29, 2013, PBAPS issued a revision to EP-AA-121 to provide appropriate compensatory measure guidance for a degraded or inoperable B ventilation stack radiation monitor. Additionally, on September 5, 2013, Revision 28, to the PBAPS Emergency Plan Annex was issued, which reincorporated the A ventilation stack radiation monitor into radiological effluent EAL matrix Table 3-1 for use in UE classifications. Because this finding was of very low safety significance and was entered into the Exelons CAP via IRs 1539484 and 1539674, this violation is being treated as an NCV consistent with Section 2.3.2 of the NRCs Enforcement Policy. (NCV 05000277, 278/2013004-01, Inadequate EP Procedure Change Management Controls to Ensure Adequate EAL Classification and Assessment Capability for Effluent Parameters)

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

The Office of Nuclear Security and Incident Response (NSIR) headquarters staff performed an in-office review of the latest revisions of various Emergency Plan Implementing Procedures and the Emergency Plan located under ADAMS accession numbers ML13162A199 and ML13200A124 as listed in the Attachment.

The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection. The specific documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings were identified.

1EP6 EP Drill Evaluation

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine PBAPS emergency drill on July 9, 2013, to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator and technical support center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the station drill critique to compare inspector observations with those identified by Exelon staff in order to evaluate PBAPSs critique and to verify whether the PBAPS staff was properly identifying weaknesses and entering them into the CAP.

b. Findings

No findings were identified.

2RS1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

During the week of September 16-20, 2013, the inspectors reviewed and assessed Exelon performance in assessing the radiological hazards in the workplace and the implementation of appropriate radiation monitoring and exposure control measures.

The inspectors used the requirements in 10 CFR Part 20 and guidance in Regulatory Guide (RG) 8.38 Control of Access to High and VHRAs for Nuclear Plants, the TSs, and the licensees procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspector reviewed Exelon performance indicators (PIs) for the Occupational Exposure cornerstone for follow-up. The inspectors reviewed the results of RP program audits and reports of operational occurrences related to occupational radiation safety since the last inspection.

Radiological Hazard Assessment The inspectors selected radiologically risk-significant work activities that involved exposure to radiation. The inspectors verified that appropriate pre-work surveys were performed. The inspectors evaluated the radiological survey program to determine if radiological hazards were properly identified.

The inspectors selected air sample survey records and verified that samples were collected and counted in accordance with licensee procedures. The inspectors observed work in potential airborne areas, and verified that air samples were representative of the breathing air zone. The inspectors verified that Exelon has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne.

Instructions to Workers The inspectors reviewed radiation work permits (RWPs) used to access HRAs and identify what work control instructions or control barriers had been specified. The inspectors verified that allowable stay times or permissible dose for radiologically significant work under each RWP was clearly identified. The inspectors verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy.

The inspectors reviewed instances of EPD malfunction or alarm. The inspectors verified that the issue was included in the CAP and dose evaluations were conducted as appropriate.

Contamination and Radioactive Material Control The inspectors observed several locations where the licensee monitors potentially contaminated material leaving the radiologically controlled area (RCA), and inspected the methods used for control, survey, and release from these areas. The inspectors verified that the radiation monitoring instrumentation had appropriate detection sensitivity. The inspectors reviewed Exelons criteria for the survey and release of potentially contaminated material.

Radiological Hazards Control and Work Coverage During tours of the facility and review of ongoing work the inspectors evaluated current radiological conditions and verified that existing conditions were consistent with posted surveys, RWPs, and worker briefings. During job performance observations, the inspectors verified the adequacy of radiological controls and evaluated Exelons means of using EPDs in high noise areas as HRA monitoring devices.

The inspectors verified that radiation monitoring devices were placed on the individuals body in the location of highest dose or were utilizing an NRC-approved method of determining effective dose equivalent.

The inspectors reviewed RWPs for work within airborne radioactivity areas and evaluated the controls and monitoring. For these airborne radioactive material areas, the inspectors verified barrier integrity and temporary high-efficiency particulate air (HEPA) ventilation system operation.

During job performance observations, the inspectors observed radiation worker performance and RP technicians with respect to RP requirements. The inspectors evaluated if they were aware of the radiological conditions in their workplace, their RWP requirements, and that their performance was commensurate with these requirements.

The inspectors reviewed radiological problem reports since the last inspection that found the cause of the event to be human performance or RP technician error. The inspectors determined that there was no observable pattern traceable to similar causes. The inspectors determined that this perspective matched the corrective action approach taken by Exelon to resolve the reported problems. The inspectors discussed with the radiation protection manager (RPM) any problems with the corrective actions planned or taken. The inspectors determined that this perspective matched the corrective action approach taken by Exelon to resolve the reported problems.

The inspectors verified that problems associated with radiation monitoring and exposure control were being identified by Exelon at an appropriate threshold and were properly addressed for resolution in the licensees CAP. In addition to the above, the inspectors verified the appropriateness of the corrective actions for a selected sample of problems documented by Exelon that involve radiation monitoring and exposure controls. The inspectors determined that the licensee was assessing the applicability of operating experience to their plants.

b. Findings

No findings were identified.

2RS2 Occupational ALARA Planning and Controls

a. Inspection Scope

During the week of July 29 - August 2, 2013 and September 16-20, 2013, the inspectors assessed performance with respect to maintaining individual and collective radiation exposures ALARA. The inspectors used the requirements in 10 CFR Part 20, RG 8.8, Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Plants will be ALARA, RG 8.10. Operating Philosophy for Maintaining Occupational Radiation Exposure ALARA, the TSs, and the licensees procedures required by TSs as criteria for determining compliance.

Radiological Work Planning The inspectors selected from a list of work activities that were in progress or that have been completed during the last outage, those work activities of highest collective exposure. For those work activities, the inspectors reviewed the ALARA work activity evaluations, exposure estimates, and exposure mitigation requirements. The inspectors evaluated if Exelon had reasonably grouped the radiological work into work activities, based on historical precedence. The inspectors assessed whether Exelons planning identified appropriate dose mitigation features; considered alternate mitigation features; and defined reasonable dose goals. The inspectors evaluated whether Exelons ALARA assessment had taken into account decreased worker efficiency from use of respiratory protective devices. The inspectors also evaluated if Exelons work planning considered the use of remote technologies and the use of other dose reduction insights from industry operating experience and plant-specific lessons learned. The inspectors reviewed the integration of ALARA requirements into work procedure and RWP documents.

Verification of Dose Estimates and Exposure Tracking Systems The inspectors evaluated Exelons measures to track, trend, and reduce occupational doses for ongoing work activities. The inspectors verified that dose threshold criteria were established to prompt additional ALARA planning and controls.

The inspectors evaluated Exelons method of adjusting exposure estimates, or re-planning work when unexpected changes in scope or emergent work were encountered.

The inspectors evaluated if adjustments to exposure estimates were based on sound RP and ALARA principles or if they were just adjusted due to failure to control the work.

Radiation Worker Performance The inspectors observed radiation worker and RP technician performance during work activities being performed in radiation areas, airborne radioactivity areas, or high radiation areas. The inspectors determined that workers demonstrate the ALARA philosophy in practice and that there were no procedure compliance issues. Also, the inspectors observed radiation worker performance to determine whether the training and skill level was sufficient with respect to the radiological hazards and the work involved.

Source Term Reduction and Control Using licensee records, the inspectors determined the historical trends and current status of significant tracked plant source term. The inspectors determined that the licensee was making allowances or developing contingency plans for expected changes in the source term as the result of changes in plant fuel performance issues or changes in plant primary chemistry.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

a. Inspection Scope

During the week of July 29 - August 2, 2013, the inspectors reviewed the accuracy and operability of personal monitoring equipment; the accuracy and effectiveness of Exelons methods for determining total effective dose equivalent; and the adequacy of occupational dose monitoring. The inspectors used the requirements in 10 CFR Part 20, the guidance in RG 8.13, Instructions Concerning Prenatal Radiation Exposures, RG 8.36, Radiation Dose to Embryo Fetus, RG 8.40, Methods for Measuring Effective Dose Equivalent from External Exposure, TSs, and the licensees procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspectors reviewed the results of RP program audits related to internal and external dosimetry.

Internal Dosimetry The inspectors reviewed the adequacy of Exelons program for dose assessments based on airborne/Derived Air Concentration (DAC) monitoring. The inspectors verified that flow rates and collection times for fixed head air samplers were adequate to ensure that appropriate lower limits of detection were obtained. The inspectors reviewed the adequacy of procedural guidance used to assess dose when Exelon applies protection factors. The inspectors reviewed dose assessments performed using airborne/DAC monitoring. The inspectors verified that Exelons DAC calculations were representative of the actual airborne radionuclide mixture, including hard-to-detect nuclides.

The inspectors reviewed the adequacy of Exelons internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose equivalent.

The inspectors determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures. Exelon had one individual with an assigned internal dose assessment of 20 millirem during the all 2012 Unit 2 RFO.

Special Dosimetric Situations The inspectors verified that Exelon informed workers of the risks of radiation exposure to the embryo/fetus, the regulatory aspects of declaring a pregnancy, and the specific process to be used for (voluntarily) declaring a pregnancy.

The inspectors selected individuals who had declared their pregnancy during the current assessment period, and verified that Exelons radiological monitoring program for declared pregnant workers was technically adequate to assess the dose to the embryo/fetus. One individual was in a declared status during a portion of the assessment period of January 1, 2012 - August 1, 2013.

Problem Identification and Resolution The inspectors verified that problems associated with occupational dose assessment were being identified by Exelon at an appropriate threshold and were properly addressed for resolution in Exelons CAP. In addition, the inspectors verified the appropriateness of the corrective actions for a selected sample of problems documented by the licensee involving occupational dose assessment.

b. Findings

No findings were identified.

2RS5 Radiation Monitoring Instrumentation

a. Inspection Scope

During the week of July 29 - August 2, 2013, the inspectors reviewed the accuracy and operability of radiation monitoring instruments that are used to

(1) monitor areas, materials, and workers and

(2) detect and quantify radioactive process streams and effluent releases. The instrumentation subject to this review included equipment used to monitor radiological conditions incident to normal plant operations, including anticipated operational occurrences, and conditions resulting from postulated accidents. The inspectors used the requirements in 10 CFR Part 20, 10 CFR Part 50, Appendix A, Criterion 60, Control of Release of Radioactivity to the Environment, and Criterion 64, Monitoring Radioactive Releases, 10 CFR 50, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to meet the Criterion, ALARA for Radioactive Material in Light-Water - Cooled Nuclear Power Reactor Effluents, 40 CFR Part 190, Environmental RP Standards for Nuclear Power Operations, NUREG 0737, Clarification of Three Mile Island Corrective Action Requirements, the TSs/Offsite Dose Calculation Manual (ODCM), applicable industry standards, and the licensees procedures required by TSs as criteria for determining compliance.

Walkdowns and Observations The inspectors checked portable survey instrument calibration and source check stickers for currency, and assessed instrument material condition and operability.

The inspectors observed licensee staff demonstrate source checks for various types of portable survey instruments. The inspectors determined that high-range instruments were source checked on all appropriate scales.

The inspectors walked down area radiation monitors (ARMs) and continuous air monitors (CAMs) and determined that they were appropriately positioned relative to the radiation sources or areas they were intended to monitor.

The inspectors verified that the periodic source checks for personnel contamination monitors and small article monitors were performed in accordance with the manufacturers recommendations and licensee procedures. The inspectors verified that the alarm set-point values were reasonable under the circumstances to ensure that licensed material is not released from the site.

Calibration and Testing Program The inspectors reviewed the methods and sources used to perform whole body counter (WBC) functional checks before daily use of the instrument. The inspectors determined that check sources were appropriate for the plants isotopic mix.

The inspectors reviewed WBC calibration reports completed since the last inspection to verify that calibration sources were representative of the plant source term and that appropriate calibration phantoms were used. Exelon maintains two FASTSCAN WBCs, one located by the RCA access control point, and another at the security building.

The inspectors reviewed calibration documentation for each instrument mentioned above and reviewed the calibration methods used to determine consistency with the manufacturers recommendations.

For portable survey instruments and ARMs, the inspectors reviewed detector measurement geometry and calibration methods, and observed the licensee demonstrate use of the instrument calibrator.

The inspectors selected portable survey instruments that did not meet acceptance criteria during calibration or source checks. The inspectors verified that the licensee had taken appropriate corrective action for instruments found out of calibration.

The inspectors reviewed the current output values for Exelons portable survey and ARM instrument calibrator units. The inspectors verified that Exelon periodically measured calibrator output over the useful range of the instruments.

The inspectors visited the Exelon Power Lab in Coatesville, PA, and verified that the measuring devices had been calibrated using National Institute of Standards and Technology traceable sources and that correction factors for these measuring devices were properly applied in instrument output verification.

The inspectors reviewed the licensees 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste, source term to determine if the calibration sources used were representative of the types and energies of radiation encountered in the plant.

Problem Identification and Resolution The inspectors verified that problems associated with radiation monitoring instrumentation were being identified by Exelon at an appropriate threshold and were properly addressed for resolution in the licensees CAP.

b. Findings

No findings were identified.

2RS7 Radiological Environmental Monitoring Program (REMP)

a. Inspection Scope

During the week of September 3-6, 2013, the inspectors verified that the REMP validates the integrity of the radioactive gaseous and liquid effluent release program.

The inspectors used the requirements in 10 CFR Part 20; 10 CFR Part 50, Appendix A, Criterion 60 - Control of Release of Radioactivity to the Environment; 10 CFR 50, Appendix I Numerical Guides for Design Objectives and Limiting Conditions for Operations to Meet the Criterion ALARA for Radioactive Material in Light-Water -

Cooled Nuclear Power Reactor Effluents; 40 CFR Part 190, Environmental RP Standards for Nuclear Power Operations; 40 CFR Part 141, Maximum Contaminant Levels for Radionuclides; the guidance in RGs 1.23, 4.1 and 4.15, NUREG 1301 or 1302, as well as, applicable industry standards and licensee procedures as criteria for determining compliance.

Inspection Planning

The inspectors reviewed the annual radiological environmental operating reports, and the results of any licensee assessments since the last inspection, to verify that the REMP was implemented in accordance with the plant TS and the ODCM. The inspectors reviewed the report for changes to the ODCM with respect to environmental monitoring, sampling locations, monitoring and measurement frequencies, land use census, inter-laboratory comparison program, and data analysis. The inspectors reviewed the ODCM to identify locations of environmental monitoring stations. The inspectors reviewed the final safety analysis report (FSAR) for information regarding the environmental monitoring program and meteorological monitoring instrumentation.

The inspectors reviewed the annual effluent release report and the 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste, report, to determine if the licensee was sampling for the predominant radionuclides released in effluents.

Site Inspection The inspectors walked down air sampling stations and thermoluminescent dosimeter (TLD) monitoring stations to determine whether they were located as described in the ODCM and to determine the equipment material condition.

For the air samplers and TLDs selected above, the inspectors reviewed the calibration and maintenance records to verify the operability of these components. Additionally, the inspectors reviewed the calibration and maintenance records of composite water samplers. The inspectors verified that Exelon had initiated appropriate sampling upon loss of a required sampling station.

The inspectors observed the collection and preparation of various types of environmental samples. The inspectors verified that environmental sampling was representative of the release pathways as specified in the ODCM and that sampling techniques were in accordance with procedures.

Based on direct observation and review of records, the inspectors verified that the meteorological instruments are operable, calibrated, and maintained. The inspectors verified that the meteorological data readout and recording instruments in the control room and at the tower were operable.

The inspectors verified that missed and or anomalous environmental samples were identified and reported in the annual environmental monitoring report. The inspectors reviewed Exelons assessment of any positive sample results. The inspectors reviewed the associated radioactive effluent release data that was the source of the released material.

The inspectors selected SSCs that involved the potential release of radioactive liquids due to leaks to reach ground water, and verified that the licensee had implemented a sampling and monitoring program sufficient to detect leakage of these SSCs to ground water. The inspectors verified that records of leaks, spills, and remediation since the previous inspection were maintained.

The inspectors reviewed any significant changes made by Exelon to the ODCM as the result of changes to the land census, long-term meteorological conditions (3-year average), or modifications to the sampler stations since the last inspection. The inspectors reviewed technical justifications for any changed sampling locations. The inspectors verified that the licensee performed the reviews required to ensure that the changes did not affect its ability to monitor the impacts of radioactive effluent releases on the environment.

The inspectors verified that the appropriate detection sensitivities with respect to TS/ODCM were used for counting samples. The inspectors reviewed quality control charts for maintaining radiation measurement instrument status and actions taken for degrading detector performance.

The inspectors reviewed the results of the licensees inter-laboratory comparison program to verify the adequacy of environmental sample analyses performed by the licensee. The inspectors verified that the inter-laboratory comparison test included the media/nuclide mix appropriate for the facility.

Identification and Resolution of Problems The inspectors verified that problems associated with the REMP are being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensees CAP. The inspectors verified the appropriateness of the corrective actions for a selected sample of problems documented by the licensee that involved the REMP.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure (IP) 71152, Problem Identification 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 condition report screening meetings.

b. Findings

No findings were identified.

.2 Semi-Annual Trend Review (1 Semi-annual Trend sample)

a. Inspection Scope

The inspectors performed a semi-annual review of site issues, as required by IP 71152, Problem Identification and Resolution, to identify trends that might indicate the existence of more significant safety issues. In this review, the inspectors included repetitive or closely-related issues that may have been documented by PBAPS outside of the CAP, such as trend reports, PIs, major equipment problem lists, system health reports, MR assessments, and maintenance or CAP backlogs. The inspectors also reviewed PBAPSs CAP database for the six month period covering September 1, 2012 through March 2013, to assess CRs written in various subject areas (equipment problems, human performance issues, etc.), and individual issues identified during the NRCs daily CR review (Section 4OA2.1). The inspectors reviewed the PBAPSs trend report for the fourth quarter of 2012 and the first quarter of 2013, conducted under LS-AA-125-1005, Coding and Analysis Manual, to verify that PBAPS personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures.

b. Findings and Observations

No findings were identified. The inspectors noted minor adverse trends identified by PBAPS in the areas of site-wide human performance, maintenance work package quality, and aging equipment reliability. There were no adverse safety consequences as a result of these low level trend issues. Based on the overall results of the semi-annual trend review, the inspectors determined that PBAPS was appropriately identifying and entering issues into the CAP, adequately evaluating the identified issues, and properly identifying adverse trends before they became more safety significant problems.

.3 Annual Sample: Review of the Operator Workaround (OWA) Program (1 sample)

a. Inspection Scope

The inspectors reviewed the cumulative effects of the existing OWAs, operator burdens, existing operator aids, disabled alarms, and open MCR deficiencies to identify any effect on emergency operating procedure operator actions, and any impact on possible initiating events and mitigating systems. The inspectors evaluated whether station personnel had identified, assessed, and reviewed OWAs as specified in Exelon procedure OP-AA-102-103, OWA Program.

The inspectors reviewed PBAPSs process to identify, prioritize, and resolve MCR distractions to minimize operator burdens. The inspectors reviewed the system used to track these OWAs and recent PBAPS self-assessments of the program. The inspectors also toured the control room and discussed the current operator workarounds with the operators to ensure the items were being addressed on a schedule consistent with their relative safety significance. The inspectors attended an OWA board meeting to evaluate PBAPs process to update existing OWA items and screen new items.

b. Findings and Observations

No findings were identified. The inspectors determined that the issues reviewed did not adversely affect the capability of the operators to implement abnormal or emergency operating procedures. The inspectors also verified that PBAPS entered OWAs and burdens into the CAP at an appropriate threshold and planned or implemented corrective actions commensurate with their safety significance.

.4 Annual Sample: Review of Various Component Leaks (1 sample)

a. Inspection Scope

The inspectors reviewed Exelons actions to resolve various component leaks that occurred during the past year to verify that the leaks were appropriately identified, evaluated and mitigated. The scope of issues reviewed was identified by conducting a search of the AR and the work tracking data bases. The search included IRs and AR reports of leakage in gaskets, seals, and pressure boundary components. Leak locations that were accessible during plant operation were observed by the inspector and corrective actions were discussed with the responsible engineers to verify that appropriate corrective and preventive actions were implemented. The inspection scope included ASME Boiler and Pressure Vessel Code Class 1, 2, and 3 systems, including the emergency service water system, HPSW system, hydraulic control units, buried piping, flow accelerated corrosion susceptible systems, and the service water system.

Corporate and site specific processes and procedures for leak response were reviewed and compared to the selected samples to verify that the procedures were followed and the effectiveness of the actions implemented.

b. Findings

No findings were identified. The inspector noted that leakage of risk and safety significant components were evaluated and mitigated appropriately, in accordance to the ASME Code requirements, plant procedures, industry standards, and NRC guidance.

4OA5 Other Activities

.1 Radiological Hazard Assessment

a. Inspection Scope

The inspectors determined if changes to plant operations prior to the start of the Unit 3 refuel and maintenance outage resulted in any new radiological hazards that could impact the onsite workers. The inspectors conducted walk-downs in the reactor and turbine buildings to evaluate plant equipment material and radiological conditions. The inspectors selected work activities that involved exposure to radiation, reviewed and assessed Exelon performance in evaluating the radiological hazards in the workplace, and the implementation of appropriate radiation monitoring and exposure control measures. The inspectors used the requirements in 10 CFR Part 20, RG 8.38, Control of Access to High and VHRAs for Nuclear Plants, the TS 5.7.2, HRAs, and Exelons procedures to determine compliance.

b. Findings

Introduction.

The inspectors identified a Green NCV of TS 5.7.2. because PBAPS did not follow the administrative and physical controls described in procedure RP-AA-460, Controls for High and LHRAs, Revision 24. There was an initial delay entering the issue into Exelons CAP after identification that Peach Bottom did not have adequate controls to prevent workers from accessing the LHRA around the Unit 3 low and high pressure turbine area.

Description.

On August 16, 2013, the inspectors identified that access to a LHRA was possible from a temporary scaffold built on the south shield wall between the electrical generator and the main turbine in the turbine building, elevation 165 feet. The inspectors identified on August 19, 2013, that the north side of the shield wall contained a built-in metal ladder that was accessible due to the scaffold built on the south side of the wall. This ladder allowed access to the LHRA around the low and high pressure turbines with no placard controls or barricades to alert plant workers of the LHRA.

Based on the RP-AA-460 procedure definition of an accessible area, the inspectors considered the area was accessible after a scaffold was built from the floor to within approximately six feet from the top of the wall and no tools, ladder, mobile platform, or other exceptional measures were needed to gain access.

Based on the inspectors feedback, on August 19, 2013, PBAPS posted two RP technicians at the Unit 3 TB shield wall until a metal plate was installed on the turbine shield wall above the ladder rungs to prevent access to the LHRA.

Analysis.

The inspectors determined that Exelons inability to adequately control access to a LHRA was a PD that could have been foreseen and prevented. The PD was more than minor because it is associated with the cornerstone attribute of Program and Process (RP controls) and negatively affected the Radiation Safety - Occupational Radiation Safety cornerstone objective to ensure the adequate protection of workers health and safety from exposure to radiation during routine civilian nuclear power operation. There was also a more than minor example of this PD in IMC 0612, Appendix E, Examples of Minor Issues, example 6.g. This example concludes that the issue is more than minor because actual dose rates in excess of the posting requirements existed in the area and was greater than 100 mrem/hr. LHRAs are required to be posted and controlled properly to avoid unnecessary worker exposure.

The finding was evaluated using 0609, Appendix C, Occupational Radiation Safety SDP, and was determined to be of very low safety significance (Green) because it was not related to ALARA planning, did not involve an overexposure, did not constitute a substantial potential for overexposure, and the ability to access dose was not compromised.

The finding included a cross-cutting aspect in the area of Work Controls, Human Performance component, because Exelon did not appropriately plan work activities and identify the potential job site conditions (radiological hazards) associated with building a scaffold next to a LHRA wall [H.3.(a)].

Enforcement.

TS 5.7.2, HRAs, requires, in part, that each entryway to a HRA in which the intensity of radiation is greater than 1000 mrem/hr at 30 centimeters from the radiation source or from any surface which the radiation penetrates, shall be conspicuously posted as a HRA and shall be provided with a locked or continuously guarded door or gate that prevents unauthorized entry. Contrary to the above, on August 16, 2013, Exelon did not conspicuously post and lock or guard the entryway created by the scaffold to the high and low pressure turbines where doses in excess of 1000 mrem/hr existed. On August 19, 2013, PBAPS posted two RP technicians at the Unit 3 TB shield wall until a metal plate was installed on the turbine shield wall above the ladder rungs to prevent access to the LHRA. The issue was documented in Exelons CAP as AR 01548397. Because this violation is of very low safety significance and was entered into Exelons CAP, it is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Manual. (NCV 05000-278/2013004-02, Failure to Conspicuously Post and Lock/Guard a HRA on the Unit 3 Turbine Deck)

4OA6 Meetings, Including Exit

Quarterly Resident

Exit Meeting Summary

On October 28, 2013, the resident inspectors presented the inspection results to Pat Navin, Plant Manager, and other PBAPS staff, who acknowledged the findings. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Exelon Generation Company Personnel

M. Massaro, Site Vice President

P. Navin, Plant Manager

N. Alexakos, Emergency Preparedness Manager

J. Armstrong, Regulatory Assurance Manager

R. Bolding, Respiratory Physicist

J. Bowers, Training Director

B. Hennigan, Operations Training Manager

M. Herr, Operations Director

R. Holmes, Radiation Protection Manager

J. Kovalchick, Security Manager

T. Moore, Site Engineering Director

P. Rau, Work Management Director

R. Reiner, Chemistry Manager

R. Shortes, Radiological Engineering Manager

D. Striebig, Emergency Preparedness Coordinator

NRC Personnel

F. Bower, Branch Chief

S. Hansell, Senior Resident Inspector

A. Ziedonis, Resident Inspector

E. Burket, EP Inspector, DRS

J. Furia, Senior Health Physicist

H. Gray, Senior Reactor Inspector

J. Laughlin, EP Inspector, NSIR

T. OHara, Reactor Inspector

R. Rolph, Acting Resident Inspector

B. Smith, Resident Inspector

J. Tomlinson, Operations Engineer

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

05000277, 278/2013004-01 NCV Inadequate EP Procedure Change Management Controls to Ensure Adequate EAL Classification and Assessment Capability for Effluent Parameters (Section 1R22)

05000278/2013004-02 NCV Failure to Conspicuously Post and Lock/Guard a HRA on the Unit 3 Turbine Deck Scaffold (Section 4OA5.1)

Opened

None Discussed/Updated None