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=Text=
=Text=
{{#Wiki_filter:==SUBJECT:==
{{#Wiki_filter:UNITED STATES N UCLEAR REGULATORY COMM ISSION
PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000277 1201 1 01 0 AND 05000278/201 1 010
 
==REGION I==
475 ALLENDALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19406.1415
==SUBJECT:==
PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000277 1201 1 01 0 AND 05000278/201 1 010


==Dear Mr. Pacilio:==
==Dear Mr. Pacilio:==
On August 12,2011, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Peach Bottom Atomic Power Station, Units 2 and 3 (Peach Bottom). The enclosed report documents the inspection results discussed with Mr. Thomas Dougherty, Peach Bottom Site Vice President, and other members of your staff.This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commission's rules and regulations and conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.
On August 12,2011, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Peach Bottom Atomic Power Station, Units 2 and 3 (Peach Bottom). The enclosed report documents the inspection results discussed with Mr. Thomas Dougherty, Peach Bottom Site Vice President, and other members of your staff.


Based on the samples selected for review, the inspectors concluded that Exelon was generally effective in identifying, evaluating, and resolving problems.
This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commission's rules and regulations and conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.


Exelon personnel identified problems and entered them into the corrective action program at a low threshold.
Based on the samples selected for review, the inspectors concluded that Exelon was generally effective in identifying, evaluating, and resolving problems. Exelon personnel identified problems and entered them into the corrective action program at a low threshold. Exelon personnel prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner.


Exelon personnel prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner.This report documents one NRC-identified finding of very low safety significance (Green). The inspectors determined that this finding also involved a violation of NRC requirements.
This report documents one NRC-identified finding of very low safety significance (Green). The inspectors determined that this finding also involved a violation of NRC requirements. However, because of the very low safety significance and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy. lf you contest this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, Region l; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident lnspector at Peach Bottom. In addition, if you disagree with the cross-cutting aspect assigned to any finding 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 Regional Administrator, Region l, and the NRC Resident Inspector at Peach Bottom. ln accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the 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:/imrvrv.nrc.qovireadino-rm/adams.html (the Public Electronic Reading Room).


However, because of the very low safety significance and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy. lf you contest this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, Region l; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident lnspector at Peach Bottom. In addition, if you disagree with the cross-cutting aspect assigned to any finding 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 Regional Administrator, Region l, and the NRC Resident Inspector at Peach Bottom. ln accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the 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:/imrvrv.nrc.qovireadino-rm/adams.html (the Public Electronic Reading Room).
fu-e,ru


Sincerely, Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56 Enclosure:
Sincerely, Paul G. Krohn, Chief Projects Branch 4 Division of Reactor Projects Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56 Enclosure: I nspectio n Re port 0500027 7 l 20 1 1 0 10 a nd 0500027 8l 20 1101 0 MAttachment: Supplemental Information cc w/encl: Distribution via ListServ
cc w/encl: fu-e,ru Paul G. Krohn, Chief Projects Branch 4 Division of Reactor Projects I nspectio n Re port 0500027 7 l 20 1 1 0 10 a nd 0500027 8 l 20 1 1 0 1 0 MAttachment:
Supplemental Information Distribution via ListServ


=SUMMARY OF FINDINGS=
=SUMMARY OF FINDINGS=
I nspection  
I nspection Report 0500027 7 l 20 1 1 010 a nd 05000278/ 201 1 0 1 O: OT t2,t ZO1 1 }Bt 1 2t 20 1 1 :
 
Report 0500027 7 l 20 1 1 010 a nd 05000278/
201 1 0 1 O: OT t2,t ZO1 1 - }Bt 1 2t 20 1 1 : Peach Bottom Units 2 and 3; Biennial Baseline Inspection of Problem ldentification and Resolution.
 
The inspectors identified one finding in the area of effectiveness of corrective actions.This NRC team inspection was performed by three regional inspectors and one resident inspector.


The inspectors identified one finding of very low safety significance (Green) during this inspection and classified this finding as a non-cited violation (NCV). The significance of -most findings is indicated by their color (Green, White, Yellow, Red) using NRClnspection Man_ual Chapter (lMC) 0609, "significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or assigned a severity level after NRC management review. Cross-cutting aspects associated with findings are determined using IMC 0C10,"Components Within the Cross-Cutting Areas." The NRC's program for oveiseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Re-actor Oversight Process," Revision 4, dated December 2006.Problem ldentification and Resolution The inspectors concluded that Exelon was generally etfective in identifying, evaluating, and resolving problems.
                                                                                    -
Peach Bottom Units 2 and 3; Biennial Baseline Inspection of Problem ldentification and Resolution. The inspectors identified one finding in the area of effectiveness of corrective actions.


Exelon personnel identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with their safety significance.
This NRC team inspection was performed by three regional inspectors and one resident inspector. The inspectors identified one finding of very low safety significance (Green) during this inspection and classified this finding as a non-cited violation (NCV). The significance of -
most findings is indicated by their color (Green, White, Yellow, Red) using NRClnspection Man_ual Chapter (lMC) 0609, "significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or assigned a severity level after NRC management review. Cross-cutting aspects associated with findings are determined using IMC 0C10,
"Components Within the Cross-Cutting Areas." The NRC's program for oveiseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Re-actor Oversight Process," Revision 4, dated December 2006.


ln most cases, Exelon personnel appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences.
Problem ldentification and Resolution The inspectors concluded that Exelon was generally etfective in identifying, evaluating, and resolving problems. Exelon personnel identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with their safety significance. ln most cases, Exelon personnel appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that Exelon personneltypically implemented corrective actions to address the problems identified in the corrective action program in a timely manner. However, the inspectors identified one violation of NRC requirements in the area of effectiveness of corrective actions regarding safety relief valve setpoint drift in excess of TS requirements.


The inspectors also determined that Exelon personneltypically implemented corrective actions to address the problems identified in the corrective action program in a timely manner. However, the inspectors identified one violation of NRC requirements in the area of effectiveness of corrective actions regarding safety relief valve setpoint drift in excess of TS requirements.
The inspectors concluded that, in general, Exelon personnel adequately identified, reviewed, and applied relevant industry operating experience to Peach Bottom operations. In addition, based on those items selected for review, the inspectors determined that Exelon's self-assessments and audits were thorough.


The inspectors concluded that, in general, Exelon personnel adequately identified, reviewed, and applied relevant industry operating experience to Peach Bottom operations.
Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify indicationsthat site personnel were unwilling to raise safety issues nor did they identify conditions that could have had a negative impact on the site's safety conscious work environment.


In addition, based on those items selected for review, the inspectors determined that Exelon's self-assessments and audits were thorough.Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify indicationsthat site personnel were unwilling to raise safety issues nor did they identify conditions that could have had a negative impact on the site's safety conscious work environment.
Gornerstone: Mitigating Systems
 
.
Gornerstone:
Mitigating Systems.
: '''Green.'''
: '''Green.'''
The inspectors identified a finding of very low safety significance (Green) involving a NCV of 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," because Exelon staff OiO not implement timely corrective action associated with safety relief valve (SRV)/safety valve (SV) lift setpoint drift in excess of Technical Specification (TS) 3.4.3, "Safety Relief Valves and Safety Valves" requirements.
The inspectors identified a finding of very low safety significance (Green) involving a NCV of 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," because Exelon staff OiO not implement timely corrective action associated with safety relief valve (SRV)/safety valve (SV) lift setpoint drift in excess of Technical Specification (TS) 3.4.3, "Safety Relief Valves and Safety Valves" requirements. Specifically, Exelon staff did not implement timely or adequate actions to correct SRV lift setpoint drift that, on four occasions since 2004, has exceeded TS acceptance criteria and resulted in repeat TS violations. The station entered this issue into their corrective action program (CAP) as issue report (tR) 1250472 to evaluate the corrective actions needed to address this issue including evaluation of the proposed revision to the Peach Bottom licensing basis through a TS amendment.


Specifically, Exelon staff did not implement timely or adequate actions to correct SRV lift setpoint drift that, on four occasions since 2004, has exceeded TS acceptance criteria and resulted in repeat TS violations.
The inspectors determined that the finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the capability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).


The station entered this issue into their corrective action program (CAP) as issue report (tR) 1250472 to evaluate the corrective actions needed to address this issue including evaluation of the proposed revision to the Peach Bottom licensing basis through a TS amendment.
Specifically, SRVs continue to experience reliability challenges regarding SRV/SV lift setpoint drift and the station remains vulnerable to future TS compliance issues. The inspectors evaluated the significance of this finding using IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings." The inspectors determined that this finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not represent a loss of safety system function, and did not screen as potentially risk-significant due to external initiating events. The inspectors' review did not identify a loss of SRV/SV safety function with regard to SRVs/SVs being able to lift within the necessary pressure range to maintain margin to design pressure and stress limits.


The inspectors determined that the finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the capability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).Specifically, SRVs continue to experience reliability challenges regarding SRV/SV lift setpoint drift and the station remains vulnerable to future TS compliance issues. The inspectors evaluated the significance of this finding using IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings." The inspectors determined that this finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not represent a loss of safety system function, and did not screen as potentially risk-significant due to external initiating events. The inspectors'
The finding has a cross-cutting aspect in the area of problem identification and resolution, corrective action program, because Exelon personnel did not implement timely corrective actions to address a longstanding SRV tolerance setpoint condition that has resulted in multiple TS compliance violations. [P. 1 . (d)] [Section 4OAZ. 1 .c.(1 )]
review did not identify a loss of SRV/SV safety function with regard to SRVs/SVs being able to lift within the necessary pressure range to maintain margin to design pressure and stress limits.The finding has a cross-cutting aspect in the area of problem identification and resolution, corrective action program, because Exelon personnel did not implement timely corrective actions to address a longstanding SRV tolerance setpoint condition that has resulted in multiple TS compliance violations.
 
[P. 1 . (d)] [Section 4OAZ. 1 .c.(1 )]Enclosure
.1 4


=REPORT DETAILS=
=REPORT DETAILS=
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==OTHER ACTIVITIES (OA)==
==OTHER ACTIVITIES (OA)==
{{a|4OA2}}
{{a|4OA2}}
==4OA2 Problem ldentification==
==4OA2 Problem ldentification and Resolution (711528)==


and Resolution (711528)This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure71152.
resolution This inspection constitutes one biennial sample of problem identification and this as defined by Inspection Procedure71152. All documents reviewed during inspection are listed in the Attachment  to  this report'


All documents reviewed during this inspection are listed in the Attachment to this report'a. Inspection ScoPe The inspectors reviewed the procedures that described Exelon's corrective action program at peach Bottom. To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: problem identification' prioritization and evaluation of issues, and corrective action implementation.
===.1 a.===


The inspectors compared performance in these areas to the requirements and standards contained in 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," and Exelon procedure, l-S-nn-t 25,;'Corrective Action Program Procedure." For each of these areas, the inspectors considered risk insights flom the station's risk analysis and reviewed issue reforts selected across the seven cornerstones of safety in the NRCs Reactor Ouerrighii.""r..
Inspection ScoPe action The inspectors reviewed the procedures that described Exelon's corrective peach                                            of the corrective    action  program, program at            Bottom. To assess the effectiveness primary  areas:   problem  identification' the inspectors reviewed performance in three The prioritization and evaluation of issues, and corrective action implementation.
Additionally, the inspectors attended multiple Plan-ofthe-Day, Station Orinership Committee, and Management Review Committee meetings'The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection' chemistry, physical security, and oversight programs'(1) Effectiveness of Problem ldentification ln addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports. The inspectors also completed field walkdowns of various systems on site, such as the emergency diesel generators and high pressure service water structures.


Additionally, the inspectors revidweO a sample of lRs written to document issues identified through internal self-assessments, audits, and the operating experience program. The inspectors completed this review to verify that Exelon personnel entered conditions adverse to quaiity into their conective action program as appropriate'
standards inspectors compared performance in these areas to the requirements and Exelon contained in 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," and procedure, l-S-nn-t 25,;'Corrective Action Program Procedure." For each of these and areas, the inspectors considered risk insights flom the station's risk analysis of  safety  in  the  NRCs reviewed issue reforts selected across the seven cornerstones Reactor Ouerrighii.""r.. Additionally, the inspectors attended            multiple  Plan-ofthe-meetings' Day, Station Orinership Committee, and Management Review Committee The inspectors selected items from the following functional areas for review:
: (2) Effectiveness of Prioritization and Evaluation of lssues The inspectors reviewed the evaluation and prioritization.of a sample of lRs issued since the last'NRC biennial Problem ldentification and Resolution inspection completed in August 2009. The inspectors also reviewed lRs that were assigned lower levels of rig;ifi""n.e that did not include formal cause evaluations to ensure that they were pr"operfy classified.
protection' engineering, operations, maintenance, emergency preparedness, radiation chemistry, physical security, and oversight programs'
: (1) Effectiveness of Problem ldentification ln addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports. The inspectors systems    on site,  such  as the emergency also completed field walkdowns of various structures.


The inspectors'-review included the appropriateness of the assigned signiticince, the scope and depth of the causal analysis, and the timeliness of resolution.
Additionally,    the diesel generators and high pressure service water issues  identified  through inspectors revidweO a sample of lRs written to document program. The internal self-assessments, audits, and the operating experience conditions inspectors completed this review to verify that Exelon personnel entered adverse to quaiity into their conective action program as appropriate'
: (2) Effectiveness of Prioritization and Evaluation of lssues of lRs issued since The inspectors reviewed the evaluation and prioritization.of a sample completed in the last'NRC biennial Problem ldentification and Resolution inspection lower levels of August 2009. The inspectors also reviewed lRs that were assigned were rig;ifi""n.e that did not include formal cause evaluations to ensure that they      of  the assigned pr"operfy classified. The inspectors'-review   included   the appropriateness and  the  timeliness    of signiticince, the scope and depth of the causal analysis, likely causes for resolution. The inspectors assessed whether the evaluations identified identified the issues and developed appropriate corrective actions to address the causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.
: (3) Effectiveness of Corrective Actions The inspectors reviewed Exelon's completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed lRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Exelon's timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of lRs associated with selected NCVs and findings to verify that Exelon personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate Exelon personnel's actions related to safety relief valves, the high pressure service water intake structure, and material and test control equipment aspects.


The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified 5 causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.(3) Effectiveness of Corrective Actions The inspectors reviewed Exelon's completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems.
b.


The inspectors also reviewed lRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Exelon's timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of lRs associated with selected NCVs and findings to verify that Exelon personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate Exelon personnel's actions related to safety relief valves, the high pressure service water intake structure, and material and test control equipment aspects.b. Assessment
Assessment
: (1) Effectiveness of Problem ldentification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Exelon personnel identified problems and entered them into the corrective action program at a low threshold.
: (1) Effectiveness of Problem ldentification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Exelon personnel identified problems and entered them into the corrective action program at a low threshold.


Exelon staff at Peach Bottom initiated approximately 30,000 lRs between August 2009 and July 2011. The inspectors observed supervisors at the Plan-of-the-Day, Station Ownership Committee, and Management Review Committee meetings appropriately questioning and challenging lRs to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that Exelon staff trended equipment and programmatic issues, and appropriately identified problems in lRs. The inspectors verified that conditions adverse to quality identified through this review were entered into the corrective action program as appropriate.
Exelon staff at Peach Bottom initiated approximately 30,000 lRs between August 2009 and July 2011. The inspectors observed supervisors at the Plan-of-the-Day, Station Ownership Committee, and Management Review Committee meetings appropriately questioning and challenging lRs to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that Exelon staff trended equipment and programmatic issues, and appropriately identified problems in lRs. The inspectors verified that conditions adverse to quality identified through this review were entered into the corrective action program as appropriate. Additionally, inspectors concluded that personnelwere identifying trends at low levels. In general, inspectors did not identify issues or concerns that had not been appropriately entered into the corrective action program for evaluation and resolution.
: (2) Effectiveness of Prioritization and Evaluation of lssues The inspectors determined that, in general, Exelon personnel appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. Exelon personnel screened lRs for operability and reportability, categorized the lRs by significance, and assigned actions to the appropriate department for evaluation and resolution. The lR screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.


Additionally, inspectors concluded that personnelwere identifying trends at low levels. In general, inspectors did not identify issues or concerns that had not been appropriately entered into the corrective action program for evaluation and resolution.
Based on the sample of lRs reviewed, the inspectors noted that the guidance provided by Exelon's corrective action program implementing procedures appeared sufficient to ensure consistency in categorization of issues. Operability and reportability determinations were generally performed when conditions warranted and in most cases, the evaluations supported the conclusion. Causal analyses appropriately considered the extent-of-condition or problem, generic issues, and previous occurrences of the issue.
: (2) Effectiveness of Prioritization and Evaluation of lssues The inspectors determined that, in general, Exelon personnel appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. Exelon personnel screened lRs for operability and reportability, categorized the lRs by significance, and assigned actions to the appropriate department for evaluation and resolution.


The lR screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.
However, the inspectors did note one observation in Exelon's staff evaluation of the following issue:
Exelon staff's maintenance rule evaluation of lR 1120516 (SRV setpoint drift) missed an opportunity to identify that the maintenance rule pedormance reliability criteria for SRV/SVs (System 01A) was not consistent with Exelon procedure ER-AA-310-1003, "Maintenance Rule - Performance Criteria Selection." Specifically, the reliability criteria threshold was not sensitive to SRV/SV lift setpoint testing/surveillance frequencies and, therefore, the criteria established (> 3 maintenance preventable functionalfailures per 24 months) was not an effective monitoring toolwith regard to SRV/SV reliability.


Based on the sample of lRs reviewed, the inspectors noted that the guidance provided by Exelon's corrective action program implementing procedures appeared sufficient to Enclosure 6 ensure consistency in categorization of issues. Operability and reportability determinations were generally performed when conditions warranted and in most cases, the evaluations supported the conclusion.
Notwithstanding, the inspectors determined that, overall, Exelon's system classification and maintenance rule performance monitoring of the SRV/SVs remained consistent with their maintenance rule procedures in that the SRV/SV system classification as maintenance rule (aX2) remained valid. Therefore, the inspectors determined that the issue was of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy. Exelon statf documented this issue in lR 1249391.
: (3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, Exelon staff identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC NCVs and findings since the last problem identification and resolution inspection were timely and effective. The inspectors identified one violation regarding Exelon's resolution of a longstanding condition adverse to quality regarding SRV lift setpoints exceeding TS acceptance criteria which is documented below.


Causal analyses appropriately considered the extent-of-condition or problem, generic issues, and previous occurrences of the issue.However, the inspectors did note one observation in Exelon's staff evaluation of the following issue: Exelon staff's maintenance rule evaluation of lR 1120516 (SRV setpoint drift) missed an opportunity to identify that the maintenance rule pedormance reliability criteria for SRV/SVs (System 01A) was not consistent with Exelon procedure ER-AA-310-1003,"Maintenance Rule - Performance Criteria Selection." Specifically, the reliability criteria threshold was not sensitive to SRV/SV lift setpoint testing/surveillance frequencies and, therefore, the criteria established
c.
(> 3 maintenance preventable functionalfailures per 24 months) was not an effective monitoring toolwith regard to SRV/SV reliability.


Notwithstanding, the inspectors determined that, overall, Exelon's system classification and maintenance rule performance monitoring of the SRV/SVs remained consistent with their maintenance rule procedures in that the SRV/SV system classification as maintenance rule (aX2) remained valid. Therefore, the inspectors determined that the issue was of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy. Exelon statf documented this issue in lR 1249391.(3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented.
Findinqs
 
For significant conditions adverse to quality, Exelon staff identified actions to prevent recurrence.
 
The inspectors concluded that corrective actions to address the sample of NRC NCVs and findings since the last problem identification and resolution inspection were timely and effective.
 
The inspectors identified one violation regarding Exelon's resolution of a longstanding condition adverse to quality regarding SRV lift setpoints exceeding TS acceptance criteria which is documented below.c. Findinqs


=====Introduction:=====
=====Introduction:=====
The inspectors identified a finding of very low safety significance (Green)involving a NCV of 10 CFR 50 Appendix B, Criterion XVl, "Corrective Action," because Exelon staff did not implement corrective actions in a timely manner to correct safety relief valve (SRV)/safety valve (SV) lift setpoint drift in excess of Technical Specification 3.4.3, "Safety Relief Valves and Safety Valves" requirements.
The inspectors identified a finding of very low safety significance (Green)involving a NCV of 10 CFR 50 Appendix B, Criterion XVl, "Corrective Action," because Exelon staff did not implement corrective actions in a timely manner to correct safety relief valve (SRV)/safety valve (SV) lift setpoint drift in excess of Technical Specification 3.4.3, "Safety Relief Valves and Safety Valves" requirements. Specifically, Exelon staff did not implement timely or adequate actions to correct SRV lift setpoint drift that, on four occasions since 2004 and as recently as 2010, has exceeded TS surveillance acceptance criteria and resulted in TS non-compliances.
 
Specifically, Exelon staff did not implement timely or adequate actions to correct SRV lift setpoint drift that, on four occasions since 2004 and as recently as 2010, has exceeded TS surveillance acceptance criteria and resulted in TS non-compliances.


=====Description:=====
=====Description:=====
Eleven SRVs and two SVs are installed in the main steam system to provide reactor pressure vessel overpressure protection and provide for automatic/manual depressurization functions.
Eleven SRVs and two SVs are installed in the main steam system to provide reactor pressure vessel overpressure protection and provide for automatic/manual depressurization functions. TS 3.4.3, "Safety Relief Valves and Safety Valves," requires that 1 1 of the 13 SRV/SVs be operable to ensure the safety function. TS surveillance requirement (SR) 3.4.3.1 requires verification that the safety function lift setpoints of the required SRV/SVs are within +l- 1o/o of the nominal setpoint.
 
TS 3.4.3, "Safety Relief Valves and Safety Valves," requires that 1 1 of the 13 SRV/SVs be operable to ensure the safety function.
 
TS surveillance requirement (SR) 3.4.3.1 requires verification that the safety function lift setpoints of the required SRV/SVs are within +l- 1o/o of the nominal setpoint.This surveillance testing is conducted during refueling outages when the SRV/SVs are accessible during reactor shutdown conditions.
 
7 Since 2003, six of the last eight outages at Peach Bottom have had as-found SRV/SV lift test failures outside the TS SR 3.4.3.1 acceptance criteria of +l-1o/o. On four of those occasions there were greater than two SRV/SV setpoint failures which resulted in non-compliance with TS 3.4.3. Each time Exelon staff initiated lRs to document the as-found conditions in the corrective action program. In general, since 2003 Exelon staff has determined that the SRV/SV setpoint drift experienced at Peach Bottom is due to overly restrictive TS setpoint criteria (10lo vs. typical industry standard of 3o/otolerance)and have not identified the condition to be a result of equipment reliability or maintenance-related aspects. Exelon statf has.consistently determined that a TS amendment to increase the setpoint tolerance to 3%, consistent with other Exelon sites, was the appropriate corrective action to address the TS noncompliance condition that existed at both units. Exelon staff, except for the action to evaluate and submit a TS revision.
 
have not recommended interim or long-term corrective actions to address the SRV/SV setpoint drift TS compliance issue.The inspectors' corrective action review noted that as early as 2003 Exelon staff had discussed the option of submitting a TS revision to increase the SRV/SV setpoint tolerance.


ln2007 (lR 559430), Exelon authorized a vendor to conduct a SRV/SV tolerance study to evaluate the feasibility and potential impacts of an increase in SRV/SV setpoint tolerance to 3o/o. Based on the results of that study, in early 2009, Exelon authorized a more comprehensive evaluation by a vendor whicn was completed in March 2010 and indicated a 3% tolerance would likely be acceptable with some additional site specific areas of evaluation.
This surveillance testing is conducted during refueling outages when the SRV/SVs are accessible during reactor shutdown conditions.


However, in May 2010, Exelon deferred the TS revision since an extended power up-rate project was being considered and the impacts of that power up-rate on the SRV/SV setpoint tolerance, at that time, was not fully known. Subsequently, Exelon staff identified during its most recent outage on Unit 2 in 2010 that two SRVs and one SVs failed to meet TS allowable tolerance and therefore were in violation of TS 3.4.3 as documented and submitted by Exelon in LER 4500027712010003.
Since 2003, six of the last eight outages at Peach Bottom have had as-found SRV/SV lift test failures outside the TS SR 3.4.3.1 acceptance criteria of +l-1o/o. On four of those occasions there were greater than two SRV/SV setpoint failures which resulted in non-compliance with TS 3.4.3. Each time Exelon staff initiated lRs to document the as-found conditions in the corrective action program. In general, since 2003 Exelon staff has determined that the SRV/SV setpoint drift experienced at Peach Bottom is due to overly restrictive TS setpoint criteria (10lo vs. typical industry standard of 3o/otolerance) and have not identified the condition to be a result of equipment reliability or maintenance-related aspects. Exelon statf has.consistently determined that a TS amendment to increase the setpoint tolerance to 3%, consistent with other Exelon sites, was the appropriate corrective action to address the TS noncompliance condition that existed at both units. Exelon staff, except for the action to evaluate and submit a TS revision. have not recommended interim or long-term corrective actions to address the SRV/SV setpoint drift TS compliance issue.


Exelon staff's evaluation (lR 121662811120516)determined that the non-compliance issue was the result of less than aggressive implementation of a TS revision for the SRV/SV setpoint tolerance.
The inspectors' corrective action review noted that as early as 2003 Exelon staff had discussed the option of submitting a TS revision to increase the SRV/SV setpoint tolerance. ln2007 (lR 559430), Exelon authorized a vendor to conduct a SRV/SV tolerance study to evaluate the feasibility and potential impacts of an increase in SRV/SV setpoint tolerance to 3o/o. Based on the results of that study, in early 2009, Exelon authorized a more comprehensive evaluation by a vendor whicn was completed in March 2010 and indicated a 3% tolerance would likely be acceptable with some additional site specific areas of evaluation. However, in May 2010, Exelon deferred the TS revision since an extended power up-rate project was being considered and the impacts of that power up-rate on the SRV/SV setpoint tolerance, at that time, was not fully known. Subsequently, Exelon staff identified during its most recent outage on Unit 2 in 2010 that two SRVs and one SVs failed to meet TS allowable tolerance and therefore were in violation of TS 3.4.3 as documented and submitted by Exelon in LER 4500027712010003. Exelon staff's evaluation (lR 121662811120516) determined that the non-compliance issue was the result of less than aggressive implementation of a TS revision for the SRV/SV setpoint tolerance.


The inspectors' review determined that Exelon staff has not implemented timely corrective actions consistent with expectations outlined in LS-AA-125, "Corrective Action Program Procedure," in that actions have not been timely or effective to correct a long-standing condition adverse to quality (sRV lift setpoint rs non-compliances).
The inspectors' review determined that Exelon staff has not implemented timely corrective actions consistent with expectations outlined in LS-AA-125, "Corrective Action Program Procedure," in that actions have not been timely or effective to correct a long-standing condition adverse to quality (sRV lift setpoint rs non-compliances).


Specifically, the inspectors determined that the action identified by the station to correct the SRV/SV setpoint drift and associated TS non-compliance aspects has not been implemented.
Specifically, the inspectors determined that the action identified by the station to correct the SRV/SV setpoint drift and associated TS non-compliance aspects has not been implemented. Exelon has deferred or delayed implementation of the TS revision on severaloccasions. Additionally, the inspectors determined that Exelon has had several opportunities to revisit the timeliness aspects of the long term TS revision action and has not identified interim or compensatory corrective actions to mitigate future TS non-compliances with regard to SRV/SV lift setpoints. The inspectors noted that Exelon staff has implemented several SRV/SV reliability actions over the last five years to improve overall SRV reliability; however, based on interviews with engineering staff and review of corrective action documents, those actions are not expected to directly mitigate or address the TS non-compliance vulnerability that still exists regarding the SRV/SV lift setpoint.
 
Exelon has deferred or delayed implementation of the TS revision on severaloccasions.
 
Additionally, the inspectors determined that Exelon has had several opportunities to revisit the timeliness aspects of the long term TS revision action and has not identified interim or compensatory corrective actions to mitigate future TS non-compliances with regard to SRV/SV lift setpoints.
 
The inspectors noted that Exelon staff has implemented several SRV/SV reliability actions over the last five years to improve overall SRV reliability; however, based on interviews with engineering staff and review of corrective action documents, those actions are not expected to directly mitigate or address the TS non-compliance vulnerability that still exists regarding the SRV/SV lift setpoint.As documented in lR 112051611216628, Exelon staff has actions scheduled in2012to conduct site specific evaluations required for the TS revision.


However, the inspectors
As documented in lR 112051611216628, Exelon staff has actions scheduled in2012to conduct site specific evaluations required for the TS revision. However, the inspectors also noted that the actual date of the TS revision submittal, based on interviews with Exelon staff, is not affirmed and may continue to be delayed due to continuing conflicts with power up-rate considerations. The inspectors determined that corrective actions resultant from lR 112051611216628 have not resulted in corrective actions to mitigate or address the potential for continued TS setpoint non-compliances going forward. Exelon staff initiated lR 1250472tor disposition of this issue in the station's CAP.


===.2 8 also noted that the actual date of the TS revision submittal, based on interviews===
Analvsis: The inspectors determined that the finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the capability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, SRVs/SVs continue to experience reliability challenges associated with SRV/SV lift setpoint margin and remain vulnerable to future TS non-compliances. The inspectors evaluated the significance of this finding using IMC 0609.04, "Phase 1 - lnitial Screening and Characterization of Findings." The inspectors determined that this finding was of very low safety significance (Green)because the finding was not a design or qualification deficiency, did not represent a loss of safety system function, and did not screen as potentially risk-significant due to external initiating events. The inspectors determined there had not been a loss of SRV/SV safety function with regard to SRVs/SVs being able to lift within the necessary pressure range to maintain sufficient margin to design pressure and stress limits.


with Exelon staff, is not affirmed and may continue to be delayed due to continuing conflicts with power up-rate considerations.
The finding has a cross-cutting aspect in the area of problem identification and resolution, corrective action program, because Exelon personnel did not implement timely corrective actions to address the longstanding SRV setpoint drift conditions that have resulted in multiple TS compliance violations. IP.1.(d)I
 
The inspectors determined that corrective actions resultant from lR 112051611216628 have not resulted in corrective actions to mitigate or address the potential for continued TS setpoint non-compliances going forward. Exelon staff initiated lR 1250472tor disposition of this issue in the station's CAP.Analvsis:
The inspectors determined that the finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the capability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, SRVs/SVs continue to experience reliability challenges associated with SRV/SV lift setpoint margin and remain vulnerable to future TS non-compliances.
 
The inspectors evaluated the significance of this finding using IMC 0609.04, "Phase 1 - lnitial Screening and Characterization of Findings." The inspectors determined that this finding was of very low safety significance (Green)because the finding was not a design or qualification deficiency, did not represent a loss of safety system function, and did not screen as potentially risk-significant due to external initiating events. The inspectors determined there had not been a loss of SRV/SV safety function with regard to SRVs/SVs being able to lift within the necessary pressure range to maintain sufficient margin to design pressure and stress limits.The finding has a cross-cutting aspect in the area of problem identification and resolution, corrective action program, because Exelon personnel did not implement timely corrective actions to address the longstanding SRV setpoint drift conditions that have resulted in multiple TS compliance violations.
 
IP.1.(d)I


=====Enforcement:=====
=====Enforcement:=====
10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected.
10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. Contrary to the above, Exelon staff failed to promptly implement actions and correct a condition adverse to quality associated with SRVs/SVs, on both Units 2 and 3, exceeding TS lift setpoint acceptance criteria. As a result, there have been several occasions since 2003 where TS violations have occurred with the most recent occurring on Unit 3 in 2010.


Contrary to the above, Exelon staff failed to promptly implement actions and correct a condition adverse to quality associated with SRVs/SVs, on both Units 2 and 3, exceeding TS lift setpoint acceptance criteria.
Since this finding was determined to be of very low safety significance (Green) and has been entered into Exelon's corrective action program (lR 1250472) it is being treated as an NCV, consistent with the Enforcement Policy. (NCV 050002771278 - 20110{0-01, Inadequate Corrective Actions Associated With SRV Lift Setpoint Drift)


As a result, there have been several occasions since 2003 where TS violations have occurred with the most recent occurring on Unit 3 in 2010.Since this finding was determined to be of very low safety significance (Green) and has been entered into Exelon's corrective action program (lR 1250472) it is being treated as an NCV, consistent with the Enforcement Policy. (NCV 050002771278 - 20110{0-01, Inadequate Corrective Actions Associated With SRV Lift Setpoint Drift)Assessment of the Use of Operatinq Experience Inspection Scope The inspectors reviewed a sample of issue reports associated with review of industry operating experience to determine whether Exelon personnel appropriately evaluated the operating experience information for applicability to Peach Bottom and had taken appropriate actions, when warranted.
===.2 Assessment of the Use of Operatinq Experience===


The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Exelon personnel adequately considered the underlying problems associated with the issues for resolution via their corrective action program. In a.Enclosure b.I addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.
====a. Inspection Scope====
The inspectors reviewed a sample of issue reports associated with review of industry operating experience to determine whether Exelon personnel appropriately evaluated the operating experience information for applicability to Peach Bottom and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Exelon personnel adequately considered the underlying problems associated with the issues for resolution via their corrective action program. In I
addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.


Assessment The inspectors determined that Exelon personnel appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate.
b. Assessment The inspectors determined that Exelon personnel appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also observed that industry operating experience was routinely discussed and considered during the conduct of station meetings.


The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable.
Findinos No findings were identified.


The inspectors also observed that industry operating experience was routinely discussed and considered during the conduct of station meetings.Findinos No findings were identified.
===.3 Assessment of Self-Assessments and Audits===


Assessment of Self-Assessments and Audits Inspection Scope The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, departmental self-assessments, and assessments performed by independent organizations.
====a. Inspection Scope====
The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, departmental self-assessments, and assessments performed by independent organizations. Inspectors performed these reviews to determine if Exelon entered problems identified through these assessments into the corrective action program, when appropriate, and whether Exelon staff initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.


Inspectors performed these reviews to determine if Exelon entered problems identified through these assessments into the corrective action program, when appropriate, and whether Exelon staff initiated corrective actions to address identified deficiencies.
b. Assessment The inspectors concluded that self-assessments, audits, and other internal Exelon assessments were generally critical, thorough, and effective in identifying issues. The inspectors observed that Exelon personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. Exelon personnel completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. In general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance.
 
The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.
 
Assessment The inspectors concluded that self-assessments, audits, and other internal Exelon assessments were generally critical, thorough, and effective in identifying issues. The inspectors observed that Exelon personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. Exelon personnel completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation.
 
In general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance.


Findinss No findings were identified.
Findinss No findings were identified.


===.3 a.b.Enclosure===
===.4 Assessment of Safetv Conscious Work Envilonment===
 
===.4 10 Assessment===
 
of Safetv Conscious Work Envilonment Inspection Scope During interviews with station personnel, the inspectors assessed the safety conscious work environment at Peach Bottom. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees are aware of the program and its availability with regards to raising safety concerns.


The inspectors reviewed the Employee Concerns Program files to ensure that Exelon staff and management entered issues into the corrective action program when appropriate.
====a. Inspection Scope====
During interviews with station personnel, the inspectors assessed the safety conscious work environment at Peach Bottom. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees are aware of the program and its availability with regards to raising safety concerns. The inspectors reviewed the Employee Concerns Program files to ensure that Exelon staff and management entered issues into the corrective action program when appropriate.


Assessment During interviews, Exelon staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the corrective action program and the Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.
b. Assessment During interviews, Exelon staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the corrective action program and the Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.


Findinqs No findings were identified.
Findinqs No findings were identified.


Meetinos.
40A6 Meetinos. lncludino Exit On August 12,2011, the inspectors presented the inspection results to T. Dougherty, Site Vice President, and other members of the Exelon staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.


lncludino Exit On August 12,2011, the inspectors presented the inspection results to T. Dougherty, Site Vice President, and other members of the Exelon staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.ATTACHMENT:  
ATTACHMENT:  


=SUPPLEMENTARY
=SUPPLEMENTARY INFORMATION=
INFORMATION=


==KEY POINTS OF CONTACT==
==KEY POINTS OF CONTACT==


===Licensee Personnel===
===Licensee Personnel===
T. Dougherty
T. Dougherty               Site Vice President
Site Vice President G. Stathes Plant Manager P. Navin Operations
G. Stathes                 Plant Manager
Director J. Armstrong
P. Navin                   Operations Director
Regulatory
J. Armstrong               Regulatory Assurance Manager
Assurance
P. Cowan                   Work Management Director
Manager P. Cowan Work Management
: [[contact::R. Reiner                   Chemistry]], Environmental and Radwaste Manager
Director  
D. McClellan               Corrective Action Program Manager
: [[contact::R. Reiner Chemistry]], Environmental
S. Sullivan                 Operations Support Manager
and Radwaste Manager D. McClellan
J. James                   Maintenance Support Manager
Corrective
H. McCrory                 Technical Support Manager
Action Program Manager S. Sullivan Operations
B.Shortes                   Radiological Engineering Manager
Support Manager J. James Maintenance
B. Hedrick                 Shift Operations Superintendent
Support Manager H. McCrory Technical
D. Henry                   Engineering Programs Manager
Support Manager B.Shortes
R. Brower                   Electrical Design Manager
Radiological
J. Chizever                 Mechanical Design Manager
Engineering
R. Smith                   Regulatory Assurance
Manager B. Hedrick Shift Operations
J. Dunlap                   Decontamination Advanced Radiation Worker Supervisor
Superintendent
T. Purcell                 Electrical Design Engineering
D. Henry Engineering
H. Coleman                 Mechanical Design Engineering
Programs Manager R. Brower Electrical
D. Lord                     Mechanical Design Engineering
Design Manager J. Chizever Mechanical
P. Kester                   Mechanical Design Engineering
Design Manager R. Smith Regulatory
K. Hudson                   Mechanical Design Engineering
Assurance J. Dunlap Decontamination
J. Donell                   Programs Engineering
Advanced Radiation
J. Searer                   Programs Engineering
Worker Supervisor
G. Cilliffo                 Programs Engineering
T. Purcell Electrical
C. Burryman                 Prolect Engineering
Design Engineering
S. Allen                   Plant Chemistry
H. Coleman Mechanical
C. Vest                     Measurement and Test Equipment Tool Room Attendant
Design Engineering
J. Lowe                     Work Management Predefine Coordinator
D. Lord Mechanical
D. Wheeler                 Maintenance Rule Program Coordinator
Design Engineering
P. Kester Mechanical
Design Engineering
K. Hudson Mechanical
Design Engineering
J. Donell Programs Engineering
J. Searer Programs Engineering
G. Cilliffo Programs Engineering
C. Burryman Prolect Engineering
S. Allen Plant Chemistry C. Vest Measurement
and Test Equipment
Tool Room Attendant J. Lowe Work Management
Predefine
Coordinator
D. Wheeler Maintenance
Rule Program Coordinator


==LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED==
==LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED==
Opened and Closed 0500027 7 l 27 I l 20 1 1 0 1 0-0 1 Inadequate
Corrective
Actions Associated
With SRV Lift Setpoint Drift (Section 4C.42.1.c)
NCV Attachment


==LIST OF DOCUMENTS==
===Opened and Closed===
 
0500027 7l 27 I l 20 1 1 0 1 0-0 1      NCV          Inadequate Corrective Actions Associated With SRV Lift Setpoint Drift (Section 4C.42.1.c)
 
==LIST OF DOCUMENTS REVIEWED==


}}
}}

Latest revision as of 15:36, 12 November 2019

IR 05000277/2011010 and 05000278/2011010, on 07/25/11 - 08/12/11, Peach Bottom, Units 2 and 3, Biennial Baseline Inspection of Problem Identification and Resolution
ML112590432
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 09/16/2011
From: Paul Krohn
Reactor Projects Region 1 Branch 4
To: Pacilio M
Exelon Generation Co
Krohn P
References
IR-11-010
Download: ML112590432 (20)


Text

UNITED STATES N UCLEAR REGULATORY COMM ISSION

REGION I

475 ALLENDALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19406.1415

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000277 1201 1 01 0 AND 05000278/201 1 010

Dear Mr. Pacilio:

On August 12,2011, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Peach Bottom Atomic Power Station, Units 2 and 3 (Peach Bottom). The enclosed report documents the inspection results discussed with Mr. Thomas Dougherty, Peach Bottom Site Vice President, and other members of your staff.

This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commission's rules and regulations and conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

Based on the samples selected for review, the inspectors concluded that Exelon was generally effective in identifying, evaluating, and resolving problems. Exelon personnel identified problems and entered them into the corrective action program at a low threshold. Exelon personnel prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner.

This report documents one NRC-identified finding of very low safety significance (Green). The inspectors determined that this finding also involved a violation of NRC requirements. However, because of the very low safety significance and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy. lf you contest this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, Region l; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident lnspector at Peach Bottom. In addition, if you disagree with the cross-cutting aspect assigned to any finding 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 Regional Administrator, Region l, and the NRC Resident Inspector at Peach Bottom. ln accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the 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:/imrvrv.nrc.qovireadino-rm/adams.html (the Public Electronic Reading Room).

fu-e,ru

Sincerely, Paul G. Krohn, Chief Projects Branch 4 Division of Reactor Projects Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56 Enclosure: I nspectio n Re port 0500027 7 l 20 1 1 0 10 a nd 0500027 8l 20 1101 0 MAttachment: Supplemental Information cc w/encl: Distribution via ListServ

SUMMARY OF FINDINGS

I nspection Report 0500027 7 l 20 1 1 010 a nd 05000278/ 201 1 0 1 O: OT t2,t ZO1 1 }Bt 1 2t 20 1 1 :

-

Peach Bottom Units 2 and 3; Biennial Baseline Inspection of Problem ldentification and Resolution. The inspectors identified one finding in the area of effectiveness of corrective actions.

This NRC team inspection was performed by three regional inspectors and one resident inspector. The inspectors identified one finding of very low safety significance (Green) during this inspection and classified this finding as a non-cited violation (NCV). The significance of -

most findings is indicated by their color (Green, White, Yellow, Red) using NRClnspection Man_ual Chapter (lMC) 0609, "significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or assigned a severity level after NRC management review. Cross-cutting aspects associated with findings are determined using IMC 0C10,

"Components Within the Cross-Cutting Areas." The NRC's program for oveiseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Re-actor Oversight Process," Revision 4, dated December 2006.

Problem ldentification and Resolution The inspectors concluded that Exelon was generally etfective in identifying, evaluating, and resolving problems. Exelon personnel identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with their safety significance. ln most cases, Exelon personnel appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that Exelon personneltypically implemented corrective actions to address the problems identified in the corrective action program in a timely manner. However, the inspectors identified one violation of NRC requirements in the area of effectiveness of corrective actions regarding safety relief valve setpoint drift in excess of TS requirements.

The inspectors concluded that, in general, Exelon personnel adequately identified, reviewed, and applied relevant industry operating experience to Peach Bottom operations. In addition, based on those items selected for review, the inspectors determined that Exelon's self-assessments and audits were thorough.

Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify indicationsthat site personnel were unwilling to raise safety issues nor did they identify conditions that could have had a negative impact on the site's safety conscious work environment.

Gornerstone: Mitigating Systems

.

Green.

The inspectors identified a finding of very low safety significance (Green) involving a NCV of 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," because Exelon staff OiO not implement timely corrective action associated with safety relief valve (SRV)/safety valve (SV) lift setpoint drift in excess of Technical Specification (TS) 3.4.3, "Safety Relief Valves and Safety Valves" requirements. Specifically, Exelon staff did not implement timely or adequate actions to correct SRV lift setpoint drift that, on four occasions since 2004, has exceeded TS acceptance criteria and resulted in repeat TS violations. The station entered this issue into their corrective action program (CAP) as issue report (tR) 1250472 to evaluate the corrective actions needed to address this issue including evaluation of the proposed revision to the Peach Bottom licensing basis through a TS amendment.

The inspectors determined that the finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the capability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).

Specifically, SRVs continue to experience reliability challenges regarding SRV/SV lift setpoint drift and the station remains vulnerable to future TS compliance issues. The inspectors evaluated the significance of this finding using IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings." The inspectors determined that this finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not represent a loss of safety system function, and did not screen as potentially risk-significant due to external initiating events. The inspectors' review did not identify a loss of SRV/SV safety function with regard to SRVs/SVs being able to lift within the necessary pressure range to maintain margin to design pressure and stress limits.

The finding has a cross-cutting aspect in the area of problem identification and resolution, corrective action program, because Exelon personnel did not implement timely corrective actions to address a longstanding SRV tolerance setpoint condition that has resulted in multiple TS compliance violations. [P. 1 . (d)] [Section 4OAZ. 1 .c.(1 )]

REPORT DETAILS

OTHER ACTIVITIES (OA)

4OA2 Problem ldentification and Resolution (711528)

resolution This inspection constitutes one biennial sample of problem identification and this as defined by Inspection Procedure71152. All documents reviewed during inspection are listed in the Attachment to this report'

.1 a.

Inspection ScoPe action The inspectors reviewed the procedures that described Exelon's corrective peach of the corrective action program, program at Bottom. To assess the effectiveness primary areas: problem identification' the inspectors reviewed performance in three The prioritization and evaluation of issues, and corrective action implementation.

standards inspectors compared performance in these areas to the requirements and Exelon contained in 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," and procedure, l-S-nn-t 25,;'Corrective Action Program Procedure." For each of these and areas, the inspectors considered risk insights flom the station's risk analysis of safety in the NRCs reviewed issue reforts selected across the seven cornerstones Reactor Ouerrighii.""r.. Additionally, the inspectors attended multiple Plan-ofthe-meetings' Day, Station Orinership Committee, and Management Review Committee The inspectors selected items from the following functional areas for review:

protection' engineering, operations, maintenance, emergency preparedness, radiation chemistry, physical security, and oversight programs'

(1) Effectiveness of Problem ldentification ln addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports. The inspectors systems on site, such as the emergency also completed field walkdowns of various structures.

Additionally, the diesel generators and high pressure service water issues identified through inspectors revidweO a sample of lRs written to document program. The internal self-assessments, audits, and the operating experience conditions inspectors completed this review to verify that Exelon personnel entered adverse to quaiity into their conective action program as appropriate'

(2) Effectiveness of Prioritization and Evaluation of lssues of lRs issued since The inspectors reviewed the evaluation and prioritization.of a sample completed in the last'NRC biennial Problem ldentification and Resolution inspection lower levels of August 2009. The inspectors also reviewed lRs that were assigned were rig;ifi""n.e that did not include formal cause evaluations to ensure that they of the assigned pr"operfy classified. The inspectors'-review included the appropriateness and the timeliness of signiticince, the scope and depth of the causal analysis, likely causes for resolution. The inspectors assessed whether the evaluations identified identified the issues and developed appropriate corrective actions to address the causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.
(3) Effectiveness of Corrective Actions The inspectors reviewed Exelon's completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed lRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Exelon's timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of lRs associated with selected NCVs and findings to verify that Exelon personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate Exelon personnel's actions related to safety relief valves, the high pressure service water intake structure, and material and test control equipment aspects.

b.

Assessment

(1) Effectiveness of Problem ldentification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Exelon personnel identified problems and entered them into the corrective action program at a low threshold.

Exelon staff at Peach Bottom initiated approximately 30,000 lRs between August 2009 and July 2011. The inspectors observed supervisors at the Plan-of-the-Day, Station Ownership Committee, and Management Review Committee meetings appropriately questioning and challenging lRs to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that Exelon staff trended equipment and programmatic issues, and appropriately identified problems in lRs. The inspectors verified that conditions adverse to quality identified through this review were entered into the corrective action program as appropriate. Additionally, inspectors concluded that personnelwere identifying trends at low levels. In general, inspectors did not identify issues or concerns that had not been appropriately entered into the corrective action program for evaluation and resolution.

(2) Effectiveness of Prioritization and Evaluation of lssues The inspectors determined that, in general, Exelon personnel appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. Exelon personnel screened lRs for operability and reportability, categorized the lRs by significance, and assigned actions to the appropriate department for evaluation and resolution. The lR screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.

Based on the sample of lRs reviewed, the inspectors noted that the guidance provided by Exelon's corrective action program implementing procedures appeared sufficient to ensure consistency in categorization of issues. Operability and reportability determinations were generally performed when conditions warranted and in most cases, the evaluations supported the conclusion. Causal analyses appropriately considered the extent-of-condition or problem, generic issues, and previous occurrences of the issue.

However, the inspectors did note one observation in Exelon's staff evaluation of the following issue:

Exelon staff's maintenance rule evaluation of lR 1120516 (SRV setpoint drift) missed an opportunity to identify that the maintenance rule pedormance reliability criteria for SRV/SVs (System 01A) was not consistent with Exelon procedure ER-AA-310-1003, "Maintenance Rule - Performance Criteria Selection." Specifically, the reliability criteria threshold was not sensitive to SRV/SV lift setpoint testing/surveillance frequencies and, therefore, the criteria established (> 3 maintenance preventable functionalfailures per 24 months) was not an effective monitoring toolwith regard to SRV/SV reliability.

Notwithstanding, the inspectors determined that, overall, Exelon's system classification and maintenance rule performance monitoring of the SRV/SVs remained consistent with their maintenance rule procedures in that the SRV/SV system classification as maintenance rule (aX2) remained valid. Therefore, the inspectors determined that the issue was of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy. Exelon statf documented this issue in lR 1249391.

(3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, Exelon staff identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC NCVs and findings since the last problem identification and resolution inspection were timely and effective. The inspectors identified one violation regarding Exelon's resolution of a longstanding condition adverse to quality regarding SRV lift setpoints exceeding TS acceptance criteria which is documented below.

c.

Findinqs

Introduction:

The inspectors identified a finding of very low safety significance (Green)involving a NCV of 10 CFR 50 Appendix B, Criterion XVl, "Corrective Action," because Exelon staff did not implement corrective actions in a timely manner to correct safety relief valve (SRV)/safety valve (SV) lift setpoint drift in excess of Technical Specification 3.4.3, "Safety Relief Valves and Safety Valves" requirements. Specifically, Exelon staff did not implement timely or adequate actions to correct SRV lift setpoint drift that, on four occasions since 2004 and as recently as 2010, has exceeded TS surveillance acceptance criteria and resulted in TS non-compliances.

Description:

Eleven SRVs and two SVs are installed in the main steam system to provide reactor pressure vessel overpressure protection and provide for automatic/manual depressurization functions. TS 3.4.3, "Safety Relief Valves and Safety Valves," requires that 1 1 of the 13 SRV/SVs be operable to ensure the safety function. TS surveillance requirement (SR) 3.4.3.1 requires verification that the safety function lift setpoints of the required SRV/SVs are within +l- 1o/o of the nominal setpoint.

This surveillance testing is conducted during refueling outages when the SRV/SVs are accessible during reactor shutdown conditions.

Since 2003, six of the last eight outages at Peach Bottom have had as-found SRV/SV lift test failures outside the TS SR 3.4.3.1 acceptance criteria of +l-1o/o. On four of those occasions there were greater than two SRV/SV setpoint failures which resulted in non-compliance with TS 3.4.3. Each time Exelon staff initiated lRs to document the as-found conditions in the corrective action program. In general, since 2003 Exelon staff has determined that the SRV/SV setpoint drift experienced at Peach Bottom is due to overly restrictive TS setpoint criteria (10lo vs. typical industry standard of 3o/otolerance) and have not identified the condition to be a result of equipment reliability or maintenance-related aspects. Exelon statf has.consistently determined that a TS amendment to increase the setpoint tolerance to 3%, consistent with other Exelon sites, was the appropriate corrective action to address the TS noncompliance condition that existed at both units. Exelon staff, except for the action to evaluate and submit a TS revision. have not recommended interim or long-term corrective actions to address the SRV/SV setpoint drift TS compliance issue.

The inspectors' corrective action review noted that as early as 2003 Exelon staff had discussed the option of submitting a TS revision to increase the SRV/SV setpoint tolerance. ln2007 (lR 559430), Exelon authorized a vendor to conduct a SRV/SV tolerance study to evaluate the feasibility and potential impacts of an increase in SRV/SV setpoint tolerance to 3o/o. Based on the results of that study, in early 2009, Exelon authorized a more comprehensive evaluation by a vendor whicn was completed in March 2010 and indicated a 3% tolerance would likely be acceptable with some additional site specific areas of evaluation. However, in May 2010, Exelon deferred the TS revision since an extended power up-rate project was being considered and the impacts of that power up-rate on the SRV/SV setpoint tolerance, at that time, was not fully known. Subsequently, Exelon staff identified during its most recent outage on Unit 2 in 2010 that two SRVs and one SVs failed to meet TS allowable tolerance and therefore were in violation of TS 3.4.3 as documented and submitted by Exelon in LER 4500027712010003. Exelon staff's evaluation (lR 121662811120516) determined that the non-compliance issue was the result of less than aggressive implementation of a TS revision for the SRV/SV setpoint tolerance.

The inspectors' review determined that Exelon staff has not implemented timely corrective actions consistent with expectations outlined in LS-AA-125, "Corrective Action Program Procedure," in that actions have not been timely or effective to correct a long-standing condition adverse to quality (sRV lift setpoint rs non-compliances).

Specifically, the inspectors determined that the action identified by the station to correct the SRV/SV setpoint drift and associated TS non-compliance aspects has not been implemented. Exelon has deferred or delayed implementation of the TS revision on severaloccasions. Additionally, the inspectors determined that Exelon has had several opportunities to revisit the timeliness aspects of the long term TS revision action and has not identified interim or compensatory corrective actions to mitigate future TS non-compliances with regard to SRV/SV lift setpoints. The inspectors noted that Exelon staff has implemented several SRV/SV reliability actions over the last five years to improve overall SRV reliability; however, based on interviews with engineering staff and review of corrective action documents, those actions are not expected to directly mitigate or address the TS non-compliance vulnerability that still exists regarding the SRV/SV lift setpoint.

As documented in lR 112051611216628, Exelon staff has actions scheduled in2012to conduct site specific evaluations required for the TS revision. However, the inspectors also noted that the actual date of the TS revision submittal, based on interviews with Exelon staff, is not affirmed and may continue to be delayed due to continuing conflicts with power up-rate considerations. The inspectors determined that corrective actions resultant from lR 112051611216628 have not resulted in corrective actions to mitigate or address the potential for continued TS setpoint non-compliances going forward. Exelon staff initiated lR 1250472tor disposition of this issue in the station's CAP.

Analvsis: The inspectors determined that the finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the capability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, SRVs/SVs continue to experience reliability challenges associated with SRV/SV lift setpoint margin and remain vulnerable to future TS non-compliances. The inspectors evaluated the significance of this finding using IMC 0609.04, "Phase 1 - lnitial Screening and Characterization of Findings." The inspectors determined that this finding was of very low safety significance (Green)because the finding was not a design or qualification deficiency, did not represent a loss of safety system function, and did not screen as potentially risk-significant due to external initiating events. The inspectors determined there had not been a loss of SRV/SV safety function with regard to SRVs/SVs being able to lift within the necessary pressure range to maintain sufficient margin to design pressure and stress limits.

The finding has a cross-cutting aspect in the area of problem identification and resolution, corrective action program, because Exelon personnel did not implement timely corrective actions to address the longstanding SRV setpoint drift conditions that have resulted in multiple TS compliance violations. IP.1.(d)I

Enforcement:

10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. Contrary to the above, Exelon staff failed to promptly implement actions and correct a condition adverse to quality associated with SRVs/SVs, on both Units 2 and 3, exceeding TS lift setpoint acceptance criteria. As a result, there have been several occasions since 2003 where TS violations have occurred with the most recent occurring on Unit 3 in 2010.

Since this finding was determined to be of very low safety significance (Green) and has been entered into Exelon's corrective action program (lR 1250472) it is being treated as an NCV, consistent with the Enforcement Policy. (NCV 050002771278 - 20110{0-01, Inadequate Corrective Actions Associated With SRV Lift Setpoint Drift)

.2 Assessment of the Use of Operatinq Experience

a. Inspection Scope

The inspectors reviewed a sample of issue reports associated with review of industry operating experience to determine whether Exelon personnel appropriately evaluated the operating experience information for applicability to Peach Bottom and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Exelon personnel adequately considered the underlying problems associated with the issues for resolution via their corrective action program. In I

addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.

b. Assessment The inspectors determined that Exelon personnel appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also observed that industry operating experience was routinely discussed and considered during the conduct of station meetings.

Findinos No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, departmental self-assessments, and assessments performed by independent organizations. Inspectors performed these reviews to determine if Exelon entered problems identified through these assessments into the corrective action program, when appropriate, and whether Exelon staff initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.

b. Assessment The inspectors concluded that self-assessments, audits, and other internal Exelon assessments were generally critical, thorough, and effective in identifying issues. The inspectors observed that Exelon personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. Exelon personnel completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. In general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance.

Findinss No findings were identified.

.4 Assessment of Safetv Conscious Work Envilonment

a. Inspection Scope

During interviews with station personnel, the inspectors assessed the safety conscious work environment at Peach Bottom. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees are aware of the program and its availability with regards to raising safety concerns. The inspectors reviewed the Employee Concerns Program files to ensure that Exelon staff and management entered issues into the corrective action program when appropriate.

b. Assessment During interviews, Exelon staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the corrective action program and the Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.

Findinqs No findings were identified.

40A6 Meetinos. lncludino Exit On August 12,2011, the inspectors presented the inspection results to T. Dougherty, Site Vice President, and other members of the Exelon staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Dougherty Site Vice President

G. Stathes Plant Manager

P. Navin Operations Director

J. Armstrong Regulatory Assurance Manager

P. Cowan Work Management Director

R. Reiner Chemistry, Environmental and Radwaste Manager

D. McClellan Corrective Action Program Manager

S. Sullivan Operations Support Manager

J. James Maintenance Support Manager

H. McCrory Technical Support Manager

B.Shortes Radiological Engineering Manager

B. Hedrick Shift Operations Superintendent

D. Henry Engineering Programs Manager

R. Brower Electrical Design Manager

J. Chizever Mechanical Design Manager

R. Smith Regulatory Assurance

J. Dunlap Decontamination Advanced Radiation Worker Supervisor

T. Purcell Electrical Design Engineering

H. Coleman Mechanical Design Engineering

D. Lord Mechanical Design Engineering

P. Kester Mechanical Design Engineering

K. Hudson Mechanical Design Engineering

J. Donell Programs Engineering

J. Searer Programs Engineering

G. Cilliffo Programs Engineering

C. Burryman Prolect Engineering

S. Allen Plant Chemistry

C. Vest Measurement and Test Equipment Tool Room Attendant

J. Lowe Work Management Predefine Coordinator

D. Wheeler Maintenance Rule Program Coordinator

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened and Closed

0500027 7l 27 I l 20 1 1 0 1 0-0 1 NCV Inadequate Corrective Actions Associated With SRV Lift Setpoint Drift (Section 4C.42.1.c)

LIST OF DOCUMENTS REVIEWED