IR 05000277/2011010

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
Issue date:	09/16/2011
From:	Krohn P G Reactor Projects Region 1 Branch 4
To:	Pacilio M J Exelon Generation Co
Krohn P G
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 September 16, 2OLl Mr. MichaelJ.

Pacilio Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Rd.Warrenville.

lL 60555

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).

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

Enclosure:

cc w/encl: fu-e,ru Paul G. Krohn, Chief Projects Branch 4 Division of Reactor Projects I nspectio n Re port 0500027 7 l 20 1 1 0 10 a nd 0500027 8 l 20 1 1 0 1 0 M

Attachment:

Supplemental Information 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 )]Enclosure

.1 4

REPORT DETAILS

4OA2 Problem ldentification

and Resolution (711528)This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure71152.

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

The inspectors compared performance in these areas to the requirements and standards contained in 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," and Exelon procedure, l-S-nn-t 25,;'Corrective Action Program Procedure." For each of these areas, the inspectors considered risk insights flom the station's risk analysis and reviewed issue reforts selected across the seven cornerstones of safety in the NRCs Reactor Ouerrighii.""r..

Additionally, the inspectors attended multiple Plan-ofthe-Day, Station Orinership Committee, and Management Review Committee meetings'The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection' chemistry, physical security, and oversight programs'(1) Effectiveness of Problem ldentification ln addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports. The inspectors also completed field walkdowns of various systems on site, such as the emergency diesel generators and high pressure service water structures.

Additionally, the inspectors revidweO a sample of lRs written to document issues identified through internal self-assessments, audits, and the operating experience program. The inspectors completed this review to verify that Exelon personnel entered conditions adverse to quaiity into their conective action program as appropriate' (2) Effectiveness of Prioritization and Evaluation of lssues The inspectors reviewed the evaluation and prioritization.of a sample of lRs issued since the last'NRC biennial Problem ldentification and Resolution inspection completed in August 2009. The inspectors also reviewed lRs that were assigned lower levels of rig;ifi""n.e that did not include formal cause evaluations to ensure that they were pr"operfy classified.

The inspectors'-review included the appropriateness of the assigned signiticince, the scope and depth of the causal analysis, and the timeliness of resolution.

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

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 Enclosure 6 ensure consistency in categorization of issues. Operability and reportability determinations were generally performed when conditions warranted and in most cases, the evaluations supported the conclusion.

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.

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

have not recommended interim or long-term corrective actions to address the SRV/SV setpoint drift TS compliance issue.The inspectors' corrective action review noted that as early as 2003 Exelon staff had discussed the option of submitting a TS revision to increase the SRV/SV setpoint tolerance.

ln2007 (lR 559430), Exelon authorized a vendor to conduct a SRV/SV tolerance study to evaluate the feasibility and potential impacts of an increase in SRV/SV setpoint tolerance to 3o/o. Based on the results of that study, in early 2009, Exelon authorized a more comprehensive evaluation by a vendor whicn was completed in March 2010 and indicated a 3% tolerance would likely be acceptable with some additional site specific areas of evaluation.

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

.2 8 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)Assessment of the Use of Operatinq Experience Inspection Scope The inspectors reviewed a sample of issue reports associated with review of industry operating experience to determine whether Exelon personnel appropriately evaluated the operating experience information for applicability to Peach Bottom and had taken appropriate actions, when warranted.

The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Exelon personnel adequately considered the underlying problems associated with the issues for resolution via their corrective action program. In a.Enclosure b.I addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.

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.

Assessment of Self-Assessments and Audits Inspection Scope The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, departmental self-assessments, and assessments performed by independent organizations.

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.

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 10 Assessment

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

The inspectors reviewed the Employee Concerns Program files to ensure that Exelon staff and management entered issues into the corrective action program when appropriate.

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.

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 7 l 27 I l 20 1 1 0 1 0-0 1 Inadequate

Corrective

Actions Associated

With SRV Lift Setpoint Drift (Section 4C.42.1.c)

NCV Attachment

LIST OF DOCUMENTS

REVIEWED

Section 4OA2: Problem ldentificatlon

and Resolution Audits and Self-Assessments Corrective Action Program Focused Area Self Assessment (FASA) 2011

NOSA-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 964765964765NOSA-PEA-'I

1-03 Emergency Preparedness Audit (AR 1 182406)00878553, FASA, EACE for E-4 Diesel Panel 0DC013 Kl Relay Not Unlatching

0Q999277, FASA, ASME Section Xl In-service lnspection Program

01141657, Peach Bottom Measurement and Test Equipment Check-ln Self Assessment

130816, Maintenance Rule Functional Area Self-Assessment

229866, Corporate Measurement and Test Equipment Check-ln Self Assessment

011130gg, FASA, Non-segregated Bus Failure and Complicated Scram response to

SER-5-09

01138918, FASA, Submerged Cables

01222716, FASA, Standards Deficiency regarding

lR

1056218 lssue Reports (* indicates that condition report was generafed as a result of this inspection)

514214

545165 6581 39

707459

759710

793791

798807

880090

881417

890940

922870

923239

950438

950439

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979809

982085

987597

987738

990733 991 763 991 798 991 800

992345

992353

992376

992392

992410

992582

994585

994591 99661 I

998238

1002703

1005319

1009728

1013740

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1021126

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1027306 1

030481 1

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1039022

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1042843 1047Q23

1051167

1053670

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1101013

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1139434

1140522 Attachment

1144132

1148346

1149324 1 1 59362

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1162376

1164271 1 1 65331 1 1 65384 1

166134

1166492 1 1 70006

1171049

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187831

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1195257 1 1 96006 1 1 96032

1197623

1199026 A-3

1200667

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207383

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1212234

1212585

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1216628

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1233403

1234191

1235289

1235630 1 23581 5

1235840

1240154

1242473

1242944

1243567

1247233

1247240

1247241

1247247

1247248

1777591 1244280-1248287*1249391.1249900.1249910.1249919*1249921*1 2501 80.1 2501 80*1250327.1250415.1250472*1250710*1250829*Operatinq Experience

f..lRC lnfotrnat'on

f.fotice 2010-0g, lmportance of Understanding Circuit Breaker Control Panel Indications (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 Unanalyzed Internal Flooding Events and Inadequate Design

959926

987597

987738 NCVs and Findinqs

1071480 1

076056

1080794 1 0891 24 1 1 00807

1108044

1177875 1 1 88695 1 '190984

NCV 0500027g12009003-02, Inadequate

Procedure

Adherence Results in Trip of 3 'A' Recirc Pump and Plant Transient Ncv 0s000 )tltzoogo0S-o1 , osooo27z/200900s-01 , continously submerged cables Design Deficiency

FIN 0500027712009005-02, 0500027712009005-02, Failure to Follow Procedures and lmplement the Exelon Nuclear Cable Condition Monitoring Program for Non-Safety Related Control and Power Cables within the Scope of the Maintenance Rule

NRC 0500027712009005, Failure to maintain safety-related power cables in an environment for which they were designed and tested (lR

1013730,

1022206, 1030481)NCV 0500027712009008, Failure to correct procedure regarding adequate grease of contactor pins in DC breakers for HPCI and RCIC on Unit 2 and 3 (lR

897128,

950438,

950439, 972167)NCV

05000277, 27812010005-01, Inadequate

MSIV Test Control

NCV 05000277,27g12011002-01, FH Procedures were Inadequate to Prevent Fuel from Contacting an Obstruction

NCV 05000277]tOl1007-01,0500027812011007-01 , Failure to Demonstrate the Capability of the EDG Fuel Oil Transfer Pumps to Fulfill their Safety Functions under All Conditions

NCV 05000 27712011007-02, 05OOO278I2O11OO7-02, Temporary Battery cart Seismic Configuration DeficiencY

Calculations

pM-0046, Diesel Generator Fuel Oil Storage Tank Volume Determinations, Rev. 2 pM-O123, Diesel Generator Fuel Oil Consumption for 7-days Operation with LOCA Dependent Loads, Rev. 5 pM-0S33, Emergency Diesel Generator Operability Curves with Reduced ESW Rates, Rev. 1 pM-0677, Emergency Diesel Generator Operability Curves for Various ESW Flows and Temperatures, Rev. 1 pM-067g, performance curves for Emergency Diesel Generator Heat Exchangers to support Generic Letter 89-13 Monitoring Program, Rev' 0

PM-1042, Determination of Diesel operability with cross-Flow, Rev. 3 pM-1048, Design Basis for Internal Flood Protection for the HPSWESW Pump Structure, Rev.0

PS-0028, Design Cart to Transport and Support Temporary Batteries, Rev' 2 Procedures

AO 52D.1, Transferring Diesel Fuel oil Between Storage Tanks, Rev. 7

AO 52D.2,, Diesel rueioit Day Tank Filling with Associated Transfer Pump out of service, Rev.3

AO 52D.3, Diesel Generator Fuel Oil Day Tank Filling from Another Storage Tanks, Rev' 3

CY-AA-120-4110, Raw Water Chemistry Strategic Plan, Rev' 6

CY-PB-120-9260, MIC Sampling, Rev' 0 Emergency Diesel Generator gg-t g Heat Exchanger Testing Report, 2001 - 2007 fmeriency Diesel Generator

GL 89-13 Post-Test Data Reduction, Rev' 1 fn-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, OCE376l718

com pleted O5l 1 O l 11, ODE376 17 l 8 completed

21 07 1 1 1 El-AA-1, Safety Conscious Work Environment, Rev' 3 El-AA-101, Employee Concerns Program, Rev' 9 E1-AA-101-100i, Employee Concerns Program Process, Rev' 11 El-AA-101-1002, Employee lssues Trending, Rev' 7

ER-AA-310, lmplementation of the Maintenance Rule, Rev' 8

ER-AA-310-1001, Maintenance Rule - Scoping, Rev' 4

ER-AA-31 0-1002, Maintenance Rule Functioni - safety significance classification, Rev. 3

ER-AA-310-1004, Maintenance Rule - Performance Monitoring, Rev. I

ER-AA-310-1005, Maintenance Rule - Dispositioning Between (a)(1) ang. (3{Z)' Rev' 5

ER-AA-310-1005, Maintenance Rule - Expert Panel Roles and Responsibilities, Rev. 4

ER-AA-310-1007, Maintenance Rule Periodic (aX3) Assessment, Rev. 4

ER-AA-310-1008, ExelOn Maintenance Rule Process Map, Rev. 0

ER-AA-310-1009, Maintenance Rule Program Performance Indicators, Rev' 1

ER-AA-310-1010, Maintenance Rule lmplementation Peach Bottom Atomic Power Station, Rev.5

ER-AA-3003, Cable Condition Monitoring Program, Rev' 2 Attachment

ER-AA-5400-1002, Buried Piping Examination Guide, Rev' 2

ER-PB-310-1010, Attachment

4, Peach Bottom Maintenance Rule Structural Monitoring Program, Rev.5

FH-6C, Core Component Movement - Core Transfers, Rev' 64

LS-AA-1012, Safety Culture Monitoring, Rev. 0

LS-AA-115, Operating Experience Program, Rev. 17

LS-AA-1 15-1001, Processing of Significant Level 1 OPEX Evaluations, Rev. 4

LS-AA-1 15-1002, Processing of Significant Level 2 OPEX Evaluations, Rev. 3

LS-AA-115-1003, Processing of Significant Level 3 OPEX Evaluations, Rev. 1

LS-AA-1 15-1004, Processing of NERs and NNOEs, Rev. 1

LS-M-120, lssue ldentification and Screening Process, Rev. 12

LS-AA-125, Corrective Action Program, Rev. 15

LS-AA-125-1001, Root Cause Analysis Manual, Rev. 8

LS-AA-125-1002, Common Cause Analysis Manual, Rev. 7

LS-AA-125-1003, Apparent Cause Evaluation Manual, Rev' 9

LS-AA-125-1004, Effectiveness Review Manual, Rev- 5

LS-AA-125-1005, Coding and Analysis Manual, Rev. 8

LS-AA-126, Self-Assessment Program, Rev' 6

LS-AA-126-1001, Focused Area Self Assessments, Rev.6

LS-AA-1 26-1002, Management Observations of Activities, Rev' 3

LS-AA-126-1005, Check-ln Self Assessments, Rev. 4

LS-AA-126-1006, Benchmarking Program, Rev. 2

MA-AA-716-040, Control of Portable Measurement and Test Equipment Program, Rev' 7

MA-AA-716-011, Work Executions and Close Out, Rev. 15

MA-MA-716-009, Preventive Maintenance (PM) Work Order Process, Rev. 6

NO-AA-210, Nuclear oversight Regulatory Audit Procedure, Rev. 2

NO-AA-210-1001, Nuclear Oversight Audit Handbook, Rev' 3

NO-AA-210-1002, Nuclear Oversight Audit Templates, Rev' 2

OU-AB-4001, BWR Fuel Handling Practices, Rev. 5

SO-18.1.A-2, Operation of Refueling Platform, Rev. 24

ST-M-01A-

471-2, Main Steam lsolation Valve Timing, Springs Only Closure and Position Switch Adjustment, Rev. 11

ST-M-037-350-2, Safety-Related Door Inspection, Rev. 3 sT-o-o7c-470-2, Main Steam lsolation Valve closure Timing, Rev. 17

ST-O-O7G-

475-2, Main Steam lsolation Valve Closure Timing at Shutdown, Rev' 4

OP-AA-103-102, Watch Standing Practices, Rev. 8 Op-AA-108-105, Equipment Deficiency ldentification and Documentation, Rev' 7

OP-AA-108-1

15, Operability Determinations, Rev. 10

RT-O-052-204-2, E4 DieselGenerator Load Run, Rev. 23

RT-O-033-600-2, Flow Test of ESW to ECCS Coolers and Diesel Generator Coolers, Rev. 19

SO 32.1.A-2, High Pressure Service Water System Startup and Normal Operations, Rev. 16

ST-M-037-311-i, Detailed Visual lnspection of Penetration Seals and Difficult to View Fire Barriers, Rev. 4

WC-AA-101-1002, On Line Scheduling Process, Rev. 11

WC-AA-106, Work Screening and Processing, Rev. 12 Attachment

ARs

A0647984 41

167100 A1392515 A1395258 A1395258 A1443165 A1472713 Work Orders c0216856 c0235893 c0231377 Miscellaneous

A1474777 A1487254 A1539643 A1595522

41600902

41601130 A1633586 A1638094 A1739265 A1739709 A1754253 A1772214 A1776686 A1777591 A1777593 A1777616 A1777856 A1777857 A1778747 10

CFR 50.65(a)(3)

periodic Assessment of Maintenance Rule Program, Peach Bottom Atomic power Station Units 2 and 3, Aprit 2007 through March 2009, Rev. 1

ER-AA-120, 550.5411;

erogram Evaluation and Effectiveness Review, Evaluation No' 11-20'03115111 Exelon Nuclear: Peach Bottom station

PM.1 PM Performance (Non-Outage)

Performance lndicator, Jun-10 - MaY-11 Letter from D.M. Benyak, gxeton Generation Company, LLC, to U'S' Nuclear Regulatory Commission, iFitn"r, for Duty Performance Data Reports - Annual 2909 " Letter from J.L. Hansen, Exelon Gen-eration Company, LLC, to U.S. Nuclear Regulatory Commission, ,,Revision to Exelon Fitness ior Duty Performance Data Reports - Annual 2010." Maintenance Division Lost Measurement and Test Equipment Performance Indicator, July 2011 Monthly Expert Panel Meeting Minutes, January 27,2011 pBApS Maintenance Rule SJope and Performince Monitoring, System 01A-- Main Steam: Main Steam Relief Valves (MSRV); Main Steam Safety Valves (SV); Main Steam lsolation Valves (MSIV)PEA Station Ownership Committee Agenda, 07 127 l 1 I personnel Exposure Investigation

10-b23, O5l25l1O,

RP-AA-203-1001, PEls, Rev' 6

ST-M-023-G30-2, HPCI Teslable Check Vatve Seat Leakage Test, Rev.1o,-Performed

10104110 sT-o-007-

41Q-2, Pcls Valves cold shutdown Inservice Test, Rev. 25, Performed

10/06/10

ST-O-007-

S1O-2, pClS Valves Remote Position Indication Verification, Rev. 7, Performed

10106110 system 07 - Primary containment, Q2-2011 System Health Report system 10/10A - nHn and RHR Sample, Q2-2011 System Health Report syst"m 51H - Station Blackout (sBo), Q2-2011 System Health Report ai;i# /444N148 - Core Spray and rorus Cleanup, Q2-2011 System Health Report M'-283, System ffi3Emergency Service Water lsometric - Diesel Generator Building, Rev. 1 M-377, Sheet 4, Rev. 40 M-541, Plumbing and Drainage circulating water Pump structure Plan and Details, Rev' 6

ECR 97-03ZZg, t-S-0S04 Set[oint Change and Drawing M-541 Sheet 1 Correlation

ECR gB-02202, ECR to lnstall Test Equipment to Support D/G Heat Exchanger Testing

ECR 01-01 116, Qlarify Design Basis for Pump structure Internal Flooding Attachment

ECR 09-00581, E-4 EDG Jacket cooling water Piping Below Min wall Commitment

T04333, NRC Generic Letter 89-13 Activities Commitment

T01730, Monthly Testing of the ESW System per Test Procedure DBD P-T-09, Internal Hazards Design Basis Document, Rev. 8 Enterprise Maintenance Rule Database, Peach Bottom, Evaluation Section, System 70 (Structures)

EpRl

NF-7552, Heat Exchanger Performance Monitoring Guidelines, December 1991 Generic Letter 89-13 Ultrasonic Piping Inspection Locations,

08108111

NEI 96-03, Industry Guidelines for Monitoring the Conditions of Structures at Nuclear Power Plants lndividual Plant Examination of External Events, Peach Bottom Units 2 and 3, May 1996 PECO Letter to U.S. NRC, dated A1,29190, Response to Generic Letter 89-13 Specification

NE-075 for Penetration Seals in Hazard Barriers, Rev' 4 ST 8.1.9, Diesel OilTransfer Pump FunctionalTest, completed

01/16191 Technicaf Evaluation

A1272226-22,lJnverified Cross-flow Assumption in Calculation

PM-1042 Rev.1 andz Ultrasonic Examination Report Form under Work Order C0229238-17

NEI 09-14, Guideline for the Management of Buried Piping Integrity, Revision 0

NES-MS-1S.2, Exelon Standard:

Guidance for Determining Reasonable Assurance for structural and/or Leakage lntegrity for Buried Piping, Revision 0 NRC Generic Letter 2OO7-01: lnaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients

NRC lnformation Notice 2Q1O-26: Submerged Electrical cables Operations Short Duration Time Clock Log, Install RPS Test Box to Support Shield Block Removal.

09102110 ADAMS AR CAP CFR tMc IR NCV NRC PARS Peach Bottom SDP SR SRV SV TS

LIST OF ACRONYMS

Agency-wide

Documents

Access and Management

System Action Request Corrective

Action Program Code of Federal Regulations

Inspection

Manual ChaPter lssue Report Non-Cited

Violation Nuclear Regulatory

Commission

Publicly Available

Records System Peach Bottom Atomic Power Station Significance

Determination

Process Surveillance

Req uirement Safety Relief Valve Safety Valve Technical

Specifications

Attachment