IR 05000277/2011010: Difference between revisions

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| issue date = 09/16/2011
| issue date = 09/16/2011
| title = 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
| title = 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
| author name = Krohn P G
| author name = Krohn P
| author affiliation = NRC/RGN-I/DRP/PB4
| author affiliation = NRC/RGN-I/DRP/PB4
| addressee name = Pacilio M J
| addressee name = Pacilio M
| addressee affiliation = Exelon Generation Co, LLC
| addressee affiliation = Exelon Generation Co, LLC
| docket = 05000277, 05000278
| docket = 05000277, 05000278
| license number = DPR-044, DPR-056
| license number = DPR-044, DPR-056
| contact person = Krohn P G
| contact person = Krohn P
| document report number = IR-11-010
| document report number = IR-11-010
| document type = Inspection Report, Letter
| document type = Inspection Report, Letter
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter: , with copies to the Regional Administrator, Region l; the Director, Office of Enforcement,United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRCResident lnspector at Peach Bottom. In addition, if you disagree with the cross-cutting aspectassigned to any finding in this report, you should provide a response, within 30 days of the dateof this inspection report, with the basis for your disagreement, to the Regional Administrator,Region l, and the NRC Resident Inspector at Peach Bottom.
{{#Wiki_filter:UNITED STATES N UCLEAR REGULATORY COMM ISSION


M. Pacilioln accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be available electronically for public inspection in theNRC Public Document Room or from the Publicly Available Records (PARS) component of theNRC's document system (ADAMS). ADAMS is accessible from the NRC website athttp:/imrvrv.nrc.qovireadino-rm/adams.html (the Public Electronic Reading Room).
==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


Sincerely,Docket Nos.: 50-277, 50-278License Nos.: DPR-44, DPR-56
==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.


===Enclosure:===
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.
cc w/encl:fu-e,ruPaul G. Krohn, ChiefProjects Branch 4Division of Reactor ProjectsI nspectio n Re port 0500027 7 l 20 1 1 0 10 a nd 0500027 8 l 20 1 1 0 1 0M


===Attachment:===
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.
Supplemental InformationDistribution via ListServ
 
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=
=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 andResolution. The inspectors identified one finding in the area of effectiveness of correctiveactions.This NRC team inspection was performed by three regional inspectors and one residentinspector. The inspectors identified one finding of very low safety significance (Green) duringthis 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 NRClnspectionMan_ual Chapter (lMC) 0609, "significance Determination Process" (SDP). Findings for whichthe SDP does not apply may be Green or assigned a severity level after NRC managementreview. Cross-cutting aspects associated with findings are determined using IMC 0C10,"Components Within the Cross-Cutting Areas." The NRC's program for oveiseeing the safeoperation of commercial nuclear power reactors is described in NUREG-1649, "Re-actorOversight Process," Revision 4, dated December 2006.Problem ldentification and ResolutionThe inspectors concluded that Exelon was generally etfective in identifying, evaluating, andresolving problems. Exelon personnel identified problems, entered them into the correctiveaction program at a low threshold, and prioritized issues commensurate with their safetysignificance. ln most cases, Exelon personnel appropriately screened issues for operability andreportability, and performed causal analyses that appropriately considered extent of condition,generic issues, and previous occurrences. The inspectors also determined that Exelonpersonneltypically implemented corrective actions to address the problems identified in thecorrective action program in a timely manner. However, the inspectors identified one violationof NRC requirements in the area of effectiveness of corrective actions regarding safety reliefvalve 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 andemployee concerns program issues, the inspectors did not identify indicationsthat sitepersonnel were unwilling to raise safety issues nor did they identify conditions that could havehad a negative impact on the site's safety conscious work environment.Gornerstone: Mitigating Systems.
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.'''
: '''Green.'''
The inspectors identified a finding of very low safety significance (Green) involving aNCV of 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," because Exelon staff OiOnot 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 Valvesand Safety Valves" requirements. Specifically, Exelon staff did not implement timely oradequate actions to correct SRV lift setpoint drift that, on four occasions since 2004, hasexceeded TS acceptance criteria and resulted in repeat TS violations. The station enteredEnclosure 3this issue into their corrective action program (CAP) as issue report (tR) 1250472 toevaluate the corrective actions needed to address this issue including evaluation of theproposed revision to the Peach Bottom licensing basis through a TS amendment.The inspectors determined that the finding was more than minor because it was associatedwith the equipment performance attribute of the Mitigating Systems cornerstone andaffected the cornerstone objective of ensuring the capability and reliability of systems thatrespond to initiating events to prevent undesirable consequences (i.e., core damage).Specifically, SRVs continue to experience reliability challenges regarding SRV/SV liftsetpoint drift and the station remains vulnerable to future TS compliance issues. Theinspectors evaluated the significance of this finding using IMC 0609.04, "Phase 1 - InitialScreening and Characterization of Findings." The inspectors determined that this findingwas of very low safety significance (Green) because the finding was not a design orqualification deficiency, did not represent a loss of safety system function, and did notscreen as potentially risk-significant due to external initiating events. The inspectors' reviewdid not identify a loss of SRV/SV safety function with regard to SRVs/SVs being able to liftwithin 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 correctiveactions to address a longstanding SRV tolerance setpoint condition that has resulted inmultiple TS compliance violations. [P. 1 . (d)] [Section 4OAZ. 1 .c.(1 )]Enclosure
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.
.14
 
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=
=REPORT DETAILS=
4.


==OTHER ACTIVITIES (OA)==
==OTHER ACTIVITIES (OA)==
{{a|4OA2}}
{{a|4OA2}}
==4OA2 Problem ldentification and Resolution (711528)This inspection constitutes one biennial sample of problem identification and resolutionas defined by Inspection Procedure71152. All documents reviewed during thisinspection are listed in the Attachment to this report'a. Inspection ScoPeThe inspectors reviewed the procedures that described Exelon's corrective actionprogram 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. Theinspectors compared performance in these areas to the requirements and standardscontained in 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," and Exelonprocedure, l-S-nn-t 25,;'Corrective Action Program Procedure." For each of theseareas, the inspectors considered risk insights flom the station's risk analysis andreviewed issue reforts selected across the seven cornerstones of safety in the NRCsReactor Ouerrighii.""r.. 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 ldentificationln addition to the items described above, the inspectors reviewed system health reports,a sample of completed corrective and preventative maintenance work orders, completedsurveillance test procedures, operator logs, and periodic trend reports. The inspectorsalso completed field walkdowns of various systems on site, such as the emergencydiesel generators and high pressure service water structures. Additionally, theinspectors revidweO a sample of lRs written to document issues identified throughinternal self-assessments, audits, and the operating experience program. Theinspectors completed this review to verify that Exelon personnel entered conditionsadverse to quaiity into their conective action program as appropriate'(2) Effectiveness of Prioritization and Evaluation of lssuesThe inspectors reviewed the evaluation and prioritization.of a sample of lRs issued sincethe last'NRC biennial Problem ldentification and Resolution inspection completed inAugust 2009. The inspectors also reviewed lRs that were assigned lower levels ofrig;ifi""n.e that did not include formal cause evaluations to ensure that they werepr"operfy classified. The inspectors'-review included the appropriateness of the assignedsigniticince, the scope and depth of the causal analysis, and the timeliness ofresolution. The inspectors assessed whether the evaluations identified likely causes forthe issues and developed appropriate corrective actions to address the identifiedEnclosure==
==4OA2 Problem ldentification and Resolution (711528)==


5causes. Further, the inspectors reviewed equipment operability determinations,reportability assessments, and extent-of-condition reviews for selected problems toverify these processes adequately addressed equipment operability, reporting of issuesto the NRC, and the extent of the issues.(3) Effectiveness of Corrective ActionsThe inspectors reviewed Exelon's completed corrective actions through documentationreview and, in some cases, field walkdowns to determine whether the actions addressedthe identified causes of the problems. The inspectors also reviewed lRs for adversetrends and repetitive problems to determine whether corrective actions were effective inaddressing the broader issues. The inspectors reviewed Exelon's timeliness inimplementing corrective actions and effectiveness in precluding recurrence for significantconditions adverse to quality. The inspectors also reviewed a sample of lRs associatedwith selected NCVs and findings to verify that Exelon personnel properly evaluated andresolved these issues. In addition, the inspectors expanded the corrective action reviewto five years to evaluate Exelon personnel's actions related to safety relief valves, thehigh pressure service water intake structure, and material and test control equipmentaspects.b. Assessment(1) Effectiveness of Problem ldentificationBased on the selected samples, plant walkdowns, and interviews of site personnel inmultiple functional areas, the inspectors determined that Exelon personnel identifiedproblems and entered them into the corrective action program at a low threshold.Exelon staff at Peach Bottom initiated approximately 30,000 lRs between August 2009and July 2011. The inspectors observed supervisors at the Plan-of-the-Day, StationOwnership Committee, and Management Review Committee meetings appropriatelyquestioning and challenging lRs to ensure clarification of the issues. Based on thesamples reviewed, the inspectors determined that Exelon staff trended equipment andprogrammatic issues, and appropriately identified problems in lRs. The inspectorsverified that conditions adverse to quality identified through this review were entered intothe corrective action program as appropriate. Additionally, inspectors concluded thatpersonnelwere identifying trends at low levels. In general, inspectors did not identifyissues or concerns that had not been appropriately entered into the corrective actionprogram for evaluation and resolution.(2) Effectiveness of Prioritization and Evaluation of lssuesThe inspectors determined that, in general, Exelon personnel appropriately prioritizedand evaluated issues commensurate with the safety significance of the identifiedproblem. Exelon personnel screened lRs for operability and reportability, categorizedthe lRs by significance, and assigned actions to the appropriate department forevaluation and resolution. The lR screening process considered human performanceissues, radiological safety concerns, repetitiveness, adverse trends, and potential impacton the safety conscious work environment.Based on the sample of lRs reviewed, the inspectors noted that the guidance providedby Exelon's corrective action program implementing procedures appeared sufficient toEnclosure 6ensure consistency in categorization of issues. Operability and reportabilitydeterminations were generally performed when conditions warranted and in most cases,the evaluations supported the conclusion. Causal analyses appropriately considered theextent-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 thefollowing issue:Exelon staff's maintenance rule evaluation of lR 1120516 (SRV setpoint drift) missed anopportunity to identify that the maintenance rule pedormance reliability criteria forSRV/SVs (System 01A) was not consistent with Exelon procedure ER-AA-310-1003,"Maintenance Rule - Performance Criteria Selection." Specifically, the reliability criteriathreshold was not sensitive to SRV/SV lift setpoint testing/surveillance frequencies and,therefore, the criteria established (> 3 maintenance preventable functionalfailures per24 months) was not an effective monitoring toolwith regard to SRV/SV reliability.Notwithstanding, the inspectors determined that, overall, Exelon's system classificationand maintenance rule performance monitoring of the SRV/SVs remained consistent withtheir maintenance rule procedures in that the SRV/SV system classification asmaintenance rule (aX2) remained valid. Therefore, the inspectors determined that theissue was of minor significance and not subject to enforcement action in accordancewith the NRCs Enforcement Policy. Exelon statf documented this issue in lR 1249391.(3) Effectiveness of Corrective ActionsThe inspectors concluded that corrective actions for identified deficiencies weregenerally timely and adequately implemented. For significant conditions adverse toquality, Exelon staff identified actions to prevent recurrence. The inspectors concludedthat corrective actions to address the sample of NRC NCVs and findings since the lastproblem identification and resolution inspection were timely and effective. Theinspectors identified one violation regarding Exelon's resolution of a longstandingcondition adverse to quality regarding SRV lift setpoints exceeding TS acceptancecriteria which is documented below.c. FindinqsIntroduction: The inspectors identified a finding of very low safety significance (Green)involving a NCV of 10 CFR 50 Appendix B, Criterion XVl, "Corrective Action," becauseExelon staff did not implement corrective actions in a timely manner to correct safetyrelief valve (SRV)/safety valve (SV) lift setpoint drift in excess of Technical Specification3.4.3, "Safety Relief Valves and Safety Valves" requirements. Specifically, Exelon staffdid not implement timely or adequate actions to correct SRV lift setpoint drift that, on fouroccasions since 2004 and as recently as 2010, has exceeded TS surveillanceacceptance criteria and resulted in TS non-compliances.Description: Eleven SRVs and two SVs are installed in the main steam system toprovide reactor pressure vessel overpressure protection and provide forautomatic/manual depressurization functions. TS 3.4.3, "Safety Relief Valves andSafety Valves," requires that 1 1 of the 13 SRV/SVs be operable to ensure the safetyfunction. TS surveillance requirement (SR) 3.4.3.1 requires verification that the safetyfunction 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 areaccessible during reactor shutdown conditions.Enclosure 7Since 2003, six of the last eight outages at Peach Bottom have had as-found SRV/SV lifttest failures outside the TS SR 3.4.3.1 acceptance criteria of +l-1o/o. On four of thoseoccasions 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-foundconditions in the corrective action program. In general, since 2003 Exelon staff hasdetermined that the SRV/SV setpoint drift experienced at Peach Bottom is due to overlyrestrictive TS setpoint criteria (10lo vs. typical industry standard of 3o/otolerance) andhave not identified the condition to be a result of equipment reliability or maintenance-related aspects. Exelon statf has.consistently determined that a TS amendment toincrease the setpoint tolerance to 3%, consistent with other Exelon sites, was theappropriate corrective action to address the TS noncompliance condition that existed atboth units. Exelon staff, except for the action to evaluate and submit a TS revision. havenot recommended interim or long-term corrective actions to address the SRV/SVsetpoint drift TS compliance issue.The inspectors' corrective action review noted that as early as 2003 Exelon staff haddiscussed the option of submitting a TS revision to increase the SRV/SV setpointtolerance. ln2007 (lR 559430), Exelon authorized a vendor to conduct a SRV/SVtolerance study to evaluate the feasibility and potential impacts of an increase inSRV/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 completedin March 2010 and indicated a 3% tolerance would likely be acceptable with someadditional site specific areas of evaluation. However, in May 2010, Exelon deferred theTS revision since an extended power up-rate project was being considered and theimpacts of that power up-rate on the SRV/SV setpoint tolerance, at that time, was notfully known. Subsequently, Exelon staff identified during its most recent outage on Unit2 in 2010 that two SRVs and one SVs failed to meet TS allowable tolerance andtherefore were in violation of TS 3.4.3 as documented and submitted by Exelon in LER4500027712010003. Exelon staff's evaluation (lR 121662811120516) determined thatthe non-compliance issue was the result of less than aggressive implementation of a TSrevision for the SRV/SV setpoint tolerance.The inspectors' review determined that Exelon staff has not implemented timelycorrective actions consistent with expectations outlined in LS-AA-125, "Corrective ActionProgram 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 correctthe SRV/SV setpoint drift and associated TS non-compliance aspects has not beenimplemented. Exelon has deferred or delayed implementation of the TS revision onseveraloccasions. Additionally, the inspectors determined that Exelon has had severalopportunities to revisit the timeliness aspects of the long term TS revision action and hasnot identified interim or compensatory corrective actions to mitigate future TS non-compliances with regard to SRV/SV lift setpoints. The inspectors noted that Exelon staffhas implemented several SRV/SV reliability actions over the last five years to improveoverall SRV reliability; however, based on interviews with engineering staff and review ofcorrective action documents, those actions are not expected to directly mitigate oraddress the TS non-compliance vulnerability that still exists regarding the SRV/SV liftsetpoint.As documented in lR 112051611216628, Exelon staff has actions scheduled in2012toconduct site specific evaluations required for the TS revision. However, the inspectorsEnclosure
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'


===.28 also noted that the actual date of the TS revision submittal, based on interviews withExelon staff, is not affirmed and may continue to be delayed due to continuing conflictswith power up-rate considerations. The inspectors determined that corrective actionsresultant from lR 112051611216628 have not resulted in corrective actions to mitigate oraddress the potential for continued TS setpoint non-compliances going forward. Exelonstaff initiated lR 1250472tor disposition of this issue in the station's CAP.Analvsis: The inspectors determined that the finding was more than minor because itwas associated with the equipment performance attribute of the Mitigating Systemscornerstone and affected the cornerstone objective of ensuring the capability andreliability of systems that respond to initiating events to prevent undesirableconsequences (i.e., core damage). Specifically, SRVs/SVs continue to experiencereliability challenges associated with SRV/SV lift setpoint margin and remain vulnerableto future TS non-compliances. The inspectors evaluated the significance of this findingusing IMC 0609.04, "Phase 1 - lnitial Screening and Characterization of Findings." Theinspectors 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 lossof safety system function, and did not screen as potentially risk-significant due toexternal initiating events. The inspectors determined there had not been a loss ofSRV/SV safety function with regard to SRVs/SVs being able to lift within the necessarypressure range to maintain sufficient margin to design pressure and stress limits.The finding has a cross-cutting aspect in the area of problem identification andresolution, corrective action program, because Exelon personnel did not implementtimely corrective actions to address the longstanding SRV setpoint drift conditions thathave resulted in multiple TS compliance violations. IP.1.(d)IEnforcement: 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," requires, inpart, that measures shall be established to assure that conditions adverse to quality,such as failures, malfunctions, deficiencies, deviations, defective material andequipment, and non-conformances are promptly identified and corrected. Contrary tothe above, Exelon staff failed to promptly implement actions and correct a conditionadverse to quality associated with SRVs/SVs, on both Units 2 and 3, exceeding TS liftsetpoint acceptance criteria. As a result, there have been several occasions since 2003where 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 hasbeen entered into Exelon's corrective action program (lR 1250472) it is being treated asan 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 ExperienceInspection ScopeThe inspectors reviewed a sample of issue reports associated with review of industryoperating experience to determine whether Exelon personnel appropriately evaluatedthe operating experience information for applicability to Peach Bottom and had takenappropriate actions, when warranted. The inspectors also reviewed evaluations ofoperating experience documents associated with a sample of NRC genericcommunications to ensure that Exelon personnel adequately considered the underlyingproblems associated with the issues for resolution via their corrective action program. Ina.Enclosure===
===.1 a.===


b.Iaddition, the inspectors observed various plant activities to determine if the stationconsidered industry operating experience during the performance of routine andinfrequently performed activities.AssessmentThe inspectors determined that Exelon personnel appropriately considered industryoperating experience information for applicability, and used the information for correctiveand preventive actions to identify and prevent similar issues when appropriate. Theinspectors determined that operating experience was appropriately applied and lessonslearned were communicated and incorporated into plant operations and procedureswhen applicable. The inspectors also observed that industry operating experience wasroutinely discussed and considered during the conduct of station meetings.FindinosNo findings were identified.Assessment of Self-Assessments and AuditsInspection ScopeThe inspectors reviewed a sample of audits, including the most recent audit of thecorrective action program, departmental self-assessments, and assessments performedby independent organizations. Inspectors performed these reviews to determine ifExelon entered problems identified through these assessments into the corrective actionprogram, when appropriate, and whether Exelon staff initiated corrective actions toaddress identified deficiencies. The inspectors evaluated the effectiveness of the auditsand assessments by comparing audit and assessment results against self-revealing andNRC-identified observations made during the inspection.AssessmentThe inspectors concluded that self-assessments, audits, and other internal Exelonassessments were generally critical, thorough, and effective in identifying issues. Theinspectors observed that Exelon personnel knowledgeable in the subject completedthese audits and self-assessments in a methodical manner. Exelon personnelcompleted these audits and self-assessments to a sufficient depth to identify issueswhich were then entered into the corrective action program for evaluation. In general,the station implemented corrective actions associated with the identified issuescommensurate with their safety significance.FindinssNo findings were identified..3a.b.Enclosure
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.
.410Assessment of Safetv Conscious Work EnvilonmentInspection ScopeDuring interviews with station personnel, the inspectors assessed the safety consciouswork environment at Peach Bottom. Specifically, the inspectors interviewed personnelto determine whether they were hesitant to raise safety concerns to their managementand/or the NRC. The inspectors also interviewed the station Employee ConcernsProgram coordinator to determine what actions are implemented to ensure employeesare aware of the program and its availability with regards to raising safety concerns. Theinspectors reviewed the Employee Concerns Program files to ensure that Exelon staffand management entered issues into the corrective action program when appropriate.AssessmentDuring interviews, Exelon staff expressed a willingness to use the corrective actionprogram to identify plant issues and deficiencies and stated that they were willing toraise safety issues. The inspectors noted that no one interviewed stated that theypersonally experienced or were aware of a situation in which an individual had beenretaliated against for raising a safety issue. All persons interviewed demonstrated anadequate knowledge of the corrective action program and the Employee ConcernsProgram. Based on these limited interviews, the inspectors concluded that there was noevidence of an unacceptable safety conscious work environment and no significantchallenges to the free flow of information.FindinqsNo findings were identified.Meetinos. lncludino ExitOn 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 thatno proprietary information was retained by the inspectors or documented in this report.ATTACHMENT:  
 
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=
=SUPPLEMENTARY INFORMATION=
Line 55: Line 169:


===Licensee Personnel===
===Licensee Personnel===
: [[contact::T. Dougherty Site Vice PresidentG. Stathes Plant ManagerP. Navin Operations DirectorJ. Armstrong Regulatory Assurance ManagerP. Cowan Work Management DirectorR. Reiner Chemistry]], Environmental and Radwaste ManagerD. McClellan Corrective Action Program ManagerS. Sullivan Operations Support ManagerJ. James Maintenance Support ManagerH. McCrory Technical Support ManagerB.Shortes Radiological Engineering ManagerB. Hedrick Shift Operations SuperintendentD. Henry Engineering Programs ManagerR. Brower Electrical Design ManagerJ. Chizever Mechanical Design ManagerR. Smith Regulatory AssuranceJ. Dunlap Decontamination Advanced Radiation Worker SupervisorT. Purcell Electrical Design EngineeringH. Coleman Mechanical Design EngineeringD. Lord Mechanical Design EngineeringP. Kester Mechanical Design EngineeringK. Hudson Mechanical Design EngineeringJ. Donell Programs EngineeringJ. Searer Programs EngineeringG. Cilliffo Programs EngineeringC. Burryman Prolect EngineeringS. Allen Plant ChemistryC. Vest Measurement and Test Equipment Tool Room AttendantJ. Lowe Work Management Predefine CoordinatorD. Wheeler Maintenance Rule Program Coordinator
T. Dougherty               Site Vice President
G. Stathes                 Plant Manager
P. Navin                   Operations Director
J. Armstrong               Regulatory Assurance Manager
P. Cowan                   Work Management Director
: [[contact::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==
==LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED==
Opened and
 
===Closed===
===Opened and Closed===
: 0500027 7 l 27 I l 20 1 1 0 1 0-0 1Inadequate Corrective Actions Associated WithSRV Lift Setpoint Drift (Section 4C.42.1.c)NCVAttachment
 
: A-2
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==
==LIST OF DOCUMENTS REVIEWED==
==Section 4OA2: Problem ldentificatlon and ResolutionAudits and Self-AssessmentsCorrective Action Program Focused Area Self Assessment (FASA) 2011NOSA-PEA-11-12Chemistry, Radwaste, Effluent, and Environmental Monitoring Program Audit(AR 1202556)NOSA-PEA-10-10 Fire Protection Audit Report (AR 1101342)NOSA-PEA-09-07 Operations Audit Report (AR 964765)NOSA-PEA-'I==
 
: 1-03 Emergency Preparedness Audit (AR 1 182406)00878553, FASA, EACE for E-4 Diesel Panel 0DC013 Kl Relay Not Unlatching0Q999277, FASA, ASME Section Xl In-service lnspection Program01141657, Peach Bottom Measurement and Test Equipment Check-ln Self Assessment01
: 130816, Maintenance Rule Functional Area Self-Assessment01229866, Corporate Measurement and Test Equipment Check-ln Self Assessment011130gg, FASA, Non-segregated Bus Failure and Complicated Scram response to
: SER-5-0901138918, FASA, Submerged Cables01222716, FASA, Standards Deficiency regarding lR 1056218lssue Reports (* indicates that condition report was generafed as a result of this inspection)5142145451656581 397074597597107937917988078800908814178909409228709232399504389504399567689567989569809599269609749612599661 51972167972266972272973739975705977749979537979809982085987597987738990733991
: 763991
: 798991 80099234599235399237699239299241099258299458599459199661 I998238100270310053191009728101374010166211021126102597110273061
: 0304811
: 0349351
: 0389281
: 0389281 03901 7103902210390551 041 58810428431047Q2310511671053670105671510571391
: 0590971
: 0596071 061 57310624411
: 0639701 06398410665531 06655610681281 069325107148010714831 0731 801 07385310746911
: 0760561 08028110807941 083695108506410891241 0901 551
: 0909911 09469810978041 0991 4011010131102943110804411085241 1 09300111070711123501112568111267Q111274611128591114588111482811150411116222111640111167651117 418111785411198461119848111988711201231120156112091611209231121887112359411242051130434113132711317851 1
: 348881 1 366591137854113795411379631 1 38056113912511394341140522Attachment
: 1144132114834611493241 1 593621161283116237611642711 1
: 653311 1
: 653841 16613411664921 1 700061171049117553411767541177133117754811778751 1 79399117988711829891 183063118522711855191185526118634411872981 1
: 876391 18783111886411 1
: 886951 1
: 894091 1 9098411952571 1
: 960061 1 9603211976231199026A-31200667120270412027221202752120724212073721 2073831208493121070612122341212585121260112128101216579121662812202381222674122477012249391225029122683412334031234191123528912356301 23581 5123584012401541242473124294412435671247233124724012472411247247124724817775911244280-1248287*1249391.1249900.1249910.1249919*1249921*1 2501 80.1 2501 80*1250327.1250415.1250472*1250710*1250829*Operatinq Experiencef..lRC lnfotrnat'on f.fotice 2010-0g, lmportance of Understanding Circuit Breaker Control PanelIndications (lR 1 0571 39)NRC lnformation Notice 2010-26, Submerged Electrical Cables (lR 1 1 66492)NRC lnformation Notice 2005-30, Safe Shutdown Potentially Challenged by UnanalyzedInternal Flooding Events and Inadequate Design959926987597987738NCVs and Findinqs10714801 07605610807941 0891 241 1 00807110804411778751 1
: 886951 '190984NCV 0500027g12009003-02, Inadequate Procedure Adherence Results in Trip of 3 'A' RecircPump and Plant TransientNcv 0s000 )tltzoogo0S-o1 , osooo27z/200900s-01 , continously submerged cables DesignDeficiencyFIN 0500027712009005-02, 0500027712009005-02, Failure to Follow Procedures andlmplement the Exelon Nuclear Cable Condition Monitoring Program for Non-SafetyRelated Control and Power Cables within the Scope of the Maintenance RuleNRC 0500027712009005, Failure to maintain safety-related power cables in an environment forwhich they were designed and tested (lR
: 1013730,
: 1022206, 1030481)NCV 0500027712009008, Failure to correct procedure regarding adequate grease of contactorpins in DC breakers for HPCI and RCIC on Unit 2 and 3 (lR
: 897128,
: 950438,
: 950439,972167)NCV
: 05000277, 27812010005-01, Inadequate MSIV Test ControlNCV
: 05000277,27g12011002-01, FH Procedures were Inadequate to Prevent Fuel fromContacting an ObstructionNCV 05000277]tOl1007-01, 0500027812011007-01 , Failure to Demonstrate theCapability of the EDG Fuel Oil Transfer Pumps to Fulfill their Safety Functions under AllConditionsAttachment
: A-4NCV 05000 27712011007-02, 05OOO278I2O11OO7-02, Temporary Battery cart SeismicConfiguration DeficiencYCalculationspM-0046, Diesel Generator Fuel Oil Storage Tank Volume Determinations, Rev. 2pM-O123, Diesel Generator Fuel Oil Consumption for 7-days Operation with LOCA DependentLoads, Rev. 5pM-0S33, Emergency Diesel Generator Operability Curves with Reduced ESW Rates,Rev. 1pM-0677, Emergency Diesel Generator Operability Curves for Various ESW Flows andTemperatures, Rev. 1pM-067g, performance curves for Emergency Diesel Generator Heat Exchangers to supportGeneric Letter 89-13 Monitoring Program, Rev' 0PM-1042, Determination of Diesel operability with cross-Flow, Rev. 3pM-1048, Design Basis for Internal Flood Protection for the HPSWESW Pump Structure,Rev.0PS-0028, Design Cart to Transport and Support Temporary Batteries, Rev' 2ProceduresAO 52D.1, Transferring Diesel Fuel oil Between Storage Tanks, Rev. 7AO 52D.2,, Diesel rueioit Day Tank Filling with Associated Transfer Pump out of service,Rev.3AO 52D.3, Diesel Generator Fuel Oil Day Tank Filling from Another Storage Tanks, Rev' 3CY-AA-120-4110, Raw Water Chemistry Strategic Plan, Rev' 6CY-PB-120-9260, MIC Sampling, Rev' 0Emergency Diesel Generator gg-t g Heat Exchanger Testing Report, 2001 - 2007fmeriency Diesel Generator
: GL 89-13 Post-Test Data Reduction, Rev' 1fn-nA-g+g -iOO2, Emergency Diesel Generator Heat Exchanger Test Reqorts:OAE3761T lA .or"pt"t.; d 06122-23/09, OBE37 61718 completed 05/03/1 0, OCE376l718com pleted O5l 1 O l 11, ODE376 17 l 8 completed 021 07 1 1 1El-AA-1, Safety Conscious Work Environment, Rev' 3El-AA-101, Employee Concerns Program, Rev' 9E1-AA-101-100i, Employee Concerns Program Process, Rev' 11El-AA-101-1002, Employee lssues Trending, Rev' 7ER-AA-310, lmplementation of the Maintenance Rule, Rev' 8ER-AA-310-1001, Maintenance Rule - Scoping, Rev' 4ER-AA-31 0-1002, Maintenance Rule Functioni - safety significance classification, Rev. 3ER-AA-310-1004, Maintenance Rule - Performance Monitoring, Rev.
: IER-AA-310-1005, Maintenance Rule - Dispositioning Between (a)(1) ang. (3{Z)' Rev' 5ER-AA-310-1005, Maintenance Rule - Expert Panel Roles and Responsibilities, Rev. 4ER-AA-310-1007, Maintenance Rule Periodic (aX3) Assessment, Rev. 4ER-AA-310-1008, ExelOn Maintenance Rule Process Map, Rev. 0ER-AA-310-1009, Maintenance Rule Program Performance Indicators, Rev' 1ER-AA-310-1010, Maintenance Rule lmplementation Peach Bottom Atomic Power Station,Rev.5ER-AA-3003, Cable Condition Monitoring Program, Rev' 2Attachment
: A-5ER-AA-5400-1002, Buried Piping Examination Guide, Rev' 2ER-PB-310-1010, Attachment 4, Peach Bottom Maintenance Rule Structural MonitoringProgram, Rev.5FH-6C, Core Component Movement - Core Transfers, Rev' 64LS-AA-1012, Safety Culture Monitoring, Rev. 0LS-AA-115, Operating Experience Program, Rev. 17LS-AA-1 15-1001, Processing of Significant Level 1 OPEX Evaluations, Rev. 4LS-AA-1 15-1002, Processing of Significant Level 2 OPEX Evaluations, Rev. 3LS-AA-115-1003, Processing of Significant Level 3 OPEX Evaluations, Rev. 1LS-AA-1 15-1004, Processing of NERs and NNOEs, Rev. 1LS-M-120, lssue ldentification and Screening Process, Rev. 12LS-AA-125, Corrective Action Program, Rev. 15LS-AA-125-1001, Root Cause Analysis Manual, Rev. 8LS-AA-125-1002, Common Cause Analysis Manual, Rev. 7LS-AA-125-1003, Apparent Cause Evaluation Manual, Rev' 9LS-AA-125-1004, Effectiveness Review Manual, Rev- 5LS-AA-125-1005, Coding and Analysis Manual, Rev. 8LS-AA-126, Self-Assessment Program, Rev' 6LS-AA-126-1001, Focused Area Self Assessments, Rev.6LS-AA-1 26-1002, Management Observations of Activities, Rev' 3LS-AA-126-1005, Check-ln Self Assessments, Rev. 4LS-AA-126-1006, Benchmarking Program, Rev. 2MA-AA-716-040, Control of Portable Measurement and Test Equipment Program, Rev' 7MA-AA-716-011, Work Executions and Close Out, Rev. 15MA-MA-716-009, Preventive Maintenance (PM) Work Order Process, Rev. 6NO-AA-210, Nuclear oversight Regulatory Audit Procedure, Rev. 2NO-AA-210-1001, Nuclear Oversight Audit Handbook, Rev' 3NO-AA-210-1002, Nuclear Oversight Audit Templates, Rev' 2OU-AB-4001, BWR Fuel Handling Practices, Rev. 5SO-18.1.A-2, Operation of Refueling Platform, Rev. 24ST-M-01A- 471-2, Main Steam lsolation Valve Timing, Springs Only Closure and Position SwitchAdjustment, Rev. 11ST-M-037-350-2, Safety-Related Door Inspection, Rev. 3sT-o-o7c-470-2, Main Steam lsolation Valve closure Timing, Rev. 17ST-O-O7G- 475-2, Main Steam lsolation Valve Closure Timing at Shutdown, Rev' 4OP-AA-103-102, Watch Standing Practices, Rev. 8Op-AA-108-105, Equipment Deficiency ldentification and Documentation, Rev' 7OP-AA-108-1 15, Operability Determinations, Rev. 10RT-O-052-204-2, E4 DieselGenerator Load Run, Rev. 23RT-O-033-600-2, Flow Test of ESW to ECCS Coolers and Diesel Generator Coolers,Rev. 19SO 32.1.A-2, High Pressure Service Water System Startup and Normal Operations, Rev. 16ST-M-037-311-i, Detailed Visual lnspection of Penetration Seals and Difficult toView Fire Barriers, Rev. 4WC-AA-101-1002, On Line Scheduling Process, Rev. 11WC-AA-106, Work Screening and Processing, Rev. 12Attachment
: A-6ARsA064798441 167100A1392515A1395258A1395258A1443165A1472713Work Ordersc0216856c0235893c0231377MiscellaneousA1474777A1487254A1539643A15955224160090241601130A1633586A1638094A1739265A1739709A1754253A1772214A1776686A1777591A1777593A1777616A1777856A1777857A177874710
: CFR 50.65(a)(3) periodic Assessment of Maintenance Rule Program, Peach Bottom Atomicpower Station Units 2 and 3, Aprit 2007 through March 2009, Rev. 1ER-AA-120, 550.5411; erogram Evaluation and Effectiveness Review, Evaluation No' 11-20'03115111Exelon Nuclear: Peach Bottom station
: PM.1 PM Performance (Non-Outage) Performancelndicator, Jun-10 - MaY-11Letter from D.M. Benyak, gxeton Generation Company, LLC, to U'S' Nuclear RegulatoryCommission, iFitn"r, for Duty Performance Data Reports - Annual 2909 "Letter from J.L. Hansen, Exelon Gen-eration Company, LLC, to U.S. Nuclear RegulatoryCommission, ,,Revision to Exelon Fitness ior Duty Performance Data Reports - Annual2010."Maintenance Division Lost Measurement and Test Equipment Performance Indicator, July 2011Monthly Expert Panel Meeting Minutes, January 27,2011pBApS Maintenance Rule SJope and Performince Monitoring, System 01A-- Main Steam:Main Steam Relief Valves (MSRV); Main Steam Safety Valves (SV); Main Steamlsolation Valves (MSIV)PEA Station Ownership Committee Agenda, 07 127 l 1 Ipersonnel Exposure Investigation 10-b23, O5l25l1O,
: RP-AA-203-1001, PEls, Rev' 6ST-M-023-G30-2, HPCI Teslable Check Vatve Seat Leakage Test, Rev.1o,-Performed 10104110sT-o-007- 41Q-2, Pcls Valves cold shutdown Inservice Test, Rev. 25, Performed 10/06/10ST-O-007- S1O-2, pClS Valves Remote Position Indication Verification, Rev. 7, Performed10106110system 07 - Primary containment, Q2-2011 System Health Reportsystem 10/10A - nHn and RHR Sample, Q2-2011 System Health Reportsyst"m 51H - Station Blackout (sBo), Q2-2011 System Health Reportai;i# /444N148 - Core Spray and rorus Cleanup, Q2-2011 System Health ReportM'-283, System ffi3Emergency Service Water lsometric - Diesel Generator Building,Rev. 1M-377, Sheet 4, Rev. 40M-541, Plumbing and Drainage circulating water Pump structure Plan and Details, Rev' 6ECR 97-03ZZg, t-S-0S04 Set[oint Change and Drawing M-541 Sheet 1 CorrelationECR gB-02202, ECR to lnstall Test Equipment to Support D/G Heat Exchanger TestingECR 01-01 116, Qlarify Design Basis for Pump structure Internal FloodingAttachment
: A-7ECR 09-00581, E-4 EDG Jacket cooling water Piping Below Min wallCommitment T04333, NRC Generic Letter 89-13 ActivitiesCommitment T01730, Monthly Testing of the ESW System per Test ProcedureDBD P-T-09, Internal Hazards Design Basis Document, Rev. 8Enterprise Maintenance Rule Database, Peach Bottom, Evaluation Section, System 70(Structures)EpRl
: NF-7552, Heat Exchanger Performance Monitoring Guidelines, December 1991Generic Letter 89-13 Ultrasonic Piping Inspection Locations, 08108111NEI 96-03, Industry Guidelines for Monitoring the Conditions of Structures at Nuclear PowerPlantslndividual Plant Examination of External Events, Peach Bottom Units 2 and 3, May 1996PECO Letter to U.S. NRC, dated A1,29190, Response to Generic Letter 89-13Specification
: NE-075 for Penetration Seals in Hazard Barriers, Rev' 4ST 8.1.9, Diesel OilTransfer Pump FunctionalTest, completed 01/16191Technicaf Evaluation A1272226-22,lJnverified Cross-flow Assumption in Calculation
: PM-1042Rev.1 andzUltrasonic Examination Report Form under Work Order C0229238-17NEI 09-14, Guideline for the Management of Buried Piping Integrity, Revision 0NES-MS-1S.2, Exelon Standard: Guidance for Determining Reasonable Assurance forstructural and/or Leakage lntegrity for Buried Piping, Revision 0NRC Generic Letter 2OO7-01: lnaccessible or Underground Power Cable Failures that DisableAccident Mitigation Systems or Cause Plant TransientsNRC lnformation Notice 2Q1O-26: Submerged Electrical cablesOperations Short Duration Time Clock Log, Install RPS Test Box to Support Shield BlockRemoval. 09102110ADAMSARCAPCFRtMcIRNCVNRCPARSPeach BottomSDPSRSRVSVTS
==LIST OF ACRONYMS==
Agency-wide Documents Access and Management SystemAction RequestCorrective Action ProgramCode of Federal RegulationsInspection Manual ChaPterlssue ReportNon-Cited ViolationNuclear Regulatory CommissionPublicly Available Records SystemPeach Bottom Atomic Power StationSignificance Determination ProcessSurveillance Req uirementSafety Relief ValveSafety ValveTechnical SpecificationsAttachment
}}
}}

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