IR 05000277/2011005
| ML12041A323 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/10/2012 |
| From: | Krohn P G Reactor Projects Region 1 Branch 4 |
| To: | Pacilio M J Exelon Nuclear, Exelon Generation Co |
| krohn, pg | |
| References | |
| IR-11-005 | |
| Download: ML12041A323 (59) | |
Text
February 10, 2OL2Mr. Michael J. PacilioSenior Vice President, Exelon Generation Company, LLCPresident and Chief Nuclear Officer, Exelon Nuclear4300 Winfield RoadWarrenville, lL 60555
SUBJECT: PEACH BOTTOM ATOMIC POWER STATION - NRC INTEGRATEDI NSPECTlON REPORT O5}OO277 t20 1 1 005 AND 0500 027 81201 I 005
Dear Mr. Pacilio:
On December 31 ,201'1, the U. S. Nuclear Regulatory Commission (NRQ)-co.lnpleted an -integrated inspection at'your Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3'Thelnclosed integrated inspection report documents the inspection results, which werediscussed on January 2,0t,2b12, with Mr. Thomas Dougherty, Peach Bottom Site Vice President'and other members of Your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license.The inspectors reviewed selected procedures aid records, observed activities, and interviewedpersonnel.This report documents one self-revealing finding and one inspector-identified finding of very lowsafety significance (Green). One finding was d_etermined to involve a violation of NRCiequiiem-ents. Additionallf, two license6-identified violations, which were determined to be ofvery low safety significanie, are listed in this report. However, because of the very low safetysignificance and because they are entered into your corrective action program (CAP), the NRCir-tr".ting the findings "" " non-"ited violations (NCVs;, consistent with Section2'3'2 of theNRC's Enforcemenieoti"y. lf you contest any NCVs in this report, you should provide a .'"rponr" within go iavs of tn"'d"t" of this inspection rep_ort, with the basis for your denial, tct -the Nuclear Regutatory Commission, ATTN: bocument'Control Desk, Washingtorr,-DC 20555-0001; with copi6s to the Regional Administrator, Region l; the Director, Otfice of Enforcement,U. S. NRC, Washington, Di 20555-0001, and the NRC Senior Resident lnspector at thepBApS. tn additiori ii Vb, disagree with ihe cross-cutting aspects assigned.to the findings inthis report, you should provide a response within 30 dayJ of the date of this inspection, with thenasis ior your disagieement, to the Regional Administrator, Region 1, and the NRC Residentlnspector at PBAPS.
M. PacilioIn accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRC's"Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will beavailable electronically for public inspection in the NRC Public Document Room or from thePublicly Available Records (PARS) component of the NRC's document system (ADAMS).ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html(the Public Electronic Reading Room).
Sincerely,f,*/zMPaul G. Krohn, ChiefReactor Projects Branch 4Division of Reactor ProlectsDocket Nos.: 50-277, 50-278License Nos.: DPR-44, DPR-56
Enclosure:
Inspection Report 0500027712011005 and 0500027812011005
w/Attachment:
Supplementary lnformationcc Mencl: Distribution via ListServ M. Pacilioln accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRC's"Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will beavailable electronically for public inspection in the NRC Public Document Room or from thePublicly Available Records (PARS) component of the NRC's document system (ADAMS).ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html(the Public Electronic Reading Room).
Sincerely,/RA/PaulG. Krohn, ChiefReactor Projects Branch 4Division of Reactor ProjectsDocket Nos.: 50-277, 50-278License Nos.: DPR-44, DPR-56
Enclosure:
Inspection Report 0500027712011005 and 0500027812011005
w/Attachment:
Supplementary Informationcc Mencl: Distribution via ListServDistribution w/encl:(via E-mail)W. Dean, RAD. Lew. DRAJ. Tappert, DRPJ. Clifford, DRPC. Miller. DRSP. Wilson, DRSP. Krohn, DRPA. Rosebrook, DRPS. lbarrola, DRPE. Miller, DRPS. Hansell, DRP, SRIA. Ziedonis, DRP, RlS. Schmitt, DRP, OAL. Chang, Rl OEDORidsNrrPMPeachBottom ResourceRidsNrrDorlLpl 1 -2 ResourceROPreports ResourceSUNSI Review Complete: PGK (Reviewer's Initials)ML120414323DOC NAME: G:\DRP\BRANCH4\lnspection Reporls\Peach Bottom\2011\PB 4th QTR\PBIR2011-005_Final.docxAfter declaring this document'An OfficialAgency Record' it will be released to the Public.dathchmenuendosure "N"= No copyTo receive a0f thisindicate in the boxwihout attachment/enclosureOFFICE mmtRI/DRPRI/DRPR1/DRPNAMESHansell/ PGK forARosebrooUAARPKrohn/ PGKDATE02t11t1202t10t1202t10t12 Docket Nos.:License Nos.:Report No.:Licensee:Facility:Location:Dates:Inspectors:Approved by:U. S. NUCLEAR REGULATORY COMMISSIONREGION I50-277, 50-278DPR-44, DPR-5605000277 120 1 1 005 and 0500027 81201 1005Exelon Generation ComPanY, LLCPeach Bottom Atomic Power Station, Units 2 and 3Delta, PennsylvaniaOctober 1,2011 through December 31,2011S. Hansell Senior Resident InspectorA. Ziedonis, Resident InsPectorS. Barr, Senior Emergency Preparedness lnspectorE. Miller, Region 1 Project EngineerR. Nimitz, Senior Health PhYsicistJ. Tomlinson, Operations EngineerK. Young, Senior Reactor lnsPectorPaul G. Krohn, ChiefReactor Projects Branch 4Division of Reactor ProjectsEnclosure 2
SUMMARY OF FINDINGS
tR 05000227t2011005, 0500027812011005; 1010112011 - 1213112011; Peach Bottom AtomicPower Station (PBAPS), Units 2 and 3; Maintenance Effectiveness and Radioactive Gaseousand Liquid Effluent Treatment.The report covered a three-month period of inspection by resident inspectors and announcedinspeciions performed by regional inspectors. One self-revealing (Green) finding and oneinspector-identified finding were identified. The significance of most findings is indicated by theircolor (Green, White, Yellow, or Red) using Inspection Manual Chapter (lMC) 0609, "SignificanceDetermination Process" (SDP). The cross-cutting aspect associated with the findings wasdetermined using IMC 0310, "Components Within the Cross-Cutting Areas." Findings forwhichthe SDP does not apply may be Green, or be assigned a severity level after NRC managementreview. The NRC's program for overseeing the safe operation of commercial nuclear powerreactors is describeO inNUREG-1649, "Reactor Oversight Process," Revision 4, datedDecember 2006.Cornerstones: Initiating Events, Mitigating Systems, and Barrier lntegrityGreen. The inspectors determined that Exelon's failure to promptly correct a conditionaOverse to quality associated with a safety-related motor-operated valve (MOV)constituted a Green, self-revealing NCV of 10 CFR Part 50, Appendix B, Criterion XVl,"Corrective Action." Specifically, corrective actions to prevent recurrence of MOVprogram testing failures due to degraded stem lubrication in 2009 were not performed ina timely manner to prevent the inoperability of a safety-related MOV due to degradedlubricaiion, as identified on September 22,2011. PBAPS entered this issue into theCAP via issue reports (lRs) 1266600 and 1266604'This finding was more than minor because it was associated with the configurationcontrol attribute of the Barrier Integrity (Bl) cornerstone and affected the cornerstoneobjective of providing reasonable assurance that physical design barriers protect thepu-Oti" from iadionuciide releases caused by accidents or events. Specifically, the Unit 3reactor water cleanup (RWCU) outboard isolation valve MO-3-12-018 did not developsufficient thrust at the torque switch trip setpoint during diagnostic testing on September22, 2011. The RWCU MOV would not have been able to perform its safety function toclose during the most limiting design condition. Using the Phase '1 worksheet inAppendix a of IMC 0609, "SDP," the finding affected the Bl cornerstone and was of verylow safety significance (Green) because it did not represent an actual open pathway inthe physical integrity of containment.This finding had a cross-cutting aspect in the area of Problem ldentification & Resolution(pl&R), CAP, because Exelon did not take appropriate corrective actions to address theadverse trend of degraded stem lubrication on a safety-related MOV in a timely manner(Section 1 R12) IP.1(d)1.
Cornerstone: Public Radiation Safety
- Green.
The inspectors identified a Green finding associated with the failure to establish,imptement, and maintain adequate quality assurance (QA) program elements in the areaEnclosure 4of effluent and environmental monitoring as required by Peach Bottom, Units 2 and 3Technical Specification (TS), Section 5.4.1. Specifically, Exelon's QA program foreffluent and environmental monitoring was not sufficient to ensure: 1) that bothadequate and timely evaluation and assessment of changes described in the PublicLand Use Census were conducted for purposes of dose validation and samplingprogram modification; 2) that changes in meteorological parameters, used for publicdose projections and assessment, were promptly and adequately evaluated; and 3) thatlaboratory QA programs for effluent and environmental sample analysis measurementsystems were adequate and implemented properly. Exelon placed thes_e issues in itsinp as Action Requests (ARs): 1226969, 1226202,1299543, 1299476,1302720, and1303308.The finding is more than minor because it is associated with the Public Radiation Safetycornerstone attribute of programs and processes and adversely affected the associatedcornerstone objective in that failure to establish, implement, and maintain an adequateQA program in the effluents and environmental monitoring program area adverselyaffected the licensee's ability to ensure adequate protection of public health and safety.The finding was assessed for significance using IMC 0609, Appendix D, and determinedto be of very tow safety significance (Green) because: the issue was contrary to TSsand is a radioactive effluent release program deficiency; there was no indication of a spillor release of radioactive material on the licensee's site or to the offsite environs thatwould impact public dose assessment, and there was no substantialfailure to implementthe radioactive effluent release program. The licensee re-assessed the dose tomembers of the public from routine releases and determined that projected doses didnot, nor were likely to, exceed applicable limits, including as low as is reasonablyachievable (ALARA) design specifications of 10 CFR Part 50, Appendix l; or 10 CFR20.1301(e). The cause of this finding is related to the cross-cutting area of HumanPerformance, Work Practices, Aspect H.4(b) because the licensee did not ensurepersonnelfollowed procedure compliance requirements activities for effluent andenvironmental monitoring program. (Section 2RS06) tH.4(b)1.
Other Findings
Two violations of very low safety significance, which were identified by the licensee, have beenreviewed by the inspectors.' CoireCtive actions taken or planned by Exelon have been enteredinto the CAp. Tnese violations and the corrective action tracking numbers are listed in Section4OA7 of this report.Enclosure 5
REPORT DETAILS
Summarv of Plant StatusUnit 2 began the inspection period at 100 percent rated thermal power(RTP)- On November19, 2011,-operators reduced' power to approximatelyS0 percent to perform main turbine valvetesting, and'planned maintenance on the 'C' reactoi feed pump (RFP). The unit was returned to100 p-ercent RTp the next day. The unit remained at RTP through the end of the inspectionperiod, except for brief periodi to support planned testing and rod pattern adjustments.Unit 3 began the inspection period shutdown for the 18th refueling outage (RFO) (P3R18) Oloctober i3, the reactor mod'e switch was placed in start-up and the unit was synchronized to thegrid on October 14. On October 17, the unit was returned to 100 percent RTP. On October 26'in unplanned downpower was performed to approximately 79 percent to remove the 'B' RFPfrom service to repair an oil leak in the feed pump turbine speed control hydraulic system. Theunit was returned to 100 percent RTP later that same day following successful repairs' OnNovember 30, an emergent downpower to approximately 94 percent was performed to swap thein-service lubricating oiipump for trre 'B' recirculation pump motor generator (MG) set due toelevated noise and iibrations associated with the 'E' lube oil pump. After placing the 'F'lubricating oil pump in-seryice, the unit was returned to 100 percent power later that same day.Unit 3 reriained at RTp until the end of the inspection period, except for brief periods to supportplanned testing and rod pattern adjustments'1.
REACTOR SAFETY
Gornerstones: lnitiating Events, Mitigating Systems, and Barrier Integrity1R01 Adverse Weather Protection (71111'01 - 1 sample)Readiness for Seasonal Extreme Weather Conditionsa. lnspection ScoPeThe inspectors performed a review of PBAPS's readiness for the onset of seasonal coldtemperatur"s. The review focused on the auxiliary boiler system heallng steam supply,emergency diesel generators (EDGs), emergency service water (ESW) and highpressure service wlter (HPSW) pump rooms, the outer intake cooling water pumpstructure building, and the innei intake cooling water screen structure' The inspectorsreviewed tfre UplO'ated Final Safety Analysis Report (UFSAR), Technical Specifications(TSs), control room logs, and the CAP to determine what temperatures or otherseasonal weather could challenge these systems, and to ensure PBAPS personnel hadadequately prepared for these challenges. The inspectors reviewed station procedures,including pgnpS's seasonal weather preparation procedure and applicable operatingprocedures. The inspectors performed walkdowns of the selected systems to ensurestation personnel identified issues that could challenge the operability of the systemsduring cold weather conditions. The inspectors also reviewed CAP items to verify thatpBApS was identifying adverse weather issues at an appropriate threshold and enteringthem into their CAP iriaccordance with station corrective action procedures. Documentsreviewed for each section of this inspection report are listed in the Attachment.Enclosure 6b. FindinqsNo findings were identified.
a.ctivities on redundantirains'of equipment in order to identify conditions that could have impacted systemperformance of their intended safety functions. The inspectors performed fieldwalkdowns of accessible portions of the systems to verify system components andsupport equipment were aligned correctly and were operable. The inspectors examinedthe material condition of the components and observed operating parameters ofequipment to verify that there were no deficiencies. The inspectors also reviewedwhether PBAPS siaff had properly identified equipment issues and entered them into theCAP for resolution with the appropriate significance characterization.b. FindinqsNo findings were identified.
1R05 Fire Protection (71111.05Q - 5 samples)Resident I nspector Quarterlv Walkdq\,Vnsa. lnspection ScoPeThe inspectors conducted tours of the areas listed below to assess the materialcondition and operational status of fire protection features. The inspectors verified thatpBAPS controlled combustible materials and ignition sources in accordance withadministrative procedures. The inspectors verified that fire protection and suppressionequipment was available for use as specified in the area pre-fire plan, and passive firebarriers were maintained in good material condition. The inspectors also verified thatstation personnel implemented compensatory measures for out-of-service, degraded orinopera'ble fire protection equipment, as applicable, in accordance with procedures'Enclosure
7Unit 3, reactor building (RB) north and south control rod drive equipment areas,elevation 135'-0 inches on November 9 (Fire Zones PF-13H and 13P)Unit 3, refuel floor, elevation 234'-0 inches on November 9 (Fire Zone PF-55)Unit 2, RB closed loop cooling water room, elevation 1 16'-0 inches on November 10(Fire Zone PF-5F). Unit 2 reaclor recirculation MG and alternate shutdown area on November 10(Fire Zone PF-4C)o HPSW and ESW intake structure on November 14 (Fire Zone 144)b. FindinqsNo findings were identified.1R1 1 Licensed operator Requalification Proqram (71111.11).1 Resident Inspector Quarterlv Review (71111.11Q - 1 sample)a. Inspection ScoPeThe inspectors observed licensed operator simulator training on November 7, whichincluded a loss of offsite electrical power with a failure of one emergency bus to load-,failure of the reactor core isolation cooling (RCIC) system to operate, and a failure ofhigh pressure coolant injection (HPCI) system to automatically start. The inspectorsev:aluated operator performance during ihe simulated event and verified completion ofrisk significant operator actions, including the use of abnormal and emergency operatingprocedures. The inspectors assessed tfre clarity and effectiveness of communications,implementation of aciions in response to alarms and degrading plant conditions, and theoversight and direction provided by the control room supervisor. The inspectors verifiedthe accuracy and timeliness of the emergency classification made by the shift manager(SM), the SM's identification of TS action statements, and the shift technical advisor'sverification of the SM's decisions. Additionally, the inspectors assessed the ability of thecrew and training staff to identify and document crew performance problems.b. FindinosNo findings were identified.andactor Operators (71111'11B - 1 sample)Inspection ScopeOn Decem ber 21,20j1, one NRC region-based inspector conducted an in-office reviewof the licensee-administered annual operating tests and comprehensive w_ritten examresults for Limerick and peach Bottom Limited Refueling Senior Reactor Operators for2.011. The inspection assessed whether pass rates were consistent with the guidance ofNRC Manual Chapter 0609, Appendix l, "Operator Requalification Human PerformanceSDP." The insPector verified that:o Individual pass rates on the written exam were greater than 80 percent'(Pass rate was 100 Percent)ao.2Enclosure
8. Individual pass rates on the job performance measures of the operating exam weregreater than 80 percent. (Pass rate was 91 percent). lndividual pass rates on the simulator operating exam were greater than 80 percent.(Pass rate was 100 Percent). Overall pass rate among individuals for all portions of the exam was greater than orequal to 75 percent. (Overall pass rate was 91 percent)b. FindinqsNo findings were identified.
1R12 Maintenance Effectiveness (71111'12Q - 2 samples)a. Inspection ScopeThe inspectors reviewed the samples listed below to assess the effectiveness ofmaintenance activities on structures, systems, and components (SSCs) performanceand reliability. The inspectors reviewed system health reports, CAP documents,maintenance WOs, and maintenance rule (MR) basis documents to ensure that PBAPSwas identifying and properly evaluating performance problems ryitJ,f the scope of theMR. For "".lirarple seletted, the inspectors verified that the SSC was properlyscoped into the MR in accordance with 10 CFR 50.65 and verified that the (aX2)performance criteria established by PBAPS staff was reasonable. As applicable, forSSCs classified as (a)(1), the inspectors assessed the adequacy of goals and correctiveactions to return tnese'SSCs to (a)(2). Additionally, the inspectors ensured that PBAPSstaff was identifying and addressing common cause failures that occurred within andacross MR system boundaries.o Unit 3 RWCU system leaks on October 16 and 22,2011o Unit 3 RWCU outboard isolation MOV diagnostic testing failure and degradedlubrication on November 14, 15, and 21 , 2011b. FindinqsIntroduction. The inspectors determined that Exelon's failure to promptly correct acondition adverse to quality associated with a safety-related MOV constituted a Green,self-revealing NCV of 'tO ifn 50, Appendix B, Criterion XVl, "Corrective Action."Speci1cally, iorrective actions to prevent recurrence of MOV program testing failuresdue to degraded stem lubrication in 2009 were not performed in a timely manner toprevent thL inoperability of a safety-related MOV due to degraded lubrication, asidentified on SePtember 22.Description. During as-found diagnostic testing performed by Exelon on September 22,the unit 3 RWCU o-utboard Mov Mo-3-12-018 did not develop sufficient thrust at thetorque switch trip setpoint to ensure that the valve would close under the most limitingdesign basis differeniial pressure scenario. Subsequent inspeclionby Exelonmaintenance personnel determined that the MOV stem lubrication, Exxon Nebula EP-1'was dry and caked on the valve stem with no functioning lubricant on the stem threads.pBApS determined that the cause of the underthrust condition was attributed todegraded stem lubrication and the resultant increased coefficient of friction on the valveEnclosure
9stem. lmmediate corrective actions included cleaning and removing the Nebula EP-1grease, applying MOV Long-Life grease to the valve stem, and performing successfulIs-left diagnostic testing. PBAPS-'s extent-of-condition (EOC) efforts are summarized inthe last paragraph of the "Description" section of this finding'pBApS root cause evaluation report 892191-08 determined that degraded MOV stemlubrication resulted in four safety-related MOV program test failures in March and April of2009. pBAPS performed multiple corrective actions to address the 2009 MOV programtesting failures, as well as an EOC scoping that included inspection, diagnostic testing,and/oi corrective maintenance on 45 safety-related MOVs in March and April of 2009.Additional corrective actions included revising MOV program procedures and preventivemaintenance (PM) frequencies. PBAPS also identified degraded Nebula EP-1 greaseon MOV program valves in 2006, 2007, and 2008, as discussed in root cause evaluationieport Agbt g-1-Oe, Attachment 1 . The root cause evaluation identified that PBAPS hadthe longest allowable MOV PM lubrication intervals (10 years) in the United Statesnuclear-industry. Another factor related to MOV stem lubrication, the vendor cancelledproduction of lriebula EP-1 in 2001, stating a one-ye_ar limited shelf life. Additionally,Lxelon internal operating experience identified a MOV test failure due to degraded stemlubrication at Braidwood on June 21 ,2010. As a result of the PBAPS and Braidwooddegraded MOV grease events, Exelon has initiated corporate actions to transition allsites from Nebula EP-1 to MOV Long-Life by the end of 2014'Root cause evaluation report 892191-08 required changing the MOV stem lubricantto MOV Long-Life grease as a corrective action to prevent recurrence of MOV programtesting failures Oue to degraded stem lubrication. PBAPS implemented a risk-informedif ign,heOium and tow riif) corrective action plan based on the level of susceptibility toOelraOeO stem lubrication. RWCU outboard isolation valve MO-3-12-018 was includedin iire ',medium," risk population of MOV program valves that had not yet been convertedto MOV Long-Life grease at the time of the diagnostic test_failure on September 22.MO-3-1 Z-}1-Bwas scheduled for PM and conversion to MOV Long-Life following as-found diagnostic testing, which constituted a six-year PM interval. PBAPS identified thatthe MOV program scofing for MO-3-12-018 did not include the correct high temperaturestem factor, wnicn would have reduced the PM frequency to four years'At the close of the inspection period, PBAPS had transitioned 128 of the 182 MOVprogram valves to MdV Long-111" grease. In addition to the previously discussedcoriective actions in responsl to thl Mo-3-12-018 degraded grease, PBAPS.performedan EOC review of all MOVs that have not yet been converted to MOV Long-Life grease,including MOV program calculations to identify additional errors such as theaforeme-ntioneO nign temperature stem factor on MO-3-12-018. Field walkdowns werealso performed onlll Unit g MOVs with NebulaEP-1grease, as well as all accessibleUnit 2 MOVs with Nebula EP-1 grease. Based on the EOC review, 14 MOVs had theirgrease conversion dates moved fonrvard. Additionally, PBAPS has expedited correctiveIctions to complete the MOV Long-Life conversion on all MOV program valves fromDecember 2O14to December 2013. The NRC inspectors reviewed the final EOCscoping and determination performed by PBAPS, and found that it was appropriate tothe circumstances.Analvsis. The inspectors determined that Exelon's failure to promptly correct a conditionlEffito quality associated with a safety-related MOV constitutes a performanceJ"ti"i"n.y. 'speiiticatty, degraded Exxon Nebula EP-1 stem lubricant caused RWCUEnclosure 10outboard isolation valve MO-3-12-018 to fail diagnostic testing on September 22,2011,after a root cause evaluation required changing the stem lubricant to MOV Long-Lifegrease to prevent recurrence of multiple safety-related MOV diagnostic testing failures inMarch and April of 2009. This finding was more than minor because it was associatedwith the containment configuration control attribute of the Barrier Integrity cornerstoneand affected the cornerstone objective of providing reasonable assurance that physicaldesign barriers protect the public from radionuclide releases caused by accidents orevents. Specifically, the RWCU outboard isolation valve MO-3-12-018 did not developsufficient thrust at the torque switch trip setpoint during diagnostic testing on September22,2011, and therefore would not have been able to perform its safety function to closeduring the most limiting design condition. Using the Phase 1 worksheet in Attachment 4of IMC 0609, "SDP," the inspectors determined that this finding was of very low safetysignificance (Green) because it did not represent an actual open pathway in the physicalintegrity of reactor containment.This finding had a cross-cutting aspect in the area of Pl&R, CAP, because Exelon didnot take appropriate corrective actions to address a safety issue in a timely mannerlP.1(d)]. Specifically, Exelon failed to address the adverse trend of degraded MOV stemlubricant in a timely manner, which resulted in loss of the RWCU outboard isolation valveclosing safety function for the most limiting design condition.Enforcement. 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," states, in part,that measures shall be established to assure that conditions adverse to quality arepromptly identified and corrected. Contrary to the above, Exelon failed to promptlycorrect a condition adverse to quality associated with degraded stem lubrication onRWCU outboard isolation valve MO-3-12-018. Specifically, root cause evaluation892191-08 required Exelon to change MOV stem lubrication from Nebula EP-1 to MOVLong-Life, as a corrective action to prevent recurrence of multiple MOV program testingfailures due to degraded stem lubrication identified in 2009. As a consequence ofExelon's failure to promptly correct this condition adverse to quality, MO-3-12-018 faileddiagnostic testing due to degraded Nebula EP-1 stem lubrication on September 22,2011. Because this finding is of very low safety significance and has been entered intothe CAP via lRs 1266600 and 1266604, this violation is being treated as a Green NCVconsistent with the NRC Enforcement Policy. (NCV 05000278/201{005-01, UntimelyGorrective Action to Correct MOV Degraded Stem Lubrication)1R13 MaintenanceRiskAssessmentsandEmeroentWorkControl (71111.13- 3samples)a. Inspection ScopeThe inspectors reviewed station evaluation and management of plant risk for themaintenance and emergent work activities listed below to verify that PBAPSperformed the appropriate risk assessments prior to removing equipment for work. Theinspectors selected these activities based on potential risk significance relative to theReactor Safety cornerstone. As applicable for each activity, the inspectors verified thatPBAPS personnel performed risk assessments as required by 10 CFR 50.65(aX4) andthat the assessments were accurate and complete. When PBAPS performed emergentwork, the inspectors verified that operations personnel promptly assessed and managedplant risk. The inspectors reviewed the scope of maintenance work and discussed theresults of the assessment with the station's probabilistic risk analyst to verify plantconditions were consistent with the risk assessment. The inspectors also reviewed theEnclosure l1TS requirements and inspected portions of redundant safety systems, when applicable,to veriiy risk analysis assumptions were valid and applicable requirements were met.. Unit 3 average power range monitor (APRM) 2-out-of-4 voter failure on November 4,2011. E-2 EDG emergent work on November I and. E-2 EDG declared inoperable due to voltagework on December 5,2011b. FindinqsNo findings were identified.1R.lS Operabilitv Determinations and Functionalitv Assessments (71111'15 - 5 samples)a. Inspection ScoPeThe inspectors reviewed five operability determinations for the following degraded ornon-conforming conditions:o Operability Evaluation 11-003: Control rod seismic impact from fuel channel frictionon October 6,2011o Technical Evaluation 1268076-02: Past operability review of Unit 3 automaticdepressurization system valve 718 on November 3,2011. Unit 2 reaclor feedwater pump control station loss of power on November 10,2Q11. Unit 3 SLC tank temperature control degraded equipment on November 15,2Q11o primary containment overpressure credit for emergency core cooling pumps onNovember 23 and 29,2011The inspectors selected these issues based on the risk significance of the associatedcomponents and systems. The inspectors evaluated the technical adequacy of theoperability determihations to assess whether TS operability was properly justified andthe subject component or system remained available such that no unrecognizedincrease in risk occurred. The inspectors compared the operability and design criteria inthe appropriate sections of the TSs and UFSAR to PBAPS's evaluations to determinewhether the components or systems were operable. Where compensatory measureswere required to maintain operability, the inspectors determined whether the measuresin place would function as intended and were properly controlled by PBAPS' Theinspectors determined, where appropriate, compliance with bounding limitationsassociated with the evaluations.b. FindinqsNo findings were identified.1 R18 Plant Modifications (71111.18 - 1 sample)Permanent Mod ifications10,2011regulator malfunction and emergentEnclosure 12a. Inspection ScoPeThe inspectors evaluated the permanent modification to the Multiple Spurious OperationMotor Control Center Breaker implemented by Engineering Change Request (ECR) 10-OO44g, "Multiple Spurious Operation Motor Control Center Breaker Rework" onNovember 1d and 17. The inspectors verified that the design bases, licensing bases,and performance capability of the affected systems were not degraded by themodification. In addition, the inspectors reviewed modification documents associatedwith the upgrade and design change, which included 10 CFR Part 50.59 documentationand post-mbdification testing resulis. The inspectors also conducted field walkdowns ofthe modifications to verify that the temporary modifications did not degrade the designbases, licensing bases, and performance capability of the affected systems.b. FindinqsNo findings were identified.
1R19 Post-Maintenance Testinq (71111.19 - 8 samples)a. Inspection ScopeThe inspectors reviewed the post-maintenance tests (PMTs) for the maintenanceactivities listed below to verify that procedures and test activities ensured systemoperability and functional capability. The inspectors reviewed the test procedure toverify tnai tne procedure adequately tested the safety functions that may have beenaffeited by the maintenance activity, that the acceptance criteria in the procedure wasconsistenfwith the information in the applicable licensing basis and/or design basisdocuments, and that the procedure had been properly reviewed and approved. Theinspectors also witnessed the test or reviewed test data to verify that the test resultsadequately demonstrated restoration of the affected safety functions.. Unit 3 main steam isolation valve (MSIV) stroke timing on October 3,2011, followingP3R1 I maintenance activities. Unit 3 E-23 vital bus loss of coolant accident (LOCA) / loss of offsite power (LOOP)testing on October 5,2011, following planned maintenance. Unit 3 low pressure turbine acceptance testing during start-up between October 14and 1 7 ,2011 , following P3R18 retrofit modification. Unit 3 'B' reactor protection system (RPS) MG set between October 23 to 24,2011,following flywheel inboard bearing replacement. Unit 2MO-2-10-1548 last performed diagnostic test onplanned maintenanceMay 18,2011, followingo Unit 3 APRM 3 voter card replacement and partial surveillanceAPRM-31FS on November 4,2011test (ST) Sl3N-60A-r Unit 3 M-004-400 reactor vessel head bolt tensioning verification in response toindustry operating experience on November 29,2011. E-1 EDG inspection post-maintenance functional test on November 28 and 29,2011following two-year maintenance overhaulEnclosure
13b. FindinosNo findings were identified.
1R20 Refuelinq and Other Outaoe Activities (71111'20 - 1 sample)Peach Bottom Unit 3 Outaqe - Refuelinq (P3R18)a. Inspection ScoPeThe inspectors reviewed the station's work schedule and outage risk plan for the Unit 3maintenance and refueling outage (3R18), which was conducted September 1 1 throughOctober 14,2011. This simple completes the inspection activity begun in the PBAPS3'd quarter 201 1 inspection report ,2011005. The inspectors reviewed PBAPS'sdevelopment and implementation of outage plans and schedules to verify that risk,industry experience, previous site-specific problems, and defense-in-depth wereconsidered. During the outage, the inspectors observed portions of the shutdown andcooldown processes and monitored controls associated with the following outageactivities:. Refueling Activities - verified that PBAPS was using adequate controls to ensure thelocation of tne fuel assemblies were properly tracked and verified that procedures forforeign material control and retrievalwere implemented on the refueling floor. Core Verification - independently reviewed selected portions of other core verificationactivitieso Torus Closure - conducted a thorough walkdown of accessible torus areas above thesuppression pool water line prior to reactor startup to verify that all debris, tools, anddiving gear were removed. Oryw-elt Closure - conducted a thorough inspection and walkdown of containmentpribr to reactor startup to identify any remaining debris, tools, and equipment wereremoved prior to reactor startuP. Reactor Startup Preparations - reviewed the tracking of startup prerequisites andobserved selected Plant Operations Review Committee meetings where outstandingoutage issues and startup reviews were discussedo Startup and Ascension to Full Power Operation - observed selected activitiesincluding: reactor criticality; portions of the plant heat-up, main generatorsynchronization to the grid; portions of the power ascension to full power operationo Licensee ldentification and Resolution of Problems - reviewed corrective actionreports related to RFO and startup activities to verify that PBAPS was identifyingissues at the appropriate level and taking adequate corrective actionb. FindinqsNo findings were identified.Enclosure
141R22 Surveillance Testinq (71111'22 - 3 samples)a. Inspection Scope (2 routine surveillances; 1 in-service test (lST))The inspectors observed performance of surveillance tests (STs) and/or reviewed testdata of selected risk-signiiicant SSCs to assess whether test results satisfied TSs, theUFSnn, and pBApS piocedure requirements. The inspectors verified that testacceptance criteria were clear, tests demonstrated operational readiness and wereconsistent with desijn documentation, test instrumentation had current calibrations andthe range and accur-acy for the application, tests were performed as written, andapplica6le test prerequisites were satisfied. Upon test completion, the inspectorsconsidered whether the test results supported that equipment was capable of performingthe required safety functions. The inspectors reviewed the following STs:RT-O-01 0-304-3, RHRyHPSW system valves alternateNovember 14and15ST-0-023-301 -2, Unit 2 HPCI Pump, Valve, Flow, andDecember 12. sT-o-0 52-154-2, E-4 EDG Simulated Unit 2 Emergency core cooling system(ECCS) Signat Auto Start with Offsite Power Available on December 21b. FindinqsNo findings were identified.EmergencY PreParedness (EP)lEPO Drill Evaluation (71114'06 - 1 sample)lnspection ScoPeThe inspectors evaluated the conduct of a routine PBAPS emergency drill on December5 to identify any weaknesses and deficiencies in the classification, notification, andprotective iction recommendation development activities. The inspectors observedemergency response operations in the simulator, and technical support center todeteririne-wheiher the event classification, notifications, and protective actionrecommendations were performed in accordance with procedures' The inspectorsdiscussed the results of tfre station drill critique with the lead drill controller, andreviewed the items entered into the CAP, to compare inspector observations with thoseiJ"nliti"J by pBAps staff in order to evaluate PBAPS's critique and to verify whether thePBAPS staff was properly identifying weaknesses in the cAP.FindinosNo findings were identified.RADIATION SAFEryCornerstone: Occupationat Radiation Safety (OS)controltesting onUnit Cooler IST on2.Enclosure 152RS01 Access Control to Radioloqicallv Siqnificant Areas (71124.01- 1 sample)a. Inspection ScopeThe inspectors reviewed selected activities, and associated documentation, in the belowlisted areas. The evaluation of Exelon's performance was against criteria contained inTitle 10 of the CFR Part 20, applicable TSs, and applicable station procedures.Inspection PlanninsThe inspectors reviewed Performance Indicators (Pls) for the Occupational Exposurecornerstone.Radiolooical Hazard AssessmentThe inspectors conducted walkdowns of the facility, including the dry-active wastecollection location and the low-level waste storage facility, including associated yardarea, to evaluate material and radiological conditions. The inspectors madeindependent radiation measurements to verify conditions. During the walk-downs theinspectors selectively reviewed survey data, as available.The inspectors selectively reviewed radiologically risk-significant work activities thatinvolve exposure to radiation. The inspectors verified that appropriate pre-work surveyswere performed. The inspectors evaluated the radiological survey program to determineif hazards were properly identified (e.9., discrete particles, hard-to-detect radionuclides,transient radiation dose rates and dose rate gradients).Instructions to WorkersThe inspectors selectively reviewed occurrences where a worker's electronic dosimeternoticeably malfunctioned or alarmed to verify appropriate worker response and inclusionof issues in CAP, as applicable. The inspectors evaluated licensee dose evaluations asapplicable for these occurrences.Contamination and Radioactive Material ControlThe inspectors observed locations where the licensee monitors potentially contaminatedmaterial leaving the Radiological Controlled Area (RCA), and inspected the methodsused for control, survey, and release from these areas. The inspectors selectivelyevaluated the radiation monitoring instrumentation sensitivity for the type(s) of radiationpresent.Radiolooical Hazards Control and Work CoveraqeThe inspectors toured the facility and evaluated ambient radiological conditions(e.9., radiation levels or potential radiation levels).The inspectors conducted selective inspection of posting and physical controls for highradiation areas (HRAs) and very high radiation areas (VHRAs), to verify conformancewith the Occupational Pl.Enclosure 16Rad iation Worker PerformanceThe inspectors selectively reviewed radiological problem reports since the last inspectionto identify human performance errors and to determine if there were any observablepatterns. The inspectors discussed corrective actions for identified concerns withlicensee Personnel.Radiation Protection Technician ProficiencvThe inspectors selectively reviewed outage radiological problem reports to identify thosethat indicate the cause oi tne event to be radiation protection technician error and toevaluate corrective action approach taken by the licensee to resolve the reportedproblems. The inspectors discussed corrective actions for identified concerns withlicensee Personnel.Problem ldentification and ResolutionThe inspectors determined if problems associated with radiation monitoring andexposure controlwere being identified by the licensee at an appropriate threshold andwere properly addressed foi resolution in the licensee CAP. The inspectors discussedcorrective actions for identified concerns with Exelon personnel'b. FindinqsNo findings were identified'and2RSO2a.(71124.02- 1 samPle)lnspection ScoPeInspection PlanninqThe inspectors selectively reviewed pertinent information regarding plant collectiveexposuie history, .urreni"*posure tiends, and ongoing or planned activities in order toura"r, current performance and exposure challenges. The inspectors reviewed as lowas is reasonably achievable (ALARA) results associated with the 2011 Unit 3 outage'The inspectors'selectively reviewed conformance with the ALARA program aspects of10 cFR 20j101.Radiolooical Work PlanninqThe inspectors selectively compared accrued results achieved (dose rate reductions,person-rem used), ar auiil"ble, with the intended dose established in the licensee'snf_nnn planning ior selected work activities (Unit 3 2O1.1.outage) including person-hourestimates. The-inspectors focused on work activities with an accrued dose of fiveperson-rem. The inspectors determined, as applicable, and where analyses wereLompleted at the time of the inspection, the reasons for inconsistencies betweenintended and actualwork activity doses.sample)Enclosure 17The inspectors determined if post-job (work activity) reviews were conducted and ifidentified problems were entered into the CAP including lessons learned.The inspectors selectively reviewed 2011 Station ALARA Committee meeting minutes.The inspectors selectively reviewed outage report information collected and assembledas of the date of the insPection'Verification of Dose Estimates and Exposure TrackingThe inspectors selectively verified work activities that Exelon had established measuresto track, trend, and if necessary to reduce, occupational doses for ongoing workactivities. The inspectors reviewed control rod drive work, recirculation pump work,in-vessel work, scaffolding, Unit 3 main condenser work, and reactor disassembly andre-assemblySource Term Reduction and ControlThe inspectors discussed source term mitigation effectiveness with licensee staffassociated with the Unit 3 outage'Problem ldentification and ResolutionThe inspectors determined if problems associated with ALARA planning and controlswere being identified by the licensee at an appropriate threshold and were properlyaddressed for resolution in the licensee CAP. The inspectors discussed correctiveactions for identified ALARA concerns rruith Exelon personnel.b. FindinqsNo findings were identified'2RS03 ln-Plant Airborne Radioactivitv Control and Mitiqation (71124.03 - 1 sample)Inspection ScoPelnspection PlanninqThe inspectors reviewed the reported Pls to identify any related to unintended doseresulting from intakes of radioactive materials.Problem ldentification and ResolutionThe inspectors reviewed and discussed problems associated with the control andmitigation of in-plant airborne radioactivity to evaluate the licensee's identification andresolution of issues in the CAP.FindinqsNo findings were identified.a.b.Enclosure 182RS04 Occupational Dose Assessment (71124.04 - 1 sample)Inspection ScopeInspection PlanninqThe inspectors selectively reviewed licensee procedures associated with dosimetryoperations. The inspectors evaluated procedure guidance for personnel monitoring.External DosimetrvThe inspectors evaluated the use of the licensee's personnel dosimeters that requireprocessing were National Voluntary Laboratory Accreditation Program (NVLAP)accredited-. The inspectors determined if the licensee used a "correction factod'toaddress the response of the electronic dosimeter (ED) as compared to itsthermoluminescent dosimeter (TLD) for situations when the ED must be used toassign dose.lnternal DosimetrvThe inspectors selectively reviewed routine bioassay (in vivo) procedures and wholebody count results used to assess dose from potentially internally deposited nuclidesusing whole body counting equipment.Special Dosimetrv SituationsThe inspectors selectively reviewed exposure results, and monitoring controls employed,associaied with declared pregnant individuals during the current assessment period.The inspectors selectively reviewed the licensee's implementation of monitoring forexternai dose for the Unii 3 outage in situations in which non-uniform fields are expectedor large dose rate gradients (i.e., use of multi-badging or determination of effective doseequivilent for exteinal exposures (EDEXs) using an NRC approved method).Neutron Dose AssessmentThe inspectors selectively evaluated the licensee's neutron dosimetry program, includingdosi meter type(s) and/or survey instrumentation.Shallow Dose EquivalentThe inspectors selectively reviewed personnel contamination instances to evaluatefrequency, causes, and dose assessment, as appropriate. The inspectors alsodiscussei identification and logging of personnel contamination occurrences during theUnit 3 outage including actions taken to identify and limit personnel contaminationevents. The inspectors reviewed a common cause analysis associated with personnelcontamination events (AR 1 268194).Enclosure 19Dose AssiqnmentThe inspectors evaluated assignment of dose of record for total effective doseequivalent, shallow dose equivalent, and lens dose equivalent.Problem ldentification and ResolutionThe inspectors selectively reviewed corrective action documents to verify that problemsassociated with occupational dose assessment were being identified by the licensee atan appropriate threshold and were properly addressed for resolution in the licensee'sCAp. The inspectors discussed corrective actions for identified concerns with Exelonpersonnel.b. FindinqsNo findings were identified.2RS05 Radiation Monitorinq lnstrumentation (71122.05 - 1 sample)a. Inspection ScoPeInspection PlanninqThe inspectors reviewed the plant updated final safety analysis lepgrt (UFSAR)' asapplicable, to identify radiation instruments associated with monitoring area radiologicalconditions, includingairborne radioactivity, process streams, effluents, materials/articles,and workers.Walkdowns and ObservationsThe inspectors selected portable survey instruments in use or available for issuance andchecked calibration and source check stickers for currency, and to assess instrumentmaterial condition and operability.Calibration and Testino ProqramThe inspectors selectively reviewed calibration of Units 2 and Unit 3 drywell high rangemonitors. The inspectors selectively verified electronic calibration and sourcecalibration.The inspectors selectively reviewed and discussed the licensee's capability to collecthigh range, post-accident iodine effluent samples'The inspectors selectively reviewed and discussed high-range effluent monitorcalibrations.Problem ldentification and ResolutionThe inspectors selectively reviewed corrective action documents associated withradiation monitoring instrumentation to determine if the licensee identified issues at anappropriate tfrreshdtd and placed the issues in the CAP for resolution' In addition, theEnclosure 20inspectors evaluated the appropriateness of the corrective actions for a selected sampleof problems documented by the licensee that involve radiation monitoringinstrumentation. The inspectors discussed corrective actions for identified concerns withExelon personnel.b. FindinqsNo findings were identified.Gornerstone: Public Radiation Safety (PS)2RS06 Radioactive Gaseous and Liquid Effluent Treatment (71124'06 - 1 sample)a. lnspection ScoPeThe inspectors selectively reviewed UFSAR descriptions of the radioactive effluentmonitoring systems, treatment systems, and effluent flow paths.The inspectors selectively reviewed changes to the ODCM made by the licensee sincethe last inspection to identify differences.The inspectors discussed, and selectively determined, if the licensee had identified anynon-rad'ioactive systems that have become contaminated as disclosed either through anevent report or are documented in the ODCM since the last inspection. The inspectorsselectively determined if any newly contaminated systems had an unmonitored effluentdischarge path to the environment.Walk downs and ObservationsThe inspectors selectively walked down components of the gaseous and liquid dischargesystems to verify equipm-ent configuration, flow paths, and material conditions'The inspectors selectively reviewed liquid waste discharge permits'Samplinq and AnalvsesThe inspectors selectively reviewed, as available, effluent discharges made withinopera'ble (declared outbf-service) effluent radiation monitors to verify that controlsweie in-place to ensure compensatory sampling was performed consistent with theRad iolog ical Effl uents Tech nical specification (RETS)/ODCM.The inspectors selectively determined if the facility was relying on the use ofcompensatory sampling in lieu of adequate system maintenance.The inspectors selectively reviewed the results of the inter-laboratory and intra-laboratory comparison p.gr"r to verify the quality of the radioactive effluent sampleanalyses.Enclosure b.21Dose CalculationsThe inspectors selectively reviewed liquid and gaseous waste discharges to verify thatthe projected doses to members of the public were accurate and based onrepresentative samples of the discharge path.The inspectors selectively evaluated the methods used to determine the isotopes thatwere included in the source term to ensure all applicable radionuclides were included,within detection standards.The inspectors selectively reviewed changes in the licensee's offsite dose calculationssince the last inspection io verify changes were consistent with the ODCM andRegulatory Guide (RG) 1
.109 . The inspectors also reviewed meteorological dispersionanO Oepoiition factors used in the ODCM and effluent dose calculations to ensureappropriate factors were being used for public dose calculations.The inspectors reviewed the latest Public Land Use Census to verify that changes hadbeen factored into the dose calculations and to verify calculated doses were within the10 CFR Part 50, Appendix I and TS dose criteria.The inspectors selectively reviewed, as available, abnormal gaseous or liquid tankdischarges and associated dose calculations, evaluations, and corrective actions.Ground Water Protection lnitiative lmplementationThe inspectors selectively reviewed implementation of the ground water monitoringprogram. The inspectors reviewed monitoring results of the Ground Water Protectioniniti-ative (Gpl) to determine if the licensee had implemented its program as intended andto identify any anomalous or missed results and to determine if the licensee hadidentified and addressed deficiencies through its CAP'Problem ldentification and ResolutionThe inspectors verified that problems associated with the effluent monitoring and controlprogram were being identified by the licensee at an appropriate threshold and werefro[erty addressed'for resolution in the CAP. The inspectors discussed correctiveactions-for identified concerns with Exelon personnel'Findinoslntroduction. The inspectors identified a Green Finding associated with failure toestabl'Sh, 'rnplement, and maintain adequate QA program elements in the area ofeffluent and environmental monitoring as required by Peach Bottom Units 2 and 3TSs Sectio n 5.4.1.c, "Quality assurance for effluent and environmental monitoring."Specifically, Exelonjs QA program for effluent and environmental monitoring was notsufficient to ensure: 1) that Ootfr adequate and timely evaluation and assessment of.h"ngur described in ifre 2010 Public Land Use Census were conducted for purposes ofdose validation and sampling program modification; 2) that changes in meteorologicalfarameters, used for public Oose prolections and assessment, were promptly andEnclosure
22adequately evaluated; and 3) that laboratory quality assurance programs for effluent andenviionmental sample analysis measurement systems were adequate and implementedproperly.Description. Peach Bottom Units 2 and 3 TSs require in Section 5.4.1.c, among otherrequtrements, that QA procedures for effluent and environmental monitoring beestablished, implemented, and maintained'Exelon established various effluent and environmental monitoring QA programprocedures to provide QA for important elements of the effluent and environmentalmonitoring program that could collectively and individually impact public dose projectionsattributable to effluent releases from the Peach Bottom Station. These QA elementscovered such matters as: 1) evaluation of public land use around the station to ensuredose pathway analyses were conducted taking into consideration current land usearound the facility; 2) evaluation of changes to important meteorological parametersused for public dose'projection; and 3) various laboratory QA program elements toprovide assurance that onsite and vendor laboratories were providing acceptableanalytical results. The inspectors identified six examples where the effluent andenvironmental QA program was ineffective as follows:. Exelon did not conduct an evaluation of its 2010 Land Use Census results inaccordance with Procedure CY-AA-1 70-1 000, Revision 5, "RadiologicalEnvironmental Monitoring Program and Meteorological Program lmplementation."The evaluation supports tfre Oetermination, from a QA perspective, of the need foradditional new monitoring stations (compensatory measures) based on changes inthe land use and calculaied dose or dose commitment. Procedure CY-AA-170-1000required in section 4.5, that the census be reviewed against the requirements listedin ine station's ODCM, and the ODCM required that compensatory measures betaken to add new environmental monitoring locations, within 31 days, if needed'Exelon had completed its 2010 Land Use Census (dated January 4, 2011) for PeachBottom and provided a summary of the census to the NRC in its May 31,2011'Annual Radiological Operating Report (No. 63). Exelon subsequently conducted anevaluation of the 2010 Land Use Census in July 2011, which included newinformation, and concluded no change in monitoring was required. Exelon placedthis issue into its CAP (AR 1226969)'. Exelon did not conduct an assessment of its long term meteorological data tocompare the 2010 annual meteorology values of )UQ (dispersion factor) and D/Q(deposition factor) against long term averages to determine if non-conservativeirends existed. Exel6n Procedure CY-AA-170-1000, Revision 5, "RadiologicalEnvironmental Monitoring Program and Meteorological Program lmplementation,"required in Section +.0.+ltnatihe annual meteorologicalXQ (dispersion) and D/Q(deposition) values be compared to the long term historical X/Q and D/Q values forsignificant changes in a non-conservative direction. The procedure required that ifthe values were-found to be trending non-conservatively higher over a period of time,then action was to be initiated, including initiating the corrective action process, ifthere was a gap between ODCM requirements and sample locations. Exelonsubsequently compared the data in June 2011 and placed this issue in the CAP (AR1226202).Enclosure 23. The inspectors identified that Exelon's QA program for meteorological dataevaluation failed to detect that the existing ground-level meteorological )UQ value,for the Units 2 and 3 vent stacks, used in the ODCM for purposes of dose projection,was non-conservative relative to the latest calculated long term meteorologicalaverage values resulting in potential incorrect dose calculations. Exelonsubsequently evaluated this new data in December 2011 and concluded there wasno significant change in critical sector dose projections and that public doseprojections continued to be well within 10 CFR Part 50, Appendix l, ALAM designvalues and 10 CFR 20.1301(e). Exelon placed this issue into its CAP (AR 1299543).. The inspectors identified that Exelon did not conduct an evaluation of its first,second, and third quarter 2011 inter-laboratory cross-check samples to determineif sample analyses met applicable QA requirements, as required by ProcedureCY-AA-130-201, Revision 1, "Radiochemistry Quality Control," Section 4.3. Thecross-check samples that were not evaluated included: tritium; gross alpha;Sr-89/90; and filter gas and solid samples. The inter and intra laboratory sampleswere subsequently evaluated in December 2011 using the criteria within ProcedureCY-AA-130-201, Attachment F. Exelon placed this issue into its CAP (AR1299476).. The inspectors identified that Exelon's QA program did not ensure that actual QAsample analysis results, obtained from a vendor laboratory for analysis, weresubsequently critically evaluated against applicable criteria specified in procedures.Exelon did not conduct its onsite biennial evaluation for liquid tritium analysis duringsecond quarter 2011 sampling activity, in that a traceable standard was not analyzedonsite in accordance with the QA program requirements specified in CY-AA-130-201Revision 1. Exelon subsequently placed this issue into its CAP (AR 1302720), andsuccessfully performed the analysis in December 2011.o The inspectors identified that Exelon's QA cross-check procedure, RT-C-095-861-2,"Radiochemistry Intra-laboratory Cross-Check Analysis Program," did not containsufficient guidance to ensure appropriate analytical data was used for sample inter-comparison resolution. Exelon subsequently identified similar concerns in othercross-check procedures. ln addition, incorrect sample inter-comparison analysisresultswere identified (e.9., November 14,2011 tritium sample analysis). Exelonplaced this issue into its CAP (AR 1303308) to correct the procedural deficienciesand re-perform the cross-check using appropriate analytical methods.Given the identified issues, Exelon conducted extensive re-analysis of projected offsitedoses taking into consideration new Land Use Census data as well as the identifiedchanges in meteorological parameters. Exelon concluded there was no significantimpact on public doses and public dose projections remained well within 10 CFR Part 50Appendix I ALARA design specifications. Exelon also reviewed environmental sampledata and did not identify any anomalous results. Exelon also evaluated those samplesresults (as well as inter-comparison results) that had not been critically evaluated (orincorrectly evaluated) and concluded, based on data review, that the sample results metcomparison criteria once evaluated properly. Exelon was continuing its data review.Further, Exelon conducted a liquid tritium analysis and concluded that the analysisresults were within acceptance criteria. The inspectors discussed and selectivelyreviewed Exelon's analyses and did not identify any significant dose consequence.Enclosure 24Analvsis. Exelon did not establish, implement, and maintain an adequate QA program inthe area of etfluent and environmental monitoring as required by Peach Bottom Units 2and 3 TSs, Section 5.4.1.c, for elements of its effluent and environmental monitoringprogram. Specifically, Exelon's QA program for effluent and environmental monitoringwaJnot sufficiently robust to ensure: 1) that both adequate and timely evaluation andassessment of chinges described in the 2010 Public Land Use Census were conductedfor purposes of dose validation and sampling program modification; 2) that changes inmeteorological parameters, used for public dose projections and assessment, werepromptly a-nd adequately evaluated; and 3) that laboratory QA programs, for effluent andenvironmental sample analysis measurement systems were both adequate andimplemented. The failures to establish, implement, and maintain such a QA programwas reasonably within the Exelon's ability to foresee and should have been prevented.The finding is more than minor because it is associated with the Public Radiation Safetycornerstone attribute of programs and processes and adversely affected the associatedcornerstone objective in thai failure to establish, implement, and maintain an adequateeA program inine effluents and environmental monitoring program area adverselyaffeiteO the licensee's ability to ensure adequate protection of public health and safety'Specifically, Exelon's QA program for effluent and environmental monitoring, was notsufficienly robust to ensuie: i; tnat adequate and timely evaluations and assessment ofchanges described in the 2010 Public Land Use Census were conducted for purposes ofdose validation and sampling program modification; 2) that changes in meteorologicalparameters, used for public dose projections and assessment, were evaluated in anadequate and timely manner; and 3) that laboratory QA programs for effluent andenviionmental sample analysis measurement systems were adequate and properlyimplemented.This finding was assessed using IMC 0609, Appendix D, and determined to be of verylow safetyiignificance (Green) because: the issue was contrary to the licensee's TSs;there wai no indication of a spill or release of radioactive material on the licensee's siteor to the offsite environs that would impact public dose assessment; and there was nosubstantial failure to implement the radioactive effluent release program. The licenseewas able to re-assess the dose to members of the public from routine releases anddetermined that projected doses did not nor were likely to exceed applicable limitsincluding ALARA design specifications of 10 CFR Part 50, Appendix l, or ..10 CFR20.1301(e). There was no effluent monitor calibration issue and the licenseehad data by which io assess dose to a member of the public. Exelon plans to provideupdated efiluent release and dose reports, as necessary, to reflect revised analyses.The cause of this finding is related to the crosscutting area of Human Performance,Work Practices, Aspect H.+(O) because the licensee did not ensure personnelfollowedprocedure compliance requirements activities for the effluent and environmentalmonitoring programs.Enforcement. The violation related to this finding is currently under review by the NRC.When that review is completed, the decision relative to any violation will be transmittedto Exelon via separate correspondence. In accordance with NRC IMC 0612, since thesignificance determination of ihe underlying finding has been completed and does notinlerfere with the NRC's current review of the violation, the finding can be issued at thistime. The finding and associated violation, although dispositioned separately, only countaS one input into the plant assessment process. However, the number andcharacterization of violations is subject to change pending the NRC's final review.Enclosure 25Exelon entered this matter into its CAP (ARs: 1226969,12262Q2,1299543,1299476,13O272O,and 1303308), (FtN 0500027712011005-02;0500027812011005'02; Failure toEstablish, lmplement,'and Maintain Adequate QA for Effluent and EnvironmentalMonitoring)2RS07 Radioloqical Environmental Monitorinq Proqram (71124.07 - 1 sample)a. Inspection ScoPeInspection Planninqfne 'nWectoffictively reviewed the annual radiological environmental and effluentoperating reports (2009, 2O1O), and the results of licensee assessments since the lastinspection, to verify that the Radiological Environmental Monitoring Program (REYllwas implemented in accordance with the Peach Bottom Units 2 and 3 TSs and ODCM'The inspectors reviewed the report for changes to the ODCM with respect toenvironmental monitoring, commitments in terms of sampling locations, monitoringand measurement frequencies, Land Use Census, inter-laboratory comparison program'program exceptions, and analysis of data'The inspectors selectively reviewed the ODCM to identify locations of environmentalmonitoring stations.The inspectors selectively reviewed the Peach Bottom Units 2 and 3 Updated FinalSafety Analysis Report (UfSnn) for information regarding the environmental monitoringprogram and meteorological monitoring instrumentation'Site InsPectionThe inspectors selectively reviewed any significant changes made by the licensee tothe ODCM as the result of changes to the Public Land Use Census, long-termmeteorological conditions (e.g., -3-year average), or modifications to the sampler stationssince the last inspection. itre inspectors reviewed technicaljustifications for anychanged samPling locations.The inspectors evaluated detection sensitivities with respect to TS/ODCM used forcounting samples (i.e., the samples meet the TS/ODCM required lower limits ofdetection (LLD).ldentification and Resolution of ProblemsThe inspectors determined if problems associated with the REMP were being identifiedby the licensee at an appropriate threshold and were properly addressed for resolution inthe CAp. In addition to the above, the inspectors verified the appropriateness of thecorrective actions for a selected sample oi problems documented by the licensee thatinvolve the REMp. The inspectors discussed corrective actions for identified concernswith Exelon Personnel'b. FindinqsNo findings were identified.Enclosure 26Transportation (7 1 124.08 - 1 sample)Inspection ScoPeInspection PlanninqThe inspectors selectively reviewed the solid radioactive waste system des,cription in theUFSAR, the process conirol program (PCP), and the recent radiological effluent releasereports ior iniormation on the types, amounts, and processing of radioactive wastedisposed.Radioactive Material StoraqeThe inspectors selectively reviewed areas where containers of radioactive waste werestored, io verify that the containers were labeled in accordance with 10 CFR 20'1904',;t"O"ling Coniainers," or controlled in accordance with 10 CFR 20.1905, "Exemptions toLabeling Req uirements," as appropriate.The inspectors selectively toured the facility to verify that the radioactive materialsstorage areas were controlled and posted in accordance with the requirements of10 CFR part20, "standards for Protection against Radiation."Radioactive Waste Svstem WalkdownThe inspectors reviewed and discussed liquid and solid radioactive waste processingsystems. The inspectors also selectively reviewed various photographs, live camerauL*r, and radiological surveys to access material conditions of rooms and tanks. Theinspectors reviewed area staius logs for radioactive waste areas and systems.Shipment PreParationThe inspectors selectively observed shipment packaging, surveying, labeling.' marking'placarding, vehicle checks, emergency instructions, disposal manifest, shipping papersirovided [o tn" driver, and licensee verification of shipment readiness[srripment pM-1 1-1si ;. rne inspectors observed radiation workers during the conductof tne radioactive material shipment preparation. The inspectors determined if theshippers were knowledgeable of the shipping regulations and whether shippingpeisonnel demonstratei adequate skills to accomplish the package preparationiequirements. The inspectors verified that the licensee's training program providedtraining to personnel responsible for the conduct of radioactive waste processing andradioactive material shipment preparation activities'ldentification and Resolution of ProblemsThe inspectors determined if problems associated with radioactive waste processing,handling, storage, and transportation, were being identified by the licensee at.an"ppropii"t" thr6shold, ur" piop"rly characterized, and are properly addressed forEnclosure 27resolution in the licensee CAp. The inspectors discussed corrective actions for identifiedconcerns with Exelon Personnel'b. FindinqsNo findings were identified.4.
OTHER ACTIVITIES
4OA1 Performance lndicator Verification (71151 - 14 samples)Cornerstone: Mitigating SYstems
.1 Mitioatinq Svstems Performance lndex (10 samples)a. Inspection ScoPeThe inspectors sampled PBAPS's submittals of the Mitigating Systelg Performancelndex ifrrfSef l for the following systems for the period of October 1,2010 throughSeptember 30,2Q11:o Unit 2 and Unit 3 Emergency Alternating Current Power System (MS06)o Unit 2 and Unit 3 HPCI System (MS07)r Unit 2 and Unit 3 RCIC System (MS08)o Unit 2 and Unit 3 RHR SYstem (MS09)o Unit 2 and Unit 3 Support Cooling Water System (MS10)To determine the accuracy of the Pl data reported during this period,lhe inspectors useddefinitions and guidance iontained in Nuclear Energy lnstitute (NEl) Document 99-02,,,Regulatory AsJessment Pl Guideline," Revision 6. The inspectors also reviewedpBApS operator narrative logs, condition reports (CRs), MSPI derivation reports, eventreports, and NRC integrated inspection reports to validate the accuracy of thesubmittals.b. FindinqsNo findings were identified..2 Safetv Svstem Functional Failures (2 samples)a. lnspection ScoPeThe inspectors sampled PBAPS's submittals for the safety system functional failurepl for both Unit 2 and Unit 3 for the period of October 1,2010, through September 30,2011. To determine the accuracy of the Pl data reported during this period, inspectorsused definitions and guidance contained in the NEI Document 99-02, "RegulatoryAssessment pl GuidJline," Revision 6, and NUREG-1o22, "Event Reporting Guidelines10 cFR 5}.72and 10 cFR 50.73." The inspectors reviewed PBAPS's operator narrativelogs, operability assessments, MR records, maintenance WOs, condition reports, eventreports, anO l..tRC integrated inspection reports to validate the accuracy of thesubmittals.Enclosure b.a..328FindinqsNo findings were identified.Occupational Exposure Control Effectiveness (71151- 1 Sample)lnspection ScopeThe implementation of the Occupational Exposure Control Effectiveness Pl Programwas reviewed. The inspectors selectively reviewed CAP records for occurrencesinvolving HRAs, VHRAs, and unplanned personnel radiation exposures since the lastinspection in this area and the previous four complete quarters. The review was againstthe applicable criteria specified in NEI 99-02, "Regulatory Assessment Pl Guideline,"Revision 6. The purpose of this review was to verify that occurrences that met NEIcriteria were recognized and identified as Pls.FindinosNo findings were identified.RETS/ODCM Radiolosical Effluent Occurrences (71151- 1 Sample)lnspection ScopeThe implementation of the RETS/ODCM Pl was reviewed. The inspectors selectivelyreviewed CAP records and projected monthly and quarterly dose assessment resultsdue to radioactive liquid and gaseous effluent releases; for the past four completequarters. The review was against the applicable criteria specified in NEI 99-02,"Regulatory Assessment Pl Guideline," Revision 6. The purpose of this review was toverify that occurrences that met NEI criteria were recognized and identified as Pls.As part of this review, the inspectors also reviewed Exelon's evaluations and public doseassessments, as necessary, associated with identification of localized onsite groundwater contamination within the restricted area.FindinosNo findings were identified.ldentification and Resolution of Problems (71152 - 4 samples)Routine Review of Pl&R Activitieslnsoection ScopeAs required by Inspection Procedure71152, "Problem ldentification and Resolution,"the inspectors routinely reviewed issues during baseline inspection activities and plantstatus reviews to verify that PBAPS entered issues into the CAP at an appropriatethreshold, gave adequate attention to timely corrective actions, and identified andaddressed adverse trends. In order to assist with the identification of repetitiveequipment failures and specific human performance issues for follow-up, the inspectors.4b.40.p.2.1a.Enclosure b.29performed a daily screening of items entered into the CAP and periodically attended CRscreening meetings.Findinqs and ObservationsNo findings were identified.(71152 - 1 annual.2b.sample)Inspection ScopeThe inspectors reviewed the CRs and the corresponding corrective actions from the lastRFO on Units 2 and 3. The inspectors interviewed key site personnel regarding theincidents and changes to the refueling process. The inspectors evaluated effectivenessof the corrective actions, EOC, and station personnel knowledge of the processchanges. The inspectors reviewed Peach Bottom procedures related to FH and therecenl training provided to the FH personnel. The inspectors assessed Exelon'sproblem ident-ification threshold, cause analyses, EOC reviews, compensatory actions,and the prioritization and timeliness of corrective actions to determine whether Exelonperson nel were appropriately identifyi ng, characterizi ng, and correcti ng problemsassociated with this issue, ahd whether the planned or completed corrective actionswere effective. The inspectors compared the actions taken to the requirements ofExelon's CAp and 10 iFR Part 50, Appendix B, "QA Criteria for Nuclear Power Pantsand Fuel Reprocessing Plant." In addition, the inspectors performed in plant walkdownsand interviewed site p6rsonnel to assess the effectiveness of the implemented correctiveactions.The inspectors reviewed Peach Bottom's process to identify, prioritize-, and resolverefuel floor distractions in an attempt to minimize operator burdens. The inspectorsobserved Exelon personnel conducting fuel movement in the reactor vessel during theSeptember 2011 Unit 3 RFO.Findinos and ObservationsNo findings were identified.The inspectors determined that the Exelon corrective actions were comprehensive andimplemented in a timely fashion. Specifically, the just-intime training of the FH crewswas performed at the sjte prior to the Unit 3 outage. The inspectors observed. goodcommunications between the FH crew members during fuel movement' The inspectorsobserved a constant management presence during FH activities. The inspectorsobserved that plant personnel involved with the FH activities were knowledgeableregarding the previous FH events and associated corrective actions. The inspectorsobserved a strong commitment toward zero FH events.The inspectors observed that the revised Potential Obstruction Compensatory Plan'compleied the day before the FH and core verification, would have provided morebenefit to refueling personnel if it had been updated at the start of the Unit 3 RFO. Therevision to the plan'was a corrective action determined from the FH events during the2010 Unit 2 RFO.Enclosure 30.3Review of the Units 2 and 3 Spent Fuel Pool (SFP) Boraflex Deqradation CorrectiveActions (71152 - 1 annual sample)lnspection ScopeThe inspectors assessed Peach Bottom's historical SFP shutdown margin. Theinspectors compared Exelon's SFP Boraflex CAP documentation and 10 CFR Part 50,Appendix B, 'QA Criteria for Nuclear Power Plants." The SFP criticality calculationslisted in lR 1225840-13 were evaluated to determine the significance of the Boraflexdegradation. The Exelon SFP Boraflex technical evaluation was reviewed to determineif the SFP TS sub-criticality margin remained less than
b.31Findinos and ObservationsNo findings were identified.Based on the overall review of the selected sample, the inspectors concluded thatpBApS was appropriately identifying and entering issues into the CAP, adequatelyevaluating the identified issues, and properly identifying a.dverse trends before theybecame riore safety significant problems. However, the inspectors did note the threeadverse trends discussed below'Human performance and configuration control continued to be focus areas for PBAPSduring the second half of 2011. PBAPS identified four configuration control events fromJune-1 through December 1, 2A11, (lRs 1234874 (two events), 1245157, a1! 1271883);seven total in 2011, and five configuration control events were identified in 2010' Acommon cause analysis (ccA) was performed in June of 201 1 (lR 1203953.), and aConfiguration Control Recovery Team was implemented to focus on correcting theadverle trend. Since July 1, two additional configuration control events were noted.None of the configuration control events in 2011 resulted in significant consequences.lndustrial safety issues continue to challenge PBAPS. There were three OccupationalSafety and Heilt6 Administration recordable injuries in September of 2011 (lRs12616gg,1264502, and1265372). Additionally, there were 45 first aid events during'theSeptember and October 2011Unit 3 RFO (P3R18). PBAPS identified this negativetrend, and has performed a CCA to address the adverse trend in industrial safetyperformance during P3R18 (\R1277414). The inspecto_rs noted that PBAPS hasferformed additionil causal investigations in the area of industrial safety performance:a CCA was completed in April of ZOtl to address an inadequate trend in industrial safetyperformance between January 1 and April 25 of 20]l (lR 1203002): and an ApparentCause Evaluation was completeO in November of 2011 in response to Nuclear OversighttruOSl identifying pBAPS's failure to complete actions to address unsatisfactoryperformance from 2010 in the area of industrial safety'The inspectors identified an adverse trend in the area of equipment reliability. Duringthe review period from June 't to December 1, 2011, PBAPS submitted five licenseeevent reports (LERs) related to degraded or failed equipment, and also noted a sixthequipment reliabilitY issue:o Failed Relay Results in Unplanned EDG Actuation during Surveillance Testing(LER 0500 0277 l2O1 1 -003-00)o EDG Oil Leak (LER 0500027712011-004-00)o Hardened Grease in a Safety-Related MOV (LER 05000278/2011-001, this findingwas documented in Section 1R12 of this report)o Leaking Relief Valve in the RHR System (LER 0500027812011-002-00). Actuator Diaphragm Thread Seal Leakage in an Automatic Depressurization SystemSafety Relief Valve (SRV) (LER 05000278i2011-003-00). Repeiitive Leaks on the Unit 3'B'RWCU System (lR 1281888)The inspectors verified that all of the equipment issues identified above have beenentered into the PBAPS's CAP.Enclosure 32.5Actions(71152- 1 annual samPle)Inspection ScopeThe i"spectors 'eviewed licensee actions to resolve vital bus degraded voltageprotectibn issues. The inspectors selected lR 01 119440 as a Pl&R sample for a detailediollow-up review because it tracked the analysis and disposition of the issue' Therewere numerous lRs associated with the vital bus degraded voltage protection issue. Asdocumented in NRC Inspection Report 0500027712008007 and 0500027812008007, anunresolved item (URl) was opened to determine whether the approved PBAPS licensingbasis included the use of automatic load tap changers (LTCs) to protect the vital"r"tg"n.y buses from unacceptable low voltage co1d!!i91s during a design basisLOCA. As documented in inspection report 0500027712010004 and 0500027812010004,the NRC, Region l, requested that a formal review (task interface agreement (TlA) 2009-007) be cond-ucted Oy tfre NRC, Nuclear Reactor Regulation to resolve the issue' Thelnaf ttn response determined that PBAPS license basis for degraded voltage relayiettings did not include credit for the LTCs on the startup transformers to protect theclass"l-E safety-related equipment during a design basis LocA. The inspection reportalso closed the URI and enforcement action was documented. The licenseesubsequently issued LER 2010004-00 which was reviewed by the Nfp and closed asdocumentedin inspection report 0500027712010005 and 0500027812010005 with noadditional enforcement action.The inspectors assessed Exelon's problem identification threshold, EOC reviews,operabiiity evaluations, technical evaluations, modification packages, a1d interimcompensatory measures. The inspectors also assessed Exelon's prioritization andtimeiiness of corrective actions to determine whether Exelon was appropriatelyidentifying, characterizing, and correcting problems associated with the identified issueand whether the compleieO or planned c-orrective actions were appropriate to preventrecurrence. Additionally, the inspectors performed walkdowns of accessible portions ofaffected motor control ienters (lrrtCCs) and components to assess if abnormal conditionsexisted. The inspectors also interviewed plant personnel to gain insights regarding theidentified issues and implemented or planned corrective actions'Findinqs and ObservationsNo findings were identified.The inspectors determined that Exelon properly implemented their CAP regarding theinitial discovery of the reviewed issue. The lR package was complete and included'operability evaiuations, technical evaluations, interim compensatory measures, EOCreviews, and contained implemented and planned corrective actions. Additionally, theelements of the lR, technical evaluations, and operability evaluations were detailed andthorough. lmplemented and planned corrective actions appeared appropriate tominimiie the potential of recurrence. The inspectors determined that corrective actionsincluded performing an operability evaluation, which included electrical calculations thatused the most limiiing uoitrg" level allowed by the TS (excluding the LTC), identifyingcomponents that wou"ld not-have adequate voltage to operate under the identified.ondition, implementing interim compensatory measures (revising operationsprocedures and operaior training) to operate equipment that would not have adequatea.b.Enclosure 33voltage to operate in the design basis LOCA, and creating and implementingmodification packages for MOVs and MCCs to allow equipment to operate under theanalyzed condition. The inspectors found the operability evaluation and interimcompensatory measures reasonable. Exelon had completed all modificationsassociated *itn ftlOvr and MCCs that would not have adequate voltage during a designbasis LOCA.Additional corrective actions included performing an evaluation of vital buses at a lowervoltage (3737 volts) than the TS lower limit for the function four LOCA relay setting. Thisanalysis'was perfoimed to identify equipment needing margil impro.vement, butremiined operable for the TS function four relay setting band. The inspectorsdetermined that Exelon had completed modifications on some of the equipmentidentified in the analysis and had scheduled modifications on the remaining equipmentidentified..6 ldentification and Resolution of Problems (71124.01,71124'Q2,71124'03,71124'04,71124.05,71124.06)a. lnspection ScoPeThe inspectors selectively reviewed corrective action documents for occupationalradiation safety program and effluent and environmental monitoring program' Seedocuments reviewed.The review was against criteria contained in 10 CFR ParI20, TSs, ODCM, andapplicable station audit and surveillance procedures'b. FindinqsNo findings were identified.(71153 - 4 samples)(closed) LER 05000277/2011003-00: Delayed Relay operation Results in E-3 EDGActuation during Surveillance TestingOn Septem ber 21, 2011, during the P3R18 RFO, an unplanned, valid actuation of theE-3 EDG occurred during surveillance (functional) testing of the E-33 4 kV emergencybus undervoltage relays.- The E-3 EDG started unexpectedly when time delay relay3-54-1g3-1708 did noi operate properly, resulting in a delayed E-33 bus fast-transferbetween the TS off-site sources. This delay resulted in the operation of an additionalundervoltage relay and thereby caused a valid actuation of the E-3 EDG on low voltage'Because the E-33 bus delayed fast transfer occurred prior to the EDG reaching fullspeed and voltage, the EDG output breaker was not required to close.The cause of the event was due to the failure of the 3-54-183-1708 time delay relay topioperty tunction. The relay was replaced and tested satisfactorily. There was no actualsafety consequences assoiiated with this event. PBAPS entered this item into the CAPfor additional evaluation and investigation. The inspectors determined that there was noperformance deficiency associated with the failed relay. This LER is closed.40A3.1Enclosure 34.2(Ctosed) LER 05000277/2011004-00: Oil Leak Resulting in E-1 EDG lnoperabilityOn September 23,2011, during the P3R18 RFO, an oil leak was discovered on the E-1EDG when the engine was being shutdown during 4kV emergency bus lesting. The leakwas determined to be from a crack on the lube oil drain line for the combustion air intakeblower (supercharger). Analysis determined that the leak previously existed and theEDG would not have been able to perform its safety function to successfully run for a24-hour mission time.pBApS determined that the cause of the event was ineffective maintenance practices,and the drain line should have previously been replaced during maintenance activities.The leaking drain line was replaced on September 23,2011, and the E-1 EDG wastested suciessfully with no leaks in the drain line. PBAPS entered this issue into theCAp, performed EOC inspections, and took corrective action to revise the associatedmaintenance procedure. The enforcement aspects of this LER are discussed in Section4OA7. This LER is closed.(Ctosed) LER 05000278/2011001-00: Containment lsolation Valve Inability to Close fora Design Basis Event due to Degraded LubricantOn Septem ber 22, 2011 , during the P3R18 RFO, it was identified that the ability of theUnit 3 RWCU outboard isolation valve (MO-3-12-018) to close was degraded due to amotor-operator greasing deficiency. This deficiency was identified during performanceof routine MOV maintenance and diagnostic testing. lt was determined that thiscondition was prohibited by TSs since this primary containment isolation valve wasdetermined to be inoperable for containment isolation purposes during the previousoperating cycle for a time period longer than allowed by TS. The cause of the greasingdeficienjy was due to inadequate lubrication. The valve was repaired on September 23,2011. There was no actual safety consequences associated with this event. Theenforcement aspects of this LER are discussed in Section 1Rl2' This LER is closed.(Ctosed) LER 05000278/201 1002-00: RHR Leaking Relief Valve Results in ConditionProhibited by TSOn September 19, 2011, during the P3R18 RFO, Engineering personneldetermined thata leak on the inlet connection to the'D' RHR suction piping thermal relief valve was dueto cracking of the relief valve body and not due to a mechanicaljoint leak as originallyidentified -uring cycle 18 operations on April 27 , 2010. On April27 , 2010, PBAPSidentified the leik to be one drop per two minutes, and incorrectly determined that theleak was from a threaded connection. Subsequent non-destructive evaluation followingthe September 19, 201 1 determination confirmed the leak to be through the relief valvebody. Based on analysis, PBAPS determined the relief valve could have becomedetjched from the piping during the worst case design basis seismic event' Thiscondition would resuit in tfre 'D; RHR pump being inoperable, thereby affecting theRHR low pressure coolant injection function.pBApS determined the cause of the delay in identifying the inoperable condition wasdue to inadequate technical rigor when evaluating the operability of the relief _valve onApril 27, 2010. The leaking relief valve was replaced on October 2,2011. EOC reviewswere performed for similar components in Unit 2 and Unit 3. Operations has instituted.3.4Enclosure a.35additionaltraining and procedure revisions to drive improved performance regardingoperability evaluitions. There were no actual safety consequences as result of thisevent. This event was considered as a condition prohibited by TSs and loss of safetyfunction. The enforcement aspects of this LER are discussed in Section
lnspection ScoPeThe inspectors selectively reviewed routine operational surveillance data, includingradiological surveillance,ior the Independent Spent Fuel Storage Installation (lSFSl)facility. The inspectors toured the facility and made independent radiationre"rur"rents of the facility. The data was evaluated against 10 CFR Part 20 andapplicable Exelon Procedures.FindinqsNo findings were identified..2a.Enclosure 364046 Meetinqs. lncludinq ExitQuarterlv Resident Exit Meetinq SummarvOn January 20,2012, the resident inspectors presented the inspection results toMr. Thomas Dougherty and other PBAPS staff, who acknowledged the findings.Mr. P. Krohn, Cniet, U-SrunC, Region 1, Division of Reactor Projects, Branch 4,attended this quarterly inspection exit meeting. The inspectors verified. that noproprietary informatioh was retained by the inspectors nor documented in this report'4C,A7 Licensee-ldentified ViolationsThe following violations of very low safety significance (Green) were identified by thelicensee "nd-rr" violations of runC requirem-ents which meet the criteria of the NRCEnforcement Policy for being dispositioned as NCVs'. TS b.4.1 states, in part, that written procedures shall be implemented a1d maintainedas recommended ln nC 1.33, Appendix A, November 1972. RG 1'33, Appendix A'Section l, "procedures for Performing Maintenance," subsection 1, states thefollowing: "Maintenance which can affect the performance of safety-relatedequipm6nt should be properly preplanned and performed in accordance with writtenprocedures, documenied insiructions, or drawings appropriate to the circumstances'bkill, nottally possessed by qualified maintenance personnel may not requiredetailed step--by-step delineition in a procedure." Contrary to the aboye,. PBAPSdid not properly preplan and perform maintenance which affected the E-1 EDG'Specifically, pAApd determined that a damaged lubricating oil drain line should havebeen identified and replaced during planned maintenance activities prior to theoccurrence of leakage. As a consequence of not identifying and replacing thedamaged drain line,-pBAPS determined that the E-1 EDG was unable to perform its24-hour mission time, and therefore was inoperable, during the period of timebetween April27 , 2011, and September 23, 2011'The finding was determined to be of very low safety significance, for both PeachBottom Units 2 and 3, in accordance wit-h lMc 0609, Appendix A, "Delgrlnining theSignificance of Reactor Inspection Findings for At-Pow-er Situations" (lMC 06094)uslng SDp phase s 1,2 and 3. Phase 1 screened the finding to Phase 2 becauseit reiresented a loss of the E-1 EDG safety function, between April27 andSepiember 23,2011 (149 days), longer thln the TS limiting condition for operation(Lco) of 14 dayi. A ilegion i senioi Reactor Analyst (SRA) conducted a Phase 3analysis because the Phlse 2 analysis, conducted by.the inspectors using- the PeachBottom pre-solved Risk-lnformed lnspection Notebook, indicated that the findingcould be more than very low significance'The SRA used the peach Bottom Standardized Plant Analysis Risk (SPAR) model,Revision 8.19 and 8.17, for units 2 and 3 respectively and SAPHIRE 8 to conductthe phase 3 analysis, with the conservative assumption that the E-1 EDG would nothave operated at all for its 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> mission time over the 149 day exposure period'This analysis was conservative given the EDG could have operated for over twohours assuming that the drain line broke and the potential that operators could havetemporarily limiied the leakage from the supercharge lube oil drain line. ThisEnclosure 37analysis indicated an increase in core damage frequency (ACDf) forinternalinitiaiing events in the range of one core damage accident in 2,500,000 years ofreactor operation, in the low E-7 range per year for each unit. The dominate coredamage sequences included losses of offsite power with the failure of all EDGsresulting in a station blackout (SBO), followed by the failure of operators to reducedirect current loading to allow extended operation of the RCIC system alq -depressurize the realtor, and with inability to recover offsite power, the SBO sourceof power from the Conowingo Dam or an EDG in two hours. In accordance with IMCOObgR, for a finding with an internal events ACDF above 1E-7, the SRA assessedthe impact of the tinOing on: 1) External events such as fire, seismic and flooding,determining, using the external events portion of the Peach Bottom Unit 2 and 3SpAR modlls, tfrit tne total ACDF (internal plus external) would not be above the1 E-6 threshold; and 2) the increase in large early release frequency (ALERF)'determining that given the operators ability, following core damage, to recover offsitepower and depressurize and inject water to the reactor from low pressure sourcesand to flood the containment that the ALERF was in the low E-8 per year range'Because this finding is of very low safety significance and has been entered intoExelon's CAp under lR 1266b37, this violation is being treated as a Green, licensee-identified NCV consistent with the NRC Enforcement Policy.. TS LCO 3.5.1, Condition A, requires that one inoperable low pressure ECCSinjection subsystem should be iestored to an OPERABLE status within seven daysduring operatibnal modes 1 and 2, or requires action to place the unit in operationalmode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Contrary to the above, the 'D' LPCI pump was inoperableduring a period of time between April27,2O1O, and October2,2011. Specifically'pBApS determined that the leaking relief valve body, as identified on April 27,2010,could have become detached from the 'D' RHR suction piping during the worst casedesign basis seismic event. This condition would result in the 'D' RHR pump beinginop6rable, thereby affecting the RHR LPCI function. Because the 'B' RHR pumpwas unaffected by this even-t, there was no total loss of the 'B' LPCI train safetyfunction. The inspectors determined that this event screens to Green using theTable 4b seismic screening criteria in Attachment 4 of IMC 0609, "SDP." Becausethis finding is of very low sifety significance and has been entered into Exelon's CAPunder lR i264g09, ihis violation iJbeing treated as a Green, licensee-identified NCVconsistent with the NRC Enforcement Policy'ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Exelon Generation Companv Personnel
- T. Dougherty, Site Vice President
- G. Stathes, Plant Manager
- J. Armstrong, Regulatory Assurance Manager
- T. Moore, Site Engineering Director
- P. Navin, Operations Director
- J. Kovalchick, SecuritY Manager
- P. Cowan, Work Management Director
- B. Reiner, ChemistrY Manager
- R. Holmes, Radiation Protection Manager
- J. Bower, Training Director
- B. Hennigan, Operations Training Manager
- R. Shortes, Radiological Engineering Manager
- J. Stenclik, Chemistry SuPervisor
- H. McCrory, Technical Support Manager
- R. Reiner, Manager, Chemistry, Environmental and Radwaste
- C. Crabtree, Senior Environmental Chemist
- D. Dullum, RegulatorY Assurance
- N. Burkins, lnstrument SuPervisor
- M. Pawlowski, Radwaste ShiPPer
- M. Ballew, Radiation Protection Supervisor
- E. Schwartz, Chemist
- R. Ridge, Instrument PhYsicist
- D. Hornberger, Radwaste Chemist
NRC Personnel
- P. Krohn, Branch Chief
- S. Hansell, Senior Resident Inspector
- A. Ziedonis, Resident InsPector
- S. Barr, Sr. Emergency Preparedness Inspector
- E. Miller, Project Engineer
- R. Nimitz, Senior Health PhYsicist
- J. Tomlinson, OPerations Engineer
- K. Young, Senior Reactor Engineer
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened/Closed05000278/201 1 005-01NCVUntimely Corrective Action to Correct MOVDegraded Stem Lubrication(Section 1R12)Attachment
A-2
Opened
Closed
- 050002771201 1003-00050002771201 1004-0005000278/201 1 001 -0005000278/2011002-000500027712011502-010500027812011502-010500027712011502-02
Discussed
0500027712010004-01FINFailure to Establish, lmplement, andMaintain Adequate QA forEffluent and Environmental Monitoring(Section 2RS06)Delayed Relay Operation Results in E-3EDG Actuation during Surveillance Testing(Section 4OA3.1)Oil Leak Resulting in E-1 EDG Inoperability(Section 4OA3.2)Containment lsolation Valve lnability toClose for a Design Basis Event due toDegraded Lubricant(Section 4OA.3)RHR Leaking Relief Valve Results inCondition Prohibited bY TS(Section 4OA3.4)(Traditional Enforcement) Changes tofRt gasis Decreased the Effectiveness ofthe Plan without Prior NRC Approval(Section 4OA5)Changes to EAL Basis Decreased theEffectiveness of the Plan without Prior NRCApproval (Section 4OA5)Non-conservative TS and Potential Non-Compliance Associated with Degraded SFPBoraflex Panels (Section 40A2'3)LERLERLERLERNCVURIFINAttachment
A-3
LIST OF DOCUMENTS REVIEWED
- -- lndicates NRC-identified
Section 1R01: Adverse Weather ProtectionProceduresRT-l{66200-2, Heat Trace System Testing, Revision 9, Completed 09/01/1'tRT-l-066-200-2 (partial pMT) i{eat Trace System Testing, Revision 9, Completed 10105/11RT-O-040-620-2, Outbuilding
- HVAC and Outer Screen Inspection for Winter Operation,Revision 16, ComPleled 11113111RT-O-040- 630-2, Winterizing Procedure, Revision 1 2, Completed 1 1 l 1 21 1 1CRslR
- 941208, Trash Racks Need to be ReplacedlR
- 1078304-10, 2010-201 1 Winter Readiness CritiquelR
- 1165388, Request for AR to Support Trash Rack ReplacementlR 1
- 197180, 201
- 1-2012Winter Readiness Tracking AssignmentslR
- 1201542,Heater Fan Still Running with control Switch in offlR
- 1239380, HeatTrace Exposed with No Insulation on ValvelR
- 1239385, Heat Trace Missing Insulation on ValvelR
- 1239394, lnsulation Falling Apart on valve Hv-2-278-26113lR
- 1241418, Winter Readineis Attachment 3 Plant Manager Approval Overdue (06/30/1 1)lR
- 1242337, Conduit if Broken Off due to Steam LeakslR
- 1244622, ZOll-ZOlZ Winter Readiness Tracking Assignments (Snow)lR
- 1250769, Unlt Z Condensate Storage Tank Low Level Alarm Challenges HPCI/RCICOperabilitYlR 125g2b6, Administration Building Heat Trace Alarm PanelAll Circuits in AlarmlR
- 1258267, RT-l-066-200-2 UnsatlR 127726gj,, ZAEI29 Thermostat Cover is Broken / Temp Adjustment Knob is MissinglR
- 1278940, 3AE1 54 Unit Heater Will Not EnergizelR
- 1283033, Louver #1 at unit 2 circ Pump structure MissinglR
- 1283034, Louver #2 at Unit 2 Circ Pump Structure could Not be operatedlR
- 1283323, Lo* Temperature at Main Stack Radiation Monitor BuildinglR
- 128401 1, Torus Lining Project RCA Exit Trailer (Mini Mobile) No HeatlR
- 1284600, Roof Exhauster Dampers Will Not CloselR
- 1284613, Roof Exhauster Dampers Will Not CloselR
- 1284621, Fan Will Not StartlR
- 1284689, Deicing Sparger Broken Under WaterlR 12gg743, Docurieni Unsat Sign-off on Winterization Routine Test due to ClearancelR
- 1291388, 201
- 1-2012 Winter Readiness Certification Letter ApprovallR
- 1296229, Winter Readiness Open ltems Not Complete Prior to 121Q1111WOs / Action Requests41?80640{1, Request Deferral to Complete RT-l-066-200-3A1794038-04, Plan Activity for Temporary Power and Lighting to Mini Mobile TrailerA1803090, Unit 2 Circulating Water Pump Structure Louvers and ScreensA1815797, Unit 2 Circ Bay lntake Dampers Require RebuildC0231975-13, Install Heat Trace per
- ECR 10-00055Attachment
- A-4Miscellaneouspeach Bottom Certification LetterforWinter Readiness, dated November 15,2011
Section 1R04: Equipment AliqnmentProceduresTSG 4:1, peach Bottom Station Operational Contingency Guidelines, Revision 18CRstn
- ZOS+ZS-08 and Attachments 1-3 and 6-8, Engineering Computations and
- TRT 08-029 forTSG 4.1 ChangeslR
- 1268445, Valve Actuator Would Not Go Into Manual ModeDrawinosM-361, Sheet 1, RHR System P&lD, Revision 81MiscellaneousIMC 0609, Appendix L, B.5.b SDPNRC Safety Lvaluation Related to Order
- EA-02-026, Docket Numbers 50-277 and 50-278'Section 3.4.9: Inject Water into the DrywellTemporary lnstruction ZSlSt171, Verification of Site Specific lmplementation of B.5.b Phase 2and 3 Mitigation Strategies, Revision 1
Section 1R05: Fire ProtectionProceduresEP4A-1007, Radiological
- EP Annex for PBAPS, Revision 22pF-48, Unit 2 RadwaJte Building, RBCCW Room - Elevation 116'-0 inch, Revision 4PF-4C, Radwaste Building; Unit2 Recirculating Pump MG Set Room - Elevation135'-0", Revision 7PF-144, Circulating Water Pump Structure - General Area, Revision 4CRs.tn tZZOOO0, Review Criteria for Table H2-Vital AreaMiscellaneousNEI 99{1, tvlethod for Development of Emergency Action Levels, Revision 5ProceduresRequalification Scenario Guide, PSEGl 11 1R, Revision 1Section 1 R12: Maintenance EffectivenessProceduresCH-10, ChemistrY Goals, Revision 16CY-AB-120-100, Reactor Water Chemistry, Revision 12Cy-pB-120-100, Reactor Water Chemistry - GEH Fuel Warranty Limits, Revision 0sT-c-o95T-103, Sheet 1, Secondary Containment ControlER-AA-302-1004, MOV Performance Trending, Revision 6Attachment
- A-5CRstA lZnZA& Unit 3 RWCU System Secured due to Steam LeaklR
- 1279788, Potential Small Unit 3 Main Condenser Tube LeaklR
- 1279935, Unit 3 Reactor Water lnfluent Conductivity Step Change TrendslR
- 1280025, Unit 3 RWCU System Secured due to LeaklR
- 1280255, Action Level 1 Entered for Unit 3 Reactor ConductivitylR
- 1280228, 'B' RWCU Pump Discharge Block ValvelR
- 1280406, lssue to Track 90 Days Completion for TClR
- 1281063, Rejectable Indication Found on Unit 3 RWCU PipinglR
- 1281385, Leak Observed at "T" WeldlR
- 1281888, Action Level 1 Entered For Unit 3 Reactor ChlorideslR
- 1281989, Unit 3 RBCCW High Radiation AlarmlR
- 1289399, Request to Provide Engineering with Vibration DatalR
- 1290153, Root Cause Manpower InadequatelR
- 1295254, Request for cMo to obtain RWcu Piping Vibration DatalR
- 1295469, Request Work Management Create Unit 3 'B' RWCU Online Work WindowlR
- 892191-08, Root Cause Evaluation - MOV Degraded Stem LubricationlR 10970g5, Nuclear Event Report 10-047-Y MOV Failure due to Degraded Stem LubricationlR
- 1266604,
- MO-3-12-018 As-Found UnderthrustlR
- 1266600 ,
- MA4-12-018 Operator Grease Condition UnsatisfactorylR
- 1277605, MOV Program Health Declined to Yellow in Third Quarter 2011tR
- 1296205 ,
- MO-2-23-024: Per'form Valve PM in 1203 Instead of 1303MiscellaneousT04336, Peach Bottom License Renewal chemistry commitmentsUnified Control Room Log, Sunday, October 16,2011, Night ShiftUnified Control Room Log, Tuesday, October 18,2011, Day ShiftUnified Control Room Log, Saturday, October 22, 2011, Day ShiftUnified Control Room Log, Sunday, October 23,2011, Day ShiftProceduresSO SZn.t.B, Diesel Generator Operations, Revision 48sT-o-052-702-2, E-2 Diesel Generator 24-Hour Endurance TestCRslR
- 1220521 Failure of Unit 3 APRM #1 214 VoterlR 1230g41, Five critical component Failures Due to Reactor Nuclear Instrumentation overPast YearlR
- 1286163,
- APRM-LM-3-PB3 2l4Logic Module Did Not Drop Out RPS LogiclR
- 1286435, A2 Channel/zscram during APRM Logic Module RepairlR
- 1287120, APRM Voter Card Failures - Need Accelerated ReplacementlR
- 1144694, Operating Experience Review: EDG Voltage Regulator Inspection lmprovementlR
- 1287186, EDG Voltage Not RespondinglR
- 1287282, Clearance and TaggingDrawinqsE-+tg, Sleet2, Standby Diesel Engine Generators, Revision 17Attachment
- A-6MiscellaneousUnfied Control Room Log, Friday, November 4,2Q11, Day ShiftSection 1 Rl 5: Operabilitv EvaluationsProceduresNF+B-l3F 1 42O,Establishing Channel Distortion Monitoring Populations, Revision 0CRslnlZSql55-04, Operability Evaluation 11-03, Seismic Effects on NWR Control Rod SCRAM atLow Reactor Pressures, Revision 0lR
- 1254155, Part 21
- SC 11-04 Seismic lmpact on Channel DistortionlR Q54A27, Title: Part2l
- SC 11-04 Seismic lmpact on Channel DistortionlR
- 1270659, Failure to lnclude Seismic Input in Channel-Blade GuidancelR
- 1267512,
- CHK-3-164-332058 Leaks ThroughlR
- 1267639,
- HV-3-164-33170C Has Through-Seat LeakagelR
- 1267641 ,
- CHK-3-16A-33205C Leaks ThroughtR
- 1268076,
- RV-3-02-071 B Failed Leak Test during sT-M-o1G-600-3Drawinotrrt-Agg, Sheet 1, Instrument Nitrogen, Revision 37M-851, Sheet 1, Nuclear Boiler, Revision 37MiscellaneousME-213, ADS SRV Air Accumulator SizingUnified Control Room Log, Monday, October 3,2Q11, Day Shift
Section 1R18: Plant ModificationsCRsttf. tZgOgZ2,
- ECR 10-00449 HPCI Cable Incorrectly RoutedDrawinqsffir'eet2,RacewayLayoutRB,Unit3,Area16,Elevation135'-0inch,Revision 77E-1236, Sheet 3, Raceway Layout RB, Unit 3, Area 16, Elevation 135',-0 inCh,Revision 77M-1-5-36, Sheet 22,Electrical schematic Diagram HPCI, Revision 77Miscellaneouspeach Bottom Fire Protection Plan, Section 5.1, Analysis and Capability to Achieve SafeShutdown, Revision 16peach Bottom Fire Protection Plan, Section 5.2, Description of Reactor Shutdown Methods,Revision 16Peach Bottom Fire Protection Plan, Section 5.3'11, Fire Area 135, Revision 18NRC Event Notificatio n
- EN 47442.. peach Bottom 8-hour Non-Emergency Event Notification forHpCl System Steam Supply Valve Cable Unprotected during Postulated Fireunified control Room Log, Tuesday, November 15,2011, Night shiftAttachment
- A-7
Section 1R19: Post-Maintenance TestingProcedures51-9-976-470-3,
- MSIV Closure Timing, Revision 16, Performed 10/03/11ST-O-054-752-3, E-29 4kV Bus Under Voltage Relays and LOCA LOOP Functional Test andE-234 Alternative Shutdown Control Functional Test, Revision 22, Performed 10105111ARC 30C208L A-2, Turbine Vibration Thrust High, Revision 18ARC 20C208L A-2, Turbine Vibration Thrust High, Revision 10SI-3N-60A-APRM-31FS, Functional Check of APRM 3RT-O-052-251-2, E1 Diesel Generator lnspection Post-Maintenance FunctionalTest,Revision 21, Performed 11120111M-004-400, Reactor Pressure Vessel Reassembly, Revision, 29CRs\R1262081, MSIV Stroke Times UNSATlR
- 1271818, 'A' Inboard MSIV Stroke TimelR
- 1271823, 'A' Outboard MSIV Stroke TimelR
- 1271825,'D' Outboard MSIV Stroke TimelR
- 1271826, 'B' Inboard MSIV Stroke TimelR
- 1271827,'D' lnboard MSIV Stroke TimelR
- 1271849, 'C' Inboard MSIV Stroke TimelR
- 1272231, NOS lD: SRO OP Basis/lR's for MSIV Stroke Times lmprovementlR
- 1272796, NOS lD: "Reportable Basis" Determination in lR
- 1262081 is LTAlR
- 1274027, 'D' lnboard MSIV Stroke TimelR 127230i, 3 'A' I 3'C' Battery Ground When Emergency Transformer Switch S38 OperatedlR
- 1272310, E-3 Diesel Generator Stator Cooling High Winding Temperature AlarmlR
- 1271137, PMM1 Activity Needed to Support 3BD003 to Alternate SourcelR
- 1271368, Documentation of an Alternate compensatory MeasurelR
- 1276633, Unit 3 Main Turbine Tripped due to High VibrationlR
- 1276861, 4.0 Crew Critique of Unit 3 PB Main Turbine Startup after P3R18\R1276862, Unit 3 Main Turbine Tripped due to High VibrationlR
- 1276962, Unit 3 Main Turbine Tripped due to High VibrationlR
- 1276988, MCR Vibration Alarm
- ARC-305 A-2 AlarmedlR
- 1277000 Unit 3 Main Turbine Tripped due to High VibrationlR
- 1277081, Turbine Bearing Metal High Alarm Received on unit 3lR
- 1279264, PSO4 End-of-shift critique for Dayshift october 17 - 20lR
- 1279985, Loose Terminations in Panel 38C114lR
- 1278641, NER
- NC-1 1-038 - Browns Ferry MOV Failure LessonstR
- 1296131, MOV Operator Inspection in Response to Operating Experience lPart2llR
- 1286163,
- APRM-LM-3-PB3 214 Logic Module Did Not Drop Out of RPS LogicDrawinqsM-833, Sheet 1, Instrument Nitrogen, Revision 37M-851, Nuclear Boiler, Revision 37WOs / Action RequestsC0240372,Investigate and Repair as RequiredAttachment
- A-8MiscellaneousOutage Control Center Log, Friday, October 7, 2011, NightUnified Control Room Log, Tuesday, October 4,2011, DayshiftTS 3.8.1MAT
- PB 09-0533-3: LP Turbine Retrofit Mod Acceptance Test, Performed 10114-1712011Unified Control Room Log, Friday, October 14,2011, Day ShiftUnified Control Room Log, Friday, October 14,2Q11, Night ShiftUnified Control Room Log, Saturday, October 15,2011, Night ShiftUnified Control Room Log, Saturday, October 15, 2011, Day ShiftUnified Control Room Log, Sunday, October 23,2011, Day ShiftExelon Nuclear MOV Program MOV Post-Test Data Review Worksheet,
- MO-2-10-154B, TestDate 05/18/1 1WO R1161992-07,
- MO-2-10-1548-OP As-Left Diagnostic TestM-21 3, Automatic Depressurization System Accumulator Sizing
==Section 1R20: Refuelinq and Other Outaqe ActivitiesProceduresSA-AA-111, Heat Stress Control, Revision 8T-103, Secondary Containment Control, Revision 17CRslR
- 1271280, Additional Oversight Needed for Future Outages"lR 1271674,==
- NRC Resident lnspector-ldentified Loose ConduitlR
- 1271780, RHR
- RV-3-10-072D Leakage Operability Determination\R1272329, MSIV
- AO-3-01A-080D PMT Diagnostic UNSATlR
- 1274674, HPCI Piping Needs Additional VentinglR
- 1277414, Industrial Safety Events during P3R18 Were UnsatisfactorylR
- 1271889, P3R18 MSRV/MSSV As-Found Lift Test ResultslR
- 1271909, Threshold for Entering Near Misses in CAP May be Too HighlR
- 1273083, Adverse Trend in FME EventslR
- 1273354, P3R18 Drywell Critical Insulation lnspection ResultslR
- 1274320, 40-3-02-021 Penflex Conduit Needs ReplacedlR
- 1274322, Penflex to Temperature Monitor DetachedlR
- 1274325, Penflex to 71A SRV DetachedlR
- 1274328, Penflex to Pot-3-02-0708 DegradedlR
- 1274329, Main Steam Piping lnsulation Band Needs to be InstalledlR
- 1274330, J Box Screws MissinglR
- 1274332, A0-3-444-30258-01-OP Penflex is Detached at Limit SwitchlR
- 1274333, Insulation Damaged on Cooler PipinglR
- 1274334, Penflex to Magnetrol Switch is Underneath Insulation BlankettR
- 1274335, Found Ground Straps Off of Pump and Pump MotorlR
- 1274338, Temp Probe on Top of
- RV-3-02-O71C (TBO491) is DeterminedlR
- 1275808, High Vibration on 3'C' Feed Pump TurbinelR
- 1276474, Off-Gas lsolations during Off-Gas StartuplR
- 1276502,
- PC-9417A Appears to be Causing SJAE Discharge lsolationslR
- 1276510, Off-Normal Procedure EntrylR
- 1276519,
- PIC-32398: SJAE Pressure OscillatinglR
- 1277268, Unit 3 RWCU System Secured Due to Steam LeaklR
- 1277329, Unit 3 Fire Water System LeaklR 1277836. Heat Stress Awareness MissedAttachment
- A-9lR1277UA, 4.0 Crew Critique of Unit 3 RWCU LeaklR
- 1277876, Contamination Associated with the unit 3 RWCU System SecuredlR
- 1281266, P3R18 Ended 86 Hours and 12 Minutes Behind Day 0 ScheduleMiscellaneousOutage Control Center Log, Sunday, October 9,2011, NightOutage Control Center Log, Monday, October 10,2011, NightUnifiJd Control Room Log, Thursday, October 13, 2011, Night ShiftSgction 1 R22: Surveillance TestinqProceduresp1-ga-19304-3, RHFyHPSW System Valves Alternative ControlTesting, RevisionRT-O-o10-304-3, RHRyHPSW System Valves Alternative ControlTesting, RevisionPerformed 11113111RT-O-010-304-3, RHRyHPSW System Valves Alternative ControlTesting, RevisionTemporary Change 11-204, Performed 11113111RT-O-023-Z'SO-g,-HpCl Functional Test from Alternative Control Panels, Revision 15RT-O-023-750-3, HPCI Valve and Component Test from Alternative Control Panels,Revision 13sT-o-052- 154-2, E-4 EDG Simulated unit 2 ECCS Simulated Auto Start with offsite PowerAvailable, Revision 11, Performed 1212112011SO 52A.1.8, Diesel Generator Operations, Revision 48ST-O-052-314-2, E4 EDG Slow Start Full Load and IST Test, Revision 20, Performed1212112011CRsttf. tZAggO+, Temporary Change to
- 1289882, lssue Encountered during Testing of Mo-3-10-0258lR
- 1174494, Differential Temperatures High Out of SpeclR 13055gg, Erratic Reading on Main Conlrol Room E-4 EDG Allterex Volts CD MeterDrawinqsMr1^S*5, Sheet 56, Electrical Schematic Diagram RHR, Revision 100MiscellaneousUn'fied Control Room Log, Sunday, November 13, 2011, Day Shift
Section 1EP6: Drill EvaluationProceduresEP4A-100?, Exelon Nuclear Radiological
- EP Annex for PBAPS, Revision 22OT-101, High Drywell Pressure, Revision 13OT-101 Baies, High Drywell Pressure Bases, Revision 14CRs]n-tOgS+20, NOS lD: During EP Drill RCIC lsolated with HPCI InoperablelR
- 1298444, NOS lD: EP Drill Deficiencies Not CorrectedlR
- 1307225, lZlOStll EP Drill - EP03 Facilities and Equipment lssues]R
- 1307226,
- 12105111 EP Drill - Atom Road Access / EgresstR
- 1307227,12105111 Drill - Evaluate
- EP-AA-113-F-04 for Revision1112,12,Attachment
- A-10lR
- 1305868, Unsat Demonstration criteria in
- 12105111 DEP DrillMiscellaneousNO6CPA+B-11-16, Peach Bottom Emergency Preparedness Performance Report (AR1 279553-35)pBApS December 5,2011 Station DEP Drill Scenario and Evaluator NotebookPBAPS December 5,2011 Drill Evaluation ReportProceduresRP-AA-460, Controlfor High and Locked HRAs, Revision 20RP-AA-460-001, Control for VHRAs, Revision 2RP-AB-460, TIP Area Access Controls, Revision 1RT-H-ogg-960-2, Outside Radioactive Material Storage Area Inspection and Survey,RP-AA-201, Access to the RCA for Escorted Visitors, Revision 4DocumentsDose RecordsContamination Control - Personnel Contamination DataDosimetry Performance Testing DataCorrective Action Documents (various ARs)Pl Verification DataPl Summary DataRevision 7ProceduresRP-AA-401, OperationalALARA Planning and controls, Revision 13DocumentsGeneral Source Term DataBRAC Point DataBusiness Plan and Site ALARA Plan Goals (P3R18)Work-ln-Progress Job Reviews and ALARA ReviewsOutage Report Data (added scope analysis)post-Job Review Data (control rod drives, sirain gauge, recirculation pump work, in-vesselwork,cavity decontamination, reactor vessel disassembly/reassem bly, turbinework/scaffolding, and condenser work)ARsTgssg,
- 1217457,
- 1263077,
- 1264425, and 1262272DocumentsCorrective Action DocumentsAirborne Radioactivity Intake AssessmentsAttachment
- A-11Section 2RS04: Occupational Dose AssessmentProceduresRP-AA-210,DocumentsUse Weighting Factors for External Exposure, datedNRC Safety Evaluation, Application toDecember 20,2006Exposure Control and Dose RecordsGeneral Source Term DataPersonnel Contamination Event LogsPersonnel lntake InvestigationsCorrective Action Documents (various ARs: 1268194)Data for Conduct of EDEX AssessmentSection 2RS05: Radiation Monitoring lnstrumentationProceduresnp-nn-aOt, Radiological Air Sampling Program, Revision 4RP-AA-210-1001, Dosimetry Logs and Forms, Revision 5Cy-AA-170-000, Radioactive Effluent and Environmental Monitoring Program, Revision 5CY-AA-170-1100, QA for Radiological Monitoring Program, Revision 1CY-AA-170-200, Radioactive Effluent control Program, Revision 1RT-C-095-892-2, Periodic Intra-laboratory Analysis, Revision 1RT-C-095-897-2, Quarterly cross-check Sample Analyses, Revision 1RT-C-095-846-2 Gamma lsotopic Analysis of Unmonitored Liquid EffluentST-C-095-805-2, Liquid Radwaste DischargeST-C-Ogb-BS8-2, Determination of
- SR-89, Sr-90, and ALPHA Activity for Main Stackand Roof Vents Particulates Filters, Revision 6ST-C-095-0855-2, Analysis of Gaseous Releases for Tritium, Revision 3sT-c-095-862-2, Determination of Instantaneous Noble gas ReleaseST-C-095-900-2, Plant Effluent Concentration Dose Analysis, Revision 1Sl2R-63F-0S0-A1CE, Main Stack Radiation Monitor Electronic Calibration CheckRY-0-17-0504, Revision 1 1ST-C-095-805-2, Liquid Radwaste Discharge, Revision 13 (Alarm set-point)sT-c-095-868-2, Drywell High Range Radiation Monitor calibrationsT-c-095-868-3, Drywell High Range Radiation Monitor calibrationS l2R-63E- 2g7 g-B1iE, Venistack Rad iation Monitor
- RY-29798, Electronic CalibrationSt3R-63E-3979-B1CE Vent Stack Radiation Monitor
- RY-3979B Electronic CalibrationDosimetry lssue, Usage, and Control, Revision 18DocumentsCalculation and Bases for Effluent RadiationCriteria for Choosing Radiological GaseousRadiation Monitor System NotebookRM-14,
- RO-20, TelePole, RadPro 5,lnstrument Calibration Records (Gas Air Samplers,Ludlum, REM ball)Out-of-Tolerance RePortsNVLAP Dosimeter Accreditation (Scope of Accreditation)Shepard Calibrator Source Calibration DataShepard 89 Verification March 3,2Q11Area Radiation Monitor Calibration Data (CH-36,
- CH-27Monitor CalibrationsEffluent EAL ThresholdAttachment
- 2Effluent Lower Limit of Detection Determination Data (October 6,2011 (gaseous, liquids)General Source Term Data2010 Annual QA RePortDrywell High Radiation Monitor Calibration Procedures (Unit 2 and Unit 3) (various)Wide Range Gas Monitor Calibration Data (various)Teledyne Brown QuarterlY RePortsContamination Monitoring Instrument MatrixARs1299543,1299476ProceduresEN4A40&4000, Revision 0, Radiological Ground Water Protection Program lmplementationEN-PB-408-4160, Revision 0, Peach Bottom RGPP Reference MaterialDocuments2010 Annual Radioactive Effluent Release Report No. 53Land Use Census, January 4,2011Annual Radiological Environmental, Effluent Release Reports-2008, 2009ODCM and ChangesReports (various) - Routine Ground WaterGeneral Source Term DataGround Water AnalYsesCorrective Action Documents (various ARs)ProceduresODCM, Revision 13Documents:2010 Annual Radioactive Effluent Release Report No. 53Land Use Census, January 4,2A11 2O1O)Annual Radiological Environmental, Effluent Release Reports-2009' 201 0ODCM and ChangesReports (various) - Routine Ground WaterGeneral Source Term DataGround Water AnalYsesCorrective Action Documents (various ARs)ProceduresRTi /20D"965-2, Low Level Radwaste Storage Facility Waste Container StorageCell lnspectionOP-AA-102-102, GeneralArea Checks and Operator Field Rounds, Revision 9Attachment
- A-13DocumentsRadioactive Waste Facilities Walk-down Reports and StatusRadioactive Waste Shipment Records (Shipment
- PM-1 1-151)Shipper and radiation Worker Training RecordsSection 4OA1 : Performance lndicator VerificationMSPI Deviation Reports and Svstem Manaqer Notebookg:october 2010 through september 2011, Unit 2 and Unit 3 RHRyHPSWOctober 2010 through September 2Q11, Unit 2 and Unit 3 ESWOctober 2010 through September 2011, Unit 2 and Unit 3 EDGsOctober 2010 through September 2011, Unit 2 and Unit 3 HPCIOctober 2010 through September 2011 , Unit 2 and Unit 3 RCICProcedures:ER4ASOo-1047, Mitigating Performance Index Basis Document, Revision 5ER-AA-2008, MSPI Failure Determination EvaluationER-AA-2020, Equipment Performance and Information Exchange (EPIX), Revision 5LS-AA-2001, Collecting and Reporting of NRC Pl Data, Revision 14LS-AA-2080, Monthly Data Elements for NRC SSFFs, Revision 4LS-AA-2200, MSPI Data Acquisition and Reporting,Revision 4ST-C-095-865-2, Revision 1, Determination of Annual Dose Equivalent for All Uranium FuelCycle SourceCRs:tn t tSSZO0, PRA Model Change and CDE Updates RequiredlR 117452a E-4 EDG Out-of-Date as Found Value sT-0-052-414-2tR
- 1830889, 0APO60 Pump DP in Action Range
- DAR 1804236, E-2 Diesel Generator Control Power Light Not LitAR
- 1772696,
- RT-0-098-500-2 Dailey Production LogARs 12599 44, 126s6gs, 12T0773, i2g55g,
- 1263077,
- 1264425,
- 1262272,
- 1259944, 1 2651 80,1265391 ,
- 1266002,
- 1266237 ,
- 1266279,
- 1266283,
- 1266454, 1 1 68966,
- 1173026,1201 437, 1 22647 2, 1
- 226687, 1 227 440, 1 235086)Miscellaneous:LER 11{0140, HpCl System lnoperable due to Leaking Cooling Water Header Relief ValveNEt 99-02, Regulatory Assessment Indicator Guideline, Revision 6PBAPS MSPI Basis Document, Revision 3Technical Evaluation 1 17 4526-02Annual Radiological Environmental, Effluent Release Reports - 2008, 2009Public Dose Projections (Liquid, Gaseous)Reports (various) - Routine Ground Water dataProceduresLS-AA-125, CAP Procedure, Revision 15OU-AA-4002, Revision 1, Fuel and Core Component Handling Performance MonitoringProcess. Revision 2Attachment
- A-14OU-AB-4001, Revision 5, BWR FH Practices, Revision 6so 18.1.A-3, Revision 24, operation of Refueling Platform, Revision 25RT-R-004-990-2, Boraflex surveillance using the Racklife ProgramNF-pB-310-2000, Special Nuclear Material and Core Component Movement - Peach BottomoP-AA-108-115NET-264-02 P Revision 4CRs.f n Sf 6731-04, Revise
- SF-220 as Needed to be in Compliance with
- OM-12 Revision 2lR
- 1222491, Unit 2 Control Rod 02-35 High Temperature and Control Rod DriftlR
- 1272847, tenon Seat Ring Disc on 126Valve of Hydraulic Control Unit 18-59 Found Torn.lR
- 1281090, TRM 3.9 Typo Needs to be CorrectedlR
- 1281553, Hydraulic Oil Leak on Fitting to 3 'B' RFP Control Valve ActuatorlR
- 1281565, Emergent Clearance Written for Unit 3'B' RFP Turbine HydraulicPower UnitslR
- 1281601, Filter Differential Pressure HighlR
- 1281806, Insulation Ineffective (Needs Replacing) on RWCU PipinglR
- 1282235, Inconsistencies with Maneuver Guidance from Fleet NormlR
- 1282317, 4.0 Crew Critique -
- GP-9 to Remove 3 'B' RFP from ServicelR
- 1284565, Review Operations Procedures for Power Reduction lmprovement.lR
- 1293507, Revise Sf -ZZl to Ensure Compliance with
- OM-12, Revision 2.lR
- 129351 1 , Revise
- SF-290 as Necessary to Ensure Compliance with
- OM-12, Revision 2.lR
- 1295818, LER Numerical Designation ErrorlR
- 1295435, Increased Rate of LERS for 2011lR
- 971001, Orientation of Fuel Bundle in Incorrect in Fuel Prep MachinelR
- 971385, Fuel Channel Dropped in Unit 3 SFPlR
- 972679, P3R17 Fuel Bundle Mispositioned during Core Shuffle lllR
- 1114828, Level 4 Event Refuel Bridge Stopped by SpotterlR 1 1 1 5041, P2R18 Fuel Bundle Came in Contact with SCI SublR
- 1117854, P2R18 Dummy Bundle Came in Contact with Bundle in SFPlR
- 1257323, Failed PMT on 30H332 Refuel Platform Mono Hoist MotorCR-1261969-03, Engineering to Submit Technical Evaluation Being Conducted Under ACIT 02to MRC for Review and APProvallR
- 1261969-04, Document Detailed Exelon Review of
- TIA 2011-004WOs / Action RequestsffiRefuelingoperationsonUnit3ReactorEncoderCheck,CheckBridge/TrolleY EncodersMiscellaneousAb"omlal Condition Monitoring Plans for P3R18 Refueling OperationsPeach Bottom Station Trend Review, Second Quarter 2011 Analysispeach Bottom Technical Evaluation to Verify the Adequacy of the PBAPS SPF Storage RackCriticality Margins Dated August 16,2010Task lnterfacJAgreement 201 1-004, Peach Bottom Units 2 and 3 SFP Neutron AbsorberDegradationLER 11-002-00, Event date: June 6,2011Attachment
- A-15Section 4OA2.4: Review of Licensee Actions to Resolve Vital Bus Degraded VoltageProtection lssuesCalculationspf-OO+8. AC MCC Control Circuit Evaluation, Revision 9PE-0121, Voltage Regulation Study, Revision 7PE-0225, Degraded Grid Relays Setpoints, Revision 0lssue ReportsOOZAZTt, NRC CDBI- URlfor LTC Licensing Basis00781059, NRC URI 2OO80O7-3, Vital Bus Degraded Voltage Protection00918762, Voltage Reg. Study ETAP File Has Load Flow DifferencesQ1117782,
- MO-2-10-1 54A: Margin lmprovement Modification Required01117787,
- MO-3-1 0-1 54B: Margin lmprovement Modification Required01119440, LTC URI DisPosition011261SS, trlO-e-t0-01iD, Overall Gear Ratio Modification Required for Degraded Voltage01126164,
- MO-3-10-0348: LS Modification Required Based on Degraded Voltage01126193,
- MO-3-23-015: P3R18 Modification Based on Degraded Voltage-01
- 138920, NRC
- NCV 2010004-3: Adequate Voltage to sR Equipment Not Ensured01149455, Low Voltage at MCC Contactor Using LOCA Relay Setpoints01149471, Low Voltage at MCC Contactor Using LOCA Relay Setpoints01149488, Low Voltage at MCC Contactor Using LOCA Relay Setpoints01149493, Low Voltage at MCC Contactor Using LOCA Relay SetpointsCompleted Surveillance Proceduresp,Valve,Flow,&UnitCoolerFunctionalandlnserviceTest, Revision 33, Completed 11122111ST-O-010-306-2, 'B' RHR Loop Pump, Valve, Flow, & Unit Cooler Functional and InserviceTest, Revision 31, Completed 08129111ST-O-010-306-3, 'B' RHR Loop Pump, Valve, Flow, & Unit Cooler Functional and InserviceTest, Revision 33, Completed 11102111Drawinqsr-r srreet 1, single Line Diagram, station, Revision 50 (10/04/1 1)E-71, Sheet 1, Electrical Schematic Diagram, Emer. Aux. Swgr. Reg. Trans. Source 4.16KVCkt. Breaker, Revision 38 (01/27100)Enqineerinq ChanqesM0,EvaluateARlStartersandAssociatedComponentsECR PB 't0-00360 000,
- MO-2-10-154A (B), Install Closed Torque Switch BypassECR
- PB 10-00362 000, Mo-3-10-0268, lnstall closed Torque Switch BypassEnoineerinq Technical Evaluations & operabilitv Evaluationswitfr the 4kV Bus Voltage at 3836V, Revision 010-006, lR 1 1 1 9440-07, LTC URI Disposition, Revision
- 31119440-12, Documentation of MOV Operability for NRC CDBI URl, Revision 0Licensinq DocumentsPBAPS TSSPBAPS UFSARAttachment
- A-16Miscellaneoussr"n rrrirg Brief 10-12, closing Mo-2(3)-10-154A (B),_"RHR Loop A (B) Outboard DischargeValve" Under Startup Source Degraded Voltage Conditions,09l29l10ProceduresLS-AA-125, CAP Procedure, Revision 15LS-AA-125-1001, Root Cause Analysis Manual, Revision 8LS-AA-125-1003, Apparent cause Evaluation Manual, Revision 9OP-AA-1 08-1 1 5, Operability Determinations, Revision 1 0OP-AA-10g-1 15-1001 , Operability Evaluation Passport Engineering Change Desktop Guide,Revision 1OP-AA-10g-1 15-1002, Supplemental Consideration for On-Shift lmmediate OperabilityDeterminations, Revision 2Procedures (Operations)AO 10.g.2, Unit 2, itacirig Torus Cooling in Service with LOCA Signal Present or Has Occurred,Revision 10AO 10.g.3, Unit 3, placing Torus Cooling in Service with LOCA Signal Present or Has Occurred,Revision 101-204-2, Unit 2, Initiation of containment Sprays Using RHR, Revision 5T-204-3i,, Unit 3, Initiation of Containment Sprays Using RHR, Revision 4T-231-2, Unit 2, HPSW Injection into the Torus, Revision 6T-231-3, Unit 3, HPSW Injection into the Torus, Revision 6RRC 1 Oi.1-2, Unit 2, RHR System Torus Cooling during a Plant Event, Revision 4RRC 10.1-3, Unit 3, RHR System Torus cooling during a Plant Event, Revision 5Svstem & Proqram Health RePorts4 kV, Unit 2,3rd Quarter 20114 kV, Unit 3, 3rd Quarter
- 2011480 V Emergency & NSR Load center, Unit 2,3rd Quarter
- 2011480 V rmergency & NSR Load center, Unit 3, 3rd Quarter 2011MOV Program, 3rd Quarter 2011Substatiois/Startup Sources, Units 2 & 3, 3rd Quarter 2011WOsCOZSSA+g,
- MO-2-10-1 54A, Margin I mprovementR099841 1, E1 24-D-A (5322), Perform Breaker Mai ntenanceR1
- 055237, E324-D-A(5545), Perform MCU InspectionR1085871,
- MO-3-10-0268-OP, Perform Motor Operator P'M'ARs125gg44,1265695,1270773,129559,1263077,1264425,1262272,1259944'1265180'1265391,
- 1266002,
- 1266237,
- 1266279,
- 1266283,
- 1266454,1 1 68966, 1173026'1 201 437 . 1 22647 2,
- 1226687, 1 227 440, 1 235086)section 40A3: Follow-up of Events and Notices of Enforcement DiscretionProceduresOP4A-108-1 15, Operability Determinations, Revision 10M-052-002, Diesel Engine Maintenance, Revision 35Attachment
- A-17CRsIR
- 1264398,
- RV-3-10-72D Inlet Piping ConfigurationlR
- 1264909,
- RV-3-10-072D Update from A1758904 (Leakage Source on RV)lR
- 1265892, E-33 LOCA/LOOP had Unexpected E-3 EDG StartlR
- 1307019, Document Corrective Actions for
- RV-3-1 0-072D (lR 1264909)lR
- 582657, Oil Leak on Outboard of Engine BlowerlR
- 894706, Oil Leak atE-2 BlowerlR
- 1266837, Oil Leak from E-1 EDG Supercharger Drain LinelR
- 1293991, OIO Benchmark E-1 Diesel Blower Oil Drain LinelR
- 1309963, E-1 EDG Oil Leak CAP Product Quality lssuesDrawinqsf Sf -g61, Sneet 4: ASME Section Xl lsl Boundaries RHR System, Revision 1 1WOsn18Z5tg8, RHR Pump 3DP035 Suction Relief Valve41758094, RHR Pump 3DP035 Suction Relief ValveMiscellaneousAdrt"t V".a;r Data Sheet: Nuclear Qualified Control Relays - Se{esjGP/EML/ETREiectric power Research Institute
- TR-106857, PM Basis - Volume 30: Relays - ControlNRC Generic Letter 90-05: Guidance for Performing Temporary Non-Code Repair of ASMECode Class 1, 2, and 3 PiPingPBAPS PCM Templates: Relays - Control/ TimingNRC fnformation Notice20OT-27 Recurring Events Involving EDG OperabilityPBAPS EDG Run Database, April - November 2011PBAPS CAP Search: 3-year History of EDG Oil Leaks
Section 4OA5: Other ActivitiesEP-AA-1007; Radiological
- EP Annex for PBAPS, Revisions 16 and 21tR 01.1g4333; Ep NotLe of Violation for EAL Change-lmplement EAL Basis Change forHU6; Marcn7,2011Radiological SurveYs - lFSlInspection RePorts - lFSlAttachment
- ADAMSALARAARAPRMASMEBICAPccACDFCFRCRsEALECCSECREDEDEXEDGEOCEPESWFHFSARGPIHEPAHPCIHPSWHRArMcIRISFSIISTLCOLERLERFLHRALLDLOCALOOPLTCMCCMGMOVMRMSIVMSPINCVNEIA-18
LIST OF ACRONYMS
Agencywide Documents Access and Management Systemas low as is reasonablY achievableaction requestaverage power range monitorAmerican Society of Mechanical Engineersbarrier integritycorrective action Programcommon cause analYsiscore damage frequencYCode of Federal Regulationcondition reportsemergency action levelemergency core cooling sYstemengineering change requestelectronic dosimetereffective dose equivalent for external exposureemergency diesel generatorextent of conditionEmergency Planemergency service waterfuel handlingfinal safety analYsis rePortgroundwater protection initiativehigh efficiency particulate airhigh pressure coolant injectionhigh pressure service waterhigh radiation areainspection manual chaPterissue reportindependent spent fuel storage installationinservice testinglimiting condition for oPerationlicensee event rePortlarge early release frequencYlocked high radiation arealower limits of detectionloss of coolant accidentloss of offsite powerload tap changermotor control centermotor generatormotor-operated valvemaintenance rulemain steam isolation valvemitigating system performance indicatornon-cited violationNuclear Energy I nstituteAttachment
- NIOSHN [[OSNRCNRRNVLAPODCMP3R18PARSPBAPSPCPPDPIPI&RPMPMTQARBRBCCWRCARCICREMPRETSRFORFPRGRPSRHRRTPRWCUSBOSDPSFPSLCSMSPARSRASRVSSCsSTTIATLDTSUFSARURIVHRAWBCWOsA-19National Institute for Occupational Safety and Healthnuclear oversightNuclear RegulatorY CommissionNuclear Reactor RegulationNational Laboratory Accreditation Programoffsite dose calculation manualPeach Bottom Unit 3 Refueling Outage Number 18publicly available recordsPeach Bottom Atomic Power Stationprocess control programperformance deficiencYperformance indicatorproblem identification and resolutionpreventive maintenancepost-maintenance testquality assurancereactor buildingreactor building closed cooling systemradiological controlled areareactor core isolation coolingRadiological Environmental Monitoring Programradiological effluents technical specificationrefueling outagereactor feed pumPregulatory guidereactor protection sYstemresidual heat removalrated thermal Powerreactor water cleanuPstation blackoutsignificance determination processspent fuel Poolstandby liquid controlshift managerstandardized plant analYsis risksenior reactor analYstsafety relief valvestructures, systems, and componentssurveillance testtask interface agreementthermoluminescent dosimetertechnical specificationupdated final safety analysis reportunresolved itemvery high radiation areawhole body counterwork ordersAttachment]]