IR 05000277/2009008
| ML092600662 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/17/2009 |
| From: | Powell R J NRC/RGN-I/DRP/PB7 |
| To: | Pardee C G Exelon Generation Co, Exelon Nuclear |
| POWELL, RJ | |
| References | |
| IR-09-008 | |
| Download: ML092600662 (26) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I 475 ALLENDALE ROAD KING OF PRUSSIA, PA 19406-1415 September 17, 2009
Mr. Charles Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Rd.
Warrenville, IL 60555
SUBJECT: PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 -
NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000277/2009008 AND 05000278/2009008
Dear Mr. Pardee:
On August 7, 2009, the United States Nuclear Regulatory Commission (NRC) completed an
inspection at your Peach Bottom Atomic Power Station, Units 2 and 3. The enclosed report
documents the inspection results discussed on August 7, 2009, with Mr. G. Stathes and other
members of your staff.
This inspection was an examination of activities conducted under your license as they relate to
the identification and resolution of problems and compliance with the Commission
=s rules and regulations and the conditions of your license. Within these areas, the inspection involved
examination of selected procedures and representative records, observations of activities, and
interviews with personnel.
The inspectors concluded that Exelon was generally effective in identifying, evaluating, and
resolving problems. Exelon personnel identified problems and entered them into the corrective
action program at a low threshold. Exelon prioritized and evaluated issues commensurate with
the safety significance of the problems and corre ctive actions were generally implemented in a timely manner.
Based on the results of this inspection one finding of very low safety significance (Green) was
identified. The finding was associated with inadequate corrective action implementation and
involved a violation of NRC requirements. The NRC is treating this finding as a non-cited
violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy because of the
very low safety significance of the violation and because it was entered into your corrective
action program. If you contest this non-cited violation, 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 1; the Director, Office of Enforcement, United
States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Peach Bottom Atomic Power Station. In addition, if you disagree with the characterization 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 I, and the NRC Resident Inspector at Peach Bottom Atomic Power
Station. The information you provide will be considered in accordance with Inspection Manual
Chapter 0305.
In accordance with Title 10 of the Code of Federal Regulations, Part 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 Web Site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/
Raymond J. Powell, Chief
Technical Support & Assessment Branch
Division of Reactor Projects
Docket Nos: 50-277, 50-278 License Nos: DPR-44, DPR-56
Enclosure:
Inspection Report 05000277/2009008 and 05000278/2009008
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, 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 P. Navin, 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
SUMMARY OF FINDINGS
IR 05000277/2008009 and 05000278/2008009; 07/20/2009 - 08/07/2009; Peach Bottom Atomic
Power Station, Units 2 and 3; Identification and Resolution of Problems, One finding was identified in the area of corrective action program effectiveness.
This NRC team inspection was performed by two resident inspectors and three regional inspectors. One finding of very low safety significance (Green) was identified by the NRC during this inspection and was classified as a non-cited violation (NCV). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using NRC Inspection
Manual Chapter (IMC) 0609, A Significance Determination Process
@ (SDP). The cross-cutting aspect was determined using IMC 0305, "Operati ng Reactor Assessment Program." Findings for which the SDP does not apply may be Green or assigned a severity level after NRC management review. The NRC
=s program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, A Reactor Oversight Process,@ Revision 4, dated December 2006.
Identification and Resolution of Problems
The inspectors concluded that Exelon was generally effective in identifying, evaluating and resolving problems. Specifically, Exelon pers onnel identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with the safety significance. For most cases, Exelon appropriately screened issues for operability and reportability and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. Corrective actions taken to address the problems identified in Exelon's corrective action process we re typically implemented in a timely manner.
However, for one issue reviewed by the inspectors, inadequate implementation of corrective actions resulted in one NRC-identified finding.
The inspectors also concluded that, in general, Exelon adequately identified, reviewed, and applied relevant industry operating experience to Peach Bottom Atomic Power Station (PBAPS)
operations. In addition, based on those items selected for review by the inspectors, Exelon's audits and self-assessments were thorough and probing.
Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspecto rs did not identify any concerns that site personnel were not willing to raise safety issues nor did they identify conditions that could have had a negative impact on the site's safety conscious work environment.
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a non-cited violation (NCV) of 10 CFR 50 Appendix B, Criterion XVI, "Corrective Action," for failure to identify and correct a condition adverse to quality. Specifically, in March 2009, Exelon did not take adequate corrective action to address a procedure deficiency and to ensure that grease inappropriately applied to Cutler Hammer direct current (DC) contactor pivot pins, in an unknown number of DC breakers in the high pressure coolant injection (HPCI) and reactor core isolation cooling (RCIC) systems at Unit 2 and 3, would be identified and removed in a timely manner. Because the grease could harden over time and cause inadequate DC breaker performance, the inspectors determined that this condition, if left uncorrected, could prevent certain Units 2 and 3 HPCI and RCIC system valves from performing their safety-related function.
Exelon entered this issue into their corrective action program as issue report (IR) 950438 and IR 950439
.
The finding affected the Mitigating Systems cornerstone and was determined to be more than minor because the condition, if left uncorrected, could have become a more significant safety concern. By not requiring, by procedure, the removal of all grease from the affected Cutler
Hammer DC contactor pivot pins, Exelon did not ensure that all of the potentially affected DC motor-operated valves in the Unit 2 and Unit 3 HPCI and RCIC systems would be available to perform their design functions if called upon. The inspectors evaluated this finding using Phase
I of Manual Chapter 0609 and determined the finding to be of very low safety significance (Green) because it was not a design or qualification deficiency confirmed not to result in loss of operability or functionality, did not represent a loss of system or train safety function, and was not potentially risk significant due to external events. This finding has a cross-cutting aspect in the area of problem identification and resolution, corrective action program, because Exelon failed to take appropriate corrective actions to address a safety issue in a timely manner, commensurate with the safety-significance and comp lexity P.1(d). Specifically, Exelon did not take appropriate corrective actions to ensure that grease inappropriately applied to Cutler
Hammer DC contactor pivot pins would be, by procedure, identified and removed in a timely manner. (Section 4OA2.1.c)
Other Findings
None.
4
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
.1 Assessment of the Corrective Action Program (CAP) Effectiveness
a. Inspection Scope
The inspectors reviewed the procedures that describe Exelon's CAP at Peach Bottom
Atomic Power Station (PBAPS). Exelon identified problems for evaluation and resolution
by initiating and processing issue reports (IRs) using the Passport web-based computer
application. Problems were screened for operability and reportability, categorized based
on significance (1 to 5) and assigned a level for the cause evaluation (A to D) based on
significance and the level of uncertainty for the cause. When work was necessary to
correct a problem, the work request (PIMS) system was used to generate action
requests (ARs) or work orders. As such, at PBAPS, the work management and
engineering change processes were part of the CAP and were utilized to correct
identified conditions when deemed appropriate.
To assess the effectiveness of the CAP at PBAPS, the inspectors reviewed performance
in three primary areas: problem identification, prioritization and evaluation, and
corrective action (CA) implementation. The inspectors compared performance in these three areas to the requirements and standards contained in 10 CFR 50 Appendix B Criterion XVI, "Corrective Action," and Exelon procedure, LS-AA-125, "Corrective Action
Program Procedure." The scope of the inspectors' review for each of these areas at
PBAPS is described below. The IRs and other documents reviewed for the inspection
are listed in the Attachment.
Effectiveness of Problem Identification
The inspectors reviewed a sample of plan of the day (POD) meeting packages and
meeting minutes for a sample of plant operations review committee (PORC), nuclear
safety review board (NSRB), and maintenance rule expert panel meetings. The
inspectors also attended a number of POD, management review committee (MRC), and
station ownership committee (SOC) meetings. The inspectors verified that identified
issues discussed at these meetings were entered into the CAP for evaluation and CA, as
appropriate.
The inspectors reviewed the condition of the emergency diesel generators (EDGs), the
emergency service water (ESW) system, the high pressure coolant injection (HPCI)system, and the primary containment isolation (PCI) system. The inspectors reviewed
system health reports, a sample of completed preventative and corrective maintenance
work orders, and completed surveillance test procedures. The inspectors also
completed a field walkdown of the accessible portions of the EDG and ESW systems.
The inspectors verified that conditions adverse to quality identified through this review
were entered into the CAP, as appropriate.
The inspectors reviewed a random sample of security, operations, chemistry, radiation 5 protection, and outage control center logs. The inspectors verified that problems
identified in these logs were entered into the CAP as appropriate.
The inspectors reviewed the March 25, 2008, PBAPS Pre-Exercise Emergency
Response Organization Drill Report issued on April 24, 2008, and the 2008 Peach
Bottom Station-Only Drill and Exercise Performance Drill Series Findings and
Observations Report issued on July 24, 2008. The inspectors verified that drill performance deficiencies identified in these reports were entered into the CAP as
appropriate.
The inspectors reviewed the results of Exelon periodic trend analyses conducted in
accordance with LS-AA-125-1005, "Coding and Analysis Manual," and LS-AA-126-1007, "Performance Improvement Toolbox." The ins pectors verified that identified trends discussed in selected quarterly reviews of station focus areas were entered into the CAP
for further evaluation and CA as appropriate. The inspectors also verified the
applicability of trend codes entered for a sample of CAP IRs.
The inspectors also verified that issues identified through internal self-assessments and
audits and the operating experience (OE) program were entered into the CAP for
evaluation and CA, as appropriate.
Effectiveness of Prioritization and Evaluation of Issues
The inspectors reviewed the evaluation and prioritization for a sample of IRs issued
since the last NRC problem identification and resolution inspection that was performed in
May 2007. The inspectors considered risk insights from the station's risk analysis and
ensured that the selected IRs were appropriately distributed across the seven
cornerstones of safety and the emergency preparedness, engineering, maintenance, operations, physical security, and radiation safety functional areas. Inspectors' samples
in this area were focused on but not limited to the offsite power system, the EDGs, the
primary containment and PCI systems, and t he high pressure service water (HPSW) and ESW systems.
To assess Exelon's effectiveness in the prioritization of issues, the inspectors observed
three daily IR screening meetings conduct ed by the SOC during the onsite weeks and reviewed the packages for a random sample of MRC meetings conducted since the last
inspection. During the daily IR screening meetings, the SOC reviewed new IRs for
prioritization and assignment. Subsequently, the MRC reviewed the IRs and made
priority adjustments as necessary.
The issues and IRs reviewed encompassed the full range of evaluations, including root
cause analyses (RCA), apparent cause evaluations (ACEs), and common cause
analyses (CCAs). IRs that were assigned lower levels of significance that did not
include formal cause evaluations were also reviewed by the inspectors to ensure they
were appropriately classified. The inspectors' review included the appropriateness of
the assigned significance, the scope and depth of the causal analysis, and the
timeliness of resolution. The inspectors assessed whether the evaluations identified
likely causes for the issues and whether Exelon developed appropriate CAs to address
the identified causes. Further, the inspectors reviewed equipment operability
determinations, reportability assessments, and extent-of-condition reviews for selected 6 problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of problems. During the onsite weeks, the inspectors also observed MRC meetings during which Exelon managers reviewed
completed RCAs, as well as selected ACEs and CA assignments.
Effectiveness of CAs
The inspectors verified completion of CAs for a sample of IRs issued since the last NRC
problem identification and resolution inspection that was performed in May 2007. The
inspectors considered risk insights from the station's risk analysis and ensured that the
selected IRs were appropriately distributed across the seven cornerstones of safety and
the emergency preparedness, engineering, maintenance, operations, physical security, and radiation safety functional areas. Inspectors' samples in this area were focused on
but not limited to the offsite power system , the EDGs, the primary containment and PCI systems, and the HPSW and ESW systems. CAs were verified to have been completed
through documentation and, in some cases, field walkdowns. The inspectors also
reviewed a sample of CAs for IRs greater than two years old. The inspectors selected
these items based on risk significance, verified appropriate interim actions were in place, and that the basis for not completing the specified CAs was appropriately documented
and well supported.
The inspectors reviewed IRs for adverse trends and repetitive problems to determine
whether CAs were effective in addressing the broader issues. The inspectors reviewed
Exelon's timeliness in implementing CAs and effectiveness in precluding recurrence for
significant conditions adverse to quality. The inspectors also reviewed a sample of IRs
associated with selected non-cited violations (NCVs), findings, and licensee event
reports, to verify that Exelon personnel proper ly evaluated and resolved these issues. In addition, the CA review was expanded to five years to evaluate Exelon's actions related
to torus shell corrosion control, raw water system corrosion control, and age-related
valve performance issues.
b. Assessment Effectiveness of Problem Identification
Based on the samples selected, the inspectors determined that Exelon identified
problems and entered them into the CAP at a low threshold. Exelon personnel at
PBAPS initiated approximately 29,000 IRs between May 2007 and June 2009. During
the inspection the inspectors reviewed approximately 200 IRs written during that same
period. Based on this review and the review of the items discussed in the scope above, the inspectors determined that in most cases, Exelon appropriately documented
identified problems in IRs that resulted in an evaluation and/or CA assignment or
completion.
The inspectors also verified that Exelon trended equipment and programmatic issues in
order to identify emerging issues at a low level. The trending process at PBAPS for the
period reviewed was controlled by Exelon procedure's LS-AA-125-1005, "Coding and
Analysis Manual," Revision 6 and LS-AA-126-1007, "Performance Improvement Toolbox," Revision 0. The inspectors concluded that, in accordance with Exelon
procedures, Exelon personnel identified emerging trends at a low level and used the 7 CAP to conduct evaluations and implement CAs when appropriate. The inspectors, based on the samples selected, also did not identify trends or repetitive issues that
Exelon had not self-identified through its trending process.
Effectiveness of Prioritization and Evaluation of Issues
The inspectors determined, based on the samples selected that Exelon, in general, appropriately prioritized and evaluated issues commensurate with the safety significance
of the identified problem. IRs were screened for operability and reportability, categorized
by significance, and assigned to a department for evaluation and resolution. The various
IR screening and management review groups considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the
safety conscious work environment (SCWE) during the conduct of reviews.
Items reviewed by the inspectors during the inspection were categorized for evaluation
and resolution commensurate with the significance of the issues. Guidance provided by
Exelon procedure LS-AA-120, "Issue Identification and Screening Process," for
categorization appeared sufficient to ensure consistent implementation based on the
sample of IRs reviewed by the inspectors. In general, issues were appropriately
screened and prioritized commensurate with their safety significance.
The inspectors reviewed four root cause analyses, eight apparent cause analyses, three
common cause evaluations, and approximately 16 work group evaluations. For the
evaluations reviewed, the inspectors noted that Exelon's evaluations were generally
thorough and appropriately considered extent of condition, generic issues, and previous
occurrences.
Exelon procedure LS-AA-120, "Issue Identification and Screening Process," stated that
the operating shift must evaluate whether or not the reported deficiency affected the
operability of the system and document the basis for the determination. In addition, in
cases where additional information was necessary to support the basis for operability, an
action must be assigned to complete the more formal evaluation. For each of the IR
cause analyses reviewed, the inspectors reviewed the completed operability evaluations
and determined that, in general, the evaluations were appropriately performed.
However, in one case the inspectors identified an issue regarding the adequacy of the
documented operability evaluation.
Specifically, IR 871970 was written to document that the 2C core spray room cooler did
not meet its fouling factor acceptance criteria during testing conducted in December
2008. The inspectors reviewed the evaluation performed by Exelon to assess the
impact of the higher-than-expected fouling factor on the ability of the cooler to perform its
safety function. The factors that impacted the ability of the cooler to perform its safety
function included ESW flow rate, river water temperature, and the heat exchanger
fouling factor. Exelon's evaluation of cooler operability used the minimum assumed
ESW flow rate, the design river temperature, and the fouling factor calculated during the
most recent thermal performance test. Based on this evaluation, Exelon lowered the
maximum allowable river temperature required for cooler operability.
The inspectors determined that using the fouling factor calculated at the time of testing
was a non-conservative assumption. Specifically, between the last unit cooler test (in 8 December 2007) and the current test (in December 2008), the fouling factor had
increased by approximately six percent. The inspectors determined that Exelon should
have used these results to project the additional cooler fouling that could occur between
the December 2008 test and the next scheduled test (in December 2009), and then
calculate maximum allowable river temperature from this projected fouling factor.
By not accounting for the additional fouling that could occur before the next scheduled
cleaning or thermal performance test, Exelon did not ensure that appropriate CAs could
be taken to correct a condition adverse to quality (CAQ) and maintain the cooler
operable. The inspectors determined that this was a performance deficiency. The issue
was determined to be minor, and therefore not subject to enforcement action in
accordance with the NRC's Enforcement Policy. Specifically, because there was
significant margin between actual measured ESW flow to the cooler and the minimum
design ESW flow to the cooler, such that using a more conservatively calculated fouling
factor would not have required action to be taken to ensure cooler operability. Exelon
documented this concern in IR 949567.
Effectiveness of CAs
The inspectors concluded that CAs for identified deficiencies were generally
implemented in a timely and adequate manner. The inspectors also concluded that
Exelon performed in-depth effectiveness reviews for significant issues to verify that
implemented CAs were effective. However, the inspectors' review of the IR disposition
documentation and verification of corrective CA implementation through a review of work
orders and discussions with personnel involved identified one issue and one finding of
very low safety significance regarding CA implementation. The issue is described below
and the finding is described in section 4OA2.1c.
IR 588335 was written by Exelon to evaluate their untimely response to IR 584506 that
documented the presence of corrosion products on a weld in ESW piping. Exelon
eventually determined that these corrosion products were the result of a through-wall
leak, completed an evaluation in accordance with ASME code case N-513 that
determined the leak did not affect the operability of the pipe or ESW system, and then
repaired the leak. However, the timeliness of this CA was questioned by management
and a quick human performance investigation (QHPI) was initiated under IR 588335.
The QHPI determined that when the SOC reviewed IR 584506, they directed the
operations department to inspect the affected pipe's condition during the next ESW
pump and valve flow surveillance test to confirm the initial operability call that there was
not a through-wall leak. The QHPI determined that the operations department tracked
this action as part of shift turnover, but, due to various human performance errors
including inadequate pre-job briefs, shift turnover communication, and work scheduling, did not complete the necessary observation as originally directed. This delayed the
identification of the through-wall leak on the pipe.
The inspectors determined that Exelon immediately completed CAs to address the
inadequate pre-job briefs and shift turnover communication and initiated a CA
assignment (coded as a CA - an action taken or planned that restores a CAQ to an
acceptable condition) to address the work scheduling issues. The specific assignment
description stated, "Develop a method for assuring that SOC follow-up items that are
evolution/milestone dependent are more robustly tracked to completion." The 9 completion notes documented in the IR stated that there were already many ways
available for SOC to close items, and that these methods should be used at the
discretion of the SOC. The assignment was closed by the evaluator without developing
any additional methods. The inspectors determined that this did not meet the intent of
the CA, that in accordance with LS-AA-125, "Corrective Action Program (CAP)
Procedure," step 4.8.1, required the responsible department heads approval, and that for
this instance no approval was given.
The inspectors determined that the failure of the evaluator to obtain the proper approvals
was a performance deficiency associated with the Mitigating System cornerstone. The
deficiency was not more than minor because the inspectors determined that it was not a
precursor to a significant event; if left uncorrected it would not lead to a more significant
safety concern; and it did not adversely affect the Mitigating Systems cornerstone objective of ensuring the availability, reliability and capability of systems that response to
initiating events to prevent undesirable consequences. Specifically, Exelon determined
that had the appropriate approval been sought for the change of intent for the CA, it
would have been approved. In addition, as stated above the station took immediate
corrective action to address the inadequate pre-job briefs and shift turnover
communication associated with this issue. Exelon documented this concern in IR
949578.
c. Findings
Introduction
- The inspectors identified a Green NCV of 10 CFR 50 Appendix B, Criterion XVI, "Corrective Action," for Exelon's failure to identify and correct a CAQ. Specifically, in March 2009, Exelon did not take adequate corrective action to address a procedure
deficiency and to ensure that grease inappropriately applied to Cutler Hammer direct
current (DC) contactor pivot pins, in an unknown number of DC breakers in the high
pressure coolant injection (HPCI) and reactor core isolation cooling (RCIC) systems at
Unit 2 and 3, would be identified and removed in a timely manner. Because the grease
could harden over time and cause inadequate DC breaker performance, the inspectors
determined that this condition, if left uncorrected, could prevent certain Unit 2 and 3
HPCI and RCIC system valves from perfo rming their safety-related function.
Description
- On March 24, 2009, Exelon performed diagnostic testing of motor-operated valve (MOV) MO-2-23-017, the Unit 2 HPCI condensate storage tank (CST) suction
valve. During the test, it was noted that the measured drop-out time for the open
contactor inside the valve's DC breaker exceeded its established acceptance criteria.
Because the open contactor was responsible for stopping valve movement in the open
direction, the delayed contactor operation resulted in the valve disc driving too far into its
open seat. Exelon performed an engineering evaluation to determine whether the over-
travel condition had resulted in damage to the valve components or motor operator.
Exelon determined that the torque generated by the over-travel condition was below
design limits for the valve, and therefore the valve remained operable.
Exelon's initial investigations determined that the slow contactor operation was caused
by grease that had been previously applied to the contactor pivot pin during preventative maintenance and then subsequently hardened with age. Further evaluation, including
discussions with the vendor, revealed that grease should not have been applied to the
contactor pivot pin, and any grease that was applied should be removed. If the
contactor pivot pin required lubrication, Cutler Hammer publication 13719 stated that 10 these pins should be occasionally lubricated with oil. Exelon discovered that the
preventative maintenance (PM) procedure did not provide guidance regarding lubrication
of DC contactor pivot pins and that on occasion, technicians had applied grease to the
pins if contactor response was sluggish.
To address the identified procedure deficiency, Exelon revised the PM procedure,
M-057-008, "250 Volt DC Breaker Assembly Inspection and Maintenance." Specifically, Exelon added steps 5.1.5 through 5.1.7, which directed technicians to examine the pivot
pin for "evidence of degraded lubricant," and "
IF degraded lubricant is present, THEN" clean the pin and apply oil. The inspectors determined that this procedure revision did
not adequately address the issue, because Exelon's cause analysis had determined that
all grease must be removed from the DC contactor pivot pins. The PM procedure, as
revised, allowed for technicians to assess the grease condition and remove it only if it
was determined to be degraded. The inspectors concluded that the procedure should
have required technicians to remove the grease regardless of its condition. Exelon
entered this issue into the CAP as IR 950438.
The inspectors determined that the lack of adequate procedural guidance and the use of
grease to lubricate the contactor pivot pins in DC breakers in the Unit 2 and Unit 3 HPCI
and RCIC systems were CAQs. These conditions, if left uncorrected, could become a
more significant safety concern in that the operability of safety-related MOVs, specifically
the ability to shut or open, could have been affected in that previously applied grease
may not be removed due to an inadequate preventive maintenance procedure change.
Exelon determined that there were 48 breakers installed in the Unit 2 and Unit 3 HPCI
and RCIC systems that were potentially susceptible to this condition. However, it was
unknown how many contactor pivot pins actually had grease applied to them due to lack
of documentation in the maintenance records.
In June 2009, Exelon inspected five of the remaining 48 potentially affected breakers
and identified that no grease was applied to the contactors associated with those
breakers. Exelon also reviewed the maintenance history for the Unit 2 HPCI CST
suction valve and breaker, which had experienced the slow contactor operation on
March 24, and determined that the last breaker PM was performed 11 years ago, and
the last valve diagnostic test was performed six years ago. Because both of these
activities provide indication of proper contactor operation, Exelon determined that the
contactors most at risk for grease hardening would be those whose valves had not been
diagnostic tested and whose breakers had not received PMs in the last six years.
Exelon reviewed the maintenance history of the remaining 43 valves and determined
that only one other valve met these criteria. As a result, Exelon moved up the breaker
PM for this valve to early 2010 to inspect for the presence of grease. Because all of the
remaining susceptible breakers had received a breaker PM or satisfactory MOV
diagnostic test within the last six years, and the associated valves for each breaker were
stroked periodically, the inspectors determined that there was no immediate safety
concern associated with this issue. In addition, based on discussions with the
inspectors, Exelon initiated IR 950439 to evaluate the future operability of the remaining
breakers to ensure that an appropriate timeline for inspecting the breakers was
established.
Analysis:
Exelon's failure to establish adequate CAs to ensure grease was, by procedure, removed from Cutler Hammer DC contactor pivot pins was a performance 11 deficiency. The finding affected the Mitigating Systems cornerstone and was determined
to be more than minor because the condition, if left uncorrected, could have become a
more significant safety concern. Specifically, by not requiring the removal of all grease
from the affected Cutler Hammer DC contactor pivot pins, Exelon did not ensure that all
of the potentially affected DC MOVs in the Unit 2 and Unit 3 HPCI and RCIC systems
would be available to perform their design functions if called upon. Although the Unit 2
HPCI CST suction valve, MO-2-23-017, was not damaged by the backseating condition
that resulted from the delayed contactor operation, it could not be assured that the
outcome would be the same for all of the valves whose breakers had the grease
incorrectly applied. The inspectors evaluated this finding using Phase I of Manual
Chapter 0609 and determined the finding to be of very low safety significance (Green)
because it was not a design or qualification deficiency confirmed not to result in loss of
operability or functionality, did not represent a loss of system or train safety function, and
was not potentially risk significant due to external events.
This finding has a cross-cutting aspect in the area of problem identification and
resolution, CAP, because Exelon failed to take appropriate CAs to address a safety
issue in a timely manner, commensurate with the safety-significance and complexity
P.1(d). Specifically, Exelon did not take appropriate CAs to ensure that grease
inappropriately applied to Cutler Hammer DC contactor pivot pins would be, by
procedure, identified and removed in a timely manner.
Enforcement:
10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to quality, are
promptly identified and corrected. Contrary to the above, Exelon did not take adequate CA to ensure that a CAQ was promptly identified and corrected. Specifically, by not
requiring, by procedure, the removal of all grease from the Cutler Hammer DC contactor
pivot pins, Exelon did not ensure that the remaining DC MOVs in the Unit 2 and Unit 3
HPCI and RCIC systems would be available to perform their design functions if required.
Because this finding was determined to be of very low safety significance (Green) and
has been entered into Exelon's CAP (IR 950438 and IR 950439), it is being treated as a
non-cited violation, consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV
05000277, 278/2009008-01, Failure to Take Timely and Adequate CAs for Grease
Applied to DC Contactors.)
.2 Assessment of the Use of OE
a. Inspection Scope
The inspectors selected a sample of industry OE issues to confirm that Exelon evaluated
the OE information for applicability to PBAPS and took appropriate actions when
warranted. The inspectors reviewed OE documents to verify that Exelon appropriately
considered the underlying problems associated with the issues for resolution via their
CAP. A list of the documents reviewed is included in the Attachment.
b. Assessment
The inspectors determined, based on the sample of OE reviewed, that Exelon
appropriately considered industry OE information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues.
12 The inspectors assessed that, in general, OE was appropriately applied and lessons
learned were communicated and incorporated into plant operations.
However, the inspectors identified one issue of concern related to OE where the
evaluation of applicability of an OE item to PBAPS was not adequate. Specifically, the
inspectors reviewed IRs 469346 and 593531, which documented Exelon's review of
issues documented in NRC IN 2007-05, "Vertical Deep Draft Pump Shaft and Coupling
Failures." It discussed OE related to vertical deep draft pump shaft and coupling failures
due to intergranular stress corrosion cracking (IGSCC). Exelon's procedure LS-AA-115-1003, "Processing of Significance Level 3 OPEX Evaluations," directed that the quality
review of the closeout documentation for the OE review should ensure that the
documentation stands alone and is clear enough to identify that the review was
completed satisfactorily.
The inspectors identified that Exelon's evaluation concluded that their ESW pumps were
not susceptible to the concerns described in the OE because the Peach Bottom ESW
pumps were standby pumps and therefore were not subject to the same levels of stress
as the pumps described in the OE. The inspectors questioned the adequacy of this
evaluation because some of the pumps discussed in the OE also were standby pumps.
The inspectors determined that the documented evaluation was inadequate in that it was
based on an unconfirmed assumption, and the inspectors' review of the OE determined
that the assumption was invalid. This was a performance deficiency associated with the
Mitigating Systems cornerstone. The issue was not more than minor because the
inspectors determined, through discussions with Exelon, that historically Exelon has not
identified evidence of IGSCC on the standby service water pumps. Exelon documented
this issue of concern in IR 950683 and also planned to inspect the 3C HPSW pump for
evidence of IGSCC when the pump is remov ed for replacement in November 2009 to confirm the adequacy of the OE evaluation and corrective actions.
c. Findings
No findings of significance were identified.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors reviewed a sample of audits, including the most recent audit of the CAP, departmental self-assessments, and assessments performed by independent organizations. These reviews were performed to determine if problems identified
through these assessments were entered into the CAP, when appropriate, and whether
CAs were initiated to address identified deficiencies. The effectiveness of the audits and
assessments was evaluated by compari ng audit and assessment results against self-revealing and NRC-identified observations made during the inspection. A list of
documents reviewed is included in the Attachment to this report.
b. Assessment
The inspectors concluded that self-assessments, audits, and other internal Exelon
assessments were generally critical, probing, thorough, and effective in identifying 13 issues. The inspectors observed that these audits and self-assessments were
completed in a methodical manner by personnel knowledgeable in the subject. The
audits and self-assessments were completed to a sufficient depth to identify issues that
were entered into the CAP for evaluation. In general, CAs associated with the identified
issues were implemented commensurate with their safety significance.
c. Findings
No findings of significance were identified.
4. Assessment of SCWE
a. Inspection Scope
The inspectors reviewed the SCWE at PBAPS through conduct of the following
activities.
- During interviews with staff personnel, the inspectors questioned individuals regarding: willingness to raise safety concerns, knowledge of the avenues available for raising safety concerns, the effectiveness of actions taken by management to
foster a SCWE at the site, and knowledge of other individuals who had experienced
a negative reaction for raising a safety concern. The inspectors interviewed
approximately 40 personnel in a cross section of organizations.
- The inspectors reviewed implementation of the site employee concerns program (ECP). The inspectors compared the number and type of issues documented in the PBAPS ECP between May of 2007 to June of 2009 to the number and type of issues
documented as PBAPS NRC allegations for that same period. The inspectors
reviewed the site procedure for conducting ECP investigations and reviewed a
sample of ECP files to assess the program's effectiveness at addressing potential
safety issues.
- The inspectors reviewed the results of the site nuclear safety culture survey performed in November 2008 and the CAs identified by the assessment that Exelon
performed when it reviewed the survey results. This was the only safety culture
assessment performed after the SCWE inspection that was done in March 2008.
That inspection was performed in accordance with the Deviation Memorandum (ML073320344) that was issued to authorize additional inspection of Exelon's actions to resolve work environment issues related to inattentive security officers that
were identified at PBAPS in September 2007. The results for the inspection were
documented in IR 05000277/2008405 and 05000278/2008405 (ML081490058).
b. Assessment
Based on interviews and reviews of the CAP and the ECP, the inspectors determined
that in general site personnel were willing to identify and raise safety issues. All persons
interviewed demonstrated an adequate knowledge of the avenues available for raising
safety concerns including CAP and ECP. In addition, comparisons of PBAPS ECP files
to NRC allegation information did not identify any impediments to the free flow of
information at PBAPS.
c. Findings
No findings of significance were identified.
4OA6 Meetings, Including Exit
On August 7, 2009, the inspectors presented the inspection results to Mr. G. Stathes, Plant Manager, and other members of the PBAPS staff. The inspectors confirmed that
proprietary information was reviewed by inspectors during the course of the inspection, that any proprietary information that was reviewed was returned to Exelon, and that the
content of this report includes no proprietary information.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- W. Maguire, Site Vice President
- G. Stathes, Plant Manager
- J. Armstrong, Manager, Regulatory Assurance
- E. Flick, Director, Engineering
- P. Navin, Director, Work Management
- L. Lucas, Manager, Chemistry
- R. Franssen, Director, Operations
- R. Holmes, Manager, Radiation Protection
- D. DeBoer, Director, Security
- T. Wasong, Director, Training
- K. Pederson, Corporate Employee Concerns Program
- D. McClellan, Regulatory Assurance, Site CAPCO
- S. Minnick, Manager, Nuclear Oversight
- T. Basso, Director, Maintenance
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
- 05000277, 278/2009008-01 NCV Failure to Take Adequate CAs for
Grease Applied to DC Contactors
(Section 4OA2.1.c.)
LIST OF DOCUMENTS REVIEWED
Section 4OA2: Identification and Resolution of Problems
- Audits and Self-Assessments
- Focused Area Self Assessment (FASA), Preparation for the 2008 NRC Component Design Basis Inspection, 1/11/2008
- FASA, Emergency Diesel Generating Mitigating Systems Performance Index Margin, 2007 (AR
- FASA, Emergency Diesel Generator 2008 Readiness Assessment (IR 686249)
- FASA, Operating Experience Program, 6/12/2007 (IR 620699)
- FASA, Maintenance Procedure Adherence, 8/29/2008 (IR 704403)
- Independent Assessment of the Exelon Employ ee Concerns Program, Ron Hall National Inspections & Consultants, 9/25/2008
- Check-in Self Assessment Report (CIA), PB Sa fety Culture November 2008 Survey Results, 4/2/2009 CIA, Control Room Watchstanding Practices, 2008, (IR 704626)
- CIA, Operations Operability Determination Documentation, 6/26/2007 (IR 569297)
- Executive Review of Exelon's Learning Programs for April 2009
- NOSA-PEA-08-03, Emergency Preparedness Audit , 4/16/2008
- NOSA-PEA-09-01, Corrective Action Program Audit Report, 4/8/2009 (AR 890318890318
- NOSA-PEA-08-04, Chemistry, Radwaste, Effluen
t, and Environmental Monitoring Audit Report,
- 5/14/2008 (IR 745600)
- Issue Reports (IR) full review
- IR 680399
- IR 673505
- IR 722737
- IR 913307
- IR 931277
- IR 931476
- IR 899665
- IR 911479
- IR 913410
- IR 732205
- IR 799684
- IR 711075
- IR 782186
- IR 750545
- IR 923324
- IR 492616
- IR 658047
- IR 692897
- IR 836406
- IR 752794
- IR 687330
- IR 798807
- IR 207837
- IR 571207
- IR 590032
- IR 590051
- IR 605123
- IR 605618
- IR 605624
- IR 609714
- IR 648809
- IR 680813
- IR 707459
- IR 762246
- IR 773960
- IR 803964
- IR 821815
- IR 828325
- IR 917739
- IR 917742
- IR 948351
- IR 874398
- IR 615437
- IR 820443
- IR 604364
- IR 729090
- IR 658607
- IR 704052
- IR 894291
- IR 732764
- IR 175881
- IR 254854
- IR 256909
- IR 281508
- IR 310857
- IR 367684
- IR 474783
- IR 500512
- IR 500514
- IR 500533
- IR 500534
- IR 500617
- IR 500669
- IR 500720
- IR 500728
- IR 500730
- IR 500747
- IR 500751
- IR 507732
- IR 527491
- IR 532405
- IR 533278
- IR 538108
- IR 539349
- IR 569974
- IR 572347
- IR 587062
- IR 609714
- IR 622372
- IR 624281
- IR 632468
- IR 635604
- IR 635608
- IR 654258
- IR 674622
- IR 681337
- IR 682858
- IR 692892
- IR 701430
- IR 740580
- IR 754903
- IR 757017
- IR 757617
- IR 764372
- IR 767501
- IR 782517
- IR 801937
- IR 818517
- IR 826015
- IR 861324
- IR 873016
- IR 889914
- IR 914019
- IR 633532
- IR 667926
- IR 658606
- IR 923324
- IR 217618
- IR 588335
- IR 871970
- IR 148966
- IR 899332
- IR 715260
- IR 589654
- IR 834736
- IR 706108
- IR 639199
- IR 680244
- IR 898030
- IR 721672
- IR 759925
- IR 726429
- IR 943889
- IR 823612
- IR 821124
- IR 759710
- IR 791470
- IR 708293
- IR 708284
- IR 794298
- IR 823592
- IR 881382
- IR 716295
- IR 737832
- IR 785997
- IR 636940
- IR 778210
- IR 895789
- IR 822594
- IR 840082
- IR 899886
- IR 896894
- IR 713836
- IR 798033
- IR 517099
- IR 582301
- IR 608000
- IR 675629
- IR 919813
- IR 659670
- IR 755968
- IR 798807
- IR 794363
- IR 584506
- NRC-Identified IRs for Inspection
- IR 945288, Main steam isolation valve position limit switch surveillance testing
- IR 945465, Operator responsibilities regarding in-service testing action levels
- IR 949015, OCC log entry improvem ent for corrective action items
- IR 949567, Inadequate operability evaluations for ECCS room cooler heat exchanger performance testing
- IR 949578, Corrective action closure was less than adequate for
- IR 588335 action 4
- IR 950438, Inadequate procedure change for condition adverse to quality
- IR 950466, IRs older than two years with no open assignments that require closure
- IR 950469, Error in processing the deletion of an NRC commitment related to first aid drills
- IR 950683, Inadequate evaluation of the applicability of deep draft service water pump operating experience to Peach Bottom
- IR 951780, Potential inadequate corrective actions for failure to follow alarm response
procedure for high level lube oil sump alarm
- IRs partial review
- IR 777756
- IR 779071
- IR 809505
- IR 840761
- IR 845174
- IR 852173
- IR 896381
- IR 902728
- IR 915179
- IR 943502
- IR 175881
- IR 917602
- IR 901213
- IR 913307
- IR 864304
- IR 867732
- IR 867719
- IR 881184
- IR 682042
- IR 683747
- IR 826015
- IR 942439
- IR 942446
- IR 942447
- IR 942448
- IR 942451
- IR 942452
- IR 942454
- IR 942458
- IR 582805
- IR 799571
- IR 762432
- IR 762013
- IR 163240
- IR 574158
- IR 453385
- IR 473526
- IR 188409
- IR 122191
- IR 902273
- IR 813642
- IR 827889
- IR 892191
Action Requests
- A1311290
- A1404542
- A1420399
- A1605535
- A1607930
- A1711229 A1714585
- A1666097
- A1665751
- A1626863
- A1606987
- A1500685 A1564635
- A1584148
- A1681763
- A1711229
- A1623631
- A1685463 A1204444
- A1529844
- A1492499
- A1592912
- A1644702
- A1546882 A1465360
- A1631136
- A1607586
- A1623631
- A1598039
- A1602845 Drawings
- E-5-32 sheet 2, Electrical Schematic Standby EDG exciter/ regulator schematic, Rev 6
- E-5-7 sheet 1 of 22, Electrical Schematic Standby EDG, Rev 50
- E-5-7 sheet 2B, Electrical Schematic Standby EDG, Rev 3
- Drawing M-283, ISO 2-33-101, Diesel Generator Building, Rev 7
- Drawing M-283, ISO 2-33-102, Diesel Generator Building, Rev 1
- Drawing M-283, ISO 2-33-103, Diesel Generator Building, Rev 0
- Drawing M-283, ISO 2-33-104, Diesel Generator Building, Rev 3
Miscellaneous
- Memorandum, Michael Prospero, Director - Nuclear Oversight Performance Assessment to William Grundmann, Manager Licensing Programs, Response to NOS Elevation Letter
- NOVA-08-118, Elevation - Inadequate Governance, Oversight, and Implementation of the Operating Experience Program, dated 12/18/2008
- Memorandum,
- NOVA-08-118, Dave Gudger, Manager Licensing Programs to Michael Prospero, Director - Nuclear Oversight Performance Assessment, Elevation -
- Inadequate Governance, Oversight, and Implementation of the Operating Experience
- Program, dated 12/4/2008
- Memorandum, Garey Stathes, Peach Bottom Plant Manager to Peach Bottom Station Employees and Supplemental Personnel, Deliberate Misconduct, dated 5/22/2009
- Supervisory Brief Information for Supervisors, SBS 6-11-09, Bill Maguire, Site Vice President, Willfull Misconduct Not Tolerated, 6/11/2009
- Supervisory Brief Information for Supervisors, SBS 7-15-09, Bill Maguire, Site Vice President, Deliberate Misconduct Computer Based Training Module, 7/15/2009
- Computer based training module, The Impact of Deliberate Misconduct
- SSC 07 Primary Containment and PCIVs Maintenance Rule Scope and Performance Monitoring Basis Document
- SSC 10-1 Residual Heat Removal LPCI Mode Maintenance Rule Scope and Performance Monitoring Basis Document
- SSC 10-2 Residual Heat Removal Shutdown Cooling/ Torus Cooling Maintenance Rule Scope and Performance Monitoring Basis Document
- Memorandum, Peach Bottom Nuclear Safety Review Board Meeting, dated 6/15/09
- Peach Bottom Atomic Power Station PORC Meeting Minutes, dated 4/7/09
- Maintenance Rule Expert Panel Meeting Minutes, dated 6/17/09
- Unit 2 Primary Containment System Health Report, dated 1/1/09 - 3/31/09
- Unit 3 Primary Containment System Health Report, dated 1/1/09 - 3/31/09
- Unit 2 Primary Containment Isolation System Health Report, dated 1/1/09 - 3/31/09
- Unit 3 Primary Containment Isolation System Health Report, dated 1/1/09 - 3/31/09
- Peach Bottom Plan of the Day Meeting Agenda, dated 02/04/2008
- Peach Bottom Plan of the Day Meeting Agenda, dated 08/04/2009
- Peach Bottom Plan of the Day Meeting Agenda, dated 08/04/2009
- Peach Bottom Plan of the Day Meeting Agenda, dated 06/18/2009
- Peach Bottom Plan of the Day Meeting Agenda, dated 07/29/2009
- Peach Bottom Plan of the Day Meeting Agenda, dated 01/29/2009
- Peach Bottom Plan of the Day Meeting Agenda, dated 02/05/2009
- Management Review Committee (MRC) Agenda, dated 06/17/2009
- MRC Agenda, dated 3/19/2009
- MRC Agenda, dated 7/21/2009
- MRC Agenda, dated 02/11/2009
- MRC Agenda, dated 08/04/2009
- MRC Agenda, dated 08/05/2009
- MRC Agenda, dated 08/06/2009
- MRC Agenda, dated 3/16/2009
- MRC Agenda, dated 7/30/2009
- MRC Agenda, dated 7/29/2009
- MRC Agenda, dated 5/14/2009
- MRC Agenda, dated 6/16/2009
- MRC Agenda, dated 7/27/2009
- MRC Agenda, dated 2/6/2008
- MRC Agenda, dated 2/7/2008
- MRC Agenda Week of 7/27/09 to 7/31/09
- Station Ownership Committee (SOC) Meeting Agenda, dated 07/23/2009
- SOC Meeting Package, dated 08/04/2009
- SOC Meeting Package, dated 08/05/2009
- SOC Meeting Package, dated 08/06/2009
- SOC Meeting Package dated 07/22/2009
- SOC Meeting Package dated 7/21/09
- Health Physics Control Point Log, dated 2/6/08-2/7/08
- Outage Control Center Log, dated 2/6/08-2/8/08
- Chemistry Logbook, dated 2/6/08-2/8/08
- Operations Logs, dated 2/6/08-2/8/08
- River Temperature Data from June through September for 2005-2008
- River Temperature Data from June 2009 through July 2009
- Pump Differential Pressure Performance Data for 3C HPSW Pump from August 1999 through July 2009
- Maintenance Rule Expert Panel Meeting Minutes for 3/19/09
- T04342, Commitment, PBLR Fire Protection Activities
- Chemistry Logs 6/29/09 to 7/1/09
- Ops Logs 2/10/07 to 2/11/07
- Ops Logs 3/16/07 to 3/17/07
- T03135, Commitment, Simulation of First Aid Drills
- Engine Combustion Report - E3 EDG 4/24/09
- AK/AKR 1/11-12/2000, Joint Meeting Minutes AK/AKR Mange-Blast Circuit, Breaker Users Group Meetings Ops logs 1/06 to 1/09 looking at EDG periods of Inoperability
- Ops logs 6/29/09 to 7/1/09
- OCC Logs 10/19/08 to 10/21/08
- RP Logs 6/29/09 to 7/1/09
- Unit 2 'B' Recirc Pump Trip Breaker Temperatures Rev 0
- WO R0847668
- WO R1056916
- Non-Cited Violations
- NCV 05000277/2008003-01, Foreign Material Discovered in Fire Valve (IR 807013)
- NCV 05000277/2007003-03, Failure to follow procedure damaged diesel fire pump (IR 604364)
- NCV 05000277/2007003-02, Failure to follow procedure overloaded E-3 EDG (IR 633532)
- NCV 05000277/2008005-01, Incorrect Procedure results in inoperable DC bus (IR 820443)
- NCV 05000278/2007003-01, Inadequate Work Order Implementation causes fire (IR 658545)
- NCV 05000277, 278/2008004-01, Inadequate EOC Review Results in Delay in Discovery of ESW Leaks (IR 845092)
- Licensee Identified Violation (LIV) 05000277/2007002,
- LER 05000277/2006001, Main Steam Isolation Valves Exceeded Their Allowable Leakage Limits On September 22, 2006 (IR
- 534622)
- LER 05000278/2009-003, Inoperable Containment Isolation Valve Results in Condition Prohibited by Technical Specifications, dated 3/26/09
- LER 05000278/2009-001, Control Rods Inoperable During Mode 2 Operations as a result of Interferences
- 05000278, Unplanned, invalid actuation of the Unit 3 Primary Containment Isolation System
Operating Experience
- NRC Information Notice 2007-36, EDG Voltage Regulator Problems (IR 703489)
- NRC Information Notice 2008-05 Fires involving EDG exhaust manifolds (IR 769756)
- NRC Information Notice 2007-27, Recurring events - EDG inoperability (IR 661725)
- NRC Information Notice 2007-05, Vertical Deep Draft Pump Shaft and Coupling Failures
(IR 469346)
- IR 736911, Gas instrusion in safety systems
- IR 710058, EDG Demand and run failures
- OPEX OE24956 Loss of Transformer cooling requires shutdown (IR 639082)
- IR 917229, Catastrophic Failure of Main Turbine (D.C. Cook)
- NRC Information Notice 2007-28, Potential Common Cause Vulnerabilities in Essential Service Water Systems Due to Inadequate Chemistry Controls Part 21 Notification for Applied Analysis Corporation, PipeFlo Software Version 10.0
- 2008-11, Service Water System Degradation at Brunswick Steam Electric Plant Unit 1
- OPEX SME Review for NRC Information Notice 2007-28, Potential Common-Cause Vulnerabilities in Essential Service Water Systems due to Inadequate Chemistry
- Controls OPEX SME Review for NRC Information Notice 2007-06, Potential Common-Cause Vulnerabilities in Essential Service Water Systems OPEX SME Review for GE
- SIL 484 Supplement 7, Cracking of Lower Endshields on Vertical Motors OPEX SME Review for NRC Information Notice 2006-26, Failure of Magnesium Rotors in Motor-Operated Valve Actuators
- IR 560621, Degradation of Essential Service Water Piping
Procedures
- LS-AA-120, Issue Identification and Screening Process, Revision 9
- LS-AA-125, Corrective Action Program Procedure, Revision 12
- LS-AA-125-1003, Apparent Cause Evaluation Manual, Revision 8
- LS-AA-125-1004, Effectiveness Review Manual, Revision 4
- LS-AA-125-1005, Coding and Analysis Manual, Revision 6
- EI-AA-101-1002, Employee Concerns Program Trending and Reporting Tools, Revision 5
- EI-AA-101-1001, Employee Concerns Program Process, Revision 8
- EI-AA-101, Employee Concerns Program, Revision 8
- LS-AA-1012, Safety Culture Monitoring, Revision 0
- OP-AA-108-115, Operability Determinations, Revision 8
- Fundamentals Management System User Instructions, Revision 4
- OP-MA-109-101-1001, Clearance and Tagging HIT Team Performance Management Process, Revision 4
- AD-PB-101-2002, Preparation of Surveillance/Routine Test Procedures, Revision 0
- WC-PB-101-1002, On Line Scheduling Process, Rev 0
- OP-AA-108-115-1002, Supplemental Consideration For On-shift Immediate operability determinations (CM-1), Rev 0
- OP-AA-108-115-1001, Operability Evaluation Passport Engineering Change Desktop Guide, Rev 0 M-054-005, Magne-Blast Circuit Breaker Routine PM, Rev 12
- ST-O-37D-340-2, Diesel Driven Fire Pump Flow Rate Test, Rev 16
- ST-O-052-203-2, Data Sheet 10 - 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> diesel log, Rev 19
- SO 52A.8.C, Diesel Generator Running Inspection, Rev 31
- ER-AA-330-009, ASME Section XI Repair/Replacement Program, Rev 4
- A-5LS-AA-110, Commitment Management, Rev 6
- OP-AA-103-102, Watch Standing Practices, Rev 8
- Completed Surveillances
- ST-O-052-413-2, E3 Diesel Generator Fast Start and Full Load Test, completed 2/14/2007
- RT-O-052-251-2, E1 Diesel Generator Inspection Post Maintenance Functional Test, completed 8/3/2007
- ST-O-052-121-2, E1 Diesel Generator RHR Pump Reject Test, completed 8/30/2007
- ST-O-054-751-E2, E12 4KV bus Undervoltage Relays and LOCA LOOP Functional Test, completed 9/25/2008
- ST-O-054-751-E2, E12 4KV bus Undervoltage Relays and LOCA LOOP Functional Test, completed 9/25/2008
- ST-O-054-751-E2, E12 4KV bus Undervoltage Relays and LOCA LOOP Functional Test, completed 9/26/2008
- ST-O-054-751-E2, E12 4KV bus Undervoltage Relays and LOCA LOOP Functional Test, completed 10/9/2008
- ST-O-054-751-E2, E12 4KV bus Undervoltage Relays and LOCA LOOP Functional Test, completed 9/25/2009
- ST-O-054-751-E2, E12 4KV bus Undervoltage Relays and LOCA LOOP Functional Test, completed 9/26/2009
- ST-O-054-751-E2, E12 4KV bus Undervoltage Relays and LOCA LOOP Functional Test, completed 10/9/2009
- ST-N-080-900-2, Visual Examination of Drywell and Torus Surfaces, Revision 2, completed 9/27/08
- ST-N-080-900-3, Visual Examination of Drywell and Torus Surfaces, Revision 1, completed 10/9/05
- ST-O-010-611-2, RHR Loop A Piping Pressure Test Inspection, Revision 2, completed 11/18/07
- ST-O-010-611-3, RHR Loop A Piping Pressure Test Inspection, Revision 2, completed 4/9/07
- ST-O-010-616-2, RHR Loop B Piping Pressure Test Inspection, Revision 1, completed 11/26/07
- ST-O-010-616-3, RHR Loop B Piping Pressure Test Inspection, Revision 1, completed 4/30/08
- ST-O-07G-475-2, Main Steam Isolation Valve Closure Timing at Shutdown, Revision 1, 9/14/04
- ST-O-07G-475-2, Main Steam Isolation Valve Closure Timing at Shutdown, Revision 1, 9/18/06
- ST-O-07G-475-2, Main Steam Isolation Valve Closure Timing at Shutdown, Revision 1, 9/15/08
- ST-O-07G-475-3, Main Steam Isolation Valve Closure Timing at Shutdown, Revision 1, 9/20/05
- ST-O-07G-475-3, Main Steam Isolation Valve Closure Timing at Shutdown, Revision 2, 9/24/07
- ST-O-07G-470-2, Main Steam Isolation Valve Closure Timing, Revision13, 10/8/08
- ST-O-032-301-2, HPCI Pump, Valve, Flow and Unit Cooler Functional and In-service Test, Rev 51, completed 3/29/09
- ST-O-032-301-2, HPSW Pump, Valve and Flow Functional and Inservice Test, Rev 24, completed 3/30/09 SI2L-23-74-XXCQ, Calibration Check of (HPCI) Condensate Storage Tank Level Instruments
- RT-O-023-750-2, HPCI Functional Test from Alternative Control Panels, Rev 16, completed 3/11/08
- RT-O-032-310-3, High Pressure Service Water Oil Cooler Heat Transfer Capability Test, Rev
- 10, completed 7/17/08
- RT-O-033-600-2, Flow Test of ESW to ECCS Coolers and Diesel Generator Coolers, Rev 17, completed 7/5/09
- ST-O-033-400-3, ESW Valve
- CHK-3-33-514 Inservice Test, Rev 9, completed 10/03/07
- RT-M-033-675-2, Unit 2 Pump Intake Structure Inspection and Cleaning, completed 9/28/08
LIST OF ACRONYMS
ADAMS Agency-wide Documents
Access and Management System