IR 05000277/2023003
| 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, 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:
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
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.
REACTOR SAFETY
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
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:
- (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) (8 Samples)
- (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
- (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,
RADIATION SAFETY
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
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Condition Reports
IR 04675719
Procedures
AO 53.2-0
Equipment Checks After a Thunderstorm or High Wind Event
Revision 12
Procedures
OP-AA-108-111-
1001
Severe Weather and Natural Disaster Guidelines
Revision 26
Procedures
Severe Weather Preparation and Response
Revision 3
Procedures
Seasonal Readiness
Revision 25
Corrective Action
Documents
Issue Reports
294905
04518445
04521787
04536815
04551077
04552323
04680971
04698993
Drawings
280-M-359
Sheet 1
P & I Diagram RCIC System
Revision 50
Drawings
280-M-359
Sheet 2
P & I Diagram RCIC System
Revision 48
Miscellaneous
M-365
P & I Diagram, HPCI System, Sheet 2
Revision 66
Miscellaneous
M-366
P & I Diagram, HPCI Pump - Turbine Details, Lube Oil and
Control System, Sheet 3
Revision 45
Procedures
M-361, P&I
Diagram
RHR System
Revision 88
Procedures
HPCI Pump, Valve, Flow and Unit Cooler Functional and In-
Service Test Without Vibration Data Collection
Revision 22
Procedures
HPCI Pump, Valve, Flow and Unit Cooler Functional and In-
Service Test With Vibration Data Collection
Revision 79
Procedures
HPCI Pump, Valve, Flow and Unit Cooler Functional and In-
Service Comprehensive Test and MO-3-23-014 Component
Revision 22
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Test from Alternative Control Panel
Work Orders
05357476
04806856
Procedures
Procedures
Procedures
PF-1
Unit 2 Reactor Building, '2A' & '2C' RHR Pump and HX
Room, Elevation 91'-6"/116'-0"
Revision 5
Procedures
PF-127
Unit 2 Turbine Building, Emergency Battery SWGR Rooms,
Elevation 135'-0"
Revision 11
Procedures
PF-152
Peach Bottom Unit 2 Main Transformer Yard Pre-Fire Plan
Revision 8
Procedures
PF-3
Unit 2 RX Building, '2B' & '2D' RHR Pump and HX Room,
Elevation 91'-6"/116'-0"
Revision 6
Procedures
AO 20A.1
Temporary Removal and Installation of Flood Barriers in the
Reactor Building Drainage System
Revision 19
Procedures
CC-PB-201
Hazard Barrier Control Program
Revision 14
Procedures
M-C-700-605
Inspection and Required Maintenance for Watertight Doors
Revision 5
Corrective Action
Documents
04547694
Corrective Action
Documents
04696254
Corrective Action
Documents
Corrective Action
Documents
Corrective Action
Documents
Issue Report (IR)
04692201
Procedures
3D MONICORE - Operation and Maintenance
Revision 8
Work Orders
Corrective Action
Documents
04552645
Corrective Action
Documents
04686159
Corrective Action
Documents
04699649
04699651
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
04699907
Corrective Action
Documents
IRs
04701411
04701903
Miscellaneous
BOP-UT-23-017
BOP-PT-23-024
BOP-MT-23-045
Procedures
Determination of Rate and Location of Drywell Leakage
Revision 2
Procedures
Verification of Generator Gross and Net Reactive Power
Capability Test
Revision 16
Procedures
XXC2
Calibration Check of RCIC Flow Instruments FT 2-13-58,
Fl/FC 2-13-91, FS 2-13-57, and Fl/FC 2-13-91X
Revision 5
Procedures
Computer Room Cardox Simulated Actuation and Air Flow
Test
Revision 3
Procedures
Standby Liquid Control Pump B Functional Test for IST
Revision 6
Procedures
Reactor Coolant Leakage Test
Revision 16
Procedures
HPSW Pump, Valve and Flow Functional and In-service Test
Revision 44
Procedures
HPSW System Pressure Test Examination
Revision 11
Procedures
Stroke Time Testing of Valves for Pre-Maintenance or Post-
Maintenance Testing
Revision 10
Procedures
Stroke Time Testing of Valves for Pre-Maintenance or Post-
Maintenance Testing
Revision 10
Work Orders
Work Orders
01546884
Work Orders
05158790
Work Orders
05339071
Work Orders
05396262
Work Orders
05399102
01546975
05398523
71152A
Corrective Action
4514004
Inspection
Procedure
Type
Designation
Description or Title
Revision or
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
Documents
Resulting from
Inspection
4695506
71152A
Engineering
Evaluations
29051-04
River Water Cooled HX Fouling Work Group Evaluation
dated
11/18/22
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71152A
Miscellaneous
PMC-23-143113
Change Online Common Intake Bay Inspection/Cleaning PM
back to 2 Year Frequency
dated
6/30/23
71152A
Miscellaneous
2FE058 RHR Room Cooler ESW Heat Transfer Test
performed
2/23/23
71152A
Miscellaneous
3AE058 RHR Room Cooler ESW Heat Transfer Test
performed
1/19/23
71152A
Miscellaneous
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
GL 89-13 Program Implementing Procedure
Revision 11
71152A
Procedures
Issue Identification and Screening Process
Revision 13
71152A
Procedures
CAP Procedure
Revision 8
71152A
Work Orders
05130994
293312
05313704