ML082470454
| ML082470454 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/02/2008 |
| From: | Collins S Region 1 Administrator |
| To: | Pardee C AmerGen Energy Co, Exelon Generation Co |
| KROHN P, RI/DRP/PB4/610-337-5120 | |
| References | |
| Download: ML082470454 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE ROAD KING OF PRUSSIA, PA 19406-1415 September 2, 2008 Mr. Charles G. Pardee Chief Nuclear Officer (CNO) and Senior Vice President Exelon Generation Company, LLC Chief Nuclear Officer (CNO)
AmerGen Energy Company, LLC 200 Exelon Way Kennett Square, PA 19348
SUBJECT:
MID-CYCLE PERFORMANCE ASSESSMENT LETTER -
PEACH BOTTOM ATOMIC POWER STATION
Dear Mr. Pardee:
On August 7, 2008, the NRC staff completed its performance review of Peach Bottom Atomic Power Station (PBAPS). Our technical staff reviewed performance indicators (PIs) for the most recent quarter and inspection results for the period from July 1, 2007, through June 30, 2008. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.
With the exception of information already available in the public domain, this performance review and enclosed inspection plan do not include physical protection information. A separate letter designated and marked Official Use OnlySecurity Information will include the security cornerstone review and resultant inspection plan.
Overall, Peach Bottom Atomic Power Station Units 2 and 3 operated in a manner that preserved public health and safety and fully met all reactor and radiation safety cornerstone objectives.
For the six cornerstones within the reactor and radiation safety strategic performance areas, plant performance for the most recent quarter at Peach Bottom Units 2 and 3 was within the Licensee Response column of the NRCs Action Matrix, based on all inspection findings being classified as having very low safety significance (Green) and all PIs indicating performance at a level requiring no additional NRC oversight (Green). Therefore, for the reactor and radiation safety cornerstones, we plan to conduct reactor oversight process (ROP) baseline inspections at your facility. In addition to baseline inspections, we plan to conduct independent spent fuel storage facility inspections at Peach Bottom.
While plant performance for the most recent quarter is within the Licensee Response column of the Action Matrix for the reactor and radiation safety strategic performance areas, there was a security-related finding of low to moderate safety significance (White) assigned to the last quarter of 2007. Specifically, the security-related finding had a documented cross-cutting aspect in the area of safety conscious work environment (SCWE) because supervision did not encourage the free flow of information related to raising safety concerns; and security supervisors who had information regarding inattentive officers did not respond to employee safety concerns in an open, honest, and non-defensive manner (Inspection Manual Chapter 0305, S.1(a)).
C. Pardee 2 In evaluating the licensee scope of efforts and progress in addressing this SCWE cross-cutting aspect, significant Agency actions have been taken to address inattentiveness and SCWE issues including Augmented Inspection Teams (ML073090061 and ML073550590), a Confirmatory Action Letter (ML072920283), an ROP Deviation Memorandum (ML073320344),
an inspection of the transition from a contract to an in-house security force (ML080720030), an inspection of the corrective actions in response to the inattentive security officer events (ML081090311), an inspection of your activities directly related to safety conscious work environment (ML081490058), and an assessment of the status of other commitments documented in the Confirmatory Action Letter (ML081970338). These Agency actions provided the regulatory framework to monitor your progress in addressing SCWE issues at Peach Bottom.
The Confirmatory Action Letter discussed above was closed on August 28, 2008, (ML082410183) based on multiple NRC inspections that evaluated the scope, status of completion, and effectiveness of the committed actions; reasonable assurance that the Peach Bottom facility will continue to be operated safely; and adequate corrective actions to prevent reoccurrence of the underlying issues that led to the inattentive security officer events.
Regarding the ROP Deviation Memorandum issued on November 23, 2007, the NRC has independently verified satisfactory completion of Exelons corrective actions as described in the inattentive security officer root cause evaluation. Therefore, the Deviation Memorandum for the inattentive security officer events will be allowed to expire in December 2008.
The NRC determined, through independent inspection activities, that Exelons response to the SCWE issue identified in September 2007 has been appropriate. Specifically, inspectors verified that Exelon had completed a thorough root cause evaluation and implemented numerous corrective actions including multiple SCWE surveys, training activities, and self-assessments. As a result, the NRC has concluded that your scope of efforts and progress in response to the White finding and concerns in the area of safety conscious work environment, have been acceptable. Therefore, consistent with our ROP assessment process, the NRC has concluded that a substantive cross-cutting issue in the area of safety conscious work environment does not exist at this time. The NRC will continue to monitor Exelons progress in addressing SCWE issues through baseline inspections.
Notwithstanding the progress related to SCWE issues, the staff identified five green findings and one White finding (related to the inattentive security officer event) for the current 12-month assessment period with documented cross-cutting aspects in the area of human performance.
A cross-cutting theme regarding resources and complete, accurate and up-to-date design documentation, and procedures (H.2(c)) was associated with four of the green findings. In evaluating the scope of efforts and progress in addressing the cross-cutting theme, the staff determined that the licensee appropriately identified the cross-cutting theme; recognized the impacts of the cross-cutting theme in multiple departments; and has scheduled a range of corrective actions for which additional time is needed to evaluate effectiveness. Therefore, consistent with our ROP assessment process, the NRC has concluded that a substantive cross-cutting issue in the area of human performance does not exist at this time. The NRC will continue to monitor Exelons progress in addressing the human performance cross-cutting theme through baseline inspections.
In addition, a supplemental inspection (conducted in accordance with ROP procedure 95001) for the White security-related finding was completed on July 25, 2008, and the inspection report was issued on August 29, 2008 (ML082420606). The 95001 supplemental inspection team did not identify any findings of significance and confirmed that Exelons response to the
C. Pardee 3 inattentiveness issues identified in September 2007 has been appropriate. Therefore, the white finding will be closed and removed from consideration in the ROP assessment process following the 3rd quarter of 2008.
Notwithstanding closure of the ROP white finding, the NRC continues to review and evaluate violations associated with the inattentive security officer events. As noted in the February 12, 2008, letter (ML080440012), any traditional enforcement action related to the violations will be handled by separate correspondence.
The enclosed inspection plan details the inspections, except those related to physical protection, scheduled through December 31, 2009. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last nine months of the inspection plan are tentative and may be revised at the end-of-cycle review.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Paul Krohn at 610-337-5120 with any questions you may have regarding this letter or the inspection plan.
Sincerely,
/RA/
Samuel J. Collins Regional Administrator Docket Nos. 50-277, 50-278 License Nos. NPF-44, NPF-56
Enclosure:
Peach Bottom Inspection/ Activity Plan cc w/encl:
C. Crane, Executive Vice President, Exelon, Chief Operating Officer, Exelon Generation M. Pacilio, Chief Operating Officer, Exelon W. Maguire, Site Vice President, Peach Bottom R. DeGregorio, Senior Vice President, Mid-Atlantic R. Hovey, Senior Vice President, Nuclear Oversight G. Stathes, Acting Plant Manager, Peach Bottom J. Armstrong, Regulatory Assurance Manager, Peach Bottom J. Bardurski, Manager, Financial Control & Co-Owner Affairs B. Franssen, Acting Director, Operations P. Cowan, Director, Licensing D. Helker, Licensing
C. Pardee 4 K. Jury, Vice President, Licensing and Regulatory Affairs J. Bradley Fewell, Associate General Counsel, Exelon T. Wasong, Director, Training Correspondence Control Desk D. Allard, Director, Bureau of Radiation Protection, PA Department of Environmental Protection S. Gray, Power Plant and Environmental Review Division (MD)
S. Pattison, Secretary, MD Department of the Environment M. Griffen, Maryland Department of Environment A. Lauland, Director, Homeland Security Advisor Public Service Commission of Maryland, Engineering Division Board of Supervisors, Peach Bottom Township B. OConnor, Council Administrator of Harford County Council R. Ayers, Deputy Mgr, Harford County Div of Emergency Operations E. Crist, Harford County Div of Emergency Operations S. Ayers, Emergency Planner, Harford County Div of Emergency Operations R. Brooks, Cecil County Dept of Emergency Services Mr. & Mrs. Dennis Hiebert, Peach Bottom Alliance E. Epstein, TMI - Alert J. Johnsrud, National Energy Committee, Sierra Club Mr. & Mrs. Kip Adams R. Fletcher, Dir, MD Environmental Program Manager, Radiological Health Program J. Powers, Director, PA Office of Homeland Security R. French, Dir, PA Emergency Management Agency D. Lockbaum, Union of Concerned Scientists
Page 1 of 2 Peach Bottom 08/28/2008 17:24:50 Inspection / Activity Plan Report 22 08/01/2008 - 12/31/2009 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type 7111111B - LSRO REQUAL INSPECTION 4 2, 3 IP 7111111B Licensed Operator Requalification Program 08/03/2008 08/08/2008 Baseline Inspections 60855.1 - ISFSI SUPPORT 1 2, 3 IP 60855.1 Operation of an Independent Spent Fuel Storage Installation at Operating Plants 07/14/2008 08/01/2008 Other Routine 12/08EXM - U2&3 OPERATOR LICENSING INITIAL EXAMS 4 2 U01692 FY09 - PEACH BOTTOM UNIT 2 & 3 INITIAL OPERATOR EXAM 11/10/2008 11/14/2008 Not Applicable 2 U01692 FY09 - PEACH BOTTOM UNIT 2 & 3 INITIAL OPERATOR EXAM 12/08/2008 12/19/2008 Not Applicable 71121 - OCC RAD SAFETY 1 2, 3 IP 7112101 Access Control to Radiologically Significant Areas 08/18/2008 08/22/2008 Baseline Inspections 2, 3 IP 7112102 ALARA Planning and Controls 08/18/2008 08/22/2008 Baseline Inspections 2, 3 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 08/18/2008 08/22/2008 Baseline Inspections 7111108G - U2 INSERVICE INSPECTION 1 2 IP 7111108G Inservice Inspection Activities - BWR 09/22/2008 09/26/2008 Baseline Inspections 71121 - OCC RAD SAFETY 1 2, 3 IP 7112101 Access Control to Radiologically Significant Areas 09/22/2008 09/26/2008 Baseline Inspections 2, 3 IP 7112102 ALARA Planning and Controls 09/22/2008 09/26/2008 Baseline Inspections 2, 3 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 09/22/2008 09/26/2008 Baseline Inspections 71121 - OCC RAD SAFETY 1 2, 3 IP 60855.1 Operation of an Independent Spent Fuel Storage Installation at Operating Plants 11/10/2008 11/14/2008 Other Routine 2, 3 IP 7112101 Access Control to Radiologically Significant Areas 11/10/2008 11/14/2008 Baseline Inspections 2, 3 IP 7112102 ALARA Planning and Controls 11/10/2008 11/14/2008 Baseline Inspections 2, 3 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 11/10/2008 11/14/2008 Baseline Inspections 2, 3 IP 71151-OR01 Occupational Exposure Control Effectiveness 11/10/2008 11/14/2008 Baseline Inspections 2, 3 IP 71151-PR01 RETS/ODCM Radiological Effluent 11/10/2008 11/14/2008 Baseline Inspections TI 176 - TI 176 1 2, 3 IP 2515/176 Emergency Diesel Generator Tech Spec Surveillance Requirements Re: Endurance & Margin 12/15/2008 12/19/2008 Generic Safety Inspectio Testing 711111B - BIENNIAL REQUAL INSP WITH P/F RESULTS 3 2, 3 IP 7111111B Licensed Operator Requalification Program 03/02/2009 03/13/2009 Baseline Inspections TRI FIRE - TRIENNIAL FIRE PROTECTION INSPECTION 3 2, 3 IP 7111105T Fire Protection [Triennial] 03/16/2009 03/20/2009 Baseline Inspections 2, 3 IP 7111105T Fire Protection [Triennial] 03/30/2009 04/03/2009 Baseline Inspections ISFSI - ANNUAL SAMPLE - ISFSI INSPECTION 1 3 IP 60855 Operation Of An ISFSI 04/01/2009 06/30/2009 Other Routine 71121 - OCC RAD 1 2, 3 IP 7112101 Access Control to Radiologically Significant Areas 04/20/2009 04/24/2009 Baseline Inspections This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Page 2 of 2 Peach Bottom 08/28/2008 17:24:50 Inspection / Activity Plan Report 22 08/01/2008 - 12/31/2009 Unit No. of Staff Planned Dates Inspection Number Inspection Activity Title on Site Start End Type 71121 - OCC RAD 1 2, 3 IP 7112102 ALARA Planning and Controls 04/20/2009 04/24/2009 Baseline Inspections 2, 3 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 04/20/2009 04/24/2009 Baseline Inspections 71121 - OCC RAD SAFETY 1 2, 3 IP 7112101 Access Control to Radiologically Significant Areas 07/13/2009 07/17/2009 Baseline Inspections 2, 3 IP 7112102 ALARA Planning and Controls 07/13/2009 07/17/2009 Baseline Inspections 2, 3 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 07/13/2009 07/17/2009 Baseline Inspections 71152B - PI&R BIENNIAL TEAM 4 2, 3 IP 71152B Identification and Resolution of Problems 07/20/2009 07/24/2009 Baseline Inspections 71122 - REMP 1 2, 3 IP 7112203 Radiological Environmental Monitoring Program (REMP) And Radioactive Material Control Program 07/27/2009 07/31/2009 Baseline Inspections 71152B - PI&R BIENNIAL TEAM 4 2, 3 IP 71152B Identification and Resolution of Problems 08/03/2009 08/07/2009 Baseline Inspections 71121 - OCC RAD SAFETY 1 2, 3 IP 7111101 Adverse Weather Protection 09/21/2009 09/25/2009 Baseline Inspections 2, 3 IP 7112101 Access Control to Radiologically Significant Areas 09/21/2009 09/25/2009 Baseline Inspections 2, 3 IP 7112102 ALARA Planning and Controls 09/21/2009 09/25/2009 Baseline Inspections 7111108G - U3 INSERVICE INSPECTION 1 3 IP 7111108G Inservice Inspection Activities - BWR 09/28/2009 10/02/2009 Baseline Inspections 71121 - OCC RAD SAFETY & ISFSI 1 2, 3 IP 60855 Operation Of An ISFSI 11/16/2009 11/20/2009 Other Routine 2, 3 IP 7112101 Access Control to Radiologically Significant Areas 11/16/2009 11/20/2009 Baseline Inspections 2, 3 IP 7112102 ALARA Planning and Controls 11/16/2009 11/20/2009 Baseline Inspections 2, 3 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment 11/16/2009 11/20/2009 Baseline Inspections 2, 3 IP 71151 Performance Indicator Verification 11/16/2009 11/20/2009 Baseline Inspections This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.