IR 05000277/2023012
| ML23069A019 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/10/2023 |
| From: | Glenn Dentel Division of Operating Reactors |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2023012 | |
| Download: ML23069A019 (1) | |
Text
March 10, 2023
SUBJECT:
PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 - TITLE 10 OF THE CODE OF FEDERAL REGULATIONS 50.69 RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS, AND COMPONENTS INSPECTION REPORT 05000277/2023012 AND 05000278/2023012
Dear David Rhoades:
On February 10, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Peach Bottom Atomic Power Station, Units 2 and 3, and discussed the results of this inspection with Ryan Stiltner, Director Site Operations, and other members of your staff.
The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Peach Bottom Atomic Power Station, Units 2 and 3.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; and the NRC Resident Inspector at Peach Bottom Atomic Power Station, Units 2 and 3. 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, Glenn T. Dentel, Chief Engineering Branch 2 Division of Operating Reactor Safety
Docket Nos. 05000277 and 05000278 License Nos. DPR-44 and DPR-56
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000277 and 05000278
License Numbers:
Report Numbers:
05000277/2023012 and 05000278/2023012
Enterprise Identifier: I-2023-012-0005
Licensee:
Constellation Energy Generation, LLC
Facility:
Peach Bottom Atomic Power Station, Units 2 and 3
Location:
Delta, PA 17314
Inspection Dates:
January 23, 2023 to February 10, 2023
Inspectors:
F. Arner, Senior Reactor Analyst
L. Cline, Senior Reactor Inspector
B. Pinson, Senior Reactor Inspector
S. Rutenkroger, Senior Resident Inspector
Approved By:
Glenn T. Dentel, Chief
Engineering Branch 2
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Title 10 of the Code of Federal Regulations (10 CFR) 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components 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
Failure to Adequately Perform Passive Risk Categorization of the Emergency Service Water (ESW) System Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000277,05000278/2023012-01 Open/Closed
[H.2] - Field Presence 37060 The inspectors identified a Green non-cited violation (NCV) of Peach Bottom Operating License Condition 2.C, paragraph 17, because the licensee categorized ESW piping segments P3-ESW-01, P3-ESW-02, and P3-ESW-04 as low safety significance by crediting operator action but did not meet the conditions required by the prescribed passive categorization method.
Additional Tracking Items
None.
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.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
37060 - 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components (SSCs) Inspection
The inspectors reviewed the licensees program and implementation of 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors, in accordance with the following procedure sections. Section 02.04 was not completed during this inspection because the feedback and process adjustment required by 10 CFR 50.69(e) was not implemented by the licensee. As of the date of this inspection, two refueling outages have not occurred since system categorization was completed on at least three systems.
Review of the Licensees Programs and Procedures (IP Section 02.01) (1 Partial)
(1)
(Partial)
The inspectors reviewed the licensees program and procedures associated with 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors, license amendment described in the plant safety evaluation and Updated Final Safety Analysis Report and documented in the staffs Safety Evaluation Report (ADAMS Accession Nos. ML18263A232 and ML18302A257).
Review of the Licensees 10 CFR 50.69 Program Implementation (IP Section 02.02) (1 Partial)
(1)
(Partial)
The inspectors reviewed the licensees 10 CFR 50.69 categorization process and alternate treatment requirements completed on the following systems:
- High Pressure Service Water
- ESW/Emergency Cooling Water (ECW)
- Containment Atmospheric Control Problem Identification and Resolution (IP Section 02.03) (1 Partial)
(1)
(Partial)
For the systems listed above, the inspectors reviewed the licensees corrective action program to verify that conditions that would prevent Risk-Informed Safety Class (RISC)-3 SSCs from performing their safety-related function have been corrected.
Additionally, the inspectors verified that, as appropriate, the licensee performed common cause reviews for RISC-3 SSC deficiencies to ensure that the licensees SSC categorization process remains valid.
INSPECTION RESULTS
Failure to Adequately Perform Passive Risk Categorization of the Emergency Service Water (ESW) System Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000277,05000278/2023012-01 Open/Closed
[H.2] - Field Presence 37060 The inspectors identified a Green NCV of Peach Bottom Operating License Condition 2.C, paragraph 17, because the licensee categorized ESW piping segments P3-ESW-01, P3-ESW-02, and P3-ESW-04 as low safety significance by crediting operator action but did not meet the conditions required by the prescribed passive categorization method.
Description:
On October 25, 2018, the NRC approved Peach Bottom Atomic Power Station (PBAPS) License Amendment Nos. 321 and 324 (ML18263A232 and ML18302A257) that approved 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors, for implementation at PBAPS.
On March 3, 2022, the licensee completed 50.69 categorization for the PBAPS ESW and ECW systems. The categorization was performed by a contractor in accordance with the industry guidance available in NEI 00-04, as endorsed by NRC Regulatory Guide (RG) 1.201 and the Arkansas Nuclear One, Unit 2 (ANO-2) passive categorization method previously approved by the NRC (ML090930246). Both methods were part of the overall methodology assessed by the Safety Evaluation Report issued by the NRC to allow the licensee to implement 10 CFR 50.69 at PBAPS.
Licensee procedure ER-AA-569, 10 CFR 50.69 Program, states that components having a pressure retaining function are required to undergo a separate process to determine their passive risk categorization. Procedure ER-AA-569-1002, 10 CFR 50.69 Passive Component Categorization, assigns components a passive categorization, either low safety significance (LSS) or high safety significance (HSS), in accordance with the license requirements using the ANO-2 passive categorization method.
Using the approved 50.69 categorization process, LSS components are determined to not be significant contributors to safety based on a risk-informed process that combines probabilistic risk analysis (PRA) insights, operating experience, and other technical information. Safety-related components determined to be LSS are no longer required to be subject to the special treatment requirements imposed by several NRC regulations including, but not limited to, in-service inspection, and specific repair and replacement requirements for ASME Class 2 and Class 3 SSCs.
In accordance with the ANO-2 method as described in Section I-3.0.1 of Attachment 1 to Request for Alternative ANO2-R&R-004, Revision 1 (ML071150108), pressure-retaining items (i.e., piping) are grouped into segments and evaluated for significance categorization based on conditional consequences that consider direct and indirect effects for each segment given a postulated failure of the piping segment. According to the method, the evaluation may credit operator actions to the extent that actions and equipment activated would not be affected by failure of the segment under consideration. When crediting operator action, the evaluation shall ensure the following features are provided:
- An alarm or other system feature provides clear indication of failure;
- Equipment activated to recover from the condition must not be affected by the failure;
- Time duration and resources are sufficient to perform operator action;
- Plant procedures define operator actions; and
- Operators are trained on the procedures.
Licensee procedure ER-AA-569-1002, 10 CFR 50.69 Passive Component Categorization, step 4.2.2.4.A.4, also required the above conditions to be met to consider operator action credit during the passive categorization evaluation. Procedure PB-5069-033-48-002, Revision 0, Emergency Service Water and Emergency Cooling Water Rupture Analysis, defined ESW piping segments P3-ESW-01, P3-ESW-02, and P3-ESW-04 as the following:
- Segment P3-ESW-01 includes the piping in the B ESW pump room up to the pump room penetration.
- Segment P3-ESW-02 includes piping from the ESW B pump room to motor-operated valves MO-3972 and MO-2972.
- Segment P3-ESW-04 begins at valves 0-33-509 (B ESW train emergency diesel generator (EDG) cooler supply header isolation) and concludes at 0-33-504A (B, C, D) (B ESW train EDG cooler supply header individual EDG cooler isolations).
Based on the passive consequence risk analysis completed by the contractor, these three piping segments were classified medium consequence and categorized as LSS within the overall ESW categorization procedure. Postulated pipe breaks in these three B ESW train piping segments were determined to result in a loss of all ESW and ECW without credit for operator action. However, according to the consequence analysis, these segments are isolable from the A train of the ESW system by shutting normally open motor-operated valves MO-3972 and MO-2972. Taking credit for isolation of postulated breaks in these piping segments reduced the consequence or conditional core damage probability value to allow LSS categorization. The categorization documentation provided by the licensee did not include specific details regarding alarms and indications that would cue operator response, the plant procedures operators would use to respond, the time available to respond, and operator training on the procedures used for response.
The inspectors requested these additional details to evaluate the basis for the operator action credit in accordance with the ANO-2 passive categorization method. The initial response to this request stated that for an ESW line break in many secondary containment rooms, including core spray, ESW, high pressure coolant injection, reactor core isolation cooling, and residual heat removal pump rooms, there are sump level indications and room flooding alarms in the control room. In the event of an alarm, operators are trained to enter Emergency operating procedure T-103, Secondary Containment Control, to respond. The stated position was that for the postulated pipe breaks in the associated LSS piping segments operators using the T-103 procedure would connect the high sump level indications with the symptoms of reduced or interrupted flow to the EDGs and/or emergency core cooling system room coolers and an automatic start of ECW pumps (due to low ESW header pressure), and then complete timely action to isolate the pipe break and start the opposite ESW train. The inspectors questioned the applicability of this procedure to these three piping segments because a significant portion of the piping in these segments is located outside of the secondary containment and, based on the information provided, the sump alarms and rooms addressed by T-103 would not be applicable to a response to a pipe break in these pipe segments.
The licensee conducted a further evaluation in response to the inspectors questions. The evaluation reviewed available alarms, control room alarm response cards, ESW system abnormal operating procedures and the training available that would address actions for postulated breaks in the three pipe segments. The licensees evaluation referred to three procedures for the postulated breaks. The procedures referenced included the control room alarm response cards (ARCs) for low discharge pressure on both the A and B ESW pumps, ARC-002 00C226B D-5 and ARC-004 00C226C D-5; flooding in the A and B ESW pump rooms, ARC-004 00C226C A-3 and ARC-004 00C226C A-4; and the abnormal operating procedure AO 33.6-0, ESW Pump Discharge Crosstie Operation. The licensee stated that indications such as flood level alarms in the ESW pump rooms, and/or running ESW pump low discharge pressure alarms combined with a standby ESW pump start and a potential ECW pump auto start would provide sufficient indications to cue operators to take actions.
These would be in accordance with the ARCs and the abnormal operating procedure and complete timely isolation of the piping segments in question. The licensee also concluded that operators were trained in flooding response and execution of alarm response cards and abnormal operating procedures.
The inspectors reviewed the ARCs and abnormal operating procedure referenced by the licensee and concluded that they did not provide sufficient direction to operators to ensure the timely isolation of the postulated breaks in the piping segments. The procedures did not provide specific direction for leak isolation in these piping segments. For example, the ESW pump room flooding ARC only specifically directed operation of flood doors to minimize impact on equipment and the low ESW pump discharge pressure ARC directed operators to investigate the cause and isolation of the service water to ESW crosstie with a manual isolation valve if a check valve was determined to have failed. The abnormal operating procedure, AO 33.6-0, for crosstie operation provided flexibility to align the ESW system, as needed, for off-normal configurations like system maintenance, but did not include specific direction for leak isolation. It was unclear to the inspectors how operators would enter this procedure during leak response given the purpose of the procedure.
The inspectors concluded that the licensee did not meet the ANO-2 method requirements for crediting operator response as part of piping segment consequence analysis. The inspectors did not identify any documentation or analysis that described how an alarm or system feature would provide clear indication of failure regarding all of the applicable segments of piping that took credit for operator action in the consequence analysis. It was not clear to the inspectors whether valves credited for isolation would not be affected by the failure (e.g., if the EDGs tripped on high jacket water temperature due to reduced cooling given the postulated pipe ruptures, the AC power to the ESW pumps and two motor-operated valves specifically credited by the licensee for isolation would be lost). It is also unclear if the subsequent loss of pumps and pressure could also impact the ability to detect the leak location. Further, the inspectors did not identify any supporting information that demonstrated the time duration and resources were sufficient to credit the operator action of isolating the break. Plant procedures referenced by the licensee in their response to inspector questions do not define or direct the operators to perform the actions that would be required to ensure adequate isolation. None of the procedures provided to the inspectors directed closure of the motor-operated valves that the licensees analysis credited for isolation of a postulated break in the applicable ESW pipe segments. Further, due to the configuration of the ESW supply in series to the EDG air, lube oil and jacket water coolers, for a break in these three piping segments it was not clear that the A train piping would have been isolated by the credited operator action to close the two motor-operated valves. The licensee proposed that adequate flow would be maintained to the EDGs due to piping length and flow resistance. However, without additional supporting information the inspectors could not confirm the adequacy of these configurations. In addition, the inspectors concluded that operators were not trained on the procedures because there were no procedures that defined the operator actions or specific valves to isolate for the postulated pipe ruptures within the applicable B pipe segments.
Corrective Actions: The licensee initiated PBAPS Ops Standing Order 23-02 to ensure that ESW system piping segments P3-ESW-01, P3-ESW-02, and P3-ESW-04 are treated as HSS until an adequate basis for LSS categorization for those piping segments is completed.
Corrective action was initiated to complete further engineering analysis.
Corrective Action References: IR 4553779
Performance Assessment:
Performance Deficiency: ER-AA-569-1002, 10 CFR 50.69 Passive Component Categorization, step 4.2.2.4.A.4, requires that to take into account any operator action credit during passive categorization the following conditions must be true: alarms or other system features provide clear indication of the postulated failure, plant procedures define operator response actions, operators are trained on the procedures, equipment activated to recover from the condition was not affected by the failure, and the time duration and resources were sufficient to perform the operator action. The inspectors determined that the licensee incorrectly categorized ESW piping segments P3-ESW-01, P3-ESW-02, and P3-ESW-04 as LSS because the consequence and risk analyses that were used credited operator actions, but the licensee did not ensure that all of the above conditions were satisfied.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the inspectors determined that the lack of a complete evaluation of the cues, timing, procedures, and training in place to support the credited operator actions resulted in reasonable doubt about the piping segments LSS categorization. This required the licensee to complete additional evaluation and analysis to resolve the concern. Safety-related piping determined to be LSS is exempt from specific ASME Section XI repair and replacement requirements; therefore, the incomplete categorization evaluation resulted in reduced standards relative to this piping.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the finding was of very low safety significance (Green) because it was not a deficiency affecting the system design or qualification and it did not represent a loss of system function.
Cross-Cutting Aspect: H.2 - Field Presence: Leaders are commonly seen in the work areas of the plant observing, coaching, and reinforcing standards and expectations. Deviations from standards and expectations are corrected promptly. Senior managers ensure supervisory and management oversight of work activities, including contractors and supplemental personnel.
Specifically, the inspectors determined the licensee did not ensure adequate oversight of the 50.69 categorization process. The inspectors identified multiple categorization process supporting documents that did not include information needed to support passive component categorization in accordance with the approved process.
Enforcement:
Violation: Peach Bottom Operating License Condition 2.C, paragraph 17 states that the licensee is approved to implement 10 CFR 50.69 using the processes for categorization of RISC-1, RISC-2, RISC-3, and RISC-4 SSCs using, in part, the ANO-2 passive categorization method to assess passive component risk for Class 2 and Class 3 SSCs and their associated supports.
Procedure ER-AA-569, 10 CFR 50.69 Program, states that components having a pressure retaining function are required to undergo a separate process to determine their passive risk categorization. Procedure ER-AA-569-1002, 10 CFR 50.69 Passive Component Categorization, assigns components a passive categorization, either LSS or HSS, using the ANO-2 passive categorization method as described in Section I-3.0.1 of Attachment 1 to Request for Alternative ANO2-R&R-004, Revision 1 (ML071150108). ER-AA-569-1002, step 4.2.2.4.A.4, allows the licensee to credit operator actions as long as all of the following conditions were true: alarms or other system features provide clear indication of the postulated failure, plant procedures define operator response actions, operators are trained on the procedures, equipment activated to recover from the condition was not affected by the failure, and the time duration and resources were sufficient to perform the operator action.
Contrary to the above, from March 3, 2022, the licensee failed to categorize ESW piping segments P3-ESW-01, P3-ESW-02, and P3-ESW-04 in accordance with ER-AA-569-1002. Specifically, the licensee credited operator actions when all of the following conditions were not true: alarms or other system features provide clear indication of the postulated failure, plant procedures define operator response actions, operators are trained on the procedures, equipment activated to recover from the condition was not affected by the failure, and the time duration and resources were sufficient to perform the operator action.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On February 10, 2023, the inspectors presented the special inspection results to Ryan Stiltner, Director Site Operations, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
37060
Corrective Action
Documents
04091066
04097319
04179080
04184353
04185196
04187424
04197590
204464
212920
218337
218341
235748
263436
286215
293985
298774
298938
04304181
04307723
04333925
04338785
04390516
04359593
04374639
04374693
04377120
04388225
04396164
04400698
04404382
04421253
04455471
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
04457427
04460094
04466868
04511604
04513239
04516972
04520791
04521045
04522137
04522181
04523718
04525062
04525081
04527428
04532960
04537178
04537685
04548647
Corrective Action
Documents
Resulting from
Inspection
04550492
04550746
04551533
04553779
04553631
04553784
Drawings
E-349, Sheet 1
Electrical Schematic Diagram Emergency Cooling Water
System Emer. Cool. Wtr. PP & Disch. Valve
Revision 25
E-349, Sheet 2
Electrical Schematic Diagram Emergency Cooling Water
System Emer. Cool. Wtr. PP & Disch. Valve
Revision 21
M-315, Sheet 1
Revision 92
M-315, Sheet 2
Revision 57
M-315, Sheet 4
Revision 56
M-315, Sheet 5
Revision 59
M-330, Sheet 1
P&ID Emergency Cooling System
Revision 38
R-315, Sheet 1
50.69 Passive RISC Boundary P&ID ESW and HPSW Syss
Revision 0
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
R-315, Sheet 3
50.69 Passive RISC Boundary P&ID ESW and HPSW Syss
Revision 0
R-36, Sheet 2
50.69 Passive RISC Boundary P&ID Containment
Atmospheric Control System
Revision 0
R-361, Sheet 1
50.69 Passive RISC Boundary P&ID RHR System
Revision 0
R-361, Sheet 2
50.69 Passive RISC Boundary P&ID RHR System
Revision 0
R-361, Sheet 3
50.69 Passive RISC Boundary P&ID RHR System
Revision 0
R-361, Sheet 4
50.69 Passive RISC Boundary P&ID RHR System
Revision 0
R-362, Sheet 2
50.69 Passive RISC Boundary P&ID Core Spray Cooling
System
Revision 0
R-367, Sheet 1
50.69 Passive RISC Boundary P&ID Containment
Atmospheric Control System
Revision 0
Engineering
Evaluations
Task Analysis for Core Spray Cooling System Valves
Alternative Treatment
2/23/21
Peach Bottom RHR Air Operated Valve Alternative
Treatment Plan
Environmental Qualification Equipment Alternate Treatment
Evaluation
Alternative Treatment - Environmental Qualification
Requirements
Revision 0
EQ-PB-013
Environmental Qualification / Valcor Solenoid Valves
Revision 1
MREQ
04350871-12
HPSW Risk Informed Safety Class (RISC) 2 Evaluation
MREQ 4346216-
RHR Risk Informed Safety Class (RISC) 2 Evaluation
PMC-20-124348
50.69 White Paper for Alternative Treatment Plan
09/28/20
PMC-20-128110
50.69 White Paper for Alternative Treatment Plan 10 - RHR
PMC-21-127521
50.69 White Paper for Alternative Treatment Plan
03/15/21
PMC-21-127706
Task Analysis for Core Spray Pump Discharge Relief Valves
RV-2(3)-13-020A.B Alternative Treatment
10/28/20
PMC-21-128174
Task Analysis for Containment Atmosphere Control System
Valves Alternative Treatment
10/18/21
Task Analysis for
HPSW Relief
(RV-2-32-180A, B, C, D, RV-3-32-180A, B, C, D)
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Valve Alternative
Treatment
Task Analysis for
Residual Heat
Removal Relief
Valve Alternative
Treatment
(RV-2-10-035A, B, RV-2-10-181A, B, C, D, RV-3-10-035A, B,
RV-3-10-181A, B, C, D)
Fire Plans
Flood - Bases
Revision 34
Miscellaneous
Philadelphia Electric Company Ltr to NRC, Response to NRC
Questions Concerning Voltage Regulation Technical
Specification Amendment Application (TSP 88-12)
Dated
3/6/1989
NRC Ltr to Arkansas Nuclear One Unit 2 - Approval of
Request for Alternative ANO2-R&R-004, Revision 1, Request
to Use Risk Informed Safety Classification and Treatment for
Repair/Replacement Activities in Class 2 and 3 Moderate
and High Energy Systems (TAC No, MD5250)
4/22/2009
NE-117-54
IPEEE/SQUG Technical Report for PBAPS Success Path
Component List (SPCL)
Revision 0
P-S-27
Design Basis Document for Emergency Cooling Water
System
Revision 11
PB-5069-001
50.69 Component Categorization Database Inputs - Internal
Events Model Rollout Support Application PB218A5 and
PB318A5
Revision 1
PB-5069-002
50.69 Component Categorization Database Inputs - Fire
Model Rollout Support Application PB218A5F0 and
PB318A5F0
Revision 1
PB-5069-010-001
50.69 Active Categorization Risk: PRA Inputs to 50.69
Database for Categorization of Residual Heat Removal
System (010)
Revision 0
PB-5069-014-001
50.69 Active Categorization Risk: PRA Inputs to 50.69
Database for Categorization of Core Spray System (014)
Revision 0
PB-5069-032-001
50.69 Active Categorization Risk: PRA Inputs to 50.69
Database for Categorization of HPSW System (032)
Revision 0
PB-5069-032-002
HPSW Passive Consequence Development in Support of
Revision 0
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
50.69 Passive Categorization
PB-5069-07B-
CFR 50.69 SCD - Containment Atmosphere Control
System (7B, 07D, 07J)
Revision 2
PB-5069-10-10A-
003
CFR 50.69 SCD - RHR System
Revision 6
PB-5069-14-14A-
003
CFR 50.69 SCD - Core Spray System
Revision 1
PB-5069-32-003
CFR 50.69 SCD - HPSW System
Revision 6
PB-5069-33-48-
2
ESW and ECW Passive Consequence Development in
Support of 50.69 Passive Categorization
Revision 0
PB-5069-33-48-
003
CFR 50.69 SCD - Emergency Service Water (33) and
Emergency Cooling Water Systems (48)
Revision 0
PB-MISC-027
External Hazards Assessment for Peach Bottom Atomic
Power Station
Revision 5
PB-MISC-050
Determination of Component Risk Contribution to the
ISLOCA Initiating Event for 50.69 Categorization
Revision 0
PB-MISC-056
Peach Bottom Atomic Power Station Probabilistic Risk
Assessment, Responses to NRC DBAI PORV Inspector
Questions
PB-MISC-32
RHR Passive Categorization Support
Revision 0
PB-PRA-005.05
PBAPS Probabilistic Risk Assessment RHR System
Notebook
Revision 4
PB-PRA-005.06
PBAPS Probabilistic Risk Assessment - Core Spray System
Notebook
Revision 4
PB-PRA-005.12
Peach Bottom Atomic Power Station Probabilistic Risk
Assessment High Pressure Service Water (HPSW) System
Notebook
Revision 4
PB-PRA-005.20
PBAPS Probabilistic Risk Assessment - Containment
Systems (CONT) System Notebook
Revision 3
PB-PRA-012
PBAPS Internal Flood Evaluation Summary Notebook
Revision 5
Loss of Conowingo Pond - Bases
Revision 21
Operability
Evaluations
AO 33.6-0
ESW Pump Discharge Cross-tie Operation
Procedures
CFR 50.69 Alternate Treatment Plan Guidance For RISC-
Revision 2
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Motor Operated Valves
CFR 50.69 Interim Alternative Treatments and De-
Scoping of RISC-3 IST Program Components
Revision 1
CFR 50.69 Program
Revision 6
CFR 50.69 Active Component Risk Significance Insights
Revision 6
CFR 50.69 Passive Component Categorization
Revision 4
CFR 50.69 Risk Informed Categorization for Structure,
Systems, and Components
Revision 8
ER-AA-569-1003-
F-01
CFR 50.69 System Categorization Document
Revision 8
CFR 50.69 Alternative Treatment Implementation Process
Revision 6
Integrated Decision-Making Panel for Risk Informed SSC
Categorization Duties and Responsibilities
Revision 8
PBAPS Alarm
Response Card
A Emerg Service Water Header Lo Press, 002-00C226B, D-5 Revision 5
PBAPS Alarm
Response Card
B Emerg Service Water Header Lo Press, 004-00C226C, D-5 Revision 5
PBAPS Alarm
Response Card
B Emerg Service Water Pump Room Flooded, 004-
00C226C, A-4
Revision 9
PBAPS Alarm
Response Card
A Emerg Service Water Pump Room Flooded, 004-
00C226C, A-3
Revision 9
Issue Identification and Screening Process
Revision 13
Corrective Action Program Procedure
Revision 8
Loss of Conowingo Pond - Procedure
Revision 24
Flood - Procedure
Revision 43
SO 48.1B
Emergency Cooling Water System Startup
Revision 22
Work Orders
247179
247947
277654
R1137772
R1196156
04915412-01