IR 05000277/2010005

IR 05000277-10-005 and 05000278-10-005; on 10/01/2010 - 12/31/2010 Peach; Bottom Atomic Power Station (Pbaps), Units 2 and 3; Surveillance Testing

ML110341057
Person / Time
Site:	Peach Bottom
Issue date:	02/03/2011
From:	Paul Krohn Reactor Projects Region 1 Branch 4
To:	Pacilio M Exelon Nuclear, Exelon Generation Co
Krohn P
References
IR-10-005
Download: ML110341057 (56)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE ROAD KtNG OF PRUSSIA. PA 19406-1415 February 3, ZOLL Mr. MichaelJ.

Pacilio 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 N S PECTI O N RE PORT 0500027 7 t20 1 0005 AN D 0500 027 8t20 1 0005

Dear Mr. Pacilio:

On December 31 ,2010, the U. S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3.The enclosed integrated inspection report documents the inspection results, which were discussed on January 21, 2011, with Mr. Thomas Dougherty 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 and records, observed activities, and interviewed personnel.

Based on the results of this inspection, one finding of significance was identified.

This finding was determined to involve a violation of NRC requirements.

However, because of the very low safety significance and because the finding has been entered into your correction action program (CAP), the NRC is treating the finding as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC's Enforcement Policy.lf you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region l; the Director, Otfice of Enforcement, U. S. NRC, Washington, DC 20555-0001; and the NRC Senior Resident Inspector at the PBAPS. lf you disagree with the cross-cutting aspect to the finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region 1 and the NRC Senior Resident Inspector at PBAPS. The information you provide will be considered in accordance with Inspection Manual Chapter (lMC) 0305. 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.qov/readinq-rm/adams.html (the Public Electronic Reading Room).

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

Enclosure:

Inspection Report 0500027712010005 and 0500027812010005 w/Attachment:

Supplemental Information

REGION I Docket Nos.: 50-277, 50-278 License Nos.: DPR-44. DPR-56 Report No.: 0500027712010005 and 0500027812010005 Licensee:

Exelon Generation Company, LLC Facility: Peach Bottom Atomic Power Station. Units 2 and 3 Location:

Delta, Pennsylvania Dates: October 1, 2014 through December 31, 2010 Inspectors:

F. Bower, Senior Resident Inspector A. Ziedonis, Resident Inspector J. Brand, Reactor Inspector S. Hammonds, Senior Health Physicist J. Lilliendahl, Reactor Inspector J. Nicholson, Health Physicist R. Nimitz, Senior Health Physicist K. Mangan, Senior Reactor lnspector A. Rosebrook, Senior Project Engineer Approved by: Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure 2

SUMMARY OF FINDINGS

lR 0500027712010005, 05000278/2010005; 1010112010 - 1213112010;

Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3; Surveillance Testing.The report covered a three-month period of inspection by resident inspectors and announced inspections by a senior health physicist, two NRC region-based Decommissioning Branch inspectors, three regional reactor inspectors, and a region based Senior Project Engineer.

One inspector-identified finding was identified.

The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using NRC lnspection Manual Chapter (lMC) 0609,"Significance Determination Process (SDP)." Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. Cross-cutting aspects associated with findings are determined using IMC 0310, "Components Within The Cross-Cutting Areas," dated February 2010. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.Cornerstones:

Initiating Events, Mitigating Systems, and Barrier Integrity.

Green.

The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion Xl,"Test Control." The inspectors determined that PBAPS's test control of ST-O-07G-470-3, "Main Steam lsolation Valve (MSIV) Closure Timing," Revision 15, was inadequate to demonstrate satisfactory performance of MSIVs during power operations.

PBAPS entered this issue into the CAP via lRs 1140706 and 1141888.This finding was more than minor because it is similar to examples 3.j and 3.k of IMC 0612, Appendix E. Specifically, in the absence of further engineering evaluation, there was reasonable doubt of MSIV operability at power operations, based upon cold stroke time testing results. This finding impacted the Barrier Integrity cornerstone and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers, such as containment, protect the public from radionuclide releases caused by accidents or plant events. Using IMC 0609, 'SDP," Attachment 4,"Phase 1 - Initial Screening and Characterization of Findings," Table 4a, the inspectors determined that this violation screened to Green (very low safety significance)because the finding did not reprdsent an actual open pathway in the physical integrity of reactor containment.

The inspectors concluded that this finding had a cross-cutting aspect in the area of Problem ldentification and Resolution (Pl&R), CAP component.

Specifically, the licensee did not thoroughly evaluate the test control problems such that the resolution ensured MSIV operability and addressed the cause and extent of condition (EOC). (P.1.c). (Section 1R22)

4

REPORT DETAILS

Summarv of Plant Status Unit 2 began the inspection period shutdown in its 18th Refueling Outage (RFO) (P2R18). On October 7 , 2010, the reactor was restarted and the unit was synch ronized to the grid on October 8,2010. On October 10,2010, the unit was returned to 100 percent rated thermal power (RTP) where it remained until the end of the inspection period, except for brief periods to support planned testing and rod pattern adjustments.

Unit 3 began the inspection period at 100 percent RTP. On November 13, power was reduced to approximately 85 percent RTP in response to an increasing trend of dissolved combustible gases accumulating in the 3 'B' main power transformer (MPT) oil. On November 15,2010, a shutdown from approximately 85 percent RTP was commenced and the main generator breaker was opened to start the unit's 9tn maintenance outage (3M09)to replace the 3 'B' MPT and the 3 'B' safety relief valve (SRV). Operators inserted a planned manual scram from approximately six percent RTP to complete the reactor shutdown.

On November 19, 2010, the reactor was restarted.

The unit was synchronized to the grid on November 20, 2010, and returned to 100 percent RTP on November 21, 2010, where it remained until the end of the inspection period, except for brief periods to support planned testing and rod pattern adjustments.

1. REACTORSAFETY

Cornerstones:

lnitiating Events, Mitigating Systems, and Barrier Integrity 1R01 Adverse Weather Protection (71111.01 - 1 System Sample)Preparation for Cold Weather Conditions a. lnspection Scope The inspectors performed a detailed review of PBAPS's and Exelon's written procedures for winter readiness and low temperatures to evaluate PBAPS's implementation of adverse weather preparation and compensatory measures for the affected conditions prior to the onset of cold weather. The inspectors selected the following structures, systems and components (SSCs)to verify the physical condition of the cold weather protection features, and to verify that adequate controls were in place to ensure operability:

o Emergency diesel generator (EDG) and cardox buildings;. Pump structure building;o Emergency service water (ESW) and high pressure service water (HPSW) pump rooms; and o Intake screen structure.

The above selection constituted one sample. The inspectors also reviewed adverse weather procedures to ensure they are adequate to maintain readiness of essential systems. 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 in Enclosure 5 accordance with station corrective action procedures.

Documents reviewed are listed in the Attachment.

b. Findinqs No findings were identified.

1R04 Equipment

Alionment (71111.04 - 3 Samples).1 PartialWalkdown (71111.04Q - 2 Samples)a. Inspection Scope The inspectors performed a partial walkdown of two systems to verify the operability of redundant or diverse trains and components when safety-related equipment was inoperable.

The inspectors performed walkdowns to identify any discrepancies that could impact the function of the system and potentially increase risk. The inspectors reviewed selected operations procedures, walked down system components, and verified that selected breakers, valves, and support equipment were in the correct position to support system operation.

Documents reviewed are listed in the Attachment.

The two systems reviewed were:. Unit 2 'B'shutdown cooling alignment, following

'A' loop discharge check valve split indication (Technical Evaluation lR 1 1 18232 - 02); and. Unit 3 reactor core isolation cooling (RCIC) system while the Unit 3 high pressure coolant injection (HPCI) system was out-of-service (OOS) for planned maintenance that included replacement of the HPCI pump seals.b. Findinqs No findings were identified.

.2 Complete Walkdown (71111.04S - 1 Sample)a. lnspection

Scooe The inspectors performed a complete walkdown of the accessible portions of the electrical substations and transformers common to Unit 2 and Unit 3, to verify adequate alignment of the offsite power sources as the preferred supply to safety-related on-site electrical loads per Technical Specification (TS) 3.8.1, and to verify adequate performance and material condition of major electrical equipment that could result in a plant transient upon failure. Inspector walkdowns were performed at the north and south substations, emergency transformers on-site, vital and non-vital switchgear inside the plant, and the main control room panels. The inspectors reviewed electrical prints and system operating procedures to verify that the system alignment was properly translated into procedures and drawings.

The inspectors discussed electrical system operation with the plant operators, and discussed electrical system issues and maintenance with the system engineer.Enclosure 6 b. Findinqs No findings were identified.

lR05 Fire Protection (71111.05Q - 4 Samples).1 Fire Protection - Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment.

The inspectors reviewed areas to assess whether PBAPS had implemented the Peach Bottom Fire Protection Plan (FPP) and adequately:

controlled combustibles and ignition sources within the plant;maintained fire detection and suppression capability; and maintained the material condition of passive fire protection features.

For the areas inspected, the inspectors also verified that PBAPS had followed the Technical Requirements Manual (TRM)and the FPP when compensatory measures were implemented for OOS, degraded or inoperable fire protection equipment, systems, or features.

The inspectors verified:

that fire hoses and extinguishers were in their designated locations and available for immediate use;that fire detectors and sprinklers were unobstructed; that transient combustible materials were managed in accordance with plant procedures; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition.

Documents reviewed during the inspection are listed in the Attachment.

The inspectors toured the folfowing areas:. Unit 2 turbine building reactor feed pump turbine i chiller area, elevation 165'-0" (Fire Zone 102);. Unit 3 radwaste building and Unit 3 reactor building closed loop cooling water room, elevation 1 16'-0" (Fire Zone 128);. Unit 3 reactor building 3'B'and 3'D'core spray (CS) room, elevation 91'-6" (Fire Zones 13A and 138); and. Unit 3 reactor building sump room, elevation 88'-0" (Fire Zone 64).b. Findinqs No findings were identified.

1R06 lnternal Flood Protection

(71111.06 - 1 Sample)a. Inspection Scope The inspectors reviewed selected risk-important plant design features intended to protect the plant and its safety-related equipment from internal flooding events. The inspectors reviewed a sample of issue reports (lR) in the area of internal flood protection, to verify adequate margin between any identified sources of water intrusion into the plant and the plant design and licensing basis, and to verify appropriate corrective actions. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), Design Basis Documents (DBDs), calculations, and design specifications to verify the adequacy of plant flood protection design. The inspectors walked down the Unit 2 and Unit 3 emergency pump structure for internalflooding to evaluate the condition of penetration seals, watertight doors, and other internal design features to verify that they were as described in the Individual Plant Examination (lPE).Enclosure 7 b. Findinqs No findings were identified.

1R11 Licensed Operator Requalification

Proqram (71111.11Q - 1 Sample)Resident Inspector Quarterlv Review

a. Inspection Scope

On October 25,2010, the inspectors observed a simulator-based licensed operator evaluation, during requalification training, to assess licensed operator performance and the evaluator's post-scenario critique.

The inspectors evaluated crew performance in the areas of:. Clarity and formality of communications;. Ability to take timely actions;. Prioritization, interpretation, and verification of alarms;. Procedure usage;. Timely control board manipulations with a focus on high-risk operator actions;. Shift supervisor command and control, including identification and implementation of TSs, event classification, and emergency response actions; and o Group dynamics involved in crew performance.

The inspectors verified that any crew performance issues and weaknesses were discussed in the post-scenario critique.

The inspectors also verified simulator physical fidelity, to ensure that the simulator arrangement closely paralleled the main control room. These activities constituted one quarterly licensed operator requalification training' program inspection sample. Documents reviewed during the inspection are listed in the Attachment.

b. Findinqs No findings were identified.

1R12 Maintenance

Effectiveness (71111.12Q - 2 Samples)a. Inspection Scope The inspectors evaluated PBAPS's work practices and follow-up corrective actions for safety-related SSC's and identified issues to assess the effectiveness of PBAPS's maintenance activities.

The inspectors reviewed the performance history of SSCs and assessed PBAPS's extent of condition (EOC) determinations for those issues with potential common cause or generic implications to evaluate the adequacy of the PBAPS's corrective actions. The inspectors assessed PBAPS's problem identification and resolution (Pl&R) actions for these issues to evaluate whether PBAPS had appropriately monitored, evaluated, and dispositioned the issues in accordance with Exelon procedures, including ER-AA-310, "lmplementation of the Maintenance Rule (MR)," and the requirements of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance." ln addition, the inspectors reviewed selected SSC Enclosure b.

1R13 8 classifications, performance

criteria and goals, and PBAPS's corrective actions that were taken or planned, to evaluate whether the actions were reasonable and appropriate.

Documents reviewed during the inspection are listed in the Attachment.

The inspectors performed the following two samples: r High Risk Buried Piping Inspection and Mitigation (lR 1019963);

and. MR Screening System 70A for Manhole Water Monitoring (lR 1151546).Findinos No findings were identified.

Maintenance Risk Assessments and Emeroent Work Control (71111.13 - 3 Samples)a. lnspection Scope The inspectors evaluated PBAPS's implementation of the Maintenance Risk Program with respect to the effectiveness of risk assessments performed for maintenance activities that were conducted on SSC's. The inspectors also verified that PBAPS managed the risk in accordance with 10 CFR Part 50.65(a)(4)and procedure WC-AA-101, "On-line Work Control Process." The inspectors evaluated whether PBAPS had taken the necessary steps to plan and control emergent work activities and to manage overall plant risk. The inspectors selectively reviewed PBAPS's use of the online risk monitoring software and daily work schedules.

The activities selected were based on plant maintenance schedules and systems that contributed to risk. Documents reviewed during the inspection are listed in the Attachment.

The inspectors completed three evaluations of maintenance activities on the following:

o Planning and control of emergent work in response to low inter-seal pressure alarms on independent spent fuel storage installation (lSFSl) Cask #1, during ISFSI Cask 50 low inter-seal pressure leakage troubleshooting (lR 1126789 and lR 1 109955);e Emergent work in response to the 3'C' HPSW pump failing post-maintenance testing (PMT) after reinstallation (lR 1 157318); and o Planning and control of emergent work in response to Unit 3 main turbine stop valve#3 failure to close during monthly testing (lR 1154176).b. Findinos No findings were identified.

1R15 Operabilitv

Evaluations (71111.15 - 5 Samples)a. Inspection Scope The inspectors reviewed five issues to assess the technical adequacy of the operability evaluations, the use and control of compensatory measures, and compliance with the licensing and design bases. Associated adverse condition monitoring plans (ACMPS), engineering technical evaluations, and operational and technicaldecision making (OTDM) documents were also reviewed.

The inspectors verified these processes were performed in accordance with the applicable administrative procedures and were Enclosure 9 consistent with NRC guidance.

Specifically, the inspectors referenced procedure OP-AA-108-115, "Operability Determinations," and NRC IMC Part 9900, "Operability Determinations

& Functionality Assessments for Resolutions of Degraded or Nonconforming Conditions Adverse to Quality or Safety." The inspectors also used TSs, TRM, UFSAR, and associated DBDs as references during these reviews. Documents reviewed are listed in the Attachment.

The following degraded equipment issues were reviewed: e ISFSI alarm received for Cask #50 (lR 1 109955);. 3 'B' MPT ACMP threshold met (lR 1136995);. Better pedigree needed for operations with a potential to drain the reactor vessel (OPDRV) 1.5" opening threshold (lR 1069325-02);

r 'A' ESW supply piping pinhole leak (lR 1137854-02);

and. Exposed buried piping protection against natural phenomena (AR 1744929-03).

b. Findinqs No findings were identified.

1R19 Post-Maintenance

Testino (71111.19 - 6 Samples)a. Inspection Scope The inspectors reviewed completed test records or observed selected PMT activities.

The inspectors verified whether the tests were performed in accordance with the approved procedures or instructions and assessed the adequacy of the test methodology based on the scope of maintenance work performed.

In addition, the inspectors assessed the test acceptance criteria to evaluate whether the test demonstrated that components satisfied the applicable design and licensing bases and the TS requirements.

The inspectors reviewed the recorded test data to verify that the acceptance criteria were satisfied.

Documents reviewed during the inspection are listed in the Attachment.

The inspectors reviewed six PMTs performed in conjunction with the following maintenance activities:

o Integrated leak testing of ISFSI Cask #1, following transportation from the ISFSI dry cask storage facility to the Unit 2 refuelfloor (work order (WO) C0235207-A1);

r Y-distribution panel 20Y050 Breaker #15 closure (operational risk activity)following replacement to support in-plant wireless radio upgrade project (WO C0233481-31);. 3 'C' HPSW pump test after pump replacement to correct low margin conditions (WO R1135041);

o Battery charger 28D003-1 capability test, following maintenance and troubleshooting of low output voltage condition (WO C0235655-01 to 15, 17 to 24);. HPCI pump, valve and flow test following pump seal replacement (WO C0232672)and gland seal condenser condensate return vent valve installation (WO C0233235);

and o Stroke time testing of MO-0-48-0502A following in-body inspection and cleaning (WO c0236060-01).

10 b. Findinos No findings were identified.

1R20 Refuelino

and Other Outaqe Activities (71111.20 - 2 Samples).1 Peach Bottom Unit 2 RFO 18 (P2R18) (1 Sample)a. Insp*ction Scope The Unit 2 RFO (P2R18) was conducted from September 12, 2010 through October 8,2010. During this inspection period, the inspectors performed the activities listed below to verify PBAPS's controls over outage activities:

o Refueling Activities - verified that PBAPS was using adequate controls to ensure the location of the fuel assemblies were properly tracked and verified that procedures for foreign material control and retrieval were 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 prior to reactor startup to verify that all debris, tools, and diving gear were removed;r Drywell Closure - conducted a thorough inspection and walkdown of containment prior to reactor startup to identify remaining debris, tools, and equipment for removal;. SRVs - reviewed the post-removal lift test results and noted that two

(2) SRVs and one main steam safety valve (SV) failed to lift within the TS required pressure range of their normal setpoint and this condition was documented in the CAP (lR 1120516);. Startup Preparations - reviewed the tracking of startup prerequisites and observed selected Plant Operations Review Committee (PORC) meetings where outstanding outage issues and startup reviews were discussed;. Startup and Ascension to Full Power Operation - observed selected activities including:

criticality; portions of the plant heat-up, main generator synchronization to the grid; portions of the power ascension to full power operation; and r 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.Documents reviewed are listed in the Attachment.

Findinqs No findings were identified.

Peach Bottom Unit 3 Maintenance Outaqe (1 Sample)Inspection Scope PBAPS conducted a maintenance outage on Unit 3 from November 15 through November 20, to replace the 3 'B' MPT and the 'B' SRV. During the outage, the inspectors reviewed the station's work schedule and outage risk management activities.

b..2 a.Enclosure 11 The risk management activities were reviewed to confirm that PBAPS had appropriately considered risk, industry experience, and previous site specific problems in developing and implementing a plan that maintained shutdown safety defense-in-depth.

During the outage, the inspectors observed portions of the shutdown, cool down, and start up processes and monitored the activities listed below to verify PBAPS controls over the outage activities:. Observed the control room operators removing the main generator from the grid, completing a manual'scram of Unit 3 from approximately six percent power, including stabilizing the plant in Mode 3;r Monitored emergent work activities related to the 3 'B' MPT replacement; r Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable TS when taking equipment OOS;o Monitored of decay heat removal operations; o Monitored reactor water inventory controls, including flow paths, configurations, alternative means for inventory additions, and controls to prevent inventory loss;o Monitored the status and configuration of electrical systems and switchyard activities to ensure that TS were met;o Monitored activities that could affect reactivity; and. Observed selected startup and ascension to full power operation activities including:

criticality; portions of the plant heat-up, and main generator synchronization to the grid.b. Findinqs No findings were identified.

1R22 Surveillance

Testing (71111.22 - 5 Samples)a. Inspection Scope (3 Routine Surveillances; 1 lsolation Valve; and 1 In-service Test (lST) Sample)The inspectors reviewed or observed selected portions of the following STs, and compared test data with established acceptance criteria to verify the systems demonstrated the capability of performing the intended safety functions.

The inspectors also verified that the systems and components maintained operational readiness, met applicable TS reguirements, and were capable of performing design basis functions.

The five STs reviewed or observed included:. ST-M-O1G-450-2, "Main Steam Safety and Relief Valve Replacement" ilSTl;o Sl2P-71-0701-XXC3, "Channel Operational Test (COT) of ISFSI Cask #1 Low Pressure Switches, PS-70701A and PS-707Q18";. ST-O-013-301-3, "RCIC Pump, Valve, Flow and Unit Cooler Functional and lST";. ST-O-07G-470-3, 'MSIV Closure Timing"; and. RT-O-O1D-402-2, " Master Trip Solenoid Valves Operability Test." Enclosure 12 b. Findinqs IntroductiQn:

The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion Xl, "Test Control." The inspectors determined that PBAPS's test control of ST-O-07G-470-3, .MSIV Closure Timing," Revision 15, was inadequate to demonstrate satisfactory performance of MSIVs during power operations.

Description:

The inspectors observed that acceptance criteria in ST-O-07G-470-3 required light-to-light fast-closure stroke times greater than or equal to 3.0 seconds, and switch-to-light fast-closure stroke times less than or equal to 5.0 seconds. Light-to-light fast-closure stroke timing measures the amount of time it takes for the position indication lights to change state. For MSIV closure, this is the time it takes between the close, or upper, position light illuminating and the open, or lower, position light extinguishing.

Switch-to-light fast-closure stroke timing measures the amount of time from an operator actuating the closure switch until the open, or lower, position light extinguishes.

The inspectors also noted that ST-O-07G-470-3, step 7.2.1 requires adjustment of the fast-closure stroke time for any MSIV that is not within 3.6 and 4.8 seconds when timed using either the light-to-light or switch{o-light measurement method. ST-O-07G-470-3 is performed to satisfyTS Surveillance Requirement (SR) 3.6.1.3.9, which requires MSIV closure in greater than or equal to 3 seconds and less than or equal to 5 seconds.MSIVs are required to be operable in MODES 1, 2, and 3.On November 15, 2010, during the performance of ST-O-O7G-470-3, two MSIV fast-closure stroke times were measured below the 3.0 second acceptance criteria for light-to-light stroke times. The 'A' outboard valve (40-3-02-864)fast-closure time was measured at2.9 seconds, and 'C' inboard (AO-3-02-80C)fast-closure time was measured at2.8 seconds. Alleight MSIVs'closure times were measured at less than 3.6 seconds. The test was performed in cold shutdown conditions (MODE 4) during a maintenance outage.On November 17,2010, Technical Evaluation (TE) 1140706-42 was completed to address the Unit 3 40-3-02-864 and AO-3-02-80C MSIVs'fast-closure stroke times being outside of the TS acceptance criteria.

The TE calculated the differences in stroke time between limit switch activation and full valve stroke, based upon field measurements taken during the previous RFO. Measurements of the stem length between the upper and lower limit switch position (i.e., close and open position indication)and full valve travelwere obtained.

Using these lengths and assuming a constant stroke speed, the light-to-light stroke time was extrapolated to determine the actual closure time for the full length of the stem travel for'both the A0-3-02-86A and AO-3-02-80C MSlVs. TE 1140706-02 concluded that the actual fast-closure full-stroke times for the A0-3-02-86A and AO-3-02-80C MSIVs were 3.49 seconds and 3.48 seconds, respectively.

Consequently, work orders (WOs) were generated to adjust the stroke times for these two MSlVs. After in-field adjustments, the as-left light-to-light stroke time for the AO-3-02-80C MSIV was 3.0 seconds, but the 40-3-02-864 MSIV light-to-light stroke time was left at 2.94 seconds to ensure the switch-to-light stroke time remained less than 5 seconds (as-left was 4.8 seconds).

lt was noted that no lR or WOs were generated to adjust the stroke times for the remaining 6 MSIVs with fast-closure stroke times less than 3.6 seconds, contrary to the requirements of ST-O-Q7G-470-3, Step 7.2.1. However, the requirements of TS SR 3.6.1.3.9 continued to be met.Enclosure 13 On November 19, a second TE, 1 140706-05, was completed to support the as-left condition of the A0-3-02-86A MSIV (2.94 second lightto-light stroke time). Peach Bottom incorporated correction factors into the TE, in response to NRC inspector questions, to account for the differences between MSIV closure-related effects during power operations versus cold testing conditions of the MSlVs. This TE cited relevant external Operating Experience (Limerick and Hatch) and used appropriate correction factors that account for the dynamic effects of steam flow on the valve closure during power operation and oil dashpot viscosity changes with temperature (cold shutdown versus power operation).

Both of these correction factors would increase the valve stroke speed during operations in Modes 1, 2 and 3. The inspector found the TE acceptable for MSIV operability purposes; however, the TE did not adequately address the PBAPS's failure to appropriately evaluate an out of specification test result without prompting by the inspector.

The inspectors identified an additional deficiency associated with ST-O-07G-470-3 and TEs 1140706-02 and 1140706-05.

The TEs used the limit switch position measurements to extrapolate the light-to-light timing and extend the valve stroke for comparison to the minimum acceptable TS limit (3 seconds).

This extrapolation used field measurements of stem travel from initial valve movement to the upper (closed) limit switch activation, combined with stem travel from lower (open) limit switch de-activation to full valve closure. However, neither the TE nor ST-O-07G-470-3 used an extrapolated full stroke time for comparison to the maximum acceptable TS limit (5.0 seconds).

The extrapolation did not account for the impact of stem travel outside of the stroke time measured by switch{o-light stroke time. Specifically, the measurement of stem travel from the lower (open) limit switch de-activation to full valve closure was not combined with the switch-to-light stroke time. Therefore, the inspectors determined that PBAPS's application of the full stroke extrapolation method based on limit switch field measurements was not applied consistently in the TEs, and was unaccounted for in sT-o-07G-47Q-3.

Analvsis:

The inspectors determined that PBAPS's inadequate resolution of as-found MSIV closure times and inconsistent test measurement and evaluation methodology per ST-O-07G-470-3 was a performance deficiency (PD) and contrary to 10 CFR Part 50, Appendix B Criterion Xl, "Test Control" requirements.

Traditional enforcement does not apply because this issue did not have any actual safety consequences or potentialfor impacting the NRC's regulatory function and was not the result of any willful violation of NRC requirements or PBAPS procedures.

This violation of 10 CFR Part 50 was more than minor because it is similar to examples 3.j and 3.k of IMC 0612, Appendix E.Specifically, in the absence of further engineering evaluation, there was reasonable doubt of MSIV operability at power operations, based upon cold stroke time testing results. This test control PD impacted the Barrier lntegrity cornerstone and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers, such as containment, protect the public from radionuclide releases caused by accidents or plant events. Using IMC 0609, "SDP," Attachment 4, "Phase 't -f nitial Screening and Characterization of Findings," Table 4a, the inspectors determined that this violation screened to Green (very low safety significance)because the finding did not represent an actual open pathway in the physical integrity of reactor containment.

2.14 The inspectors concluded that this finding had a cross-cutting aspect in the area of Pl&R, CAP - Evaluation of ldentified Problems.

PBAPS did not thoroughly evaluate problems such that the resolutions address causes and extent of conditions, as necessary.

This includes properly classifying, prioritizing, and evaluating for operability and reportability conditions adverse to quality. PBAPS failed to evaluate the above noted test control problems such that the resolution ensured MSIV operability and addressed the cause and EOC. Specifically, TEs 1140706-02 and 1140706-05 did not adequately evaluate out of specification test results without prompting by the inspector.

Additionally, an equipment apparent cause evaluation (964717-05)did not adequately evaluate and resolve similar MSIV test control problems raised by NRC inspectors in 2009 (P.1.c).Enforcement:

10 CFR 50, Appendix B, Criterion Xl, "Test Control," states, in part, that testing required to demonstrate that systems and components will perform satisfactorily in service is performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.

Contrary to the above, between November 15 and 19, 201Q, PBAPS did not identify that procedure ST-O-07G-470-3, "MSIV Closure Timing," Revision 15, contained acceptance criteria that were inadequate to demonstrate that the MSIVs would satisfactorily isolate within the time limits contained in TS SR 3.6.1.3.9 during power operations.

Specifically, MSIV fast-closure stroke timing acceptance criteria in ST-O-07G-470-3 did not account for the differences between cold testing conditions and power operations, and did not account for the impact of measuring isolation times using the full stroke extrapolation method for switch-to-light stroke timing. In addition, PBAPS failed to perform MSIV surveillance testing in accordance with the written procedure in that step 7.2.1 of ST-O-07G-470-3 was not performed as written for six of the eight MSIVs tested. Since this finding was of very low safety significance (Green), and has been entered into the CAP via lRs 1140706 and 1141888, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000277, 27812010005-01, Inadequate MSIV Test Control)RADIATION SAFEW Cornerstone:

Occupational Radiation Safety (OS)Access Control to Radiolooicallv Siqnificant Areas (71124.01-1 Sample)Insoection 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 10 CFR 20, applicable TSs, and applicable station procedures.

lnspection Plannino The inspectors reviewed Performance Indicators (Pls) for the Occupational Exposure cornerstone.

RSOl Enclosure 15 Radioloqical Hazard Assessment The inspectors conducted walkdowns of the facility, including the dry-active waste collection location, the low-level waste storage facility, and associated yard area, to evaluate material and radiological conditions.

The inspectors made independent radiation measurements to verify conditions.

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 the CAP, as applicable.

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

Contamination and Radioactive Material Control The inspectors observed locations where the licensee monitors potentially contaminated material leaving the radiological controlled area, 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.Radioloqical 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 (VHMs), to the extent necessary to verify conformance with the Occupational Pl.Rad iation Worker Performance The inspectors selectively reviewed radiological problem reports since the last inspection to identify human performance errors and 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 of the event to be radiation protection technician error and to evaluate the corrective action approach taken by the licensee to resolve the reported problems.PI&R The inspectors determined if problems associated with radiation monitoring and exposure control 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 concerns. (See Section 4OA2)Enclosure b.16 Findinos No findings were identified.

OccupationalAs Low As Reasonablv Achievable (ALARA) Planninq and Controls (71124.02)

Inspection Scope Inspection Planninq The inspectors selectively reviewed pertinent information regarding plant collective exposure history, current exposure trends, and ongoing or planned activities in order to assess current performance and exposure challenges.

Radiolooical Work Planninq The inspectors selectively compared accrued results achieved (dose rate reductions, person-rem used), as available, with the intended dose established in the licensee's ALARA planning for selected work activities 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 completed at the time of the inspection, the reasons for inconsistencies between intended and actualwork activity doses.The inspectors determined if post-job (work activity)reviews were conducted and if identified problems were entered into the CAP.Source Term Reduction and Control The inspectors discussed source term mitigation effectiveness with licensee staff associated with the Unit 2 outage.PI&R 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's CAP. The inspectors discussed corrective actions for identified ALARA concerns. (See Section 4OA2)Findinqs No findings were identified.

RSO2 b.Enclosure a.17 RS03 ln-Plant Airborne Radioactivitv Control and Mitioation (71124.03)

RSO4 lnspection Scope lnspection Planninq The inspectors reviewed the reported Pls to identify any related to unintended dose resulting from intakes of radioactive materials.

PI&R 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. (See Section 4OA2)Findinqs No findings were identified.

Occupational Dose Assessment (7 1 124.04)Inspection Scopq lnspection 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 to ensure they were National Voluntary Laboratory Accreditation Program (NVLAP) accredited.

The inspectors determined if the licensee uses a "correction factor" to address the response of the electronic dosimeter (ED) as compared to its thermoluminescent dosimeter 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 Dosimetric Situations The inspectors selectively reviewed exposure results, and monitoring controls employed, associated with declared pregnant individuals during the current assessment period.The inspectors selectively reviewed the licensee's implementation of monitoring for external dose in situations in which non-uniform fields are expected or large dose b.a.Enclosure b.18 gradients (i.e., use of multi-badging or determination of effective dose equivalent for external exposures using an NRC approved method).Shallow Dose Equivalent The inspectors selectively reviewed personnel contamination instances to evaluate frequency, causes, and dose assessment, as appropriate.

The inspectors also discussed identification and logging of personnel contamination occurrences during the Unit 2 outage, including actions taken to identify and limit personnel contamination events.PI&R 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 CAP. (See Section 4OA2)Findinos No findings were identified.

Radiation Monitorinq lnstrumentation (7 1122.05)Inspection Scope PI&R The inspectors selectively reviewed corrective action documents associated with radiation monitoring instrumentation to determine if the licensee identified issues at an appropriate threshold and placed the issues in the CAP for resolution.

In addition, the inspectors evaluated the appropriateness of the corrective actions for a selected sample of problems documented by the licensee that involve radiation monitoring instrumentation. (See Section 4OA2)Findinqg No findings were identified.

Cornerstone:

Public Radiation Safety (PS)Radioactive Gaseous and Liquid Effluent Treatment (71124.06)

Insoection Scopg Ground Water Protection Initiative (GPl) lmplementation The inspectors selectively reviewed implementation of the ground water monitoring program. The inspectors reviewed monitoring results of the GPI to determine if the licensee has implemented its program as intended and to identify any anomalous or missed results and to determine if the licensee has identified and addressed deficiencies through its CAP.RSO5 RSO6 b.a.Enclosure 19 PI&R 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 properly addressed for resolution in the CAP. (See Section 4OA2)b. Findinqs No findings were identified.

4. OTHER ACTTVTTTES (OA)4OA1 Performance

Indicator (Pl) Verificatign (71151- 14 Samples)Cornerstone:

Mitigating Systems.1 Mitiqatinq Svstems Performance lndicators (MSPls) (71151- 10 Samples)a. Inspection Scope The inspectors reviewed a selected sample of PBAPS's information submitted for the five Mitigating Systems Pls listed below to assess the accuracy and completeness of the data reported to the NRC for these Pls. The Pl definitions and the guidance contained in Nuclear Energy lnstitute (NEl) 99-02, "Regulatory Assessment Indicator Guideline," Revision 6, and Exelon procedure LS-AA-2200, "Mitigating System Performance Index Data Acquisition and Reporting," Revision 3, were used to verify that procedure and reporting requirements were met. The inspectors reviewed raw Pl data collected from October 2009 through September 2010 and compared graphical representations from the applicable Pl reports to the raw data to verify the data was included in the report.The inspectors also examined a selected sample of operations logs, licensee event reports (LERs), CAP records, equipment clearances, and MR data to verify the Pl data was appropriately captured for inclusion into the Pl report and that the individual Pls were correctly calculated.

Documents reviewed are listed in the Attachment.

o MSPI - Emergency Alternating Current Power System, Unit 2 and Unit 3 (MSO6);. MSPI - High Pressure Injection System, Unit2 and Unit 3 (MS07);. MSPI - Heat Removal System, Unit 2 and Unit 3 (MS08);. MSPI - Residual Heat Removal (RHR) System, Unit 2 and Unit 3 (MS09); and. MSPI - Support Cooling Water System, Unit2 and Unit 3 (MS10).b. Findinos No findings were identified.

.2 Review of Safetv Svstem Functional

Failures (SSFFS) Pls (71151- 2 Samples)a. Inspection Scope The inspectors reviewed PBAPS's submittals for the SSFFs Pls for both Units 2 and 3 (MS05). For the functional failures, the inspectors looked at the period from the October 2009 through October 2010. The Pl definitions and the guidance contained in NEI 99-02, "Regulatory Assessment Indicator Guideline," Revision 6, and Exelon procedure Enclosure b.20 LS-M-2080, "Monthly Data Elements for NRC SSFFs," Revision 4, were used to verify that procedure and reporting requirements were met.The inspectors reviewed LERs issued during the referenced timeframe for SSFFS. The documents reviewed are listed in the Attachment.

The inspectors also compared graphical representations from the most recent Pl report to the raw data to verify that the data was correctly reflected in the report.Findinos No findings were identified.

Occupational Exposure Control Effectiveness (71151- 1 Sample)Cornerstone:

Public Radiation Safety Inspection Scope The implementation of the Occupational Exposure Control Effectiveness Pl Program (OR01) was reviewed.

The inspectors selectively reviewed CAP records for occurrences involving HRA, VHRA, and unplanned personnel radiation exposures since the last inspection in this area. The review was against the applicable criteria specified in NEI 99-02, "Regulatory Assessment Indicator 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.

Radioloqical Effluents Technical Specification (RETS) /Off-site Dose Calculation Manual (ODCM) Radioloqical Effluent Occurrences (71151- 1 Sample)Inspection Scope The implementation of the RETS/ODCM Pl (PR01)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 Indicator 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 associated with identification of localized ground water contamination within the restricted area.Findinos No findings were identified.

.3 a.b.a..4

b.Enclosure 4c.42.1 a.21 ldentification and Resolution of Problems (Pl&R) (71152 - 3 Samples)Review of ltems Entered into the CAP Inspection Scope As required by Inspection Procedure (lP) 71152, "ldentification and Resolution of Problems," and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed screening of all items entered into the licensee's CAP. This was accomplished by reviewing the description of each new action request (AR) / lR and attending daily management review committee meetings.Findinqs No findings were identified.

Semi-Annual Review to ldentifv Trends (1 Semi-annual Resident Inspector Sample)Inspection Scope The inspectors reviewed lists of CAP items to identify trends (either NRC or licensee identified)that might indicate the existence of a safety issue. First, the inspectors reviewed a list of approximately 7,700 lRs that PBAPS initiated and entered into the CAP action tracking system (Passport)from June 1, 2Q10 through December 1, 2010.The inspectors also reviewed approximately 3,530 open lRs in the CAP that remained open with outstanding actions. The list was reviewed and screened to complete the required semi-annual Pl&R trend review. Based on the review, a sample of 68 Passport lRs (listed in Attachment 1) were selected for a more detailed review to verify whether the issues were adequately identified and evaluated, and that corrective actions were planned. The inspectors evaluated the lRs against the requirements of Exelon procedure, LS-AA-125, and 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action." Findinqs and Observations No findings were identified.

During this trend review period, the inspectors noted two significant events involving overpressure gas (helium) leaking from ISFSI Casks Numbers 1 (lR 1 126689) and 50 (lR 1 129931). A root cause analysis (RCA) for cask number 1 (lR 1 131123) was in progress at the end of the inspection period. See Sections 4OA3.1, 4OA3.2 and 4OA5.3 of this report for additional discussion.

Also during this period, PBAPS performed a RCA for the Unit 2 reactor water chemistry reaching action level 1 as a result of a HPSW to RHR leak within the 2 'C' RHR Heat Exchanger (HX) (lR 1112617, lR 1080382).

The inspectors concluded that the performance of these two RCAs for equipment reliability issues was appropriate.

A work group evaluation (WGE) was performed for another equipment reliability issue.Specifically, a WGE acknowledged that the increase in total dissolved combustible gases in the 3'B' MPT that required a plant shutdown and replacement during a maintenance outage (lR1 139814) was the result of operating the MPT 12 to 17 years b.a..2 Enclosure

.3 22 past its normal expected service life. Since the MPT is not a safety-related

component, there was no violation of NRC requirements.

The Outage/Reactor Services group experienced several issues during this trend assessment period that included:

the refueling equipment performance indicator turning red (lR 1121101);

a dummy fuel bundle coming in contact with a bundle in the spent fuel pool (SFP) (lR 11 17854); and a fuel bundle coming in contact with an in-vessel inspection submarine (lR 1115A41).

PBAPS appropriately initiated a common cause analysis (CCA) to assess an adverse trend in reactor services crew clock resets (rR 1128280).The inspectors observed that PBAPS took appropriate action to perform CCA's of three additional trends. The first involved an adverse trend of human performance events in the first and second quarter si2010 (1R1095534).

The second involved liquid radwaste releases exceeding established station goals (lR 1120323).

The third involved a significant recurring trend of issues associated with the perimeter intrusion detection system (lR 1095601).

The inspectors noted additional adverse trends related to the following subject areas: confined space program implementation (lR 1113275, lR 1 1 13557, lR 1 1 1 5107 ,lR 1 154579), ESW system corrosion and thru-wall leakage (lR 1099140, lR 1 137854,lR 1138619, lR 1139646, lR 1141622), water intrusion into manholes containing underground cables (lR 1 1 31251, lR 1 136152, lR 1 147495, lR 1152771), assuring operability of Units 2 and 3 SFPs (lR 1 1 53723,lR 1147062, lR 1147066, lR 1139377) and recurring 3'A'circulating water pump trips (lR 1093772, lR 1094164, lR 1109905);

however, 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 acceptably identifying adverse trends before they became more safety significant problems.

Each of these trends were evaluated using IMC 0612 Appendix B, "lssue Screening" and Appendix E,"Examples of Minor lssues," and the inspectors determined that they do not represent a finding of more than minor significance at this time.Annual Sample: Motor Operated Valve (MOV) Effectiveness of Corrective Actions for Hardened Grease Challenoes (1 Annual Sample)lnspection Scope This inspection focused on Exelon's effectiveness of corrective actions, EOC reviews, and resolution of challenges associated with hardened grease on safety-related MOV's.The initial NRC review of this issue was documented in lnspection Report 05000277;0500027 812009003 ( Green N CV 05000 27 7, 0500027 8 l 2009003-0 1, MOV Prog ra m Procedures were lnadequate with Regard to Periodicity of Preventing Maintenance Activities for Stem Lubrication).

The inspectors reviewed Exelon's corrective actions reports, a sample of diagnostic and stroke time test data, and interviewed plant personnel to evaluate the adequacy of Exelon's corrective actions. Finally, the inspectors reviewed MOV program procedures to evaluate the quality and effectiveness of the Exelon MOV program, as implemented at PBAPS. Documents reviewed are listed in the Attachment.

b.23 Findinqs and Observations No findings were identified.

MOV failures caused by grease hardening have been a chaflenge at Peach Bottom Units 2 and 3. Specifically, on March 12 and March 21, 2009, two HPCI valves (MO-2-23-058 and MO-3-23-057)failed to stroke to the full open position during their ST. Investigation by Exelon identified hardened grease on the stem and inside the stem nut, as well as stem nut wear. Initial EOC evaluations also revealed that two RHR valves developed less-than-required closing thrust for successful diagnostic test acceptance (MO-3-10-13D and MO-2-'10-1548).

Hardened grease was also identified on the stem and inside the stem nut of both RHR valves. In addition, severe stem nut thread damage (broken and missing threads and sharp edges) was identified on valve MO-3-10-13D (lR-898030).

The final EOC scoping determined that 45 safety-related MOVs required additional evaluation appropriate to the circumstances, such as visual inspection, grease evaluation, diagnostic testing, and/or corrective maintenance.

The root cause evaluation performed by Exelon under lR-892191

, determined that Peach Bottom MOV preventive maintenance (PM) frequencies and actions had not appropriately included stem lubricant performance feedback.

ln addition, the root cause evaluation identified that Exelon had the longest allowable MOV PM lubrication intervals in the entire nuclear fleet (up to 10 years).The inspectors concluded that Exelon has taken timely and appropriate actions as delineated in the root cause evaluation to address the grease hardening challenges.

The corrective actions, including PM reviews and implementation frequency adjustments, lubrication/grease replacement and inspections of all safety related MOVs (total population of 184 valves) are being properly tracked, appropriately documented, and completed as scheduled.

The inspectors noted that Exelon's management and Exelon's Management Review Committee, system engineers and MOV program experts, and the independent oversight group have demonstrated appropriate engagement and safety focus through the process (the initial corrective action lR assignment, root cause review, action tracking, EOC reviews, and effectiveness reviews)to improve the reliability of safety-related MOVs and prevent or minimize reoccurrence of grease hardening issues.Annual Sample: Review of Corrective Actions for Submerqed Cables (1 Annual Sample)Inspection Scope The inspectors performed a focused review of the corrective actions regarding submerged cables. The issues with submerged cables at Peach Bottom were documented in two findings, 05000277,27812009005-01 and 05000277, 27812009005-02.

The inspectors interviewed the knowledgeable design engineer to understand the history of the submerged cable issues at Peach Bottom and to assess Exelon's evaluation and corrective actions. The inspectors observed inspection and maintenance activities to assess the material condition of the cable manholes and to evaluate the adequacy of maintenance.

The inspectors reviewed WOs and test results to verify that testing and maintenance are being performed in accordance with vendor instructions and industry standards.

The inspectors also reviewed lRs to verify the adequacy of corrective actions. Documents reviewed for this inspection activity are listed in the Attachment.

.4 a.Enclosure

b.24 Findinqs and Observations No findings were identified.

The inspectors determined that the PBAPS is adequately evaluating, trending, and correcting issues related to submerged cables. The inspectors reviewed a detailed apparent cause evaluation for the submerged cables issues. The inspectors noted that Peach Bottom's initial corrective actions included performing cable testing on a sample of cables to provide baseline data for future testing and performing initial manhole inspections to verify the adequacy of conditions in the manholes.

The inspectors noted that Peach Bottom's ongoing corrective actions include periodic inspections of manholes, installing water level detectors in manholes, and more extensive cable testing. The inspectors determined that Peach Bottom is taking adequate corrective actions to maintain their cables in accordance with their design basis and industry guidance.The inspectors observed one instance of failing to document a condition adverse to quality in an lR. As part of Exelon's corrective actions, water level detectors were installed in manholes at Peach Bottom to ensure that cables did not remain submerged for extended periods of time. Since the installation of manhole water level alarms in August 2010, the responsibility for monitoring the alarms rested on a single design engineer.

On October 27,2010, several lRs were written documenting that high water level alarms had been received for five manholes.

The lRs correctly stated that the manholes must be pumped within three weeks based on industry guidance; but at the time the lRs were written, cables in the manholes had already been submerged for over three weeks. A corrective action was added to an existing lR to transfer alarm monitoring responsibility to operations, but the failure to drain the manholes within the time limit was not documented in an lR. Consequently, there was no interim corrective action to ensure that alarms were not missed again.The failure to document the missed time requirement was based upon reliance on a previous operability evaluation (Op Eval 10-002). During this inspection, an lR was written to document this issue (1152475)which will implement a more rigorous interim alarm monitoring program until the program is fully transferred to operations.

The lR also documented an evaluation that confirmed that the Op Eval 10-002 did, in fact, provide a valid basis for operability for this circumstance.

The inspectors determined that the failure was an isolated incident and operability was not in doubt. Using IMC 0612 Appendix B, "lssue Screening" and Appendix E, "Examples of Minor lssues," the inspectors determined this issue was of minor significance.

Occupational Radiation Safetv Proqram and Effluent and Environmental Monitorinq Proqram (7 1 1 24.01, 7 1 1 24.02, 7 I 1 24.03, 7 1 1 24.04, 7 1 1 24.05, 7 1 1 24.06)Inspection Scope The inspectors selectively reviewed corrective action documents for Occupational Radiation Safety Program and Effluent and Environmental Monitoring Program. See Attachment for a list of documents reviewed.The review was against criteria contained in 10 CFR 20, TSs, ODCM, and applicable station audit and surveillance procedures.

.5 a.Enclosure

b, 25 Findinqs No findings were identified.

Follow-up of Events and Notices of Enforcement Discretion (71 153 - 1 Sample)Event Notice #46353: ISFSI Cask TN-50-A Inspection Scope On October 22,2010, PBAPS personnel informed the inspectors that an event notification report was planned to meet the requirements of 10 CFR Part72.Specifically, the report was made pursuant to 10 CFR 72.75(c)(1)as a result of a material defect in a weld on an ISFSI cask main lid and pursuant to 10 CFR 72.75(c)(2)as a result of a reduction in the effectiveness of the cask confinement system.Event Notice #46353 reported that on October 22, 2010, at 1058, troubleshooting of ISFSI Cask TN-50-A indicated that a leak existed in the cask lid sealing area at a leak rate greater than allowed by ISFSI Cask TS Section 3.1.3, "Cask Helium Leak Rate." TS 3.1.3 limits the Cask Helium Leak Rate to 1.0 E-05 ref-cc/sec.

The cask was in UNLOADING OPERATIONS and was located within the PBAPS Unit 3 containment building.

PBAPS's preliminary review indicated that a leak existed at the sealwelded plug that provided sealing of the drilled interseal passageway associated with the drain port penetration of the cask lid. This leak effectively provides a bypass of the main lid outer confinement seal.Findinos No findings were identified and a review of this issue by region based ISFSI specialist inspectors is documented in report section 4OA5.3.Event Notice #46373: ISFSI Cask TN-68-01 (1 Sample)Inspection Scope On October 27,2Q10, PBAPS personnel informed the inspectors that an event notification report was planned to meet the requirements of 10 CFR Part72.Specifically, the report was made pursuant to 10 CFR 72.75(c)(2)as a result of a reduction in the effectiveness of an ISFSI cask confinement system.Event Notice #46373 reported that on 10127110, at 1 107, troubleshooting of ISFSI Cask TN-68-01 identified that a helium leak exists in the cask lid sealing area at a leak rate greater than allowed by ISFSI Cask TS Section 3.1.3, "Cask Helium Leak Rate." TS 3.1.3 limits the Cask Helium Leak Rate to 1.0 E-05 ref-cc/sec.

The cask was in LOADING OPERATIONS and was located within the PBAPS Unit 2 containment building.

PBAPS's preliminary review indicated that a leak existed in the Cask Main Lid Outer Closure Seal. ISFSI cask TN-68-01 was subsequently unloaded into the Unit 2 spent fuel pool on November 20,2010.40A3 ,1 a.b..2 Enclosure b.26 Findinqs No findings were identified and a review of this issue by region based ISFSI specialist inspectors will be documented in NRC lR 0500027712010010.(Closed) LER 05000277//2010004-00.

lmproper Credit for Function of Off-site Power Source Transformer Load Tap Chanqer (LTC) (1 Sample)Based on information provided by the NRC as part of their closeout of a Task Interface Agreement associated with an NRC unresolved item, the plant management staff determined that certain plant equipment could be degraded as a result of lower voltages that may exist during a postulated design basis loss-of-coolant event coupled with certain degraded voltage conditions.

Although the safety significance of this event is considered to be very low, the event is considered to be a condition prohibited by TSs.The cause of the event was due to the previous assumption that credit could be taken for the operation of the LTCs associated with the offsite power course transformers.

This credit would result in higher voltages to the supplied equipment.

Upgrades to most of the TS impacted equipment have been performed.

Other compensatory measures have been put in place to assure operability of other components until other design upgrades can be completed.

The enforcement aspects of this issue were documented in lnspection Report 05QQ0277,27812010004, Section 4C.45.2, as an inspector-identified, Green NCV (NCV 05000277,27812010004-03)of 10 CFR 50, Appendix B, Criterion lll, "Design Control," in that, Exelon did not use the voltage levels provided by the degraded grid relay setpoints to determine the operability of safety-related components.

The inspectors reviewed the LER and did not identify any additional violations of regulatory requirements.

Therefore, this LER is closed.Other Activities (Closed) Confirmatorv Order EA-09-007 and EA-09-059 Follow Up Inspection (92702 - 1 Sample)Background On December 1, 2009, the NRC issued the Exelon Generating Company, LLC, a Confirmatory Order for EA-09-007 and EA-09-059, which confirmed commitments made to the NRC made as part of a settlement agreement between the NRC and Exelon using the NRC's Alternative Dispute Resolution Program (ADR). This order can be found in the NRC's document system (ADAMS) as Accession Number ML093350150.

This order confirmed the following commitments:

A. Complete the following actions by June 30,201A, and send the NRC a letter informing the agency that the actions are complete within 30 days of their completion:

.3 40A5 ,1 Enclosure

a.27 a. Review special obligations of licensed operators and supervisors in Peach Bottom licensed operator training program, including Peach Bottom operating experience.

b. Develop an assessment to verify the effectiveness of actions associated with deliberate misconduct training.c. Perform Peach Bottom Site Employee lssues Advisory Council (EIAC) reviews regarding employee conduct issues/concerns, including any apparent trends in these areas; and ensure corporate EIAC emphasizes comparison of site data to identify trends or outliers.d. Repeat Peach Bottom training module on deliberate misconduct for new employees and current Peach Bottom personnel in 2010, emphasizing the impact of deliberate misconduct on nuclear safety culture.B. Complete the following actions by September 30, 2010, and send the NRC a letter informing the agency that the actions are complete within 30 days of their completion:

a. lnclude deliberate misconduct training in the fleet-wide Supervisory Development Program for new supervisors.

b. lmplement Peach Bottom training module fleet-wide, emphasizing the impact of deliberate misconduct on nuclear safety culture. Exelon will also review its current contractor training on deliberate misconduct and add the training module, if necessary.

c. Provide additional information fleet-wide, to educate the workforce on Behavior Observation Program, Fitness-for-Duty requirements, and Employee Assistance Program seryices.d. Provide lessons learnedtype article to Professional Reactor Operators Society (PROS) requesting consideration for inclusion in industry newsletters.

e. Provide lessons learnedtype article to NEI requesting consideration for inclusion in its industry newsletter.

f. Discuss with Institute of Nuclear Power Operations (INPO) the possibility of incorporating into its supervisor and operations development programs, a module regarding the significance and impact of deliberate misconduct.

Inspection Scope In order to independently verify that Exelon's commitments had been met, in accordance with NRC lP 92702, the inspectors conducted a review of CAP records and evaluations, training materials and records, appropriate Exelon procedures, site and corporate EIAC meeting minutes, interviewed appropriate plant staff, and reviewed Exelon's docketed letters informing the NRC of completion of the PBAPS specific commitments dated July 23,2010 (ML102150454), and the fleet-wide commitments dated October 27,2010 (M1103070176).

ln addition, the inspectors reviewed CAP documents and evaluations, CCA, effectiveness reviews, and interyiewed personnel to assess, using NRC lP 92722 as guidance, whether Exelon's actions to evaluate a potential adverse trend of deliberate misconduct exists at PBAPS, evaluate Exelon's corrective actions to address this potential trend, and to monitor for such a trend going fonruard.

Documents reviewed and personnel contacted are listed in the attachment.

b.28 Findinqs and Observations No findings were identified.

Based upon the inspection activities described above, the inspectors determined that PBAPS and Exelon have satisfied the obligations of the December 1, 2009 Confirmatory Order described in Sections V. A and V. B. Exelon developed and conducted training at both the station and fleet levels, performed site and corporate EIAC reviews to identify and monitor any potential trends at both PBAPS and other Exelon sites, and submitted articles for consideration to PROS, INPO, and NEI for consideration for inclusion in industry publications and training modules.PBAPS conducted a CCA of nine deliberate misconduct events which had occurred at PBAPS between 2005 and 2008. The inspectors reviewed PBAPS's CCA, its findings and observations, and the corrective actions developed to address those observations.

PBAPS determined that there was currently no adverse trend of deliberate misconduct.

The inspectors independently reviewed the data collected during the CCA. The deliberate acts were spread among the Operations, Maintenance, and Security Departments and involved both temporary and permanent plant staff. The majority of the events were from the 2007 timeframe and involved the actions of a single individual.

The exception being the 2007 Inattentive Security Officer's Event, where an entire crew was involved.

PBAPS management and Exelon began taking corrective actions in the 2007 timeframe, to specifically address a number of these issues and those actions did appear to be effective as the number of events has dropped significantly.

Thus, based on these actions and the additional training and actions which were taken as a result of the Confirmatory Order, the inspectors concluded that there is currently no adverse trend of deliberate misconduct at PBAPS. However, there is evidence to suggest that there was such a trend in the 2007 timeframe, but Exelon did appear to identify this issue and take appropriate corrective actions.The inspectors also reviewed EIAC records and check-in-self assessments conducted to monitor the effectiveness of the training and monitor for future trends. The inspectors determined that these reviews were thorough and probing, employed appropriate techniques to develop conclusions, and the conclusions were reasonable and supported by the data.fn summary, the inspectors determined that Exelon has satisfied the commitments set out in the Confirmatory Order, and has taken appropriate actions to monitor, evaluate, and develop corrective action for a potential adverse trend of deliberate misconduct.(Closed) NRC Temporarv Instruction (Tl) 2515/177 - Manaqinq Gas Accumulation in Emerqencv Core Coolinq. Decav Heat Removal and Containment Sprav Svstems lnspection Scope The inspectors performed the inspection in accordance with Tl25151177, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal and Containment Spray Systems." The NRC staff developed Tl 25151177 to support the NRC's confirmatory review of licensee responses to NRC Generic Letter (GL) 2008-01,"Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal and Containment Spray Systems." The Office of Nuclear Reactor Regulation (NRR).2 a.Enclosure 29 reviewed Exelon's GL 2008-01 response and based on this review, the NRR staff provided guidance on a Tl inspection scope to the regional inspectors.

The inspectors used this inspection guidance along with the Tl to verify that Exelon implemented or was in the process of acceptably implementing the commitments, modifications, and programmatically controlled actions described in their GL 2008-01 response.

The inspectors verified that the plant-specific information (including licensing basis documents and design information)was consistent with the information that Exelon submitted in their GL 2008-01 response.The inspectors reviewed a sample of isometric drawings and piping and instrumentation diagrams, and conducted selected system piping walkdowns to verify that Exelon's drawings reflected the subject system configurations and UFSAR descriptions.

Specifically, the inspectors verified the following related to a sample of isometric drawings for the HPCI, CS, and RHR systems:. High point vents were identified;. High points that did not have vents were recognized and evaluated with respect to their potential for gas buildup;. Other areas where gas could accumulate and potentially impact subject system operability, such as orifices in horizontal pipes, isolated branch lines, HXs, improperly sloped piping, and under closed valves, were acceptably evaluated in engineering reviews or had ultrasonic testing (UT) points which would reasonably detect void formation; and. For piping segments reviewed, branch lines and fittings were clearly shown.The inspectors conducted walkdowns of portions of the above systems to assess the acceptability of the drawings Exelon used during their review of GL 2008-01. The inspectors verified that Exelon conducted walkdowns of the applicable systems to confirm that the combination of system orientation, vents, instructions and procedures, and testing, would ensure that each system was sufficiently full of water to assure operability.

The inspectors reviewed Exelon's methodology used to determine system piping high points, identification of negative sloped piping, and calculations of void sizes based on UT equipment readings, to ensure the methods were reasonable.

The inspectors observed a field UT measurement in the CS system discharge piping to assess the adequacy of the monitoring techniques used to ensure system operability.

The inspectors also verified that Exelon identified and evaluated all systems within the scope of the GL.The inspectors reviewed a sample of Exelon's procedures used for filling and venting the identified GL 2008-01 systems to verify that the procedures were effective in venting or reducing void sizing to acceptable levels. The inspectors verified that Exelon's surveillance frequencies were consistent with the PBAPS TSs and associated bases, and the UFSAR. The inspectors reviewed a sample of system venting surveillance results to ensure proper implementation of the surveillance program and that the existence of unacceptable gas accumulation was evaluated within the CAP, as necessary.

The inspectors reviewed CAP documents to verify that selected actions described in Exelon's nine-month and supplemental response submittals were acceptably b.30 documented, including completed actions and implementation schedules for incomplete actions, and to verify that NRC commitments were included the CAP. Additionally, the inspectors reviewed evaluations and corrective actions for issues Exelon identified during their GL 2008-01 review. The inspectors performed this review to ensure Exelon appropriately identified and corrected gas voiding issues. Documents reviewed are listed in the Attachment.

Findinqs No findings were identified.

The inspectors identified a discrepancy between Exelon's GL response and existing plant procedures regarding the techniques used to maintain the systems full of water. The inspectors reviewed the plant procedures to verify their adequacy and discussed the issue with NRR. The inspectors determined the issue was minor because it did not impact operability or impede the regulatory process. Exelon amended their GL response (ML103490536)to correct the discrepancy.

This completes the inspection requirements for Tl 25151177 .ISFSI Cask #50 Leakino Helium (60855 - 1 Sample)Backqround Cask #50 was loaded with spent fuel in accordance with Certificate of Compliance (CoC)1027, Amendment 1, issued October 30, 2007. The cask was placed on the ISFSI pad in May 2010. The casks on the ISFSI pad are continuously monitored for helium pressure.

On September 4, 2010, an alarm was received indicating low helium pressure for Cask #50. On September 5,2010, the helium over pressure system was measured to be 40 psig and was then recharged to 75 psig. On September 9, 2010, the cask was transported to the refuelfloor of Unit 3. PBAPS initiated a monitoring plan to record and chart the helium pressure within the cask on a daily basis. The monitoring program revealed the cask continued to slowly leak helium. PBAPS began troubleshooting on October 17 , 2010, and used procedure SF-910, "Spent Fuel Cask Leakage Location Determination," to identify the source of the helium leak as the lid seal weld on October 22,2010. PBAPS reported the identified helium leak to the NRC Operations Center as required by 10 CFR72.75.

The lid sealweld is performed during the cask manufacturing stage: therefore, it is considered a manufacturing defect. PBAPS is working with the cask manufacturer to prepare and execute a repair plan. PBAPS estimates the repair plan approval and subsequent repair work will take place in the first calendar quarter of 2411.Inspection Scooe The inspectors were on-site October 13, 201Q, to review the licensee's actions, their projected path fonvard, and to verify PBAPS was in compliance with the CoC Technical Specifications (CoC TS). The CoC TS 3.1.5, requires the cask interseal pressure to be at least 3.0 atm (approximately 29.4 psig) and the CoC TS 3.1.4, requires the helium leak rate for the overpressure system to be less than 1.0 E-5 ref-cc/second.

PBAPS has successfully kept the interseal pressure above the required limit by continuously monitoring the pressure and recharging it as necessary.

The helium leak rate for the overpressure system did not meet the CoC TS requirement.

The CoC TS states that if the helium leak rate for the overpressure system is greater than the limit the cask must.3 a.Enclosure b.31 be returned to the spent fuel unloading facility within 30 days. PBAPS complied with this requirement when it moved the cask to the Unit 3 refuel floor on September 9,2010.The projected path forward, as described above, was determined to be adequate.Findinqs No findings were identified.

rsFsr - (60855.1)Inspection Scope The inspectors selectively reviewed routine operational surveillance dala, including radiological surveillance, for the ISFSI facility.

The inspectors toured the facility and made independent radiation measurements of the facility.

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

Findinqs No findings were identified.

Meetinqs.

lncludinq Exit Quarterlv Resident Exit Meetinq Summarv On January 21,2011, the resident inspectors presented the inspection results to Mr. Thomas Dougherty and other PBAPS staff, who acknowledged the findings.Mr. P. Krohn, Chief, USNRC, Region 1, Division of Reactor Projects, Branch 4, attended this quarterly inspection exit meeting. The inspectors asked the licensee whether any of the information discussed as being included in the report should be considered proprietary.

No proprietary information was identified.

Manaqement Meetinos.4 a.40A6.1 b.,2 The inspection results for the inspection of ISFSI Cask #50 Leaking Helium were discussed with Mr. Garey Stathes, Plant Manager, and other members of the PBAPS staff via teleconference on January 5, 2011.The inspection results for the inspection of Public and Occupational Performance Indicators, Ground Water Protection Program, and Unit 2 and Unit 3 Occupational Radiological Controls were discussed with members of Exelon Nuclear management on December 17,2010 and January 11,2011.The inspection results for the inspection of Tl 25151177 - Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removaland Containment Spray Systems were discussed with Mr. Thomas Dougherty, Site Vice President, and other members of the PBAPS staff on December 3, 2010.ATTACHMENT:

=SUPPLEMENTAL

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

R. Franssen, Work Management

Director

L. Lucas, Chemistry

Manager

R. Holmes, Radiation

Protection

Manager

T. Wasong, Training Director

C. Goff, Operations

Training Manager

NRC Personnel

P. Krohn, Branch Chief

F. Bower, Senior Resident Inspector

A. Ziedonis, Resident Inspector

J. Brand, Reactor Inspector

S. Hammonds, Senior Health Physicist

J. Lilliendahl, Reactor Inspector

K. Mangan, Senior Reactor Inspector

J. Nicholson, Health Physicist

R. Nimitz, Senior Health Physicist

A. Rosebrook, Senior Project Engineer

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None Ooened/Closed

0500027 7 &27 I I 20 1 0 00 s-0 1 Closed 05a00277t2010004-00

NCV LER Inadequate

MSIV Test Control (Section 1R22)lmproper Credit for Function of Off-site Power Source Transformer

LTC (Section 4OA3.3)Attachment

Discussed 050002 77& 27 8 l 2009003-0

0500027 7 &27 81 2009005-0

0 50 002 7 7 & 27 I l 200900 5-02 NCV MOV Program Procedures

were Inadequate

with Regard to Periodicity

of Preventing

Maintenance

Activities

for Stem Lubrication (Section 4OA2.3)Continuously

Submerged

Cables Design Deficiency (Section 4OA2.4)Failure to Follow Procedures

and lmplement the Exelon Nuclear Cable Condition Monitoring

Prog ram for Non-Safety-Related

Control and Power Cables Within The Scope of the Maintenance

Rule (Section 4OA2.4)Failure to Ensure Adequate Voltage was Available

to Safety-Related

Equipment (Section 4OA3.3)NCV 0500027 7, 27 I l 20 10004-03 NCV