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:	Krohn P G Reactor Projects Region 1 Branch 4
To:	Pacilio M J Exelon Nuclear, Exelon Generation Co
Krohn P G
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 cc dencl: Distribution via ListServ 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.qov/readinq-rm/adams.html (the Public Electronic Reading Room).

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

Enclosure:

lnspection Report 0500027712010005 and 0500027812010005 M

Attachment:

Supplemental Information cc w/encl: Distribution via ListServ Distribution w/encl: (via E-mail)W. Dean, RA (RIORAMAIL Resource)D. Lew, DRA (RIORAMAlL Resource)D. Roberts, DRP (R1 DRPMail Resource)J. Clifford, DRP (RIDRPMAlL Resource)P. Wilson, DRS (RlDRSMail Resource)P. Krohn. DRP A. Rosebrook, DRP S. lbarrola, DRP E. Torres, DRP F. Bower, DRP, SRI A. Ziedonis, DRP, Rl S. Schmitt, DRP, OA J. Trapp, RIOEDO RidsNrrPMPeachBoftom Resource RidsNrrDorlLpl 1 -2Resource ROPreportsResource@nrc.qov SUNSI Review Complete:

AAR (Reviewer's Initials)MLI10341057 DOC NAM E : G :\DRP\BRANCH4\I NS PECTION REPORTS\PEACH BOTTOM\201 0\4TH QTR INSPECTION\PBIR2O1 O.OOs-REV2.DOCX After declaring this document "An OfficialAgency Record" it will be released to the Public.To receive a copy of this dooment, indicate in the box "C" = Copy without athchmenuenclosure "E" = Copy dattachmenuenclosure "N'= No copy IFFICE mmf RUDRP RI/DRP R1/DRP lAME FBower/MR for ARosebrooUMR PKrohn/PGK)ATE 0'U 31 t1',l 01t31 111 02t 02 t11 1 U.S. NUCLEAR REGULATORY COMMISSION 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

LIST OF DOCUMENTS

REVIEWED Section 1R01: Adversp Weather Protection Peach Bottom Certification Letter for Winter Readiness, dated November 30, 2010

WC-AA-107, Revision 9, Seasonal Readiness

MA-PB-1003, Revision 7, Winter Readiness and Storm Response Guidelines for the Peach Bottom Facility

AO 29.2, Revision 16, Discharge Canal lntake Pond Cross-Tie Gate Operation and Frazil lce Mitigation

OP-AA-108-111-1001, Revision 5, Severe Weather and Natural Disaster Guidelines

OP-PB-108-1

1-1001 , Revision 4, Preparation for Severe Weather

SO 48.4.A, Revision 4, Draining ESW and HPSW Return Lines to Emergency Cooling Tower for Winter Freeze Protection

eSOMS Suite Operator Rounds: Operator Daily Outside Rounds lR

1046286, 2009 and 2010 Winter Execution Critique Action ltems lR 1

036865, 2010-2011

Winter Readiness Tracking Assignments

lR

1078404,2010

and 2011 AR for Site Winter Readiness Actions - PEA RT-l-066-200-2, Revision 8, Heat Trace System Testing, completed

08/30/10

RT-O-040-620-2, Revision 15, Outbuilding

HVAC and Outer Screen Inspection for Winter Operation, completed

1 l 18109

RT-O-040-630-2, Revision 1 2, Winterizing Procedure, completed

1 l 1 ElOg lR

1089563, B5B Pump Engine Heater Tripped lR

1150920, Tear in the B.5.8 Hose Trailer Cover lR 1

129696, Insulation Missing on Aux Steam Lines lR

1129402, Cover for AC Unit in Station Blackout (SBO) Building Broken lR 1

130635, North and South Outer Screen Structure Doors Need Winterizing

lR 1

132962, Door at Outer Screen Structure Won't Close, Frame lnterference

lR

1136575, TIC Indicates Low lR

1137753, The Heaters Will Get Hot but the Fan Will Not Run FIN Attachment

lR

1142081, Engineering Evaluation Needed to Support 50.59 Screening lR

1149072, Per

AO 29.2 Evaluate Intake Pond Crosstie Gate Operation lR 1

150258 ,2'B' Trash Pit Sump Pump Water Found in Oil lR

1138684, zSU Switchgear Building Louvers Will Not Close lR

1138703, Fan 0CV070 Backdraft Damper Failed Open lR

1139283, Steam Heater Fan Not Running lR

1139285, Heater Not Operating lR

1139300, Heater Failed to Start with Thermostat at MaxlR1128372,0DE139

Fan Failed to Start lR

1128375, 0GE139 Fan Failed to Start lR

1129361, 0CV066 Fan Backdraft Dampers Did Not Close lR

1129362, 0DV066 Fan Backdraft Dampers Did Not Close lR

1129365,U2and

U3 Circ Water Pump Structure Intake Louvers are Stuck lR

1129379, 'A' Cooling Tower Pump House Unit Heater Control Station fR

1129400, Louvers #3 and #4 on West Wall Not Able to be Moved lR

1129404, Dampers Failed to Close lR

1129406, Fan Damper Failed to Close

Section 1R04: Equipment

Alionment

AO 10.4-2, Revision 21, RHR System - Fuel Pool to Reactor Mode lR

1118232,2'A'

RHR Loop Check

AO-2-10-0464

No lndication in Main Control Room lR

1122003,

AO-2-10-0464

Fails to Indicate Closed lR

1122426,

AO-2-10-0464, No Acoustic lmpact Event Recorded lR

1123044, A0-2-10-046A

Failed to Indicate Closed, Follow-up

lR

1118232 SO 13.1.A-3.

COL, Revision 4, RCIC System Peach Bottom Single Line Diagram, North Substation, South Substation, Terminal Yard E-1, Sheet 1, Revision 47, Station Single Line Diagram E-5343, Revision 16, SBO Substation Single Line lR

1105699, SBO Test Line Breaker Will Trip lf Close 21,22,23 or 24 Breaker lR 1131 456,#l Transformer'B' Sudden Pressure Relay Sensor Oil Tap lsolation Valve Oil Leak Licensed Operator Training Lesson Plans, System 51 (Substations and Transformers), 51H (SBO), 53 (13 kV System) and 54 (4 kV System)SO 53.1.A COL, Revision 13, 13 kV Electrical System, Common Plant

SO 53.1 .A-2 COL, Revision 0, 13 kV Electrical System

SO 53.1.A-3 COL, Revision 1, 13 kV Electrical System

SO 53.7.4, Appendix 7, Revision 1, Removal of 343SU Transformer

00X01 1 from Service

SO 54.1.A COL, Revision 1, 4160 Volt Emergency Auxiliary Switchgear

TS 3.8.1 and Bases UFSAR, Revision 19, Figure 8.3.1 UFSAR, Revision 14, Figure 8.3.2 UFSAR, Revision 22, Section 8.4 UPFSAR, Revision 21,Table 8.4.1 Section 1R05: Fire Protection

lR 1124534. Fire in 2 'B' Reactor Feed Pump (RFP) Lagging lR

1124571, Critique ol2'B' RFP Turbine Fire

OP-AA-201-002, Revision 4, Attachment

1: Fire Event Report 10-6, dated

10110110

PF-102, Revision 5, Unit 2 Turbine Building, RFP Turbine / Chiller Area -Elevation

165'-0"

PF-128, Revision 4, Radwaste Building Unit 3 Reactor Building Closed Loop Cooling Water Attachment Room, Elevation

16'-0"

PF-134&38, Revision 2, Unit 3 Reactor Building 3'B'and 3'D'CS Room, Elevation g1'-6"

PF-64, Revision 2, Unit 3 Reactor Building Sump Room, Elevation

88'-0"

PM-1048, Revision 0, Design Basis for Internal Flood Protection for the HPSW / ESW Pump Structure Specification

NE-075, Revision 4, Penetration Seals in Hazard Barriers at Peach Bottom and Limerick A/R A1167100, Outside Fire System Leakage through Penetrations in Pump Structure A/R A1249047, Outside Fire System Leakage through Penetrations in Pump Structure A/R A1777591, Water Leaking from Load Center E224-P-A Safety Concern DBD P-T-09, Revision 9, Internal Hazards Topical Design Basis Document

ECR 01-01116, Clarify Design Basis for Pump Structure Internal Flooding lR

1120123, Ground Water Intrusion into E224-P-A MCC lR

1120156, Ground Water Intrusion into E224-P-A MCC lR 1 1201 56, Ground Water Intrusion into E124-P-A MCC lR

1120916, ldentify Source of Leaks ldentified by lssue

1120123 lR

1120923, ldentify Source of Leaks by lssue

1120123 lR

1131243,

LT-2-70A-006

Has Alarmed lR

1131246,

LT-2-7OA-009

Has Alarmed lR

1131247,

LT-2-7OA-025A

Has Alarmed lR 113'1250,

LT-2-70A-025C

Has Alarmed lR 1 131 251,

LT-2-7 0A-060 Has Alarmed lR

1131252,

LT-2-70A-061

Has Alarmed lR

1131255, Manhole 0268 Has Alarmed lR

1139453,2CP342

RHR Floor Drain Sump Does Not Work Correctly in Auto lR

1119887, Rain Water at Junction Box of Motor Driven Fire Pump Controls lR

1119848, Water Leaking from Load Center E224-P-A Safety Concern lR

1120123, Ground Water Intrusion into E224-P-A Motor Control Center Section 1R1 1: Licensed Operator Requalification Prooram

PSEG-1107R, Revision 2: "Out-of-the-Box" (OTB) Evaluation Scenario, performed

10125110

TQ-M-150, Revision 4, Operator Training Programs

EP-M-1007, Revision 19, Radiological Emergency Planning Annex for PBAPS

AT-102, Revision 7, Reactor High Pressure T-100, Revision 11, Scram T-101, Revision 19, Reactor Pressure Vessel: Power, Level and Pressure Control T-103, Revision 16, Secondary Containment

T-112, Revision 16, Emergency Blowdown

Section 1R12: Maintenance

Effectiveness

ER-M-5400, Buried Piping and Raw Water Corrosion Program (BPRWCP) Guide

ER-AA-5400-1001, Raw Water Corosion Program Guide

ER-AA-5400-1002, Buried Piping Examination Guide

ER-M-5400-1

003, BPRWCP Performance Indicators

lR

1019963, High Risk Piping Requires Inspection and Mitigation Action lR

1019949, Buried Piping lnspections Yield Moderate Area of Interest lR

1019952, Buried Piping Inspection Yields SubstantialArea of Interest lR

1019955, Buried Piping Inspection Yields Moderate Area of lnterest lR

1019958, Buried Piping lnspection Yields Moderate Area of Interest lR

1022452, Buried Piping Initiative Excavation Location One Attachment

lR1022453, Buried Piping Initiative Excavation Location Two lR

1022456, Buried Piping Initiative Excavation Location Three lR

1022458, Buried Piping Initiative Excavation Location Four lR

1022463, Buried Piping Initiative Excavation Location Five lR

1022464, Buried Piping Initiative Excavation Location Six lR

1022620, Buried Piping G-Wave Inspection Scope for P2R18 lR

1022622,2010

Above Ground Accessible Guided Wave Inspection

lR

1039055, Raw Water Chemistry Strategy Not Optimized lR

1039797,2A10

LTAM Strategy For Buried Pipe & Raw Water lR

1067943, Evaluate Vendor Recommendations for Raw Water Systems lR

1103126, ESW Corrosion Control Enhancements

lR

1116429, 2R18 Radwaste Discharge Piping G-Wave ResultslR1128228, P3R18 Buried Piping Initiative

G-Wave Inspections

137854, Pinhole Leak ldentified on 'A' ESW Supply in Excavation

138619, Below Minimum Wall Reading on 20 lnch'A'ESW

Supply in Excavation

139646, Possible Min Wall Reading on2O Inch'A'ESW

Supply in Excavation

lR

1141622, Low Wall Reading on 16 Inch 'A' ESW Supply in Excavation

lR

1148136, Piping Repair Required on a 16 lnch 'A' ESW in Cardox Room lR 1

148140, Piping Repair Required on a 2Q lnch 'A' ESW in Cardox Room lR

1148745, Linear Indication Discovered on 20 Inch 'A' ESW f R

1149298, Linear lndication Discovered on 20Inch 'A' ESW Pipe f R

1149753, Piping Repair Required on 20Inch 'A' ESW in Pump Structure lR

1148776, Unit 3 ESW Admiralty Corrosion Rate Exceeds Target lR

1148774, Unit 2 ESW Admiralty Corrosion Rate Exceeds Target lR

1153112, Evaluate 'A' and 'B' ESW Piping Corrosion f R

1152937, Coating Degradation in Excavation

IR IR IR lR 1

154783 , 2Q11

GL 89-13 Piping Inspection Scope lR

1154787 , 2011

GL 89-13 Piping Inspection Scope lR 1

154798 ,2011

GL 89-13 Piping lnspection Scope lR 1

154807 , 2011

GL 89-13 Piping Inspection Scope lR 1 15481 1, 2011

GL 89-13 Piping Inspection Scope lR 1

154813, 2011

GL 89-13 Piping lnspection Scope lR 1 15481 9, 2011

GL 89-13 Piping Inspection Scope lR 1

154823 , 2011

GL 89-13 Piping Inspection Scope lR 1

154830 , 2011

GL 89-13 Piping lnspection Scope lR

1154833,2011

GL 89-13 Piping Inspection Scope lR

1154842,2011

GL 89-13 Piping lnspection Scope lR 1

154845 ,2011

GL 89-13 Piping Inspection Scope lR 1

154847 , 2011

GL 89-13 Piping Inspection Scope so-2-33-16)

so-3-33-9)

so-2-33-102)

so-2-32-10)

s0-3-32-8)

so-3-32-10)

so-2-48-12)

so-2-48-13)

so-2-32-4)

so-2-33-101)

so-2-33-103)

s0-3-32-6)

so-3-32-7)

AR A1744872, Buried Piping lnspection Yields Moderate Area of Interest AR A1745528, Buried Piping Inspection Yields Substantial Area of Interest AR A1745527, Buried Piping Inspection Yields Moderate Area of Interest AR A1745526, Buried Piping lnspection Yields Moderate Area of Interest AR A1744933, Buried Piping Initiative Excavation Location One

AR 41744932, Buried Piping Initiative Excavation Location Two

AR 41744931, Buried Piping Initiative Excavation Location Three AR A1744930, Buried Piping Initiative Excavation Location Four AR A1744929, Buried Piping Initiative Excavation Location Five AR A1744903, Buried Piping G-Wave lnspection Scope for P2R18 AR A1744927,2010

Above Ground Accessible Guided Wave Inspection

AR 41776553, 2R18 Radwaste Discharge Piping G-Wave Results lR

1151546, MR Screening System 70A for Manhole Water Monitoring

lR 1 15371 1, lmprove Reliability of Manhole Water Monitoring System lR

1152475, Cable Program lnvestigation

lR

1152771,

LT-2-70A-060

Has Alarmed lR 1 1 52789,

LT-2-70A-0268

Position Requires Investigation

Section 1R13: Maintenance

Risk Assessments and Emerqent Work Control

SF-900, Revision 7, ISFSI Abnormal Conditions Response lR

1127274, Unit 2 Reactor Building Crane Would Not Raise With a Load lR

1127245, Does Cask #601 and #650 Work Need

CC-AA-112 (TCCP) Review?lR

1127018, Buried Piping Excavation Delays Due to ISFSI Movement lR

1109955, ISFSI Alarm Received for Cask #50 1R1125128, ISFSI Cask#42 False Alarms lR

1126789, lssue Written to Create a New A/R for Work Planning lR

1126968, Spent Fuel Casks #48 to #52 Not Licensed as Dual Purpose lR 1

126691, Performance Trending of Cask OP Pressure Monitoring

LTA.lR 1

126689,72.48150.59

Reviews Not Performed for Recent ISFSI Procedure Revisions lR

1126353, NOS lD: No Limit for the Number of Re-Pressure of ISFSI Cask lR

1128307, ISFSI Cask #1 - Foreign Substance on Cask & Pad lR

1128724, ISFSI Cask #01 (Protective Cover)lR

1130349, Bolting on Cask #1 Weather Cover Rusted Beyond Use 50.59 Applicability Review Form for

SF-290 Revision 6, dated

10115110 50.59 Screening

PB-2010-71-S,

SF-290, Revision 6, Spent Fuel Cask Loading and Storage Operations

2.48 Screening Form, Revision 6 of

SF-290, dated

10115110 A/R 41744932-04.

Walkdown and Specify Excavation Restriction for ISFSI Casks

SA-AA-1 17, Revision 12, Excavation, Trenching, and Shoring

RT-O-001-4Q0-2,Individual Full Closure of Main Turbine Stop Valves, performed

2120110 lR

1154167, U2 Main Turbine Stop Valve #3 Failed to Stroke During Testing lR

1154331, Relay XK80 Needs Replaced Licensed Operator Training, System 1 'B' - Main Turbine TSs Sections 3.3.1.1 and Bases TSs Sections 3.3.2.2 and Bases TSs Sections 3.3.4.2 and Bases Unified Control Room Log, Saturday December 18, 2010, Night Shift Unified Control Room Log, Sunday December 19, 2010, Day Shift Unified Control Room Log, Sunday December 19,2010, Night Shift lR

1157318, 3'C' HPSW Pump Failed PMT* - lndicates

NRC ldentified Section 1 R1 5: Ooerabilitv Evaluations Simplified Troubleshooting/Repair Guide for

TN-68-50A

Cask Apparent Leakage

AR 41773748,lSFSl Alarm Received for Cask #50 WO M1773748, Repair Cause of ISFSI Alarm for Cask #50 WO

C0235207, Troubleshoot and Recover Cask #50 to Pad WO

C0234633, Repair Cause of ISFSI Alarm for Cask #50 lR

1126689,72.48

/ 50.59 Reviews Not Performed for Recent ISFSI Procedure Revisions lR

1126691, Performance Trending of Cask Overpressure Monitoring

LTA lR

1126968, Spent Fuel Casks #48 to #53 not Licensed as Dual-Purpose

lR

1127245, Does Casks #601 and #650 Work Need

CC-AA-112 (TCCP) Review Attachment

lR

1127757, Pages of Calculation

349-T-VC-9

Are Missing lR

1129931, ISFSI Cask #50 Helium Leak lR

1145858, ISFSI TS Does Not Provide Guidance lR

1145752, 50.59 Review Needed for ISFSI Cask #50 lR

1145528, Downward Trend in Cask #50 Pressure lR

1147581, Recommend Evaluating

ISFSI Helium Leak Test Method lR

1151642, ProceduralApproval Form 50.59172.48

Checkbox Usage lR

1136859, Unit 3 'B' MPT - 3Bx001 lR

1139189, 3 'B' MPT ACMP Threshold Exceeded for TDCG R.O.C. > 100 PPM/Day lR

1139482, 3 'B' MPT ACMP Threshold Exceeded for TDCG R.O.C. > 150 PPM/Day lR

1139814, 3'B' MPT Gassing Exceeded ACMP Threshold lR

1140382, Bushing Test Results lR

1069325, Better Pedigree Needed for OPDRV 1.5" Opening Threshold lR

985243-03, Initiative to Consider CRD Exchange as Not an OPDRV lR

967045, Revision to TRM Section 1.1 lR

865411, Evaluate Making CRD Exchange a non-OPDRV

Evolution lR

495940, Engineering Evaluation Requested to Support CRD Flange De-Torque lR

378310, CRD Exchange Delayed - OPDRV During De-Torquing

lR377754, Procedure/CCTS

Coordination lssue Resulted in 20 Minute Delay

FH-6C, Core Component Movement - Core Transfers

GP-6, Refueling Operations

GP-26, Coordination of HCU, CRB, CRD, DGB, and PIP Work during a RFO M-C-747-01

1, Control Rod Drive Exchange Using NES Machine Letter from M. A. Ring (U.S. NRC) to M. J. Pacilio (Exelon Generation Company, LLC),"Clinton Power Station NRC Integrated lnspection Report 05000461/2010-003," dated August 3,2010 Letter from F. A. Kearney (Exelon Generation Company, LLC) to Document Control Desk (U.S. NRC), "Response to NRC Integrated Inspection Report 05000461/2010-

003," dated September

1, 2010 (M1102530283)

Letter from T. A. lppolito (U.S. NRC) to E.GJ. Bauer Jr. (Philadelphia Electric Company),"Amendment Numbers 65 and 64 to Facility Operating License Numbers

DPR-44 and

DPR-56 for PBAPS Unit Numbers 2 and 3," dated March 26, 1980 (Adams Accession Numbers

8004230409,

800423041

4, and

800423041

9)Peach Bottom TRM Section 1.1, "Definitions," Revision 5 (Proposed/Not

PORC Approved)50.59 Review Coversheet Form,

PB-2009-029-S, Revision 0,'TRM Definitions (PBAPS Units 2 and 3) - Revision to Definition of OPDRV to Allow a Single CRD Change 50.59 Screening Form,

PB-2009-029-S, Revision 0, "TRM Section 1.1 (PBAPS Units 2 and 3)10

CFR 50.59 Safety Evaluation Definition of Operations with the Potential for Draining the Reactor Vessel, PBAPS Units 2 and 3, dated December 29, 1995, (Approved in PORC Meeting 96-01, January 1, 1995)Clearance

10002101, ESW Discharge Piping 'A' Header Repair

ECR 10-00443, Repair of ESW Piping at Sites 1 & 2 Operability Evaluation

10-008, under lR

1137854-02, Pin Hole Leak ldentified on 'A' ESW Supply in Excavation

OP-AA-1 08-1 1 5, Revision 9, Operability Determinations

ER-AA-330-009, Revision 5, ASME Section Xl Repair/Replacement Program A/R

41783258, Pin Hole Leak ldentified on 'A' ESW Supply in Excavation

ASME Boiler and Pressure Vessel Code, Section Xl, 2001 Edition, July 1, 2003 Addenda lR 1

137854, Pin Hole Leak ldentified on 'A' ESW Supply in Excavation

lR

1138619, Below Min Wall Reading on 2O-inch 'A' ESW Supply in Excavation

lR

1148136, Piping Repair Required on 16"'A' ESW in Cardox Room lR

1148745, Linear Indication Discovered on 2O-inch 'A' ESW Attachment

lR

1148774, ESW Admiralty Corrosion Rate Exceeds Target lR

1148776, U3 ESW Admiralty Corrosion Rate Exceeds Target lR

1148784, Service Water Admiralty Corrosion Rate Exceeds Target f R 1

149753, Piping Repair Required on 20" 'A' ESW in Pump Structure

41744929-03

and 13, Buried Piping Initiative Excavation Location Five

41744930-03

and 13, Buried Piping lnitiative Excavation Location Four

41744932-03

and 13, Buried Piping Initiative Excavation Location Two

41744933-03

and 13, Buried Piping Initiative Excavation Location One PBAPS UFSAR, Revision 22, Appendix C - Structural Design Criteria

SA-AA-1 17, Revision 1, Soil Type Classification

Section 1R19: Post-Maintenance

Testinq

SF-250, Revision 6, Varian 979-70 Helium Leak Detector Operations and Calibration, performed 10t18t10

SF-220, Revision 24, Spent Fuel Cask Loading and Transport Operations

SF-900, Revision 7, lSFSlAbnormal Conditions Response lR 1

126691, Performance Trending of Cask OP Pressure Monitoring

LTA.f R

1126689,72.48150.59

Reviews Not Performed for Recent ISFSI Procedure Revisions lR

1126353, NOS lD: No Limit for the Number of Re-Pressure of ISFSI Cask lR

1128095, ISFSI Cask

TN-68-01 OP System Low Pressure - Learnings

/ Actions lR

1128997, ISFSI Fuel Cask 00T701 Helium Leakage - EOC lR

1129931, ISFSI Cask #50 Helium Leak NRC Event#46353, Peach Bottom Spent Fuel Storage Related Defect, dated

10122110 50.59 Applicability Review Form for

SF-290 Revision 6, dated

10115110 50.59 Screening

PB-2010-71-S,

SF-290, Revision 6, Spent Fuel Cask Loading and Storage Operations

2.48 Screening Form, Revision 6 of

SF-290, dated

10115110 WO

C0235207,Troubleshoot and Recover Cask to Pad

ECR 10-00162, Peach Bottom Radio Refresh Project WO

C0233481-31, Peach Bottom Radio Refresh Project Walkdowns lR

1130888, 20Y050 Breaker #15 Will Not Reclose

ON-112, Revision 10, Loss of Uninterruptible

AC Power lR

1144389, 3 'C' HPSW Pump Performance Differed From Expected lR

1143572, Unable to Hook UP Flow Box to Obtain Proper Reading

ST-O-032-301-3, HPSW Pump Valve and Flow Functional and Inservice Test (test record, completed

1112412010)

AR A1714862,

ST-O-032-301-3 - HPSW PVF Functional

IST AR A1785091, 3 'C' HPSW Pump Performance Differed From Expected WO R1135041, HPSW PVF Functional

IST lR

1151049, HPSW PV&F Not Completed In Accordance with the Plan lR

1151050, HPSW PV&F (Partial IST) Not Completed

IAW Plan lR

1157318, 3'C' HPSW Pump Failed PMT A/R A1782741, Received 2'B' Battery Charger Trouble Alarm Drawing

NE-102-4, Sheet 1, Revision 2, Cyberex Model 130/200R3-S

Battery Charger Power Stage lR

919666, 2 'C' Station Battery Charger TroublelR923273,2DD003

Battery Charger Failure Alarm Came ln lR

955526, 3AD003-1 Charger Fail/AC Failure Alarms Light Will Not Reset lR

1037820, Loose Jack on SCR Board in 2CD003-2 Charger ldentified

lR

1130109, 2 'B' Station Battery Charger Trouble Alarm and Low Voltage lR

1136993, Received 2 'B' Battery Charger Trouble Alarm Attachment

lR '1138029, Adverse Trend in Electrical Troubleshooting

lR

1138219, 28D003-1 Alarms Came in During Setup for PMT lR

1143057,

C0235655-16

Failed PMT after Board Replacement

lR

1143077, 2CD003-2 Charger Fail Alarms lR

1147293, Need for Battery Charger Training M-057-014, Revision 13, Cyberex 125 Volt Battery Charger Maintenance

ST-M-57B-762-2, Battery Charger 28D003-1 and 28D003-2 Capability Test, performed 11t26t10 Unified Control Room Log, Friday, November 26,2010, Day Shift Unified Control Room Log, Tuesday, November 30, 2010, Day Shift lR

1153706, U3 HPCI Suction Hi Pressure Alarm lR

1154614, U3 HPCI TSA Duration -20% Scheduled versus Actual

ST-O-023-301-3, HPCI Pump, Valve and Flow and Unit Cooler Functional and In-Service Test Unified Control Room Logs, Saturday, December 18,2010 Night Shift

ECR 09-00160, System-23-Q

Unit 3, Install New Vent Valves

ER-AA-302-1007, Revision 5, MOV Limitorque Actuator Capability Determination Methodology

lR

1048641, U3 HPCI 30P038 Inboard and Outboard Seal Leak After Run lR

1153114,

MO-0-48-0502A:

Metal Scale Found in Body M-366, Sheet 4, Revision 52, P & l Diagram - HPCI Pump Turbine Details

RT-O-032-300-2, HPSW Pump, Valve and Flow Functional Test, performed

2107110

RT-M-048-02A-2, Revision 0, M0-0-48-0502A

Outgoing Interlocks Test

ST-O-094-400-2, Stroke Time Testing of Valves for PMT, performed

2116110 WO

C0236060 MOV Diagnostic Test Instructions, MO-0-48-05024

WO

C0236060 MOV Post-Test Data Review Worksheet,

MO-0-48-0502A, performed

2116110* - lndicates

NRC ldentified

Section 1R20: Refuelinq

and Other Outaqe Activities

lR 1122534. Black Box UnSat during RCIC ST-O-013-750-2

lR

1121897, Risk Assessment for Unit 2 RCIC RSD Panel Testing lR

1091494, Documentation of Startup Analysis for lR

1121897 lR

1121485, LCO 3.0.4.b Used to Support the RPV Pressure Test lR1122485, Risk Assessment Did Not Follow All Requirements of

OU-AA-103 lR 112025l P2R18 Core Verification - Fuel Assembly Not Fully Seated lR

1120516, P2R18 MSRV/MSSV

As-Found Lift Test Results lR

1121393, PORC Feedback - Operability Evaluation

10-006, Revision 1 lR

1121643,

RV-2-02-0708

Leak at Discharge During RPV Pressure Test lR

1121076, P2R18 Drywell Critical lnsulation Inspection Results lR

1120904, Potential Low Margin Condition ldentified in Analysis lR

1121590, SCRAM Times Require Test Performance Evaluation

lR

1122003, A0-2-10-46A

Fails to Indicate Closed lR

1122962, Bio-Shield lssues lR

1123594, Documentation of Bio-Shield Doors Walkdowns lR

1122565, Reportability Review Assignment Not Generated lR 1 1231 12, E224 Load Center Main Feed Breaker Very Noisy lR

1120717, Rod 18-11 Drifted in When Restoring the CRD Charging Header lR

1120719, Rod 54-31 Drifted in When Restoring the CRD Charging Header lR

1122904, Rod 54-15 Drifted from 00 lR

1123113, Unit 2 Main Generator Casing Leak Test UnSat'lR

1123502, Higher Than Expected Drywell Floor Drain Pumpouts lR

1125574, Frequent Small Drywell Floor Drain Pumpouts Attachment

lR

1124523, Rod 50-27 Less Than 10% Margin to TS SCRAM Time Limit lR

1124318, Control Rod Stuck lR 1

123360, Shutdown & Online Risk Procedure Conflicts on Assessment Transition

lR

1123240, Indicated

RCIC Flow on

FC-2-13-091

during HPCI Operation lR

1123114,

CB-K134E ITE Breaker in E224 (1112) Cubicle is Humming lR

1128280, Reactor Services East Crew Clock Resets lR

1130256, Bioshield Door Bolting - Follow up lR

1140450, Transformer Control Cabinet TCCP Removal lR

1140424, Bushing Testing - Determine Spare Availability

lR

1140127, Control Road 06-47 Changed Position Indication When Selected lR

1140505, A WRNM Detector Reading Higher Than Other Detectors lR

1140900, Unit 3 Bioshield Doors on 186'Missing Supports and Bolting lR

1140859, Rod Worth Minimizer Software Modification Change Not in Forced Outage Scope lR

1140814, Unit 3

CRD 14-55 Difficult to Move from 00-06 lR

1140875, 3'B' MPT Replacement:

Engineering to Verify All Design Documents Revised lR

1141099, Problems Moving Unit 3

CRD 26-03 lR

1141087, Control Rod 34-03 Difficult to Move lR

1141105, The New 38X001 Transformer Sudden Pressure Relay lR

1141418, LLRT Fittings Found on the Unit 3 Stabilizer Manways lR

1142469, Oil Leaks on Replacement

(38X001) MPT lR

1142541, 38X001 Bushing Enclosure Box (Doghouse)

Damper lR

1142620,

HCU 38-51 Double Notched on Single Notch Withdrawal

lR

1142657, Replace 3 'B' MPT Heater and HTR CKT Breaker lR

1142742, Unit 3 Recirc Pump Vibration Alarms During Start-up lR

1143092, Control Rod 34-51 Double Notched on Single Notch Withdrawal Section 1 R22: Surveillance Testinq lR

1123502, Higher Than Expected Drywell Floor Drain Pumpouts lR

1125574, Frequent Small Drywell Floor Drain Pumpouts lR 1

126557, MSRV 71H Tailpipe Temperature High OOS lR

1120516, P2R18, MSRV/MSSV

As-Found Lift Test Results

AR 41779557,ISFSI

Cask #1 (Location

t$42) False Alarms lR 1

126689 ,72.48 / 50.59 Reviews Not Performed for Recent ISFSI Procedure Revisions lR 1

126691, Performance Trending of Cask Overpressure Monitoring

LTA lR

1126789, lssue Written to Create a New AR for Work Planning lR

1127245, Does Casks #601 and #650 Work Need

CC-M-112 (TCCP) Review lR

1127757, Pages of Calculation

349-T-VC-9

Are Missing lR

1128997, ISFSI Fuel Cask 00T701 Helium Leakage - EOC lR

1128724, ISFSI Cask #01 lR

1130349, Bolting on Cask #1 Weather Cover Rusted Beyond Use lR 1

128307, ISFSI Cask #01 - Foreign Substance on Cask & Pad lR

1131123, ISFSI Cask #1 - Potential Helium Leak lR ISFSI Cask

TN-68-01 OP System Low Pressure - Learnings

/ Actions lR

1136204, No ISFSI Inspection

PM and Concerns with the ILRT Test lR

1143711, Station Support Needed for Root Cause Investigation

I R

728348, Sl2P-7 1 -0701 -XXC3 through Sl2P-7 1 -0737-XXC3

Change Request lR

1125128, ISFSI Cask #1 (Location tl42) False Alarms lR

1125935, Need Revision of

SF-900 for

TC-10-164 lR

1126353, No Limit for the Number of Re-Pressurizations of ISFSI Casks f R

1126689 ,72.48 / 50.59 Reviews Not Performed for Recent ISFSI Procedure Revisions lR 1

126691 , Performance Trending of Cask Operating Pressure Monitoring

LTA Attachment

SF-610,

TN-68 Cask Repressurization, Revision 0

SF-290, Spent Fuel Cask Transport and Unloading Operations, Revision 5

SF-290, Spent Fuel Cask Transport and Unloading Operations, Revision 6

SF-490, Radiation Protection Requirements During Spent Fuel Cask Unloading and Transport Operations, Revision 1 0 SF-g10, Spent Fuel Cask Leakage Location Determination, Revision 0

SF-900 ISFSI Abnormal Condition Response, Revision 7 WO R0875235, COT of ISFSI Low Pressure Switches (lncreased Frequency)

Simplified Troubleshooting/Repair Guide for

TN-68-50A

Cask Apparent Leakage

ST-O-013-301-3, Revision 35, RCIC Pump, Valve, Flow and Unit Cooler Functional and lST, performed

10120110

ST-O-023-3Q1-2, Revision 57, HPCI Pump, Valve, Flow and Unit Cooler Functional and IST Sl2(3)M-13-GOV-XXC2, Revision 3, Calibration and Check of RCIC Turbine Governor

RT-O-023-725-2(3), Revision 1 8, HPCI Response Time A/R

40385844, Replace HPCI RGSC A/R

40384750, Replace HPCI RGSC (RGSC-23)lR

0532405, Valve Stroke UNSAT in Accordance with ST-O-07G-475-2

lR

0964717,

AO-3-01A-086A

Failed Minimum Allowed Stroke Time lR

1112430, MSIV

AO-80A Long Stroke Time lR

1140706,

ST-O-07G-470-3

Failure Due to Fast Stroke Times lR

1141888, NOS lD: MSIV Stroke Time Not Adjusted lR

1142180,

AO-3-014-864

Outboard MSIV Failed

ST-O-07G-470-3

Again lR

1142234,

AO-3-01A-864:

Manifold Noise during Fast Closure!R1142672, Final Measured Close Time of

AO-3-01A-864

at 4.82 Seconds lR

1142401, Clearance and Tagging Challenge lR

1142784, NOS lD: Test Results Evaluation Not Used for MSIV Failed Surveillance

lR

1142850, NOS lD: Test Results Not Approved by Responsible Superintendent.lR

1159854, Record U2 MSIV LS Position

NUREG-1482, Revision 1, Guidelines for IST for Nuclear Power Plants PBAPS PCM Templates, BWR MSIV

ST-M-01A-471-3, Revision 9, MSIV Timing, Springs Only Closure and Position Switch Adjustment, performed

l181 10

ST-M-01A-471-2, Revision 10, MSIV Timing, Springs Only Closure and Position Switch Adjustment

ST-O-O7G-470-3, MSIV Closure Timing, Revision 13, performed

10/03/08, and 10/08/08

ST-O-O7G-470-3, MSIV Closure Timing, Revision 13, performed

01122109

ST-O-07G-470-3, MSIV Closure Timing, Revision 14, performed

09/29109

ST-O-O7G-470-2, MSIV Closure Timing, Revision 15, performed

10/01i 10

ST-O-07G-47Q-3, MSIV Closure Timing, Revision 15, performed

11115/10, and

11118110

ST-O-O7G-475-2, MSIV Closure Timing at Shutdown, Revision 3, Performed

09/13/10 Unified Control Room Log, Monday, November 15, 201Q, Night Shift Unified Control Room Log, Thursday, November 18, 2010, Day Shift Unified Control Room Log, Thursday, November 18, 2010, Night Shift PBAPS UFSAR, Revision 22, Section 14.3 - Unacceptable Safety Results for Accidents PBAPS UFSAR, Revision 22, Section 14.5 - Analysis of Abnormal Operating Transients

WO

C0235823, Adjust Stroke Times Limerick 5T-6-041-202-1, Revision22, MSIV Cold Shutdown Valve Test NRC lnspection Report 05000352&35312003-003, Limerick Generating Station lR

0147485, MSIV Stoke Time UNSAT lR

0164391, NRC Concerns on Unit 2 MSIVs and MSIV Test Methods Attachment Weir Valves and Controls Company Procedure Number 302-90422, Revision 1, Sensitivity of MSIV Stroke Time to Variations in Flow Parameters and to Changes to Hydraulic Damper Oil Temperature, performed for Hatch Electric Generating Plant, approved 07t01t03

RT-O-O1D-402-2, Master Trip Solenoid Valves Operability Test, Revision 7 (test record dated December 13, 2010)RT-O-O1D-402-2, Master Trip Solenoid Valves Operability Test, Revision 7 (retest record dated December 14,2010)lR

1151657, Unit 2 Main Turbine MTSV'B' Slow to Trip during Monthly Testing

AR 41787340,

SV-2-01D-48698 - Main Turbine Master Trip Solenoid Valve 'B'

Section RSO1: &cess Con'lrol to Radiolosically

Siqnificant Areas Procedures

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

RP-M-460-001, Revision 2, Control for VHRA

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

RT-H-099-960-2, Revision 7, Outside Radioactive Material Storage Area Inspection and Survey Documents Dose Records Common Cause Analysis -

AR1117442 Work Practices -

AR1137954 Exposure Control -

AR1126541 Contamination Control - Personnel Contamination Data Dosimetry Performance Testing Data Corrective Action Documents (ARs 1

115575,

1115631 ,

1121887,

1127152,

1118825,

1117442, 1 1 26501,

11379541,

1119162,

111917 4, 1121134)Memorandum to Paul G. Krohn thru Pamela J. Henderson, from Ronald L. Nimitz, Public and Occupational Performance lndicators, Ground Water Protection Program, Unit 2 and 3 Occupational Radiological Control, Including Unit 2 Post-outage Radiological Controls Review Inspection Report Feeder for PBAPS, Units 2 and 3 lntegrated lnspection Report Numbers

05000277 and 0500027812010005, dated January 18,2011 (ML110180498)

Sectislr_BS0Z:

Occupational

ALABA Planning and Controls Documents General Source Term data BRAC Point Data Business Plan and Site ALARA Plan Goals Work Job reviews and ALARA reviews Outage Report Data Corrective Action Documents (ARs-

1121190,

1121194,

11211980, 1 1 15333,

1115629,

1115845,1

15918,

1117253,

1117412,

1117756, 1117758)

Section RS04: 9ccupational

Dose Assessment

Procedures

RP-AA-210, Revision 18, Dosimetry lssue, Usage, and Control Documents Attachment

NRC Safety Evaluation, Application to Use Weighting Factors for External Exposure, dated December 20,2006 Exposure Controland Dose Records General Source Term data Personnel Contamination Event Logs Personnel Intake Investigations Corrective Action Documents (ARs-

1117248,

1117263,

1117424,

1117625,

1117729, 1 1 18001, 1118030,118281)

Section RS05: Radiation

Monitorinq Instrumentation

Documents

General Source Term data BRAC Point Data ALARA Work In Progress Reviews Contamination Monitoring Instrument Matrix

Section RS06: Radioactive

Gaseous and Liquid Effluent Treatment Procedures

EN-M-408-4000, Revision 0, Radiological Ground Water Protection Program lmplementation

EN-PB-408-4160, Revision 0, Peach Bottom RGPP Reference Material Documents Annual Radiological Environmental, Effluent Release Reports - 2008, 2009 ODCM and Changes Reports (various) - Routine Ground Water General Source Term Data Ground Water Analyses Section 4OA1 : Performance lndicator Verification

MSPI Deviation Reports and Svstem Manaqer Notebooks:

October 2009 through September

2010, Unit 2 and Unit 3 RHRyHPSW October 2009 through September

2010, Unit 2 and Unit 3 ESW October 2009 through September

2010, Unit 2 and Unit 3 EDGs October 2009 through September

2010, Unit 2 and Unit 3 HPCI October 2009 through September

2010, Unit 2 and Unit 3 RCIC lRs: lR

1034923, Use of Incorrect Parameters for MSPI Terms lR

1110941, lmproper Assignment Closure - MSPI UA Terms Procedures:

LS-AA-2001, Collecting and Reporting of NRC Pl Data, Revision 13

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

MSPI Failure Determination Evaluation, Revision 4

ER-AA-600-1047, Mitigating Performance lndex Basis Document, Revision 5

ST-C-095-865-2, Determination of Annual Dose Equivalent for All Uranium Fuel Cycle Source, Revision 1 LERs:

LER 03-09-05, Common Cause Failure of 'C' and 'E'Wide Range Neutron Monitors Attachment

LER 02-09-02, Pneumatic Supply Degraded for Containment lsolation Valves Due to Mis-Positioned Valve

LER 03-09-06, Unplanned Manual Scram Due to Shortening Reactor Period During Scheduled Shutdown

LER 03-09-07, Oil Leak from MSIV Dashpot Results in Short Valve Stroke Time

LER 02-10-01, Multiple Slow Control Rods Results in Condition Prohibited by TSs Docume[Ls

NEI 99-02, "Regulatory Assessment Indicator Guideline," Revision 6.Annual Radiological Environmental, Effluent Release Reports- 2008, 2009 Public Dose Projections (Liquid, Gaseous)Reports (various) - Routine Ground Water data Corrective Action Documents (ARs- 1

132685, 1 1 14909,

1115323, 11160Q2,

116401 ,

1116765, 1 1 32685, 1 1 32685, 1 1 1 4909, 1 I 15323, 1 1 1 6002, 1 1 6401, 1 1 16486, 1116644)

Section 4OA2: ldentification

and Resolution of Problems lssue Reports lR

1128059, Station Trend Review -

511110 to 8i31110 lR

1139125, NRC

URI 2010004-02:

P2R18 Fuel Handling Performance Errors lR

1139377, NRC

URI 2010004-01:

Degraded SFP Boraflex Panels lssues lR

1131123, ISFSI Cask #1 - Potential Helium Leak lR

1129931, ISFSI Cask # 50 Helium Leak lR

1126689,72.48150.59

Reviews not Performed for Recent ISFSI Procedure Reviews lR

1112617, Action Level 1 Entered for Unit 2 Reactor Water Influent lR

1080382 ,

DPI-2-10-130A

lndication Lowering with 2 'A' HPSW Pump in Service lR

1139814, 3'B' MPT Gassing Exceeded ACMP Threshold lR

1121101, Outage Services Refueling Equipment Performance IndicatorTurned Red f R 1 1 17854, Dummy Bundle Came In Contact With Bundle ln SFP lR 1 1 15041, Fuel Bundle Came in Contact with CSI Submarine lR

1128280, Reactor Services East Crew Clock Resets lR

1095534, Human Performance

CCA - lsdt and 2no Quarter 2010 lR

1120323, Initiate a Common Cause for Liquid Radwaste Releases lR

1095601, Security PIDS Common Cause Analysis lR

1113275, Energy lntroduced lnto Confined Space during Personnel Entry lR

1113557, Confined Space Used Without Required Rescue Plan lR

1115107, Air Conditioning Hose Removed From 'B' Condenser lR

1154579, ESW Excavation Site 5 Confined Space Deficiencies

lR

1116175, Effectiveness of Confined Space Communication Needs Review lR

1115190, WO Fails to Drive Posting of Confined Space lR Limited Distribution of Safety Information on Confined Space lR 1 1 17655, lndustrial Safety Concern lR

1119860, Clearance Event Challenged and Reclassified

lR

1114045, Condenser Entry Without Signing On Clearance lR

1114077, Follow-up to lR 1

113275 Confined Space Entry lR

1114185, Work Delayed in 'B' Condenser lR

1099140, 8 DPM Leak from 'A' ESW Discharge Check Valve lR

1137854, Pin Hole Leak ldentified on 'A' ESW Supply in Excavation

lR

1138619, Below Minimum Wall Reading on 20 Inch 'A' ESW Supply in Excavation

lR

1139646, Possible Minimum Wall Reading on 20 lnch'A' ESW Supply in Excavation

lR

1141622, Low Wall Reading on 16 lnch 'A' ESW Supply in Excavation

lR

1137763, 'A' ESW Repair Partially Complete Due to Valve Seat Leakage Attachment

lR

1131251 ,

LT-2-70A-060

Has Alarmed lR

1136152,

LT-2-70A-060

Has Alarmed lR

1147495,

LT-2-70A-060

Has Alarmed lR

1152771,

LT-2-70A-060

Has Alarmed lR

1108435,

LT-2-70A-060

tn Alarm lR

1147493,

LT-2-70A-009

Has Alarmed lR

1131246,

LT-2-70A-009

Has Alarmed lR

1108433,

LT-2-70A-009

Has Alarmed lR

1131247,

LT-2-70A-025A

Has Alarmed lR

1147494,

LT-2-70A-025A

Has Alarmed lR

1131250,

LT-2-70A-025C

Has Alarmed lR

1131252,

LT-2-70A-061

Has Alarmed lR

1131255,

LT-2-70A-0268

Has Alarmed lR 1 131 243, lT -2-7 0A-006 Has Alarmed lR

1080603, Submerged Cables Found in Manhole MH076 lR

1076477, Submerged Cables Found in Manhole MH077 lR

1076483, Submerged Cables Found in Manhole MH078 lR

1076511, Submerged Cables Found in Manhole MH079 lR

1076528, Submerged Cables Found in Manhole MH104 lR

1078220, Submerged Cables Found in Manhole MH101 lR

1078240, Submerged Cables Found in Manhole MH100 lR

1076477, Submerged Cables Found in Manhole MH077 lR

1080533, Submerged Cables Found in Manhole MH044 lR

1080613, Submerged Cables Found in Manhole MH082 lR

1080636, Submerged Cables Found in Manhole MH084 lR

1082143, Submerged Cables Found in Manhole MH083 lR

1082151, Submerged Cables Found in Manhole MH075 lR

1082156, Submerged Cables Found in Manhole MH081 lR

1082728, Submerged Cables Found in Manhole MHO19 lR

1140906, Low Battery Voltage Indicated on LT-2-7QA-057

lR

1140910, Low Battery Voltage Indicated on LT-2-70A-041

lR 1

140914, Low Battery Voltage Indicated on LT-2-70A-035

lR 1

140906 ,

LT-2-70A-041

Has Stopped Transmitting

lR

1119949, Manhole 26 - Requires Pumpout lR

1153723, Discrepancy in Calculation

PM-842 lR

1147062, Unit 2 Fuel Pool Rack Boraflex Upgrade Project lR

1147066, Unit 3 Fuel Pool Rack Boraflex Upgrade Project

ER-AA-300-1001, l"tQuarter Program Health Report PBAPS MOV Program, Revision 4

ER-AA-300-1001, 2no Quarter Program Health Report PBAPS MOV Program, Revision 5

ER-AA-300-1001,3'o Quarter Program Health Report PBAPS MOV Program, Revision 5

ER-AA-300, MOV Program Administrative Procedure, Revision 6

ER-AA-302, MOV Program Engineering Procedure, Revision 5

ER-AA-302-1001, MOV Rising Stem MOV Thrust and Torque Sizing and Set-up Window Determination Methodology, Revision 6

ER-AA-302-1003, MOV Margin Analysis and Periodic Verification Test Intervals, Revision 5

ER-AA-302-1004, MOV Performance Trending, Revision 4

ER-M-302-1006,

GL 96-05 Program MOV Maintenance and Testing Guidelines, Revision 9

LS-AA-126-1001, Attachment

FASA Self-Assessment Report Template, Revision 5

MA-AA-723-300, Diagnostic Testing of MOV Valves, Revision 3

MA-AA-723-301, Periodic Inspection of Limitorque Model SMB/SB/SBD-000

through 5 MOV, Revision 6 Attachment

A-16lR827482, U2 HPCI

MO-57 Stroked in Alert Range Then Stopped Moving lR

892191 ,

MA-2-23-058

Stopped In Intermediate Position lR

892191, Assignment

8, Root Cause for MOV Degraded Grease and Performance lssues lR

895626, U3 HPCI Suction Valve Stem Grease Condition lR

895789, U3 HPClTorus Suction

MO-3-23-57, Split Indication

lR

896914, Test Results of Stored Exxon Nebula

EP-1 Grease lR

898030,

MO-3-10-13D

Stem Nut Wear & Underthrust

lR

898645, MOV Stem Lube Activity and PM Frequency Recommendation

lR

899298, Procedure

MA-AA-723-301

Deficiency

lR

901501,

MO-2-10-154B

As-found Test Underthrust

lR

906768,

MO-2-10-015D

Did Not Stroke Open During PMT lR

1097085, Exelon Fleet Wide Actions 'or Nuclear Event Report (NER) NC-10-047Y

lR

1136045, Recommend Evaluation on Handwheel Operation Of Valves NRC lntegrated Inspection Report 0500027712A070A5

and 0500027812007005, Section 4OA2.3: U3 MOV Failure to Stroke Follow-up N RC I nteg rated I nspection Report

05000277 l

2009003 a nd 05000 27 81

2009003 NRC Pl&R Inspection Report 0500027712009008

and 0500027812009008

Work Orders

wo co228400, Mo-2-10-13A, EOC,

41112009 wo co228395,

MO-2-1013C, EOC,

313112009 wo c0228321,

MO-3-1 0-1 3C, EOC,

312912009 wo c022831 9,

MO-3-1 3D,

EOC 3127 12009 WO R0821517,

MO-3-10-18, Perform Motor Operator PM Task, 9/30/2009 WO R0944691,

MO-3-23-19, Motor Operator PM, 10/3/2009 WO

C0228295,

MO-3-23-057, Clean & Lube Valve Stem,

312212009 WO

C0228299,

MO-2-23-058, Clean stem & perform Testing, 3124/2009 wo c0228449,

MO-3-1 0-314, EOC,

41312009 WO R1087541,

MO-3-10-34A, Operator PM,

911012009 WO R1001292,

MO-2-10-89D, Perform Motor Operator PM task,

41912009 wo c0228484,

MO-3-10-154A, EOC,

41412009 wo c0228 438,

MO-2-1 0-1 548, EOC,

41212009 WO R0897679,

MO-2-10-176, Perform Motor Operator PM, 4l14l11 Documents Corrective Action Documents (lRs

1116765,

1117248,1117263,

1117424,

1117625,

1117729, 1 1 1 8001 , 1 1 1 8030, 1 1 1 8281 )Additional

Documents

Memorandum from: Javier Brand to PaulG. Krohn, Peach Bottom Problem ldentification and Resolution Sample lnspection Report Feeder for Inspection Report 050Q027 7 : 05AOA27 I 120 1 0005, dated Decem ber 22, 20 1 0 ( M L 1 03570284)Memorandum to Paul G. Krohn thru John F. Rogge from Jon M. Lilliendahl, Problem ldentification and Resolution Sample Inspection Report Feeder for PBAPS, Units 2 and 3 lntegrated lnspection Report Numbers

05000277 and 0500027812010005, dated January 4, 2011 (ML1 10040342)Work Orders A1

785978 A1777807 c0233693 Attachment

c0234654 lssue Reports

1022206

1027869 1 03901 7

1048012

1073860

1073866

1093747

1129133

1131247

1131250

1131255

1136072

1136152

1140522

1140522

1140906

1140910

1147493

1147494

1147495

1151546

1151671 1152475.1152771 1152789.*ldentified during inspection

Miscellaneous

E-1400, Sheet 34, Manhole Symbols, Notes, and Details, Revision 0

ECR 10-00236, Modification to Electrical Manholes, Revision 0

ER-AA-3003, Cable Condition Monitoring Program, Revision 0 Letter from D. Benyak to NRC, 90-Day Response to

GL 2007-01, dated 517107

Section 4OA3: Follow-up

of Events and Notices of Enforcement Discretion

lR

1125359, Reportability Aspects of NRC URI lnvolving

LTCs Letter from G. L. Stathes (Exelon Generation Company, LLC) to Document Control Desk (U.S. NRC), "Peach Bottom Units 2 and 3, Submittal of ISFSI Cask Event Report," dated October 29, 2010 (M1103050091)

Letter from G. L. Stathes (Exelon Generation Company, LLC) to Document Control Desk (U.S. NRC), "Peach Bottom Units 2 and 3, Submittalof

ISFSI Cask Event Report," dated December 1, 2010 (ML1 10060275)

Section 4OA5: Other Activities

ARs

01098226 01

128059 01 1 36333 001 16949 0091 3307

00982243

01129794 01 1 35657

0095601 7 01

008473 01

038005

00292407

00299897

00373281 001 12308 Condition Reports 01146526.01147978.01147560"

00124059

00124567

00134207

01073744 01

073957

00853737

00259372 00881 328

01138567

00256108 001 99021

00176577

00085201

00769448

00577900

00486926

00377415 01 1 16858 01

030682

00983472

00947038

00852688 0031 5873

01129794

0095601 7

00913307

0096521 I

00966972 01

062638

01093292

00961772 01 0831 65 Attachment

00767650

00773824

00773933

00778595

00779772

00827889

00897894

00968986

00969669

01071092 01071 150

01111101

01117180

01117182

01117213

01134029 01

146505

01146526 *ldentifiedduring inspection Procedures:

SY-AA-1 03-508 Revision 7, "Conducting Background Investigations"

LS-AA-1012

Revision 0, "Safety Culture Monitoring"

HR-M-600 Revision 1, "Corporate

EIAC"

HR-AA-600-0001

Revision 0, "Corporate

EIAC Notification"

HR-AA-600-0002

Revision 0, "Corporate

EIAC Monthly Meeting and Report"

LS-AA-126-1005

Revision 4, "Check In Self Assessment Report"

TQ-AA-223-F070

Revision l,"Document Based Instruction Guide for Supervisor Development Program Instruction Guide - Week 4"

TQ-AA-121

Revision 10," Exelon Supervisor Development Program"

HR-AA-4000

Revision 20, "Employees Entering Exelon Nuclear, Changing Positions Within Exelon Nuclear or Exiting Exelon Nuclear"

ILOT-PLOT

-1525 Revision 6, "Licensee Obligations and Responsibilities"

OP-AA-108-111, Adverse Condition Monitoring and Contingency Plan, Spent Fuel Cask#50 Helium Overpressure System Leakage Monitoring

2P-71-0703-XXC3, COT of ISFSI Low Pressure Switches

PS-70703A

and

PS-70703B

SF-290, Spent Fuel Cask Transport and Unloading Operations

SF-220 Spent Fuel Cask Loading and Transport Operations

SF-490, Radiation Requirement during Spent Fuel Cask Unloading and Transport Operations

SF-61 0,

TN-68 Cask Repressurization

SF-900, ISFSI Abnormal Condition Response SF-g10, Spent FuelCask Leakage Location Determination

RT-H-071-901-2, Revision 1, ISFSI Quarterly Inspection Radiation Survey

RP-M-376-1001, Revision 4, Radiological Posting, Labeling, and Marking Standard

RP-AA-500, Revision 14, Radioactive Material (RAM) Control

RT-H-099-960-2, Revision 7, Outside Radiological Material Storage Area Inspection and Survey

CC-AA-102, Design Input and Configuration Change lmpact Screening, Revision 20

ER-AA-2009, Managing Gas Accumulation, Revision 1

ER-AA-335-007, Ultrasonic lnspection for Determination of Sedimentation in Piping Systems or Components and Fluid Level Measurements, Revision 3

OP-AA-108-106, Equipment Return to Service, Revision 4 Attachment Planning Desktop Guide Insert, "GL 08-01 Requires UT for Air Voids of ECCS Following System FillA/enting," dated November 2008

SO 14.1.A-2, CS System Alignment for Automatic or Manual Operation, Revision 5

SO 14.3.A-2, Manually Venting of the CS Line Vent Accumulator Lines, Revision 2

SO-10.3.A-2, RHR System A Loop Filling and Venting, Revision 18

SO-10.3.8-2, RHR System B Loop Filling and Venting, Revision 18

SO-10.5.A-2, RHR System Piping Flush, Revision 10

SO-23.1.A-2, HPCI System Setup for Automatic or Manual Operation, Revision 18

SO-23.1.A-3, HPCI System Setup for Automatic or Manual Operation, Revision 16

ST-0-010-301-2,'A'RHR

Loop Pump, Valve, Flow, and Unit Cooler Functional and lST, Revision 32

ST-O-010-350-2, RHR Loop A and Cross Tie Valve Position and Filled and Vented Verification, Revision 8

ST-0-010-355-2, RHR Loop B Valve Position and Filled and Vented Verification, Revision 4 Completed Surveillance Test Procedures

ST-O-014-350-2, CS Loop'A'Valve Alignment and Filled and Vented Verification, performed 8/30/10

ST-O-014-350-3, CS Loop 'A'Valve Alignment and Filled and Vented Verification, performed 9t15t10

ST-O-014-355-2, CS Loop 'B'Valve Alignment and Filled and Vented Verification, performed

918110

ST-O-014-355-3, CS Loop 'B'Valve Alignment and Filled and Vented Verification, performed 9t20110

ST-O-023-350-2, HPCI Valve Alignment and Filled and Vented Verification, performed

319110, 417 l 10, 41291 1 0, 6121 10, 7 17 l 10, 8l4l 10, and 9/8/1 0

ST-O-023-350-3, HPCI Valve Alignment and Filled and Vented Verification, performed

24110,

4112110,

5112110,

6115110,7114110,

8111110, and 9/15/10 NRC Enforcement Actions:

EA-08-298

dated January 6, 2009

EA-10-093

and

EA-10-121

dated September

16,2010

EA-09-029

dated July 9, 2009

EA-09-007

and

EA-09-059

dated December 1, 2009 lA-09-023

dated December 1, 2009 fA-09-025

dated December 2,2009 Inspection

Procedures

Used 60855 Operation of an ISFSI Documents

COC 1027, Amendment

0, 1 Radiological Surveys - lFSl Sl-2P-71-0728-XXC3, Revision 0, COT of ISFSI Low Pressure Switches

PS-70728A

and

PS-707288, performed

05126110 Sl-2P-71-0733-XXC3, Revision 0, COT of ISFSI Low Pressure Switches

PS-70733A

and

PS-707338, performed

07106110 Sl-2P-71-0735-XXC3, Revision 0, COT of ISFSI Low Pressure Switches

PS-70735A

and

PS-707358, performed

07106110 Sl-2P-71-0737-XXC3, Revision 0, COT of ISFSI Low Pressure Switches

PS-70737A

and

PS-707378, performed

06/08/10 Attachment

ST-S-071-901-2, Revision 51, ISFSI Cask Interseal Pressure Check, performed

11113110,

11128110, and

12105110

TN-68 TSs and Bases, Section 3.1.5

TN-68 TSs and Bases, Amendment

1, Section 3.1.5 Additional

Documents

Memorandum to Paul Krohn thru Judith A. Joustra from Stephen Hammann and John Nicholson, PBAPS Feeder for Inspection Reports 0500027712010005

and 0500027812010005, dated January 7 , 2011 (ML{ 10070096)Memorandum to Paul Krohn thru Lawrence T. Doerflein from Kevin Mangan, PBAPS Feeder for Tl25151177 - Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal and Containment Spray Systems, lnspection Reports 0500027712010005

and 05000278/2010005

dated January 18,2011 (ML 110190398)

Drawinos Drawing

OTN9.OOKO 161F290, Process Diagram CS System, Revision 0 6280-M-309, Sht. 1, P&lD - Condensate

& Refuel Water Storage and Transfer System, Revision 64 6280-M-361, Sht. 1 and 2, P&lD - RHR System, Revision 81 and 67 6280-M-362, Sht. 1 and 14, P&lD - CS Cooling System, Revision 62 and 3 6280-M-365, Sht. 1, P&lD - HPCI System, Revision 63 6280-M-366, Sht. 1, P&lD - HPCI Pump Turbine Details, Revision 57 ISO DWG 2-10, Shts. 1-9, 11-13, 16,17, 19-23,29,31, and 36, #10 RHR, Revision 8, 7, 6, 5, 5, 2, 1, 1, 9, 11, 5, 5, 5, 6,7,8, 2, 3, 1 1, 5, and 2, respectively

ISO DWG 2-13, Shts. 3-8, 12, and 13, #23 HPCI, Revision 2, 1, 11,2,2, 2, 4 and 5, respectively

f SO DWG 2-14, Shts. 1, 2, and 4-17, #14 CS - Unit 2, Revision 4, 11, 2, 3, 4, 2, 3, 2,3, 10, 3, 5, 3, 8, 4, and 8, respectively Enqineerino Evaluations

GL 2008-01 System Evaluation - PBAPS - CS, dated

9120108

GL 2008-01 System Evaluation - PBAPS - RHR, dated

9120108

GL 2008-01 System Evaluation - PBAPS - HPCI, dated

9120108 Miscellaneous

767650-A24, Gas Accumulations Program Monitoring Frequency, dated

4130109 Exelon letter to NRC, Response to Request for Additional Information Regarding

GL 2008-01, dated

11110109 Exefon letter to NRC, Nine Month Response to

GL 2008-01, dated 1011412008

Exelon letter to NRC, Peach Bottom Supplemental Response to

GL 2008-01, dated

1116109 Gas Accumulation Program

GL 08-01 UT Activity Plan Operability Evaluation

08-007, Revision 1 Peach Bottom Final Safety Analysis Report, Revision 22 Peach Bottom Unit 2 TSs, Revision 278 wo

4177047 Attachment

ACMPS ADAMS ADR ALARA AR CAP ccA CFR coc COC TS cor CRs CS DBD EACE ED EDG EIAC EOC ESW FPP GL GPI HPCI HPSW HRA HX rMc INPO IP IPE IR ISFSI IST LER LTC MOV MPT MR MSIV MSPIs NCV NEI NRC NRR NVLAP ODCM oos A-21

LIST OF ACRONYMS

Adverse Condition

Monitoring

Plans Agency-wide

Documents

Access and Management

System Alternate

Dispute Resolution

As Low As Reasonably

Achievable

Action Request Corrective

Action Program Common Cause Analysis Code of Federal Regulations

Certif i cate-of-Co

m p I ia n ce Certificate-of-Com

pliance Techn ical Specifications

Channel Operational

Test Condition

Reports Core Spray Design Basis Document Equipment

Apparent Cause Evaluation

Electronic

Dosimeter Emergency

Diesel Generator Employee lssues Advisory Council Extent-of-Condition

Emergency

Service Water Fire Protection

Plan Generic Letter Ground Water Protection

Initiative

High Pressure Coolant lnjection High Pressure Service Water High Radiation

Area Heat Exchanger Inspection

Manual Chapter Institute

of Nuclear Power Operation Inspection

Procedure Individual

Plant Examination

lssue Report Independent

Spent Fuel Storage Installation

Inservice

Testing Licensee Event Report Load Tap Changer Motor Operated Valves Main Power Transformer

Maintenance

Rule Main Steam lsolation

Valve Mitigating

Systems Performance

Indicators

Non-cited

Violation Nuclear Energy Institute Nuclear Regulatory

Commission

Nuclear Reactor Regulation

National Voluntary

Laboratory

Accreditation

Program Off-site Dose Calculation

Manual Out-of-Service

OPDRV [[]]

OTDM [[]]

PARS [[]]

PBAPS [[]]

PD [[]]

PI [[]]

PI&R [[]]

PM [[]]

PMT [[]]

PORC [[]]

PROS [[]]

RCA RCtC

RETS [[]]

RFO [[]]

RFP [[]]

RHR [[]]

RTP [[]]

SBO [[]]

SDP [[]]

SFP [[]]

SRV [[]]

SSC [[]]

SSFFS [[]]

ST [[]]

SV [[]]

TE [[]]

TI [[]]

TRM [[]]

TS [[]]

UFSAR [[]]

UT [[]]

VHRA [[]]

WGE [[]]

WO A-22 Operations

with a Potential

to Drain the Reactor Vessel Operational

and Technical

Decision Making Publicly Available

Records Peach Bottom Atomic Power Station Performance

Deficiency

Performance

lndicator Problem ldentification

and Resolution

Preventive

Ma i ntenance Post-Maintenance

Testi ng Plant Operations

Review Committee Professional

Reactor Operator Society Root Cause Analysis Reactor Core lsolation

Cooling Radiological

Effluent Technical

Specification

Refueling

Outage Reactor Feed Pump Residual Heat Removal Rated Thermal Power Station Blackout Significance

Determination

Process Spent Fuel Pool Safety Relief Valve Structures, Systems, and Components

Safety System Functional

Failures Surveillance

Tests Safety Valve Technical

Evaluation

Temporary

Instruction

Technical

Requirements

Manual Technical

Specifications

Updated Final Safety Analysis Report Ultrasonic

Testing Very High Radiation

Area Work Group Evaluation

Work Order Attachment