EXELON - PEACH BOTTOM - PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION VIOLATION

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by Bob Meyer

M.J. Pacilio, President and CNO of Exelon Nuclear was notified in a letter from the NRC dated September 16, 2011 of the violation. Even though there has been several occasions since 2003 where TS violations have occurred with the most recent occurring on Unit 3 in 2010, this is still only a green finding.

How many times have you trained Operators on Safety Relief Valves not lifting as designed? If this happens during a plant transient, it may cause a misdiagnosis of the event by the operators.

Green. The inspectors identified a finding of very low safety significance (Green) involving a Violation of 10 CFR 50, Appendix B, Criterion XVl, "Corrective Action," because Exelon staff did not implement timely corrective action associated with safety relief valve (SRV)/safety valve (SV) lift setpoint drift in excess of Technical Specification (TS) 3.4.3, "Safety Relief Valves and Safety Valves" requirements. Specifically, Exelon staff did not implement timely or adequate actions to correct SRV lift setpoint drift that, on four occasions since 2004, has exceeded TS acceptance criteria and resulted in repeat TS violations.

The finding has a cross-cutting aspect in the area of problem identification and resolution, corrective action program, because Exelon personnel did not implement timely corrective actions to address a longstanding SRV tolerance setpoint condition that has resulted in multiple TS compliance violations.

Exelon staff's maintenance rule evaluation of lR 1120516 (SRV setpoint drift) missed an opportunity to identify that the maintenance rule pedormance reliability criteria for SRV/SVs (System 01A) was not consistent with Exelon procedure ER-AA-310-1003, "Maintenance Rule - Performance Criteria Selection." Specifically, the reliability criteria threshold was not sensitive to SRV/SV lift setpoint testing/surveillance frequencies and, therefore, the criteria established (> 3 maintenance preventable functionalfailures per 24 months) was not an effective monitoring toolwith regard to SRV/SV reliability.

Licensee Personnel

T. Dougherty Site Vice President

G. Stathes Plant Manager

P. Navin Operations Director

J. Armstrong Regulatory Assurance Manager

P. Cowan Work Management Director

R. Reiner Chemistry, Environmental and Radwaste Manager

D. McClellan Corrective Action Program Manager

S. Sullivan Operations Support Manager

J. James Maintenance Support Manager

H. McCrory Technical Support Manager

B.Shortes Radiological Engineering Manager

B. Hedrick Shift Operations Superintendent

D. Henry Engineering Programs Manager

R. Brower Electrical Design Manager

J. Chizever Mechanical Design Manager

R. Smith Regulatory Assurance

J. Dunlap Decontamination Advanced Radiation Worker Supervisor

T. Purcell Electrical Design Engineering

H. Coleman Mechanical Design Engineering

D. Lord Mechanical Design Engineering

P. Kester Mechanical Design Engineering

K. Hudson Mechanical Design Engineering

J. Donell Programs Engineering

J. Searer Programs Engineering

G. Cilliffo Programs Engineering

C. Burryman Prolect Engineering

S. Allen Plant Chemistry

C. Vest Measurement and Test Equipment Tool Room Attendant

J. Lowe Work Management Predefine Coordinator

D. Wheeler Maintenance Rule Program Coordinator

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