IR 05000277/2020003

Integrated Inspection Report 05000277/2020003 and 05000278/2020003

ML20314A019
Person / Time
Site:	Peach Bottom
Issue date:	11/09/2020
From:	Jon Greives Reactor Projects Region 1 Branch 4
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Greives J
References
IR 2020003
Download: ML20314A019 (13)

Text

November 9, 2020

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 -

INTEGRATED INSPECTION REPORT 05000277/2020003 AND 05000278/2020003

Dear Mr. Hanson:

On September 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Peach Bottom Atomic Power Station, Units 2 and 3. On October 9, 2020, the NRC inspectors discussed the results of this inspection with Mr. Matthew Herr, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, X /RA/

Signed by: Jonathan E. Greives

Jonathan E. Greives, Chief Reactor Projects Branch 4 Division of Reactor Projects

Docket Nos. 05000277 and 05000278 License Nos. DPR-44 and DPR-56

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000277 and 05000278

License Numbers:

DPR-44 and DPR-56

Report Numbers:

05000277/2020003 and 05000278/2020003

Licensee:

Exelon Generation Company, LLC

Facility:

Peach Bottom Atomic Power Station, Units 2 and 3

Location:

Delta, PA 17314

Inspection Dates:

July 1, 2020 to September 30, 2020

Inspectors:

S. Rutenkroger, Senior Resident Inspector

P. Boguszewski, Resident Inspector

E. Andrews, Health Physicist

Approved By:

Jonathan E. Greives, Chief

Reactor Projects Branch 4

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Peach Bottom Atomic Power Station,

Units 2 and 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

PLANT STATUS

Unit 2 began the inspection period at rated thermal power (RTP). The unit remained at or near RTP for the remainder of the inspection period, reaching 83 percent of RTP due to end of cycle coastdown.

Unit 3 began the inspection period at RTP. On September 12, 2020, the unit was down powered to 66 percent for a control rod sequence exchange and turbine valve testing. The unit was returned to RTP the following day, and remained at or near RTP for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted. As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from potential severe weather given a tropical storm warning on August 4, 2020

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on September 22, 2020

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 3 'B' and 'C' drywell chillers during inspection of the 'A' drywell chiller on June 30, 2020

(2) Emergency cooling system during 'A' emergency cooling tower system outage window (SOW) on July 8, 2020

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) Hardened containment vent system and severe accident water addition implementation strategy completed in conjunction with TI-193 inspection on August 12, 2020

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Unit 3 reactor building (RB) 'C' residual heat removal (RHR) pump and heat exchanger room on July 30, 2020

(2) Unit 3 RB closed loop cooling water room on July 30, 2020

(3) Unit 2 RB, 195' General Area on July 30, 2020

(4) Unit 2 RB, 135' General Area on July 30, 2020

(5) Unit common intake structure on September 24, 2020

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade performance during an unannounced fire drill on August 13, 2020

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) Unit common 'E-4' emergency diesel generator (EDG) jacket coolant, lube oil, and air coolant heat exchangers on July 13-14, 2020

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during the Unit 2 downpower to 90 percent to remove 4th stage feedwater heaters from service followed by power ascension on August 12, 2020

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (3 Samples)

(1) The inspectors observed and evaluated licensed operator requalification training in the simulator on July 20, 2020

(2) The inspectors observed and evaluated licensed operator requalification training in the simulator on August 11, 2020

(3) The inspectors observed and evaluated licensed operator requalification training in the simulator on September 21, 2020

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (3 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Unit 3 RHR system during the week of August 6, 2020

(2) Unit common 'E-1' EDG with review of A(1) Maintenance Review Action Plan on September 14, 2020

(3) Unit 3 reactor core isolation cooling (RCIC) as of September 25, 2020

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) Unit common 'E-4' EDG overhaul on July 13 to July 16, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Unit common 'E-4' EDG planned maintenance on July 14 to July 16, 2020

(2) Unit 3 'A' high-pressure service water (HPSW) planned maintenance on July 28, 2020

(3) Unit common 'E-3' EDG planned maintenance on August 10 to August 12, 2020

(4) Unit 3 'B' HPSW system planned maintenance on August 21, 2020

(5) Unit common 'E-4' EDG 24-hour endurance run on September 17, 2020

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (8 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Unit common 'E-3' failure to shutdown using normal means requiring tripping of the fuel racks on June 30, 2020

(2) Unit 3 high-pressure coolant injection (HPCI) lube oil mechanical trip valve on July 20, 2020

(3) Unit 2 RCIC lube oil cooling water pressure was low on August 13, 2020

(4) Unit common 'E-2' EDG excessive lube oil usage during 24-hour endurance run completed on August 24, 2020

(5) Unit 2 standby liquid coolant (SBLC) degraded heater level switch on August 27, 2020

(6) Unit common '2SU' startup transformer 'A' phase high voltage bushing oil level high on August 27, 2020

(7) Unit 2 'D' RHR room safety structural supports degraded from groundwater intrusion on September 9, 2020

(8) Unit 3 'C' RHR flow control valve limit switch indicated closed and the lock nut and stem nut were later identified to be loose on September 15, 2020

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)

The inspectors evaluated the following temporary or permanent modification:

(1) Unit 2 RCIC staged testing equipment on August 13, 2020

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) Unit common 'E-4' EDG maintenance overhaul on July 18, 2020

(2) Unit 3 'B' RHR room flood switch replacement on July 21, 2020

(3) Unit 2 SBLC level switch post-maintenance testing on August 26, 2020

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Unit common 'E-2' EDG cardox system surveillance test on July 6, 2020

(2) Unit common 'E-3' EDG run with governor troubleshooting on July 22, 2020

Inservice Testing (IP Section 03.01) (1 Sample)

(1) Unit 3 'A' core spray pump, valve, and flow test on August 13, 2020

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)

(1) The inspectors observed a full scope emergency preparedness drill conducted on September 9, 2020

Drill/Training Evolution Observation (IP Section 03.02) (2 Samples)

The inspectors evaluated:

(1) The inspectors observed a focused area emergency preparedness drill conducted on July 29, 2020

(2) The inspectors observed a focused area emergency preparedness drill conducted on August 19,

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (1 Sample)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) Main control room emergency ventilation system and standby gas treatment system

Temporary Ventilation Systems (IP Section 03.02) (1 Sample)

The inspectors evaluated the configuration of the following temporary ventilation system:

(1) Temporary ventilation for continuing independent spent fuel storage installation work

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees use of respiratory protection devices

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to external dosimetry that is used to assign occupational dose

Internal Dosimetry (IP Section 03.03) (2 Samples)

The inspectors evaluated the following internal dose assessments for actual internal exposures:

(1) There were no actual internal dose assessments during the inspection period

(2) The inspectors reviewed one investigational whole body count for an individual. No dose assignment was required.

Special Dosimetric Situations (IP Section 03.04) (2 Samples)

The inspectors evaluated the following special dosimetric situations:

(1) The dose assessment for one declared pregnant worker in 2019

(2) The dose assessment for two declared pregnant workers in 2020

71124.07 - Radiological Environmental Monitoring Program

Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples

Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program

GPI Implementation (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees implementation of the Groundwater Protection Initiative program to identify incomplete or discontinued program elements

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified Exelons performance indicator submittals listed below for the period October 1, 2019 through September 30, 2020 (8 samples):

MS07: High Pressure Injection Systems (IP Section 02.06)===

(1) Unit 2 high pressure injection systems

(2) Unit 3 high pressure injection systems

MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)

(1) Unit 2 heat removal systems

(2) Unit 3 heat removal systems

MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)

(1) Unit 2 RHR systems

(2) Unit 3 RHR systems

MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)

(1) Unit 2 cooling water support systems

(2) Unit 3 cooling water support systems

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On August 28, 2020, the inspectors presented the Respiratory Protection and Dose Assessment inspection results to Mr. Matthew Herr, Site Vice President, and other members of the licensee staff.

• On September 25, 2020, the inspectors presented the Radiological Environmental Monitoring Program inspection results to Mr. David Henry, Plant Manager, and other members of the licensee staff.

• On October 9, 2020, the inspectors presented the integrated inspection results to Mr. Matthew Herr, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.05

Miscellaneous

FSI 00010091

Bypass A-156 during Hot Work 3 'C' RHR

71111.07A

Miscellaneous

PM-1042

Determination of Diesel Operability with Cross-flow

Revision 6

Work Orders

WO 04329764,

WO 04329765,

WO 04329766

71111.11Q Corrective Action

Documents

Resulting from

Inspection

IR 4362435

71111.15

Corrective Action

Documents

IR 4343617

IR 4363306

IR 4366086

IR 4368194

IR 4369617

IR 4371233

IR 4371491

Corrective Action

Documents

Resulting from

Inspection

IR 4355988

71111.18

Corrective Action

Documents

IR 4364444

Procedures

ST-O-13-300-2

RCIC Pump, Valve, Flow & Unit Cooler Functional and In-

service Test without Vibration Data Collection

Revision 13

71111.19

Procedures

RT-O-052-254-2

E-4 Diesel Generator Inspection Post-Maintenance

Functional Test

Revision 40

Work Orders

WO 04857656

71111.22

Corrective Action

Documents

Resulting from

Inspection

IR 4366855

Procedures

ST-O-014-301-3

Core Spray LOOP 'A' Pump, Valve, Flow, and Cooler

Revision 37

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Functional and Inservice Test

Work Orders

WO 05054567

71124.03

Procedures

RP-AA-440

Respiratory Protection Program

RP-AA-825

Maintenance, Care and Inspection of Respiratory Protective

Equipment

71124.04

Procedures

RP-AA-210

Dosimetry Issue, Usage, and Control

71124.07

Miscellaneous

Offsite Dose Calculation Manual

Report No. 76

2018 Annual Radiological Environmental Operating Report

Report No. 77

2019 Annual Radiological Environmental Operating Report