IR 05000277/2010005: Difference between revisions

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| number = ML110341057
| number = ML110341057
| issue date = 02/03/2011
| issue date = 02/03/2011
| title = 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
| title = 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
| author name = Krohn P G
| author name = Krohn P G
| author affiliation = NRC/RGN-I/DRP/PB4
| author affiliation = NRC/RGN-I/DRP/PB4

Revision as of 09:32, 4 March 2018

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  Constellation icon.png
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

February 3, ZOLLMr. MichaelJ. PacilioSenior Vice President, Exelon Generation Company, LLCPresident and Chief Nuclear Officer, Exelon Nuclear4300 Winfield RoadWarrenville, lL 60555

SUBJECT: PEACH BOTTOM ATOMIC POWER STATION - NRC INTEGRATEDI 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 anintegrated inspection at your Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3.The enclosed integrated inspection report documents the inspection results, which werediscussed 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 andcompliance with the Commission's rules and regulations and with the conditions of your license.The inspectors reviewed selected procedures and records, observed activities, and interviewedpersonnel.Based on the results of this inspection, one finding of significance was identified. This findingwas determined to involve a violation of NRC requirements. However, because of the very lowsafety significance and because the finding has been entered into your correction actionprogram (CAP), the NRC is treating the finding as a non-cited violation (NCV), consistent withSection 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 dateof 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 RegionalAdministrator, Region l; the Director, Otfice of Enforcement, U. S. NRC, Washington, DC20555-0001; and the NRC Senior Resident Inspector at the PBAPS. lf you disagree with thecross-cutting aspect to the finding in this report, you should provide a response within 30 daysof the date of this inspection report, with the basis for your disagreement, to the RegionalAdministrator, Region 1 and the NRC Senior Resident Inspector at PBAPS. The informationyou 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 beavailable electronically for public inspection in the NRC Public Document Room or from thePublicly Available Records (PARS) component of the NRC's document system (ADAMS).ADAMS is accessible from the NRC Website at http://www.nrc.qov/readinq-rm/adams.html(the Public Electronic Reading Room).

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

Enclosure:

Inspection Report 0500027712010005 and 0500027812010005

w/Attachment:

Supplemental Informationcc dencl: Distribution via ListServ M. PacilioIn accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRC's"Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will beavailable electronically for public inspection in the NRC Public Document Room or from thePublicly Available Records (PARS) component of the NRC's document system (ADAMS).ADAMS is accessible from the NRC Website at http://www.nrc.qov/readinq-rm/adams.html(the Public Electronic Reading Room).

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

Enclosure:

lnspection Report 0500027712010005 and 0500027812010005M

Attachment:

Supplemental Informationcc w/encl: Distribution via ListServDistribution 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. DRPA. Rosebrook, DRPS. lbarrola, DRPE. Torres, DRPF. Bower, DRP, SRIA. Ziedonis, DRP, RlS. Schmitt, DRP, OAJ. Trapp, RIOEDORidsNrrPMPeachBoftom ResourceRidsNrrDorlLpl 1 -2ResourceROPreportsResource@nrc.qovSUNSI Review Complete: AAR (Reviewer's Initials)MLI10341057DOC NAM E : G :\DRP\BRANCH4\I NS PECTION REPORTS\PEACH BOTTOM\201 0\4TH QTR INSPECTION\PBIR2O1 O.OOs-REV2.DOCXAfter 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 mmfRUDRPRI/DRPR1/DRPlAMEFBower/MR forARosebrooUMRPKrohn/PGK)ATE0'U 31 t1',l01t31 11102t 02 t11 1U.S. NUCLEAR REGULATORY COMMISSIONREGION IDocket Nos.: 50-277, 50-278License Nos.: DPR-44. DPR-56Report No.: 0500027712010005 and 0500027812010005Licensee: Exelon Generation Company, LLCFacility:Peach Bottom Atomic Power Station. Units 2 and 3Location: Delta, PennsylvaniaDates:October 1, 2014 through December 31, 2010Inspectors: F. Bower, Senior Resident InspectorA. Ziedonis, Resident InspectorJ. Brand, Reactor InspectorS. Hammonds, Senior Health PhysicistJ. Lilliendahl, Reactor InspectorJ. Nicholson, Health PhysicistR. Nimitz, Senior Health PhysicistK. Mangan, Senior Reactor lnspectorA. Rosebrook, Senior Project EngineerApproved by: Paul G. Krohn, ChiefReactor Projects Branch 4Division of Reactor ProjectsEnclosure 2

SUMMARY OF FINDINGS

lR 0500027712010005, 05000278/2010005; 1010112010 - 1213112010; Peach Bottom AtomicPower Station (PBAPS), Units 2 and 3; Surveillance Testing.The report covered a three-month period of inspection by resident inspectors and announcedinspections by a senior health physicist, two NRC region-based Decommissioning Branchinspectors, three regional reactor inspectors, and a region based Senior Project Engineer. Oneinspector- identified finding was identified. The significance of most findings is indicated by theircolor (Green, White, Yellow, or Red) using NRC lnspection Manual Chapter (lMC) 0609,"Significance Determination Process (SDP)." Findings for which the SDP does not apply maybe Green or be assigned a severity level after NRC management review. Cross-cutting aspectsassociated 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 ofcommercial 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 ofST-O-07G-470-3, "Main Steam lsolation Valve (MSIV) Closure Timing," Revision 15,was inadequate to demonstrate satisfactory performance of MSIVs during poweroperations. 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 IMC0612, Appendix E. Specifically, in the absence of further engineering evaluation, therewas reasonable doubt of MSIV operability at power operations, based upon cold stroketime testing results. This finding impacted the Barrier Integrity cornerstone andadversely affected the cornerstone objective of providing reasonable assurance thatphysical design barriers, such as containment, protect the public from radionuclidereleases caused by accidents or plant events. Using IMC 0609, 'SDP," Attachment 4,"Phase 1 - Initial Screening and Characterization of Findings," Table 4a, the inspectorsdetermined that this violation screened to Green (very low safety significance) becausethe finding did not reprdsent an actual open pathway in the physical integrity of reactorcontainment. The inspectors concluded that this finding had a cross-cutting aspect inthe area of Problem ldentification and Resolution (Pl&R), CAP component. Specifically,the licensee did not thoroughly evaluate the test control problems such that theresolution ensured MSIV operability and addressed the cause and extent of condition(EOC). (P.1.c). (Section 1R22)

4

REPORT DETAILS

Summarv of Plant StatusUnit 2 began the inspection period shutdown in its 18th Refueling Outage (RFO) (P2R18). OnOctober 7 , 2010, the reactor was restarted and the unit was synch ronized to the grid onOctober 8,2010. On October 10,2010, the unit was returned to 100 percent rated thermalpower (RTP) where it remained until the end of the inspection period, except for brief periods tosupport planned testing and rod pattern adjustments.Unit 3 began the inspection period at 100 percent RTP. On November 13, power was reducedto approximately 85 percent RTP in response to an increasing trend of dissolved combustiblegases accumulating in the 3 'B' main power transformer (MPT) oil. On November 15,2010, ashutdown from approximately 85 percent RTP was commenced and the main generator breakerwas opened to start the unit's 9tn maintenance outage (3M09)to replace the 3 'B' MPT and the3 'B' safety relief valve (SRV). Operators inserted a planned manual scram from approximatelysix percent RTP to complete the reactor shutdown. On November 19, 2010, the reactor wasrestarted. The unit was synchronized to the grid on November 20, 2010, and returned to 100percent 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. REACTORSAFETYCornerstones: lnitiating Events, Mitigating Systems, and Barrier Integrity1R01 Adverse Weather Protection (71111.01 - 1 System Sample)Preparation for Cold Weather Conditionsa. lnspection ScopeThe inspectors performed a detailed review of PBAPS's and Exelon's written proceduresfor winter readiness and low temperatures to evaluate PBAPS's implementation ofadverse weather preparation and compensatory measures for the affected conditionsprior to the onset of cold weather. The inspectors selected the following structures,systems and components (SSCs)to verify the physical condition of the cold weatherprotection features, and to verify that adequate controls were in place to ensureoperability:o Emergency diesel generator (EDG) and cardox buildings;. Pump structure building;o Emergency service water (ESW) and high pressure service water (HPSW) pumprooms; ando Intake screen structure.The above selection constituted one sample. The inspectors also reviewed adverseweather procedures to ensure they are adequate to maintain readiness of essentialsystems. The inspectors also reviewed CAP items to verify that PBAPS was identifyingadverse weather issues at an appropriate threshold and entering them into their CAP inEnclosure 5accordance with station corrective action procedures. Documents reviewed are listed inthe Attachment.b. FindinqsNo findings were identified.

1R04 Equipment Alionment (71111.04 - 3 Samples)

.1 PartialWalkdown (71111.04Q - 2 Samples)a. Inspection ScopeThe inspectors performed a partial walkdown of two systems to verify the operability ofredundant or diverse trains and components when safety-related equipment wasinoperable. The inspectors performed walkdowns to identify any discrepancies thatcould impact the function of the system and potentially increase risk. The inspectorsreviewed selected operations procedures, walked down system components, andverified that selected breakers, valves, and support equipment were in the correctposition 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 splitindication (Technical Evaluation lR 1 1 18232 - 02); and. Unit 3 reactor core isolation cooling (RCIC) system while the Unit 3 high pressurecoolant injection (HPCI) system was out-of-service (OOS) for planned maintenancethat included replacement of the HPCI pump seals.b. FindinqsNo findings were identified..2 Complete Walkdown (71111.04S - 1 Sample)a. lnspection ScooeThe inspectors performed a complete walkdown of the accessible portions of theelectrical substations and transformers common to Unit 2 and Unit 3, to verify adequatealignment of the offsite power sources as the preferred supply to safety-related on-siteelectrical loads per Technical Specification (TS) 3.8.1, and to verify adequateperformance and material condition of major electrical equipment that could result in aplant transient upon failure. Inspector walkdowns were performed at the north and southsubstations, emergency transformers on-site, vital and non-vital switchgear inside theplant, and the main control room panels. The inspectors reviewed electrical prints andsystem operating procedures to verify that the system alignment was properly translatedinto procedures and drawings. The inspectors discussed electrical system operationwith the plant operators, and discussed electrical system issues and maintenance withthe system engineer.Enclosure 6b. FindinqsNo findings were identified.lR05 Fire Protection (71111.05Q - 4 Samples).1 Fire Protection - Toursa. Inspection ScopeThe inspectors conducted fire protection walkdowns which were focused on availability,accessibility, and the condition of firefighting equipment. The inspectors reviewed areasto 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 materialcondition of passive fire protection features. For the areas inspected, the inspectors alsoverified that PBAPS had followed the Technical Requirements Manual (TRM)and theFPP when compensatory measures were implemented for OOS, degraded or inoperablefire protection equipment, systems, or features. The inspectors verified: that fire hosesand extinguishers were in their designated locations and available for immediate use;that fire detectors and sprinklers were unobstructed; that transient combustible materialswere managed in accordance with plant procedures; and fire doors, dampers, andpenetration seals appeared to be in satisfactory condition. Documents reviewed duringthe 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" (FireZone 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" (FireZones 13A and 138); and. Unit 3 reactor building sump room, elevation 88'-0" (Fire Zone 64).b. FindinqsNo findings were identified.

1R06 lnternal Flood Protection (71111.06 - 1 Sample)a. Inspection ScopeThe inspectors reviewed selected risk-important plant design features intended toprotect the plant and its safety-related equipment from internal flooding events. Theinspectors reviewed a sample of issue reports (lR) in the area of internal floodprotection, to verify adequate margin between any identified sources of water intrusioninto the plant and the plant design and licensing basis, and to verify appropriatecorrective actions. The inspectors reviewed the Updated Final Safety Analysis Report(UFSAR), Design Basis Documents (DBDs), calculations, and design specifications toverify the adequacy of plant flood protection design. The inspectors walked down theUnit 2 and Unit 3 emergency pump structure for internalflooding to evaluate thecondition of penetration seals, watertight doors, and other internal design features toverify that they were as described in the Individual Plant Examination (lPE).Enclosure

7b. FindinqsNo findings were identified.

1R11 Licensed Operator Requalification Proqram (71111.11Q - 1 Sample)Resident Inspector Quarterlv Reviewa. Inspection ScopeOn October 25,2010, the inspectors observed a simulator-based licensed operatorevaluation, during requalification training, to assess licensed operator performance andthe evaluator's post-scenario critique. The inspectors evaluated crew performance inthe 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 ofTSs, event classification, and emergency response actions; ando Group dynamics involved in crew performance.The inspectors verified that any crew performance issues and weaknesses werediscussed in the post-scenario critique. The inspectors also verified simulator physicalfidelity, to ensure that the simulator arrangement closely paralleled the main controlroom. These activities constituted one quarterly licensed operator requalification training' program inspection sample. Documents reviewed during the inspection are listed in theAttachment.b. FindinqsNo findings were identified.1R12 Maintenance Effectiveness (71111.12Q - 2 Samples)a. Inspection ScopeThe inspectors evaluated PBAPS's work practices and follow-up corrective actions forsafety-related SSC's and identified issues to assess the effectiveness of PBAPS'smaintenance activities. The inspectors reviewed the performance history of SSCs andassessed PBAPS's extent of condition (EOC) determinations for those issues withpotential common cause or generic implications to evaluate the adequacy of thePBAPS's corrective actions. The inspectors assessed PBAPS's problem identificationand resolution (Pl&R) actions for these issues to evaluate whether PBAPS hadappropriately monitored, evaluated, and dispositioned the issues in accordance withExelon procedures, including ER-AA-310, "lmplementation of the Maintenance Rule(MR)," and the requirements of 10 CFR 50.65, "Requirements for Monitoring theEffectiveness of Maintenance." ln addition, the inspectors reviewed selected SSCEnclosure

b.

1R13 8classifications, performance criteria and goals, and PBAPS's corrective actions that weretaken or planned, to evaluate whether the actions were reasonable and appropriate.Documents reviewed during the inspection are listed in the Attachment. The inspectorsperformed 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).FindinosNo findings were identified.Maintenance Risk Assessments and Emeroent Work Control (71111.13 - 3 Samples)a. lnspection ScopeThe inspectors evaluated PBAPS's implementation of the Maintenance Risk Programwith respect to the effectiveness of risk assessments performed for maintenanceactivities that were conducted on SSC's. The inspectors also verified that PBAPSmanaged the risk in accordance with 10 CFR Part 50.65(a)(4) and procedureWC-AA-101, "On-line Work Control Process." The inspectors evaluated whether PBAPShad taken the necessary steps to plan and control emergent work activities and tomanage overall plant risk. The inspectors selectively reviewed PBAPS's use of theonline risk monitoring software and daily work schedules. The activities selected werebased on plant maintenance schedules and systems that contributed to risk. Documentsreviewed during the inspection are listed in the Attachment. The inspectors completedthree evaluations of maintenance activities on the following:o Planning and control of emergent work in response to low inter-seal pressure alarmson independent spent fuel storage installation (lSFSl) Cask #1, during ISFSI Cask 50low 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); ando 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. FindinosNo findings were identified.1R15 Operabilitv Evaluations (71111.15 - 5 Samples)a. Inspection ScopeThe inspectors reviewed five issues to assess the technical adequacy of the operabilityevaluations, the use and control of compensatory measures, and compliance with thelicensing 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 wereperformed in accordance with the applicable administrative procedures and wereEnclosure

9consistent with NRC guidance. Specifically, the inspectors referenced procedureOP-AA-108-115, "Operability Determinations," and NRC IMC Part 9900, "OperabilityDeterminations & Functionality Assessments for Resolutions of Degraded orNonconforming Conditions Adverse to Quality or Safety." The inspectors also used TSs,TRM, UFSAR, and associated DBDs as references during these reviews. Documentsreviewed are listed in the Attachment. The following degraded equipment issues werereviewed: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. FindinqsNo findings were identified.

1R19 Post-Maintenance Testino (71111.19 - 6 Samples)a. Inspection ScopeThe inspectors reviewed completed test records or observed selected PMT activities.The inspectors verified whether the tests were performed in accordance with theapproved procedures or instructions and assessed the adequacy of the testmethodology based on the scope of maintenance work performed. In addition, theinspectors assessed the test acceptance criteria to evaluate whether the testdemonstrated that components satisfied the applicable design and licensing bases andthe TS requirements. The inspectors reviewed the recorded test data to verify that theacceptance criteria were satisfied. Documents reviewed during the inspection are listedin the Attachment. The inspectors reviewed six PMTs performed in conjunction with thefollowing maintenance activities:o Integrated leak testing of ISFSI Cask #1, following transportation from the ISFSI drycask storage facility to the Unit 2 refuelfloor (work order (WO) C0235207-A1);r Y-distribution panel 20Y050 Breaker #15 closure (operational risk activity) followingreplacement to support in-plant wireless radio upgrade project (WO C0233481-31);. 3 'C' HPSW pump test after pump replacement to correct low margin conditions (WOR1135041);o Battery charger 28D003-1 capability test, following maintenance and troubleshootingof 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);ando Stroke time testing of MO-0-48-0502A following in-body inspection and cleaning (WOc0236060-01).Enclosure

10b. FindinosNo 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 ScopeThe Unit 2 RFO (P2R18) was conducted from September 12, 2010 throughOctober 8,2010. During this inspection period, the inspectors performed the activitieslisted below to verify PBAPS's controls over outage activities:o Refueling Activities - verified that PBAPS was using adequate controls to ensure thelocation of the fuel assemblies were properly tracked and verified that procedures forforeign material control and retrieval were implemented on the refueling floor;. Core Verification - independently reviewed selected portions of other core verificationactivities;o Torus Closure - conducted a thorough walkdown of accessible torus areas above thesuppression pool prior to reactor startup to verify that all debris, tools, and divinggear were removed;r Drywell Closure - conducted a thorough inspection and walkdown of containmentprior 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 andone main steam safety valve (SV) failed to lift within the TS required pressure rangeof their normal setpoint and this condition was documented in the CAP (lR 1120516);. Startup Preparations - reviewed the tracking of startup prerequisites and observedselected Plant Operations Review Committee (PORC) meetings where outstandingoutage issues and startup reviews were discussed;. Startup and Ascension to Full Power Operation - observed selected activitiesincluding: criticality; portions of the plant heat-up, main generator synchronization tothe grid; portions of the power ascension to full power operation; andr Licensee ldentification and Resolution of Problems - reviewed corrective actionreports related to RFO and startup activities to verify that PBAPS was identifyingissues at the appropriate level and taking adequate corrective action.Documents reviewed are listed in the Attachment.FindinqsNo findings were identified.Peach Bottom Unit 3 Maintenance Outaqe (1 Sample)Inspection ScopePBAPS conducted a maintenance outage on Unit 3 from November 15 throughNovember 20, to replace the 3 'B' MPT and the 'B' SRV. During the outage, theinspectors reviewed the station's work schedule and outage risk management activities.b..2a.Enclosure 11The risk management activities were reviewed to confirm that PBAPS had appropriatelyconsidered risk, industry experience, and previous site specific problems in developingand implementing a plan that maintained shutdown safety defense-in-depth. During theoutage, the inspectors observed portions of the shutdown, cool down, and start upprocesses and monitored the activities listed below to verify PBAPS controls over theoutage 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, includingstabilizing 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 withthe 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 activitiesto 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 thegrid.b. FindinqsNo 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, andcompared test data with established acceptance criteria to verify the systemsdemonstrated the capability of performing the intended safety functions. The inspectorsalso verified that the systems and components maintained operational readiness, metapplicable 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 LowPressure 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

12b. FindinqsIntroductiQn: 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 demonstratesatisfactory performance of MSIVs during power operations.Description: The inspectors observed that acceptance criteria in ST-O-07G-470-3required light-to-light fast-closure stroke times greater than or equal to 3.0 seconds, andswitch-to-light fast-closure stroke times less than or equal to 5.0 seconds. Light-to-lightfast-closure stroke timing measures the amount of time it takes for the position indicationlights to change state. For MSIV closure, this is the time it takes between the close, orupper, 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 operatoractuating the closure switch until the open, or lower, position light extinguishes. Theinspectors 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 usingeither the light-to-light or switch{o-light measurement method. ST-O-07G-470-3 isperformed to satisfyTS Surveillance Requirement (SR) 3.6.1.3.9, which requires MSIVclosure 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 wasmeasured at2.9 seconds, and 'C' inboard (AO-3-02-80C) fast-closure time wasmeasured at2.8 seconds. Alleight MSIVs'closure times were measured at less than3.6 seconds. The test was performed in cold shutdown conditions (MODE 4) during amaintenance outage.On November 17,2010, Technical Evaluation (TE) 1140706-42 was completed toaddress the Unit 3 40-3-02-864 and AO-3-02-80C MSIVs'fast-closure stroke timesbeing outside of the TS acceptance criteria. The TE calculated the differences in stroketime between limit switch activation and full valve stroke, based upon fieldmeasurements taken during the previous RFO. Measurements of the stem lengthbetween the upper and lower limit switch position (i.e., close and open positionindication) and full valve travelwere obtained. Using these lengths and assuming aconstant stroke speed, the light-to-light stroke time was extrapolated to determine theactual closure time for the full length of the stem travel for'both the A0-3-02-86A andAO-3-02-80C MSlVs. TE 1140706-02 concluded that the actual fast-closure full-stroketimes for the A0-3-02-86A and AO-3-02-80C MSIVs were 3.49 seconds and 3.48seconds, respectively. Consequently, work orders (WOs) were generated to adjust thestroke times for these two MSlVs. After in-field adjustments, the as-left light-to-lightstroke time for the AO-3-02-80C MSIV was 3.0 seconds, but the 40-3-02-864 MSIVlight-to-light stroke time was left at 2.94 seconds to ensure the switch-to-light stroke timeremained less than 5 seconds (as-left was 4.8 seconds). lt was noted that no lR or WOswere generated to adjust the stroke times for the remaining 6 MSIVs with fast-closurestroke 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 13On November 19, a second TE, 1 140706-05, was completed to support the as-leftcondition of the A0-3-02-86A MSIV (2.94 second lightto-light stroke time). PeachBottom incorporated correction factors into the TE, in response to NRC inspectorquestions, to account for the differences between MSIV closure-related effects duringpower operations versus cold testing conditions of the MSlVs. This TE cited relevantexternal Operating Experience (Limerick and Hatch) and used appropriate correctionfactors that account for the dynamic effects of steam flow on the valve closure duringpower operation and oil dashpot viscosity changes with temperature (cold shutdownversus power operation). Both of these correction factors would increase the valvestroke speed during operations in Modes 1, 2 and 3. The inspector found the TEacceptable for MSIV operability purposes; however, the TE did not adequately addressthe PBAPS's failure to appropriately evaluate an out of specification test result withoutprompting by the inspector.The inspectors identified an additional deficiency associated with ST-O-07G-470-3 andTEs 1140706-02 and 1140706-05. The TEs used the limit switch positionmeasurements to extrapolate the light-to-light timing and extend the valve stroke forcomparison to the minimum acceptable TS limit (3 seconds). This extrapolation usedfield measurements of stem travel from initial valve movement to the upper (closed) limitswitch activation, combined with stem travel from lower (open) limit switch de-activationto full valve closure. However, neither the TE nor ST-O-07G-470-3 used an extrapolatedfull stroke time for comparison to the maximum acceptable TS limit (5.0 seconds). Theextrapolation did not account for the impact of stem travel outside of the stroke timemeasured by switch{o-light stroke time. Specifically, the measurement of stem travelfrom the lower (open) limit switch de-activation to full valve closure was not combinedwith the switch-to-light stroke time. Therefore, the inspectors determined that PBAPS'sapplication of the full stroke extrapolation method based on limit switch fieldmeasurements was not applied consistently in the TEs, and was unaccounted for insT-o-07G-47Q-3.Analvsis: The inspectors determined that PBAPS's inadequate resolution of as-foundMSIV closure times and inconsistent test measurement and evaluation methodology perST-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 notapply because this issue did not have any actual safety consequences or potentialforimpacting the NRC's regulatory function and was not the result of any willful violation ofNRC requirements or PBAPS procedures. This violation of 10 CFR Part 50 was morethan 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 reasonabledoubt of MSIV operability at power operations, based upon cold stroke time testingresults. This test control PD impacted the Barrier lntegrity cornerstone and adverselyaffected the cornerstone objective of providing reasonable assurance that physicaldesign barriers, such as containment, protect the public from radionuclide releasescaused by accidents or plant events. Using IMC 0609, "SDP," Attachment 4, "Phase 't -f nitial Screening and Characterization of Findings," Table 4a, the inspectors determinedthat this violation screened to Green (very low safety significance) because the findingdid not represent an actual open pathway in the physical integrity of reactor containment.Enclosure 2.14The inspectors concluded that this finding had a cross-cutting aspect in the area ofPl&R, CAP - Evaluation of ldentified Problems. PBAPS did not thoroughly evaluateproblems such that the resolutions address causes and extent of conditions, asnecessary. This includes properly classifying, prioritizing, and evaluating for operabilityand reportability conditions adverse to quality. PBAPS failed to evaluate the abovenoted test control problems such that the resolution ensured MSIV operability andaddressed the cause and EOC. Specifically, TEs 1140706-02 and 1140706-05 did notadequately evaluate out of specification test results without prompting by the inspector.Additionally, an equipment apparent cause evaluation (964717-05) did not adequatelyevaluate and resolve similar MSIV test control problems raised by NRC inspectors in2009 (P.1.c).Enforcement: 10 CFR 50, Appendix B, Criterion Xl, "Test Control," states, in part, thattesting required to demonstrate that systems and components will perform satisfactorilyin service is performed in accordance with written test procedures which incorporate therequirements and acceptance limits contained in applicable design documents. Contraryto the above, between November 15 and 19, 201Q, PBAPS did not identify thatprocedure ST-O-07G-470-3, "MSIV Closure Timing," Revision 15, contained acceptancecriteria that were inadequate to demonstrate that the MSIVs would satisfactorily isolatewithin 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 accountfor the differences between cold testing conditions and power operations, and did notaccount for the impact of measuring isolation times using the full stroke extrapolationmethod for switch-to-light stroke timing. In addition, PBAPS failed to perform MSIVsurveillance 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 thisfinding was of very low safety significance (Green), and has been entered into the CAPvia lRs 1140706 and 1141888, this violation is being treated as an NCV, consistent withSection 2.3.2 of the NRC Enforcement Policy. (NCV 05000277, 27812010005-01,Inadequate MSIV Test Control)RADIATION SAFEWCornerstone: Occupational Radiation Safety (OS)Access Control to Radiolooicallv Siqnificant Areas (71124.01- 1 Sample)Insoection ScopeThe inspectors reviewed selected activities, and associated documentation, in the belowlisted areas. The evaluation of Exelon's performance was against criteria contained in10 CFR 20, applicable TSs, and applicable station procedures.lnspection PlanninoThe inspectors reviewed Performance Indicators (Pls) for the Occupational Exposurecornerstone.RSOlEnclosure 15Radioloqical Hazard AssessmentThe inspectors conducted walkdowns of the facility, including the dry-active wastecollection location, the low-level waste storage facility, and associated yard area, toevaluate material and radiological conditions. The inspectors made independentradiation measurements to verify conditions.Instructions to WorkersThe inspectors selectively reviewed occurrences where a worker's electronic dosimeternoticeably malfunctioned or alarmed to verify appropriate worker response and inclusionof issues in the CAP, as applicable. The inspectors evaluated licensee dose evaluationsas applicable for the occurrences.Contamination and Radioactive Material ControlThe inspectors observed locations where the licensee monitors potentially contaminatedmaterial leaving the radiological controlled area, and inspected the methods used forcontrol, survey, and release from these areas. The inspectors selectively evaluated theradiation monitoring instrumentation sensitivity for the type(s) of radiation present.Radioloqical Hazards Control and Work CoveraqeThe inspectors toured the facility and evaluated ambient radiological conditions (e.9.,radiation levels or potential radiation levels),The inspectors conducted selective inspection of posting and physical controls for HighRadiation Areas (HRAs) and Very High Radiation Areas (VHMs), to the extentnecessary to verify conformance with the Occupational Pl.Rad iation Worker PerformanceThe inspectors selectively reviewed radiological problem reports since the last inspectionto identify human performance errors and determine if there were any observablepatterns. The inspectors discussed corrective actions for identified concerns withlicensee personnel.Radiation Protection Technician ProficiencvThe inspectors selectively reviewed outage radiological problem reports to identify thosethat indicate the cause of the event to be radiation protection technician error and toevaluate the corrective action approach taken by the licensee to resolve the reportedproblems.PI&RThe inspectors determined if problems associated with radiation monitoring andexposure control were being identified by the licensee at an appropriate threshold andwere properly addressed for resolution in the licensee CAP. The inspectors discussedcorrective actions for identified concerns. (See Section 4OA2)Enclosure b.16FindinosNo findings were identified.OccupationalAs Low As Reasonablv Achievable (ALARA) Planninq and Controls(71124.02)Inspection ScopeInspection PlanninqThe inspectors selectively reviewed pertinent information regarding plant collectiveexposure history, current exposure trends, and ongoing or planned activities in order toassess current performance and exposure challenges.Radiolooical Work PlanninqThe inspectors selectively compared accrued results achieved (dose rate reductions,person-rem used), as available, with the intended dose established in the licensee'sALARA planning for selected work activities including person-hour estimates. Theinspectors focused on work activities with an accrued dose of five person-rem. Theinspectors determined, as applicable and where analyses were completed at the time ofthe inspection, the reasons for inconsistencies between intended and actualwork activitydoses.The inspectors determined if post-job (work activity) reviews were conducted and ifidentified problems were entered into the CAP.Source Term Reduction and ControlThe inspectors discussed source term mitigation effectiveness with licensee staffassociated with the Unit 2 outage.PI&RThe inspectors determined if problems associated with ALARA planning and controlswere being identified by the licensee at an appropriate threshold and were properlyaddressed for resolution in the licensee's CAP. The inspectors discussed correctiveactions for identified ALARA concerns. (See Section 4OA2)FindinqsNo findings were identified.RSO2b.Enclosure a.17RS03 ln-Plant Airborne Radioactivitv Control and Mitioation (71124.03)RSO4lnspection Scopelnspection PlanninqThe inspectors reviewed the reported Pls to identify any related to unintended doseresulting from intakes of radioactive materials.PI&RThe inspectors reviewed and discussed problems associated with the control andmitigation of in-plant airborne radioactivity to evaluate the licensee's identification andresolution of issues in the CAP. (See Section 4OA2)FindinqsNo findings were identified.Occupational Dose Assessment (7 1 124.04)Inspection Scopqlnspection PlanninqThe inspectors selectively reviewed licensee procedures associated with dosimetryoperations. The inspectors evaluated procedure guidance for personnel monitoring.External DosimetrvThe inspectors evaluated the use of the licensee's personnel dosimeters that requireprocessing 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 itsthermoluminescent dosimeter for situations when the ED must be used to assign dose.lnternal DosimetrvThe inspectors selectively reviewed routine bioassay (in vivo) procedures and wholebody count results used to assess dose from potentially internally deposited nuclidesusing whole body counting equipment.Special Dosimetric SituationsThe 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 forexternal dose in situations in which non-uniform fields are expected or large doseb.a.Enclosure b.18gradients (i.e., use of multi-badging or determination of effective dose equivalent forexternal exposures using an NRC approved method).Shallow Dose EquivalentThe inspectors selectively reviewed personnel contamination instances to evaluatefrequency, causes, and dose assessment, as appropriate. The inspectors alsodiscussed identification and logging of personnel contamination occurrences during theUnit 2 outage, including actions taken to identify and limit personnel contaminationevents.PI&RThe inspectors selectively reviewed corrective action documents to verify that problemsassociated with occupational dose assessment were being identified by the licensee atan appropriate threshold and were properly addressed for resolution in the licenseeCAP. (See Section

4OA2 )FindinosNo findings were identified.Radiation Monitorinq lnstrumentation (7 1122.05)Inspection ScopePI&RThe inspectors selectively reviewed corrective action documents associated withradiation monitoring instrumentation to determine if the licensee identified issues at anappropriate threshold and placed the issues in the CAP for resolution. In addition, theinspectors evaluated the appropriateness of the corrective actions for a selected sampleof problems documented by the licensee that involve radiation monitoringinstrumentation. (See Section 4OA2)FindinqgNo findings were identified.Cornerstone: Public Radiation Safety (PS)Radioactive Gaseous and Liquid Effluent Treatment

Insoection ScopgGround Water Protection Initiative (GPl) lmplementationThe inspectors selectively reviewed implementation of the ground water monitoringprogram. The inspectors reviewed monitoring results of the GPI to determine if thelicensee has implemented its program as intended and to identify any anomalous ormissed results and to determine if the licensee has identified and addressed deficienciesthrough its CAP.RSO5RSO6b.a.Enclosure 19PI&RThe inspectors verified that problems associated with the effluent monitoring and controlprogram were being identified by the licensee at an appropriate threshold and wereproperly addressed for resolution in the CAP. (See Section 4OA2)b. FindinqsNo 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 ScopeThe inspectors reviewed a selected sample of PBAPS's information submitted for thefive Mitigating Systems Pls listed below to assess the accuracy and completeness of thedata reported to the NRC for these Pls. The Pl definitions and the guidance contained inNuclear Energy lnstitute (NEl) 99-02, "Regulatory Assessment Indicator Guideline,"Revision 6, and Exelon procedure LS-AA-2200, "Mitigating System Performance IndexData Acquisition and Reporting," Revision 3, were used to verify that procedure andreporting requirements were met. The inspectors reviewed raw Pl data collected fromOctober 2009 through September 2010 and compared graphical representations fromthe 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 eventreports (LERs), CAP records, equipment clearances, and MR data to verify the Pl datawas appropriately captured for inclusion into the Pl report and that the individual Plswere 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. FindinosNo findings were identified..2 Review of Safetv Svstem Functional Failures (SSFFS) Pls (71151- 2 Samples)a. Inspection ScopeThe 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 October2009 through October 2010. The Pl definitions and the guidance contained in NEI99-02, "Regulatory Assessment Indicator Guideline," Revision 6, and Exelon procedureEnclosure b.20LS-M-2080, "Monthly Data Elements for NRC SSFFs," Revision 4, were used to verifythat procedure and reporting requirements were met.The inspectors reviewed LERs issued during the referenced timeframe for SSFFS. Thedocuments reviewed are listed in the Attachment. The inspectors also comparedgraphical representations from the most recent Pl report to the raw data to verify that thedata was correctly reflected in the report.FindinosNo findings were identified.Occupational Exposure Control Effectiveness (71151- 1 Sample)Cornerstone: Public Radiation SafetyInspection ScopeThe implementation of the Occupational Exposure Control Effectiveness Pl Program(OR01) was reviewed. The inspectors selectively reviewed CAP records foroccurrences involving HRA, VHRA, and unplanned personnel radiation exposures sincethe last inspection in this area. The review was against the applicable criteria specifiedin NEI 99-02, "Regulatory Assessment Indicator Guideline," Revision 6. The purpose ofthis review was to verify that occurrences that met NEI criteria were recognized andidentified as Pls.FindinosNo findings were identified.Radioloqical Effluents Technical Specification (RETS) /Off-site Dose Calculation Manual(ODCM) Radioloqical Effluent Occurrences (71151- 1 Sample)Inspection ScopeThe implementation of the RETS/ODCM Pl (PR01)was reviewed. The inspectorsselectively reviewed CAP records and projected monthly and quarterly dose assessmentresults due to radioactive liquid and gaseous effluent releases; for the past four completequarters. The review was against the applicable criteria specified in NEI 99-02,"Regulatory Assessment Indicator Guideline," Revision 6. The purpose of this reviewwas to verify that occurrences that met NEI criteria were recognized and identified asPls.As part of this review, the inspectors also reviewed Exelon's evaluations and public doseassessments associated with identification of localized ground water contaminationwithin the restricted area.FindinosNo findings were identified..3a.b.a..4b.Enclosure 4c.42.1a.21ldentification and Resolution of Problems (Pl&R) (71152 - 3 Samples)Review of ltems Entered into the CAPInspection ScopeAs required by Inspection Procedure (lP) 71152, "ldentification and Resolution ofProblems," and in order to help identify repetitive equipment failures or specific humanperformance issues for follow-up, the inspectors performed screening of all itemsentered into the licensee's CAP. This was accomplished by reviewing the description ofeach new action request (AR) / lR and attending daily management review committeemeetings.FindinqsNo findings were identified.Semi-Annual Review to ldentifv Trends (1 Semi-annual Resident Inspector Sample)Inspection ScopeThe inspectors reviewed lists of CAP items to identify trends (either NRC or licenseeidentified) that might indicate the existence of a safety issue. First, the inspectorsreviewed a list of approximately 7,700 lRs that PBAPS initiated and entered into theCAP 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 remainedopen with outstanding actions. The list was reviewed and screened to complete therequired semi-annual Pl&R trend review. Based on the review, a sample of 68 PassportlRs (listed in Attachment 1) were selected for a more detailed review to verify whetherthe issues were adequately identified and evaluated, and that corrective actions wereplanned. The inspectors evaluated the lRs against the requirements of Exelonprocedure, LS-AA-125, and 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action."Findinqs and ObservationsNo findings were identified. During this trend review period, the inspectors noted twosignificant events involving overpressure gas (helium) leaking from ISFSI CasksNumbers 1 (lR 1 126689) and 50 (lR 1 129931). A root cause analysis (RCA) for casknumber 1 (lR 1 131123) was in progress at the end of the inspection period. SeeSections 4OA3.1, 4OA3.2 and 4OA5.3 of this report for additional discussion. Alsoduring this period, PBAPS performed a RCA for the Unit 2 reactor water chemistryreaching action level 1 as a result of a HPSW to RHR leak within the 2 'C' RHR HeatExchanger (HX) (lR 1112617, lR 1080382). The inspectors concluded that theperformance 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 combustiblegases in the 3'B' MPT that required a plant shutdown and replacement during amaintenance outage (lR1 139814) was the result of operating the MPT 12 to 17 yearsb.a..2Enclosure

.322 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 trendassessment period that included: the refueling equipment performance indicator turningred (lR 1121101); a dummy fuel bundle coming in contact with a bundle in the spent fuelpool (SFP) (lR 11 17854); and a fuel bundle coming in contact with an in-vesselinspection submarine (lR 1115A41). PBAPS appropriately initiated a common causeanalysis (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 threeadditional trends. The first involved an adverse trend of human performance events inthe first and second quarter si2010 (1R1095534). The second involved liquid radwastereleases exceeding established station goals (lR 1120323). The third involved asignificant recurring trend of issues associated with the perimeter intrusion detectionsystem (lR 1095601). The inspectors noted additional adverse trends related to thefollowing 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 intomanholes 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 issuesinto the CAP, adequately evaluating the identified issues, and acceptably identifyingadverse trends before they became more safety significant problems. Each of thesetrends 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 afinding of more than minor significance at this time.Annual Sample: Motor Operated Valve (MOV) Effectiveness of Corrective Actions forHardened Grease Challenoes (1 Annual Sample)lnspection ScopeThis 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 mProcedures were lnadequate with Regard to Periodicity of Preventing MaintenanceActivities for Stem Lubrication).The inspectors reviewed Exelon's corrective actions reports, a sample of diagnostic andstroke time test data, and interviewed plant personnel to evaluate the adequacy ofExelon's corrective actions. Finally, the inspectors reviewed MOV program proceduresto evaluate the quality and effectiveness of the Exelon MOV program, as implemented atPBAPS. Documents reviewed are listed in the Attachment.Enclosure

b.23Findinqs and ObservationsNo findings were identified. MOV failures caused by grease hardening have been achaflenge 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 openposition during their ST. Investigation by Exelon identified hardened grease on the stemand inside the stem nut, as well as stem nut wear. Initial EOC evaluations also revealedthat two RHR valves developed less-than-required closing thrust for successfuldiagnostic test acceptance (MO-3-10-13D and MO-2-'10-1548). Hardened grease wasalso 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) wasidentified on valve MO-3-10-13D (lR-898030). The final EOC scoping determined that45 safety-related MOVs required additional evaluation appropriate to the circumstances,such as visual inspection, grease evaluation, diagnostic testing, and/or correctivemaintenance. The root cause evaluation performed by Exelon under lR-892191 ,determined that Peach Bottom MOV preventive maintenance (PM) frequencies andactions had not appropriately included stem lubricant performance feedback. lnaddition, the root cause evaluation identified that Exelon had the longest allowable MOVPM lubrication intervals in the entire nuclear fleet (up to 10 years).The inspectors concluded that Exelon has taken timely and appropriate actions asdelineated in the root cause evaluation to address the grease hardening challenges.The corrective actions, including PM reviews and implementation frequencyadjustments, 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 andExelon's Management Review Committee, system engineers and MOV programexperts, and the independent oversight group have demonstrated appropriateengagement and safety focus through the process (the initial corrective action lRassignment, root cause review, action tracking, EOC reviews, and effectiveness reviews)to improve the reliability of safety-related MOVs and prevent or minimize reoccurrence ofgrease hardening issues.Annual Sample: Review of Corrective Actions for Submerqed Cables (1 Annual Sample)Inspection ScopeThe inspectors performed a focused review of the corrective actions regardingsubmerged cables. The issues with submerged cables at Peach Bottom weredocumented in two findings, 05000277,27812009005-01 and 05000277,27812009005-02. The inspectors interviewed the knowledgeable design engineer tounderstand the history of the submerged cable issues at Peach Bottom and to assessExelon's evaluation and corrective actions. The inspectors observed inspection andmaintenance activities to assess the material condition of the cable manholes and toevaluate the adequacy of maintenance. The inspectors reviewed WOs and test resultsto verify that testing and maintenance are being performed in accordance with vendorinstructions and industry standards. The inspectors also reviewed lRs to verify theadequacy of corrective actions. Documents reviewed for this inspection activity arelisted in the Attachment..4a.Enclosure b.24Findinqs and ObservationsNo findings were identified. The inspectors determined that the PBAPS is adequatelyevaluating, trending, and correcting issues related to submerged cables. The inspectorsreviewed a detailed apparent cause evaluation for the submerged cables issues. Theinspectors noted that Peach Bottom's initial corrective actions included performing cabletesting on a sample of cables to provide baseline data for future testing and performinginitial manhole inspections to verify the adequacy of conditions in the manholes. Theinspectors noted that Peach Bottom's ongoing corrective actions include periodicinspections of manholes, installing water level detectors in manholes, and moreextensive cable testing. The inspectors determined that Peach Bottom is takingadequate corrective actions to maintain their cables in accordance with their designbasis and industry guidance.The inspectors observed one instance of failing to document a condition adverse toquality in an lR. As part of Exelon's corrective actions, water level detectors wereinstalled in manholes at Peach Bottom to ensure that cables did not remain submergedfor extended periods of time. Since the installation of manhole water level alarms inAugust 2010, the responsibility for monitoring the alarms rested on a single designengineer. On October 27,2010, several lRs were written documenting that high waterlevel alarms had been received for five manholes. The lRs correctly stated that themanholes must be pumped within three weeks based on industry guidance; but at thetime the lRs were written, cables in the manholes had already been submerged for overthree weeks. A corrective action was added to an existing lR to transfer alarmmonitoring responsibility to operations, but the failure to drain the manholes within thetime limit was not documented in an lR. Consequently, there was no interim correctiveaction to ensure that alarms were not missed again.The failure to document the missed time requirement was based upon reliance on aprevious operability evaluation (Op Eval 10-002). During this inspection, an lR waswritten to document this issue (1152475) which will implement a more rigorous interimalarm monitoring program until the program is fully transferred to operations. The lRalso 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 determinedthat the failure was an isolated incident and operability was not in doubt. Using IMC0612 Appendix B, "lssue Screening" and Appendix E, "Examples of Minor lssues," theinspectors determined this issue was of minor significance.Occupational Radiation Safetv Proqram and Effluent and Environmental MonitorinqProqram (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 ScopeThe inspectors selectively reviewed corrective action documents for OccupationalRadiation Safety Program and Effluent and Environmental Monitoring Program. SeeAttachment for a list of documents reviewed.The review was against criteria contained in 10 CFR 20, TSs, ODCM, and applicablestation audit and surveillance procedures..5a.Enclosure b,25FindinqsNo findings were identified.Follow-up of Events and Notices of Enforcement Discretion (71 153 - 1 Sample)Event Notice #46353: ISFSI Cask TN-50-AInspection ScopeOn October 22,2010, PBAPS personnel informed the inspectors that an eventnotification 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 amaterial 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 ofISFSI Cask TN-50-A indicated that a leak existed in the cask lid sealing area at a leakrate 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 inUNLOADING OPERATIONS and was located within the PBAPS Unit 3 containmentbuilding. PBAPS's preliminary review indicated that a leak existed at the sealweldedplug that provided sealing of the drilled interseal passageway associated with the drainport penetration of the cask lid. This leak effectively provides a bypass of the main lidouter confinement seal.FindinosNo findings were identified and a review of this issue by region based ISFSI specialistinspectors is documented in report section 4OA5.3.Event Notice #46373: ISFSI Cask TN-68-01 (1 Sample)Inspection ScopeOn October 27,2Q10, PBAPS personnel informed the inspectors that an eventnotification 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 areduction in the effectiveness of an ISFSI cask confinement system.Event Notice #46373 reported that on 10127110, at 1 107, troubleshooting of ISFSI CaskTN-68-01 identified that a helium leak exists in the cask lid sealing area at a leak rategreater than allowed by ISFSI Cask TS Section 3.1.3, "Cask Helium Leak Rate." TS3.1.3 limits the Cask Helium Leak Rate to 1.0 E-05 ref-cc/sec. The cask was inLOADING OPERATIONS and was located within the PBAPS Unit 2 containmentbuilding. PBAPS's preliminary review indicated that a leak existed in the Cask Main LidOuter Closure Seal. ISFSI cask TN-68-01 was subsequently unloaded into the Unit 2spent fuel pool on November 20,2010.40A3,1a.b..2Enclosure b.26FindinqsNo findings were identified and a review of this issue by region based ISFSI specialistinspectors will be documented in NRC lR 0500027712010010.(Closed) LER 05000277//2010004-00. lmproper Credit for Function of Off-site PowerSource Transformer Load Tap Chanqer (LTC) (1 Sample)Based on information provided by the NRC as part of their closeout of a Task InterfaceAgreement associated with an NRC unresolved item, the plant management staffdetermined that certain plant equipment could be degraded as a result of lower voltagesthat may exist during a postulated design basis loss-of-coolant event coupled withcertain degraded voltage conditions. Although the safety significance of this event isconsidered 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 takenfor 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 mostof the TS impacted equipment have been performed. Other compensatory measureshave been put in place to assure operability of other components until other designupgrades can be completed. The enforcement aspects of this issue were documentedin 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 bythe degraded grid relay setpoints to determine the operability of safety-relatedcomponents.The inspectors reviewed the LER and did not identify any additional violations ofregulatory requirements. Therefore, this LER is closed.Other Activities(Closed) Confirmatorv Order EA-09-007 and EA-09-059 Follow Up Inspection(92702 - 1 Sample)BackgroundOn December 1, 2009, the NRC issued the Exelon Generating Company, LLC, aConfirmatory Order for EA-09-007 and EA-09-059, which confirmed commitments madeto the NRC made as part of a settlement agreement between the NRC and Exelon usingthe NRC's Alternative Dispute Resolution Program (ADR). This order can be found inthe NRC's document system (ADAMS) as Accession Number ML093350150. This orderconfirmed the following commitments:A. Complete the following actions by June 30,201A, and send the NRC a letterinforming the agency that the actions are complete within 30 days of theircompletion:.340A5,1Enclosure a.27a. Review special obligations of licensed operators and supervisors in PeachBottom licensed operator training program, including Peach Bottom operatingexperience.b. Develop an assessment to verify the effectiveness of actions associated withdeliberate misconduct training.c. Perform Peach Bottom Site Employee lssues Advisory Council (EIAC) reviewsregarding employee conduct issues/concerns, including any apparent trends inthese areas; and ensure corporate EIAC emphasizes comparison of site data toidentify trends or outliers.d. Repeat Peach Bottom training module on deliberate misconduct for newemployees and current Peach Bottom personnel in 2010, emphasizing theimpact of deliberate misconduct on nuclear safety culture.B. Complete the following actions by September 30, 2010, and send the NRC a letterinforming the agency that the actions are complete within 30 days of theircompletion:a. lnclude deliberate misconduct training in the fleet-wide Supervisory DevelopmentProgram for new supervisors.b. lmplement Peach Bottom training module fleet-wide, emphasizing the impact ofdeliberate misconduct on nuclear safety culture. Exelon will also review itscurrent contractor training on deliberate misconduct and add the training module,if necessary.c. Provide additional information fleet-wide, to educate the workforce on BehaviorObservation Program, Fitness-for-Duty requirements, and Employee AssistanceProgram 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 inclusionin its industry newsletter.f. Discuss with Institute of Nuclear Power Operations (INPO) the possibility ofincorporating into its supervisor and operations development programs, a moduleregarding the significance and impact of deliberate misconduct.Inspection ScopeIn order to independently verify that Exelon's commitments had been met, in accordancewith NRC lP 92702, the inspectors conducted a review of CAP records and evaluations,training materials and records, appropriate Exelon procedures, site and corporate EIACmeeting minutes, interviewed appropriate plant staff, and reviewed Exelon's docketedletters informing the NRC of completion of the PBAPS specific commitments dated July23,2010 (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 asguidance, whether Exelon's actions to evaluate a potential adverse trend of deliberatemisconduct exists at PBAPS, evaluate Exelon's corrective actions to address thispotential trend, and to monitor for such a trend going fonruard. Documents reviewed andpersonnel contacted are listed in the attachment.Enclosure b.28Findinqs and ObservationsNo findings were identified. Based upon the inspection activities described above, theinspectors determined that PBAPS and Exelon have satisfied the obligations of theDecember 1, 2009 Confirmatory Order described in Sections V. A and V. B. Exelondeveloped and conducted training at both the station and fleet levels, performed site andcorporate EIAC reviews to identify and monitor any potential trends at both PBAPS andother Exelon sites, and submitted articles for consideration to PROS, INPO, and NEI forconsideration for inclusion in industry publications and training modules.PBAPS conducted a CCA of nine deliberate misconduct events which had occurred atPBAPS between 2005 and 2008. The inspectors reviewed PBAPS's CCA, its findingsand 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. Thedeliberate acts were spread among the Operations, Maintenance, and SecurityDepartments and involved both temporary and permanent plant staff. The majority ofthe 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 crewwas involved. PBAPS management and Exelon began taking corrective actions in the2007 timeframe, to specifically address a number of these issues and those actions didappear to be effective as the number of events has dropped significantly. Thus, basedon these actions and the additional training and actions which were taken as a result ofthe Confirmatory Order, the inspectors concluded that there is currently no adverse trendof deliberate misconduct at PBAPS. However, there is evidence to suggest that therewas such a trend in the 2007 timeframe, but Exelon did appear to identify this issue andtake appropriate corrective actions.The inspectors also reviewed EIAC records and check-in-self assessments conducted tomonitor the effectiveness of the training and monitor for future trends. The inspectorsdetermined that these reviews were thorough and probing, employed appropriatetechniques to develop conclusions, and the conclusions were reasonable and supportedby the data.fn summary, the inspectors determined that Exelon has satisfied the commitments setout 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 inEmerqencv Core Coolinq. Decav Heat Removal and Containment Sprav Svstemslnspection ScopeThe inspectors performed the inspection in accordance with Tl25151177, "ManagingGas Accumulation in Emergency Core Cooling, Decay Heat Removal and ContainmentSpray Systems." The NRC staff developed Tl 25151177 to support the NRC'sconfirmatory review of licensee responses to NRC Generic Letter (GL) 2008-01,"Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal andContainment Spray Systems." The Office of Nuclear Reactor Regulation (NRR).2a.Enclosure 29reviewed Exelon's GL 2008-01 response and based on this review, the NRR staffprovided guidance on a Tl inspection scope to the regional inspectors. The inspectorsused this inspection guidance along with the Tl to verify that Exelon implemented or wasin the process of acceptably implementing the commitments, modifications, andprogrammatically controlled actions described in their GL 2008-01 response. Theinspectors verified that the plant-specific information (including licensing basisdocuments and design information) was consistent with the information that Exelonsubmitted in their GL 2008-01 response.The inspectors reviewed a sample of isometric drawings and piping and instrumentationdiagrams, and conducted selected system piping walkdowns to verify that Exelon'sdrawings reflected the subject system configurations and UFSAR descriptions.Specifically, the inspectors verified the following related to a sample of isometricdrawings 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 totheir potential for gas buildup;. Other areas where gas could accumulate and potentially impact subject systemoperability, such as orifices in horizontal pipes, isolated branch lines, HXs,improperly sloped piping, and under closed valves, were acceptably evaluated inengineering reviews or had ultrasonic testing (UT) points which would reasonablydetect 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 theacceptability of the drawings Exelon used during their review of GL 2008-01. Theinspectors verified that Exelon conducted walkdowns of the applicable systems toconfirm that the combination of system orientation, vents, instructions and procedures,and testing, would ensure that each system was sufficiently full of water to assureoperability. The inspectors reviewed Exelon's methodology used to determine systempiping high points, identification of negative sloped piping, and calculations of void sizesbased on UT equipment readings, to ensure the methods were reasonable.The inspectors observed a field UT measurement in the CS system discharge piping toassess the adequacy of the monitoring techniques used to ensure system operability.The inspectors also verified that Exelon identified and evaluated all systems within thescope of the GL.The inspectors reviewed a sample of Exelon's procedures used for filling and venting theidentified GL 2008-01 systems to verify that the procedures were effective in venting orreducing void sizing to acceptable levels. The inspectors verified that Exelon'ssurveillance frequencies were consistent with the PBAPS TSs and associated bases,and the UFSAR. The inspectors reviewed a sample of system venting surveillanceresults to ensure proper implementation of the surveillance program and that theexistence of unacceptable gas accumulation was evaluated within the CAP, asnecessary.The inspectors reviewed CAP documents to verify that selected actions described inExelon's nine-month and supplemental response submittals were acceptablyEnclosure b.30documented, including completed actions and implementation schedules for incompleteactions, and to verify that NRC commitments were included the CAP. Additionally, theinspectors reviewed evaluations and corrective actions for issues Exelon identifiedduring their GL 2008-01 review. The inspectors performed this review to ensure Exelonappropriately identified and corrected gas voiding issues. Documents reviewed arelisted in the Attachment.FindinqsNo findings were identified. The inspectors identified a discrepancy between Exelon'sGL response and existing plant procedures regarding the techniques used to maintainthe systems full of water. The inspectors reviewed the plant procedures to verify theiradequacy and discussed the issue with NRR. The inspectors determined the issue wasminor because it did not impact operability or impede the regulatory process. Exelonamended their GL response (ML103490536) to correct the discrepancy. This completesthe inspection requirements for Tl 25151177 .ISFSI Cask #50 Leakino Helium (60855 - 1 Sample)BackqroundCask #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 padin May 2010. The casks on the ISFSI pad are continuously monitored for heliumpressure. On September 4, 2010, an alarm was received indicating low helium pressurefor Cask #50. On September 5,2010, the helium over pressure system was measuredto be 40 psig and was then recharged to 75 psig. On September 9, 2010, the cask wastransported to the refuelfloor of Unit 3. PBAPS initiated a monitoring plan to record andchart the helium pressure within the cask on a daily basis. The monitoring programrevealed the cask continued to slowly leak helium. PBAPS began troubleshooting onOctober 17 , 2010, and used procedure SF-910, "Spent Fuel Cask Leakage LocationDetermination," to identify the source of the helium leak as the lid seal weld onOctober 22,2010. PBAPS reported the identified helium leak to the NRC OperationsCenter as required by 10 CFR72.75. The lid sealweld is performed during the caskmanufacturing stage: therefore, it is considered a manufacturing defect. PBAPS isworking with the cask manufacturer to prepare and execute a repair plan. PBAPSestimates the repair plan approval and subsequent repair work will take place in the firstcalendar quarter of 2411.Inspection ScooeThe inspectors were on-site October 13, 201Q, to review the licensee's actions, theirprojected path fonvard, and to verify PBAPS was in compliance with the CoC TechnicalSpecifications (CoC TS). The CoC TS 3.1.5, requires the cask interseal pressure to beat least 3.0 atm (approximately 29.4 psig) and the CoC TS 3.1.4, requires the heliumleak rate for the overpressure system to be less than 1.0 E-5 ref-cc/second. PBAPS hassuccessfully kept the interseal pressure above the required limit by continuouslymonitoring the pressure and recharging it as necessary. The helium leak rate for theoverpressure system did not meet the CoC TS requirement. The CoC TS states that ifthe helium leak rate for the overpressure system is greater than the limit the cask must.3a.Enclosure b.31be returned to the spent fuel unloading facility within 30 days. PBAPS complied with thisrequirement 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.FindinqsNo findings were identified.rsFsr - (60855.1)Inspection ScopeThe inspectors selectively reviewed routine operational surveillance dala, includingradiological surveillance, for the ISFSI facility. The inspectors toured the facility andmade independent radiation measurements of the facility. The data was evaluatedagainst 10 CFR Part 20 and applicable Exelon procedures.FindinqsNo findings were identified.Meetinqs. lncludinq ExitQuarterlv Resident Exit Meetinq SummarvOn January 21,2011, the resident inspectors presented the inspection results toMr. Thomas Dougherty and other PBAPS staff, who acknowledged the findings.Mr. P. Krohn, Chief, USNRC, Region 1, Division of Reactor Projects, Branch 4, attendedthis quarterly inspection exit meeting. The inspectors asked the licensee whether any ofthe information discussed as being included in the report should be consideredproprietary. No proprietary information was identified.Manaqement Meetinos.4a.40A6.1b.,2The inspection results for the inspection of ISFSI Cask #50 Leaking Helium werediscussed with Mr. Garey Stathes, Plant Manager, and other members of the PBAPSstaff via teleconference on January 5, 2011.The inspection results for the inspection of Public and Occupational PerformanceIndicators, Ground Water Protection Program, and Unit 2 and Unit 3 OccupationalRadiological Controls were discussed with members of Exelon Nuclear management onDecember 17,2010 and January 11,2011.The inspection results for the inspection of Tl 25151177 - Managing Gas Accumulationin Emergency Core Cooling, Decay Heat Removaland Containment Spray Systemswere discussed with Mr. Thomas Dougherty, Site Vice President, and other members ofthe 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

OpenedNoneOoened/Closed0500027 7 &27 I I 20 1 0 00 s-0 1Closed05a00277t2010004-00NCVLERInadequate MSIV Test Control(Section 1R22)lmproper Credit for Function of Off-sitePower Source Transformer LTC(Section 4OA3.3)Attachment

A-2

Discussed

050002 77& 27 8 l 2009003-0 10500027 7 &27 81 2009005-0 10 50 002 7 7 & 27 I l 200900 5-02NCVMOV Program Procedures were Inadequatewith Regard to Periodicity of PreventingMaintenance Activities for Stem Lubrication(Section 4OA2.3)Continuously Submerged Cables DesignDeficiency (Section 4OA2.4)Failure to Follow Procedures and lmplementthe Exelon Nuclear Cable ConditionMonitoring Prog ram for Non-Safety-RelatedControl and Power Cables Within TheScope of the Maintenance Rule(Section 4OA2.4)Failure to Ensure Adequate Voltage wasAvailable to Safety-Related Equipment(Section 4OA3.3)NCV0500027 7, 27 I l 20 10004-03NCV

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adversp Weather ProtectionPeach Bottom Certification Letter for Winter Readiness, dated November 30, 2010WC-AA-107, Revision 9, Seasonal ReadinessMA-PB-1003, Revision 7, Winter Readiness and Storm Response Guidelines for the PeachBottom FacilityAO 29.2, Revision 16, Discharge Canal lntake Pond Cross-Tie Gate Operation and Frazil lceMitigationOP-AA-108-111-1001, Revision 5, Severe Weather and Natural Disaster GuidelinesOP-PB-108-1 1

1-1001 , Revision 4, Preparation for Severe WeatherSO 48.4.A, Revision 4, Draining ESW and HPSWReturn Lines to Emergency Cooling Tower for Winter Freeze ProtectioneSOMS Suite Operator Rounds: Operator Daily Outside RoundslR
1046286, 2009 and 2010 Winter Execution Critique Action ltemslR 1
036865, 2010-2011 Winter Readiness Tracking AssignmentslR
1078404,2010 and 2011 AR for Site Winter Readiness Actions - PEART-l-066-200-2, Revision 8, Heat Trace System Testing, completed 08/30/10RT-O-040-620-2, Revision 15, Outbuilding HVAC and Outer Screen Inspection forWinter Operation, completed 1 1 l 18109RT-O-040-630-2, Revision 1 2, Winterizing Procedure, completed 1 1 l 1 ElOglR
1089563, B5B Pump Engine Heater TrippedlR
1150920, Tear in the B.5.8 Hose Trailer CoverlR 1
129696, Insulation Missing on Aux Steam LineslR
1129402, Cover for AC Unit in Station Blackout (SBO) Building BrokenlR 1
130635, North and South Outer Screen Structure Doors Need WinterizinglR 1
132962, Door at Outer Screen Structure Won't Close, Frame lnterferencelR
1136575, TIC Indicates LowlR
1137753, The Heaters Will Get Hot but the Fan Will Not RunFINAttachment
A-3lR
1142081, Engineering Evaluation Needed to Support 50.59 ScreeninglR
1149072, Per
AO 29.2 Evaluate Intake Pond Crosstie Gate OperationlR 1
150258 ,2'B' Trash Pit Sump Pump Water Found in OillR
1138684, zSU Switchgear Building Louvers Will Not CloselR
1138703, Fan 0CV070 Backdraft Damper Failed OpenlR
1139283, Steam Heater Fan Not RunninglR
1139285, Heater Not OperatinglR
1139300, Heater Failed to Start with Thermostat at MaxlR1128372,0DE139 Fan Failed to StartlR
1128375, 0GE139 Fan Failed to StartlR
1129361, 0CV066 Fan Backdraft Dampers Did Not CloselR
1129362, 0DV066 Fan Backdraft Dampers Did Not CloselR
1129365,U2and U3 Circ Water Pump Structure Intake Louvers are StucklR
1129379, 'A' Cooling Tower Pump House Unit Heater Control StationfR
1129400, Louvers #3 and #4 on West Wall Not Able to be MovedlR
1129404, Dampers Failed to CloselR
1129406, Fan Damper Failed to Close

Section 1R04: Equipment AlionmentAO 10.4-2, Revision 21,

RHR System - Fuel Pool to Reactor ModelR
1118232,2'A' RHR Loop Check
AO-2-10-0464 No lndication in Main Control RoomlR
1122003,
AO-2-10-0464 Fails to Indicate ClosedlR
1122426,
AO-2-10-0464, No Acoustic lmpact Event RecordedlR
1123044, A0-2-10-046A Failed to Indicate Closed, Follow-up lR 1118232SO 13.1.A-3. COL, Revision 4, RCIC SystemPeach Bottom Single Line Diagram, North Substation, South Substation, Terminal YardE-1, Sheet 1, Revision 47, Station Single Line DiagramE-5343, Revision 16, SBO Substation Single LinelR
1105699, SBO Test Line Breaker Will Trip lf Close 21,22,23 or 24 BreakerlR 1131 456,#l Transformer'B' Sudden Pressure Relay Sensor Oil Tap lsolation Valve Oil LeakLicensed 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 PlantSO 53.1 .A-2 COL, Revision 0, 13 kV Electrical SystemSO 53.1.A-3 COL, Revision 1, 13 kV Electrical SystemSO 53.7.4, Appendix 7, Revision 1, Removal of 343SU Transformer 00X01 1 from ServiceSO 54.1.A COL, Revision 1, 4160 Volt Emergency Auxiliary SwitchgearTS 3.8.1 and BasesUFSAR, Revision 19, Figure 8.3.1UFSAR, Revision 14, Figure 8.3.2UFSAR, Revision 22, Section 8.4UPFSAR, Revision 21,Table 8.4.1

==Section 1R05: Fire ProtectionlR 1124534. Fire in 2 'B' Reactor Feed Pump (RFP) LagginglR

1124571, Critique ol2'B'==
RFP Turbine FireOP-AA-201-002, Revision 4, Attachment 1: Fire Event Report 10-6, dated 10110110PF-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 WaterAttachment
A-4Room, Elevation 1 16'-0"PF-134&38, Revision 2, Unit 3 Reactor Building 3'B'and 3'D'CS Room, Elevationg1'-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 PumpStructure Specification
NE-075, Revision 4, Penetration Seals in Hazard Barriers atPeach Bottom and LimerickA/R A1167100, Outside Fire System Leakage through Penetrations in Pump StructureA/R A1249047, Outside Fire System Leakage through Penetrations in Pump StructureA/R A1777591, Water Leaking from Load Center E224-P-A Safety ConcernDBD P-T-09, Revision 9, Internal Hazards Topical Design Basis DocumentECR 01-01116, Clarify Design Basis for Pump Structure Internal FloodinglR
1120123, Ground Water Intrusion into E224-P-A MCClR
1120156, Ground Water Intrusion into E224-P-A MCClR 1 1201 56, Ground Water Intrusion into E124-P-A MCClR
1120916, ldentify Source of Leaks ldentified by lssue 1120123lR
1120923, ldentify Source of Leaks by lssue 1120123lR
1131243,
LT-2-70A-006 Has AlarmedlR
1131246,
LT-2-7OA-009 Has AlarmedlR
1131247,
LT-2-7OA-025A Has AlarmedlR 113'1250,
LT-2-70A-025C Has AlarmedlR 1 131 251,
LT-2-7 0A-060 Has AlarmedlR
1131252,
LT-2-70A-061 Has AlarmedlR
1131255, Manhole 0268 Has AlarmedlR
1139453,2CP342 RHR Floor Drain Sump Does Not Work Correctly in AutolR
1119887, Rain Water at Junction Box of Motor Driven Fire Pump ControlslR
1119848, Water Leaking from Load Center E224-P-A Safety ConcernlR
1120123, Ground Water Intrusion into E224-P-A Motor Control CenterSection 1R1 1: Licensed Operator Requalification ProoramPSEG-1107R, Revision 2: "Out-of-the-Box" (OTB) Evaluation Scenario, performed 10125110TQ-M-150, Revision 4, Operator Training ProgramsEP-M-1007, Revision 19, Radiological Emergency Planning Annex for PBAPSAT-102, Revision 7, Reactor High PressureT-100, Revision 11, ScramT-101, Revision 19, Reactor Pressure Vessel: Power, Level and Pressure ControlT-103, Revision 16, Secondary ContainmentT-112, Revision 16, Emergency Blowdown

Section 1R12: Maintenance EffectivenessER-M-5400, Buried Piping and Raw Water Corrosion Program (BPRWCP) GuideER-AA-5400-1001, Raw Water Corosion Program GuideER-AA-5400-1002, Buried Piping Examination GuideER-M-5400-1 003,

BPRWCP Performance IndicatorslR
1019963, High Risk Piping Requires Inspection and Mitigation ActionlR
1019949, Buried Piping lnspections Yield Moderate Area of InterestlR
1019952, Buried Piping Inspection Yields SubstantialArea of InterestlR
1019955, Buried Piping Inspection Yields Moderate Area of lnterestlR
1019958, Buried Piping lnspection Yields Moderate Area of InterestlR
1022452, Buried Piping Initiative Excavation Location OneAttachment
A-5lR1022453, Buried Piping Initiative Excavation Location TwolR
1022456, Buried Piping Initiative Excavation Location ThreelR
1022458, Buried Piping Initiative Excavation Location FourlR
1022463, Buried Piping Initiative Excavation Location FivelR
1022464, Buried Piping Initiative Excavation Location SixlR
1022620, Buried Piping G-Wave Inspection Scope for P2R18lR
1022622,2010 Above Ground Accessible Guided Wave InspectionlR
1039055, Raw Water Chemistry Strategy Not OptimizedlR
1039797,2A10 LTAM Strategy For Buried Pipe & Raw WaterlR
1067943, Evaluate Vendor Recommendations for Raw Water SystemslR
1103126, ESW Corrosion Control EnhancementslR
1116429, 2R18 Radwaste Discharge Piping G-Wave ResultslR1128228, P3R18 Buried Piping Initiative G-Wave Inspections137854, Pinhole Leak ldentified on 'A' ESW Supply in Excavation
2138619, Below Minimum Wall Reading on 20 lnch'A'ESW Supply in Excavation139646, Possible Min Wall Reading on2O Inch'A'ESW Supply in ExcavationlR
1141622, Low Wall Reading on 16 Inch 'A' ESW Supply in Excavation 4lR
1148136, Piping Repair Required on a 16 lnch 'A' ESW in Cardox RoomlR 1
148140, Piping Repair Required on a 2Q lnch 'A' ESW in Cardox RoomlR
1148745, Linear Indication Discovered on 20 Inch 'A' ESWf R
1149298, Linear lndication Discovered on 20Inch 'A' ESW Pipef R
1149753, Piping Repair Required on 20Inch 'A' ESW in Pump StructurelR
1148776, Unit 3 ESW Admiralty Corrosion Rate Exceeds TargetlR
1148774, Unit 2 ESW Admiralty Corrosion Rate Exceeds TargetlR
1153112, Evaluate 'A' and 'B' ESW Piping Corrosionf R
1152937, Coating Degradation in Excavation 2IRIRIRlR 1
154783 , 2Q11
GL 89-13 Piping Inspection ScopelR
1154787 , 2011
GL 89-13 Piping Inspection ScopelR 1
154798 ,2011
GL 89-13 Piping lnspection ScopelR 1
154807 , 2011
GL 89-13 Piping Inspection ScopelR 1 15481 1, 2011
GL 89-13 Piping Inspection ScopelR 1
154813, 2011
GL 89-13 Piping lnspection ScopelR 1 15481 9, 2011
GL 89-13 Piping Inspection ScopelR 1
154823 , 2011
GL 89-13 Piping Inspection ScopelR 1
154830 , 2011
GL 89-13 Piping lnspection ScopelR
1154833,2011
GL 89-13 Piping Inspection ScopelR
1154842,2011
GL 89-13 Piping lnspection ScopelR 1
154845 ,2011
GL 89-13 Piping Inspection ScopelR 1
154847 , 2011
GL 89-13 Piping Inspection Scopeso-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 InterestAR A1745528, Buried Piping Inspection Yields Substantial Area of InterestAR A1745527, Buried Piping Inspection Yields Moderate Area of InterestAR A1745526, Buried Piping lnspection Yields Moderate Area of InterestAR A1744933, Buried Piping Initiative Excavation Location OneAR
41744932, Buried Piping Initiative Excavation Location TwoAR
41744931, Buried Piping Initiative Excavation Location ThreeAR A1744930, Buried Piping Initiative Excavation Location FourAR A1744929, Buried Piping Initiative Excavation Location FiveAR A1744903, Buried Piping G-Wave lnspection Scope for P2R18AR A1744927,2010 Above Ground Accessible Guided Wave InspectionAR
41776553, 2R18 Radwaste Discharge Piping G-Wave ResultslR
1151546, MR Screening System 70A for Manhole Water MonitoringAttachment
A-6lR 1 15371 1, lmprove Reliability of Manhole Water Monitoring SystemlR
1152475, Cable Program lnvestigationlR
1152771,
LT-2-70A-060 Has AlarmedlR 1 1 52789,
LT-2-70A-0268 Position Requires Investigation

Section 1R13: Maintenance Risk Assessments and Emerqent Work ControlSF-900, Revision 7,

ISFSI Abnormal Conditions ResponselR
1127274, Unit 2 Reactor Building Crane Would Not Raise With a LoadlR
1127245, Does Cask #601 and #650 Work Need
CC-AA-112 (TCCP) Review?lR
1127018, Buried Piping Excavation Delays Due to ISFSI MovementlR
1109955, ISFSI Alarm Received for Cask #501R1125128, ISFSI Cask#42 False AlarmslR
1126789, lssue Written to Create a New A/R for Work PlanninglR
1126968, Spent Fuel Casks #48 to #52 Not Licensed as Dual PurposelR 1
126691, Performance Trending of Cask OP Pressure Monitoring LTA.lR 1
126689,72.48150.59 Reviews Not Performed for Recent ISFSI Procedure RevisionslR
1126353, NOS lD: No Limit for the Number of Re-Pressure of ISFSI CasklR
1128307, ISFSI Cask #1 - Foreign Substance on Cask & PadlR
1128724, ISFSI Cask #01 (Protective Cover)lR
1130349, Bolting on Cask #1 Weather Cover Rusted Beyond Use50.59 Applicability Review Form for
SF-290 Revision 6, dated 1011511050.59 Screening
PB-2010-71-S,
SF-290, Revision 6, Spent Fuel Cask Loading and StorageOperations72.48 Screening Form, Revision 6 of
SF-290, dated 10115110A/R 41744932-04. Walkdown and Specify Excavation Restriction for ISFSI CasksSA-AA-1 17, Revision 12, Excavation, Trenching, and ShoringRT-O-001-4Q0-2,Individual Full Closure of Main Turbine Stop Valves, performed 12120110lR
1154167, U2 Main Turbine Stop Valve #3 Failed to Stroke During TestinglR
1154331, Relay XK80 Needs ReplacedLicensed Operator Training, System 1 'B' - Main TurbineTSs Sections 3.3.1.1 and BasesTSs Sections 3.3.2.2 and BasesTSs Sections 3.3.4.2 and BasesUnified Control Room Log, Saturday December 18, 2010, Night ShiftUnified Control Room Log, Sunday December 19, 2010, Day ShiftUnified Control Room Log, Sunday December 19,2010, Night ShiftlR
1157318, 3'C' HPSW Pump Failed PMT* - lndicates NRC ldentifiedSection 1 R1 5: Ooerabilitv EvaluationsSimplified Troubleshooting/Repair Guide for
TN-68-50A Cask Apparent LeakageAR
41773748,lSFSl Alarm Received for Cask #50WO M1773748, Repair Cause of ISFSI Alarm for Cask #50WO
C0235207, Troubleshoot and Recover Cask #50 to PadWO
C0234633, Repair Cause of ISFSI Alarm for Cask #50lR
1126689,72.48 / 50.59 Reviews Not Performed for Recent ISFSI Procedure RevisionslR
1126691, Performance Trending of Cask Overpressure Monitoring LTAlR
1126968, Spent Fuel Casks #48 to #53 not Licensed as Dual-PurposelR
1127245, Does Casks #601 and #650 Work Need
CC-AA-112 (TCCP) ReviewAttachment
A-7lR
1127757, Pages of Calculation 349-T-VC-9 Are MissinglR
1129931, ISFSI Cask #50 Helium LeaklR
1145858, ISFSI TS Does Not Provide GuidancelR
1145752, 50.59 Review Needed for ISFSI Cask #50lR
1145528, Downward Trend in Cask #50 PressurelR
1147581, Recommend Evaluating ISFSI Helium Leak Test MethodlR
1151642, ProceduralApproval Form 50.59172.48 Checkbox UsagelR
1136859, Unit 3 'B' MPT - 3Bx001lR
1139189, 3 'B' MPT ACMP Threshold Exceeded for TDCG R.O.C. > 100 PPM/DaylR
1139482, 3 'B' MPT ACMP Threshold Exceeded for TDCG R.O.C. > 150 PPM/DaylR
1139814, 3'B' MPT Gassing Exceeded ACMP ThresholdlR
1140382, Bushing Test ResultslR
1069325, Better Pedigree Needed for OPDRV 1.5" Opening ThresholdlR
985243-03, Initiative to Consider CRD Exchange as Not an OPDRVlR
967045, Revision to TRM Section 1.1lR
865411, Evaluate Making CRD Exchange a non-OPDRV EvolutionlR
495940, Engineering Evaluation Requested to Support CRD Flange De-TorquelR
378310, CRD Exchange Delayed - OPDRV During De-TorquinglR377754, Procedure/CCTS Coordination lssue Resulted in 20 Minute DelayFH-6C, Core Component Movement - Core TransfersGP-6, Refueling OperationsGP-26, Coordination of HCU, CRB, CRD, DGB, and PIP Work during a
RFOM-C-747-01 1, Control Rod Drive Exchange Using NES MachineLetter 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," datedAugust 3,2010Letter from F. A. Kearney (Exelon Generation Company, LLC) to Document ControlDesk (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 andDPR-56 for PBAPS Unit Numbers 2 and 3," dated March 26, 1980 (Adams AccessionNumbers
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 (PBAPSUnits 2 and 3) - Revision to Definition of OPDRV to Allow a Single CRD Change50.59 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 theReactor Vessel, PBAPS Units 2 and 3, dated December 29, 1995, (Approved in PORCMeeting 96-01, January 1, 1995)Clearance
10002101, ESW Discharge Piping 'A' Header RepairECR 10-00443, Repair of ESW Piping at Sites 1 & 2Operability Evaluation 10-008, under lR
1137854-02, Pin Hole Leak ldentified on 'A' ESWSupply in Excavation 2OP-AA-1 08-1 1 5, Revision 9, Operability DeterminationsER-AA-330-009, Revision 5, ASME Section Xl Repair/Replacement ProgramA/R
41783258, Pin Hole Leak ldentified on 'A' ESW Supply in Excavation 2ASME Boiler and Pressure Vessel Code, Section Xl, 2001 Edition, July 1, 2003 AddendalR 1
137854, Pin Hole Leak ldentified on 'A' ESW Supply in Excavation 2lR
1138619, Below Min Wall Reading on 2O-inch 'A' ESW Supply in Excavation 1lR
1148136, Piping Repair Required on 16"'A' ESW in Cardox RoomlR
1148745, Linear Indication Discovered on 2O-inch 'A' ESWAttachment
A-8lR
1148774, ESW Admiralty Corrosion Rate Exceeds TargetlR
1148776, U3 ESW Admiralty Corrosion Rate Exceeds TargetlR
1148784, Service Water Admiralty Corrosion Rate Exceeds Targetf R 1
149753, Piping Repair Required on 20" 'A' ESW in Pump Structure41744929-03 and 13, Buried Piping Initiative Excavation Location Five41744930-03 and 13, Buried Piping lnitiative Excavation Location Four41744932-03 and 13, Buried Piping Initiative Excavation Location Two41744933-03 and 13, Buried Piping Initiative Excavation Location OnePBAPS UFSAR, Revision 22, Appendix C - Structural Design CriteriaSA-AA-1 17, Revision 1, Soil Type Classification

==Section 1R19: Post-Maintenance TestinqSF-250, Revision 6, Varian 979-70 Helium Leak Detector Operations and Calibration, performed10t18t10SF-220, Revision 24, Spent Fuel Cask Loading and Transport OperationsSF-900, Revision 7, lSFSlAbnormal Conditions ResponselR 1

126691, Performance Trending of Cask==
OP Pressure Monitoring LTA.f R
1126689,72.48150.59 Reviews Not Performed for Recent ISFSI Procedure RevisionslR
1126353, NOS lD: No Limit for the Number of Re-Pressure of ISFSI CasklR
1128095, ISFSI Cask
TN-68-01 OP System Low Pressure - Learnings / ActionslR
1128997, ISFSI Fuel Cask 00T701 Helium Leakage - EOClR
1129931, ISFSI Cask #50 Helium LeakNRC Event Report #46353, Peach Bottom Spent Fuel Storage Related Defect, dated 1012211050.59 Applicability Review Form for
SF-290 Revision 6, dated 1011511050.59 Screening
PB-2010-71-S,
SF-290, Revision 6, Spent Fuel Cask Loading and StorageOperations72.48 Screening Form, Revision 6 of
SF-290, dated 10115110WO
C0235207,Troubleshoot and Recover Cask to PadECR 10-00162, Peach Bottom Radio Refresh ProjectWO
C0233481-31, Peach Bottom Radio Refresh Project WalkdownslR
1130888, 20Y050 Breaker #15 Will Not RecloseON-112, Revision 10, Loss of Uninterruptible AC PowerlR
1144389, 3 'C' HPSW Pump Performance Differed From ExpectedlR
1143572, Unable to Hook UP Flow Box to Obtain Proper ReadingST-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 ISTAR A1785091, 3 'C' HPSW Pump Performance Differed From ExpectedWO R1135041, HPSW PVF Functional ISTlR
1151049, HPSW PV&F Not Completed In Accordance with the PlanlR
1151050, HPSW PV&F (Partial IST) Not Completed IAW PlanlR
1157318, 3'C' HPSW Pump Failed PMTA/R A1782741, Received 2'B' Battery Charger Trouble AlarmDrawing
NE-102-4, Sheet 1, Revision 2, Cyberex Model 130/200R3-S Battery Charger PowerStagelR
919666, 2 'C' Station Battery Charger TroublelR923273,2DD003 Battery Charger Failure Alarm Came lnlR
955526, 3AD003-1 Charger Fail/AC Failure Alarms Light Will Not ResetlR
1037820, Loose Jack on SCR Board in 2CD003-2 Charger ldentifiedlR
1130109, 2 'B' Station Battery Charger Trouble Alarm and Low VoltagelR
1136993, Received 2 'B' Battery Charger Trouble AlarmAttachment
A-9lR '1138029, Adverse Trend in Electrical TroubleshootinglR
1138219, 28D003-1 Alarms Came in During Setup for PMTlR
1143057,
C0235655-16 Failed PMT after Board ReplacementlR
1143077, 2CD003-2 Charger Fail AlarmslR
1147293, Need for Battery Charger TrainingM-057-014, Revision 13, Cyberex 125 Volt Battery Charger MaintenanceST-M-57B-762-2, Battery Charger 28D003-1 and 28D003-2 Capability Test, performed11t26t10Unified Control Room Log, Friday, November 26,2010, Day ShiftUnified Control Room Log, Tuesday, November 30, 2010, Day ShiftlR
1153706, U3 HPCI Suction Hi Pressure AlarmlR
1154614, U3 HPCI TSA Duration -20% Scheduled versus ActualST-O-023-301-3, HPCI Pump, Valve and Flow and Unit Cooler Functional and In-Service TestUnified Control Room Logs, Saturday, December 18,2010 Night ShiftECR 09-00160, System-23-Q Unit 3, Install New Vent ValvesER-AA-302-1007, Revision 5, MOV Limitorque Actuator Capability Determination MethodologylR
1048641, U3 HPCI 30P038 Inboard and Outboard Seal Leak After RunlR
1153114,
MO-0-48-0502A: Metal Scale Found in BodyM-366, Sheet 4, Revision 52, P & l Diagram - HPCI Pump Turbine DetailsRT-O-032-300-2, HPSW Pump, Valve and Flow Functional Test, performed 12107110RT-M-048-02A-2, Revision 0, M0-0-48-0502A Outgoing Interlocks TestST-O-094-400-2, Stroke Time Testing of Valves for PMT, performed 12116110WO
C0236060 MOV Diagnostic Test Instructions,
MO-0-48-05024WO
C0236060 MOV Post-Test Data Review Worksheet,
MO-0-48-0502A, performed
12116110* - lndicates NRC ldentified

Section 1R20: Refuelinq and Other Outaqe ActivitieslR 1122534. Black Box UnSat during

RCIC
ST-O-013-750-2lR
1121897, Risk Assessment for Unit 2 RCIC RSD Panel TestinglR
1091494, Documentation of Startup Analysis for lR 1121897lR
1121485, LCO 3.0.4.b Used to Support the RPV Pressure TestlR1122485, Risk Assessment Did Not Follow All Requirements of
OU-AA-103lR 112025l P2R18 Core Verification - Fuel Assembly Not Fully SeatedlR
1120516, P2R18 MSRV/MSSV As-Found Lift Test ResultslR
1121393, PORC Feedback - Operability Evaluation 10-006, Revision 1lR
1121643,
RV-2-02-0708 Leak at Discharge During RPV Pressure TestlR
1121076, P2R18 Drywell Critical lnsulation Inspection ResultslR
1120904, Potential Low Margin Condition ldentified in AnalysislR
1121590, SCRAM Times Require Test Performance EvaluationlR
1122003, A0-2-10-46A Fails to Indicate ClosedlR
1122962, Bio-Shield lssueslR
1123594, Documentation of Bio-Shield Doors WalkdownslR
1122565, Reportability Review Assignment Not GeneratedlR 1 1231 12, E224 Load Center Main Feed Breaker Very NoisylR
1120717, Rod 18-11 Drifted in When Restoring the CRD Charging HeaderlR
1120719, Rod 54-31 Drifted in When Restoring the CRD Charging HeaderlR
1122904, Rod 54-15 Drifted from 00lR
1123113, Unit 2 Main Generator Casing Leak Test UnSat'lR
1123502, Higher Than Expected Drywell Floor Drain PumpoutslR
1125574, Frequent Small Drywell Floor Drain PumpoutsAttachment
A-10lR
1124523, Rod 50-27 Less Than 10% Margin to TS SCRAM Time LimitlR
1124318, Control Rod StucklR 1
123360, Shutdown & Online Risk Procedure Conflicts on Assessment TransitionlR
1123240, Indicated RCIC Flow on
FC-2-13-091 during HPCI OperationlR
1123114,
CB-K134E ITE Breaker in E224 (1112) Cubicle is HumminglR
1128280, Reactor Services East Crew Clock ResetslR
1130256, Bioshield Door Bolting - Follow uplR
1140450, Transformer Control Cabinet TCCP RemovallR
1140424, Bushing Testing - Determine Spare AvailabilitylR
1140127, Control Road 06-47 Changed Position Indication When SelectedlR
1140505, A WRNM Detector Reading Higher Than Other DetectorslR
1140900, Unit 3 Bioshield Doors on 186'Missing Supports and BoltinglR
1140859, Rod Worth Minimizer Software Modification Change Not in Forced Outage ScopelR
1140814, Unit 3
CRD 14-55 Difficult to Move from 00-06lR
1140875, 3'B' MPT Replacement: Engineering to Verify All Design Documents RevisedlR
1141099, Problems Moving Unit 3
CRD 26-03lR
1141087, Control Rod 34-03 Difficult to MovelR
1141105, The New 38X001 Transformer Sudden Pressure RelaylR
1141418, LLRT Fittings Found on the Unit 3 Stabilizer ManwayslR
1142469, Oil Leaks on Replacement (38X001) MPTlR
1142541, 38X001 Bushing Enclosure Box (Doghouse) DamperlR
1142620,
HCU 38-51 Double Notched on Single Notch WithdrawallR
1142657, Replace 3 'B' MPT Heater and HTR CKT BreakerlR
1142742, Unit 3 Recirc Pump Vibration Alarms During Start-uplR
1143092, Control Rod 34-51 Double Notched on Single Notch WithdrawalSection 1 R22: Surveillance TestinqlR
1123502, Higher Than Expected Drywell Floor Drain PumpoutslR
1125574, Frequent Small Drywell Floor Drain PumpoutslR 1
126557, MSRV 71H Tailpipe Temperature High OOSlR
1120516, P2R18, MSRV/MSSV As-Found Lift Test ResultsAR
41779557,ISFSI Cask #1 (Location t$42) False AlarmslR 1
126689 ,72.48 / 50.59 Reviews Not Performed for Recent ISFSI Procedure RevisionslR 1
126691, Performance Trending of Cask Overpressure Monitoring LTAlR
1126789, lssue Written to Create a New AR for Work PlanninglR
1127245, Does Casks #601 and #650 Work Need
CC-M-112 (TCCP) ReviewlR
1127757, Pages of Calculation 349-T-VC-9 Are MissinglR
1128997, ISFSI Fuel Cask 00T701 Helium Leakage - EOClR
1128724, ISFSI Cask #01lR
1130349, Bolting on Cask #1 Weather Cover Rusted Beyond UselR 1
128307, ISFSI Cask #01 - Foreign Substance on Cask & PadlR
1131123, ISFSI Cask #1 - Potential Helium LeaklR ISFSI Cask
TN-68-01 OP System Low Pressure - Learnings / ActionslR
1136204, No ISFSI Inspection PM and Concerns with the ILRT TestlR
1143711, Station Support Needed for Root Cause InvestigationI R
728348, Sl2P-7 1 -0701 -XXC3 through Sl2P-7 1 -0737-XXC3 Change RequestlR
1125128, ISFSI Cask #1 (Location tl42) False AlarmslR
1125935, Need Revision of
SF-900 for
TC-10-164lR
1126353, No Limit for the Number of Re-Pressurizations of ISFSI Casksf R
1126689 ,72.48 / 50.59 Reviews Not Performed for Recent ISFSI Procedure RevisionslR 1
126691 , Performance Trending of Cask Operating Pressure Monitoring LTAAttachment
A-11SF-610,
TN-68 Cask Repressurization, Revision 0SF-290, Spent Fuel Cask Transport and Unloading Operations, Revision 5SF-290, Spent Fuel Cask Transport and Unloading Operations, Revision 6SF-490, Radiation Protection Requirements During Spent Fuel Cask Unloading and TransportOperations, Revision 1 0SF-g10, Spent Fuel Cask Leakage Location Determination, Revision 0SF-900 ISFSI Abnormal Condition Response, Revision 7WO R0875235, COT of ISFSI Low Pressure Switches (lncreased Frequency)Simplified Troubleshooting/Repair Guide for
TN-68-50A Cask Apparent LeakageST-O-013-301-3, Revision 35, RCIC Pump, Valve, Flow and Unit Cooler Functional and lST,performed 10120110ST-O-023-3Q1-2, Revision 57, HPCI Pump, Valve, Flow and Unit Cooler Functional and ISTSl2(3)M-13-GOV-XXC2, Revision 3, Calibration and Check of RCIC Turbine GovernorRT-O-023-725-2(3), Revision 1 8, HPCI Response TimeA/R
40385844, Replace HPCI RGSCA/R
40384750, Replace HPCI RGSC (RGSC-23)lR
0532405, Valve Stroke UNSAT in Accordance with
ST-O-07G-475-2lR
0964717,
AO-3-01A-086A Failed Minimum Allowed Stroke TimelR
1112430, MSIV
AO-80A Long Stroke TimelR
1140706,
ST-O-07G-470-3 Failure Due to Fast Stroke TimeslR
1141888, NOS lD: MSIV Stroke Time Not AdjustedlR
1142180,
AO-3-014-864 Outboard MSIV Failed
ST-O-07G-470-3 AgainlR
1142234,
AO-3-01A-864: Manifold Noise during Fast Closure!R1142672, Final Measured Close Time of
AO-3-01A-864 at 4.82 SecondslR
1142401, Clearance and Tagging ChallengelR
1142784, NOS lD: Test Results Evaluation Not Used for MSIV Failed SurveillancelR
1142850, NOS lD: Test Results Not Approved by Responsible Superintendent.lR
1159854, Record U2 MSIV LS PositionNUREG-1482, Revision 1, Guidelines for IST for Nuclear Power PlantsPBAPS PCM Templates, BWR
MSIVST-M-01A-471-3, Revision 9, MSIV Timing, Springs Only Closure andPosition Switch Adjustment, performed 11 l181 10ST-M-01A-471-2, Revision 10, MSIV Timing, Springs Only Closure andPosition Switch AdjustmentST-O-O7G-470-3, MSIV Closure Timing, Revision 13, performed 10/03/08, and 10/08/08ST-O-O7G-470-3, MSIV Closure Timing, Revision 13, performed 01122109ST-O-07G-470-3, MSIV Closure Timing, Revision 14, performed 09/29109ST-O-O7G-470-2, MSIV Closure Timing, Revision 15, performed 10/01i 10ST-O-07G-47Q-3, MSIV Closure Timing, Revision 15, performed 11115/10, and 11118110ST-O-O7G-475-2, MSIV Closure Timing at Shutdown, Revision 3,Performed 09/13/10Unified Control Room Log, Monday, November 15, 201Q, Night ShiftUnified Control Room Log, Thursday, November 18, 2010, Day ShiftUnified Control Room Log, Thursday, November 18, 2010, Night ShiftPBAPS UFSAR, Revision 22, Section 14.3 - Unacceptable Safety Results for AccidentsPBAPS UFSAR, Revision 22, Section 14.5 - Analysis of Abnormal Operating TransientsWO
C0235823, Adjust Stroke TimesLimerick 5T-6-041-202-1, Revision22, MSIV Cold Shutdown Valve TestNRC lnspection Report 05000352&35312003-003, Limerick Generating StationlR
0147485, MSIV Stoke Time UNSATlR
0164391, NRC Concerns on Unit 2 MSIVs and MSIV Test MethodsAttachment
2Weir Valves and Controls Company Procedure Number 302-90422, Revision 1, Sensitivity ofMSIV Stroke Time to Variations in Flow Parameters and to Changes to HydraulicDamper Oil Temperature, performed for Hatch Electric Generating Plant, approved07t01t03RT-O-O1D-402-2, Master Trip Solenoid Valves Operability Test, Revision 7 (test record datedDecember 13, 2010)RT-O-O1D-402-2, Master Trip Solenoid Valves Operability Test, Revision 7 (retest record datedDecember 14,2010)lR
1151657, Unit 2 Main Turbine MTSV'B' Slow to Trip during Monthly TestingAR
41787340,
SV-2-01D-48698 - Main Turbine Master Trip Solenoid Valve 'B'

Section RSO1: &cess Con'lrol to Radiolosically Siqnificant AreasProceduresRP-AA-460, Revision 20, Controlfor High and Locked

HRARP-M-460-001, Revision 2, Control for
VHRARP-AB-460, Revision 1, TIP Area Access ControlsRT-H-099-960-2, Revision 7, Outside Radioactive Material Storage Area Inspection and SurveyDocumentsDose RecordsCommon Cause Analysis - AR1117442Work Practices - AR1137954Exposure Control - AR1126541Contamination Control - Personnel Contamination DataDosimetry Performance Testing DataCorrective 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 andOccupational Performance lndicators, Ground Water Protection Program, Unit 2 and 3Occupational Radiological Control, Including Unit 2 Post-outage Radiological ControlsReview Inspection Report Feeder for PBAPS, Units 2 and 3 lntegrated lnspection ReportNumbers
05000277 and 0500027812010005, dated January 18,2011 (ML110180498)Sectislr_BS0Z: Occupational ALABA Planning and ControlsDocumentsGeneral Source Term dataBRAC Point DataBusiness Plan and Site ALARA Plan GoalsWork Job reviews and ALARA reviewsOutage Report DataCorrective Action Documents (ARs-
1121190,
1121194,
11211980, 1 1 15333,
1115629,1115845,1 1 15918,
1117253,
1117412,
1117756, 1117758)

Section RS04: 9ccupational Dose AssessmentProceduresRP-AA-210, Revision 18, Dosimetry lssue, Usage, and ControlDocumentsAttachment

A-13NRC Safety Evaluation, Application to Use Weighting Factors for External Exposure, datedDecember 20,2006Exposure Controland Dose RecordsGeneral Source Term dataPersonnel Contamination Event LogsPersonnel Intake InvestigationsCorrective Action Documents (ARs-
1117248,
1117263,
1117424,
1117625,
1117729, 1 1 18001,1118030,118281)

Section RS05: Radiation Monitorinq InstrumentationDocumentsGeneral Source Term dataBRAC Point DataALARA Work In Progress ReviewsContamination Monitoring Instrument MatrixSection

RS06: Radioactive Gaseous and Liquid Effluent TreatmentProceduresEN-M-408-4000, Revision 0, Radiological Ground Water Protection Program lmplementationEN-PB-408-4160, Revision 0, Peach Bottom RGPP Reference MaterialDocumentsAnnual Radiological Environmental, Effluent Release Reports - 2008, 2009ODCM and ChangesReports (various) - Routine Ground WaterGeneral Source Term DataGround Water AnalysesSection 4OA1 : Performance lndicator VerificationMSPI Deviation Reports and Svstem Manaqer Notebooks:October 2009 through September 2010, Unit 2 and Unit 3 RHRyHPSWOctober 2009 through September 2010, Unit 2 and Unit 3 ESWOctober 2009 through September 2010, Unit 2 and Unit 3 EDGsOctober 2009 through September 2010, Unit 2 and Unit 3 HPCIOctober 2009 through September 2010, Unit 2 and Unit 3 RCIClRs:lR
1034923, Use of Incorrect Parameters for MSPI TermslR
1110941, lmproper Assignment Closure - MSPI UA TermsProcedures:LS-AA-2001, Collecting and Reporting of NRC Pl Data, Revision 13ER-AA-2020, Equipment Performance and Information Exchange (EPIX)and MSPI FailureDetermination Evaluation, Revision 4ER-AA-600-1047, Mitigating Performance lndex Basis Document, Revision 5ST-C-095-865-2, Determination of Annual Dose Equivalent for All Uranium FuelCycle Source, Revision 1LERs:LER 03-09-05, Common Cause Failure of 'C' and 'E'Wide Range Neutron MonitorsAttachment
A-14LER 02-09-02, Pneumatic Supply Degraded for Containment lsolation Valves Due toMis-Positioned ValveLER 03-09-06, Unplanned Manual Scram Due to Shortening Reactor Period DuringScheduled ShutdownLER 03-09-07, Oil Leak from MSIV Dashpot Results in Short Valve Stroke TimeLER 02-10-01, Multiple Slow Control Rods Results in Condition Prohibited by TSsDocume[LsNEI 99-02, "Regulatory Assessment Indicator Guideline," Revision 6.Annual Radiological Environmental, Effluent Release Reports- 2008, 2009Public Dose Projections (Liquid, Gaseous)Reports (various) - Routine Ground Water dataCorrective 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 Problemslssue ReportslR

1128059, Station Trend Review -
511110 to 8i31110lR 1139125,==
NRC
URI 2010004-02: P2R18 Fuel Handling Performance ErrorslR
1139377, NRC
URI 2010004-01: Degraded SFP Boraflex Panels lssueslR
1131123, ISFSI Cask #1 - Potential Helium LeaklR
1129931, ISFSI Cask # 50 Helium LeaklR
1126689,72.48150.59 Reviews not Performed for Recent ISFSI Procedure ReviewslR
1112617, Action Level 1 Entered for Unit 2 Reactor Water InfluentlR
1080382 ,
DPI-2-10-130A lndication Lowering with 2 'A' HPSW Pump in ServicelR
1139814, 3'B' MPT Gassing Exceeded ACMP ThresholdlR
1121101, Outage Services Refueling Equipment Performance IndicatorTurned Redf R 1 1 17854, Dummy Bundle Came In Contact With Bundle ln SFPlR 1 1 15041, Fuel Bundle Came in Contact with CSI SubmarinelR
1128280, Reactor Services East Crew Clock ResetslR
1095534, Human Performance CCA - lsdt and 2no Quarter 2010lR
1120323, Initiate a Common Cause for Liquid Radwaste ReleaseslR
1095601, Security PIDS Common Cause AnalysislR
1113275, Energy lntroduced lnto Confined Space during Personnel EntrylR
1113557, Confined Space Used Without Required Rescue PlanlR
1115107, Air Conditioning Hose Removed From 'B' CondenserlR
1154579, ESW Excavation Site 5 Confined Space DeficiencieslR
1116175, Effectiveness of Confined Space Communication Needs ReviewlR
1115190, WO Fails to Drive Posting of Confined SpacelR Limited Distribution of Safety Information on Confined SpacelR 1 1 17655, lndustrial Safety ConcernlR
1119860, Clearance Event Challenged and ReclassifiedlR
1114045, Condenser Entry Without Signing On ClearancelR
1114077, Follow-up to lR 1
113275 Confined Space EntrylR
1114185, Work Delayed in 'B' CondenserlR
1099140, 8 DPM Leak from 'A' ESW Discharge Check ValvelR
1137854, Pin Hole Leak ldentified on 'A' ESW Supply in Excavation 2lR
1138619, Below Minimum Wall Reading on 20 Inch 'A' ESW Supply in Excavation 1lR
1139646, Possible Minimum Wall Reading on 20 lnch'A' ESW Supply in ExcavationlR
1141622, Low Wall Reading on 16 lnch 'A' ESW Supply in Excavation 4lR
1137763, 'A' ESW Repair Partially Complete Due to Valve Seat LeakageAttachment
A-15lR
1131251 ,
LT-2-70A-060 Has AlarmedlR
1136152,
LT-2-70A-060 Has AlarmedlR
1147495,
LT-2-70A-060 Has AlarmedlR
1152771,
LT-2-70A-060 Has AlarmedlR
1108435,
LT-2-70A-060 tn AlarmlR
1147493,
LT-2-70A-009 Has AlarmedlR
1131246,
LT-2-70A-009 Has AlarmedlR
1108433,
LT-2-70A-009 Has AlarmedlR
1131247,
LT-2-70A-025A Has AlarmedlR
1147494,
LT-2-70A-025A Has AlarmedlR
1131250,
LT-2-70A-025C Has AlarmedlR
1131252,
LT-2-70A-061 Has AlarmedlR
1131255,
LT-2-70A-0268 Has AlarmedlR 1 131 243, lT -2-7 0A-006 Has AlarmedlR
1080603, Submerged Cables Found in Manhole MH076lR
1076477, Submerged Cables Found in Manhole MH077lR
1076483, Submerged Cables Found in Manhole MH078lR
1076511, Submerged Cables Found in Manhole MH079lR
1076528, Submerged Cables Found in Manhole MH104lR
1078220, Submerged Cables Found in Manhole MH101lR
1078240, Submerged Cables Found in Manhole MH100lR
1076477, Submerged Cables Found in Manhole MH077lR
1080533, Submerged Cables Found in Manhole MH044lR
1080613, Submerged Cables Found in Manhole MH082lR
1080636, Submerged Cables Found in Manhole MH084lR
1082143, Submerged Cables Found in Manhole MH083lR
1082151, Submerged Cables Found in Manhole MH075lR
1082156, Submerged Cables Found in Manhole MH081lR
1082728, Submerged Cables Found in Manhole MHO19lR
1140906, Low Battery Voltage Indicated on
LT-2-7QA-057lR
1140910, Low Battery Voltage Indicated on
LT-2-70A-041lR 1
140914, Low Battery Voltage Indicated on
LT-2-70A-035lR 1
140906 ,
LT-2-70A-041 Has Stopped TransmittinglR
1119949, Manhole 26 - Requires PumpoutlR
1153723, Discrepancy in Calculation
PM-842lR
1147062, Unit 2 Fuel Pool Rack Boraflex Upgrade ProjectlR
1147066, Unit 3 Fuel Pool Rack Boraflex Upgrade ProjectER-AA-300-1001, l"tQuarter Program Health Report PBAPS MOV Program, Revision 4ER-AA-300-1001, 2no Quarter Program Health Report PBAPSMOV Program, Revision 5ER-AA-300-1001,3'o Quarter Program Health Report PBAPS MOV Program, Revision 5ER-AA-300, MOV Program Administrative Procedure, Revision 6ER-AA-302, MOV Program Engineering Procedure, Revision 5ER-AA-302-1001, MOV Rising Stem MOV Thrust and Torque Sizing andSet-up Window Determination Methodology, Revision 6ER-AA-302-1003, MOV Margin Analysis and Periodic Verification Test Intervals, Revision 5ER-AA-302-1004, MOV Performance Trending, Revision 4ER-M-302-1006,
GL 96-05 Program MOV Maintenance and Testing Guidelines, Revision 9LS-AA-126-1001, Attachment 2 FASA Self-Assessment Report Template, Revision 5MA-AA-723-300, Diagnostic Testing of MOV Valves, Revision 3MA-AA-723-301, Periodic Inspection of Limitorque Model SMB/SB/SBD-000 through 5 MOV,Revision 6Attachment
A-16lR827482, U2 HPCI
MO-57 Stroked in Alert Range Then Stopped MovinglR
892191 ,
MA-2-23-058 Stopped In Intermediate PositionlR
892191, Assignment 8, Root Cause for MOV Degraded Grease and Performance lssueslR
895626, U3 HPCI Suction Valve Stem Grease ConditionlR
895789, U3 HPClTorus Suction
MO-3-23-57, Split IndicationlR
896914, Test Results of Stored Exxon Nebula
EP-1 GreaselR
898030,
MO-3-10-13D Stem Nut Wear & UnderthrustlR
898645, MOV Stem Lube Activity and PM Frequency RecommendationlR
899298, Procedure
MA-AA-723-301 DeficiencylR
901501,
MO-2-10-154B As-found Test UnderthrustlR
906768,
MO-2-10-015D Did Not Stroke Open During PMTlR
1097085, Exelon Fleet Wide Actions 'or Nuclear Event Report (NER)
NC-10-047YlR
1136045, Recommend Evaluation on Handwheel Operation Of ValvesNRC lntegrated Inspection Report 0500027712A070A5 and 0500027812007005, Section4OA2.3: U3 MOV Failure to Stroke Follow-upN RC I nteg rated I nspection Report
05000277 l
2009003 a nd 05000 27 81 2009003NRC Pl&R Inspection Report 0500027712009008 and 0500027812009008Work Orderswo co228400, Mo-2-10-13A, EOC, 41112009wo co228395,
MO-2-1013C, EOC, 313112009wo c0228321,
MO-3-1 0-1 3C, EOC, 312912009wo c022831 9,
MO-3-1 3D,
EOC 3127 12009WO R0821517,
MO-3-10-18, Perform Motor Operator PM Task, 9/30/2009WO R0944691,
MO-3-23-19, Motor Operator PM, 10/3/2009WO
C0228295,
MO-3-23-057, Clean & Lube Valve Stem, 312212009WO
C0228299,
MO-2-23-058, Clean stem & perform Testing, 3124/2009wo c0228449,
MO-3-1 0-314, EOC, 41312009WO R1087541,
MO-3-10-34A, Operator PM, 911012009WO R1001292,
MO-2-10-89D, Perform Motor Operator PM task, 41912009wo c0228484,
MO-3-10-154A, EOC, 41412009wo c0228 438,
MO-2-1 0-1 548, EOC, 41212009WO R0897679,
MO-2-10-176, Perform Motor Operator PM, 4l14l11DocumentsCorrective Action Documents (lRs
1116765,
1117248,1117263,
1117424,
1117625,
1117729,1 1 1 8001 , 1 1 1 8030, 1 1 1 8281 )Additional DocumentsMemorandum from: Javier Brand to PaulG. Krohn, Peach Bottom Problemldentification and Resolution Sample lnspection Report Feeder for Inspection Report050Q027 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, Problemldentification and Resolution Sample Inspection Report Feeder for PBAPS, Units 2 and3 lntegrated lnspection Report Numbers
05000277 and 0500027812010005, datedJanuary 4, 2011 (ML1 10040342)Work OrdersA1 785978A1777807c0233693Attachment
A-17c0234654lssue Reports102220610278691 03901 710480121073860107386610937471129133113124711312501131255113607211361521140522114052211409061140910114749311474941147495115154611516711152475.11527711152789.*ldentified during inspectionMiscellaneousE-1400, Sheet 34, Manhole Symbols, Notes, and Details, Revision 0ECR 10-00236, Modification to Electrical Manholes, Revision 0ER-AA-3003, Cable Condition Monitoring Program, Revision 0Letter from D. Benyak to NRC, 90-Day Response to
GL 2007-01, dated 517107

==Section 4OA3: Follow-up of Events and Notices of Enforcement DiscretionlR

1125359, Reportability Aspects of==
NRC URI lnvolving LTCsLetter from G. L. Stathes (Exelon Generation Company, LLC) to Document ControlDesk (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 ControlDesk (U.S. NRC), "Peach Bottom Units 2 and 3, Submittalof ISFSI Cask Event Report,"dated December 1, 2010 (ML1 10060275)

==Section 4OA5: Other ActivitiesARs0109822601

12805901 1
36333001
169490091 3307009822430112979401 1 356570095601 701
00847301 038005002924070029989700373281001 12308Condition Reports01146526.01147978.01147560"0012405900124567001342070107374401 073957008537370025937200881 3280113856700256108001 9902100176577000852010076944800577900004869260037741501 1
1685801 0306820098347200947038008526880031 5873011297940095601 7009133070096521 I0096697201 062638010932920096177201 0831 65Attachment==
A-180076765000773824007739330077859500779772008278890089789400968986009696690107109201071 150011111010111718001117182011172130113402901 14650501146526 *ldentifiedduring inspectionProcedures: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 DevelopmentProgram Instruction Guide - Week 4"TQ-AA-121 Revision 10," Exelon Supervisor Development Program"HR-AA-4000 Revision 20, "Employees Entering Exelon Nuclear, Changing Positions WithinExelon 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#50Helium Overpressure System Leakage Monitoring512P-71-0703-XXC3, COT of ISFSI Low Pressure Switches
PS-70703A and
PS-70703BSF-290, Spent Fuel Cask Transport and Unloading OperationsSF-220 Spent Fuel Cask Loading and Transport OperationsSF-490, Radiation Requirement during Spent Fuel Cask Unloading and Transport OperationsSF-61 0,
TN-68 Cask RepressurizationSF-900, ISFSI Abnormal Condition ResponseSF-g10, Spent FuelCask Leakage Location DeterminationRT-H-071-901-2, Revision 1, ISFSI Quarterly Inspection Radiation SurveyRP-M-376-1001, Revision 4, Radiological Posting, Labeling, and Marking StandardRP-AA-500, Revision 14, Radioactive Material (RAM) ControlRT-H-099-960-2, Revision 7, Outside Radiological Material Storage Area Inspection and SurveyCC-AA-102, Design Input and Configuration Change lmpact Screening, Revision 20ER-AA-2009, Managing Gas Accumulation, Revision 1ER-AA-335-007, Ultrasonic lnspection for Determination of Sedimentation in Piping Systems orComponents and Fluid Level Measurements, Revision 3OP-AA-108-106, Equipment Return to Service, Revision 4Attachment
A-19Planning Desktop Guide Insert, "GL 08-01 Requires UT for Air Voids of ECCS Following SystemFillA/enting," dated November 2008SO 14.1.A-2, CS System Alignment for Automatic or Manual Operation, Revision 5SO 14.3.A-2, Manually Venting of the CS Line Vent Accumulator Lines, Revision 2SO-10.3.A-2, RHR System A Loop Filling and Venting, Revision 18SO-10.3.8-2, RHR System B Loop Filling and Venting, Revision 18SO-10.5.A-2, RHR System Piping Flush, Revision 10SO-23.1.A-2, HPCI System Setup for Automatic or Manual Operation, Revision 18SO-23.1.A-3, HPCI System Setup for Automatic or Manual Operation, Revision 16ST-0-010-301-2,'A'RHR Loop Pump, Valve, Flow, and Unit Cooler Functional and lST,Revision 32ST-O-010-350-2, RHR Loop A and Cross Tie Valve Position and Filled and Vented Verification,Revision 8ST-0-010-355-2, RHR Loop B Valve Position and Filled and Vented Verification, Revision 4Completed Surveillance Test ProceduresST-O-014-350-2, CS Loop'A'Valve Alignment and Filled and Vented Verification, performed8/30/10ST-O-014-350-3, CS Loop 'A'Valve Alignment and Filled and Vented Verification, performed9t15t10ST-O-014-355-2, CS Loop 'B'Valve Alignment and Filled and Vented Verification, performed918110ST-O-014-355-3, CS Loop 'B'Valve Alignment and Filled and Vented Verification, performed9t20110ST-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 0ST-O-023-350-3, HPCI Valve Alignment and Filled and Vented Verification, performed
3124110,4112110,
5112110,
6115110,7114110,
8111110, and 9/15/10NRC Enforcement Actions:EA-08-298 dated January 6, 2009EA-10-093 and
EA-10-121 dated September 16,2010EA-09-029 dated July 9, 2009EA-09-007 and
EA-09-059 dated December 1, 2009lA-09-023 dated December 1, 2009fA-09-025 dated December 2,2009Inspection Procedures Used60855 Operation of an ISFSIDocumentsCOC 1027, Amendment 0, 1Radiological Surveys - lFSlSl-2P-71-0728-XXC3, Revision 0, COT of ISFSI Low Pressure SwitchesPS-70728A and
PS-707288, performed 05126110Sl-2P-71-0733-XXC3, Revision 0, COT of ISFSI Low Pressure SwitchesPS-70733A and
PS-707338, performed 07106110Sl-2P-71-0735-XXC3, Revision 0, COT of ISFSI Low Pressure SwitchesPS-70735A and
PS-707358, performed 07106110Sl-2P-71-0737-XXC3, Revision 0, COT of ISFSI Low Pressure SwitchesPS-70737A and
PS-707378, performed 06/08/10Attachment
A-20ST-S-071-901-2, Revision 51, ISFSI Cask Interseal Pressure Check, performed
11113110,11128110, and 12105110TN-68 TSs and Bases, Section 3.1.5TN-68 TSs and Bases, Amendment 1, Section 3.1.5Additional DocumentsMemorandum to Paul Krohn thru Judith A. Joustra from Stephen Hammann and JohnNicholson, PBAPS Feeder for Inspection Reports 0500027712010005 and0500027812010005, dated January 7 , 2011 (ML{ 10070096)Memorandum to Paul Krohn thru Lawrence T. Doerflein from Kevin Mangan, PBAPS Feeder forTl25151177 - Managing Gas Accumulation in Emergency Core Cooling, Decay HeatRemoval and Containment Spray Systems, lnspection Reports 0500027712010005 and05000278/2010005 dated January 18,2011 (ML 110190398)DrawinosDrawing
OTN9.OOKO161F290, Process Diagram CS System, Revision 06280-M-309, Sht. 1, P&lD - Condensate & Refuel Water Storage and Transfer System,Revision 646280-M-361, Sht. 1 and 2, P&lD - RHR System, Revision 81 and 676280-M-362, Sht. 1 and 14, P&lD - CS Cooling System, Revision 62 and 36280-M-365, Sht. 1, P&lD - HPCI System, Revision 636280-M-366, Sht. 1, P&lD - HPCI Pump Turbine Details, Revision 57ISO 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, respectivelyISO DWG 2-13, Shts. 3-8, 12, and 13, #23 HPCI, Revision 2, 1, 11,2,2, 2, 4 and 5, respectivelyf 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, respectivelyEnqineerino EvaluationsGL 2008-01 System Evaluation - PBAPS - CS, dated 9120108GL 2008-01 System Evaluation - PBAPS - RHR, dated 9120108GL 2008-01 System Evaluation - PBAPS - HPCI, dated 9120108Miscellaneous767650-A24, Gas Accumulations Program Monitoring Frequency, dated 4130109Exelon letter to NRC, Response to Request for Additional Information Regarding
GL 2008-01,dated 11110109Exefon letter to NRC, Nine Month Response to
GL 2008-01, dated 1011412008Exelon letter to NRC, Peach Bottom Supplemental Response to
GL 2008-01, dated 1116109Gas Accumulation Program
GL 08-01 UT Activity PlanOperability Evaluation 08-007, Revision 1Peach Bottom Final Safety Analysis Report, Revision 22Peach Bottom Unit 2 TSs, Revision 278wo 4177047Attachment
ACMPSADAMSADRALARAARCAPccACFRcocCOC TScorCRsCSDBDEACEEDEDGEIACEOCESWFPPGLGPIHPCIHPSWHRAHXrMcINPOIPIPEIRISFSIISTLERLTCMOVMPTMRMSIVMSPIsNCVNEINRCNRRNVLAPODCMoosA-21

LIST OF ACRONYMS

Adverse Condition Monitoring PlansAgency-wide Documents Access and Management SystemAlternate Dispute ResolutionAs Low As Reasonably AchievableAction RequestCorrective Action ProgramCommon Cause AnalysisCode of Federal RegulationsCertif i cate-of-Co m p I ia n ceCertificate-of-Com pliance Techn ical SpecificationsChannel Operational TestCondition ReportsCore SprayDesign Basis DocumentEquipment Apparent Cause EvaluationElectronic DosimeterEmergency Diesel GeneratorEmployee lssues Advisory CouncilExtent-of-ConditionEmergency Service WaterFire Protection PlanGeneric LetterGround Water Protection InitiativeHigh Pressure Coolant lnjectionHigh Pressure Service WaterHigh Radiation AreaHeat ExchangerInspection Manual ChapterInstitute of Nuclear Power OperationInspection ProcedureIndividual Plant Examinationlssue ReportIndependent Spent Fuel Storage InstallationInservice TestingLicensee Event ReportLoad Tap ChangerMotor Operated ValvesMain Power TransformerMaintenance RuleMain Steam lsolation ValveMitigating Systems Performance IndicatorsNon-cited ViolationNuclear Energy InstituteNuclear Regulatory CommissionNuclear Reactor RegulationNational Voluntary Laboratory Accreditation ProgramOff-site Dose Calculation ManualOut-of-ServiceAttachment

OPDRVO [[TDMPARSPBAPSPDPIPI&RPMPMTPORCPROSRCARCtCRETSRFORFPRHRRTPSBOSDPSFPSRVSSCsSSFFSSTsSVTETITRMTSUFSARUTVHRAWGEWOA-22Operations with a Potential to Drain the Reactor VesselOperational and Technical Decision MakingPublicly Available RecordsPeach Bottom Atomic Power StationPerformance DeficiencyPerformance lndicatorProblem ldentification and ResolutionPreventive Ma i ntenancePost-Maintenance Testi ngPlant Operations Review CommitteeProfessional Reactor Operator SocietyRoot Cause AnalysisReactor Core lsolation CoolingRadiological Effluent Technical SpecificationRefueling OutageReactor Feed PumpResidual Heat RemovalRated Thermal PowerStation BlackoutSignificance Determination ProcessSpent Fuel PoolSafety Relief ValveStructures, Systems, and ComponentsSafety System Functional FailuresSurveillance TestsSafety ValveTechnical EvaluationTemporary InstructionTechnical Requirements ManualTechnical SpecificationsUpdated Final Safety Analysis ReportUltrasonic TestingVery High Radiation AreaWork Group EvaluationWork OrderAttachment]]