IR 05000277/2014002

IR 05000277-14-002 & 05000278-14-002, on 01/01/2014 - 03/31/2014; Peach Bottom Atomic Power Station (Pbaps), Units 2 and 3, Integrated Inspection Report

ML14121A474
Person / Time
Site:	Peach Bottom
Issue date:	05/01/2014
From:	Fred Bower Reactor Projects Region 1 Branch 4
To:	Pacilio M Exelon Generation Co, Exelon Nuclear
BOWER, FL
References
Download: ML14121A474 (32)

Text

May 1, 2014

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000277/2014002 AND 05000278/2014002

Dear Mr. Pacilio:

On March 31, 2014, 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 inspection report documents the inspection results, which were discussed on April 11, 2014, with Mr. Pat Navin, Peach Bottom Plant Manager, and other members of your staff.

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

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

Based on the results of this inspection, no findings were identified. However, one licensee-identified violation, which was determined to be of very low safety significance, is listed in this report. However, because of the very low safety significance, and because it is entered into your corrective action program, the NRC is treating the finding as a non-cited violation (NCV),

consistent with Section 2.3.2.a of the NRC Enforcement Policy. If 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 I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the PBAPS.

Additionally, as we informed you in the most recent NRC integrated inspection report, cross-cutting aspects identified in the last six months of 2013 using the previous terminology were being converted in accordance with the cross-reference in Inspection Manual Chapter (IMC) 0310. Section 4OA5 of the enclosed report documents the conversion of these cross-cutting aspects which will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review. 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 NRCs Public Document Room or from the Publicly Available Records component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Fred L. Bower III, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos: 50-277, 50-278 License Nos: DPR-44, DPR-56

Enclosure:

Inspection Report 05000277/2014002 and 05000278/2014002 w/Attachment: Supplementary Information

REGION I==

Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56 Report No.: 05000277/2014002 and 05000278/2014002 Licensee: Exelon Generation Company, LLC Facility: Peach Bottom Atomic Power Station, Units 2 and 3 Location: Delta, Pennsylvania Dates: January 1, 2014 through March 31, 2014 Inspectors: S. Hansell, Senior Resident Inspector B. Smith, Resident Inspector E. Burket, Emergency Preparedness Inspector M. Fannon, Reactor Engineer J. Furia, Senior Health Physicist G. Meyer, Senior Reactor Inspector M. Modes, Senior Reactor Inspector J. Tomlison, Operations Engineer Approved by: Fred L. Bower III, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000277/2014002, 05000278/2014002; 01/01/2014 - 03/31/2014; Peach Bottom Atomic

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

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. No findings were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

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

Other Findings

A violation of very low safety significance that was identified by Exelon was reviewed by the inspectors. Corrective actions taken or planned by Exelon have been entered into Exelons corrective action program (CAP). This violation and the corrective action tracking number is listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 2 began the inspection period at 100 percent rated thermal power (RTP). On January 22, 2014, operators reduced RTP to approximately 89 percent to mitigate lowering intake water level due to frazil ice conditions. The unit was returned to 100 percent RTP later that same day.

On February 28, 2014, operators reduced RTP to approximately 40 percent to perform planned main condenser waterbox cleaning, main turbine control valve testing, control rod scram timing testing, and a control rod pattern adjustment. The unit was returned to 100 percent RTP on March 2, 2014. The unit remained at 100 percent RTP through the end of the inspection period.

Unit 3 began the inspection period at 100 percent RTP. On February 7, 2014, operators reduced RTP to approximately 60 percent to perform planned reactor feed pump (RFP)inspections, main turbine control valve testing, control rod scram timing testing, and a control rod pattern adjustment. The unit was returned to 100 percent RTP on February 10, 2014. On February 23, 2014, operators conducted an unplanned power reduction to approximately 25 percent after identifying arcing and sparking on the main generator 3G3 disconnect. The unit was returned to 100 percent RTP on February 26, 2014. The unit remained at 100 percent RTP through the end of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Emergency Preparedness, and Barrier Integrity

1R01 Adverse Weather Protection

Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

The inspectors performed a review of PBAPSs preparations for the onset of adverse weather and extreme cold conditions on January 8, 2014 and on January 21, 2014. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset and during extreme cold weather conditions. The inspectors walked down the emergency diesel generator (EDG) enclosure, the river water intake structure, and cooling ponds to ensure system availability. The inspectors verified that operator actions defined in PBAPSs adverse weather procedure maintained the readiness of essential systems. The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

Unit 2 reactor core isolation cooling (RCIC) with high-pressure coolant injection (HPCI) out of service (OOS) on January 14, 2014 E-3 and E-4 EDGs with Unit 3 HPCI OOS on January 21, 2014 E-1, E-2, E-3, and E-4 EDGs during extreme cold weather on January 28, 2014 Unit 3 electrohydraulic control (EHC) system following pressure fluctuations on February 20, 2014 Unit 3 north switchyard after damage to the 3G3 main generator disconnect on February 24, 2014 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), condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether PBAPS staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

.2 Full System Walkdown

a. Inspection Scope

On March 3 - 7, 2014, the inspectors performed a complete system walkdown of accessible portions of the Unit 2 HPCI system to verify the existing equipment lineup was correct. The inspectors performed field walkdowns of accessible portions of the system to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies.

Additionally, the inspectors reviewed a sample of related CRs and WOs to ensure PBAPS appropriately evaluated and resolved any deficiencies.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Resident Inspector Quarterly Walkdowns

a. Inspection Scope

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

Unit 2 and Unit 3 cable spreading and computer rooms on March 3, 2014 Unit 2 HPCI room on March 4, 2014 Unit 3 HPCI room on March 5, 2014 Unit 2 and Unit 3 control rooms on March 26, 2014

b. Findings

No findings were identified.

.2 Fire Protection - Drill Observation

Inspection Scope The inspectors observed two fire brigade drill scenarios conducted on February 21, 2014, and on February 26, 2014, that simulated fires in the Unit 2 turbine building. The simulated fires were staged on elevation 165 in the A RFP hydraulic power unit (HPU)area, and in the B RFP HPU area. The inspectors evaluated the fire brigades initial response time, proper retrieval of required gear and equipment, and implementation of fire-fighting strategies. The inspectors verified that PBAPS personnel identified deficiencies, openly discussed them in a self-critical manner at the debrief, and took appropriate corrective actions to improve performance. The inspectors evaluated specific attributes as follows:

Proper use of turnout gear and self-contained breathing apparatus Employment of appropriate fire-fighting techniques Sufficient fire-fighting equipment brought to the scene Effectiveness of command and control Search for victims and propagation of the fire into other plant areas Smoke removal operations Utilization of pre-planned strategies Adherence to the pre-planned drill scenario Drill objectives met

b. Findings

No findings were identified.

1R06 Flood Protection Measures

Internal Flooding Review

a. Inspection Scope

The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to assess susceptibilities involving internal flooding. The inspectors also reviewed the CAP to determine if PBAPS identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors focused on the Unit 2 high pressure service water (HPSW) pump room in the inner river water intake structure on January 13, 2014, to verify the adequacy of equipment seals located below the flood line during the Unit 2 B HPSW pump motor replacement with the pump uncoupled. The inspectors also verified the adequacy of the watertight door seals, sump pumps, and room flooding alarms.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Quarterly Review of Licensed Operator Requalification Testing and Training (1 sample)

a. Inspection Scope

The inspectors observed a licensed operator annual requalification simulator exam on March 5, 2014, which included a simulated plant event related to a loss of offsite power combined with the failure of the RCIC system to inject water into the vessel as well as the unavailability of the HPCI system, necessitating operators to perform an emergency blowdown. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of emergency classifications made by the shift manager and the TS action statements entered by the shift technical advisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

b. Findings

No findings were identified.

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

(2 samples)

a. Inspection Scope

The inspectors observed licensed operator performance during non-routine reactivity manipulations on two occasions in the Unit 2 and Unit 3 main control room. On January 22, 2014, the inspectors observed a Unit 2 reactor power reduction to 89 percent RTP. Reactor power was reduced due to the removal of the Unit 2 A and B circulating water (CW) cooling pumps. The two CW pumps were stopped when the outer intake river water level lowered due to blockage caused by the formation of frazil ice conditions. After removal of the frazil ice from the water intake area, the A and B CW pumps were restarted and reactor power was increased to 100 percent.

On February 23 - 24, 2014, the inspectors observed a Unit 3 reactor power reduction to 25 percent RTP, and the removal of the Unit 3 main generator from service due to a turbine bearing high vibration condition. The inspectors observed reactivity manipulations to verify that they were performed in a safe and controlled manner, and included the appropriate level of peer verification and supervisory oversight.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structures, systems, and components (SSCs) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance WOs, and maintenance rule (MR) basis documents to ensure that PBAPS was identifying and properly evaluating performance problems within the scope of the MR. For each sample selected, the inspectors verified that the SSC was properly scoped into the MR in accordance with Title 10 Code of Federal Regulation (CFR) 50.65 and that the (a)

(2) performance criteria established by the PBAPS staff were reasonable. As applicable, for SSCs classified as (a) (1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)

(2) status.

Additionally, the inspectors ensured that PBAPS staff was identifying and addressing common cause failures that occurred within and across MR system boundaries.

Unit 2 HPSW functional failure review on January 29 - 31, 2014 E-2 EDG planned overhaul and restoration on March 10 - 12, 2014 Unit 3 A core spray (CS) pump functional failure review on March 10 - 14, 2014 Unit 2 reactor manual control system functional failure review on March 17, 2014

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that PBAPS performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the Reactor Safety cornerstones. As applicable for each activity, the inspectors verified that PBAPS personnel performed risk assessments as required by 10 CFR 50.65(a)

(4) and that the assessments were accurate and complete. When PBAPS performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

Unit 3 yellow risk, HPCI unavailable on January 13 - 16, 2014 Unit 2 orange risk, maximum generation action and HPCI unavailable on January 23, 2014 Unit 2 and Unit 3 orange risk, maximum generation action and station blackout (SBO) generator OOS on January 30, 2014 Unit 3 yellow risk, B residual heat removal (RHR) unavailable on February 18 - 21, 2014 Unit 3 green risk, 500 kV 3G3 disconnect damage prior to a power reduction on February 23, 2014 Unit 2 and Unit 3 yellow risk, E-2 EDG 6-year preventative maintenance and a Power Team Generation Dispatch action on March 4, 2014

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

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

Unit 3 A RHR pump valve and flow test acceptance criteria data on January 2, 2014 Unit 2 RCIC steam void on January 30, 2014 Unit 3 noble metal injection flow into the reactor coolant system and minor reactor power oscillation on February 2, 2014 Unit 2 and Unit 3 secondary containment operability during inadvertent short duration opening of multiple reactor building doors on February 3, 2014 Unit 2 A HPSW piping minimum wall thickness exceeded during ultrasonic testing (UT) on February 12, 2014 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the ODs to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to PBAPSs evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by PBAPS. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

b. Findings

No findings were identified.

1R18 Plant Modifications

a. Inspection Scope

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

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

A1856813, Place Heating Blanket on Emergency Service Water and HPSW Piping, on February 11 - 12, 2014 A1580120-28, Containment Atmosphere Dilution Tank Drained, on March 24 - 27, 2014

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

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

ST-O-023-301-2, HPCI Pump, Valve, and Flow Functional and Inservice Test (IST),

Revision 66, following maintenance outage on Unit 2 HPCI on January 16, 2014 ST-O-032-301-2, HPSW Pump, Valve, and Flow Functional and IST, Revision 28, following motor replacement on Unit 2 B HPSW on January 29, 2014 ST-O-51H-200-2, SBO Line Operability Verification, Revision 14, following fuse replacement on January 31, 2014 ST-O-014-301-3, CS Pump, Valve, Flow and Cooler Functional and IST, Revision 35, following breaker maintenance on Unit 3 A CS on February 11, 2014 ST-O-010-306-3, RHR Loop, Pump, Valve, Flow, and Unit Cooler Functional and IST, Revision 38, following maintenance outage on Unit 3 B RHR on February 20, 2014 ST-O-052-202-2, E-2 Diesel Generator Slow Start and Full Load Test, following 6-year preventative maintenance outage on March 9 - 10, 2014

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

(3 routine surveillances; 2 IST samples)

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

ST-O-013-301-3, Unit 3 RCIC Pump, Valve, and Flow Test, Revision 42, on January 15, 2014 (IST sample)

ST-O-023-301-3, Unit 3 HPCI Pump, Valve, and Flow Test, Revision 62, on January 24, 2014 (IST sample)

RT-O-032-300-3, Unit 3 HPSW Pump, Valve, and Flow Functional Test, Revision 17, on February 7, 2014 ST-I-023-100-3, Unit 3 HPCI Logic System Functional Test (LSFT), Revision 18, on February 12, 2014 ST-I-023-100-2, Unit 2 HPCI LSFT, Revision 18, on February 18, 2014

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

Exelon implemented various changes to the Peach Bottom Emergency Action Levels (EALs), Emergency Plan (EP), and Implementing Procedures. Exelon had determined that, in accordance with 10 CFR 50.54(q)(3), any change made to the EALs, EP, and its lower-tier implementing procedures, had not resulted in any reduction in effectiveness of the Plan, and that the revised Plan continued to meet the standards in 50.47(b) and the requirements of 10 CFR 50 Appendix E.

The inspectors performed an in-office review of all EAL and EP changes submitted by Exelon as required by 10 CFR 50.54(q)(5), including the changes to lower-tier EP Implementing Procedures, to evaluate for any potential reductions in effectiveness of the EP. This review by the inspectors was not documented in an NRC Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The requirements in 10 CFR 50.54(q) were used as reference criteria.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the shift manager\emergency directors EP implementation during a licensed operator annual requalification simulator exam on March 5, 2014. The inspectors observed emergency response operations in the simulator to determine whether event classifications and notifications were performed in accordance with approved procedures. The inspectors also attended the control room simulator drill critique to compare inspector observations with those identified by PBAPS staff in order to evaluate whether PBAPS staff was properly identifying emergency preparedness weaknesses and entering them into the CAP.

b. Findings

No findings were identified.

2RS1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

During the week of January 13 - 17, 2014, the inspectors reviewed PBAPSs performance in assessing the radiological hazards in the workplace associated with licensed activities and the implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures. The inspectors verified that PBAPS is properly identifying and reporting performance indicators (PIs) for the Occupational Radiation Safety cornerstone and identifying those performance deficiencies that were reportable as a PI and which may have represented a substantial potential for overexposure of the worker. The inspectors used the requirements in 10 CFR Part 20 and guidance in Regulatory Guide (RG) 8.38, Control of Access to High and Very High Radiation Areas for Nuclear Plants, the TSs, and Exelons procedures required by TSs as criteria for determining compliance.

Radiological Hazard Assessment The inspectors determined if, since the last inspection, there have been changes to plant operations that may result in a significant new radiological hazard for onsite workers or members of the public. The inspectors verified the licensee has assessed the potential impact of these changes and has implemented periodic monitoring to detect and quantify the radiological hazard.

The inspectors reviewed radiological surveys from selected plant areas. The inspectors verified that the thoroughness and frequency of the surveys is appropriate for the given radiological hazard.

The inspectors conducted walk downs of the facility, including radioactive waste processing, storage, and handling areas to evaluate material conditions and potential radiological conditions.

Radiological Hazards Control and Work Coverage The inspectors reviewed radiation work permits (RWPs) for work within airborne radioactivity areas with the potential for individual worker internal exposures. The inspectors evaluated airborne radioactive controls and monitoring, including potentials for significant airborne contamination. For these selected airborne radioactive material areas, the inspectors verified barrier integrity and temporary high-efficiency particulate air ventilation system operation.

b. Findings

No findings were identified.

2RS2 Occupational As Low As is Reasonably Achievable Planning and Controls

a. Inspection Scope

During the week of January 13 - 17, 2014, the inspectors assessed performance with respect to maintaining individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspectors used the requirements in 10 CFR Part 20, RG 8.8, Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Plants will be ALARA, RG 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposure ALARA, the TSs, and Exelons procedures required by TSs as criteria for determining compliance.

Radiological Work Planning The inspectors obtained from PBAPS a list of work activities ranked by actual or estimated collective exposure that were in progress or that have been completed during the last outage, and selected work activities of the highest exposure significance.

The inspectors reviewed the ALARA work activity evaluations, exposure estimates, and exposure mitigation requirements. The inspectors determined that PBAPS had reasonably grouped the radiological work into work activities, based on historical precedence, industry norms, and/or special circumstances.

The inspectors verified that PBAPSs planning identified appropriate dose mitigation features; considered commensurate with the risk of the work activity, alternate mitigation features; and defined reasonable dose goals. The inspectors verified that PBAPSs ALARA assessment had taken into account decreased worker efficiency from use of respiratory protective devices and or heat stress mitigation equipment. The inspectors determined that the licensees work planning considered the use of remote technologies as a means to reduce dose and the use of dose reduction insights from industry operating experience and plant-specific lessons learned. The inspectors verified the integration of ALARA requirements into work procedure and RWP documents.

The inspectors compared the results achieved with the intended dose established in the licensees ALARA planning for these work activities. The inspectors compared the person-hour estimates provided by maintenance planning and other groups to the radiation protection group with the actual work activity time requirements, and evaluated the accuracy of these time estimates. The inspectors determined the reasons for any inconsistencies between intended and actual work activity doses. The inspectors focused on those work activities with planned or accrued collective exposure greater than 5 person-rem.

The inspectors determined that post-job reviews were conducted and that identified problems were entered into Exelons CAP.

b. Findings

No findings were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

a. Inspection Scope

During the week of January 13 - 17, 2014, the inspectors verified that in-plant airborne concentrations are being controlled consistent with ALARA to the extent necessary to validate plant operations as reported by the PI and to verify that the practices and use of respiratory protection devices on site do not pose an undue risk to the wearer. The inspectors used the requirements in 10 CFR Part 20, the guidance in RG 8.15, Acceptable Programs for Respiratory Protection, RG 8.25, Air Sampling in the Workplace, NUREG-0041, Manual of Respiratory Protection Against Airborne Radioactive Material, the TSs, and Exelons procedures required by TSs as criteria for determining compliance.

Engineering Controls The inspectors verified that PBAPS used ventilation systems as part of its engineering controls, in lieu of respiratory protection devices, to control airborne radioactivity. The inspectors reviewed procedural guidance for use of installed plant systems, and verified that the systems were used, to the extent practicable, during high-risk activities. The inspectors selected installed ventilation systems used to mitigate the potential for airborne radioactivity, and verified that ventilation airflow capacity, flow path, and filter/charcoal unit efficiencies were consistent with maintaining concentrations of airborne radioactivity in work areas below the concentrations of an airborne area to the extent practicable.

The inspectors selected temporary ventilation system setups high-efficiency particulate air used to support work in contaminated areas. The inspectors verified that the use of these systems was consistent with licensee procedural guidance and ALARA.

The inspectors selected installed systems to monitor and warn of changing airborne concentrations in the plant. The inspectors verified that alarms and set-points were sufficient to prompt licensee/worker action to ensure that doses were maintained within the limits. The inspectors verified that the licensee had established action level criteria for evaluating levels of airborne beta-emitting and alpha-emitting radionuclides.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

a. Inspection Scope

During the week of January 13 - 17, 2014, the inspectors determined the accuracy and operability of personal monitoring equipment; determined the accuracy and effectiveness of Exelons methods for determining total effective dose equivalent; and ensured that occupational dose is appropriately monitored. The inspectors used the requirements in 10 CFR Part 20, the guidance in RG 8.13, Instructions Concerning Prenatal Radiation Exposures, RG 8.36, Radiation Dose to Embryo Fetus, RG 8.40, Methods for Measuring Effective Dose Equivalent from External Exposure, TSs, and Exelons procedures required by TSs as criteria for determining compliance.

Internal Dosimetry The inspectors reviewed procedures used to assess dose from internally deposited nuclides using whole body counting equipment. The inspectors verified that the procedures addressed methods for determining if an individual was internally or externally contaminated the release of contaminated individuals, the determination of entry route and assignment of dose.

The inspectors verified that the frequency of such measurements was consistent with the biological half-life of the potential nuclides available for intake.

The inspectors evaluated the minimum detectable activity (MDA) of the instrument. The inspectors determined that the MDA was adequate to determine the potential for internally deposited radionuclides sufficient to prompt additional investigation.

The inspectors verified that the system used in each bioassay had sufficient counting time/low background to ensure appropriate sensitivity for the potential radionuclides of interest. The inspectors verified that the appropriate nuclide library was used. The inspectors verified that any anomalous count peaks/nuclides indicated in each output spectra received appropriate disposition.

The inspectors selected internal dose assessments obtained using in-vitro monitoring.

The inspectors reviewed and assessed the adequacy of PBAPSs program for in-vitro monitoring of radionuclides, including collection and storage of samples.

The inspectors reviewed the counting laboratorys quality assurance program or, if a vendor lab is used, the licensees audits of the lab. The inspectors verified that the lab participated in an analysis cross-check program and that out-of-tolerance results were evaluated and resolved appropriately.

The inspectors reviewed the adequacy of PBAPSs program for dose assessments based on airborne/derived air concentration (DAC) monitoring. The inspectors verified that flow rates and/or collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection are obtained. The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors. The inspectors reviewed dose assessments performed using airborne/DAC monitoring. The inspectors verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture, including hard-to-detect nuclides.

The inspectors reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose equivalent. The inspectors determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

Initiating Events The inspectors reviewed a selected sample of the PBAPSs information submitted for the six initiating events PIs listed below to assess the accuracy and completeness of the data reported to the NRC for these PIs. The PI definitions and the guidance contained in Nuclear Energy Institute 99 02, "Regulatory Assessment Indicator Guideline," Revision 6, and Exelon procedure LS-AA-2001, Collecting and Reporting of NRC PI Data, Revision 14, were used to verify that procedure and reporting requirements were met.

The inspectors reviewed raw PI data collected from January 1, 2013 to December 31, 2013, and compared graphical representations from the applicable PI reports to the raw data to verify the data was included in the report. The inspectors also examined a selected sample of operations logs and plant computer thermal power data trends to verify the PI data was appropriately captured for inclusion into the PI report and that the individual PIs were correctly calculated.

Units 2 and 3 Unplanned Scrams per 7,000 Critical Hours (IE01)

Unplanned Scrams with Complications (IE04)

Unplanned Power Changes per 7,000 Critical Hours (IE03)

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

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

b. Findings

No findings were identified.

.2 Annual Sample: Instrumentation & Control (I&C) Package Review

a. Inspection Scope

The inspectors reviewed the following Instrumentation and Controls (I&C) surveillance tests (STs): ST-I-37G-393-2, E-3 Diesel Generator Cardox System Simulated Actuation and Air Flow Test, Revision 8; SI3A-2-ECCS-A2FQ, Functional Test of ECCS A/C-2 Card File Test, Revision 12; ST-I-03B-100-2, ARI\RPT Channel A Logic System Functional Test, Revision 7; ST-I-01G-100-3, Automatic Deppressurization System (ADS) Channel A Logic System Functional Test, Revision 7, and AR 1636046, which documented station documents that were not processed within 30 days as required by station procedures. Exelon procedure HU-AA-104-101, Procedure Use and Adherence, Revision 4, was used to evaluate the I&C STs and associated documentation. The inspectors also interviewed multiple I&C first line supervisors, lead technicians, and the maintenance support manager.

b. Findings and Observations

No findings were identified. The inspectors concluded that the I&C surveillance test performance and associated documentation were performed as required by Exelon procedures and did not include any errors or missing initials\signatures. The completed STs included legible pages, complete supervisor reviews of the data, and final approval documentation. The completed STs included the proper documentation of all independent and concurrent verification steps. The inspectors verified that the safety-related and risk significant equipment was tested properly and documented the continued operability and availability.

.3 Annual Sample: Station Planning Work Package Closure Review (1 sample)

a. Inspection Scope

The inspectors reviewed the following IRs and ARs: 1587659, 1576269, 1300314, 1618337, 1445306, and 1300314, which documented station planning work package closure errors. Specific document errors identified in the IRs included missing signatures, illegible in-field procedures, and incomplete supervisor reviews of work packages. The inspectors reviewed a selected sample of safety-related and risk significant surveillances, tests, and WOs from 2010 through March 2014. The inspectors also interviewed multiple first line supervisors in mechanical and electrical maintenance, lead technicians, and the manager of station planning.

b. Findings and Observations

No findings of significance were identified. The inspectors concluded that work package closeout has been an issue of concern for the station and requirements outlined in procedure HU-AA-104-101, Revision 4, Procedure Use and Adherence, had not been followed for all cases. Numerous cases were identified of workers not initialing worker verifications in the hard copy of WOs. First line supervisors had not identified missing initials during post-job closeout reviews. In one case, sections of a procedure were illegible but still implemented in the field. However, the inspectors did not identify an example in which an error significantly impacted safety-related or risk significant equipment. Therefore, the inspectors concluded that the identified errors were of minor significance.

4OA3 Followup of Events and Notices of Enforcement Discretion

Unit 3 3G3 Disconnect Damage and Main Generator Removal from Service

a. Inspection Scope

On February 23, 2014, operators witnessed arcing and sparking in the 500 kV switchyard on the A phase of the Unit 3 main generator disconnect 3G3. To avoid a potential reactor transient from an electrical fault, operators reduced power to 25 percent RTP in order to be below the 29.5 percent turbine trip/RPT scram setpoint and to remove the Unit 3 main generator from service to perform switchyard maintenance activities on February 24, 2014. The inspectors observed control room manipulations during the downpower and witnessed maintenance activities in the 500 kV switchyard to verify these activities were performed in a safe and controlled manner, and included appropriate peer verifications and supervisory oversight.

b. Findings

No findings were identified.

4OA5 Other Activities

.1 Cross-cutting Aspects Table

The table below provides a cross-reference for findings and cross-cutting aspects identified in the last six months of 2013 to the new cross-cutting aspects in Inspection Manual Chapter (IMC) 0310 resulting from the common language initiative. These aspects and any others identified since January 2014 will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review.

Finding Old Cross-Cutting Aspect New Cross-Cutting Aspect 05000277 and H.3.b H.5 05000278/201300401 05000278/201300402 H.3.a H.5

.2 License Renewal Inspection

Commitment 10: Perform a One-Time Inspection of a Cast Iron Fire Protection Component for Selective Leaching

a. Inspection Scope

The objective of the inspection was to assess whether selective leaching existed; selective leaching is the removal of carbon atoms from gray cast iron (graphitization),such that a porous, weakened metal structure remains. During the Unit 2 inspection, PBAPS had established ongoing aging management of selective leaching by means of continued destructive evaluations of fire protection system valves removed from service.

Of an original population of approximately 70 valves, half had been replaced.

Subsequent to the Unit 2 inspection, no additional valve replacements had occurred.

During the Unit 3 inspection, the inspectors reviewed Book 2.9, Fire Protection Activities Aging Management Program Result Binder, Revision 0, and ER-AA-700-401, License Renewal Selective Leaching Program, Draft Revision 0, and discussed this commitment with applicable plant staff and license renewal personnel.

b. Findings

No findings were identified. The inspectors concluded there is reasonable assurance Commitment 10 has been implemented at Peach Bottom Unit 3.

Commitment 14: Perform a One-Time Inspection of Wall Thickness of Selected Torus Piping Prior to the Beginning of the Extended Period of Operation

a. Inspection Scope

Samples meeting the criteria for selection for this commitment were:

HPCI steam exhaust line located in Bay 13 RCIC steam exhaust line located in Bay 12 The inspectors reviewed the results of the ultrasonic inspection and compared the procedural requirements for conformance with American Society of Mechanical Engineers (ASME) requirements. The inspectors noted that readings were taken three inches above the water line and three inches below the water line. The inspectors reviewed calculation summary 131547-02 to establish ultrasonic testing (UT) thickness criteria for Unit 3 "J" and "K" safety/relief valve discharge piping, and HPCI and RCIC turbine exhaust piping. The inspectors compared these values reported by the ultrasonic thickness gauging report 147, dated September 23, 2010, detailing readings for all four locations. The inspectors also reviewed qualifications of nondestructive evaluation technicians, noting one was qualified to ASME Section XI, Appendix VIII, by the Performance Demonstration Initiative administered by the Electric Power Research Institute.

b. Findings

No findings were identified. The inspectors concluded there is reasonable assurance Commitment 14 has been implemented at Peach Bottom Unit 3.

Commitment 17: Perform a One-Time Piping Inspection Activities for Standby Liquid Control System, Auxiliary Steam System, Plant Equipment and Floor Drain System, Service Water, and Radiation Monitoring System Commitment 18: Perform a One-Time Inspection of Susceptible Locations for Loss of Material in the Spent Fuel Pool Cooling System to Verify Effectiveness of Spent Fuel Pool Chemistry Activities Commitment 19: Perform a One-Time Inspection of Carbon Steel Piping for Loss of Material in RPV Instrumentation and Reactor Recirculation System

a. Inspection Scope

The objective of these inspections was to evaluate the loss of material and cracking in piping in various systems; PBAPS chose to perform UT to measure the piping wall thickness and inspect for cracking. During the Unit 2 inspection, PBAPS had completed Unit 2 inspections and determined that three locations merited followup actions, including re-inspection of one location within four years, an expanded extent of condition for one location, and re-evaluation of a location based on future inspections of a similar Unit 3 location. During the Unit 3 inspection, the inspectors reviewed Book 3.4, One-Time Piping Inspection Activities Result Binder, Revision 1, including a summary of inspection results and associated corrective action documents, and discussed this commitment with applicable plant staff and license renewal personnel.

b. Findings

No findings were identified. The inspectors concluded there is reasonable assurance Commitments 17, 18, and 19 have been implemented at Peach Bottom Unit 3.

Program A.2.5, Outdoor, Buried, and Submerged Component Inspections

a. Inspection Scope

As part of the license renewal application, Exelon stated that:

Inspection of the refueling water storage tank (RWST) will be performed as a representative inspection to determine the condition of the underside of the condensate storage tanks (CSTs). This inspection will be a volumetric inspection of the bottom of the RWST for corrosion. Degradation of the RWST noted during this examination will result in the CSTs being inspected for degradation. The following effects are managed:

Loss of material and cracking.

The inspectors reviewed Book 2.5, Outdoor, Buried, and Submerged Component Inspection Activities Result Binder, Revision 1, including RWST inspection results, and discussed this commitment with applicable plant staff and license renewal personnel.

The volumetric inspection was completed on May 14, 2013, under WO R1104905-03, 00T0044: Perform visual inspection and UT testing, which determined that the RWST bottom was acceptable and no additional inspection was merited.

b. Findings

No findings were identified. The inspectors concluded there is reasonable assurance Program A.2.5, Outdoor, Buried, and Submerged Component Inspections, has been implemented at Peach Bottom Unit 3.

4OA6 Meetings, Including Exit

Quarterly Resident

Exit Meeting Summary

On April 11, 2014, the resident inspectors presented the inspection results to Mr. Pat Navin, Peach Bottom Plant Manager, and other PBAPS staff, who acknowledged the findings. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

4OA7 Licensee-Identified Violation

The following violation of very low safety significance (Green) was identified by PBAPS and is a violation of NRC requirements which met the criteria of the NRC Enforcement Policy for being dispositioned as an NCV.

Title 10 of CFR Part 50.65 (a)(4) requires, in part, that before performing maintenance activities (including but not limited to surveillance, PMT, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed activities. Contrary to the above, on January 30, 2014, PBAPS did not initially assess an increase in plant risk resulting in an upgrade in established risk classification from yellow to orange. PBAPSs additional risk management actions, required by procedure, were delayed. On January 30, 2014, at 2:55 am, PBAPS removed their SBO line from service for planned maintenance and upgraded on-line risk to yellow for the duration of the maintenance activity. At 5:55 am, Pennsylvania-Jersey-Maryland (PJM)

Interconnection issued a Maximum Emergency Generation Action for the Mid-Atlantic Region. However, as required, PBAPS was not notified at this time by a Power Team Generation Dispatch. A reactor operator monitoring PJMs website subsequently noticed the Maximum Emergency Generation Action. During a follow-up call to the Power Team Generation Dispatch contact, the Peach Bottom reactor operator was erroneously told that the grid emergency did not apply to nuclear power plants. In accordance with Exelons risk model and procedures, a Maximum Emergency Generation Action requires an upgrade to the next color risk category.

For PBAPSs configuration with the SBO OOS, a risk upgrade from yellow to orange was required. At 7:58 am, PBAPS was notified of the Maximum Emergency Generation Action, identified that their current risk category was incorrect, upgraded the plant risk to orange, and directed the safety tagout clearance on the SBO line to be suspended until the grid emergency was lifted.

PBAPS also identified that this issue was a repeat problem from a similar event on July 18, 2012. This previous event, documented in IR 1389933 and IR 1390285, was for PBAPS not being notified as required of a grid emergency by the Power Team Generation Dispatch.

The inspectors determined that the finding was of very low safety significance (Green) in accordance with Flowchart 1 of Appendix K of IMC 0609, "Maintenance Risk Assessment and Risk Assessment Significance Determination Process, because the incremental core damage probability deficit was significantly less than one E-6. PBAPS was in the less conservative risk category for approximately two hours. The inspectors reviewed PBAPSs planned corrective actions, which were to train power team dispatchers and revise applicable procedures to address the communication problem between generation dispatch and PBAPS. The inspectors considered the planned corrective actions appropriate. Because this finding is of very low safety significance and the issue was entered into Exelon's CAP under IRs 1614646 and 1615043, this violation is being treated as a Green NCV consistent with the NRCs Enforcement Policy.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Exelon Generation Company Personnel

M. Massaro, Site Vice President

P. Navin, Plant Manager

N. Alexakos, Emergency Preparedness Manager

J. Armstrong, Regulatory Assurance Manager

D. Baracco, ALARA Manager

R. Bolding, Respiratory Physicist

B. Reiner, Training Director

B. Hennigan, Operations Training Manager

M. Herr, Operations Director

R. Holmes, Radiation Protection Manager

P. Simmons, Security Manager

T. Moore, Site Engineering Director

M. Weidman, Work Management Director

F. Leone, Chemistry Manager

D. Baracco, Radiological Engineering Manager

D. Striebig, Emergency Preparedness Coordinator

NRC Personnel

F. Bower III, Branch Chief

S. Hansell, Senior Resident Inspector

B. Smith, Resident Inspector

E. Burket, Emergency Preparedness Inspector

M. Fannon, Reactor Engineer

J. Furia, Senior Health Physicist

G. Meyer, Senior Reactor Inspector

M. Modes, Senior Reactor Inspector

J. Tomlison, Operations Engineer

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

None

Opened

None

Closed

None Discussed/Updated None