IR 05000277/2007006

IR 050000277-07-006 and 05000278-07-006, on 04/23/2007 - 05/18/2007, Peach Bottom Atomic, Problem Identification and Resolution

ML071780097
Person / Time
Site:	Peach Bottom
Issue date:	06/26/2007
From:	Mel Gray Division Reactor Projects I
To:	Crane C Exelon Generation Co, Exelon Nuclear
Gray M, RI/DRP/TSAB/610-337-5209
References
IR-07-006
Download: ML071780097 (25)

Text

une 26, 2007

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT NOS. 05000277/2007006 and 05000278/2007006

Dear Mr. Crane:

On May 18, 2007, the US Nuclear Regulatory Commission (NRC) completed a team inspection at your Peach Bottom Atomic Power Station. The enclosed inspection report documents the inspection results, which were discussed on May 18, 2007, with Mr. Michael Massaro, Peach Bottom Plant Manager, and other members of your staff.

This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and the conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

On the basis of the sample selected for review, the team concluded that implementation of the corrective action program at Peach Bottom was generally effective in that problems were properly identified, evaluated, and corrected. Two findings of very low safety significance (Green) were identified during this inspection, both related to untimely corrective actions for conditions adverse to quality, which were previously identified in Non-Cited Violations (NCVs).

The first finding was related to a 2006 NCV, which identified less than adequate surveillance test acceptance criteria for the high pressure coolant injection (HPCI) pumps. The second finding was related to a 2005 NCV, which identified the failure to follow the appropriate site procedure that resulted in a delayed operability determination for the HPCI system. The findings were determined to be violations of NRC requirements. However, because each of the findings was of very low safety significance (Green) and because they were entered into your corrective action program, the NRC is treating these as NCVs, in accordance with Section VI.A.1 of the NRCs Enforcement Policy. If you deny either of these NCVs, you should provide a response with the basis for your denial, within 30 days of the date of this inspection report, to the U.S. Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC, 20555-0001, with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC, 20555-0001; and the NRC Resident Inspector at the Peach Bottom facility. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publically Available Records (PARS) component of the NRCs 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).

Sincerely,

/RA/

Mel Gray, Chief Technical Support & Assessment Branch Division of Reactor Projects Docket Nos. 50-277, 50-278 License Nos. DPR-44, DPR-56 Enclosure: Inspection Report Nos. 05000277/2007006, 05000278/2007006 w/Attachment: Supplemental Information cc w/encl:

Chief Operating Officer, Exelon Generation Company, LLC Site Vice President, Peach Bottom Atomic Power Station Plant Manager, Peach Bottom Atomic Power Station Regulatory Assurance Manager - Peach Bottom Manager, Financial Control & Co-Owner Affairs Vice President, Licensing and Regulatory Affairs Senior Vice President, Mid-Atlantic Senior Vice President - Operations Support Director, Licensing and Regulatory Affairs J. Bradley Fewell, Assistant General Counsel, Exelon Nuclear Manager Licensing, PBAPS Director, Training Correspondence Control Desk Director, Bureau of Radiation Protection, Department of Environmental Protection R. McLean, Power Plant and Environmental Review Division (MD)

G. Aburn, Maryland Department of Environment T. Snyder, Director, Air and Radiation Management Administration, Maryland Department of the Environment (SLO, MD)

Public Service Commission of Maryland, Engineering Division Board of Supervisors, Peach Bottom Township B. Ruth, Council Administrator of Harford County Council Mr. & Mrs. Dennis Hiebert, Peach Bottom Alliance TMI - Alert (TMIA)

J. Johnsrud, National Energy Committee, Sierra Club Mr. & Mrs. Kip Adams E. Epstein, TMI Alert R. Fletcher, Department of Environment, Radiological Health Program

SUMMARY OF FINDINGS

IR 05000277/2007-006, 05000278/2007-006; 04/23/2007 - 05/18/2007; Peach Bottom Atomic

Power Station; Biennial Baseline Inspection of the Identification and Resolution of Problems; two violations were identified in the timeliness of corrective actions.

This team inspection was performed by three regional inspectors and one resident inspector.

Two findings of very low safety significance (Green) were identified during this inspection. Each of the findings was classified as a Non-Cited Violation (NCV). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using NRC Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). 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.

Identification and Resolution of Problems The team concluded that the implementation of the corrective action program (CAP) at Peach Bottom was generally effective. Peach Bottom had a low threshold for identifying problems and entering them in the CAP. Once entered into the system, items were screened and prioritized in a timely manner using established criteria. Items entered into the CAP were properly evaluated commensurate with their safety significance; and corrective actions were normally implemented in a timely manner, commensurate with the safety significance. However, the team noted that corrective actions were not completed for two NCVs issued in the last two years. Also, corrective action tracking documentation for two other NCVs was less then thorough in documenting action completion. The team observed that Peach Bottom appropriately reviewed and applied lessons learned from industry operating experience. Audits were noted to be very good, and self-assessments were acceptable. On the basis of interviews conducted during the inspection, workers at the site expressed freedom to enter safety concerns into the CAP.

There were two Green NCVs identified by the team during this inspection, both related to untimely corrective actions for conditions adverse to quality that were previously identified in NCVs. The first was related to a March 2006 violation, which identified less than adequate surveillance test acceptance criteria for the high pressure coolant injection (HPCI) pumps. The violation identified that acceptance criteria were such that the surveillance test could be completed satisfactorily, but the pump could be inoperable due to not being able to meet design basis requirements. The licensee verified that the system had remained operable. The second was related to a July 2005 violation, which identified that the failure to follow the appropriate site procedure resulted in a delayed operability determination for the HPCI system. Specifically, the operators referenced the Technical Requirements Manual (which allowed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for an evaluation of operability) instead of the operability determination procedure (which required the system be declared inoperable immediately).

a.

Cornerstone: Mitigating Systems

C Green: The NRC identified a Green NCV of 10CFR50, Appendix B, Criterion XVI,

Corrective Actions, related to the failure to correct the March 2006 deficiency identified in NCV 05000277,278/2006009-01, related to less than adequate acceptance criteria in ii

a quarterly surveillance test procedure for the HPCI pumps. The team identified that Exelon had not revised the procedure and had continued to conduct the surveillance test, thirteen times since the issue was discovered by the NRC. Exelon performed an evaluation of the recent HPCI pump surveillance test results and concluded that the pumps currently met the design basis requirements, and had remained operable. The performance deficiency has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because Exelon failed to take prompt corrective actions to address a safety issue in a timely manner, commensurate with safety significance and complexity. [P.1.(d)]

The finding is more than minor because it affects the procedure quality attribute associated with the Mitigating Systems Cornerstone objective to ensure the capability of HPCI, a mitigating system. The finding is of very low safety significance because the finding was not a design or qualification deficiency, did not represent a loss of system safety function, and was not risk significant due to external initiating events.

(Section 4OA2.a(3)(a))

C Green: The NRC identified a Green NCV of 10CFR50, Appendix B, Criterion XVI,

Corrective Action, for failure to correct a condition adverse to quality for approximately 22 months, associated with Class 1, 2, and 3 pressure boundary leakage. Specifically,

NCV 05000277/2005003-02, issued in July 2005, documented a delayed operability determination due to the station not promptly evaluating a steam leak on a HPCI valve, in accordance with the site procedures. A contributing cause was the inconsistent guidance provided by the Technical Requirements Manual (TRM) and the Operability Determination procedure. The TRM allowed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to evaluate the structural integrity of the boundary, while the procedure required that the system be declared inoperable immediately. In July 2005, the licensee initiated a condition report to evaluate the difference, and determined that one of the corrective actions was to revise the TRM to be consistent with the procedure. During this inspection, the team determined the TRM had not been revised . The performance deficiency has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because Exelon did not take appropriate corrective actions to address a safety issue in a timely manner, commensurate with its safety significance and complexity. P.1(d)

The finding is more than minor because it affects the procedure quality attribute associated with the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events; in that, operators were provided with conflicting guidance for response to Class 1, 2, and 3 component pressure boundary leaks. The finding is of very low safety significance because the finding was not a design or qualification deficiency, did not represent a loss of system safety function, and was not risk significant due to external initiating events.

(Section 4OA2.a(3)(b))

b.

Licensee-Identified Violations

None iii

REPORT DETAILS

4OA2 Problem Identification and Resolution (PI&R) (Biennial - IP 71152B)

a.

Assessment of the Corrective Action Program

(1) Inspection Scope The inspection team reviewed the procedures describing the corrective action program (CAP) at Exelons Peach Bottom Atomic Power Station (PBAPS). Exelon identifies problems by initiating Issue Reports for conditions adverse to quality, plant equipment deficiencies, industrial or radiological safety concerns, and other significant issues. The Issue Reports are subsequently screened for operability, categorized by priority (1 to 5)and significance (A through D), and assigned for evaluation and resolution; after the Issue Reports are screened, they result in Action Requests and other assignments. The Issue Reports and Action Requests are collectively referred to as Condition Reports (CRs).

The team reviewed CRs selected across the seven cornerstones of safety in the NRCs Reactor Oversight Program (ROP) to determine if problems were being properly identified, characterized, and entered into the CAP for evaluation and resolution. The team selected items from the maintenance, operations, engineering, emergency preparedness, physical security, radiation safety, training, and oversight programs to ensure that Peach Bottom was appropriately considering problems identified in each functional area. The team used this information to select a risk-informed sample of CRs that had been issued since the last NRC PI&R inspection, which was conducted in July 2005.

The team selected items from other processes, to verify that Peach Bottom appropriately considered these items for entry into the CAP. Specifically, the team reviewed a sample of engineering requests, training work requests, maintenance work requests, operator log entries, control room deficiency and operator work-around lists, operability determinations, engineering system health reports, completed surveillance tests, and current temporary configuration change packages. In addition, the team interviewed plant staff and management to determine their understanding of and involvement with the CAP at Peach Bottom. The CRs and other documents reviewed, and a list of key personnel contacted, are listed in the Attachment to this report.

The team considered risk insights from the NRCs and Peach Bottoms risk analyses to focus the sample selection and plant tours on risk-significant components. The team determined that the highest risk-significant systems were the 4160 volt alternating current (vac) emergency buses, 125 volt direct current (vdc) electrical distribution system, the reactor core isolation cooling (RCIC) and high pressure coolant injection (HPCI) systems, the 13 kvac (kilo volt ac) system, and the emergency diesel generators (EDGs). For the selected risk-significant systems, the team reviewed the applicable system health reports, a sample of work requests and engineering documents, plant log entries, and results from surveillance tests and maintenance tasks.

The team reviewed the CRs to assess whether Peach Bottom adequately evaluated and prioritized the identified problems. The CRs reviewed encompassed the full range of Peach Bottoms evaluations, including root cause analyses (RCA), apparent cause evaluations (ACE), common cause analyses, and work group evaluations. The review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of the resolutions. For significant conditions adverse to quality, the team reviewed the effectiveness of the corrective actions to preclude recurrence. The team observed meetings of the Station Oversight Committee (SOC -

in which Peach Bottom personnel reviewed new CRs for prioritization, and evaluated preliminary corrective action assignments, analyses, and plans) and the Management Review Committee (MRC - where senior managers reviewed new Significance Level 1-3 CRs, all completed RCAs, and selected ACEs). The team also reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems. The team assessed the backlog of corrective actions in the maintenance, engineering, and operations departments, to determine, individually and collectively, if there was an increased risk due to delays in implementation of corrective actions. The team further reviewed equipment performance results and assessments documented in completed surveillance procedures, operator log entries, and trend data to determine whether the equipment performance evaluations were technically adequate to identify degrading or non-conforming equipment.

The team reviewed the corrective actions associated with selected CRs to determine whether the actions addressed the identified causes of the problems. The team reviewed CRs for significant repetitive problems to determine whether previous corrective actions were effective. The team also reviewed Peach Bottoms timeliness in implementing corrective actions. The team reviewed the CRs associated with selected non-cited violations (NCVs) and findings (FINs) to determine whether Peach Bottom properly evaluated and resolved these issues.

(2) Assessment Identification of Issues No findings of significance were identified in the area of identification of issues. The team considered the identification of equipment deficiencies at Peach Bottom to be adequate. There was a low threshold for the identification of individual issues, approximately 10,000 CRs were written per year. The housekeeping and cleanliness of the plant was generally good, although the team observed a few minor exceptions. For example, the team noted that the area under two of the EDGs had considerable accumulation of oil, making it difficult for personnel to trend an existing leak or determine if a new leak developed. The conditions did not affect the equipment of the surrounding area. Also, the team identified oily rags left on top of radioactive material barrels in a locked tool cage, a potential fire hazard. However, the general cleanliness enhanced the ability of personnel to easily identify equipment deficiencies and monitor equipment for worsening conditions.

The team noted that trending of individual deficiencies at Peach Bottom had resulted in the identification of negative performance trends in several area. Specifically, in the area of foreign material exclusion (FME) control, configuration control, and the control of contractors.

Prioritization and Evaluation of Issues No findings of significance were identified in the area of prioritization and evaluation of issues. The team determined that Peach Bottoms performance in this area was adequate. The station screened the CRs appropriately and properly classified them for significance. There were no items in the operations, engineering, or maintenance backlogs that were risk significant, individually or collectively. The team considered the contributions of the SOC and MRC to add value to the CAP process. The discussions about specific topics were detailed, and there were no classifications or immediate operability determinations with which the team disagreed.

The quality of the causal analyses reviewed was good, in that the technical depth to identify the cause and the extent of condition reviews supported the determination.

Those performed in the latter part of the inspection period showing improved quality.

For example, the RCA for the failure of a primary containment isolation valve in the Unit 3 HPCI turbine drain line was of a high quality (CR 475597).

However, the engineering technical evaluation documentation to support a temporary modification of a Unit 3 reactor recirculation pump did not adequately address safety questions identified by the team. An abnormal operating procedure (AO-2A.16-3, Manual Adjustment of Recirculating Pump Seal Second Stage Pressure) had been revised to allow the continuos venting of the pump mechanical seals while at power.

The teams specific questions included environmental qualification challenges created by the venting, offsite and occupational dose consequences, and the impact of the venting on the recirculation pump seal pressure indication in the main control room. In addition, the team questioned why a 10CFR50.59 evaluation/screening had not been performed for the procedure change. Exelon revised the technical evaluation, including revising the 10CFR50.59 evaluation that had been performed in the early 1990s to address the current conditions. The team reviewed the revised evaluation and the 50.59 screening and found them acceptable. In addition, the evaluation/screening conducted after the teams questions revealed that NRC prior approval was not required.

Effectiveness of Corrective Actions There were two Green violations identified in the area of effectiveness of corrective actions, both involving the failure of Exelon to correct previous NRC-identified NCVs in a timely manner. Specifically, Exelon failed to revise a quarterly surveillance test procedure for the HPCI system after it was identified in March 2006 that the procedure contained non-conservative acceptance criteria; and Exelon failed to revise the Technical Requirements Manual (TRM) to be consistent with the operability determination procedure, after the inconsistent guidance contributed to a delayed evaluation in July 2005.

In general, the team concluded that corrective actions were adequate and completed in a timely manner. For significant conditions adverse to quality, corrective actions were identified to prevent recurrence. Also, the team noted a decreasing (improving) trend in the number of backlogged items.

However, the team identified that corrective actions were not taken for two of the fourteen NCVs issued since the last PI&R inspection. Exelon has placed the specific issues in the CAP and has communicated the issue to the other Exelon plants. The two instances involved the following non-cited violations:

C NCV 2005003-02, Delayed Inoperability Declaration When Activities Affecting Quality Were Not Accomplished in Accordance with Site Procedures - The performance deficiency was a failure to follow the operability determination procedure; instead, the operators referenced the TRM which had a non-conservative time (as compared to the procedure) to declare the HPCI system inoperable. The corrective actions proposed by Exelon included revising the TRM to be consistent with the procedure. As of this PI&R inspection (2 years later) the TRM had not been changed. The failure to correct the condition is being characterized as a NCV in this report, refer to Section 4OA2.a(3)(b) for more details.

C NCV 2006009-01, Non-Conservative HPCI and RCIC Pumps Test Acceptance Criteria - The performance deficiency was that the licensee did not set the HPCI and RCIC pump test acceptance criteria so that they would be capable of providing design basis flow during all accident conditions. The inadequate test is a quarterly Technical Specification (TS) surveillance which has been performed thirteen time since the 2006 inspection and the acceptance criteria have not been revised. The failure to correct the condition is being characterized as an NCV in this report, refer to Section 4OA2.a(3)(a) for more details.

In addition, the team identified that the tracking documentation for two other previously identified NCVs were less than thorough in documenting action competition. Those two examples involved the following NCVs:

C NCV 2006003-02, Inadequate Accomplishment of FME Integrity Recovery Procedures Following Identification of FME in the U3 HPCI Turbine Exhaust Drain Piping - The performance deficiency was the failure of the FME evaluations to prevent reoccurrence, after similar instances had occurred at Unit 2 in 2004 and at Unit 3 during the 2005 outage. Exelon addressed the technical issue of how FME entered the system (CR 475597), and provided corrective actions to address the FME concerns. However, the CR provided by Exelon did not address the performance deficiency in the inspection report. After questioning by the team, Exelon determined that CRs 533369 and 534509 addressed station-wide FME program trends and concerns. Although the additional CRs were not a direct result of the NCV, the corrective actions addressed the performance deficiency identified in the 2006003 inspection report, and the team concluded that the performance deficiency had been corrected.

C NCV 2006005-01, "Failure to Follow Operability Determination Procedure" - The performance deficiency was a failure to follow procedures that resulted in a determination that did not provide a reasonable expectation of operability.

Engineering management had provided to their staff, via emails, corrective actions to improve the technical quality of operability determinations. The corrective actions had not been promulgated to the engineering or operations staffs in a procedure to ensure longer term implementation. After discussion with the team, Exelon formalized the additional requirements by incorporating them into a Peach Bottom specific Technical and Reference Manual (T&RM) procedure; the team concluded that the issue was minor and the deficiency was corrected.

(3) Findings

(a) Failure to Correct a 2006 NRC-Identified NCV in a Timely Manner - Surveillance Test with Non-Conservative Acceptance Criteria for the HPCI Pump

Introduction:

The NRC identified a Green NCV of 10CFR50, Appendix B, Criterion XVI, Corrective Actions, related to the failure to correct the performance deficiency identified in NCV 05000277,278/2006009-01, Non-Conservative HPCI and RCIC Pumps Test Acceptance Criteria. The team identified that the licensee had not revised the HPCI surveillance test and had continued to conduct the surveillance, thirteen additional times since the issue was discovered by the NRC in March 2006. The original violation was that the acceptance criteria in the surveillance test did not ensure that the system design basis requirements could be met under all accident conditions.

Description:

In March 2006, an NRC engineering inspection determined that the surveillance test procedure met the TS Surveillance Requirement (TSSR) and the ASME Section XI requirements. However, the test did not demonstrate that the pump met certain design bases requirements. This generic issue was promulgated to the industry in NRC Information Notice 97-90, Use of Non-Conservative Acceptance Criteria in Safety Related Pump Surveillance Tests, and in NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants. If the HPCI pump had degraded to the differential pressure acceptance limit, it would not have been able to reach the design basis discharge pressure and flow requirements. Thus, the pump could pass the surveillance test but actually be inoperable. This resulted in a violation of 10CFR50, Appendix B, Criterion XI, Test Control. (NCV 05000277,278/2006009-01, Non-Conservative HPCI and RCIC Pumps Test Acceptance Criteria)

The team reviewed the corrective actions listed in CR 478007 for the RCIC surveillance test. The licensee had evaluated the acceptance criteria for the RCIC pump and determined that they were sufficiently narrow and would not have allowed the RCIC pump to be inadvertently inoperable. With respect to the HPCI procedure, the team reviewed Surveillance Test ST-O-023-301-2, HPCI Pump, Valve, Flow and Unit Cooler Functional and In-Service Test, Revisions 44 and 47. The team discovered that the HPCI pump pressure and flow acceptance criteria had not been revised, and that the test procedure had been run thirteen times since it was in March 2006. The original corrective action, to revise the surveillance procedures for both units, had been characterized in the CAP as an enhancement, and the action was deferred until February 2008, a period of 23 months after the issue was identified to the licensee. The team also noted that the procedures for both units had been revised three times during this period. Considering that this procedure is a TS quarterly surveillance test to establish pump operability and the test has been performed repeatedly with identified less than inadequate acceptance criteria, the team concluded that Exelons corrective actions were untimely.

Exelon performed an evaluation of the HPCI pump surveillance test results. The resulting calculation concluded that the pumps currently had adequate discharge pressure, flow, and speed to meet the design basis requirements. The team reviewed the calculation and concluded that the conclusion was supported.

The performance deficiency associated with this finding is that the licensee did not promptly correct a condition adverse to quality. Specifically, Exelon failed to revise an inadequate TS surveillance test procedure to ensure that the HPCI pump would be capable of providing the required design basis flow during all accident conditions. This deficiency was identified by the NRC in March 2006, during an engineering team inspection, and was documented as NCV 05000277,278/2006009-01.

Analysis:

The finding is more than minor because it affects the procedure quality attribute (pre-event testing procedure) associated with the Mitigating Systems Cornerstone objective to ensure the capability of HPCI, a mitigating system. In accordance with Inspection Manual Chapter (IMC) 0609, Appendix A, Determining the Significance of Reactor Inspection Findings for At-Power Situations, the inspectors conducted a Phase I SDP screening and determined that the finding was Green (very low safety significance) because the finding was not a design or qualification deficiency, did not represent a loss of system safety function, and was not risk significant due to external initiating events.

The performance deficiency has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because Exelon did not take prompt corrective actions to address a safety issue in a timely manner, commensurate with safety significance and complexity. [P.1.(d)]

Enforcement:

10CFR50 Appendix B, Criterion XVI, Corrective Actions, requires that conditions adverse to quality be promptly identified and corrected. Contrary to the above, between March 2006 and April 2007, Exelon failed to revise the acceptance criteria in surveillance test procedures ST-O-023-301-2/3, HPCI Pump, Valve, Flow and Unit Cooler Functional and In-Service Test, for the HPCI systems at both units, such that they met design basis requirements. This was identified by the NRC in March 2006, and was documented as NCV 05000277,278/2006009-01. Exelon initiated CRs 630832 and 630385 to address this issue, and plans to revise the procedures for both units before the next performance of the quarterly surveillance test. Because this finding was of very low safety significance (Green), and was entered into Exelons corrective action program, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000277, 278/2007006-01, Failure to Correct a 2006 NRC-Identified NCV in a Timely Manner - Quarterly Surveillance Test with Non-Conservative Acceptance Criteria for the HPCI Pump)

(b) Failure to Correct an 2005 NRC-Identified NCV in a Timely Manner - Failure to Follow a Site Procedure Results in a Delayed Operability Determination

Introduction:

The NRC identified a Green NCV of 10CFR50, Appendix B, Criterion XVI, Corrective Action, for failure to correct a condition adverse to quality for approximately two years, associated with Class 1, 2, and 3 pressure boundary leakage. Specifically, NCV 05000277/2005003-02, issued in July 2005, documented a delayed operability determination due to the station not promptly evaluating a steam leak on a HPCI valve, in accordance with the site procedures.

Description:

In July 2005, the NRC issued a violation of 10CFR50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Peach Bottom did not appropriately evaluate operability, in accordance with the prescribed station procedure, LS-AA-105, Operability Determinations, Revision 1, for a steam leak from the Unit 2 HPCI steam admission valve. Specifically, procedure LS-AA-105 stated that upon discovery of leakage from a Class 1, 2, or 3 component pressure boundary, the associated component was inoperable. (NCV 05000277/2005003-02, Delayed Inoperability Declaration When Activities Affecting Quality Were Not Accomplished in Accordance with Site Procedures)

The steam leak was identified by an equipment operator (EO) on April 20, 2005, who assumed the steam was due to a packing leak. The leak was entered into the CAP, and the valve was considered to be operable since the packing leak did not appear to be affecting HPCI or any adjacent components. On April 21, 2005, the HPCI System Manager and the Motor Operated Valve (MOV) Program Manager inspected the valve, and identified that the leak was not a packing leak, but was through the leak-off plug.

The actual location of the leak was discussed with operations shift personnel and engineering management; however, the original CR was not revised to correct the location of the leak, nor was a new CR initiated. A new operability determination was considered, but was determined to not be needed. On April 25, 2005, the ASME Code Program Manager determined that the leakage was through the Class 2 pressure boundary.

The Operations shift reviewed the TRM, Specification 3.10, Structural Integrity, and determined that Peach Bottom had 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to evaluate the structural integrity of this Class 2 boundary - and therefore the operability of the HPCI system. About four hours later, after engineering and regulatory affairs personnel informed Operations of the more limiting requirement in the procedure, the Unit 2 HPCI system was declared inoperable (Technical Specifications 3.5.1). The decision was based on a review of LS-AA-105, Operability Determinations, Step 4.5.10.5, which stated that, upon discovery of leakage from a Class 1, 2, or 3 component pressure boundary declare the component inoperable. The licensee initiated CR 328880, Evaluate Difference Between TRM 3.10 and LS-AA-105.

The July 2005 NRC inspection report identified the performance deficiency as a failure to accomplish activities affecting quality in accordance with station procedure LS-AA-105. The NCV cited 10CFR50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, as the requirement that was not met.

During this inspection, the team reviewed the applicable CRs (326706, 328735, 328880, 348745, 352391, and 430384), as provided by Exelon. CR 328880 was generated to revise the TRM to include the requirements of LS-AA-105, with an original due date of July 29, 2005. In addition, the ACE performed as a result of CR 352391, noted that the differences between the TRM and procedure contributed to the delay in declaring the system inoperable. The corrective action for this was an emphasis on the existing assignment in CR 328880, with a due date of February 3, 2006. The inspectors noticed that the original assignment was classified as an ACIT (administrative task) while the ACE recommended that the assignment be classified as a CA (corrective action). The due date was extended at least nine times between the initiation of the assignment and this inspection. In addition, Exelon conducted a self-assessment prior to the start of this inspection and identified that the assignment had been closed without the action being taken and without justification as to why it was closed. CR-590772 was written on February 13, 2007, and the original assignment was re-opened. At the beginning of the inspection, the due date was April 5, 2007. During this inspection, the due date was changed to April 15, 2007. As of the exit, the TRM had not been revised and the difference between the two documents continued to exist.

As an interim corrective action, Exelon had conducted limited training for some Engineering and Operations personnel relative to following the requirements of LS-AA-105. In addition, the Operability Determination procedure was changed from a Licensing document (LS-AA-105) to an Operations document (OP-AA-108-115).

The performance deficiency is a failure to correct a condition adverse to quality in a timely manner, associated with Class 1, 2, and 3 pressure boundary leakage.

Specifically, Exelon failed to revise the TRM to be consistent with the requirements of LS-AA-105, Operability Determinations. The deficiency was originally identified in July 2005, in NRC Inspection Report 05000277/2005003, as a NCV; and it was reasonable to correct this deficiency, because it was likely that the procedure would be used in this time frame..

Analysis:

The finding is more than minor because it affects the procedure quality attribute associated with the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences; in that, operators were provided with conflicting guidance for response to Class 1, 2, and 3 component pressure boundary leaks. The inspectors conducted a Phase I SDP screening in accordance with IMC 0609, Appendix A, Determining the Significance of Reactor Inspection Findings for At-Power Situations, and determined that the finding was Green (very low safety significance)because the finding was not a design or qualification deficiency, did not represent a loss of system safety function, and was not risk significant due to external initiating events.

The performance deficiency has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because Exelon failed to take appropriate corrective actions to address a safety issue in a timely manner, commensurate with its safety significance and complexity. P.1(d)

Enforcement:

10CFR50, Appendix B, Criterion XVI, Corrective Action, requires that conditions adverse to quality be promptly identified and corrected. Contrary to the above, between July 2005 and April 2007, Exelon failed to implement corrective actions in a timely manner for a contributing cause for NCV 05000277/2005003-02.

Specifically, the July 2005 NCV noted that the operators were slow in making an operability determination, in part due to inconsistent information in the TRM and the Operability Determination procedure (LS-AA-105) concerning Class 1, 2, and 3 pressure boundary leakage. Approximately two years after the 2005 NCV was issued, Exelon had not revised the TRM to be consistent with the procedure. Exelon initiated CRs 622468, 630378, and 630385 to address this issue, and plans to revise the TRM to be consistent with the procedure. Because this finding was of very low safety significance (Green), and was entered into Exelons correction action program, this violation is being treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy.

(NCV 05000277/2007006-02, Failure to Correct a 2005 NRC-Identified NCV in a Timely Manner - Failure to Follow a Site Procedure Resulted in a Delayed Operability Determination)b.

Assessment of the Use of Operating Experience

(1) Inspection Scope The team reviewed a sample of operating experience (OE) issues for applicability to Peach Bottom, and for the associated actions. The documents were reviewed to ensure that underlying problems associated with each issue were appropriately considered for resolution in accordance with the corrective action process. The team also reviewed a sample of action plans for Maintenance Rule 10CFR50.65(a)(1) systems, to see how operating experience was used. The team conducted a five year review of equipment issues associated with the EDGs, and reviewed the licensees efforts to evaluate, trend, monitor, and correct issues with this equipment.

(2) Assessment No findings of significance were identified in the area of prioritization and evaluation of issues. The use of OE at Peach Bottom was generally effective. The OE issues were reviewed for applicability to Peach Bottom and CRs were written, as needed, to request additional reviews and develop necessary corrective actions. The station has a daily OE moment at the Plan-of-the-Day meeting, and has incorporated the use of OE into pre-job briefs for maintenance work packages, and into training materials.

Examples of prompt and effective use of OE included CRs 628251 and 628341, which captured In-Service Inspection issues raised by the NRC at another Exelon station.

These issues were reviewed for applicability and resolved at Peach Bottom well before industry OE or NRC Generic Communications were developed.

c.

Assessment of Self-Assessments and Audits

(1) Inspection Scope The team reviewed a sample of Nuclear Oversight (NOS) audits, including the most recent audit of the CAP, the CAP trend reports, and departmental self-assessments.

The team specifically reviewed the Exelon Fleet Safety Culture Assessment Report.

This review was performed to determine if problems identified through these evaluations were entered into the CAP system, and whether the corrective actions were properly completed to resolve the deficiencies. The effectiveness of the audits and self-assessments was evaluated by comparing audit and self-assessment results against self-revealing and NRC-identified findings, and observations during the inspection.

(2) Assessment No findings of significance were identified in the area of audits and self-assessments.

The team considered the quality of the NOS audits to be thorough and critical, CRs were initiated for all issues identified by NOS. In addition, the self-assessments were acceptable; but, they were not at the same level of quality as the audits.

The team reviewed the results of the Peach Bottom Nuclear Safety Culture Survey Results Report, conducted in December 2006. The survey consisted of a safety culture survey and interviews. The report identified some minor weaknesses at the station, which were entered into the CAP. The team did not identify any results that were inconsistent with Exelons conclusions.

d.

Assessment of Safety Conscious Work Environment

(1) Inspection Scope During interviews with many of the station personnel, the team assessed the safety conscious work environment (SCWE) at Peach Bottom. Specifically, the team interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC, due to a fear of retaliation. The team also interviewed the station ECP coordinator to determine if employees were aware of the program and had used it to raise concerns. The team reviewed a sample of the ECP files to ensure that issues were entered into the corrective action program, as appropriate.

(2) Assessment No findings of significance were identified. The team determined that the plant staff were aware of the importance of having a strong SCWE and expressed a willingness to raise safety issues. No one interviewed indicated that they had experienced retaliation for rasing safety issues, or indicated that they knew of anyone who did not raise safety issues. All persons interviewed demonstrated had an adequate knowledge of the CAP and ECP. Based on these interviews, the team concluded that there was not evidence of an unacceptable SCWE.

4OA6 Meetings, Including Exit:

On May 18, 2007, the team presented the inspection results to Mr. Michael Massaro, Peach Bottom Plant Manager, and to other members of the Peach Bottom staff, who acknowledged the findings. The team confirmed that no proprietary information reviewed during the inspection was retained.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

C. Behrend - Director, Site Engineering

P. Breidenbagh - Operations Services Manager

S. Craig - Acting Security Manager

D. Foss - Senior Regulatory Engineer

J. Glunt - Nuclear Oversight Manager

J. Grimes - Site Vice President

D. Henry- Manager, Systems Engineering, NSSS

J. James - Maintenance Supervisor

J. Jordan - Design Engineering Manager, Mechanical

J. Kozakowski - Recirculation System Manager

D. Lewis - Director, Operations

M. Massaro - Plant Manager

D. McClellen - Station Corrective Action Program Coordinator (CAPCo)

S. Mokkapati - Recirculation System Manager

P. Navin - Senior Manager, System Engineering

J. Neff- Maintenance Supervisor

K. Pedersen - Employee Concerns Investigator

A. Piha - Manager, System Engineering, Balance of Plant

P. Rau - Senior Manager, Modification Design

A. Sherwood - Lead Assessor, NOS

S. Taylor - Radiation Protection Manager

W. Trump - Manager, Regulatory Assurance (acting)

T. VanWyen - Operations Training Manager

D. Wheeler - SHIP Program Manager

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

050000277/2007006-01 NCV Failure to Correct a 2006 NRC-Identified NCV in a Timely

050000278/2007006-01 Manner - Quarterly Surveillance Test with Non-Conservative Acceptance Criteria for the HPCI Pump (Section 4OA2.a(3)(a))

050000277/2007006-02 NCV Failure to Correct a 2005 NRC-Identified NCV in a Timely Manner - Failure to Follow a Site Procedure Resulted in a Delayed Operability Determination (Section 4OA2.a(3)(b))

Discussed

05000277/2005003-02 NCV Delayed Inoperability Declaration When Activities Affecting Quality Were Not Accomplished in Accordance with Site Procedures (Sections 4OA2.a(2) and 4OA2.a(3)(b))

05000278/2006003-02 NCV Inadequate Accomplishment of FME Integrity Recovery Procedures Following Identification of FME in the U3 HPCI Turbine Exhaust Drain Piping (Section 4OA2.a(2))

05000277/2006005-01 NCV Failure to Follow Operability Determination Procedure (Section 4OA2.a(2))

05000277/2006009-01 NCV Non-Conservative HPCI & RCIC Pumps Test Acceptance

05000278/2006009-01 Criteria (Sections 4OA2.a(2) and 4OA2.a(3)(a))