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 followup 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.
