ML16032A095
| ML16032A095 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/01/2016 |
| From: | Daniel Schroeder Reactor Projects Region 1 Branch 4 |
| To: | Bryan Hanson Exelon Nuclear |
| SCHROEDER, DL | |
| References | |
| IR 2015004 | |
| Download: ML16032A095 (43) | |
See also: IR 05000277/2015004
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BLVD., SUITE 100
KING OF PRUSSIA, PA 19406-2713
February 1, 2016
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 05000277/2015004 AND 05000278/2015004
Dear Mr. Hanson:
On December 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The enclosed
inspection report documents the inspection results, which were discussed on January 15, 2016,
with Mr. Pat Navin, Peach Bottom Plant Manager, and other members of your staff.
NRC Inspectors examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
The inspectors documented one finding of very low safety significance (Green) in this report.
This finding involved a violation of NRC requirements. The NRC is treating this violation as a
non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the NCV in this report, 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, United States Nuclear Regulatory
Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at PBAPS.
B. Hanson
- 2 -
In accordance with Title 10 of the Code of Federal Regulations (CFR) 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 NRCs Public Document Room or from
the Publicly Available Records component of the NRC's Agencywide Documents Access
and 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/
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 05000277/2015004 and 05000278/2015004
w/Attachment: Supplementary Information
cc w/encl: Distribution via ListServ
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
OFFICE RI/DRP
RI/DRP
R1/DRP
NAME JHeinly/ DLS by telecon
ATurilin/ AT
DSchroeder/ DLS
DATE
01/28 /16
01/28 /16
02/01/16
1
Enclosure
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket Nos.
50-277 and 50-278
License Nos.
Report No.
05000277/2015004 and 05000278/2015004
Licensee:
Exelon Generation Company, LLC
Facility:
Peach Bottom Atomic Power Station, Units 2 and 3
Location:
Delta, Pennsylvania
Dates:
October 1, 2015 through December 31, 2015
Inspectors:
B. Smith, (Acting) Senior Resident Inspector
L. Micewski, (Acting) Senior Resident Inspector
B. Reyes, (Acting) Senior Resident Inspector
J. Patel, (Acting) Resident Inspector
S. Barber, Senior Project Engineer
N. Floyd, Reactor Inspector
C. Graves, Health Physicist
C. Highley, Project Engineer
D. Kern, Senior Reactor Inspector
M. Modes, Reactor Inspector
D. Orr, Senior Reactor Inspector
A. Turilin, Project Engineer
Approved By:
Daniel L. Schroeder, Chief
Reactor Projects Branch 4
Division of Reactor Projects
2
TABLE OF CONTENTS
SUMMARY ................................................................................................................................. 3
1. REACTOR SAFETY ................................................................................................................ 4
1R01
Adverse Weather Protection ...................................................................................... 4
1R04
Equipment Alignment ................................................................................................. 5
1R05
Fire Protection .......................................................................................................... 6
1R07
Heat Sink Performance ............................................................................................. 7
1R08
In-service Inspection Activities ................................................................................... 7
1R11
Licensed Operator Requalification Program and Licensed Operator Performance..... 9
1R12
Maintenance Effectiveness ...................................................................................... 10
1R13
Maintenance Risk Assessments and Emergent Work Control ................................ 10
1R15
Operability Determinations and Functionality Assessments ..................................... 11
1R18
Plant Modifications ................................................................................................... 11
1R19
Post-Maintenance Testing ...................................................................................... 12
1R20
Refueling and Other Outage Activities .................................................................... 13
1R22
Surveillance Testing ............................................................................................... 14
1EP6
Drill Evaluation ........................................................................................................ 14
2. RADIATION SAFETY ............................................................................................................ 17
2RS1
Radiological Hazard Assessment and Exposure Controls ....................................... 17
2RS2
Occupational ALARA Planning and Controls .......................................................... 18
2RS3
In-Plant Airborne Radioactivity Control and Mitigation ............................................. 19
2RS5
Radiation Monitoring Instrumentation ...................................................................... 20
2RS6
Radioactive Gaseous and Liquid Effluent Treatment ............................................... 21
4. OTHER ACTIVITIES ............................................................................................................. 21
4OA1
Performance Indicator Verification .......................................................................... 21
4OA2
Problem Identification and Resolution ..................................................................... 22
4OA3
Follow-Up of Events and Notices of Enforcement Discretion .................................. 26
4OA5
Other Activities ....................................................................................................... 26
4OA6
Meetings, Including Exit ........................................................................................... 26
SUPPLEMENTARY INFORMATION ....................................................................................... A-1
KEY POINTS OF CONTACT .................................................................................................. A-1
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED .................................... A-1
LIST OF DOCUMENTS REVIEWED ....................................................................................... A-2
LIST OF ACRONYMS ........................................................................................................... A-12
3
SUMMARY
IR 05000277/2015004, 05000278/2015004, 10/01/2015 - 12/31/2015; Peach Bottom Atomic
Power Station (PBAPS), Units 2 and 3; Surveillance Testing.
This report covered a three-month period of inspection by resident inspectors, and announced
baseline inspections performed by regional inspectors. The inspectors identified one non-cited
violation (NCV), 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 using Inspection Manual Chapter (IMC) 0609, Significance Determination Process
(SDP), dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects
Within Cross-Cutting Areas, dated December 19, 2013. All violations of NRC requirements are
dispositioned in accordance with the NRCs Enforcement Policy, dated July 09, 2013. The
NRCs program for overseeing the safe operation of commercial nuclear power reactors is
described in NUREG-1649, Reactor Oversight Process, Revision 5.
Cornerstone: Mitigating Systems
Green. The inspectors identified a non-cited violation (NCV) of very low safety significance
of 10 Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion III, Design
Control, for not ensuring that the adequacy of PBAPS emergency diesel generator (EDG)
lubrication oil (LO) supply was designed to withstand the effects of natural phenomena.
Specifically, additional LO, evaluated by PBAPS to meet their EDG technical specification
(TS) mission time of seven days of continuous operation, was housed in a non-class I
structure that would be unable to withstand the effects of natural phenomena. PBAPS
entered the issue into the correction action program (CAP) as issue report (IR) 02603369
and took immediate corrective actions to relocate the LO reserve inventory from their
warehouse to the 135 elevation of the PBAPS radwaste building, which is a seismic class I
structure
The finding is considered more than minor because it is associated with the Protection
Against External Factors attribute of the Reactor Safety Mitigating Systems cornerstone and
adversely affected the cornerstones objective of ensuring reliability and capability of
systems that respond to initiating events to prevent undesirable consequences (i.e., core
damage). The inspectors evaluated the significance of this finding using IMC 0609
Appendix A, The SDP for Findings at Power, Exhibit 2, Mitigating Systems Screening
Questions. The inspectors determined that this finding was of very low safety significance
(Green) because the finding is a design deficiency which did not result in an actual loss of
functionality of the EDGs. This finding did not have a cross-cutting aspect because the most
significant contributor of the performance deficiency (PD) occurred during the 1994
conversion to improved technical specifications (ITS) and, thus, was not reflective of current
plant performance. Specifically, PBAPS current engineering change request (ECR)
process would evaluate for natural phenomena considerations such as seismic, tornado,
flood, etc. (Section 1R22)
Other Findings
None.
4
REPORT DETAILS
Summary of Plant Status
Unit 2 began the inspection period at 100 percent rated thermal power (RTP). On
December 13, 2015, Unit 2 commenced a shutdown from 100 percent RTP and entered into
a forced outage to repair packing on the 2 C inboard main steam isolation Valve (MSIV). On
December 15, 2015, the Unit 2 reactor mode switch was placed in start-up and the main
generator was synchronized to the electrical grid on December 17, 2015. On December 18,
2015, Unit 2 was returned to 100 percent RTP, and remained at 100 percent RTP until the end
of the inspection period.
Unit 3 began the inspection period in a refueling outage (RFO) (P3R20). On October 21, 2015,
the Unit 3 reactor mode switch was placed in start-up and the main generator was synchronized
to the electrical grid on October 22, 2015. On October 25, 2015, Unit 3 was returned to
89 percent power (the pre-extended power uprate (EPU) 100 percent power limit). On
November 24, 2015, Unit 3 down powered from 92 percent RTP to 77 percent RTP to perform
breaker maintenance on the 3 A condensate pump. Unit 3 returned to 92 percent RTP later
that same day. On December 3, 2015, Unit 3 raised power to the full 100 percent RTP EPU
limit after final NRC approval for power ascension. Unit 3 remained at 100 percent RTP until
the end of the inspection period.
1.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection (71111.01 - 2 samples)
.1
Readiness for Impending Adverse Weather Conditions (1 sample)
a. Inspection Scope
The inspectors reviewed PBAPS preparations for the onset of a thunderstorm on
October 2, 2015, resulting from Hurricane Joaquin. The inspectors reviewed the
implementation of PBAPS' adverse weather preparation procedures before the onset
of the adverse weather condition. The inspectors walked down the north substation,
EDGs, and output transformer yard system availability. The inspectors verified that
operator actions defined in PBAPS adverse weather procedure maintained the
readiness of essential systems. The inspectors discussed readiness and staff
availability for adverse weather response with operations and work control personnel.
Documents reviewed for each section of this inspection report are listed in the
Attachment.
b. Findings
No findings were identified.
5
.2
Winter Readiness - Seasonal Extreme (1 sample)
a. Inspection Scope
The inspectors reviewed PBAPS readiness for the cold weather preparations on
December 11, 2015. The review focused on the EDGs, the river water intake structure
travelling screens, emergency cooling tower (ECT), circulating water pump house, and
associated support equipment. The inspectors reviewed the Updated Final Safety
Analysis Report (UFSAR), TSs, and the CAP to determine the temperatures or other
seasonal weather conditions that could challenge these systems. The review ensured
PBAPS personnel had prepared adequately for the weather-related challenges. The
inspectors reviewed station procedures, including PBAPS seasonal weather preparation
procedure, and applicable operating procedures. The inspectors performed walkdowns
of the selected systems to ensure station personnel identified issues that could challenge
the operability of the systems during cold weather conditions.
b. Findings
No findings were identified.
1R04 Equipment Alignment (71111.04 - 3 samples)
.1
Partial System Walkdowns (71111.04Q - 2 samples)
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
Unit 3 B residual heat removal (RHR) following the cross-tie modification on
October 20, 2015
Unit 3 reactor core isolation cooling (RCIC) following restoration after the RFO on
October 21, 2015
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 UFSAR, TSs, 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 systems 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 PBAPS 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.
6
.2
Full System Walkdown (71111.04S - 1 sample)
a. Inspection Scope
During the week of September 28, 2015, the inspectors performed a complete system
walkdown of accessible portions of the Unit 3 automatic depressurization system and
associated Unit 3 safety relief valves (SRVs) to verify the existing equipment lineup was
correct. The inspectors reviewed operating procedures, surveillance tests (STs),
drawings, equipment line-up check-off lists, and the UFSAR to verify the system was
aligned to perform its required safety functions. The inspectors also reviewed electrical
power availability, component lubrication and equipment cooling, hanger and support
functionality, and operability of support systems. The inspectors performed field
walkdowns of accessible portions of the system to verify as-built system configuration
matched plant documentation, and that system components and support equipment
remained operable. The inspectors confirmed that systems and components were
aligned correctly, free from interference from temporary services or isolation boundaries,
environmentally qualified, and protected from external threats. The inspectors also
examined the material condition of the components for degradation and observed
operating parameters of equipment to verify that there were no deficiencies.
Additionally, the inspectors reviewed a sample of related IRs and WOs to ensure PBAPS
appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified.
1R05 Fire Protection (71111.05Q - 5 samples)
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 PBAPS controlled combustible materials and ignition sources were controlled 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 3 recirculation pump motor generator (MG) set room and adjustable speed drive
(ASD) trailer on October 1, 2015
Unit 3 torus space on October 19, 2015
Unit 3 outboard MSIV room on October 20, 2015
Units 2 and 3 cable spreading room on October 30, 2015
Units 2 and 3 main control room on November 5, 2015
7
b. Findings
No findings were identified.
1R07 Heat Sink Performance (71111.07A - 1 sample)
a. Inspection Scope
The inspectors reviewed the Unit 2 A RHR/high pressure service water (HPSW) heat
exchanger (HX) during the week of November 2, 2015, to determine its readiness and
availability to perform is safety functions. The inspectors reviewed the design basis for
the component and verified PBAPS commitments to NRC Generic Letter 89-13,
Service Water System Requirements Affecting Safety-Related Equipment. The
inspectors reviewed the results of the most recent thermal performance monitoring test
(performed February 12, 2015), the most recent internal visual inspection, including tube
sheet partition plate inspection and eddy current testing (performed February 12, 2015),
and trend assessment based on comparison with previous inspections and performance
tests. The inspectors discussed the results of the most recent inspection with
engineering staff. The inspectors verified that PBAPS initiated appropriate corrective
actions for identified deficiencies. The inspectors also verified that the number of tubes
plugged within the HX did not exceed the maximum amount allowed.
b. Findings
No findings were identified.
1R08 In-service Inspection Activities (71111.08 - 1 sample)
a. Inspection Scope
The inspectors reviewed Exelon staff implementation of in-service inspection (ISI)
program activities for monitoring degradation of the reactor coolant system boundary,
risk significant piping and components, and containment systems during the PBAPS
Unit 3 20th RFO. The inspection was completed onsite September 21 to 28, 2015,
followed by in-office review October 8 to 9, 2015. The sample selection for this
inspection was based on the inspection procedure objectives and risk priority of those
pressure retaining components in systems where degradation would result in a
significant increase in risk. The inspectors observed in-process non-destructive
examinations (NDE), reviewed documentation, and interviewed Exelon personnel to
verify that the NDE activities performed as part of the fourth interval, third period, of the
Peach Bottom Unit 3 ISI program were conducted in accordance with the requirements
of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel
Code,Section XI, 2001 Edition with 2002 and 2003 Addenda.
NDE and Welding Activities
The inspectors performed direct observation of NDE activities in process and reviewed
documentation of completed examinations listed below. Activities included review of
ultrasonic testing (UT), radiographic testing (RT), and visual examination (VT).
8
The inspectors reviewed certifications of the NDE technicians performing the
examinations and verified that the inspections were performed in accordance with
approved NDE procedures and industry guidance. For UT activities, the inspectors also
verified the calibration of equipment used to perform the examinations. The inspectors
verified that the test results were reviewed and evaluated by certified Level III NDE
personnel and that the parameters used in the test were in accordance with the
limitations, precautions, and prerequisites specified in the test procedure.
ASME Code Required Examinations:
Direct observation of the manual UT of the N4E nozzle-to-vessel weld in the
feedwater system.
Direct observation of the manual UT of the N4E nozzle inner radius and bore in the
feedwater system.
Documentation review of the manual UT of the reactor pressure vessel closure head
studs (Studs 47-92).
Documentation review of the RT of two pipe-to-flange welds (10-2XC020-11 and -12)
and one pipe-to-pipe weld (10-2DC20-29), 20-inch diameter, performed as part of a
modification activity in the RHR system.
Direct observation of the VT of the drywell (i.e., containment) interior and exterior
penetrations and surfaces. The inspectors independently examined the condition of
the drywell interior liner surfaces at all floor elevations, including the moisture barrier
at the 11911 elevation. The inspectors performed a documentation review of the
drywell VT records and compared those to the inspector walkdowns.
Review of Previous Indications Accepted by Evaluation
The inspectors did not review any previous indications because there were no relevant
indications from the previous outage that required evaluation for continued service.
Repair/Replacement Activities Including Welding Activities
The inspectors reviewed the modification package associated with engineering change
11-00376, which implemented plant changes as part of the EPU project. Specifically,
the scope of the modification was to install a piping cross-tie between the Unit 3 A and
C trains of the RHR system in order to increase the containment cooling capability
following a postulated design basis event.
The inspectors performed a direct observation of the welding activities associated with
two piping welds (10-2XC020-11 and -12) in progress and performed a documentation
review of one completed weld (10-2DC20-29) to verify that welding and applicable NDE
activities were performed in accordance with ASME code requirements. The inspectors
reviewed the weld procedure and weld information data sheet, and also reviewed the
radiography data sheets for final acceptance of the welds. The modification was
performed under WOs C0255830 and C0255936.
9
Identification and Resolution of Problems
The inspectors reviewed a sample of PBAPS Unit 3 corrective action reports, which
identified NDE indications, deficiencies, and other non-conforming conditions since the
previous RFO and during the current outage. The inspectors verified that non-
conforming conditions were properly identified, characterized, evaluated, and that
corrective actions were identified and entered into the CAP for resolution.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
(71111.11Q - 3 samples)
.1
Quarterly Review of Licensed Operator Requalification Testing and Training (1 sample)
a. Inspection Scope
The inspectors observed a licensed operator requalification training scenario for the site
area on November 9, 2015. The inspectors evaluated operator performance during the
simulated event 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
(2 samples)
a. Inspection Scope
The inspectors observed and reviewed the licensed operator performance from the main
control room during the reactivity evolutions 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 plant startup and heat up from RFO 3R20 on October 20 and 21, 2015
Unit 2 plant shutdown and cooldown for a forced outage to repair a packing leak on
the C inboard MSIV on December 13, 2015
10
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness (71111.12Q - 1 sample)
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
PBAPS 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 CFR 50.65 and that the (a)(2) performance
criteria established by the PBAPS staff were 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
PBAPS staff was identifying and addressing common cause failures that occurred within
and across MR system boundaries.
Unit 3 recirculation system and ASDs on November 4, 2015
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 3 samples)
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 PBAPS 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 PBAPS
personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the
assessments were accurate and complete. When PBAPS 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 the assessment with the stations 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.
Elevated risk, Unit 3 operation with a potential for draining the reactor vessel
(OPDRV) during local power range monitor swaps on October 1, October 5, and
October 6, 2015
Elevated risk, Unit 2 E-43 bus outage on October 13, 2015
Elevated risk, Unit 3 containment not fully inerted during plant startup on October 21,
2015
11
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments (71111.15 - 6 samples)
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 standby liquid control (SBLC) test in which an explosive (squib) valve did not
appear to fire correctly on October 8, 2015
Unit 3 reactor water cleanup class 1 piping below minimum wall thickness on
October 8, 2015
Unit 3 MSIV snubbers low oil identified in reservoirs on October 9, 2015
Unit 3 D HPSW outlet valve tripped on torque switch on October 22, 2015
Unit 3 high-pressure coolant injection (HPCI) drain valve leaking by on October 22,
2015
Operator workarounds (OWAs) on November 5, 2015
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
PBAPS 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 OWAs, the inspectors determined whether the measures in place
would function as intended and were properly controlled by PBAPS. Based on the
review of selected OWAs listed above, the inspectors verified that PBAPS identified
OWAs at an appropriate threshold and addressed them in a manner that effectively
managed OWA-related adverse effects on operators and SSCs.
b. Findings
No findings were identified.
1R18 Plant Modifications (71111.18 - 1 sample)
Permanent Modification
a. Inspection Scope
The inspectors evaluated the following modification listed below:
Unit 3 reactor recirculation pump and ASDs modification on November 2 to
November 5, 2015
12
The inspectors verified that the design bases, licensing bases, and performance
capability of the affected systems were not degraded by the modifications. In addition,
the inspectors reviewed modification documents associated with the upgrade and design
change. The inspectors also reviewed 10 CFR 50.59 documentation, post-modification
testing results, procedure revisions, training documentation, and conducted field
walkdowns of the modifications.
b. Findings
No findings were identified
1R19 Post-Maintenance Testing (71111.19 - 9 samples)
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 points were performed and checked, and
that results adequately demonstrated restoration of the affected safety functions.
Unit 3 A core spray (CS) valve local leak rate test (LLRT) following valve
maintenance on October 4, 2015
Unit 3 HPCI vacuum relief valves LLRTs following maintenance on October 5, 2015
Unit 3 A inboard MSIV LLRT following rework after failed LLRT on October 7, 2015
Unit 3 A HPSW following flex modifications on October 13, 2015
Unit 3 RCIC overspeed trip test following maintenance outage on October 15, 2015
Unit 3 A RHR PMT following crosstie modification on October 19, 2015
Unit 3 emergency auxiliary transformer following maintenance outage on November
19, 2015
Unit 3 B reactor feed pump PMT following maintenance on November 20, 2015
Unit 2 C inboard MSIV stroke timing following repacking on December 16, 2015
b. Findings
No findings were identified.
13
1R20 Refueling and Other Outage Activities (71111.20 - 2 samples)
.1
Unit 3 Refueling Outage (3R20) (1 sample)
a. Inspection Scope
The inspectors reviewed the stations work schedule and outage risk plan for the Unit 3
maintenance and RFO (3R20), conducted September 21 to October 20, 2015. The
inspectors reviewed Exelons development and implementation of outage plans and
schedules to verify that risk, industry experience, previous site-specific problems, and
defense-in-depth were considered. During the outage, the inspectors observed portions
of the shutdown and cooldown processes and monitored controls associated with the
following outage activities:
Configuration management, including maintenance of defense-in-depth,
commensurate with the outage plan for the key safety functions and compliance with
the applicable TSs when taking equipment OOS
Implementation of clearance activities and confirmation that tags were properly hung
and that equipment was appropriately configured to safely support the associated
work or testing
Installation and configuration of reactor coolant pressure, level, and temperature
instruments to provide accurate indication and instrument error accounting
Status and configuration of electrical systems and switchyard activities to ensure that
TSs were met
Monitoring of decay heat removal operations
Impact of outage work on the ability of the operators to operate the spent fuel pool
cooling system
Reactor water inventory controls, including flow paths, configurations, alternative
means for inventory additions, and controls to prevent inventory loss
Activities that could affect reactivity
Maintenance of secondary containment as required by TSs
Fatigue management
Refueling activities, including fuel handling and fuel receipt inspections
Tracking of startup prerequisites, walkdown of the drywell (primary containment) to
verify that debris had not been left which could block the emergency core cooling
system suction strainers, and startup and ascension to full power operation
Identification and resolution of problems related to refueling outage activities
b. Findings
No findings were identified.
14
.2
Unit 2 Forced Outage (1 sample)
a. Inspection Scope
The inspectors observed a Unit 2 forced outage following elevated unidentified reactor
coolant system (RCS) leakage, conducted December 13 to 15, 2015. The elevated
leakage was later identified to be a packing leak from the Unit 2 C inboard MSIV. The
inspectors reviewed Exelons development and implementation of the forced outage
schedule to verify that risk, industry experience, previous site-specific problems, and
defense-in-depth were considered. During the outage, the inspectors observed portions
of the shutdown and cooldown processes and monitored controls associated with the
following outage activities:
Configuration management, including maintenance of defense-in-depth,
commensurate with the forced outage plan for the key safety functions and
compliance with the applicable TSs when taking equipment OOS
Implementation of clearance activities and confirmation that tags were properly hung
and that equipment was appropriately configured to safely support the associated
work or testing
Monitoring of decay heat removal operations
Tracking of startup prerequisites, partial walkdown of the drywell to verify clearances
had been removed and debris had not been left around the C inboard MSIV which
could block the emergency core cooling system suction strainers, and startup and
ascension to full power operation
Identification and resolution of problems related to the forced outage activities
b. Findings
No findings were identified.
1R22 Surveillance Testing (71111.22 - 5 samples)
a. Inspection Scope
The inspectors observed performance of STs and/or reviewed test data of selected risk
SSCs to assess whether test results satisfied TSs, the UFSAR, and PBAPS 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 and routine tests:
Unit 3 B standby liquid control (SBLC) test on October 15, 2015
Unit 3 HPCI low pressure test on October 21, 2015
Unit 3 A MSIV closure test on October 26, 2015
Unit common, E-2 EDG monthly test on November 9, 2015
Unit 2 RCS unidentified leakage surveillance on December 7, 2015
15
b. Findings
Introduction. The inspectors identified a NCV of very low safety significance of
10 CFR Part 50, Appendix B, Criterion III, Design Control, for not ensuring that the
PBAPS EDG LO supply was designed to withstand the effects of natural phenomena.
Specifically, additional LO, evaluated by PBAPS to meet their EDG TS mission time of
seven days of continuous operation, was housed in a non-seismic Class 1 structure that
was not designed to withstand the effects of natural phenomena.
Description. On November 9, 2015, the inspectors reviewed IR 02583825, concerning
loss of LO inventory in the E-2 EDG LO storage tank during an E-2 EDG monthly ST.
The IR documented in its basis for operability that total LO inventory onsite was within
TS limits. In 1994, PBAPS converted from custom to ITS. During the ITS conversion,
the NRC requested PBAPS to evaluate the EDG LO consumption rate to determine if
inventory requirements met their intended design. In response to the request for
information, PBAPS evaluated, under evaluation A0784276, the oil consumption rate
to be 2.0 gallons per hour based both on vendor specifications and conservatism
recommended by the vendor since LO consumption is affected by the quality of the oil
used and engine wear. PBAPS identified that the EDGs required additional inventory to
meet their design requirements because of the consumption rate, capacity of the in-room
storage (i.e., LO tank, associated piping, and LO sump), and seven day continuous
operational design requirement.
TS 3.8.3 requires a LO inventory of 350 gallons per EDG to be operable. The TS bases
states that LO stored in the onsite warehouse can be credited towards achieving the
required inventory. PBAPS performs a monthly verification of EDG lubrication oil to
satisfy their TS requirement. The inspectors independently walked down the additional
inventory in PBAPS onsite warehouse and identified that the LO may become
unavailable during a natural phenomena event.
The EDGs are part of the standby safety power supply system. PBAPS UFSAR 8.5.2.4,
Safety Design Basis, states that, each diesel generator unit is housed in a seismic
Class I structure, and located such that the equipment is protected against other natural
phenomena such as flood, tornado, rain, ice, snow, and lightning. Furthermore, UFSAR
Section 8.5.4, Safety Evaluation, states, in part, that, diesel generator units are
capable of operating continuously for a period of seven days without any offsite
supplies, and that the units and all necessary auxiliary systems are housed in seismic
Class I structures and are protected against other natural phenomena. UFSAR 8.5.2.1
states that the standby alternating current power supply design conforms to the intent of
Proposed Institute of Electrical and Electronics Engineers (IEEE) Criteria for Class 1E
Electrical Systems for Nuclear Power Generating Stations, dated June, 1969. The
Proposed IEEE Criteria for Class 1E Electrical Systems for Nuclear Power Generating
Stations, dated June, 1969, Section 5.2.4, Standby Power Supply, states, in part, that
the standby power supply shall consist of all components from the stored energy to the
connection to the distribution systems supply breaker (e.g., generators and excitation
equipment; all auxiliary systems and appurtenances.) This standard was subsequently
approved as IEEE Standard 308-1971, IEEE Standard Criteria for Class 1E Electric
Systems for Nuclear Power Generating Stations, dated September 16, 1971, and which
contains an identical description of a standby power supply. The IEEE standard also
lists design basis events in Section 2 and in Table 1 to include the natural phenomena
(i.e., seismic, flood, tornado, etc.) to which the Class 1E Electric Systems must remain
functional under the conditions produced by the design basis events.
16
The inspectors questioned whether the LO stored in the warehouse was adequately
protected and would remain available for replenishment into the EDG system following
natural phenomena. The inspectors questioned how PBAPS ensured the integrity of the
LO barrels to maintain the LO free from containments that might be introduced during a
flood, and to prevent loss of the oil if the containers were damaged during a seismic
event or tornado. The inspectors also questioned the accessibility of the barrels, and
the feasibility of transporting the barrels from the warehouse to the EDG building during
natural phenomena.
The inspectors identified that since the warehouse was not a seismic Class I structure,
there is not reasonable assurance that the LO would be available for replenishment
following a seismic event. In addition, the inspectors reviewed PBAPS severe weather
and seismic event procedures and found no instructions or preparations to relocate the
required LO barrels in the event of natural phenomena. No additional design
documentation was identified approving the warehouse as an acceptable storage
location. As a result, PBAPS entered the issue into the CAP as IR 02603369 and took
immediate corrective actions to relocate the LO reserve inventory from the warehouse to
the 135 elevation of PBAPS radwaste building, which is listed in the UFSAR Appendix
C.1.2 as a seismic Class I structure. PBAPS specified a corrective action in IR
02603369 to evaluate a long term storage location and to enhance their severe weather
and natural phenomena procedures.
Analysis. PBAPS failure to ensure that the safety-related function of the EDG
lubrication system was not susceptible to natural phenomena was a performance
deficiency (PD). Specifically, barrels of LO for makeup to the EDGs credited towards the
TS 3.8.3 requirement of 350 gallons on site were stored in a warehouse that is not a
seismic Class I structure and would not be protected from natural phenomena specified
in PBAPS design basis. This PD was considered more than minor because it is
associated with the Protection Against External Factors Attribute of the Reactor Safety
Mitigating Systems cornerstone, and adversely affected the cornerstones objective of
ensuring reliability and capability of systems that respond to initiating events to prevent
undesirable consequences (i.e., core damage).
The inspectors evaluated the significance of this finding using IMC 0609 Appendix A,
The SDP for Findings at Power, Exhibit 2, Mitigating Systems Screening Questions.
The inspectors determined that this finding was of very low safety significance (Green)
because the finding is a design deficiency which did not result in an actual loss of
functionality of the EDGs.
This finding did not have a cross-cutting aspect because the most significant contributor
of the PD occurred during the 1994 conversion to ITS and, thus, was not reflective of
current plant performance. Specifically, PBAPS current engineering change request
(ECR) process would evaluate for natural phenomena considerations such as seismic,
tornado, flood, etc.
Enforcement. 10 CFR Part 50, Appendix B, Criterion III, Design Control, states, in part,
that measures shall be established to assure that applicable regulatory requirements
and the design basis as specified in the license are correctly translated into
specifications, drawings, procedures, and instructions, and that measures shall also be
established for the selection and review for suitability of application of materials, parts,
equipment, and processes that are essential to the safety-related functions of the SSCs.
Contrary to the above, PBAPS did not establish measures to review for suitability of
17
materials and processes that are essential to the safety-related functions of SSCs.
Specifically, PBAPS did not ensure the adequacy of PBAPS EDG LO supply design to
withstand the effects of natural phenomena. Because this finding is of very low safety
significance, and PBAPS has entered it into their CAP (IR 02603369), this violation is
being treated as an NCV, consistent with section 2.3.2a of the NRCs Enforcement
Policy. (NCV 05000277/278/2015004-01, Failure to Ensure Design Basis of EDG
Lubrication System)
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation (71114.06 - 1 sample)
Emergency Preparedness (EP) Drill/Simulator Evaluation/Observation
a. Inspection Scope
The inspectors evaluated the shift manager\\emergency directors EP implementation
during a licensed operator annual requalification training scenario on November 9, 2015.
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 PBAPS staff in order
to evaluate whether PBAPS staff was properly identifying emergency preparedness
weaknesses and entering them into the CAP.
b. Findings
No findings were identified.
2.
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety (OS)
2RS1 Radiological Hazard Assessment and Exposure Controls (71124.01 - 1 sample)
a. Inspection Scope
During September 28 - October 2, 2015, the inspectors reviewed Exelons performance
in assessing and controlling radiological hazards in the workplace. The inspectors used
the requirements contained in 10 CFR 20, TSs, applicable Regulatory Guides (RGs),
and the procedures required by TSs as criteria for determining compliance.
Inspection Planning
The inspectors reviewed the performance indicators for the occupational exposure
cornerstone, radiation protection (RP) program audits, and reports of operational
occurrences in occupational radiation safety since the last inspection.
18
Radiological Hazard Assessment
The inspectors reviewed recent plant radiation surveys and any changes to plant
operations since the last inspection to identify any new radiological hazards for onsite
workers or members of the public.
Contamination and Radioactive Material Control
The inspectors observed the monitoring of potentially contaminated material leaving
the radiological control area and inspected the methods and radiation monitoring
instrumentation used for control, survey, and release of that material. The inspectors
selected several sealed sources from inventory records and assessed whether the
sources were accounted for and were tested for loose surface contamination. The
inspectors evaluated whether any recent transactions involving nationally tracked
sources were reported in accordance with requirements.
Radiological Hazards Control and Work Coverage
The inspectors evaluated in-plant radiological conditions and performed independent
radiation measurements during facility walk-downs and observation of radiological work
activities. The inspectors assessed whether posted surveys, radiation work permits
(RWPs), worker radiological briefings, the use of continuous air monitoring and
dosimetry monitoring were consistent with the present conditions. The inspectors
examined the control of highly activated or contaminated materials stored within the
spent fuel pools and the posting and physical controls for selected high radiation areas
(HRAs), locked high radiation areas (LHRAs) and very high radiation areas (VHRA) to
verify conformance with the occupational exposure control effectiveness performance
indicator.
Risk-Significant HRA and VHRA Controls
The inspectors reviewed the controls and procedures for HRAs, VHRAs, and radiological
transient areas in the plant.
Problem Identification and Resolution
The inspectors evaluated whether problems associated with radiation monitoring and
exposure control were identified at an appropriate threshold and properly addressed in
the CAP.
b. Findings
No findings were identified.
2RS2 Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls
(71124.02 - 1 sample)
a. Inspection Scope
During September 28 - October 2, 2015, the inspectors assessed Exelons performance
with respect to maintaining occupational individual and collective radiation exposures
19
ALARA. The inspectors used the requirements contained in 10 CFR 20, applicable
RGs, TSs, and procedures required by TSs as criteria for determining compliance.
Inspection Planning
The inspectors conducted a review of PBAPS collective dose history and trends;
ongoing and planned radiological work activities; radiological source term history and
trends; and ALARA dose estimating and tracking procedures.
Radiological Work Planning
The inspectors selected the following radiological work activities based on exposure
significance for review:
RWP PB-C-15-00823, Feed Water Heater Replacement (3AE003 & 3CE003)
RWP PB-C-15-822, Unit 3 High Pressure Turbine Disassembly, 1000 mrad,
Heavy Work, High Efficiency Particulate Air & Wet Surface
RWP PB-C-15-00510, Drywell Main Steam SRV Activities
RWP PB-C-1500513, Control Rod Drive Exchange, Effective Dose Equivalent
Monitoring Required
For each of these activities, the inspectors reviewed: ALARA work activity evaluations,
exposure estimates, and exposure reduction requirements.
Problem Identification and Resolution
The inspectors evaluated whether problems associated with ALARA planning and
controls were identified at an appropriate threshold and properly addressed in the CAP.
b. Findings
No findings were identified.
2RS3 In-Plant Airborne Radioactivity Control and Mitigation (71124.03 - 1 sample)
a. Inspection Scope
During September 28 - October 2, 2015, the inspectors reviewed the control of in-plant
airborne radioactivity and the use of respiratory protection devices for radiological
protection. The inspectors used the requirements in 10 CFR 20, RG 8.15, RG 8.25,
NUREG/CR-0041, TS, and procedures required by TS as criteria for determining
compliance.
Inspection Planning
The inspectors reviewed the UFSAR to identify ventilation and radiation monitoring
systems associated with airborne radioactivity controls and respiratory protection
equipment staged for emergency use. The inspectors also reviewed respiratory
protection program procedures and current performance indicators for unintended
internal exposure incidents.
20
Use of Respiratory Protection Devices
The inspectors reviewed the adequacy of the licensees use of respiratory protection
devices in the plant to include applicable ALARA evaluations, respiratory protection
device certification, respiratory equipment storage, air quality testing records, and
individual qualification records.
Problem Identification and Resolution
The inspectors evaluated whether problems associated with the control and mitigation of
in-plant airborne radioactivity were identified at an appropriate threshold and addressed
by the licensees CAP.
b. Findings
No findings were identified.
2RS5 Radiation Monitoring Instrumentation (71124.05 - 1 sample)
a. Inspection Scope
During September 28 - October 2, 2015, the inspectors reviewed performance in
assuring the accuracy and operability of radiation monitoring instruments used to protect
occupational workers and for effluent monitoring and analysis. The inspectors used the
requirements in 10 CFR 20, 10 CFR 50, Appendix I; TSs; Offsite Dose Calculation
Manual (ODCM); RGs; applicable industry standards; and procedures required by TSs
as criteria for determining compliance.
Inspection Planning
The inspectors reviewed records of in-service survey instrumentation and procedures for
instrument source checks and calibrations.
Walkdowns and Observations
The inspectors conducted walk-downs of plant area radiation monitors, continuous
air monitors and radioactive gaseous and liquid effluent monitoring systems. The
inspectors reviewed the calibration and source check status of various portable radiation
survey instruments and contamination detection monitors for personnel and equipment.
Calibration and Testing Program
For the following radiation detection instrumentation, the inspectors reviewed the current
detector and electronic channel calibration, functional testing results and alarm set-
points: portal monitors; personnel contamination monitors; small article monitors;
portable survey instruments; area radiation monitors; electronic dosimetry; air samplers;
and continuous air monitors.
b. Findings
No findings were identified.
21
2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06 - 1 sample)
a. Inspection Scope
During September 28 - October 2, 2015, the inspectors reviewed the treatment,
monitoring, and control of radioactive gaseous and liquid effluents. The inspectors used
the requirements in 10 CFR 20, 10 CFR 50, Appendix I; TS; ODCM; applicable industry
standards; and procedures required by TSs as criteria for determining compliance.
Groundwater Protection Initiative (GPI) Implementation
The inspectors reviewed: groundwater monitoring results; changes to the GPI program
since the last inspection; anomalous results or missed groundwater samples; leakage or
spill events including entries made into the decommissioning files (10 CFR 50.75(g));
and Exelons evaluation of any positive groundwater sample results, including
appropriate stakeholder notifications and effluent reporting requirements.
b. Findings
No findings were identified.
4.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification (71151 - 8 samples)
.1
Mitigating Systems Performance Index
a. Inspection Scope
The inspectors reviewed Exelons submittal for the Mitigating Systems Performance
Index (MSPI) for the period of October 1, 2014 through September 30, 2015.
Unit 2 and Unit 3 HPCI (MS07)
Unit 2 and Unit 3 RCIC (MS08)
Unit 2 and Unit 3 RHR (MS09)
Unit 2 and Unit 3 cooling water (MS10)
To determine the accuracy of the PI data reported during those periods, the inspectors
used definitions and guidance contained in Nuclear Energy Institute Document 99-02,
Regulatory Assessment PI Guideline, Revision 6. The inspectors also reviewed RCS
sample analysis and control room logs of daily measurements of RCS leakage, and
compared that information to the data reported by the PI.
b. Findings
No findings were identified.
22
4OA2 Problem Identification and Resolution (71152 - 3 samples)
.1
Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure (IP) 71152, Problem Identification and Resolution,
the inspectors routinely reviewed issues during baseline inspection activities and plant
status reviews to verify that PBAPS entered issues into the CAP at an appropriate
threshold, gave adequate attention to timely corrective actions, 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
condition report screening meetings. The inspectors also confirmed, on a sampling
basis, that, as applicable, for identified defects and non-conformances, PBAPS
performed an evaluation in accordance with 10 CFR Part 21.
b. Findings
No findings were identified.
.2
Annual Sample: Trend of Leaks in the ESW and HPSW System Piping (1 sample)
a. Inspection Scope
The inspectors performed an in-depth review of Exelons apparent cause evaluation and
corrective actions associated with CR AR 01695675, ESW Pinhole Leak on Supply
Elbow to Unit 2 Ring Header. Specifically, a through-wall leak developed on an ESW
pipe fitting, which resulted in both subsystems of ESW being declared inoperable and an
entry into the action statement associated with TS 3.7.2. The inspectors also reviewed
leaks and wall thinning conditions identified in the HPSW system. Both the ESW and
HPSW systems use the Susquehanna River as a water source for providing cooling to
various safety-related plant components.
The inspectors assessed Exelons problem identification threshold, cause analyses,
extent of condition (EOC) reviews, compensatory actions, and the prioritization and
timeliness of Exelons corrective actions to determine whether Exelons staff were
appropriately identifying, characterizing, and correcting problems associated with the
leak and whether the planned or completed corrective actions were appropriate. The
inspectors compared the actions taken to Exelons CAP and the requirements of 10 CFR
50, Appendix B. The inspectors interviewed engineering personnel to discuss the
results of the cause evaluation and to assess the effectiveness of the implemented
corrective actions. The inspectors also conducted walkdowns of the accessible portions
of the ESW and HPSW systems to observe the general material conditions of the piping
and associated components.
b. Findings and Observations
No findings were identified.
23
Exelon staff determined the apparent cause of the emergency service water (ESW)
elbow leak was due to under deposit pitting corrosion and microbiologically influenced
corrosion in raw water (i.e., river water) piping, which was increased by flow effects in
this particular location. Specifically, deposits formed on the inside of the pipe from silt
and microbiological organisms associated with the untreated river water that led to
isolated pitting corrosion under the deposits and subsequently a pinhole leak. For the
ESW elbow leak, Exelon staff determined that there was one contributing cause due to
inadequate understanding of failure consequence and probability, which resulted in a
lower examination priority.
The inspectors concluded that Exelon staff conducted an appropriate review to identify
the likely causes of the piping leak. The inspectors also concluded that Exelon staff
identified the EOC, which included all safety-related raw water piping in Peach Bottom
Units 2 and 3. Immediate corrective actions included an evaluation of the component for
operability and structural integrity, scheduling for replacement of the leaking component,
and routine monitoring for any changes in leakage. The inspectors noted that Exelon
utilized ASME Code Case N-513-3 to evaluate the leak, which allows temporary
acceptance and operation of the component until replacement at the next RFO. Exelon
staff was required to submit a relief request to the NRC because Code Case N-513-3 is
limited to the evaluation of piping and does not include elbows, fittings, or other non-pipe
components. Exelon staff implemented further corrective actions, which included a
review of the raw water piping database to address the risk ranking factors and
consequences; revision of ER-AA-5400-1001, Raw Water Corrosion Program Guide,
to include additional guidance on risk ranking of piping with potential integrity threats;
evaluation of corrosion rates based on results of this leak and EOC inspections; and a
review of other elbows and fittings most susceptible to integrity concerns.
The inspectors reviewed Peach Bottoms raw water corrosion database, including a
sample of pipe locations currently being monitored for wall thickness, to verify that
Exelon staff were adequately tracking and prioritizing pipes for inspection and
replacement. The inspectors noted that the raw water corrosion engineer utilized a
supplemental database, which incorporated additional parameters for establishing
corrosion rates, estimating remaining life, and scheduling future inspections. The
inspectors also reviewed another Peach Bottom specific tool that used risk ranking for
large sections of system piping rather than individual pipe locations in order to prioritize
vulnerable sections of piping for future replacement.
In addition, the inspectors reviewed currently ongoing and planned raw water piping
projects to verify that Exelon staff were proactively mitigating piping integrity issues.
One recent project involved the replacement of high risk-based piping at the ESW
pumps discharge. While there were no chemistry control corrective actions identified in
the apparent cause evaluation, the inspectors noted that there is a planned project in the
review process to evaluate potential combinations of chemistry controls and cleaning for
internal pipe corrosion. The inspectors determined Exelons overall response to the
ESW elbow leak as well as other related raw water issues was commensurate with the
safety significance, was timely, and included appropriate compensatory actions. The
inspectors concluded that completed and planned actions were reasonable to correct the
problem and help prevent reoccurrence.
24
.3
Annual Sample: Review of Unit 2 Torus Coating Defects (1 sample)
a. Inspection Scope
The inspectors reviewed corrective actions completed by Exelon staff as a consequence
of CR 02413128, Coating Defects and Pinpoint Rust in Torus Belly Band Area, and CR
02407173, Pit with Depth of 126 mils. The inspectors reviewed the results of Exelons
report to identify, prioritize and resolve the causes of the coating defects, rust, and
pitting. The inspectors also reviewed results of torus examinations on a sampling basis
for the previous PBAPS Unit 2 RFOs back to 2006, and Unit 3 RFOs back to 2007.
The inspectors determined if the completion of corrective actions was in a timely manner
commensurate with the safety significance of the issue. The inspectors considered if
any delays in implementation were justified based on the safety significance of the issue.
The inspectors considered if any permanent corrective actions required significant time
to implement and if interim corrective actions and/or compensatory actions were
identified and implemented to minimize the problem and/or mitigate its effects until the
permanent action could be implemented.
The inspectors reviewed the actions taken to determine if the actions resulted in the
correction of the identified problem. In the case of this condition, the inspectors
determined if the corrective action taken would preclude repetition. Finally the
inspectors reviewed operating experience to determine if it was adequately evaluated
for applicability, and applicable lessons learned were communicated to appropriate
organizations and implemented.
b. Findings and Observations
No findings were identified.
The corrective action of the coating defects and pinpoint rust in the torus belly band
area, was to continue to monitor this area for further degradation. Exelon staff took into
account operability, consideration of EOC and cause, generic implications, common
cause, and previous occurrences. This corrective action was reviewed by the inspectors
to determine if the classification and prioritization of the problems resolution was
commensurate with the safety significance.
The corrective action for the pit with a depth of 126 mils was to determine if the pit
impacted operability and to repair and recoat the area. Exelon staff took into account
the EOC by reviewing prior inspection reports for the area associated with the pit to
determine if other pits, in the immediate area which had been repaired previously, could
impact the integrity of the newly discovered pit. Exelon staff took into consideration
generic implications, common cause, and previous occurrences. This corrective action
was reviewed by the inspectors to determine if the classification and prioritization of the
problems resolution was commensurate with the safety significance.
The inspectors interviewed station personnel involved in developing the monitoring and
repair plans. The derived information was compared with the corrective actions
identification of contributing causes of the problem. The inspectors ascertained if the
documented information was reported to appropriate levels of management. The
25
inspectors reviewed the corrective action to determine if the corrective action was
appropriately focused to correct the problem (and to address the root and contributing
causes for significant conditions adverse to quality).
The inspectors review determined Exelon staff established a defined threshold to assure
that no pit would threaten the torus minimum wall thickness prior to the torus recoat
activity. The threshold was sufficient to ensure that the torus pressure boundary
remained acceptable. The inspectors determined the threshold included a corrosion
allowance for all uncoated pits based on actual corrosion data and the planned recoat
schedule. The inspectors determined that pits with depths exceeding the defined
threshold were evaluated by Exelon engineering staff and were coated to assure no
further degradation.
The inspectors determined the actions of monitoring, analysis, and recoating resulted in
the correction of the identified problem. The inspectors determined the actions
maintained the safety barrier integrity by assuring the torus wall thickness was above the
design minimum requirement.
.4
Semi-Annual Trend Review (1 sample)
a. Inspection Scope
The inspectors performed a semi-annual review of site issues to identify trends that
might indicate the existence of more significant safety concerns. As part of this review,
the inspectors included repetitive or closely-related issues documented by PBAPS in
trend reports, site PIs, priority work lists, system health reports, MR assessments, and
maintenance or CAP backlogs. The inspectors also reviewed PBAPS CAP database
for the third and fourth quarters of 2015 to assess IRs written in various subject areas
(equipment problems, human performance issues, etc.), as well as individual issues
identified during the NRCs daily CR review (Section 4OA2.1). The inspectors reviewed
the PBAPS quarterly trend report for the third quarter of 2015, conducted under PI-AA-
125-1005, Coding and Analysis Manual, Revision 0, to verify that PBAPS personnel
were appropriately evaluating and trending adverse conditions in accordance with
applicable procedures.
b. Findings and Observations
No findings were identified.
The inspectors evaluated a sample of CRs generated over the course of the past two
quarters by departments that provide input to the quarterly trend reports. The inspectors
determined that, in most cases, the issues were appropriately evaluated by PBAPS staff
for potential trends and resolved within the scope of the CAP. The inspectors did
identify repeated occurrences regarding a lack of awareness in the travel path of check
valve swing arms in safety-related systems which did or could have impacted system
operability. The inspectors identified three occurrences where PBAPS obstructed the
travel path of check valve swing arms identified in IRs 1680741, IR 2519751, and IR
2559874. PBAPS initiated IR 2574611 to document the inspectors concern and
evaluate how to increase awareness of the travel path of safety-related check valve
swing arms.
26
The inspectors also noted and discussed with PBAPS staff ongoing minor adverse
trends in rigor and attention to detail in CAP products, including apparent cause
evaluations and work group evaluations, and in configuration control with tasks
performed by PBAPS maintenance department. However, the inspectors determined
that there were no adverse safety consequences as a result of these low level trends.
Based on the overall results of the semi-annual trend review, the inspectors determined
that PBAPS was appropriately identifying and entering issues into the CAP, adequately
evaluating the identified issues, and properly identifying adverse trends before they
became more safety significant operability problems.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153 - 1 sample)
(Closed) Licensee Event Report (LER) 05000/277-2-15-001: Condition Prohibited by
TS Due to Insufficient Remote Shutdown System Surveillance Testing
The NRC determined on September 4, 2015, that insufficient surveillance requirement (SR) 3.3.3.2.1 testing was being performed for certain functions from the remote
shutdown system (RSS) panel. Subsequently, during surveillance testing performed on
September 16, 2015, operations personnel identified that the RCIC system steam
admission valve (MO-2-13-131) would not open when operated from the RSS panel.
Prompt troubleshooting performed on September 16, 2015, identified that a wire within
the RSS panel associated with the logic for the MO-2-13-131 valve was not connected.
This condition did not impact the normal operation of the MO-2-13-131 valve from the
MCR, nor did it impact the automatic function of the MO-2-13-131 valve for licensed
events. Only the manual open function of the valve from the RSS panel (located outside
of the control room) was affected. The disconnected wire was re-landed and the MO-2-
13-131 was verified to operate properly from the RSS panel. The cause of the event
was previous insufficient RSS panel testing that did not detect this disconnected wire.
Surveillance test procedures of the RSS panel functions have been upgraded. A Green
NCV of TS 5.4.1a was identified and documented in the 2015003 inspection report (NCV
05000277/278/2015003-01, Incomplete Testing of Components from the Remote
Shutdown Panel). This LER is closed.
4OA5 Other Activities
Extended Power Uprate (EPU) Closure and Summary (71004)
a. Inspection Scope
On August 25, 2014, the NRC approved PBAPS License Amendments Nos. 293 and
296 for an approximately 12.4-percent EPU at Units 2 and 3 and issued the associated
safety evaluation (ADAMS package ML122860201). The inspectors have observed and
reviewed selected activities throughout the phased EPU implementation on both units.
The inspectors have determined, based on a sample review of these activities and
comparison of records and tests with the current licensing documents, that Exelons
commitments have been met regarding the PBAPS Unit 2 and Unit 3 EPU and that
Exelon has fully implemented the EPUs within its approved implementation timelines.
27
As required by IP 71004, Power Uprate, all inspection sample requirements for the
power uprate on Unit 2 and Unit 3 have been verified completed and recorded,
consistent with the inspection plan. This entry provides a summary of all inspection
samples associated with implementation of and as required by IP 71004.
Inspection Sample
Inspection Procedure (IP)
Inspection Report
Operator Simulator
Scenario
71111.11, 71004
2014004
Operator Simulator
Scenario
71111.11, 71004
2014005
EC/FAC
71004
2014005
Integrated Plant
Evolutions
71004
2014005
Major Plant Tests
71111.20, 71004
2014005
CST Standpipe
Modification
71111.17, 71004
2015002
Unit 2 HPSW Cross-tie
Modification
71111.17, 71004
2015002
Unit 3 A RHR Cross-tie
Modification PMT
71111.19, 71004
2015004
Unit 2 B CS Suction
71111.21, 71004
2015002
Unit 3 SBLC IST
71111.22, 71004
2015004
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
Quarterly Resident Exit Meeting Summary
On January 15, 2016, the inspectors presented the inspection results to Mr. Pat Navin,
Peach Bottom Plant Manager, and other members of the PBAPS staff. The inspectors
verified that no proprietary information was retained by the inspectors or documented in
this report.
ATTACHMENT: SUPPLEMENTARY INFORMATION
A-1
Attachment
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Exelon Generation Company Personnel
M. Massaro, Site Vice President
P. Navin, Plant Manager
J. Armstrong, Regulatory Assurance Manager
J. Boil, EPU RHR Project Manager
G. Cilluffo, Raw Water Corrosion Engineer
D. Dullum, Regulatory Assurance Engineer
J. Hawkins, Exelon NDE Level III
B. Holmes, Radiation Protection Manager
H. McCroy, Radiation Protection Technical Support Manager
B. Rufo, ISI Program Owner
NRC PERSONNEL
B. Smith, (Acting) Senior Resident Inspector
L. Micewski, (Acting) Senior Resident Inspector
B. Reyes, (Acting) Senior Resident Inspector
J. Patel, (Acting) Resident Inspector
S. Barber, Senior Project Engineer
N. Floyd, Reactor Inspector
C. Graves, Health Physicist
C. Highley, Project Engineer
D. Kern, Senior Reactor Inspector
M. Modes, Reactor Inspector
D. Orr, Senior Reactor Inspector
A. Turilin, Project Engineer
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
05000277/278/2015004-01 NCV
Failure to Ensure Design Basis of Emergency
Diesel Generator Lubrication System
(Section 1R22)
Closed
05000277/2-15-001
LER
Condition Prohibited by TS Due to Insufficient
Remote Shutdown System Surveillance Testing
(Section 4OA3)
A-2
LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather
Procedures
MA-PB-1003, Winter Readiness and Storm Response Guidelines for the Peach Bottom Facility,
Revision 11
OP-AA-108-111-1001, Severe Weather and Natural Disaster Guidelines, Revision 13
OP-PB-108-111-1001, Preparation for Severe Weather, Revision 13
RT-I-066-200-2, Heat Trace System Testing, Revision 11
RT-O-040-620-2, Outbuilding HVAC and Outer Screen Inspection for Winter Operation,
Revision 22
RT-O-040-630-2, Winterizing Procedure, Revision 14
WC-AA-107, Seasonal Readiness, Revision 16
IRs
01610850
02481268
Miscellaneous
Memo from M. Massaro to T. Dougherty, Certification of 2015-2016 PBAPS Winter Readiness,
dated October 29, 2015
Section 1R04: Equipment Alignment
Procedures
ARC-325 30C203B D-1, B RHR Pump Auto Start
SO 10.1.E-3, RHR System Torus Cooling Using the RHR Loop Cross-Tie
SO 13.1.B-3 COL, RCIC System Control Board Lineup, Revision 3
SI3M-2-SRV-XXMM, Instrument Check of SRV Position Indicators, Revision 8
SI3T-2-SRV-XXF2, Channel Functional Check of MSRV MSSV Thermocouples, Revision 2
Section 1R05: Fire Protection
Procedures
CC-AA-201, Plant Barrier Control Program, Revision 2
CC-AA-209, Fire Protection Program Configuration Change Review, Revision 5
CC-AA-211, Fire Protection Program, Revision 6
LS-AA-128, Regulatory Review of Proposed Changes to the Approved Fire Protection Program,
Revision 2
OP-AA-201-009, Control of Transient Combustible Material, Revision 17
PF-12C, Unit 3 Recirculation Pump MG Set Room Pre-Fire Strategy Plan, Revision 7
PF-117, Unit 3 Turbine Building, Emergency Battery Switchgear Rooms, Elevation 135-0,
Revision 10
PF-78H, Turbine Building Common, Cable Spreading and Computer Rooms - Elevation 150-0,
Revision 9
RT-O-57A-745-1, Balance of Plant and Miscellaneous Battery Monthly Check, Revision 16
RT-O-100-505-2, Emergency Operating Procedure Tool Inventory, Revision 39
A-3
Drawings
Drawing No. E-1313, Sheet 47D, Lighting Symbol, Notes & Details, Revision 1
Drawing No. 6260-E-1069, Sheet 1, Lighting, Communications & Power Layout - Control Room,
Revision 18
AR 951114951114
Miscellaneous
MR System Basis Document for Emergency DC Lighting, System 57E
Section 1R07: Heat Sink Performance
Procedures
ER-AA-340-1002, Service Water HX Inspection Guide, Revision 6
CRs
01619316
Miscellaneous
2nd Trimester, 2015 PBAPS GL 89-13 Program Health Report
PM-0589, RHR HX Performance Evaluation, Revision 5
RHR System Periodic Review Meeting Notes dated March 27, 2015
RT-O-010-660-2, RHR HX Performance Test, Performed February 12, 2015
RT-X-010-661-2, RHR HX Performance Calculation Test, Performed March 25, 2015
R0963795
Section 1R08: In-service Inspection
Procedures
100-RT-001, Radiographic Examination in Accordance with ASME Section V, Article 2,
Revision 8
386HA480, GE Hitachi Nuclear Energy Written Practice for Certification of Nondestructive Test
Personnel, Revision 26
GEH-PDI-UT-5, PDI Generic Procedure for Straight Beam Ultrasonic Examination of Bolts and
Studs, Revision 6.1
GEH-UT-300, Procedure for Manual Examination of Reactor Vessel Assembly Welds,
Revision 12
GEH-UT-311, Procedure for Manual Examination of Nozzle Inner Radii and Bore, Revision 19
MA-PB-793-001, Visual Examination of Containment Vessels and Internals, Revision 2
ST-N-080-900-3, Visual Examinations of Drywell and Torus Surfaces, Revision 4
Drawings
6280-ISI-401, Sheet 4, ASME Section XI ISI Boundaries Drywell I.D. Roll-out and Penetrations,
Revision 0
A-4
CRs
01559490
02557950
02558014
02558524
C0255830
C0255936
C0255941
R1208385
Miscellaneous
ASME Repair/Replacement Plan for RHR Cross-tie Piping and Support Welds, dated
April 29, 2015
Completed Procedure ST-N-080-900-3 with Attached ASME IWE/IWL Visual Exam NDE
Reports, dated October 15, 2013
ECR 11-00376, RHR Cross-Tie Modification for EPU - Unit 3 A/C Trains, Revision 6
Focused Area Self-Assessment for ISI Program, dated September 3, 2015
GE Customer Notification Form 004, dated September 26, 2015
GE Customer Notification Form 006, dated September 28, 2015
IHI Reactor Vessel NDE Project Plan, Revision 0
Multiple VT Data Reports for ASME IWE/IWL Drywell Interior and Exterior from Procedure
MA-PB-793-001, dated October 2015
Owner's Activity Report for the 19th RFO for Unit 3, dated January 21, 2014
Owner's Activity Report for the 20th RFO for Unit 2, dated March 3, 2015
Peach Bottom ISI Program Plan for the 4th 10-Year Inspection Interval, Revision 4
Report 003600, UT Data Sheet for N4E Feedwater Nozzle-to-Vessel Weld, dated
September 27, 2015
Report 003650, UT Data Sheet for N4E Feedwater Nozzle Bore, dated September 28, 2015
Report 006350, UT Data Sheet for N4E Feedwater Nozzle Inner Radius, dated September 28,
2015
Report 010705, UT Data Sheet for RPV Studs 47-92, dated September 23, 2015
RPV Stud Qualification for NDE Personnel, dated September 24, 2015
RT Data Sheet for Weld 10-2DC20-29, dated September 30, 2015
RT Data Sheet for Weld 10-2XC020-11, dated October 2, 2015
RT Data Sheet for Weld 10-2XC020-12, dated October 2, 2015
Weld Information Data Sheet for 10-2DC20-29, dated September 28, 2015
Weld Information Data Sheet for 10-2XC020-11 and -12, dated September 28, 2015
Weld Traveler 212824-TR-308 for 10-2DC20-29, dated September 28, 2015
WPS-01-01-TS-200, Weld Procedure Specification for Manual GTAW/SMAW of P1 Metals,
Revision 9
Section 1R11: Licensed Operator Requalification Program
Procedures
OP-AA-101-115, Senior Management of the Operating Crews, Revision 4
Miscellaneous
PSEG-0235R Scenario 1, Group 1/ATWS
PSEG-0235R Scenario 2, Turbine Trip/ATWS
Peach Bottom Unit 3 BOC Startup Checklists
Peach Bottom Unit 2 BOC Startup Checklists
A-5
Section 1R12: Maintenance Effectiveness
Procedures
ER-AA-200-1001, Equipment Classification, Revision 1
02459304
CRs
02455787
02459304
02459304-05
Miscellaneous
PI-AA-125-1003, Apparent Cause Investigation Report (Equipment), Revision 2
Section 1R13: Maintenance Risk Assessments and Emergent Work Control
Procedures
OP-AA-108-117, Protected Equipment Program, Attachment 1 - Protected Equipment Work
Approval Form September 25, 2015, B and D CS, Revision 4
Miscellaneous
EGM 11-003, Revision 2, Memo to William Dean from Roy Zimmerman, dated
December 13, 2013
C0254584
Miscellaneous
Paragon Risk Profiles, October 1, 2015
Section 1R15: Operability Evaluations
Procedures
OP-AA-102-103, OWA Program, Revision 4
ST-O-011-405-3, Standby Liquid Control B Loop Injection Test, Revision 12
OP-AA-102-103, OWA Program, Revision 4
A1985864
02574110
CRs
02561427
02563769
02574110
C0256242
A-6
Drawings
LR-M-358, Standby Liquid Control System, Sheet 1, Revision 0
P&I Diagram, ESW and HPSW Systems
Miscellaneous
OWA Board Meeting Minutes, dated March 19, 2014
OWA Board Meeting Minutes, dated April 29, 2014
OWA Board Meeting Minutes, dated June 17, 2014
OWA Board Meeting Minutes, dated October 1, 2014
OWA Board Meeting Minutes, dated December 30, 2014
OWA Board Meeting Minutes, dated March 26, 2015
OWA Board Meeting Minutes, dated June 26, 2015
Section 1R18: Plant Modifications
Procedures
CC-AA-102, Design Input and Configuration Change Impact Screening, Revision 28
CC-AA-103, Configuration Change Control for Permanent Physical Plant Changes, Revision 27
CC-AA-104, Document Change Requests, Revision 16
CRs
02577302
02577693
02579116
02581643
02581644
02581240
02582201
Modifications
ECR: PB 13-00338, Unit 3 Recirculation MG Replacement - Outage Phase, Revisions 0, 1, 3,
and 4
ECR: PB 13-00340, Unit 3 Reactor Recirculation MG Set Decommissioning, Revision 0
ECR: PB 13-00341, Unit 3 Replacement of Reactor Recirculation System MGs with ASDs
(Pre-Outage P3R20 Work Scope), Revision 0, 1, 2, and 3
ECR: PB 14-00356, ASD Structure, Revisions 0, 1, and 2
Training Documents
N-PB-ENG-CT-1502B, Recirculation Adjustable Speed Drives (ASD), Revision 0
PLORT-1409C, Licensed Operator Training for ASD Modification to Unit 3 Reactor Recirculation
System, Revision 0
PSEG-0234R, ASD Operations Training Guide, Revision 0
Siemens Water-Cooled III, High Availability Variable Frequency Drive, Revision 0
Miscellaneous
MAT PB 13-00338-1-3, Unit 3 Adjustable Speed Drive (ASD) Uncoupled Recirculation Pump
Motor Modification Acceptance Test, Revision 0
MAT PB 13-00338-2-3, Unit 3 ASD Coupled Recirculation Pump Motor Modification Acceptance
Test dated October 20, 2015
MAT PB 13-00338-3-3, Unit 3 ASD Power Ascension Modification Acceptance Test, Revision 0
MAT PB 13-00341-1-3, Unit 3 ASD Cooling Water Modification Acceptance Test dated
September 24, 2015
A-7
Section 1R19: Post-Maintenance Testing
Procedures
ST/LLRT 30.01A.02, MSIV LLRT, Revision 14
ST/LLRT 30.14.01, LLRT CS A Loop, Revision 14
ST/LLRT 30.23.08, LLRT HPCI Vacuum Relief Valves, Revision 6
RT-O-013-240-3, RCIC Overspeed Trip Test Using Aux Steam, Revision 1
ST-O-032-301-3, HPSW Pump, Valve and Flow Functional and Inservice Test, Revision 31
IC-C-11-2009, Field Testing of Power Transformers, Revision 0
MA-AA-716-004, Complex Troubleshooting Data Sheet A, Revision 12
MA-AA-716-004, Support/Refute Method, Revision 13
MA-AA-716-012, PMT, Revision 20
C0256126
R1271865
R1122613
A1930510
A1546929
A1484162
A1049047
A1678925
A1600928
A1891126
A1975865
01171049
02600713
CRs
02561049
02561375
02570399
02587931
025888888
025888889
02589442
02589443
02590036
02599822
R1128367
R1128369
R1274711
R1018560
R1018560
R1018560
R0901395 C0172705
R1056916
R1249350
Miscellaneous
3 B Feedwater Testing and Maintenance Schedule
RHR P3R20 Planning Punchlist, Revision 8, dated March 10, 2015
Section 1R20: Refueling Outage
Procedures
OP-AA-108-108, Attachment 1, Engineering Department Start-Up Checklist, Revision 18
OP-AA-108-108, Attachment 9, Emergency Exceptions Checklist, Revision 18
A1930510
A1546929
A1484162
A1049047
A1678925
A1600928
A1891126
A1975865
02600713
01171049
CRs
02494904
02561427
02600168
02599822
R1274711
R1018560
R1018560
R1018560
C0172705
R1056916
R1249350
R0901395
C0172705
R1056916
R1249350
Section 1R22: Surveillance Testing
Procedures
A-8
EP-AA-1007, Addendum 3, Revision 0
MA-AA-723-301, Periodic Inspection of Limitorque Model SMB/SB/SBD-000 Through 5 Motor
Operated Valves, Revision 10
MA-AA-723-301, Periodic Inspection of Limitorque Model SMB/SB/SBD-000 Through 5 Motor
Operated Valves, Revision 11
PI-AA-120, Issue Identification and Screening Process, Revision 3
RRC 94.1-2, Reactor Operator Scram Actions
RRC 94.2-2, Plant Reactor Operator Scram Actions, Revision 3
SE-13.1-2, RCIC Manual Operations on Loss of 125/250 VDC Bus 2DA-W-A, Revision 0
SE-1 Bases, SE-1 Plant Shutdown from the Remote Shutdown Panel - Bases, Revision 22
SE-1 Procedure, SE-1 Plant Shutdown From the Remote Shutdown Panel - Procedure,
Revision 22
SO 13.7.A-2, Recovery From RCIC System Isolation or Turbine Trip, Revision 14
ST-O-033-750-2, ESW Pump Remote Shutdown Panel Test, Revision 0
ST-O-052-412-2, E-2 Diesel Generator Fast Start and Full Load Test, Revision 23
ST-O-052-202-2, E-2 Diesel Generator Slow Start and Full Load Test, Revision 21
ST-O-003-901-2, CRD Pump Remote Shutdown Panel Test, Revision 0
ST-O-003-901-3, CRD Pump Remote Shutdown Panel Test, Revision 0
ST-O-011-405-3, Standby Liquid Control System B Loop Injection Test, Revision 12
ST-O-013-201-2, RCIC Alternative Control Panel Test, and Remote Shutdown Panel Test,
Revision 5
ST-O-013-201-2, RCIC Alternative Control Panel Test, and Remote Shutdown Panel Test,
Revision 6
ST-O-013-201-3, RCIC Alternative Control Panel Test, and Remote Shutdown Panel Test,
Revision 5
ST-O-013-301-2, RCIC Pump, Valve, Flow and Unit Cooler Functional and In-service Test,
Revision 45
ST-O-013-750-3, Emergency Shutdown Control Panel Test, Revision 7
ST-O-013-750-2, Emergency Shutdown Control Panel Test, Revision 8
ST-O-013-750-2, Emergency Shutdown Control Panel Test, Revision 9
ST-O-023-200-3, HPCI Flow Rate at 175 PSIG Steam Pressure, Revision 17
A1978308
02414219
A2012485
A2015148
CRs
02012485
02413679
02414219
02526507
025500445
02551342
02551348
02556042
02556608
02556651
02556526
02555841
02558858
02556564
02575136
Drawings
M-1-S-42, Electrical Schematic Diagram RCIC System, Revision 75
SE-10, Alternative Shutdown, Revision 20
6280-M-365
6280-M-366
Miscellaneous
Appendix A Surveillances
Limitorque Technical Update 14-01, Issue Date: August 25, 2014
Remote Shutdown System 3.3.3.2, PBAPS Unit 3, Amendment No. 281
Remote Shutdown System B 3.3.3.2, PBAPS Unit 2, Revision No. 0
A-9
Remote Shutdown System 3.3.3.2, General Electric BWR/4 STS, 3.3.3.2-1, Revision 4.0
Position Paper for Justifying Compliance with LCO 3.3.3.2, Remote Shutdown System
Surveillance Requirement SR 3.3.3.2.1 (IR 2526507)
Unit 2 Limiting Conditions for Operation, Surveillance Requirements, Amendment No. 184
TSCR 93-16, PBAPS Current TSs Comparison Document
STI-28, Shutdown From Outside the Control Room
ARC-0AC097 B-6, Revision 6
Section 1EP6: Drill Evaluation
Procedures
OP-AA-101-115, Senior Management of the Operating Crews, Revision 4
Miscellaneous
PSEG-0235R Scenario 1, Group 1/ATWS
PSEG-0235R Scenario 2, Turbine Trip/ATWS
Section 2RS1: Access Control to Radiologically Significant Areas
Procedures
RP-AA-19, HRA Program Description, Revision 2
RP-AA-100, Conduct of Radiation Protection Operations, Revision 0
RP-AA-111, Advanced Radiation Worker (ARW), Revision 2
RP-AA-460, Controls for High and LHR Areas, Revision 26
RP-AA-460-002, Additional High Radiation Exposure Control, Revision 2
RP-AA-1008, Unescorted Access to and Conduct in Radiologically Controlled Areas, Revision 4
Documents
Unit 3 TSs
Unit 3 UFSAR
DW Survey All Levels Weeks of September 21, 2015 & September 28, 2015
Section 2RS2: Occupational ALARA Planning and Controls
Procedures
RP-AA-401, Operational ALARA Planning and Controls, Revision 19
RP-AA-401-1002, Radiological Risk Management, Revision 7
RP-AA-403, Administration of the Radiation Work Permit Program, Revision 6
Documents
RWP PB-C-15-00823, Feedwater Heater Replacement (3AE003 & 3CE003)
Wet Surface
RWP PB-C-15-00510, DW Main Steam SRV Activities
RWP PB-C-1500513, CRD Exchange, EDE Monitoring Required
A-10
Section 2RS3: In-plant Airborne Radioactivity Control and Mitigation
Procedures
RP-AA-440, Respiratory Protection Program, Revision 10
RP-AA-441, Evaluation and Selection Process for Radiological Respirator Use, Revision 5
RP-AA-301, Radiological Air Sampling Program, Revision 8
RP-AA-825-1001, Inspection of Respiratory Protection Equipment, Revision 5
RP-AA-825-1020, Operation and Use of Air Line Supplied Respirators, Revision 0
RP-PB-825-1011, Inspection and Use of the Muroroa V4 F1R Air Supplied Suit, Revision 2
Documents
NRC Approval Letter to Use Non-NIOSH approved Delta Suit, January 31, 2005
Breathing Zone Air Sample 15-07931 September 23, 2015
Breathing Zone Air Sample 15-08511 September 26, 2015
Work Area Air Sample for Valve MO-3-14-12A Breach September 27, 2015
Section 2RS5: Radiation Monitoring Instrumentation
Procedures
RP-AA-700-1501, Operation and Calibration of the Model SAM-9/11 Small Articles Monitor,
Revision 1
RP-AA-700-1214, Operation and Calibration of the PCM-1B Personnel Monitor, Revision 1
RP-AA-700-1240, Operation and Calibration of the Canberra ARGOS-5 Personnel
Contamination Monitor, Revision 2
RP-AA-700-1239, Operation and Calibration of the SAM-12 Small Articles Monitor, Revision 1
RP-AA-700-1235, Operation and Calibration of the PM-12 Portal Monitor, Revision 1
Section 2RS6: Radioactive Gaseous and Liquid Effluent Treatment
Procedures
CY-AA-130-205-F-02, Tritium, Gross Alpha, and Gross Beta Sample Preparation for
Scintillation Counting, Revision 2
CY-AA-170-000, Radioactive Effluent and Environmental Monitoring Programs, Revision 6
CY-AA-170-1000, Radiological Environmental Monitoring Program and Meteorological Program
Implementation, Revision 8
ODCM, Revision 15
Section 4OA1: Performance Indicator Verification
Procedures
ER-AA-2008, MSPI Monitoring and Margin Evaluation, Revision 4
LS-AA-2200, MSPI Data Acquisition and Reporting, Revision 5
LS-AA-2200, Reactor Core Isolation Data Sheets, October 2014 - September 2015, Revision 5,
Attachment 3
LS-AA-2200, High Pressure Injection Data Sheets, October 2014 - September 2015,
Revision 5, Attachment 2
CRs
02426670
02412767
02413412
02412748
02411606
02409746
A-11
Section 4OA2: Problem Identification and Resolution
Procedures
ER-AA-5400, Underground (Buried) Piping and Raw Water Corrosion Program (UPRWCP)
Guide, Revision 8
ER-AA-5400-1001, Raw Water Corrosion Program Guide, Revision 8
PI-AA-125, CAP Procedure, Revision 2
PI-AA-125-1005, Coding and Analysis Manual, Revision 0
Drawings
6280-M-315, Sheet 1, P&ID ESW and HPSW Systems, Revision 83
6280-M-315, Sheet 4, P&ID ESW and HPSW Systems, Revision 56
CRs
01411997
01680741
01695675
02407173
02411498
02413128
02427541
02489386
02494904
02519751
02520612
02559874
02568856
02574611
Miscellaneous
Apparent Cause Investigation Report titled "ESW Pinhole Leak on Supply Elbow to Unit 2 Ring
Header" (AR 01695675), dated October 15, 2014
Apparent Cause Investigation Report Titled, "HPSW Pipe Below Minimum Required Thickness"
(AR 01411997), dated September 27, 2012
PVP2014-28781, Piping Corrosion Rate & Remaining Life Basis: Commercializing
Conservatism in First Time Inspections, Revision 0
Third and Fourth Quarter 2015 Station Trend Reports
Technical Evaluation CC-AA-309-101, 2407173-2, Pit evaluation
Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion
Miscellaneous
LER 05000/277-2-15-001: Condition Prohibited by TS Due to Insufficient Remote Shutdown
System ST
A-12
LIST OF ACRONYMS
Agencywide Documents Access and Management System
as low as reasonably achievable
adjustable speed drive
American Society of Mechanical Engineers
corrective action program
CFR
Code of Federal Regulations
CR
condition report
engineering change request
emergency cooling tower
extended power uprate
emergency service water
groundwater protection initiative
high pressure coolant injection
high pressure service water
heat exchanger
IEEE
Institute of Electrical and Electronics Engineer
IMC
inspection manual chapter
IP
inspection procedure
IR
issue report
in-service inspection
improve technical specifications
LER
licensee event report
local leak rate test
lubrication oil
motor generator
maintenance rule
mitigating system performance index
non-cited violation
NRC
Nuclear Regulatory Commission
offsite dose calculation manual
out of service
operator workarounds
publicly available records
Peach Bottom Atomic Power Station
performance deficiency
performance indicator
post-maintenance testing
Refueling Outage
reactor core isolation cooling
A-13
Regulatory Guide
radiation protection
radiation protection manager
remote shutdown system
radiographic testing
rated thermal power
radiation work permit
SBLC
significance determination process
SR
surveillance requirement
safety/relief valve
structures, systems, and components
surveillance test
TS
technical specification
Updated Final Safety Analysis Report
ultrasonic testing
very high radiation area
visual examination
work orders