IR 05000277/2011003
| ML112150590 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/03/2011 |
| From: | Paul Krohn Reactor Projects Region 1 Branch 4 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| Krohn P | |
| References | |
| IR-11-003 | |
| Download: ML112150590 (51) | |
Text
UNITED STATES N UCLEAR REGU LATORY COMMISSION W
REGION I
4T5ALLENDALE ROAD KING OF PRUSSIA. PENNSYLVANIA 19406-1415 August 3, 2OI7 Mr. Michael Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road Warenville, lL 60555 SUBJECT: PEACH BorroM AToMlc powER srATtoN - NRc TNTEGRATED I NSPECTION REPORT 05000277 t20 1 1 003 AN D O50oO 27 8t201 1 oo3
Dear Mr. Pacilio:
On June 30,2011, the U. S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Peach Bottom Atomic Powerstation (PBAP's), Units 2 and 3. The encfosed integrated inspection report documents the inspection results, w'nicn were discussed on July 29, 2011, with Mr. Thomas Dougherty, Peach Bottom Site Vice President, and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of youi license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of this inspection, no findings were identified. However, a licensee-identified violation, which was determined to be of very low safety significance, is listed in this report. However, because of the very low safety significance and because it has been entered into your corrective action program (CAP), the NRC is treating the finding as a non-cited violation (NCV) consistent with Section 2.3.2 of the NRC's Enlorcement policy. lf you contest the NCV in this report, you should provide a response within 30 days of the dite of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN:
Document control Desk, washington, DC 20sss-0001; with copiJs to thb Regionat 49lli{qtor, Region l; the Director, office of Enforcement, u. s. NRc, washington, DC 20555-0001; and the NRC senior Resident Inspector at the pBAps.
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 iesponse (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.qov/readinq-rm/adams.html (the Public Electronic Reading Room).
Sincerely, Paul G. Krohn, Chief Projects Branch 4 Division of Reactor Projects Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56
Enclosure:
Inspection Report 050002771201 1003 and 05000278120110003 w/Attachment: Supplemental lnformation
REGION I Docket Nos.: 50-277,50-278 License Nos.: DPR-44, DPR-56 Report No.: 05000277 1201 1 003 and 0500027 81201 1003 Licensee: Exelon Generation Company, LLC Facility: Peach Bottom Atomic Power Station, Units 2 and 3 Location: Delta, Pennsylvania Dates: April 1 ,2011through June 30, 2011 Inspectors: F. Bower, Senior Resident Inspector N. Lafferty, Acting Resident lnspector A. Ziedonis, Resident Inspector D. Molteni, Reactor Inspector R. Nimitz, Senior Health Physicist J. Nicolson, Health Physicist B. Dionne, Health Physicist Approved by: Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
TABLE OF CONTENTS suMMARy OF FlNDlNGS............ ...,,....3 REPORT DETATLS ...............4 1. REACTOR SAFETY .........4 1R01 Adverse Weather Protection ...............4 1R04 Equipment Alignment ........6 1R05 Fire Protection .......... .........6 1R06 Flood Protection Measures .................7 1R11 Licensed Operator Requalification Program ............. ............7 1R12 Maintenance Effectiveness ......... ........8 1R13 Maintenance Risk Assessments and Emergent Work Control ................................9 1R15 Operability Evaluations ........,.,............9 1R18 Plant Modifications ..........10 1R19 Post-Maintenance Testing ................10 1R22 Surveillance Testing ........11 1EPO Drill Evaluation ......... .......11 2. RADlATION SAFETY .....................12 2RS01 Access Control to Radiologically Significant Areas .................12 2RS05 Radiation Monitoring Instrumentation ........ ..........,,13 2RS06 Radioactive Gaseous and Liquid Effluent Treatment .........14 2RS07 Radiological Environmental Monitoring Program (REMP) . , .....17 2RS08 Radioactive Solid Waste Processing and Radioactive Material, Handling Storage, and Transportation ..........19 4. OTHER ACTTVTTTES (OA) ..............22 4OA1 Performance lndicator Verification .....................22 4OA2 ldentification and Resolution of Problems (Pl&R) ...............22 4OA3 Follow-up of Events and Notices of Enforcement Discretion .................25 4OA5 Other Activities .................25 4OAO Meetings, Including Exit........... ..........28 4OA7 Licensee-ldentified Violations ............28 ATTACHMENT: SUPPLEMENTAL INFORMATION ..............29 SUPPLEMENTAL INFORMATION .......... .....,..... A-1 KEY POTNTS OF CONTACT ............. A-1 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED .,..4.2 LIST OF DOCUMENTS REVIEWED ..,........ ....... A-3 LlsT oF ACRONYMS............... ....... A-20 Enclosure
SUMMARY OF FINDINGS
lR 0500027712011003, 0500027812011003; 0410112011 - 061301201 1; Peach Bottom Atomic
Power Station (PBAPS), Units 2 and 3; Integrated Inspection.
The report covered a three-month period of inspection by resident inspectors and announced inspections by a regional reactor inspector and a senior health physicist. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
Cornerstones: Initiating Events, Mitigating Systems, and Barrier lntegrity None.
Other Findinqs One violation of very low safety significance, which was identified by the licensee, has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's CAP. This violation and the licensee's corrective action tracking numbers are listed in Section 4OA7 of this report.
REPORT DETAILS
Summarv of Plant Status Unit 2 began the inspection period at 100 percent rated thermal power (RTP) where it generally remained until power was reduced to approximately 60 percent on May 20, to support summer readiness maintenance. The unit was returned to 100 percent RTP on May 21, where it generally remained until May 31, when power was reduced to 83 percent in response to a control rod drifting into the core. The unit was returned to 100 percent RTP later that day where it generally remained until the end of the inspection period, except for brief periods to support planned testing, maintenance, and rod pattern adjustments.
Unit 3 began the inspection period at 100 percent RTP where it generally remained until power was reduced to approximately 60 percent beginning on April 29, to support summer readiness maintenance. The unit was returned to 100 percent RTP on May 2, where it generally remained until the end of the inspection period, except for brief periods to support planned testing, maintenance, and rod pattern adjustments.
1. REACTOR SAFEW
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection (71111.01 - 4 Samples)
.1 Grid Reliabilitv (1 Grid Reliability Sample)
a.
lnspection Scope The inspectors reviewed plant features and procedures for operation and continued availability of offsite and backup power systems during adverse weather (summer conditions). The inspectors reviewed communication protocols between the control room personnel and electrical system operations, as well as measures prescribed and taken to maintain the availability and reliability of these alternating current systems.
Documents reviewed are listed in the Attachment.
b.
Findinqs No findings were identified.
.2 External Floodinq (1 External Flooding Sample)
a. Inspection Scope
The inspectors reviewed selected risk-important plant design features intended to protect the plant and its safety-related equipment from external flooding events. The inspectors reviewed the external flood analyses in Design Bases Document (DBD)
P-T-07, "External Hazards," selected sections of the Updated Final Safety Analysis Report (UFSAR), and Special Event (SE) Procedure, SE-4, "Flood Procedure." On April 2, 2Q11, the inspectors walked down the high pressure service water (HPSW) rooms, emergency cooling tower, and the emergency service water (ESW) room to review the licensee's external flooding protection. ln addition, flooding design bases, flooding procedures, and relevant issue reports (lRs) were reviewed.
Findinqs No findings were identified.
.3 Summer Seasonal Readiness Preparations (1 Seasonal Readiness Sample)
a. lnspection Scope The inspectors conducted a review of PBAPS's preparations for the 2011 summer conditions to verify selected features of the plant's design were sufficient to protect mitigating systems from the effects of adverse weather. The inspectors performed a detailed review of PBAPS's and Exelon's written procedures for summer readiness, including PBAPS's implementation of procedure WC-AA-107, "Seasonal Readiness," in preparation for summer season readiness. Documentation for selected risk-significant systems was reviewed to ensure that these systems would remain functional when challenged by inclement weather. During the inspection, the inspectors focused on plant specific design features and the licensee's procedures used to mitigate or respond to adverse weather conditions. The inspectors reviewed the UFSAR and performance requirements for systems selected for inspection. The inspectors reviewed CAP records to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their CAP. In addition, the inspectors reviewed the "Certification of 2011 Peach Bottom Summer Readiness" memorandum dated May 13,2011. Documents reviewed during this inspection are listed in the Attachment.
The inspectors walked down the following systems and equipment:
.
Unit 2 HPSW and ESW pump room;
.
Unit 3 HPSW and ESW pump room; r Emergency dieselgenerator (EDG) rooms; and
.
'A' and 'B' environmental cooling towers, b. Findinos No findings were identified.
4. Adverse Weather Event (1 Event Sample)
a. Inspection Scope
During two time periods on April 28,2011, tornado warnings were declared for the areas in the vicinity of PBAPS. The inspectors verified that the control room operator crew entered procedure OP-PB-108-1 1 1-1001, "Preparation for Severe Weather." The inspectors also verified that operators recognized the increase (from green to yellow) in online risk due to weather conditions per the guidance in procedure WC-AA-101, "On-Line Work Control Process." Additionally, the inspectors walked down and inspected areas external to the plant look for potential missile hazards and informed PBAPS personnel of potential areas of concern. The inspectors confirmed that there were no actual high winds effects on the plant on April 28, 2011. The inspectors also reviewed CAP items to verify that PBAPS was identifying adverse weather issues at an appropriate threshold and entering them into their CAP in accordance with station corrective action procedures. Documents reviewed during the inspection are listed in the Attachment. This activity constituted one inspection sample.
b.
Findinqs No findings were identified.
1R04 Equipment Alionment (71111.04Q - 3 Samples)
PartialWalkdown a.
lnspection Scope The inspectors performed a partial walkdown of three systems to verify the operability of redundant or diverse trains and components when safety-related equipment was inoperable. The inspectors performed walkdowns to identify any discrepancies that coufd impact the function of the system and potentially increase risk. The inspectors reviewed selected applicable operations procedures, walked down system components, and verified that selected breakers, valves, and support equipment were in the correct position to support system operation. Documents reviewed during the inspection are listed in the Attachment. The three systems reviewed were:
.
'A'train of ESW during 'B'train planned maintenance; o Unit 2 'B'train of core spray (CS) during 'A'train planned maintenance; and
.
Unit 3 'B'train of residual heat removal during 'A'train planned maintenance.
b.
Findinos No findings were identified.
1R05 Fire Protection (71111.05Q - 6 Samples)
Fire Protection - Tours a.
lnspection Scope The inspectors conducted six fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment. The inspectors reviewed areas to assess whether PBAPS had implemented the Peach Bottom Fire Protection Plan (FPP) and adequately: controlled combustibles and ignition sources within the plant; maintained fire detection and suppression capability; and maintained the material condition of passive fire protection features. For the areas inspected, the inspectors also verified that PBAPS had followed the Technical Requirements Manual (TRM) and the FPP when compensatory measures were implemented for out-of-service, degraded or inoperable fire protection equipment, systems, or features. The inspectors verified: that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient combustible materials were managed in accordance with plant procedures; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition.
Documents reviewed during the inspection are listed in the Attachment. The inspectors toured the following areas:
o Unit 2 RB, GeneralArea North - Elevation 135'-0" (Fire Zone 5H);
.
Unit 2 Reactor Building (RB), GeneralArea - Elevation 165'-0' (Fire Zone 5J);
.
Unit 2 RB, GeneralArea - Elevation 195'-0' (Fire Zone 5K);
.
Unit 2 RB, 135'Elevation South (Fire Zone 5P);
.
Unit 3 RB; GeneralArea - Elevation 165'-0' (Fire Zone 13J); and
.
Unit 2 RB, Refuel Floor - Elevation 234'-0" (Fire Zone 57).
Findinqs No findings were identified.
1 R06 Flood Protection Measures (71111.06 - 1 Sample)lnternal Flood Protection Insoection Scope The inspectors reviewed selected risk-important plant design features intended to protect the plant and its safety-related equipment from flooding events. The inspectors reviewed the flood analysis and UFSAR. The inspectors walked down the interior of the cardox room in the EDG building with PBAPS engineering personnelto evaluate the condition of penetration seals, watertight doors, and other flood protection design features. The inspectors also verified that PBAPS personnel initiated lRs to enter the identified discrepancies into the CAP. The lRs and other documents reviewed are listed in the Attachment.
b.
Findinqs No findings were identified.
1R1 1 Licensed Operator Requalification Prooram (71111.1 1Q - 1 Sample)
Resident Inspector Quarterlv Review a.
Insoection Scope On April 18,2011, the inspectors observed a simulator-based licensed operator evaluation, during requalification training, to assess licensed operator performance and the evaluator's post-scenario critique. The inspectors evaluated crew performance in the areas of:
.
Clarity and formality of communications;
.
Ability to take timely actions; o Prioritization, interpretation, and verification of alarms;
.
Procedure usage; r Timely control board manipulations with a focus on high-risk operator actions; o Shift supervisor command and control, including identification and implementation of Technical Specifications (TSs), event classification, and emergency response actions; and
.
Group dynamics involved in crew performance.
The inspectors verified that any crew performance issues and weaknesses were discussed in the post-scenario critique. The inspectors also verified simulator physical fidelity, to ensure that the simulator arrangement closely paralleled the main control room (MCR). Documents reviewed during the inspection are listed in the Attachment.
These activities constituted one quarterly licensed operator requalification training program inspection sample.
b. Findinqs No findings were identified.
1R12 Maintenance Effectiveness (71111J2Q - 2 Samples)
a. Inspection Scope
The inspectors evaluated PBAPS's work practices and follow-up corrective actions for safety-related structures, systems, and components (SSCs) and identified issues to assess the effectiveness of PBAPS's maintenance activities. The inspectors reviewed the performance history of SSCs and assessed PBAPS's extent-of-condition determinations for those issues with potential common cause or generic implications to evaluate the adequacy of the PBAPS's corrective actions. The inspectors assessed PBAPS's problem identification and resolution (Pl&R) actions for these issues to evaluate whether PBAPS had appropriately monitored, evaluated, and dispositioned the issues in accordance with Exelon procedures, including ER-AA-310, "lmplementation of the Maintenance Rule," and the requirements of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance." In addition, the inspectors reviewed selected SSC classifications, performance criteria and goals, and PBAPS's corrective actions that were taken or planned, to evaluate whether the actions were reasonable and appropriate. The inspectors performed the following two samples:
.
Unit 2 Reactor Building Closed-Cooling Water System (RBCCW) unavailability limit exceeded (lR 1169733); and o Manhole (MH) 60 water level is above limit (lR 1206494).
b. Findinos No findings were identified.
1R13 Maintenance Risk Assessments and Emerqent Work Control (71111.13 - 4 Samples)
a. Inspection Scope
The inspectors evaluated PBAPS's implementation of the Maintenance Risk Program with respect to the effectiveness of risk assessments performed for maintenance activities that were conducted on SSC's. The inspectors also verified that PBAPS managed the risk in accordance with 10 CFR Part 50.65(a)(4) and procedure WC-AA-101, "On-line Work Control Process." The inspectors evaluated whether PBAPS had taken the necessary steps to plan and control emergent work activities and to manage overall plant risk. The inspectors selectively reviewed PBAPS's use of the online risk monitoring software and daily work schedules. Documents reviewed during the inspection are listed in the Attachment. The activities selected were based on plant I
maintenance schedules and systems that contributed to risk. The inspectors completed four evaluations of maintenance activities on the following:
o Unit 3 High Pressure Coolant Injection System (HPCI) planned maintenance (Clearance 1 1000628);
.
Unit 3 unplanned half scram during Average Power Range Monitoring System (APRM) #4 surveillance testing (work order (WO) R1178116);o Unit 2 control rod 02-35 drift and unplanned entry into off normal procedure for a rod drift, ON-121 (lR 1222498); and
.
Unplanned entry into SE procedure (SE)-16, "Grid Emergency," due to receipt of a maximum generation action issued by PJM (load dispatcher/grid operator tR 1222821).
b. Findinqs No findings were identified.
1R15 Operabilitv Evaluations (71111.15 - 6 Samples)
a. lnspection Scope The inspectors reviewed six issues to assess the technical adequacy of the operability determinations (ODs), the use and control of compensatory measures, and compliance with the licensing and design bases. Associated adverse condition monitoring plans (ACMPs), engineering technical evaluations, and operational and technical decision making (OTDM) documents were also reviewed. The inspectors verified these processes were performed in accordance with the applicable administrative procedures and were consistent with NRC guidance. Specifically, the inspectors referenced procedure OP-AA-108-115, "ODs," and NRC Inspection Manual Chapter (lMC) Part 9900, "ODs & Functionality Assessments for Resolutions of Degraded or Nonconforming Conditions Adverse to Quality or Safety." The inspectors also used TSs, TRM, UFSAR, and associated DBDs as references during these reviews. Documents reviewed during the inspection are listed in the Attachment. The following degraded equipment issues were reviewed:
o Unit 2 Condenser Leakage ACMP, Revision 3 (lR 1171316-10);
. Unit 3 Condensate and Reactor Chemistry Limits and Actions ACMP, Revision 1 (rR 1181380-06);
. 2'B' D003-1 Battery Charger Failure (lR 121 0275);
. Control Rod 38-03 Stuck (lR 1212944);o ' E-2 EDG voltage oscillations during scheduled load run (lR 1220717): and
. Receipt of NRC Task lnterface Agreement for Spent Fuel Pool (SFP) Boraflex Degradation (lR 1225431 ).
b. Findinos No findings were identified.
1R18 Plant Modifications (71111.18 - 1 Sample)
Temporarv Modification a. lnspection Scope The inspectors reviewed the following temporary modification to ensure that it did not adversely affect the availability, reliability, or functional capability of any risk significant SSCs, and to verify that modification implementation did not place the plant in an unsafe condition. The inspectors reviewed the applicable engineering change request (ECR),supporting documentation, and discussed the modification with engineering and maintenance, and operations personnel. The control of the modifications was compared to the regulatory requirements, regulatory guidance documents for on-line leak repairs, industry standards, and PBAPS procedural requirements. The inspectors also verified that the leak repair plan was consistent with the modification documentation and that the drawings, and that the post-installation testing was adequate. Documents reviewed during the inspection are listed in the Attachment.
o TCCP ECR 09-00484, "Low Steam Flow lsolation Setpoint Lowered to Provide Additional Operation Margin Due to Unit 2 Recombiner Steam Flow Slowly Decreasing," Revision 1.
b. Findinss No findings were identified.
1R19 Post-Maintenance Testino (71111.19 - 6 Samples)
a. Inspection Scope
The inspectors reviewed completed test records or observed selected post-maintenance testing (PMT) activities. The inspectors verified whether the tests were performed in accordance with the approved procedures or instructions and assessed'the adequacy of the test methodology based on the scope of maintenance work performed. In addition, the inspectors assessed the test acceptance criteria to evaluate whether the test demonstrated that components satisfied the applicable design and licensing bases and the TS requirements. The inspectors reviewed the recorded test data to verify that the acceptance criteria were satisfied. Documents reviewed during the inspection are listed in the Attachment. The inspectors reviewed six PMTs performed in conjunction with the following maintenance activities:
o Structural and electrical inspections following pumping water out of MH 64 after it was found to have an unacceptable water level (wo R1174133-39);o E-1 EDG lubricating oiltemperature switch replacement WO C0237857);c 2'A'turbine building closed cooling water pump coupling preventative maintenance and pump bearing oil change (R1 132701);o 2'B' D0O3-1 battery charger post-maintenance test following troubleshooting and maintenance WO C02381 32);o 2'A' CS loop pump, valve, flow, and cooler functional and inservice test following planned maintenance (Clearance 1 1000926); and e Post-maintenance test following the repair of a leak on the Unit 3 HPCI steam supply pressure sensing line (WO C0238736).
b. Findinqs No findings were identified.
1R22 Surveillance Testinq (71111.22 - 5 Samples)
a. Inspection Scope
(3 Routine Surveillances; 1 Reactor Coolant System (RCS) Leak Detection; and 1 Inservice Testing (lST) Sample)
The inspectors reviewed or observed selected portions of the following surveillance tests (STs), and compared test data with established acceptance criteria to verify the systems demonstrated the capability of performing the intended safety functions. The inspectors also verified that the systems and components maintained operational readiness, met applicable TS requirements, and were capable of performing design basis functions.
Documents reviewed during the inspection are listed in the Attachment. The five STs reviewed or observed included:
r RT-O-100-505-2, Emergency Operating Procedure Tool Inventory, Revision 30;
.
RT-O-28B-800-2, Revision 16, River Temperature and Flow Monitoring and Test;
.
5T-0-020-560-213, Units 2 & 3 - Reactor Coolant Leakage (RCL) Test [1 RCS Leakage samplel;
.
ST-O-032-301-3, HPSW Pump, Valve and Flow Functional and Inservice Test
[1 IST sample]; and o ST-O-052-313-2, E-3 Diesel Generator Slow Start Full Load and IST Test [STl.
b. Findinqs No findings of significance were identified.
Cornerstone: Emergency Preparedness (EP)
lEPO Drill Evaluation (71114.06 - 1 Sample) Drill Observation (1 Drill/EV Sample)
a. Inspection Scope
On June 21, the inspectors observed licensee performance during the hostile action based (HAB) site emergency preparedness exercise in the security central alarm station (CAS), in the alternate technical support center (ATSC), and at the incident command post (lCP). Additionally, an operations crew was located in the simulated control room to simulate the response actions that would be taken in the MCR during an actual HAB event. The inspectors noted that prior to the HAB exercise, the licensee determined that the exercise would not be counted against the Drill and Exercise Performance Indicator (pl). The inspectors observed security response actions in the CAS. The inspectors also observed CAS coordination with the simulated MCR, up to and including the declaration of a Site Area Emergency (HS1: Hostile Action within the Protected Area),followed later by the declaration of a General Emergency (HG1: Hostile Action resulting in the loss of physical control of the facility). After the emergency response organization (ERO) was called out in response to the simulated event, the inspectors observed pBAfS personnel activate and man the ATSC to communicate with and provide technical support to the shift manager in the simulator control room. The inspectors also observed PBAPS personnel coordinate response actions with local law enforcement agency personnel in the lCP. The inspectors also observed portions of the post-exerciseidrill critique to verify that issues observed by the inspectors were also identified by the licensee's evaluators. The inspectors verified that the licensee entered the issues identified during the critiques into the CAP. This inspection activity constituted one drill sample for Inspection Procedure (lP) 71114.06.
b.
Findinqs No findings were identified.
2. RADIATION SAFEW
Cornerstone: Occupational Radiation Safety (OS)
2RS0 1 Access Control to Radioloqicallv Siqnificant Areas
a. Inspection Scope
The inspectors reviewed selected activities, and associated documentation, in the below listed areas. The evaluation of PBAPS's performance was against criteria contained in 10 CFR Part 20, applicable TSs, and applicable station procedures.
Inspection Planninq The inspectors reviewed Pls for the Occupational Exposure cornerstone.
Radioloqical Hazard Assessment The inspectors conducted walk-downs of the facility, including the dry-active waste collection location including associated yard area, to evaluate material and radiological conditions. The inspectors made independent radiation measurements to verify conditions.
Contamination and Radioactive Material Control The inspectors selectively observed locations where the licensee monitors potentially contaminated material leaving the radiological controlled area, and inspected the methods used for control, survey, and release from these areas. The inspectors selectively evaluated the radiation monitoring instrumentation sensitivity, based on 10 CFR Part 61 waste stream analyses, for the type(s) of radiation present.
Radioloqical Hazards Control and Work Coveraqe The inspectors toured the facility and evaluated ambient radiological conditions (e.9., radiation levels or potential radiation levels).
The inspectors conducted selective inspection of posting and physical controls for high radiation areas, to the extent necessary to verify conformance with the Occupational Pl.
Problem ldentification and Resolution The inspectors selectively verified that problems associated occupational exposure and access control were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensee CAP. (See Section 4OA2)b.
Findinqs No findings were identified.
Cornerstone: Occupationaland Public Radiation Safety (OS and PS)
2RS05 Radiation Monitorinq lnstrumentation (7 1 124.05)
a. Inspection Scope
Inspection Planninq The inspectors selectively reviewed the plant UFSAR to identify radiation instruments associated with monitoring radiological conditions (process streams and effluents).
The inspectors obtained copies of licensee and third-party (independent) evaluation reports of the radiation monitoring program since the last inspection, including audits of the licensee's offsite calibration facility (if applicable). The inspectors reviewed the reports for insights into the licensee's program and to aid in selecting areas for review.
Walk-downs and Observations The inspectors walked down the stack effluent radiation monitoring systems. The inspectors focused on any flow measurement devices. The inspectors selectively verified that effluenVprocess monitor configurations align with the offsite dose calculation manual (ODCM) descriptions. The inspectors looked for monitor degradation and out-of-service tags including apparent by-pass of sampling systems. The inspectors observed sample media as it was collected.
Calibration and Testinq Proqram Process and Effluent Monitors The inspectors selectively reviewed calibration, function testing, and checking of the liquid effluent, Unit 2 and 3 service water, and Unit 2 and 3 plant vent and main stack monitors to verify that channel calibration, functionaltests, and source checks were performed consistent with radiological effluent TSs (Radiological Effluent Technical Specification (RETS)/ODCM. )
PI&R The inspectors selectively reviewed problems associated with radiation monitoring instrumentation to determine if problems were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensee's CAP.
(See Section 40,42)
Findinqs No findings were identified.
Gornerstone: Public Radiation Safety (PS)
2RS0 6 Radioactive Gaseous and Liouid Effluent Treatment
a. Inspection Scope
Inspection Planninq and Prooram Reviews The inspectors performed in-office preparation before the inspection associated with review of effluent and environmental reports (2009, 2010) and the UFSAR, as well as the ODCM.
Event Report and Effluent Report Reviews The inspectors selectively reviewed the latest Annual Radiological Effluent Release Report (2010) issued since the last inspection to determine if the report was submitted as required by the ODCM/TSs. The review was conducted to note any anomalous results, unexpected trends or abnormal releases identified by the licensee for further inspection to determine if they were evaluated, were entered in the CAP, and were adequately resolved.
The inspectors reviewed onsite radioactive effluent monitor operability issues reported by the licensee as provided in effluent release reports, as warranted, given their relative significance. The inspectors determined if the issues were entered into the CAP and adequately resolved.
ODCM and UFSAR Reviews The inspectors selectively reviewed changes to the ODCM (Revision 13) made by the licensee since the last inspection. The inspectors selectively reviewed changes against the guidance in NUREG-1302 and 0133, and Regulatory Guides (RGs) 1.109, 1'21, and 4.1. The inspectors reviewed the technical basis or evaluations of any changes during the onsite inspection, as applicable.
The inspectors determined if the licensee had identified, since the last inspection, any non-radioactive systems that have become contaminated as disclosed either through a corrective action document, an event report, or as documented in the ODCM since the last inspection. The inspectors reviewed any 10 CFR 50.59 evaluations, as applicable, that had been performed for systems that had been identified as contaminated since the last inspection. The inspectors determined, as applicable, if any newly contaminated systems had an.unmonitored effluent discharge path to the environment, whether any required ODCM revisions were made to incorporate these new pathways and whether the associated effluents were reported in accordance with RG 1'21.
Groundwater Protection Initiative (GPl) Prooram The inspectors selectively reviewed reported groundwater monitoring results since the previous inspection, and changes to the licensee's written program for identifying and controlling contaminated spills/leaks to groundwater. The inspectors also reviewed the licensee's groundwater monitoring report included with its 2010 Annual Radiological Environmental Operating Report.
The inspectors selectively reviewed and discussed monitoring results of the GPI to determine if the licensee had implemented its program as intended and to identify any anomalous or missed results and to determine if the licensee had identified and addressed deficiencies through its CAP.
Procedures, Special Reports, and Other Documents The inspectors selectively reviewed and discussed, as available, event reports and/or special reports related to the effluent program issued since the previous inspection to identify any additional focus areas.
The inspectors selectively reviewed effluent program implementing procedures, particularly those associated with effluent monitor calibration and functionaltesting.
The inspectors selectively reviewed, as available, copies of licensee and third party (independent) evaluation reports of the effluent monitoring program since the last inspection. The inspectors reviewed the reports for insights into the licensee's program and to aid in selecting areas for review. The inspectors reviewed licensee Check-ln assessments and Quality Assurance (QA) audits.
Walk-downs and Observations The inspectors selectively walked down and evaluated the material condition of the station stack sampling systems during observation of sample collection. The inspectors observed gaseous effluent sample collection and analysis for the station stack.
Samplinq and Analvses The inspectors discussed the licensee's effluent sampling activities and efforts to ensure collection of representative samples. The inspectors selected the stack monitor to verify that adequate controls were implemented to ensure representative samples were obtained (e.9., detection of filter by-pass).
The inspectors discussed effluent discharges made with inoperable (declared out-of-service) effluent radiation monitors, as applicable, to ensure controls were in-place to ensure compensatory sampling is performed consistent with the RETS/ODCM and that the controls were adequate to prevent the release of unmonitored liquid and gaseous effluents.
The inspectors evaluated monitor availability to determine whether the facility was routinely relying on the use of compensatory sampling in lieu of adequate system maintenance, based on the frequency of compensatory sampling since the last inspection.
Effluent Flow Measurino Instruments The inspectors selectively reviewed the methodology the licensee used to calibrate and determine the effluent stack and vent flow rates including calibration data.
Dose Calculations The inspectors selectively evaluated changes in reported dose values compared to the previous Radiological Effluent Release Report to evaluate the factors which may have resulted in the change.
The inspectors discussed changes in the ODCM dose calculations, since the last inspection, to verify any changes were consistent with the ODCM and RG 1.109. The inspectors selectively reviewed meteorological dispersion and deposition factors used in the ODCM and effluent dose calculations to ensure appropriate factors are being used for public dose calculations based on meteorological studies.
The inspectors selectively reviewed the latest Land Use Census (2010) to verify that changes (e.9., significant increases or decreases to population in the plant environs, changes in critical exposure pathways, the location of nearest member of the public or critical receptor, etc.) had been factored into the dose calculations.
The inspectors selectively evaluated public dose projections to verify that the calculated doses (monthly, quarterly, and annualdose) were within 10 CFR Part 50, Appendix l, and TS dose criteria.
The inspectors discussed abnormal liquid or gaseous discharges. The inspectors evaluated monitoring of plant effluents at discharge points.
GPI lmplementation The inspectors verified that the licensee was continuing to implement the voluntary Nuclear Energy Institute (NEl)/lndustry GPl.
The inspectors selectively reviewed identified leakage or spill events and entries made into 10 CFR 50.75
- (g) records, since the last inspection, to review any remediation action taken for effectiveness.
The inspectors evaluated whether sufficient radiological surveys were performed to evaluate the extent of the contamination and the radiological source term.
PI&R The inspectors verified that problems associated with the effluent monitoring and control program were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensee CAP. (See Section 4OP'2)2RS07 Radiolosical Environmental Monitorinq Proqram (REMP) (7 1 124.07)
a. Inspection Scope
Inspection Planninq The inspectors selectively reviewed the Annual Radiological Environmental and Effluent Operating Reports (2009 and 2010) and the results of licensee assessments since the last inspection, to verify that the REMP was implemented in accordance with the TS and ODCM. The inspectors reviewed the report for changes to the ODCM with respect to environmental monitoring, commitments in terms of sampling locations, monitoring and measurement frequencies, Land Use Census, inter-laboratory comparison program, program exceptions, and analysis of data.
The inspectors selectively reviewed the ODCM to identify locations of environmental monitoring stations.
The inspectors selectively reviewed the UFSAR for information regarding the environmental monitoring program and meteorological monitoring instrumentation.
The inspectors selectively reviewed available QA audit results of the program. The inspectors selectively reviewed any audits and technical evaluations performed on the licensee's vendor's program, as applicable, if used to analyze REMP samples.
Site lnspection The inspectors verified that the licensee had initiated, as appropriate, sampling of other appropriate media upon loss of a required sampling station Based on direct observation and review of records, the inspectors selectively verified that the meteorological instruments were operable, calibrated, and maintained in accordance with guidance contained in the UFSAR, NRC RG 1.23, "Meteorological Monitoring Progiams for Nuclear Power Plants," and licensee procedures. The inspectors verified tnaithe meteorological data readout and recording instruments in the control room and at the tower were operable. The inspectors toured the meteorological tower.
The inspectors verified that missed and or anomalous environmental samples were identified and reported in the annual environmental monitoring report. As available, the inspectors selected events that involved a missed sample, inoperable sampler, lost thermoluminescence dosimeter, or anomalous measurement, and verified that the licensee had identified the cause and had implemented corrective actions. The inspectors reviewed the licensee's assessment of any positive sample results (i.e.,
licensed radioactive material detected above the lower limits of detection (LLDs). The inspectors reviewed, as appropriate, the associated radioactive effluent release data that was the source of the released material, as applicable.
The inspectors setected and discussed SSCs that involve or could reasonably involve licensed material for which there is a credible mechanism for licensed material to reach groundwater, and verified that the licensee had implemented a sampling and monitoring program (new well installations) sufficient to detect leakage of these SSCs to groundwater. The inspectors discussed new monitoring well locations to support groundwater monitoring efforts.
The inspectors verified that records, as required by 10 CFR 50.75(9), of leaks, spills, and remediation since the previous inspection were retained in a retrievable manner.
The inspectors selectively reviewed any significant changes made by the licensee to the ODCM as the result of changes to the land census, long-term meteorological conditions (e.9., 3-year average), or modifications to the sampler stations since the last inspection.
The inspectors reviewed technicaljustifications for any changed sampling locations.
The inspectors evaluated detection sensitivities with respect to the TS/ODCM used for counting samples (i.e., the samples meet the TS/ODCM required LLDs).
ldentification and Resolution of Problems The inspectors determined if problems associated with the REMP were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the CAP. In addition to the above, the inspectors verified the appropriateness of the corrective actions for a selected sample of problems documented by the licensee that involve the REMP. (See Section 4OA2)
Findinqs No findings were identified.
2RS08 Radioactive Solid Waste Processinq and Radioactive Material. Handlinq Storaoe, and Transportation (7 1 1 24.08)
Inspection Scope Inspection Plannino The inspectors discussed the inspection schedule with the licensee to coordinate observation of risk-significant activities.
The inspectors selectively reviewed the solid radioactive waste system description in the Final Safety Analysis Report (FSAR), the Process Control Program (PCP), and the recent radiological etfluent release reports for information on the types, amounts, and processing of radioactive waste disposed.
The inspectors selectively reviewed the scope of any QA audits in this area since the last inspection to gain insights into the licensee's performance and inform the "smart sampling" inspection planning.
Radioactive Material Storase The inspectors selectively reviewed areas where containers of radioactive waste were stored, to verify that the containers were labeled in accordance with 10 CFR 20J904, "Labeling Containers," or controlled in accordance with 10 CFR 20.1905, "Exemptions to Labeling Requirements," as appropriate.
The inspectors selectively toured the facility to verify that the radioactive materials storage areas were controlled and posted in accordance with the requirements of 10 CFR Part20, "Standards for Protection against Radiation."
The inspectors selectively reviewed the licensee process for monitoring the impact of long-term storage (e.9., buildup of any gases produced by waste decomposition, chemical reactions, container deformation, loss of container integrity, or re-release of free-flowing water) to identify potential unmonitored, unplanned releases or nonconformance with waste disposal requirements.
Radioactive Waste Svstem Walk-down The inspectors selected accessible liquid and solid radioactive waste processing systems and walked down accessible portions of systems to verify and assess that the current system configuration and operation agree with the descriptions in the FSAR, ODCM, and PCP. The inspectors also selectively reviewed various photographs, live camera views, and radiological surveys to access material conditions of rooms and tanks.
The inspectors discussed radioactive waste processing equipment that was not operational to determine if it was abandoned in place, and discussed if the licensee had established administrative and/or physical controls (i.e., drainage and isolation of the system from other systems) to ensure that the equipment would not contribute to an unmonitored release path and/or affect operating systems or be a source of unnecessary personnel exposure. The inspectors discussed if the licensee had reviewed the safety significance of systems and equipment abandoned in place in accordance with 10 CFR 50.59, "Changes, Tests, and Experiments."
The inspectors selectively reviewed the adequacy of any changes made to the radioactive waste processing systems since the last inspection to verify that changes from what is described in the FSAR were reviewed and documented in accordance with 10 CFR 50.59, as appropriate. The inspectors selectively reviewed and discussed the impact, if any, on radiation doses to workers or members of the public.
The inspectors selected the processes for transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers. The inspectors visually inspected the resin sampling system. The inspectors verified (for the selected processes) that the waste stream mixing, sampling procedures, and methodology for waste concentration averaging were consistent with the PCP, and provide representative samples of the waste product for the purposes of waste classification as described in 10 CFR 61
.55 ,
"Waste Classification. "
The inspectors discussed and evaluated, for those systems that provide tank recirculation, that the tank recirculation procedure and means used, provided sufficient mixing.
The inspectors reviewed the licensee's PCP to determine if it correctly describes the current methods and procedures for dewatering and waste stabilization (e.9., removal of freestanding liquid).
Waste Characterization and Classification The inspectors selected radioactive waste streams (e.9., dry active waste, ion exchange resins, mechanical filters, sludges, and activated materials), to verify that the licensee's radiochemical sample analysis results were sufficient to support radioactive waste characterization as required by 10 CFR Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste." The inspectors selectively verified that the licensee's use of scaling factors and calculations to account for difficult-to-measure radionuclides was technically sound and based on current 10 CFR Part 61 analyses.
The inspectors selectively verified that, for plant waste streams, changes to plant operational parameters were taken into account to
- (1) maintain the validity of the waste stream composition data between the annual or biennial sample analysis update, and
- (2) verity that waste shipments continue to meet the requirements of 10 CFR Part 61 .
The inspectors reviewed the licensee's QA program to determine if the licensee had established and maintained an adequate QA program to ensure compliance with the waste classification and characterization requirements of 10 CFR 61
.55 and
10 CFR 61.56, "Waste Characteristics."
Shippino Records The inspectors selectively reviewed three non-excepted radioactive material package shipments (PM-10-009, PW-09-017 , and PW-10-009). The inspectors verified that the shipping documents indicate the proper shipper name; emergency response information and a 24-hour contact telephone number; accurate curie content and volume of material; and appropriate waste classification, transport index, and UN number, as applicable.
The inspectors discussed the shipment placarding, as applicable, to determine if it was consistent with the information in the shipping documentation. The inspectors selectively confirmed, by hand calculation, radionuclide content of packages based on current 10 CFR Part 61 analyses.
ldentification and Resolution of Problems The inspectors determined if problems associated with radioactive waste processing, handling, storage, and transportation, were being identified by the licensee at an appropriate threshold, are properly characterized, and are properly addressed for resolution in the licensee's CAP. ln addition, the inspectors verified the appropriateness of the corrective actions for a selected sample of problems documented by the licensee that involve radioactive waste processing, handling, storage, and transportation.
The inspectors reviewed the results of selected audits, performed since the last inspection of this program, to evaluate the adequacy of the licensee's corrective actions for issues identified during those audits.
b. Findinqs No findings were identified.
4. OTHER ACTIVTTTES (OA)
4OA1 Performance Indicator Verification (71151- 4 Samples)
Barrier Integrity Barrier Inteqritv Pls Inspection Scope The inspectors reviewed a sample of PBAPS's submittals for the four Barrier Integrity Pls listed below to verify the accuracy of the data reported. The Pl definitions and the guidance contained in NEI 99-02, "Regulatory Assessment Indicator Guideline,"
Revision 6, and Exelon procedure LS-AA-2001, "Collecting and Reporting of NRC Pl Data," were used to verify that the reporting requirements were met. The inspectors reviewed Pl data collected from January 2Q10 to April 2011. The inspectors compared the graphical representations from the most recent Pl report available from the NRC public website to the raw Pl data to verify the data was properly included in the report.
The Pls reviewed were:
.
Unit 2 and Unit 3 RCS specific activity (8101); and
.
Unit 2 and Unit 3 RCS leakage (8102).
Findinqs No findings were identified.
4c.42 ldentification and Resolution of Problems (Pl&R) (71152 - 2 Samples)
.1 Review of ltems Entered into the CAP
Inspection Scope As required by lP 71 152, "ldentification and Resolution of Problems," and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed screening of all items entered into the licensee's CAP. This was accomplished by reviewing the description of each new action request (ARylR and attending daily management review committee meetings.
b. Findinqs No findings were identified.
.2 Semi-Annual Review to ldentifv Trends (1 Semi-Annual Trend Sample)
Inspection Scope The inspectors reviewed lists of CAP items to identify trends (either NRC or licensee identified) that might indicate the existence of a safety issue. First, the inspectors reviewed a list of approximately 7,200lRs that PBAPS initiated and entered into the CAP action tracking system (Passport) from December 1, 2010, through June 1 ,2011.
The inspectors also reviewed approximately 2,250 open lRs in the CAP that remained open with outstanding actions. The list was reviewed and screened to complete the required semi-annual Pl&R trend review. Based on the review, a sample of Passport lRs (listed in Attachment 1) were selected for a more detailed review to verify whether the issues were adequately identified and evaluated, and that corrective actions were planned. The inspectors evaluated the lRs against the requirements of Exelon procedure, LS-M-125, and 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action."
Findinqs and Observations.
No findings were identified. During this trend review period, the inspectors noted a significant event involving the Unit 2 HPCI discharge piping being continuously drained through a leaking relief valve (lR 1 188457). An apparent cause evaluation (ACE) was performed for this event. Additional discussion of this event is documented in this report, Sections 4OA3 and 4OA7. The inspectors concluded that the performance of this ACE ,/
was appropriate. Several configuration control issues (lRs 1162006, 1222585,12Q0382, 1173391 and 1173150) were identified during this trend assessment period. PBAPS appropriately initiated a common cause analysis (CCA) to assess an adverse trend in the number of configuration control events during 2010 and 2011 (lR 1203953).
The inspectors observed that PBAPS took appropriate action to perform CCA's of four additional human performance related trends. The first involved an adverse trend in industrial safety performance (lR 1203002). The second involved human performance contributions to rework issues (lR 1170201). The third involved an increase in the number of missed drill and exercise Pl calls by operating crews (lR 1 191 109). The fourth was related to inadequacies of corrective actions to address radiochemistry deficiencies (lR 1 212810).
The inspectors noted additional adverse trends related to the following subject areas: 46 fatigue assessments for work hour waivers with most being for security officers; continued instances of ESW system corrosion and reduced wall thickness (lR 1232678, lR 1233403), 92 issues related to water intrusion into MHs containing underground cables, 43 issues related MH level transmitter deficiencies, and issues related to assuring operability of Units 2 and 3 SFPs (lR 1225431, lR 1225840). However, based on the overall review of the selected sample, the inspectors concluded that PBAPS was:
appropriately identifying and entering issues into the CAP, adequately evaluating the identified issues, and acceptably identifying adverse trends before they became more safety significant problems.
.3 Review of Operator Work Arounds (OWAs) (1 OWA Sample)
Inspection Scope As required by lP 71152, "ldentification and Resolution of Problems," the inspectors conducted a review of the OWA program to verify that PBAPS was identifying OWA problems at an appropriate threshold, have entered them in the CAP, and proposed or implemented appropriate corrective actions. The inspectors reviewed the list of OWAs and operator challenges (OCs) identified and managed in accordance with Exelon Procedure, OP-AA-102-103, "OWA Program." Specifically, the review was conducted to determine if any OWAs for mitigating systems affected the mitigating system's safety functions or affected the operators' ability to implement abnormal and emergency operating procedures. The inspectors reviewed the following open OWAs being tracked by PBAPS:
.
Unit 2 main steam control valve to recombiner isolated requiring manual control of recombiner steam flow (AR A1778819).
The inspectors also reviewed the lists of open OCs (deficiencies that are obstacles to normal plant operations), periodically walked down the panels in the MCR, and have reviewed control room deficiencies to identify and be cognizant of
.
Require operations contrary to past training or require more detailed knowledge than routinely provided;
.
Require a change from longstanding operational practices;
.
Require operation of a system or component in a manner different from similar systems or components;
.
Create the potential for the compensatory action to be performed on equipment or under conditions for which it is not appropriate;
.
lmpair access to required indications, increase dependence on oral communications, or require actions under adverse environmental conditions; and
.
Require the use of equipment and interfaces that have not been designed with consideration of the task being performed.
The inspectors interviewed operators to determine if any compensatory actions they routinely take are (or should be) categorized as workarounds/challenges. Finally, the inspectors reviewed current operator turnover documentation to determine if there are documented compensatory actions that should be categorized as workarounds or challenges.
b. Findinqs No findings were identified.
The inspectors determined that Peach Bottom's OWA program was appropriately managing risk and correcting control room deficiencies, operator challenges, and operator workarounds.
.4 Occupational Radiation Safety Prooram (71124.01,71124.05,71124.06,71124.07,
a. Inspection Scope
The inspectors selectively reviewed corrective action documents for the occupational radiation safety program and effluent and environmental monitoring program. See documents reviewed.
The review was against criteria contained in 10 CFR Parl20, TSs, ODCM, and applicable station audit and surveillance procedures.
b. Findinqs No findings were identified.
40A3 Follow-up of Events and Notices of Enforcement Discretion (71153 - 1 Sample)
(Closed) Licensee Event Report (LER) 05000277/2011001-00, HPCI System Inoperable Due to Leaking Cooling Water Header Relief Valve On March 16,2011, PBAPS personnel declared the Unit 2 HPCI system inoperable as a result of the discovery of voiding in a portion of the Unit 2 HPCI pump discharge piping while the HPCI system suction was aligned to the suppression pool. PBAPS personnel determined that the leak was from the Unit 2 HPCI cooling water header relief valve (RV-2-23B-066). When HPCI was aligned to the suppression pool as the suction source, this leakage was sufficient to create voids in the HPCI discharge piping. The relief valve was replaced and HPCI was declared operable on March 18,2011. Since it is possible that a void induced water hammer could have caused damage to the Unit 2 HPCI system discharge piping during a design basis event, the licensee concluded that a deterministic loss of system safety function occurred. This event also resulted in a condition prohibited by TSs due to Unit 2 HPCI being inoperable for a time period greater than allowed by TS. The enforcement aspects of this LER review are documented in Section 4OA7. The inspectors reviewed this LER and did not identify any additionalviolations. This LER is closed.
4045 Other Activities
.1 Nuclear Station Fuel Damaoe Event"
a. lnsoection Scooe The inspectors assessed the activities and actions taken by the licensee to assess its readiness to respond to an event similar to the Fukushima Daiichi nuclear plant fuel damage event. This included
- (1) an assessment of the licensee's capability to mitigate conditions that may result from beyond design basis events, with a particular emphasis on strategies related to the SFP, as required by NRC Security Order Section 8.5.b issued February 25,2002, as committed to in severe accident management guidelines, and as required by 10 CFR 50.54(hh);
- (2) an assessment of the licensee's capability to mitigate station blackout conditions, as required by 10 CFR 50.63 and station design bases;
- (3) an assessment of the licensee's capability to mitigate internal and external flooding events, as required by station design bases; and
- (4) an assessment of the thoroughness of the walkdowns and inspections of important equipment needed to mitigate fire and flood events, which were performed by the licensee to identify any potential loss of function of this equipment during seismic events possible for the site.
I nspection Report (l R) 05000 277 12011 009, 0500027 81201 1 009 (ML111300540)documented detailed results of this inspection activity.
b. Findinqs No findings were identified.
(Closed) NRC Tl 2515/184. "Availabilitv and Readiness lnspection of Severe Accident Manaqement Guidelines (SAMGS)"
Inspection Scope On May 12,2011, the inspectors completed a review of the licensee's SAMGS, implemented as a voluntary industry initiative in the 1990's, to determine
- (1) whether the SAMGs were available and updated,
- (2) whether the licensee had procedures and processes in place to control and update its SAMGs,
- (3) the nature and extent of the licensee's training of personnel on the use of SAMGS, and
- (4) licensee personnel's familiarity with SAMG implementation.
The results of this review were provided to the NRC task force chartered by the Executive Director for Operations to conduct a near-term evaluation of the need for agency actions following the Fukushima Daiichifuel damage event in Japan. Plant-specific results for PBAPS were provided in an Attachment to a memorandum to the Chief, Reactor Inspection Branch, Division of lnspection and Regional Support, dated May 27,201 1 (ML111470361).
Findinos No findings were identified.
.3 (Closed) NRC Tl 2515/179. "National Source Trackinq Svstem (NSTS)"
Inspection Scope During the period April 5-8, 2011, the inspectors conducted the following activities to confirm the inventories of materials possessed at Peach Bottom were appropriately reported and documented in the NSTS in accordance with 10 CFR 20.2207.
Inspection Planninq The inspectors retrieved and reviewed a copy of the licensee's submitted NSTS source inventory. The inspectors also reviewed reconciliation reports.
lnventorv Verification The inspectors performed a physical inventory of the sources listed on the licensee's inventory to identify each source listed on the inventory.
The inspectors verified the presence of the nationally tracked sources by conducting a radiation survey of the source shield, as possible, and discussions with personnel.
The inspectors examined the physical condition of the source containers, evaluated the effectiveness of the procedures for secure storage and handling, discussed maintenance of the device including source leak tests, and verified the posting and labeling of the source was appropriate.
The inspectors reviewed licensee records for the source and compared the records with the data from the NSTS source inventory. The inspectors evaluated the effectiveness of procedures for updating the inventory records.
Determine the Location of Unaccounted-for Nationallv Tracked Source(s)
The inspectors reviewed the licensee's source inventory and verified Peach Bottom has no unaccounted-for source(s).
Review of Other Administrative Information The inspectors reviewed the administrative information contained in the NSTS inventory printout with licensee personnel to determine if all administrative information (e.9.,
mailing address, docket number, and license number) were correct. The inspectors discussed updates to the information.
b. Findinss No findings were identified.
.4 Unit 3 ISFSI Loadinq Campaion and Troubleshootinq (lP 60855.1)
a. Inspection Scope
From May 23 - 27, two NRC region-based Decommissioning Branch inspectors conducted a review of activities associated with the loading of spent fuel from Unit 3 into a dry storage cask and placement of the cask at the Independent Spent Fuel Storage InstallationltsfSt). The inspectors utilized lP 60855.1 and documented the results of the inspection in a separate inspection report issued July 29, 2011 (NRC Region I ISFSI lnspection Report Nos. 050002771201A010 and 0500027812010010 (ML112101576)).
b. Findinqs No findings were identified.
40A6 Meetinos, Includino Exit
.1 Quarterlv Resident Exit Meetino Summary
On July 29,2011, the resident inspectors presented the inspection results to Mr. Garey Stathes, Peach Bottom Plant Manager, and other PBAPS staff, who acknowledged the findings. The inspectors asked the licensee whether any of the information discussed as being included in the report should be considered proprietary.
No proprietary information was identified.
.2 Manaqement Meetinqs
The inspectors presented the inspection findings for the radwaste processing and transportation inspection on April 8, 2011, and the radiological environmental monitoring and effluent programs inspection on June 10,2011, to members of PBAPS's management. PBAPS personnel acknowledged the inspection findings. No proprietary information was identified.
4C.A7 Licensee-ldentified Violations The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy, for being dispositioned as a NCV:
r In Mode 1, with the HPCI system inoperable for more than 14 days, TS Limiting Condition for Operation 3.5,1 requires the unit to be in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Contrary to the above, the Unit 2 HPCI system was determined to be inoperable from approximately January 20 to March 18, 201 1 , with the reactor in Mode 1 , due to a leaking relief valve (RV-2-238-066) on the HPCI cooling water header. With HPCI aligned to the normal, non-safety-related, Condensate Storage Tank (CST) suction source, no voiding would occur in the HPCI discharge piping due to the higher elevation of the CST. However, during a subset of design basis events where HPCI suction would be transferred to the suppression pool, its alternate and safety-related suction source, and the HPCI pump secured, voiding could develop in the discharge piping. The licensee concluded that if HPCI was then restarted, a water hammer condition could potentially result and render Unit 2 HPCI unable to perform its deterministic design function. The voiding in the HPCI discharge piping had been discovered by PBAPS personnel during a ST while transferring Unit 2 HPCI suction from the CST to the suppression pool to support an l&C surveillance. The relief valve was replaced, and subsequent to testing, HPCI was declared operable on March 18, 2011.
The inspectors reviewed this condition using IMC 0609, Attachment 4, and in consultation with a Region I Senior Reactor Analyst (SRA), concluded the Unit 2 HPCI system would likely have been able to perform its Significance Determination Process safety function, given the numerous postulated equipment failures and specific system configurations that would have to occur to cause a system failure.
Therefore, and as such this issue screened to very low safety significance. A Region I SRA also confirmed the very low significance (mid E-9 increase in core damage frequency) with a conservative analysis. This analysis assumed the HPCI system would have failed if the operators failed to refill the CST, and HPCI switched over to the torus suction, for the 58 day exposure period. The licensee documented the event in their CAP as lRs 1 1 88457 and 1 188987. The LER associated with this event was documented in Section 4OA3.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Exelon Generation Companv Personnel
- T. Dougherty, Site Vice President
G, Stathes, Plant Manager
- J. Armstrong, Regulatory Assurance Manager
- T. Moore, Site Engineering Director
- P. Navin, Operations Director
- J. Kovalchick, Security Manager
- P. Cowan, Work Management Director
- R. Holmes, Radiation Protection Manager
- R. Reiner, Chemistry Manager
- S. Hesse, NOS Manager
NRC Personnel
- P. Krohn, Branch Chief
- F. Bower, Senior Resident lnspector
- N. Lafferty, Acting Resident Inspector
- A. Ziedonis, Resident Inspector
- C. Cahill, Senior Reactor Analyst
- S. Hammann, Senior Health Physicist
- D. Molteni, Senior Reactor Inspector
- R. Nimitz, Senior Health Physicist
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Opened/Closed
None
Closed
- 05000277t2011001-00 LER HPCI System Inoperable Due to Leaking Cooling Water Header Relief Valve (Section 4OA3)
2515t183 TI Follow-up to the Fukushima Daiichi Nuclear Station Fuel Damage Event (Section 4OA5.1)
2515t184 TI Availability and Readiness lnspection of Severe Accident Management Guidelines (Section 4C45.2)
2515t179 TI National Source Tracking System (NSTS (Section 4OA5.3)
Discussed
None