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

, 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.

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).

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

Enclosure:

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:

Supplemental InformationDistribution 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 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.

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

.14

REPORT DETAILS

4.

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

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

.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

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

.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:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

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

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

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

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 964765964765NOSA-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