IR 05000277/2013005
| ML14035A333 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/04/2014 |
| From: | Fred Bower Reactor Projects Region 1 Branch 4 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| BOWER, FL | |
| References | |
| IR-13-005 | |
| Download: ML14035A333 (33) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ary 4, 2014
SUBJECT:
PEACH BOTTOM ATOMIC POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000277/2013005 AND 05000278/2013005
Dear Mr. Pacilio:
On December 31, 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 January 8, 2014, with Mr. Michael Massaro, Peach Bottom Site Vice President, 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, no findings were identified. However, one licensee-identified violation, which was determined to be of very low safety significance, is listed in this report. However, because of the very low safety significance, and because it is entered into your corrective action program (CAP), the NRC is treating the finding as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the PBAPS.
As a result of the Safety Culture Common Language Initiative, the terminology and coding of cross-cutting aspects were revised beginning in calendar year (CY) 2014. New cross-cutting aspects identified in CY 2014 will be coded under the latest revision to Inspection Manual Chapter (IMC) 0310. Cross-cutting aspects identified in the last six months of 2013 using the previous terminology will be converted to the latest revision in accordance with the cross-reference in IMC 0310. The revised cross-cutting aspects will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the CY 2014 mid-cycle assessment review.
In accordance with Title 10 of Code of Federal Regulations (10 CFR) 2.390 of the NRCs 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 component of the NRCs document system Agencywide Documents Access 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 05000277/2013005 and 05000278/2013005 w/Attachment: Supplementary Information
REGION I==
Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56 Report No.: 05000277/2013005 and 05000278/2013005 Licensee: Exelon Generation Company, LLC Facility: Peach Bottom Atomic Power Station, Units 2 and 3 Location: Delta, Pennsylvania Dates: October 1, 2013 through December 31, 2013 Inspectors: S. Hansell, Senior Resident Inspector B. Smith, Resident Inspector J. DAntonio, Senior Operations Engineer J. Furia, Senior Health Physicist J. Grieves, Senior Resident Inspector, Susquehanna J. Laughlin, Emergency Preparedness Inspector, NSIR/ECB Approved by: Fred L. Bower III, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000277/2013005, 05000278/2013005; 10/01/2013 - 12/31/2013; Peach Bottom Atomic
Power Station (PBAPS), Units 2 and 3; Integrated Inspection Report.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. No findings were identified. 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: Initiating Events, Mitigating Systems, Emergency Preparedness, and Barrier Integrity None.
Other Findings
One violation of very low safety significance that was identified by Exelon was reviewed by the inspectors. Corrective actions taken or planned by Exelon have been entered into Exelons corrective action program (CAP). This violation and the corrective action tracking number is listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Unit 2 began the inspection period at 100 percent power. On November 8, 2013, operators reduced power to approximately 63 percent to perform main turbine control valve testing, control rod scram timing testing, and a control rod pattern adjustment. The unit was returned to 100 percent rated thermal power on November 9, 2013. The unit remained at 100 percent power through the end of the inspection period.
Unit 3 began the inspection period shutdown for the 19th refueling outage (RFO) (P3R19).
On October 17, 2013, the reactor mode switch was placed in start-up and the main generator was synchronized to the electrical grid on October 24, 2013. On October 28, 2013, the unit was returned to 100 percent power. Unit 3 remained at 100 percent power until the end of the inspection period, except for brief periods to support planned testing and control rod pattern adjustments.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Emergency Preparedness, and Barrier Integrity
1R01 Adverse Weather Protection
Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
The inspectors performed a review of PBAPSs readiness for the cold weather preparations on November 12, 2013. The review focused on the emergency diesel generators (EDGs) and the river water intake structure travelling screens and associated support equipment. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), technical specifications (TSs), control room logs, and the CAP to determine what temperatures or other seasonal weather could challenge these systems, and to ensure PBAPS personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including PBAPSs 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 during cold weather conditions.
Documents reviewed for each section of this inspection report are listed in the
.
b. Findings
No findings were identified.
1R04 Equipment Alignment
Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
Unit 3 high-pressure coolant injection (HPCI) after overspeed test on October 16, 2013 Unit 3 high pressure service water (HPSW) after RFO on October 29, 2013 Unit 3 main turbine bearing walkdown during startup on October 30, 2013 Unit 2 HPCI and reactor core isolation cooling (RCIC) during yellow risk on December 10, 2013 Unit 2 and Unit 3 emergency service water (ESW) after crosstie restored on December 18, 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 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 PBAPS 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.
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 out of service (OOS), degraded or inoperable fire protection equipment, as applicable, in accordance with procedures.
Unit 3 refuel floor on October 13, 2013 Unit 2 HPCI during yellow risk on December 12, 2013 Unit 2 RCIC during yellow risk on December 12, 2013 Unit 2 and Unit 3 ESW room on December 19, 2013 Unit 3 HPSW room on December 23, 2013
b. Findings
No findings were identified.
1R06 Flood Protection Measures
.1 Internal Flooding Review (2 samples)
a. Inspection Scope
The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to assess susceptibilities involving internal flooding. The inspectors also reviewed the CAP to determine if PBAPS identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors focused on the diesel rooms (DG), elevation 36 on November 15, 2013, and the Unit 3 HPSW loop after system cross-tie modification on December 19, 2013, to verify the adequacy of equipment seals located below the flood line, floor and water penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and temporary or removable flood barriers.
b. Findings
No findings were identified.
.2 Annual Review of Cables Located in Underground Bunkers/Manholes (1 sample)
The inspectors conducted an inspection of underground bunkers/manholes subject to flooding that contain cables whose failure could disable risk-significant areas, including manhole 67, 101, and 107, to verify that the cables were not submerged in water, that cables and/or splices appeared intact, and to observe the condition of cable support structures. When applicable, the inspectors verified proper sump pump operation and verified level alarm circuits were set in accordance with station procedures and calculations to ensure that the cables will not be submerged. The inspectors also ensured that drainage was provided and functioning properly in areas where dewatering devices were not installed.
b. Findings
No findings were identified.
1R07 Heat Sink Performance
a. Inspection Scope
The inspectors reviewed the E-3 emergency diesel generator (EDG) heat exchanger (HX) on December 13, 2013, to determine its readiness and availability to perform its safety functions. The inspectors reviewed the design basis for the component and verified Exelons commitments to NRC Generic Letter 89-13. The inspectors reviewed the results of the previous inspections of the EDG HXs. The inspectors discussed the results of the most recent inspection with engineering staff and reviewed pictures of the as-found and as-left conditions. The inspectors verified that PBAPS initiated appropriate corrective actions for identified deficiencies. The inspector also verified that the number of tubes plugged within the HX did not exceed the maximum amount allowed.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Quarterly Review of Licensed Operator Requalification Testing and Training (2 samples)
a. Inspection Scope
The inspectors observed licensed operator requalification simulator training on November 18, 2013, and December 2, 2013, which included simulated plant events related to a loss of turbine building closed cooling water, loss of instrument air, a loss of offsite electrical power combined with the failure of the E-2 and E-3 EDGs to automatically start, the failure of the RCIC system to inject water into the reactor vessel, and the failure of the HPCI system to automatically start and inject water into the reactor vessel. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the TS action statements entered by the shift technical advisor.
Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room (MCR)
(2 samples)
a. Inspection Scope
The inspectors observed licensed operator performance in the Unit 2 MCR during the main turbine high vibration on October 1, 2013, and the Unit 3 shutdown cooling re-alignment on October 14, 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.
.3 Licensed Operator Requalification Program
a. Inspection Scope
On December 9, 2013, one NRC region-based inspector conducted an in-office review of results of the licensee-administered requalification examination results for Senior Reactor Operator Limited to Fuel Handling. The inspection assessed whether pass rates were consistent with the guidance of NRC Manual Chapter 0609, Appendix I, Operator Requalification Human Performance Significance Determination Process (SDP). The inspectors verified that:
Overall pass rate among individuals for all portions of the exam was greater than or equal to 80 percent. (Overall pass rate was 100 percent)
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
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 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 10 CFR 50.65 and that the (a)(2) performance criteria established by the PBAPS 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.
Units 2 and 3 review of 10 CFR 50.65 (a)(3) periodic assessment of the MR program on November 6, 2013 Emergency lighting on November 15-18, 2013 MCR radiation monitors on November 20-27, 2013 Unit 3 feedwater leading edge flow meter on December 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.
Unit 3 reactor vessel water level draindown on October 14, 2013 Unit 3 main stack vent radiation monitor A and B channels OOS on October 29, 2013 Electrical startup source line 343 OOS during the week of November 25, 2013 Unit 3 yellow risk for half scram and station blackout (SBO) testing December 9, 2013 Unit 2 HPCI/RCIC yellow risk with SBO OOS on December 13, 2013
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed five operability determinations (ODs) for the following degraded or non-conforming conditions:
Unit 3 torus recoating non-qualified portions on October 10, 2013 Unit 3 B and D residual heat removal (RHR) pump discharge valves on October 15, 2013 Unit 3 D RHR minimum flow valve on October 16, 2013 Unit 3 control rod drive 18-11 on October 25, 2013 Unit 2 containment atmosphere dilution OOS on October 31, 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.
1R18 Plant Modifications
a. Inspection Scope
The inspectors reviewed the temporary modifications listed below to determine whether the modification affected the safety functions of systems that are important to safety.
The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results, and conducted field walkdowns of the modifications to verify that the temporary modification did not degrade the design bases, licensing bases, and performance capability of the affected systems.
Unit 3 Engineering Change Request (ECR) PB-00442-000, MO-3-01A-077 motor replaced on December 2, 2013 Unit 3 ECR 09-00554-001, RCIC pressure switch change on December 19, 2013
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.
ST-O-010-306-3, Unit 3 RHR Pump, Valve and Flow Test, Revision 30, on October 13, 2013, after planned maintenance outage.
RT-O-023-240-3, Unit 3 HPCI Overspeed Trip Test Using Auxiliary Steam, Revision 1, on October 14, 2013, to verify operability during the Unit 3 startup.
ST-R-003-490-3, Zero Pressure Scram Times, Revision 4, on October 14, 2013, after the replacement of control rod drive mechanisms.
RT-O-013-240-3, Unit 3 RCIC Overspeed Trip Test Using Auxiliary Steam, Revision 1, on October 15, 2013, to verify operability during the Unit 3 startup.
ST-O-094-400-3, Unit 3 HPCI Steam Admission Valve, Revision 4, on October 16, 2013 ST-O-014-306-3, Unit 3 Core Spray (CS) Minimum Flow Valve, Revision 37, on December 11, 2013 AO33.2, ESW System Manual Startup and Operations, Revision 8, on December 19, 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 RFO (P3R19) which began on September 8, 2013, and was completed on October 24, 2013. 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. The Unit 3 CS piping design, removal of the degraded in-vessel CS pipe and support brackets, installation of the new Unit 3 CS pipe and support brackets; that included bolted flange connections in place of typical welded pipe sections were inspected. The replacement included two loops of the CS piping from the reactor vessel nozzles to the CS spargers.
The inspectors also focused on the torus internal metal shell grit blasting and re-coating that were performed to mitigate the torus metal pitting condition. In addition to the torus closeout inspection, the inspectors performed a detailed drywell closeout walkdown to verify the removal of equipment and temporary support material. The inspectors also observed portions of the plant startup including the reactor startup, initial criticality, and power accension. Another major activity reviewed was the initial startup of the new main generator, associated alterex exciter and voltage regulator, and the main generator initial connection to the offsite electrical grid. In addition to observation of the plant heatup and power ascension, the following outage inspection activities were performed:
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 instrumentation 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 sustained operation of the spent fuel pool cooling system Reactor water inventory controls, including flow paths, alternative means for water inventory additions, and controls to prevent unexpected inventory changes Maintenance of secondary containment as required by TSs Core verification - independently reviewed selected portions of core verification activities and reactor physics testing 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 Drywell closure - conducted a thorough inspection and walkdown of the primary containment prior 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 the Plant Operations Review Committee meeting on October 15, 2012, to ensure outstanding outage issues were resolved, and startup reviews were detailed 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, and portions of the power ascension to full power operation Licensee identification 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 to resolve the issues
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
(1 routine surveillance; 4 IST samples)
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-009-200-3, Unit 3 Secondary Containment Capability Test, Revision 19, on October 15, 2013 ST-O-052-313-2, E-3 DG Slow Start Full Load and IST Test, Revision 20 on October 30, 2013 ST-O-010-306-3, B RHR Loop Pump, Valve, Flow, and Unit Cooler Functional and Inservice Test, Revision 38, on November 19, 2013 (IST)
ST-O-052-214-2, E-4 DG Slow Start Full Load and IST Test, Revision 24, on November 26 RT-O-032-300-2, Unit 2 HPSW Pump, Valve and Flow Functional Test, Revision 12, on December 9, 2013
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
The 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 number ML13260A163 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 - Simulator Evaluation
a. Inspection Scope
The inspectors evaluated the shift manager\emergency directors emergency plan implementation during requalification simulator training on December 11, 2013. The inspectors observed emergency response operations in the simulator to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with approved procedures. The inspectors also attended the control room simulator drill critique to compare inspector observations with those identified by PBAPS staff in order to evaluate whether PBAPS staff was properly identifying emergency preparedness weaknesses and entering them into the CAP.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Occupational/Public Radiation Safety (PS)
2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,
and Transportation (71124.08 - 1 sample)
a. Inspection Scope
During the week of October 28 - November 1, 2013, the inspectors verified the effectiveness of PBAPSs programs for processing, handling, storage, and transportation of radioactive material. The inspectors used the requirements of 10 CFR Parts 20, 61, and 71, and 10 CFR Part 50 Appendix A -Criterion 63 - Monitoring Fuel and Waste Storage, and licensee procedures required by the TSs and Process Control Program (PCP) to determine regulatory compliance.
The inspectors reviewed the solid radioactive waste system description in the Final Safety Analysis Report (FSAR), the PCP, and the recent radiological effluent release report for information on the types, amounts, and processing of radioactive waste disposed.
The inspectors reviewed the scope and the results of quality assurance (QA) audits performed for this area since the last program inspection, and evaluated the adequacy of PBAPSs corrective actions for issues identified during the QA audits.
Radioactive Material Storage The inspectors evaluated areas where containers of radioactive waste were stored.
The inspectors verified that the radioactive materials storage areas were controlled and posted as required.
The inspectors verified that PBAPS had established a process for monitoring the impact of long-term storage (e.g., buildup of any gases produced by waste decomposition, chemical reactions, container deformation, loss of container integrity, or re-release of free-flowing water) sufficient to identify potential unmonitored, unplanned releases, or nonconformance with waste disposal requirements. The inspectors verified that there were no signs of component swelling, leakage, or deformation.
Radioactive Waste System Walkdown The inspectors walked down accessible portions of liquid and solid radioactive waste processing systems to verify and assess that the current system configuration and operation agree with the descriptions in the FSAR, offsite dose calculation manual, and PCP.
The inspectors identified radioactive waste processing equipment that was not operational and/or was abandoned in place, and verified that PBAPS had established administrative and/or physical controls to minimize personnel exposure.
The inspectors reviewed the adequacy of any changes made to the radioactive waste processing systems since the last inspection. The inspectors verified that changes from what was described in the FSAR were reviewed and documented.
The inspectors identified processes for transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers. The inspectors verified that the waste stream mixing, sampling procedures, and methodology for waste concentration averaging were consistent with the PCP, and provided representative samples of the waste product for the purposes of waste classification.
For those systems that provide tank recirculation, the inspectors verified that the tank recirculation procedure provided sufficient mixing.
The inspectors verified that PBAPSs PCP correctly described the current methods and procedures for dewatering waste.
Waste Characterization and Classification The inspectors identified radioactive waste streams, and verified that PBAPSs radiochemical sample analysis results were sufficient to support radioactive waste characterization. The inspectors verified that PBAPSs use of scaling factors and calculations to account for difficult-to-measure radionuclides was technically sound and based on current analyses.
The inspectors verified that changes to plant operational parameters were taken into account to
- (1) maintain the validity of the waste stream composition data between the annual or biennial sample analysis update, and
- (2) verified that waste shipments continued to meet applicable requirements.
The inspectors verified that PBAPS had established and maintained an adequate QA program to ensure compliance with applicable waste classification and characterization requirements.
Shipment Preparation The inspectors reviewed the records of shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and PBAPS verification of shipment readiness. The inspectors verified that the requirements of applicable transport cask certificate of compliance had been met. The inspectors verified that the receiving licensee was authorized to receive the shipment packages.
The inspectors determined that the shippers were knowledgeable of the shipping regulations and that shipping personnel demonstrated adequate skills to accomplish the package preparation requirements for public transport. The inspectors verified that the PBAPSs training program provided training to personnel responsible for the conduct of radioactive waste processing and radioactive material shipment preparation activities.
Shipping Records The inspectors identified non-excepted package shipment records and verified that the shipping documents included the proper shipper name; emergency response information and a 24-hour contact telephone number; accurate curie content and volume of material; and appropriate waste classification, transport index, and international shipping identification number. The inspectors verified that the shipment placarding was consistent with the information in the shipping documentation.
Identification and Resolution of Problems The inspectors verified that problems associated with radioactive waste processing, handling, storage, and transportation, were being identified by PBAPS at an appropriate threshold, were characterized properly, and were addressed properly for resolution in Exelons CAP. The inspectors verified the appropriateness of the corrective actions for a selected sample of problems documented by the licensee that involved radioactive waste processing, handling, storage, and transportation. PBAPS generated six condition reports to document material condition deficiencies identified during this inspection.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Safety System Functional Failures (MS05) (2 samples)
a. Inspection Scope
The inspectors sampled PBAPS's submittals for the safety system functional failures (SSFFs) performance indicator (PI) for both Unit 2 and Unit 3 for the period of October 1, 2012 through October 1, 2013. To determine the accuracy of the PI data reported during those periods, inspectors used definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment PI Guideline, Revision 6, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73."
The inspectors reviewed PBAPS's operator narrative logs, operability assessments, MR records, maintenance WOs, CRs, event reports and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.2 Mitigating Systems Performance Index (10 samples)
a. Inspection Scope
The inspectors sampled PBAPSs submittals of the Mitigating Systems Performance Index (MSPI) for the period of October 1, 2012 through October 1, 2013:
Unit 2 and Unit 3 Emergency Alternating Current Power System (MS06)
Unit 2 and Unit 3 HPCI System (MS07)
Unit 2 and Unit 3 RCIC System (MS08)
Unit 2 and Unit 3 RHR System (MS09)
Unit 2 and Unit 3 Support Cooling Water System (MS10)
To determine the accuracy of the PI data reported during this period, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment PI Guideline, Revision 6. The inspectors also reviewed PBAPS operator narrative logs, CRs, MSPI derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.3 Occupational Radiation Safety Cornerstone (1 sample)
a. Inspection Scope
The inspectors reviewed a listing of PBAPSs issue reports for issues related to the Occupational Radiation Safety PI, which measures non-conformances with high radiation areas greater than 1 Roentgen/hour (R/hr) and unplanned personnel exposures greater than 100 millirem (mrem) total effective dose equivalent (TEDE),5 rem skin dose equivalent (SDE), 1.5 rem lens dose equivalent (LDE), or 100 mrem to the unborn child.
The inspectors determined if any of these PI events involved dose rates >25 R/hr at 30 centimeters or >500 R/hr at 1 meter. If so, the inspectors determined what barriers had failed and if there were any barriers left to prevent personnel access. For unintended exposures >100 mrem TEDE (or >5 rem SDE or >1.5 rem LDE), the inspectors determined if there were any overexposures or substantial potential for overexposure. PBAPS reported and the NRC issued a finding related to one PI event for the Unit 3 turbine building main turbine during this assessment period.
b. Findings
No findings were identified.
.4 Public Radiation Safety Cornerstone (1 sample)
a. Inspection Scope
The inspectors reviewed a listing of PBAPSs action reports for issues related to the public radiation safety PI, which measures radiological effluent release occurrences per site that exceed 1.5 mrem/quarter (qtr) whole body or 5 mrem/qtr organ dose for liquid effluents; or 5 millirads (mrads)/qtr gamma air dose, 10 mrads/qtr beta air dose; or 7.5 mrems/qtr organ doses from Iodine-131 (I-131), I-133, Hydrogen-3 (H-3) and particulates for gaseous effluents. The inspectors determined that no PI events for public radiation safety had occurred during the assessment period.
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 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.
4OA3 Follow-up of Events and Notices of Enforcement Discretion
(Closed) Licensee Event Report (LER) 05000278/2013-001-00: Laboratory Analysis Identifies Safety Relief Valves (SRVs) and Safety Valve (SV) Set Point Deficiencies On October 1, 2013, site engineering personnel determined that five SRVs/SV as-found opening setpoints were outside of the TS allowable +/- 1% tolerance. The four SRVs and one SV that were outside of their TS allowable setpoint range were within their ASME Code allowable +/- 3% tolerance. The cause of the SRVs/SV being outside of their allowable as-found setpoints was due to setpoint drift. The SRVs/SV were replaced with refurbished SRVs/SV for the 20th Unit 3 operating cycle. There were no actual safety consequences associated with this event. The enforcement aspects of this LER are discussed in Section 4OA7. This LER is closed.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
Quarterly Resident
Exit Meeting Summary
On January 8, 2014, the resident inspectors presented the inspection results to Mr. Michael Massaro, Peach Bottom Site Vice President, 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.
4OA7 Licensee-Identified Violation
The following violation of very low safety significance (Green) was identified by PBAPS and is a violation of NRC requirements which meet the criteria of the NRC Enforcement Policy for being dispositioned as an NCV.
TS 3.4.3 Limiting Condition for Operation requires that 11 of 13 SRVs\SVs shall be operable in reactor operating modes 1, 2, and 3. TS 3.4.3.1 surveillance requirement states that the SRVs\SVs opening lift setpoints are maintained within
+/- 1% tolerance of the design opening pressure. Contrary to the above, information received by site engineering from a laboratory performing SRV\SV as-found testing, determined that on October 1, 2013, the valve setpoint deficiencies existed with four SRVs and one SV that were in place during the Unit 3 19th operating cycle. The SRVs/SV were determined to have their as-found setpoints outside of the TS allowable +/- 1% tolerance. The four SRVs and one SV outside of their TS allowable setpoint range were within the ASME Code allowable +/- 3% tolerance. The cause of the SRVs/SV being outside of their allowable as-found setpoints was due to setpoint drift. The SRVs/SV were replaced with refurbished SRVs/SV for the 20th Unit 3 operating cycle. The amount of setpoint drift was within the as found Target Rock SRV values when compared to industry data. The SRVs/SV were replaced with refurbished valves that were tested and opened within the allowable +/- 1% tolerance.
The inspectors determined that the finding was of very low safety significance (Green) in accordance with Section A" of Exhibit 2 in Appendix A of IMC 0609, "The SDP for Findings at Power, because the SRVs safety function was not affected. Although outside the lift setpoint tolerance, the as-found SRV/SV lift pressure values would not have challenged the reactor vessel design maximum pressure rating during the most limiting postulated accident event.
The inspectors reviewed PBAPSs planned corrective actions to address the SRV setpoint drift issue and a planned industry standard TS setpoint change submittal to a +/- 3% tolerance appropriate. Because this finding is of very low safety significance, the as-found out of tolerance SRVs were replaced with SRVs that had the proper lift setpoint prior to the Unit 3 reactor plant startup, and the issue was entered into Exelon's CAP under Issue Report 1567200, this violation is being treated as a Green NCV consistent with the NRCs Enforcement Policy.
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
- B. Reiner, Training Director
- B. Hennigan, Operations Training Manager
- M. Herr, Operations Director
- R. Holmes, Radiation Protection Manager
- P. Simmons, Security Manager
- T. Moore, Site Engineering Director
- M. Weidman, Work Management Director
- F. Leone, Chemistry Manager
- D. Baracco, Radiological Engineering Manager
- D. Striebig, Emergency Preparedness Coordinator
NRC Personnel
- F. Bower III, Branch Chief
- S. Hansell, Senior Resident Inspector
- B. Smith, Resident Inspector
- J. DAntonio, Senior Operations Engineer
- J. Furia, Senior Health Physicist
- J. Grieves, Senior Resident Inspector, Susquehanna
- J. Laughlin, Emergency Preparedness Inspector, NSIR/ECB
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
None
Closed
- 05000278/2013-001-00 LER Laboratory Analysis Identifies Safety Relief Valves (SRVs) and Safety Valve (SV) Set Point Deficiencies (Section 4OA3)
Opened
None Discussed/Updated None