IR 05000277/2023003

Integrated Inspection Report 05000277/2023003 and 05000278/2023003 and Exercise of Enforcement Discretion

ML23303A091
Person / Time
Site:	Peach Bottom
Issue date:	10/30/2023
From:	Sarah Elkhiamy NRC/RGN-I/DORS
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
EA-23-096 IR 2023003
Download: ML23303A091 (1)

Text

October 30, 2023

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 -

INTEGRATED INSPECTION REPORT 05000277/2023003 AND 05000278/2023003 AND EXERCISE OF ENFORCEMENT DISCRETION

Dear David Rhoades:

On September 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Peach Bottom Atomic Power Station. On October 12, 2023, the NRC inspectors discussed the results of this inspection with Adam Frain, Operations Director, and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Digitally signed by Sarah Sarah H. H. Elkhiamy Date: 2023.10.30 Elkhiamy 14:11:06 -04'00'

Sarah H. Elkhiamy, Acting Chief Projects Branch 4 Division of Operating Reactor Safety Docket Nos. 05000277 and 05000278 License Nos. DPR-44 and DPR-56

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000277 and 05000278 License Numbers: DPR-44 and DPR-56 Report Numbers: 05000277/2023003 and 05000278/2023003 Enterprise Identifier: I-2023-003-0041 Licensee: Constellation Energy Generation, LLC Facility: Peach Bottom Atomic Power Station Location: Delta, PA 17314 Inspection Dates: July 1, 2023 to September 30, 2023 Inspectors: S. Rutenkroger, Senior Resident Inspector C. Dukehart, Resident Inspector C. Borman, Health Physicist B. Edwards, Health Physicist D. Kern, Senior Reactor Inspector N. Mentzer, Reactor Inspector J. Schoppy, Senior Reactor Inspector Approved By: Sarah H. Elkhiamy, Acting Chief Projects Branch 4 Division of Operating Reactor Safety Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Peach Bottom Atomic Power Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal warm temperatures for the following systems: emergency diesel generators (EDGs), emergency service water (ESW), motor and diesel driven fire pumps, and high-pressure service water (HPSW) on July 27, 2023

Impending Severe Weather (IP Section 03.02) (1 Sample)

(1) Unit common, the inspectors evaluated the adequacy of the overall preparations to protect risk significant systems from impending severe thunderstorms and high winds on August 7, 2023

71111.04 - Equipment Alignment

Partial Walkdown (IP Section 03.01) (2 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 2, reactor core isolation cooling (RCIC) system during high-pressure coolant injection (HPCI) system maintenance on July 10, 2023

(2) Unit 2, residual heat removal (RHR) 'B' loop on September 28, 2023

Complete Walkdown (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the Unit 3 HPCI system on August 29, 2023

71111.05 - Fire Protection

Fire Area Walkdown and Inspection (IP Section 03.01) (3 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Unit 2, emergency battery and switchgear rooms, PF-127, on August 1, 2023

(2) Unit 2, '2A' & '2C' RHR pump and emergency core cooling system (ECCS) heat exchangers (HXs) room, PF-1, on September 28, 2023

(3) Unit 2, '2B' & '2D' RHR pump and HXs room, PF-3, on September 28, 2023

Fire Brigade Drill Performance (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the on-site fire brigade training and performance during an unannounced fire drill on August 10, 2023

71111.06 - Flood Protection Measures

Flooding (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated internal flooding mitigation protections in Units 2 and 3, specifically watertight door conditions and flood protection readiness on 88 and 96 elevations on August 7, 2023

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during the operator response to an issue with the Unit 3, #3 turbine control valve, on August 28, 2023

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operator requalification training in the simulator on September 11, 2023

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:

(1) Unit common, EDGs through September 30, 2023

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management (IP Section 03.01) (3 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Unit 2, 'A' loop of RHR and HPSW maintenance on July 31, 2023

(2) Unit 2, A and C HPSW pump replacements and implementation of a 30-day risk-informed completion time on August 9, 2023

(3) Unit 2, 'A' and 'C' HPSW pump replacements and field modifications on August 14, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Unit 2, HPCI steam supply drain pot level switch isolation valve packing leak first identified on January 10, 2023

(2) Unit 2, drywell gas radiation monitor trouble alarm received on July 24, 2023

(3) Unit 3, power cable 3Q0992B for reactor protection system scram discharge volume level switch LS-3-03-231C listed as a smaller gauge size on a design drawing than analyzed in voltage drop analysis on August 11, 2023

(4) Unit 2, fuel pool filter demineralizer hold pump '0AP086' oil leak on August 13, 2023

(5) Unit 3, local power range monitoring input to thermal limit calculations not functioning requiring usage of adaption mode calculations for steady state operation with a thermal limit penalty on September 19, 2023

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system

operability and/or functionality: Post-Maintenance Testing (IP Section 03.01)

(1) Unit 3, argon gas supply to containment vent header relief valve leak replacement on July 5, 2023

(2) Unit 2, RCIC remote shutdown panel flow controller replacement on July 17, 2023

(3) Unit 2, 'A' and 'C' HPSW pump replacements and system modification on August 16, 2023

(4) Unit 3, '3A/C' HPSW header leak repair components with piping flaw preparation and characterization and fabrication of tophat modification on September 2, 2023

(5) Unit 3, '3A/C' HPSW header leak repair on September 3, 2023

(6) Unit 2, HPCI turbine heat up bypass valve position limit switch replacement on September 7, 2023

(7) Unit 3, 3B standby liquid control pump accumulator replacement on September 11, 2023

(8) Unit common, computer room fire damper maintenance on September 30, 2023

Surveillance Testing (IP Section 03.01) (1 Sample)

(1) Unit 3, generator verification of gross and net reactive power capability on July 26, 2023

Reactor Coolant System Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) Units 2 and 3, monitored for increased drywell unidentified leakage as of July 12,

71124.07 - Radiological Environmental Monitoring Program

Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples.

Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.

Groundwater Protection Initiative (GPI) Implementation (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees implementation of the GPI program to identify incomplete or discontinued program elements.

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation

Radioactive Material Storage (IP Section 03.01)

The inspectors evaluated the licensees performance in controlling, labeling and securing the following radioactive materials:

(1) Spent resin pump and tank room

(2) Unit 3 waste sludge pump and tank room

Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)

The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:

(1) Unit 3, condensate storage tank moat

(2) Unit 3 waste/floor drain sample tank area

Waste Characterization and Classification (IP Section 03.03) (2 Samples)

The inspectors evaluated the following characterization and classification of radioactive waste:

(1) Characterization of Low Specific Activity (LSA) - II package U231328

(2) Characterization of LSA - II package U231317

Shipment Preparation (IP Section 03.04) (1 Sample)

(1) The inspectors observed the preparation of radioactive shipment U231328

Shipping Records (IP Section 03.05) (4 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through a record review:

(1) UN 3321, LSA - II, Package #U231328LSA

(2) UN 3321, LSA - II, Package #U231317

(3) UN 3321, LSA - II, Package #U231998

(4) UN 3321, LSA - II, Package #U231999

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified Constellation's performance indicators submittals listed below for the period October 1, 2022, through September 30, 2023, except where otherwise noted:

IE04: Unplanned Scrams with Complications Sample (IP Section 02.03) ===

(1) Unit 2 for the period January 1, 2022, through December 31, 2022

MS07: High-Pressure Injection Systems (IP Section 02.06) (2 Samples)

(1) Unit 2 high-pressure injection systems

(2) Unit 3 high-pressure injection systems

MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)

(1) Unit 2 heat removal systems

(2) Unit 3 heat removal systems

MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)

(1) Unit 2 RHR systems

(2) Unit 3 RHR systems

MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)

(1) Unit 2 cooling water support systems

(2) Unit 3 cooling water support systems

71152A - Annual Follow-up Problem Identification and Resolution (PI&R) Annual Follow-up of Selected Issues (Section 03.03)

The inspectors reviewed the licensees implementation of its corrective action program (CAP) related to the following issues:

(1) IR 4529051, River Water Cooled HX Fouling Trend Issue

INSPECTION RESULTS

Minor Violation 71124.08 Minor Violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 37 Minor Violation: A minor violation of 10 CFR Part 37 with respect to Category 2 quantities of radioactive material stored in robust structures was identified and the issue was discussed during the exit meeting. However, the inspectors verified that Constellation met all the criteria in NRC Enforcement Guidance Memorandum (EGM) 14-001, Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52. Therefore, the NRC is exercising enforcement discretion (EA-23-096) and will not issue any enforcement action for this violation. In accordance with IMC 0612 App. E, section 7, violations within the scope of EGM-2014-001 are considered minor violations and are to be documented in inspection reports with an enforcement action number (EA-23-096) for tracking purposes.

Screening: The inspectors determined the performance deficiency was minor. The inspectors determined this violation screened to minor in accordance with IMC 0612, Appendix B, Issue Screening. See example 7b of IMC 0612, Appendix E.

Enforcement:

10 CFR 37.49(a)(1) Monitoring and Detection, states in part, that licensees shall establish and maintain the capability to continuously monitor and detect without delay all unauthorized entries into its security zones. Contrary to this requirement, the Category 2 sources stored in certain areas were not continuously monitored as required. The inspectors verified that the violation meets the conditions for enforcement discretion specified in EGM 14-001, Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52, issued March 14, 2014. Namely, the site has identified in writing the robust structures that were not in compliance, has a written 10 CFR Part 37 security plan that provides security measures adequate to detect, assess, and respond to actual or attempted theft or diversion with a written analysis that considers the time needed to accomplish these activities given the proximity and mobility of the equipment available for the robust structures, and has a written analysis which confirms that the compensatory measures do not decrease the effectiveness of the 10 CFR Part 73 security plan. Therefore, the NRC is exercising enforcement discretion and not pursuing any enforcement action for this violation.

Observation: River Water Cooled HX Fouling Trend Issue Annual PI&R Sample 71152A On October 13, 2022, Constellation staff initiated corrective action issue report (IR) 4529051 for an adverse trend in individual IRs and work requests generated during the summer of 2022 associated with river water cooled HX fouling during low river flow and/or high river water temperature periods. Specifically, IR 4529051 listed 26 HX fouling-related IRs; with 15 of the IRs associated with the ECCS room coolers.

Engineering staffs associated evaluation attributed the HX fouling to river conditions during the late summer period which resulted in low river water flows, high river water temperatures, and low river levels. The lower river levels in the plant intakes can cause a disturbance of river-related debris in the service water (SW) bays due to turbulent mixing and result in increased debris entrainment in the SW supplied to plant equipment. The increased debris entrainment in the SW flowing through the HXs resulted in fouling of the tube sheets and tubes on the inlet side of the various HXs and necessitated more frequent flushing and/or cleaning of the HXs. Constellation staffs corrective actions included:

(1) monitoring additional parameters in their online summer performance monitoring program,

(2) increasing the frequency of the intake inspection and cleaning preventive maintenance (PM) task, (3)evaluating the need for scheduling a periodic HX cleaning PM for the ECCS room coolers, and

(4) developing a design change to replace obsolete SW flow elements and SW flow indicators in the ECCS pump rooms.

The inspectors determined that Constellations associated engineering evaluations and trending were sufficient to identify corrective actions that were appropriately focused to correct the problem. Constellations corrective actions were completed in a timely manner commensurate with the safety significance of the issues. Based on the documents reviewed and independent walkdowns of all Unit 2 and Unit 3 ECCS room coolers, the inspectors noted that Constellation personnel identified problems and entered them into the CAP completely, accurately and timely. The inspectors noted that equipment operators effectively monitored SW flow through the ECCS room coolers during the rounds and initiated corrective actions to flush and/or clean the coolers using the CAP to preclude emergent adverse impact on the supported ECCS equipment. The inspectors considered the standards that applied in Constellations abnormal operating procedures, CAP, 10 CFR 50 Appendix B, and the Peach Bottom Atomic Power Station Technical Specifications and Technical Requirements Manual. Based on the documents reviewed, SW and room cooler walkdowns, and discussions with operations and engineering personnel, the inspectors did not identify any findings of more than minor significance during this inspection.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On August 10, 2023, the inspectors presented the River Water Cooled HX Fouling Trend Issue PI&R annual sample inspection results to Kevin Stauffer, Nuclear Steam Supply System Engineering Branch Manager, and other members of the licensee staff.

• On October 12, 2023, the inspectors presented the integrated inspection results to Adam Frain, Operations Director, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Corrective Action Condition Reports

Documents IR 04695144

IR 04675719

71111.01 Procedures AO 53.2-0 Equipment Checks After a Thunderstorm or High Wind Event Revision 12

71111.01 Procedures OP-AA-108-111- Severe Weather and Natural Disaster Guidelines Revision 26

1001

71111.01 Procedures SY-AA-101-146 Severe Weather Preparation and Response Revision 3

71111.01 Procedures WC-AA-107 Seasonal Readiness Revision 25

71111.04 Corrective Action Issue Reports

Documents 04294905

04518445

04521787

04536815

04551077

04552323

04680971

04698993

71111.04 Drawings 6280-M-359 P & I Diagram RCIC System Revision 50

Sheet 1

71111.04 Drawings 6280-M-359 P & I Diagram RCIC System Revision 48

Sheet 2

71111.04 Miscellaneous M-365 P & I Diagram, HPCI System, Sheet 2 Revision 66

71111.04 Miscellaneous M-366 P & I Diagram, HPCI Pump - Turbine Details, Lube Oil and Revision 45

Control System, Sheet 3

71111.04 Procedures M-361, P&I RHR System Revision 88

Diagram

71111.04 Procedures ST-O-023-300-3 HPCI Pump, Valve, Flow and Unit Cooler Functional and In- Revision 22

Service Test Without Vibration Data Collection

71111.04 Procedures ST-O-023-301-3 HPCI Pump, Valve, Flow and Unit Cooler Functional and In- Revision 79

Service Test With Vibration Data Collection

71111.04 Procedures ST-O-023-302-3 HPCI Pump, Valve, Flow and Unit Cooler Functional and In- Revision 22

Service Comprehensive Test and MO-3-23-014 Component

Inspection Type Designation Description or Title Revision or

Procedure Date

Test from Alternative Control Panel

71111.04 Work Orders 05357476

04806856

71111.05 Procedures

71111.05 Procedures

71111.05 Procedures PF-1 Unit 2 Reactor Building, '2A' & '2C' RHR Pump and HX Revision 5

Room, Elevation 91'-6"/116'-0"

71111.05 Procedures PF-127 Unit 2 Turbine Building, Emergency Battery SWGR Rooms, Revision 11

Elevation 135'-0"

71111.05 Procedures PF-152 Peach Bottom Unit 2 Main Transformer Yard Pre-Fire Plan Revision 8

71111.05 Procedures PF-3 Unit 2 RX Building, '2B' & '2D' RHR Pump and HX Room, Revision 6

Elevation 91'-6"/116'-0"

71111.06 Procedures AO 20A.1 Temporary Removal and Installation of Flood Barriers in the Revision 19

Reactor Building Drainage System

71111.06 Procedures CC-PB-201 Hazard Barrier Control Program Revision 14

71111.06 Procedures M-C-700-605 Inspection and Required Maintenance for Watertight Doors Revision 5

71111.15 Corrective Action 04547694

Documents

71111.15 Corrective Action 04696254

Documents

71111.15 Corrective Action IR 0469039

Documents

71111.15 Corrective Action IR 04703664

Documents

71111.15 Corrective Action Issue Report (IR)

Documents 04692201

71111.15 Procedures NF-AB-707 3D MONICORE - Operation and Maintenance Revision 8

71111.15 Work Orders WR 1531524

71111.24 Corrective Action 04552645

Documents

71111.24 Corrective Action 04686159

Documents

71111.24 Corrective Action 04699649

Documents 04699651

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.24 Corrective Action 04699907

Documents

71111.24 Corrective Action IRs

Documents 04701411

04701903

71111.24 Miscellaneous EC 639707

BOP-UT-23-017

BOP-PT-23-024

BOP-MT-23-045

71111.24 Procedures RT-O-020-100-2 Determination of Rate and Location of Drywell Leakage Revision 2

71111.24 Procedures RT-O-050-540-3 Verification of Generator Gross and Net Reactive Power Revision 16

Capability Test

71111.24 Procedures S12F-13-58- Calibration Check of RCIC Flow Instruments FT 2-13-58, Revision 5

XXC2 Fl/FC 2-13-91, FS 2-13-57, and Fl/FC 2-13-91X

71111.24 Procedures ST-I-37A-311 Computer Room Cardox Simulated Actuation and Air Flow Revision 3

Test

71111.24 Procedures ST-O-011-306-3 Standby Liquid Control Pump B Functional Test for IST Revision 6

71111.24 Procedures ST-O-020-056-2 Reactor Coolant Leakage Test Revision 16

71111.24 Procedures ST-O-032-301-3 HPSW Pump, Valve and Flow Functional and In-service Test Revision 44

71111.24 Procedures ST-O-032-635-3 HPSW System Pressure Test Examination Revision 11

71111.24 Procedures ST-O-094-400-2 Stroke Time Testing of Valves for Pre-Maintenance or Post- Revision 10

Maintenance Testing

71111.24 Procedures ST-O-094-400-2 Stroke Time Testing of Valves for Pre-Maintenance or Post- Revision 10

Maintenance Testing

71111.24 Work Orders

71111.24 Work Orders 01546884

71111.24 Work Orders 05158790

71111.24 Work Orders 05339071

71111.24 Work Orders 05396262

71111.24 Work Orders 05399102

01546975

05398523

71152A Corrective Action 4514004

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents 4516882

4516918

4517287

4517998

4518779

4519330

4519951

20488

21519

24004

24658

26154

29051

4538816

4546512

4548568

4561003

4563611

4669591

4673225

4673227

4682011

4682568

4685575

4685784

4687517

4689450

4691824

71152A Corrective Action 4695506

Documents

Resulting from

Inspection

71152A Engineering 4529051-04 River Water Cooled HX Fouling Work Group Evaluation dated

Evaluations 11/18/22

Inspection Type Designation Description or Title Revision or

Procedure Date

71152A Miscellaneous PMC-23-143113 Change Online Common Intake Bay Inspection/Cleaning PM dated

back to 2 Year Frequency 6/30/23

71152A Miscellaneous RT-1-033-632-2 2FE058 RHR Room Cooler ESW Heat Transfer Test performed

2/23/23

71152A Miscellaneous RT-1-033-632-3 3AE058 RHR Room Cooler ESW Heat Transfer Test performed

1/19/23

71152A Miscellaneous RT-1-033-632-3 3BE057 Core Spray Room Cooler ESW Heat Transfer Test performed

2/28/23

71152A Procedures AO 33.5.A RHR/CORE SPRAY/HPCI/RCIC Room Cooler Flush Revision 4

71152A Procedures ER-AA-340 GL 89-13 Program Implementing Procedure Revision 11

71152A Procedures PI-AA-120 Issue Identification and Screening Process Revision 13

71152A Procedures PI-AA-125 CAP Procedure Revision 8

71152A Work Orders 05130994

293312

05313704

14