IR 05000277/2011004

IR 05000277-11-004 & 05000278-11-004, on 07-01-11 - 09-30-11; Peach Bottom Atomic Power Station - NRC Integrated Inspection Report 05000277-2011004 and 05000278/2011004

ML113140265
Person / Time
Site:	Peach Bottom
Issue date:	11/10/2011
From:	Paul Krohn Reactor Projects Region 1 Branch 4
To:	Pacilio M Exelon Nuclear, Exelon Generation Co
Krohn P
References
IR-11-004
Download: ML113140265 (48)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I

475 ALLENDALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19406-1415

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION - NRC INTEGRATED IN S pECTt ON R E PORT 0500027 7 t20 1 1 004 AN D 0500027 81201 1 004

Dear Mr. Pacilio:

On September 30, 2011, 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 October 21,2011, with Mr. Garey Stathes, 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 Commission's 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. However, a licensee-identified violation, which was determined to be of very low safety significance is listed in this report. NRC is treating this violation as a non-cited violation (NCV) consistent with Section2.3.2 of the NRC Enforcement Policy because of the very low safety significance of the violation and because it is entered into your corrective action program. lf you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, 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 response (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.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely, A/*

Paul G. Krohn. Chief Reactor Projects Branch 4

,41*Z-Division of Reactor Projects Docket Nos.: 50-277.50-278 License Nos.: DPR44, DPR-56

Enclosure:

I nspection Report O5OO027 7 I 20 1 1 004 and 0500027 I 120 1 1 004 w/Attachment: Supplementary Information

REGION I Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56 Report No.: 0500427 7 1201 1 004 and 0500027 81201 1004 Licensee: Exelon Generation Company, LLC Facility: Peach Bottom Atomic Power Station. Units 2 and 3 Location: Delta, Pennsylvania Dates: July 1 ,2011, through September 30,2011 Inspectors: S. Hansell, Senior Resident Inspector A. Ziedonis, Resident Inspector H. Gray, Senior Reactor lnspector S. lbarrola, Project Engineer R. Nimitz, Senior Health Physioist J. Greives, Susquehanna Resident lnspector Approved by: Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

lR 0500027712011004, 0500027812011004; 0710112011 - 0913012011; Peach Bottom Atomic

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

The report covered a three-month period of inspectiOn by resident inspectors and announced inspections performed by regional inspectors. 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: lnitiating Events, Mitigating Systems, and Barrier lntegrity None.

Other Findings

A violation of very fow safety significance that was identified by the licensee was reviewed by the inspectors. Conective actions taken or planned by the licensee have been entered into the licensee's corrective action program (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 remained until power was reduced to approximately 55 percent on August 26, to support planned testing, maintenance, and control rod pattern adjustment. On August27, the unit was returned to 100 percent RTP until August 28, when power was reduoed to approximately g0 percent for a follow-up control rod pattern adjustment. The unit was returned to full power on August 29, where it remained until the end of the inspection period, except for brief periods to support planned testing.

Unit 3 began the inspection period at 100 percent RTP. On July 15, the unit began its end-of-cycle (EOC) coast down period. A planned power reduction was performed on July 17 to approximately 90 percent, to remove the fifth stage feedwater (FW) heat exchanger (HX) from service during the EOC coast down. The unit was returned to RTP on the same day.

Additionally, a planned power reduction was performed on August 5, to approximately 80 percent power, to remove the fourth stage feedwater heater from service during the EOC coast down. The unit was returned to RTP on August 6. On September 11, a planned shutdown from approximately 80 percent was commenced and the rnain generator breaker was opened to start the unit's 18th refueling outage (RFO) P3R18. Durirtg the shutdown, operators inserted a planned manual scram from approximately 4 percent reactor power. The unit remained in P3R18 through the end of the inspection period.

REACTOR SAFETY

Gornerstones: Initiating Events, Mitigating Systqms, and Barrier Integrity

1R01 Adverse Weather Protection

a. Inspection Scope

The inspectors reviewed station preparations for severe weather related to the arrival of Hurricane lrene on August 28,2011. The inspectors toured the outside protected area, plant intake structure, and emergency diesel generator (EDG) buildings, to assess the site conditions in preparation for the impending storm. The inspectors discussed overall station readiness with members of operations, maintenance, and security, as well as the station duty manager, to assess the adequacy of the station's physical protection. The inspectors discussed the status of the electrioal grid and plant operational conditions with the operations shift manager. Additionalfy, the inspectors reviewed procedures for severe weather preparation, main control room logs, and condition reports (CRs).

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

.

Findinos No findings were identified.

R04 Equipment Alionment

.1 Partial Svstem Walkdowns (71111.04Q - 4 sqmples)

a.

Insoection Scope The inspectors performed partial walkdowns of the following four systems:

r Unit 3 reactor core isolation cooling (RCIQ) during high-pressure coolant injection (HPCI) planned maintenance on August22,2011 r Unit 2 'B' subsystem high pressure servi@ water (HPSW) during cross-tie valve diagnostic testing on September 18,2011 o Multiple risk-significant systems following August 23 seismic event o Unit 3 traverse in-core probe (TlP) during the Unit 3 RFO on September 29,2011 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 Updated Final Safety Analysis Report (UFSAR), Technical Specifications (TSs), work orders (WOs), CRs, and the impact of ongoing work activities on redundar'rt trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed fielp 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 PBAP$ staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findinqs No findings were identified.

.2 Fuff Svstem Walkdown (71111.04S

- 1 sample)

a. Inspection Scope

On September 24, 28,29, and 30, the inspectors performed a complete system walkdown of accessible portions of the Unit 3 HPCI during the RFO to verify the existing equipment lineup was correct. The inspectorq reviewed operating procedures, surveillance tests (STs), drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its rqquired safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hangar and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned conectly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there wre no deficiencies. Additionally, the inspectors reviewed a sample of related GRs and WOs to ensure PBAPS appropriately evaluated and resolved any deficiencies.

b.

Findinqs No findings were identified.

1R05 Fire Protection

Resident lnspector Quarterlv Walkdowns a.

lnspection Scope The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protedlion 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 fof use as specified in the area pre-fire plan, and passive fire barriers were maintained in lood material condition. The inspectors also verified that station personnel implemerlted compensatory measures for out-of-service (OOS), degraded or inoperable fire protection equipment, as applicable, in accordance with procedures.

o Water treatment building (includes emer$ency equipment storage)o Unit 3 reactor building (RB), RCIC room, elevation 88'-0' o Intake pump structure o Unit 3 radwaste building, RB closed cooling water (RBCCW) room, elevation 116'-0' b. Findinqs No findings were identified.

lROO Flood Protection Measures (71111.06 - 1 sample)

Internal Floodinq Review

a. Inspection Scope

The inspectors walked down the interior of the safety-related intake structure to evaluate the condition of the internal flood protection design features, as well as to verify that credited operator actions could be performed during the most limiting design basis internalflooding event. The inspectors reviewed the internalflood design basis as described in the UFSAR and the internalflood analysis. The inspectors also reviewed design basis calculations, drawings, and propedures to verify that the internalflooding design basis was appropriately translated into controlled documents.

b. Findinqs No findings were identified.

1R08 Inservice Inspection

a. Inspection Scope

Activities inspected during the Peach Bottonl Unit 3 RFO 18 (P3R18) included observations of ultrasonic testing (UT); calibfation practices and analysis of test results using traditional UT; specialty UT for reactor pressure vessel (RPV) nozzle inner radius materialexaminations; and the Phased Arralt UT technique manual based UT, where the Performance Demonstration Initiative (Ppl) practices were required. The inspectors reviewed the applicable UT procedures, qualification certification for the personnel and procedures, observed UT data analysis review, and confirmed that relevant indications were properly documented and presented to PBAPS for disposition.

The RPV UT observations included the upper head meridian weld CH-MA done per the GE-UT-300 procedure, and the RPV Inner Radius of Nozzle N4A, a 24-inch diameter FW line performed by UT Procedure GEH-UT-311. Additionally, the inspectors reviewed the UT data package for the N-10, RPV lower head 1 inch diameter piping penetration done per the procedure GE-UT-300.

For the dissimilar metal (DM) weld N2D, Nozple 2-BHD-8 that was UT examined with the phased array technique, using Procedure EPRI-DMW-PA-1-Revision 3, the inspectors observed the pretest equipment setup, calibrAtion and post-test results.

The preparation, calibration, and UT procedure for the reactor water cleanup pipe welds 12-14-12 and 12-14-13 using 45 and 60 degiee shear waves were reviewed prior to observation of the UT examination in the plant.

For in-vessel visual inspection (lwl), the inspectors sampled the remote enhanced visual examination of reactor vessel internals, mainly of the core spray (CS) piping done per procedure GEH-UT-204813 inside the reactor vessel. The lWl video records of portions of the core shroud, steam dryer, jet pump 13 and 16 components, and top guide bars at location 14were also examined. The in-vesselexaminations included re-examination of previously identified indicatfions. The inspection included a review of the applicable parts of the lWl procedure, observation of a sample of digital video records, the analysis process for the observafions, and documentation of indications.

The inspectors observed the condition of the torus, inside as visible from the internal catwalk and outside as visible from the torus foom floor, and reviewed the work plan for the underwater visual examination (VT-1) that was in progress by divers. A sample of video inspection records to the W-1 requirements were reviewed, including a verification that adequate visual clarity was obtained.

The inspectors reviewed the radiographs and portions of the Radiographic Examination Procedure for a completed 12-inch diameter X 0.375 inch wall piping, weld number 1O-CSI 812-19 for a modification being installed during the RFO. The sensitivity of the radiographic method as shown by the penetrameter, the identification of the radiographer, and provision for acceptance by the radiographic test (RT) data reviewers were observed.

b.

Findinqs No findings were identified.

1R1 1 Licensed Operator Requalification Proqram {71111.11)

Resident Inspector Quarterlv Review (71111i11Q - 1 sample)a.

Inspeclion Scope On August 22 and 29, the inspectors observ$d a simulator scenario at the start of the requalification training week which included {n anticipated transient without scram coincident with a leak in the drywell as well as a loss of coolant accident coincident with a leak in the drywell. The inspectors assessod the performance of risk significant operator actions, including the use of emergdncy operating procedures. The inspectors evaluated crew performance in the areas of:

o Clarity and formality of communications o Event classification and emergency respqnse actions

.

Ability to take timely actions r Prioritization, interpretation, and verification of alarms r Procedure usage o Control board manipulations o Command and control The inspectors verified that evaluators were ipentifying and documenting crew performance problems. These activities con$tituted one quarterly licensed operator req ual ification training program inspection sain ple.

b.

Findinos 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 verified that the (a)(2)performance criteria established by the PBAFS staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and conective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that PBAPS staff was identifying and addressing common cause failures that occurred within and across MR system boundaries.

o Unit 2 control rod drive 02-35 high temperbture and control rod drift

.

'A'emergency service water (ESW underground pipe repair and initial maintenance system problems

.

Unit 3 torus pitting evaluations and recodting b. Findinos No findings were identified.

1R13 Maintenance Risk Assessments and Emerqent Work Control

a.

lnspection Scope The inspectors reviewed station evaluation qnd management of plant risk for the maintenance and emergent work activities li$ted below to verify that PBAPS performed the appropriate risk assessments prior to rennoving equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activitl, the inspectors verified that PBAPS personnel performed risk assessments as reguired by 10 CFR 50.64(aX4) and that the assessments were accurate and complete. When PBAPS performed emergent work, the inspectors verified that operations persorlnel promptly assessed and managed plant risk. The inspectors reviewed the scope of niaintenance work and discussed the results of the assessment with the station's probabiliptic risk analyst to verify plant conditions were consistent with the risk assessment.

assessment. The inspectors also reviewed the TS requirements and inspected portions of redurldant safety systems, when applicable, to tr verify risk analysis assumptions were valid ahd applicable requirements were met.

o Unit 2 'A' recirculation pump motor generbtor set, generator field ground emergent troubleshooting o Unit 3 main turbine control valve oscillatiolns emergent troubleshooting

.

Unit 3 reactor feed pump (RFP) turbine speed control hydraulic power unit filter high d ifferential pressure emergent troublesho0ting o Unit 3 electrical power key safety function during E-33 bus outage, 3 'C' station battery testing, and 3'A'station battery testing b. Findin$

No findings were identified.

1R15 Operabilitv Determinations and Functionalitv Assessments

Insoection Scope The inspectors reviewed five operability determinations for the following degraded or non-conform ing conditions :

r Unit 2 continued operation with Unit 2 'A' recirculation pump motor generator set, generator field ground on July 7,2011

.

Unit 2 'A'station battery low pilot cell voltage on July 11,2011 o Unit 3 high moisture carryover on July 18,t?011 and September 16,2011 o Unit 2 and Unit 3 seismic impact on control rod channel distortion on September 7 ,

2011 I

I o Unit 3 Core Spray sparger leakage on September 6,2011 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspector eyaluated the technical adequacy of the operability determinations to assess whethed TS operability was properly justified and the subject component or system remained dvailable such that no unrecognized increase in risk occurred. The inspectors cofnpared the operability and design criteria in the appropriate sections of the TSs and UFSAR to PBAPS's 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, c0mpliance with bounding limitations associated with the evaluations.

b.

Findinqs No findings were identified.

1R18 Plant Modifications

Temporarv Modifications

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 modification documents associated with the upgrade and design change, discussed the modification wifh engineers, and observed portions of the installation to verify that the temporary modifibation did not degrade the current design bases, licensing bases, and performance capability of the affected systems.

o ECR 11-00077, Revision 1, Unit 2 Fuel Pgol Rack Boraflex Upgrade Project b. Findinqs No findings were identified.

1R19 Post-Maintenance Testino

lnspection Scope The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activilies ensured system operability and functional capability. The inspectors reviewe{ the test procedure to verify that the procedure adequately tested the safety functiQns that may have been affected by the maintenance activity, that the acceptance critQria in the procedure was consistent with the information in the applicable licensing bas{s and/or design basis documents (DBDs),and that the procedure had been properly revibwed and approved. The inspectors also witnessed the test or reviewed test data to velify that the test results adequately demonstrated restoration of the affected safety functions.

o Post-seismic-event calibration check of triaxial peak accelerographs (mechanical) on August 26,2011 o Post-seismic-event calibration of triaxial fime-history accelerographs (elec'tronic) and central recording equipment under Sl2SI67-SSA3-XXC2 on August 27,2011 r Unit 3 RPS partial logic system functiondltesting following K11 relay replacement on September 14,2011 b. Findinqs No findings were identified.

1R20 Refuelinq and Other Outaoe Activities (71111.20 - 1 partial sample)

lnspection Scope The Unit 3 RFO (P3R18) was conducted frorh September 11 through the end of the inspection period. Prior to the start of P3R1$, the inspectors reviewed the station's work schedule and the Outage Risk Assessment l{lanagement (ORAM) Plan against procedures OU-PB-104, "Shutdown Safety $anagement Program;" OU-PB-104-1001, "Shutdown Risk Management for Outages;" and OU-AA-103, "Shutdown Safety Management Program." The ORAM plan was reviewed to confirm that the PBAPS had appropriately considered risk, industry experibnce, and previous site specific problems in developing and implementing a plan that maintained shutdown safety defense-in-depth.

During the RFO, the inspectors observed portions of the shutdown and cooldown processes and selectively monitored the actiVities listed below to verify PBAPS controls over the outage activities:

.

Observed Plant Operations Review Comrpittee meetings where the reactor shutdown, shutdown safety plans, and outage risk assessments were discussed

.

Observed the control room operators redtpce power to approximately 4 percent, initiate a planned manual scram of Unit 3, and stabilize the plant in Mode 3 o Observed selected plant cooldown activities and verified the cooldown rate did not exceed TS limits o Conducted drywell walkdowns to check for discrepant conditions o Maintenance of secondary containment a$ required by TS o Configuration management, including maihtenance of defense-in-depth, commensurate with the outage risk plan fOr the key safety functions and compliance with the applicable TS when taking equiprnent OOS o Monitored decay heat removal operationsl including alternate decay heat removal via the spent fuel pool (SFP)

.

Monitored reactor water inventory controlg, including flow paths, configurations, alternative means for inventory additions {nd controls to prevent inventory loss during operations with a potential to drain the reactor vessel and during short "time to boil" refuel activities o Monitored the status and configuration of #lectrical systems and switchyard activities to ensure that TSs were met o Monitored activities that could affect reactiVity o Monitored refueling activities, including fugl handling r ldentification and resolution of problems rdlated to RFO activities

.

Conducted a walkdown of the Unit 3 'C' RFP clearance and restoration after the system overhaul was completed o Verified the 10 CFR Part 26 fatigue manFgement and work hour limits were not exceeded for operations, reactor servicep, and the fire brigade b.

Findinos No findings were identified.

1R22 Surveillance Testino (71111.22 - 5 samples)i

a.

lnspection Scope (3 routine surveillances; 1 isolation valve; and 1 in-service test (lST) sample)

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

o ST-O-032-301-2, (partial) stroke of MA-2+32-2344 on August 1,2011, and lR 1235289 for missed surveillance o ST-O-052-203-2, E-3 diesel generator slow start and full load test on August 12, 2011 o 5T-0-020-560-213, Units 2 &3 - reactor $olant leakage (RCL) test [1 RCS leakage samplel on August 15,2011 and August 17,2011

.

ST-O-07G475-3, Unit 3 main steam isol{tion valve (MSIV) stroke timing on September 12,2011 [1 isolation valves sample]

ST-O-052-414-2, E4 diesel generator fast start and full load test on August 5, 2011

[1 IST sample]

b. Findinss No findings were identified.

RADIATION SAFEW

2RS0 1 Access Controlto Radiolooicallv Sionificant Afeas

Inspection Scope The inspectors selectively reviewed activities, and associated documentation, in the below listed areas. The inspectors evaluated PBAPS performance against criteria contained in 10 CFR PxI20, applicable TSs, lnd applicable station procedures.

Inspection Plannino The inspectors reviewed Performance Indicators (Pls) for the Occupational Exposure cornerstone. The inspectors also reviewed tfie results of recent radiation protection program audits and assessments, as available, and any reports of operational occurrences, as applicable, related to occupgtional radiation safety since the last Radiolooical Hazard Assessment The inspectors discussed plant operations, ag applicable, to identify any significant new radiofogical hazard for onsite workers or merpbers of the public. The inspectors assessed the potential impact of the change$ and monitoring, as appropriate, to detect and quantify the radiological hazard. The indpectors discussed the Unit 3 outage radiological source term.

The inspectors toured radiological controlled iar"as and reviewed ongoing and completed radiologicalsurveys from various felected plant areas (e.9., re-fueling floor, reactor cavity, RB, turbine building, condens$r areas, drywell, and torus), to verify that the thoroughness and frequency of the survefrs were appropriate for the given radiological hazard.

The inspectors conducted walk-downs of the facility's radiological controlled areas, including the dry-active waste collection locatfon and the protected area, to evaluate material conditions and potential radiologicalconditions. The inspectors made independent radiation measurements to verify conditions.

The inspectors selected various radiological risk-significant work activities (reactor cavity, in-vessel work activities, drywell work fctivities, condenser work, residual heat removal (RHR) system work, drywellwork, arid torus diving activities) that involved exposure to radiation to verify that adequate pre-work radiological surveys were performed to identify and quant'fy the radiological hazard and to establish adequate protective measures. The evaluation included, as applicable: identification of discrete particles, the presence of alpha emitters, the potentialfor airborne radioactive materials, potential changes in radiological conditions (ttensient conditions), non-uniform exposures of the body (radiation dose gradierits), and presence of hard-to detect radionuclides.

The inspectors selectively reviewed and discr,lssed air sample survey records associated with various work activities to verify that sampfles were representative of the breathing zone and were collected and counted in accoldance with applicable procedures, as appropriate. The inspectors verified that PBAPS has a program to monitor loose surface contamination with the potentialto become airbome.

lnstructions to Workers The inspectors toured the radiologically controlled areas, including Unit 3 outage work areas, and reviewed labeling of containers of f'adioactive material containers to verify labeling was consistent with requirements and was informative to workers, as applicable.

The inspectors evaluated whether containers {vere shielded and stored, as appropriate to limit personnel occupational exposure.

The inspectors reviewed various radiation wfrk permits (RWPs), as low as is reasonably achievable (ALARA) reviews, and radiologicalsurveys, used to access high radiation areas (HRAs), to determine if work control instructions or control baniers specified, use of stay times or permissible dose, and appropriate electronic personal dosimeter (EPD)alarm set-points were in conformance with sgrvey indications. The inspectors evaluated PBAPS changes to set-points for specified cpnditions and updating of radiation work permits. The inspectors reviewed ongoing rgmote monitoring via video monitoring as well as teledosimetry, including diving activities.

The inspectors selected occurrences where h worker's dosimeter noticeably malfunctioned or alarmed to verify that workdrs responded appropriately to the off-normal conditions. The inspectors verified the issue was included in the CAP and dose calculations were conducted as appropriate. The inspectors also reviewed instances of personnel exceeding 100 millirem relative to limits in applicable radiation work permits.

The inspectors reviewed ongoing work activi{ies in the radiological controlled area to evaluate methods used by PBAPS to updatq workers on changes in radiological conditions.

The inspectors observed locations where PBAPS monitors potentially contaminated material leaving the radiologically controlled {rea (RCA), and inspected the methods used for control, suryey, and release from th4se areas. The inspectors observed the performance of personnel surveying and relebsing material for unrestricted use to verify that the work was performed in accordance ulith plant procedures and the procedures were sufficient to control the spread of contadpination and prevent unintended release of radioactive materials from the site. The inspectors selectively evaluated the radiation monitoring instrumentation sensitivity for the type(s) of radiation present.

The inspectors reviewed PBAPS criteria, and/or any changes thereto, for the survey and release of potentially contaminated material. The inspectors verified that there was guidance on how to respond to an alarm that indicates the presence of radioactive material.

The inspectors reviewed PBAPS procedures pnd records to verify that the radiation detection instrumentation was used at its typiOal sensitivity level based on appropriate counting parameters including application of alarm set-points based on the instrument's typical sensitivity. The inspectors also discussed alarm set-points and typicaldetection capabilities with PBAPS personnel.

The inspectors toured the facility and reviewed ongoing work and evaluated ambient radiological conditions (e.9., radiation levels op potential radiation levels). The inspectors verified the existing conditions were consistent with posted surveys, RWPs, and worker briefings, as applicable.

The inspectors observed ongoing work activitibs and verified the adequacy of radiological controls, such as required survey$ (including system breach radiation, contamination, and airborne surveys), radiation protection job coverage (including audio and visual surveillance for remote job coverage), and contamination controls. The inspectors selectively evaluated PBAPS's mbans of using EPDs in high noise areas as HRA monitoring devices (e.9., use of teledo$imetry).

The inspectors verified that radiation monito4ing devices thermoluminescent dosimeters (TLDs) were placed on the individual's body consistent with the method that PBAPS is employing to monitor dose from external radiation sources. The inspectors verified by direct observation that the dosimeters were placed in the location of highest expected dose, including for control rod drive work. The inspectors reviewed, for HRW, areas with significant dose rate gradients, the use of dopimetry to effectively monitor exposure to personnel.

The inspectors selectively reviewed RWPs fdr work within potential airborne radioactivity areas with the potentialfor individualworker intemalexposures. The inspectors evaluated airborne radioactive controls and rhonitoring, including potentials for significant airborne levels (e.9., grinding, grit blasting, system breaches, entry into tanks, cubicles, reactor cavities). The inspectors dif'ectly observed contaminated system breach activities including use of local ventildtion system and respiratory protection equipment to minimize airborne radioactive exposure.

The inspectors selectively observed ongoing lwork activities within flooded pools and examined PBAPS physical and programmati$ controls for highly activated or contaminated materials (nonfuel) stored withiir storage pools. The inspectors verified that appropriate controls (i.e., administrative End physical controls) were in place to preclude inadvertent removal of these materifls from the pool.

The inspectors conducted selective inspectioh of posting and physical controls for HRAs and very high radiation areas (VHRAs), to thQ extent necessary to verify conformance with the Occupational Pl. The inspectors evfluated down-posting of areas from HRAs.

Risk-Siqnificant HRA and VHRA Controls The inspectors reviewed and discussed with lhe radiation protection manager the controls and procedures for high-risk HRAs and VHRAs and any procedural changes since the last inspection. The inspectors discirssed methods employed by PBAPS to provide stricter control of VHRA access inclu{ing potential reduction in the effectiveness and level of worker protection (e.9., use of lodk boxes).

The inspectors selectively discussed with hea[th physics supervisors, and in-field staff the controls for special areas that have the pqtentialto become VHMs during certain plant operations including controls to ensure tfiat an individual is not able to gain unauthorized access to the VHM.

Radiation Worker Performance The inspectors observed radiation worker performance with respect to stated radiation protection work requirements to determine if performance reflected the level of radiological hazards present. The inspectors interviewed numerous workers conducting work activities in the radiological controlled arda to determine if workers were aware of the radiological conditions in their workplace dnd the RWP controls/limits in place. The inspectors discussed ongoing activities and Nmbient radiological conditions with workers in the Unit 3 drywell, condenser bay, refuelirig floor, and other areas.

The inspectors selectively reviewed radiologfcal problem reports since the last inspection to identify human performance errors and dQtermine if there were any observable patterns. The inspectors discussed correctirie actions for identified concerns with PBAPS personnel.

Radiation Protection Technician Proficiencv The inspectors observed the performance oflthe radiation protection technician with respect to all radiation protection work requirpments to determine if technicians were aware of the radiological conditions in their workplace and the RWP controls/limits and ar if their performance is consistent with their traihing and qualifications with respect to the radiological hazards and work activities.

The inspectors selectively reviewed outage radiological problem reports caused by radiation protection technician error and to evaluate the corrective action approach taken by PBAPS to resolve the reported problems.

Problem ldentification & Resolution (Pl&R)

The inspeclors determined if problems associated with radiation monitoring and exposure controlwere being identified by PBAPS at an appropriate threshold and were properly addressed for resolution in the CAP. The inspectors discussed corrective actions with radiologicalcontrols staff and mdnagement.

b.

Findinqs No findings were identified.

2RS02 OccupationalALAM Planninq and Controls 471124.A2)

a. Inspection Scope

The inspectors selectively reviewed pertinent linformation regarding plant collective exposure history, cunent exposure trends, and ongoing or planned activities in order to assess current performance and exposure chfllenges.

The inspectors evaluated current site-specific trends in collective exposures using various methods such as plant historical data,jincluding outage work dose based on task, evaluation of ALARA data, and PBAPS $ource term data.

The inspectors reviewed site-specific procedu;"es associated with maintaining occupational exposures ALARA including the processes used to estimate and track exposures from specific work activities.

Radioloqical Work Plannino The inspectors obtained a list of Unit 3 outage work activities ranked by actual or estimated exposure that were planned or in prbgress and selected work activities of the highest exposure significance. These included reactor disassembly, control rod drive work, scaffolding, RHR work, torus diving, tufbine work, and valve work.

The inspectors selectively reviewed the AI-ARA work activity evaluations, exposure estimates, and exposure mitigation requirempnts. The inspectors determined if PBAPS reasonably grouped the radiologicalwork intf work activities, based on historical precedence, industry norms, and/or special circumstances.

The inspectors determined if the PBAPS plar'lrning identified appropriate dose mitigation features; considered, commensurate with th$ risk of the work activity, alternate mitigation features; and defined reasonable {ose goals. As applicable, the inspectors verified that PBAPS ALARA assessments had taken into account decreased worker efficiency from the use of respiratory protectite devices.

The inspectors determined if PBAPS work plhnning considered the use of remote technologies (such as teledosimetry, remote Visual monitoring, and robotics) as a means to reduce dose and the use of dose reductiorl insights from industry operating experience and plant-specific lessons learned. The inspectors verified the integration of ALAM requirements into work procedure anp RWP documents. The inspectors selectively reviewed 2011 Station AISRA Co;nmittee meeting minutes.

The inspectors compared accrued results aclnieved (dose rate reductions, person-rem used), as available, with the intended dose e$tablished in PBAPS ALAM planning for these work activities, including person'hour eBtimates. The inspectors determined, as applicable, the reasons for inconsistencies bdtween intended and actualwork activity doses.

The inspectors determined if post-work (i.e., for previous outage work in 2009 and 2010) were conducted and if identified were entered into the CAP. The inspectors reviewed various previous station reports. The inspectors selectively reviewed post-work reviews for 2 'A' reactorwater clean-up (RWCU) HX work.

The inspectors selected various ATARA worki (e.9., MSIV work, control rod drive work, strain gauge work, diving, work activities, and turbine retro-fit) and reviewed the assumptions and bases for the exposure estimate for reasonable accuracy. The inspectors reviewed procedures to determine the methodology for estimating exposures from specific work and the intended dose outcome.

The inspectors also reviewed approvals by station ALARA committee as applicable, The inspectors verified, for the selected work hctivities, that PBAPS established measures to track, trend, and if necessary to reduce, occupational doses for ongoing work activities, including criteria to prompt ad{itional reviews and/or controls.

The inspectors evaluated the adequacy of PBAPS's method of adjusting exposure estimates, or re-planning work, when unexpedted changes in scope or emergent work are encountered. The inspectors evaluated ahy changes needed as a result of unanticipated Unit 3 outage radiation dose ratb changes.

Source Term Reduction and Control The inspectors met with station chemistry peisonnel and used PBAPS records to determine the historical trends and current status of significant tracked plant source terms known to contribute to elevated facility aggregate exposure. The inspectors discussed source term mitigation with PBAPS staff and reviewed the station's Five-Year ALARA plan. The inspectors discussed contingency plans for potential changes in the source term as the result of changes in plant fuel performance issues or changes in plant primary chemistry. The inspectors evaluated any significant changes in Unit 3 outage source term as compared to expecte{ values.

The inspectors observed both radiation and radiation protection technician performance during outage work activities performed in radiation areas, airborne radioactivity areas, or HRA. The inspectors if workers demonstrated the ALARA philosophy in practice and whether were any procedure compliance issues. The inspectors observed to determine whether the training and skill levelwere sufficient with respect to the ical hazards and the work involved.

PI&R The inspectors determined if problems assodiated with AISRA planning and controls were being identified by PBAPS at an appropriate threshold and were properly addressed for resolution in the CAP. The infpectors discussed corrective actions for identified ALARA concems. (See Section 4OA2)

Findinos No findings were identified.

2RS0 3 f n-Plant Airborne Radioactivitv Control and Mitiqation

a.

Inspeclion Scope Inspection Plannins The inspectors selectively reviewed the plan! UFSAR, as applicable, to identify areas of the plant designed as potential airborne radiation areas and any associated ventilation systems or airborne monitoring instrumentatipn. The inspectors also reviewed the UFSAR for an overview of the respiratory prdlection program and a description of the types of devices used.

The inspectors selectively reviewed PBAPS procedures for maintenance, inspection, and use of respiratory protection equipment ifrcluding procedures for air quality maintenance. The inspectors also selectivel! reviewed, and directly obserued, use of respiratory protection equipment during ongoing work activity.

The inspectors reviewed the reported Pls to identify any related unintended dose resulting from intakes of radioactive materialg.

Enqineerinq Controls The inspectors selectively evaluated PBAPS use of ventilation systems as part of its engineering controls to control airborne radiQactivity, speciflcally during the Unit 3 outage. The inspectors discussed procedur{l guidance for use of installed plant systems to verify proper system use, to the dxtent practicable, during high-risk activities.

The inspectors discussed verification of plant ventilation systems during reactor cavity work. The inspectors selectively reviewed inbtalled ventilation systems used to mitigate the potential for airborne radioactivity. The idspectors discussed use of installed systems during woil< activities.

The inspectors selected two temporary ventilBtion systems set up (high efficiency particulate air (HEPA) filters) to support worklin contaminated areas. The inspectors discussed the use of these systems during aftivities such as RHR system work, reactor cavity work, and condenser bay work with re$ards to procedural guidance and ALARA.

The inspectors selected installed systems th4t monitor and warn of changing airborne concentrations in the plant. The inspectors egaluated the alarms and set-points to prompt licensee/worker action to ensure that poses are maintained within the limits of 10 CFR Part20 and ALAM. The inspectors observed monitoring of ambient conditions by use of telemetry air monitoring systems.

The inspectors evaluated PBAPS use of trigger points for evaluating levels of hardto detect airborne radionuclides. The inspectorq evaluated Unit 3 radiological conditions as regards mon itori ng of hardto-detect radionudlides.

Use of Respiratory Protection Devices The inspectors selectively evaluated PBAPS pse of respiratory protective devices to maintain occupational doses ALARA. The selected two work activities where respiratory protection devices were used to lirlrit the intake of radioactive materials, and evaluated the use of respirators. The i evaluated PBAPS's means to verify that the level of protection (protection factor) by the respiratory protection devices during use was at least as good as tflat assumed in PBAPS work controls and dose assessment. The inspectors evaluated Use of respiratory protection for control rod drive removal.

The inspectors evaluated the use of certified $quipment (respiratory protection devices)to limit the intake of radioactive materials andievaluated that the devices were used consistent with their National Institute for OccUpational Safety and Health/Mine Safety Health Administration certification or any conditions of their NRC approval. The inspectors evaluated use of respiratory proteqtion for grit blasting and for reactor cavity work.

The inspectors reviewed records of air testingjfor supplied-air devices (compressors)and self-contained breathing apparatus (SCBA) bottles to verify that air used in these devices met or exceeded appropriate quality. The inspectors evaluated whether the plant breathing air supply systems (device suSply manifolds) met the minimum pressure and airflow requirements for the devices in usf. The inspectors selectively reviewed use of supplied air systems and air quality test resf.rlts.

The inspectors selected individuals qualified [o use respiratory protection devices, and verified that they have been deemed qualified to use the devices. The inspectors observed individuals assigned to wear a respiratory protection device and observed them donning and functionally checking the {evice, as appropriate. The inspectors discussed their use of the devices, including frow to properly respond to any device malfunction or unusual occurrence.

The inspectors reviewed respiratory protectile equipment storage, maintenance, and quality assurance. The inspectors chose respiratory protection devices staged and ready for use in the plant or stocked for issu{nce for use. The inspectors obseryed the physicaf condition of the device components fmask or hood, harnesses, air lines, regulators, air bottles, etc.) and reviewed of routine inspection for each, as applicable. The inspectors reviewed of maintenance on the vital components (e.9., pressure regulators, valves, hose couplings). The inspectors verified that personnel assigned to repair vital components were determined to be qualified, as appropriate.

SCBA for Emerqencv Use The inspectors reviewed (based on UFSAR, lfSs, and emergency operating procedure requirements) the status and surveillance reoords of three SCBAs staged in-plant for use during emergencies. The inspectors evaluatdd PBAPS's capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions.

The inspectors selected various individuals oh control room shift crews and individuals from designated departments currently assigped emergency duties (e.9., onsite search and rescue duties) to determine if control room operators and other emergency response and radiation protection personnel (assigned in-plant search and rescue duties or as required by emergency operating procepures or the emergency plan) were trained and qualified in the use of SCBAs (including ;fersonal bottle change-out). The inspectors determined if personnel assigned fo refill bottles were trained and qualified for that task, as appropriate.

The inspectors selectively verified that appropriate mask sizes and types were available for use (in-field mask size and type should mftch what was used in fit-testing). The inspectors entered the station control room arl'rd verified that on shift operators exhibited no facial hair that would interfere with the sedling of the mask to the face. While in the control room, the inspectors verified that vision correction devices (e.9., glasses, inserts, or corrective lenses that did not penetrate the face seal) were available as appropriate.

The inspectors also selectively reviewed, as Available due to new equipment being used, maintenance records for four SCBA units (pabk 14, 34,83, 435) used to support operator activities during accident conditions and designated as "ready for service." The inspectors verified that any maintenance or rgpairs on an SCBA unit's vital components were performed by an individual, or individuals, certified by the manufacturer of the device to perform the work. The inspectors sblectively reviewed that the required, periodic air cylinder hydrostatic testing was dpcumented and upto-date, and the retest air cylinder markings required by the U.S. Department of Transportation were in place.

PI&R The inspectors selectively reviewed and disclssed problems associated with the control and mitigation of in-plant airborne radioactivity to evaluate the PBAPS identification and resolution of issues in the CAP. (See Section 4OA2)

The inspectors reviewed the reported Pls to identify any related unintended dose resulting from intakes of radioactive material$.

b.

Findinqs No findings were identified.

2RS04 Occupational Dose Assessment (7 1 124.04)

a. Inspection Scope

External Dosimetry The inspectors selectively evaluated the use of personnel dosimeters that require processing were National Voluntary Laboratdry Accreditation Program accredited. The inspectors determined if PBAPS uses a "correction facto/'to address the response of the electronic dosimeter (ED) as compared tf its TLD for situations when the ED must be used to assign dose.

The inspectors evaluated the onsite storage bf dosimeters before their issuance, during use, and before processing/reading. The insDectors verified that guidance is provided to radiation workers with respect to care and st$rage of dosimeters since issued dosimetry is not required to be stored on-site during thd wear period.

Internal Dosimetrv The inspectors selectively reviewed routine kjioassay (in vivo) procedures and whole body count results used to assess dose from potentially internally deposited nuclides using whole body counting equipment. The inspectors selected available whole body counts and verified through data review, that the system used in each had sufficient counting time/low background to ensure appfopriate sensitivity for the potential radionuclides of interest. The inspectors evqluated the program library used. The inspectors verified that anomalous count peaks/nuclides indicated in each output spectra received appropriate disposition. The inspectors reviewed the PBAPS 10 CFR Part 61, "Licensing Requirements for Land Disposal Qf Radioactive Waste," analyses to ensure that the libraries include appropriate gamma emitting nuclides. The inspectors evaluated the assessment of internal dose from hardto-detect nuclides.

Special Dosimetric Situations The inspectors selectively reviewed exposure results, and monitoring controls employed, associated with declared pregnant individual$ during the current assessment period.

The inspectors selectively reviewed PBAPS implementation of monitoring for external dose in situations in which non-uniform fieldg are expected or large dose gradients (i.e., use of multi-badging or determination oi effective dose equivalent (EDE) for externalexposures (EDEX) using an NRC a$proved method).

Shallow Dose Equivalent The inspectors selectively reviewed personnpl contamination instances to evaluate frequency, causes, and dose assessment, a$ appropriate. The inspectors also discussed identification and logging of persopnel contamination occurrences during the Unit 2 outage, including actions taken to iderftify and limit personnel contamination events. The inspectors also selectively reviewed the PBAPS Personnel Contamination Control Plan.

PI&R The inspectors selectively reviewed correctivp action documents to verify that problems associated with occupational dose assessmdnt were being identified by PBAPS at an appropriate threshold and were properly addl'essed for resolution in the CAP. (See Section 4OA )

b.

Findinqs No findings were identified.

2RS05 Radiation Monitorins Instrumentation (7 1 124,,05)

a. Inspection Scope

lnspection Plannino The inspectors selectively reviewed the plan{ UFSAR to identify radiation instruments associated with monitoring area radiological ponditions including airbome radioactivity, process streams, effluents, materials/articles; and workerc. Additionally, inspectors identified instrumentation and associated TS requirements for post-accident monitoring instrumentation, including those instruments used for remote emergency assessment.

The inspectors reviewed a listing of in-servicp survey instrumentation including air samplers and small article monitors (SAMs), along with instruments used for detecting and analyzing workers'externalcontaminati$n (personnelcontamination monitors (PCMs)) and workers' internal contaminationl(portal monitors (PMs), whole body counters (WBCs), etc.). The inspectors reviewed the list to determine whether an adequate number and type of instruments were available to support operations.

Laboratorv Instrumentation The inspectors selectively reviewed laboratory analytical instruments used for radiological analyses (e.9., gross alpha, grosb beta, proportional counters, gamma spectroscopy (including germanium-lithium, ltigh purity-intrinsic germanium) and liquid scintillation counters). The inspectors selectiVely verified daily performance checks and calibration data to determine calibration freqdency adequacy and verify there were no indications of degraded instrument performafi ce.

As part of the Pl&R review, the inspectors verifed that appropriate corrective actions were implemented in response to indications of degraded instrument performance.

Whole Bodv Counter The inspectors reviewed the methods and sdurces used to perform WBC functional checks before daily use of the instrument. Tlhe inspectors determined whether check sources were appropriate and aligned with the plant's isotopic mix.

The inspectors reviewed WBC calibration re$orts (July 2011) completed since the last inspection to verify that calibration sources Were representative of the plant source term and that appropriate calibration phantoms wdre used. The inspectors verified there were no anomalous results or other indications of instrument performance problems.

Dal r lIJleI srvut tul tugutt /e\l[ tvt()[ilIol s The inspectors selectively reviewed calibratiqn documentation for various radiological instruments (e.9., RO-2, RO-20, RM-14, MGP telepole). The inspectors discussed detector measurement geometry, calibration methods, and discussed use of instrument calibrator. During in-field walk-downs, the inbpectors inter-compared instrument readings and posted or previously documentFd radiological surveys.

For instruments that did not meet acceptanc$ criteria during calibration or source checks, the inspectors discussed PBAPS ac{ions taken, including possible consequences of instrument use since the latt successful calibration or source check.

PI&R The inspectors selectively reviewed correctiVe action documents associated with radiation monitoring instrumentation to detenl'nine if PBAPS identified issues at an appropriate threshold and placed the issues in tne CAP for resolution. In addition, the inspectors evaluated the appropriateness of fhe conective actions for a selected sample of problems documented by PBAPS that involve radiation monitoring instrumentation.

(See Section 4OA2)

b. Findings

No findings were identified.

(71124.06)

Inspection Scopq Ground Water Protection Initiative (GPl) lmplFmentation The inspectors selectively reviewed and disctrssed implementation of the ground water monitoring program. The inspectors revieweiJ current monitoring results and trends of the GPI to determine if PBAPS has implemeflted its program as intended and to identify identifr anv anomalous or missed results and to detdrmine if PBAPS has identified and any addressed deficiencies through its CAP. Thd inspectors discussed the site ground water flow conceptual site model.

PI&R The inspectors verified that problems associ{ted with the effluent monitoring and control program were being identified by PBAPS at {n appropriate threshold and were properly addressed for resolution in the CAP. (See SFction 4OFQ)

Findinqs No findings were identified.

OTHER ACTIVITIES

4OA Problem ldentification and Resolution (Pl&R)

.1 Review of ltems Entered into the CAP (7115? - 1 sample)

a. Inspection Scope

As required by Inspection Procedure (lP) tllSZ, "Problem ldentification and Resolution,"

the inspectors routinely reviewed issues durihg 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 ponective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human perfofmance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended CR screening meetings.

Findinss No findings were identified.

.2 Prooram (7 1 124.01,

71 124.02, 71 124.03, 7 1 24,04, 71 124.05, 71 124.46)lnspection Scope l

The inspectors selectively reviewed correctivF action documents for the occupational radiation safety program and effluent monitoling program. See documents reviewed.

The review was against criteria contained in 'f 0 CFR Part 20, TSs, ODCM, and applicable station audit and surveillance prooedures.

Findinss No findings were identified.

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

Unusual Event Due to Earthquake (71153 - 1 sample)

Insoection Scope On August 23,2011, PBAPS declared an Unbsual Event (UE) due to receipt of an alamt in the main control room (MCR) indicating seismic activity. confirmed to be felt by the operators in the MCR. The inspectors fulfillefl the NRC emergency response responsibilities and immediately responded t0 the MCR and the outage control center to observe and assess PBAPS response to the UE. The operators in the MCR promptly entered the appropriate procedures, and ma$e timely and appropriate notifications to state and local authorities, as well as the NRp's Operations Center. The inspectors reviewed the data recorded by the seismic inFtrumentation system, and verified that the operating basis earthquake was not exceedeS. PBAPS operators, engineers, and maintenance technicians performed thorougll walkdowns, both internal and externalto the plant, and did not identify any damage. The inspectors performed independent walkdowns and did not identify any damage. The inspectors determined that PBAPS response to the UE was conducted in a timelf and appropriate manner to ensure that the plant was operating safely.

Findinss No findings were identified.

40A5 Other Activities

.1 EA-10-121 (lP 92702 - 1 sample)

a. lnspection Scope On September 16, 2010, the NRC issued Inqpection Report 50-278 &5A-27912010009 which contained a Severity Level lV NCV of '10 CFR 50.9, 'Completeness and Accuracy of Information" and 10 CFR 73.56(c), "PersofinelAccess Authorization Requirements for Nuclear Power Plants," when Exelon failed tQ ensure the adequacy of its Physical Security Plan and background checks to ideintify past actions and appropriately evaluate the trustworthiness and reliability of applicanfs for unescorted access (UA). This failure resulted when a former contract outage employee at PBAPS failed to disclose on a personnel history questionnaire (PHQ), a pretrrious, non-nuclear employment from which the individual had been terminated for a posifive fitness-for-duty (FFD) test.

The f P g2l}zobjective is to determine that a'dequate corrective actions have been implemented for traditional enforcement actiQns including violations. To assess and document Exelon's response and corrective dctions regarding the issued violation, the region elected to perform this inspection actiyity during the conduct of the biennial Pl&R team inspection and informed Exelon of the NRC's intent to conduct this inspection as part of the 2011 NRC mid-cycle assessment.

The inspectors reviewed Exelon's work group evaluation, actions taken, related CRs, procedures, and relevant references to ensulte the adequacy of, and adherence to, the background investigation process.

Findinos No findings were identified. The inspectors determined that the corrective actions taken, and planned for the violations were adequatd and of sufficient scope.

40A6 Meetings, Includinq Exit

.1 Quarterlv Resident Exit Meetinq Summarv

On October 21,2011, the resident inspectorg presented the inspection results to Mr. Garey Stathes, Peach Bottom Plant Manpger, 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.

.3 Summarv

The inspectors presented the inspection resqlts from the occupational radiation safety program and the effluent monitoring progranito members of Exelon Nuclear management on August 26, 2011 and Septefiber 23,2011. The inspectors also discussed the inspection results with the licelrsee staff on September 27,2011. Exelon personnel acknowledged the inspection results. No proprietary material is included in this inspection report.

4OA7 Licensee-ldentified Molation

The following violation of very low safety sigrlificance (Green) was identified by the licensee and is a violation of NRC requirements which meet the criteria of the NRC Enforcement Policy, for being dispositioned 4s an NCV.

10 CFR, Part 50, Appendix B, Criterion lll requires, in part, that "measures shall be established to assure that the design basis, for those SSCs that mitigate the consequences of postulated accidents arf corectly translated into procedures."

Contrary to the above, PBAPS did not enpure that the CS system required flow of 6,874 gallons per minute (gpm) was corrqctly translated into Emergency Operating Procedure T-111, "Level Restoration," to ensure long term core cooling following a loss of coolant accident. The 6,874 gpm flowrate was determined by engineering analysis to account for the 624 gpm leakdge through the CS sparger headers and into the reactor vessel annulus region, thereby bypassing long-term cooling of the fuel in the core shroud region. The inspeptors determined that this finding was of very low safety significance (Green) in acpordance with NRC IMC 0609, Attachment 4, "Phase 1 - Initial Screening and CharaQterization of Findings," Mitigating Systems cornerstone, because the finding did not rpsult in the actual loss of safety function.

PBAPS engineering review of quarterly sqrveillance tests for the last three years determined that the CS pumps have mor$ than sufficient margin to account for the leakage. The inspectors verified the deteimination through an independent inspection sampling of surveillance test dhta. This finding has been documented in the CAP under lR 1245207.

ATTACHMENT:

SUPPLEMENTARY 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. Reiner, Chemistry Manager

R. Holmes, Radiation Protection Manager

J. Bowers, Training Director

B. Henningan, Operations Training Manager

NRC Personnel

P. Krohn, Branch Chief

S. Hansell, Senior Resident lnspector

A. Ziedonis, Resident Inspector

H. Gray, Senior Reactor Inspector

S. lbarola, Project Engineer

R. Nimitz, Senior Health Physicist

J. Greives, Susquehanna Resident Inspector

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened

None

Opened/Closed

None

Closed

None Discussed/Closed

05000278; 27912010009-01 EA-10-093 Followup on NRC lnvestigation Reports (Of 1-2009-05311-20A9-046) ENIA-121 Nos. 1-2009-53 and 1-2009-046 (Section 4OA5.1)