IR 05000171/2009007
| ML092540142 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/11/2009 |
| From: | NRC Region 1 |
| To: | Pardee C G Exelon Generation Co |
| References | |
| IR-09-007 | |
| Download: ML092540142 (12) | |
Text
Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION I INSPECTION REPORT Inspection No. 05000171/2009007 Docket No. 05000171
License No. DPR-12 Licensee: Exelon Generation Company, LLC
Facility: Peach Bottom Atomic Power Station, Unit 1 Location: Delta, Pennsylvania 17314-9032 Inspection Dates: August 10-12, 2009
Inspector: Laurie A. Kauffman, Health Physicist Decommissioning Branch Division of Nuclear Materials Safety Approved By: Judith A. Joustra, Chief Decommissioning Branch Division of Nuclear Materials Safety
2 Enclosure
EXECUTIVE SUMMARY
Exelon Generation Company, LLC Peach Bottom Atomic Power Station (PBAPS), Unit 1 (U1) NRC Inspection Report No. 05000171/2009007
This routine inspection included a review of SAFSTOR activities related to the safe storage of radioactive material and implementation of the U1 Technical Specification (TS) requirements. The inspection was conducted by an NRC Region I health physics inspector, and focused on Exelon's implementation of access controls to the exclusion areas, performance of periodic maintenance inspections, maintenance of records, and submittal of annual reports. In addition, the inspector reviewed Exelon's programs for quality assurance, corrective actions, maintenance and surveillance, radiation controls, radioactive effluents, environmental monitoring and radioactive waste management and transportation.
Operations and Decommissioning
The licensee implemented adequate management oversight of SAFSTOR activities for the U1 facility, as required by TS and the U1 Updated Final Safety Analysis Report, Revision 4 (UFSAR). The licensee adequately evaluated, conducted, managed and controlled facility design changes and modifications. This included appropriate verification that the changes and modifications did not require license amendments. The licensee implemented its established maintenance and surveillance program to maintain the U1 facility and monitor for potential ground water leakage into the containment vessel. The licensee also adequately utilized its established corrective action program to self-identify, evaluate, and resolve deficiencies associated with the facility.
Plant Support and Radiological Controls The licensee's implementation and oversight of the SAFSTOR program were effective for the storage of radioactive material. The licensee adequately implemented and maintained the radiation protection, radioactive effluent controls, radiological environmental monitoring, and radioactive waste management programs. The licensee provided adequate controls to limit exposures of workers to external sources of radiation. Posting and labeling of radioactive material areas and radiation areas complied with regulatory requirements. No occupational or public dose concerns were identified.
There were no NRC identified findings or self-revealing findings as a result of this inspection.
1 SAFSTOR, according to NRC Inspection Manual Chapter 2561, is the decommissioning method of placing and maintaining the nuclear facility in a condition that allows the radioactive material to be safely stored and the facility to be subsequently decontaminated to permit the release of the property and termination of the license.
REPORT DETAILS
1.0 Background The Peach Bottom Atomic Power Station, (PBAPS) Unit 1 (U1) is a high temperature gas-cooled demonstration power reactor that operated from February 1966 until October 31, 1974, and has been permanently shutdown and in safe storage (SAFSTOR) since that time. All fuel has been removed from the reactor and shipped to an offsite facility. The spent fuel pool has been drained and decontaminated, and all radioactive liquids have been removed.
2.0 Organization and Management Controls 2.1 Organization and Management Controls; Design Changes and Modifications; and Decommissioning Status
a. Inspection Scope
(Inspection Procedures (IPs) 36801, 37801, 71801)
The inspector evaluated the licensee's organization regarding management oversight of SAFSTOR responsibilities for U1, required by Technical Specifications (TS) 2.1(a). The TS 2.1(a) stipulates that the Peach Bottom Plant Manager maintain the responsibility for administration of all U1 functions.
The inspector reviewed the U1 Updated Final Safety Analysis Report, Revision 4 (UFSAR), the licensee's processes and procedures (LS-PB-800, Unit 1 Process Control Program and LS-AA-104, Exelon 50.59 Review Process), and conducted interviews with engineering and licensing personnel, to evaluate plant modifications that involved (1) the removal of certain barricades to support an assessment of potential ground water intrusion into the containment vessel and (2) the removal of water that accumulated in the containment vessel and was transferred to the Unit 2 radioactive waste building. The inspector reviewed the licensee's processes and procedures, including Action Request (A/R 1676648) and engineering design change request (ECR 08-00414) to determine that facility design changes and modifications were conducted, managed and controlled for the above modifications.
b. Observations and Findings
Since the previous inspection, the licensee had assembled a team and created a charter to provide a focused responsibility to implement the SAFSTOR program as required by the U1 TS. The Chemistry Manager was designated as the team lead and reports directly to the plant manager. Team members were designated from several disciplines (chemistry, operations, engineering, business operations, radiation protection/radioactive waste, maintenance, document control, and decommissioning) to perform cross functional area oversight. During this inspection, the inspector reviewed procedures associated with the SAFSTOR program and interviewed and observed selected team members during the semi-annual surveillance test (ST), ST-H-099-960-2, Unit 1 2 A list of acronyms used in the report is included at the end of the Report Details.
4 Enclosure Exclusion Area Semi-Annual Inspection, which includes entry into the containment vessel. Based on the team's implementation of the ST, the material condition of the containment vessel, and the team's increased awareness of the SAFSTOR program, the inspector determined that the team improved the licensee's oversight of SAFSTOR activities and implementation of the U1 TS and the SAFSTOR program.
During the previous inspection, the inspector identified a non-cited violation associated with the presence of water in the basement of the containment vessel. (Refer to NRC Inspection Report 05000171/2008009, dated October 10, 2008, [ADAMS Accession Nos.: ML082880597 and ML082880609] for details.) Since the previous inspection, the licensee initiated an evaluation to identify potential sources of ground water intrusion. The licensee determined that certain barricades inside the containment vessel had to be removed in order to access areas of the building that had not been accessed for approximately thirty years. During the evaluation, the licensee identified several possible sources of water intrusion and instituted repairs. Details of the sources of water intrusion are discussed in Section 3.1.b of this inspection report. The licensee pumped the water that had accumulated in the containment vessel into drums. The licensee conducted an engineering evaluation (ECR 08-00414) prior to the removal and transfer of water from the U1 containment vessel to the Unit 2 radioactive waste building.
When the facility was placed in SAFSTOR, barricades were installed (bolted to the concrete) to prevent inadvertent personnel access and to maintain control of radioactive material and to comply with Title 10 of the Code of Federal Regulations, Part 20 (10 CFR Part 20), Standards for Protection Against Radiation. The barricades are illustrated in UFSAR Section 4.4.3 (Figures 4.4-2, 4.4-4 and 4.4-5). Additionally, the barricades are specifically identified in the semi-annual surveillance test (ST), ST-H-099-960-2, Unit 1 Exclusion Area Semi-Annual Inspection. These barricades, identified in the ST, were installed on the ground floor (barricades B-5, B-6 and B-7), upper basement (barricades B-8 and B-9), lower basement (barricades B-10, B-11 and B-12), and refueling floor (barricades B-13, B-14, B-15, B-16 and B-17). The inspector conducted a tour inside the containment vessel and verified that the UFSAR barricades B-6, B-8, B-9, B-10 and B-12 were removed for access and inspection and that the barricades required by TS 2.1(b) 1. vi., located on the refueling floor, remained in place.
The inspector verified that the licensee adequately used procedures LS-PB-800, Unit 1 Process Control Program and LS-AA-104, Exelon 50.59 Review Process to determine that the changes and modifications did not require license amendments prior to the removal of the barricades. The inspector reviewed the licensee's technical evaluations and UFSAR, and verified that the facility design changes and modifications were properly conducted, managed and controlled. The inspector also confirmed that the UFSAR was updated to reflect the changes of the water removal, and because the barricades are not specifically described in the UFSAR, the inspector determined that the UFSAR was not updated relative to the removal of specific barricades.
c. Conclusions
The licensee implemented adequate management oversight of SAFSTOR activities for the U1 facility, as required by TS 2.1(a), and the U1 UFSAR, Revision 4. The licensee adequately evaluated, conducted, managed and controlled facility design changes and modifications. In addition, the licensee verified that the changes and modifications did not require license amendments.
2.2. Self-Assessment, Auditing, and Corrective Action Programs
a. Inspection Scope
(IP 40801)
The inspector reviewed and evaluated three assessments conducted by Nuclear Oversight (NOS) and one self-assessment conducted by radiation protection regarding the SAFSTOR activities at U1. The inspector also reviewed elements of the corrective action program (CAP) for the identification, evaluation, and resolution of problems. The inspector reviewed the procedure, LS-AA-125, Corrective Action Program (CAP) Procedure and reviewed selected assignment reports (ARs) and issue reports (IRs) from August 2008 through August 12, 2009 relative to U1 issues, including monitoring for potential water intrusion into the containment vessel.
b. Observations and Findings
A self-assessment of the U1 SAFSTOR program was conducted using the procedure, LS-AA-126-1005, Check-In Self-Assessments, Revision 4. The self-assessment was conducted to assess whether U1 facility maintenance, monitoring, and safety programs were effective at maintaining public health and safety, and environmental safety, while the plant remains in a SAFSTOR condition. The self-assessment included an evaluation of the previous NRC-identified non-cited violations, the water intrusion evaluation, and associated procedures and processes. The licensee's self-assessment was thorough and sufficiently detailed to identify strengths and weaknesses related to the U1 facility.
Three NOS assessments were performed since the previous inspection. These assessments were sufficiently detailed to identify issues at the U1 facility.
The licensee used the CAP to identify and resolve issues. Corrective actions were established to address identified issues, and were being tracked to closure using the CAP. The priority for addressing IRs and ARs and implementing corrective actions was adequate and based upon safety significance. The inspector determined that the licensee identified and corrected concerns related to the U1 facility, including monitoring for potential water intrusion into the containment vessel. No adverse trends or safety concerns were identified.
c. Conclusions
The licensee utilized its established corrective action program to identify, evaluate and resolve concerns associated with the U1 facility, including monitoring for potential water intrusion into the containment vessel.
3.0 Decommissioning Performance and Status at Permanently Shutdown Reactors 3.1 Maintenance and Surveillance Program and Decommissioning Status
a. Inspection Scope
(IPs 62801 and 71801)
The inspector evaluated the maintenance and surveillance program related to the implementation of the semi-annual surveillance test (ST), ST-H-099-960-2, Unit 1 Exclusion Area Semi-Annual Inspection, Revision 16. The inspector selected portions of the ST to ensure that the licensee verifies that the U1 exclusion area barriers and personnel access doors to the containment vessel, the radioactive waste building, and the spent fuel pool building are locked and intact (TS 2.1.b.1); verifies that water accumulation in the containment sump is less than 500 gallons (TS 2.1.b.9.), and assesses the material condition of the U1 facility (TS 2.3.b.1), including the containment vessel, the radioactive waste building, and the spent fuel pool building.
b. Observations and Findings
The inspector observed the licensee conducting visual inspections to assess the material condition of the containment vessel, the radioactive waste building, and the spent fuel building. The inspector also observed the licensee check for water intrusion and verify that the accumulation of water in the containment sump was less than 500 gallons. The inspector reviewed and assessed the completed ST records from January 2009 to August 12, 2009. The inspector determined that the license implemented its maintenance and surveillance program according to the ST and the applicable TS requirements.
The inspector determined that the licensee had identified three additional areas where water had accumulated due to apparent ground water intrusion. During the previous inspection, the inspector identified a non-cited violation for the presence of water in the basement of the containment vessel and for the licensee's failure to perform a radiological analysis of the water. Specifically, water accumulated in the containment vessel on the 87-foot, 9-inch (87'9") elevation under a removable floor plate (diamond-plate) in the hallway that leads to the sub-pile room and the licensee did not conduct a thorough evaluation to determine the source of the water. As of March 2009, all the water had been removed from the containment vessel, processed through the Unit 2 (U2) radioactive waste processing system, and discharged using the radioactive discharge procedure, ST-C-095-805-2, Liquid Radwaste Discharge, Revision 13. As of August 12, 2009, there was no evidence of ground water leakage into the containment vessel. The licensee's investigation and dose assessment are discussed in Section 4.2(b) of this inspection report.
c. Conclusions
The licensee implemented its established maintenance and surveillance program to maintain the U1 facility and monitor for potential ground water leakage into the containment vessel.
4.0 Plant Support and Radiological Controls
4.1 Occupational Radiation Safety; Radioactive Effluent Control Program; and Radiological Environmental Monitoring Program; Radioactive Waste Management and Transportation
a. Inspection Scope
(IPs 83750, 84750, 86750 and 84850)
The inspector evaluated the licensee's SAFSTOR activities, including portions of the following programs: radiation protection, radioactive effluent monitoring, radiological environmental monitoring, and radioactive waste management and transportation. The inspector evaluated the licensee's implementation of the TS requirements for: (1) control of access to the exclusion areas (TS 2.1.b.1); (2) performance of periodic inspections (TS 2.1.b.7, TS 2.1.b.8, TS 2.3.b.); and, (3) maintenance of records, including records required by 10 CFR 50.75(g) and reportable events (TS 2.3), and (4) submittal of annual reports (TS 2.4.a). The inspector also evaluated the radiation protection program related to the implementation of the semi-annual ST, ST-H-099-960-2, "Unit 1 Exclusion Area Semi-Annual Inspection, Revision 16 and associated records from January 2009 to August 12, 2009. The inspector reviewed the most recent annual report, PBAPS Unit 1 Decommissioning Status Report, dated May 8, 2009. The inspector also verified that the licensee complied with the requirements of 10 CFR Part 20, Appendix B, and 10 CFR Part 50, Appendix I.
b. Observations and Findings
The inspector observed the licensee implement the exclusion area ST, which included the performance of radiation survey measurements, surface contamination surveys, and air particulate samples in the containment vessel. The inspector also observed the licensee conduct visual inspections relative to material condition of the containment vessel, radioactive waste building, and the spent fuel pool building, including monitoring for potential water intrusion. The inspector assessed radiation worker practices, radiological postings and barriers, and access controls to the containment vessel, the radioactive waste building, and the spent fuel pool building. The inspector determined that the licensee had verified that the radiation levels in the containment vessel, the spent fuel pool building and the radioactive waste building were less than 0.2 millirem per hour (mrem/hr), and that smearable contamination levels were less than 1000 disintegrations per minute per 100 square centimeters (1000 dpm/100 cm 2) for beta and gamma radiation. The inspector also determined that the licensee adequately conducted visual inspections, including a check for water intrusion into the buildings and the containment vessel.
Since the previous inspection, the licensee initiated an evaluation to determine the source of the water in containment vessel. The licensee identified that the water may have seeped into the containment vessel through small shrinkage cracks in the concrete and gaps in the flashing on the ring trench that surrounds the exterior of the containment vessel. The licensee identified areas where seepage into the containment vessel was 8 Enclosure suspect and instituted repairs. The licensee also unblocked the floor drain pipes that lead to the containment sump, to allow any water accumulation to flow to the sump as originally designed. The licensee also unclogged the storm drains that surround the U1 building, which may have also contributed to the water intrusion. After these areas were repaired, the licensee verified that water has not re-entered the containment vessel, even after heavy rainfall. Additionally, the licensee identified that water had seeped into the containment vessel over a long period of time (since U1 was placed in SAFSTOR), accumulated in the basement. While confined in the containment vessel, the water entered a cycle of evaporation and condensation. Because of the helium purification process associated with the operation of the U1 reactor, tritium became entrained in the concrete. During the evaporation/condensation cycle, the entrained tritium in the concrete had leached into the water, resulting in significantly elevated tritium concentrations in the confined water. During the evaluation, the licensee identified three additional locations where water had accumulated. Prior to removing the water from these locations, the licensee sampled and analyzed the water for radioactivity. The licensee determined that the activity in the water was approximately 4,000,000 picoCuries per liter (pCi/L) of tritium and that the concentration of tritium in the containment vessel air was approximately 100 pCi/L.
During April 2008, July 2008 and January 2009, the licensee removed the water (approximately 900 gallons) from the containment vessel using procedure, RW-PB-900, Revision 0, Movement of Water Containing Tritium from Unit 1 Exclusion Area to PBAPS Radwaste System. The licensee pumped the water into drums and transferred the drums to the U2 radioactive waste building. The inspector determined that the licensee had verified that the transfer of the contaminated water was within the scope of their license and had established procedure RW-PB-900 to transfer the water from the U1 containment vessel to the radioactive waste building. In March 2009, the licensee processed this water through the U2 radioactive waste processing system and discharged it in two batch releases using the ST, ST-C-095-805-2, Liquid Radwaste Discharge, Revision 13. The inspector reviewed the licensee's liquid radwaste discharge permits and determined that the licensee followed the ST procedure. The licensee used the appropriate dilution volumes and flows and ensured that the water would be discharged according to the applicable 10 CFR Part 20 and Part 50 requirements. The inspector verified that the total effective dose equivalent to the public as a result of this effluent release was a small fraction of the applicable limit in 10 CFR Part 20.
The inspector verified, through interviews with the licensee, that gaseous effluents are not released from the containment vessel. The analytical results indicate that the regulatory gaseous release limit for tritium, as specified in 10 CFR Part 20, Appendix B, Table 2, Column 1, was not exceeded. Also, based on the analytical results, the inspector verified that the total effective dose equivalent to the public was below the regulatory limit of 0.1 rem in one year.
The licensee used their existing groundwater data and installed four additional monitoring wells east of the U1 building, which is downgradient of the flow of ground water, to augment their tritium ground water monitoring program. The inspector reviewed the radiological analytical results of water sampled from the monitoring wells near U1 during January 2008 through August 12, 2009. The inspector determined that 9 Enclosure the samples were collected according to procedure, CY-PB-170-4160, Station RGPP Controlled Sample Point Parameters and were analyzed by a contract laboratory. The well water sample results were less than the lower limit of detection (LLD) (200 pCi/L) for tritium. The analytical results of the monitoring well water samples indicate that the regulatory liquid release limit for tritium, as specified in 10 CFR Part 20, Appendix B, Table 2, Column 2, was not exceeded. Also based on the analytical results, the inspector verified that the total effective dose equivalent to the public was below the regulatory limit of 0.1 rem in one year.
The licensee used the annual limit on intake and derived air concentration values in 10 CFR Part 20, Appendix B, Table 1, Columns 2 and 3, respectively, to estimate the doses to the radiation workers. The inspector evaluated these doses and determined that the licensee demonstrated compliance with the occupational dose limits of 10 CFR 20.2101. The inspector verified that the occupational dose to radiation workers was a small fraction of the regulatory limit of 5 rem in one year, total effective dose equivalent.
The inspector verified that the licensee maintained records in sufficient scope regarding the results of inspections, including records required by 10 CFR 50.75(g) and reportable events. During the previous inspection, the inspector identified a non-cited violation relative to the licensee's failure to properly maintain (or reference the location of) all decommissioning records important to the safe and effective decommissioning of the U1 facility, in an identified location, as specified in 10 CFR 50.75(g). (Refer to NRC Inspection Report 05000171/2008009, dated October 10, 2008, [ADAMS Accession Nos.: ML082880597 and ML082880609] for details.) The inspector determined, through interviews with representatives of the licensing staff, that all decommissioning records related to U1 were assembled, organized, and entered into a newly established database. The licensee demonstrated features of the database and that the decommissioning records are being maintained in an identified location, as required by 10 CFR 50.75(g). Based on these observations, the inspector determined that the licensee significantly improved the record-keeping files related to 10 CFR 50.75(g).
The inspector reviewed the most recent annual report, PBAPS Unit 1 Decommissioning Status Report, dated May 8, 2009. The annual report contained a summary of the status of the U1 facility, including radiation survey results, quantities of radioactive effluents released, results of water analyses from the containment vessel, and performance of security and surveillance measures. The inspector determined that the licensee's submittal met the requirements of TS 2.4.a.
The inspector reviewed the radioactive waste management and transportation program to determine if there had been any radioactive waste shipments from the U1 facility for offsite disposal. The inspector interviewed selected licensee staff and reviewed the contamination survey results from the U1 facility. The reviewed results indicate that the loose contamination levels were not exceeded. Based on these results, the licensee did not generate any radioactive waste and therefore, did not ship radioactive waste from the U1 facility for offsite disposal.
c. Conclusions
The licensee's implementation and oversight of the SAFSTOR program were effective for the storage of radioactive material. The licensee adequately implemented and maintained the radiation protection, radioactive effluent controls, radiological environmental monitoring, and radioactive waste management programs. The licensee provided adequate controls to limit exposures of workers to external sources of radiation. Posting and labeling of radioactive material areas and radiation areas complied with regulatory requirements. No occupational or public dose concerns were identified.
5.0 Exit Meeting On August 12, 2009, the inspector presented the inspection results to William Maguire, and members of the Exelon staff. The inspector confirmed that proprietary information was not provided or examined during the inspection.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Licensee
- J. Armstrong, Regulatory Affairs Manager
- D. Foss, Senior Regulatory Affairs Engineer
- D. Hines, Radiation Protection Supervisor
- R. Holmes, Radiation Protection Manager
- C. Howell, Mechanical Design Engineer
- L. Lucas, Chemistry Manager
- W. Maguire, Site Vice President
- H. McCrory, Radiation Protection Technical Support Manager
- S. Minnick, Nuclear Oversight Manager
- M. Moonitz, Radiation Protection Junior Technician
- J. Popielarski, Shift Operations Superintendent
- M. Ross, Radwaste and Environmental Supervisor
- M. Schwartz, Maintenance Technician
- R. Smith, Regulatory Affairs Engineer
- G. Stathes, Plant Manager
- M. Taltoan, Chemistry Engineer
- T. Wasong, Training Director
- E. Workinger, Radiation Protection Senior Technician
- R. Workinger, Radiation Protection Senior Technician
INSPECTION PROCEDURES USED
36801 Organization, Management, and Cost Controls at Permanently Shutdown Reactors 37801 Safety Reviews and Design Changes 40801 Self Assessment and Corrective Action 62801 Maintenance and Surveillance at Permanently Shutdown Reactors 71801 Decommissioning Performance and Status Reviews 83750 Occupational Radiation Exposure
84750 Radioactive Waste Treatment and Effluent and Environmental Monitoring 86750 Solid Radioactive Waste Management and Transportation
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
None Discussed None
LIST OF ACRONYMS USED
ADAMS Agencywide Documents and Management Access System
AR Action Report A/R Action Request CAP Corrective Action Program CFR Code of Federal Regulations ECR engineering design change request
IP Inspection Procedure IR Issue Report LLD lower limit of detection NOS Nuclear Oversight NRC Nuclear Regulatory Commission PBAPS Peach Bottom Atomic Power Station pCi/L picoCuries per liter
SAFSTOR safe storage ST Surveillance Test TS Technical Specifications U1 Unit 1 U2 Unit 2