IR 05000277/2013003

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IR 05000277-13-003, 05000278-13-003; 04/01/2013 06/30/2013, Peach Bottom Atomic Power Station, Units 2 and 3, Integrated Inspection Report and Independent Spent Fuel Storage Installation Report 07200029-13-001
ML13213A239
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 08/01/2013
From: Mel Gray
Reactor Projects Region 1 Branch 4
To: Pacilio M
Exelon Nuclear, Exelon Generation Co
GRAY, MEL
References
IR-13-001, IR-13-003
Download: ML13213A239 (30)


Text

UNITED STATES gust 1, 2013

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000277/2013003 AND 05000278/2013003 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION REPORT 07200029/2013001

Dear Mr. Pacilio:

On June 30, 2013, the U. S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The enclosed integrated inspection report documents the inspection results, which were discussed on July 19, 2013, with Pat Navin, Peach Bottom Plant Manager, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, no findings were identified.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRC's Agencywide Documents Access Management System (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.htmL (the Public Electronic Reading Room).

Sincerely,

/RA/

Mel Gray, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56

Enclosure:

Inspection Report 05000277/2013003 and 05000278/2013003

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000277/2013003 AND 05000278/2013003 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION REPORT 07200029/2013001

Dear Mr. Pacilio:

On June 30, 2013, the U. S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The enclosed integrated inspection report documents the inspection results, which were discussed on July 19, 2013, with Pat Navin, Peach Bottom Plant Manager, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, no findings were identified.

In a

REGION I==

Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56 Report No.: 05000277/2013003 and 05000278/2013003 Licensee: Exelon Generation Company, LLC Facility: Peach Bottom Atomic Power Station, Units 2 and 3 Location: Delta, Pennsylvania Dates: April 1, 2013 through June 30, 2013 Inspectors: S. Hansell, Senior Resident Inspector A. Ziedonis, Resident Inspector E. DiPaolo, Limerick Senior Resident Inspector T. Dunn, Operations Engineer J. Nicholson, Health Physicist J. Schoppy, Senior Reactor Inspector A. Turilin, Project Engineer J. Woodfield, Storage and Transportation Engineer Approved by: Mel Gray, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000277/2013003, 05000278/2013003; 04/01/2013 - 06/30/2013; Peach Bottom Atomic

Power Station (PBAPS), Units 2 and 3; Integrated Inspection Report.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity None.

Other Findings

None.

REPORT DETAILS

Summary of Plant Status

Unit 2 began the inspection period at 100 percent power. On May 17, 2013, operators reduced power to approximately 55 percent to perform planned activities that included control rod pattern adjustment, control rod testing, main turbine valve testing, main steam isolation valve (MSIV)testing, and reactor feed pump (RFP) maintenance and testing. The unit was returned to 100 percent rated thermal power (RTP) the next day. The unit remained at RTP through the end of the inspection period, except for brief periods to support planned testing and control rod pattern adjustments.

Unit 3 began the inspection period at 100 percent power. On April 27, 2013, operators reduced power to approximately 55 percent to perform planned activities that included control rod pattern adjustment, control rod testing, main turbine valve testing, and RFP maintenance and testing.

The unit was returned to 100 percent RTP the next day. The unit remained at RTP through the end of the inspection period, except for brief periods to support planned testing and control rod pattern adjustments.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Readiness for Seasonal Extreme Weather Conditions (1 sample)

a. Inspection Scope

The inspectors performed a review of PBAPSs readiness for the onset of seasonal high temperatures. The review focused on the emergency switchgear (SWGR), safety-related batteries, the emergency cooling tower (ECT), the emergency diesel generators (EDGs), emergency core cooling systems (ECCS), emergency service water (ESW),high-pressure service water (HPSW), and the associated ventilation systems and room coolers. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR),technical specifications (TSs), control room logs, and the corrective action program (CAP) to determine what temperatures or other seasonal weather could challenge these systems, and to ensure PBAPS personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including PBAPSs seasonal weather preparation procedure, and applicable operating procedures. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during hot weather conditions.

Documents reviewed for each section of this inspection report are listed in the

.

b. Findings

No findings were identified.

.2 Summer Readiness of Offsite and Alternate Alternating Current (AC) Power Systems

(1 sample)

a. Inspection Scope

The inspectors performed a review of plant features and procedures for the operation and continued availability of the offsite and alternate AC power systems to evaluate the readiness of the systems prior to seasonal high grid loading. The inspectors reviewed PBAPSs procedures related to these areas and the communication protocols between the transmission system operator and PBAPS. This review focused on changes to the established program and material condition of the offsite and alternate AC power equipment. The inspectors assessed whether PBAPS established and implemented appropriate procedures and protocols to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system. The inspectors evaluated the material condition of the associated equipment by interviewing the responsible system manager, reviewing condition reports (CRs) and open work orders (WOs), and walking down the 500 kilovolt (kV) main power transformers, the non-vital 13.2 kV SWGR, the number 2 start-up and emergency auxiliary transformer (230 to 13.8 kV), the emergency auxiliary transformers (13.2 to 4.16 kV), and the emergency 4 kV SWGR.

b. Findings

No findings were identified.

.3 Readiness for Impending Adverse Weather Conditions (1 sample)

a. Inspection Scope

The inspectors reviewed PBAPSs preparations for the onset of severe thunderstorms and high winds on June 13, 2013. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during this adverse weather condition. The inspectors reviewed TSs, control room logs, emergency action level entry conditions, and the CAP to determine the anticipated adverse weather impact, and to ensure PBAPS personnel had adequately prepared and responded to the challenges. The inspectors performed general plant walkdowns verified that the actions defined in PBAPSs adverse weather procedure maintained the readiness of essential systems. The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

B ESW with A ESW inoperable on April 17, 2013 E-1, E-2, and E-3 EDGs with E-4 out-of-service (OOS) the week of April 15, 2013 Unit 2 high pressure coolant injection (HPCI) system on May 23, 2013 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, TSs, WOs, CRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies.

The inspectors also reviewed whether PBAPS staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Resident Inspector Quarterly Walkdowns

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that PBAPS controlled combustible materials and ignition sources were controlled in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for OOS, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

E-3 and E-4 EDGs on May 21, 2013 Control structure fan room on June 12, 2013 Unit 3 HPCI pump room on June 20, 2013 Unit 3 A and C core spray (CS) pump rooms on June 20, 2013 Unit 3 reactor core isolation cooling (RCIC) pump room on June 20, 2013 Unit 3 reactor building (RB) 135 elevation on June 21, 2013

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed licensed operator simulator training on June 13, 2013, which included annual human performance evaluations using job performance measures (JPMs). The inspectors evaluated operator performance during the training scenario and verified the completion of operator actions, including the use of human performance tools, verification practices, and operator fundamentals, as outlined in station procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and changing plant conditions, and the oversight and direction provided by the control room supervisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

b. Findings

No findings were identified.

.2 Quarterly Review of Licensed Operator Performance in the Main Control Room

a. Inspection Scope

The inspectors observed RFP maintenance and testing, and the planned power ascension from approximately 75 percent reactor power following the planned Unit 2 summer readiness load drop on May 18, 2013. The inspectors observed maintenance and test performance to verify that procedure use, crew communications, and coordination of activities between work groups met established expectations and standards. Additionally, the inspectors observed reactivity manipulations to verify that they were performed in a safe and controlled manner, and included the appropriate level of peer verification and supervisory oversight.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structures, systems, and components (SSCs) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance WOs, and maintenance rule (MR) basis documents to ensure that PBAPS was identifying and properly evaluating performance problems within the scope of the MR. For each sample selected, the inspectors verified that the SSC was properly scoped into the MR in accordance with 10 CFR 50.65 and that the (a)(2) performance criteria established by the PBAPS staff were reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2) status. Additionally, the inspectors ensured that PBAPS staff was identifying and addressing common cause failures that occurred within and across MR system boundaries.

Unit 2 CS loop A full flow test valve, MO-2-14-026A, and motor operator valve (MOV) program valve maintenance effectiveness Diesel driven fire pump (DDFP)

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that PBAPS performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that PBAPS personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When PBAPS performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

E-4 EDG planned maintenance and associated elevated risk on April 16, 2013 Unit 2 RCIC planned maintenance and associated elevated plant risk on May 14, 2013 Severe weather and associated elevated risk on Units 2 and 3 on June 13, 2013

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed four operability determinations (ODs) for the following degraded or non-conforming conditions:

Unit 3 RCIC pump elevated vibration levels on May 1, 2013 Unit 2 and Unit 3 emergency SWGR and battery room ventilation on May 17, 2013 Unit 2 CS loop A full flow test MOV stem nut machining tolerance changes on June 3, 2013 Unit 3 HPCI steam supply valve MO-3-23-014 on June 24 and 26, 2013 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the ODs to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to PBAPSs evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by PBAPS. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

b. Findings

No findings were identified.

1R18 Plant Modifications

Temporary Modification

a. Inspection Scope

The inspectors reviewed the temporary modification listed below to determine whether the modification affected the safety functions of systems that are important to safety.

The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results, and conducted field walkdowns of the modifications to verify that the temporary modification did not degrade the design bases, licensing bases, and performance capability of the affected systems.

EDG fuel oil transfer system historical (1995) TS bases change and 50.59 evaluation to credit manual operator action in lieu of automatic action for EDG operability

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the post-maintenance tests (PMTs) for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents (DBDs), and that the procedure had been properly reviewed and approved.

The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.

Unit 2 and Unit 3 intake structure 480V motor control center E-224-P-A corrective maintenance on April 24, 2013 Unit 3 main steam line (MSL) detection emergent maintenance on May 15, 2013 E-1 EDG PMT following two-year overhaul on May 16, 2013 Emergency SWGR and battery room fan damper backup nitrogen supply corrective maintenance on May 28, 2013

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

(3 routine surveillances; 1 RCS sample; 1 IST sample)

The inspectors observed performance of surveillance tests (STs) and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TSs, the UFSAR, and PBAPS procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following STs:

ST-O-013-301-3, RCIC Pump, Valve, Flow and Unit Cooler Functional and In-service Test on April 24, 2013 ST-I-002-250-3, Core Flow Verification on May 13, 2013 ST-I-01G-105-2, Automatic Depressurization System Channel B Logic System Functional Test on May 22, 2013 ST-O-033-300-2, ESW, Valve, Unit Cooler, and ECT Fans Functional Inservice Test on May 29, 2013 ST-O-020-560-2, Reactor Coolant Leakage Test on June 11, 2013

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 EP Drill Evaluation

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine PBAPS emergency drill on April 3, 2013, to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator and technical support center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the station drill critique to compare inspector observations with those identified by PBAPS staff in order to evaluate PBAPSs critique and to verify whether the PBAPS staff was properly identifying weaknesses and entering them into the CAP.

b. Findings

No findings were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator Verification

.1 Reactor Coolant System (RCS) Specific Activity and RCS Leak Rate

a. Inspection Scope

The inspectors reviewed PBAPSs submittal for the RCS specific activity and RCS leak rate performance indicators (PIs) for both Unit 2 and Unit 3 for the period of January 1, 2012, through March 31, 2013. To determine the accuracy of the PI data reported during those periods, the inspectors used definitions and guidance contained in Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment PI Guideline, Revision 6. The inspectors also reviewed RCS sample analysis and control room logs of daily measurements of RCS leakage, and compared that information to the data reported by the PI. Additionally, the inspectors observed chemistry technician surveillance activities that determined the RCS identified leakage rate, and discussed the chemistry RCS sampling data and analysis.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure (IP) 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that PBAPS entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended condition report screening meetings.

b. Findings

No findings were identified.

.2 Semi-Annual Trend Review (1 Semi-annual Trend sample)

a. Inspection Scope

The inspectors performed a semi-annual review of site issues, as required by IP 71152, Problem Identification and Resolution, to identify trends that might indicate the existence of more significant safety issues. In this review, the inspectors included repetitive or closely-related issues that may have been documented by PBAPS outside of the CAP, such as trend reports, PIs, major equipment problem lists, system health reports, MR assessments, and maintenance or CAP backlogs. The inspectors also reviewed PBAPSs CAP database for the six month period covering December 1, 2012 through May 31, 2013, to assess CRs written in various subject areas (equipment problems, human performance issues, etc.), and individual issues identified during the NRCs daily CR review (Section 4OA2.1). The inspectors reviewed the PBAPSs trend report for the fourth quarter of 2012 and the first quarter of 2013, conducted under LS-AA-125-1005, Coding and Analysis Manual, to verify that PBAPS personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures.

b. Findings and Observations

No findings were identified.

The inspectors noted minor adverse trends identified by PBAPS in the areas of site-wide human performance, maintenance work package quality, and aging equipment reliability.

There were no adverse safety consequences as a result of these low level trend issues.

Based on the overall results of the semi-annual trend review, the inspectors determined that PBAPS was appropriately identifying and entering issues into the CAP, adequately evaluating the identified issues, and properly identifying adverse trends before they became more safety significant problems.

.3 Annual Sample: Review of the Operator Workaround Program

a. Inspection Scope

The inspectors reviewed the cumulative effects of the existing operator workarounds (OWAs), operator burdens, existing operator aids and disabled alarms, and open main control room deficiencies to identify any effect on operator actions included in emergency operating procedures, and any impact on possible initiating events or mitigating systems. The inspectors evaluated whether station personnel had identified, assessed, and reviewed OWAs as specified in PBAPS procedure OP-AA-102-103, Operator Work-Around Program.

The inspectors reviewed PBAPSs process to identify, prioritize and resolve main control room distractions to minimize operator burdens. The inspectors reviewed the system used to track these OWAs and recent PBAPS self assessments of the program. The inspectors also toured the control room and discussed the current OWAs with the operators to ensure the items were being addressed on a schedule consistent with their relative safety significance.

b. Findings and Observations

No findings were identified.

The inspectors determined that the issues reviewed did not adversely affect the capability of the operators to implement abnormal or emergency operating procedures.

The inspectors also verified that PBAPS entered OWAs and burdens into the CAP at an appropriate threshold and planned or implemented corrective actions commensurate with their safety significance.

4OA3 Follow-up of Events and Notices of Enforcement Discretion

(Closed) Cask Event Report (CER) 05000277/05000278/07200029 dated February 22, 2013: Submittal of Independent Spent Fuel Storage Installation (ISFSI) CER On January 24, 2013, PBAPS staff determined that in the June/July 2001 ISFSI loading campaign, a total of four Unit 3 fuel assemblies that were cooled for 9.8 years and had a decay heat value of 0.201 kW each, were loaded into four Transnuclear (TN) 68 storage casks. The Certificate of Compliance (CoC) 72-102, TS, Amendment 0, Section 2.1.1, Table 2.1.1-1, requires fuel assemblies to be cooled for 10 years before being loaded into casks.

PBAPS reported this event to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery on January 25, 2013, as a condition prohibited by TS, and followed up with a CER dated February 22, 2013, in accordance with TS 2.2.2 and 2.2.3. There were no actual safety consequences associated with this event. The four General Electric (GE) six 8x8 type fuel assemblies were each below the 0.312 kW assembly limit of TS 2.1.1.E.ii at the time they were loaded into the storage casks. The actual fuel decay heat values did not result in any thermal issues with the fuel or casks. PBAPS staff also entered the issue into the CAP as action request (AR) 1466359.

The inspectors determined that this performance deficiency was not more than minor because each spent fuel assembly had a calculated decay heat value of 0.201 kW at the time they were loaded into the storage casks, which is below the 0.312 kW per assembly limit in TN CoC 72-1027, TS 2.1.1, Amendment 0. The inspectors reviewed the PBAPS evaluation that determined the loading of the four fuel assemblies did not impact the shielding, confinement, and thermal design functions of the loaded TN-68 casks. The four assemblies that were loaded in June/July 2001 became compliant with the ten year cooling TS requirement on September 14, 2001. The NRC approved Amendment 1 to TN CoC 72-1027 in October 2007. Amendment 1 increased the TS average burn-up limit and decreased the TS minimum allowable cooling time for all fuel types except GE 7x7 assemblies. The revised minimum cooling time for the 8x8 assemblies was reduced to seven years in accordance with Amendment 1. In April 2013, PBAPS staff updated the four applicable TN-68 casks to the requirements of CoC 72-1027, Amendment 1, in accordance with 10 CFR 72 requirements. The inspectors reviewed the changes made in the fuel selection process with personnel from reactor engineering and determined that the improved process reduces the probability of a similar problem. PBAPS personnel also performed a review of all fuel assemblies currently stored in dry casks and did not identify any additional assemblies that did not meet the ten-year TS cooling time requirement for casks loaded to TS, Amendment 0 criteria.

In conclusion, the four spent fuel assemblies, at the time they were loaded, would meet the current TS requirements for fuel loaded under TS, Amendment 1, which Exelon now follows for cask loading. PBAPS submitted an exemption request to the NRC dated May 23, 2013, to document the four TN-68 casks that were loaded with one assembly that did not meet the minimum cooling time. This CER is closed.

4OA5 Other Activities

.1 Independent Spent Fuel Storage Installation (ISFSI) Cask Loading and Transport

(60855, 60855.1)

a. Inspection Scope

The inspectors verified by direct observation and independent evaluation that PBAPS staff performed cask loading activities in a safe manner and in compliance with the CoC, TS, regulations, and Exelon procedures. The inspectors conducted direct observations of various aspects of the loading and preparation of one spent fuel cask (No. 63) during the week of May 13, 2013. The inspectors toured the ISFSI and observed portions of PBAPSs cask maneuvers at the ISFSI pad during the 2013 cask re-spacing campaign.

The inspectors also reviewed PBAPS activities related to long-term operation and monitoring of the ISFSI. The inspectors visited the central alarm station (CAS) and observed the cask helium pressure monitoring alarms and indications.

The inspectors observed and evaluated PBAPSs loading of the third TN-68 cask associated with PBAPSs current ISFSI dry cask loading campaign for Unit 3, and reviewed documentation and records associated with the first two TN-68 loading activities. The inspectors observed TN-68 loading and processing operations including:

placement of the cask into the spent fuel pool (SFP), loading spent fuel into the cask, removal of the cask from the SFP, decontamination and surveying, cask draining, vacuum drying, helium backfilling, leak testing, and transport of the cask to the ISFSI pad. The inspectors also observed the lid bolt torqueing process via remote cameras on the cask platform. The inspectors were able to verify adherence to the bolt torqueing pattern and multiple staged passes. During performance of the activities, the inspectors evaluated PBAPSs familiarity with procedures, supervisory oversight, and communication and coordination between the personnel involved. The inspectors attended PBAPSs briefings to assess their ability to identify critical steps of the evolution, potential failure scenarios, and human performance tools to prevent errors.

The inspectors also reviewed the loading and monitoring procedures and evaluated PBAPSs procedure adherence. The inspectors attended pre-shift briefs and noted that the discussions included procedure adherence, three-way communications, and a review of the work activities.

The inspectors reviewed PBAPSs program associated with fuel characterization and selection for storage. The inspectors reviewed cask fuel selection packages to verify that PBAPS staff were loading fuel in accordance with the CoC and TS. In addition, the inspectors independently verified the cask loading for cask Nos. 61 and 63 via review of the digital recording. PBAPS staff did not plan to load any damaged fuel assemblies during this campaign.

The inspectors reviewed radiation protection (RP) procedures and radiation work permits (RWPs) associated with the ISFSI loading campaign. The inspectors also reviewed the as-low-as-is-reasonably-achievable (ALARA) goal for the loading of all three casks to determine the adequacy of Exelons radiological controls and to ensure that radiation worker doses were ALARA, and that project dose goals could be achieved. The inspectors reviewed radiological records from the current loading campaign to confirm that contamination levels measured on the TN-68 casks were within the limits specified by the TS and consistent with values specified in the UFSAR.

The inspectors toured the ISFSI pad to assess the material condition of the pad and the loaded TN-68 casks and verified that PBAPS staff appropriately performed surveillance tests in accordance with TS requirements. The inspectors also verified that transient combustibles were not being stored on the ISFSI pad or in the vicinity of the loaded casks. The environmental reports were reviewed to verify that areas around the ISFSI site boundary were within the limits specified in 10 CFR Part 20 and 10 CFR 72.104.

The inspectors reviewed PBAPSs 10 CFR 72.48 screenings, corrective action reports, and the associated follow-up actions that were generated since the last loading campaign at PBAPS to ensure that issues were entered into the CAP, prioritized, and evaluated commensurate with their safety significance.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Quarterly Resident

Exit Meeting Summary

On July 19, 2013, the resident inspectors presented the inspection results to Pat Navin, Plant Manager, and other PBAPS staff, who acknowledged the findings.

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

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Exelon Generation Company Personnel

M. Massaro, Site Vice President
P. Navin, Plant Manager
N. Alexakos, Emergency Preparedness Manager
J. Armstrong, Regulatory Assurance Manager
R. Bolding, Respiratory Physicist
J. Bowers, Training Director
B. Hennigan, Operations Training Manager
M. Herr, Operations Director
R. Holmes, Radiation Protection Manager
J. Kovalchick, Security Manager
T. Moore, Site Engineering Director
P. Rau, Work Management Director
R. Reiner, Chemistry Manager
R. Shortes, Radiological Engineering Manager
D. Striebig, Emergency Preparedness Coordinator

NRC Personnel

M. Gray, Branch Chief
S. Hansell, Senior Resident Inspector
A. Ziedonis, Resident Inspector
E. DiPaolo, Limerick Senior Resident Inspector
T. Dunn, Operations Engineer
J. Nicholson, Health Physicist
J. Schoppy, Senior Reactor Inspector
A. Turilin, Project Engineer
J. Woodfield, Storage and Transportation Engineer

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

None

Closed

200029/2013001 CER Submittal of Independent Spent Fuel Storage Installation (ISFSI) Cask Event Report (CER)

(Section 4OA3)

Opened

None Discussed/Updated None

LIST OF DOCUMENTS REVIEWED