IR 05000352/2008004
| ML083181209 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/13/2008 |
| From: | Paul Krohn Reactor Projects Region 1 Branch 4 |
| To: | Pardee C AmerGen Energy Co, Exelon Nuclear |
| KROHN P, RI/DRP/PB4/610-337-5120 | |
| References | |
| IR-08-004 | |
| Download: ML083181209 (24) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ber 13, 2008
SUBJECT:
LIMERICK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000352/2008004 AND 05000353/2008004
Dear Mr. Pardee:
On September 30, 2008, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Limerick Generating Station Units 1 and 2. The enclosed integrated inspection report documents the inspection results which were discussed on October 2, 2008, with Mr. C. Mudrick and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents one NRC-identified finding of very low safety significance (Green).
The finding was determined to involve a violation of an NRC requirement. However, because of the very low safety significance and because it is 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 basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administration, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-001; and the NRC Resident Inspector at the Limerick facility.
In accordance with 10 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 NRCs 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 Projects Branch 4 Division of Reactor Projects Docket Nos: 50-352, 50-353 License Nos: NPF-39, NPF-85 Enclosure: Inspection Report 05000352/2008004 and 05000353/2008004 w/Attachment: Supplemental Information cc w/encl:
C. Crane, President and Chief Operating Officer, Exelon Generation M. Pacilio, Chief Operating Officer, Exelon Generation Company, LLC C. Mudrick, Site Vice President - Limerick Generating Station E. Callan, Plant Manager, Limerick Generating Station R. Kreider, Regulatory Assurance Manager R. DeGregorio, Senior Vice President, Mid-Atlantic Operations K. Jury, Vice President, Licensing and Regulatory Affairs P. Cowan, Director, Licensing D. Helker, Licensing B. Fewell, Associate General Counsel Correspondence Control Desk D. Allard, Director, PA Department of Environmental Protection J. Johnsrud, National Energy Committee, Sierra Club Chairman, Board of Supervisors of Limerick Township J. Powers, Director, PA Office of Homeland Security R. French, Director, PA Emergency Management Agency
SUMMARY OF FINDINGS
IR 05000352/2008004, 05000353/2008004; 07/01/2008 - 09/30/2008; Limerick Generating
Station, Units 1 and 2; Flood Protection Measures.
The report covered a three-month period of inspection by resident inspectors and announced inspections by regional reactor inspectors. One NRC-identified Green finding, determined to be a non-cited violation (NCV), was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (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. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight," Revision 4, dated December 2006.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a NCV of Technical Specification (TS) 6.8.1,
Administrative Controls - Procedures, because Exelon did not maintain adequate procedures in that Emergency Operating Procedure T-103, Secondary Containment Control, contained an inappropriate high maximum safe operating flooding level for the Unit 2 High Pressure Coolant Injection (HPCI) room.
The inspectors determined that this finding was greater than minor because it affected the procedure quality attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring availability, reliability, and capability of the HPCI system. Emergency Operating Procedure T-103, Secondary Containment Control, delineated an incorrect value of 40 inches for the Unit 2 HPCI room maximum safe operating (MSO) flooding level. Water at this height in the Unit 2 HPCI room would submerge the auxiliary oil pump and would render the HPCI system inoperable. This finding is of very low safety significance because it did not represent a design or qualification deficiency, a loss of safety system function, an actual loss of safety function of a single train for greater than its TS allowed outage time, or a total loss of any safety function that contributes to external event-initiated core damage sequences. The inspectors determined that this violation has a cross-cutting aspect in the area of problem identification and resolution because Limerick did not perform a thorough extent-of-condition review following a 2005 NCV for a similar issue for the Unit 1 RCIC room MSO level (NCV 05000352/2005003-01).
Although the station identified that the Unit 2 HPCI auxiliary oil pump and its associated junction box were located below the MSO level during the review,
Limerick did not thoroughly evaluate the impact of the elevation difference on the operation of the HPCI system (P.1(c)). (Section 1R06)
Licensee-Identified Violations
None.
REPORT DETAILS
Summary of Plant Status
Unit 1 began the inspection period operating at full rated thermal power (RTP). On September 6, 2008, operators reduced power to approximately 80 percent to facilitate main steam isolation and main turbine valve testing, control rod scram time testing, and a control rod sequence exchange. Full RTP was achieved on September 7, 2008. Unit 1 operated at full RTP for the remainder of the inspection period.
Unit 2 began the inspection period operating at full RTP. On September 12, 2008, operators reduced power to approximately 60 percent to facilitate main condenser tube leak detection and tube plugging, main steam isolation and main turbine valve testing, control rod scram time testing, and a control rod sequence exchange. Full RTP was achieved on September 15, 2008.
Unit 2 operated at full RTP for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
Impending Adverse Weather Conditions (71111.01 - 1 sample)
a. Inspection Scope
The inspectors evaluated implementation of adverse weather preparation procedures and compensatory measures as a result of severe thunderstorms and associated high winds experienced on July 24, 2008. The inspectors toured risk-significant and susceptible plant areas to verify preparation procedures and compensatory measures before the onset of the adverse weather conditions. The inspectors verified that Exelon reviewed emergency response capabilities following the storm. The inspectors reviewed associated issues entered into the corrective action program (CAP) to verify that they were properly characterized for resolution. Documents reviewed are listed in the
.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
.1 Partial Walkdown
a. Inspection Scope
The inspectors performed a partial walkdown of the plant systems listed below to verify the operability of risk significant systems or redundant trains and components when safety-related equipment in the opposite train was either inoperable, undergoing surveillance testing, or potentially degraded. The inspectors used TSs, Exelon operating procedures, plant piping and instrumentation drawings (P&IDs), and the Updated Final Safety Analysis Report (UFSAR) as guidance for conducting partial system walkdowns. The inspectors reviewed the alignment of system valves and electrical breakers to ensure proper in-service or standby configurations as described in plant procedures and drawings. During the walkdown, the inspectors evaluated the material condition and general housekeeping of the system and adjacent spaces. The documents reviewed are listed in the Attachment. The inspectors performed walkdowns of the following areas:
- Unit 2 HPCI system;
- A, B, and C Residual Heat Removal Service Water (RHRSW) pumps when D RHRSW pump was out-of-service; and
b. Findings
No findings of significance were identified.
.2 Complete System Walkdown
a. Inspection Scope
The inspectors conducted one complete system walkdown of the Unit 1 HPCI system to verify that equipment was properly aligned. The walkdown included reviews of valve positions, major system components, electrical power availability, and equipment deficiencies. The inspectors reviewed system check-off lists, system operating procedures, the system P&IDs, and the UFSAR. The inspectors reviewed outstanding maintenance activities and issue reports (IRs) associated with the Unit 1 HPCI system to determine if they would adversely affect system operability. The inspectors reviewed a sample of IRs dating back to 2003 associated with the system to verify that Exelon evaluated and implemented appropriate corrective actions. The walkdown also included an evaluation of system piping, supports, and component foundations to ensure they were not degraded. The documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R05 Fire Protection
Fire Protection - Tours (71111.05Q - 6 samples)
a. Inspection Scope
The inspectors conducted a tour of the six areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that combustibles and ignition sources were controlled in accordance with Exelons administrative procedures. Fire detection and suppression equipment was verified to be available for use, and passive fire barriers were verified to be maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out-of-service, degraded, or inoperable fire protection equipment in accordance with the stations fire plan. The inspectors toured the following areas:
- Unit 1 A Battery Room;
- D11 Switchgear Room;
- Unit 1 Cable Spreading Room;
- Unit 2 Cable Spreading Room;
- Unit 1 Inverter Room; and
- Unit 2 Inverter Room.
a. Findings
No findings of significance were identified.
1R06 Flood Protection Measures
a. Inspection Scope
The inspectors reviewed the UFSAR and related flood analysis documents to identify areas that can be affected by internal flooding, to identify features designed to alert operators of a flooding event, and to identify features designed for coping with internal flooding. The inspectors performed a walkdown of the Unit 1 and Unit 2 HPCI rooms.
The inspectors observed flood protection features to assess their ability to minimize the impact of a flooding event. The inspectors performed a review of operator actions contained in off-normal and emergency operating procedures for flooding to verify that they can reasonably be used to achieve desired actions. Documents reviewed are listed in the Attachment.
b. Findings
Introduction.
The inspectors identified a Green NCV of TS 6.8.1, Administrative Controls - Procedures, because Exelon did not maintain adequate procedures in that Emergency Operating Procedure T-103, Secondary Containment Control, Revision 20 contained an inappropriately high maximum safe operating (MSO) flooding level for the Unit 2 HPCI room.
Description.
The bases document for Emergency Operating Procedure T-103, Secondary Containment Control, describes the MSO level as the highest value of a parameter, at which neither
- (1) equipment necessary for the safe shutdown of the plant will fail, nor
- (2) personnel access necessary for the safe shutdown of the plant will be precluded. Limerick defined the MSO value for flooding of the Unit 2 HPCI room to be 40 inches above the room floor surface in Emergency Operating Procedure T-103.
Determination of this level was based on a letter from the vendor, dated June 24, 1988, which stated that the limiting component in the Unit 2 HPCI room, with regards to rising water level, would be a junction box on the HPCI turbine located at a height of 40 inches.
The inspectors performed a walkdown of the Unit 2 HPCI room to verify that there were no components required for operation of HPCI that were located at a height less than the MSO level and discovered that the HPCI auxiliary oil pump and its associated junction box were located below the MSO level. The HPCI auxiliary oil pump provides control oil pressure during system startup for proper functioning of the hydraulic control system to open the turbine stop and control valves. Disabling the auxiliary oil pump prior to system startup would render the HPCI system inoperable and not capable of performing its intended safety function. The inspectors concluded that the MSO level was incorrect because operating at this level would render HPCI inoperable due to partial submergence of the auxiliary oil pump motor. The inspectors also determined that Exelon had a previous opportunity to identify this discrepancy in 2005 following an NRC-identified NCV (NCV 05000352/2005003-01) for a similar issue associated with the Unit 1 RCIC room MSO level. As part of the extent of condition review for the 2005 NCV, Exelon evaluated the Unit 2 HPCI room. The review identified that the HPCI auxiliary oil pump and its associated junction box were located below the MSO level.
However, the impact of the elevation difference was not fully evaluated and dispositioned.
This finding is a performance deficiency because Limerick did not designate an appropriate MSO level for the Unit 2 HPCI room in Emergency Operating Procedure T-103, Secondary Containment Control, Revision 20. The station determined that a new MSO level value of 29 inches would be more appropriate. Limerick implemented a temporary change to T-103 to reflect this new value as an interim measure until the procedure is permanently revised. Additionally, Limerick is planning an extent of condition review on the other Unit 1 and Unit 2 emergency core cooling system rooms.
Exelon documented these items in IR 804992.
Analysis.
The inspectors determined that this finding was greater than minor because it affected the procedure quality attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring availability, reliability, and capability of the HPCI system. Emergency Operating Procedure T-103, Secondary Containment Control, delineated an incorrect value of 40 inches for the Unit 2 HPCI room MSO flooding level. Water at this height in the Unit 2 HPCI room would submerge the auxiliary oil pump and would render the HPCI system inoperable. Inspectors evaluated this finding using IMC 0609, Attachment 4, Initial Screening and Characterization of Findings. This finding is of very low safety significance because it is not a design or qualification deficiency, did not represent a loss of safety system function, did not result in an actual loss of safety function of a single train for greater than its TS allowed outage time, or a total loss of any safety function that contributes to external event-initiated core damage sequences.
The inspectors determined that this violation has a cross-cutting aspect in the area of problem identification and resolution because Limerick did not perform a thorough extent-of-condition review following a 2005 NCV for a similar issue for the Unit 1 RCIC room MSO level (NCV 05000352/2005003-01). Although the station identified that the HPCI auxiliary oil pump and its associated junction box were located below the MSO level during the review, Limerick did not thoroughly evaluate the impact of the elevation difference on the operation of the HPCI system (P.1(c)).
Enforcement.
TS 6.8.1 states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures as recommended in NRC Regulatory Guide 1.33, Appendix A, February 1978. NRC Regulatory Guide 1.33, Appendix A, Section 6.0, includes procedures for combating emergencies and other significant events, including flooding. Contrary to the above, Emergency Operating Procedure T-103, Secondary Containment Control, Revision 20 was inadequate in that it delineated an incorrect value for the Unit 2 HPCI room MSO for flooding. Specifically, the value described in T-103 for the Unit 2 HPCI room was 40 inches. Water at this height in the Unit 2 HPCI room would submerge the HPCI auxiliary oil pump and would render the HPCI system inoperable. Because this finding is of very low safety significance and Exelon has entered this finding into their corrective action program (IR 804992), this violation is being treated as a non-cited violation consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000353/2008004001, Inadequate Secondary Containment Control Procedure)
1R07 Biennial Heat Sink Performance
a. Inspection Scope
Based on safety significance and prior inspection history, the inspectors selected the following heat exchangers to evaluate Exelon=s means (inspection, cleaning, maintenance, and performance monitoring) of ensuring adequate heat sink performance:
- Unit 2 A Residual Heat Removal (RHR) heat exchanger (2AE205); and
- Unit 2 D Emergency diesel generator intercooler heat exchanger (2DE586);
Unit 2 D Emergency diesel generator jacket water cooler (2DE507); and Unit 2 D Emergency diesel generator lube oil cooler (2DE506).
The inspectors assessed the external condition of the above heat exchangers in the field; reviewed the eddy current, surveillance test, and inspection results; and reviewed the applicable system health reports to confirm that results were acceptable and that design basis assumptions for flow rate, plugged tube percentage, and heat transfer capability had been met. The inspectors discussed cathodic protection, piping corrosion, and heat exchanger practices, including the specifications and procedures for heat exchanger maintenance, with the Generic Letter 89-13 program engineer, applicable system engineers, and chemistry personnel. The inspectors reviewed applicable corrective action program documents to confirm that identified problems and degraded conditions had been resolved properly. Also, the inspectors inspected equipment conditions in Units 1 and 2 Pipe Tunnel, 2B RHR Room, and 2D Core Spray Room.
The inspectors assessed the condition of the spray pond (ultimate heat sink) and the pump house, and reviewed the 2007 evaluation of spray pond sediment depth. The chemical treatment programs for the spray pond were reviewed to verify that potential bio-fouling mechanisms were being addressed, including ongoing treatment and monitoring. The review included discussions with chemistry personnel and the RHRSW system engineer. The documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification Program
.1 Quarterly Licensed Operator Requalification Program
a. Inspection Scope
On August 5, 2008, the inspectors evaluated licensed operator requalification simulator scenarios on two operating crews. The scenario tested the operators ability to respond to engineered safety feature actuations and various failures, including a recirculation pump trip, a loss of coolant accident, and site structure damage. The inspectors observed licensed operator performance including operator critical tasks that measured operator actions required to ensure the safe operation of the reactor and protection of the nuclear fuel and primary containment barriers. The inspectors also assessed group dynamics and supervisory oversight to verify the ability of operators to properly identify and implement appropriate TS actions, regulatory reports, and notifications. The inspectors observed and reviewed the training evaluators grading and critiques and assessed whether appropriate feedback was provided to the licensed operators. The documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
.2 Limited Licensed Operator Requalification Program
a. Inspection Scope
The requalification program for Senior Reactor Operators Limited to Fuel Handling (LSRO) was evaluated using NUREG 1021, Revision 9, AOperator Licensing Examination Standards for Power Reactors@ and Inspection Procedure Attachment 7111111, ALicensed Operator Requalification Program.@
A review was conducted of recent operating history documentation regarding fuel handling found in inspection reports, licensee event reports, the licensee=s corrective action program, and the most recent NRC plant issues matrix. The inspectors also reviewed specific events from the licensee=s corrective action program to determine if possible training deficiencies existed.
The inspectors evaluated the Limerick 2008 and Peach Bottom 2007 operating tests and the Limerick 2008 and Peach Bottom 2006 written examinations for quality and compliance with the Examiner=s Standards. Administration of the five job performance measure operating examinations at Limerick was observed.
On August 12, 2008, the results of the biennial written examination and annual operating tests for 2008 were reviewed to determine whether pass/fail rates were consistent with the guidance of NUREG-1021, Revision 9, AOperator Licensing Examination Standards for Power Reactors.@ Performance of all individuals over two years was reviewed to check for adverse trends.
Two years of records for requalification training attendance and license reactivation for all four LSROs were reviewed for compliance with license conditions and NRC regulations. Medical records for three individuals were reviewed.
A sampling of feedback was reviewed and training materials were evaluated for response to this feedback. These materials were also reviewed for incorporation of plant modifications and industry events. The documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors evaluated Exelons work practices and follow-up corrective actions for structures, systems, and components (SSCs) and identified issues to assess the effectiveness of Exelons maintenance activities. The inspectors reviewed the performance history of risk significant SSCs and assessed Exelons extent-of-condition determinations for those issues with potential common cause or generic implications to evaluate the adequacy of the stations corrective actions. The inspectors assessed Exelons problem identification and resolution actions for these issues to evaluate whether Exelon 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 Exelons corrective actions that were taken or planned, to evaluate whether the actions were reasonable and appropriate. The documents reviewed are listed in the
. The inspectors performed the following samples:
- IR 516425, Unit 1 Core Spray Test Bypass Valve Failed to Close; and
- IR 798687, Emergency Diesel Generator (EDG) D14 Unresponsive to Main Control Room Controls Coincident with Voltage Swings.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors evaluated the effectiveness of Exelons maintenance risk assessments required by 10 CFR 50.65(a)(4). This inspection included discussion with control room operators and risk analysis personnel regarding the use of Exelons on-line risk monitoring software. The inspectors reviewed equipment tracking documentation, daily work schedules, and performed plant tours to gain assurance that the actual plant configuration matched the assessed configuration. Additionally, the inspectors verified that Exelons risk management actions, for both planned and emergent work, were consistent with those described in Exelon procedure, ER-AA-600-1042, On-Line Risk Management. The documents reviewed are listed in the Attachment. Inspectors reviewed the following samples:
- C0225355, Installation of Gag on Unit 2 A Recirculation Pump Motor-Generator Controls;
- IR 798188, B.5.b Pump Run;
- IR 808608, Unit 2 Online Risk with D Emergency Service Water (ESW), B RHR, and D RHRSW Pumps Out-of-Service.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
a. Inspection Scope
For the seven operability evaluations described below, the inspectors assessed the technical adequacy of the evaluations to ensure that Exelon properly justified TS operability and verified that the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors reviewed the UFSAR to verify that the system or component remained available to perform its intended safety function. In addition, the inspectors reviewed compensatory measures implemented to ensure that the measures worked and were adequately controlled. The inspectors also reviewed a sample of issue reports to verify that Exelon identified and corrected deficiencies associated with operability evaluations. The inspectors performed the following evaluations:
- IR 794500, Ultrasonic Test Results for RHRSW Piping in Manhole 212;
- IR 792556, Wiring Discrepancy Identified on Unit 2 D Core Spray Pump Suction Primary Containment Isolation Valve (HV-052-2F001D) Controller;
- IR 800086, Control Room Fresh Air Supply System Operability with Compensatory Measure to Start B Supply Fan With Dedicated Operator;
- IR 799896, Flat Washers on Safeguard Systems Blowout Panel (secondary containment);
- IR 808608, D ESW Instrument Tap Piping Leak; and
b. Findings
No findings of significance were identified.
1R18 Plant Modifications
.1 Temporary Modifications
a. Inspection Scope
The inspectors reviewed a temporary plant modification documented in Temporary Change 08-00231, RHRSW Compensatory Actions for Minimum Wall Condition in Manhole 212. This modification changed the normal operating configuration of system components. The inspectors reviewed the change to ensure that it did not adversely affect systems important to safety. The inspectors compared the temporary change with the UFSAR and TSs to verify that the modification did not affect system operability or availability. The inspectors ensured that station personnel implemented the modification in accordance with the applicable temporary configuration change process. The inspectors also reviewed the impact on existing procedures to verify Exelon made appropriate revisions to reflect the temporary configuration change. The documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
.2 Permanent Modifications
a. Inspection Scope
The inspectors reviewed a permanent plant modification documented in Engineering Change LG 04-00185, AVCO Scram Solenoid Pilot Valve Upgrade. The inspectors verified that the modification met the design bases and design assumptions, and that the modification preparation, staging, and implementation did not impair emergency or abnormal operating procedure actions and key safety functions. The inspectors also reviewed the modification to verify that the post-modification testing would establish operability, that unintended system interactions would not occur, and that testing demonstrated that the modification acceptance criteria were met. The documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the five post-maintenance tests (PMTs) listed below to verify that procedures and test activities ensured system operability and functional capability.
The inspectors reviewed Exelons test procedures to verify that the procedures adequately tested the safety functions that may have been affected by the maintenance activity, and that the acceptance criteria in the procedures were consistent with information in the licensing and design basis documents. The inspectors also witnessed the test or reviewed test data to verify that the results adequately demonstrated restoration of the affected safety functions. The documents reviewed are listed in the
. The inspectors performed the following samples:
- C0225781, Troubleshoot and Repair EDG D14 Following Voltage and Load Surges During Testing;
- C0225896, Rework Control Room Supply Fan Flow Switch, FSL-078-029B;
- C0226039, D ESW Pump Discharge Instrument Line Through Wall Leak Repair;
- R0947845, Perform Calibration of 20 Regulating Transformer Automatic Controls; and
- C0226215, Unit 1A Reactor Enclosure Recirculation System Inoperable Due to System Dampers Cycling.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors witnessed the performance and reviewed test data for seven surveillance tests (STs) that are associated with risk-significant SSCs. The review verified that Exelon personnel followed TS requirements and that acceptance criteria were appropriate. The inspectors also verified that the station established proper test conditions, as specified in the procedures, that no equipment preconditioning activities occurred, and that acceptance criteria had been met. The documents reviewed are listed in the Attachment. The inspectors reviewed STs for the following systems and components:
- ST-6-092-313-1, EDG D13 (slow start) Test;
- ST-6-098-230-2, 2B Standby Liquid Control Pump, Valve and Flow Test;
- ST-6-012-231-0, A Loop RHRSW Pump, Valve and Flow Test;
- ST-6-092-365-0, Inoperable Unit 1 Safeguard Power Supply Actions for Both Units;
- ST-6-051-233-1, C RHR Pump, Valve and Flow Test;
- ST-6-020-814-2, EDG D24 Diesel Fuel Oil Analysis; and
- ST-6-092-312-2, EDG D22 Diesel Generator Slow Start Operability Test Run.
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes (71114.04 -1 Sample)
a. Inspection Scope
Prior to this inspection, the NRC had received and acknowledged changes made to the Limerick Generating Station Emergency Plan and its implementing procedures. Exelon developed these changes in accordance with 10 CFR 50.54(q), and determined that the changes did not result in a decrease in effectiveness of the Emergency Plan. The licensee also determined that the Emergency Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR 50. During this inspection, the inspectors conducted a review of Exelon=s 10 CFR 50.54(q) screenings for all the changes made to the Emergency Action Level (EAL) Plan, and all of the changes made to the Emergency Plan from August 2007 through July 2008 that could have potentially resulted in a decrease in effectiveness of the Emergency Plan. The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 4. The requirements in 10 CFR 50.54(q) were used as reference criteria. The documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
4. OTHER ACTIVITES
4OA1 Performance Indicator (PI) Verification
.1 Mitigating System and Initiating Events Performance Indicators
a. Inspection Scope
The inspectors sampled Exelons submittal of the initiating events and mitigating systems performance indicators listed below to verify the accuracy of the data recorded from the fourth quarter of 2007 through the first quarter of 2008. The inspectors utilized performance indicator definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator Guidelines, Revision 5, to verify the basis in reporting for each data element. The inspectors reviewed various documents, including portions of the main control room logs, issue reports, power history curves, work orders, and system derivation reports. The inspectors also discussed the method for compiling and reporting performance indicators with cognizant engineering personnel and compared graphical representations from the most recent performance indicator (PI) report to the raw data to verify that the report correctly reflected the data.
The documents reviewed are listed in the Attachment.
Cornerstone: Mitigating Systems (2 samples)
- Units 1 and 2 RHR Mitigating Systems Performance Index.
Cornerstone: Initiating Events (4 samples)
- Units 1 and 2 Unplanned Scrams per 7000 Critical Hours; and
- Units 1 and 2 Unplanned Scrams with Complications.
b. Findings
No findings of significance were identified.
.2 Emergency Preparedness (EP) Performance Indicators (3 samples)
a. Inspection Scope
The inspectors reviewed data for the Limerick EP PIs, which included: Drill and Exercise Performance (DEP); Emergency Response Organization (ERO) Drill Participation; and Alert and Notification System (ANS) Reliability. The inspectors reviewed the PI data, its supporting documentation, and the information Exelon reported for the third and fourth quarters of 2007, and the first and second quarters of 2008, to verify the accuracy of the reported data. The review of these PIs was conducted in accordance with NRC Inspection Procedure 71151. The acceptance criteria used for the review were 10 CFR 50.9 and NEI 99-02, Revision 5, ARegulatory Assessment Performance Indicator Guidelines.@
Additionally, the inspectors performed NRC Temporary Instruction (TI) 2515/175, Emergency Response Organization, Drill/Exercise Performance Indicator Program Review, which ensured the completeness of the licensees completed Attachment 1 from the TI, and forwarded that data to NRC Headquarters. The documents reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
.1 Review of Items Entered into the Corrective Action Program
a. Inspection Scope
As required by Inspection Procedure 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 screened all items entered into Limericks corrective action program. The inspectors accomplished this by reviewing each new condition report, attending management review committee meetings, and accessing Exelons computerized database.
.2 Annual Sample - Load Tap Changer Timing
a. Inspection Scope
The inspectors reviewed Exelons evaluation and corrective actions associated with load tap changer timing verification. The inspectors reviewed condition reports and the associated actions against the requirements of Exelons corrective action program to ensure that the full extent of the issues were identified, appropriate evaluations were performed, and appropriate corrective actions were specified and prioritized. The inspectors interviewed relevant station personnel and reviewed applicable station procedures to ensure that the issues were addressed appropriately. The documents reviewed are listed in the Attachment.
b. Findings and Observations
No findings of significance were identified.
The inspectors determined that Exelons proposed corrective actions were reasonable with respect to the load tap changer timing issue. Exelon performed an appropriate extent-of-condition review and implemented calculation updates that reflected the current plant configuration. Exelon has scheduled tests to verify the mechanical times for each tap changer in order to validate the voltage calculation study. The inspectors determined that Exelons conclusion was appropriate. Namely, that although sufficient voltage may exist, there is little margin. Exelon entered this condition into the station margin management program for future action.
.3 Annual Sample - RHRSW Corrosion Issues
a. Inspection Scope
The inspectors reviewed implementation of the licensee=s corrective action program as it related to ESW and RHRSW pipe wall thinning. The inspectors reviewed corrective action program IRs, work orders, and associated documents. The inspectors reviewed the problem identification documentation including the evaluations of operability and reportability for accuracy and completeness. The inspectors reviewed the extent-of-condition determinations and common cause evaluations. The inspectors reviewed the classification and prioritization of the resolutions to correct the problem. The inspectors interviewed engineering personnel and toured the RHR rooms in Units 1 and 2 to observe the replacement of carbon steel piping with stainless steel piping. The inspectors noted that more testing, evaluation, and corrective actions are scheduled for the near term. The documents reviewed are listed in the Attachment.
b. Findings and Observations
No findings of significance were identified.
The inspectors determined that Exelons proposed corrective actions were reasonable with respect to the pipe wall thinning issue. Exelon contracted with a vendor to perform an appropriate extent-of-condition and to develop a flaw handbook. Exelon has scheduled tests to verify the condition of buried RHRSW piping using Guided Wave Examination (G-scan) methods. The inspectors observed that one due date out of thirty
- (30) was changed without fully assessing the impact to other corrective actions. The due date was for an action to develop contingencies to address the results of the Guided Wave Examinations. Exelon agreed to re-evaluate and assign a due date more representative of the overall corrective action schedule.
.4 Operator Workarounds
a. Inspection Scope
The inspectors performed an in-depth annual review of plant operator workarounds as documented in Exelons operator workaround program and corrective action documents.
This review was performed to verify that the licensee identified operator workarounds at an appropriate threshold, entered the issues into the CAP, and planned or implemented appropriate corrective actions. The documents reviewed are listed in the Attachment.
The inspectors reviewed the actions taken to verify that the licensee had adequately addressed the following attributes:
- Complete, accurate, and timely identification of the problem;
- Evaluation and disposition of operability and reportability issues;
- Consideration of previous failures, extent-of-condition, generic or common cause implications;
- Prioritization and resolution of the issue commensurate with the safety significance;
- Identification of the root cause and contributing causes of the problem; and
- Identification and implementation of corrective actions commensurate with the safety significance of the issue.
b. Findings and Observations
No findings of significance were identified. The inspectors determined that the issues reviewed did not adversely affect the capability of the operators to implement abnormal or emergency operating procedures and had been appropriately classified and prioritized.
the inspectors performed routine screening of issues entered into Limericks CAP. The review was accomplished by selectively reviewing copies of Issue Reports (IRs) and accessing Limericks computerized database.
4OA3 Event Follow-up
a. Inspection Scope
The inspectors observed plant parameters and evaluated performance of mitigating systems when a section of RHRSW loop A return piping indicated below American Society of Mechanical Engineers (ASME) minimum wall thickness measurements. The inspectors communicated the event to appropriate regional personnel and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of additional reactive inspection activities. The inspectors reviewed Exelons follow-up actions related to the event to assure that appropriate corrective actions were implemented commensurate with their safety significance.
b. Findings
No findings of significance were identified.
4OA5 Other Activities
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 review and inspection activities.
b. Findings
No findings of significance were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On October 2, 2008, the resident inspectors presented the inspection results to Mr. C. Mudrick and other members of his staff. The inspectors confirmed that proprietary information was not included in the inspection report.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Exelon Generation Company
- C. Mudrick, Site Vice President
- E. Callan, Plant Manager
- D. DiCello, Manager, Radiation Protection
- R. Dickinson, Director, Engineering
- P. Gardner, Director, Operations
- R. Kreider, Manager, Regulatory Assurance
- M. Jesse, Manager, Nuclear Oversight
- S. Bobyock, Manager, Plant Engineering
- M. Crim, Manager, Operations Services
- C. Gray, Manager, Radiological Engineering
- R. Harding, Engineer, Regulatory Assurance
- M. Gift, System Manager, Radiation Monitoring Systems
- R. Gosby, Radiation Protection Technician, Instrumentation
- D. Malinowski, Simulator Instructor
- J. Sprucinski, Senior Radiation Protection Technician
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Closed
2515/175 TI Emergency Response Organization, Drill/Exercise Performance Indicator, Program Review (Section 4OA1.2)
Opened and Closed
- 05000353/2008004-01 NCV Inadequate Secondary Containment Control Procedure (Section 1R06)
Discussed
None