IR 05000277/2014005
| ML15035A435 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/04/2015 |
| From: | Fred Bower Reactor Projects Region 1 Branch 4 |
| To: | Bryan Hanson Exelon Nuclear |
| BOWER, FL | |
| References | |
| IR 2014005 | |
| Download: ML15035A435 (34) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PA 19406-2713 February 4, 2015 Mr. Bryan Hanson Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 SUBJECT: PEACH BOTTOM ATOMIC POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000277/2014005 AND 05000278/2014005
Dear Mr. Hanson:
On December 31, 2014, 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 16, 2015, with Mr. Michael Massaro, 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.
In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRC's
"Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRC's Agency wide 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 05000277/2014005 and 05000278/2014005 w/Attachment: Supplementary Information
REGION I==
Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56 Report No.: 05000277/2014005 and 05000278/2014005 Licensee: Exelon Generation Company, LLC (Exelon)
Facility: Peach Bottom Atomic Power Station, Units 2 and 3 Location: Delta, Pennsylvania Dates: October 1, 2014 through December 31, 2014 Inspectors: S. Hansell, Senior Resident Inspector B. Smith, Resident Inspector E. Burket, Emergency Preparedness Inspector S. Chaudhary, Senior Reactor Inspector T. Daun, Resident Inspector - Susquehanna T. Dunn, Operations Engineer M. Fannon, NSPDP, Region 1 J. Furia, Senior Health Physicist M. Modes, Senior Reactor Inspector P. Presby, Senior Operations Engineer Approved by: Fred L. Bower III, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000277/2014005, 05000278/2014005, 10/01/2014 - 12/31/2014; 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 5.
Cornerstone: Initiating Events, Mitigating Systems, and Barrier Integrity, Emergency
Preparedness None.
Other Findings
None.
REPORT DETAILS
Summary of Plant Status
Unit 2 began the inspection period at 100 percent rated thermal power (RTP). On October 19, 2014, operators shutdown Unit 2 for the 20th refueling outage (RFO) (P2R20).
On November 30, 2014, the reactor mode switch was placed in start-up and the main generator was synchronized to the electrical grid on December 3, 2014. On December 7, 2014, the unit was returned to 89 percent power (the pre-extended power uprate 100 percent power limit).
On December 12, 2014, Peach Bottom Unit 2 down powered from 89 percent to 50 percent to perform repairs to the main turbine number one control valve. The unit was returned to 89 percent RTP on December 13, 2014. The unit remained at 89 percent RTP through the end of the inspection period.
Unit 3 began the inspection period at 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
Winter Readiness - Seasonal Extreme
a. Inspection Scope
The inspectors performed a review of PBAPS readiness for the cold weather preparations on October 16, 2014. The review focused on the emergency diesel generators (EDGs), the river water intake structure travelling screens, emergency cooling tower, circulating water pump house, and associated support equipment. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), technical specifications (TSs), and the corrective action program (CAP) to determine the temperatures or other seasonal weather conditions that could challenge these systems.
The review ensured PBAPS personnel had prepared adequately for the weather-related challenges. The inspectors reviewed station procedures, including PBAPS 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
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial walkdowns of the following three systems:
Unit 2 reactor feed pumps A, B, and C to identify offgas in-leakage on December 3, 2014 Unit 2 feedwater (FW) system following the repair of 4 C FW heater drain valve and main turbine control valve (CV-1) servo on December 13, 2014 Units 2 and 3 E-1, E-2, and E-3 EDGs during E-4 EDG fuel nozzle tubing replacement on December 14, 2014 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.
.2 Full System Walkdown
a. Inspection Scope
On November 12 - 17, 2014, the inspectors performed a complete system walkdown of accessible portions of the Unit 2 A residual heat removal (RHR) system to verify the existing equipment lineup was correct. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, technical specifications, work orders, condition reports, 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 performed field walkdowns of accessible portions of the system 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 PBAPS appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified.
1R05 Fire Protection
Resident Inspector Quarterly Walkdowns
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.
Units 2 and 3 EDG carbon dioxide (cardox) room and E-1, E-2, E-3, and E-4 EDG rooms on October 15, 2014 Units 2 and 3 emergency cooling tower on October 16, 2014 Unit 2 drywell on November 13, 2014 Unit 2 A RHR quadrant room on November 13, 2014
b. Findings
No findings were identified.
1R07 Heat Sink Performance
a. Inspection Scope
The inspectors reviewed the Unit 3 B RHR heat exchanger (HX) on December 12, 2014, 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 B RHR HX. The inspectors discussed the results of the most recent inspections with engineering staff and verified that PBAPS initiated appropriate corrective actions for identified deficiencies. The inspectors also verified that the number of tubes plugged within the heat exchanger did not exceed the maximum amount allowed.
b. Findings
No findings were identified.
1R08 In-Service Inspection
.1 Nondestructive Examination (NDE) and Welding Activities
a. Inspection Scope
Inservice inspection activities detect precursors to pressure boundary failures in reactor coolant systems, emergency core cooling systems, risk-significant piping and components, and containment systems. Degradation of pressure retaining components in these systems would result in a significant increase in risk. This inspection is intended to assess the effectiveness of Exelons program for monitoring degradation of vital system boundaries.
NDE and Welding Activities (IMC Section 02.01) and Other Augmented or Industry Initiative Examinations The inspectors reviewed the results of the ultrasonic inspection of the N-9 reactor vessel nozzle which consisted of both augmented and American National Standard: American Society of Mechanical Engineers, Boiler and Pressure Vessel Code (ASME), required examinations within one component. This component is a capped control rod drive mechanism return line nozzle. Because the nozzle is shortened and has two insulation brackets welded to the vessel wall that obstruct ultrasonic scanning, the licensee invoked ASME Code Case N-613-1, Ultrasonic Examination of Penetration Nozzles in Vessels, Examination Category B-D, Item Nos. B3.10 and B3.90, Reactor Nozzle-to-Vessel Welds, Figs. IWB-2500-7(a), (b), and (c),Section XI, Division 1, which allows for a limited volume of insonification. The inspectors verified the Code Case was accepted by the NRC in Regulatory Guide (RG) 1.147, Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1. The inspectors noted the Code Case was accepted by the NRC without conditional stipulations. The inspectors compared the requirements in the Code Case with the application of the Code Case to this component.
The Code Case stipulates welds previously ultrasonically examined using the examination volumes of Figs. IWB-2500-7(a), (b), and
- (c) may use the reduced coverage volume of the Code Case. The inspectors reviewed the results of a prior inspection of this nozzle (Inspection Report 00400, October 14, 1994, and Procedure UT-PBM-300V0, Procedure for Manual Examination of Reactor Pressure Vessel Assembly Welds, Revision 0, September 9, 1994) to determine the full ASME IWB-2700-7 scanning volume had been insonified prior to implementing the smaller scan volume allowed by the Code Case. The inspectors then compared the scan coverage volume in the Code Case with those recorded in the final test report to verify the coverage was in compliance with the Code Case requirements for this configuration.
Exelon staff also invoked the coverage requirements of ASME Section XI, 2001 Edition with 2003 Addenda, to justify the inability to scan 360° around the nozzle, from the vessel plate, due to interference by the welded insulation brackets. Because of the nozzles truncated length, scanning from the nozzle direction is not feasible. The inspectors verified the limit was in conformance with ASME Section XI I-3420 Examinations Conducted from the Outside.
The inspectors interviewed the corporate Level III and determined that relevant prior indications were supplied to, and discussed with, the qualified examination personal prior to implementing the ultrasonic testing. The inspectors noted that no new indications were reported and the inspectors verified the one indication reported in a prior examination was interrogated ultrasonically for possible growth. The inspectors noted this previously reported indication currently would no longer be recorded using required reportability standards.
The inspectors also reviewed the results of the ultrasonic inspection of FW Nozzle N-4-D, FW Nozzle N-4-F, and FW Nozzle N-4-E.
b. Findings
No findings were identified.
.2 Power Uprate (Flow Accelerated Corrosion)
a. Inspection Scope
The purpose of this inspection was to address risk-significant concerns identified by the licensees flow accelerated corrosion and erosion/corrosion programs which could be exacerbated by power uprate changes or evolutions (See NRC Inspection Procedure (IP) 71004, Section 02.01 f.).
The inspectors reviewed Exelon Analytic Report PEAM-EPU-81, which updated the PBAPS, Units 2 and 3, Checworks Steam/FW Models using extended power uprate (EPU) conditions. The inspectors noted the revised models appropriately used the uprate heat balance diagram increased by 122.4 percent, the increased power level, projected steam cycle data, and water chemistry.
The inspectors reviewed the evaluation results listing the lines predicted to increase in wear as a consequence of the uprate conditions. The inspectors noted the worst case wear for Unit 2 was an increase of 0.011 inches per year or 11 mil per year in FW heater drain 3 to 2. This component currently has a wall thickness of 600 mil, and a calculated minimum wall thickness requirement of 113 mil. At the current increased rate of flow accelerated wear, the component is predicted to reach minimum wall in approximately 44 years, more than twice the current license extended-period-of-operation. In addition, the inspectors noted this is a component of low risk significance. The next seven components listed were all low risk significant components related to the FW heaters and had rates of wear from 4 to 1 mil per year.
Because no risk-significant concerns were identified by Exelons Peach Bottom flow accelerated corrosion and erosion/corrosion programs, which could be exacerbated by power uprate changes, and the flow accelerated program was reviewed as part of the IP 71003 inspection of license renewal commitment 9 (NRC Report 05000277/2013007)with no findings, the inspectors did not implement IP49001.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Quarterly Review of Licensed Operator Requalification Testing and Training (1 sample)
a. Inspection Scope
The inspectors observed a licensed operator training simulator scenario related to the standby liquid control, main turbine electro-hydraulic control system, and safety relief valve simulator modifications for Unit 2 on November 8, 2014. Specifically, the inspectors observed a turbine trip and reactor scram without turbine bypass valves scenario and a LOOP scenario on the newly updated EPU simulator to compare and contrast differences between operator performance on the old and new models. 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 emergency classifications made by the shift manager and the technical specification (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)
(71111.11 - 1 sample)
a. Inspection Scope
The inspectors observed licensed operator performance in the MCR for a shutdown to begin the Unit 2 RFO on October 19, 2014. 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
a. Inspection Scope
The following inspection activities were performed using NUREG-1021, Revision 9, Supplement 1, Operator Licensing Examination Standards for Power Reactors, IP Attachment 71111.11, Licensed Operator Requalification Program.
A review was conducted of recent operating history documentation regarding fuel handling found in the licensees CAP. The inspectors also reviewed specific events from Exelons CAP to determine if possible training deficiencies existed.
The inspectors evaluated the 2014 Limerick and the 2013 Peach Bottom Limited Senior Reactor Operator (LSRO) refueling operating tests and the 2014 Limerick and 2014 Peach Bottom LSRO biennial written examinations for quality and compliance with the Examination Standards. Inspectors observed the administration of refuel platform job performance measures to four operators at Limerick on June 3, 2014.
The results of the biennial written examinations at Limerick and annual operating tests for 2014 were reviewed to determine whether pass/fail rates were consistent with the guidance of NUREG-1021, Revision 9, Supplement 1, Operator Licensing Examination Standards for Power Reactors, and NRC Manual Chapter 0609, Appendix I, Operator Requalification Human Performance Significance Determination Process (SDP). All LSROs passed their examinations. Performance of all LSROs over two years was reviewed and indicated no adverse trends.
Two years of records for requalification training attendance and license reactivation for all four LSROs were reviewed for compliance with license conditions and NRC regulations. Medical records for all four LSROs were also reviewed. LSRO license maintenance was evaluated by the review of the 4th Quarter Active License status entries of 2013.
A sampling of feedback was reviewed and training materials were evaluated for response to this feedback. These materials were also reviewed for incorporation of plant modifications and industry events.
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 the 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.
An (a)(3) assessment review on November 17 - 21, 2014
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 assessment (PRA) 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.
Yellow risk for Unit 2 containment de-inertedon October 28, 2014 Yellow risk for Unit 3 during E-22 breaker testing on November 13, 2014 Yellow risk for Unit 2 filling and venting of the B recirculation line on November 18, 2014 Yellow risk for Unit 2 during reduced reactor vessel water level inventory on November 25, 2014
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed six operability determinations (ODs) for the following degraded or non-conforming conditions:
Unit 3 high-pressure coolant injection (HPCI) turbine thrust bearing high temperature on October 16, 2014 Unit 2 torus coating inspections on October 29, 2014 Unit 2 A RHR HX flow control valve operator exceeded its specified torque on November 12, 2014 Unit 2 jet pump wedge wear on November 17, 2014 Units 2 and 3 E-3 EDG lube oil leak on December 15, 2014 Unit 3 E safety-relief valve (SRV) bellows alarm on December 17, 2014 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 justified properly 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 PBAPS 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 controlled properly by PBAPS. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.
b. Findings
No findings were identified.
1R18 Plant Modifications
Permanent Modifications
a. Inspection Scope
The inspectors reviewed the permanent modifications listed below to determine whether the modification affected the safety function 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 modification to verify that the modifications did not degrade the design bases, licensing bases, and performance capability of the affected system.
Unit 2 standby liquid control boron enrichment on December 2 - December 3, 2014 Unit 2 third safety valve installed for EPU on December 15 - December 16, 2014
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 2 high-pressure service water (HPSW) LOOP after MO-89 HX outlet valve and replacement on October 10, 2014 Units 2 and 3 E-1 EDG fast start after E-12 bus outage on October 28, 2014 Units 2 and 3 E-4 EDG full load after fuel oil tubing replacement on November 19, 2014 Unit 2 turbine CV-1 testing after servo repair on December 14, 2014 Unit 2 electrohydraulic control stability test on December 15, 2014 Unit 2 main generator H2 leak and repair on December 16, 2014
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities
Peach Bottom Unit 2 Outage - Refueling (P2R20)
a. Inspection Scope
The inspectors reviewed the stations work schedule and outage risk plan for the Unit 2 maintenance and refueling outage (P2R20) which began on October 19, 2014, and was completed on November 30, 2014. 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 inspectors observed the Unit 2 replacement main steam dryer (RSD) delivery, welding of the upper dryer section to the dryer skirt on the refuel floor, RSD weld repairs and examinations to correct initial fabrication discrepancies, initial reactor vessel installation and fit-up measurements, final installation prior to Unit 2 reactor startup, and removal of the original main steam dryer. The inspectors also reviewed the preparation work and installation of numerous risk significant EPU modifications that included RHR HX cross-tie piping modifications, high-pressure service water (HPSW)cross-tie modifications, standby liquid control tank boron chemical concentration changes, condensate storage tank standpipe modifications for HPCI and reactor core isolation cooling (RCIC), and the addition of a new main steam SRV.
The inspectors also focused on the prior outage torus re-coating as-found conditions, to ensure that coating de-lamination problems noted at a similar boiling water reactor, were inspected and evaluated at Peach Bottom. 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 ascension.
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, the following outage 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 November 24, 2014, 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; 2 IST samples; 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:
Unit 2 main steam isolation valve (MSIV) containment isolation valve stroke time test after shutdown on October 20, 2014 (IST)
Unit 2 local leak rate testing for RHR and core spray (CS) valves on October 23, 2014 Unit 2 TIP (transverse incore probe) shear valve explosive charge test on November 5, 2014 (IST)
Unit 2 RCIC overspeed test on November 18 - 20, 2014
b. Findings
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
Exelon implemented various changes to the Peach Bottom Emergency Action Levels (EALs), Emergency Plan, and Implementing Procedures. Exelon determined that, in accordance with 10 CFR 50.54(q)(3), any change made to the EALs, Emergency Plan, and its lower-tier implementing procedures, did not result in any reduction in effective-ness of the Plan, and that the revised Plan continued to meet the standards in 50.47(b)and the requirements of 10 CFR 50 Appendix E.
The inspectors performed an in-office review of all EAL and Emergency Plan changes submitted by Exelon as required by 10 CFR 50.54(q)(5), including the changes to lower-tier Emergency Plan implementing procedures, to evaluate for any potential reductions in effectiveness of the Emergency Plan. The inspectors review was not documented in an NRC Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The requirements in 10 CFR 50.54(q) were used as reference criteria.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
Emergency Preparedness Drill/Simulator Evaluation/Observation
a. Inspection Scope
The inspectors evaluated the shift manager/emergency directors EP implementation during licensed operator simulator training on November 18, 2014. The inspectors observed emergency response operations in the simulator to determine whether event classifications and notifications were performed in accordance with approved procedures. The inspectors also reviewed the control room simulator drill critique to evaluate whether PBAPS staff were properly identifying emergency preparedness weaknesses and entering them into the CAP.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
During November 10-14, 2014, inspectors reviewed and evaluated Peach Bottom performance in assessing the radiological hazards and exposure control in the workplace. The inspectors used the requirements in 10 CFR Part 20; TSs; applicable industry standards; and procedures required by TSs as criteria for determining compliance.
Radiological Hazard Assessment The inspectors reviewed radiological surveys from selected pre-work surveys and plant areas.
Radiological Hazards Control and Work Coverage The inspectors:
toured the facility and reviewed work associated with outage P2R20 reviewed ambient radiological conditions reviewed existing conditions with posted surveys, radiation work permits (RWPs),and worker briefings reviewed the adequacy of radiological controls reviewed the use of electronic personal dosimeters (EPDs) in high noise areas and as high radiation area (HRA) monitoring devices.
reviewed the application of dosimetry to effectively monitor exposure in work areas with significant dose rate gradients reviewed airborne radioactivity controls and monitoring Radiation Worker Performance The inspectors:
observed radiation worker performance with respect to radiation protection work requirements reviewed workers awareness of the radiological conditions in their workplace and the RWP controls/limits in place
b. Findings
No findings were identified.
2RS2 Occupational As Low As Reasonably Achievable Planning and Controls (71124.02 -
1 sample)
a. Inspection Scope
During November 10-14, 2014, the inspectors assessed performance with respect to maintaining occupational individual and collective radiation exposures as low as reasonably achievable (ALARA). The inspectors used the requirements in 10 CFR Part 20; TSs; applicable industry standards; and procedures required by TSs as criteria for determining compliance.
Radiological Work Planning The inspectors:
selected the highest exposure work activities for outage P2R20 reviewed the ALARA work activity evaluations, exposure estimates, and exposure mitigation requirements for these work activities reviewed the licensees grouping of the radiological work into work activities reviewed the licensees planning to identify appropriate dose mitigation features reviewed the licensees ALARA assessment in the use of respiratory protective devices reviewed the integration of ALARA requirements into work procedure and RWP documents Verification of Dose Estimates and Exposure Tracking Systems The inspectors:
selected ALARA work packages and reviewed the dose calculations reviewed the applicable procedures to determine the dose estimating methodology reviewed the selected work activities for established measures to track, trend, and reduce exposure reviewed dose threshold criteria established to prompt additional ALARA reviews reviewed the licensees method of adjusting exposure estimates reviewed the bases for adjustments to exposure estimates Radiation Worker Performance The inspectors observed radiation worker and radiation protection technician performance during work.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
Mitigating Systems Performance Index
a. Inspection Scope
The inspectors sampled PBAPS submittals of the Mitigating Systems Performance Index (MSPI) for the period of October 1, 2013 through October 1, 2014:
Unit 2 and Unit 3 HPCI Systems (MS07)
Unit 2 and Unit 3 RCIC Systems (MS08)
Unit 2 and Unit 3 RHR Systems (MS09)
To determine the accuracy of the performance indicator (PI) data reported during this period, the inspectors used definitions and guidance contained in Nuclear Energy Institute (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.
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 Annual Sample: Increase in Total Organic Carbon in Unit 2 Torus Water (1 sample)
a. Inspection Scope
The inspectors performed an in-depth review of Exelon staffs evaluation and corrective actions related to identification of increased Total Organic Carbon (TOC) in a floor drain tank water sample that exceeded plant procedure limits. The review included Exelon staffs actions in identifying, assessing, evaluating and initiating technically adequate and timely corrective actions. The inspectors reviewed relevant corrective action documents and discussed the issues with cognizant technical and management personnel. The inspectors reviewed these activities to determine whether Exelon staff was identifying, characterizing, and correcting problems at an appropriate threshold.
The inspectors compared the actions taken to identify and correct the problems with the requirements of Exelons CAP and 10 CFR 50, Appendix B.
b. Findings and Observations
During routine sampling of torus water chemistry in December 2013, Exelon staff observed that the sample obtained from a floor drain tank had increased TOC greater than specified by plant procedures. Exelon staff initiated an investigation to identify the source and causes of elevated TOC. It was determined that a significant amount of the water in the drain tank came from the Unit 2 torus. Exelon staff reviewed chemistry sampling data from the most recent Unit 2 torus sample taken on December 4, 2013, and identified a TOC concentration of 2240 ppb. Exelon staff identified this value as greater than the limit of 1000 ppb contained in their procedure CY-PB-120-310. Further data review showed that the TOC content had been increasing since the fall refueling outage in 2012, when the Peach Bottom Unit 2 torus was recoated. After the refueling outage, the TOC was measured to be 319 ppb on November 4, 2012. Exelon staff entered the problem into their CAP in action report (AR) 01601661.
Exelon staff determined the TOC concentration had increased over the past 13 months with all of the other Unit 2 torus chemistry (chlorides and sulfates) parameters remaining at normal levels. As a result Exelon, staff concluded the problem did not involve in-leakage from the HPSW system during torus cooling lineup. Exelon staff identified the recent coating of torus interior surfaces as the likely source of elevated TOC because laboratory analyses indicated the coating curing agent included benzyl alcohol which was the majority TOC substituent. Exelon staff determined the Unit 3 torus water TOC was also increasing (likely because it received the same torus recoat) and initiated AR 01601996.
Exelon staff initiated corrective actions to address the delay in their staff not identifying the increased TOC trend from the Unit 2 refuel outage and to evaluate the acceptability of the condition and take action to limit TOC increases. Regarding timely identification of chemistry conditions that are out of specification, Exelon completed corrective actions that included reinforcing expectations to validate chemistry limits when recording sample results using the appropriate procedure and completing a review and comparison of each chemistry system procedure to ensure the flags for goals and limits in their database matched and contained the appropriate direction for action.
Regarding the increasing TOC trend in the Unit 2 and 3 torus water, Exelon staff evaluated the condition using post-UV anion analysis and determined that, while the effects of increasing TOC can impact radwaste resin bed effectiveness, it will not affect the safety-related function of the torus water. Specifically, TOC exposed to the reactor core neutron flux can break down over time to more aggressive chemical constituents involving sulfates and chlorides; however, it will not affect the function of torus water to provide core cooling if injected into the reactor coolant system from the emergency core cooling system. If torus water were injected, action would be necessary by Exelon staff to meet required chemistry limits prior to plant restart. Regarding radwaste resin beds, Exelon staff completed corrective action to place activated charcoal as an overlay to the floor drain deep bed demineralizer to provide for the radwaste system removal of TOC from torus water when used for normal torus level control. The inspectors further determined Exelon engineering staff was considering actions to develop a water purification skid to remove TOC.
Exelon staff reviewed the approval process for the torus recoating activity and identified governing documents for the coating did not include testing for leachable TOC as a consideration. Exelon staff tracked corrective actions to address this condition with the document owner and completed communications to the industry regarding increased TOC in torus water and the causes via an industry operating experience report.
The inspectors reviewed Exelons corrective actions to ensure timely identification of out of specification chemistry conditions. The inspectors did not identify additional issues. The inspectors determined Exelons overall response to identify the causes of increased TOC in the Unit 2 and 3 torus water, evaluate the impact, and initiate corrective actions met the standards in their CAP. The scope and timing of their corrective actions was determined to be commensurate with the safety significance of the problems.
.3 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 PBAPS CAP database for the six month period covering July 1, 2014 through December 31, 2014, 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 PBAPS trend report for the third quarter of 2014, 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 a minor adverse trend identified by PBAPS in the area of Foreign Material Exclusion program oversight during the Unit 2 RFO. The inspectors also noted and discussed with PBAPS staff a minor adverse trend in rigor and attention to detail in CAP products, including apparent cause evaluations and work group evaluations, but noted that there were no adverse safety consequences as a result of these low level trends. 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.
4OA5 Other Activities
.1 Institute of Nuclear Power Operations Report Review
a. Inspection Scope
The inspectors reviewed the final report for the PBAPS Institute of Nuclear Power Operations (INPO) assessment conducted during the weeks of April 28 and May 5, 2014. The inspectors reviewed this report to ensure that any issues identified were consistent with NRC perspectives of PBAPS performance and to determine if INPO identified any significant safety issues that required further NRC follow-up.
b. Findings
No findings were identified.
.2 Power Uprate, Inspection Procedure 71004
Unit 2 Extended Power Uprate and 20-percent Power Ascension
a. Inspection Scope
The inspectors observed selected plant testing and other power ascension activities during the implementation of the 20% phase (3514 to 3951 MWth) of a planned 2-phase extended power uprate totaling approximately 20% power. Inspectors observed and reviewed selected plant changes and testing prior to the power ascension that began on December 7, 2014. The inspectors observed control room and in-plant activities during the ascension to the old 100% power level, and walked down plant systems to ensure adverse conditions were identified, and if warranted, entered into the corrective action program for resolution. The inspectors also reviewed operator actions, applicable procedure changes, and selected plant design changes and other inspection activities conducted under the normal baseline inspection program, to ensure an adequate sample of risk-significant attributes required by the governing procedure were evaluated.
This included changes to plant operator briefings and training to address the actions resulting from a revised control room simulator model. Specific inspections already completed and credited in this NRC inspection report are listed below:
Flow Accelerated Corrosion (1R08)
Quarterly Review of Licensed Operator Requalification Testing and Training (1R11)
Plant Modifications (1R18)
Refueling and Other Outage Activities (1R20)
b. Findings
No findings of significance were identified
4OA6 Meetings, Including Exit
Quarterly Resident
Exit Meeting Summary
On January 16, 2015, the resident inspectors presented the inspection results to Mr. Michael Massaro, 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.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Exelon Generation Company Personnel
- M. Massaro, Site Vice President
- P. Navin, Plant Manager
- K. Aleshire, Exelon Corporate Emergency Preparedness Manager
- N. Alexakos, Emergency Preparedness Manager
- J. Armstrong, Regulatory Assurance Manager
- D. Baracco, ALARA Manager
- R. Bolding, Respiratory Physicist
- V. Cwietniewicz, Mid-Atlantic Corproate Emergency Preparedness Manager
- C. Cilluffo, Buried Piping and Tanks Program Engineer
- B. DeWalt, Engineering Programs
- D. Dullum, Exelon Senior Regulatory Engineer
- J. Feaster, Welding Engineer
- D. Foss, Regulatory Assurance Engineer
- J. Hawkins, NDE Corporate Level III
- B. Hennigan, Operations Training Manager
- M. Herr, Operations Director
- R. Holmes, Radiation Protection Manager
- M. Jesse, Regulatory Assurance Manager
- F. Leone, Chemistry Manager
- T. Moore, Site Engineering Director
- B. Reiner, Training Director
- R. Ridge, Supervisor, Radiological Instruments
- E. Schwarz, ODCM/RECP/REMP Program Manager
- B. Sessions, FAC/GL 89-13 Program Manager
- P. Simmons, Security Manager
- J. Stenclik, Chemistry Programs Supervisor
- D. Striebig, Emergency Preparedness Coordinator
- M. Weidman, Work Management Director
- J. Zellmer, LSRO Exam Developer
NRC Personnel
- F. Bower III, Branch Chief
- S. Hansell, Senior Resident Inspector
- B. Smith, Resident Inspector
- E. Burket, Emergency Preparedness Inspector
- S. Chaudhary, Senior Reactor Inspector
- T. Daun, Resident Inspector - Susquehanna
- T. Dunn, Operations Engineer
- M. Fannon, NSPDP, Region 1
- J. Furia, Senior Health Physicist
- M. Modes, Senior Reactor Inspector
- P. Presby, Senior Operations Engineer
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
None.
Discussed/Updated None.