IR 05000277/2013008

IR 05000277-13-008; 05000278-13-008; on 05/06/13 - 05/23/13; Peach Bottom Atomic Power Station, Units 2 and 3 - Nuclear Regulatory Commission Problem Identification and Resolution Inspection Report

ML13176A401
Person / Time
Site:	Peach Bottom
Issue date:	06/25/2013
From:	Mel Gray Reactor Projects Region 1 Branch 4
To:	Pacilio M Exelon Generation Co, Exelon Nuclear
gray, mel
References
IR-13-008
Download: ML13176A401 (16)

Text

June 25, 2013

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 - NUCLEAR REGULATORY COMMISSION PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000277/2013008 AND 05000278/2013008

Dear Mr. Pacilio:

On May 23, 2013, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Peach Bottom Atomic Power Station, Units 2 and 3. The enclosed report documents the inspection results, which were discussed on May 23, 2013, with Mr. Patrick Navin, Plant Manager, and other members of your staff.

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

Based on the samples selected for review, the inspectors did not identify any findings during this inspection. The inspectors concluded that Exelon was generally effective in identifying, evaluating, and resolving problems. Exelon personnel identified problems and entered them into the corrective action program at a low threshold. Exelon, in general, prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were implemented in a timely manner. Lessons learned from industry operating experience were effectively reviewed and applied when appropriate. Additionally, the inspectors concluded that self-assessments and audits reviewed during the inspection were critical, thorough, and effective in identifying issues.

In accordance with Title 10 Code of Federal Regulations 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencyw ide Documents Access 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/ Mel Gray, Chief Reactor Projects Branch 4 Division of Reactor Projects

Docket Nos. 50-277, 50-278 License Nos. DPR-44, DPR-56

Enclosure:

Inspection Report 05000277/2013008 and 05000278/2013008 w/Attachment: Supplementary Information

REGION I==

Docket Nos. 50-277 and 50-278

License Nos. DPR-44 and DPR-56

Report Nos. 05000277/2013008 and 05000278/2013008

Licensee: Exelon Generation Company, LLC

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

Location: Delta, PA

Dates: May 6, 2013 through May 23, 2013

Team Leader: Thomas Setzer, Senior Project Engineer

Inspectors: Carey Bickett, Senior Project Engineer George Smith, Physical Security Inspector Adam Ziedonis, Peach Bottom Resident Inspector

Approved by: Mel Gray, Chief Reactor Projects Branch 4 Division of Reactor Projects

2 Enclosure

SUMMARY

IR 05000277/2013008 and 05000278/2013008; 05/06/13 - 05/23/13; Peach Bottom Atomic Power Station, Units 2 and 3; Biennial Baseline Inspection of Problem Identification and

Resolution.

This NRC team inspection was performed by three regional inspectors and one resident inspector. The NRC's program for overseeing t he safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reac tor Oversight Process," Revision 4, dated December 2006.

Problem Identification and Resolution The inspectors concluded that Exelon was genera lly effective in identifying, evaluating, and resolving problems. Exelon personnel identified problems, entered them into the corrective action program at a low threshold, and in general, prioritized issues commensurate with their safety significance. Exelon appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that Exelon implemented corrective actions to address the problems identified in the corrective action program in a timely manner.

The inspectors concluded that Exelon adequately identified, reviewed, and applied relevant industry operating experience to Peach Bottom operations. In addition, based on those items selected for review, the inspectors determined that Exelon's self-assessments and audits were thorough.

Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues, nor did they identify any conditions that could have had a negative impact on the site's safety conscious work environment.

No findings were identified.

REPORT DETAILS

4OA2 Problem Identification and Resolution

This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. All documents reviewed during this inspection are listed in the Attachment to this report.

.1 Assessment of Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures that described Exelon's corrective action program at Peach Bottom. To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in thes e areas to the requirements and standards contained in Title 10 Code of Federal Regulations 50, Appendix B, Criterion XVI, "Corrective Action," and Exelon procedure LS-AA-125, "Corrective Action Program Procedure." For each of these areas, the inspectors considered risk insights from the station's risk analysis and reviewed condition reports selected across the seven cornerstones of safety in the NRC's Reacto r Oversight Process. Additionally, the inspectors attended multiple Plan-of-the-Day, Station Ownership Committee, and Management Review Committee meetings. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, and radiation protection.

(1) Effectiveness of Problem Identification

In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures and periodic trend reports. The inspectors also completed field walkdowns of various systems on site, such as the emergency diesel generators, high pressure coolant injection, reactor core isolation cooling, core spray, residual heat removal, 125 Vdc batteries, and 4kV equipment rooms. Additionally, the inspectors reviewed a sample of condition reports written to document issues identified through internal self-assessments, audits, and the operating experience program. The inspectors completed this review to verify that Exelon entered conditions adverse to quality into their corrective action program as appropriate.

(2) Effectiveness of Prioritization and Evaluation of Issues

The inspectors reviewed the evaluation and prioritization of a sample of condition reports issued since the last NRC biennial Problem Identification and Resolution inspection completed in August 2011. The inspectors also reviewed condition reports that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors' review included the 4 Enclosure appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.

(3) Effectiveness of Corrective Actions The inspectors reviewed Exelon's completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed condition reports for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Exelon's timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of condition reports associated with selected non-cited violations and findings to verify that Exelon personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate Exelon actions related to average power range monitors and conditions associated with reactor half-scram signals.

b. Assessment

(1) Effectiveness of Problem Identification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Exelon identified problems and entered them into the corrective action program at a low threshold. Exelon staff at Peach Bottom initiated approximately 32,000 condition reports between August 2011 and May 2013. The inspectors observed supervisors at the Plan-of-the-Day, Station Ownership Committee, and Management Review Committee meetings appropriately questioning and challenging condition reports to ensure clarification of the issues.

Based on the samples reviewed, the inspectors determined that Exelon trended equipment and programmatic issues, and appropriately identified problems in condition reports. Additionally, inspectors concluded that personnel were identifying trends at low levels. In general, inspectors did not identify any issues or concerns that had not been appropriately entered into the corrective action program for evaluation and resolution. In response to several questions and minor equipment observations identified by the inspectors during plant walkdowns, Exelon personnel promptly initiated condition reports and took immediate action to address the issues.

(2) Effectiveness of Prioritization and Evaluation of Issues

The inspectors determined that, in general, Exelon appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. Exelon screened condition reports for operability and reportability, categorized the condition reports by significance, and assigned actions to the appropriate department for evaluation and resolution. The condition report screening process considered human 5 Enclosure performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.

Based on the sample of condition reports reviewed, the inspectors noted that the guidance provided by Exelon corrective action program implementing procedures appeared sufficient to ensure consistency in categorization of issues. Operability and reportability determinations were performed when conditions warranted and the evaluations supported the conclusion. Causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue. However, the inspectors noted the following observation in Exelon's prioritization of condition reports.

Exelon generated condition reports 1396023 and 1272124 to document Maintenance Rule concerns with the 480V and core spray systems, respectively. Included in these condition reports were actions to perform a Maintenance Rule paragraph a(1) determination to evaluate each system's Maintenance rule classification. The station assigned a significance level of 4 to both of these condition reports. Exelon procedure LS-AA-120, Attachment 2, "Issue Report Level and Class Criteria," provides examples to be considered when assigning a condition report significance level. LS-AA-120 defines a potential Maintenance Rule a(1) condition as a significance level 3 condition report. The inspectors determined that assigning a level 4 to condition reports 1396023 and 1272124 did not meet the guidance described in LS-AA-120, and therefore, was a performance deficiency. However, because these issues were isolated cases and did not indicate a programmatic weakness to properly prioritize condition reports, the inspectors determined that the issue was of minor significance and not subject to enforcement action in accordance with the NRC's Enforcement Policy. Exelon documented this issue in condition report 1513303.

(3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were, in general, timely and adequately implemented. For significant conditions adverse to quality, Exelon, in general, identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC non-cited violations and findings since the last problem identification and resolution inspection were timely and effective. However, the inspectors noted the following observation associated with prompt corrective action.

The inspectors reviewed root cause evaluation 938245 and determined that Exelon did not take prompt corrective action for a condition adverse to quality. Since 2009, Exelon has experienced multiple steam leak detection instrument power supply failures due to grounds that have affected the 125Vdc syst em. Exelon staff developed a corrective action to prevent recurrence (CAPR) to revise design specifications for the steam leak detection system power supplies to include adequate voltage surge suppression capability for equipment connected to the direct current system. The CAPR, however, did not require replacement of the power supplies currently installed in the plant under the previous design specification.

Since power supply failures have continued to occur since the CAPR was completed, the inspectors determined that not promptly correcting the steam leak detection system power supply failures was a performance deficiency.

The inspectors screened the issue in accordance with NRC Inspection Manual Chapter (IMC) 0612, Appendix B, "Issue Screening," and IMC Appendix E, "Examples of Minor 6 Enclosure Issues," and determined the issue was similar to the minor example in example 4d. The inspectors determined the issue was of minor significance and not subject to enforcement action because the failure of Exelon's CAPR to promptly correct power supplies problems did not impact safety. The main steam leak detection system is designed with redundant power supplies, therefore a single power supply failure has no safety impact, and multiple, concurrent failures would be required to generate a single channel containment isolation valve trip signal. Exelon entered this issue into the corrective action program in condition report 1522740.

c. Findings

No findings were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed a sample of condition reports associated with review of industry operating experience to determine whether Exelon personnel appropriately evaluated the operating experience information for applicability to Peach Bottom and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Exelon personnel adequately considered the underlying problems associated with the issues for resolution via their corrective action program. In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.

b. Assessment The inspectors determined that Exelon appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also observed that industry operating experience was routinely discussed and considered during the conduct of Station Ownership Committee and Management Review Committee meetings.

c. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, focused area self-assessments, and check-in self-assessments performed by Exelon. Inspectors performed these reviews to determine if Exelon entered problems identified through these assessments into the corrective action 7 Enclosure program, when appropriate, and whether Exelon initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.

b. Assessment The inspectors concluded that focused area self-assessments, check-in self-assessments, and audits were critical, thorough, and effective in identifying issues. The inspectors observed that Exelon personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. Exelon staff completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. The station implemented corrective actions associated with the identified issues commensurate with their safety significance.

c. Findings

No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

During interviews with station personnel, the inspectors assessed the safety conscious work environment at Peach Bottom. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management or the NRC. The inspectors also interview ed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns. The inspectors reviewed the Employee Concerns Program files to ensure that Exelon entered issues into the corrective action program when appropriate.

b. Assessment During interviews, Peach Bottom staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the corrective action program and the Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was not evidence of an unacceptable safety conscious work environment and there were not significant challenges to the free flow of information.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On May 23, 2013, the inspectors presented the inspection results to Mr. Patrick Navin, Plant Manager, and other members of the Peach Bottom staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this

report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Arters, Chemistry Technician

C. Bauer, RCIC System Manager

R. Brightup, Air Operated Valve Program Manager

D. Dullum, Licensing Engineer

M. Flynn, Senior Maintenance Programs Specialist

A. Fogarty, Chemistry Staff

J. Fogarty, Outage Planner

S. Griffith, Security Operations Manager

M. Grim, Chemistry Technician

J. Kelly, Employee Concerns Specialist

J. Kovalchick, Site Security Manager

R. Lack, System Engineer

M. Long, Senior Engineering Manager

D. McClellan, Senior Regulatory Engineer

G. Mehrotra, Senior Electrical Engineer

M. Miller, Employee Concerns Specialist

J. Moore, Operations Outage Manager Assistant

R. Moye, System Engineer

J. Paxson, Chemistry Technician

C. Reynolds, Motor Operated Valve Program Manager

R. Shortes, Radiation Engineering Manager

D. Turek, Shift Operations Superintendent

D. Wheeler, Maintenance Rule Program Coordinator

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened and Closed

None