IR 05000277/2017003

Integrated Inspection Report 05000277/2017003 and 05000278/2017003

ML17306A079
Person / Time
Site:	Peach Bottom
Issue date:	11/02/2017
From:	Schroeder D L Reactor Projects Region 1 Branch 4
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Schroeder D L
References
IR 2017003
Download: ML17306A079 (27)

Text

[Type here] November 2, 2017 Mr. Bryan 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 05000277/2017003 AND 05000278/2017003

Dear Mr. Hanson:

On September 30, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Peach Bottom Atomic Power Station, Units 2 and 3. On October 17, 2017, the NRC inspectors discussed the results of this inspection with Mr. Pat Navin, Site Vice President, 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 NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy. Further, NRC inspectors documented a licensee-identified violation which was determined to be of very low safety significance (Severity Level IV) in this report. 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 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 NRC Resident Inspector at Peach Bottom. 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 NRC Public Document Room in accordance with 10 Code of Federal Regulations (CFR) Exemptions, Requests for Withholding

Sincerely,

/RA/ Daniel L. Schroeder, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 50-277 and 50-278 License Nos. DPR-44 and DPR-56 Enclosure: Inspection Report 05000277/2017003 and 05000278/2017003 w/Attachment: Supplementary Information Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION I Docket Nos.: 50-277 and 50-278 License Nos.: DPR-44 and DPR-56 Report No.: 05000277/2017003 and 05000278/2017003 Licensee: Exelon Generation Company, LLC Facility: Peach Bottom Atomic Power Station, Units 2 and 3 Location: Delta, Pennsylvania Dates: July 1, 2017 through September 30, 2017 Inspectors: J. Heinly, Senior Resident Inspector B. Smith, Resident Inspector C. Bickett, Senior Reactor Inspector T. Daun, Resident Inspector, Susquehanna J. Furia, Senior Health Physicist A. Turilin, Project Engineer D. Werkheiser, Senior Reactor Inspector Approved By: Daniel L. Schroeder, Chief Reactor Projects Branch 4 Division of Reactor Projects 2

SUMMARY

Inspection Report 05000277/2017003 and 05000278/2017003; 07/01/2017 09/30/2017; Peach Bottom Atomic Power Station (PB), Units 2 and 3; Operability Evaluations. This report covered a three-month period of inspection by resident inspectors and announced baseline inspections performed by four region-based inspectors. The inspectors identified one finding, which was of very low safety significance (Green). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined dated April 29, 2015. Cross-Cross-of commercial nuclear power reactors is described in NUREG-Revision 6.

Cornerstone: Mitigating Systems

Green.

A self-revealing NCV of Technical Specification (TS) 5.4.1, Procedures, of very low safety significance (Green) was identified for Exelon not implementing procedural instructions for the replacement of the HS-3-40H-3AV060 switch block associated with the 3AV060 high pressure service water (HPSW) ventilation fan. Exelon did not ensure that electrical connections were free of loose wire strands per their procedural standard E-1317, Wire and Cable Notes and Details, Power, Control, and Instrumentation, Revision 55, and from the vendor manual instructions. As a result, on July 10, 2017, the 3AV060 HPSW ventilation fan failed its surveillance test (ST) and rendered one subsystem of Unit 3 HPSW inoperable. Exelon entered this issue into their corrective action program (CAP) as issue reports (IR) 4030367 and 4044444, straightened out the remaining loose strands, and specified additional electrical panels for an extent of condition (EOC) review. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstoneto ensure the reliability, availability, and capability of systems to respond to initiating events to prevent undesirable consequences (i.e. core damage). By not implementing the E-1317 procedural instructions, the 3AV060 fan failed and affected the reliability of one HPSW subsystem. The inspectors evaluated the finding in accordance with Exhibit 2 of IMC 0609, -significance (Green) because it did not represent a loss of system function or represent an actual loss of function of at least a single train for longer than its TS allowed outage time. The inspectors determined no cross-cutting aspect applied because the PD occurred in 2010 and was not indicative of current performance. (Section 1R15)

Other Findings

A Severity Level IV violation was identified by Exelon has been reviewed by the inspectors. Corrective actions taken and planned by Exelon have been entered into CAP. This violation and corrective action tracking numbers are listed in 4OA7 of this report.

4

REPORT DETAILS

Summary of Plant Status Unit 2 began the inspection period at 100 percent rated thermal power (RTP). On September 12, 2017, operators performed a downpower to 82 percent RTP to remove reactor feed pump (RFP) from service due to control valve oscillations. Following repairs, RFP to service and the unit was returned to 100 percent RTP on September 13, 2017. The unit remained at 100 percent RTP except for brief periods to support planned testing and control rod pattern adjustments.

Unit 3 began the inspection period at 100 percent RTP and remained at 100 percent RTP except for brief periods to support planned testing and control rod pattern adjustments. The unit then began end-of-cycle coastdown for refueling outage 3R21 on August 18, 2017, and ended the inspection period at 86 percent RTP.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems: Unit 3 high-pressure coolant injection (HPCI) system while the reactor core isolation cooling (RCIC) system was inoperable for electrical troubleshooting on August 29, 2017 Unit 2 and Unit 3 E-1, E-3, and E-4 emergency diesel generators (EDG) while E-2 EDG was inoperable for bolt replacements on the exhaust manifold on August 30, 2017 core spray (CS) system during E-1 EDG overhaul on September 14, 2017 residual heat removal (RHR) outage on September 28, 2017 The inspectors selected these systems based on their risk-significance relative to the Reactor Safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the updated final safety analysis report (UFSAR), TS, work orders (WOs), IRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted the system performance of its intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Exelon staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Resident Inspector Quarterly Walkdowns

a. Inspection Scope

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

Unit 2 torus room (PF-5C) on August 11, 2017 Unit 3 torus room (PF-13C) on August 11, 2017 Unit 2 and Unit 3 EDG building (PF-132) on August 30, 2017 and ooms (PF-5D) on September 14, 2017

b. Findings

No findings were identified.

.2 Fire Protection Drill Observation

a. Inspection Scope

The inspectors observed a fire brigade drill scenario conducted on September 22, 2017, that involved a simulated fire in the Unit 2 reactor broom. The inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that the fire brigade instructors identified deficiencies, openly discussed them in a self-critical manner at the debrief, and took appropriate corrective actions (CAs) as required. The inspectors evaluated the following specific attributes of the drill: Proper use of turnout gear and self-contained breathing apparatus Proper use and layout of fire hoses Employment of appropriate fire-fighting techniques Sufficient fire-fighting equipment brought to the scene Effectiveness of command and control Search for victims and propagation of the fire into other plant areas Smoke removal operations Utilization of pre-planned strategies Adherence to the pre-planned drill scenario Drill objectives met

-fighting strategies.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

Internal Flooding Review

a. Inspection Scope

The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to identify internal flooding susceptibilities for the site. The inspectors review focused on the EDG building on August 2, 2017. The inspectors verified the adequacy of equipment seals located below the flood line, floor and water penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and temporary or removable flood barriers. It assessed the adequacy of operator actions that Exelon had identified as necessary to cope with flooding in this area and also reviewed the CAP to determine if Exelon was identifying and correcting problems associated with both flood mitigation features and site procedures for responding to flooding.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

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

a. Inspection Scope

The inspectors observed licensed operator out-of-the-box simulator training on September 11, 2017, which involved a loss of all reactor pressure vessel (RPV) instrumentation requiring flooding of the RPV. The inspectors evaluated operator performance in the control room simulator during the training and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classifications made by the shift manager and the TS action statements entered by the shift technical advisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

b. Findings

No findings were identified.

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

(1 sample)

a. Inspection Scope

The inspectors observed and reviewed the licensed operator performance from the main control room during the activities listed below. The inspectors observed use of and compliance with procedures, crew communications, interpretation, diagnosis, and understanding of plant alarms, use of human error prevention techniques, documentation of activities, and management oversight of the evolution to verify that the crew was following procedures and plant expectations for conduct of operations.

Unit 3 removal of th stage feedwater heaters on July 22, 2017 and turbine on September 13, 2017 The inspectors observed control room briefings and power changes. Additionally, the inspectors observed power changes to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structures, systems, and components (SSCs) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance WOs, and maintenance rule (MR) basis documents to ensure that Exelon was identifying and properly evaluating performance problems within the scope of the MR. For each sample selected, the inspectors verified that the SSC was properly scoped into the MR in accordance with 10 Code of Federal Regulations (CFR) 50.65 and verified that the (a)(2) performance criteria established by the Exelon staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2) status. Additionally, the inspectors ensured that Exelon staff was identifying and addressing common cause failures that occurred within and across MR system boundaries.

Unit 3 drywell chillers on July 24 through 28, 2017 Unit 2 and Unit 3 Appendix R emergency lighting on September 11 through 15, 2017

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Exelon performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the Reactor Safety cornerstones. As applicable for each activity, the inspectors verified that Exelon personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Exelon performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

Unit 2 and Unit 3 E-3 EDG exhaust manifold bolt replacement on July 26, 2017 Unit 2 and Unit 3 standby gas planned maintenance on August 7, 2017 Unit 3 HPSW/RHR cross-tie pipe leak on August 15, 2017 Unit 2 and Unit 3 station blackout (SBO) line tripped on August 17, 2017 Unit 2 and Unit 3 E-1 EDG overhaul on September 11, 2017

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed operability determinations (ODs) for the following degraded or non-conforming conditions based on the risk significance of the associated components and systems: Unit 3 HPCI pressure control valve leaking on July 17, 2017 Unit 3 HPSW cross-tie pipe unexpectedly contained water on August 15, 2017 Unit 2 and Unit 3 HPSW ventilation wire not connected on August 18, 2017 Unit 3 maximum fraction of limiting power density higher than expected on August 25, 2017 Unit 3 Krelief valve electrical ground in the bellows alarm detection circuit on September 5, 2017 Unit 3 HPCI water intrusion into oil reservoir on September 19, 2017 The inspectors evaluated the technical adequacy of the ODs to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to evaluations to determine whether the components or systems were operable.

The inspectors confirmed, where appropriate, compliance with bounding limitations associated with the evaluations, including compliance with in-service testing requirements. Where compensatory measures were required to maintain operability, such as in the case of operator workarounds, the inspectors determined whether the measures in place would function as intended and were properly controlled by Exelon.

b. Findings

Introduction.

A self-revealing NCV of TS 5.4.1, Procedures, of very low safety significance (Green) was identified for Exelon not implementing procedural instructions for the replacement of the HS-3-40H-3AV060 switch block associated with the 3AV060 HPSW ventilation fan. Specifically, Exelon did not ensure that electrical connections were free of loose wire strands per their procedural standard E-1317, and from the vendor manual E-5-167 instructions. As a result on July 10, 2017, the 3AV060 HPSW ventilation fan failed its surveillance test and rendered one subsystem of Unit 3 HPSW inoperable.

Description.

The safety objective of the Unit 3 HPSW system is to provide a reliable supply of cooling water for the Unit 3 RHR system under post-accident conditions. Unit 3 HPSW consists of four 4500 gpm pumps installed in parallel in the pump structure with its normal water supply to the suction of the pumps from the Conowingo pond. Within the pump structure, two emergency ventilation supply and exhaust fans maintain suitable temperatures for safety-related equipment protection during post-accident conditions. Furthermore, the Unit 3 Technical Requirements Manual (TRM) 3.11 requires that two pump structure ventilation subsystems be operable. In the event that one pump structure ventilation subsystem is inoperable, the TRM requires that the station immediately comply with TS section 3.7.1, Condition A, and declare one HPSW subsystem inoperable. On July 10, 2017, during the quarterly ST-O-033-300-2, Revision 42, Unit 3 ESW, Valve, Unit Cooler, and Emergency Cooling Tower Fan Functional In-Service Test, the 3AV060 fan switch was taken to start, but the fan did not start. Upon further disconnected rendering the 3AV060 fan inoperable. Exelon generated IR 4030367 in the CAP and entered TS 3.7.1, declaring the HPSW subsystem inoperable. Exelon subsequently re-landed the wire within one hour, successfully completed the surveillance, and exited the TS 3.7.1 action statement. Previously, the 3AV060 ventilation fan operated successfully on April 14, 2017, during the prior quarterly surveillance. The inspectors discussed C technicians as to the cause of need for an EOC review. In response to the Exelon generated IR 4044444 on August 22, 2017, and identified that IR 4030367 did not have sufficient detail concerning the cause of the disconnected review for the from the wire were loose and not captured under the terminal clamp such that adequate clamping force was not provided. In 2010, the switch block associated with the 3AV060 fan, HS-3-40H-3AV060, had been replaced under WO C0234066 following a previous failure of the 3AV060 fan.

Exelon standard E-1317, Wire & Cable Notes and Details for Power, Control and Instrumentation, Revision 55, states in section 3.3.1 that, n the exceptions section it -5-167, for these snugly. To avoid trouble do noidentified many loose wire strands that had not been captured under the terminal clamp Exelon entered this issue into their CAP as IR 4030367 and IR 4044444, straightened out the remaining loose strands, and specified additional electrical panels for an EOC review.

Analysis.

Exelon-1317 procedural instructions for the replacement of the HS-3-40H-3AV060 switch block was a PD that was within their ability to foresee and correct and should have been prevented. The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone to ensure the reliability, availability, and capability of systems to respond to initiating events to prevent undesirable consequences (i.e., core damage). By not implementing their E-1317 procedural instructions, the 3AV060 fan failed and adversely affected the reliability of one HPSW subsystem. The inspectors evaluated the finding in accordance with Exhibit -Power,finding was of very low safety significance (Green) because it did not represent a loss of system function or represent an actual loss of function of at least a single train for longer than its TS allowed outage time. The inspectors determined no cross-cutting aspect applied because the PD occurred in 2010 and was not indicative of current performance.

Enforcement.

TS 5.4.1, Procedures, states, in part, that written procedures shall be implemented for the applicable procedures recommended in Regulatory Guide (RG) 1.33, Appendix A, November 1972. RG 1.33 section I.1 specifies procedures and instructions shall be preplanned and followed for performing maintenance which can affect the performance of safety-related equipment. Contrary to the above requirement, Exelon did not follow the procedural instructions in E-1317 for ensuring that the replacement of switch block HS-3-40H-3AV060 was installed properly. Because this finding was of very low safety significance and was eIRs 4030367 and 4044444, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000278/2017003-01, Instructions Not Followed for Replacement of HPSW Ventilation Switch Block)

1R18 Plant Modifications

Permanent Modifications

a. Inspection Scope

The inspectors reviewed the station seismic monitoring system replacement modification on August 3, 2017, to determine whether the modification affected the safety function of systems that are important to safety. The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results, and conducted field walkdowns of the modification to verify that the permanent modification did not degrade the design bases, licensing bases, and performance capability of the affected system.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the post-maintenance tests (PMTs) for the maintenance activities listed below to verify that procedures and test activities tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure were consistent with the information in the applicable licensing basis and/or design basis documents, and that the test results were properly reviewed and accepted and problems were appropriately documented. The inspectors also walked down the affected job site, observed the pre-job brief and post-job critique where possible, confirmed work site cleanliness was maintained, and witnessed the test or reviewed test data to verify quality control hold point were performed and checked, and that results adequately demonstrated restoration of the affected safety functions.

Unit 2 and Unit 3 emergency cooling tower valve replacement PMT on July 13, 2017 Unit 2 reactor protection system (RPS) level switch LIS-2-3-99C replacement PMT on August 2, 2017 Unit 2 and Unit 3 standby gas treatment valve replacement PMT on August 7, 2017 Unit 3 RCIC M-series relay contact replacements and PMT on August 14, 2017 Unit 2 and Unit 3 E-1 EDG cam shaft replacement and engine overhaul PMT on September 18, 2017 PMT on September 28, 2017

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed performance of surveillance tests (STs) and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied TSs, the UFSAR, and Exelon procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following STs: Unit 3 control rod settle time testing on July 5, 2017 Unit 2 jet pump core flow verification on July 18, 2017 standby liquid control (SBLC) test on September 18, 2017 Unit 3 HPCI pump, valve, and flow test (IST) on September 20, 2017

b. Findings

No findings were identified. Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation

Emergency Preparedness Drill/Simulator Evaluation/Observation

a. Inspection Scope

The inspectors evaluated the shift manager\preparedness (EP) implementation during a licensed operator out-of-the-box simulator training on September 11, 2017, which involved a loss of all RPV instrumentation requiring flooding of the RPV. The inspectors observed emergency response operations in the simulator to determine whether event classifications and notifications were performed in accordance with approved procedures. The inspectors also attended the control room simulator drill critique to compare inspector observations with those identified by Exelon staff in order to evaluate whether Exelon staff were properly identifying emergency preparedness weaknesses and entering them into the CAP.

b. Findings

No findings were identified.

RADIATION SAFETY

===Cornerstone: Public Radiation Safety

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation

a. Inspection Scope

The inspectors verified the effectiveness of programs for processing, handling, storage, and transportation of radioactive material. The inspectors used the requirements of 49 CFR 170-177, 10 CFR 20, 61, and 71, applicable industry standards, RGs, and procedures required by TS as criteria for determining compliance.

Inspection Planning

The inspectors conducted an in-office review of the solid radioactive waste system description in the UFSAR, the process control program, and the recent radiological effluent release report for information on the types, amounts, and processing of radioactive waste disposed. The inspectors reviewed the scope of quality assurance audits performed for this area since the last inspection.===

Radioactive Material Storage (1 sample) The inspectors observed radioactive waste container storage areas and verified the postings and controls and that Exelon had established a process for monitoring the impact of long-term storage of the waste.

Radioactive Waste System Walkdown (1 sample) The inspectors walked down the following: Accessible portions of liquid and solid radioactive waste processing systems to verify current system alignment and material condition Abandoned in place radioactive waste processing equipment to review the controls in place to ensure protection of personnel Changes made to the radioactive waste processing systems since the last inspection Processes for mixing and transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers Current methods and procedures for dewatering waste Waste Characterization and Classification (1 sample) The inspectors identified radioactive waste streams and reviewed radiochemical sample analysis results to support radioactive waste characterization. The inspectors reviewed the use of scaling factors and calculations to account for difficult-to-measure radionuclides.

Shipment Preparation (1 sample) The inspectors reviewed the records of shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and licensee verification of shipment readiness. Shipping Records (1 sample) The inspectors reviewed selected non-excepted package shipment records. Problem Identification and Resolution (1 sample) The inspectors assessed whether problems associated with radioactive waste processing, handling, storage, and transportation, were identified at an appropriate threshold and properly addressed in CAP.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure (IP) the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Exelon entered issues into the CAP at an appropriate threshold, gave adequate attention to timely CAs, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended IR screening meetings. The inspectors also confirmed, on a sampling basis, that, as applicable, for identified defects and non-conformances, Exelon performed an evaluation in accordance with 10 CFR Part 21.

b. Findings

No findings were identified.

.2 Annual Sample: 10 CFR 50 Appendix R Switchgear Cubicle Wiring Discrepancy

a. Inspection Scope

The inspectors performed an in-actions related to a wiring discrepancy in switchgear cubicles, as documented in issue reports 02465711, 02472724, 02486367, and 02486371. Specifically, during an extent of condition review resulting from another issue, Exelon identified four switchgear cubicles that contained 14-gauge wiring instead of 8-gauge wiring, as specified in station design documents.

The inspectors assessed Exeevaluate whether Exelon staff appropriately identified, characterized, prioritized, and corrected problems associated with this issue. The inspectors compared the actions taken to the requirements in Exelon procedure PI-AA-reviewed associated documents, conducted interviews with station personnel, and completed field walkdowns to gain an understanding of the implemented and planned corrective actions associated with this issue.

b. Findings and Observations

No findings were identified.

In March 2014, the station discovered broken wires during an inspection of the E23 (1606) breaker cubicle (see NRC NCV 05000277, 278/2014004-01). The function of these wires is to connect 125VDC control power to the associated 10 CFR 50 Appendix R transfer/isolation switch when the switch is taken to the emergency position. Use of these transfer/isolation switches is cFire Protection Program as Shutdown Method D, which would be utilized for a fire in the main control room, the cable spreading room, the computer room, or the emergency shutdown panel area. As a result of the apparent cause evaluation associated with this issue, Exelon determined that the following repairs would be completed in breaker cubicles that were part of the extent of condition for this issue: Provide proper and effective strain relief for the affected wires Move the wires from the hinge side of the terminal strip to the opposite side Replace the wire with one that contains a higher strand count and is better suited to handle fatigue stress ctive action program documentation for this issue: Cancellation of Extent of Condition Repairs for Cubicle E22 (1607) The extent of condition repairs discussed above for breaker cubicle E22 (1607) for the 2B high pressure service water pump were cancelled with the following closure remarks: that cancellation of the work order for the specified reason was inappropriate because the switches in this cubicle are used for alternative shutdown per document NE-296, -Exelon documented this issue in the corrective action program as issue report 04053708 questions, the station conducted a walkdown of this breaker cubicle.

Based on the results of the evaluation and walkdown, Exelon concluded that it was appropriate to cancel this work order, but the justification used was less than adequate. Exelon determined that no repairs were needed since the configuration of the terminal strip was different, in that, there was more space between the terminal block and the door hinge, which eliminated the tight radius bend that wires in other cubicles experienced when the door was closed. Additionally, the station determined that the wire loop inside the cubicle was properly secured. Exelon also noted that the cause of this issue was indeterminate, as the individual who had cancelled the work was no longer with the company, and no other documentation was available to provide justification for the closure. The inspectors determined that the station did not appropriately implement Section 4.7.1 of Exelon procedure PI-AA-125 for closure of the issue report and associated action request implementing the extent of condition repairs on breaker cubicle E22 (1607). This section states, in part, that in assignment type, Management Review Committee review and approval is required. This enough to identify the corrective action, as intended, was completed satisfactorily.

subsequent evaluation of this issue, as documented in issue report 04053708, was reasonable, and noted that the evaluation view Committee. The inspectors screened this issue in accordance with NRC Inspection Manual Chapter 0612, Appendix issue was of minor significance because the repairs were ultimately not required, and the condition of the breaker cubicle was acceptable as-is. Untimely Corrective Actions for Wiring Discrepancies During implementation of the extent of condition repairs discussed above, Exelon identified four breaker cubicles where the installed wiring was actually 14-gauge instead of the 8-gauge wiring that was specified in design documentation. Exelon conducted a technical evaluation of the condition, as documented in issue report 02465711-02, and noted that a deficiency did exist, in that, this 14-gauge wire was not protected from damage during fault current situations because the upstream protective device was sized for 8-gauge wire. The station further concluded that based on the configuration and length of the affected cable, the function of the breaker, and the presence of a with the 14 [gauge] wire (temporarily) until the next [technical specification action] (TSA)/outage when the necessary work and planning can be completed prior to entering the TSA conclusions were reasonable. However, though Exelon had discovered the condition in March 2015, the inspectors noted that in some cases, the work to correct this condition was scheduled almost 10 years after discovery, in order to coincide with previously scheduled bus outages. Additionally, the inspectors determined that the station did not revisit the associated technical evaluation prior to extending this work to ensure that the assumptions documented in the evaluation were still appropriate for the work schedule. Exelon entered this issue into their corrective action program as issue report 04064032. The inspectors determined that this issue was a violation of Peach Bottom Unit 2 Operating License Condition 2.C(4) which states, in part, that Exelon shall implement and maintain in effect all provisions of the approved fire protection program. Peach Bottom Fire Protection Program document Section 3.1.2, Item 11.8, adverse to fire protection are promptly identified, reported and corrected. The inspectors screened this issue in accordance with NRC Inspection Manual Chapter 0612, Appendix Enforcement Policy. Specifically, the inspectors noted that there has not been any failures related to this non-conformance since implementation of the modification in 1985. Additionally, the technical evaluation provided reasonable assurance that this non-conformance would have minimal impact on the statioshutdown. Finally, the station has proceduralized steps to manually operate the associated breaker in the event control power is not available.

4OA6 Meetings, Including Exit

Quarterly Resident

Exit Meeting Summary

On October 17, 2017, the inspectors presented the inspection results to Mr. Pat Navin, Site Vice President, and other staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

4OA7 Licensee-Identified Violations

The following violation of Severity Level IV was identified by Exelon and is a violation of NRC requirements which meet the criteria of the NRC Enforcement Policy for being dispositioned as a NCV. 10 CFR 55.25 states, in part, that if an operator develops a permanent physical or mental condition that causes the operator to fail to meet the requirements of 10 CFR 55.21, the facility licensee shall notify the Commission within 30 days of learning of the diagnosis, in accordance with 10 CFR 50.74(c), which states, that the regional administrator shall be notified if a licensed operator develops a permanent disability or illness. Contrary to these requirements, as the result of ical examination audit completed September 26, 2017, Exelon identified a change in a licensed operator medical condition that was not communicated to the NRC within the required 30 days. The results of the medical examination audit were documented in IR 4054146 and subsequent notifications were made to the NRC. This violation is subject to traditional enforcement because of the potential impact upon The inspectors determined that this issue meets the criteria for a Severity Level IV violation using example 6.4.d.1(a) from the NRC Enforcement Policy because no incorrect regulatory decision was made as the result of the failure of the licensee to report within 30 days. This is of very low safety significance because after NRC review of the subsequent notifications, no changes to license restrictions were required.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Exelon Generation Company Personnel

P. Navin, Site Vice President

M. Herr, Plant Manager

N. Alexakos, Emergency Preparedness Manager

J. Armstrong, Regulatory Assurance Manager

D. Baracco, Radiation Protection Manager

D. Dullum, Regulatory Assurance Engineer

S. Griffith, Manager Site Security

D. Henry, Engineering Director

B. Holmes, Radiation Protection Manager

D. Hornberger, Chemistry/Radwaste

P. Kester, Senior Design Engineer

B. Miller, Fire Protection Engineer

M. Rector, Engineering Response Team Manager

M. Retzer, Senior Manager Systems Engineering

R. Riley, Radwaste Shipper

D. Turek, Operations Director

M. Weidman, Work Management Director

T. Wickle, Senior Design Manager

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

05000278/2017003-01 NCV Instructions Not Followed for Replacement of HPSW Ventilation Switch Block (Section 1R15)

LIST OF DOCUMENTS REVIEWED

• -- Indicates NRC-identified

Section 1R04: Equipment Alignment

Procedures

COL 10.1.A-3B, RHR system Setup for Automatic Operation Loop B, Revision 27

COL 14.1.A-2B, CS System Loop B, Revision 11

COL 23.1.A-3, HPCI System, Revision 24

COL 52A.1.A-2, E-2 DG Normal Standby, Revision 15

SO 52A.1.A, DG Lineup for Automatic Start, Revision 14

Drawings

6280-M-361, Sheet 4, RHR System, Revision 74 6280-M-365, Sheet 1, P&ID Diagram HPCI System, Revision 63

Section 1R05: Fire Protection

Procedures

CC-AA-211, Fire Protection Program, Revision 6

FF-01, Fire Brigade, Revision 23

OP-AA-201-001, Fire Marshall Tours, Revision 6

OP-AA-201-003, Fire Drill Performance, Revision 16

OP-AA-201-008, Pre-Fire Plant Manual, Revision 3

OP-AA-201-009, Control of Transient Combustible Material, Revision 19 PF-- PF--

PF-13C, Unit 3 RX Bldg. -

PF-132, DG Building, General Area -

PF-132A DG Building General Area (Upper Level), Revision 4

RT-F-101-922-2, Fire Drill, Revision 3

IRs *4041067 *4041746 *4041879 *4041251

Miscellaneous

Fire Drill Scenario 2017-19 PB Fire Protection Program, Revision 21

Section 1R06: Flood Protection Measures

ARs

00505423

Drawings

C-51, Underground Piping South Area, Revision 37 M-543, Plumbing & Drainage DG Building Floor Plan, Revision 3

Procedures

Internal Hazards DBD No. P-T-09, Revision 11

SE-4 Flood Procedure, Revision 41

Miscellaneous

MR System Basis Document, PB, System 52/52A-G/40F, EDGs, dated August 1, 2017 PBs Alarm Response Card

Section 1R11: Licensed Operator Requalification Program

Procedures

GP-5-2, Power Operations, Revision 5

Miscellaneous

NEI 99-02, Regulatory Assessment PI Guideline, Revision 7 PB3C21-17.0, Reactivity Maneuver Plan, Revision 7/4/17

PSEG-2018R, LORT Scenario, Revision 1

Section 1R12: Maintenance Effectiveness

Procedures

SO 44A.2.A-3, Removing a Drywell Chiller from Service

SO 44A.6.A-3, Placing an Additional Drywell Chiller in Service

SO 44A.7.F-3, Response to a Drywell Chiller Trouble Alarm

SO 44A.8.A-3 Drywell Chilled Water System Routine Inspection, Revision 16

IRs

4036429

4034288

4021846

Work Requests

1358023

1357305

Miscellaneous

Drywell Ventilation MR Basis Document, System Health Report, and Performance History Documents MREP Meeting Minutes on Function 37-1 ELUs Exclusion from the MR

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures

ER-AA-600, Risk Management, Revision 7

ER-AA-600-1042, On-Line Risk Management, Revision 10

OP-AA-108-117, Protected Equipment Program, Revision 4

OP-AA-108-117-1000, PB Protected Equipment Program, Revision 3

OP-AA-201-012-1001, Operations On-line Fire Risk Management, Revision 1

OP-PB-108-101-1002, PB Protected Equipment Tracking Sheet, Attachment A

WC-AA-101, On-Line Work Control Process, Revision 26

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

WC-AA-104, Integrated Risk Management, Revision 23

Miscellaneous

P3R21 Paragon Shutdown Safety Overview P3R21 Shutdown Safety Profile Protective Equipment Tracking Sheets

1R15: Operability Determinations and Functionality Assessments

Procedures

CC-AA-309-101, Engineering Technical Evaluations, Revision 15

ER-AA-200, Preventive Maintenance Program, Revision 2

HU-AA-1212, Technical Task/Rigor Assessment, Pre-job Brief, Independent Third Party Review, and Post-job Review, Revision 7

MA-AA-716-100, Attachment 1, Maintenance Alterations Log, Revision 10

MA-AA-716-100-F-1, Maintenance Alterations Log, Revision 0

OP-AA-108-111, Adverse Conditioning Monitoring and Contingency Plan, Revision 10

ST-O-023-300-3, HPCI Pump, Valve, Flow and Unit Cooler Functional and In-service Test Without Vibration Data Collection, Revision 12

Drawings

6280-M-365, Sheet 1, HPCI System, Revision 63 6280-M-366, Sheet 1, HPCI Pump Turbine Details, Revision 57 E-202, Electrical Schematic Diagram Intake Structure Ventilation System, Revision 22 E-1317, Wire and Cable Notes and Details Power, Control, and Instrumentation, Revision 55

WO 0234066

0240071

4306865

4688304

WR 1283394

1359912

IRs

4030367 *4044444 *4052562 *4052566

4054022

4033575

4050431

4047489

4075403

3966085

4045515

1523656

4041821

Miscellaneous

ACMP for PB3 High Core Thermal Limit (MFLPD)

BWROG-TP-14-016, HPCI Steam Admission Valve Leakage, Revision 0 Technical Evaluation for U3 71K Safety Relief Valve Bellows Pressure Leak Monitor Circuit Ground Vendor Manual E-5-167 Instructions CR2940 Push Button and Signal Station

Section 1R18: Plant Modifications

Procedures

WC-AA-101, On-Line Work Control Process Revision 27

IRs

4049250

Miscellaneous

EC556261, Seismic Monitoring System Replacement, Revision 0

Section 1R19: Post-Maintenance Testing

Procedures

MA-AA-716-012, PMT, Revision 23

RT-O-052-251-2, E-1 DG Inspection Post-Maintenance Functional Test, Revision 32

ST-I-60F-100-2, RPS Logic System Functional Test, Revision 10

ST-O-010-406-3, RHR Loop A Backup Power Supply Transfer Test, Revision 1

ST-O-013-301-2, RCIC Pump, Valve, Flow, and Unit Cooler Functional and In-Service Test,

Revision 48

ST-O-033-300-2, ESW Valve Unit Cooler and ECT Fans Functional Inservice Test, Revision 42

ARs

A1522766

WOs

4181947

4181947

4231284

4243305

4279032

4295177

4298707

4601445

4609778

WRs 1264825

1363466

IRs

4032455

4033110

4033375

4050985

4050989

4051006

4051042

4051076

4051097

4051322

4051323

4051324

4051386

4051390

4051655

4051748

4051827

4052685

4052691

4052816

4052819

4052823

4052844

4052849

4052931

4053452 4053511

Section 1R22: Surveillance Testing

Procedures

RT-R-003-961-3, CRD Friction Monitoring

Settle and Full Stroke Insertion Testing, Revision 8

ST-O-011-301-2, Standby Liquid Control Pump A Functional Test for IST

ST-O-023-300-3, HPCI Pump, Valve, Flow and Unit Cooler Functional and In-service Test Without Vibration Data Collection, Revision 12

ST-I-002-250-2, Core Flow Verification, Revision 5

ST-O-02F-560-2, Daily Jet Pump Operability, Revision 18

Miscellaneous

SC 11-05, Failure to Include Seismic Input in Channel-Control Blade Interference Customer Guidance, Revision 2

Section 1EP6: Drill Evaluation

Miscellaneous

NEI 99-02, Regulatory Assessment PI Guideline, Revision 7

PSEG-2018R, LORT Scenario, Revision 1

Section 2RS8: Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation

Procedures:

CY-PB-130-516, Resin Analysis, Revision 1

RP-AA-602, Packaging of Radioactive Material Shipments, Revision 20

RP-AA-602-1001, Packaging of Radioactive Materials/Waste Shipments, Revision 17

RP-AA-603, Inspection and Loading of Radioactive Material Shipments, Revision 10

RP-PB-605-1001,

PB 10

CFR 61 Program, Revision 3

RT-H-099-931-2, Rad Pro Shipping QA Review for 10

CFR 20, App G, Revision 2

RW-AA-100, Process Control Program for Radioactive Wastes, Revision 11

RW-AA-605, 10

CFR 61 Program, Revision 7

Quality Assurance Check-In Self-Assessment, Radwaste, August 2015

10 CFR Part 61 Scaling Factors: Teledyne Brown Engineering Reports of Analysis for Dry Active Waste, Unit 2 Spent Fuel Pool, Unit 3 Spent Fuel Pool, Radwaste Resin, Oil Samples, RWCU Elements, and RWCU Filters

IRs:

02673186

02694231

02700574

02718219

02727434

03978900

03985906

03992177

04016356

Training:

HAZSEC-A1, DOT Security Awareness and Transportation Security Plan, Rev 0 NRWSHP1000, DOT/79-19 Training for Support of Radioactive and Asbestos Shipments

Shipments:

16-0019 16-0020 16-0011 17-0020 17-0021

Section 4OA2: Problem Identification and Resolution

IRs

01662555

01690543

01690548

01690524

01690527

01690529

01690533

01690535

01690536

01690537

01690543

01690545

01690548

01690550

01690553

01690555

02465711

02472724

02486367

02486371

04053708

Drawings

E-193, Sheet 2, Electrical Schematic Diagram Emergency Auxiliary Switchgear Diesel Generator 4160V Circuit Breaker, Revision 33 E-1317, Wire and Cable

Notes & Details, Power, Control, and Instrumentation, Revision 55 6280-E7-142-1, Medium Voltage Metalclad Switchgear Connection Diagram, Revision 7

Procedures

AO 54.2, 4KV Breaker Manual Operation, Revision 0

CC-AA-309-101, Engineering Technical Evaluations, Revision 15

SE-10, Alternative Shutdown, Revision 21

SE-10, Plant Shutdown from the Alternative Shutdown Panels

Bases, Revision 29

SE-10, Attachment 6, 4KV Alternative Shutdown Panel Setup and Transfer of 125V Battery Charger 2BD003 to Alternate Power Source

PI-AA-125, Corrective Action Program Procedure, Revision 5

WC-AA-106, Work Screening and Processing, Revision 17

CC-AA-309-101, Engineering Technical Evaluations, Revision 15

Surveillance Tests

ST-O-054-752-2, E22 4KV Bus Undervoltage Relays and LOCA LOOP Functional Test and E22 and E224 Alternative Shutdown Control Functional Test, Revision 27, completed 10/31/2016

Miscellaneous

LER 2-14-001, Unanalyzed Condition due to Broken Wires in Breakers Used for Appendix R Post-Fire Safe Shutdown Peach Bottom Atomic Power Station Fire Protection Program, Revision 19

LIST OF ACRONYMS

CA corrective action

CAP corrective action program

CFR Code of Federal Regulations

CR condition report

CS core spray

DG diesel generator

EDG emergency diesel generator

ESW emergency service water

HPCI high pressure coolant injection

HPSW high pressure service water

IMC inspection manual chapter

IP inspection procedure

IR issue report

MR maintenance rule

NCV non-cited violation

NEI Nuclear Energy Institute

NRC Nuclear Regulatory Commission

OD operability determinations

OOS out of service

PARS publicly available records

PB Peach Bottom Atomic Power Station

PD performance deficiency

PI performance indicator

PMT post-maintenance testing

RCIC reactor core isolation cooling

RFP reactor feed pump

RG regulatory guide

RHR residual heat removal

RPV reactor pressure vessel

RTP rated thermal power

SDP significance determination process

SSC structure, system, and component

ST surveillance test

TRM technical requirements manual

TS technical specification

UFSAR Updated Final Safety Analysis Report WOs work orders