IR 05000277/2007004

IR 05000277-07-004 and 05000278-07-004, on 07/01/07 - 09/30/07, Peach Bottom Integrated Inspection Report

ML073180112
Person / Time
Site:	Peach Bottom
Issue date:	11/13/2007
From:	Paul Krohn Reactor Projects Region 1 Branch 4
To:	Crane C Exelon Generation Co, Exelon Nuclear
KROHN, PG
References
IR-07-004
Download: ML073180112 (42)

Text

UNITED STATES mber 13, 2007

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000277/2007004 AND 05000278/2007004

Dear Mr. Crane:

On September 30, 2007, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Peach Bottom Atomic Power Station (PBAPS) Units 2 and 3. The enclosed integrated inspection report documents the inspection results, which were discussed on October 19, 2007, with Mr. J. Grimes and other members of your staff.

The inspection 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.

Based on the results of this inspection, no findings of significance were identified.

In accordance with 10 Code of Federal Regulations (CFR) 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document 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/

Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56

Enclosures:

Inspection Report 05000277/2007004 and 05000278/2007004 w/Attachment: Supplemental Information

C.

REGION I==

Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56 Report No.: 05000277/2007004 and 05000278/2007004 Licensee: Exelon Generation Company, LLC Facility: Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 Location: Delta, Pennsylvania Dates: July 1, 2007 through September 30, 2007 Inspectors: F. Bower, Senior Resident Inspector M. Brown, Resident Inspector T. Burns, Reactor Inspector R. Fuhrmeister, Senior Project Engineer E. Gray, Senior Reactor Inspector F. Jaxheimer, Senior Resident Inspector, Susquehanna M. Modes, Senior Reactor Inspector R. Nimitz, Senior Health Physicist G. Ottenberg, Reactor Inspector Approved by: Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects

SUMMARY OF FINDINGS

IR 05000277/2007-004, 05000278/2007-004; 07/01/2007 - 09/30/2007; Peach Bottom Atomic

Power Station (PBAPS), Units 2 and 3; Integrated Inspection.

The report covered a 3-month period of inspection by resident inspectors, a Susquehanna senior resident inspector, a senior project engineer, and announced inspections by a senior health physicist and four regional specialist inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified and Self-Revealing Findings

None.

Licensee-Identified Violations

None.

iv

REPORT DETAILS

Summary of Plant Status

Unit 2 began the inspection period at 100 percent rated thermal power (RTP) until September 5, 2007, when power was reduced to 55 percent for planned power suppression testing. On September 11, 2007, the unit returned to full power where it remained until the end of the inspection period, except for brief periods to support planned testing and rod pattern adjustments.

Unit 3 began the inspection period at 100 percent RTP until July 25, 2007, when the unit began a planned coastdown toward a refueling outage. On July 28, 2007, an unplanned power reduction to 89 percent was made due to a rapid rise in 3 A recirculation pump second stage seal temperature and, while the unit was at reduced power, the fifth stage feedwater heaters were removed from service. The unit returned to full power on July 28, 2007. On August 12, 2007, power was reduced to 93 percent for planned removal of the fourth stage feedwater heaters. The unit returned to full power on August 13, 2007. On August 30, 2007, power was reduced from 92 percent to 82 percent due to another rapid rise in the 3 A recirculation pump second stage seal temperature. Power was returned to maximum power for end-of-cycle coastdown on August 31, 2007. On September 1, 2007, power was reduced from 92 percent to 86 percent due to control rod 34-07 scramming from full out to full in during performance of ST-O-60F-100-3, Functional Test of Reactor Protection System (RPS) Channel A Scram Test Switches. ON-121, Drifting Control Rod procedure was entered and all required actions were performed. After repairs were made, power was returned to maximum power for end-of-cycle coastdown on September 2, 2007, and the plant continued to coastdown until the unit was taken offline for a refueling outage on September 23, 2007, where it remained until the end of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment (71111.04Q - 3 Partial Walkdown Samples)

.1 Partial Walkdown

a. Inspection Scope

The inspectors performed a partial walkdown of three systems to verify the operability of redundant or diverse trains and components when safety-related equipment was inoperable. The inspectors performed walkdowns to identify any discrepancies that could impact the function of the system and potentially increase risk. The inspectors reviewed applicable operating procedures, walked down system components, and verified that selected breakers, valves, and support equipment were in the correct position to support system operation. The inspectors also verified that PBAPS had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the Corrective Action Program (CAP). The three systems reviewed were:

• 3 A High Pressure Service Water (HPSW) System with 3 B HPSW Out-of Service;

• 2 A Residual Heat Removal (RHR) System with 2 B RHR System

• Out-of-Service; and

• 3 B RHR System with 3 A RHR System Out-of-Service and Reactor Vessel not Flooded Up.

b. Findings

No findings of significance were identified.

.2 Complete Walkdown (71111.04S - 1 Sample)

a. Inspection Scope

During the week of September 24, 2007, the inspectors conducted one complete walkdown of the E-2 Emergency Diesel Generator (EDG) system to verify the functional capability of the system. The inspectors used the licensee procedures and other documents listed below to verify proper system alignment:

• Drawing E-1, Single Line Diagram Station;

• Drawing M-377, Diesel Generator (DG) Auxiliary Systems;

• Procedure SO 52A.1.A-2, COL E-2 DG Normal Standby;

• Procedure SO 52A.1.A, DG Lineup for Automatic Start; and

• Procedure SO 52A.1.B, DG Operations.

The inspectors also verified the EDG electrical power requirements, operator workarounds, labeling, hangers and support installation, and associated support systems status. Diesel support systems (air systems, fuel oil systems, etc.) were walked down to ensure proper operation. The walkdowns also included evaluation of system piping and supports against the following considerations:

• Piping and Pipe Supports did not Show Evidence of Water Hammer;

• Oil Reservoir Levels Appeared Normal;

• Snubbers did not Appear to be Leaking Hydraulic Fluid;

• Hangers were Functional; and

• Component Foundations were not Degraded.

A review of outstanding maintenance work orders (WOs) was performed to verify that the deficiencies did not significantly affect the EDG system function. In addition, the inspectors reviewed the incident report database to verify that EDG equipment alignment problems were being identified and appropriately resolved.

b. Findings

No findings of significance were identified.

1R05 Fire Protection (71111.05Q - 9 Samples)

Fire Protection - Tours

a. Inspection Scope

The inspectors reviewed PBAPSs Fire Protection Plan, Technical Requirements Manual (TRM), and the respective pre-fire action plan procedures to determine the required fire protection design features, fire area boundaries, and combustible loading requirements for the areas examined during this inspection. The fire risk analysis was reviewed to gain risk insights regarding the areas selected for inspection. The inspectors performed walkdowns of nine areas to assess the material condition of active and passive fire protection systems and features. The inspection was also performed to verify the adequacy of the control of transient combustible material and ignition sources, the condition of manual firefighting equipment, fire barriers, and the status of any related compensatory measures. The following nine fire areas were reviewed for impaired fire protection features:

• Unit 2 and Unit 3 Cable Spreading Room and Computer Room (Fire Zones 78H and 129);

• Unit 2 Core Spray Instrument Room, Reactor Building, 116' Elevation (Fire Zone 5F);

• Unit 3 Core Spray Instrument Room, Reactor Building, 116' Elevation (Fire Zone 13F);

• Unit 3 Lubricating Oil Tank Room, Turbine Building, 116' Elevation (Fire Zone 89);

• Unit 3 Turbine Lubricating Oil Reservoir & Battery Room, Turbine Building, 135' Elevation (Fire Zone 93);

• Unit 3 B RHR Pump and Heat Exchanger (HX) Room, Reactor Building, 91'6" NS 116' Elevation (Fire Zone 10);

• Unit 2, Reactor Building, 135' Elevation (Fire Zone 5H)

• Unit 2, Turbine Lubricating Oil Reservoir & Battery Room (Fire Zone 90); and

• Unit 3, 135 Drywell Area (Fire Zone 32).

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures (71111.06 - 1 External Sample)

External Flooding

a. Inspection Scope

The inspectors reviewed the design, material condition and procedures for coping with the design basis maximum probable flood. The inspectors reviewed the abnormal operating procedure for mitigating the design basis flood. The inspectors reviewed publicly available information relating to dams upstream and downstream of the station to confirm potential water levels which could be achieved in the event of failures or extreme weather.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program (71111.11Q - 1 Sample)

Resident Inspector Quarterly Review

a. Inspection Scope

On August 27, 2007, the inspectors observed operators in PBAPSs simulator during licensed operator requalification training to verify that operator performance was adequate and that evaluators were identifying and documenting crew performance issues. The inspectors verified that performance issues were discussed in the crews post-scenario critiques. The inspectors also observed the operators implementation of operating procedures. The inspectors discussed the training, simulator scenarios, and critiques with the operators, shift supervision, and the training instructors. The evaluated scenario observed for this one sample involved the events listed below:

• An Anticipated Transient Without Scram; and

• Loss of Shutdown Cooling.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness (71111.12Q - 3 Samples)

a. Inspection Scope

The inspectors reviewed three samples of PBAPSs evaluation of degraded conditions involving safety-related structures, systems, and components (SSCs) for maintenance effectiveness during this inspection period. The inspectors reviewed PBAPSs implementation of the Maintenance Rule (MR), and verified that the conditions associated with the referenced condition reports (CRs) were evaluated against applicable MR functional failure criteria as found in the licensees scoping documents and procedures.

The inspectors also discussed these issues with system engineers and MR coordinators to verify that they were tracked against performance criteria and that the systems were classified in accordance with MR implementation guidance. Documents reviewed during the inspection are listed in the Attachment. The following conditions were reviewed:

• Issue Report (IR) 622567, Maintenance Preventable Functional Failure for AO-2-23-042 Failure to Open;

• IR 654785, Rapid Rise in 3 A Recirculation Pump Second Stage Seal Temperature; and

• E-1 Diesel Running Alarm and Reset During Full Load Run, CR 656655.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 5 Samples)

a. Inspection Scope

The inspectors evaluated PBAPSs implementation of their maintenance risk program with respect to the effectiveness of risk assessments performed for maintenance activities that were conducted on SSCs and verified that the licensee managed the risk in accordance with 10 CFR Part 50.65(a)(4) and procedure WC-AA-101, On-line Work Control Process. The inspectors evaluated whether PBAPS had taken the necessary steps to plan and control emergent work activities; and to manage overall plant risk. The activities selected were based on plant maintenance schedules and systems that contributed to risk. The inspectors completed five evaluations of maintenance activities on the following:

• WO C0221701, Replace E-1 EDG Angle Gear Drive;

• WO C0221104-16, Perform Online Noble Chemistry Injection;

• IR 653733, Missed Technical Specification (TS) - Inservice Testing (IST)

Surveillance on two PBAPS Safety/Relief Valves;

• IR 654019, Missed TS - IST Surveillance on PBAPS Relief Valve; and

• IR 659815, 4 A Feedwater Heater High Level Alarm.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations (71111.15 - 5 Samples)

a. Inspection Scope

The inspectors reviewed five issues to assess the technical adequacy of the evaluations, the use and control of compensatory measures, and compliance with the licensing and design bases. Associated adverse condition monitoring plans, engineering technical evaluations, and operational and technical decision making documents were also reviewed. The inspectors verified these processes were performed in accordance with the applicable procedures. The inspectors used TS, TRM, the Updated Final Safety Analysis Report (UFSAR), and associated Design Basis Documents (DBDs) as references during these reviews. The issues reviewed included:

• B Emergency Cooling Tower Fan (AR A0041691);

• Heavy Loads Review for RIS 2005-25 (IR 647808);

• Linear Elastic Fracture Mechanics (LEFM) System Impact Due to Letter from Manufacturer (IR 642941);

• E-1 EDG Ventilation Logic System Functional Test (ST-l-40F-251-2), (IR 658387);and

• 2 B Core Spray Room Flooding (IR 670207).

b. Findings

No findings of significance were identified.

1R17 Permanent Plant Modifications (71111.17 - 2 Samples)

.1 Design Change to MO-2-014-26A

a. Inspection Scope

The inspectors reviewed procedures CC-AA-102, "Design Input and Configuration Change Impact," and CC-AA-103, "Configuration Change Control," and reviewed PBAPSs activities to perform a design change for a motor-operated valve. The engineering change request (ECR PB 07-00031) was developed to increase the available torque for four motor operators by changing gear sets. The ECR package was developed to be applied to the motor operators on the core spray system loop A and loop B full flow test valves on Units 2 and 3. The Unit 2 loop A valve (MO-2-014-26A) was the focus of this inspection. The review was conducted to verify that the design bases, licensing bases, and performance capability of the motor-operated valve had not been degraded through this modification. The review of selected post-modification testing results were also conducted to verify that operability was established, to verify that unintended system interactions did not occur, and to verify that the test acceptance criteria were met.

b. Findings

No findings of significance were identified.

.2 Online Addition of NobleChem to Unit 3

a. Inspection Scope

The inspectors reviewed procedures CC-AA-102, "Design Input and Configuration Change Impact," and CC-AA-103, "Configuration Change Control," and reviewed PBAPSs activities to perform a design change for performing an application of Online NobleChem'. ECR PB 07-00118 was developed to inject noble metals into the reactor coolant via the feedwater system to mitigate intergranular stress corrosion cracking. The review was conducted to verify that the design bases, licensing bases, and performance capability of safety-related systems and components were not degraded through this modification. The associated 10 CFR 50.59 screening evaluation was also reviewed to verify its technical adequacy.

b. Findings

No findings of significance were identified.

1R19 Post-Maintenance Testing (71111.19 - 6 Samples)

a. Inspection Scope

The inspectors observed selected portions of post-maintenance testing (PMT) activities and reviewed completed test records. The inspectors observed whether the tests were performed in accordance with the approved procedures and assessed the adequacy of the test methodology based on the scope of maintenance work performed. In addition, the inspectors assessed the test acceptance criteria to evaluate whether the test demonstrated that the tested components satisfied the applicable design and licensing bases and the TS requirements. The inspectors reviewed the recorded test data to verify that the acceptance criteria were satisfied. The inspectors reviewed six PMTs performed in conjunction with the following maintenance activities:

• WO C0220918, Replace RO-3800D/RO-3789D/RO-3801D;

• WO C0221375, Repair Leak on 2 D Core Spray Pump Cyclone Separator;

• WO C0217450, Replacement of DPIS-3-02-116C;

• Troubleshoot Rework Testing (TRT)07-041, Raise Power Following 3 A Recirc Pump Seal Contact Event on August 30, 2007;

• WO C0222695, AO-3-10-046A, Correct Check Valve Seat Leakage; and

• WO R0880609, Remove and Replace E134-W-A.

b. Findings

No findings of significance were identified.

1R20 Refueling and Other Outage Activities (71111.20 - 1 Sample)

.1 Unit 3 Refueling Outage (RFO) 16

a. Inspection Scope

The Unit 3 RFO (P3R16) was conducted from September 23, 2007 through the end of the inspection period. Prior to the start of P3R16 on September 23, 2007, the inspectors reviewed the Outage Risk Assessment Management (ORAM) Plan against procedures OU-PB-104, "Shutdown Safety Management Program;" OU-PB-104-1001, "Shutdown Risk Management for Outages;" and OU-AA-103, "Shutdown Safety Management Program." The ORAM plan was reviewed to confirm that the PBAPS had appropriately considered risk, industry experience, and previous site specific problems in developing and implementing a plan that maintained shutdown safety defense-in-depth.

During the RFO, the inspectors observed portions of the shutdown process and performed the activities listed below to verify PBAPS controls over the outage activities:

• Unit Shutdown - observed operators removing the generator from the grid, reactor scram, and operator response to the scram including stabilizing the plant in Mode 3;

• Containment - conducted an initial drywell walkdown to check for unidentified leakage or other discrepant conditions;

• Clearance Activities - verified clearances on the A loop of RHR;

• Electrical Equipment - conducted complete system equipment alignment of the E2 EDG with the A RHR loop out-of-service;

• Decay Heat Removal - conducted partial system equipment alignment walkdown of B loop of RHR shutdown cooling, verifying proper alignment of decay heat removal systems while the A RHR loop was out-of-service;

• Inventory Control - verified procedures were being followed for the control rod drive decoupling/replacement;

• Reactivity Control - verified that control rod blade removal was being performed in accordance with PBAPS procedures and the TSs;

• Refueling Activities - verified that the PBAPS was using adequate controls to ensure the location of the fuel assemblies was properly tracked; and

• PBAPS Identification and Resolution of Problems - verified that the PBAPS was properly documenting outage issues in their CAP.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing (71111.22 - 6 Samples) [1 IST Sample; 1 Reactor Coolant System

(RCS) Leakage Sample; 1 Isolation Valve Sample; 3 Routine Samples]

a. Inspection Scope

The inspectors reviewed and observed portions of selected surveillance tests (STs), and compared test data with established acceptance criteria to verify the systems demonstrated the capability of performing the intended safety functions. The inspectors also verified that the systems and components maintained operational readiness, met applicable TS requirements, and were capable of performing the design basis functions.

The six STs reviewed and observed included:

• ST-O-052-154-2, E-4 DG Simulated Unit 2 Emergency Core Cooling System Signal Auto Start with Offsite Power Available;

• ST-O-014-301-3, Core Spray Loop A Pump, Valve, Flow and Cooler Functional and In-Service Test [IST Sample];

• ST-O-052-211-2, E-1 Diesel Generator (DG) Slow Start Full Load;

• ST-O-052-214-2, E-4 DG Slow Start Full Load;

• ST/Local Leak-Rate Test (LLRT) 30.10.07, LLRT - A - RHR Pump Discharge Valve (Isolation Valve Sample); and

• ST-O-020-560-2, Reactor Coolant Leakage Test.

b. Findings

No findings of significance were identified.

1R23 Temporary Plant Modifications (71111.23 - 1 Sample)

a. Inspection Scope

The inspectors reviewed one temporary configuration change package (TCCP) to verify that implementation of the modification did not affect systems important to safety. The review was also conducted to verify that the design bases, licensing bases, and performance capability of risk significant SSCs had not been degraded through these modifications. The inspectors reviewed the TCCP against the UFSAR and TSs to ensure the modifications did not affect system operability or availability. The inspectors compared the TCCP implementation to the guidance provided in procedures CC-AA-112, Temporary Configuration Changes, and CC-MA-112-1001, TCCP.

• TCCP 07-00325, Jumper Installed on B Phase of the Main Generator Output Disconnect Switch (3G3).

b. Findings

No findings of significance were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation (71114.06 - 1 Sample) Simulated Training Evolution

a. Inspection Scope

The inspectors evaluated the conduct of a routine emergency drill conducted by Exelon on July 10, 2007. The inspectors observed activities in the control room simulator and Technical Support Center to evaluate classification, notification, and protective action recommendation development activities. The inspectors also attended the drill critique conducted by Exelon to compare inspector observations to those of the Exelon drill evaluators.

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety

2OS1 Access Controls (71121.01 - 2 Samples)

a. Inspection Scope

The inspector selectively reviewed activities and associated documentation in the below listed areas. The evaluation of Exelons performance in these areas was against criteria contained in 10 CFR 20, applicable TSs, and applicable Exelon procedures.

Inspection Planning - Performance Indicators The inspectors reviewed performance indicators (PIs) for the Occupational Exposure Cornerstone. The inspectors also discussed and reviewed current performance, relative to the indicators, with cognizant Exelon personnel.

Plant Walkdowns, Radiation Work Permit (RWP) Reviews, and Jobs-in-Progress Reviews The inspectors walked down selected radiological controlled areas and reviewed housekeeping, material conditions, posting, barricading, and access controls to radiological areas. The inspectors made selective independent ambient radiation level measurements to verify conditions.

The inspectors reviewed and discussed internal dose assessments for 2006 and 2007, since the previous inspection, to identify any apparent actual occupational internal doses greater than 50 millirem committed effective dose equivalent. The review also included the adequacy of evaluation of selected dose assessments, as appropriate, and included selected review of the program for evaluation of potential intakes associated with hard-to-detect radionuclides (e.g., transuranics). The inspectors selectively reviewed in-plant source term evaluations including average energy determinations.

The inspectors reviewed and discussed the high radiation area controls program with radiation protection supervisors and technicians to identify changes that could potentially reduce program effectiveness and the level of worker protection.

Problem Identification and Resolution The inspectors selectively reviewed self-assessments and audits since the previous inspection to determine if identified problems were entered into the corrective action program for resolution. The inspectors evaluated the database for repetitive deficiencies or significant individual deficiencies to determine if self-assessment activities were identifying and addressing the deficiencies. The review also included evaluation of data to determine if any problems involved PI events with dose rates greater that 25 R/hr at 30 centimeters, greater than 500 R/hr at 1 meter or unintended exposures greater than 100 millirem total effective dose equivalent, 5 rem shallow dose equivalent (SDE), or 1.5 rem lens dose equivalent.

The inspectors reviewed problem reports since the last inspection which involved potential radiation worker or radiation protection personnel errors to determine if there was an observable pattern traceable to a similar cause. The review included an evaluation of corrective actions, as appropriate. (See Section 4OA2.6)

b. Findings

No findings of significance were identified.

2OS2 ALARA Planning and Controls (71121.02 - 5 Samples)

a. Inspection Scope

The inspectors conducted the following activities to determine if Exelon was properly implementing operational, engineering, and administrative controls to maintain personnel exposure as low as is reasonably achievable (ALARA). Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, applicable industry standards, and applicable station procedures.

Inspection Planning

The inspectors reviewed station collective dose history, current exposure trends, and ongoing and planned activities to assess current performance and exposure challenges.

The inspectors determined the plants current 3-year rolling average collective exposure and determined the site specific trends in collective exposures (using NUREG-0713 and plant historical data).

The inspectors reviewed planning and preparation for the Unit 3 maintenance outage.

The inspectors evaluated interfaces between various station departments from an ALARA planning perspective. The inspectors evaluated the status of radiation protection shielding requests. The inspectors reviewed ALARA plans for work activities likely to result in the highest personnel collective exposures and reviewed the planning and preparation for those work activities to determine if ALARA requirements were integrated into work procedure and radiation work permit documents. The work activities selectively reviewed were: reactor coolant re-circulation pump work, torus inspection (diving activities), under vessel work/control rod drive change-out, in-service inspection, scaffolding activities, refueling activities, and various valve work activities. The inspectors reviewed the Unit 2 2006 Refueling Outage Report. The inspectors reviewed and discussed various Station ALARA Committee meeting minutes (2007) and reviewed the Peach Bottom Station 2007-2012 Exposure Reduction Plan.

Verification of Dose Estimates and Exposure Tracking Systems The inspectors reviewed the assumptions and basis for current annual collective exposure estimates. The inspectors reviewed the exposure tracking system to evaluate the level of detail, and exposure report timeliness.

Source-Term Reduction and Control The inspectors selectively reviewed and discussed Exelons understanding of the plant source-term, including knowledge of input mechanisms to reduce the source term; and the source-term control strategy in place. The inspectors reviewed and discussed work planning contingencies for changes in source term or radiation dose rates. The inspectors discussed the licensees program for identification and control of areas of localized dose rates (hot spots). The inspectors reviewed station dose rates used for trending.

Problem Identification and Resolutions The inspectors selectively reviewed applicable self-assessments and audits related to the ALARA program. (See Section 4OA2.6)

b. Findings

No findings of significance were identified.

2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03 - 3 Samples)

a. Inspection Scope

The inspectors reviewed selected activities, and associated documentation, in the below listed areas. The evaluation of Exelons performance in these areas was against criteria contained in 10 CFR 20, applicable TSs, and applicable station procedures.

Calibration, Operability, Alarm Setpoint The inspectors selectively reviewed calibration of the following instrumentation used for radiological assessment and used for ongoing work activities:

• Area Radiation Monitor Channels (Criticality Monitors), Reactor Building Refuel Floor Monitors/Fuel Pool (Unit 3 Refueling Floor Areas);

• Alpha Counter (SAC-4), 78486, 79099;

• Radiation Survey Meter (Telepole) - 75622, 79146;

• Portable Area Monitor (AM-2) - 76530, 333690;

• Contamination Monitors (RM-14) - 74050; and

• Local Air Monitor (AMS-4) - 334638.

The inspectors selectively reviewed operability checks; calibration, including use of appropriate sources; and alarm setpoints, as applicable.

The inspectors selectively reviewed applicable self-assessments and audits related to the radiation monitoring instrumentation and protective equipment program. (See Section 4OA2.6)

b. Findings

No findings of significance were identified.

Cornerstone: Public Radiation Safety

2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (71122.01 - 1 Sample)

a. Inspection Scope

The inspectors selectively reviewed the calibration of flow rate instrumentation for the station plant vents and main stack. The review was against criteria contained in the Offsite Dose Calculation Manual (ODCM).

b. Findings

No findings of significance were identified.

2PS3 Radiological Environmental Monitoring Program (REMP) (71122.03 - 11 Samples)

.1 Review of the Implementation of Exelons REMP

a. Inspection Scope

The inspectors reviewed the implementation of Exelons REMP. The review was against applicable criteria specified in TSs, station procedures, the REMP program requirements outlined in the ODCM, and applicable NRC Guidance.

Inspection Planning and In-Office Inspection The inspectors reviewed the 2005 and 2006 Annual Environmental Monitoring Reports and licensee assessment results to verify that the REMP was implemented as required by TS and the ODCM. The inspectors reviewed the reports for changes to the ODCM with respect to environmental monitoring, commitments in terms of sampling locations, monitoring and measurement frequencies, land use census, inter-laboratory comparison program, and analysis of data. The inspectors also reviewed the UFSAR results for information regarding the environmental monitoring program and meteorological monitoring instrumentation.

The inspectors reviewed licensee self-assessments, audits, licensee event reports, and inter-laboratory comparison program results. (See Section 40A2.6)

Onsite Inspection The inspectors observed 10 thermoluminescence dosimeter (TLD) monitoring stations to determine whether they are located as described in the ODCM and to determine the equipment material condition. The inspectors observed collection of air particulate and iodine samples at five locations. The inspectors observed collection of a composite drinking water sample at one location. The inspectors observed ongoing surface water sampling at the station discharge. The inspectors verified that the environmental sampling was representative of the release pathways as specified in the ODCM and that sampling techniques were in accordance with applicable procedures.

The inspectors selectively reviewed calibration testing records for the meteorological tower (tower 2) to verify that meteorological instruments were operable, calibrated, and maintained in accordance with guidance contained in the UFSAR, NRC Safety Guide 23, and licensee procedures.

The inspectors reviewed events documented in the Annual Environmental Monitoring Report, as applicable, which involved a missed sample, inoperable sampler, lost TLD, or anomalous measurement for the cause and corrective actions.

The inspectors conducted a review of the Exelons assessment of positive sample results (i.e., licensed radioactive material detected above the lower limits of detection), as applicable. The inspectors reviewed, as applicable, the associated dose calculations and radioactive effluent release data that was the likely source of the released material.

The inspectors reviewed any significant changes made by Exelon to the ODCM as the result of changes to the land census (2005, 2006) or sampler station modifications since the last inspection. The inspectors reviewed technical justifications for any changed sampling locations. The inspectors evaluated the reviews, as applicable, required to ensure that the changes did not affect the ability to monitor the impacts of radioactive effluent releases on the environment.

The inspectors reviewed the calibration and maintenance records for selected air samplers, composite water samplers, and thermoluminescent dosimeters.

The inspectors reviewed the results of Exelons vendor laboratory to analyze the REMP samples and reviewed the results of the vendors quality control program, including the inter-laboratory comparison program, to verify the adequacy of the vendors program.

The inspectors reviewed audits and technical evaluations performed on the vendors program. The inspectors reviewed the results of the inter-laboratory comparison program to verify the adequacy of environmental sample analyses performed and the quality control evaluation of the inter-laboratory comparison program and the corrective actions for any deficiencies. Where applicable, the inspectors reviewed determination of any bias to the data and the overall effect on the REMP. The inspectors reviewed quality assurance audit results of the program to determine whether Exelon met applicable the TS/ODCM requirements.

Unrestricted Release of Material from the Radiologically Controlled Area (RCA)

The inspectors selectively observed locations where Exelon monitors potentially contaminated material leaving the RCA, and inspected the methods used for control, survey, and release from these areas. The inspectors observed the performance of personnel surveying and releasing material for unrestricted use to verify that the work was performed in accordance with plant procedures.

The inspectors verified that the radiation monitoring instrumentation was appropriate for the radiation types present and was calibrated with appropriate radiation sources. The inspectors reviewed Exelons criteria for the survey and release of potentially contaminated material and verified that there was guidance on how to respond to an alarm which indicated the presence of licensed radioactive material.

The inspectors reviewed Exelons equipment to ensure the radiation detection sensitivities were consistent with the NRC guidance for surface contamination and for volumetrically contaminated material. The inspectors discussed Exelons capabilities to detect radionuclides that decay via electron capture. The inspectors reviewed procedures and records to verify that the radiation detection instrumentation was used at its typical sensitivity level based on appropriate counting parameters (i.e., counting times and background radiation levels). The inspectors verified that Exelon had not established a release limit by altering the instruments typical sensitivity through methods such as raising the energy discriminator level or locating the instrument in a high radiation background area.

Identification and Resolution of Problems The inspectors reviewed Exelon event reports, special reports, audits, and self-assessments, as applicable, related to the REMP, since the previous inspection to determine if identified problems are entered into the CAP for resolution commensurate with their importance to safety and risk. The inspectors also reviewed ARs to evaluate Exelons threshold for identifying, evaluating, and resolving problems relating to occupational radiation safety. The review included a check of possible repetitive issues such as radiation worker or radiation protection technician errors. The following documents were reviewed:

• Program Area Audit - NOSA-PEA-06-04(AR476157476157, May 3, 2006, Chemistry, Radwaste, Effluent and Environmental Program;

• Check-in Assessment - (609506); and

• ARs: 648182, 646600, 143932, 359300, 481820, 525342, 542286, 578328, 359297, 394589, 429224, 438574, 593040).

This review was against the criteria contained in 10 CFR 20, TSs, and the station procedures.

b. Findings

No findings of significance were identified.

.2 Review of Meteorological Data

a. Inspection Scope

The inspectors selectively reviewed the meteorological data associated with the various meteorological towers at the station and discussed the data with cognizant licensee personnel. The inspectors also reviewed and discussed determination of ambient environmental radiation doses using thermoluminescent dosimetry. The review was against criteria contained in the ODCM.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator (PI) Verification (71151 - 10 Samples)

Cornerstone: Mitigating Systems

a. Inspection Scope

The inspectors reviewed a sample of the PBAPSs submittals for the PIs listed below to verify the accuracy of the data reported. The PI definitions and the guidance contained in Nuclear Energy Institute (NEI) 99-02, "Regulatory Assessment Indicator Guideline,"

Revision 4, and Exelon procedure LS-AA-2200, "Mitigating System Performance Index Data Acquisition and Reporting," were used to verify that procedure and reporting requirements were met. The inspectors reviewed raw PI data collected since January 2007 and compared graphical representations from the most recent PI report to the raw data to verify the data was included in the report. The inspectors also examined a selected sample of operations logs, licensee event reports, CAP records and procedures to verify the PI data was appropriately captured for inclusion into the PI report and the individual PIs were correctly calculated.

• High Pressure Coolant Injection (HPCI), Unit 2 and Unit 3;

• Reactor Core Isolation Cooling (RCIC), Unit 2 and Unit 3;

• EDGs, Unit 2 and Unit 3;

• RHR System, Unit 2 and Unit 3; and

• Emergency Service Water System, Unit 2 and Unit 3.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems (PI&R) (71152 - 4 Annual Samples)

.1 Torus Inspection

a. Inspection Scope

Based on identification of prior problems with the Unit 2 torus during an NRC Inservice Inspection Program inspection and resident inspector input, the inspectors selected condition reports IR 500730, 500728, 500747, 500533, 500534, 500617, 500732, and 500751 as a PI&R sample for a detailed follow-up review. The prior inspection had identified weaknesses in the torus program, such as the follow-up on repaired areas, sample size, sample distribution, pit tracking, repair re-examination, and root cause.

The inspectors assessed Exelons PI&R program and specific response to the issues raised by the prior NRC inspection. The inspectors reviewed the corrective actions taken in response to the NRC concerns to determine if appropriate cause analyses, extent of condition reviews, and prioritization was undertaken. The inspectors reviewed the timeliness of Exelons corrective actions to determine whether Exelon was appropriately identifying, characterizing, and correcting problems associated with this issue. This review was undertaken in order to understand if the ultimate corrective action of recoating the torus was being planned in a timely fashion.

b. Findings and Observations

No findings of significance were identified. The inspectors determined that Exelon's overall response to the issue was timely. The inspectors noted that Exelon's evaluation and follow-up corrective actions, as documented, were, in some cases, not completely responsive to the identified concern. Program owners and responsible engineering staff at PBAPS, however, clearly understood the concern and had implemented or were planning programmatic adjustments to accommodate the concerns. "Issue Report 670222, "LTA [Less-Than-Adequate] Documentation to Previously Identified NRC Questions," was written by Peach Bottom to capture this issue and enter it into their corrective action program."

.2 Inspection of Foreign Material Exclusion (FME) Practices and Corrective Actions Taken to

Exclude Foreign Material from Entering Plant Systems

a. Inspection Scope

The inspectors selected four IRs initiated in 2R16 (2006) for detailed review (IRs 533285, 533343, 534435 and 534509). The IRs were associated with the introduction of foreign materials into SSCs which could impact nuclear safety and risk. The IRs were reviewed to ensure that the full extent of the FME issues were identified, appropriate evaluations were performed, root and contributing causes were identified, and appropriate corrective actions were specified and prioritized. The inspectors reviewed a number of action requests (ARs) associated with the disposition of each IR to determine if the actions taken or planned would restore a condition adverse to quality to an acceptable condition or capability. The inspectors reviewed the FME program, refuel floor FME plans, FME training materials and lesson plans, and the CAP. The inspectors interviewed personnel responsible for implementation of the FME program. The inspectors also conducted a plant walkdown of accessible areas of Unit 2, including the refuel floor where new fuel was being receipt inspected and placed into the fuel pool. The inspectors evaluated the refuel floor FME area, examined the personnel log, tool and parts log, and observed the maintenance and control of the physical boundary of the area which is designated as a FME Area 1 (highest level of control).

b. Findings and Observations

No findings of significance were identified associated with the review of the selected IRs and action assignments. However, the inspectors noted that there had been a previous loss of foreign material integrity on the refuel floor during refuel outages in 2003 (Unit 3)and 2004 (Unit 2). In the previous outages, the loss of foreign material occurred from the same location (reactor cavity work platform) and was found in the reactor vessel. The foreign material was removed without identified damage to reactor structural internals, fuel, connecting systems, or other vital components during those outages. The inspectors noted that a safety-related component was replaced (D RHR pump impeller) due to identified damage caused by the loss of a calibration standard during the Unit 2 refuel outage 2R16 (2006). The inspectors discussed this incident and previous instances with PBAPS and concluded that the same vendor was involved in the performance of the in-vessel visual inspection. This contractor was responsible for the work location and the control of various cameras, calibration standards, lanyard material, and other devices used to secure tools and loose equipment in use on the platform.

The inspectors reviewed the corrective action(s) specified to enhance safety and performance of personnel responsible for implementation of the FME program to preclude similar occurrences of material loss in areas where systems and components are exposed and the risk of tool and material loss is high. The corrective actions appear to have been marginally successful, in that, there was loss of foreign material from the reactor cavity work platform during the last refueling outage (P3R16) and the overall number of FME events decreased. However, this is still a focus area for the plant because there was a significant event involving FME that caused damage to a turbine bearing and a slight extension to the refueling outage.

.3 Corrective Actions for the RCIC System Drain Line Crack/Leak of October 2006 Near the

Torus Shell

a. Inspection Scope

This inspection focused on the PI&R and corrective action aspects of the RCIC system drain line leak that occurred in October 2006, near location of the RCIC discharge location at the torus.

The inspectors reviewed the applicable ARs that described the leak condition, cause analysis, and provided for assignments for completion of corrective and preventive actions. The ARs reviewed included:

• AR 541265541265 Leak in Pipe Downstream, MO-2-23-031;

• AR 541936541936 ANII Review of Work Done Under Issue 541265; and

• AR 554818554818 Safety-Related Pipe not Classed per 10 CFR 50.55(a).

To see the location of the initial leak, the as-repaired configuration, and to verify the extent-of-condition effectiveness, the inspectors conducted walkdowns in the Unit 2 torus room and of portions of the Unit 2 and Unit 3 HPCI and RCIC systems. The inspectors interviewed the responsible engineering and American Society of Mechanical Engineers (ASME) Code inspection personnel to verify the adequacy of corrective actions. The inspection scope included review of the process for AR tracking, assignment tracking and control of the adequacy of task completion, the classification of safety-related piping, pipe flow rate evaluation scope, and the basis for confirmation that Unit 3 was not affected by a similar problem.

b. Findings

No findings of significance were identified.

.4 PECO/Exelon Procedures and Backlogged Procedural Changes

a. Inspection Scope

In order to determine if the backlog of procedure change requests negatively impacted plant safety, the inspectors reviewed Peach Bottoms CAP documents associated with requested procedure updates and enhancements that were backlogged in the licensees procedure change tracking databases. The inspectors also reviewed whether conflicts existed that could have a detrimental effect on procedure completion in cases where there was an active PECO procedure and an Exelon controlling document. In December 2006, an initiative (IR 569168) to evaluate the number and potential effects of conflicting PECO and Exelon documents was put in place by the licensee.

A sample of procedure modifications and enhancements was reviewed by the inspectors to determine the impact the change would have on the procedure, and whether the amount of time it took the licensee to evaluate and implement the change was appropriate based on its impact. The inspectors also interviewed station personnel and searched the corrective action program documents to determine if any procedural conflicts resulted in any negative impact on plant operation.

b. Findings and Observations

No findings of significance were identified. Interviews with station personnel and review of IRs indicated that no significant procedural conflicts existed between active PECO procedures and Exelon procedures. Of the sample that the inspectors performed on the existing items in the backlog of procedural updates, the majority were enhancements to the procedure intended to improve human factors or correct editorial errors. No examples were identified where a suggested procedure change involved critical steps of the procedure. Interviews with station personnel and review of backlogged procedure revisions indicated that appropriate prioritization methods were used based on the expected effect of the revision and when the procedure would be performed next.

During the time of the inspection, a backlog of 1,558 requested procedure revisions existed station-wide. Approximately 1,400 of these were in operations and maintenance.

In general, Peach Bottom has established a plan to address new procedure change requests and reduce the backlog. Based on interviews with Peach Bottom personnel responsible for making the procedure changes, the inspectors acknowledged that additional resources would be required to effect a large reduction in the number of backlogged procedure change requests that would not be commensurate with the significance of the procedural enhancements. However, the inspectors noted a minor example of a procedure change request being inappropriately cancelled, with resources being a contributing factor in IR 663248.

.5 Routine Review of Items Entered Into the CAP

a. Inspection Scope

As required by Inspection Procedure (IP) 71152, Identification and Resolution of Problems, and in order to help identify repetitive equipment failures, human performance issues or program issues for follow-up, the inspectors performed routine screening of issues entered into PBAPSs CAP. This review was accomplished by selectively reviewing copies of IRs and accessing PBAPSs computerized database.

b. Findings

No findings of significance were identified.

4OA3 Event Followup (71153 - 1 Sample)

.1 Alert Declared Due to Carbon Dioxide Leak from a Portable Fire Extinguisher in the Diesel

Generator Building

a. Inspection Scope

The inspectors reviewed selected applicable plant records, correction action documents and approved procedures while evaluating the performance of PBAPS personnel in response to a non-routine evolution. The inspectors assessed personnel performance to determine what occurred and how the operators responded, and to determine if plant personnels response was in accordance with plant procedures and training. The review also included the inspectors observations in the main control room and the technical support center during the event. The following non-routine evolution was observed and reviewed:

At 3:25 p.m. on August 8, 2007, plant personnel notified the main control room that the seal on a CO2 extinguisher in the E-3 EDG room had failed and the CO2 was rapidly discharging into the room. The concentrations of carbon dioxide and oxygen were not known and the room was evacuated. At 3:36 p.m., using EP-AA-1007, "Radiological Emergency Plan Annex for Peach Bottom Atomic Power Station," the shift manager declared an Alert based on emergency action level (EAL) HA7, "Release of Toxic of Flammable Gases." State and Local Agencies notifications were completed at 3:46 p.m.

The emergency response facilities were staffed and activiated by 4:24 p.m. The event was terminated at 4:53 p.m. in accordance with plant procedures after the E-3 EDG room was ventilated and verified to be safe for access. PBAPS personnel determined that the E-3 EDG was unaffected by the event and remained available if needed.

The inspectors verified that this event was placed into the CAP (IR 658607). The inspectors verified that this issue captured the results of a subsequent review that determined that the emergency declaration was not required since an atmosphere immediately dangerous to life and health could not have been created by this equipment failure. The inspectors reviewed the root cause report (RCR) for this event (IR 658607-09) which documented that the basis for EAL HA7 was confusing. The inspectors also verified that insufficient training on changes to the HA7 basis were documented as a contributing cause.

b. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On October 19, 2007, the resident inspectors presented the inspection results to Mr. J. Grimes and other PBAPS staff, who acknowledged the findings. The inspectors asked the licensee whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Exelon Generation Company Personnel

M. Flynn, Maintenance CAPCO

D. Foss, Senior Regulatory Engineer

F. Giaco, Core Spray/ Primary Containment System Engineer

J. Grimes, Site Vice President

A. Lloyd, Operations Support AD Coordinator

M. Massaro, Plant Manager

N. Alexakos, Manager, Engineering-Programs

J. Armstrong, Regulatory Assurance Manager

C. Behrend, Engineering Director

C. Jordan, Chemistry Manager

D. Lewis, Operations Director

D. Oltmans, Chemist

G. Stathes, Maintenance Director

S. Sullivan, Operations Support Manager

R. Taylor, Radiation Protection

S. Taylor, Manager, Radiation Protection

W. Thorpe, Chemistry CAPCO

A. Wasong, Training Director

NRC Personnel

F. Bower, Senior Resident Inspector

M. Brown, Resident Inspector

T. Burns, Reactor Inspector

R. Fuhrmeister, Senior Project Engineer

E. Gray, Senior Reactor Inspector

F. Jaxheimer, Susquehanna SRI

M. Modes, Senior Reactor Inspector

R. Nimitz, Senior Health Physicist

G. Ottenberg, Reactor Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None.

Closed

None.

Discussed

None.