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#REDIRECT [[IR 05000277/2018002]]
{{Adams
| number = ML18225A086
| issue date = 08/13/2018
| title = Integrated Inspection Report 05000277/2018002 and 05000278/2018002 and Independent Spent Fuel Storage Installation Report 07200029/2018002
| author name = Greives J
| author affiliation = NRC/RGN-I/DRP/PB4
| addressee name = Hanson B
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| docket = 05000277, 05000278, 07200029
| license number = DPR-044, DPR-056
| contact person = Greives J
| document report number = IR 2018002, ISFSI 2018002
| document type = Inspection Report, Letter
| page count = 19
}}
See also: [[see also::IR 05000277/2018002]]
 
=Text=
{{#Wiki_filter:UNITED STATES
                          NUCLEAR REGULATORY COMMISSION
                                            REGION I
                            2100 RENAISSANCE BOULEVARD, SUITE 100
                                  KING OF PRUSSIA, PA 19406-2713
                                        August 13, 2018
Mr. Bryan C. Hanson
Senior Vice President, Exelon Generation Company, LLC
President and Chief Nuclear Officer, Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT:      PEACH BOTTOM ATOMIC POWER STATION - INTEGRATED INSPECTION
              REPORT 05000277/2018002 AND 05000278/2018002 AND INDEPENDENT
              SPENT FUEL STORAGE INSTALLATION REPORT 07200029/2018002
Dear Mr. Hanson:
On June 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at
your Peach Bottom Atomic Power Station (Peach Bottom), Units 2 and 3. On July 13, 2018, the
NRC inspectors discussed the results of this inspection with Mr. Matthew Herr, Plant Manager,
and other members of your staff. The results of this inspection are documented in the enclosed
report.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
The finding involved a violation of NRC requirements. The NRC is treating this violation as a
non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violation or significance of the NCV, you should provide a response within
30 days of the date of this inspection report, with the basis for your denial, 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; and the
NRCs Resident Inspector at Peach Bottom. In addition, if you disagree with a cross-cutting
aspect assignment or a finding not associated with a regulatory requirement in this report, you
should provide a response within 30 days of the date of this inspection report, with the basis for
your disagreement, to the U. S. Nuclear Regulatory Commission, ATTN: Document Control
Desk, Washington, DC, 20555-0001; with copies to the Regional Administrator, Region I, and
the NRCs Resident Inspector at Peach Bottom.
 
B. Hanson                                          2
This letter, its enclosure, and your response (if any) will be made available for public inspection
and copying at http://www.nrc.gov/reading-rm/adams.html and the NRCs Public Document
Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 2.390,
Public Inspections, Exemptions, Requests for Withholding.
                                              Sincerely,
                                                /RA/
                                              Jonathan E. Greives, Chief
                                              Reactor Projects Branch 4
                                              Division of Reactor Projects
Docket Numbers: 50-277 and 50-278
License Numbers: DPR-44 and DPR-56
Enclosure:
Inspection Report 05000277/2018002
  and 05000278/2018002
  and 07200029/2018002
cc w/encl: Distribution via ListServ
 
 
ML18225A086
                                            Non-Sensitive                            Publicly Available
      SUNSI Review
                                            Sensitive                                Non-Publicly Available
  OFFICE        RI/DRP              RI/DRP                RI/DRP
  NAME          JHeinly via email  SBarber              JGreives
  DATE          8/9/18              8/9/18                8/13/18
                                         
                                                1
                          U.S. NUCLEAR REGULATORY COMMISSION
                                        Inspection Report
Docket Numbers:        50-277 and 50-278
License Numbers:      DPR-44 and DPR-56
Report Numbers:        05000277/2018002 and 05000278/2018002 and 07200029/2018002
Enterprise Identifier: I-2018-002-0064
Licensee:              Exelon Generation Company, LLC
Facility:              Peach Bottom Atomic Power Station, Units 2 and 3
Location:              Delta, Pennsylvania
Inspection Dates:      April 1, 2018 to June 30, 2018
Inspectors:            J. Heinly, Senior Resident Inspector
                      B. Smith, Resident Inspector
                      O. Masnyk Bailey, Health Physicist
                      J. Cassata, Health Physicist
                      J. Nicholson, Senior Health Physicist
                      M. Orr, Reactor Inspector
                      A. Turilin, Project Engineer
Approved By:          Jonathan E. Grieves, Chief
                      Reactor Projects Branch 4
                      Division of Reactor Projects
                                                                            Enclosure
 
                                                  2
                                              SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Exelons performance at
Peach Bottom Atomic Power Station, Units 2 and 3, by conducting the baseline inspections
described in this report in accordance with the Reactor Oversight Process. The Reactor
Oversight Process is the NRCs program for overseeing the safe operation of commercial
nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more
information. NRC-identified and self-revealed findings, violations, and additional items are
summarized in the table below.
                                  List of Findings and Violations
  Failure to Identify and Promptly Correct a Condition Adverse to Quality Concerning Battery
  Charger 2B-003-1
  Cornerstone          Significance                                Cross-Cutting      Report
                                                                      Aspect            Section
  Mitigating            Green NCV                                    P.1 - Problem      71111.19
  Systems              05000277/2018-002-01                        Identification and
                        Opened/Closed                                Resolution
                                                                      Identification
  The NRC identified a Green non-cited violation (NCV) of 10 Code of Federal Regulations
  (CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, because Exelon did not identify
  and promptly correct a condition adverse to quality (CAQ) commensurate with its safety
  significance concerning the 2BD-003-1 safety-related battery charger. Specifically, Exelon did
  not appropriately prioritize repairs for a CAQ and, as a result, the 2BD-003-1 battery charger
  failed to operate when placed in service on June 5, 2018.
                                      Additional Tracking Items
  Type      Issue number                Title                            Report        Status
                                                                          Section
  LER      05000277/2018-001-00        Fire Safe Shutdown              71153          Closed
                                        Requirements Not Met for
                                        Spurious Operation of Valves
                                        at a High-Low Pressure
                                        Interface
 
                                                  3
PLANT STATUS
Unit 2 began the inspection period at rated thermal power (RTP). On June 1, 2018, the unit was
down powered to 58 percent thermal power to perform summer readiness waterbox cleaning.
The unit was returned to RTP on June 2, 2018, and remained at or near RTP for the remainder
of the inspection period.
Unit 3 began the inspection period at RTP. On April 9, 2018, the unit was down powered to 57
percent thermal power to perform power suppression testing for a suspected fuel leak. The unit
was returned to RTP on April 12, 2018. On June 8, 2018, the 3B adjustable speed drive
tripped off-line and the unit was down powered to 40 percent RTP. Exelon repaired a failed
power supply on the 3B adjustable speed drive system and the unit was returned to RTP on
June 11, 2018. The unit remained at or near RTP for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors performed plant status activities described in
IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152,
Problem Identification, and Resolution. The inspectors reviewed selected procedures and
records, observed activities, and interviewed personnel to assess Exelons performance and
compliance with Commission rules and regulations, license conditions, site procedures, and
standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
    Summer Readiness (1 Sample)
    The inspectors evaluated summer readiness of offsite and alternate AC power systems on
    May 3 and 4, 2018.
71111.04 - Equipment Alignment
    Partial Walkdowns (3 Samples)
    The inspectors evaluated system configurations during partial walkdowns of the following
    systems/trains:
    (1) Unit 2 reactor core isolation cooling (RCIC) on May 2, 2018
    (2) Offsite power and station blackout on June 14, 2018
    (3) Emergency cooling tower (ECT) on June 25, 2018
 
                                                  4
  Complete Walkdown (1 Sample)
  The inspectors evaluated system configurations during a complete walkdown of the Unit 2
  high-pressure coolant injection from May 11 through 18, 2018.
71111.05AQ - Fire Protection Annual/Quarterly
  Quarterly Inspection (5 Samples)
  The inspectors evaluated fire protection program implementation in the following selected
  areas:
  (1) Unit 3 turbine building, 116 elevation on April 10, 2018
  (2) Unit 2 reactor building, 195 general area on April 26, 2018
  (3) ECT, 136 general area on May 3, 2018
  (4) Unit 2 core spray (CS) instrument room, 116 elevation, on May 18, 2018
  (5) Unit 3 main transformer yard on May 21, 2018
71111.07 - Heat Sink Performance
  Heat Sink (1 Sample)
  The inspectors evaluated Exelons monitoring and maintenance of the E-4 emergency diesel
  generator (EDG) heat exchanger on May 7, 2018.
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
  Operator Requalification (1 Sample)
  The inspectors observed and evaluated the simulator scenario involving a torus leak and
  anticipated transient without scram on May 7, 2018.
  Operator Performance (1 Sample)
  The inspectors observed a downpower to support Unit 3 fuel power suppression testing from
  April 9 through 11, 2018.
71111.12 - Maintenance Effectiveness
  Routine Maintenance Effectiveness (1 Sample)
  The inspectors evaluated the effectiveness of routine maintenance activities associated
  with the following equipment and/or safety significant functions:
  (1) a(1) determination for Unit 3 failed fuel assembly from April 30 through May 4, 2018
 
                                                5
71111.13 - Maintenance Risk Assessments and Emergent Work Control (4 Samples)
  The inspectors evaluated the risk assessments for the following planned and emergent
  work activities:
  (1) Unit 3 RCIC unavailable and yellow risk on April 22, 2018
  (2) Unit 2 high-pressure coolant injection unavailable and yellow risk on May 2, 2018
  (3) E-1 EDG high crank case pressure trip unavailability on May 4, 2018
  (4) Unit 2 high-pressure service water A inlet to ECT Reservoir valve repairs on June 4,
      2018
71111.15 - Operability Determinations and Functionality Assessments (5 Samples)
  The inspectors evaluated the following operability determinations and functionality
  assessments:
  (1) Unit 2 C residual heat removal (RHR) heat exchanger leak on April 6, 2018
  (2) Unit 2 torus vacuum relief valve pressure switch out of service on April 12, 2018
  (3) Unit 2 RCIC MO-2-13-20 valve degraded stroke time on April 25, 2018
  (4) Unit 3 D battery charger fail alarm on May 22, 2018
  (5) Unit 2 and Unit 3 automatic depressurization system backup nitrogen time delay relays
      out of calibration on June 18, 2018
71111.18 - Plant Modifications (1 Sample)
  The inspectors evaluated the following permanent modification:
  (1) Engineering Change Package EC07-00031, Unit 3 CS Full Flow Test Valve
      MO-3-14-026A Not Able to Meet Minimum Thrust on June 12, 2018
71111.19 - Post-Maintenance Testing (6 Samples)
  The inspectors evaluated post-maintenance testing for the following maintenance/repair
  activities:
  (1) Unit 3 RCIC failed pressure switch replacement on April 23, 2018
  (2) Unit 2 AO-2-40B-20467 actuator replacement on April 24, 2018
  (3) E-1 EDG high crank case pressure on May 4, 2018
  (4) E-4 EDG cylinder liner replacement on May 17, 2018
  (5) Unit 2 B battery charger repair on June 6, 2018
  (6) E-3 EDG high temperature and turbo charger replacement on June 14, 2018
71111.22 - Surveillance Testing
  The inspectors evaluated the following surveillance tests:
  Routine (5 Samples)
  (1) Unit 3 reactor protection system B channel control valve fast closure on
      April 9, 2018
 
                                                6
  (2) Main control room emergency ventilation logic system functional testing (LSFT) on
        April 17, 2018
  (3) E-2 EDG ventilation LSFT on April 18, 2018
  (4) Chemical storage accounting inventory on April 30, 2018
  (5) Unit 3 B RHR surveillance test on June 7, 2018
  Inservice (1 Sample)
  (1) Unit 2 A CS inservice test on May 29, 2018
71114.06 - Drill Evaluation
  Drill/Training Evolution (1 Sample)
  The inspectors observed and evaluated the simulator scenario and emergency classification
  and notifications involving a torus leak and anticipated transient without scram on May 7,
  2018.
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
  Radiological Hazard Assessment (1 Sample)
  The inspectors conducted independent radiation measurements during walkdowns of the
  facility and reviewed:
  (1)  The radiological survey program
  (2)  Any changes to plant operations since the last inspection
  (3)  Recent plant radiation surveys for radiological work activities
  (4)  Air sampling and analysis
  (5)  Continuous air monitor use
  Contamination and Radioactive Material Control (1 Sample)
  The inspectors observed the monitoring of potentially contaminated material leaving the
  radiological controlled area and inspected the methods and radiation monitoring
  instrumentation used for control, survey, and release of that material. The inspectors
  selected several sealed sources from inventory records and assessed whether the sources
  were accounted for and were tested for loose surface contamination. The inspectors
  evaluated whether any recent transactions involving nationally tracked sources were
  reported in accordance with requirements.
  Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)
  The inspectors evaluated radiation worker performance with respect to radiation protection
  work permit requirements. The inspectors evaluated radiation protection technicians in
  performance of radiation surveys and in providing radiological job coverage.
 
                                                  7
71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning
and Controls
  Radiological Work Planning (1 Sample)
  The inspectors evaluated radiological work planning by reviewing significant work activities
  to verify that ALARA planning was integrated into work procedures and radiation work
  permit documents.
  Radiation Worker Performance (1 Sample)
  The inspectors observed radiation worker and radiation protection technician performance
  during radiological work to evaluate worker ALARA performance according to specified work
  controls and procedures.
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification (4 Samples)
  The inspectors verified licensee performance indicators submittals listed below for the
  period from April 1, 2017 through March 31, 2018.
  (1) Unit 2 Reactor Coolant System (RCS) Activity (BI01)
  (2) Unit 3 RCS Activity (BI01)
  (3) Unit 2 RCS Leakage (B102)
  (4) Unit 3 RCS Leakage (B102)
71152 - Problem Identification and Resolution
  Semi-Annual Trend Review (1 Sample)
  The inspectors reviewed Exelons corrective action program (CAP) for trends that might be
  indicative of a more significant safety issue.
  Annual Follow-up of Selected Issues (2 Samples)
  The inspectors reviewed Exelons implementation of its CAP related to the following issues:
  (1) Issue Report (IR) 3963696, Cable reliability program on May 29, 2018
  (2) IR 3999563, CS motor vibration trend and extent of condition on June 21, 2018
71153 - Follow-up of Events and Notices of Enforcement Discretion
  Licensee Event Reports (1 Sample)
  The inspectors evaluated the following Exelon event report which can be accessed at
  https://lersearch.inl.gov/LERSearchCriteria.aspx:
  (1) Licensee Event Report (LER) 05000277/2018-001-00, Fire Safe Shutdown
      Requirements Not Met for Spurious Operation of Valves at a High-Low Pressure
 
                                                    8
        Interface on March 14, 2018. The review for this event is documented in
        IR 05000277/2018010 and 05000278/2018010 as a licensee-identified NCV.
OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT, AND ABNORMAL
60855.1 - Operation of an Independent Spent Fuel Storage Installation (1 Sample)
    The inspectors evaluated Exelons independent spent fuel storage installation cask loading
    on June 18-22, 2018. Specifically, the inspectors reviewed or observed the following
    activities:
    (1) Fuel selection and fuel loading
    (2) Heavy load movement of the loaded TN-68 cask
    (3) Closure bolting
    (4) Final helium leak test
    (5) Radiological field surveys
    (6) Drying and backfill evolutions
    (7) Transfer and transport evolutions
    (8) Radiological field surveys
INSPECTION RESULTS
Failure to Identify and Promptly Correct a Condition Adverse to Quality Concerning Battery
Charger 2B-003-1
Cornerstone            Significance                              Cross-cutting      Report
                                                                    Aspect            Section
Mitigating              Green NCV                                  P.1 - Problem      71111.19
Systems                05000277/2018002-01                        Identification
                                                                    and Resolution,
                                                                    Identification
Introduction: The NRC identified a NCV of 10 CFR Part 50, Appendix B, Criterion XVI,
Corrective Action, because Exelon did not identify and promptly correct a CAQ
commensurate with its safety significance concerning the 2BD-003-1 safety-related battery
charger. Specifically, Exelon did not appropriately prioritize repairs for a CAQ and, as a
result, the 2BD-003-1 battery charger failed to operate when placed in service on June 5,
2018.
Description: Peach Bottom has two independent safety-related 125/250 VDC systems per
unit. Each system is comprised of two 125 V batteries, each with its own charger panel
consisting of two 100 percent chargers. The safety-related chargers are full wave, silicon
controlled rectifiers, suitable for float charging the lead-calcium battery at 2.25 V per cell, and
supplying an equalizing charge at 2.33 V per cell. The chargers operate from 480 V, 3 phase,
60 Hz sources supplied from separate 480 V motor control centers and are capable of
carrying the normal DC system load and, at the same time, supplying charging current to
keep the batteries in a fully charged condition.
On March 5, 2018, IR 4111441 was initiated for Exelon to investigate and troubleshoot a fan
failure alarm of the 2BD-003-1 battery charger under Work Order (WO) 4755435. The IR was
placed on Exelons priority work list (PWL) and operators swapped in-service battery chargers
to the 2BD-003-2 charger in preparation to conduct troubleshooting on the 2BD-003-01
charger. During the troubleshooting for the fan failure alarm, Exelons fix-it-now (FIN)
 
                                                9
department observed a separate condition; the battery fail alarm light was lit when the battery
was placed in-service but unloaded.
IR 4116697 was initiated and closed to WO 4755435 to investigate the new issue concerning
the lit 2BD-003-01 fail light. Exelon installed a recorder to obtain data on the 2BD-003-1 while
in service before swapping back to the 2BD-003-2 to remain in-service. The recorder data
was reviewed for both unloaded and full load battery service. IR 4116697 documents that
under full load service, the 2BD-003-1 showed no abnormalities in the recorder traces and
that the battery fail light extinguished when load was placed on the charger. The IR
recommended no additional actions and concluded that the condition was being worked
under and could be closed to WO 4755435. Subsequently, the 2BD-003-1 issue was
removed from the PWL.
However, after March 19, 2018, during review of the in-service unloaded traces identified
during troubleshooting, FIN identified that the frequency reading on the silicon-controlled
rectifier (SCR) bus was 180 Hz as opposed to the expected 360 Hz. FIN also observed that
the gate pulses originating from the negative gate SCR driver board were approximately half
the amplitude of the positive driver board, and consequently half the amplitude of what would
be expected pulses from the negative board. Additionally, FIN observed that the fail light
returned to being lit when the battery was unloaded. Following the troubleshooting, FIN
concluded that the negative SCR gate driver board and/or the connectors on the harness of
the driver board were degraded. FIN initiated a material request on April 3, 2018, to the
station warehouse to obtain an in-stock negative gate SCR driver board for replacement. The
inspectors identified that this new information that FIN had noted was not documented in a
new IR, nor added to the existing IR 4116697, nor documented in the WO completion notes,
but only kept on an unofficial record by the FIN lead technician. Therefore, Exelon missed
the opportunity to place the issue back on their PWL, to evaluate the risk of a degraded
negative SCR gate driver board, and to have work control assign a due date commensurate
with Exelons Procedure WC-AA-106, Attachment 1, Revision 18, Priority Screening Matrix.
Considering the part was in stock and work could be performed while 2BD-003-01 was not in-
service, the inspectors determined it was reasonable for Exelon to have repaired the
degraded condition before the condition worsened or the charger was placed back into
service.
On June 5, 2018, Exelon attempted to place the 2BD-003-01 battery charger in service;
however, voltage could not be maintained at 130 VDC. Exelon secured 2BD-003-01, entered
Technical Specification (TS) 3.8.4, which required restoration of the Unit 2 DC electrical
power subsystem within 2 hours and then to be in Mode 3 within 12 hours. Exelon
subsequently placed the 2BD-003-02 battery charger in-service, and exited TS 3.8.4. IR
4144546 was then initiated and troubleshooting recommenced to determine why there was
insufficient DC output on 2BD-003-01. Exelon determined that the negative SCR gate driver
board had failed rendering 2BD-003-01 inoperable. The negative SCR gate driver board was
replaced with the in-stock driver board, the battery charger was tested satisfactorily, and was
returned to an operable status with no abnormalities being identified. Exelon subsequently
captured the inspectors concerns regarding CAP documentation and prioritization in IR
4149360 written on June 21, 2018.
Corrective Actions: Exelon replaced the negative SCR gate driver board and restored the
charger. Additionall, Exelon initiated IR 4149360 to address advocating an earlier repair
window, communicating troubleshooting results in a formal manner to other departments
 
                                                10
(operations, work control, maintenance), and ensuring troubleshooting results are
documented in a quality record.
Corrective Action Reference: IR 4149360
Performance Assessment:
Performance Deficiency: The inspectors determined that Exelons failure to identify and
promptly perform corrective actions commensurate with the safety significance of a degraded
battery charger is a performance deficiency reasonably within Exelons ability to foresee and
correct. Specifically, Exelon missed an opportunity by not adequately prioritizing repairs of a
degraded negative SCR gate driver board that eventually failed the 2BD-003-1 battery
charger on June 5, 2018.
Screening: The finding is more than minor, because it is associated with the Equipment
Performance attribute of the Mitigating Systems cornerstone and adversely affected the
cornerstone's objective to ensure the availability, reliability, and capability of systems that
respond to initiating events to prevent undesirable consequences (i.e., core damage)
Specifically, 2BD-003-1 failed to perform its safety-related function as a result of Exelon not
prioritizing repairs for a CAQ.
Significance: The inspectors evaluated the significance of the finding using IMC 0609,
Appendix A, Significance Determination Process for Findings at Power, Exhibit 2 -
Mitigating Systems Screening Questions. The inspectors determined this finding was of very
low safety significance (Green) because the finding was not a design deficiency, not a loss of
a safety function, and was not the loss of function of a single train for longer than its TS
allowed outage time.
Cross-Cutting Aspect: The inspectors determined this finding had a cross-cutting aspect in
the area of Problem Identification and Resolution, Identification, because Exelon did not
ensure the issue was entered in the CAP in sufficient detail to ensure it could be appropriately
prioritized, trended, and assigned for resolution. [P.1]
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires that
measures shall be established to assure conditions adverse to quality are promptly identified
and corrected. Contrary to this requirement, from March 19, 2018, until June 5, 2018, Exelon
did not promptly identify and correct a CAQ associated with a degraded battery charger
2BD-003-1. Specifically, Exelon did not appropriately prioritize repairs for a CAQ
commensurate with its safety significance. As a result, battery charger 2BD-003-1 failed to
operate when placed in service on June 5, 2018.
Disposition: This violation is being treated as an NCV, consistent with Section 2.3.2a of the
Enforcement Policy.
 
                                                  11
                                      Observations                                        71152
Semi-Annual Trend Review
The inspectors evaluated a sample of issues and events that occurred over the course of the
first and second quarters of 2018 to determine whether issues were appropriately considered
as emerging or adverse trends. The inspectors verified that these issues were addressed
within the scope of the CAP or through department review.
The inspectors review did not identify any new adverse trends; however, they did identify
multiple condition reports that detail CAQs related to engineering programs that are intended
to identify, manage, and retain plant design and safety margins. Specifically, the inspectors
reviewed issues with the roles and responsibilities within the Structural Monitoring, GL 89-13,
In-Service Testing, and Aging Management programs. The inspectors identified that elevated
engineering turnover rate and substantial engineering department reorganization was a
primary contributor to the documented issues. The inspectors determined that the issues
were adequately documented in the CAP (IRs 4094922, 4097435) and reasonable actions
have been created to address the issues. While most actions have not been in effect long
enough to adequately assess their impact, the inspectors did note positive improvement in the
structural monitoring program. The inspectors will continue to monitor the effectiveness of the
corrective actions.
Exelon did identify an adverse trend in equipment reliability due to several safety-related and
non-safety-related equipment failures in the past six months. These issues were documented
in IRs 4155918 and 4155200. The inspectors reviewed the IRs; however, the actions
associated have not been completed and will be reviewed under future inspection samples.
The inspectors did not identify any issues of concern at this time.
Exelon performed a self-assessment of the CAP and identified one deficiency and multiple
recommendations which were documented in IR 4072771. The deficiency related to the
stations adequacy of actions to address an NRC-identified issue of concern documented in an
IR. Specifically, the station identified that a required action was not created to address the
concern and documented the issue in the CAP under IR 4142994. Furthermore, Exelon
reviewed NRC-identified IRs that were closed to work requests that currently remained open.
Exelons review did not identify any immediate safety concerns or operability issues with the
remaining work requests. The inspectors determined that Exelons review was adequate and
that the deficiency was minor. However, the inspectors noted that an NCV,
05000278/2018001-01, had been documented in Inspection Report 2018001 for the failure to
perform timely corrective actions for an NRC-identified concern, similar to the deficiency noted
above. In addition, the inspectors documented an NCV, 05000277/2018002-01, for failure to
perform prompt corrective actions for a known degraded condition on the 2B battery charger
in this report. The inspectors continue to review the corrective actions from these events and
monitor the performance of the CAP to take timely corrective actions for known degraded
conditions. No additional issues of concern were identified.
                                      Observations                                        71152
Cable Reliability Program
The inspectors did not identify any findings during the review. However, the inspectors
identified the following observations. Exelon missed two opportunities, in 2016 and in 2018,
to replace cables associated with the Unit 3 emergency auxiliary transformer after testing
 
                                                  12
  results in 2014 concluded that the cables were in the action range and required replacement
  at the next available work window. In 2018, the validity of the 2014 testing results was
  brought into question by Exelon. The inspectors noted that the invalid test results identified by
  the cable reliability program could have been identified and communicated as early as 2014.
  Since the communication did not take place until 2018, the station did not appropriately
  prioritize the replacement schedule given the true condition of the cables. The inspectors also
  noted that during the period between 2014 and 2018, Exelons cable reliability program held
  four different program owners which contributed to less program ownership and program
  continuity than expected.
  The inspectors determined that these observations were minor, in that, there had not been an
  actual adverse impact regarding actual cable performance. Additionally, Exelons cable
  reliability program had accomplished separate corrective actions to repair multiple
  underground vaults containing cables important to safety and these repairs had effectively
  limited the ingress of water into the vaults. The inspectors determined that these actions have
  adequately protected the medium voltage cables from degradation due to submergence in
  water. No issues of concern were identified.
                                      Observations                                      71152
  Core Spray Motor Vibrations
  The inspectors reviewed Exelons corrective actions for an elevated vibration trend on the 2C
  core spray motor documented under IR 3999563 and NCV 05000277/2017008001. Exelon
  appropriately entered the issue into their CAP and developed actions to troubleshoot and
  correct the CAQ. The cause of the elevated vibrations were identified to be resonance
  vibration of the motor occurring at the normal running speed of the pump. This resonance has
  induced an elevated vibration in the motor. Exelon is currently performing interim actions to
  mitigate the resonance vibration while long term actions for the motor replacement can be
  accomplished. In addition, an extent of condition review was performed on all safety-related
  vertically mounted pumps which included RHR, high-pressure service water, and emergency
  service water. It was identified that additional core spray motors had symptoms of resonance
  vibration, although less significant than the 2C motor. Exelon has established corrective
  actions to replace these motors with refurbished motors on a staggered schedule. The
  inspectors determined that Exelons completed and proposed actions were reasonable. The
  inspectors noted that Exelon consulted with industry vibration experts to develop extensive
  and in-depth troubleshooting and mitigating actions. The actions appeared reasonable and
  commensurate with the safety significance of the issue. No additional issues of concern were
  identified.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
  On July 13, 2018, the inspectors presented the quarterly resident inspector inspection results
    to Mr. Matthew Herr, Plant Manager, and other members of the Exelon staff.
 
                                              13
DOCUMENTS REVIEWED
71111.01
Procedures
MA-AA-716-230-1003, Thermography Program Guide, Revision 5
SE-16, Attachment A, Generation Dispatch TSO Communications to Peach Bottom, Revision 11
71111.04
Procedures
ST-O-51H-201-2, SBO Line TS 3.8.1 B.1 Verification, Revision 4
ST-O-054-951-2, Offsite and Onsite Electrical Power Breaker Alignment and Power Availability
      Check with a Start-Up source and/or EDG Inoperable, Revision 7
SO 48.7.A, Emergency Cooling Water System Makeup to Tower Using a High
      Pressure Service Water Pump, Revision 10
Drawings
6280-M-359, Sheet 1, RCIC System, Revision 50
6280-M-360, Sheet 1, RCIC Pump Turbine Details, Revision 56
71111.05Q
Procedures
PF-5F, Unit 2 Reactor Building, CS Instrument Room, Elevation 116-0, Revision 4
PF-5K, Unit 2 Reactor Building, General Area, Elevation 195, Revision 7
PF-136, ECT, General Area, Elevation 123-0/153-0, Revision 3
PF-152, Unit 3 Main Transformer Yard, Revision 6
71111.07
Procedures
ER-AA-340-1002, Service Water Heat Exchanger Inspection Guide, Revision 7
WC-AA-101-1004, E-4 EDG TSA - WW 1819/1820, Revision 8
71111.13
Procedures
CC-AA-301, Engineering Standard Request Form, Revision 3
CC-MA-103-2001, Setpoint Methodology for PB and Limerick Generating Station, Revision 2
MA-MA-796-024-1001, Scaffolding Criteria for the Mid-Atlantic Stations, Revision 9
OP-PB-108-117-1000, PB Protected Equipment Tracking Sheet, Attachment 1
SI3P-13-72-ABCE, Calibration Check of RCIC Pump and Turbine Pressure Switches
      PS 3-13-67-1 and PS 3-13-72A/B, Revision 7
WC-AA-101-1006, On-line Risk Management and Assessment, Revision 2
Drawings
6280-M-1-S-42, Sheet 21, RCIC System, Revision 77
6280-M-359, Sheet 2, RCIC System, Revision 48
6280-M-360, Sheet 2, RCIC Pump Turbine Details, Revision 54
 
                                            14
WOs
4260039
Miscellaneous
EC Number: 623997
71111.15
Procedures
ER-AA-321, IST Valve Evaluation Form, Revision 12
OP-AA-108-115, Operability Determinations, Revision 21
Condition Reports
4120966      4130754
Drawings
6280-M-1-S-42, Sheet 17, RCIC System, Revision 74
6280-M-359, Sheet 1, RCIC System, Revision 50
ARs
1311814
71111.18
Engineering Change
ECR PB 07-00031, MO-3-14-026A Not Able to Meet Minimum Thrust, Revision 0
71111.19
Procedures
MA-AA-716-004, Conduct of Troubleshooting, Revision 15
MA-AA-716-234, FIN Team Process, Revision 12
RT-O-052-254-2, E-4 Diesel Generator Inspection Post-Maintenance Functional Test,
      Revision 37
ST-I-052-254-2, E-4 Diesel Generator Inspection Post-Maintenance Instrumentation and Logic
      Test, Revision 7
ST-I-052-264-2, E-4 Diesel Generator Inspection Post-Maintenance Handswitch Logic Test,
      Revision 3
ST-M-57B-762-2, Battery Charger 2BD003-1 and 2BD003-2 Capability Test, Revision 6
ST-O-052-311-2, E-1 Diesel Generator Slow Start Full Load and IST Test, Revision 22
ST-O-052-414-2, E-4 Diesel Generator Fast Start and Full Load Test, Revision 26
ST-O-094-400-2, Stroke Time Testing of Valves for Pre-Maintenance or PMT, Revision 5
WC-AA-106, Priority Screening Matrix, Attachment 1, Revision 18
WC-AA-111-F-01, Surveillance WO Disposition Sheet, Revision 0
Condition Reports
2685664      3968502      4019553        4025384      4054307      4056725
4066576      4070794      4072646        4078903      4111441      4116697
4130767      4134248      4138230        4138464      4139205      4144536
4144592      4149360
 
                                            15
Drawings
D-11938-10, Wiring Diag. Charger 1, Model 130/200R3-S Battery Charger Power State,
      Sheet 1 of 1
WOs
04306095-01 04595788        04755435
Miscellaneous
Battery Information, 2BD003-1 dated June 6, 2018
Log Entries Search Report dated June 5, 2018
71111.22
Procedures
EN-AA-501, Controlled Material Storage Owner Inspection Checklist, Attachment 6, Revision 3
SI3F-10-109-B1C2, Calibration Check of RHR B Loop Flow Instruments FT-3-10-109B,
      FR-3-10-143, FI-3-10-139B, FT-3-10-111B, FT-3-10-91076B, FT-3-10-91076D,
      FI-3-10-91076B, FI-3-10-91076D, and FI-3-10-136B, Revision 7
ST-I-40D-200-2, Control Room Emergency Ventilation LSFT, Revision 11
Miscellaneous
Pennsylvania Tier II Emergency and Hazardous Chemical Inventory, PB, dated January 1, 2017
      to December 31, 2017
Condition Reports
1668149        4125513      4314575
71124.01
Procedures
RW-PB-570, Storage of Radioactive Material and Radiation Waste at the Low Radiation
      Storage Area, Revision 007
SF-421, Radiation Protection Requirements for Spent Fuel Casks TN-68-01 through TN-68-44
      and TN-68-48 through TN-68-92 Loading and Transport Operations, Revision 008
Condition Reports
04079512      04084790      04098830    04099291      04120191      04135486
Radiation Work Permits
PB-C-18-205
Documents
RP-AA-401, Attachment 2, Combined ALARA / Micro ALARA Plan, U-2 RWCU Sample Sink
      Chiller Work 5/21/2018
71124.02
Procedures
NISP-RP-003, Nuclear Industry Standard Process - Radiological Air Sampling
RP-AA-300, Radiological Survey Program, Revision 16.
 
                                            16
Condition Reports
04068960      04070035
Documents
PB 2017, P3R21 Refuel Outage Report (10/232017-11/072017)
PB 2018-2022, Dose Excellence Plan, Revision 0
71151
Procedures
ST-O-020-560-2, Reactor Coolant Leakage Test, Revision 13
71152
ARs
4000970
Condition Reports
3990487      4012283
Miscellaneous
PB-17-0027, Obtain Spare CS Motor
71153
Procedures
SF-221, Spent Fuel Casks TN-68 Loading and Transport Operations, Revision 20
SF-421, Radiation Protection Requirements for Spent Fuel Casks TN-68-01 through TN-68-44
      and TN-68-48 through TN-68-92 Loading and Transport Operations, Revision 8
}}

Latest revision as of 19:04, 20 October 2019

Integrated Inspection Report 05000277/2018002 and 05000278/2018002 and Independent Spent Fuel Storage Installation Report 07200029/2018002
ML18225A086
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 08/13/2018
From: Jon Greives
Reactor Projects Region 1 Branch 4
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
Greives J
References
IR 2018002, ISFSI 2018002
Download: ML18225A086 (19)


See also: IR 05000277/2018002

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BOULEVARD, SUITE 100

KING OF PRUSSIA, PA 19406-2713

August 13, 2018

Mr. Bryan C. Hanson

Senior Vice President, Exelon Generation Company, LLC

President and Chief Nuclear Officer, Exelon Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: PEACH BOTTOM ATOMIC POWER STATION - INTEGRATED INSPECTION

REPORT 05000277/2018002 AND 05000278/2018002 AND INDEPENDENT

SPENT FUEL STORAGE INSTALLATION REPORT 07200029/2018002

Dear Mr. Hanson:

On June 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at

your Peach Bottom Atomic Power Station (Peach Bottom), Units 2 and 3. On July 13, 2018, the

NRC inspectors discussed the results of this inspection with Mr. Matthew Herr, Plant Manager,

and other members of your staff. The results of this inspection are documented in the enclosed

report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

The finding involved a violation of NRC requirements. The NRC is treating this violation as a

non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation or significance of the NCV, you should provide a response within

30 days of the date of this inspection report, with the basis for your denial, 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; and the

NRCs Resident Inspector at Peach Bottom. In addition, if you disagree with a cross-cutting

aspect assignment or a finding not associated with a regulatory requirement in this report, you

should provide a response within 30 days of the date of this inspection report, with the basis for

your disagreement, to the U. S. Nuclear Regulatory Commission, ATTN: Document Control

Desk, Washington, DC, 20555-0001; with copies to the Regional Administrator, Region I, and

the NRCs Resident Inspector at Peach Bottom.

B. Hanson 2

This letter, its enclosure, and your response (if any) will be made available for public inspection

and copying at http://www.nrc.gov/reading-rm/adams.html and the NRCs Public Document

Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 2.390,

Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Jonathan E. Greives, Chief

Reactor Projects Branch 4

Division of Reactor Projects

Docket Numbers: 50-277 and 50-278

License Numbers: DPR-44 and DPR-56

Enclosure:

Inspection Report 05000277/2018002

and 05000278/2018002

and 07200029/2018002

cc w/encl: Distribution via ListServ

ML18225A086

Non-Sensitive Publicly Available

SUNSI Review

Sensitive Non-Publicly Available

OFFICE RI/DRP RI/DRP RI/DRP

NAME JHeinly via email SBarber JGreives

DATE 8/9/18 8/9/18 8/13/18

1

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Numbers: 50-277 and 50-278

License Numbers: DPR-44 and DPR-56

Report Numbers: 05000277/2018002 and 05000278/2018002 and 07200029/2018002

Enterprise Identifier: I-2018-002-0064

Licensee: Exelon Generation Company, LLC

Facility: Peach Bottom Atomic Power Station, Units 2 and 3

Location: Delta, Pennsylvania

Inspection Dates: April 1, 2018 to June 30, 2018

Inspectors: J. Heinly, Senior Resident Inspector

B. Smith, Resident Inspector

O. Masnyk Bailey, Health Physicist

J. Cassata, Health Physicist

J. Nicholson, Senior Health Physicist

M. Orr, Reactor Inspector

A. Turilin, Project Engineer

Approved By: Jonathan E. Grieves, Chief

Reactor Projects Branch 4

Division of Reactor Projects

Enclosure

2

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Exelons performance at

Peach Bottom Atomic Power Station, Units 2 and 3, by conducting the baseline inspections

described in this report in accordance with the Reactor Oversight Process. The Reactor

Oversight Process is the NRCs program for overseeing the safe operation of commercial

nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more

information. NRC-identified and self-revealed findings, violations, and additional items are

summarized in the table below.

List of Findings and Violations

Failure to Identify and Promptly Correct a Condition Adverse to Quality Concerning Battery

Charger 2B-003-1

Cornerstone Significance Cross-Cutting Report

Aspect Section

Mitigating Green NCV P.1 - Problem 71111.19

Systems 05000277/2018-002-01 Identification and

Opened/Closed Resolution

Identification

The NRC identified a Green non-cited violation (NCV) of 10 Code of Federal Regulations

(CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, because Exelon did not identify

and promptly correct a condition adverse to quality (CAQ) commensurate with its safety

significance concerning the 2BD-003-1 safety-related battery charger. Specifically, Exelon did

not appropriately prioritize repairs for a CAQ and, as a result, the 2BD-003-1 battery charger

failed to operate when placed in service on June 5, 2018.

Additional Tracking Items

Type Issue number Title Report Status

Section

LER 05000277/2018-001-00 Fire Safe Shutdown 71153 Closed

Requirements Not Met for

Spurious Operation of Valves

at a High-Low Pressure

Interface

3

PLANT STATUS

Unit 2 began the inspection period at rated thermal power (RTP). On June 1, 2018, the unit was

down powered to 58 percent thermal power to perform summer readiness waterbox cleaning.

The unit was returned to RTP on June 2, 2018, and remained at or near RTP for the remainder

of the inspection period.

Unit 3 began the inspection period at RTP. On April 9, 2018, the unit was down powered to 57

percent thermal power to perform power suppression testing for a suspected fuel leak. The unit

was returned to RTP on April 12, 2018. On June 8, 2018, the 3B adjustable speed drive

tripped off-line and the unit was down powered to 40 percent RTP. Exelon repaired a failed

power supply on the 3B adjustable speed drive system and the unit was returned to RTP on

June 11, 2018. The unit remained at or near RTP for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in

effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with

their attached revision histories are located on the public website at http://www.nrc.gov/reading-

rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared

complete when the IP requirements most appropriate to the inspection activity were met

consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection

Program - Operations Phase. The inspectors performed plant status activities described in

IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152,

Problem Identification, and Resolution. The inspectors reviewed selected procedures and

records, observed activities, and interviewed personnel to assess Exelons performance and

compliance with Commission rules and regulations, license conditions, site procedures, and

standards.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Summer Readiness (1 Sample)

The inspectors evaluated summer readiness of offsite and alternate AC power systems on

May 3 and 4, 2018.

71111.04 - Equipment Alignment

Partial Walkdowns (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) Unit 2 reactor core isolation cooling (RCIC) on May 2, 2018

(2) Offsite power and station blackout on June 14, 2018

(3) Emergency cooling tower (ECT) on June 25, 2018

4

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the Unit 2

high-pressure coolant injection from May 11 through 18, 2018.

71111.05AQ - Fire Protection Annual/Quarterly

Quarterly Inspection (5 Samples)

The inspectors evaluated fire protection program implementation in the following selected

areas:

(1) Unit 3 turbine building, 116 elevation on April 10, 2018

(2) Unit 2 reactor building, 195 general area on April 26, 2018

(3) ECT, 136 general area on May 3, 2018

(4) Unit 2 core spray (CS) instrument room, 116 elevation, on May 18, 2018

(5) Unit 3 main transformer yard on May 21, 2018

71111.07 - Heat Sink Performance

Heat Sink (1 Sample)

The inspectors evaluated Exelons monitoring and maintenance of the E-4 emergency diesel

generator (EDG) heat exchanger on May 7, 2018.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated the simulator scenario involving a torus leak and

anticipated transient without scram on May 7, 2018.

Operator Performance (1 Sample)

The inspectors observed a downpower to support Unit 3 fuel power suppression testing from

April 9 through 11, 2018.

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness (1 Sample)

The inspectors evaluated the effectiveness of routine maintenance activities associated

with the following equipment and/or safety significant functions:

(1) a(1) determination for Unit 3 failed fuel assembly from April 30 through May 4, 2018

5

71111.13 - Maintenance Risk Assessments and Emergent Work Control (4 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent

work activities:

(1) Unit 3 RCIC unavailable and yellow risk on April 22, 2018

(2) Unit 2 high-pressure coolant injection unavailable and yellow risk on May 2, 2018

(3) E-1 EDG high crank case pressure trip unavailability on May 4, 2018

(4) Unit 2 high-pressure service water A inlet to ECT Reservoir valve repairs on June 4,

2018

71111.15 - Operability Determinations and Functionality Assessments (5 Samples)

The inspectors evaluated the following operability determinations and functionality

assessments:

(1) Unit 2 C residual heat removal (RHR) heat exchanger leak on April 6, 2018

(2) Unit 2 torus vacuum relief valve pressure switch out of service on April 12, 2018

(3) Unit 2 RCIC MO-2-13-20 valve degraded stroke time on April 25, 2018

(4) Unit 3 D battery charger fail alarm on May 22, 2018

(5) Unit 2 and Unit 3 automatic depressurization system backup nitrogen time delay relays

out of calibration on June 18, 2018

71111.18 - Plant Modifications (1 Sample)

The inspectors evaluated the following permanent modification:

(1) Engineering Change Package EC07-00031, Unit 3 CS Full Flow Test Valve

MO-3-14-026A Not Able to Meet Minimum Thrust on June 12, 2018

71111.19 - Post-Maintenance Testing (6 Samples)

The inspectors evaluated post-maintenance testing for the following maintenance/repair

activities:

(1) Unit 3 RCIC failed pressure switch replacement on April 23, 2018

(2) Unit 2 AO-2-40B-20467 actuator replacement on April 24, 2018

(3) E-1 EDG high crank case pressure on May 4, 2018

(4) E-4 EDG cylinder liner replacement on May 17, 2018

(5) Unit 2 B battery charger repair on June 6, 2018

(6) E-3 EDG high temperature and turbo charger replacement on June 14, 2018

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (5 Samples)

(1) Unit 3 reactor protection system B channel control valve fast closure on

April 9, 2018

6

(2) Main control room emergency ventilation logic system functional testing (LSFT) on

April 17, 2018

(3) E-2 EDG ventilation LSFT on April 18, 2018

(4) Chemical storage accounting inventory on April 30, 2018

(5) Unit 3 B RHR surveillance test on June 7, 2018

Inservice (1 Sample)

(1) Unit 2 A CS inservice test on May 29, 2018

71114.06 - Drill Evaluation

Drill/Training Evolution (1 Sample)

The inspectors observed and evaluated the simulator scenario and emergency classification

and notifications involving a torus leak and anticipated transient without scram on May 7,

2018.

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (1 Sample)

The inspectors conducted independent radiation measurements during walkdowns of the

facility and reviewed:

(1) The radiological survey program

(2) Any changes to plant operations since the last inspection

(3) Recent plant radiation surveys for radiological work activities

(4) Air sampling and analysis

(5) Continuous air monitor use

Contamination and Radioactive Material Control (1 Sample)

The inspectors observed the monitoring of potentially contaminated material leaving the

radiological controlled area and inspected the methods and radiation monitoring

instrumentation used for control, survey, and release of that material. The inspectors

selected several sealed sources from inventory records and assessed whether the sources

were accounted for and were tested for loose surface contamination. The inspectors

evaluated whether any recent transactions involving nationally tracked sources were

reported in accordance with requirements.

Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)

The inspectors evaluated radiation worker performance with respect to radiation protection

work permit requirements. The inspectors evaluated radiation protection technicians in

performance of radiation surveys and in providing radiological job coverage.

7

71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning

and Controls

Radiological Work Planning (1 Sample)

The inspectors evaluated radiological work planning by reviewing significant work activities

to verify that ALARA planning was integrated into work procedures and radiation work

permit documents.

Radiation Worker Performance (1 Sample)

The inspectors observed radiation worker and radiation protection technician performance

during radiological work to evaluate worker ALARA performance according to specified work

controls and procedures.

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification (4 Samples)

The inspectors verified licensee performance indicators submittals listed below for the

period from April 1, 2017 through March 31, 2018.

(1) Unit 2 Reactor Coolant System (RCS) Activity (BI01)

(2) Unit 3 RCS Activity (BI01)

(3) Unit 2 RCS Leakage (B102)

(4) Unit 3 RCS Leakage (B102)

71152 - Problem Identification and Resolution

Semi-Annual Trend Review (1 Sample)

The inspectors reviewed Exelons corrective action program (CAP) for trends that might be

indicative of a more significant safety issue.

Annual Follow-up of Selected Issues (2 Samples)

The inspectors reviewed Exelons implementation of its CAP related to the following issues:

(1) Issue Report (IR) 3963696, Cable reliability program on May 29, 2018

(2) IR 3999563, CS motor vibration trend and extent of condition on June 21, 2018

71153 - Follow-up of Events and Notices of Enforcement Discretion

Licensee Event Reports (1 Sample)

The inspectors evaluated the following Exelon event report which can be accessed at

https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report (LER) 05000277/2018-001-00, Fire Safe Shutdown

Requirements Not Met for Spurious Operation of Valves at a High-Low Pressure

8

Interface on March 14, 2018. The review for this event is documented in

IR 05000277/2018010 and 05000278/2018010 as a licensee-identified NCV.

OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT, AND ABNORMAL

60855.1 - Operation of an Independent Spent Fuel Storage Installation (1 Sample)

The inspectors evaluated Exelons independent spent fuel storage installation cask loading

on June 18-22, 2018. Specifically, the inspectors reviewed or observed the following

activities:

(1) Fuel selection and fuel loading

(2) Heavy load movement of the loaded TN-68 cask

(3) Closure bolting

(4) Final helium leak test

(5) Radiological field surveys

(6) Drying and backfill evolutions

(7) Transfer and transport evolutions

(8) Radiological field surveys

INSPECTION RESULTS

Failure to Identify and Promptly Correct a Condition Adverse to Quality Concerning Battery

Charger 2B-003-1

Cornerstone Significance Cross-cutting Report

Aspect Section

Mitigating Green NCV P.1 - Problem 71111.19

Systems05000277/2018002-01 Identification

and Resolution,

Identification

Introduction: The NRC identified a NCV of 10 CFR Part 50, Appendix B, Criterion XVI,

Corrective Action, because Exelon did not identify and promptly correct a CAQ

commensurate with its safety significance concerning the 2BD-003-1 safety-related battery

charger. Specifically, Exelon did not appropriately prioritize repairs for a CAQ and, as a

result, the 2BD-003-1 battery charger failed to operate when placed in service on June 5,

2018.

Description: Peach Bottom has two independent safety-related 125/250 VDC systems per

unit. Each system is comprised of two 125 V batteries, each with its own charger panel

consisting of two 100 percent chargers. The safety-related chargers are full wave, silicon

controlled rectifiers, suitable for float charging the lead-calcium battery at 2.25 V per cell, and

supplying an equalizing charge at 2.33 V per cell. The chargers operate from 480 V, 3 phase,

60 Hz sources supplied from separate 480 V motor control centers and are capable of

carrying the normal DC system load and, at the same time, supplying charging current to

keep the batteries in a fully charged condition.

On March 5, 2018, IR 4111441 was initiated for Exelon to investigate and troubleshoot a fan

failure alarm of the 2BD-003-1 battery charger under Work Order (WO) 4755435. The IR was

placed on Exelons priority work list (PWL) and operators swapped in-service battery chargers

to the 2BD-003-2 charger in preparation to conduct troubleshooting on the 2BD-003-01

charger. During the troubleshooting for the fan failure alarm, Exelons fix-it-now (FIN)

9

department observed a separate condition; the battery fail alarm light was lit when the battery

was placed in-service but unloaded.

IR 4116697 was initiated and closed to WO 4755435 to investigate the new issue concerning

the lit 2BD-003-01 fail light. Exelon installed a recorder to obtain data on the 2BD-003-1 while

in service before swapping back to the 2BD-003-2 to remain in-service. The recorder data

was reviewed for both unloaded and full load battery service. IR 4116697 documents that

under full load service, the 2BD-003-1 showed no abnormalities in the recorder traces and

that the battery fail light extinguished when load was placed on the charger. The IR

recommended no additional actions and concluded that the condition was being worked

under and could be closed to WO 4755435. Subsequently, the 2BD-003-1 issue was

removed from the PWL.

However, after March 19, 2018, during review of the in-service unloaded traces identified

during troubleshooting, FIN identified that the frequency reading on the silicon-controlled

rectifier (SCR) bus was 180 Hz as opposed to the expected 360 Hz. FIN also observed that

the gate pulses originating from the negative gate SCR driver board were approximately half

the amplitude of the positive driver board, and consequently half the amplitude of what would

be expected pulses from the negative board. Additionally, FIN observed that the fail light

returned to being lit when the battery was unloaded. Following the troubleshooting, FIN

concluded that the negative SCR gate driver board and/or the connectors on the harness of

the driver board were degraded. FIN initiated a material request on April 3, 2018, to the

station warehouse to obtain an in-stock negative gate SCR driver board for replacement. The

inspectors identified that this new information that FIN had noted was not documented in a

new IR, nor added to the existing IR 4116697, nor documented in the WO completion notes,

but only kept on an unofficial record by the FIN lead technician. Therefore, Exelon missed

the opportunity to place the issue back on their PWL, to evaluate the risk of a degraded

negative SCR gate driver board, and to have work control assign a due date commensurate

with Exelons Procedure WC-AA-106, Attachment 1, Revision 18, Priority Screening Matrix.

Considering the part was in stock and work could be performed while 2BD-003-01 was not in-

service, the inspectors determined it was reasonable for Exelon to have repaired the

degraded condition before the condition worsened or the charger was placed back into

service.

On June 5, 2018, Exelon attempted to place the 2BD-003-01 battery charger in service;

however, voltage could not be maintained at 130 VDC. Exelon secured 2BD-003-01, entered

Technical Specification (TS) 3.8.4, which required restoration of the Unit 2 DC electrical

power subsystem within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and then to be in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Exelon

subsequently placed the 2BD-003-02 battery charger in-service, and exited TS 3.8.4. IR 4144546 was then initiated and troubleshooting recommenced to determine why there was

insufficient DC output on 2BD-003-01. Exelon determined that the negative SCR gate driver

board had failed rendering 2BD-003-01 inoperable. The negative SCR gate driver board was

replaced with the in-stock driver board, the battery charger was tested satisfactorily, and was

returned to an operable status with no abnormalities being identified. Exelon subsequently

captured the inspectors concerns regarding CAP documentation and prioritization in IR 4149360 written on June 21, 2018.

Corrective Actions: Exelon replaced the negative SCR gate driver board and restored the

charger. Additionall, Exelon initiated IR 4149360 to address advocating an earlier repair

window, communicating troubleshooting results in a formal manner to other departments

10

(operations, work control, maintenance), and ensuring troubleshooting results are

documented in a quality record.

Corrective Action Reference: IR 4149360

Performance Assessment:

Performance Deficiency: The inspectors determined that Exelons failure to identify and

promptly perform corrective actions commensurate with the safety significance of a degraded

battery charger is a performance deficiency reasonably within Exelons ability to foresee and

correct. Specifically, Exelon missed an opportunity by not adequately prioritizing repairs of a

degraded negative SCR gate driver board that eventually failed the 2BD-003-1 battery

charger on June 5, 2018.

Screening: The finding is more than minor, because it is associated with the Equipment

Performance attribute of the Mitigating Systems cornerstone and adversely affected the

cornerstone's objective to ensure the availability, reliability, and capability of systems that

respond to initiating events to prevent undesirable consequences (i.e., core damage)

Specifically, 2BD-003-1 failed to perform its safety-related function as a result of Exelon not

prioritizing repairs for a CAQ.

Significance: The inspectors evaluated the significance of the finding using IMC 0609,

Appendix A, Significance Determination Process for Findings at Power, Exhibit 2 -

Mitigating Systems Screening Questions. The inspectors determined this finding was of very

low safety significance (Green) because the finding was not a design deficiency, not a loss of

a safety function, and was not the loss of function of a single train for longer than its TS

allowed outage time.

Cross-Cutting Aspect: The inspectors determined this finding had a cross-cutting aspect in

the area of Problem Identification and Resolution, Identification, because Exelon did not

ensure the issue was entered in the CAP in sufficient detail to ensure it could be appropriately

prioritized, trended, and assigned for resolution. [P.1]

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires that

measures shall be established to assure conditions adverse to quality are promptly identified

and corrected. Contrary to this requirement, from March 19, 2018, until June 5, 2018, Exelon

did not promptly identify and correct a CAQ associated with a degraded battery charger

2BD-003-1. Specifically, Exelon did not appropriately prioritize repairs for a CAQ

commensurate with its safety significance. As a result, battery charger 2BD-003-1 failed to

operate when placed in service on June 5, 2018.

Disposition: This violation is being treated as an NCV, consistent with Section 2.3.2a of the

Enforcement Policy.

11

Observations 71152

Semi-Annual Trend Review

The inspectors evaluated a sample of issues and events that occurred over the course of the

first and second quarters of 2018 to determine whether issues were appropriately considered

as emerging or adverse trends. The inspectors verified that these issues were addressed

within the scope of the CAP or through department review.

The inspectors review did not identify any new adverse trends; however, they did identify

multiple condition reports that detail CAQs related to engineering programs that are intended

to identify, manage, and retain plant design and safety margins. Specifically, the inspectors

reviewed issues with the roles and responsibilities within the Structural Monitoring, GL 89-13,

In-Service Testing, and Aging Management programs. The inspectors identified that elevated

engineering turnover rate and substantial engineering department reorganization was a

primary contributor to the documented issues. The inspectors determined that the issues

were adequately documented in the CAP (IRs 4094922, 4097435) and reasonable actions

have been created to address the issues. While most actions have not been in effect long

enough to adequately assess their impact, the inspectors did note positive improvement in the

structural monitoring program. The inspectors will continue to monitor the effectiveness of the

corrective actions.

Exelon did identify an adverse trend in equipment reliability due to several safety-related and

non-safety-related equipment failures in the past six months. These issues were documented

in IRs 4155918 and 4155200. The inspectors reviewed the IRs; however, the actions

associated have not been completed and will be reviewed under future inspection samples.

The inspectors did not identify any issues of concern at this time.

Exelon performed a self-assessment of the CAP and identified one deficiency and multiple

recommendations which were documented in IR 4072771. The deficiency related to the

stations adequacy of actions to address an NRC-identified issue of concern documented in an

IR. Specifically, the station identified that a required action was not created to address the

concern and documented the issue in the CAP under IR 4142994. Furthermore, Exelon

reviewed NRC-identified IRs that were closed to work requests that currently remained open.

Exelons review did not identify any immediate safety concerns or operability issues with the

remaining work requests. The inspectors determined that Exelons review was adequate and

that the deficiency was minor. However, the inspectors noted that an NCV,05000278/2018001-01, had been documented in Inspection Report 2018001 for the failure to

perform timely corrective actions for an NRC-identified concern, similar to the deficiency noted

above. In addition, the inspectors documented an NCV,05000277/2018002-01, for failure to

perform prompt corrective actions for a known degraded condition on the 2B battery charger

in this report. The inspectors continue to review the corrective actions from these events and

monitor the performance of the CAP to take timely corrective actions for known degraded

conditions. No additional issues of concern were identified.

Observations 71152

Cable Reliability Program

The inspectors did not identify any findings during the review. However, the inspectors

identified the following observations. Exelon missed two opportunities, in 2016 and in 2018,

to replace cables associated with the Unit 3 emergency auxiliary transformer after testing

12

results in 2014 concluded that the cables were in the action range and required replacement

at the next available work window. In 2018, the validity of the 2014 testing results was

brought into question by Exelon. The inspectors noted that the invalid test results identified by

the cable reliability program could have been identified and communicated as early as 2014.

Since the communication did not take place until 2018, the station did not appropriately

prioritize the replacement schedule given the true condition of the cables. The inspectors also

noted that during the period between 2014 and 2018, Exelons cable reliability program held

four different program owners which contributed to less program ownership and program

continuity than expected.

The inspectors determined that these observations were minor, in that, there had not been an

actual adverse impact regarding actual cable performance. Additionally, Exelons cable

reliability program had accomplished separate corrective actions to repair multiple

underground vaults containing cables important to safety and these repairs had effectively

limited the ingress of water into the vaults. The inspectors determined that these actions have

adequately protected the medium voltage cables from degradation due to submergence in

water. No issues of concern were identified.

Observations 71152

Core Spray Motor Vibrations

The inspectors reviewed Exelons corrective actions for an elevated vibration trend on the 2C

core spray motor documented under IR 3999563 and NCV 05000277/2017008001. Exelon

appropriately entered the issue into their CAP and developed actions to troubleshoot and

correct the CAQ. The cause of the elevated vibrations were identified to be resonance

vibration of the motor occurring at the normal running speed of the pump. This resonance has

induced an elevated vibration in the motor. Exelon is currently performing interim actions to

mitigate the resonance vibration while long term actions for the motor replacement can be

accomplished. In addition, an extent of condition review was performed on all safety-related

vertically mounted pumps which included RHR, high-pressure service water, and emergency

service water. It was identified that additional core spray motors had symptoms of resonance

vibration, although less significant than the 2C motor. Exelon has established corrective

actions to replace these motors with refurbished motors on a staggered schedule. The

inspectors determined that Exelons completed and proposed actions were reasonable. The

inspectors noted that Exelon consulted with industry vibration experts to develop extensive

and in-depth troubleshooting and mitigating actions. The actions appeared reasonable and

commensurate with the safety significance of the issue. No additional issues of concern were

identified.

EXIT MEETINGS AND DEBRIEFS

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

On July 13, 2018, the inspectors presented the quarterly resident inspector inspection results

to Mr. Matthew Herr, Plant Manager, and other members of the Exelon staff.

13

DOCUMENTS REVIEWED

71111.01

Procedures

MA-AA-716-230-1003, Thermography Program Guide, Revision 5

SE-16, Attachment A, Generation Dispatch TSO Communications to Peach Bottom, Revision 11

71111.04

Procedures

ST-O-51H-201-2, SBO Line TS 3.8.1 B.1 Verification, Revision 4

ST-O-054-951-2, Offsite and Onsite Electrical Power Breaker Alignment and Power Availability

Check with a Start-Up source and/or EDG Inoperable, Revision 7

SO 48.7.A, Emergency Cooling Water System Makeup to Tower Using a High

Pressure Service Water Pump, Revision 10

Drawings

6280-M-359, Sheet 1, RCIC System, Revision 50

6280-M-360, Sheet 1, RCIC Pump Turbine Details, Revision 56

71111.05Q

Procedures

PF-5F, Unit 2 Reactor Building, CS Instrument Room, Elevation 116-0, Revision 4

PF-5K, Unit 2 Reactor Building, General Area, Elevation 195, Revision 7

PF-136, ECT, General Area, Elevation 123-0/153-0, Revision 3

PF-152, Unit 3 Main Transformer Yard, Revision 6

71111.07

Procedures

ER-AA-340-1002, Service Water Heat Exchanger Inspection Guide, Revision 7

WC-AA-101-1004, E-4 EDG TSA - WW 1819/1820, Revision 8

71111.13

Procedures

CC-AA-301, Engineering Standard Request Form, Revision 3

CC-MA-103-2001, Setpoint Methodology for PB and Limerick Generating Station, Revision 2

MA-MA-796-024-1001, Scaffolding Criteria for the Mid-Atlantic Stations, Revision 9

OP-PB-108-117-1000, PB Protected Equipment Tracking Sheet, Attachment 1

SI3P-13-72-ABCE, Calibration Check of RCIC Pump and Turbine Pressure Switches

PS 3-13-67-1 and PS 3-13-72A/B, Revision 7

WC-AA-101-1006, On-line Risk Management and Assessment, Revision 2

Drawings

6280-M-1-S-42, Sheet 21, RCIC System, Revision 77

6280-M-359, Sheet 2, RCIC System, Revision 48

6280-M-360, Sheet 2, RCIC Pump Turbine Details, Revision 54

14

WOs

4260039

Miscellaneous

EC Number: 623997

71111.15

Procedures

ER-AA-321, IST Valve Evaluation Form, Revision 12

OP-AA-108-115, Operability Determinations, Revision 21

Condition Reports

4120966 4130754

Drawings

6280-M-1-S-42, Sheet 17, RCIC System, Revision 74

6280-M-359, Sheet 1, RCIC System, Revision 50

ARs

1311814

71111.18

Engineering Change

ECR PB 07-00031, MO-3-14-026A Not Able to Meet Minimum Thrust, Revision 0

71111.19

Procedures

MA-AA-716-004, Conduct of Troubleshooting, Revision 15

MA-AA-716-234, FIN Team Process, Revision 12

RT-O-052-254-2, E-4 Diesel Generator Inspection Post-Maintenance Functional Test,

Revision 37

ST-I-052-254-2, E-4 Diesel Generator Inspection Post-Maintenance Instrumentation and Logic

Test, Revision 7

ST-I-052-264-2, E-4 Diesel Generator Inspection Post-Maintenance Handswitch Logic Test,

Revision 3

ST-M-57B-762-2, Battery Charger 2BD003-1 and 2BD003-2 Capability Test, Revision 6

ST-O-052-311-2, E-1 Diesel Generator Slow Start Full Load and IST Test, Revision 22

ST-O-052-414-2, E-4 Diesel Generator Fast Start and Full Load Test, Revision 26

ST-O-094-400-2, Stroke Time Testing of Valves for Pre-Maintenance or PMT, Revision 5

WC-AA-106, Priority Screening Matrix, Attachment 1, Revision 18

WC-AA-111-F-01, Surveillance WO Disposition Sheet, Revision 0

Condition Reports

2685664 3968502 4019553 4025384 4054307 4056725

4066576 4070794 4072646 4078903 4111441 4116697

4130767 4134248 4138230 4138464 4139205 4144536

4144592 4149360

15

Drawings

D-11938-10, Wiring Diag. Charger 1, Model 130/200R3-S Battery Charger Power State,

Sheet 1 of 1

WOs

04306095-01 04595788 04755435

Miscellaneous

Battery Information, 2BD003-1 dated June 6, 2018

Log Entries Search Report dated June 5, 2018

71111.22

Procedures

EN-AA-501, Controlled Material Storage Owner Inspection Checklist, Attachment 6, Revision 3

SI3F-10-109-B1C2, Calibration Check of RHR B Loop Flow Instruments FT-3-10-109B,

FR-3-10-143, FI-3-10-139B, FT-3-10-111B, FT-3-10-91076B, FT-3-10-91076D,

FI-3-10-91076B, FI-3-10-91076D, and FI-3-10-136B, Revision 7

ST-I-40D-200-2, Control Room Emergency Ventilation LSFT, Revision 11

Miscellaneous

Pennsylvania Tier II Emergency and Hazardous Chemical Inventory, PB, dated January 1, 2017

to December 31, 2017

Condition Reports

1668149 4125513 4314575

71124.01

Procedures

RW-PB-570, Storage of Radioactive Material and Radiation Waste at the Low Radiation

Storage Area, Revision 007

SF-421, Radiation Protection Requirements for Spent Fuel Casks TN-68-01 through TN-68-44

and TN-68-48 through TN-68-92 Loading and Transport Operations, Revision 008

Condition Reports

04079512 04084790 04098830 04099291 04120191 04135486

Radiation Work Permits

PB-C-18-205

Documents

RP-AA-401, Attachment 2, Combined ALARA / Micro ALARA Plan, U-2 RWCU Sample Sink

Chiller Work 5/21/2018

71124.02

Procedures

NISP-RP-003, Nuclear Industry Standard Process - Radiological Air Sampling

RP-AA-300, Radiological Survey Program, Revision 16.

16

Condition Reports

04068960 04070035

Documents

PB 2017, P3R21 Refuel Outage Report (10/232017-11/072017)

PB 2018-2022, Dose Excellence Plan, Revision 0

71151

Procedures

ST-O-020-560-2, Reactor Coolant Leakage Test, Revision 13

71152

ARs

4000970

Condition Reports

3990487 4012283

Miscellaneous

PB-17-0027, Obtain Spare CS Motor

71153

Procedures

SF-221, Spent Fuel Casks TN-68 Loading and Transport Operations, Revision 20

SF-421, Radiation Protection Requirements for Spent Fuel Casks TN-68-01 through TN-68-44

and TN-68-48 through TN-68-92 Loading and Transport Operations, Revision 8