IR 05000277/2011005

IR 05000277-11-005, 05000278-11-005; Exelon Generation Company, LLC; on 10/01/2011 - 12/31/2011; Peach Bottom Atomic Power Station - NRC Integrated Inspection Report

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

UNITED STATES N UCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE ROAD KING OF PRUSSIA. PA 19406-1415 February 10, 2OL2 Mr. Michael Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road Warrenville, lL 60555

SUBJECT: PEACH BOTTOM ATOMIC POWER STATION - NRC INTEGRATED I 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 were discussed 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 and compliance with the Commission's rules and regulations and with the conditions of your license.The inspectors reviewed selected procedures aid records, observed activities, and interviewed personnel.

This report documents one self-revealing finding and one inspector-identified finding of very low safety significance (Green). One finding was d_etermined to involve a violation of NRC iequiiem-ents.

Additionallf, two license6-identified violations, which were determined to be of very low safety significanie, are listed in this report. However, because of the very low safety significance and because they are entered into your corrective action program (CAP), the NRC ir-tr".ting the findings "" " non-"ited violations (NCVs;, consistent with Section2'3'2 of the NRC'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 the pBApS. tn additiori ii Vb, disagree with ihe cross-cutting aspects assigned.to the findings in this report, you should provide a response within 30 dayJ of the date of this inspection, with the nasis ior your disagieement, to the Regional Administrator, Region 1, and the NRC Resident lnspector at PBAPS. In 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 be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS).ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,f,*/zM Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Prolects Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56

Enclosure:

Inspection Report 0500027712011005 and 0500027812011005

w/Attachment:

Supplementary lnformation cc Mencl: Distribution via ListServ ln 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 be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS).ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/PaulG. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56

Enclosure:

Inspection Report 0500027712011005 and 0500027812011005

w/Attachment:

Supplementary Information cc Mencl: Distribution via ListServ Distribution w/encl:(via E-mail)W. Dean, RA D. Lew. DRA J. Tappert, DRP J. Clifford, DRP C. Miller. DRS P. Wilson, DRS P. Krohn, DRP A. Rosebrook, DRP S. lbarrola, DRP E. Miller, DRP S. Hansell, DRP, SRI A. Ziedonis, DRP, Rl S. Schmitt, DRP, OA L. Chang, Rl OEDO RidsNrrPMPeachBottom Resource RidsNrrDorlLpl 1 -2 Resource ROPreports Resource SUNSI Review Complete:

PGK (Reviewer's Initials)ML120414323 DOC NAME: G:\DRP\BRANCH4\lnspection Reporls\Peach Bottom\2011\PB 4th QTR\PBIR2011-005_Final.docx After declaring this document'An OfficialAgency Record' it will be released to the Public.dathchmenuendosure "N"= No copy To receive a 0f this indicate in the box wihout attachment/enclosure OFFICE mmt RI/DRP RI/DRP R1/DRP NAME SHansell/

PGK for ARosebrooUAAR PKrohn/ PGK DATE 02t11t12 02t10t12 02t10t12 Docket Nos.: License Nos.: Report No.: Licensee: Facility: Location: Dates: Inspectors:

Approved by: U. S. NUCLEAR REGULATORY COMMISSION REGION I 50-277, 50-278 DPR-44, DPR-56 05000277 120 1 1 005 and 0500027 81201 1005 Exelon Generation ComPanY, LLC Peach Bottom Atomic Power Station, Units 2 and 3 Delta, Pennsylvania October 1,2011 through December 31,2011 S. Hansell Senior Resident Inspector A. Ziedonis, Resident InsPector S. Barr, Senior Emergency Preparedness lnspector E. Miller, Region 1 Project Engineer R. Nimitz, Senior Health PhYsicist J. Tomlinson, Operations Engineer K. Young, Senior Reactor lnsPector Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure 2

SUMMARY OF FINDINGS

tR 05000227t2011005, 0500027812011005; 1010112011 - 1213112011;

Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3; Maintenance Effectiveness and Radioactive Gaseous and Liquid Effluent Treatment.

The report covered a three-month period of inspection by resident inspectors and announced inspeciions performed by regional inspectors.

One self-revealing (Green) finding and one inspector-identified finding were identified.

The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter (lMC) 0609, "Significance Determination Process" (SDP). The cross-cutting aspect associated with the findings was determined using IMC 0310, "Components Within the Cross-Cutting Areas." Findings forwhich the SDP does not apply may be Green, or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is describeO inNUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.Cornerstones:

Initiating Events, Mitigating Systems, and Barrier lntegrity

Green.

The inspectors determined that Exelon's failure to promptly correct a condition aOverse 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 MOV program testing failures due to degraded stem lubrication in 2009 were not performed in a timely manner to prevent the inoperability of a safety-related MOV due to degraded lubricaiion, as identified on September 22,2011. PBAPS entered this issue into the CAP via issue reports (lRs) 1266600 and 1266604'This finding was more than minor because it was associated with the configuration control attribute of the Barrier Integrity (Bl) cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the pu-Oti" from iadionuciide releases caused by accidents or events. Specifically, the Unit 3 reactor water cleanup (RWCU) outboard isolation valve MO-3-12-018 did not develop sufficient thrust at the torque switch trip setpoint during diagnostic testing on September 22, 2011. The RWCU MOV would not have been able to perform its safety function to close during the most limiting design condition.

Using the Phase '1 worksheet in Appendix a of IMC 0609, "SDP," the finding affected the Bl cornerstone and was of very low safety significance (Green) because it did not represent an actual open pathway in the 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 the adverse 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 area of effluent and environmental monitoring as required by Peach Bottom, Units 2 and 3 Technical Specification (TS), Section 5.4.1. Specifically, Exelon's QA program for effluent and environmental monitoring was not sufficient to ensure: 1) that both adequate and timely evaluation and assessment of changes described in the Public Land Use Census were conducted for purposes of dose validation and sampling program modification; 2) that changes in meteorological parameters, used for public dose projections and assessment, were promptly and adequately evaluated; and 3) that laboratory QA programs for effluent and environmental sample analysis measurement systems were adequate and implemented properly.

Exelon placed thes_e issues in its inp as Action Requests (ARs): 1226969, 1226202,1299543, 1299476,1302720, and 1303308.The finding is more than minor because it is associated with the Public Radiation Safety cornerstone attribute of programs and processes and adversely affected the associated cornerstone objective in that failure to establish, implement, and maintain an adequate QA program in the effluents and environmental monitoring program area adversely affected 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 determined to be of very tow safety significance (Green) because: the issue was contrary to TSs and is a radioactive effluent release program deficiency; there was no indication of a spill or release of radioactive material on the licensee's site or to the offsite environs that would impact public dose assessment, and there was no substantialfailure to implement the radioactive effluent release program. The licensee re-assessed the dose to members of the public from routine releases and determined that projected doses did not, nor were likely to, exceed applicable limits, including as low as is reasonably achievable (ALARA) design specifications of 10 CFR Part 50, Appendix l; or 10 CFR 20.1301(e).

The cause of this finding is related to the cross-cutting area of Human Performance, Work Practices, Aspect H.4(b) because the licensee did not ensure personnelfollowed procedure compliance requirements activities for effluent and environmental monitoring program. (Section 2RS06) tH.4(b)1.

Other Findings

Two violations of very low safety significance, which were identified by the licensee, have been reviewed by the inspectors.'

CoireCtive actions taken or planned by Exelon have been entered into the CAp. Tnese violations and the corrective action tracking numbers are listed in Section 4OA7 of this report.Enclosure 5

REPORT DETAILS

Summarv of Plant Status Unit 2 began the inspection period at 100 percent rated thermal power(RTP)-

On November 19, 2011,-operators reduced' power to approximatelyS0 percent to perform main turbine valve testing, and'planned maintenance on the 'C' reactoi feed pump (RFP). The unit was returned to 100 p-ercent RTp the next day. The unit remained at RTP through the end of the inspection period, 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) Ol october i3, the reactor mod'e switch was placed in start-up and the unit was synchronized to the grid 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' RFP from service to repair an oil leak in the feed pump turbine speed control hydraulic system. The unit was returned to 100 percent RTP later that same day following successful repairs' On November 30, an emergent downpower to approximately 94 percent was performed to swap the in-service lubricating oiipump for trre 'B' recirculation pump motor generator (MG) set due to elevated 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 support planned testing and rod pattern adjustments'

REACTOR SAFETY

Gornerstones:

lnitiating Events, Mitigating Systems, and Barrier Integrity 1R01 Adverse Weather Protection (71111'01 - 1 sample)Readiness for Seasonal Extreme Weather Conditions a. lnspection ScoPe The inspectors performed a review of PBAPS's readiness for the onset of seasonal cold temperatur"s.

The review focused on the auxiliary boiler system heallng steam supply, emergency diesel generators (EDGs), emergency service water (ESW) and high pressure service wlter (HPSW) pump rooms, the outer intake cooling water pump structure building, and the innei intake cooling water screen structure' The inspectors reviewed tfre UplO'ated Final Safety Analysis Report (UFSAR), Technical Specifications (TSs), control room logs, and the CAP to determine what temperatures or other seasonal weather could challenge these systems, and to ensure PBAPS personnel had adequately prepared for these challenges.

The inspectors reviewed station procedures, including pgnpS's seasonal weather preparation procedure and applicable operating procedures.

The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during cold weather conditions.

The inspectors also reviewed CAP items to verify that pBApS was identifying adverse weather issues at an appropriate threshold and entering them into their CAP iriaccordance with station corrective action procedures.

Documents reviewed for each section of this inspection report are listed in the Attachment.

6 b. Findinqs No findings were identified.

1R04 Equipment

Aliqnment (71111.04Q - 3 samples)Partial Svstem Walkdowns a. lnspection ScoPe The inspectors performed partial walkdowns of the following three systems: o Unit 3, alternate reactor pressure vessel injection with residual heat removal (RHR), on October 11,2011. Unit 3, standby liquid control (SLC) during Unit 2 SLC unavailability on November 15,2011. E-4 EDG availability during E-3 fuel oil transfer pump suction problem on December 14,2011 The inspectors selected these systems based on their risk-significance relative to the Reactor Safety cornerstones at the time they were inspected.

The_inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, TSs, work orders (WOs), condition reports (CRs), and the impact of ongoing work a.ctivities on redundant irains'of equipment in order to identify conditions that could have impacted system performance of their intended safety functions.

The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable.

The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies.

The inspectors also reviewed whether PBAPS siaff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findinqs No findings were identified.

1R05 Fire Protection

(71111.05Q - 5 samples)Resident I nspector Quarterlv Walkdq\,Vns a. lnspection ScoPe The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features.

The inspectors verified that pBAPS controlled combustible materials and ignition sources in accordance with administrative procedures.

The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition.

The inspectors also verified that station personnel implemented compensatory measures for out-of-service, degraded or inopera'ble fire protection equipment, as applicable, in accordance with procedures' 7 Unit 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. Findinqs No findings were identified.

1R1 1 Licensed operator Requalification Proqram (71111.11)

.1 Resident Inspector

Quarterlv Review (71111.11Q - 1 sample)a. Inspection ScoPe The inspectors observed licensed operator simulator training on November 7, which included 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 of high pressure coolant injection (HPCI) system to automatically start. The inspectors ev:aluated operator performance during ihe simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures.

The inspectors assessed tfre clarity and effectiveness of communications, implementation of aciions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor.

The inspectors verified the 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's verification of the SM's decisions.

Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.b. Findinos No findings were identified.

and actor Operators (71111'11B - 1 sample)Inspection Scope On Decem ber 21,20j1, one NRC region-based inspector conducted an in-office review of the licensee-administered annual operating tests and comprehensive w_ritten exam results for Limerick and peach Bottom Limited Refueling Senior Reactor Operators for 2.011. The inspection assessed whether pass rates were consistent with the guidance of NRC Manual Chapter 0609, Appendix l, "Operator Requalification Human Performance SDP." The insPector verified that: o Individual pass rates on the written exam were greater than 80 percent'(Pass rate was 100 Percent)a o.2 Enclosure

8. Individual

pass rates on the job performance measures of the operating exam were greater 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 or equal to 75 percent. (Overall pass rate was 91 percent)b. Findinqs No findings were identified.

1R12 Maintenance

Effectiveness (71111'12Q - 2 samples)a. Inspection Scope The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structures, systems, and components (SSCs) performance and reliability.

The inspectors reviewed system health reports, CAP documents, maintenance WOs, and maintenance rule (MR) basis documents to ensure that PBAPS was identifying and properly evaluating performance problems ryitJ,f the scope of the MR. For "".lirarple seletted, the inspectors verified that the SSC was properly scoped 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, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return tnese'SSCs to (a)(2). Additionally, the inspectors ensured that PBAPS staff was identifying and addressing common cause failures that occurred within and across MR system boundaries.

o Unit 3 RWCU system leaks on October 16 and 22,2011 o Unit 3 RWCU outboard isolation MOV diagnostic testing failure and degraded lubrication on November 14, 15, and 21 , 2011 b. Findinqs

Introduction.

The inspectors determined that Exelon's failure to promptly correct a condition 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 failures due to degraded stem lubrication in 2009 were not performed in a timely manner to prevent thL inoperability of a safety-related MOV due to degraded lubrication, as identified 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 the torque switch trip setpoint to ensure that the valve would close under the most limiting design basis differeniial pressure scenario.

Subsequent inspeclionby Exelon maintenance 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 to degraded stem lubrication and the resultant increased coefficient of friction on the valve Enclosure 9 stem. lmmediate corrective actions included cleaning and removing the Nebula EP-1 grease, applying MOV Long-Life grease to the valve stem, and performing successful Is-left diagnostic testing. PBAPS-'s extent-of-condition (EOC) efforts are summarized in the last paragraph of the "Description" section of this finding'pBApS root cause evaluation report 892191-08 determined that degraded MOV stem lubrication resulted in four safety-related MOV program test failures in March and April of 2009. pBAPS performed multiple corrective actions to address the 2009 MOV program testing 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 preventive maintenance (PM) frequencies.

PBAPS also identified degraded Nebula EP-1 grease on MOV program valves in 2006, 2007, and 2008, as discussed in root cause evaluation ieport Agbt g-1-Oe, Attachment 1 . The root cause evaluation identified that PBAPS had the longest allowable MOV PM lubrication intervals (10 years) in the United States nuclear-industry.

Another factor related to MOV stem lubrication, the vendor cancelled production 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 stem lubrication at Braidwood on June 21 ,2010. As a result of the PBAPS and Braidwood degraded MOV grease events, Exelon has initiated corporate actions to transition all sites from Nebula EP-1 to MOV Long-Life by the end of 2014'Root cause evaluation report 892191-08 required changing the MOV stem lubricant to MOV Long-Life grease as a corrective action to prevent recurrence of MOV program testing failures Oue to degraded stem lubrication.

PBAPS implemented a risk-informed if ign,heOium and tow riif) corrective action plan based on the level of susceptibility to OelraOeO stem lubrication.

RWCU outboard isolation valve MO-3-12-018 was included in iire ',medium," risk population of MOV program valves that had not yet been converted to 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 that the MOV program scofing for MO-3-12-018 did not include the correct high temperature stem 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 MOV program valves to MdV Long-111" grease. In addition to the previously discussed coriective actions in responsl to thl Mo-3-12-018 degraded grease, PBAPS.performed an 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 the aforeme-ntioneO nign temperature stem factor on MO-3-12-018.

Field walkdowns were also performed onlll Unit g MOVs with NebulaEP-1grease, as well as all accessible Unit 2 MOVs with Nebula EP-1 grease. Based on the EOC review, 14 MOVs had their grease conversion dates moved fonrvard.

Additionally, PBAPS has expedited corrective Ictions to complete the MOV Long-Life conversion on all MOV program valves from December 2O14to December 2013. The NRC inspectors reviewed the final EOC scoping and determination performed by PBAPS, and found that it was appropriate to the circumstances.

Analvsis.

The inspectors determined that Exelon's failure to promptly correct a condition lEffito quality associated with a safety-related MOV constitutes a performance J"ti"i"n.y.

'speiiticatty, degraded Exxon Nebula EP-1 stem lubricant caused RWCU Enclosure 10 outboard 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-Life grease to prevent recurrence of multiple safety-related MOV diagnostic testing failures in March and April of 2009. This finding was more than minor because it was associated with the containment configuration control attribute of the Barrier Integrity cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the RWCU outboard isolation valve MO-3-12-018 did not develop sufficient thrust at the torque switch trip setpoint during diagnostic testing on September 22,2011, and therefore would not have been able to perform its safety function to close during the most limiting design condition.

Using the Phase 1 worksheet in Attachment 4 of IMC 0609, "SDP," the inspectors determined that this finding was of very low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of reactor containment.

This finding had a cross-cutting aspect in the area of Pl&R, CAP, because Exelon did not take appropriate corrective actions to address a safety issue in a timely manner lP.1(d)].

Specifically, Exelon failed to address the adverse trend of degraded MOV stem lubricant in a timely manner, which resulted in loss of the RWCU outboard isolation valve closing 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 are promptly identified and corrected.

Contrary to the above, Exelon failed to promptly correct a condition adverse to quality associated with degraded stem lubrication on RWCU outboard isolation valve MO-3-12-018.

Specifically, root cause evaluation 892191-08 required Exelon to change MOV stem lubrication from Nebula EP-1 to MOV Long-Life, as a corrective action to prevent recurrence of multiple MOV program testing failures due to degraded stem lubrication identified in 2009. As a consequence of Exelon's failure to promptly correct this condition adverse to quality, MO-3-12-018 failed diagnostic 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 into the CAP via lRs 1266600 and 1266604, this violation is being treated as a Green NCV consistent with the NRC Enforcement Policy. (NCV 05000278/201{005-01, Untimely Gorrective Action to Correct MOV Degraded Stem Lubrication)

1R13 MaintenanceRiskAssessmentsandEmeroentWorkControl

(71111.13-3samples)a. Inspection Scope The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that PBAPS performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the Reactor Safety cornerstone.

As applicable for each activity, the inspectors verified that PBAPS personnel performed risk assessments as required by 10 CFR 50.65(aX4)and that the assessments were accurate and complete.

When PBAPS performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the station's probabilistic risk analyst to verify plant conditions were consistent with the risk assessment.

The inspectors also reviewed the Enclosure l1 TS 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 voltage work on December 5,2011 b. Findinqs No findings were identified.

1R.lS Operabilitv Determinations and Functionalitv Assessments (71111'15 - 5 samples)a. Inspection ScoPe The inspectors reviewed five operability determinations for the following degraded or non-conforming conditions:

o Operability Evaluation 11-003: Control rod seismic impact from fuel channel friction on October 6,2011 o Technical Evaluation 1268076-02:

Past operability review of Unit 3 automatic depressurization 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 15,2Q11 o primary containment overpressure credit for emergency core cooling pumps on November 23 and 29,2011 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determihations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred.

The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to PBAPS's evaluations to determine whether the components or systems were operable.

Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by PBAPS' The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

b. Findinqs No findings were identified.

1 R18 Plant Modifications (71111.18 - 1 sample)Permanent Mod ifications 10,2011 regulator malfunction and emergent Enclosure 12 a. Inspection ScoPe The inspectors evaluated the permanent modification to the Multiple Spurious Operation Motor Control Center Breaker implemented by Engineering Change Request (ECR) 10-OO44g, "Multiple Spurious Operation Motor Control Center Breaker Rework" on November 1d and 17. The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification.

In addition, the inspectors reviewed modification documents associated with the upgrade and design change, which included 10 CFR Part 50.59 documentation and post-mbdification testing resulis. The inspectors also conducted field walkdowns of the modifications to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance capability of the affected systems.b. Findinqs No findings were identified.

1R19 Post-Maintenance

Testinq (71111.19 - 8 samples)a. Inspection Scope The inspectors reviewed the post-maintenance tests (PMTs) for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability.

The inspectors reviewed the test procedure to verify tnai tne procedure adequately tested the safety functions that may have been affeited by the maintenance activity, that the acceptance criteria in the procedure was consistenfwith the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved.

The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.. Unit 3 main steam isolation valve (MSIV) stroke timing on October 3,2011, following P3R1 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 14 and 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 on planned maintenance May 18,2011, following o Unit 3 APRM 3 voter card replacement and partial surveillance APRM-31FS on November 4,2011 test (ST) Sl3N-60A-r Unit 3 M-004-400 reactor vessel head bolt tensioning verification in response to industry operating experience on November 29,2011. E-1 EDG inspection post-maintenance functional test on November 28 and 29,2011 following two-year maintenance overhaul Enclosure 13 b. Findinos No findings were identified.

1R20 Refuelinq

and Other Outaoe Activities (71111'20 - 1 sample)Peach Bottom Unit 3 Outaqe - Refuelinq (P3R18)a. Inspection ScoPe The inspectors reviewed the station's work schedule and outage risk plan for the Unit 3 maintenance and refueling outage (3R18), which was conducted September 1 1 through October 14,2011. This simple completes the inspection activity begun in the PBAPS 3'd quarter 201 1 inspection report ,2011005.

The inspectors reviewed PBAPS's development and implementation of outage plans and schedules to verify that risk, industry experience, previous site-specific problems, and defense-in-depth were considered.

During the outage, the inspectors observed portions of the shutdown and cooldown processes and monitored controls associated with the following outage activities:. Refueling Activities - verified that PBAPS was using adequate controls to ensure the location of tne fuel assemblies were properly tracked and verified that procedures for foreign material control and retrievalwere implemented on the refueling floor. Core Verification - independently reviewed selected portions of other core verification activities o Torus Closure - conducted a thorough walkdown of accessible torus areas above the suppression pool water line prior to reactor startup to verify that all debris, tools, and diving gear were removed. Oryw-elt Closure - conducted a thorough inspection and walkdown of containment pribr to reactor startup to identify any remaining debris, tools, and equipment were removed prior to reactor startuP. Reactor Startup Preparations - reviewed the tracking of startup prerequisites and observed selected Plant Operations Review Committee meetings where outstanding outage issues and startup reviews were discussed o Startup and Ascension to Full Power Operation - observed selected activities including:

reactor criticality; portions of the plant heat-up, main generator synchronization to the grid; portions of the power ascension to full power operation o Licensee ldentification and Resolution of Problems - reviewed corrective action reports related to RFO and startup activities to verify that PBAPS was identifying issues at the appropriate level and taking adequate corrective action b. Findinqs No findings were identified.

14 1R22 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 test data of selected risk-signiiicant SSCs to assess whether test results satisfied TSs, the UFSnn, and pBApS piocedure requirements.

The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with desijn documentation, test instrumentation had current calibrations and the range and accur-acy for the application, tests were performed as written, and applica6le test prerequisites were satisfied.

Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions.

The inspectors reviewed the following STs: RT-O-01 0-304-3, RHRyHPSW system valves alternate November 14and15 ST-0-023-301

-2, Unit 2 HPCI Pump, Valve, Flow, and December 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 21 b. Findinqs No findings were identified.

EmergencY PreParedness (EP)lEPO Drill Evaluation (71114'06 - 1 sample)lnspection ScoPe The inspectors evaluated the conduct of a routine PBAPS emergency drill on December 5 to identify any weaknesses and deficiencies in the classification, notification, and protective iction recommendation development activities.

The inspectors observed emergency response operations in the simulator, and technical support center to deteririne-wheiher the event classification, notifications, and protective action recommendations were performed in accordance with procedures' The inspectors discussed the results of tfre station drill critique with the lead drill controller, and reviewed the items entered into the CAP, to compare inspector observations with those iJ"nliti"J by pBAps staff in order to evaluate PBAPS's critique and to verify whether the PBAPS staff was properly identifying weaknesses in the cAP.Findinos No findings were identified.

RADIATION SAFEry Cornerstone:

Occupationat Radiation Safety (OS)controltesting on Unit Cooler IST on 2.Enclosure 15 2RS01 Access Control to Radioloqicallv Siqnificant Areas (71124.01-1 sample)a. Inspection Scope The inspectors reviewed selected activities, and associated documentation, in the below listed areas. The evaluation of Exelon's performance was against criteria contained in Title 10 of the CFR Part 20, applicable TSs, and applicable station procedures.

Inspection Plannins The inspectors reviewed Performance Indicators (Pls) for the Occupational Exposure cornerstone.

Radiolooical Hazard Assessment The inspectors conducted walkdowns of the facility, including the dry-active waste collection location and the low-level waste storage facility, including associated yard area, to evaluate material and radiological conditions.

The inspectors made independent radiation measurements to verify conditions.

During the walk-downs the inspectors selectively reviewed survey data, as available.

The inspectors selectively reviewed radiologically risk-significant work activities that involve exposure to radiation.

The inspectors verified that appropriate pre-work surveys were performed.

The inspectors evaluated the radiological survey program to determine if hazards were properly identified (e.9., discrete particles, hard-to-detect radionuclides, transient radiation dose rates and dose rate gradients).

Instructions to Workers The inspectors selectively reviewed occurrences where a worker's electronic dosimeter noticeably malfunctioned or alarmed to verify appropriate worker response and inclusion of issues in CAP, as applicable.

The inspectors evaluated licensee dose evaluations as applicable for these occurrences.

Contamination and Radioactive Material Control The inspectors observed locations where the licensee monitors potentially contaminated material leaving the Radiological Controlled Area (RCA), and inspected the methods used for control, survey, and release from these areas. The inspectors selectively evaluated the radiation monitoring instrumentation sensitivity for the type(s) of radiation present.Radiolooical Hazards Control and Work Coveraqe The 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 high radiation areas (HRAs) and very high radiation areas (VHRAs), to verify conformance with the Occupational Pl.Enclosure 16 Rad iation Worker Performance The inspectors selectively reviewed radiological problem reports since the last inspection to identify human performance errors and to determine if there were any observable patterns.

The inspectors discussed corrective actions for identified concerns with licensee Personnel.

Radiation Protection Technician Proficiencv The inspectors selectively reviewed outage radiological problem reports to identify those that indicate the cause oi tne event to be radiation protection technician error and to evaluate corrective action approach taken by the licensee to resolve the reported problems.

The inspectors discussed corrective actions for identified concerns with licensee Personnel.

Problem ldentification and Resolution The inspectors determined if problems associated with radiation monitoring and exposure controlwere being identified by the licensee at an appropriate threshold and were properly addressed foi resolution in the licensee CAP. The inspectors discussed corrective actions for identified concerns with Exelon personnel' b. Findinqs No findings were identified' and 2RSO2 a.(71124.02-1 samPle)lnspection ScoPe Inspection Planninq The inspectors selectively reviewed pertinent information regarding plant collective exposuie history, .urreni"*posure tiends, and ongoing or planned activities in order to ura"r, current performance and exposure challenges.

The inspectors reviewed as low as is reasonably achievable (ALARA) results associated with the 2011 Unit 3 outage'The inspectors'selectively reviewed conformance with the ALARA program aspects of 10 cFR 20j101.Radiolooical Work Planninq The inspectors selectively compared accrued results achieved (dose rate reductions, person-rem used), ar auiil"ble, with the intended dose established in the licensee's nf_nnn planning ior selected work activities (Unit 3 2O1.1.outage)including person-hour estimates.

The-inspectors focused on work activities with an accrued dose of five person-rem.

The inspectors determined, as applicable, and where analyses were Lompleted at the time of the inspection, the reasons for inconsistencies between intended and actualwork activity doses.sample)Enclosure 17 The inspectors determined if post-job (work activity)reviews were conducted and if identified 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 assembled as of the date of the insPection' Verification of Dose Estimates and Exposure Tracking The inspectors selectively verified work activities that Exelon had established measures to track, trend, and if necessary to reduce, occupational doses for ongoing work activities.

The inspectors reviewed control rod drive work, recirculation pump work, in-vessel work, scaffolding, Unit 3 main condenser work, and reactor disassembly and re-assembly Source Term Reduction and Control The inspectors discussed source term mitigation effectiveness with licensee staff associated with the Unit 3 outage'Problem ldentification and Resolution The inspectors determined if problems associated with ALARA planning and controls were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensee CAP. The inspectors discussed corrective actions for identified ALARA concerns rruith Exelon personnel.

b. Findinqs No findings were identified' 2RS03 ln-Plant Airborne Radioactivitv Control and Mitiqation (71124.03 - 1 sample)Inspection ScoPe lnspection Planninq The inspectors reviewed the reported Pls to identify any related to unintended dose resulting from intakes of radioactive materials.

Problem ldentification and Resolution The inspectors reviewed and discussed problems associated with the control and mitigation of in-plant airborne radioactivity to evaluate the licensee's identification and resolution of issues in the CAP.Findinqs No findings were identified.

a.b.Enclosure 18 2RS04 Occupational Dose Assessment (71124.04 - 1 sample)Inspection Scope Inspection Planninq The inspectors selectively reviewed licensee procedures associated with dosimetry operations.

The inspectors evaluated procedure guidance for personnel monitoring.

External Dosimetrv The inspectors evaluated the use of the licensee's personnel dosimeters that require processing were National Voluntary Laboratory Accreditation Program (NVLAP)accredited-.

The inspectors determined if the licensee used a "correction factod'to address the response of the electronic dosimeter (ED) as compared to its thermoluminescent dosimeter (TLD) for situations when the ED must be used to assign dose.lnternal Dosimetrv The inspectors selectively reviewed routine bioassay (in vivo) procedures and whole body count results used to assess dose from potentially internally deposited nuclides using whole body counting equipment.

Special Dosimetrv Situations The 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 for externai dose for the Unii 3 outage in situations in which non-uniform fields are expected or large dose rate gradients (i.e., use of multi-badging or determination of effective dose equivilent for exteinal exposures (EDEXs) using an NRC approved method).Neutron Dose Assessment The inspectors selectively evaluated the licensee's neutron dosimetry program, including dosi meter type(s) and/or survey instrumentation.

Shallow Dose Equivalent The inspectors selectively reviewed personnel contamination instances to evaluate frequency, causes, and dose assessment, as appropriate.

The inspectors also discussei identification and logging of personnel contamination occurrences during the Unit 3 outage including actions taken to identify and limit personnel contamination events. The inspectors reviewed a common cause analysis associated with personnel contamination events (AR 1 268194).Enclosure 19 Dose Assiqnment The inspectors evaluated assignment of dose of record for total effective dose equivalent, shallow dose equivalent, and lens dose equivalent.

Problem ldentification and Resolution The inspectors selectively reviewed corrective action documents to verify that problems associated with occupational dose assessment were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensee's CAp. The inspectors discussed corrective actions for identified concerns with Exelon personnel.

b. Findinqs No findings were identified.

2RS05 Radiation Monitorinq lnstrumentation (71122.05 - 1 sample)a. Inspection ScoPe Inspection Planninq The inspectors reviewed the plant updated final safety analysis lepgrt (UFSAR)' as applicable, to identify radiation instruments associated with monitoring area radiological conditions, includingairborne radioactivity, process streams, effluents, materials/articles, and workers.Walkdowns and Observations The inspectors selected portable survey instruments in use or available for issuance and checked calibration and source check stickers for currency, and to assess instrument material condition and operability.

Calibration and Testino Proqram The inspectors selectively reviewed calibration of Units 2 and Unit 3 drywell high range monitors.

The inspectors selectively verified electronic calibration and source calibration.

The inspectors selectively reviewed and discussed the licensee's capability to collect high range, post-accident iodine effluent samples'The inspectors selectively reviewed and discussed high-range effluent monitor calibrations.

Problem ldentification and Resolution The inspectors selectively reviewed corrective action documents associated with radiation monitoring instrumentation to determine if the licensee identified issues at an appropriate tfrreshdtd and placed the issues in the CAP for resolution' In addition, the Enclosure 20 inspectors evaluated the appropriateness of the corrective actions for a selected sample of problems documented by the licensee that involve radiation monitoring instrumentation.

The inspectors discussed corrective actions for identified concerns with Exelon personnel.

b. Findinqs No findings were identified.

Gornerstone:

Public Radiation Safety (PS)2RS06 Radioactive Gaseous and Liquid Effluent Treatment (71124'06 - 1 sample)a. lnspection ScoPe The inspectors selectively reviewed UFSAR descriptions of the radioactive effluent monitoring systems, treatment systems, and effluent flow paths.The inspectors selectively reviewed changes to the ODCM made by the licensee since the last inspection to identify differences.

The inspectors discussed, and selectively determined, if the licensee had identified any non-rad'ioactive systems that have become contaminated as disclosed either through an event report or are documented in the ODCM since the last inspection.

The inspectors selectively determined if any newly contaminated systems had an unmonitored effluent discharge path to the environment.

Walk downs and Observations The inspectors selectively walked down components of the gaseous and liquid discharge systems to verify equipm-ent configuration, flow paths, and material conditions' The inspectors selectively reviewed liquid waste discharge permits'Samplinq and Analvses The inspectors selectively reviewed, as available, effluent discharges made with inopera'ble (declared outbf-service)effluent radiation monitors to verify that controls weie in-place to ensure compensatory sampling was performed consistent with the Rad iolog ical Effl uents Tech nical specification (RETS)/ODCM.

The inspectors selectively determined if the facility was relying on the use of compensatory 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 sample analyses.Enclosure b.21 Dose Calculations The inspectors selectively reviewed liquid and gaseous waste discharges to verify that the projected doses to members of the public were accurate and based on representative samples of the discharge path.The inspectors selectively evaluated the methods used to determine the isotopes that were 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 calculations since the last inspection io verify changes were consistent with the ODCM and Regulatory Guide (RG) 1

.109 . The inspectors

also reviewed meteorological dispersion anO Oepoiition factors used in the ODCM and effluent dose calculations to ensure appropriate factors were being used for public dose calculations.

The inspectors reviewed the latest Public Land Use Census to verify that changes had been factored into the dose calculations and to verify calculated doses were within the 10 CFR Part 50, Appendix I and TS dose criteria.The inspectors selectively reviewed, as available, abnormal gaseous or liquid tank discharges and associated dose calculations, evaluations, and corrective actions.Ground Water Protection lnitiative lmplementation The inspectors selectively reviewed implementation of the ground water monitoring program. The inspectors reviewed monitoring results of the Ground Water Protection initi-ative (Gpl) to determine if the licensee had implemented its program as intended and to identify any anomalous or missed results and to determine if the licensee had identified and addressed deficiencies through its CAP'Problem ldentification and Resolution The inspectors verified that problems associated with the effluent monitoring and control program were being identified by the licensee at an appropriate threshold and were fro[erty addressed'for resolution in the CAP. The inspectors discussed corrective actions-for identified concerns with Exelon personnel' Findinos lntroduction.

The inspectors identified a Green Finding associated with failure to establ'Sh, 'rnplement, and maintain adequate QA program elements in the area of effluent and environmental monitoring as required by Peach Bottom Units 2 and 3 TSs Sectio n 5.4.1.c, "Quality assurance for effluent and environmental monitoring." Specifically, Exelonjs QA program for effluent and environmental monitoring was not sufficient 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 of dose validation and sampling program modification; 2) that changes in meteorological farameters, used for public Oose prolections and assessment, were promptly and Enclosure 22 adequately evaluated; and 3) that laboratory quality assurance programs for effluent and enviionmental sample analysis measurement systems were adequate and implemented properly.Description.

Peach Bottom Units 2 and 3 TSs require in Section 5.4.1.c, among other requtrements, that QA procedures for effluent and environmental monitoring be established, implemented, and maintained' Exelon established various effluent and environmental monitoring QA program procedures to provide QA for important elements of the effluent and environmental monitoring program that could collectively and individually impact public dose projections attributable to effluent releases from the Peach Bottom Station. These QA elements covered such matters as: 1) evaluation of public land use around the station to ensure dose pathway analyses were conducted taking into consideration current land use around the facility; 2) evaluation of changes to important meteorological parameters used for public dose'projection; and 3) various laboratory QA program elements to provide assurance that onsite and vendor laboratories were providing acceptable analytical results. The inspectors identified six examples where the effluent and environmental QA program was ineffective as follows:. Exelon did not conduct an evaluation of its 2010 Land Use Census results in accordance with Procedure CY-AA-1 70-1 000, Revision 5, "Radiological Environmental Monitoring Program and Meteorological Program lmplementation." The evaluation supports tfre Oetermination, from a QA perspective, of the need for additional new monitoring stations (compensatory measures)based on changes in the land use and calculaied dose or dose commitment.

Procedure CY-AA-170-1000 required in section 4.5, that the census be reviewed against the requirements listed in ine station's ODCM, and the ODCM required that compensatory measures be taken to add new environmental monitoring locations, within 31 days, if needed'Exelon had completed its 2010 Land Use Census (dated January 4, 2011) for Peach Bottom and provided a summary of the census to the NRC in its May 31,2011'Annual Radiological Operating Report (No. 63). Exelon subsequently conducted an evaluation of the 2010 Land Use Census in July 2011, which included new information, and concluded no change in monitoring was required.

Exelon placed this issue into its CAP (AR 1226969)'. Exelon did not conduct an assessment of its long term meteorological data to compare the 2010 annual meteorology values of )UQ (dispersion factor) and D/Q (deposition factor) against long term averages to determine if non-conservative irends existed. Exel6n Procedure CY-AA-170-1000, Revision 5, "Radiological Environmental 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 for significant changes in a non-conservative direction.

The procedure required that if the 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, if there was a gap between ODCM requirements and sample locations.

Exelon subsequently compared the data in June 2011 and placed this issue in the CAP (AR 1226202).Enclosure 23. The inspectors identified that Exelon's QA program for meteorological data evaluation 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 meteorological average values resulting in potential incorrect dose calculations.

Exelon subsequently evaluated this new data in December 2011 and concluded there was no significant change in critical sector dose projections and that public dose projections continued to be well within 10 CFR Part 50, Appendix l, ALAM design values 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 determine if sample analyses met applicable QA requirements, as required by Procedure CY-AA-130-201, Revision 1, "Radiochemistry Quality Control," Section 4.3. The cross-check samples that were not evaluated included:

tritium; gross alpha;Sr-89/90; and filter gas and solid samples. The inter and intra laboratory samples were subsequently evaluated in December 2011 using the criteria within Procedure CY-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 QA sample analysis results, obtained from a vendor laboratory for analysis, were subsequently critically evaluated against applicable criteria specified in procedures.

Exelon did not conduct its onsite biennial evaluation for liquid tritium analysis during second quarter 2011 sampling activity, in that a traceable standard was not analyzed onsite in accordance with the QA program requirements specified in CY-AA-130-201 Revision 1. Exelon subsequently placed this issue into its CAP (AR 1302720), and successfully 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 contain sufficient guidance to ensure appropriate analytical data was used for sample inter-comparison resolution.

Exelon subsequently identified similar concerns in other cross-check procedures.

ln addition, incorrect sample inter-comparison analysis resultswere identified (e.9., November 14,2011 tritium sample analysis).

Exelon placed this issue into its CAP (AR 1303308) to correct the procedural deficiencies and re-perform the cross-check using appropriate analytical methods.Given the identified issues, Exelon conducted extensive re-analysis of projected offsite doses taking into consideration new Land Use Census data as well as the identified changes in meteorological parameters.

Exelon concluded there was no significant impact on public doses and public dose projections remained well within 10 CFR Part 50 Appendix I ALARA design specifications.

Exelon also reviewed environmental sample data and did not identify any anomalous results. Exelon also evaluated those samples results (as well as inter-comparison results) that had not been critically evaluated (or incorrectly evaluated)and concluded, based on data review, that the sample results met comparison criteria once evaluated properly.

Exelon was continuing its data review.Further, Exelon conducted a liquid tritium analysis and concluded that the analysis results were within acceptance criteria.

The inspectors discussed and selectively reviewed Exelon's analyses and did not identify any significant dose consequence.

24 Analvsis.

Exelon did not establish, implement, and maintain an adequate QA program in the area of etfluent and environmental monitoring as required by Peach Bottom Units 2 and 3 TSs, Section 5.4.1.c, for elements of its effluent and environmental monitoring program. Specifically, Exelon's QA program for effluent and environmental monitoring waJnot sufficiently robust to ensure: 1) that both adequate and timely evaluation and assessment of chinges described in the 2010 Public Land Use Census were conducted for purposes of dose validation and sampling program modification; 2) that changes in meteorological parameters, used for public dose projections and assessment, were promptly a-nd adequately evaluated; and 3) that laboratory QA programs, for effluent and environmental sample analysis measurement systems were both adequate and implemented.

The failures to establish, implement, and maintain such a QA program was 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 Safety cornerstone attribute of programs and processes and adversely affected the associated cornerstone objective in thai failure to establish, implement, and maintain an adequate eA program inine effluents and environmental monitoring program area adversely affeiteO the licensee's ability to ensure adequate protection of public health and safety'Specifically, Exelon's QA program for effluent and environmental monitoring, was not sufficienly robust to ensuie: i; tnat adequate and timely evaluations and assessment of changes described in the 2010 Public Land Use Census were conducted for purposes of dose validation and sampling program modification; 2) that changes in meteorological parameters, used for public dose projections and assessment, were evaluated in an adequate and timely manner; and 3) that laboratory QA programs for effluent and enviionmental sample analysis measurement systems were adequate and properly implemented.

This finding was assessed using IMC 0609, Appendix D, and determined to be of very low 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 site or to the offsite environs that would impact public dose assessment; and there was no substantial failure to implement the radioactive effluent release program. The licensee was able to re-assess the dose to members of the public from routine releases and determined that projected doses did not nor were likely to exceed applicable limits including ALARA design specifications of 10 CFR Part 50, Appendix l, or ..10 CFR20.1301(e).

There was no effluent monitor calibration issue and the licensee had data by which io assess dose to a member of the public. Exelon plans to provide updated 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 personnelfollowed procedure compliance requirements activities for the effluent and environmental monitoring 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 transmitted to Exelon via separate correspondence.

In accordance with NRC IMC 0612, since the significance determination of ihe underlying finding has been completed and does not inlerfere with the NRC's current review of the violation, the finding can be issued at this time. The finding and associated violation, although dispositioned separately, only count aS one input into the plant assessment process. However, the number and characterization of violations is subject to change pending the NRC's final review.Enclosure 25 Exelon entered this matter into its CAP (ARs: 1226969,12262Q2,1299543,1299476, 13O272O,and 1303308), (FtN 0500027712011005-02;0500027812011005'02; Failure to Establish, lmplement,'and Maintain Adequate QA for Effluent and Environmental Monitoring)2RS07 Radioloqical Environmental Monitorinq Proqram (71124.07 - 1 sample)a. Inspection ScoPe Inspection Planninq fne 'nWectoffictively reviewed the annual radiological environmental and effluent operating reports (2009, 2O1O), and the results of licensee assessments since the last inspection, to verify that the Radiological Environmental Monitoring Program (REYll was 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 to environmental monitoring, commitments in terms of sampling locations, monitoring and 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 environmental monitoring stations.The inspectors selectively reviewed the Peach Bottom Units 2 and 3 Updated Final Safety Analysis Report (UfSnn) for information regarding the environmental monitoring program and meteorological monitoring instrumentation' Site InsPection The inspectors selectively reviewed any significant changes made by the licensee to the ODCM as the result of changes to the Public Land Use Census, long-term meteorological conditions (e.g., -3-year average), or modifications to the sampler stations since the last inspection.

itre inspectors reviewed technicaljustifications for any changed samPling locations.

The inspectors evaluated detection sensitivities with respect to TS/ODCM used for counting samples (i.e., the samples meet the TS/ODCM required lower limits of detection (LLD).ldentification and Resolution of Problems The inspectors determined if problems associated with the REMP were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the CAp. In addition to the above, the inspectors verified the appropriateness of the corrective actions for a selected sample oi problems documented by the licensee that involve the REMp. The inspectors discussed corrective actions for identified concerns with Exelon Personnel' b. Findinqs No findings were identified.

26 Transportation (7 1 124.08 - 1 sample)Inspection ScoPe Inspection Planninq The inspectors selectively reviewed the solid radioactive waste system des,cription in the UFSAR, the process conirol program (PCP), and the recent radiological effluent release reports ior iniormation on the types, amounts, and processing of radioactive waste disposed.Radioactive Material Storaqe The inspectors selectively reviewed areas where containers of radioactive waste were stored, 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 to Labeling Req uirements," as appropriate.

The inspectors selectively toured the facility to verify that the radioactive materials storage areas were controlled and posted in accordance with the requirements of 10 CFR part20, "standards for Protection against Radiation." Radioactive Waste Svstem Walkdown The inspectors reviewed and discussed liquid and solid radioactive waste processing systems. The inspectors also selectively reviewed various photographs, live camera uL*r, and radiological surveys to access material conditions of rooms and tanks. The inspectors reviewed area staius logs for radioactive waste areas and systems.Shipment PreParation The inspectors selectively observed shipment packaging, surveying, labeling.'

marking'placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers irovided [o tn" driver, and licensee verification of shipment readiness[srripment pM-1 1-1si ;. rne inspectors observed radiation workers during the conduct of tne radioactive material shipment preparation.

The inspectors determined if the shippers were knowledgeable of the shipping regulations and whether shipping peisonnel demonstratei adequate skills to accomplish the package preparation iequirements.

The inspectors verified that the licensee's training program provided training to personnel responsible for the conduct of radioactive waste processing and radioactive material shipment preparation activities' ldentification and Resolution of Problems The 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 for Enclosure 27 resolution in the licensee CAp. The inspectors discussed corrective actions for identified concerns with Exelon Personnel' b. Findinqs No findings were identified.

4OA1 Performance

lndicator Verification (71151 - 14 samples)Cornerstone:

Mitigating SYstems.1 Mitioatinq Svstems Performance lndex (10 samples)a. Inspection ScoPe The inspectors sampled PBAPS's submittals of the Mitigating Systelg Performance lndex ifrrfSef l for the following systems for the period of October 1,2010 through September 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 used definitions and guidance iontained in Nuclear Energy lnstitute (NEl) Document 99-02, ,,Regulatory AsJessment Pl Guideline," Revision 6. The inspectors also reviewed pBApS operator narrative logs, condition reports (CRs), MSPI derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findinqs No findings were identified.

.2 Safetv Svstem Functional

Failures (2 samples)a. lnspection ScoPe The inspectors sampled PBAPS's submittals for the safety system functional failure pl 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, inspectors used definitions and guidance contained in the NEI Document 99-02, "Regulatory Assessment pl GuidJline," Revision 6, and NUREG-1o22, "Event Reporting Guidelines 10 cFR 5}.72and 10 cFR 50.73." The inspectors reviewed PBAPS's operator narrative logs, operability assessments, MR records, maintenance WOs, condition reports, event reports, anO l..tRC integrated inspection reports to validate the accuracy of the submittals.

b.a..3 28 Findinqs No findings were identified.

Occupational Exposure Control Effectiveness (71151- 1 Sample)lnspection Scope The implementation of the Occupational Exposure Control Effectiveness Pl Program was reviewed.

The inspectors selectively reviewed CAP records for occurrences involving HRAs, VHRAs, and unplanned personnel radiation exposures since the last inspection in this area and the previous four complete quarters.

The review was against the 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 NEI criteria were recognized and identified as Pls.Findinos No findings were identified.

RETS/ODCM Radiolosical Effluent Occurrences (71151- 1 Sample)lnspection Scope The implementation of the RETS/ODCM Pl was reviewed.

The inspectors selectively reviewed CAP records and projected monthly and quarterly dose assessment results due to radioactive liquid and gaseous effluent releases; for the past four complete quarters.

The review was against the 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 NEI criteria were recognized and identified as Pls.As part of this review, the inspectors also reviewed Exelon's evaluations and public dose assessments, as necessary, associated with identification of localized onsite ground water contamination within the restricted area.Findinos No findings were identified.

ldentification and Resolution of Problems (71152 - 4 samples)Routine Review of Pl&R Activities lnsoection Scope As required by Inspection Procedure71152, "Problem ldentification and Resolution," the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that PBAPS entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors

.4 b.40.p.2.1

a.Enclosure b.29 performed a daily screening of items entered into the CAP and periodically attended CR screening meetings.Findinqs and Observations No findings were identified.

(71152 - 1 annual.2 b.sample)Inspection Scope The inspectors reviewed the CRs and the corresponding corrective actions from the last RFO on Units 2 and 3. The inspectors interviewed key site personnel regarding the incidents and changes to the refueling process. The inspectors evaluated effectiveness of the corrective actions, EOC, and station personnel knowledge of the process changes. The inspectors reviewed Peach Bottom procedures related to FH and the recenl training provided to the FH personnel.

The inspectors assessed Exelon's problem ident-ification threshold, cause analyses, EOC reviews, compensatory actions, and the prioritization and timeliness of corrective actions to determine whether Exelon person nel were appropriately identifyi ng, characterizi ng, and correcti ng problems associated with this issue, ahd whether the planned or completed corrective actions were effective.

The inspectors compared the actions taken to the requirements of Exelon's CAp and 10 iFR Part 50, Appendix B, "QA Criteria for Nuclear Power Pants and Fuel Reprocessing Plant." In addition, the inspectors performed in plant walkdowns and interviewed site p6rsonnel to assess the effectiveness of the implemented corrective actions.The inspectors reviewed Peach Bottom's process to identify, prioritize-, and resolve refuel floor distractions in an attempt to minimize operator burdens. The inspectors observed Exelon personnel conducting fuel movement in the reactor vessel during the September 2011 Unit 3 RFO.Findinos and Observations No findings were identified.

The inspectors determined that the Exelon corrective actions were comprehensive and implemented in a timely fashion. Specifically, the just-intime training of the FH crews was performed at the sjte prior to the Unit 3 outage. The inspectors observed.

good communications between the FH crew members during fuel movement' The inspectors observed a constant management presence during FH activities.

The inspectors observed that plant personnel involved with the FH activities were knowledgeable regarding the previous FH events and associated corrective actions. The inspectors observed 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 more benefit to refueling personnel if it had been updated at the start of the Unit 3 RFO. The revision to the plan'was a corrective action determined from the FH events during the 2010 Unit 2 RFO.Enclosure 30.3 Review of the Units 2 and 3 Spent Fuel Pool (SFP) Boraflex Deqradation Corrective Actions (71152 - 1 annual sample)lnspection Scope The inspectors assessed Peach Bottom's historical SFP shutdown margin. The inspectors compared Exelon's SFP Boraflex CAP documentation and 10 CFR Part 50, Appendix B, 'QA Criteria for Nuclear Power Plants." The SFP criticality calculations listed in lR 1225840-13 were evaluated to determine the significance of the Boraflex degradation.

The Exelon SFP Boraflex technical evaluation was reviewed to determine if the SFP TS sub-criticality margin remained less than

.95 Keff. The inspectors

also interviewed site personnel to assess the effectiveness of the implemented corrective actions.Findinos and Observations The inspectors identified one observation related to Exelon's implementation of the corrective actions associated with the SFP Boraflex degradation issue. The issue is currently under review by the NRC as an Unresolved ltem discussed in inspection report 2010004. When that review is completed, the final decision will be transmitted to Exelon via a separate correspondence or in the resident inspector quarterly report. The inspectors also determined that once the TIA response was provided by Nuclear Reactor Regulation (NRR), PBAPS's corrective actions were adequate.The inspectors reviewed Exelon's Technical Evaluation written to support continued operation of the SFP storage racks provided by Peach Bottom. The Technical Evaluation applied additional margins to account for the changes in fuel designs, code deficiencies, and estimated boron degradation in the SFP racks. The inspectors also reviewed the TIA provided by Nuclear Reactor Regulation (NRR) in response to a TS Amendment request. Exelon subsequently revised the calculation contained in the Technical Evaluation, applying some additional conservatisms raised by the NRR review. Actual conditions in the SFPs did not appear to exceed the TS K"tr < 0.95 limit.Based on the information provided by Exelon, the inspectors considered that TS 4.3.1.1.b., "Fuel Storage Criticality," was not exceeded.Semi-Annual Review to ldentifv Trends (1 semi-annual Resident Inspector sample)Inspection Scope The inspectors performed a detailed review of items entered into the CAP to identify trends (either NRC or licensee-identified), and develop insights into PBAPS's progress in identifying and addressing themes. The inspectors reviewed a list of approximately 8,844lRs that PBAPS initiated and entered into the CAP action tracking system (Passport)from June 1,2011 through December 1,2011. The list was reviewed and screened to complete the required semi-annual Pl&R trend review. The inspectors evaluated the lRs against the requirements of Exelon CAP procedure, LS-AA-125, and 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action." a.b..4 a.Enclosure b.31 Findinos and Observations No findings were identified.

Based on the overall review of the selected sample, the inspectors concluded that pBApS was appropriately identifying and entering issues into the CAP, adequately evaluating the identified issues, and properly identifying a.dverse trends before they became riore safety significant problems.

However, the inspectors did note the three adverse trends discussed below'Human performance and configuration control continued to be focus areas for PBAPS during the second half of 2011. PBAPS identified four configuration control events from June-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' A common cause analysis (ccA) was performed in June of 201 1 (lR 1203953.), and a Configuration Control Recovery Team was implemented to focus on correcting the adverle 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 Occupational Safety and Heilt6 Administration recordable injuries in September of 2011 (lRs 12616gg,1264502, and1265372).

Additionally, there were 45 first aid events during'the September and October 2011Unit 3 RFO (P3R18). PBAPS identified this negative trend, and has performed a CCA to address the adverse trend in industrial safety performance during P3R18 (\R1277414).

The inspecto_rs noted that PBAPS has ferformed 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 safety performance between January 1 and April 25 of 20]l (lR 1203002):

and an Apparent Cause Evaluation was completeO in November of 2011 in response to Nuclear Oversight truOSl identifying pBAPS's failure to complete actions to address unsatisfactory performance from 2010 in the area of industrial safety'The inspectors identified an adverse trend in the area of equipment reliability.

During the review period from June 't to December 1, 2011, PBAPS submitted five licensee event reports (LERs) related to degraded or failed equipment, and also noted a sixth equipment 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 finding was 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 System Safety 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 been entered into the PBAPS's CAP.Enclosure 32.5 Actions (71152- 1 annual samPle)Inspection Scope The i"spectors

'eviewed licensee actions to resolve vital bus degraded voltage protectibn issues. The inspectors selected lR 01 119440 as a Pl&R sample for a detailed iollow-up review because it tracked the analysis and disposition of the issue' There were numerous lRs associated with the vital bus degraded voltage protection issue. As documented in NRC Inspection Report 0500027712008007 and 0500027812008007, an unresolved item (URl) was opened to determine whether the approved PBAPS licensing basis 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 basis LOCA. 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' The lnaf ttn response determined that PBAPS license basis for degraded voltage relay iettings did not include credit for the LTCs on the startup transformers to protect the class"l-E safety-related equipment during a design basis LocA. The inspection report also closed the URI and enforcement action was documented.

The licensee subsequently issued LER 2010004-00 which was reviewed by the Nfp and closed as documentedin inspection report 0500027712010005 and 0500027812010005 with no additional enforcement action.The inspectors assessed Exelon's problem identification threshold, EOC reviews, operabiiity evaluations, technical evaluations, modification packages, a1d interim compensatory measures.

The inspectors also assessed Exelon's prioritization and timeiiness of corrective actions to determine whether Exelon was appropriately identifying, characterizing, and correcting problems associated with the identified issue and whether the compleieO or planned c-orrective actions were appropriate to prevent recurrence.

Additionally, the inspectors performed walkdowns of accessible portions of affected motor control ienters (lrrtCCs)and components to assess if abnormal conditions existed. The inspectors also interviewed plant personnel to gain insights regarding the identified issues and implemented or planned corrective actions'Findinqs and Observations No findings were identified.

The inspectors determined that Exelon properly implemented their CAP regarding the initial discovery of the reviewed issue. The lR package was complete and included'operability evaiuations, technical evaluations, interim compensatory measures, EOC reviews, and contained implemented and planned corrective actions. Additionally, the elements of the lR, technical evaluations, and operability evaluations were detailed and thorough.

lmplemented and planned corrective actions appeared appropriate to minimiie the potential of recurrence.

The inspectors determined that corrective actions included performing an operability evaluation, which included electrical calculations that used the most limiiing uoitrg" level allowed by the TS (excluding the LTC), identifying components that wou"ld not-have adequate voltage to operate under the identified.ondition, implementing interim compensatory measures (revising operations procedures and operaior training)to operate equipment that would not have adequate a.b.Enclosure 33 voltage to operate in the design basis LOCA, and creating and implementing modification packages for MOVs and MCCs to allow equipment to operate under the analyzed condition.

The inspectors found the operability evaluation and interim compensatory measures reasonable.

Exelon had completed all modifications associated

• itn ftlOvr and MCCs that would not have adequate voltage during a design basis LOCA.Additional corrective actions included performing an evaluation of vital buses at a lower voltage (3737 volts) than the TS lower limit for the function four LOCA relay setting. This analysis'was perfoimed to identify equipment needing margil impro.vement, but remiined operable for the TS function four relay setting band. The inspectors determined that Exelon had completed modifications on some of the equipment identified in the analysis and had scheduled modifications on the remaining equipment identified.

.6 ldentification

and Resolution of Problems (71124.01,71124'Q2,71124'03,71124'04, 71124.05,71124.06)a. lnspection ScoPe The inspectors selectively reviewed corrective action documents for occupational radiation safety program and effluent and environmental monitoring program' See documents reviewed.The review was against criteria contained in 10 CFR ParI20, TSs, ODCM, and applicable station audit and surveillance procedures' b. Findinqs No findings were identified.

(71153 - 4 samples)(closed) LER 05000277/2011003-00:

Delayed Relay operation Results in E-3 EDG Actuation during Surveillance Testing On Septem ber 21, 2011, during the P3R18 RFO, an unplanned, valid actuation of the E-3 EDG occurred during surveillance (functional)testing of the E-33 4 kV emergency bus undervoltage relays.- The E-3 EDG started unexpectedly when time delay relay 3-54-1g3-1708 did noi operate properly, resulting in a delayed E-33 bus fast-transfer between the TS off-site sources. This delay resulted in the operation of an additional undervoltage 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 full speed 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 to pioperty tunction.

The relay was replaced and tested satisfactorily.

There was no actual safety consequences assoiiated with this event. PBAPS entered this item into the CAP for additional evaluation and investigation.

The inspectors determined that there was no performance deficiency associated with the failed relay. This LER is closed.40A3.1 Enclosure 34.2 (Ctosed) LER 05000277/2011004-00:

Oil Leak Resulting in E-1 EDG lnoperability On September 23,2011, during the P3R18 RFO, an oil leak was discovered on the E-1 EDG when the engine was being shutdown during 4kV emergency bus lesting. The leak was determined to be from a crack on the lube oil drain line for the combustion air intake blower (supercharger).

Analysis determined that the leak previously existed and the EDG would not have been able to perform its safety function to successfully run for a 24-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 was tested suciessfully with no leaks in the drain line. PBAPS entered this issue into the CAp, performed EOC inspections, and took corrective action to revise the associated maintenance procedure.

The enforcement aspects of this LER are discussed in Section 4OA7. This LER is closed.(Ctosed) LER 05000278/2011001-00:

Containment lsolation Valve Inability to Close for a Design Basis Event due to Degraded Lubricant On Septem ber 22, 2011 , during the P3R18 RFO, it was identified that the ability of the Unit 3 RWCU outboard isolation valve (MO-3-12-018)to close was degraded due to a motor-operator greasing deficiency.

This deficiency was identified during performance of routine MOV maintenance and diagnostic testing. lt was determined that this condition was prohibited by TSs since this primary containment isolation valve was determined to be inoperable for containment isolation purposes during the previous operating cycle for a time period longer than allowed by TS. The cause of the greasing deficienjy was due to inadequate lubrication.

The valve was repaired on September 23, 2011. There was no actual safety consequences associated with this event. The enforcement 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 Condition Prohibited by TS On September 19, 2011, during the P3R18 RFO, Engineering personneldetermined that a leak on the inlet connection to the'D' RHR suction piping thermal relief valve was due to cracking of the relief valve body and not due to a mechanicaljoint leak as originally identified -uring cycle 18 operations on April 27 , 2010. On April27 , 2010, PBAPS identified the leik to be one drop per two minutes, and incorrectly determined that the leak was from a threaded connection.

Subsequent non-destructive evaluation following the September 19, 201 1 determination confirmed the leak to be through the relief valve body. Based on analysis, PBAPS determined the relief valve could have become detjched from the piping during the worst case design basis seismic event' This condition would resuit in tfre 'D; RHR pump being inoperable, thereby affecting the RHR low pressure coolant injection function.pBApS determined the cause of the delay in identifying the inoperable condition was due to inadequate technical rigor when evaluating the operability of the relief _valve on April 27, 2010. The leaking relief valve was replaced on October 2,2011. EOC reviews were performed for similar components in Unit 2 and Unit 3. Operations has instituted

.3.4 Enclosure

a.35 additionaltraining and procedure revisions to drive improved performance regarding operability evaluitions.

There were no actual safety consequences as result of this event. This event was considered as a condition prohibited by TSs and loss of safety function.

The enforcement aspects of this LER are discussed in Section 4OA7. This LER is closed.4OA5 Other Activities

.1 NRC Review of Exelon's Response to NCV EA-11-128 Inspection

Scope On Septem ber 12, 2011, the NRC transmitted a NCV and a Green finding to Exelon related to a change Exelon made to the emergency action level (EAL) basis for EAL HU6, which introduced a decrease in effectiveness to Peach Bottom's Emergency Plan (Ep)'and resutted in a violation of the requirements ltipulated in 10 CFR 50.5a(q).5pecifically, the licensee modified the EAL Basis in EAL HU6, Revision 16, which extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm.This change decreased the effectiveness of the EP by reducing the capability to perform a risk sign'ificant planning function in a timely mannef.- The_NCV and finding were describJd in detail in NRb Inspection Report Nos. 0500027712011502 and 0500027812011502.

In response to the NCV and finding, Exelon entered the issue into their CAP as lR 01184333 and subsequently implemented Revision 21 of the Peach Bottom EP, which restored the EAL HUO Aasis to the Revision 15 guidance, thereby removing the decrease in effectiveness.

The inspectors reviewed lR 01 184333 and the revised version of the HU6 Basis, and discussed the corrective actions with the Peach Bottom Emergency PreParedness staff'Findinqs and Observations No findings were identified.

The inspectors determined that Exelon's response and corrective actions were reasonable and appropriate to address the NCV and finding, and their underlying performance deficiency.

The NRC considers the issue to be closed'lndependent Spent Fuel Storaqe lnstallation (60855)lnspection ScoPe The inspectors selectively reviewed routine operational surveillance data, including radiological surveillance,ior the Independent Spent Fuel Storage Installation (lSFSl)facility.

The inspectors toured the facility and made independent radiation re"rur"rents of the facility.

The data was evaluated against 10 CFR Part 20 and applicable Exelon Procedures.

Findinqs No findings were identified.

.2 a.Enclosure

36 4046 Meetinqs.

lncludinq Exit Quarterlv Resident Exit Meetinq Summarv On January 20,2012, the resident inspectors presented the inspection results to Mr. 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 no proprietary informatioh was retained by the inspectors nor documented in this report'4C,A7 Licensee-ldentified Violations The following violations of very low safety significance (Green) were identified by the licensee "nd-rr" violations of runC requirem-ents which meet the criteria of the NRC Enforcement Policy for being dispositioned as NCVs'. TS b.4.1 states, in part, that written procedures shall be implemented a1d maintained as recommended ln nC 1.33, Appendix A, November 1972. RG 1'33, Appendix A'Section l, "procedures for Performing Maintenance," subsection 1, states the following: "Maintenance which can affect the performance of safety-related equipm6nt should be properly preplanned and performed in accordance with written procedures, documenied insiructions, or drawings appropriate to the circumstances' bkill, nottally possessed by qualified maintenance personnel may not require detailed step--by-step delineition in a procedure." Contrary to the aboye,. PBAPS did not properly preplan and perform maintenance which affected the E-1 EDG'Specifically, pAApd determined that a damaged lubricating oil drain line should have been identified and replaced during planned maintenance activities prior to the occurrence of leakage. As a consequence of not identifying and replacing the damaged drain line,-pBAPS determined that the E-1 EDG was unable to perform its 24-hour mission time, and therefore was inoperable, during the period of time between April27 , 2011, and September 23, 2011'The finding was determined to be of very low safety significance, for both Peach Bottom Units 2 and 3, in accordance wit-h lMc 0609, Appendix A, "Delgrlnining the Significance 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 because it reiresented a loss of the E-1 EDG safety function, between April27 and Sepiember 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 3 analysis because the Phlse 2 analysis, conducted by.the inspectors using- the Peach Bottom pre-solved Risk-lnformed lnspection Notebook, indicated that the finding could 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 conduct the phase 3 analysis, with the conservative assumption that the E-1 EDG would not have 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 two hours assuming that the drain line broke and the potential that operators could have temporarily limiied the leakage from the supercharge lube oil drain line. This Enclosure 37 analysis indicated an increase in core damage frequency (ACDf) forinternal initiaiing events in the range of one core damage accident in 2,500,000 years of reactor operation, in the low E-7 range per year for each unit. The dominate core damage sequences included losses of offsite power with the failure of all EDGs resulting in a station blackout (SBO), followed by the failure of operators to reduce direct current loading to allow extended operation of the RCIC system alq -depressurize the realtor, and with inability to recover offsite power, the SBO source of power from the Conowingo Dam or an EDG in two hours. In accordance with IMC OObgR, for a finding with an internal events ACDF above 1E-7, the SRA assessed the 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 3 SpAR modlls, tfrit tne total ACDF (internal plus external)would not be above the 1 E-6 threshold; and 2) the increase in large early release frequency (ALERF)'determining that given the operators ability, following core damage, to recover offsite power and depressurize and inject water to the reactor from low pressure sources and 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 into Exelon'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 ECCS injection subsystem should be iestored to an OPERABLE status within seven days during operatibnal modes 1 and 2, or requires action to place the unit in operational mode 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 inoperable during 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 case design basis seismic event. This condition would result in the 'D' RHR pump being inop6rable, thereby affecting the RHR LPCI function.

Because the 'B' RHR pump was unaffected by this even-t, there was no total loss of the 'B' LPCI train safety function.

The inspectors determined that this event screens to Green using the Table 4b seismic screening criteria in Attachment 4 of IMC 0609, "SDP." Because this finding is of very low sifety significance and has been entered into Exelon's CAP under lR i264g09, ihis violation iJbeing treated as a Green, licensee-identified NCV consistent 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/Closed

05000278/201

005-01 NCV Untimely Corrective

Action to Correct MOV Degraded Stem Lubrication (Section 1R12)Attachment

Opened

0500027712011005-02

05000278/2011005-02

Closed

050002771201

1003-00

050002771201

1004-00

05000278/201

001 -00

05000278/2011002-00

0500027712011502-01

0500027812011502-01

0500027712011502-02

05000278/2011502-02

Discussed

0500027712010004-01

FIN Failure to Establish, lmplement, and Maintain Adequate QA for Effluent and Environmental

Monitoring (Section 2RS06)Delayed Relay Operation

Results in E-3 EDG Actuation

during Surveillance

Testing (Section 4OA3.1)Oil Leak Resulting

in E-1 EDG Inoperability (Section 4OA3.2)Containment

lsolation

Valve lnability

to Close for a Design Basis Event due to Degraded Lubricant (Section 4OA.3)RHR Leaking Relief Valve Results in Condition

Prohibited

bY TS (Section 4OA3.4)(Traditional

Enforcement)

Changes to fRt gasis Decreased

the Effectiveness

of the Plan without Prior NRC Approval (Section 4OA5)Changes to EAL Basis Decreased

the Effectiveness

of the Plan without Prior NRC Approval (Section 4OA5)Non-conservative

TS and Potential

Non-Compliance

Associated

with Degraded SFP Boraflex Panels (Section 40A2'3)LER LER LER LER NCV URI FIN Attachment

LIST OF DOCUMENTS

REVIEWED* -- lndicates

NRC-identified

Section 1R01: Adverse Weather Protection

Procedures

RT-l{66200-2, Heat Trace System Testing, Revision 9, Completed

09/01/1't RT-l-066-200-2 (partial pMT) i{eat Trace System Testing, Revision 9, Completed

10105/11

RT-O-040-620-2, Outbuilding

HVAC and Outer Screen Inspection for Winter Operation, Revision 16, ComPleled

11113111

RT-O-040-

630-2, Winterizing Procedure, Revision 1 2, Completed

1 l 1 21 1 1 CRs lR

941208, Trash Racks Need to be Replaced lR

1078304-10, 2010-201 1 Winter Readiness Critique lR

1165388, Request for AR to Support Trash Rack Replacement

lR 1

197180, 201

1-2012Winter Readiness Tracking Assignments

lR

1201542,Heater Fan Still Running with control Switch in off lR

1239380, HeatTrace Exposed with No Insulation on Valve lR

1239385, Heat Trace Missing Insulation on Valve lR

1239394, lnsulation Falling Apart on valve Hv-2-278-26113

lR

1241418, Winter Readineis

Plant Manager Approval Overdue (06/30/1 1)lR

1242337, Conduit if Broken Off due to Steam Leaks lR

1244622, ZOll-ZOlZ

Winter Readiness Tracking Assignments (Snow)lR

1250769, Unlt Z Condensate Storage Tank Low Level Alarm Challenges

HPCI/RCIC OperabilitY

lR 125g2b6, Administration Building Heat Trace Alarm PanelAll Circuits in Alarm lR

1258267, RT-l-066-200-2

Unsat lR 127726gj,, ZAEI29 Thermostat Cover is Broken / Temp Adjustment Knob is Missing lR

1278940, 3AE1 54 Unit Heater Will Not Energize lR

1283033, Louver #1 at unit 2 circ Pump structure Missing lR

1283034, Louver #2 at Unit 2 Circ Pump Structure could Not be operated lR

1283323, Lo* Temperature at Main Stack Radiation Monitor Building lR

128401 1, Torus Lining Project RCA Exit Trailer (Mini Mobile) No Heat lR

1284600, Roof Exhauster Dampers Will Not Close lR

1284613, Roof Exhauster Dampers Will Not Close lR

1284621, Fan Will Not Start lR

1284689, Deicing Sparger Broken Under Water lR 12gg743, Docurieni Unsat Sign-off on Winterization Routine Test due to Clearance lR

1291388, 201

1-2012 Winter Readiness Certification Letter Approval lR

1296229, Winter Readiness Open ltems Not Complete Prior to 121Q1111 WOs / Action Requests 41?80640{1, Request Deferral to Complete RT-l-066-200-3

A1794038-04, Plan Activity for Temporary Power and Lighting to Mini Mobile Trailer A1803090, Unit 2 Circulating Water Pump Structure Louvers and Screens A1815797, Unit 2 Circ Bay lntake Dampers Require Rebuild

C0231975-13, Install Heat Trace per

ECR 10-00055 Attachment

Miscellaneous

peach Bottom Certification LetterforWinter Readiness, dated November 15,2011

Section 1R04: Equipment

Aliqnment Procedures

TSG 4:1, peach Bottom Station Operational Contingency Guidelines, Revision 18 CRs tn ZOS+ZS-08

and Attachments

1-3 and 6-8, Engineering Computations and

TRT 08-029 for TSG 4.1 Changes lR

1268445, Valve Actuator Would Not Go Into Manual Mode Drawinos M-361, Sheet 1, RHR System P&lD, Revision 81 Miscellaneous

IMC 0609, Appendix L, B.5.b SDP NRC Safety Lvaluation Related to Order

EA-02-026, Docket Numbers 50-277 and 50-278'Section 3.4.9: Inject Water into the Drywell Temporary lnstruction

ZSlSt171, Verification of Site Specific lmplementation of B.5.b Phase 2 and 3 Mitigation Strategies, Revision 1

Section 1R05: Fire Protection

Procedures

EP4A-1007, Radiological

EP Annex for PBAPS, Revision 22 pF-48, Unit 2 RadwaJte Building, RBCCW Room - Elevation

116'-0 inch, Revision 4

PF-4C, Radwaste Building;

Unit2 Recirculating Pump MG Set Room - Elevation 135'-0", Revision 7

PF-144, Circulating Water Pump Structure - General Area, Revision 4 CRs.tn tZZOOO0, Review Criteria for Table H2-Vital Area Miscellaneous

NEI 99{1, tvlethod for Development of Emergency Action Levels, Revision 5 Procedures Requalification Scenario Guide, PSEGl 11 1R, Revision 1 Section 1 R12: Maintenance Effectiveness

Procedures

CH-10, ChemistrY

Goals, Revision 16

CY-AB-120-100, Reactor Water Chemistry, Revision 12 Cy-pB-120-100, Reactor Water Chemistry - GEH Fuel Warranty Limits, Revision 0 sT-c-o95 T-103, Sheet 1, Secondary Containment Control

ER-AA-302-1004, MOV Performance Trending, Revision 6 Attachment

CRs tA lZnZA& Unit 3 RWCU System Secured due to Steam Leak lR

1279788, Potential Small Unit 3 Main Condenser Tube Leak lR

1279935, Unit 3 Reactor Water lnfluent Conductivity Step Change Trends lR

1280025, Unit 3 RWCU System Secured due to Leak lR

1280255, Action Level 1 Entered for Unit 3 Reactor Conductivity

lR

1280228, 'B' RWCU Pump Discharge Block Valve lR

1280406, lssue to Track 90 Days Completion for TC lR

1281063, Rejectable Indication Found on Unit 3 RWCU Piping lR

1281385, Leak Observed at "T" Weld lR

1281888, Action Level 1 Entered For Unit 3 Reactor Chlorides lR

1281989, Unit 3 RBCCW High Radiation Alarm lR

1289399, Request to Provide Engineering with Vibration Data lR

1290153, Root Cause Manpower Inadequate

lR

1295254, Request for cMo to obtain RWcu Piping Vibration Data lR

1295469, Request Work Management Create Unit 3 'B' RWCU Online Work Window lR

892191-08, Root Cause Evaluation - MOV Degraded Stem Lubrication

lR 10970g5, Nuclear Event Report 10-047-Y MOV Failure due to Degraded Stem Lubrication

lR

1266604,

MO-3-12-018

As-Found Underthrust

lR

1266600 ,

MA4-12-018

Operator Grease Condition Unsatisfactory

lR

1277605, MOV Program Health Declined to Yellow in Third Quarter 2011 tR

1296205 ,

MO-2-23-024:

Per'form Valve PM in 1203 Instead of 1303 Miscellaneous

T04336, Peach Bottom License Renewal chemistry commitments Unified Control Room Log, Sunday, October 16,2011, Night Shift Unified Control Room Log, Tuesday, October 18,2011, Day Shift Unified Control Room Log, Saturday, October 22, 2011, Day Shift Unified Control Room Log, Sunday, October 23,2011, Day Shift Procedures

SO SZn.t.B, Diesel Generator Operations, Revision 48 sT-o-052-702-2, E-2 Diesel Generator

24-Hour Endurance Test CRs lR

1220521 Failure of Unit 3 APRM #1 214 Voter lR 1230g41, Five critical component Failures Due to Reactor Nuclear Instrumentation over Past Year lR

1286163,

APRM-LM-3-PB3

2l4Logic Module Did Not Drop Out RPS Logic lR

1286435, A2 Channel/zscram during APRM Logic Module Repair lR

1287120, APRM Voter Card Failures - Need Accelerated Replacement

lR

1144694, Operating Experience Review: EDG Voltage Regulator Inspection lmprovement

lR

1287186, EDG Voltage Not Responding

lR

1287282, Clearance and Tagging Drawinqs E-+tg, Sleet2, Standby Diesel Engine Generators, Revision 17 Attachment

Miscellaneous

Unfied Control Room Log, Friday, November 4,2Q11, Day Shift Section 1 Rl 5: Operabilitv Evaluations

Procedures

NF+B-l3F 1 42O,Establishing Channel Distortion Monitoring Populations, Revision 0 CRs lnlZSql55-04, Operability Evaluation

11-03, Seismic Effects on NWR Control Rod SCRAM at Low Reactor Pressures, Revision 0 lR

1254155, Part 21

SC 11-04 Seismic lmpact on Channel Distortion

lR Q54A27, Title: Part2l

SC 11-04 Seismic lmpact on Channel Distortion

lR

1270659, Failure to lnclude Seismic Input in Channel-Blade Guidance lR

1267512,

CHK-3-164-332058

Leaks Through lR

1267639,

HV-3-164-33170C

Has Through-Seat Leakage lR

1267641 ,

CHK-3-16A-33205C

Leaks Through tR

1268076,

RV-3-02-071

B Failed Leak Test during sT-M-o1G-600-3

Drawino trrt-Agg, Sheet 1, Instrument Nitrogen, Revision 37 M-851, Sheet 1, Nuclear Boiler, Revision 37 Miscellaneous

ME-213, ADS SRV Air Accumulator Sizing Unified Control Room Log, Monday, October 3,2Q11, Day Shift

Section 1R18: Plant Modifications

CRs ttf. tZgOgZ2,

ECR 10-00449 HPCI Cable Incorrectly Routed Drawinqs ffir'eet2,RacewayLayoutRB,Unit3,Area16,Elevation135'-0inch, Revision 77 E-1236, Sheet 3, Raceway Layout RB, Unit 3, Area 16, Elevation

135',-0 inCh, Revision 77 M-1-5-36, Sheet 22,Electrical schematic Diagram HPCI, Revision 77 Miscellaneous peach Bottom Fire Protection Plan, Section 5.1, Analysis and Capability to Achieve Safe Shutdown, Revision 16 peach Bottom Fire Protection Plan, Section 5.2, Description of Reactor Shutdown Methods, Revision 16 Peach Bottom Fire Protection Plan, Section 5.3'11, Fire Area 135, Revision 18 NRC Event Notificatio

n

EN 47442.. peach Bottom 8-hour Non-Emergency Event Notification for HpCl System Steam Supply Valve Cable Unprotected during Postulated Fire unified control Room Log, Tuesday, November 15,2011, Night shift Attachment

Section 1R19: Post-Maintenance

Testing Procedures

51-9-976-470-3, MSIV Closure Timing, Revision 16, Performed

10/03/11

ST-O-054-752-3, E-29 4kV Bus Under Voltage Relays and LOCA LOOP Functional Test and E-234 Alternative Shutdown Control Functional Test, Revision 22, Performed

10105111

ARC 30C208L A-2, Turbine Vibration Thrust High, Revision 18

ARC 20C208L A-2, Turbine Vibration Thrust High, Revision 10

SI-3N-60A-APRM-31FS, Functional Check of APRM 3

RT-O-052-251-2, E1 Diesel Generator lnspection Post-Maintenance FunctionalTest, Revision 21, Performed

11120111 M-004-400, Reactor Pressure Vessel Reassembly, Revision, 29 CRs\R1262081, MSIV Stroke Times UNSAT lR

1271818, 'A' Inboard MSIV Stroke Time lR

1271823, 'A' Outboard MSIV Stroke Time lR

1271825,'D' Outboard MSIV Stroke Time lR

1271826, 'B' Inboard MSIV Stroke Time lR

1271827,'D' lnboard MSIV Stroke Time lR

1271849, 'C' Inboard MSIV Stroke Time lR

1272231, NOS lD: SRO OP Basis/lR's for MSIV Stroke Times lmprovement

lR

1272796, NOS lD: "Reportable Basis" Determination in lR

1262081 is LTA lR

1274027, 'D' lnboard MSIV Stroke Time lR 127230i, 3 'A' I 3'C' Battery Ground When Emergency Transformer Switch S38 Operated lR

1272310, E-3 Diesel Generator Stator Cooling High Winding Temperature Alarm lR

1271137, PMM1 Activity Needed to Support 3BD003 to Alternate Source lR

1271368, Documentation of an Alternate compensatory Measure lR

1276633, Unit 3 Main Turbine Tripped due to High Vibration lR

1276861, 4.0 Crew Critique of Unit 3 PB Main Turbine Startup after P3R18\R1276862, Unit 3 Main Turbine Tripped due to High Vibration lR

1276962, Unit 3 Main Turbine Tripped due to High Vibration lR

1276988, MCR Vibration Alarm

ARC-305 A-2 Alarmed lR

1277000 Unit 3 Main Turbine Tripped due to High Vibration lR

1277081, Turbine Bearing Metal High Alarm Received on unit 3 lR

1279042, 38G002 38 RPS MG Set High Temperature and Vibration tR

1279264, PSO4 End-of-shift critique for Dayshift october 17 - 20 lR

1279985, Loose Terminations in Panel 38C114 lR

1278641, NER

NC-1 1-038 - Browns Ferry MOV Failure Lessons tR

1296131, MOV Operator Inspection in Response to Operating Experience

lPart2l lR

1286163,

APRM-LM-3-PB3

214 Logic Module Did Not Drop Out of RPS Logic Drawinqs M-833, Sheet 1, Instrument Nitrogen, Revision 37 M-851, Nuclear Boiler, Revision 37 WOs / Action Requests

C0240372,Investigate and Repair as Required Attachment

Miscellaneous

Outage Control Center Log, Friday, October 7, 2011, Night Unified Control Room Log, Tuesday, October 4,2011, Dayshift TS 3.8.1 MAT

PB 09-0533-3:

LP Turbine Retrofit Mod Acceptance Test, Performed

10114-1712011

Unified Control Room Log, Friday, October 14,2011, Day Shift Unified Control Room Log, Friday, October 14,2Q11, Night Shift Unified Control Room Log, Saturday, October 15,2011, Night Shift Unified Control Room Log, Saturday, October 15, 2011, Day Shift Unified Control Room Log, Sunday, October 23,2011, Day Shift Exelon Nuclear MOV Program MOV Post-Test Data Review Worksheet,

MO-2-10-154B, Test Date 05/18/1 1 WO R1161992-07,

MO-2-10-1548-OP

As-Left Diagnostic Test M-21 3, Automatic Depressurization System Accumulator Sizing

Section 1R20: Refuelinq

and Other Outaqe Activities

Procedures

SA-AA-111, Heat Stress Control, Revision 8 T-103, Secondary Containment Control, Revision 17 CRs lR

1271280, Additional Oversight Needed for Future Outages"lR

1271674, NRC Resident lnspector-ldentified Loose Conduit lR

1271780, RHR

RV-3-10-072D

Leakage Operability Determination

\R1272329, MSIV

AO-3-01A-080D

PMT Diagnostic

UNSAT lR

1274674, HPCI Piping Needs Additional Venting lR

1277414, Industrial Safety Events during P3R18 Were Unsatisfactory

lR

1271889, P3R18 MSRV/MSSV

As-Found Lift Test Results lR

1271909, Threshold for Entering Near Misses in CAP May be Too High lR

1273083, Adverse Trend in FME Events lR

1273354, P3R18 Drywell Critical Insulation lnspection Results lR

1274320, 40-3-02-021

Penflex Conduit Needs Replaced lR

1274322, Penflex to Temperature Monitor Detached lR

1274325, Penflex to 71A SRV Detached lR

1274328, Penflex to Pot-3-02-0708

Degraded lR

1274329, Main Steam Piping lnsulation Band Needs to be Installed lR

1274330, J Box Screws Missing lR

1274332, A0-3-444-30258-01-OP

Penflex is Detached at Limit Switch lR

1274333, Insulation Damaged on Cooler Piping lR

1274334, Penflex to Magnetrol Switch is Underneath Insulation Blanket tR

1274335, Found Ground Straps Off of Pump and Pump Motor lR

1274338, Temp Probe on Top of

RV-3-02-O71C (TBO491) is Determined

lR

1275808, High Vibration on 3'C' Feed Pump Turbine lR

1276474, Off-Gas lsolations during Off-Gas Startup lR

1276502,

PC-9417A Appears to be Causing SJAE Discharge lsolations

lR

1276510, Off-Normal

Procedure

Entry lR

1276519,

PIC-32398:

SJAE Pressure Oscillating

lR

1277268, Unit 3 RWCU System Secured Due to Steam Leak lR

1277329, Unit 3 Fire Water System Leak lR 1277836. Heat Stress Awareness Missed Attachment

lR1277UA, 4.0 Crew Critique of Unit 3 RWCU Leak lR

1277876, Contamination Associated with the unit 3 RWCU System Secured lR

1281266, P3R18 Ended 86 Hours and 12 Minutes Behind Day 0 Schedule Miscellaneous Outage Control Center Log, Sunday, October 9,2011, Night Outage Control Center Log, Monday, October 10,2011, Night UnifiJd Control Room Log, Thursday, October 13, 2011, Night Shift Sgction 1 R22: Surveillance Testinq Procedures

p1-ga-19304-3, RHFyHPSW System Valves Alternative ControlTesting, Revision

RT-O-o10-304-3, RHRyHPSW System Valves Alternative ControlTesting, Revision Performed

11113111

RT-O-010-304-3, RHRyHPSW System Valves Alternative ControlTesting, Revision Temporary Change 11-204, Performed

11113111

RT-O-023-Z'SO-g,-HpCl Functional Test from Alternative Control Panels, Revision 15

RT-O-023-750-3, HPCI Valve and Component Test from Alternative Control Panels, Revision 13 sT-o-052-

154-2, E-4 EDG Simulated unit 2 ECCS Simulated Auto Start with offsite Power Available, Revision 11, Performed

212112011

SO 52A.1.8, Diesel Generator Operations, Revision 48

ST-O-052-314-2, E4 EDG Slow Start Full Load and IST Test, Revision 20, Performed 1212112011

CRs ttf. tZAggO+, Temporary Change to RT-O-O10-304-3

lR

1289882, lssue Encountered during Testing of Mo-3-10-0258

lR

1174494, Differential Temperatures High Out of Spec lR 13055gg, Erratic Reading on Main Conlrol Room E-4 EDG Allterex Volts CD Meter Drawinqs Mr1^S*5, Sheet 56, Electrical Schematic Diagram RHR, Revision 100 Miscellaneous Un'fied Control Room Log, Sunday, November 13, 2011, Day Shift

Section 1EP6: Drill Evaluation

Procedures

EP4A-100?, Exelon Nuclear Radiological

EP Annex for PBAPS, Revision 22

OT-101, High Drywell Pressure, Revision 13

OT-101 Baies, High Drywell Pressure Bases, Revision 14 CRs]n-tOgS+20, NOS lD: During EP Drill RCIC lsolated with HPCI Inoperable

lR

1298444, NOS lD: EP Drill Deficiencies Not Corrected lR

1307225, lZlOStll EP Drill - EP03 Facilities and Equipment lssues]R

1307226,

12105111 EP Drill - Atom Road Access / Egress tR

1307227,12105111

Drill - Evaluate

EP-AA-113-F-04

for Revision 11 12, 12, Attachment

lR

1307230 ,12105111

EP Drill- Review WebEOC and PMS Drill Actions lR

1305868, Unsat Demonstration criteria in

12105111 DEP Drill Miscellaneous

NO6CPA+B-11-16, Peach Bottom Emergency Preparedness Performance Report (AR 1 279553-35)

pBApS December 5,2011 Station DEP Drill Scenario and Evaluator Notebook PBAPS December 5,2011 Drill Evaluation Report Procedures

RP-AA-460, Controlfor High and Locked HRAs, Revision 20

RP-AA-460-001, Control for VHRAs, Revision 2

RP-AB-460, TIP Area Access Controls, Revision 1

RT-H-ogg-960-2, Outside Radioactive Material Storage Area Inspection and Survey,

RP-AA-201, Access to the RCA for Escorted Visitors, Revision 4 Documents Dose Records Contamination Control - Personnel Contamination Data Dosimetry Performance Testing Data Corrective Action Documents (various ARs)Pl Verification Data Pl Summary Data Revision 7 Procedures

RP-AA-401, OperationalALARA

Planning and controls, Revision 13 Documents General Source Term Data BRAC Point Data Business Plan and Site ALARA Plan Goals (P3R18)Work-ln-Progress Job Reviews and ALARA Reviews Outage 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, turbine work/scaffolding, and condenser work)ARs Tgssg,

1217457,

1263077,

1264425, and

1262272 Documents Corrective Action Documents Airborne Radioactivity Intake Assessments

Section 2RS04: Occupational Dose Assessment

Procedures

RP-AA-210, Documents Use Weighting Factors for External Exposure, dated NRC Safety Evaluation, Application to December 20,2006 Exposure Control and Dose Records General Source Term Data Personnel Contamination Event Logs Personnel lntake Investigations Corrective Action Documents (various ARs: 1268194)Data for Conduct of EDEX Assessment Section 2RS05: Radiation Monitoring lnstrumentation

Procedures

np-nn-aOt, Radiological Air Sampling Program, Revision 4

RP-AA-210-1001, Dosimetry Logs and Forms, Revision 5 Cy-AA-170-000, Radioactive Effluent and Environmental Monitoring Program, Revision 5

CY-AA-170-1100, QA for Radiological Monitoring Program, Revision 1

CY-AA-170-200, Radioactive Effluent control Program, Revision 1

RT-C-095-892-2, Periodic Intra-laboratory Analysis, Revision 1

RT-C-095-897-2, Quarterly cross-check Sample Analyses, Revision 1

RT-C-095-846-2

Gamma lsotopic Analysis of Unmonitored Liquid Effluent

ST-C-095-805-2, Liquid Radwaste Discharge

ST-C-Ogb-BS8-2, Determination of

SR-89, Sr-90, and ALPHA Activity for Main Stack and Roof Vents Particulates Filters, Revision 6

ST-C-095-0855-2, Analysis of Gaseous Releases for Tritium, Revision 3 sT-c-095-862-2, Determination of Instantaneous Noble gas Release

ST-C-095-900-2, Plant Effluent Concentration Dose Analysis, Revision 1 Sl2R-63F-0S0-A1CE, Main Stack Radiation Monitor Electronic Calibration Check

RY-0-17-0504, Revision 1 1

ST-C-095-805-2, Liquid Radwaste Discharge, Revision 13 (Alarm set-point)

sT-c-095-868-2, Drywell High Range Radiation Monitor calibration

sT-c-095-868-3, Drywell High Range Radiation Monitor calibration

S l2R-63E- 2g7 g-B1iE, Venistack Rad iation Monitor

RY-29798, Electronic Calibration St3R-63E-3979-B1CE

Vent Stack Radiation Monitor

RY-3979B Electronic Calibration Dosimetry lssue, Usage, and Control, Revision 18 Documents Calculation and Bases for Effluent Radiation Criteria for Choosing Radiological Gaseous Radiation Monitor System Notebook

RM-14,

RO-20, TelePole, RadPro 5, lnstrument Calibration Records (Gas Air Samplers, Ludlum, REM ball)Out-of-Tolerance RePorts NVLAP Dosimeter Accreditation (Scope of Accreditation)

Shepard Calibrator Source Calibration Data Shepard 89 Verification March 3,2Q11 Area Radiation Monitor Calibration Data (CH-36,

CH-18-2,

CH-18-3,

CH-27 Monitor Calibrations Effluent EAL Threshold Attachment Effluent Lower Limit of Detection Determination Data (October 6,2011 (gaseous, liquids)General Source Term Data 2010 Annual QA RePort Drywell High Radiation Monitor Calibration

Procedures

(Unit 2 and Unit 3) (various)Wide Range Gas Monitor Calibration Data (various)Teledyne Brown QuarterlY

RePorts Contamination Monitoring Instrument Matrix

ARs 1299543,1299476

Procedures

EN4A40&4000, Revision 0, Radiological Ground Water Protection Program lmplementation

EN-PB-408-4160, Revision 0, Peach Bottom RGPP Reference Material Documents 2010 Annual Radioactive Effluent Release Report No. 53 Land Use Census, January 4,2011 Annual Radiological Environmental, Effluent Release Reports-2008, 2009 ODCM and Changes Reports (various) - Routine Ground Water General Source Term Data Ground Water AnalYses Corrective Action Documents (various ARs)Procedures

ODCM, Revision 13 Documents:

2010 Annual Radioactive Effluent Release Report No. 53 Land Use Census, January 4,2A11 2O1O)Annual Radiological Environmental, Effluent Release Reports-2009'

201 0 ODCM and Changes Reports (various) - Routine Ground Water General Source Term Data Ground Water AnalYses Corrective Action Documents (various ARs)Procedures

RTi /20D"965-2, Low Level Radwaste Storage Facility Waste Container Storage Cell lnspection

OP-AA-102-102, GeneralArea Checks and Operator Field Rounds, Revision 9 Attachment

Documents

Radioactive Waste Facilities Walk-down Reports and Status Radioactive Waste Shipment Records (Shipment

PM-1 1-151)Shipper and radiation Worker Training Records Section 4OA1 : Performance lndicator Verification

MSPI Deviation Reports and Svstem Manaqer Notebookg:

october 2010 through september

2011, Unit 2 and Unit 3 RHRyHPSW October 2010 through September

2Q11, Unit 2 and Unit 3 ESW October 2010 through September

2011, Unit 2 and Unit 3 EDGs October 2010 through September

2011, Unit 2 and Unit 3 HPCI October 2010 through September

2011 , Unit 2 and Unit 3 RCIC Procedures:

ER4ASOo-1047, Mitigating Performance Index Basis Document, Revision 5

ER-AA-2008, MSPI Failure Determination Evaluation

ER-AA-2020, Equipment Performance and Information Exchange (EPIX), Revision 5

LS-AA-2001, Collecting and Reporting of NRC Pl Data, Revision 14

LS-AA-2080, Monthly Data Elements for NRC SSFFs, Revision 4

LS-AA-2200, MSPI Data Acquisition and Reporting, Revision 4

ST-C-095-865-2, Revision 1, Determination of Annual Dose Equivalent for All Uranium Fuel Cycle Source CRs: tn t tSSZO0, PRA Model Change and CDE Updates Required lR 117452a E-4 EDG Out-of-Date as Found Value sT-0-052-414-2

tR

1167998, E-3 EDG Standby Lube oil circ Pump would Not Turn off

AR 1830889, 0APO60 Pump DP in Action Range D

AR 1804236, E-2 Diesel Generator Control Power Light Not Lit

AR 1772696,

RT-0-098-500-2

Dailey Production Log ARs 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 Valve NEt 99-02, Regulatory Assessment Indicator Guideline, Revision 6 PBAPS MSPI Basis Document, Revision 3 Technical Evaluation

17 4526-02 Annual Radiological Environmental, Effluent Release Reports - 2008, 2009 Public Dose Projections (Liquid, Gaseous)Reports (various) - Routine Ground Water data Procedures

LS-AA-125, CAP Procedure, Revision 15

OU-AA-4002, Revision 1, Fuel and Core Component Handling Performance Monitoring Process. Revision 2 Attachment

OU-AB-4001, Revision 5, BWR FH Practices, Revision 6 so 18.1.A-3, Revision 24, operation of Refueling Platform, Revision 25

RT-R-004-990-2, Boraflex surveillance using the Racklife Program NF-pB-310-2000, Special Nuclear Material and Core Component Movement - Peach Bottom oP-AA-108-115

NET-264-02

P Revision 4 CRs.f n Sf 6731-04, Revise

SF-220 as Needed to be in Compliance with

OM-12 Revision 2 lR

1222491, Unit 2 Control Rod 02-35 High Temperature and Control Rod Drift lR

1272847, tenon Seat Ring Disc on 126Valve of Hydraulic Control Unit 18-59 Found Torn.lR

1281090, TRM 3.9 Typo Needs to be Corrected lR

1281553, Hydraulic Oil Leak on Fitting to 3 'B' RFP Control Valve Actuator lR

1281565, Emergent Clearance Written for Unit 3'B' RFP Turbine Hydraulic Power Units lR

1281601, Filter Differential Pressure High lR

1281806, Insulation Ineffective (Needs Replacing)

on RWCU Piping lR

1282235, Inconsistencies with Maneuver Guidance from Fleet Norm lR

1282317, 4.0 Crew Critique -

GP-9 to Remove 3 'B' RFP from Service lR

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 Error lR

1295435, Increased Rate of LERS for 2011 lR

971001, Orientation of Fuel Bundle in Incorrect in Fuel Prep Machine lR

971385, Fuel Channel Dropped in Unit 3 SFP lR

972679, P3R17 Fuel Bundle Mispositioned during Core Shuffle ll lR

1114828, Level 4 Event Refuel Bridge Stopped by Spotter lR 1 1 1 5041, P2R18 Fuel Bundle Came in Contact with SCI Sub lR

1117854, P2R18 Dummy Bundle Came in Contact with Bundle in SFP lR

1257323, Failed PMT on 30H332 Refuel Platform Mono Hoist Motor

CR-1261969-03, Engineering to Submit Technical Evaluation Being Conducted Under ACIT 02 to MRC for Review and APProval lR

1225840-13, Update - PB Review of NRC TIA Response for SFP Boraflex lR

1261969-04, Document Detailed Exelon Review of

TIA 2011-004 WOs / Action Requests ffiRefuelingoperationsonUnit3ReactorEncoderCheck,Check Bridge/TrolleY

Encoders Miscellaneous Ab"omlal Condition Monitoring Plans for P3R18 Refueling Operations Peach Bottom Station Trend Review, Second Quarter 2011 Analysis peach Bottom Technical Evaluation to Verify the Adequacy of the PBAPS SPF Storage Rack Criticality Margins Dated August 16,2010 Task lnterfacJAgreement

201 1-004, Peach Bottom Units 2 and 3 SFP Neutron Absorber Degradation

LER 11-002-00, Event date: June 6,2011 Attachment Section 4OA2.4: Review of Licensee Actions to Resolve Vital Bus Degraded Voltage Protection lssues Calculations pf-OO+8. AC MCC Control Circuit Evaluation, Revision 9

PE-0121, Voltage Regulation Study, Revision 7

PE-0225, Degraded Grid Relays Setpoints, Revision 0 lssue Reports OOZAZTt, NRC CDBI- URlfor LTC Licensing Basis

00781059, NRC URI 2OO80O7-3, Vital Bus Degraded Voltage Protection

00918762, Voltage Reg. Study ETAP File Has Load Flow Differences

Q1117782,

MO-2-10-1

54A: Margin lmprovement Modification Required

01117787,

MO-3-1 0-1 54B: Margin lmprovement Modification Required

01119440, LTC URI DisPosition

011261SS, trlO-e-t0-01iD, Overall Gear Ratio Modification Required for Degraded Voltage

01126164,

MO-3-10-0348:

LS Modification Required Based on Degraded Voltage

01126193,

MO-3-23-015:

P3R18 Modification Based on Degraded Voltage-01

138920, NRC

NCV 2010004-3:

Adequate Voltage to sR Equipment Not Ensured

01149455, Low Voltage at MCC Contactor Using LOCA Relay Setpoints

01149471, Low Voltage at MCC Contactor Using LOCA Relay Setpoints

01149488, Low Voltage at MCC Contactor Using LOCA Relay Setpoints

01149493, Low Voltage at MCC Contactor Using LOCA Relay Setpoints Completed Surveillance

Procedures

p,Valve,Flow,&UnitCoolerFunctionalandlnservice Test, Revision 33, Completed

11122111

ST-O-010-306-2, 'B' RHR Loop Pump, Valve, Flow, & Unit Cooler Functional and Inservice Test, Revision 31, Completed

08129111

ST-O-010-306-3, 'B' RHR Loop Pump, Valve, Flow, & Unit Cooler Functional and Inservice Test, Revision 33, Completed

11102111 Drawinqs r-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 4.16KV Ckt. Breaker, Revision 38 (01/27100)

Enqineerinq Chanqes M0,EvaluateARlStartersandAssociatedComponents

ECR PB 't0-00360

000,

MO-2-10-154A (B), Install Closed Torque Switch Bypass ECR

PB 10-00362 000, Mo-3-10-0268, lnstall closed Torque Switch Bypass Enoineerinq Technical Evaluations

& operabilitv Evaluations witfr the 4kV Bus Voltage at 3836V, Revision 0 10-006, lR 1 1 1 9440-07, LTC URI Disposition, Revision 3

1119440-12, Documentation of MOV Operability for NRC CDBI URl, Revision 0 Licensinq

Documents

PBAPS TSS PBAPS UFSAR Attachment

Miscellaneous

sr"n rrrirg Brief 10-12, closing Mo-2(3)-10-154A (B),_"RHR

Loop A (B) Outboard Discharge Valve" Under Startup Source Degraded Voltage Conditions,09l29l10

Procedures

LS-AA-125, CAP Procedure, Revision 15

LS-AA-125-1001, Root Cause Analysis Manual, Revision 8

LS-AA-125-1003, Apparent cause Evaluation Manual, Revision 9

OP-AA-1 08-1 1 5, Operability Determinations, Revision 1 0

OP-AA-10g-1

15-1001 , Operability Evaluation Passport Engineering Change Desktop Guide, Revision 1

OP-AA-10g-1

15-1002, Supplemental Consideration for On-Shift lmmediate Operability Determinations, Revision 2 Procedures (Operations)

AO 10.g.2, Unit 2, itacirig Torus Cooling in Service with LOCA Signal Present or Has Occurred, Revision 10

AO 10.g.3, Unit 3, placing Torus Cooling in Service with LOCA Signal Present or Has Occurred, Revision 10 1-204-2, Unit 2, Initiation of containment Sprays Using RHR, Revision 5 T-204-3i,, Unit 3, Initiation of Containment Sprays Using RHR, Revision 4 T-231-2, Unit 2, HPSW Injection into the Torus, Revision 6 T-231-3, Unit 3, HPSW Injection into the Torus, Revision 6 RRC 1 Oi.1-2, Unit 2, RHR System Torus Cooling during a Plant Event, Revision 4

RRC 10.1-3, Unit 3, RHR System Torus cooling during a Plant Event, Revision 5 Svstem & Proqram Health RePorts 4 kV, Unit 2,3rd Quarter 2011 4 kV, Unit 3, 3rd Quarter 2011 480 V Emergency

& NSR Load center, Unit 2,3rd Quarter 2011 480 V rmergency

& NSR Load center, Unit 3, 3rd Quarter 2011 MOV Program, 3rd Quarter 2011 Substatiois/Startup Sources, Units 2 & 3, 3rd Quarter 2011 WOs COZSSA+g,

MO-2-10-1

54A, Margin I mprovement

R099841 1, E1 24-D-A (5322), Perform Breaker Mai ntenance R1

055237, E324-D-A(5545), Perform MCU Inspection

R1085871,

MO-3-10-0268-OP, Perform Motor Operator P'M'ARs 125gg44,1265695,1270773,129559,1263077,1264425,1262272,1259944'1265180'

265391,

1266002,

1266237,

1266279,

1266283,

1266454,1

68966, 1173026'1 201 437 . 1 22647 2,

1226687, 1 227 440, 1 235086)section 40A3: Follow-up of Events and Notices of Enforcement Discretion

Procedures

OP4A-108-1

15, Operability Determinations, Revision 10 M-052-002, Diesel Engine Maintenance, Revision 35 Attachment

CRs

IR 1264398,

RV-3-10-72D

Inlet Piping Configuration

lR

1264909,

RV-3-10-072D

Update from A1758904 (Leakage Source on RV)lR

1265892, E-33 LOCA/LOOP

had Unexpected

E-3 EDG Start lR

1307019, Document Corrective Actions for

RV-3-1 0-072D (lR 1264909)lR

582657, Oil Leak on Outboard of Engine Blower lR

894706, Oil Leak atE-2 Blower lR

1266837, Oil Leak from E-1 EDG Supercharger Drain Line lR

1293991, OIO Benchmark

E-1 Diesel Blower Oil Drain Line lR

1309963, E-1 EDG Oil Leak CAP Product Quality lssues Drawinqs f Sf -g61, Sneet 4: ASME Section Xl lsl Boundaries

RHR System, Revision 1 1 WOs n18Z5tg8, RHR Pump 3DP035 Suction Relief Valve

41758094, RHR Pump 3DP035 Suction Relief Valve Miscellaneous Adrt"t V".a;r Data Sheet: Nuclear Qualified Control Relays - Se{esjGP/EML/ETR

Eiectric power Research Institute

TR-106857, PM Basis - Volume 30: Relays - Control NRC Generic Letter 90-05: Guidance for Performing Temporary Non-Code Repair of ASME Code Class 1, 2, and 3 PiPing PBAPS PCM Templates:

Relays - Control/ Timing NRC fnformation Notice20OT-27

Recurring Events Involving

EDG Operability

PBAPS EDG Run Database, April - November 2011 PBAPS CAP Search: 3-year History of EDG Oil Leaks

Section 4OA5: Other Activities

EP-AA-1007;

Radiological

EP Annex for PBAPS, Revisions and 21 tR 01.1g4333;

Ep NotLe of Violation for EAL Change-lmplement

EAL Basis Change for HU6; Marcn7,2011

Radiological SurveYs - lFSl Inspection RePorts - lFSl Attachment

ADAMS ALARA AR APRM ASME BI CAP ccA CDF CFR CRs EAL ECCS ECR ED EDEX EDG EOC EP ESW FH FSAR GPI HEPA HPCI HPSW HRA rMc IR ISFSI IST LCO LER LERF LHRA LLD LOCA LOOP LTC MCC MG MOV MR MSIV MSPI NCV NEI A-18

LIST OF ACRONYMS

Agencywide

Documents

Access and Management

System as low as is reasonablY

achievable

action request average power range monitor American Society of Mechanical

Engineers barrier integrity corrective

action Program common cause analYsis core damage frequencY Code of Federal Regulation

condition

reports emergency

action level emergency

core cooling sYstem engineering

change request electronic

dosimeter effective

dose equivalent

for external exposure emergency

diesel generator extent of condition Emergency

Plan emergency

service water fuel handling final safety analYsis rePort groundwater

protection

initiative

high efficiency

particulate

air high pressure coolant injection high pressure service water high radiation

area inspection

manual chaPter issue report independent

spent fuel storage installation

inservice

testing limiting condition

for oPeration licensee event rePort large early release frequencY locked high radiation

area lower limits of detection loss of coolant accident loss of offsite power load tap changer motor control center motor generator motor-operated

valve maintenance

rule main steam isolation

valve mitigating

system performance

indicator non-cited

violation Nuclear Energy I nstitute Attachment

NIOSH [[]]

NOS [[]]

NRC [[]]

NRR [[]]

NVLAP [[]]

ODCM P3R18

PARS [[]]

PBAPS [[]]

PCP [[]]

PD [[]]

PI [[]]

PI&R [[]]

PM [[]]

PMT [[]]

QA [[]]

RB [[]]

RBCCW [[]]

RCA [[]]

RCIC [[]]

REMP [[]]

RETS [[]]

RFO [[]]

RFP [[]]

RG [[]]

RPS [[]]

RHR [[]]

RTP [[]]

RWCU [[]]

SBO [[]]

SDP [[]]

SFP [[]]

SLC [[]]

SM [[]]

SPAR [[]]

SRA [[]]

SRV [[]]

SSC [[]]

ST [[]]

TIA [[]]

TLD [[]]

TS [[]]

UFSAR [[]]

URI [[]]

VHRA [[]]

WBC [[]]

WOs A-19 National Institute

for Occupational

Safety and Health nuclear oversight Nuclear RegulatorY

Commission

Nuclear Reactor Regulation

National Laboratory

Accreditation

Program offsite dose calculation

manual Peach Bottom Unit 3 Refueling

Outage Number 18 publicly available

records Peach Bottom Atomic Power Station process control program performance

deficiencY

performance

indicator problem identification

and resolution

preventive

maintenance

post-maintenance

test quality assurance reactor building reactor building closed cooling system radiological

controlled

area reactor core isolation

cooling Radiological

Environmental

Monitoring

Program radiological

effluents

technical

specification

refueling

outage reactor feed pumP regulatory

guide reactor protection

sYstem residual heat removal rated thermal Power reactor water cleanuP station blackout significance

determination

process spent fuel Pool standby liquid control shift manager standardized

plant analYsis risk senior reactor analYst safety relief valve structures, systems, and components

surveillance

test task interface

agreement thermoluminescent

dosimeter technical

specification

updated final safety analysis report unresolved

item very high radiation

area whole body counter work orders Attachment