IR 05000277/2009003: Difference between revisions

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{{Adams|number = ML092220599}}
{{Adams
| number = ML092220599
| issue date = 08/10/2009
| title = IR 05000277-09-003, 05000278-09-003, on 04/01/09 - 06/30/09; Peach Bottom Atomic Power Station,Power Station, Units 2 and 3, Identification and Resolution of Problems, Follow-up of Events and Notices of Enforcement Discretion
| author name = Krohn P G
| author affiliation = NRC/RGN-I/DRP/PB4
| addressee name = Pardee C G
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| docket = 05000277, 05000278
| license number = DPR-044, DPR-056
| contact person = KROHN P G, RI/DRP/PB4/610-337-5120
| document report number = IR-09-003
| document type = Inspection Report, Letter
| page count = 35
}}


{{IR-Nav| site = 05000277 | year = 2009 | report number = 003 }}
{{IR-Nav| site = 05000277 | year = 2009 | report number = 003 }}
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On June 30, 2009, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The enclosed integrated inspection report documents the inspection results, which were discussed on July 17, 2009, with Mr. William Maguire and other members of your staff.
On June 30, 2009, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The enclosed integrated inspection report documents the inspection results, which were discussed on July 17, 2009, with Mr. William Maguire and other members of your staff.


The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Based on the results of this inspection, two self-revealing findings of very low safety significance (Green) were identified. One of these findings was determined to involve a violation of NRC requirements. Additionally, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. However, because of the very low safety significance and because the finding has been entered into your corrective action program (CAP), the NRC is treating the finding as a non-cited violation (NCV), consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U. S. NRC, Washington, DC 20555-0001; and the NRC Resident Inspector at the PBAPS. In addition, if you disagree with the characterization of the cross-cutting aspect of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region 1 and the NRC Senior Resident Inspector at PBAPS. The information you provide will be considered in accordance with Inspection Manual Chapter (IMC) 0305.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
 
Based on the results of this inspection, two self-revealing findings of very low safety significance (Green) were identified. One of these findings was determined to involve a violation of NRC requirements. Additionally, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. However, because of the very low safety significance and because the finding has been entered into your corrective action program (CAP), the NRC is treating the finding as a non-cited violation (NCV), consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U. S. NRC, Washington, DC 20555-0001; and the NRC Resident Inspector at the PBAPS. In addition, if you disagree with the characterization of the cross-cutting aspect of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region 1 and the NRC Senior Resident Inspector at PBAPS. The information you provide will be considered in accordance with Inspection Manual Chapter (IMC) 0305.


In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
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C. Crane, President and Chief Operating Officer, Exelon Corporation M. Pacilio, Chief Operating Officer, Exelon Nuclear W. Maguire, Site Vice President, Peach Bottom J. Grimes, Acting Senior Vice President, Mid-Atlantic R. Hovey, Senior Vice President, Nuclear Oversight G. Stathes, Plant Manager, Peach Bottom J. Armstrong, Regulatory Assurance Manager, Peach Bottom J. Bardurski, Manager, Financial Control & Co-Owner Affairs R. Franssen, Director, Operations P. Cowan, Director, Licensing D. Helker, Licensing K. Jury, Vice President, Licensing and Regulatory Affairs J. Bradley Fewell, Associate General Counsel, Exelon T. Wasong, Director, Training Correspondence Control Desk D. Allard, Director, Bureau of Radiation Protection, PA Department of Environmental Protection S. Gray, Administrator, Maryland Power Plant Research Program S. Pattison, Secretary, SLO, Maryland Department of the Environment M. Griffen, Maryland Department of Environment Public Service Commission of Maryland, Engineering Division Board of Supervisors, Peach Bottom Township B. O'Connor, Council Administrator of Harford County Council Mr. & Mrs. Dennis Hiebert, Peach Bottom Alliance E. Epstein, TMI - Alert J. Johnsrud, National Energy Committee, Sierra Club Mr. & Mrs. Kip Adams R. Fletcher, Dir, MD Environmental Program Manager, Radiological Health Program Director, Nuclear Safety Project, Union of Concerned Scientists R. Ayers, Deputy Mgr, Harford County Div of Emergency Operations E. Crist, Harford County Div of Emergency Operations S. Ayers, Emergency Planner, Harford County Div of Emergency Operations R. Brooks, Cecil County Dept of Emergency Services Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
C. Crane, President and Chief Operating Officer, Exelon Corporation M. Pacilio, Chief Operating Officer, Exelon Nuclear W. Maguire, Site Vice President, Peach Bottom J. Grimes, Acting Senior Vice President, Mid-Atlantic R. Hovey, Senior Vice President, Nuclear Oversight G. Stathes, Plant Manager, Peach Bottom J. Armstrong, Regulatory Assurance Manager, Peach Bottom J. Bardurski, Manager, Financial Control & Co-Owner Affairs R. Franssen, Director, Operations P. Cowan, Director, Licensing D. Helker, Licensing K. Jury, Vice President, Licensing and Regulatory Affairs J. Bradley Fewell, Associate General Counsel, Exelon T. Wasong, Director, Training Correspondence Control Desk D. Allard, Director, Bureau of Radiation Protection, PA Department of Environmental Protection S. Gray, Administrator, Maryland Power Plant Research Program S. Pattison, Secretary, SLO, Maryland Department of the Environment M. Griffen, Maryland Department of Environment Public Service Commission of Maryland, Engineering Division Board of Supervisors, Peach Bottom Township B. O'Connor, Council Administrator of Harford County Council Mr. & Mrs. Dennis Hiebert, Peach Bottom Alliance E. Epstein, TMI - Alert J. Johnsrud, National Energy Committee, Sierra Club Mr. & Mrs. Kip Adams R. Fletcher, Dir, MD Environmental Program Manager, Radiological Health Program Director, Nuclear Safety Project, Union of Concerned Scientists R. Ayers, Deputy Mgr, Harford County Div of Emergency Operations E. Crist, Harford County Div of Emergency Operations S. Ayers, Emergency Planner, Harford County Div of Emergency Operations R. Brooks, Cecil County Dept of Emergency Services Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).


Sincerely,/RA/ Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects Distribution w/encl: (via E-mail) S. Collins, RA M. Dapas, DRA D. Lew, DRP J. Clifford, DRP P. Krohn, DRP R. Fuhrmeister, DRP A. Rosebrook, DRP E. Torres, DRP J. Bream, DRP F. Bower, DRP, SRI M. Brown, DRP, RI S. Schmitt, DRP, OA L. Trocine, RI OEDO H. Chernoff, NRR R. Nelson, NRR J. Hughey, PM NRR P. Bamford, Backup NRR ROPreports@nrc.gov Region I Docket Room (with concurrences) SUNSI Review Complete: ___PGK___ (Reviewer's Initials) ML092220599 DOCUMENT NAME: G:\DRP\BRANCH4\INSPECTION REPORTS\PEACH BOTTOM\PBIR2009-003 REV 4.DOC After declaring this document "An Official Agency Record" it will be released to the Public. To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RI/DRP RI/DRP RI/DRP NAME FBower/ PGK for JBream/ * PKrohn/ PGK DATE 08/10 /09 07/ 24 /09 08/10 /09 OFFICIAL RECORD COPY * Concurred on 7/24/09, JRB 1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION I Docket Nos.: 50-277, 50-278 License Nos.: DPR-44, DPR-56 Report No.: 05000277/2009003 and 05000278/2009003 Licensee: Exelon Generation Company, LLC Facility: Peach Bottom Atomic Power Station, Units 2 and 3 Location: Delta, Pennsylvania Dates: April 1, 2009 through June 30, 2009 Inspectors: F. Bower, Senior Resident Inspector M. Brown, Resident Inspector E. Torres, Project Engineer A. Ziedonis, Reactor Inspector Approved by: Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects  
Sincerely,/RA/ Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects  
 
Distribution w/encl:
(via E-mail)
S. Collins, RA M. Dapas, DRA D. Lew, DRP J. Clifford, DRP P. Krohn, DRP R. Fuhrmeister, DRP A. Rosebrook, DRP E. Torres, DRP J. Bream, DRP F. Bower, DRP, SRI M. Brown, DRP, RI S. Schmitt, DRP, OA L. Trocine, RI OEDO H. Chernoff, NRR R. Nelson, NRR J. Hughey, PM NRR P. Bamford, Backup NRR ROPreports@nrc.gov Region I Docket Room (with concurrences)
SUNSI Review Complete: ___PGK___ (Reviewer's Initials)
ML092220599 DOCUMENT NAME: G:\DRP\BRANCH4\INSPECTION REPORTS\PEACH BOTTOM\PBIR2009-003 REV 4.DOC After declaring this document "An Official Agency Record" it will be released to the Public.
 
To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure " E" = Copy with attachment
/enclosure "N" = No copy OFFICE RI/DRP RI/DRP RI/DRP NAME FBower/ PGK for JBream/ * PKrohn/ PGK DATE 08/10 /09 07/ 24 /09 08/10 /09 OFFICIAL RECORD COPY  
* Concurred on 7/24/09, JRB  
 
1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION I Docket Nos.: 50-277, 50-278  
 
License Nos.: DPR-44, DPR-56 Report No.: 05000277/2009003 and 05000278/2009003 Licensee: Exelon Generation Company, LLC  
 
Facility: Peach Bottom Atomic Power Station, Units 2 and 3  
 
Location: Delta, Pennsylvania Dates: April 1, 2009 through June 30, 2009  
 
Inspectors: F. Bower, Senior Resident Inspector M. Brown, Resident Inspector E. Torres, Project Engineer A. Ziedonis, Reactor Inspector  
 
Approved by: Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects  


Enclosure 2  
Enclosure 2  


=SUMMARY OF FINDINGS=
=SUMMARY OF FINDINGS=
......................................................................................................... 3
IR 05000277/2009003, 05000278/2009003; 04/01/2009 - 06/30/2009; Peach Bottom Atomic
 
Power Station, Units 2 and 3; Identification and Resolution of Problems; Follow-up of Events and Notices of Enforcement Discretion
.
The report covered a three-month period of inspection by resident inspectors and an announced inspection by a regional reactor inspector. Two self-revealing findings were identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using IMC 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. Cross-cutting aspects associated with findings are determined using IMC 0305, "Operating Reactor Assessment Program," dated January 2009. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
 
===Cornerstone: Initiating Events===
: '''Green.'''
A self-revealing finding was identified when PBAPS personnel incorrectly performed a maintenance procedure for tuning the reactor recirculation pump (RRP) motor generator (MG) set voltage regulator. Specifically, maintenance personnel adjusted a potentiometer in the wrong direction, which resulted in a trip of the RRP and an unplanned plant transient.
 
This finding is more than minor because the finding is associated with the human performance attribute of the Initiating Events Cornerstone, and adversely affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions. Specifically, this error resulted in an unplanned plant transient that reduced reactor power from 75 percent to 33 percent. In accordance with IMC 0609, Attachment 4, the inspectors determined this finding to be of very low safety significance (Green) since the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. This finding has a cross-cutting aspect in the area of human performance, Work Practices, because PBAPS did not define and effectively communicate expectations regarding procedural compliance and personnel did not follow procedures [H.4(b)]. Specifically, PBAPS personnel did not follow procedure IC-11-02011 instructions for tuning the 3 'A' RRP MG set voltage regulator. (Section 4OA3.1)
 
===Cornerstone: Mitigating Systems and Barrier Integrity===
: '''Green.'''
A self-revealing NCV of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," was identified. Specifically, Exelon's Motor Operated Valve (MOV) Program procedures lacked specific instructions to prescribe an acceptable frequency for performing valve stem lubrication, which resulted in test failures of safety-related MOVs and affected the reliability of the MOVs' safety functions.
 
On Unit 2, the inspectors determined that the finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). In accordance with IMC 0609, Attachment 4, the inspectors determined that the finding was of very low safety significance (Green)because it was not a design or qualification deficiency, did not represent a loss of system safety function, and was not associated with any external events. On Unit 3, the inspectors determined that the finding was more than minor because it was associated with the configuration control attribute of the Barrier Integrity Cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers (e.g., containment) protect the public from radionuclide releases caused by accidents or events. In accordance with IMC 0609, Attachment 4, the inspectors determined that the finding was of very low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of reactor containment. For both units, this finding has a cross-cutting aspect in the area of Problem Identification and Resolution (PI&R), Corrective Action Program, because PBAPS did not thoroughly evaluate problems such that the resolutions addressed the causes and extent of condition [P.1(c)]. Specifically, PBAPS failed to thoroughly evaluate previous conditions of degraded and hardened grease on safety-related valves, such that the extent of the condition was considered and the cause was resolved. (Section 4OA2)
 
===Other Findings===
A violation of very low safety significance, which was identified by the licensee, has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's CAP. This violation and the licensee's corrective action tracking numbers are listed in Section 4OA7 of this report.
 
5


=REPORT DETAILS=
=REPORT DETAILS=


===Summary of Plant Status===
Unit 2 began the inspection period at 100 percent rated thermal power (RTP). On April 24, a power reduction to 23 percent RTP was conducted in response to continued degradation and heating of electrical components in the electro-hydraulic control (EHC) system. On April 26, the unit was returned to full power. Unit 2 remained at or near full power for the remainder of the inspection period.
Unit 3 began the inspection period at 100 percent RTP. On May 22, power was reduced to 75 percent RTP to support planned summer readiness maintenance and adjustments to a RRP MG set voltage regulator. An unplanned power reduction from 75 percent to 32 percent occurred when the 3 'A' RRP tripped during the adjustments to its MG set voltage regulator. On May 25, the unit was returned to full power. On June 13, 2009, the unit was reduced to 62 percent for emergent maintenance to repair degrading condenser in-leakage on the 3 'B' main feed pump turbine exhaust expansion joint. On June 14, 2009, the unit was returned to full power. Unit 3 remained at or near full power for the remainder of the inspection period.
===1. ===
==REACTOR SAFETY==
==REACTOR SAFETY==
.............................................................................................................. 5 1R01 Adverse Weather Protection ............................................................................................ 5 1R04 Equipment Alignment ....................................................................................................... 6 1R05   Fire Protection ................................................................................................................. 7 1R11 Licensed Operator Requalification Program .................................................................... 8 1R12 Maintenance Effectiveness ............................................................................................. 9 1R13 Maintenance Risk Assessments and Emergent Work Control ......................................... 9 1R15 Operability Evaluations .................................................................................................. 10 1R18 Plant Modifications ........................................................................................................ 10 1R19 Post-Maintenance Testing ............................................................................................. 11 1R22 Surveillance Testing ...................................................................................................... 11 1EP6  EP Drill Evaluation
Cornerstones:  Initiating Events, Mitigating Systems, and Barrier Integrity
 
{{a|1R01}}
==1R01 Adverse Weather Protection (71111.01 - 2 Samples)==
 
===.1 Grid Reliability===
 
====a. Inspection Scope====
The inspectors reviewed plant features and procedures for operation and continued availability of offsite and backup power systems during adverse weather (summer conditions). The inspectors reviewed communication protocols between the control room personnel and electrical system operations, as well as measures prescribed and taken to maintain the availability and reliability of these alternating current (AC) systems. Documents reviewed during this inspection are listed in the Attachment.
 
====b. Findings====
No findings of significance were identified.
 
===.2 Summer Seasonal Readiness Preparations===
 
====a. Inspection Scope====
The inspectors conducted a review of PBAPS's preparations for the 2009 summer conditions to verify selected features of the plant's design were sufficient to protect mitigating systems from the effects of adverse weather. The inspectors reviewed PBAPS's implementation of procedure WC-AA-107, "Seasonal Readiness," in preparation for summer season readiness. Documentation for selected risk-significant systems was reviewed to ensure that these systems would remain functional when challenged by inclement weather. During the inspection, the inspectors focused on plant specific design features and the licensee's procedures used to mitigate or respond to adverse weather conditions. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and performance requirements for systems selected for inspection. The inspectors reviewed CAP records to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their CAP.
 
In addition, the inspectors reviewed the "Certification of 2009 Summer Readiness" memorandum dated May 15, 2009. Documents reviewed during this inspection are listed in the Attachment. The inspectors walked down the following systems and equipment:
* Intake Structure Ventilation System
;
* Emergency Diesel Generator (EDG) Building Ventilation System; and
* 'A' Supplemental Cooling Tower.
 
====b. Findings====
No findings of significance were identified.
{{a|1R04}}
==1R04 Equipment Alignment==
 
===.1 Partial Walkdown (71111.04Q - 3 Samples)===
 
====a. Inspection Scope====
The inspectors performed a partial walkdown of three systems to verify the operability of redundant or diverse trains and components when safety-related equipment was inoperable. The inspectors reviewed selected applicable operating procedures, walked down system components, and verified that selected breakers, valves, and support equipment were in the correct position to support system operation. Documents reviewed during this inspection are listed in the Attachment. The inspectors walked down the systems below:
* E-1 EDG with E-3 EDG Out-Of-Service (OOS);
* E-2, 3, and 4 EDGs with E-1 OOS; and
* 'A' Control Room Chilled Water System with 'B' Control Room Chilled Water System OOS.
 
====b. Findings====
No findings of significance were identified.
 
===.2 Complete Walkdown (71111.04S - 1 Sample)===
 
====a. Inspection Scope====
The inspectors performed a complete system walkdown of the accessible portions of the Unit 2 reactor core isolation cooling system (RCIC), verifying that accessible breakers, valves and support equipment were properly aligned to support system operation. The inspectors reviewed system operating procedures and piping and instrumentation drawings; walked down control system components; and verified that circuit breakers and valves were in the appropriate positions. Documents reviewed during this inspection are listed in the Attachment.
 
====b. Findings====
No findings of significance were identified
 
{{a|1R05}}
==1R05 Fire Protection==
 
===.1 Fire Protection - Tours (71111.05Q - 5 Samples)===
 
====a. Inspection Scope====
The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment. The inspectors reviewed areas to assess if PBAPS had implemented the Peach Bottom Fire Protection Plan (FPP) and adequately: controlled combustibles and ignition sources within the plant; maintained fire detection and suppression capability; and maintained the material condition of passive fire protection features. For the areas inspected, the inspectors also verified that PBAPS had followed the Technical Requirements Manual (TRM) and the FPP when compensatory measures were implemented for OOS, degraded, or inoperable fire protection equipment, systems, or features. The inspectors verified:  that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient combustible materials were managed in accordance with plant procedures; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. Documents reviewed during this inspection are listed in the Attachment. The inspectors toured the following areas:
* Unit 3 Reactor Building Closed-Cooling Water (RBCCW) Room, Unit 3 Radwaste Building, 116' Elevation (Fire Zone 12B);
* Unit 3 High-Pressure Coolant Injection (HPCI) Room, Unit 3 Reactor Building, 88' Elevation (Fire Zone 62);
* Unit 2 RRP MG Set Room, Radwaste Building, 135' Elevation (Fire Zone 4C);
* Main Control Room, Turbine Building, 165' Elevation (Fire Zone 108); and
* Unit 3 Lube Oil Tank Room, Turbine Building, 116' Elevation (Fire Zone 89).
 
====b. Findings====
No findings of significance were identified.
 
===.2 Annual Fire Protection Drill Observation (71111.05A - 1 Sample)===
 
====a. Inspection Scope====
On April 16, 2009, the inspectors observed fire brigade classroom training and live-fire drills at the PECO Energy Fire Academy in West Conshohocken, Pennsylvania. The inspectors noted that the classroom training provided a refresher on the Incident Management System and its techniques, methods, and terminology that are used to manage fire fighting or hazardous material events.
 
The inspectors noted that the live-fire fighting was done in burn facilities that simulated a transformer oil fire and fire involving plant cabling and equipment. The observation was used to determine whether appropriate learning opportunities were provided and to determine the readiness of the plant fire brigade to fight fires. The inspectors verified that the PBAPS fire brigade participants and the training instructors identified deficiencies; openly discussed them in a self-critical manner at the drill debrief, and appropriately documented the identified issues to develop corrective actions for future training. Specific attributes evaluated were:
* Proper Wearing of Turnout Gear and Self-contained Breathing Apparatus;
* Proper Use and Layout of Fire Hoses;
* Employment of Appropriate Fire Fighting Techniques;
* Sufficient Fire Fighting Equipment Brought to the Scene;
* Effectiveness of Fire Brigade Leader Communications, Command, and Control;
* Search for Victims and Propagation of the Fire Into Other Plant Areas;
* Smoke Removal Operations;
* Use of Pre-planned Strategies;
* Adherence to the Pre-planned Drill Scenario; and
* Drill Objectives.
 
The inspectors verified that procedure RT-F-101-922-2, "Fire Drill," was completed to record the fire drill scenario used, document that the drill objectives were met, and capture the critique results.
 
====b. Findings====
No findings of significance were identified.
{{a|1R11}}
==1R11 Licensed Operator Requalification Program (71111.11Q - 1 Sample)==
 
===.1 Resident Inspector Quarterly Review===
 
====a. Inspection Scope====
On June 23, 2009, the inspectors observed two crews of licensed operators in the plant's simulator during licensed operator requalification examinations to verify that operator performance was adequate, evaluators were identifying and documenting crew performance deficiencies, and training was being conducted in accordance with licensee procedures. The crew's performance was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed during this inspection are listed in the Attachment. The inspectors evaluated the following areas:
* Licensed Operator Performance;
* Crew's Clarity and Formality of Communications;
* Ability to Take Timely Actions in the Conservative Direction;
* Prioritization, Interpretation, and Verification of Annunciator Alarms;
* Correct Use and Implementation of Abnormal and Emergency Procedures;
* Control Board Manipulations;
* Oversight and Direction from Supervisors; and
* Ability to Identify and Implement Appropriate Technical Specification (TS) Actions and Emergency Plan Actions and Notifications.
 
====b. Findings====
No findings of significance were identified.
{{a|1R12}}
==1R12 Maintenance Effectiveness (71111.12Q - 2 Samples)==
 
====a. Inspection Scope====
The inspectors evaluated PBAPS's work practices and follow-up corrective actions for safety-related structures, systems, and components (SSCs) and identified issues to assess the effectiveness of PBAPS's maintenance activities. The inspectors reviewed the performance history of SSCs and assessed Exelon's extent-of-condition (EOC) determinations for those issues with potential common cause or generic implications to evaluate the adequacy of the PBAPS's corrective actions. The inspectors assessed PBAPS's PI&R actions for these issues to evaluate whether PBAPS had appropriately monitored, evaluated, and dispositioned the issues in accordance with Exelon procedures and the requirements of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance."  In addition, the inspectors reviewed selected SSC classifications, performance criteria and goals, and Exelon's corrective actions that were taken or planned, to evaluate whether the actions were reasonable and appropriate. Documents reviewed during this inspection are listed in the Attachment. The inspectors reviewed the following two samples:
* Repeat Master Trip Solenoid Valve (MTSV) Issues (IR 918352); and
* Apparent Cause Evaluation for Tritium Increase in Groundwater Monitoring Well #4 (IR 808183).
 
====b. Findings====
No findings of significance were identified.
{{a|1R13}}
==1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 4 Samples)==
 
====a. Inspection Scope====
The inspectors evaluated PBAPS
=s implementation of their Maintenance Risk Program with respect to the effectiveness of risk assessments performed for maintenance activities that were conducted on SSCs. The inspectors also verified that the licensee managed the risk in accordance with 10 CFR Part 50.65(a)(4) and procedure WC-AA-101, AOn-line Work Control Process."  The inspectors evaluated whether PBAPS had taken the necessary steps to plan and control emergent work activities and to manage overall plant risk. The inspectors selectively reviewed PBAPS's use of the online risk monitoring software, and daily work schedules. The activities selected were based on plant maintenance schedules and systems that contributed to risk. Documents reviewed during this inspection are listed in the Attachment. The inspectors reviewed the following samples:
* Emergent Power Reduction for Work to Correct Heating of Two Relays in the Unit 2 EHC System (Work Order (WO) C0227471 & IR 870284-08);
* Work Activities Associated with Unit 2 Residual Heat Removal (RHR) Discharge Valve MO-2-10-154B and Unit 3 RHR Pump Suction Valve MO-3-10-13D Underthrust Conditions (WO C0228319);
* Foreign Material was Found in Unit 3 'A' EHC Pump's Discharge Filter (WO C0228763); and
* Exceeded Adverse Condition Monitoring Plan (ACMP) Action Level for Unit 3 Main Condenser (WO A1714585).
 
====b. Findings====
No findings of significance were identified.
{{a|1R15}}
==1R15 Operability Evaluations (71111.15 - 4 Samples)==
 
====a. Inspection Scope====
The inspectors assessed the technical adequacy of the operability evaluations, the use and control of compensatory measures, and compliance with the licensing and design bases. Associated ACMPs, engineering technical evaluations, and operational and technical decision making documents were also reviewed. The inspectors verified these processes were performed in accordance with the applicable administrative procedures and were consistent with NRC guidance. Specifically, the inspectors referenced procedure OP-AA-108-115, "Operability Determinations," and NRC IMC Part 9900, "Operability Determinations & Functionality Assessments for Resolutions of Degraded or Nonconforming Conditions Adverse to Quality or Safety."  The inspectors also used Technical Specifications (TSs), TRM, UFSAR, and associated Design Basis Documents as references during these reviews. Documents reviewed during this inspection are listed in the Attachment. The inspectors reviewed the following samples:
* Determine the Scope of Torus Material and Method (Wet\Dry) that Requires Recoat in Unit 2 [P2R19] and Unit 3 [P3R18] Refueling Outages (IR 873016-03);
* Electrical Distribution Bases (3.8.7) Potential Needs Upgraded (IR 894904);
* Exceeded ACMP Action Levels for Unit 3 Main Condenser Air In-Leakage (IR 928762); and
* Unit 2 Reactor Recirculation Motor Breaker Action Level Changed from BLUE to YELLOW (IR 881184).
 
====b. Findings====
No findings of significance were identified.
{{a|1R18}}
==1R18 Plant Modifications (71111.18 - 1 Sample)==
 
===.1 Temporary Modifications===
 
====a. Inspection Scope====
The inspectors reviewed one temporary modification to verify that implementation of the modification did not place the plant in an unsafe condition. The review was also conducted to verify that the design bases, licensing bases, and performance capability of risk significant SSCs had not been degraded as a result of these modifications. The inspectors verified the modified equipment alignment through control room instrumentation observations; UFSAR, drawings, procedures, and WO reviews; and plant walkdowns of accessible equipment. Documents reviewed during this inspection are listed in the Attachment. The inspectors reviewed the following sample:
* ECR 09-00078 000, Re-Route Cables from Damaged Duct Bank To Support Duct Bank Repair.
 
====b. Findings====
No findings of significance were identified.
{{a|1R19}}
==1R19 Post-Maintenance Testing (71111.19 - 7 Samples)==
 
====a. Inspection Scope====
The inspectors observed selected portions of post-maintenance testing (PMT) activities and reviewed completed test records. The inspectors observed whether the tests were performed in accordance with the approved procedures and assessed the adequacy of the test methodology based on the scope of maintenance work performed. In addition, the inspectors assessed the test acceptance criteria to evaluate whether the test demonstrated that the tested components satisfied the applicable design and licensing bases and the TS requirements. The inspectors reviewed the recorded test data to verify that the acceptance criteria were satisfied. Documents reviewed during this inspection are listed in the Attachment. The inspectors reviewed the following samples:
* Perform Leak Sealant Injection on Regenerative Heat Exchanger Tube Side Outer Vent Valve (WO C0228895);
* 2 'A' Drywell Chiller, Rebuild and Eddy Current Test (WO C0220912);
* 2 'A' CAD Analyzer Failed to Trip During ST-I-07G-103-2 (WO C0229040);
* Replace Tube Bundles in the E-1 EDG (WO C0225963);
* Replace 'A' Control Room Supply Fan Motor (WO C0229077);
* Troubleshoot EDG E-1 Speed Switch, Rework as Required (WO C0229510); and
* Replace 3B EHC Micron Filter (WO M1716915).
 
====b. Findings====
No findings of significance were identified.
{{a|1R22}}
==1R22 Surveillance Testing (71111.22 - 5 Samples)==
 
====a. Inspection Scope====
The inspectors compared test data with established acceptance criteria to verify the systems demonstrated the capability of performing the intended safety functions. The inspectors also verified that the systems and components maintained operational readiness, met applicable TS requirements, and were capable of performing design basis functions. Documents reviewed during this inspection are listed in the Attachment. The inspectors reviewed the following samples:
* RT-O-01D-402-2, Master Trip Solenoid Valves Operability Test;
* SI3P-5-12-C1C2, Calibration Check of reactor protection system (RPS) Drywell Pressure Loop Instruments PT/PS 3-5-12C;
* ST-M-40D-905-2, Control Room Emergency Ventilation Filter Train 'A' Test;
* ST-O-010-301-2, 2 'A' RHR Loop Pump, Valve, Flow, and Unit Cooler Functional and Inservice Test [Inservice Test Sample]; and
* ST-O-020-560-2, Reactor Coolant Leakage Test [RCS Leakage Sample].
 
====b. Findings====
No findings of significance were identified.
 
===Cornerstone:===
Emergency Preparedness (EP)
 
1EP6 EP Drill Evaluation (71114.06 - 1 Drill Sample)
 
====a. Inspection Scope====
The inspectors evaluated the conduct of a PBAPS emergency drill on June 1, 2009, to identify any weaknesses and deficiencies in classification and notification activities. The drill was conducted to provide drill and exercise performance (DEP) opportunities for the DEP performance indicator (PI). The inspectors observed operators respond to events in the simulator control room through the declaration and notification of an alert. The inspectors observed the operations shift manager transition emergency response command and control responsibilities to the site emergency director in the technical support center (TSC). The inspectors relocated to the TSC to observe command and control of the emergency response organization and dose assessment as the event escalated to the declaration and notification of a site area emergency. The inspectors verified that the event classification and notifications were done in accordance with EP-AA-1007, "Exelon Nuclear Radiological Emergency Plan Annex for PBAPS."  The inspectors verified that the drill evaluators correctly counted the drill's contribution in the calculation of the DEP PI. The inspectors also verified that operations personnel in the simulator control room identified weaknesses or deficiencies during the critique of the drill. The following simulated events were classified during this training exercise:
* FS1 - Site Area Emergency, Fission Product Barrier Degradation; and
* HA5 - Alert, Natural and Destructive Phenomena.
 
====b. Findings====
No findings of significance were identified.


==OTHER ACTIVITIES==
==OTHER ACTIVITIES==
----------------------------....... 13
{{a|4OA1}}
{{a|4OA1}}
==4OA1 Performance Indicator Verification==
==4OA1 Performance Indicator Verification (71151 - 10 Samples)==
  ................................................................................ 12
 
===Cornerstone:===
Initiating Events and Barrier Integrity
 
===.1 Initiating Events PIs (71151 - 6 Samples)===
 
====a. Inspection Scope====
The inspectors sampled PBAPS's submittals for the PIs listed below for Units 2 and 3 for the period from January 2008 through March 2009. PI definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, were used to verify the accuracy of the PI data. The inspectors reviewed selected portions of the operating logs and raw PI data, and selected applicable licensee event reports and CAP documents from the period for each PI specified below. The inspectors compared graphical representations from the most recent PI report to the raw data and used the performance indicator definition in the NEI guideline to verify that the data were correctly reflected in the report. Documents reviewed during this inspection are listed in the Attachment. The following six PI samples were reviewed:
Units 2 and 3
* Unplanned Scrams;
* Unplanned Scrams with Complications; and
* Unplanned Power Changes.
 
====b. Findings====
No findings of significance were identified.
 
===.2 Barrier Integrity PIs (71151 - 4 Samples)===
 
====a. Inspection Scope====
The inspectors reviewed a sample of PBAPS's submittals for the four Barrier Integrity PIs listed below to verify the accuracy of the data reported. The PI definitions and the guidance contained in NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, and Exelon procedure LS-AA-2001, "Collecting and Reporting of NRC Performance Indicator Data," were used to verify that the reporting requirements were met. The inspectors reviewed raw PI data collected since January 2008 to April 2009 and compared graphical representations from the most recent PI report to the raw data to verify the data was included in the report. Documents reviewed during this inspection are listed in the Attachment. The following four PI samples were reviewed:
Units 2 and 3
* Reactor Coolant System (RCS) Specific Activity; and
* RCS Leakage.
 
{{a|4OA2}}
{{a|4OA2}}
==4OA2 Identification and Resolution of Problems (PI&R)==
==4OA2 Identification and Resolution of Problems (PI&R)==
  ......................................................... 13
 
(71152 - 2 Samples)1. Annual Sample:  MOV Hardened Grease Challenges (1 In-depth Review Sample)
 
====a. Inspection Scope====
This inspection focused on Exelon's identification, evaluation, and resolution of challenges associated with hardened grease on safety-related MOV. Specifically, two HPCI valves failed to stroke to the full open position during surveillance testing on March 12 and March 21, 2009. MOV disassembly and inspection identified hardened grease on the stem and inside the stem nut of both valves. Initial extent-of-condition evaluations revealed that two RHR valves developed less-than-required closing thrust for successful diagnostic test acceptance. Hardened grease was also identified on the stem and inside the stem nut of both RHR valves. The final extent-of-condition scoping determined that 45 safety-related MOVs required additional evaluation appropriate to the circumstances, such as visual inspection, grease evaluation, diagnostic testing, and/or corrective maintenance.
 
The inspectors reviewed Exelon's associated root cause evaluation, operability evaluations, corrective action reports, and a sample of diagnostic and stroke time test data, and interviewed plant personnel to evaluate the adequacy of Exelon's performance in the areas of problem identification, evaluation, extent-of-condition scoping, and corrective actions. Additionally, the inspectors observed the integrity of damaged, worn, and newly machined stem nuts to evaluate the effect of plant conditions on stem nut integrity. Finally, the inspectors reviewed MOV program procedures to evaluate the quality and effectiveness of the Exelon MOV program, as implemented at PBAPS. Documents reviewed are listed in the Attachment.
 
====b. Findings and Observations====
Introduction
:  A Green, self-revealing NCV of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," was identified. Specifically, Exelon's MOV Program procedures lacked specific instructions to prescribe an acceptable frequency for performing valve stem lubrication, which resulted in test failures of safety-related MOVs and affected the reliability of the MOVs' safety functions.
 
=====Description:=====
During quarterly surveillance testing performed by Exelon on March 12, 2009, the Unit 2 HPCI torus inboard suction MOV (MO-2-23-058) failed to stroke full open during its quarterly surveillance test and was subsequently declared inoperable. Investigation by Exelon identified dried and hardened grease on the valve stem and stem nut, and a root cause investigation was assigned to Exelon engineering staff.
 
Extent-of-condition inspections were performed by Exelon on select HPCI MOVs over the next several days. Degraded grease was identified on the outboard torus suction MOV for Unit 3 (MO-3-23-057), but the condition was determined not to impact valve operability. Exelon rescheduled the periodic stem lubrication interval on the Unit 3 HPCI MOV from ten years to six years, and assigned this PM to the next Unit 3 refueling outage (fall of 2009). Subsequently, on March 21, 2009, the Unit 3 HPCI torus outboard suction MOV failed to stroke full open during quarterly surveillance testing and was declared inoperable. Investigation by Exelon identified hardened grease on the stem and inside the stem nut, as well as stem nut wear. As a result of the failure, Exelon expanded the extent-of-condition scope to include diagnostic testing of MOVs on both units within the affected HPCI valve group (total of 6 MOVs), as well as eleven other safety-related MOVs based on diagnostic test data margins, as well as similar stem characteristics.
 
During the diagnostic testing of the Unit 3 RHR loop 'D' torus suction MOV  (MO-3-10-13D) on March 26, 2009, Exelon identified less-than-required thrust at the torque switch trip, and the valve was subsequently declared inoperable. Investigation by Exelon revealed that the stem grease was degraded and several stem nut threads were damaged. As a result of this test failure, the extent-of-condition scope was again expanded. Exelon concluded that 45 safety-related MOVs required additional evaluation, such as visual inspection, grease evaluation, diagnostic testing, and/or corrective maintenance. This review identified one additional MOV under-thrust condition on the Unit 2 RHR loop 'B' outboard discharge MOV (MO 2-10-154B) during diagnostic testing on April 2, 2009. Exelon investigation into this MOV test failure identified a degraded grease condition, and the MOV was declared inoperable. The NRC inspectors reviewed the final extent-of-condition scoping, and found that it was appropriate to the circumstances.
 
Exelon performed immediate corrective actions after each of the MOV failures, which included cleaning and removing the old grease from the stem and stem nut area, applying new grease, and performing diagnostic testing to ensure successful valve performance. Exelon performed operability evaluations for each of the four MOV failures, and concluded three of the four MOVs would have been capable of performing their intended safety function for all design basis events. The operability evaluation for the Unit 3 RHR loop 'D' torus suction MOV concluded that the valve would not have been able to perform its safety function of containment isolation for all design basis events.
 
Operability evaluations for the other three MOVs determined that the valves would have been capable of performing their safety functions for all design basis events. The Unit 2 RHR loop 'B' discharge MOV is normally open in a standby mode for low pressure coolant injection, and was evaluated for its design function to close during suppression pool cooling and containment spray modes of the RHR system. Exelon concluded that the valve motor torque capability would have provided enough inertia to hard seat the valve from the as-found torque switch trip condition in the extent-of-condition diagnostic test. The operability evaluations for the Unit 2 and Unit 3 HPCI torus suction MOVs stated that the torque switch trip protection, which stopped the valve from completely opening through the degraded grease conditions during the surveillance tests, is bypassed during safety actuation signals to open. Exelon determined that the valve motor torque capability, absent torque switch trip protection, was sufficient to open the valve during all design basis events despite the degraded grease conditions. The inspectors reviewed the operability evaluations and agreed that Exelon's conclusions regarding past operability were reasonable. However, the capability of the MOVs to perform their mitigating safety functions was challenged, thereby impacting their reliability.
 
A root cause evaluation was performed by Exelon in response to the four MOV failures. The root cause evaluation determined that Peach Bottom MOV PM frequencies and actions had not appropriately included stem lubricant performance feedback. The NRC inspectors reviewed the root cause evaluation and agreed that an adequate MOV program would schedule and adjust PM activities as necessary to assure that safety-related MOVs can perform their functions as required. The root cause evaluation stated that Exelon had the longest allowable MOV PM lubrication intervals in the entire nuclear fleet (up to 10 years). Previous industry guidance and vendor information had described Exxon Nebula Extreme Pressure (EP) - 1, the MOV lubricant used at PBAPS, as being susceptible to degradation and hardening phenomena. The Exelon root cause identified that Exxon cancelled production of Nebula EP-1 in 2001, stating a one-year limited shelf life. Additionally, the EOC inspections performed by Exelon identified mixtures of Nebula EP-1, along with some remains of the former PBAPS MOV lubricant, N5000 NeverSeez, on several valve stems and stem nuts. Industry guidance has noted that NeverSeez is incompatible with Nebula EP-1 due to an accelerated hardening and degradation effect. Finally, since using EP-1 grease, Peach Bottom had many opportunities to re-evaluate their MOV PM lubrication frequencies and actions, including:
* October 2006: MO-3-10-026B failed to successfully stroke. Internal inspection identified severely degraded grease, and the stem nut was replaced.
* October 2007: NRC PI&R inspection of the October 2006 MO-3-10-026B failure to stroke noted that although Exelon identified a hardened grease condition, this was not determined to be the most probable cause of the failure, and no EOC evaluation was performed. Subsequent walkdowns by the inspector identified degraded lubricating grease on MO-3-10-031A. Exelon staff noted that the grease appeared to be a mixture of EP-1 and NeverSeez. (IR 689020). This was documented in NRC Inspection Report 05000277&278/2007005.
* October 2008: MO-2-23-057 (Unit 2 HPCI outboard torus suction MOV) stroked slowly and failed to close. Degraded lubricating grease and stem nut wear were identified, and the stem nut was replaced.
* January 2009: MO-3-01A-077 failed to go full open. The valve stem was cleaned and re-lubricated and the stroke time decreased.
 
=====Analysis:=====
The inspectors determined that Exelon's failure to properly implement MOV preventive maintenance activities, specifically with respect to stem lubrication necessary to assure that MOVs will function when required, constituted a performance deficiency. Specifically, degraded stem lubrication was identified as a common factor in four safety-related MOV test failures between March 12, 2009 and April 2, 2009.
 
Unit 2:  The finding for Unit 2 was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems (MS) Cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the HPCI torus inboard suction MOV and the RHR loop 'B' outboard discharge MOV experienced test failures, were declared inoperable, and required detailed operability evaluations as described above, thereby challenging their reliability and capability to perform their safety function. Using the Phase 1 worksheet in 4 of Manual Chapter 0609, "Significance Determination Process," the finding affected the MS Cornerstone and was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of system safety function, and was not associated with any external events.
 
Unit 3:  The finding for Unit 3 was more than minor because it was associated with the configuration control attribute of the Barrier Integrity (BI) Cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers (e.g., containment) protect the public from radionuclide releases caused by accidents or events. Specifically, RHR loop 'D' torus suction MOV was determined by Exelon to not be capable of isolating for all design basis events. Using the Phase 1 worksheet in Attachment 4 of Manual Chapter 0609, "Significance Determination Process," the finding affected the BI cornerstone and was of very low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of reactor containment. Although the Unit 3 HPCI torus outboard suction MOV condition affected the mitigating system cornerstone, the Unit 3 finding analysis was assigned to the BI cornerstone because it best reflected the dominant risk of the finding.
 
This finding has a cross-cutting aspect in the area of PI&R, Corrective Action Program, because PBAPS did not thoroughly evaluate problems such that the resolutions addressed the causes and extent of condition [P.1(c)]. Specifically, PBAPS failed to thoroughly evaluate previous conditions of degraded and hardened grease on safety-related valves, such that the extent of the condition was considered and the cause was resolved. This cross-cutting aspect is applied to both Units 2 and 3.
 
=====Enforcement:=====
10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires, in part, that "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."  Contrary to the above, the Exelon MOV program procedures (ER-AA-300 Series and MA-AA-723-300 Series) were not appropriate to the circumstances, in that, they lacked specific instructions to prescribe an acceptable frequency for performing valve stem lubrication, given the limited shelf life of the MOV lubrication grease used by the station as described in the above section. As a consequence of this, four safety-related MOVs experienced test failures between March 12, 2009 and April 2, 2009, attributed to degraded and hardened lubricating grease. Because this finding is of very low safety significance and has been entered into Exelon's CAP (IR 892191), this violation is being treated as a Green NCV consistent with section VI.A.1 of the NRC Enforcement Policy:  NCV 05000277/2009003-01, and NCV 05000278/2009003-01, MOV Program Procedures were Inadequate with Regard to Periodicity of Preventive Maintenance Activities for Stem Lubrication.
 
===.2 Semi-Annual Review to Identify Trends (1 Trend Review Sample)===
 
====a. Inspection Scope====
The inspectors reviewed lists of CAP items to identify trends (either NRC or licensee identified) that might indicate the existence of a safety issue. First, the inspectors reviewed a list of approximately 7,250 IRs that PBAPS initiated and entered into the CAP action tracking system from December 1, 2008 through June 1, 2009. The inspectors also reviewed the approximately 3450 IRs that remained open with outstanding actions. The list was reviewed and screened to complete the required semi-annual PI&R trend review. Based on the review, a sample of 58 IRs (listed in the  Attachment) were selected for a more detailed review to determine whether the issues were adequately identified and evaluated, and that corrective actions were planned. The inspectors evaluated the IRs against the requirements of Exelon procedure, LS-AA-125, and 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action."
 
====b. Findings and Observations====
Based on the review, the inspectors observed that there was an adverse trend of human performance related events during the period. Specific examples included:
* the inadequate configuration control of an inoperable control rod (IR 880318);
* inadequate risk assessment and maintenance practices for work on the control circuitry for containment isolation valves (IR 887441);
* inadequate procedure adherence that resulted in the trip of a RRP (IR 923239);
* an inadequate understanding of the maintenance and operation of a WRNM channel (IR 871864); and,
* removal, for inspection, of an incorrect pin from a spent fuel bundle (IR 853625).
 
The inspectors also noted an adverse trend in equipment reliability issues that challenged plant operations. Specifically:
* the build-up of combustible gases in the 3 'A' main power transformer that resulted in an unplanned power reduction (IR 868369);
* the failure of EHC cards that led to an unplanned power reduction in response to turbine bypass valve cycling (IR 891763);
* indications of friction between selected Unit 3 control rods and fuel channels (IR 874398); and,
* inoperable motor operated valves that resulted from inadequate preventive maintenance and hardened grease (IRs 892191 and 913965).
 
However, the inspectors noted that PBAPS self-identified an adverse trend in station performance and proactively performed a common cause analysis (IR 896381) to understand the causes for the adverse trend and to identify corrective actions and improvement plans.
 
===.3 Review of Items Entered into the CAP===
 
As required by IP 71152, "Identification and Resolution of Problems," and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed screening of all items entered into the licensee' CAP. This was accomplished by reviewing the description of each new action request/issue report and attending daily management review committee meetings.
 
{{a|4OA3}}
{{a|4OA3}}
==4OA3 Follow-up of Events and Notices of Enforcement Discretion==
==4OA3 Follow-up of Events and Notices of Enforcement Discretion (71153 - 4 Samples)==
  ......................................... 18
 
===.1 Personnel Performance - 3 'A' RRP Trip===
 
====a. Inspection Scope====
The inspectors reviewed corrective action documents listed in the Attachment to this report and discussed the events surrounding the trip of the 3 'A' RRP with the personnel involved. The inspectors reviewed Revision 4 of IC-11-02011, "Recirc MG Set Voltage Regulator Tuning," and Revision 3 of HU-AA-104-101, "Procedure Use and Adherence."
 
====b. Findings====
 
=====Introduction:=====
A Green, self-revealing finding occurred when PBAPS personnel incorrectly performed a maintenance procedure for tuning the 3 'A' RRP MG set voltage regulator. Specifically, maintenance personnel adjusted a potentiometer in the wrong direction which resulted in a trip of the RRP and an unplanned Unit 3 plant transient.
 
=====Description:=====
On May 23, 2009, at approximately 9:30 a.m., the PBAPS Unit 3 'A' RRP tripped. The trip occurred while instrument and controls (I&C) maintenance technicians were performing procedure IC-11-02011, "Recirc MG Set Voltage Regulator Tuning,"
step 5.1.6.8. Step 5.1.6.8 states, "Verify step test box potentiometer is at MAXIMUM resistance (fully counter-clockwise) and CLOSE the switch of the step test circuit."  Contrary to the procedure instructions, the potentiometer, on the step test box, that is used to vary the test current applied to the RRP MG set voltage regulator field, was incorrectly positioned to the minimum resistance (fully clockwise) position. When the test box switch was closed, the incorrect positioning of the potentiometer resulted in an excessive MG set field current that tripped the MG set field breaker.
 
The trip of the MG set field breaker resulted in the loss of the 3 'A' RRP. The loss of core flow caused reactor power to decrease from approximately 75 percent to 33 percent. In response to the loss of the 3 'A' RRP, operators entered operational transient procedure, OT-112, "Unexpected/Unexplained Change in Core Flow" and executed actions to stabilize the plant in single loop operations. I&C personnel aborted the performance of IC-11-02011 and removed all test equipment. The 3 'A' RRP was subsequently restored per system operating procedure, SO 2A.1.B-3, "Starting the Second Recirculation Pump" at 4:32 p.m. the same day.
 
PBAPS's investigation indicated that there was a mindset among the technicians performing the work that the potentiometer had to be set to the maximum position and that this position was fully clockwise. Interviews with several I&C technicians indicated that the word "MAXIMUM" as it relates to the operation of variable inputs almost always refers to the fully clockwise position. During the pre-job brief there was no mention of rotating the potentiometer either clockwise or counter-clockwise, only of taking it to maximum. When the technicians reached the job site, the first technician verified the test box was in the maximum position by attempting to rotate the potentiometer in the clockwise position. The technician then announced what his actions were and handed the procedure to a second technician who read the step and took the same action to verify the potentiometer position. This peer check was flawed because the first technician inappropriately took the action without a peer check and then asked for a peer check after the action was taken. The job supervisor was present during the entire evolution providing management oversight, and failed to notice the incorrect position of the potentiometer.
 
Following the incorrect setting of the potentiometer, the technicians moved the test box switch from the OPEN to the CLOSE position which inserted the test signal and tripped the 3 'A' MG set and RRP. Immediately after the event, the technicians and their supervisor checked the connections and potentiometer position and all agreed the setup was correct. When the team reached the main control room, the procedure was re-read and the technicians realized the error in the positioning of the test box potentiometer.
 
The inspectors reviewed the root cause report to assess its details, accuracy, and planned corrective actions. The inspectors concluded that the root cause report was thorough, detailed, and comprehensive. The planned and completed corrective actions were appropriate and comprehensive. The licensee identified two root causes and two contributing causes for this event. The root causes included failure to adhere to a Level 1 (step-by-step performance) procedure due to performing work in a knowledge-based versus rule-based manner and the failure to perform an adequate peer check to verify the potentiometer position that resulted in a lost opportunity to identify the error prior to the plant transient. PBAPS's investigation determined that the technician performing the work was operating in the knowledge-based thinking mode because he knew that the potentiometer needed to be in the maximum position. If the technician had operated in the rule-based thinking mode, he would have been complying with the procedure instructions verbatim. The peer check was flawed in that the first technician took the action without a peer check and inappropriately asked the second technician for a peer check after the action was taken.
 
=====Analysis:=====
The inspectors determined that the I&C technician's failure to follow the procedure for tuning the 3 'A' RRP MG set voltage regulator that resulted in a trip of the RRP MG set and an unplanned plant transient was a performance deficiency. This finding was more than minor because it was associated with the human performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions. Specifically, this error resulted in an unplanned plant transient that reduced Unit 3 reactor power from 75 percent to 33 percent. In accordance with IMC 0609, Attachment 4, the inspectors determined this finding to be of very low safety significance (Green) since the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available.
 
This finding has a cross-cutting aspect in the area of human performance, Work Practices, because PBAPS did not define and effectively communicate expectations regarding procedural compliance and personnel did not follow procedures [H.4(b)].
Specifically, PBAPS personnel did not follow procedure IC-11-02011 instructions for tuning the 3 'A' RRP MG set voltage regulator
 
=====Enforcement:=====
The inspectors determined that the finding did not represent a violation of regulatory requirements because it involved a procedure violation of a non-safety related procedure. This finding will be tracked as FIN 05000278/2009003-02 , Inadequate Procedure Adherence Results in Trip of 3 'A' Recirc Pump and Plant Transient.
 
===.2 (Closed) Licensee Event Report (LER) 05000278/2009-03-00, Inoperable Containment Isolation Valve Results in Condition Prohibited by TSs===
 
On March 26, 2009, it was discovered that the 3D RHR pump suppression pool suction isolation valve (MO-3-10-013D) was degraded due to a greasing deficiency identified during performance of EOC testing associated with grease deficiencies previously discovered on motor-operated valves (MOVs). It was determined that this condition was prohibited by TSs since this valve is a primary containment isolation valve and was inoperable for containment isolation purposes for a time period longer than allowed by TS. The cause of the greasing deficiency was grease hardening primarily due to inadequate preventive maintenance. The valve was repaired and returned to service on March 27, 2009. A finding related to this event was documented in report section 4OA2.1. This LER is closed.
 
===.3 (Closed) LER 05000277/2009-01-00, Clearance Performance Error Results in Condition Prohibited by TSs===
 
On February 13, 2009, PBAPS personnel discovered that an operation prohibited by TS existed when a TS required action for an inoperable Unit 2 control rod (Control Rod 10-51) was found not met. Specifically, at 9:33 a.m. on February 13, during a plant walkdown being conducted in preparation to vent selected control rod drive (CRD) hydraulic control units (HCUs), the CRD HCU directional control valves (DCVs) for Control Rod 10-51 were discovered to be energized (armed). To comply with  TS 3.1.3, Condition C, these DCVs should have been de-energized (disarmed) since the 10-51 CRD HCU had been rendered inoperable for the conduct of maintenance on February 11. This condition was due to an operator error that re-armed the DCV during the modification of a safety tagging clearance that occurred at approximately 5:30 a.m. on February 12, 2009. On February 13, after the TS non-compliance was identified at 9:33 a.m., prompt action was taken to disarm the CRD and restore TS compliance by 9:42 a.m. Since Control Rod 10-51 remained fully inserted during this event, PBAPS concluded that there was no actual safety consequences associated with this event. There were no previous similar LERs identified. A licensee-identified NCV for this issue is documented in Section 4OA7; therefore, this LER is closed.
 
===.4 (Closed) LER 05000278/2009-01-00, Control Rods Inoperable During Mode 2 Operations As a Result of Interferences===
 
As a result of control rod interference monitoring testing performed by Operations personnel on January 28, 2009, it was determined that three control rods were inoperable during the Unit 3 shutdown that was performed on January 21. This testing determined that Control Rods 14-55, 18-55, and 42-55 could be inoperable for operational conditions involving time periods when reactor pressure is below 850 psig (Mode 2 operations). This occurrence was considered reportable as a common cause that resulted in the inoperability of three control rods for approximately 4.75 hours on January 21, during Mode 2 operations. The common cause is related to control rod blade interferences with the fuel bundle channel. PBAPS concluded that there were no actual safety consequences associated with this event and that appropriate shutdown margin was maintained during this event. Subsequently, a control rod interference monitoring and testing program was established. EOC testing was performed on Units 2 and 3. There were no previous similar LERS identified.
 
The inspectors reviewed the event and concluded that the condition was appropriately reported as a common-cause inoperability. However, no violation or condition prohibited by TS existed because, in accordance with TS 3.1.3, Condition E, Unit 3 was taken to Mode 3 within 12 hours of reactor pressure being reduced below 850 psig; therefore, this LER is closed.
 
{{a|4OA5}}
{{a|4OA5}}
==4OA5 Other Activities .............................................................................................................. 21 4OA6==
==4OA5 Other Activities==
Meetings, Including Exit ................................................................................................. 22
 
===.1 Quarterly Resident Inspector Observations of Security Personnel and Activities===
 
====a. Inspection Scope====
During the inspection period the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working hours.
 
These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status reviews and inspection activities.
 
====b. Findings====
No findings of significance were identified.
 
{{a|4OA6}}
==4OA6 Meetings, Including Exit==
 
===Exit Meeting Summary===
 
On July 17, 2009, the resident inspectors presented the inspection results to  Mr. W. Maguire and other PBAPS staff, who acknowledged the findings. The inspectors asked the licensee whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.
 
{{a|4OA7}}
{{a|4OA7}}
==4OA7 Licensee-Identified Violations ........................................................................................ 22==
==4OA7 Licensee-Identified Violations==
 
The following violation of very low significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Policy for being dispositioned as a NCV.
* TS 3.1.3, Condition C, requires that control rods that are inoperable for reasons other than being stuck shall be fully inserted and disarmed. TS 3.1.3, Condition E, requires the unit to be in Mode 3 within 12 hours if Condition C cannot be met. On February 11, the 10-51 CRD HCU was declared inoperable for the conduct of maintenance and the TS required actions to fully insert and disarm the CRD  were met. Following the completion of maintenance on the HCU, an operator erroneously re-armed the CRD HCU DCVs during the modification of a safety tagging clearance that occurred at approximately 5:30 a.m. on February 12. Over 28 hours later and in excess of the 12-hour completion time allowed by TS 3.1.3, PBAPS personnel discovered the error and disarmed the CRD for Control Rod 10-51. PBAPS documented this issue in the CAP as IR 880318. Since Control Rod 10-51 remained fully inserted and there was no loss of safety function during the period of non-compliance, this issue is of very low (Green) safety significance. The LER associated with the event was documented in Section 4OA3.3.
 
ATTACHMENT:   
ATTACHMENT:   


Line 60: Line 468:


==KEY POINTS OF CONTACT==
==KEY POINTS OF CONTACT==
.................................................................................................. A-1
 
Exelon Generation Company Personnel
: [[contact::W. Maguire]], Site Vice President
: [[contact::G. Stathes]], Plant Manager
: [[contact::J. Armstrong]], Regulatory Assurance Manager
: [[contact::E. Flick]], Engineering Director
: [[contact::P. Navin]], Work Management Director
: [[contact::L. Lucas]], Chemistry Manager
: [[contact::R. Franssen]], Operations Director
: [[contact::R. Holmes]], Radiation Protection Manager
: [[contact::D. DeBoer]], Security Manager
: [[contact::T. Wasong]], Training Director
 
===NRC Personnel===
: [[contact::F. Bower]], Senior Resident Inspector
: [[contact::M. Brown]], Resident Inspector
: [[contact::E. Torres]], Project Engineer
: [[contact::A. Ziedonis]], Reactor Inspector
 
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
  ....................................................... A-1
 
===Opened===
None
 
===Opened/Closed===
: 05000277/2009003-01 NCV  MOV Program Procedures were 
: 05000278/2009003-01    Inadequate with Regard to Periodicity of Preventive Maintenance Activities        for Stem Lubrication          (Section 4OA2.1)
: 05000278/2009003-02  FIN  Inadequate Procedure Adherence          Results in Trip of 3 'A'
Recirc Pump and Plant          Transient (Section 4OA3.1) 
 
===Closed===
: 05000278/2009-03-00  LER  Inoperable Containment Isolation          Valve Results in Condition Prohibited by TSs (Section 4OA3.2)
: 05000277/2009-01-00  LER  Clearance Performance Error Results in Condition Prohibited by  TSs (Section 4OA3.3)
: 05000278/2009-01-00 LER  Control Rods Inoperable During Mode 2 Operations as a Result of Interferences  (Section 4OA3.4)
 
===Discussed===
None 
==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
...................................................................................... A-2
==Section 1R01: Adverse Weather Protection==
==LIST OF ACRONYMS==
: SE-16, Revision 4, "Grid Emergency"
: [[......]] [[...................................................................................................... A-9]]
: SE-16, Attachment A, Revision 2, Power Team Generation Dispatcher/Power System Director (PTGD/PSD) Communications to Peach Bottom
: [[SUMMAR]] [[Y]]
: WC-AA-104, Revision 14, "Review and Screening for Production/Atmospheric/Environmental Risk"
: [[OF]] [[]]
: WC-AA-101, Revision 16, "On-Line Work Control Procedure"
: [[FINDIN]] [[]]
: WC-AA-107, Revision 6, "Seasonal Readiness"
GS  IR 05000277/2009003, 05000278/2009003; 04/01/2009 - 06/30/2009; Peach Bottom Atomic
: WC-AA-8000, Revision 2, "Interface Procedure between Energy Delivery (ComED/PECO) and Exelon Generation (Nuclear/Power) for Construction and Maintenance Activities"
Power Station, Units 2 and 3; Identification and Resolution of Problems; Follow-up of Events and Notices of Enforcement Discretion.
: WC-AA-8003, Revision 1, "Interface Procedure between Energy Delivery (ComED/PECO) and Exelon Generation (Nuclear/Power) for Design Engineering and Transmission Planning Activities"
The report covered a three-month period of inspection by resident inspectors and an announced inspection by a regional reactor inspector. Two self-revealing findings were identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using
: OP-AA-108-107, Revision 2, "Switchyard Control"
: [[IMC]] [[0609, "Significance Determination Process" (]]
: OP-AA-108-107-1001, Revision 2, "Station Response to Grid Capacity Conditions"
: [[SDP]] [[). Findings for which the]]
: OP-AA-108-107-1002, Revision 4, "Interface Agreement between Exelon Energy Delivery and Exelon Generation for Switchyard Operations"
: [[SDP]] [[does not apply may be Green or be assigned a severity level after]]
: McDonald, John E.; "PECO Nuclear Station Switchyard Readiness Certification for Summer 2009," Memo to Michael Pacillio; May 15, 2009
: [[NRC]] [[management review. Cross-cutting aspects associated with findings are determined using]]
: IR 891537, 2009 Summer Readiness Action Item Tracking
: [[IMC]] [[0305, "Operating Reactor Assessment Program," dated January 2009. The]]
: IR 932267, Perform Permanent Repair to 'A' Cooling Tower Lift Pump Can
: [[NRC]] [['s program for overseeing the safe operation of commercial nuclear power reactors is described in]]
: IR 922632, High Acetylene Levels in the 3SU Transformer Load Tap Changer
: [[NUR]] [[]]
: IR 921521, PBAPS and PECO Summer Readiness Certification Letters Do Not Match
EG-1649, "Reactor
: IR 921205, Aging Equipment HIT - Cooling Tower LTAM Review Issues
Oversight Process," Revision 4, dated December 2006. Cornerstone: Initiating Events  * Green. A self-revealing finding was identified when
: IR 918739, Large Transformer Summer Readiness Assessment
: [[PBAPS]] [[personnel incorrectly performed a maintenance procedure for tuning the reactor recirculation pump (]]
: IR 917454, Unit 3 Switchgear House Exhaust Fan Breaker Tripped on Magnetics
RRP) motor generator (MG) set voltage regulator. Specifically, maintenance personnel
: IR 913699, Cooling Tower Walkdown Inspection
adjusted a potentiometer in the wrong direction, which resulted in a trip of the RRP and an unplanned plant transient. This finding is more than minor because the finding is associated with the human performance attribute of the Initiating Events Cornerstone, and adversely affected the
: IR 912528, Unit 2 'B' Phase Main Transformer Cooling Bank Not Turning On 
cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions. Specifically, this error resulted in an unplanned plant transient that reduced reactor power from 75 percent to 33 percent. In accordance with IMC 0609, Attachment 4, the inspectors determined this finding to be of very low safety significance (Green) since the finding did not contribute to both the likelihood of a
: A-3IR
reactor trip and the likelihood that mitigation equipment or functions would not be available. This finding has a cross-cutting aspect in the area of human performance, Work Practices, because
: 907656, Broken Joint Found on 'A' Cooling Tower Lift Pump
: [[PBAPS]] [[did not define and effectively communicate expectations regarding procedural compliance and personnel did not follow procedures [H.4(b)]. Specifically,]]
: IR 887537, Unit 3 Auxiliary Transformer Cooling Fan Not Running
PBAPS personnel did not follow procedure IC-11-02011
 
instructions for tuning the 3 'A'
==Section 1R04: Equipment Alignment==
: [[RRP]] [[]]
: Drawing 6280-M-359, 360 RCIC System
: [[MG]] [[set voltage regulator.  (Section]]
: SO 13.1.A-2, Revision 13, RCIC System Alignment for Automatic or Manual Initiation
: [[4OA]] [[3.1)  Cornerstone: Mitigating Systems and Barrier Integrity  * Green. A self-revealing]]
: COL 13.1.A-2, RCIC System
: [[NCV]] [[of]]
: COL 13.1.B-2, RCIC System Control Board Lineup
: [[10 CFR]] [[50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," was identified. Specifically, Exelon's Motor Operated Valve (]]
: COL 44B.1.A, Revision 6, Control Room Chilled Water System
: [[MOV]] [[) Program procedures lacked specific instructions to prescribe an acceptable frequency for performing valve stem lubrication, which resulted in test failures of safety-related]]
 
: [[MOV]] [[s and affected the reliability of the]]
==Section 1R05: Fire Protection==
MOVs' safety functions.
: PF-12B, Revision 3, Prefire Strategy Plan U3 RBCCW Room Radwaste Building 116,
On Unit 2, the inspectors determined that the finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the availability, reliability,
: Fire Zone 12B
and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). In accordance with IMC 0609, Attachment 4, the inspectors determined that the finding was of very low safety significance (Green)
: PF-62, Revision 4, Prefire Strategy Plan U3 HPCI Room 88' Elevation, Fire Zone 62
because it was not a design or qualification deficiency, did not represent a loss of system safety function, and was not associated with any external events. On Unit 3, the inspectors determined that the finding was more than minor because it was associated with the configuration control attribute of the Barrier Integrity Cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design
: PF-89, Revision 2, Prefire Strategy Plan Lube Oil Tank Room,
barriers (e.g., containment) protect the public from radionuclide releases caused by accidents or events. In accordance with
: TB3-116, Fire Zone 89
: [[IMC]] [[0609, Attachment 4, the inspectors determined that the finding was of very low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of reactor containment. For both units, this finding has a cross-cutting aspect in the area of Problem Identification and Resolution (]]
: PF-108, Revision 3, Prefire Strategy Plan Control Room, Turbine Building 165' Elevation,
: [[PI&R]] [[), Corrective Action Program, because]]
: Fire Zone 108
: [[PBA]] [[]]
: PF-4C, Revision 6, Prefire Strategy Plan U2 RX Recirc Pump MG Set Room, Radwaste
PS did not thoroughly evaluate problems such that the resolutions addressed the causes and extent of
: Building, 135' Elevation, Fire Zone 4C
condition [P.1(c)]. Specifically,
 
: [[PBAPS]] [[failed to thoroughly evaluate previous conditions of degraded and hardened grease on safety-related valves, such that the extent of the condition was considered and the cause was resolved.  (Section 4]]
==Section 1R11: Licensed Operator Requalification Program==
: [[OA]] [[2)  Other Findings  A violation of very low safety significance, which was identified by the licensee, has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's]]
: OP-AA-101-111, Roles and Responsibilities of On-Shift Personnel, Revision 3
: [[CAP.]] [[This violation and the licensee's corrective action tracking numbers are listed in Section 4]]
: OP-AA-103-102, Watchstanding Practices, Revision 8
: [[OA]] [[7 of this report.]]
: OP-AA-103-103, Operation of Plant Equipment, Revision 0
: [[REPORT]] [[]]
: OP-AA-104-101, Communications, Revision 1 PSEG1009R, Revision 3, Loss of Vacuum, Electrical ATWS
: [[DETAIL]] [[S  Summary of Plant Status  Unit 2 began the inspection period at 100 percent rated thermal power (RTP). On April 24, a power reduction to 23 percent]]
 
: [[RTP]] [[was conducted in response to continued degradation and heating of electrical components in the electro-hydraulic control (]]
==Section 1R12: Maintenance Effectiveness==
EHC) system. On April 26, the unit was returned to full power. Unit 2 remained at or near full power for the remainder of the
: IR 875571, Clearances Required for Unit 3 Control Rods
inspection period. Unit 3 began the inspection period at 100 percent
: IR 889545, 2B MTSV Failed to Reset
: [[RTP.]] [[On May 22, power was reduced to 75 percent]]
: IR 906648, 2A MTSV Slow to Tripp
: [[RTP]] [[to support planned summer readiness maintenance and adjustments to a]]
: IR 906661, 2B MTSV Failed to Reset
: [[RRP]] [[]]
: IR 909080, 3A MTSV Failed to Reset
: [[MG]] [[set voltage regulator. An unplanned power reduction from 75 percent to 32 percent occurred when the 3 'A']]
: IR 909628, 2B MTSV Failed to Reset
: [[RRP]] [[tripped during the adjustments to its]]
: IR 912636, 2B MTSV Slow to Reset
MG set voltage regulator. On May 25, the unit was returned to full power. On June 13, 2009, the unit was reduced to 62 percent for
: IR 932238, Small Water Leak in Unit 3 CST Moat
emergent maintenance to repair degrading condenser in-leakage on the 3 'B' main feed pump turbine exhaust expansion joint. On June 14, 2009, the unit was returned to full power. Unit 3 remained at or near full power for the remainder of the inspection period.
: IR 930640, Unit 3 CST Moat Water is Cloudy Since Moat Recoat
1.
: IR 928861, Document Results of Tritium Age Dating
: [[REACTO]] [[R]]
: IR 927784, Develop Contingency Plans for Well Drilling
SAFETY
: IR 921975, Evaluate Soft Digging Inside the Unit 3 CST Moat Area
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
: IR 916050, Increase in Unit 3 Yard Drain Sum Tritium
1R01 Adverse Weather Protection (71111.01 - 2 Samples) 
: IR 895539, Tritium Detected in New Monitoring Wells
.1 Grid Reliability  a. Inspection Scope  The inspectors reviewed plant features and procedures for operation and continued
: IR 894134, Elevated Tritium in Unit 2 Yard Drain Sump
availability of offsite and backup power systems during adverse weather (summer conditions). The inspectors reviewed communication protocols between the control room personnel and electrical system operations, as well as measures prescribed and taken to maintain the availability and reliability of these alternating current (AC) systems. Documents reviewed during this inspection are listed in the Attachment. b. Findings  No findings of significance were identified.  .2 Summer Seasonal Readiness Preparations
: IR 859610, Tritium Dating Analysis Needed to Determine Tritium Source
a. Inspection Scope  The inspectors conducted a review of
: IR 814380, Continued Increase in Tritium Level in Well #4
: [[PBA]] [[]]
: IR 791859, Increased Tritium Level Trend for Groundwater Monitoring Well #4
: [[PS]] [['s preparations for the 2009 summer conditions to verify selected features of the plant's design were sufficient to protect mitigating systems from the effects of adverse weather. The inspectors reviewed]]
: A-4
: [[PBAPS]] [['s implementation of procedure]]
 
WC-AA-107, "Seasonal Readiness," in preparation for summer season readiness. Documentation for selected risk-significant systems was reviewed to ensure that these systems would remain functional when
==Section 1R13: Maintenance Risk Assessments and Emergent Work Control==
challenged by inclement weather. During the inspection, the inspectors focused on plant specific design features and the licensee's procedures used to mitigate or respond to adverse weather conditions. The inspectors reviewed the Updated Final Safety Analysis
: IR 870284, Heating on the Base of the XK8 Relay
Report (UFSAR) and performance requirements for systems selected for inspection. The inspectors reviewed
: IR 877404, Heating on the EHC XK17 Relay Spade Connection
: [[CAP]] [[records to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their]]
: IR 910561, Unit 2 EHC Relay XK8 Exceeded ACMP Action Level of 80C
CAP. In addition, the inspectors reviewed the "Certification of 2009 Summer Readiness" memorandum dated May 15, 2009. Documents reviewed during this inspection are
: IR 911610, Unit 2 EHC XK17 Relay Found Loose in Its Base
listed in the Attachment. The inspectors walked down the following systems and equipment: * Intake Structure Ventilation System; * Emergency Diesel Generator (EDG) Building Ventilation System; and * 'A' Supplemental Cooling Tower. b. Findings  No findings of significance were identified. 1R04 Equipment Alignment 
: IR 911675, Cause of EHC Relay Hot Spot Identified
.1 Partial Walkdown (71111.04Q - 3 Samples)  a. Inspection Scope  The inspectors performed a partial walkdown of three systems to verify the operability of
: IR 911903, Improvement Opportunity in PORC Review of EHC Power Supply AR A1695813, Heating on the Base of the XK8 Relay
redundant or diverse trains and components when safety-related equipment was inoperable. The inspectors reviewed selected applicable operating procedures, walked down system components, and verified that selected breakers, valves, and support equipment were in the correct position to support system operation. Documents reviewed during this inspection are listed in the Attachment. The inspectors walked
: WO
down the systems below: * E-1
: C0227471, Replace XK8 Relay and Base, Rework XK17 Connector
: [[EDG]] [[with E-3]]
: ER-AA-302-1001, MOV Rising Stem Motor Operated Valve Thrust and Torque
: [[EDG]] [[Out-Of-Service (OOS); * E-2, 3, and]]
: Sizing and Set-up Window Determination Methodology, Revision 6 I.E. Bulletin 85-03, Supplement 1: Motor Operated Valve Common Mode Failures During Plant
: [[4 EDG]] [[s with E-1]]
: Transients due to Improper Switch Settings
OOS; and * 'A' Control Room Chilled Water System with 'B' Control Room Chilled Water System OOS. b. Findings  No findings of significance were identified. 
: IR 060023, Dedication of Lubrication Used on Safety-Related Systems
.2 Complete Walkdown (71111.04S - 1 Sample)    a. Inspection Scope  The inspectors performed a complete system walkdown of the accessible portions of the
: IR 827482, U2 HPCI
Unit 2 reactor core isolation cooling system (RCIC), verifying that accessible breakers, valves and support equipment were properly aligned to support system operation. The inspectors reviewed system operating procedures and piping and instrumentation drawings; walked down control system components; and verified that circuit breakers
: MO-57 Stroked in Alert Range Then Stopped Moving
and valves were in the appropriate positions. Documents reviewed during this inspection are listed in the Attachment.
: IR 892191,
b. Findings  No findings of significance were identified  1R05 Fire Protection    .1 Fire Protection - Tours (71111.05Q - 5 Samples)    a. Inspection Scope  The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment. The inspectors reviewed areas
: MO-2-23-058 Stopped in Intermediate Position
to assess if
: IR 895626, U3 HPCI Suction Valve Stem Grease Condition
: [[PBAPS]] [[had implemented the Peach Bottom Fire Protection Plan (]]
: IR 895789, U3 HPCI Torus Suction
: [[FPP]] [[) and adequately: controlled combustibles and ignition sources within the plant; maintained fire detection and suppression capability; and maintained the material condition of passive fire protection features. For the areas inspected, the inspectors also verified that]]
: MO-3-23-57, Split Indication
: [[PBAPS]] [[had followed the Technical Requirements Manual (]]
: IR 896914, Test Results of Stored Exxon Nebula
TRM) and the FPP when
: EP-1 Grease
compensatory measures were implemented for OOS, degraded, or inoperable fire protection equipment, systems, or features. The inspectors verified:  that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient combustible materials were managed in accordance with plant procedures; and fire doors, dampers, and
: IR 898645, MOV Stem Lube Activity and PM Frequency Recommendation
penetration seals appeared to be in satisfactory condition. Documents reviewed during this inspection are listed in the Attachment. The inspectors toured the following areas: * Unit 3 Reactor Building Closed-Cooling Water (RBCCW) Room, Unit 3 Radwaste Building, 116' Elevation (Fire Zone 12B); * Unit 3 High-Pressure Coolant Injection (HPCI) Room, Unit 3 Reactor Building, 88' Elevation (Fire Zone 62); * Unit
: IR 899298, Procedure
: [[2 RRP]] [[]]
: MA-AA-723-301 Deficiency
MG Set Room, Radwaste Building, 135' Elevation (Fire Zone 4C); * Main Control Room, Turbine Building, 165' Elevation (Fire Zone 108); and * Unit 3 Lube Oil Tank Room, Turbine Building, 116' Elevation (Fire Zone 89). b. Findings
: IR 906768,
No findings of significance were identified.  .2 Annual Fire Protection Drill Observation (71111.05A - 1 Sample)    a. Inspection Scope  On April 16, 2009, the inspectors observed fire brigade classroom training and live-fire drills at the
: MO-2-10-015D Did Not Stroke Open During PMT
: [[PE]] [[]]
: IR 913852, FME - Foreign Material was Found in 3AF106 Discharge Micron filter WO
CO Energy Fire Academy in West Conshohocken, Pennsylvania. The inspectors noted that the classroom training provided a refresher on the Incident Management System and its techniques, methods, and terminology that are used to manage fire fighting or hazardous material events.
: C0228763, 3AP017, Investigate/Replace Pump WO R1102249, 3AF106, PM: Replace Filter Element
The inspectors noted that the live-fire fighting was done in burn facilities that simulated a transformer oil fire and fire involving plant cabling and equipment. The observation was used to determine whether appropriate learning opportunities were provided and to
: WO M1687797, Replace Filter
determine the readiness of the plant fire brigade to fight fires. The inspectors verified that the
: WO A1709877, Foreign Material was Found in 3AF106 Discharge Micron filter Letter from PBAPS to NRC, dated May 14, 1999: Response to Generic Letter 96-05 Letter from NRC to PBAPS, dated November 16, 2000: Safety Evaluation by NRR of Licensee
: [[PBA]] [[]]
: Response to Generic Letter 96-05
PS fire brigade participants and the training instructors identified deficiencies; openly discussed them in a self-critical manner at the drill debrief, and appropriately documented the identified issues to develop corrective actions for future training. Specific attributes evaluated were:  
: MA-AA-723-301, Periodic Inspection of Limitorque Model SMB/SB/SBD-000 through 5 Motor
* Proper Wearing of Turnout Gear and Self-contained Breathing Apparatus;  * Proper Use and Layout of Fire Hoses;  * Employment of Appropriate Fire Fighting Techniques;  * Sufficient Fire Fighting Equipment Brought to the Scene;  * Effectiveness of Fire Brigade Leader Communications, Command, and Control;  * Search for Victims and Propagation of the Fire Into Other Plant Areas;  * Smoke Removal Operations;  * Use of Pre-planned Strategies;  * Adherence to the Pre-planned Drill Scenario; and  * Drill Objectives. The inspectors verified that procedure RT-F-101-922-2, "Fire Drill," was completed to record the fire drill scenario used, document that the drill objectives were met, and capture the critique results. b. Findings  No findings of significance were identified.
: Operated valves, Revision 4 M-C-700-241, Limitorque Motor Operator Installation, Revision 5 NRC Inspection Report 50-277/92-82 and 50-278-92-82 NRC Inspection Report: Motor- Operated Valve Inspection 94-12
1R11 Licensed Operator Requalification Program (71111.11Q - 1 Sample) .1 Resident Inspector Quarterly Review    a. Inspection Scope  On June 23, 2009, the inspectors observed two crews of licensed operators in the plant's simulator during licensed operator requalification examinations to verify that operator performance was adequate, evaluators were identifying and documenting crew performance deficiencies, and training was being conducted in accordance with licensee
: NRC Inspection Report 50-277/96-03 and 50-278/96-03 NRC Inspection Report 50-277/97-07 and 50-278/97-07 NRC Inspection Report 50-277/99-01 and 50-278/99-01 NRC Inspection Report 05000440/2005003: Perry Supplemental Inspection NRC Inspection Report 05000277/2007005 and 05000278/2007005, Section 4OA2.3: U2 MOV
procedures. The crew's performance was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed during this inspection are listed in the Attachment. The inspectors evaluated the following areas: * Licensed Operator Performance; * Crew's Clarity and Formality of Communications; * Ability to Take Timely Actions in the Conservative Direction; * Prioritization, Interpretation, and Verification of Annunciator Alarms; * Correct Use and Implementation of Abnormal and Emergency Procedures; * Control Board Manipulations; * Oversight and Direction from Supervisors; and 
: Failure to Stroke Follow-up NUREG/CR-6750: Performance of MOV Stem Lubricants at Elevated Temperatures
* Ability to Identify and Implement Appropriate Technical Specification (TS) Actions and Emergency Plan Actions and Notifications. b. Findings  No findings of significance were identified. 1R12 Maintenance Effectiveness (71111.12Q - 2 Samples)  a. Inspection Scope  The inspectors evaluated
: P&ID: RHR, M-361, Sh. 2 WO R0013148:
: [[PBAPS]] [['s work practices and follow-up corrective actions for safety-related structures, systems, and components (]]
: MO-2-23-058-OP: Perform Operator PM WO R1018644:
: [[SSC]] [[s) and identified issues to assess the effectiveness of]]
: MO-3-10-025B-OP: Motor Operator PM WO A1714585, Exceeded ACMP Action level for U3 Main Condenser WO
: [[PBAPS]] [['s maintenance activities. The inspectors reviewed the performance history of]]
: C0227407,
: [[SSC]] [[s and assessed Exelon's extent-of-condition (EOC) determinations for those issues with potential common cause or generic implications to evaluate the adequacy of the]]
: XJ-3170B; Additional Sealant Application
: [[PBA]] [[]]
: WO A1579262, Proactive Replacement of the 3B RFPT Exhaust Expansion Joint WO A1700673, 4 scfm Step Change in U3 Offgas Flow WO A1636058, U3 Step Increase in Offgas Flow on 10/18/07 
: [[PS]] [['s corrective actions. The inspectors assessed]]
: A-5WO A1714764, LP Turbine to Condenser Expansion Joint has Leakage WO R1127007, Helium Mass Spectro Connection to Offgas
: [[PBAPS]] [['s]]
: IR 931031, Air In-leakage at 3A LP Turbine Dog Bone
: [[PI&R]] [[actions for these issues to evaluate whether]]
: IR 931035, Condensate Drain Tank - Small Leak Identified
: [[PBAPS]] [[had appropriately monitored, evaluated, and dispositioned the issues in accordance with Exelon procedures and the requirements of 10]]
: IR 936787, Bearing #6 Slop Drain Confirmed Leakage with Smoke
CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance."  In addition, the inspectors reviewed selected SSC classifications, performance criteria and goals, and Exelon's corrective actions that were
: IR 936791, U3 Turbine #4 Slop Drain Cover Dislocated Procedure SO 5.7.A-3, Revision 8, Main Condenser Vacuum Leak Monitoring and Search
taken or planned, to evaluate whether the actions were reasonable and appropriate. Documents reviewed during this inspection are listed in the Attachment. The inspectors reviewed the following two samples: * Repeat Master Trip Solenoid Valve (MTSV) Issues (IR 918352); and  * Apparent Cause Evaluation for Tritium Increase in Groundwater Monitoring Well #4 (IR 808183). b. Findings  No findings of significance were identified. 1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 4 Samples)
 
a. Inspection Scope  The inspectors evaluated
==Section 1R15: Operability Evaluations==
: [[PBAPS]] [[=s implementation of their Maintenance Risk Program with respect to the effectiveness of risk assessments performed for maintenance activities that were conducted on]]
: IR 873016, P3R18 Torus Recoat
: [[SSC]] [[s. The inspectors also verified that the licensee managed the risk in accordance with]]
: IR 838841, P3R17 CISI Scope - UT of Piping in Torus Airspace
: [[10 CFR]] [[Part 50.65(a)(4) and procedure]]
: IR 838844, P3R17 CISI Scope - Torus Diver Inspections
: [[WC]] [[-AA-101,]]
: IR 878127, P3R17 Torus Cleaning and Inspection
: [[AO]] [[n-line Work Control Process."  The inspectors evaluated whether]]
: IR 873016, P3R18 Torus Recoat
: [[PBAPS]] [[had taken the necessary steps to plan and control emergent work activities and to manage overall plant risk. The inspectors selectively reviewed]]
: IR 838841, P3R17 CISI Scope - UT of Piping in Torus Airspace
: [[PBA]] [[]]
: IR 838844, P3R17 CISI Scope - Torus Diver Inspections
PS's use of the online risk monitoring software, and daily work schedules. The activities selected were based on plant maintenance schedules and systems that contributed to risk. Documents reviewed during this inspection are listed in the Attachment. The inspectors reviewed the following samples:
: IR 878127, P3R17 Torus Cleaning and Inspection
10  * Emergent Power Reduction for Work to Correct Heating of Two Relays in the Unit
: IR 919671, TS 3.8.7 Interpretation Concerns
: [[2 EHC]] [[System (Work Order (]]
: IR 931760 -TS 3.8.7 Interpretation Concerns Information Notice 97-80:
: [[WO]] [[) C0227471 &]]
: Licensee TS Interpretations
: [[IR]] [[870284-08); * Work Activities Associated with Unit 2 Residual Heat Removal (]]
: IR 881184, 2BA034 (3402) Action Level Changed from "Blue" to "Yellow" ACMP - Unit 2 'B' Recirc Pump Trip Breaker Temperatures
: [[RHR]] [[) Discharge Valve]]
: IR 867732, 2BA034 (3401) Inspect Breaker During Next Refuel Outage
: [[MO]] [[-2-10-154B and Unit 3]]
: IR 867719, 2BA034 (3402) Inspect Breaker During Next Refuel Outage
: [[RHR]] [[Pump Suction Valve]]
 
: [[MO]] [[-3-10-13D Underthrust Conditions (]]
==Section 1R18: Plant Modifications==
: [[WO]] [[C0228319); * Foreign Material was Found in Unit 3 'A']]
: AR A1693909, Damaged Electrical Ductbank
: [[EHC]] [[Pump's Discharge Filter (]]
: WO
WO C0228763); and * Exceeded Adverse Condition Monitoring Plan (ACMP) Action Level for Unit 3 Main Condenser (WO A1714585). b. Findings  No findings of significance were identified. 1R15 Operability Evaluations (71111.15 - 4 Samples)
: C0226402, Install Monitoring Equipment/ TCCP 08-00408
a. Inspection Scope  The inspectors assessed the technical adequacy of the operability evaluations, the use and control of compensatory measures, and compliance with the licensing and design bases. Associated
 
: [[AC]] [[]]
==Section 1R19: Post-Maintenance Testing==
MPs, engineering technical evaluations, and operational and technical decision making documents were also reviewed. The inspectors verified these processes were performed in accordance with the applicable administrative procedures
: WO
and were consistent with
: C0220912, 2AK018, Rebuild and Eddy Current Test
: [[NRC]] [[guidance. Specifically, the inspectors referenced procedure]]
: SO 44A.6.A-2, Placing an Additional Drywell Chiller in Service
: [[OP]] [[-AA-108-115, "Operability Determinations," and]]
: IR 910529, 2 'A' Drywell Chiller Tripped during PMT Run
: [[NRC]] [[]]
: AR A1711246, Leakage in Unit 3 RWCU Regenerative Heat Exchanger Room WO
: [[IMC]] [[Part 9900, "Operability Determinations & Functionality Assessments for Resolutions of Degraded or Nonconforming Conditions Adverse to Quality or Safety."  The inspectors also used Technical Specifications (TSs),]]
: C0228895,
: [[TRM]] [[,]]
: HV-3-12-30K/31K:
UFSAR, and associated Design Basis Documents
: Perform Leak Repair
as references during these reviews. Documents reviewed during this inspection are listed in the Attachment. The inspectors reviewed the following samples:  * Determine the Scope of Torus Material and Method (Wet\Dry) that Requires Recoat in Unit 2 [P2R19] and Unit 3 [P3R18] Refueling Outages (IR 873016-03); * Electrical Distribution Bases (3.8.7) Potential Needs Upgraded (IR 894904); * Exceeded
: IR 918477, Leakage in Unit 3 RWCU Regenerative Heat Exchanger Room Technical Repair Procedure (TRP) - 3002, Revision 1, 1/8" NPT Drill and Tap
: [[ACMP]] [[Action Levels for Unit 3 Main Condenser Air In-Leakage (]]
: CC-AA-404, Maintenance Specification:
: [[IR]] [[928762); and * Unit 2 Reactor Recirculation Motor Breaker Action Level Changed from]]
: Application, Selection, Evaluation and Control of Temporary Leak Repairs
: [[BLUE]] [[to]]
: IR 921526, 2 'A' CAD Analyzer Failed to Trip During
YELLOW (IR 881184). b. Findings
: ST-I-07G-103-2
No findings of significance were identified. 1R18 Plant Modifications (71111.18 - 1 Sample)  .1 Temporary Modifications  a. Inspection Scope
: WO
11  The inspectors reviewed one temporary modification to verify that implementation of the modification did not place the plant in an unsafe condition. The review was also conducted to verify that the design bases, licensing bases, and performance capability of risk significant
: C0229040, Determine Which SV is Not Isolating
: [[SSC]] [[s had not been degraded as a result of these modifications. The inspectors verified the modified equipment alignment through control room instrumentation observations;]]
: ST-I-07G-103-2, PCIS Group III Logic System Functional Test, Completed on 5/19/09 WO A1712378, 2 'A' CAD Analyzer Failed to Trip WO
: [[UFSAR]] [[, drawings, procedures, and]]
: C0225963 - Replace the Tube Bundles during the TSA Window WO A1651390 - E1 EDG Jacket Coolant Heat Exchanger Reduced Margin
: [[WO]] [[reviews; and plant walkdowns of accessible equipment. Documents reviewed during this inspection are listed in the Attachment. The inspectors reviewed the following sample:  *]]
: WO
ECR 09-00078 000, Re-Route Cables from Damaged Duct Bank To Support Duct Bank Repair. b. Findings  No findings of significance were identified. 1R19 Post-Maintenance Testing (71111.19 - 7 Samples)    a. Inspection Scope  The inspectors observed selected portions of post-maintenance testing (PMT) activities and reviewed completed test records. The inspectors observed whether the tests were
: C0229077, 0AV079-DR, Replace Motor
performed in accordance with the approved procedures and assessed the adequacy of the test methodology based on the scope of maintenance work performed. In addition, the inspectors assessed the test acceptance criteria to evaluate whether the test demonstrated that the tested components satisfied the applicable design and licensing bases and the TS requirements. The inspectors reviewed the recorded test data to
: ECR 09-00291, 0AV079-DR is Obsolete WO A1712722, 0AV079-DR is Obsolete P&ID Drawing - M-384, Control Room HVAC 
verify that the acceptance criteria were satisfied. Documents reviewed during this inspection are listed in the Attachment. The inspectors reviewed the following samples:  * Perform Leak Sealant Injection on Regenerative Heat Exchanger Tube Side Outer Vent Valve (WO C0228895); * 2 'A' Drywell Chiller, Rebuild and Eddy Current Test (WO C0220912); * 2 'A'
: A-6WO
: [[CAD]] [[Analyzer Failed to Trip During]]
: C0229510, Troubleshoot Speed Switch, Rework as required WO R1067972, 0AG012-DR - Diesel Engine Inspection WO R1067972 - Act. 74, Perform PMT of Speed Switch WO R1067972 - Act 81, Remove/ Repair Tachometer
: [[ST]] [[-I-07G-103-2 (WO C0229040); * Replace Tube Bundles in the E-1]]
: IR 935794, ECW/ESW Pumps Did Not Auto Start During E-1 DG Testing
: [[EDG]] [[(]]
: IR 935800, E-1 DG Started and ESW and ECW Pumps Failed to Start
: [[WO]] [[C0225963); * Replace 'A' Control Room Supply Fan Motor (WO C0229077); * Troubleshoot]]
: IR 935053, Red indicating light on for EHC Micron Filters WO A1716915, 3BF106 Red indicating light on for EHC Micron Filters WO M1716915, Replace Filter 
: [[EDG]] [[E-1 Speed Switch, Rework as Required (]]
===Procedure===
: [[WO]] [[C0229510); and * Replace 3B]]
: SO 1D.5.A-3, Revision 25, Electrohydraulic Control System Filter Changing and Cleaning
: [[EHC]] [[Micron Filter (]]
WO M1716915). b. Findings
No findings of significance were identified. 1R22 Surveillance Testing (71111.22 - 5 Samples)    a. Inspection Scope  The inspectors compared test data with established acceptance criteria to verify the systems demonstrated the capability of performing the intended safety functions. The inspectors also verified that the systems and components maintained operational
2  readiness, met applicable TS requirements, and were capable of performing design basis functions. Documents reviewed during this inspection are listed in the Attachment. The inspectors reviewed the following samples:
*
: [[RT]] [[-O-01D-402-2, Master Trip Solenoid Valves Operability Test;  *]]
: [[SI]] [[3P-5-12-C1C2, Calibration Check of reactor protection system (RPS) Drywell Pressure Loop Instruments]]
: [[PT]] [[/]]
: [[PS]] [[3-5-12C; *]]
: [[ST]] [[-M-40D-905-2, Control Room Emergency Ventilation Filter Train 'A' Test; *]]
: [[ST]] [[-O-010-301-2, 2 'A']]
: [[RHR]] [[Loop Pump, Valve, Flow, and Unit Cooler Functional and Inservice Test [Inservice Test Sample]; and *]]
: [[ST]] [[-O-020-560-2, Reactor Coolant Leakage Test [RCS Leakage Sample]. b. Findings  No findings of significance were identified. Cornerstone:  Emergency Preparedness (EP)]]
: [[1EP]] [[6]]
: [[EP]] [[Drill Evaluation (71114.06 - 1 Drill Sample)    a. Inspection Scope  The inspectors evaluated the conduct of a]]
: [[PBA]] [[]]
PS emergency drill on June 1, 2009, to
identify any weaknesses and deficiencies in classification and notification activities. The drill was conducted to provide drill and exercise performance (DEP) opportunities for the
: [[DEP]] [[performance indicator (]]
PI). The inspectors observed operators respond to events in the simulator control room through the declaration and notification of an alert. The inspectors observed the operations shift manager transition emergency response command and control responsibilities to the site emergency director in the technical support center (TSC). The inspectors relocated to the TSC to observe command and
control of the emergency response organization and dose assessment as the event escalated to the declaration and notification of a site area emergency. The inspectors verified that the event classification and notifications were done in accordance with
: [[EP]] [[-]]
: [[AA]] [[-1007, "Exelon Nuclear Radiological Emergency Plan Annex for]]
: [[PBA]] [[]]
PS."  The inspectors verified that the drill evaluators correctly counted the drill's contribution in the
calculation of the
: [[DEP]] [[]]
: [[PI.]] [[The inspectors also verified that operations personnel in the simulator control room identified weaknesses or deficiencies during the critique of the drill. The following simulated events were classified during this training exercise:    *]]
: [[FS]] [[1 - Site Area Emergency, Fission Product Barrier Degradation; and  *]]
HA5 - Alert, Natural and Destructive Phenomena. b. Findings
No findings of significance were identified.


4.
==Section 1R22: Surveillance Testing==
: [[OTHER]] [[]]
: IR 910465, Line Up Incorrect for A CREV Filter Testing
ACTIVITIES  4OA1 Performance Indicator Verification (71151 - 10 Samples)
: ST-M-40D-905-2, Revision 17, Control Room Emergency Ventilation Filter Train 'A' Test
13  Cornerstone: Initiating Events and Barrier Integrity  .1 Initiating Events
: ON-115, Loss of Normal Main Control Room Ventilation SI3P-5-12-C1C2, Revision 8, Calibration Check of RPS Drywell Pressure Loop Instruments PT/PS 3-5-12C WO R1066021, RPS DW Pressure 'C' Loop Inst
: [[PI]] [[s (71151 - 6 Samples)  a. Inspection Scope  The inspectors sampled]]
: RT-O-01D-402-2, Revision 5, Master Trip Solenoid Valves Operability Test
: [[PBAPS]] [['s submittals for the]]
: WO R1126058, Master Trip Solenoid Valves Operability Test
: [[PI]] [[s listed below for Units 2 and 3 for the period from January 2008 through March 2009.]]
: IR 906649, 'A' MTSV Slow to Operate
PI definitions and guidance
: IR 926105, Increased Unit 2 Drywell Floor Drain Pump Outs (Unidentified Leakage)
contained in Nuclear Energy Institute (NEI) 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, were used to verify the accuracy of the
: [[PI]] [[data. The inspectors reviewed selected portions of the operating logs and raw]]
: [[PI]] [[data, and selected applicable licensee event reports and]]
: [[CAP]] [[documents from the period for each]]
: [[PI]] [[specified below. The inspectors compared graphical representations from the most recent]]
: [[PI]] [[report to the raw data and used the performance indicator definition in the]]
NEI guideline to verify that the data were correctly reflected in the report. Documents
reviewed during this inspection are listed in the Attachment. The following six
: [[PI]] [[samples were reviewed:  Units 2 and 3  * Unplanned Scrams; * Unplanned Scrams with Complications; and * Unplanned Power Changes. b. Findings  No findings of significance were identified.  .2 Barrier Integrity]]
: [[PI]] [[s (71151 - 4 Samples)    a. Inspection Scope  The inspectors reviewed a sample of]]
: [[PBAPS]] [['s submittals for the four Barrier Integrity]]
: [[PI]] [[s listed below to verify the accuracy of the data reported. The]]
: [[PI]] [[definitions and the guidance contained in]]
: [[NEI]] [[99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, and Exelon procedure]]
: [[LS]] [[-]]
: [[AA]] [[-2001, "Collecting and Reporting of]]
: [[NRC]] [[Performance Indicator Data," were used to verify that the reporting requirements were met. The inspectors reviewed raw]]
: [[PI]] [[data collected since January 2008 to April 2009 and compared graphical representations from the most recent]]
: [[PI]] [[report to the raw data to verify the data was included in the report. Documents reviewed during this inspection are listed in the Attachment. The following four]]
: [[PI]] [[samples were reviewed:  Units 2 and 3  * Reactor Coolant System (RCS) Specific Activity; and *]]
: [[RCS]] [[Leakage. 4]]
OA2 Identification and Resolution of Problems (PI&R) (71152 - 2 Samples)  1. Annual Sample:  MOV Hardened Grease Challenges (1 In-depth Review Sample)
14    a. Inspection Scope  This inspection focused on Exelon's identification, evaluation, and resolution of
challenges associated with hardened grease on safety-related
: [[MOV.]] [[Specifically, two]]
: [[HPCI]] [[valves failed to stroke to the full open position during surveillance testing on March 12 and March 21, 2009.]]
: [[MOV]] [[disassembly and inspection identified hardened grease on the stem and inside the stem nut of both valves. Initial extent-of-condition evaluations revealed that two]]
: [[RHR]] [[valves developed less-than-required closing thrust for successful diagnostic test acceptance. Hardened grease was also identified on the stem and inside the stem nut of both]]
: [[RHR]] [[valves. The final extent-of-condition scoping determined that 45 safety-related]]
MOVs required additional evaluation appropriate to the circumstances, such as visual inspection, grease evaluation, diagnostic testing, and/or corrective maintenance. The inspectors reviewed Exelon's associated root cause evaluation, operability
evaluations, corrective action reports, and a sample of diagnostic and stroke time test data, and interviewed plant personnel to evaluate the adequacy of Exelon's performance in the areas of problem identification, evaluation, extent-of-condition scoping, and corrective actions. Additionally, the inspectors observed the integrity of damaged, worn, and newly machined stem nuts to evaluate the effect of plant conditions on stem nut
integrity. Finally, the inspectors reviewed
: [[MOV]] [[program procedures to evaluate the quality and effectiveness of the Exelon]]
: [[MOV]] [[program, as implemented at]]
: [[PBAPS.]] [[Documents reviewed are listed in the Attachment. b. Findings and Observations  Introduction:  A Green, self-revealing]]
: [[NCV]] [[of]]
: [[10 CFR]] [[50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," was identified. Specifically, Exelon's]]
: [[MOV]] [[Program procedures lacked specific instructions to prescribe an acceptable frequency for performing valve stem lubrication, which resulted in test failures of safety-related]]
: [[MOV]] [[s and affected the reliability of the]]
: [[MOV]] [[s' safety functions. Description:  During quarterly surveillance testing performed by Exelon on March 12, 2009, the Unit]]
: [[2 HPCI]] [[torus inboard suction]]
MOV (MO-2-23-058) failed to stroke full open during its quarterly surveillance test and was subsequently declared inoperable. Investigation by Exelon identified dried and hardened grease on the valve stem and stem nut, and a root cause investigation was assigned to Exelon engineering staff.
Extent-of-condition inspections were performed by Exelon on select
: [[HPCI]] [[]]
: [[MOV]] [[s over the next several days. Degraded grease was identified on the outboard torus suction]]
: [[MOV]] [[for Unit 3 (]]
: [[MO]] [[-3-23-057), but the condition was determined not to impact valve operability. Exelon rescheduled the periodic stem lubrication interval on the Unit]]
: [[3 HPCI]] [[]]
MOV from ten years to six years, and assigned this PM to the next Unit 3 refueling
outage (fall of 2009). Subsequently, on March 21, 2009, the Unit
: [[3 HPCI]] [[torus outboard suction]]
MOV failed to stroke full open during quarterly surveillance testing and was declared inoperable. Investigation by Exelon identified hardened grease on the stem and inside the stem nut, as well as stem nut wear. As a result of the failure, Exelon expanded the extent-of-condition scope to include diagnostic testing of MOVs on both
units within the affected
: [[HPCI]] [[valve group (total of 6]]
MOVs), as well as eleven other safety-related MOVs based on diagnostic test data margins, as well as similar stem characteristics.
15  During the diagnostic testing of the Unit
: [[3 RHR]] [[loop 'D' torus suction]]
MOV  (MO-3-10-13D) on March 26, 2009, Exelon identified less-than-required thrust at the torque switch trip, and the valve was subsequently declared inoperable. Investigation
by Exelon revealed that the stem grease was degraded and several stem nut threads were damaged. As a result of this test failure, the extent-of-condition scope was again expanded. Exelon concluded that 45 safety-related
: [[MOV]] [[s required additional evaluation, such as visual inspection, grease evaluation, diagnostic testing, and/or corrective maintenance. This review identified one additional]]
MOV under-thrust
condition on the Unit
: [[2 RHR]] [[loop 'B' outboard discharge]]
: [[MOV]] [[(MO 2-10-154B) during diagnostic testing on April 2, 2009. Exelon investigation into this]]
: [[MOV]] [[test failure identified a degraded grease condition, and the]]
: [[MOV]] [[was declared inoperable. The]]
: [[NRC]] [[inspectors reviewed the final extent-of-condition scoping, and found that it was appropriate to the circumstances. Exelon performed immediate corrective actions after each of the]]
MOV failures, which
included cleaning and removing the old grease from the stem and stem nut area, applying new grease, and performing diagnostic testing to ensure successful valve performance. Exelon performed operability evaluations for each of the four
: [[MOV]] [[failures, and concluded three of the four]]
MOVs would have been capable of performing their intended safety function for all design basis events. The operability evaluation for
the Unit
: [[3 RHR]] [[loop 'D' torus suction]]
MOV concluded that the valve would not have been able to perform its safety function of containment isolation for all design basis events. Operability evaluations for the other three MOVs determined that the valves would have
been capable of performing their safety functions for all design basis events. The Unit
: [[2 RHR]] [[loop 'B' discharge]]
MOV is normally open in a standby mode for low pressure coolant injection, and was evaluated for its design function to close during suppression pool cooling and containment spray modes of the RHR system. Exelon concluded that the valve motor torque capability would have provided enough inertia to hard seat the
valve from the as-found torque switch trip condition in the extent-of-condition diagnostic test. The operability evaluations for the Unit 2 and Unit
: [[3 HPCI]] [[torus suction]]
MOVs stated that the torque switch trip protection, which stopped the valve from completely opening through the degraded grease conditions during the surveillance tests, is bypassed during safety actuation signals to open. Exelon determined that the valve motor torque capability, absent torque switch trip protection, was sufficient to open the valve during all design basis events despite the degraded grease conditions. The
inspectors reviewed the operability evaluations and agreed that Exelon's conclusions regarding past operability were reasonable. However, the capability of the MOVs to perform their mitigating safety functions was challenged, thereby impacting their reliability.
A root cause evaluation was performed by Exelon in response to the four
: [[MOV]] [[failures. The root cause evaluation determined that Peach Bottom]]
: [[MOV]] [[]]
: [[PM]] [[frequencies and actions had not appropriately included stem lubricant performance feedback. The]]
: [[NRC]] [[inspectors reviewed the root cause evaluation and agreed that an adequate]]
: [[MOV]] [[program would schedule and adjust]]
PM activities as necessary to assure that safety-
related
: [[MOV]] [[s can perform their functions as required. The root cause evaluation stated that Exelon had the longest allowable]]
: [[MOV]] [[]]
: [[PM]] [[lubrication intervals in the entire nuclear fleet (up to 10 years). Previous industry guidance and vendor information had described Exxon Nebula Extreme Pressure (]]
: [[EP]] [[) - 1, the]]
: [[MOV]] [[lubricant used at]]
PBAPS, as being
16  susceptible to degradation and hardening phenomena. The Exelon root cause identified that Exxon cancelled production of Nebula
: [[EP]] [[-1 in 2001, stating a one-year limited shelf life. Additionally, the]]
EOC inspections performed by Exelon identified mixtures of
Nebula
: [[EP]] [[-1, along with some remains of the former]]
: [[PBAPS]] [[]]
: [[MOV]] [[lubricant, N5000 NeverSeez, on several valve stems and stem nuts. Industry guidance has noted that NeverSeez is incompatible with Nebula]]
: [[EP]] [[-1 due to an accelerated hardening and degradation effect. Finally, since using]]
: [[EP]] [[-1 grease, Peach Bottom had many opportunities to re-evaluate their]]
MOV PM lubrication frequencies and actions, including:
* October 2006:
: [[MO]] [[-3-10-026B failed to successfully stroke. Internal inspection identified severely degraded grease, and the stem nut was replaced. * October 2007:]]
: [[NRC]] [[]]
: [[PI&R]] [[inspection of the October 2006]]
: [[MO]] [[-3-10-026B failure to stroke noted that although Exelon identified a hardened grease condition, this was not determined to be the most probable cause of the failure, and no]]
: [[EOC]] [[evaluation was performed. Subsequent walkdowns by the inspector identified degraded lubricating grease on]]
: [[MO]] [[-3-10-031A. Exelon staff noted that the grease appeared to be a mixture of]]
: [[EP]] [[-1 and NeverSeez. (]]
: [[IR]] [[689020). This was documented in]]
: [[NRC]] [[Inspection Report 05000277&278/2007005.  * October 2008:]]
: [[MO]] [[-2-23-057 (Unit]]
: [[2 HPCI]] [[outboard torus suction]]
: [[MOV]] [[) stroked slowly and failed to close. Degraded lubricating grease and stem nut wear were identified, and the stem nut was replaced. * January 2009:]]
: [[MO]] [[-3-01A-077 failed to go full open. The valve stem was cleaned and re-lubricated and the stroke time decreased. Analysis:  The inspectors determined that Exelon's failure to properly implement]]
MOV preventive maintenance activities, specifically with respect to stem lubrication necessary to assure that MOVs will function when required, constituted a performance deficiency. Specifically, degraded stem lubrication was identified as a common factor in four safety-
related
: [[MOV]] [[test failures between March 12, 2009 and April 2, 2009. Unit 2:  The finding for Unit 2 was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems (]]
MS) Cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of
systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the
: [[HPCI]] [[torus inboard suction]]
: [[MOV]] [[and the]]
: [[RHR]] [[loop 'B' outboard discharge]]
MOV experienced test failures, were declared inoperable, and required detailed operability evaluations as described above, thereby challenging their reliability and capability to perform their safety function. Using the Phase 1 worksheet in
of Manual Chapter 0609, "Significance Determination Process," the finding affected the
: [[MS]] [[Cornerstone and was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of system safety function, and was not associated with any external events. Unit 3:  The finding for Unit 3 was more than minor because it was associated with the configuration control attribute of the Barrier Integrity (]]
: [[BI]] [[) Cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers (e.g., containment) protect the public from radionuclide releases caused by accidents or events. Specifically,]]
: [[RHR]] [[loop 'D' torus suction]]
MOV was determined by Exelon to not be capable of isolating for all design basis events. Using the Phase 1 worksheet in Attachment 4 of Manual Chapter 0609, "Significance Determination Process," the finding
affected the BI cornerstone and was of very low safety significance (Green) because it
17  did not represent an actual open pathway in the physical integrity of reactor containment. Although the Unit
: [[3 HPCI]] [[torus outboard suction]]
MOV condition affected the mitigating system cornerstone, the Unit 3 finding analysis was assigned to the BI cornerstone
because it best reflected the dominant risk of the finding. This finding has a cross-cutting aspect in the area of
: [[PI&R]] [[, Corrective Action Program, because]]
: [[PBAPS]] [[did not thoroughly evaluate problems such that the resolutions addressed the causes and extent of condition [P.1(c)]. Specifically,]]
: [[PBA]] [[]]
PS failed to
thoroughly evaluate previous conditions of degraded and hardened grease on safety-related valves, such that the extent of the condition was considered and the cause was resolved. This cross-cutting aspect is applied to both Units 2 and 3. Enforcement:  10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires, in part, that "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the
circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."  Contrary to the above, the Exelon
: [[MOV]] [[program procedures (]]
: [[ER]] [[-AA-300 Series and]]
: [[MA]] [[-]]
AA-723-300 Series) were not appropriate to the circumstances, in that, they lacked specific instructions to prescribe an acceptable frequency for performing valve stem lubrication, given the limited shelf life of the
: [[MOV]] [[lubrication grease used by the station as described in the above section. As a consequence of this, four safety-related]]
: [[MOV]] [[s experienced test failures between March 12, 2009 and April 2, 2009, attributed to degraded and hardened lubricating grease. Because this finding is of very low safety significance and has been entered into Exelon's]]
: [[CAP]] [[(IR 892191), this violation is being treated as a Green]]
: [[NCV]] [[consistent with section]]
: [[VI.A.]] [[1 of the]]
: [[NRC]] [[Enforcement Policy:]]
: [[NCV]] [[05000277/2009003-01, and]]
: [[NCV]] [[05000278/2009003-01,]]
: [[MOV]] [[Program Procedures were Inadequate with Regard to Periodicity of Preventive Maintenance Activities for Stem Lubrication.  .2 Semi-Annual Review to Identify Trends (1 Trend Review Sample)    a. Inspection Scope  The inspectors reviewed lists of]]
: [[CAP]] [[items to identify trends (either]]
: [[NRC]] [[or licensee identified) that might indicate the existence of a safety issue. First, the inspectors reviewed a list of approximately 7,250]]
: [[IR]] [[s that]]
PBAPS initiated and entered into the CAP action tracking system from December 1, 2008 through June 1, 2009. The
inspectors also reviewed the approximately
: [[3450 IR]] [[s that remained open with outstanding actions. The list was reviewed and screened to complete the required semi-annual]]
PI&R trend review. Based on the review, a sample of 58 IRs (listed in the  Attachment) were selected for a more detailed review to determine whether the issues were adequately identified and evaluated, and that corrective actions were planned. The
inspectors evaluated the
: [[IR]] [[s against the requirements of Exelon procedure,]]
: [[LS]] [[-AA-125, and]]
: [[10 CFR]] [[50, Appendix B, Criterion]]
XVI, "Corrective Action."      b. Findings and Observations  Based on the review, the inspectors observed that there was an adverse trend of human performance related events during the period. Specific examples included:    * the inadequate configuration control of an inoperable control rod (IR 880318);
18  * inadequate risk assessment and maintenance practices for work on the control circuitry for containment isolation valves (IR 887441);  * inadequate procedure adherence that resulted in the trip of a
: [[RRP]] [[(]]
: [[IR]] [[923239);  * an inadequate understanding of the maintenance and operation of a]]
: [[WRNM]] [[channel (]]
: [[IR]] [[871864); and,  * removal, for inspection, of an incorrect pin from a spent fuel bundle (IR 853625). The inspectors also noted an adverse trend in equipment reliability issues that challenged plant operations. Specifically:  * the build-up of combustible gases in the 3 'A' main power transformer that resulted in an unplanned power reduction (IR 868369);  * the failure of]]
: [[EHC]] [[cards that led to an unplanned power reduction in response to turbine bypass valve cycling (]]
IR 891763);  * indications of friction between selected Unit 3 control rods and fuel channels (IR 874398); and,  * inoperable motor operated valves that resulted from inadequate preventive maintenance and hardened grease (IRs 892191 and 913965).
However, the inspectors noted that
: [[PBAPS]] [[self-identified an adverse trend in station performance and proactively performed a common cause analysis (]]
IR 896381) to understand the causes for the adverse trend and to identify corrective actions and improvement plans. 
.3 Review of Items Entered into the
: [[CAP]] [[As required by]]
: [[IP]] [[71152, "Identification and Resolution of Problems," and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed screening of all items entered into the licensee']]
: [[CAP.]] [[This was accomplished by reviewing the description of each new action request/issue report and attending daily management review committee meetings. 4]]
OA3 Follow-up of Events and Notices of Enforcement Discretion (71153 - 4 Samples)  .1 Personnel Performance - 3 'A' RRP Trip
a. Inspection Scope  The inspectors reviewed corrective action documents listed in the Attachment to this report and discussed the events surrounding the trip of the 3 'A'
: [[RRP]] [[with the personnel involved. The inspectors reviewed Revision 4 of]]
IC-11-02011, "Recirc MG Set Voltage
Regulator Tuning," and Revision 3 of
: [[HU]] [[-]]
: [[AA]] [[-104-101, "Procedure Use and Adherence."    b. Findings  Introduction:  A Green, self-revealing finding occurred when]]
: [[PBAPS]] [[personnel incorrectly performed a maintenance procedure for tuning the 3 'A']]
: [[RRP]] [[]]
: [[MG]] [[set voltage regulator. Specifically, maintenance personnel adjusted a potentiometer in the wrong direction which resulted in a trip of the]]
RRP and an unplanned Unit 3 plant transient.
19  Description:  On May 23, 2009, at approximately 9:30 a.m., the
: [[PBAPS]] [[Unit 3 'A']]
: [[RRP]] [[tripped. The trip occurred while instrument and controls (I&C) maintenance technicians were performing procedure]]
: [[IC]] [[-11-02011, "Recirc]]
MG Set Voltage Regulator Tuning,"
step 5.1.6.8. Step 5.1.6.8 states, "Verify step test box potentiometer is at
: [[MAXIMU]] [[M resistance (fully counter-clockwise) and]]
: [[CLOSE]] [[the switch of the step test circuit."  Contrary to the procedure instructions, the potentiometer, on the step test box, that is used to vary the test current applied to the]]
: [[RRP]] [[]]
MG set voltage regulator field, was incorrectly positioned to the minimum resistance (fully clockwise) position. When the
test box switch was closed, the incorrect positioning of the potentiometer resulted in an excessive
: [[MG]] [[set field current that tripped the]]
: [[MG]] [[set field breaker. The trip of the]]
: [[MG]] [[set field breaker resulted in the loss of the 3 'A']]
: [[RRP.]] [[The loss of core flow caused reactor power to decrease from approximately 75 percent to 33 percent. In response to the loss of the 3 'A']]
: [[RRP]] [[, operators entered operational transient procedure,]]
OT-112, "Unexpected/Unexplained Change in Core Flow" and
executed actions to stabilize the plant in single loop operations.
: [[I&C]] [[personnel aborted the performance of]]
: [[IC]] [[-11-02011 and removed all test equipment. The 3 'A']]
: [[RRP]] [[was subsequently restored per system operating procedure,]]
: [[SO]] [[2A.1.B-3, "Starting the Second Recirculation Pump" at 4:32 p.m. the same day.]]
: [[PBAPS]] [['s investigation indicated that there was a mindset among the technicians performing the work that the potentiometer had to be set to the maximum position and that this position was fully clockwise. Interviews with several I&C technicians indicated that the word "]]
MAXIMUM" as it relates to the operation of variable inputs almost always refers to the fully clockwise position. During the pre-job brief there was no mention of
rotating the potentiometer either clockwise or counter-clockwise, only of taking it to maximum. When the technicians reached the job site, the first technician verified the test box was in the maximum position by attempting to rotate the potentiometer in the clockwise
position. The technician then announced what his actions were and handed the procedure to a second technician who read the step and took the same action to verify the potentiometer position. This peer check was flawed because the first technician inappropriately took the action without a peer check and then asked for a peer check after the action was taken. The job supervisor was present during the entire evolution providing management oversight, and failed to notice the incorrect position of the potentiometer. Following the incorrect setting of the potentiometer, the technicians moved the test box switch from the
: [[OPEN]] [[to the]]
: [[CLOSE]] [[position which inserted the test signal and tripped the 3 'A']]
: [[MG]] [[set and]]
RRP. Immediately after the event, the technicians and their supervisor checked the connections and potentiometer position and all agreed the setup
was correct. When the team reached the main control room, the procedure was re-read and the technicians realized the error in the positioning of the test box potentiometer. The inspectors reviewed the root cause report to assess its details, accuracy, and planned corrective actions. The inspectors concluded that the root cause report was
thorough, detailed, and comprehensive. The planned and completed corrective actions were appropriate and comprehensive. The licensee identified two root causes and two contributing causes for this event. The root causes included failure to adhere to a Level 1 (step-by-step performance) procedure due to performing work in a
20  knowledge-based versus rule-based manner and the failure to perform an adequate peer check to verify the potentiometer position that resulted in a lost opportunity to identify the error prior to the plant transient.
: [[PBA]] [[]]
PS's investigation determined that the
technician performing the work was operating in the knowledge-based thinking mode because he knew that the potentiometer needed to be in the maximum position. If the technician had operated in the rule-based thinking mode, he would have been complying with the procedure instructions verbatim. The peer check was flawed in that the first technician took the action without a peer check and inappropriately asked the second
technician for a peer check after the action was taken. Analysis:  The inspectors determined that the
: [[I&C]] [[technician's failure to follow the procedure for tuning the 3 'A']]
: [[RRP]] [[]]
: [[MG]] [[set voltage regulator that resulted in a trip of the]]
RRP MG set and an unplanned plant transient was a performance deficiency. This finding was more than minor because it was associated with the human performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone
objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions. Specifically, this error resulted in an unplanned plant transient that reduced Unit 3 reactor power from 75 percent to 33 percent. In accordance with IMC 0609, Attachment 4, the inspectors determined this finding to be of very low safety significance (Green) since the finding did not contribute to both the likelihood of a reactor
trip and the likelihood that mitigation equipment or functions would not be available. This finding has a cross-cutting aspect in the area of human performance, Work Practices, because
: [[PBA]] [[]]
PS did not define and effectively communicate expectations regarding procedural compliance and personnel did not follow procedures [H.4(b)].
Specifically,
: [[PBAPS]] [[personnel did not follow procedure]]
: [[IC]] [[-11-02011 instructions for tuning the 3 'A']]
: [[RRP]] [[]]
: [[MG]] [[set voltage regulator  Enforcement:  The inspectors determined that the finding did not represent a violation of regulatory requirements because it involved a procedure violation of a non-safety related procedure. This finding will be tracked as]]
: [[FIN]] [[05000278/2009003-02, Inadequate Procedure Adherence Results in Trip of 3 'A' Recirc Pump and Plant Transient.  .2 (Closed) Licensee Event Report (]]
: [[LER]] [[) 05000278/2009-03-00, Inoperable Containment Isolation Valve Results in Condition Prohibited by]]
: [[TS]] [[s  On March 26, 2009, it was discovered that the 3D]]
RHR pump suppression pool suction
isolation valve (MO-3-10-013D) was degraded due to a greasing deficiency identified during performance of
: [[EOC]] [[testing associated with grease deficiencies previously discovered on motor-operated valves (]]
: [[MOV]] [[s). It was determined that this condition was prohibited by TSs since this valve is a primary containment isolation valve and was inoperable for containment isolation purposes for a time period longer than allowed by]]
: [[TS.]] [[The cause of the greasing deficiency was grease hardening primarily due to inadequate preventive maintenance. The valve was repaired and returned to service on March 27, 2009. A finding related to this event was documented in report section 4]]
OA2.1. This LER is closed.   
.3 (Closed)
: [[LER]] [[05000277/2009-01-00, Clearance Performance Error Results in Condition Prohibited by]]
TSs
21  On February 13, 2009,
: [[PBAPS]] [[personnel discovered that an operation prohibited by]]
TS existed when a TS required action for an inoperable Unit 2 control rod (Control Rod 10-51) was found not met. Specifically, at 9:33 a.m. on February 13, during a plant
walkdown being conducted in preparation to vent selected control rod drive (CRD) hydraulic control units (HCUs), the
: [[CRD]] [[]]
: [[HCU]] [[directional control valves (DCVs) for Control Rod 10-51 were discovered to be energized (armed). To comply with]]
: [[TS]] [[3.1.3, Condition C, these]]
: [[DCV]] [[s should have been de-energized (disarmed) since the 10-51]]
: [[CRD]] [[]]
HCU had been rendered inoperable for the conduct of maintenance on
February 11. This condition was due to an operator error that re-armed the
: [[DCV]] [[during the modification of a safety tagging clearance that occurred at approximately 5:30 a.m. on February 12, 2009. On February 13, after the]]
: [[TS]] [[non-compliance was identified at 9:33 a.m., prompt action was taken to disarm the]]
: [[CRD]] [[and restore]]
: [[TS]] [[compliance by 9:42 a.m. Since Control Rod 10-51 remained fully inserted during this event,]]
: [[PBAPS]] [[concluded that there was no actual safety consequences associated with this event. There were no previous similar]]
LERs identified. A licensee-identified NCV for this issue
is documented in Section
: [[4OA]] [[7; therefore, this]]
LER is closed.  .4 (Closed) LER 05000278/2009-01-00, Control Rods Inoperable During Mode 2 Operations As a Result of Interferences
As a result of control rod interference monitoring testing performed by Operations personnel on January 28, 2009, it was determined that three control rods were inoperable during the Unit 3 shutdown that was performed on January 21. This testing determined that Control Rods 14-55, 18-55, and 42-55 could be inoperable for operational conditions involving time periods when reactor pressure is below 850 psig
(Mode 2 operations). This occurrence was considered reportable as a common cause that resulted in the inoperability of three control rods for approximately 4.75 hours on January 21, during Mode 2 operations. The common cause is related to control rod blade interferences with the fuel bundle channel.
: [[PBA]] [[]]
PS concluded that there were no actual safety consequences associated with this event and that appropriate shutdown
margin was maintained during this event. Subsequently, a control rod interference monitoring and testing program was established.
: [[EOC]] [[testing was performed on Units 2 and 3. There were no previous similar]]
: [[LERS]] [[identified. The inspectors reviewed the event and concluded that the condition was appropriately reported as a common-cause inoperability. However, no violation or condition prohibited by]]
: [[TS]] [[existed because, in accordance with]]
TS 3.1.3, Condition E, Unit 3 was taken to
Mode 3 within 12 hours of reactor pressure being reduced below 850 psig; therefore, this
: [[LER]] [[is closed. 4]]
OA5 Other Activities   
.1 Quarterly Resident Inspector Observations of Security Personnel and Activities    a. Inspection Scope    During the inspection period the inspectors conducted observations of security force
personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working hours.
2  These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status reviews and inspection activities. b. Findings  No findings of significance were identified.
: [[4OA]] [[6 Meetings, Including Exit  Exit Meeting Summary  On July 17, 2009, the resident inspectors presented the inspection results to  Mr. W. Maguire and other]]
PBAPS staff, who acknowledged the findings. The inspectors asked the licensee whether any of the material examined during the inspection should
be considered proprietary. No proprietary information was identified. 4OA7 Licensee-Identified Violations  The following violation of very low significance (Green) was identified by the licensee
and is a violation of
: [[NRC]] [[requirements which meets the criteria of Section]]
: [[VI]] [[of the]]
: [[NRC]] [[Enforcement Policy for being dispositioned as a]]
: [[NCV.]] [[*]]
: [[TS]] [[3.1.3, Condition C, requires that control rods that are inoperable for reasons other than being stuck shall be fully inserted and disarmed.]]
: [[TS]] [[3.1.3, Condition E, requires the unit to be in Mode 3 within 12 hours if Condition C cannot be met. On February 11, the 10-51]]
: [[CRD]] [[]]
HCU was declared inoperable for the conduct of
maintenance and the
: [[TS]] [[required actions to fully insert and disarm the]]
: [[CRD]] [[were met. Following the completion of maintenance on the]]
: [[HCU]] [[, an operator erroneously re-armed the]]
: [[CRD]] [[]]
: [[HCU]] [[]]
DCVs during the modification of a safety tagging clearance that occurred at approximately 5:30 a.m. on February 12. Over 28 hours later and in excess of the 12-hour completion time allowed by
: [[TS]] [[3.1.3,]]
: [[PBAPS]] [[personnel discovered the error and disarmed the]]
: [[CRD]] [[for Control Rod 10-51.]]
: [[PBAPS]] [[documented this issue in the]]
: [[CAP]] [[as]]
: [[IR]] [[880318. Since Control Rod 10-51 remained fully inserted and there was no loss of safety function during the period of non-compliance, this issue is of very low (Green) safety significance. The]]
LER associated with the event was documented in
Section
: [[4OA]] [[3.3.]]
: [[ATTACH]] [[MENT:]]
: [[SUPPLE]] [[]]
: [[MENTAL]] [[]]
: [[INFORM]] [[]]
: [[ATION]] [[A-1]]
: [[SUPPLE]] [[]]
: [[MENTAL]] [[]]
: [[INFORM]] [[]]
: [[ATION]] [[]]
: [[KEY]] [[]]
: [[POINTS]] [[]]
: [[OF]] [[]]
CONTACT  Exelon Generation Company Personnel  W. Maguire, Site Vice President G. Stathes, Plant Manager J. Armstrong, Regulatory Assurance Manager
E. Flick, Engineering Director P. Navin, Work Management Director L. Lucas, Chemistry Manager R. Franssen, Operations Director R. Holmes, Radiation Protection Manager D. DeBoer, Security Manager T. Wasong, Training Director
: [[NRC]] [[Personnel  F. Bower, Senior Resident Inspector M. Brown, Resident Inspector]]
: [[E.]] [[Torres, Project Engineer A. Ziedonis, Reactor Inspector]]
: [[LIST]] [[]]
: [[OF]] [[]]
: [[ITEMS]] [[]]
: [[OPENED]] [[,]]
: [[CLOSED]] [[,]]
: [[AND]] [[]]
DISCUSSED
Opened  None
Opened/Closed  05000277/2009003-01
: [[NCV]] [[]]
: [[MOV]] [[Program Procedures were  05000278/2009003-01    Inadequate with Regard to Periodicity of Preventive Maintenance Activities        for Stem Lubrication          (Section]]
: [[4OA]] [[2.1)  05000278/2009003-02]]
FIN  Inadequate Procedure Adherence          Results in Trip of 3 'A'
Recirc Pump and Plant          Transient (Section 4OA3.1)
A-2Closed  05000278/2009-03-00
: [[LER]] [[Inoperable Containment Isolation          Valve Results in Condition Prohibited by]]
: [[TS]] [[s (Section]]
: [[4OA]] [[3.2)  05000277/2009-01-00]]
: [[LER]] [[Clearance Performance Error Results in Condition Prohibited by]]
: [[TS]] [[s (Section 4]]
: [[OA]] [[3.3)  05000278/2009-01-00]]
: [[LER]] [[Control Rods Inoperable During Mode 2 Operations as a Result of Interferences  (Section 4]]
: [[OA]] [[3.4)  Discussed  None]]
: [[LIST]] [[]]
: [[OF]] [[]]
: [[DOCUME]] [[]]
: [[NTS]] [[]]
: [[REVIEW]] [[]]
: [[ED]] [[Section 1R01:  Adverse Weather Protection]]
: [[SE]] [[-16, Revision 4, "Grid Emergency"]]
: [[SE]] [[-16, Attachment A, Revision 2, Power Team Generation Dispatcher/Power System Director (PTGD/PSD) Communications to Peach Bottom]]
: [[WC]] [[-]]
: [[AA]] [[-104, Revision 14, "Review and Screening for Production/Atmospheric/Environmental Risk"]]
: [[WC]] [[-]]
: [[AA]] [[-101, Revision 16, "On-Line Work Control Procedure"]]
: [[WC]] [[-]]
: [[AA]] [[-107, Revision 6, "Seasonal Readiness"]]
: [[WC]] [[-]]
: [[AA]] [[-8000, Revision 2, "Interface Procedure between Energy Delivery (ComED/PECO) and Exelon Generation (Nuclear/Power) for Construction and Maintenance Activities"]]
: [[WC]] [[-]]
: [[AA]] [[-8003, Revision 1, "Interface Procedure between Energy Delivery (ComED/PECO) and Exelon Generation (Nuclear/Power) for Design Engineering and Transmission Planning Activities"]]
: [[OP]] [[-]]
: [[AA]] [[-108-107, Revision 2, "Switchyard Control"]]
: [[OP]] [[-]]
: [[AA]] [[-108-107-1001, Revision 2, "Station Response to Grid Capacity Conditions"]]
: [[OP]] [[-]]
: [[AA]] [[-108-107-1002, Revision 4, "Interface Agreement between Exelon Energy Delivery and Exelon Generation for Switchyard Operations"  McDonald, John]]
: [[E.]] [[; "]]
: [[PECO]] [[Nuclear Station Switchyard Readiness Certification for Summer 2009," Memo to Michael Pacillio; May 15,]]
: [[2009 IR]] [[891537, 2009 Summer Readiness Action Item Tracking]]
: [[IR]] [[932267, Perform Permanent Repair to 'A' Cooling Tower Lift Pump Can]]
: [[IR]] [[922632, High Acetylene Levels in the 3]]
: [[SU]] [[Transformer Load Tap Changer]]
: [[IR]] [[921521,]]
: [[PBAPS]] [[and]]
: [[PE]] [[]]
: [[CO]] [[Summer Readiness Certification Letters Do Not Match]]
: [[IR]] [[921205, Aging Equipment]]
: [[HIT]] [[- Cooling Tower]]
: [[LTAM]] [[Review Issues]]
: [[IR]] [[918739, Large Transformer Summer Readiness Assessment]]
: [[IR]] [[917454, Unit 3 Switchgear House Exhaust Fan Breaker Tripped on Magnetics]]
IR 913699, Cooling Tower Walkdown Inspection  IR 912528, Unit 2 'B' Phase Main Transformer Cooling Bank Not Turning On
A-3IR 907656, Broken Joint Found on 'A' Cooling Tower Lift Pump IR 887537, Unit 3 Auxiliary Transformer Cooling Fan Not Running 


Section 1R04: Equipment Alignment  Drawing 6280-M-359,
==Section 4OA1: Performance Indicator (PI) Verification==
: [[360 RCIC]] [[System]]
: LS-AA-2001, Revision 12, Collecting and Reporting of NRC Performance Indicators Data
: [[SO]] [[13.1.A-2, Revision 13,]]
: LS-AA-2090, Revision 4, Monthly Data Elements for NRC RCS Specific Activity
: [[RCIC]] [[System Alignment for Automatic or Manual Initiation]]
: LS-AA-2100, Revision 5, Monthly Data Elements for NRC RCS Leakage
: [[COL]] [[13.1.A-2,]]
: ST-O-020-560-2, Reactor Coolant Leakage Test (sample of completed test records)
: [[RC]] [[]]
: ST-O-020-560-3, Reactor Coolant Leakage Test (sample of completed test records)
: [[IC]] [[System]]
: ST-C-095-864-2, Off Gas Monitor Response and Release Rate Verification by a Grab Sample
: [[COL]] [[13.1.B-2,]]
: ST-C-095-864-3, Off Gas Monitor Response and Release Rate Verification by a Grab Sample
: [[RCIC]] [[System Control Board Lineup]]
: ST-C-095-820-2, Determination of Dose Equivalent µCi/g I-131 in Primary Coolant
: [[COL]] [[44B.1.A, Revision 6, Control Room Chilled Water System  Section 1R05: Fire Protection]]
: ST-C-095-820-3, Determination of Dose Equivalent µCi/g I-131 in Primary Coolant
: [[PF]] [[-12B, Revision 3, Prefire Strategy Plan U3]]
: CH-407, Sampling of Reactor Water
: [[RBCCW]] [[Room Radwaste Building 116,  Fire Zone 12B]]
: CH-C-601, Determination of Dose Equivalent I-131
: [[PF]] [[-62, Revision 4, Prefire Strategy Plan U3]]
: [[HPCI]] [[Room 88' Elevation, Fire Zone 62]]
: [[PF]] [[-89, Revision 2, Prefire Strategy Plan Lube Oil Tank Room,]]
: [[TB]] [[3-116, Fire Zone 89]]
: [[PF]] [[-108, Revision 3, Prefire Strategy Plan Control Room, Turbine Building 165' Elevation,  Fire Zone 108]]
: [[PF]] [[-4C, Revision 6, Prefire Strategy Plan U2]]
: [[RX]] [[Recirc Pump]]
: [[MG]] [[Set Room, Radwaste  Building, 135' Elevation, Fire Zone 4C  Section 1R11: Licensed Operator Requalification Program]]
: [[OP]] [[-AA-101-111, Roles and Responsibilities of On-Shift Personnel, Revision]]
: [[3 OP]] [[-]]
: [[AA]] [[-103-102, Watchstanding Practices, Revision]]
: [[8 OP]] [[-]]
: [[AA]] [[-103-103, Operation of Plant Equipment, Revision 0]]
: [[OP]] [[-]]
: [[AA]] [[-104-101, Communications, Revision]]
: [[1 PSEG]] [[1009R, Revision 3, Loss of Vacuum, Electrical]]
: [[ATWS]] [[Section 1R12: Maintenance Effectiveness]]
: [[IR]] [[875571, Clearances Required for Unit 3 Control Rods]]
: [[IR]] [[889545, 2B]]
: [[MTSV]] [[Failed to Reset]]
: [[IR]] [[906648, 2A]]
: [[MTSV]] [[Slow to Tripp]]
: [[IR]] [[906661, 2B]]
: [[MTSV]] [[Failed to Reset]]
: [[IR]] [[909080, 3A]]
: [[MT]] [[]]
: [[SV]] [[Failed to Reset]]
: [[IR]] [[909628, 2B]]
: [[MTSV]] [[Failed to Reset]]
: [[IR]] [[912636, 2B]]
: [[MTSV]] [[Slow to Reset]]
: [[IR]] [[932238, Small Water Leak in Unit 3]]
: [[CST]] [[Moat]]
: [[IR]] [[930640, Unit 3]]
: [[CST]] [[Moat Water is Cloudy Since Moat Recoat IR 928861, Document Results of Tritium Age Dating]]
: [[IR]] [[927784, Develop Contingency Plans for Well Drilling]]
: [[IR]] [[921975, Evaluate Soft Digging Inside the Unit]]
: [[3 CST]] [[Moat Area]]
: [[IR]] [[916050, Increase in Unit 3 Yard Drain Sum Tritium]]
: [[IR]] [[895539, Tritium Detected in New Monitoring Wells]]
: [[IR]] [[894134, Elevated Tritium in Unit 2 Yard Drain Sump]]
: [[IR]] [[859610, Tritium Dating Analysis Needed to Determine Tritium Source]]
IR 814380, Continued Increase in Tritium Level in Well #4 IR 791859, Increased Tritium Level Trend for Groundwater Monitoring Well #4
A-4Section 1R13:  Maintenance Risk Assessments and Emergent Work Control
: [[IR]] [[870284, Heating on the Base of the]]
: [[XK]] [[8 Relay]]
: [[IR]] [[877404, Heating on the]]
: [[EHC]] [[XK17 Relay Spade Connection]]
: [[IR]] [[910561, Unit 2]]
: [[EHC]] [[Relay]]
: [[XK]] [[8 Exceeded]]
: [[ACMP]] [[Action Level of 80C]]
: [[IR]] [[911610, Unit 2]]
: [[EHC]] [[]]
: [[XK]] [[17 Relay Found Loose in Its Base]]
: [[IR]] [[911675, Cause of]]
: [[EHC]] [[Relay Hot Spot Identified]]
: [[IR]] [[911903, Improvement Opportunity in]]
: [[PORC]] [[Review of]]
: [[EHC]] [[Power Supply]]
: [[AR]] [[A1695813, Heating on the Base of the]]
: [[XK]] [[8 Relay]]
: [[WO]] [[C0227471, Replace]]
: [[XK]] [[8 Relay and Base, Rework]]
: [[XK]] [[17 Connector]]
: [[ER]] [[-AA-302-1001,]]
: [[MOV]] [[Rising Stem Motor Operated Valve Thrust and Torque  Sizing and Set-up Window Determination Methodology, Revision 6 I.E. Bulletin 85-03, Supplement 1: Motor Operated Valve Common Mode Failures During Plant  Transients due to Improper Switch Settings]]
: [[IR]] [[060023, Dedication of Lubrication Used on Safety-Related Systems]]
: [[IR]] [[827482, U2]]
: [[HPCI]] [[MO-57 Stroked in Alert Range Then Stopped Moving]]
: [[IR]] [[892191,]]
: [[MO]] [[-2-23-058 Stopped in Intermediate Position]]
: [[IR]] [[895626, U3]]
: [[HPCI]] [[Suction Valve Stem Grease Condition]]
: [[IR]] [[895789, U3]]
: [[HPCI]] [[Torus Suction]]
: [[MO]] [[-3-23-57, Split Indication]]
: [[IR]] [[896914, Test Results of Stored Exxon Nebula]]
: [[EP]] [[-1 Grease]]
: [[IR]] [[898645,]]
: [[MOV]] [[Stem Lube Activity and]]
: [[PM]] [[Frequency Recommendation]]
: [[IR]] [[899298, Procedure]]
: [[MA]] [[-AA-723-301 Deficiency]]
: [[IR]] [[906768,]]
: [[MO]] [[-2-10-015D Did Not Stroke Open During]]
: [[PMT]] [[]]
: [[IR]] [[913852,]]
: [[FME]] [[- Foreign Material was Found in 3]]
: [[AF]] [[106 Discharge Micron filter]]
: [[WO]] [[C0228763, 3]]
: [[AP]] [[017, Investigate/Replace Pump]]
: [[WO]] [[R1102249, 3]]
: [[AF]] [[106, PM: Replace Filter Element]]
: [[WO]] [[M1687797, Replace Filter]]
: [[WO]] [[A1709877, Foreign Material was Found in]]
: [[3AF]] [[106 Discharge Micron filter Letter from]]
: [[PBAPS]] [[to]]
: [[NRC]] [[, dated May 14, 1999: Response to Generic Letter 96-05 Letter from]]
: [[NRC]] [[to]]
: [[PBAPS]] [[, dated November 16, 2000: Safety Evaluation by]]
: [[NRR]] [[of Licensee  Response to Generic Letter 96-05]]
: [[MA]] [[-]]
: [[AA]] [[-723-301, Periodic Inspection of Limitorque Model]]
: [[SMB]] [[/]]
: [[SB]] [[/SBD-000 through 5 Motor  Operated valves, Revision 4 M-C-700-241, Limitorque Motor Operator Installation, Revision]]
: [[5 NRC]] [[Inspection Report 50-277/92-82 and 50-278-92-82]]
: [[NRC]] [[Inspection Report: Motor- Operated Valve Inspection 94-12]]
: [[NRC]] [[Inspection Report 50-277/96-03 and 50-278/96-03]]
: [[NRC]] [[Inspection Report 50-277/97-07 and 50-278/97-07]]
: [[NRC]] [[Inspection Report 50-277/99-01 and 50-278/99-01]]
: [[NRC]] [[Inspection Report 05000440/2005003: Perry Supplemental Inspection]]
: [[NRC]] [[Inspection Report 05000277/2007005 and 05000278/2007005, Section 4]]
: [[OA]] [[2.3: U2]]
: [[MOV]] [[Failure to Stroke Follow-up]]
: [[NUREG]] [[/CR-6750: Performance of MOV Stem Lubricants at Elevated Temperatures]]
: [[P&ID]] [[:]]
: [[RHR]] [[, M-361, Sh.]]
: [[2 WO]] [[R0013148:]]
: [[MO]] [[-2-23-058-OP: Perform Operator]]
: [[PM]] [[]]
: [[WO]] [[R1018644:]]
: [[MO]] [[-3-10-025B-]]
: [[OP]] [[: Motor Operator]]
: [[PM]] [[]]
: [[WO]] [[A1714585, Exceeded]]
: [[ACMP]] [[Action level for U3 Main Condenser]]
: [[WO]] [[C0227407, XJ-3170B; Additional Sealant Application]]
: [[WO]] [[A1579262, Proactive Replacement of the 3B]]
: [[RFPT]] [[Exhaust Expansion Joint]]
: [[WO]] [[A1700673, 4 scfm Step Change in U3 Offgas Flow]]
WO A1636058, U3 Step Increase in Offgas Flow on 10/18/07
A-5WO A1714764,
: [[LP]] [[Turbine to Condenser Expansion Joint has Leakage]]
: [[WO]] [[R1127007, Helium Mass Spectro Connection to Offgas]]
: [[IR]] [[931031, Air In-leakage at 3A]]
: [[LP]] [[Turbine Dog Bone IR 931035, Condensate Drain Tank - Small Leak Identified]]
: [[IR]] [[936787, Bearing #6 Slop Drain Confirmed Leakage with Smoke]]
IR 936791, U3 Turbine #4 Slop Drain Cover Dislocated Procedure SO 5.7.A-3, Revision 8, Main Condenser Vacuum Leak Monitoring and Search


Section 1R15: Operability Evaluations
==Section 4OA2: Identification and Resolution of Problems==
: [[IR]] [[873016, P3R18 Torus Recoat]]
: ER-AA-300, Motor Operated Valve Program Administrative Procedure, Revision 5
: [[IR]] [[838841, P3R17]]
: ER-AA-302, Motor Operated Valve Program Engineering Procedure, Revision 5
: [[CISI]] [[Scope -]]
: ER-AA-302-1001, MOV Rising Stem Motor Operated Valve Thrust and Torque Sizing and Set- up Window Determination Methodology, Revision 6
: [[UT]] [[of Piping in Torus Airspace]]
: ER-AA-302-1003, MOV Margin Analysis and Periodic Verification Test Intervals, Revision 5
: [[IR]] [[838844, P3R17]]
: ER-AA-302-1004, Motor Operated Valve Performance Trending, Revision 4
: [[CISI]] [[Scope - Torus Diver Inspections]]
: ER-AA-302-1006, Generic Letter 96-05 Program Motor-Operated Valve Maintenance and
: [[IR]] [[878127, P3R17 Torus Cleaning and Inspection]]
: Testing Guidelines, Revision 7 M-C-700-241, Limitorque Motor Operator Installation, Revision 5
: [[IR]] [[873016, P3R18 Torus Recoat]]
: MA-AA-723-300, Diagnostic Testing of Motor Operated Valves
: [[IR]] [[838841, P3R17]]
: MA-AA-723-300-1001, Motor Operated Valve "At the Valve" Diagnostic Test Reduction 
: [[CISI]] [[Scope - UT of Piping in Torus Airspace]]
: A-7Strategy, Revision 0
: [[IR]] [[838844, P3R17]]
: MA-AA-723-301, Periodic Inspection of Limitorque Model SMB/SB/SBD-000 through 5 Motor
: [[CISI]] [[Scope - Torus Diver Inspections]]
: Operated valves, Revision 4
: [[IR]] [[878127, P3R17 Torus Cleaning and Inspection]]
: MA-AA-723-302-1001, MOV Rising Stem Motor Operated Valve Thrust and Torque Sizing and
: [[IR]] [[919671,]]
: Set-up Window Determination Methodology M-C-700-241, Limitorque Motor Operator Installation, Revision 5
: [[TS]] [[3.8.7 Interpretation Concerns]]
: IR 060023, Dedication of Lubrication Used on Safety Related Systems
: [[IR]] [[931760 -TS 3.8.7 Interpretation Concerns Information Notice 97-80:  Licensee TS Interpretations]]
: IR 827482, U2 HPCI
: [[IR]] [[881184, 2]]
: MO-57 Stroked in Alert Range Then Stopped Moving
: [[BA]] [[034 (3402) Action Level Changed from "Blue" to "Yellow"]]
: IR 892191,
: [[ACMP]] [[- Unit 2 'B' Recirc Pump Trip Breaker Temperatures]]
: MO-2-23-058 Stopped in Intermediate Position
: [[IR]] [[867732,]]
: IR 892191, Assignment 8, Root Cause for MOV Degraded Grease and Performance Issues
: [[2BA]] [[034 (3401) Inspect Breaker During Next Refuel Outage]]
: IR 895626, U3 HPCI Suction Valve Stem Grease Condition
: [[IR]] [[867719,]]
: IR 895789, U3 HPCI Torus Suction
: [[2BA]] [[034 (3402) Inspect Breaker During Next Refuel Outage  Section 1R18:  Plant Modifications]]
: MO-3-23-57, Split Indication
: [[AR]] [[A1693909, Damaged Electrical Ductbank]]
: IR 896914, Test Results of Stored Exxon Nebula
: [[WO]] [[C0226402, Install Monitoring Equipment/]]
: EP-1 Grease
: [[TCCP]] [[08-00408  Section 1R19:  Post-Maintenance Testing]]
: IR 898030,
: [[WO]] [[C0220912, 2]]
: MO-3-10-13D Stem Nut Wear & Underthrust
: [[AK]] [[018, Rebuild and Eddy Current Test]]
: IR 898645, MOV Stem Lube Activity and PM Frequency Recommendation
: [[SO]] [[44A.6.A-2, Placing an Additional Drywell Chiller in Service]]
: IR 899298, Procedure
: [[IR]] [[910529, 2 'A' Drywell Chiller Tripped during PMT Run]]
: MA-AA-723-301 Deficiency
: [[AR]] [[A1711246, Leakage in Unit 3]]
: IR 901501,
: [[RWCU]] [[Regenerative Heat Exchanger Room]]
: MO-2-10-154B As-found Test Underthrust
: [[WO]] [[C0228895,]]
: IR 906768,
: [[HV]] [[-3-12-30K/31K: Perform Leak Repair]]
: MO-2-10-015D Did Not Stroke Open During PMT Letter from PBAPS to NRC, dated May 14, 1999: Response to Generic Letter 96-05 Letter from NRC to PBAPS, dated November 16, 2000: Safety Evaluation by NRR of Licensee
: [[IR]] [[918477, Leakage in Unit 3]]
: Response to Generic Letter 96-05 Peach Bottom Unit 3
: [[RWCU]] [[Regenerative Heat Exchanger Room Technical Repair Procedure (TRP) - 3002, Revision 1, 1/8"]]
: LER 09-03, Inoperable Containment Isolation Valve Results in Condition
: [[NPT]] [[Drill and Tap]]
: Prohibited by TSs, May 12, 2009 NRC Inspection Report 50-277/92-82 and 50-278-92-82 NRC Inspection Report: MOV Inspection 94-12 NRC Inspection Report 50-277/96-03 and 50-278/96-03
: [[CC]] [[-AA-404, Maintenance Specification:  Application, Selection, Evaluation and Control of Temporary Leak Repairs]]
: NRC Inspection Report 50-277/97-07 and 50-278/97-07 NRC Inspection Report 50-277/99-01 and 50-278/99-01 NRC Inspection Report 05000440/2005003: Perry Supplemental Inspection NRC Integrated Inspection Report 05000387/2006003 and 05000388/2006003, Section 1R15 NRC Integrated Inspection Report 05000277/2007005 and 05000278/2007005, Section
: [[IR]] [[921526, 2 'A']]
: 4OA2.3: U3 MOV Failure to Stroke Follow-up Nuclear Event Report (NER)
: [[CAD]] [[Analyzer Failed to Trip During ST-I-07G-103-2]]
: PB-09-009 Green, Peach Bottom: HPCI Torus Suction Inboard
: [[WO]] [[C0229040, Determine Which]]
: Isolation Valve
: [[SV]] [[is Not Isolating]]
: MO-2-23 Failed in Mid-stroke and did not Fully Open Nuclear Event Report (NER)
: [[ST]] [[-I-07G-103-2,]]
: NC-09-014-Y Yellow: MOVs Fail to Operate due to Degraded
: [[PCIS]] [[Group]]
: Stem Lubrication Nuclear Network Operating Experience Report,
: [[III]] [[Logic System Functional Test, Completed on 5/19/09]]
: OE 28589: Peach Bottom - MOV Failure to
: [[WO]] [[A1712378, 2 'A']]
: Fully Function NUREG/CR-6750: Performance of MOV Stem Lubricants at Elevated Temperatures P&ID: RHR, M-361, Sh. 2 EPRI Technical Repair Guideline for Limitorque Model
: [[CAD]] [[Analyzer Failed to Trip]]
: SMB-000 Valve Actuators, Revision 1 I.E. Bulletin 85-03, Supplement 1: Motor Operated Valve Common Mode Failures during Plant
: [[WO]] [[C0225963 - Replace the Tube Bundles during the]]
: Transients due to Improper Switch Settings Limitorque Bulletin
: [[TSA]] [[Window]]
: SMB1-82C, "Limitorque Type SMB Instruction Manual and Maintenance
: [[WO]] [[A1651390 - E1 EDG Jacket Coolant Heat Exchanger Reduced Margin]]
: Manual," copyright 1982 WO R0013148:
: [[WO]] [[C0229077, 0]]
: MO-2-23-058-OP: Perform Operator PM WO R1018644:
: [[AV]] [[079-DR, Replace Motor]]
: MO-3-10-025B-OP: Motor Operator PM
: [[ECR]] [[09-00291, 0]]
: Issue Reports
: [[AV]] [[079-DR is Obsolete]]
: IR 880318, U2
: [[WO]] [[A1712722, 0]]
: HCU 10-51 DCV's Connected with Control Rod Inop.
: [[AV]] [[079-DR is Obsolete]]
: IR 887441, Fuse 16A-F20 was Blown During
: [[P&ID]] [[Drawing - M-384, Control Room]]
: PS-9087G Replacement 
: [[HVAC]] [[A-6WO C0229510, Troubleshoot Speed Switch, Rework as required]]
: A-8IR
: [[WO]] [[R1067972, 0]]
: 853625, Incorrect Pins Were Removed & Inspected on Fuel Bundle JLM633
: [[AG]] [[012-DR - Diesel Engine Inspection]]
: IR 923239, 3A Recirc Pump Trip
: [[WO]] [[R1067972 - Act. 74, Perform]]
: IR 820443, 250 Volt DC Disconnect Found Closed During
: [[PMT]] [[of Speed Switch WO R1067972 - Act 81, Remove/ Repair Tachometer]]
: AO 57B.9-2
: [[IR]] [[935794,]]
: IR 871864, Spurious 'A' WRNM Short Period Trip
: [[ECW]] [[/ESW Pumps Did Not Auto Start During E-1]]
: IR 869364, 3A WRNM is Not Responding
: [[DG]] [[Testing]]
: IR 868369, U3 Power Reduction for 3C Main Transformer Gassing
: [[IR]] [[935800, E-1]]
: IR 891763, U3 #1 BPV Cycling
: [[DG]] [[Started and]]
: IR 874398, Indications of Channel Distortion - Peach Bottom 3
: [[ESW]] [[and]]
: IR 687330, Unplanned Downpower in Response to 3A Recirc Seal Hi Temp
: [[ECW]] [[Pumps Failed to Start]]
: IR 753418, Unexpected Speed Changes on 3A Recirc
: [[IR]] [[935053, Red indicating light on for]]
: IR 892191,
: [[EHC]] [[Micron Filters]]
: MO-2-23-058, Stopped in Intermediate
: [[WO]] [[A1716915,]]
: IR 913965, Failure of
: [[3BF]] [[106 Red indicating light on for]]
: MO-3-10-013D to Stroke During
EHC Micron Filters WO M1716915, Replace Filter
: RT-O-010-304-3
Procedure SO 1D.5.A-3, Revision 25, Electrohydraulic Control System Filter Changing  and Cleaning
: IR 636103,
Section 1R22: Surveillance Testing
: PE-0121 Provided Non-Conservative MOV Voltages in Midas
: [[IR]] [[910465, Line Up Incorrect for A]]
: IR 608000, Heat Transfer Test Unsat. Update PTRM
: [[CREV]] [[Filter Testing ST-M-40D-905-2, Revision 17, Control Room Emergency Ventilation Filter Train 'A' Test]]
: IR 647108, Loss of Turbine Building Negative
: [[ON]] [[-115, Loss of Normal Main Control Room Ventilation]]
: IR 642941, LEFM System Impact Due to Letter from Manufacturer
: [[SI]] [[3P-5-12-C1C2, Revision 8, Calibration Check of]]
: IR 650861, Unit 1 Water Sample Greater Than Effluent Concentration Limit
: [[RPS]] [[Drywell Pressure Loop Instruments]]
: IR 808191, Evaluation of Unit 1 Containment Tritium
: [[PT]] [[/PS 3-5-12C]]
: IR 811317, Unit 1 Tech Specs Potentially Non-Conservative
: [[WO]] [[R1066021,]]
: IR 798807, Perform a RCA for the ESW Piping Issues
: [[RPS]] [[]]
: IR 304543, Develop Strategy for Long-Term Reliability of HPSW Piping
: [[DW]] [[Pressure 'C' Loop Inst]]
: IR 618185, Cathodic Protection System Action Plan
: [[RT]] [[-O-01D-402-2, Revision 5, Master Trip Solenoid Valves Operability Test]]
: IR 822594, Service Water to ESW Cross Tie Check Valve Leaks Through
: [[WO]] [[R1126058, Master Trip Solenoid Valves Operability Test]]
: IR 451634, NRC I.D. NPSH Margin for FSSD in Re-Rate
: [[IR]] [[906649, 'A']]
: IR 453385, Low Margin in HPCI NPSH Calculation
: [[MTSV]] [[Slow to Operate]]
: IR 452577, Lack of Allowance for Frequency Variation in EDG Load Calculation
: [[IR]] [[926105, Increased Unit 2 Drywell Floor Drain Pump Outs (Unidentified Leakage)  Section]]
: IR 476280, Flow Rate Used in Calc
: [[4OA]] [[1: Performance Indicator (]]
: PM-046 Is Non-Conservative
: [[PI]] [[) Verification]]
: IR 609922, Required Power Supply Analysis Not Performed
: [[LS]] [[-]]
: IR 215452, Circuit Breaker to 343-SU Transformer
: [[AA]] [[-2001, Revision 12, Collecting and Reporting of]]
: IR 566338, LTA Modeling of Torus Level in the Update PRA
: [[NRC]] [[Performance Indicators Data]]
: IR 148966, App R Impact of Loss of CSR HVAC System
: [[LS]] [[-AA-2090, Revision 4, Monthly Data Elements for]]
: IR 643320, Omission of Item from the Commitment Tracking Program
: [[NRC]] [[]]
: IR 573736, License Renewal Commitment Identification Deficiencies
: [[RCS]] [[Specific Activity]]
: IR 571536, Actions Required to Ensure Compliance with New SRBC Docket
: [[LS]] [[-]]
: IR 163240, Conowingo Pond Level Management and SBO Line Vulnerabilities
: [[AA]] [[-2100, Revision 5, Monthly Data Elements for]]
: IR 736060, Loss of SBO Capability at Peach Bottom
: [[NRC]] [[]]
: IR 571207, Bubbles in E3 Jacket Coolant Sight-Glass During Run
: [[RCS]] [[Leakage ST-O-020-560-2, Reactor Coolant Leakage Test (sample of completed test records)]]
: IR 656655, E1 Diesel Running Alarm and Reset During Full Load Run
: [[ST]] [[-O-020-560-3, Reactor Coolant Leakage Test (sample of completed test records)]]
: IR 522128, Evaluate Ultra Low Sulfur Diesel (ULSD) Fuel Impacts
: [[ST]] [[-C-095-864-2, Off Gas Monitor Response and Release Rate Verification by a Grab Sample]]
: IR 514214, Diesel Heat Exchanger Tube Plugging
: [[ST]] [[-C-095-864-3, Off Gas Monitor Response and Release Rate Verification by a Grab Sample]]
: IR 528780, PSA Inaccuracies Regarding EDG's
: [[ST]] [[-C-095-820-2, Determination of Dose Equivalent µCi/g I-131 in Primary Coolant ST-C-095-820-3, Determination of Dose Equivalent µCi/g I-131 in Primary Coolant]]
: IR 527680, TRM Appendix B List of PCIVS Not Complete
: [[CH]] [[-407, Sampling of Reactor Water]]
: IR 591658, Change TRM Testing Requirements for SBGT Fire Suppression System
CH-C-601, Determination of Dose Equivalent I-131
: IR 569168, Exelon Versus Station or PECO Documents May Have Conflict
Section
: IR 481490, Procedures Requiring RPS Test Boxes May Need Revision
: [[4OA]] [[2:  Identification and Resolution of Problems]]
: IR 570922, IPEEE Reference on Barrier Drawings Not Addressed in A-C-134
: [[ER]] [[-]]
: IR 572347, Create Procedure Revision to Address Gas Intrusion
: [[AA]] [[-300, Motor Operated Valve Program Administrative Procedure, Revision]]
: IR 666004, NOS ID'd No PORC Reviewed Procedure for Containment Access
: [[5 ER]] [[-]]
: IR 392563, Declaration of LPCI Inoperable While In Torus CLG Not Optimized
: [[AA]] [[-302, Motor Operated Valve Program Engineering Procedure, Revision 5]]
: IR 634709, Diesel Driven Fire Pump (DDFP) Operability Testing
: [[ER]] [[-]]
: IR 637035, Unnecessary Testing
: [[AA]] [[-302-1001,]]
: IR 631157, Peach Bottom 4
: [[MOV]] [[Rising Stem Motor Operated Valve Thrust and Torque Sizing and Set- up Window Determination Methodology, Revision 6]]
th 10-Year IST Interval 
: [[ER]] [[-AA-302-1003,]]
: A-9IR
: [[MOV]] [[Margin Analysis and Periodic Verification Test Intervals, Revision 5]]
: 673505, Security Inattentiveness Allegation
: [[ER]] [[-AA-302-1004, Motor Operated Valve Performance Trending, Revision]]
: IR 473526, Maintenance Rule Performance Criteria Need Improvement
: [[4 ER]] [[-]]
: IR 632012, Winter Readiness Critique 2006-2007
: [[AA]] [[-302-1006, Generic Letter 96-05 Program Motor-Operated Valve Maintenance and  Testing Guidelines, Revision 7 M-C-700-241, Limitorque Motor Operator Installation, Revision]]
: IR 677383, Slop Drain MOD w/o Activities were Closed vs. Rescheduled
: [[5 MA]] [[-]]
: [[AA]] [[-723-300, Diagnostic Testing of Motor Operated Valves]]
: [[MA]] [[-]]
AA-723-300-1001, Motor Operated Valve "At the Valve" Diagnostic Test Reduction
A-7Strategy, Revision
: [[0 MA]] [[-]]
: [[AA]] [[-723-301, Periodic Inspection of Limitorque Model]]
: [[SMB]] [[/]]
: [[SB]] [[/SBD-000 through 5 Motor  Operated valves, Revision]]
: [[4 MA]] [[-]]
: [[AA]] [[-723-302-1001,]]
: [[MOV]] [[Rising Stem Motor Operated Valve Thrust and Torque Sizing and  Set-up Window Determination Methodology M-C-700-241, Limitorque Motor Operator Installation, Revision 5]]
: [[IR]] [[060023, Dedication of Lubrication Used on Safety Related Systems]]
: [[IR]] [[827482, U2]]
: [[HPCI]] [[]]
: [[MO]] [[-57 Stroked in Alert Range Then Stopped Moving]]
: [[IR]] [[892191, MO-2-23-058 Stopped in Intermediate Position]]
: [[IR]] [[892191, Assignment 8, Root Cause for]]
: [[MOV]] [[Degraded Grease and Performance Issues]]
: [[IR]] [[895626, U3]]
: [[HPCI]] [[Suction Valve Stem Grease Condition]]
: [[IR]] [[895789, U3]]
: [[HPCI]] [[Torus Suction]]
: [[MO]] [[-3-23-57, Split Indication]]
: [[IR]] [[896914, Test Results of Stored Exxon Nebula]]
: [[EP]] [[-1 Grease]]
: [[IR]] [[898030,]]
: [[MO]] [[-3-10-13D Stem Nut Wear & Underthrust]]
: [[IR]] [[898645,]]
: [[MOV]] [[Stem Lube Activity and]]
: [[PM]] [[Frequency Recommendation]]
: [[IR]] [[899298, Procedure]]
: [[MA]] [[-AA-723-301 Deficiency]]
: [[IR]] [[901501,]]
: [[MO]] [[-2-10-154B As-found Test Underthrust]]
: [[IR]] [[906768,]]
: [[MO]] [[-2-10-015D Did Not Stroke Open During]]
: [[PMT]] [[Letter from]]
: [[PBAPS]] [[to]]
: [[NRC]] [[, dated May 14, 1999: Response to Generic Letter 96-05 Letter from]]
: [[NRC]] [[to]]
: [[PBAPS]] [[, dated November 16, 2000: Safety Evaluation by]]
: [[NRR]] [[of Licensee  Response to Generic Letter 96-05 Peach Bottom Unit]]
: [[3 LER]] [[09-03, Inoperable Containment Isolation Valve Results in Condition  Prohibited by]]
: [[TS]] [[s, May 12,]]
: [[2009 NRC]] [[Inspection Report 50-277/92-82 and 50-278-92-82]]
: [[NRC]] [[Inspection Report:]]
: [[MOV]] [[Inspection 94-12]]
: [[NRC]] [[Inspection Report 50-277/96-03 and 50-278/96-03]]
: [[NRC]] [[Inspection Report 50-277/97-07 and 50-278/97-07]]
: [[NRC]] [[Inspection Report 50-277/99-01 and 50-278/99-01]]
: [[NRC]] [[Inspection Report 05000440/2005003: Perry Supplemental Inspection]]
: [[NRC]] [[Integrated Inspection Report 05000387/2006003 and 05000388/2006003, Section 1R15]]
: [[NRC]] [[Integrated Inspection Report 05000277/2007005 and 05000278/2007005, Section  4]]
: [[OA]] [[2.3: U3]]
: [[MOV]] [[Failure to Stroke Follow-up Nuclear Event Report (]]
: [[NER]] [[)]]
: [[PB]] [[-09-009 Green, Peach Bottom:]]
: [[HPCI]] [[Torus Suction Inboard  Isolation Valve]]
: [[MO]] [[-2-23 Failed in Mid-stroke and did not Fully Open Nuclear Event Report (]]
: [[NER]] [[)]]
: [[NC]] [[-09-014-Y Yellow:]]
: [[MOV]] [[s Fail to Operate due to Degraded  Stem Lubrication Nuclear Network Operating Experience Report,]]
: [[OE]] [[28589: Peach Bottom -]]
: [[MOV]] [[Failure to  Fully Function]]
: [[NUREG]] [[/]]
: [[CR]] [[-6750: Performance of]]
: [[MOV]] [[Stem Lubricants at Elevated Temperatures P&]]
: [[ID]] [[:]]
: [[RHR]] [[, M-361, Sh. 2]]
: [[EPRI]] [[Technical Repair Guideline for Limitorque Model]]
: [[SMB]] [[-000 Valve Actuators, Revision 1 I.E. Bulletin 85-03, Supplement 1: Motor Operated Valve Common Mode Failures during Plant  Transients due to Improper Switch Settings Limitorque Bulletin]]
: [[SMB]] [[1-82C, "Limitorque Type]]
: [[SMB]] [[Instruction Manual and Maintenance  Manual," copyright 1982]]
: [[WO]] [[R0013148:]]
: [[MO]] [[-2-23-058-]]
: [[OP]] [[: Perform Operator]]
: [[PM]] [[]]
: [[WO]] [[R1018644:]]
: [[MO]] [[-3-10-025B-]]
OP: Motor Operator
: [[PM]] [[Issue Reports]]
: [[IR]] [[880318, U2]]
: [[HCU]] [[10-51]]
: [[DCV]] [['s Connected with Control Rod Inop.]]
IR 887441, Fuse 16A-F20 was Blown During PS-9087G Replacement
A-8IR 853625, Incorrect Pins Were Removed & Inspected on Fuel Bundle
: [[JLM]] [[633]]
: [[IR]] [[923239, 3A Recirc Pump Trip]]
: [[IR]] [[820443, 250 Volt]]
: [[DC]] [[Disconnect Found Closed During]]
: [[AO]] [[57B.9-2]]
: [[IR]] [[871864, Spurious 'A']]
: [[WR]] [[]]
: [[NM]] [[Short Period Trip]]
: [[IR]] [[869364, 3A]]
: [[WRNM]] [[is Not Responding]]
: [[IR]] [[868369, U3 Power Reduction for 3C Main Transformer Gassing]]
: [[IR]] [[891763, U3 #1]]
: [[BPV]] [[Cycling]]
: [[IR]] [[874398, Indications of Channel Distortion - Peach Bottom 3 IR 687330, Unplanned Downpower in Response to 3A Recirc Seal Hi Temp]]
: [[IR]] [[753418, Unexpected Speed Changes on 3A Recirc]]
: [[IR]] [[892191,]]
: [[MO]] [[-2-23-058, Stopped in Intermediate]]
: [[IR]] [[913965, Failure of]]
: [[MO]] [[-3-10-013D to Stroke During]]
: [[RT]] [[-O-010-304-3]]
: [[IR]] [[636103,]]
: [[PE]] [[-0121 Provided Non-Conservative]]
: [[MOV]] [[Voltages in Midas]]
: [[IR]] [[608000, Heat Transfer Test Unsat. Update]]
: [[PTRM]] [[]]
: [[IR]] [[647108, Loss of Turbine Building Negative]]
: [[IR]] [[642941,]]
: [[LEFM]] [[System Impact Due to Letter from Manufacturer]]
: [[IR]] [[650861, Unit 1 Water Sample Greater Than Effluent Concentration Limit]]
: [[IR]] [[808191, Evaluation of Unit 1 Containment Tritium]]
: [[IR]] [[811317, Unit 1 Tech Specs Potentially Non-Conservative]]
: [[IR]] [[798807, Perform a]]
: [[RCA]] [[for the]]
: [[ESW]] [[Piping Issues]]
: [[IR]] [[304543, Develop Strategy for Long-Term Reliability of]]
: [[HPSW]] [[Piping]]
: [[IR]] [[618185, Cathodic Protection System Action Plan]]
: [[IR]] [[822594, Service Water to]]
: [[ESW]] [[Cross Tie Check Valve Leaks Through]]
: [[IR]] [[451634,]]
: [[NRC]] [[I.D.]]
: [[NPSH]] [[Margin for]]
: [[FSSD]] [[in Re-Rate]]
: [[IR]] [[453385, Low Margin in]]
: [[HPCI]] [[]]
: [[NPSH]] [[Calculation]]
: [[IR]] [[452577, Lack of Allowance for Frequency Variation in]]
: [[EDG]] [[Load Calculation]]
: [[IR]] [[476280, Flow Rate Used in Calc]]
: [[PM]] [[-046 Is Non-Conservative]]
: [[IR]] [[609922, Required Power Supply Analysis Not Performed]]
: [[IR]] [[215452, Circuit Breaker to 343-SU Transformer]]
: [[IR]] [[566338,]]
: [[LTA]] [[Modeling of Torus Level in the Update]]
: [[PRA]] [[]]
: [[IR]] [[148966, App R Impact of Loss of]]
: [[CSR]] [[]]
: [[HVAC]] [[System]]
: [[IR]] [[643320, Omission of Item from the Commitment Tracking Program]]
: [[IR]] [[573736, License Renewal Commitment Identification Deficiencies]]
: [[IR]] [[571536, Actions Required to Ensure Compliance with New]]
: [[SRBC]] [[Docket]]
: [[IR]] [[163240, Conowingo Pond Level Management and]]
: [[SBO]] [[Line Vulnerabilities]]
: [[IR]] [[736060, Loss of]]
: [[SBO]] [[Capability at Peach Bottom]]
: [[IR]] [[571207, Bubbles in E3 Jacket Coolant Sight-Glass During Run]]
: [[IR]] [[656655, E1 Diesel Running Alarm and Reset During Full Load Run]]
: [[IR]] [[522128, Evaluate Ultra Low Sulfur Diesel (]]
: [[ULSD]] [[) Fuel Impacts]]
: [[IR]] [[514214, Diesel Heat Exchanger Tube Plugging]]
: [[IR]] [[528780,]]
: [[PSA]] [[Inaccuracies Regarding]]
: [[EDG]] [['s]]
: [[IR]] [[527680,]]
: [[TRM]] [[Appendix B List of]]
: [[PCIVS]] [[Not Complete]]
: [[IR]] [[591658, Change]]
: [[TRM]] [[Testing Requirements for]]
: [[SBGT]] [[Fire Suppression System]]
: [[IR]] [[569168, Exelon Versus Station or]]
: [[PECO]] [[Documents May Have Conflict]]
: [[IR]] [[481490, Procedures Requiring]]
: [[RPS]] [[Test Boxes May Need Revision]]
: [[IR]] [[570922,]]
: [[IPEEE]] [[Reference on Barrier Drawings Not Addressed in A-C-134]]
: [[IR]] [[572347, Create Procedure Revision to Address Gas Intrusion]]
: [[IR]] [[666004,]]
: [[NOS]] [[]]
: [[ID]] [['d No]]
: [[PO]] [[]]
: [[RC]] [[Reviewed Procedure for Containment Access]]
: [[IR]] [[392563, Declaration of]]
: [[LPCI]] [[Inoperable While In Torus]]
: [[CLG]] [[Not Optimized]]
: [[IR]] [[634709, Diesel Driven Fire Pump (DDFP) Operability Testing]]
: [[IR]] [[637035, Unnecessary Testing]]
IR 631157, Peach Bottom 4th 10-Year IST Interval
A-9IR 673505, Security Inattentiveness Allegation
: [[IR]] [[473526, Maintenance Rule Performance Criteria Need Improvement]]
: [[IR]] [[632012, Winter Readiness Critique 2006-2007]]
: [[IR]] [[677383, Slop Drain]]
MOD w/o Activities were Closed vs. Rescheduled  


Section
==Section 4OA3: Event Followup==
: [[4OA]] [[3:  Event Followup]]
: IR 923239, 3 'A' Recirc Pump Trip (Include Root Cause Report) Procedure
: [[IR]] [[923239, 3 'A' Recirc Pump Trip (Include Root Cause Report) Procedure]]
: IC-11-02011, Revision 4, Recirc MG Set Voltage Regulator Tuning
: [[IC]] [[-11-02011, Revision 4, Recirc MG Set Voltage Regulator Tuning]]
: IR 925955, Inappropriate Action Identified During Root Cause Analysis Procedure
: [[IR]] [[925955, Inappropriate Action Identified During Root Cause Analysis Procedure]]
: GP-9-3, Revision 35, Fast Reactor Power Reduction Procedure
: [[GP]] [[-9-3, Revision 35, Fast Reactor Power Reduction Procedure]]
: OT-112, Revision 39, Unexpected/Unexplained Change in Core Flow Procedure
: [[OT]] [[-112, Revision 39, Unexpected/Unexplained Change in Core Flow Procedure]]
: GP-5-1, Exhibit - PBAPS Power Flow Operation Map PBAPS TS 3.8.7, Electrical Power Systems, Distribution Systems -
: [[GP]] [[-5-1, Exhibit -]]
: Operating
: [[PBAPS]] [[Power Flow Operation Map]]
: HU-AA-104-101, Revision 3, Procedure Use and Adherence
: [[PBAPS]] [[]]
==LIST OF ACRONYMS==
: [[TS]] [[3.8.7, Electrical Power Systems, Distribution Systems - Operating]]
: [[AC]] [[Alternating Current]]
: [[HU]] [[-AA-104-101, Revision 3, Procedure Use and Adherence]]
: [[LIST]] [[]]
: [[OF]] [[]]
: [[ACRONY]] [[]]
: [[MS]] [[AC  Alternating Current]]
: [[ACMP]] [[Adverse Condition Monitoring Plan]]
: [[ACMP]] [[Adverse Condition Monitoring Plan]]
: [[ADAMS]] [[Agency-wide Documents Access and Management System]]
: [[ADAMS]] [[Agency-wide Documents Access and Management System]]
Line 1,160: Line 838:
: [[CFR]] [[Code of Federal Regulations]]
: [[CFR]] [[Code of Federal Regulations]]
: [[CRD]] [[Control Rod Drivel]]
: [[CRD]] [[Control Rod Drivel]]
: [[DEP]] [[Drill and Exercise Performance DCVs  Directional Control Valves]]
: [[DEP]] [[Drill and Exercise Performance]]
: [[DCV]] [[Directional Control Valves]]
: [[EDG]] [[Emergency Diesel Generator]]
: [[EDG]] [[Emergency Diesel Generator]]
: [[EHC]] [[Electro-Hydraulic Control]]
: [[EHC]] [[Electro-Hydraulic Control]]
: [[EOC]] [[Extent-of-Condition]]
: [[EOC]] [[Extent-of-Condition]]
: [[EP]] [[Emergency Preparedness FPP Fire Protection Plan]]
: [[EP]] [[Emergency Preparedness]]
: [[HCU]] [[s  Hydraulic Control Units]]
: [[FPP]] [[Fire Protection Plan]]
: [[HPCI]] [[High Pressure Coolant Injection]]
: [[HCU]] [[Hydraulic Control Units]]
: [[I&C]] [[Instrument and Controls]]
: [[HPCI]] [[High Pressure Coolant Injection I&C Instrument and Controls]]
: [[IMC]] [[Inspection Manual Chapter]]
: [[IMC]] [[Inspection Manual Chapter]]
: [[IP]] [[Inspection Procedure]]
: [[IP]] [[Inspection Procedure]]
: [[IR]] [[Issue Report LER License Event Reports]]
: [[IR]] [[Issue Report]]
: [[LER]] [[License Event Reports]]
: [[MG]] [[Motor\Generator]]
: [[MG]] [[Motor\Generator]]
: [[MOV]] [[s  Motor-Operated Valves]]
: [[MOV]] [[Motor-Operated Valves]]
: [[MS]] [[Mitigating Systems]]
: [[MS]] [[Mitigating Systems]]
: [[MTSV]] [[Master Trip Solenoid Valve NCV Non-cited Violation]]
: [[MTSV]] [[Master Trip Solenoid Valve]]
: [[NCV]] [[Non-cited Violation]]
: [[NEI]] [[Nuclear Energy Institute]]
: [[NEI]] [[Nuclear Energy Institute]]
: [[NRC]] [[Nuclear Regulatory Commission]]
: [[NRC]] [[Nuclear Regulatory Commission]]
: [[OOS]] [[Out-of-Service]]
: [[OOS]] [[Out-of-Service]]
PARS  Publicly Available Records
PARS  Publicly Available Records  
 
A-10PBAPS Peach Bottom Atomic Power Station
A-10PBAPS Peach Bottom Atomic Power Station
: [[PMT]] [[Post-Maintenance Testing]]
: [[PMT]] [[Post-Maintenance Testing]]
: [[RG]] [[Regulatory Guide PI Performance Indicator]]
: [[RG]] [[Regulatory Guide]]
: [[PI]] [[Performance Indicator]]
: [[PI&R]] [[Problem Identification and Resolution]]
: [[PI&R]] [[Problem Identification and Resolution]]
: [[RCIC]] [[Reactor Core Isolation Cooling]]
: [[RCIC]] [[Reactor Core Isolation Cooling]]
: [[RCS]] [[Reactor Coolant System]]
: [[RCS]] [[Reactor Coolant System]]
: [[RG]] [[Regulatory Guide RHR Residual Heat Removal]]
: [[RG]] [[Regulatory Guide]]
: [[RHR]] [[Residual Heat Removal]]
: [[RPS]] [[Reactor Protection System]]
: [[RPS]] [[Reactor Protection System]]
: [[RRP]] [[Reactor Recirculation Pump]]
: [[RRP]] [[Reactor Recirculation Pump]]
: [[RTP]] [[Rated Thermal Power]]
: [[RTP]] [[Rated Thermal Power]]
: [[SDP]] [[Significance Determination Process]]
: [[SDP]] [[Significance Determination Process]]
: [[SSC]] [[s  Structures, Systems, and Components]]
: [[SSC]] [[Structures, Systems, and Components]]
: [[ST]] [[s  Surveillance Tests TRM Technical Requirements Manual]]
: [[ST]] [[Surveillance Tests]]
: [[TRM]] [[Technical Requirements Manual]]
: [[TS]] [[Technical Specification]]
: [[TS]] [[Technical Specification]]
: [[TSC]] [[Technical Support Center]]
: [[TSC]] [[Technical Support Center]]
: [[UFSAR]] [[Updated Final Safety Analysis Report]]
: [[UFSAR]] [[Updated Final Safety Analysis Report WO Work Order]]
: [[WO]] [[Work Order]]
}}
}}

Revision as of 17:35, 25 August 2018

IR 05000277-09-003, 05000278-09-003, on 04/01/09 - 06/30/09; Peach Bottom Atomic Power Station,Power Station, Units 2 and 3, Identification and Resolution of Problems, Follow-up of Events and Notices of Enforcement Discretion
ML092220599
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 08/10/2009
From: Krohn P G
Reactor Projects Region 1 Branch 4
To: Pardee C G
Exelon Generation Co, Exelon Nuclear
KROHN P G, RI/DRP/PB4/610-337-5120
References
IR-09-003
Download: ML092220599 (35)
v • d • e


Text

August 10, 2009

Mr. Charles Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT: PEACH BOTTOM ATOMIC POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000277/2009003 AND 05000278/2009003

Dear Mr. Pardee:

On June 30, 2009, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The enclosed integrated inspection report documents the inspection results, which were discussed on July 17, 2009, with Mr. William Maguire and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, two self-revealing findings of very low safety significance (Green) were identified. One of these findings was determined to involve a violation of NRC requirements. Additionally, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. However, because of the very low safety significance and because the finding has been entered into your corrective action program (CAP), the NRC is treating the finding as a non-cited violation (NCV), consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U. S. NRC, Washington, DC 20555-0001; and the NRC Resident Inspector at the PBAPS. In addition, if you disagree with the characterization of the cross-cutting aspect of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region 1 and the NRC Senior Resident Inspector at PBAPS. The information you provide will be considered in accordance with Inspection Manual Chapter (IMC) 0305.

In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

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

Enclosures:

Inspection Report 05000277/2009003 and 05000278/2009003

w/Attachment:

Supplemental Information cc w/encl:

C. Crane, President and Chief Operating Officer, Exelon Corporation M. Pacilio, Chief Operating Officer, Exelon Nuclear W. Maguire, Site Vice President, Peach Bottom J. Grimes, Acting Senior Vice President, Mid-Atlantic R. Hovey, Senior Vice President, Nuclear Oversight G. Stathes, Plant Manager, Peach Bottom J. Armstrong, Regulatory Assurance Manager, Peach Bottom J. Bardurski, Manager, Financial Control & Co-Owner Affairs R. Franssen, Director, Operations P. Cowan, Director, Licensing D. Helker, Licensing K. Jury, Vice President, Licensing and Regulatory Affairs J. Bradley Fewell, Associate General Counsel, Exelon T. Wasong, Director, Training Correspondence Control Desk D. Allard, Director, Bureau of Radiation Protection, PA Department of Environmental Protection S. Gray, Administrator, Maryland Power Plant Research Program S. Pattison, Secretary, SLO, Maryland Department of the Environment M. Griffen, Maryland Department of Environment Public Service Commission of Maryland, Engineering Division Board of Supervisors, Peach Bottom Township B. O'Connor, Council Administrator of Harford County Council Mr. & Mrs. Dennis Hiebert, Peach Bottom Alliance E. Epstein, TMI - Alert J. Johnsrud, National Energy Committee, Sierra Club Mr. & Mrs. Kip Adams R. Fletcher, Dir, MD Environmental Program Manager, Radiological Health Program Director, Nuclear Safety Project, Union of Concerned Scientists R. Ayers, Deputy Mgr, Harford County Div of Emergency Operations E. Crist, Harford County Div of Emergency Operations S. Ayers, Emergency Planner, Harford County Div of Emergency Operations R. Brooks, Cecil County Dept of Emergency Services Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/ Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects

Distribution w/encl:

(via E-mail)

S. Collins, RA M. Dapas, DRA D. Lew, DRP J. Clifford, DRP P. Krohn, DRP R. Fuhrmeister, DRP A. Rosebrook, DRP E. Torres, DRP J. Bream, DRP F. Bower, DRP, SRI M. Brown, DRP, RI S. Schmitt, DRP, OA L. Trocine, RI OEDO H. Chernoff, NRR R. Nelson, NRR J. Hughey, PM NRR P. Bamford, Backup NRR ROPreports@nrc.gov Region I Docket Room (with concurrences)

SUNSI Review Complete: ___PGK___ (Reviewer's Initials)

ML092220599 DOCUMENT NAME: G:\DRP\BRANCH4\INSPECTION REPORTS\PEACH BOTTOM\PBIR2009-003 REV 4.DOC After declaring this document "An Official Agency Record" it will be released to the Public.

To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure " E" = Copy with attachment

/enclosure "N" = No copy OFFICE RI/DRP RI/DRP RI/DRP NAME FBower/ PGK for JBream/ * PKrohn/ PGK DATE 08/10 /09 07/ 24 /09 08/10 /09 OFFICIAL RECORD COPY

  • Concurred on 7/24/09, JRB

1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION I Docket Nos.: 50-277, 50-278

License Nos.: DPR-44, DPR-56 Report No.: 05000277/2009003 and 05000278/2009003 Licensee: Exelon Generation Company, LLC

Facility: Peach Bottom Atomic Power Station, Units 2 and 3

Location: Delta, Pennsylvania Dates: April 1, 2009 through June 30, 2009

Inspectors: F. Bower, Senior Resident Inspector M. Brown, Resident Inspector E. Torres, Project Engineer A. Ziedonis, Reactor Inspector

Approved by: Paul G. Krohn, Chief Reactor Projects Branch 4 Division of Reactor Projects

Enclosure 2

SUMMARY OF FINDINGS

IR 05000277/2009003, 05000278/2009003; 04/01/2009 - 06/30/2009; Peach Bottom Atomic

Power Station, Units 2 and 3; Identification and Resolution of Problems; Follow-up of Events and Notices of Enforcement Discretion

.

The report covered a three-month period of inspection by resident inspectors and an announced inspection by a regional reactor inspector. Two self-revealing findings were identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using IMC 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. Cross-cutting aspects associated with findings are determined using IMC 0305, "Operating Reactor Assessment Program," dated January 2009. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Cornerstone: Initiating Events

Green.

A self-revealing finding was identified when PBAPS personnel incorrectly performed a maintenance procedure for tuning the reactor recirculation pump (RRP) motor generator (MG) set voltage regulator. Specifically, maintenance personnel adjusted a potentiometer in the wrong direction, which resulted in a trip of the RRP and an unplanned plant transient.

This finding is more than minor because the finding is associated with the human performance attribute of the Initiating Events Cornerstone, and adversely affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions. Specifically, this error resulted in an unplanned plant transient that reduced reactor power from 75 percent to 33 percent. In accordance with IMC 0609, Attachment 4, the inspectors determined this finding to be of very low safety significance (Green) since the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. This finding has a cross-cutting aspect in the area of human performance, Work Practices, because PBAPS did not define and effectively communicate expectations regarding procedural compliance and personnel did not follow procedures H.4(b). Specifically, PBAPS personnel did not follow procedure IC-11-02011 instructions for tuning the 3 'A' RRP MG set voltage regulator. (Section 4OA3.1)

Cornerstone: Mitigating Systems and Barrier Integrity

Green.

A self-revealing NCV of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," was identified. Specifically, Exelon's Motor Operated Valve (MOV) Program procedures lacked specific instructions to prescribe an acceptable frequency for performing valve stem lubrication, which resulted in test failures of safety-related MOVs and affected the reliability of the MOVs' safety functions.

On Unit 2, the inspectors determined that the finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). In accordance with IMC 0609, Attachment 4, the inspectors determined that the finding was of very low safety significance (Green)because it was not a design or qualification deficiency, did not represent a loss of system safety function, and was not associated with any external events. On Unit 3, the inspectors determined that the finding was more than minor because it was associated with the configuration control attribute of the Barrier Integrity Cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers (e.g., containment) protect the public from radionuclide releases caused by accidents or events. In accordance with IMC 0609, Attachment 4, the inspectors determined that the finding was of very low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of reactor containment. For both units, this finding has a cross-cutting aspect in the area of Problem Identification and Resolution (PI&R), Corrective Action Program, because PBAPS did not thoroughly evaluate problems such that the resolutions addressed the causes and extent of condition P.1(c). Specifically, PBAPS failed to thoroughly evaluate previous conditions of degraded and hardened grease on safety-related valves, such that the extent of the condition was considered and the cause was resolved. (Section 4OA2)

Other Findings

A violation of very low safety significance, which was identified by the licensee, has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's CAP. This violation and the licensee's corrective action tracking numbers are listed in Section 4OA7 of this report.

5

REPORT DETAILS

Summary of Plant Status

Unit 2 began the inspection period at 100 percent rated thermal power (RTP). On April 24, a power reduction to 23 percent RTP was conducted in response to continued degradation and heating of electrical components in the electro-hydraulic control (EHC) system. On April 26, the unit was returned to full power. Unit 2 remained at or near full power for the remainder of the inspection period.

Unit 3 began the inspection period at 100 percent RTP. On May 22, power was reduced to 75 percent RTP to support planned summer readiness maintenance and adjustments to a RRP MG set voltage regulator. An unplanned power reduction from 75 percent to 32 percent occurred when the 3 'A' RRP tripped during the adjustments to its MG set voltage regulator. On May 25, the unit was returned to full power. On June 13, 2009, the unit was reduced to 62 percent for emergent maintenance to repair degrading condenser in-leakage on the 3 'B' main feed pump turbine exhaust expansion joint. On June 14, 2009, the unit was returned to full power. Unit 3 remained at or near full power for the remainder of the inspection period.

1.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection (71111.01 - 2 Samples)

.1 Grid Reliability

a. Inspection Scope

The inspectors reviewed plant features and procedures for operation and continued availability of offsite and backup power systems during adverse weather (summer conditions). The inspectors reviewed communication protocols between the control room personnel and electrical system operations, as well as measures prescribed and taken to maintain the availability and reliability of these alternating current (AC) systems. Documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings of significance were identified.

.2 Summer Seasonal Readiness Preparations

a. Inspection Scope

The inspectors conducted a review of PBAPS's preparations for the 2009 summer conditions to verify selected features of the plant's design were sufficient to protect mitigating systems from the effects of adverse weather. The inspectors reviewed PBAPS's implementation of procedure WC-AA-107, "Seasonal Readiness," in preparation for summer season readiness. Documentation for selected risk-significant systems was reviewed to ensure that these systems would remain functional when challenged by inclement weather. During the inspection, the inspectors focused on plant specific design features and the licensee's procedures used to mitigate or respond to adverse weather conditions. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and performance requirements for systems selected for inspection. The inspectors reviewed CAP records to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their CAP.

In addition, the inspectors reviewed the "Certification of 2009 Summer Readiness" memorandum dated May 15, 2009. Documents reviewed during this inspection are listed in the Attachment. The inspectors walked down the following systems and equipment:

  • Intake Structure Ventilation System

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment

.1 Partial Walkdown (71111.04Q - 3 Samples)

a. Inspection Scope

The inspectors performed a partial walkdown of three systems to verify the operability of redundant or diverse trains and components when safety-related equipment was inoperable. The inspectors reviewed selected applicable operating procedures, walked down system components, and verified that selected breakers, valves, and support equipment were in the correct position to support system operation. Documents reviewed during this inspection are listed in the Attachment. The inspectors walked down the systems below:

  • E-2, 3, and 4 EDGs with E-1 OOS; and
  • 'A' Control Room Chilled Water System with 'B' Control Room Chilled Water System OOS.

b. Findings

No findings of significance were identified.

.2 Complete Walkdown (71111.04S - 1 Sample)

a. Inspection Scope

The inspectors performed a complete system walkdown of the accessible portions of the Unit 2 reactor core isolation cooling system (RCIC), verifying that accessible breakers, valves and support equipment were properly aligned to support system operation. The inspectors reviewed system operating procedures and piping and instrumentation drawings; walked down control system components; and verified that circuit breakers and valves were in the appropriate positions. Documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings of significance were identified

1R05 Fire Protection

.1 Fire Protection - Tours (71111.05Q - 5 Samples)

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment. The inspectors reviewed areas to assess if PBAPS had implemented the Peach Bottom Fire Protection Plan (FPP) and adequately: controlled combustibles and ignition sources within the plant; maintained fire detection and suppression capability; and maintained the material condition of passive fire protection features. For the areas inspected, the inspectors also verified that PBAPS had followed the Technical Requirements Manual (TRM) and the FPP when compensatory measures were implemented for OOS, degraded, or inoperable fire protection equipment, systems, or features. The inspectors verified: that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient combustible materials were managed in accordance with plant procedures; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. Documents reviewed during this inspection are listed in the Attachment. The inspectors toured the following areas:

  • Unit 3 Reactor Building Closed-Cooling Water (RBCCW) Room, Unit 3 Radwaste Building, 116' Elevation (Fire Zone 12B);
  • Unit 3 High-Pressure Coolant Injection (HPCI) Room, Unit 3 Reactor Building, 88' Elevation (Fire Zone 62);
  • Unit 2 RRP MG Set Room, Radwaste Building, 135' Elevation (Fire Zone 4C);
  • Main Control Room, Turbine Building, 165' Elevation (Fire Zone 108); and
  • Unit 3 Lube Oil Tank Room, Turbine Building, 116' Elevation (Fire Zone 89).

b. Findings

No findings of significance were identified.

.2 Annual Fire Protection Drill Observation (71111.05A - 1 Sample)

a. Inspection Scope

On April 16, 2009, the inspectors observed fire brigade classroom training and live-fire drills at the PECO Energy Fire Academy in West Conshohocken, Pennsylvania. The inspectors noted that the classroom training provided a refresher on the Incident Management System and its techniques, methods, and terminology that are used to manage fire fighting or hazardous material events.

The inspectors noted that the live-fire fighting was done in burn facilities that simulated a transformer oil fire and fire involving plant cabling and equipment. The observation was used to determine whether appropriate learning opportunities were provided and to determine the readiness of the plant fire brigade to fight fires. The inspectors verified that the PBAPS fire brigade participants and the training instructors identified deficiencies; openly discussed them in a self-critical manner at the drill debrief, and appropriately documented the identified issues to develop corrective actions for future training. Specific attributes evaluated were:

  • Proper Wearing of Turnout Gear and Self-contained Breathing Apparatus;
  • Proper Use and Layout of Fire Hoses;
  • Employment of Appropriate Fire Fighting Techniques;
  • Sufficient Fire Fighting Equipment Brought to the Scene;
  • Effectiveness of Fire Brigade Leader Communications, Command, and Control;
  • Search for Victims and Propagation of the Fire Into Other Plant Areas;
  • Smoke Removal Operations;
  • Use of Pre-planned Strategies;
  • Adherence to the Pre-planned Drill Scenario; and
  • Drill Objectives.

The inspectors verified that procedure RT-F-101-922-2, "Fire Drill," was completed to record the fire drill scenario used, document that the drill objectives were met, and capture the critique results.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program (71111.11Q - 1 Sample)

.1 Resident Inspector Quarterly Review

a. Inspection Scope

On June 23, 2009, the inspectors observed two crews of licensed operators in the plant's simulator during licensed operator requalification examinations to verify that operator performance was adequate, evaluators were identifying and documenting crew performance deficiencies, and training was being conducted in accordance with licensee procedures. The crew's performance was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed during this inspection are listed in the Attachment. The inspectors evaluated the following areas:

  • Licensed Operator Performance;
  • Crew's Clarity and Formality of Communications;
  • Ability to Take Timely Actions in the Conservative Direction;
  • Prioritization, Interpretation, and Verification of Annunciator Alarms;
  • Correct Use and Implementation of Abnormal and Emergency Procedures;
  • Control Board Manipulations;
  • Oversight and Direction from Supervisors; and
  • Ability to Identify and Implement Appropriate Technical Specification (TS) Actions and Emergency Plan Actions and Notifications.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness (71111.12Q - 2 Samples)

a. Inspection Scope

The inspectors evaluated PBAPS's work practices and follow-up corrective actions for safety-related structures, systems, and components (SSCs) and identified issues to assess the effectiveness of PBAPS's maintenance activities. The inspectors reviewed the performance history of SSCs and assessed Exelon's extent-of-condition (EOC) determinations for those issues with potential common cause or generic implications to evaluate the adequacy of the PBAPS's corrective actions. The inspectors assessed PBAPS's PI&R actions for these issues to evaluate whether PBAPS had appropriately monitored, evaluated, and dispositioned the issues in accordance with Exelon procedures and the requirements of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance." In addition, the inspectors reviewed selected SSC classifications, performance criteria and goals, and Exelon's corrective actions that were taken or planned, to evaluate whether the actions were reasonable and appropriate. Documents reviewed during this inspection are listed in the Attachment. The inspectors reviewed the following two samples:

  • Apparent Cause Evaluation for Tritium Increase in Groundwater Monitoring Well #4 (IR 808183).

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 4 Samples)

a. Inspection Scope

The inspectors evaluated PBAPS

=s implementation of their Maintenance Risk Program with respect to the effectiveness of risk assessments performed for maintenance activities that were conducted on SSCs. The inspectors also verified that the licensee managed the risk in accordance with 10 CFR Part 50.65(a)(4) and procedure WC-AA-101, AOn-line Work Control Process." The inspectors evaluated whether PBAPS had taken the necessary steps to plan and control emergent work activities and to manage overall plant risk. The inspectors selectively reviewed PBAPS's use of the online risk monitoring software, and daily work schedules. The activities selected were based on plant maintenance schedules and systems that contributed to risk. Documents reviewed during this inspection are listed in the Attachment. The inspectors reviewed the following samples:

  • Emergent Power Reduction for Work to Correct Heating of Two Relays in the Unit 2 EHC System (Work Order (WO) C0227471 & IR 870284-08);
  • Work Activities Associated with Unit 2 Residual Heat Removal (RHR) Discharge Valve MO-2-10-154B and Unit 3 RHR Pump Suction Valve MO-3-10-13D Underthrust Conditions (WO C0228319);
  • Foreign Material was Found in Unit 3 'A' EHC Pump's Discharge Filter (WO C0228763); and
  • Exceeded Adverse Condition Monitoring Plan (ACMP) Action Level for Unit 3 Main Condenser (WO A1714585).

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations (71111.15 - 4 Samples)

a. Inspection Scope

The inspectors assessed the technical adequacy of the operability evaluations, the use and control of compensatory measures, and compliance with the licensing and design bases. Associated ACMPs, engineering technical evaluations, and operational and technical decision making documents were also reviewed. The inspectors verified these processes were performed in accordance with the applicable administrative procedures and were consistent with NRC guidance. Specifically, the inspectors referenced procedure OP-AA-108-115, "Operability Determinations," and NRC IMC Part 9900, "Operability Determinations & Functionality Assessments for Resolutions of Degraded or Nonconforming Conditions Adverse to Quality or Safety." The inspectors also used Technical Specifications (TSs), TRM, UFSAR, and associated Design Basis Documents as references during these reviews. Documents reviewed during this inspection are listed in the Attachment. The inspectors reviewed the following samples:

  • Determine the Scope of Torus Material and Method (Wet\Dry) that Requires Recoat in Unit 2 [P2R19] and Unit 3 [P3R18] Refueling Outages (IR 873016-03);
  • Electrical Distribution Bases (3.8.7) Potential Needs Upgraded (IR 894904);
  • Unit 2 Reactor Recirculation Motor Breaker Action Level Changed from BLUE to YELLOW (IR 881184).

b. Findings

No findings of significance were identified.

1R18 Plant Modifications (71111.18 - 1 Sample)

.1 Temporary Modifications

a. Inspection Scope

The inspectors reviewed one temporary modification to verify that implementation of the modification did not place the plant in an unsafe condition. The review was also conducted to verify that the design bases, licensing bases, and performance capability of risk significant SSCs had not been degraded as a result of these modifications. The inspectors verified the modified equipment alignment through control room instrumentation observations; UFSAR, drawings, procedures, and WO reviews; and plant walkdowns of accessible equipment. Documents reviewed during this inspection are listed in the Attachment. The inspectors reviewed the following sample:

  • ECR 09-00078 000, Re-Route Cables from Damaged Duct Bank To Support Duct Bank Repair.

b. Findings

No findings of significance were identified.

1R19 Post-Maintenance Testing (71111.19 - 7 Samples)

a. Inspection Scope

The inspectors observed selected portions of post-maintenance testing (PMT) activities and reviewed completed test records. The inspectors observed whether the tests were performed in accordance with the approved procedures and assessed the adequacy of the test methodology based on the scope of maintenance work performed. In addition, the inspectors assessed the test acceptance criteria to evaluate whether the test demonstrated that the tested components satisfied the applicable design and licensing bases and the TS requirements. The inspectors reviewed the recorded test data to verify that the acceptance criteria were satisfied. Documents reviewed during this inspection are listed in the Attachment. The inspectors reviewed the following samples:

  • Perform Leak Sealant Injection on Regenerative Heat Exchanger Tube Side Outer Vent Valve (WO C0228895);
  • Replace Tube Bundles in the E-1 EDG (WO C0225963);
  • Replace 'A' Control Room Supply Fan Motor (WO C0229077);
  • Troubleshoot EDG E-1 Speed Switch, Rework as Required (WO C0229510); and
  • Replace 3B EHC Micron Filter (WO M1716915).

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing (71111.22 - 5 Samples)

a. Inspection Scope

The inspectors compared test data with established acceptance criteria to verify the systems demonstrated the capability of performing the intended safety functions. The inspectors also verified that the systems and components maintained operational readiness, met applicable TS requirements, and were capable of performing design basis functions. Documents reviewed during this inspection are listed in the Attachment. The inspectors reviewed the following samples:

  • ST-O-010-301-2, 2 'A' RHR Loop Pump, Valve, Flow, and Unit Cooler Functional and Inservice Test [Inservice Test Sample]; and

b. Findings

No findings of significance were identified.

Cornerstone:

Emergency Preparedness (EP)

1EP6 EP Drill Evaluation (71114.06 - 1 Drill Sample)

a. Inspection Scope

The inspectors evaluated the conduct of a PBAPS emergency drill on June 1, 2009, to identify any weaknesses and deficiencies in classification and notification activities. The drill was conducted to provide drill and exercise performance (DEP) opportunities for the DEP performance indicator (PI). The inspectors observed operators respond to events in the simulator control room through the declaration and notification of an alert. The inspectors observed the operations shift manager transition emergency response command and control responsibilities to the site emergency director in the technical support center (TSC). The inspectors relocated to the TSC to observe command and control of the emergency response organization and dose assessment as the event escalated to the declaration and notification of a site area emergency. The inspectors verified that the event classification and notifications were done in accordance with EP-AA-1007, "Exelon Nuclear Radiological Emergency Plan Annex for PBAPS." The inspectors verified that the drill evaluators correctly counted the drill's contribution in the calculation of the DEP PI. The inspectors also verified that operations personnel in the simulator control room identified weaknesses or deficiencies during the critique of the drill. The following simulated events were classified during this training exercise:

  • FS1 - Site Area Emergency, Fission Product Barrier Degradation; and
  • HA5 - Alert, Natural and Destructive Phenomena.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator Verification (71151 - 10 Samples)

Cornerstone:

Initiating Events and Barrier Integrity

.1 Initiating Events PIs (71151 - 6 Samples)

a. Inspection Scope

The inspectors sampled PBAPS's submittals for the PIs listed below for Units 2 and 3 for the period from January 2008 through March 2009. PI definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, were used to verify the accuracy of the PI data. The inspectors reviewed selected portions of the operating logs and raw PI data, and selected applicable licensee event reports and CAP documents from the period for each PI specified below. The inspectors compared graphical representations from the most recent PI report to the raw data and used the performance indicator definition in the NEI guideline to verify that the data were correctly reflected in the report. Documents reviewed during this inspection are listed in the Attachment. The following six PI samples were reviewed:

Units 2 and 3

  • Unplanned Scrams with Complications; and

b. Findings

No findings of significance were identified.

.2 Barrier Integrity PIs (71151 - 4 Samples)

a. Inspection Scope

The inspectors reviewed a sample of PBAPS's submittals for the four Barrier Integrity PIs listed below to verify the accuracy of the data reported. The PI definitions and the guidance contained in NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, and Exelon procedure LS-AA-2001, "Collecting and Reporting of NRC Performance Indicator Data," were used to verify that the reporting requirements were met. The inspectors reviewed raw PI data collected since January 2008 to April 2009 and compared graphical representations from the most recent PI report to the raw data to verify the data was included in the report. Documents reviewed during this inspection are listed in the Attachment. The following four PI samples were reviewed:

Units 2 and 3

4OA2 Identification and Resolution of Problems (PI&R)

(71152 - 2 Samples)1. Annual Sample: MOV Hardened Grease Challenges (1 In-depth Review Sample)

a. Inspection Scope

This inspection focused on Exelon's identification, evaluation, and resolution of challenges associated with hardened grease on safety-related MOV. Specifically, two HPCI valves failed to stroke to the full open position during surveillance testing on March 12 and March 21, 2009. MOV disassembly and inspection identified hardened grease on the stem and inside the stem nut of both valves. Initial extent-of-condition evaluations revealed that two RHR valves developed less-than-required closing thrust for successful diagnostic test acceptance. Hardened grease was also identified on the stem and inside the stem nut of both RHR valves. The final extent-of-condition scoping determined that 45 safety-related MOVs required additional evaluation appropriate to the circumstances, such as visual inspection, grease evaluation, diagnostic testing, and/or corrective maintenance.

The inspectors reviewed Exelon's associated root cause evaluation, operability evaluations, corrective action reports, and a sample of diagnostic and stroke time test data, and interviewed plant personnel to evaluate the adequacy of Exelon's performance in the areas of problem identification, evaluation, extent-of-condition scoping, and corrective actions. Additionally, the inspectors observed the integrity of damaged, worn, and newly machined stem nuts to evaluate the effect of plant conditions on stem nut integrity. Finally, the inspectors reviewed MOV program procedures to evaluate the quality and effectiveness of the Exelon MOV program, as implemented at PBAPS. Documents reviewed are listed in the Attachment.

b. Findings and Observations

Introduction

A Green, self-revealing NCV of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," was identified. Specifically, Exelon's MOV Program procedures lacked specific instructions to prescribe an acceptable frequency for performing valve stem lubrication, which resulted in test failures of safety-related MOVs and affected the reliability of the MOVs' safety functions.
Description:

During quarterly surveillance testing performed by Exelon on March 12, 2009, the Unit 2 HPCI torus inboard suction MOV (MO-2-23-058) failed to stroke full open during its quarterly surveillance test and was subsequently declared inoperable. Investigation by Exelon identified dried and hardened grease on the valve stem and stem nut, and a root cause investigation was assigned to Exelon engineering staff.

Extent-of-condition inspections were performed by Exelon on select HPCI MOVs over the next several days. Degraded grease was identified on the outboard torus suction MOV for Unit 3 (MO-3-23-057), but the condition was determined not to impact valve operability. Exelon rescheduled the periodic stem lubrication interval on the Unit 3 HPCI MOV from ten years to six years, and assigned this PM to the next Unit 3 refueling outage (fall of 2009). Subsequently, on March 21, 2009, the Unit 3 HPCI torus outboard suction MOV failed to stroke full open during quarterly surveillance testing and was declared inoperable. Investigation by Exelon identified hardened grease on the stem and inside the stem nut, as well as stem nut wear. As a result of the failure, Exelon expanded the extent-of-condition scope to include diagnostic testing of MOVs on both units within the affected HPCI valve group (total of 6 MOVs), as well as eleven other safety-related MOVs based on diagnostic test data margins, as well as similar stem characteristics.

During the diagnostic testing of the Unit 3 RHR loop 'D' torus suction MOV (MO-3-10-13D) on March 26, 2009, Exelon identified less-than-required thrust at the torque switch trip, and the valve was subsequently declared inoperable. Investigation by Exelon revealed that the stem grease was degraded and several stem nut threads were damaged. As a result of this test failure, the extent-of-condition scope was again expanded. Exelon concluded that 45 safety-related MOVs required additional evaluation, such as visual inspection, grease evaluation, diagnostic testing, and/or corrective maintenance. This review identified one additional MOV under-thrust condition on the Unit 2 RHR loop 'B' outboard discharge MOV (MO 2-10-154B) during diagnostic testing on April 2, 2009. Exelon investigation into this MOV test failure identified a degraded grease condition, and the MOV was declared inoperable. The NRC inspectors reviewed the final extent-of-condition scoping, and found that it was appropriate to the circumstances.

Exelon performed immediate corrective actions after each of the MOV failures, which included cleaning and removing the old grease from the stem and stem nut area, applying new grease, and performing diagnostic testing to ensure successful valve performance. Exelon performed operability evaluations for each of the four MOV failures, and concluded three of the four MOVs would have been capable of performing their intended safety function for all design basis events. The operability evaluation for the Unit 3 RHR loop 'D' torus suction MOV concluded that the valve would not have been able to perform its safety function of containment isolation for all design basis events.

Operability evaluations for the other three MOVs determined that the valves would have been capable of performing their safety functions for all design basis events. The Unit 2 RHR loop 'B' discharge MOV is normally open in a standby mode for low pressure coolant injection, and was evaluated for its design function to close during suppression pool cooling and containment spray modes of the RHR system. Exelon concluded that the valve motor torque capability would have provided enough inertia to hard seat the valve from the as-found torque switch trip condition in the extent-of-condition diagnostic test. The operability evaluations for the Unit 2 and Unit 3 HPCI torus suction MOVs stated that the torque switch trip protection, which stopped the valve from completely opening through the degraded grease conditions during the surveillance tests, is bypassed during safety actuation signals to open. Exelon determined that the valve motor torque capability, absent torque switch trip protection, was sufficient to open the valve during all design basis events despite the degraded grease conditions. The inspectors reviewed the operability evaluations and agreed that Exelon's conclusions regarding past operability were reasonable. However, the capability of the MOVs to perform their mitigating safety functions was challenged, thereby impacting their reliability.

A root cause evaluation was performed by Exelon in response to the four MOV failures. The root cause evaluation determined that Peach Bottom MOV PM frequencies and actions had not appropriately included stem lubricant performance feedback. The NRC inspectors reviewed the root cause evaluation and agreed that an adequate MOV program would schedule and adjust PM activities as necessary to assure that safety-related MOVs can perform their functions as required. The root cause evaluation stated that Exelon had the longest allowable MOV PM lubrication intervals in the entire nuclear fleet (up to 10 years). Previous industry guidance and vendor information had described Exxon Nebula Extreme Pressure (EP) - 1, the MOV lubricant used at PBAPS, as being susceptible to degradation and hardening phenomena. The Exelon root cause identified that Exxon cancelled production of Nebula EP-1 in 2001, stating a one-year limited shelf life. Additionally, the EOC inspections performed by Exelon identified mixtures of Nebula EP-1, along with some remains of the former PBAPS MOV lubricant, N5000 NeverSeez, on several valve stems and stem nuts. Industry guidance has noted that NeverSeez is incompatible with Nebula EP-1 due to an accelerated hardening and degradation effect. Finally, since using EP-1 grease, Peach Bottom had many opportunities to re-evaluate their MOV PM lubrication frequencies and actions, including:

  • October 2006: MO-3-10-026B failed to successfully stroke. Internal inspection identified severely degraded grease, and the stem nut was replaced.
  • October 2007: NRC PI&R inspection of the October 2006 MO-3-10-026B failure to stroke noted that although Exelon identified a hardened grease condition, this was not determined to be the most probable cause of the failure, and no EOC evaluation was performed. Subsequent walkdowns by the inspector identified degraded lubricating grease on MO-3-10-031A. Exelon staff noted that the grease appeared to be a mixture of EP-1 and NeverSeez. (IR 689020). This was documented in NRC Inspection Report 05000277&278/2007005.
  • October 2008: MO-2-23-057 (Unit 2 HPCI outboard torus suction MOV) stroked slowly and failed to close. Degraded lubricating grease and stem nut wear were identified, and the stem nut was replaced.
  • January 2009: MO-3-01A-077 failed to go full open. The valve stem was cleaned and re-lubricated and the stroke time decreased.
Analysis:

The inspectors determined that Exelon's failure to properly implement MOV preventive maintenance activities, specifically with respect to stem lubrication necessary to assure that MOVs will function when required, constituted a performance deficiency. Specifically, degraded stem lubrication was identified as a common factor in four safety-related MOV test failures between March 12, 2009 and April 2, 2009.

Unit 2: The finding for Unit 2 was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems (MS) Cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the HPCI torus inboard suction MOV and the RHR loop 'B' outboard discharge MOV experienced test failures, were declared inoperable, and required detailed operability evaluations as described above, thereby challenging their reliability and capability to perform their safety function. Using the Phase 1 worksheet in 4 of Manual Chapter 0609, "Significance Determination Process," the finding affected the MS Cornerstone and was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of system safety function, and was not associated with any external events.

Unit 3: The finding for Unit 3 was more than minor because it was associated with the configuration control attribute of the Barrier Integrity (BI) Cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers (e.g., containment) protect the public from radionuclide releases caused by accidents or events. Specifically, RHR loop 'D' torus suction MOV was determined by Exelon to not be capable of isolating for all design basis events. Using the Phase 1 worksheet in Attachment 4 of Manual Chapter 0609, "Significance Determination Process," the finding affected the BI cornerstone and was of very low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of reactor containment. Although the Unit 3 HPCI torus outboard suction MOV condition affected the mitigating system cornerstone, the Unit 3 finding analysis was assigned to the BI cornerstone because it best reflected the dominant risk of the finding.

This finding has a cross-cutting aspect in the area of PI&R, Corrective Action Program, because PBAPS did not thoroughly evaluate problems such that the resolutions addressed the causes and extent of condition P.1(c). Specifically, PBAPS failed to thoroughly evaluate previous conditions of degraded and hardened grease on safety-related valves, such that the extent of the condition was considered and the cause was resolved. This cross-cutting aspect is applied to both Units 2 and 3.

Enforcement:

10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires, in part, that "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings." Contrary to the above, the Exelon MOV program procedures (ER-AA-300 Series and MA-AA-723-300 Series) were not appropriate to the circumstances, in that, they lacked specific instructions to prescribe an acceptable frequency for performing valve stem lubrication, given the limited shelf life of the MOV lubrication grease used by the station as described in the above section. As a consequence of this, four safety-related MOVs experienced test failures between March 12, 2009 and April 2, 2009, attributed to degraded and hardened lubricating grease. Because this finding is of very low safety significance and has been entered into Exelon's CAP (IR 892191), this violation is being treated as a Green NCV consistent with section VI.A.1 of the NRC Enforcement Policy: NCV 05000277/2009003-01, and NCV 05000278/2009003-01, MOV Program Procedures were Inadequate with Regard to Periodicity of Preventive Maintenance Activities for Stem Lubrication.

.2 Semi-Annual Review to Identify Trends (1 Trend Review Sample)

a. Inspection Scope

The inspectors reviewed lists of CAP items to identify trends (either NRC or licensee identified) that might indicate the existence of a safety issue. First, the inspectors reviewed a list of approximately 7,250 IRs that PBAPS initiated and entered into the CAP action tracking system from December 1, 2008 through June 1, 2009. The inspectors also reviewed the approximately 3450 IRs that remained open with outstanding actions. The list was reviewed and screened to complete the required semi-annual PI&R trend review. Based on the review, a sample of 58 IRs (listed in the Attachment) were selected for a more detailed review to determine whether the issues were adequately identified and evaluated, and that corrective actions were planned. The inspectors evaluated the IRs against the requirements of Exelon procedure, LS-AA-125, and 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action."

b. Findings and Observations

Based on the review, the inspectors observed that there was an adverse trend of human performance related events during the period. Specific examples included:

  • inadequate risk assessment and maintenance practices for work on the control circuitry for containment isolation valves (IR 887441);
  • inadequate procedure adherence that resulted in the trip of a RRP (IR 923239);
  • an inadequate understanding of the maintenance and operation of a WRNM channel (IR 871864); and,
  • removal, for inspection, of an incorrect pin from a spent fuel bundle (IR 853625).

The inspectors also noted an adverse trend in equipment reliability issues that challenged plant operations. Specifically:

  • the build-up of combustible gases in the 3 'A' main power transformer that resulted in an unplanned power reduction (IR 868369);
  • the failure of EHC cards that led to an unplanned power reduction in response to turbine bypass valve cycling (IR 891763);
  • indications of friction between selected Unit 3 control rods and fuel channels (IR 874398); and,
  • inoperable motor operated valves that resulted from inadequate preventive maintenance and hardened grease (IRs 892191 and 913965).

However, the inspectors noted that PBAPS self-identified an adverse trend in station performance and proactively performed a common cause analysis (IR 896381) to understand the causes for the adverse trend and to identify corrective actions and improvement plans.

.3 Review of Items Entered into the CAP

As required by IP 71152, "Identification and Resolution of Problems," and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed screening of all items entered into the licensee' CAP. This was accomplished by reviewing the description of each new action request/issue report and attending daily management review committee meetings.

4OA3 Follow-up of Events and Notices of Enforcement Discretion (71153 - 4 Samples)

.1 Personnel Performance - 3 'A' RRP Trip

a. Inspection Scope

The inspectors reviewed corrective action documents listed in the Attachment to this report and discussed the events surrounding the trip of the 3 'A' RRP with the personnel involved. The inspectors reviewed Revision 4 of IC-11-02011, "Recirc MG Set Voltage Regulator Tuning," and Revision 3 of HU-AA-104-101, "Procedure Use and Adherence."

b. Findings

Introduction:

A Green, self-revealing finding occurred when PBAPS personnel incorrectly performed a maintenance procedure for tuning the 3 'A' RRP MG set voltage regulator. Specifically, maintenance personnel adjusted a potentiometer in the wrong direction which resulted in a trip of the RRP and an unplanned Unit 3 plant transient.

Description:

On May 23, 2009, at approximately 9:30 a.m., the PBAPS Unit 3 'A' RRP tripped. The trip occurred while instrument and controls (I&C) maintenance technicians were performing procedure IC-11-02011, "Recirc MG Set Voltage Regulator Tuning,"

step 5.1.6.8. Step 5.1.6.8 states, "Verify step test box potentiometer is at MAXIMUM resistance (fully counter-clockwise) and CLOSE the switch of the step test circuit." Contrary to the procedure instructions, the potentiometer, on the step test box, that is used to vary the test current applied to the RRP MG set voltage regulator field, was incorrectly positioned to the minimum resistance (fully clockwise) position. When the test box switch was closed, the incorrect positioning of the potentiometer resulted in an excessive MG set field current that tripped the MG set field breaker.

The trip of the MG set field breaker resulted in the loss of the 3 'A' RRP. The loss of core flow caused reactor power to decrease from approximately 75 percent to 33 percent. In response to the loss of the 3 'A' RRP, operators entered operational transient procedure, OT-112, "Unexpected/Unexplained Change in Core Flow" and executed actions to stabilize the plant in single loop operations. I&C personnel aborted the performance of IC-11-02011 and removed all test equipment. The 3 'A' RRP was subsequently restored per system operating procedure, SO 2A.1.B-3, "Starting the Second Recirculation Pump" at 4:32 p.m. the same day.

PBAPS's investigation indicated that there was a mindset among the technicians performing the work that the potentiometer had to be set to the maximum position and that this position was fully clockwise. Interviews with several I&C technicians indicated that the word "MAXIMUM" as it relates to the operation of variable inputs almost always refers to the fully clockwise position. During the pre-job brief there was no mention of rotating the potentiometer either clockwise or counter-clockwise, only of taking it to maximum. When the technicians reached the job site, the first technician verified the test box was in the maximum position by attempting to rotate the potentiometer in the clockwise position. The technician then announced what his actions were and handed the procedure to a second technician who read the step and took the same action to verify the potentiometer position. This peer check was flawed because the first technician inappropriately took the action without a peer check and then asked for a peer check after the action was taken. The job supervisor was present during the entire evolution providing management oversight, and failed to notice the incorrect position of the potentiometer.

Following the incorrect setting of the potentiometer, the technicians moved the test box switch from the OPEN to the CLOSE position which inserted the test signal and tripped the 3 'A' MG set and RRP. Immediately after the event, the technicians and their supervisor checked the connections and potentiometer position and all agreed the setup was correct. When the team reached the main control room, the procedure was re-read and the technicians realized the error in the positioning of the test box potentiometer.

The inspectors reviewed the root cause report to assess its details, accuracy, and planned corrective actions. The inspectors concluded that the root cause report was thorough, detailed, and comprehensive. The planned and completed corrective actions were appropriate and comprehensive. The licensee identified two root causes and two contributing causes for this event. The root causes included failure to adhere to a Level 1 (step-by-step performance) procedure due to performing work in a knowledge-based versus rule-based manner and the failure to perform an adequate peer check to verify the potentiometer position that resulted in a lost opportunity to identify the error prior to the plant transient. PBAPS's investigation determined that the technician performing the work was operating in the knowledge-based thinking mode because he knew that the potentiometer needed to be in the maximum position. If the technician had operated in the rule-based thinking mode, he would have been complying with the procedure instructions verbatim. The peer check was flawed in that the first technician took the action without a peer check and inappropriately asked the second technician for a peer check after the action was taken.

Analysis:

The inspectors determined that the I&C technician's failure to follow the procedure for tuning the 3 'A' RRP MG set voltage regulator that resulted in a trip of the RRP MG set and an unplanned plant transient was a performance deficiency. This finding was more than minor because it was associated with the human performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions. Specifically, this error resulted in an unplanned plant transient that reduced Unit 3 reactor power from 75 percent to 33 percent. In accordance with IMC 0609, Attachment 4, the inspectors determined this finding to be of very low safety significance (Green) since the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available.

This finding has a cross-cutting aspect in the area of human performance, Work Practices, because PBAPS did not define and effectively communicate expectations regarding procedural compliance and personnel did not follow procedures H.4(b).

Specifically, PBAPS personnel did not follow procedure IC-11-02011 instructions for tuning the 3 'A' RRP MG set voltage regulator

Enforcement:

The inspectors determined that the finding did not represent a violation of regulatory requirements because it involved a procedure violation of a non-safety related procedure. This finding will be tracked as FIN 05000278/2009003-02 , Inadequate Procedure Adherence Results in Trip of 3 'A' Recirc Pump and Plant Transient.

.2 (Closed) Licensee Event Report (LER) 05000278/2009-03-00, Inoperable Containment Isolation Valve Results in Condition Prohibited by TSs

On March 26, 2009, it was discovered that the 3D RHR pump suppression pool suction isolation valve (MO-3-10-013D) was degraded due to a greasing deficiency identified during performance of EOC testing associated with grease deficiencies previously discovered on motor-operated valves (MOVs). It was determined that this condition was prohibited by TSs since this valve is a primary containment isolation valve and was inoperable for containment isolation purposes for a time period longer than allowed by TS. The cause of the greasing deficiency was grease hardening primarily due to inadequate preventive maintenance. The valve was repaired and returned to service on March 27, 2009. A finding related to this event was documented in report section 4OA2.1. This LER is closed.

.3 (Closed) LER 05000277/2009-01-00, Clearance Performance Error Results in Condition Prohibited by TSs

On February 13, 2009, PBAPS personnel discovered that an operation prohibited by TS existed when a TS required action for an inoperable Unit 2 control rod (Control Rod 10-51) was found not met. Specifically, at 9:33 a.m. on February 13, during a plant walkdown being conducted in preparation to vent selected control rod drive (CRD) hydraulic control units (HCUs), the CRD HCU directional control valves (DCVs) for Control Rod 10-51 were discovered to be energized (armed). To comply with TS 3.1.3, Condition C, these DCVs should have been de-energized (disarmed) since the 10-51 CRD HCU had been rendered inoperable for the conduct of maintenance on February 11. This condition was due to an operator error that re-armed the DCV during the modification of a safety tagging clearance that occurred at approximately 5:30 a.m. on February 12, 2009. On February 13, after the TS non-compliance was identified at 9:33 a.m., prompt action was taken to disarm the CRD and restore TS compliance by 9:42 a.m. Since Control Rod 10-51 remained fully inserted during this event, PBAPS concluded that there was no actual safety consequences associated with this event. There were no previous similar LERs identified. A licensee-identified NCV for this issue is documented in Section 4OA7; therefore, this LER is closed.

.4 (Closed) LER 05000278/2009-01-00, Control Rods Inoperable During Mode 2 Operations As a Result of Interferences

As a result of control rod interference monitoring testing performed by Operations personnel on January 28, 2009, it was determined that three control rods were inoperable during the Unit 3 shutdown that was performed on January 21. This testing determined that Control Rods 14-55, 18-55, and 42-55 could be inoperable for operational conditions involving time periods when reactor pressure is below 850 psig (Mode 2 operations). This occurrence was considered reportable as a common cause that resulted in the inoperability of three control rods for approximately 4.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> on January 21, during Mode 2 operations. The common cause is related to control rod blade interferences with the fuel bundle channel. PBAPS concluded that there were no actual safety consequences associated with this event and that appropriate shutdown margin was maintained during this event. Subsequently, a control rod interference monitoring and testing program was established. EOC testing was performed on Units 2 and 3. There were no previous similar LERS identified.

The inspectors reviewed the event and concluded that the condition was appropriately reported as a common-cause inoperability. However, no violation or condition prohibited by TS existed because, in accordance with TS 3.1.3, Condition E, Unit 3 was taken to Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of reactor pressure being reduced below 850 psig; therefore, this LER is closed.

4OA5 Other Activities

.1 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working hours.

These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status reviews and inspection activities.

b. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On July 17, 2009, the resident inspectors presented the inspection results to Mr. W. Maguire and other PBAPS staff, who acknowledged the findings. The inspectors asked the licensee whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.

4OA7 Licensee-Identified Violations

The following violation of very low significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Policy for being dispositioned as a NCV.

  • TS 3.1.3, Condition C, requires that control rods that are inoperable for reasons other than being stuck shall be fully inserted and disarmed. TS 3.1.3, Condition E, requires the unit to be in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if Condition C cannot be met. On February 11, the 10-51 CRD HCU was declared inoperable for the conduct of maintenance and the TS required actions to fully insert and disarm the CRD were met. Following the completion of maintenance on the HCU, an operator erroneously re-armed the CRD HCU DCVs during the modification of a safety tagging clearance that occurred at approximately 5:30 a.m. on February 12. Over 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> later and in excess of the 12-hour completion time allowed by TS 3.1.3, PBAPS personnel discovered the error and disarmed the CRD for Control Rod 10-51. PBAPS documented this issue in the CAP as IR 880318. Since Control Rod 10-51 remained fully inserted and there was no loss of safety function during the period of non-compliance, this issue is of very low (Green) safety significance. The LER associated with the event was documented in Section 4OA3.3.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Exelon Generation Company Personnel

W. Maguire, Site Vice President
G. Stathes, Plant Manager
J. Armstrong, Regulatory Assurance Manager
E. Flick, Engineering Director
P. Navin, Work Management Director
L. Lucas, Chemistry Manager
R. Franssen, Operations Director
R. Holmes, Radiation Protection Manager
D. DeBoer, Security Manager
T. Wasong, Training Director

NRC Personnel

F. Bower, Senior Resident Inspector
M. Brown, Resident Inspector
E. Torres, Project Engineer
A. Ziedonis, Reactor Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Opened/Closed

05000277/2009003-01 NCV MOV Program Procedures were
05000278/2009003-01 Inadequate with Regard to Periodicity of Preventive Maintenance Activities for Stem Lubrication (Section 4OA2.1)
05000278/2009003-02 FIN Inadequate Procedure Adherence Results in Trip of 3 'A'

Recirc Pump and Plant Transient (Section 4OA3.1)

Closed

05000278/2009-03-00 LER Inoperable Containment Isolation Valve Results in Condition Prohibited by TSs (Section 4OA3.2)
05000277/2009-01-00 LER Clearance Performance Error Results in Condition Prohibited by TSs (Section 4OA3.3)
05000278/2009-01-00 LER Control Rods Inoperable During Mode 2 Operations as a Result of Interferences (Section 4OA3.4)

Discussed

None

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

SE-16, Revision 4, "Grid Emergency"
SE-16, Attachment A, Revision 2, Power Team Generation Dispatcher/Power System Director (PTGD/PSD) Communications to Peach Bottom
WC-AA-104, Revision 14, "Review and Screening for Production/Atmospheric/Environmental Risk"
WC-AA-101, Revision 16, "On-Line Work Control Procedure"
WC-AA-107, Revision 6, "Seasonal Readiness"
WC-AA-8000, Revision 2, "Interface Procedure between Energy Delivery (ComED/PECO) and Exelon Generation (Nuclear/Power) for Construction and Maintenance Activities"
WC-AA-8003, Revision 1, "Interface Procedure between Energy Delivery (ComED/PECO) and Exelon Generation (Nuclear/Power) for Design Engineering and Transmission Planning Activities"
OP-AA-108-107, Revision 2, "Switchyard Control"
OP-AA-108-107-1001, Revision 2, "Station Response to Grid Capacity Conditions"
OP-AA-108-107-1002, Revision 4, "Interface Agreement between Exelon Energy Delivery and Exelon Generation for Switchyard Operations"
McDonald, John E.; "PECO Nuclear Station Switchyard Readiness Certification for Summer 2009," Memo to Michael Pacillio; May 15, 2009
IR 891537, 2009 Summer Readiness Action Item Tracking
IR 932267, Perform Permanent Repair to 'A' Cooling Tower Lift Pump Can
IR 922632, High Acetylene Levels in the 3SU Transformer Load Tap Changer
IR 921521, PBAPS and PECO Summer Readiness Certification Letters Do Not Match
IR 921205, Aging Equipment HIT - Cooling Tower LTAM Review Issues
IR 918739, Large Transformer Summer Readiness Assessment
IR 917454, Unit 3 Switchgear House Exhaust Fan Breaker Tripped on Magnetics
IR 913699, Cooling Tower Walkdown Inspection
IR 912528, Unit 2 'B' Phase Main Transformer Cooling Bank Not Turning On
A-3IR
907656, Broken Joint Found on 'A' Cooling Tower Lift Pump
IR 887537, Unit 3 Auxiliary Transformer Cooling Fan Not Running

Section 1R04: Equipment Alignment

Drawing 6280-M-359, 360 RCIC System
SO 13.1.A-2, Revision 13, RCIC System Alignment for Automatic or Manual Initiation
COL 13.1.A-2, RCIC System
COL 13.1.B-2, RCIC System Control Board Lineup
COL 44B.1.A, Revision 6, Control Room Chilled Water System

Section 1R05: Fire Protection

PF-12B, Revision 3, Prefire Strategy Plan U3 RBCCW Room Radwaste Building 116,
Fire Zone 12B
PF-62, Revision 4, Prefire Strategy Plan U3 HPCI Room 88' Elevation, Fire Zone 62
PF-89, Revision 2, Prefire Strategy Plan Lube Oil Tank Room,
TB3-116, Fire Zone 89
PF-108, Revision 3, Prefire Strategy Plan Control Room, Turbine Building 165' Elevation,
Fire Zone 108
PF-4C, Revision 6, Prefire Strategy Plan U2 RX Recirc Pump MG Set Room, Radwaste
Building, 135' Elevation, Fire Zone 4C

Section 1R11: Licensed Operator Requalification Program

OP-AA-101-111, Roles and Responsibilities of On-Shift Personnel, Revision 3
OP-AA-103-102, Watchstanding Practices, Revision 8
OP-AA-103-103, Operation of Plant Equipment, Revision 0
OP-AA-104-101, Communications, Revision 1 PSEG1009R, Revision 3, Loss of Vacuum, Electrical ATWS

Section 1R12: Maintenance Effectiveness

IR 875571, Clearances Required for Unit 3 Control Rods
IR 889545, 2B MTSV Failed to Reset
IR 906648, 2A MTSV Slow to Tripp
IR 906661, 2B MTSV Failed to Reset
IR 909080, 3A MTSV Failed to Reset
IR 909628, 2B MTSV Failed to Reset
IR 912636, 2B MTSV Slow to Reset
IR 932238, Small Water Leak in Unit 3 CST Moat
IR 930640, Unit 3 CST Moat Water is Cloudy Since Moat Recoat
IR 928861, Document Results of Tritium Age Dating
IR 927784, Develop Contingency Plans for Well Drilling
IR 921975, Evaluate Soft Digging Inside the Unit 3 CST Moat Area
IR 916050, Increase in Unit 3 Yard Drain Sum Tritium
IR 895539, Tritium Detected in New Monitoring Wells
IR 894134, Elevated Tritium in Unit 2 Yard Drain Sump
IR 859610, Tritium Dating Analysis Needed to Determine Tritium Source
IR 814380, Continued Increase in Tritium Level in Well #4
IR 791859, Increased Tritium Level Trend for Groundwater Monitoring Well #4
A-4

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

IR 870284, Heating on the Base of the XK8 Relay
IR 877404, Heating on the EHC XK17 Relay Spade Connection
IR 910561, Unit 2 EHC Relay XK8 Exceeded ACMP Action Level of 80C
IR 911610, Unit 2 EHC XK17 Relay Found Loose in Its Base
IR 911675, Cause of EHC Relay Hot Spot Identified
IR 911903, Improvement Opportunity in PORC Review of EHC Power Supply AR A1695813, Heating on the Base of the XK8 Relay
WO
C0227471, Replace XK8 Relay and Base, Rework XK17 Connector
ER-AA-302-1001, MOV Rising Stem Motor Operated Valve Thrust and Torque
Sizing and Set-up Window Determination Methodology, Revision 6 I.E.Bulletin 85-03, Supplement 1: Motor Operated Valve Common Mode Failures During Plant
Transients due to Improper Switch Settings
IR 060023, Dedication of Lubrication Used on Safety-Related Systems
IR 827482, U2 HPCI
MO-57 Stroked in Alert Range Then Stopped Moving
IR 892191,
MO-2-23-058 Stopped in Intermediate Position
IR 895626, U3 HPCI Suction Valve Stem Grease Condition
IR 895789, U3 HPCI Torus Suction
MO-3-23-57, Split Indication
IR 896914, Test Results of Stored Exxon Nebula
EP-1 Grease
IR 898645, MOV Stem Lube Activity and PM Frequency Recommendation
IR 899298, Procedure
MA-AA-723-301 Deficiency
IR 906768,
MO-2-10-015D Did Not Stroke Open During PMT
IR 913852, FME - Foreign Material was Found in 3AF106 Discharge Micron filter WO
C0228763, 3AP017, Investigate/Replace Pump WO R1102249, 3AF106, PM: Replace Filter Element
WO M1687797, Replace Filter
WO A1709877, Foreign Material was Found in 3AF106 Discharge Micron filter Letter from PBAPS to NRC, dated May 14, 1999: Response to Generic Letter 96-05 Letter from NRC to PBAPS, dated November 16, 2000: Safety Evaluation by NRR of Licensee
Response to Generic Letter 96-05
MA-AA-723-301, Periodic Inspection of Limitorque Model SMB/SB/SBD-000 through 5 Motor
Operated valves, Revision 4 M-C-700-241, Limitorque Motor Operator Installation, Revision 5 NRC Inspection Report 50-277/92-82 and 50-278-92-82 NRC Inspection Report: Motor- Operated Valve Inspection 94-12
NRC Inspection Report 50-277/96-03 and 50-278/96-03 NRC Inspection Report 50-277/97-07 and 50-278/97-07 NRC Inspection Report 50-277/99-01 and 50-278/99-01 NRC Inspection Report 05000440/2005003: Perry Supplemental Inspection NRC Inspection Report 05000277/2007005 and 05000278/2007005, Section 4OA2.3: U2 MOV
Failure to Stroke Follow-up NUREG/CR-6750: Performance of MOV Stem Lubricants at Elevated Temperatures
P&ID: RHR, M-361, Sh. 2 WO R0013148:
MO-2-23-058-OP: Perform Operator PM WO R1018644:
MO-3-10-025B-OP: Motor Operator PM WO A1714585, Exceeded ACMP Action level for U3 Main Condenser WO
C0227407,
XJ-3170B; Additional Sealant Application
WO A1579262, Proactive Replacement of the 3B RFPT Exhaust Expansion Joint WO A1700673, 4 scfm Step Change in U3 Offgas Flow WO A1636058, U3 Step Increase in Offgas Flow on 10/18/07
A-5WO A1714764, LP Turbine to Condenser Expansion Joint has Leakage WO R1127007, Helium Mass Spectro Connection to Offgas
IR 931031, Air In-leakage at 3A LP Turbine Dog Bone
IR 931035, Condensate Drain Tank - Small Leak Identified
IR 936787, Bearing #6 Slop Drain Confirmed Leakage with Smoke
IR 936791, U3 Turbine #4 Slop Drain Cover Dislocated Procedure SO 5.7.A-3, Revision 8, Main Condenser Vacuum Leak Monitoring and Search

Section 1R15: Operability Evaluations

IR 873016, P3R18 Torus Recoat
IR 838841, P3R17 CISI Scope - UT of Piping in Torus Airspace
IR 838844, P3R17 CISI Scope - Torus Diver Inspections
IR 878127, P3R17 Torus Cleaning and Inspection
IR 873016, P3R18 Torus Recoat
IR 838841, P3R17 CISI Scope - UT of Piping in Torus Airspace
IR 838844, P3R17 CISI Scope - Torus Diver Inspections
IR 878127, P3R17 Torus Cleaning and Inspection
IR 919671, TS 3.8.7 Interpretation Concerns
IR 931760 -TS 3.8.7 Interpretation Concerns Information Notice 97-80:
Licensee TS Interpretations
IR 881184, 2BA034 (3402) Action Level Changed from "Blue" to "Yellow" ACMP - Unit 2 'B' Recirc Pump Trip Breaker Temperatures
IR 867732, 2BA034 (3401) Inspect Breaker During Next Refuel Outage
IR 867719, 2BA034 (3402) Inspect Breaker During Next Refuel Outage

Section 1R18: Plant Modifications

AR A1693909, Damaged Electrical Ductbank
WO
C0226402, Install Monitoring Equipment/ TCCP 08-00408

Section 1R19: Post-Maintenance Testing

WO
C0220912, 2AK018, Rebuild and Eddy Current Test
SO 44A.6.A-2, Placing an Additional Drywell Chiller in Service
IR 910529, 2 'A' Drywell Chiller Tripped during PMT Run
AR A1711246, Leakage in Unit 3 RWCU Regenerative Heat Exchanger Room WO
C0228895,
HV-3-12-30K/31K:
Perform Leak Repair
IR 918477, Leakage in Unit 3 RWCU Regenerative Heat Exchanger Room Technical Repair Procedure (TRP) - 3002, Revision 1, 1/8" NPT Drill and Tap
CC-AA-404, Maintenance Specification:
Application, Selection, Evaluation and Control of Temporary Leak Repairs
IR 921526, 2 'A' CAD Analyzer Failed to Trip During
ST-I-07G-103-2
WO
C0229040, Determine Which SV is Not Isolating
ST-I-07G-103-2, PCIS Group III Logic System Functional Test, Completed on 5/19/09 WO A1712378, 2 'A' CAD Analyzer Failed to Trip WO
C0225963 - Replace the Tube Bundles during the TSA Window WO A1651390 - E1 EDG Jacket Coolant Heat Exchanger Reduced Margin
WO
C0229077, 0AV079-DR, Replace Motor
ECR 09-00291, 0AV079-DR is Obsolete WO A1712722, 0AV079-DR is Obsolete P&ID Drawing - M-384, Control Room HVAC
A-6WO
C0229510, Troubleshoot Speed Switch, Rework as required WO R1067972, 0AG012-DR - Diesel Engine Inspection WO R1067972 - Act. 74, Perform PMT of Speed Switch WO R1067972 - Act 81, Remove/ Repair Tachometer
IR 935794, ECW/ESW Pumps Did Not Auto Start During E-1 DG Testing
IR 935800, E-1 DG Started and ESW and ECW Pumps Failed to Start
IR 935053, Red indicating light on for EHC Micron Filters WO A1716915, 3BF106 Red indicating light on for EHC Micron Filters WO M1716915, Replace Filter

Procedure

SO 1D.5.A-3, Revision 25, Electrohydraulic Control System Filter Changing and Cleaning

Section 1R22: Surveillance Testing

IR 910465, Line Up Incorrect for A CREV Filter Testing
ST-M-40D-905-2, Revision 17, Control Room Emergency Ventilation Filter Train 'A' Test
ON-115, Loss of Normal Main Control Room Ventilation SI3P-5-12-C1C2, Revision 8, Calibration Check of RPS Drywell Pressure Loop Instruments PT/PS 3-5-12C WO R1066021, RPS DW Pressure 'C' Loop Inst
RT-O-01D-402-2, Revision 5, Master Trip Solenoid Valves Operability Test
WO R1126058, Master Trip Solenoid Valves Operability Test
IR 906649, 'A' MTSV Slow to Operate
IR 926105, Increased Unit 2 Drywell Floor Drain Pump Outs (Unidentified Leakage)

Section 4OA1: Performance Indicator (PI) Verification

LS-AA-2001, Revision 12, Collecting and Reporting of NRC Performance Indicators Data
LS-AA-2090, Revision 4, Monthly Data Elements for NRC RCS Specific Activity
LS-AA-2100, Revision 5, Monthly Data Elements for NRC RCS Leakage
ST-O-020-560-2, Reactor Coolant Leakage Test (sample of completed test records)
ST-O-020-560-3, Reactor Coolant Leakage Test (sample of completed test records)
ST-C-095-864-2, Off Gas Monitor Response and Release Rate Verification by a Grab Sample
ST-C-095-864-3, Off Gas Monitor Response and Release Rate Verification by a Grab Sample
ST-C-095-820-2, Determination of Dose Equivalent µCi/g I-131 in Primary Coolant
ST-C-095-820-3, Determination of Dose Equivalent µCi/g I-131 in Primary Coolant
CH-407, Sampling of Reactor Water
CH-C-601, Determination of Dose Equivalent I-131

Section 4OA2: Identification and Resolution of Problems

ER-AA-300, Motor Operated Valve Program Administrative Procedure, Revision 5
ER-AA-302, Motor Operated Valve Program Engineering Procedure, Revision 5
ER-AA-302-1001, MOV Rising Stem Motor Operated Valve Thrust and Torque Sizing and Set- up Window Determination Methodology, Revision 6
ER-AA-302-1003, MOV Margin Analysis and Periodic Verification Test Intervals, Revision 5
ER-AA-302-1004, Motor Operated Valve Performance Trending, Revision 4
ER-AA-302-1006, Generic Letter 96-05 Program Motor-Operated Valve Maintenance and
Testing Guidelines, Revision 7 M-C-700-241, Limitorque Motor Operator Installation, Revision 5
MA-AA-723-300, Diagnostic Testing of Motor Operated Valves
MA-AA-723-300-1001, Motor Operated Valve "At the Valve" Diagnostic Test Reduction
A-7Strategy, Revision 0
MA-AA-723-301, Periodic Inspection of Limitorque Model SMB/SB/SBD-000 through 5 Motor
Operated valves, Revision 4
MA-AA-723-302-1001, MOV Rising Stem Motor Operated Valve Thrust and Torque Sizing and
Set-up Window Determination Methodology M-C-700-241, Limitorque Motor Operator Installation, Revision 5
IR 060023, Dedication of Lubrication Used on Safety Related Systems
IR 827482, U2 HPCI
MO-57 Stroked in Alert Range Then Stopped Moving
IR 892191,
MO-2-23-058 Stopped in Intermediate Position
IR 892191, Assignment 8, Root Cause for MOV Degraded Grease and Performance Issues
IR 895626, U3 HPCI Suction Valve Stem Grease Condition
IR 895789, U3 HPCI Torus Suction
MO-3-23-57, Split Indication
IR 896914, Test Results of Stored Exxon Nebula
EP-1 Grease
IR 898030,
MO-3-10-13D Stem Nut Wear & Underthrust
IR 898645, MOV Stem Lube Activity and PM Frequency Recommendation
IR 899298, Procedure
MA-AA-723-301 Deficiency
IR 901501,
MO-2-10-154B As-found Test Underthrust
IR 906768,
MO-2-10-015D Did Not Stroke Open During PMT Letter from PBAPS to NRC, dated May 14, 1999: Response to Generic Letter 96-05 Letter from NRC to PBAPS, dated November 16, 2000: Safety Evaluation by NRR of Licensee
Response to Generic Letter 96-05 Peach Bottom Unit 3
LER 09-03, Inoperable Containment Isolation Valve Results in Condition
Prohibited by TSs, May 12, 2009 NRC Inspection Report 50-277/92-82 and 50-278-92-82 NRC Inspection Report: MOV Inspection 94-12 NRC Inspection Report 50-277/96-03 and 50-278/96-03
NRC Inspection Report 50-277/97-07 and 50-278/97-07 NRC Inspection Report 50-277/99-01 and 50-278/99-01 NRC Inspection Report 05000440/2005003: Perry Supplemental Inspection NRC Integrated Inspection Report 05000387/2006003 and 05000388/2006003, Section 1R15 NRC Integrated Inspection Report 05000277/2007005 and 05000278/2007005, Section
4OA2.3: U3 MOV Failure to Stroke Follow-up Nuclear Event Report (NER)
PB-09-009 Green, Peach Bottom: HPCI Torus Suction Inboard
Isolation Valve
MO-2-23 Failed in Mid-stroke and did not Fully Open Nuclear Event Report (NER)
NC-09-014-Y Yellow: MOVs Fail to Operate due to Degraded
Stem Lubrication Nuclear Network Operating Experience Report,
OE 28589: Peach Bottom - MOV Failure to
Fully Function NUREG/CR-6750: Performance of MOV Stem Lubricants at Elevated Temperatures P&ID: RHR, M-361, Sh. 2 EPRI Technical Repair Guideline for Limitorque Model
SMB-000 Valve Actuators, Revision 1 I.E.Bulletin 85-03, Supplement 1: Motor Operated Valve Common Mode Failures during Plant
Transients due to Improper Switch Settings Limitorque Bulletin
SMB1-82C, "Limitorque Type SMB Instruction Manual and Maintenance
Manual," copyright 1982 WO R0013148:
MO-2-23-058-OP: Perform Operator PM WO R1018644:
MO-3-10-025B-OP: Motor Operator PM
Issue Reports
IR 880318, U2
HCU 10-51 DCV's Connected with Control Rod Inop.
IR 887441, Fuse 16A-F20 was Blown During
PS-9087G Replacement
A-8IR
853625, Incorrect Pins Were Removed & Inspected on Fuel Bundle JLM633
IR 923239, 3A Recirc Pump Trip
IR 820443, 250 Volt DC Disconnect Found Closed During
AO 57B.9-2
IR 871864, Spurious 'A' WRNM Short Period Trip
IR 869364, 3A WRNM is Not Responding
IR 868369, U3 Power Reduction for 3C Main Transformer Gassing
IR 891763, U3 #1 BPV Cycling
IR 874398, Indications of Channel Distortion - Peach Bottom 3
IR 687330, Unplanned Downpower in Response to 3A Recirc Seal Hi Temp
IR 753418, Unexpected Speed Changes on 3A Recirc
IR 892191,
MO-2-23-058, Stopped in Intermediate
IR 913965, Failure of
MO-3-10-013D to Stroke During
RT-O-010-304-3
IR 636103,
PE-0121 Provided Non-Conservative MOV Voltages in Midas
IR 608000, Heat Transfer Test Unsat. Update PTRM
IR 647108, Loss of Turbine Building Negative
IR 642941, LEFM System Impact Due to Letter from Manufacturer
IR 650861, Unit 1 Water Sample Greater Than Effluent Concentration Limit
IR 808191, Evaluation of Unit 1 Containment Tritium
IR 811317, Unit 1 Tech Specs Potentially Non-Conservative
IR 798807, Perform a RCA for the ESW Piping Issues
IR 304543, Develop Strategy for Long-Term Reliability of HPSW Piping
IR 618185, Cathodic Protection System Action Plan
IR 822594, Service Water to ESW Cross Tie Check Valve Leaks Through
IR 451634, NRC I.D. NPSH Margin for FSSD in Re-Rate
IR 453385, Low Margin in HPCI NPSH Calculation
IR 452577, Lack of Allowance for Frequency Variation in EDG Load Calculation
IR 476280, Flow Rate Used in Calc
PM-046 Is Non-Conservative
IR 609922, Required Power Supply Analysis Not Performed
IR 215452, Circuit Breaker to 343-SU Transformer
IR 566338, LTA Modeling of Torus Level in the Update PRA
IR 148966, App R Impact of Loss of CSR HVAC System
IR 643320, Omission of Item from the Commitment Tracking Program
IR 573736, License Renewal Commitment Identification Deficiencies
IR 571536, Actions Required to Ensure Compliance with New SRBC Docket
IR 163240, Conowingo Pond Level Management and SBO Line Vulnerabilities
IR 736060, Loss of SBO Capability at Peach Bottom
IR 571207, Bubbles in E3 Jacket Coolant Sight-Glass During Run
IR 656655, E1 Diesel Running Alarm and Reset During Full Load Run
IR 522128, Evaluate Ultra Low Sulfur Diesel (ULSD) Fuel Impacts
IR 514214, Diesel Heat Exchanger Tube Plugging
IR 528780, PSA Inaccuracies Regarding EDG's
IR 527680, TRM Appendix B List of PCIVS Not Complete
IR 591658, Change TRM Testing Requirements for SBGT Fire Suppression System
IR 569168, Exelon Versus Station or PECO Documents May Have Conflict
IR 481490, Procedures Requiring RPS Test Boxes May Need Revision
IR 570922, IPEEE Reference on Barrier Drawings Not Addressed in A-C-134
IR 572347, Create Procedure Revision to Address Gas Intrusion
IR 666004, NOS ID'd No PORC Reviewed Procedure for Containment Access
IR 392563, Declaration of LPCI Inoperable While In Torus CLG Not Optimized
IR 634709, Diesel Driven Fire Pump (DDFP) Operability Testing
IR 637035, Unnecessary Testing
IR 631157, Peach Bottom 4

th 10-Year IST Interval

A-9IR
673505, Security Inattentiveness Allegation
IR 473526, Maintenance Rule Performance Criteria Need Improvement
IR 632012, Winter Readiness Critique 2006-2007
IR 677383, Slop Drain MOD w/o Activities were Closed vs. Rescheduled

Section 4OA3: Event Followup

IR 923239, 3 'A' Recirc Pump Trip (Include Root Cause Report) Procedure
IC-11-02011, Revision 4, Recirc MG Set Voltage Regulator Tuning
IR 925955, Inappropriate Action Identified During Root Cause Analysis Procedure
GP-9-3, Revision 35, Fast Reactor Power Reduction Procedure
OT-112, Revision 39, Unexpected/Unexplained Change in Core Flow Procedure
GP-5-1, Exhibit - PBAPS Power Flow Operation Map PBAPS TS 3.8.7, Electrical Power Systems, Distribution Systems -
Operating
HU-AA-104-101, Revision 3, Procedure Use and Adherence

LIST OF ACRONYMS

AC Alternating Current
ACMP Adverse Condition Monitoring Plan
ADAMS Agency-wide Documents Access and Management System
AR Action Requests/Assignment Reports
BI Barrier Integrity
CAP Corrective Action Program
CFR Code of Federal Regulations
CRD Control Rod Drivel
DEP Drill and Exercise Performance
DCV Directional Control Valves
EDG Emergency Diesel Generator
EHC Electro-Hydraulic Control
EOC Extent-of-Condition
EP Emergency Preparedness
FPP Fire Protection Plan
HCU Hydraulic Control Units
HPCI High Pressure Coolant Injection I&C Instrument and Controls
IMC Inspection Manual Chapter
IP Inspection Procedure
IR Issue Report
LER License Event Reports
MG Motor\Generator
MOV Motor-Operated Valves
MS Mitigating Systems
MTSV Master Trip Solenoid Valve
NCV Non-cited Violation
NEI Nuclear Energy Institute
NRC Nuclear Regulatory Commission
OOS Out-of-Service

PARS Publicly Available Records

A-10PBAPS Peach Bottom Atomic Power Station

PMT Post-Maintenance Testing
RG Regulatory Guide
PI Performance Indicator
PI&R Problem Identification and Resolution
RCIC Reactor Core Isolation Cooling
RCS Reactor Coolant System
RG Regulatory Guide
RHR Residual Heat Removal
RPS Reactor Protection System
RRP Reactor Recirculation Pump
RTP Rated Thermal Power
SDP Significance Determination Process
SSC Structures, Systems, and Components
ST Surveillance Tests
TRM Technical Requirements Manual
TS Technical Specification
TSC Technical Support Center
UFSAR Updated Final Safety Analysis Report WO Work Order
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