IR 05000352/2010003

IR 05000352-10-003, 05000353-10-003, on 04/01/10 - 06/30/10; Limerick Generating Station, Units 1 and 2, Routine Integrated Report

ML102210139
Person / Time
Site:	Limerick
Issue date:	08/09/2010
From:	Paul Krohn Reactor Projects Region 1 Branch 4
To:	Pacilio M Exelon Generation Co, Exelon Nuclear
bellamy rr
References
IR-10-003
Download: ML102210139 (37)

Text

ust 9, 2010

SUBJECT:

LIMERICK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000352/2010003 AND 05000353/2010003

Dear Mr. Pacilio:

On June 30, 2010, 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 July 9, 2010, with Mr. W. Maguire and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Based on the results of this inspection, no findings of significance were identified.

In accordance with 10 CFR 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 Website at http://www.nrc.gov/reading-rm/adams.html(the Public Electronic Reading Room).

Sincerely,

~J.~

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 05000352/2010003 and 05000353/2010003

SUBJECT:

LIMERICK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000352/2010003 AND 05000353/2010003

Dear M

SUMMARY OF FINDINGS

IR 05000352/2010003; 05000353/2010003; 04/01/2010-06/30/2010; Limerick Generating

Station, Units 1 and 2; routine integrated report.

The report covered a three-month period of inspection by resident inspectors and announced inspections by regional reactor inspectors. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight," Revision 4, dated December 2006.

No findings of significance were identified.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period in Operational Condition (OPCON) 5 (Refueling) for refueling outage 1R13. On April 12, Unit 1 entered OPCON 2 (Startup). Operators synchronized the unit to the electrical grid ending refueling outage 1R13 on April 13. Full rated thermal power (RTP)was achieved on April 15.

On April 17, operators reduced Unit 1 power to approximately 65 percent in response to an electro-hydraulic control system fluid leak on an instrument line from the number 2 turbine control valve. Following repairs, operators returned Unit 1 to full RTP on April 18. On May 15, operators reduced power to approximately 70 percent to facilitate main turbine valve testing and secondary plant maintenance. The unit was returned to full RTP on May 16. On June 2, Unit 1 began to exhibit indications of a fuel assembly cladding leak.

On June 4, Unit 1 power was reduced to approximately 60 percent to facilitate fuel leak power suppression testing. Following the successful location and suppression of the leak (i.e., control rod insertion), power was returned to full RTP on June 9.

On June 23, operators manually scrammed Unit 1 per procedural requirements in response to the trip of both recirculation pump motor-generator sets. This was caused by a loss of the operating main generator stator water cooling pump when its power supply was lost as a result of an underground cable fault and the standby pump failed to start due to a control power problem. Unit 1 was taken to OPCON 4 (Cold Shutdown) to facilitate forced outage 1F44. A reactor startup was commenced on June 26 following reviews and the completion of other maintenance activities. Operators synchronized the unit to the electrical grid on June 27 and achieved full RTP on June 29. Unit 1 remained at full RTP for the rernainder of the inspection period.

Unit 2 began the inspection period operating at full RTP. On May 29, operators reduced power to approximately 65 percent to facilitate main turbine valve testing, control rod scram time testing, and main condenser waterbox cleaning. The unit was returned to full RTP later that day. Unit 2 remained at full RTP, except for periods of high condensate temperature due to environmental conditions (i.e., high outside temperatures), for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems and Barrier Integrity

1R01 Adverse Weather Protection (71111.0 - 1 sample)

Summer Readiness of Offsite and Alternating Current lAC) Power Systems

a. Inspection Scope

The inspectors performed a review of plant features and procedures for the operation and continued availability of the offsite and alternate AC power system to evaluate the readiness of the systems prior to seasonal high grid loading. The inspectors reviewed Exelon's procedures affecting these areas and the communications protocols between the transmission system operator and Exelon. This review focused on changes to the established program and material condition of the offsite and alternate AC power equipment. The inspectors assessed whether appropriate procedures and protocols were established and implemented to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system. The inspectors evaluated the material condition of the associated equipment by interviewing the responsible system manager, reviewing issue reports (IRs) and open work orders, and walking down portions of the offsite and AC power systems including the 500 kilo-volt and 220 kilo-volt switchyards. Documents reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment

Partial Walkdown (71111.04Q - 3 samples)

a. Inspection Scope

The inspectors performed partial walkdowns of the plant systems listed below to verify operability following realignment after a system outage window or while safety-related equipment in the opposite train was inoperable, undergoing surveillance testing, or potentially degraded. The inspectors used Technical Specifications (TS), Exelon operating procedures, plant piping and instrumentation diagrams (P&ID), 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 walkdowns, the inspectors evaluated the material condition and general housekeeping of the systems and adjacent spaces. The documents reviewed are listed in the Attachment. The inspectors performed walkdowns of the following areas:

• Motor-driven and diesel-driven fire pumps when Unit 1 high pressure coolant injection (HPCI) system was out-of-service (OOS) on April 22, 2010;

• Emergency diesel generators (EDGs) D22 and D24 when D21 was inoperable due to testing and D23 was unavailable due to maintenance on May 10, 2010; and

• EDG D23 following return-to-service on May 24, 2010.

b. Findings

No findings of significance were identified.

1 R05 Fire Protection

.1 Fire Protection - Tours (71111.050 - 4 sC!mples)

a. Inspection Scope

The inspectors conducted a tour of the four areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that combustible materials and ignition sources were controlled in accordance with Exelon's 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 OOS, degraded, or inoperable fire protection equipment in accordance with the station's fire plan. The documents reviewed are listed in the Attachment. The inspectors toured the following areas:

• Unit 1, Emergency Core Cooling System Corridor, Fire Area 40;

• Unit 1, D14 Diesel Generator and Fuel Oil-lube Oil Tank Room, Fire Area 82

• Unit 2, Class IE Battery Room, Fire Area 5; and

• Unit 2, D23 Diesel Generator and Fuel Oil-Lube Oil Tank Room, Fire Area 84.

b. Findings

No findings of significance were identified .

.2 Fire Protection - Drill Observation

a. Inspection Scope

The inspectors observed one unannounced fire drill conducted on Unit 1 Reactor Building, Elevation 201, Room 207 on June 15, 2010. The inspectors observed the drill to evaluate the readiness of the plant fire brigades to fight fires. The inspectors observed the fire brigade drill critique and assessed whether appropriate evaluator feedback was provided. The documents reviewed are listed in the Attachment. Specific attributes evaluated were:

• Proper donning of fire fighting turnout gear and self-contained breathing apparatus;

• Proper use and layout of fire hoses;

• Employment of appropriate fire fighting techniques;

• Sufficient firefighting equipment brought to the scene;

• Effectiveness of fire brigade leader communications, command, and control;

• Search for propagation of fire into other plant areas;

• Utilization of pre-planned strategies;

• Adherence to the pre-planned drill scenario; and

• Licensee self critique and drill evaluation.

b. Findings

No findings of significance were identified.

1

R08 In-Service Inspection

a. Inspection Scope

From March 29-April 2, 2010, the inspectors performed a review of Exelon's implementation of their risk-informed in-service inspection (lSI) program activities for monitoring degradation of the reactor coolant system boundary and risk significant piping system boundaries for Limerick Unit 1 using the criteria specified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI.

The sample selection was based on the inspection procedure objectives and risk priority of those components and systems where degradation would result in a significant increase in risk of core damage. The inspectors reviewed documentation, observed in-process non-destructive examinations (NDE) and interviewed inspection personnel to verify that the activities were performed in accordance with the ASME Boiler and Pressure Vessel Code Section XI requirements.

Activities inspected during the Unit 1 refueling outage 1 R13 included direct observations of in process ultrasonic testing (UT) including both automated phased array and manual UT techniques on the nozzle to safe-end dissimilar metal welds of N2J and N2H. The inspectors also observed magnetic particle testing (MT) of welds 1008 and 1009 which are flange to spool piece welds in the piping section of the residual heat removal service water (RHRSW) system that was replaced during 1R13.

The inspectors reviewed three sets of radiographic testing (RT) films from the repair of the residual heat removal (RHR) heat exchanger bypass valve, HV-C-051-1F048B. The inspectors also examined portions of videos and pictures of in-vessel visual inspections (IWI) of the jet pumps, the feedwater sparger, and the steam dryer to verify that Exelon is inspecting and monitoring in-vessel components in accordance with Boiling Water Reactor Vessel and Internals Project (BWRVIP) guidelines.

The inspectors performed direct visual inspection of the accessible portions of the drywell liner and reviewed visual inspection records of the components examined during Exelon's walk down.

Repair/Replacement Consisting of Welding Activities The inspectors reviewed three repair and replacement activities to verify that welding activities and applicable NDE were performed in accordance with ASME Code requirements. These activities included testing, removing, and replacing of 'A' and 'D' core spray pump relief valves and replacing the reactor core isolation cooling (RCIC)system barometric condenser relief valve, PSV-050-1 F033, and adjacent piping.

Additionally, the inspectors reviewed the engineering change package, ECR LG-10-00099, for the replacement of a five and one-half foot RHRSW piping section (HBC-091-01) which contained flaws in excess of minimum wall thickness previously evaluated under Code Case N-513-2. The documents reviewed are listed in the

.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Regualification Program

Resident Inspector Quarterly Review (71111.11 Quarterly - 1 sample)

a. Inspection Scope

On April 26, 2010, the inspectors observed licensed operator simulator just-in-time training and on May 5, 2010, the inspectors observed licensed operator simulator proficiency training on the operations department staff. The just-in-time training tested the operator's ability to decrease reactor power with both recirculation pumps having their scoop tubes locked. The May 5 training scenario tested the operators' ability to respond to an electro-hydraulic pressure regulator failure and to control reactor water level with the HPCI system. Another scenario on May 5 tested the operators' ability to respond to a steam leak in the drywell complicated by a scram with an anticipated transient without scram. The inspectors observed licensed operator performance including operator critical tasks, which are required to ensure the safe operation of the reactor and protection of the nuclear fuel and primary containment barriers. The inspectors also assessed crew 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 training instructor critiques and assessed whether appropriate feedback was provided to the licensed operators.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors evaluated Exelon's work practices and follow-up corrective actions for two issues within the scope of the maintenance rule. The inspectors reviewed the performance history of these structures, systems, and components (SSCs) and assessed the effectiveness of Exelon's corrective actions, including any extent-of-condition determinations to address potential common cause or generic implications.

The inspectors assessed Exelon's problem identification and resolution actions for these issues to evaluate whether Exelon had appropriately monitored, evaluated, and dis positioned the issues in accordance with Exelon procedures and the requirements of 10 CFR Part 50.65, "Requirements for Monitoring the Effectiveness of Maintenance." In addition, the inspectors reviewed the maintenance rule classifications, performance criteria, and goals for these SSCs and evaluated whether they appeared reasonable and appropriate. The documents reviewed are listed in the Attachment. The inspectors reviewed the following issues:

• IR1065596, EDG D23 failure;

• IR 1022255, Residual heat removal service water radiation monitor functional failures due to low flow); and

• IR1045832, Operator for HPCI system valve HV-055-1 F001 failed to shut-off.

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 Exelon's maintenance risk assessments required by Part 50.65(a)(4). This inspection included discussion with control room operators and risk analysis personnel regarding the use of Exelon's 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 Exelon's 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. The inspectors reviewed the following samples:

• IR 1051889, Unit 1 outage risk and Unit 2 on-line risk when the Unit 1 'A' reactor protection inverter supply breakers tripped, causing multiple engineered safety feature activations and inoperable equipment on April 2, 2010;

• Unit 1 on line risk when 'A' standby gas treatment train, Unit 'A' reactor enclosure recirculation train, and an offsite power source were unavailable on April 19, 2010;

• Recovery from heavy lift of Unit 2 spare main transformer on April 27, 2010;

• Unit 2, on-line risk when EDG D23 was OOS due to emergent repairs from May 4 to May 24, 2010; and

• A1269310, Unit 1, balance of plant battery ground and ground isolation activities on June 23, 2010.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors assessed the technical adequacy of a sample of seven operability 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 IRs to verify that Exelon identified and corrected deficiencies associated with operability evaluations. The documents reviewed are listed in the Attachment. The inspectors reviewed the following evaluations:

• IR 1055781, Abnormal color oil sample from Unit 1 HPCI booster pump bearings;

• IR 1065596, Operation Technical Decision Making Process (OTDM) for site EDG's following the failure of EDG D23 and IR 1065596,

• OTDM for returning EDG D23 to service following maintenance prior to completion failure root cause evaluation;

• IR 1075555, Fire system flow switch (FS-022-146-01) pipe connection broken;

• IR 1077831, Emergency service water valve HV-011-077 valve hung up while opening;

• IR 1080029, Unit 1 'A' (RHRSW) flow indication with no flow to heat exchanger; and

• IR 1081840, Unit 1 core spray loop '8' high pressure during HPCI pump, valve, and flow test.

b. Findings

No findings of significance were identified.

1R18 Plant Modifications

.1 Temporary Modifications

a. Inspection Scope

The inspectors reviewed the two temporary plant modifications listed below to ensure that installation of the modifications did not adversely affect systems important to safety.

The inspectors compared the modifications with the UFSAR and TS's to verify that the modification did not affect system operability, availability, or adversely affect plant operations. The inspectors ensured that station personnel implemented the modification, in accordance with the applicable temporary configurations change process. The impact on existing procedures was reviewed to verify Exelon made appropriate revisions to reflect the temporary changes. The documents reviewed are listed in the Attachment. The inspectors reviewed the following samples:

• Engineering Change LG 10-00132, Residual Heat Removal Service Water Hanger H8C-091-H003 Not Carrying Load; and

• Engineering Change LG 07-00413, Unit 1 Standby Liquid Control 'C' Pump Auto Start Inhibit Modification to HS-048-104C.

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 09-00096, "Leading Edge Flow Meter Checkplus Installation." The modification installed a Caldon leading edge flow meter ultrasonic flow measurement system to monitor the Unit 1 feedwater system to support measurement uncertainty recapture power uprate. The object of the modification was to recover lost megawatts due to fouling and inaccuracies present in the existing feedwater flow measuring devices.

The inspectors discussed the change with the responsible design engineer to assess any potential impacts on system operation and to ensure the design functions were not adversely affected. The inspectors verified affected procedures and design documents had been appropriately updated to incorporate the modification. 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 the testing demonstrated that the modification acceptance criteria were met. A field walkdown of the system was performed to verify the installed configuration was as described in the design change documentation. 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 six post-maintenance tests to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed Exelon's 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 Attachment. The inspectors reviewed the following samples:

• C0232551, Repair Unit 1 HPCI steam supply valve actuator (HV-055-1 F001);

• R1032159, Replace AC and direct current solenoid valves on main steam isolation valve HV-041-1F022A activator;

• C0233125, Repair EOG 023 piston damage;

• R1111856, Calibrate HPCI turbine speed control governor;

• C0233701, Investigate Unit 1 recirculation pump lubricating oil A2 failure to start on A 1 pump trip; and

• R0795109, EOG 014 six-year overhaul and 023 extent-of-condition inspections.

b. Findings

No findings of significance were identified.

1R20 Refueling and Other Outage Activities

.1 Unit 1 Maintenance and Refueling Outage

a. Inspection Scope

At the beginning of the inspection period, Unit 1 was in OPCON 5 (Refueling) with the reactor cavity flooded for refueling outage 1R13. On April 12, Unit 1 entered OPCON 2 (Startup). Operators synchronized the unit to the electrical grid ending completing the refueling outage on April 13. Full RTP was achieved on April 15. During the inspection period, the inspectors conducted several containment walkdowns and monitored plant startup and heatup activities. The documents reviewed are listed in the Attachment.

The inspectors reviewed Exelon's controls associated with the following outage activities:

• Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable TS when taking equipment out of service;

• Implementation of clearance activities and confirmation that tags were properly hung and that eqUipment was appropriately configured to safely support the associated work or testing;

• Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication and instrument error accounting;

• Status and configuration of electrical systems and switchyard activities to ensure that TS were met;

• Monitoring of decay heat removal operations;

• Impact of outage work on the ability of the operators to operate the spent fuel pool cooling system;

• Reactor water inventory controls, including flow paths, configurations, alternative means for inventory additions, and controls to prevent inventory loss;

• Activities that could affect reactivity;

• Maintenance of secondary containment as required by TS;

• Refueling activities, including fuel handling and fuel receipt inspections;

• Fatigue management; and

• Identification and resolution of problems related to refueling outage activities.

b. Findings

No findings of significance were identified .

.2 Unit 1 Manual Scram

a. Inspection Scope

The inspectors evaluated the activities associated with the forced outage (1 F44) that occurred as a result of a Unit 1 manual reactor scram on June 23, 2010. Operators inserted a manual scram per procedural requirements in response to the trip of both recirculation pump motor-generator sets. The recirculation pump motor-generators tripped as designed when the operating main generator stator water cooling pump lost its power supply as a result of an underground cable fault and the standby pump failed to start due to a control power problem. Unit 1 was taken to OPCON 4 (Cold Shutdown)to facilitate forced outage. A reactor startup was commenced on June 26 following reviews and the completion of other maintenance activities. The documents reviewed are listed in the Attachment. From June 23 through June 27, 2010, the inspectors monitored the activities listed below:

• Limerick's forced outage plan, including appropriate consideration of risk, industry operating experience, and previous site-specific problems;

• Plant Operations Review Committee and Outage Control Center meetings;

• Reactor water inventory controls, including flow paths, configurations, alternative means for inventory additions, and controls to prevent inventory loss;

• Monitoring of decay heat removal operations;

• Identification and resolution of problems related to refueling outage activities; and

• Portions of the reactor startup and ascension to fUll-power operation.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing (71111.22 - 6 samples; 3 routine surveillances; 2 in-service testing

(1ST); and 1 containment isolation valve)

a. Inspection Scope

The inspectors either witnessed the performance of, or reviewed test data, for six surveillance tests (STs) associated with risk-significant SSCs. The reviews verified that Exelon personnel followed TS req uirements 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 were met. The documents reviewed are listed in the Attachment. The inspectors reviewed the following samples:

• ST-6-041-202-1, MSIV Cold Shutdown Valve Test (containment isolation valve);

• RT-6-401-490-01, Suppression Pool Gross Input Leak Rate Determination;

• ST-6-055-230-01, HPCI Pump, Valve and Flow Test (1ST);

• ST-6-052-232-2, 'B' Loop Core Spray Pump, Valve and Flow Test (1ST);

• ST-6-095-918-2, Unit 2, Division 4, Safeguards Battery Inspection; and

• ST-6-092-113-2, D23 Diesel Generator, 24 Hour Endurance Test.

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS0 1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

During the period April 5 - 9, 2010, the inspectors conducted the following activities to verify that the licensee was evaluating, monitoring, and controlling radiological hazards for work performed in locked high radiation areas (LHRA) and other radiological controlled areas, and that workers were adhering to these controls when working in these areas, during the 1R13 refueling outage. Implementation of these controls was reviewed against the criteria contained in 10 CFR Part 20, TS, and the licensee's procedures.

Radiological Hazards Control and Work Coverage The inspectors identified exposure significant work areas in Unit 1. Specific work activities included demobilization activities in the Unit 1 drywell and reactor cavity draindown/decontamination. The inspectors reviewed radiation survey maps and radiation work permits (RWP) associated with these areas to determine if the associated controls were acceptable. The inspectors also attended the pre-job RWP briefing for cavity decontamination to determine if the workers were informed of the radiological conditions at the job site, respiratory protection requirements, electronic dosimeter alarm setpoints, and actions to be taken if a dosimeter alarms.

The inspectors toured the accessible radiological controlled areas in Unit 1, including the drywell, reactor building, waste processing building, and turbine building, and with the assistance of a radiation protection supervisor performed independent surveys of selected areas to confirm the accuracy of survey data and the adequacy of postings.

During this tour, the inspectors verified that selected LHRAs were properly secured and posted.

In evaluating the RWPs, the inspectors reviewed electronic dosimeter dose/dose rate alarm set points to determine if the setpoints were consistent with the survey indications and plant policy. The inspectors verified that workers were knowledgeable of the actions to be taken when the dosimeter alarms, or malfunctions, for tasks being performed under selected RWPs.

The inspectors reviewed the licensee's procedure for measuring personnel exposure using the effective dose equivalent (EDE) method. The inspectors confirmed that the method was approved by the NRC and that the implementing procedure appropriately specified the placement of whole body and extremity dosimeters on the worker.

Problem Identification and Resolution A review of a Nuclear Oversight objective evidence report, Personnel Contamination Event Reports, Issue Reports, and an Apparent Cause Evaluation, was performed to determine if identified problems and negative performance trends were entered into the corrective action program and evaluated for resolution.

IRs associated with radiation protection control access, initiated between January 2010 through March 2010, were reviewed and discussed with the licensee staff to determine if the follow up activities were being conducted in an effective and timely manner, commensurate with their safety significance.

High Radiation Area and Verv High Radiation Area Controls Procedures for controlling access to Locked High Radiation Areas (LHRA) and Very High Radiation Areas (VHRA), (e.g. the drywell and the traversing incore probe (TIP)room) were reviewed to determine if the administrative and physical controls were adequate. The inspectors also reviewed the physical and procedural controls for securing and removing highly contaminated/activated materials stored in the spent fuel pool. The inspectors discussed with radiation protection management, the adequacy of current LHRANHRA controls, including prerequisite communications and authorizations, and verified that any changes made to relevant procedures did not substantially reduce the effectiveness and level of worker protection.

Radiation Worker Performance and Radiation Protection Technician Performance The inspectors observed and questioned radiation workers and radiation protection technicians regarding radiological controls applied to various tasks, including equipment surveillance testing and maintenance tasks. The inspectors determined that the workers were aware of current RWP requirements, radiological conditions, access controls, and that the skill level was appropriate with respect to the potential radiological hazards and the work involved.

The inspectors reviewed the IRs related to radiation worker and radiation protection technician errors and personnel contamination event reports to determine if an observable pattern traceable to a similar cause was evident.

Contamination and Radioactive Material Control The inspectors observed workers surveying and releasing potentially contaminated materials for unrestricted use. The inspectors verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured.

During the period June 7 - 14, 2010, the inspectors conducted the following activities to verify that the licensee was evaluating, monitoring, and controlling radiological hazards for work performed in LHRAs and other radiological controlled areas. In particular, the inspectors conducted an in-depth review of the circumstances surrounding the temporary disabling of electromagnetic locks for four

(4) locked high radiation areas, contained in IR 1039368, in March 2010, and the subsequent apparent cause evaluation, and resulting corrective actions. Implementation of these controls was reviewed against the criteria contained in 10 CFR Part 20, TS, and the licensee's procedures.

On March 5, 2010, an isolated incident occurred at Limerick, while performing an upgrade to security systems. Electromagnetic locks to four LHRAs (door nos. 248, 266, 244, and 275) were de-energized for a short time period. The de-energization occurred during the swap over of power supplies, performed as part of a plant modification. The de-energization of the door locks was fortuitously, and coincidently, identified at the time during which the weekly verification that LHRA doors were locked was being performed.

At the time the swap over was being done, a radiation protection (RP) technician was performing his LHRA checks and found that the door opened upon challenging the door.

The technician immediately notified supervision and guarded the door, until power was restored minutes later. Upon investigating the incident, the licensee determined that four LHRA doors were unlocked for about 15 minutes during the swap over. The doors are water tight hatches that normally require an (RP) technician to unlock the electromagnetic lock and turn a large handwheel to undog the hatch. Subsequently, the RP tech remains there as a door guard until the task in the area(s) is completed.

Based on reviewing the licensee's investigation into this matter and conducting a walkdown of the affected doors, the inspectors determined that:

• The condition was self-identified by the licensee, during a routine verification process. Actions were immediately taken to control the situation and re-energize the locks. The condition was immediately entered into the corrective action program for cause evaluation. The condition was of short duration, with no safety consequence, during which no inadvertent entry or unplanned dose resulted.

• Established controls for entry into the affected areas were in-place during the swap over. The doors were well posted indicating that the area(s) were LHRA(s), requiring logging on a dedicated RWP, a pre-job briefing, an RP escort/guard, and use of a dedicated key prior to entry.

• The cause was thoroughly evaluated and comprehensive programmatic corrective actions were implemented including revisions to electrical procedures to include RP concurrence prior to any future swap over, and installation of robust secondary locking devices on the affected doors. Provisions were established to assure that an alternative means of egress from these areas was available, should the need arise.

• The licensee complied with two of three requirements contained in the TS Administrative Section 6.12.2 in that the LHRAs were conspicuously posted and that the keys to these areas were under supervisory control. The only additional action that the licensee should have taken, during the period that the LHRAs were de-energized, was to have door guards present at the disabled doors.

b. Findings

The failure to fully comply with Technical Specification Administrative Section 6.12.2, in that unlocked LHRAs were unguarded, constitutes a violation of minor significance that is not subject to enforcement action in accordance with the NRC's Enforcement Policy.

This issue was entered into the Exelon CAP as IR 1039368.

2RS02 Occupational ALARA Planning and Controls (71124.02 - 1 partial sample)

a. Inspection Scope

During the period April 5 - 9, 2010, the inspectors conducted the following activities to verify that the licensee was properly implementing operational, engineering, and administrative controls to maintain personnel exposure as low as is reasonably achievable (ALARA) for tasks performed during the Unit 1 refueling outage (1 R13).

Implementation of these controls was reviewed against the criteria contained in 10 CFR Part 20, applicable industry standards, and the Iicensee"s procedures.

Radiological Work Planning The inspectors reviewed pertinent information regarding the past Unit 1 outage exposure history, current exposure trends, and ongoing activities to assess current performance and exposure challenges for refueling outage 1 R13. A review of current ALARA Plans, Work-In-Progress Reviews, and a Post-Job ALARA review was completed to assess current performance.

The inspectors reviewed the contingency action plans that would be implemented should dose rates become elevated in various work areas during the refueling outage IR13.

Scheduled outage work included the in-service inspection of the Unit 1 reactor pressure vessel nozzles and the associated hydro-lazing and installation of temporary shielding.

Additional projects included suppression pool inspections, replacement of the reactor bottom head drain valves, and installation of coolant flow instrumentation.

The inspectors evaluated the departmental interfaces between radiation protection, operations, maintenance crafts, and engineering to identify missing ALARA program elements and interface problems. The evaluation was accomplished by attending a pre-job planning meeting for decontaminating the reactor cavity; reviewing recent Station ALARA Committee meeting minutes, work-in-progress/post-job ALARA reviews, Nuclear Oversight Objective Evidence Reports; and interviewing the site Radiation Protection Manager. The inspectors also attended two

(2) Station ALARA Committee meetings (Nos. 2010-09 & 2010-010) to assess how refueling outage 1R13 exposure challenges were being addressed by the site management and staff. Additionally, the inspectors attended a contractor's daily meeting to determine the level of detail that was provided to workers regarding ongoing ALARA performance.

Verification of Dose Estimates The inspectors reviewed the assumptions and basis for the exposure projections for the refueling 1R13 outage and compared actual cumulative exposure with established goals.

The inspectors reviewed the licensee's procedures associated with monitoring and re-evaluating dose estimates when the forecasted cumulative exposure for tasks differed from the actual exposure received. In particular, the inspectors reviewed the actions taken following identification of elevated dose rates in low pressure coolant injection piping, in which work was deferred to permit increased flushing and installation of additional temporary shielding in the affected areas, to lower dose rates. Also, the inspectors reviewed the licensee's tracking of emergent dose for increasing the scope of snubber inspections.

The inspectors reviewed the dose/dose rate alarm reports, work-in-progress evaluations, and exposure data for selected individuals receiving the highest (TEDE) for 2010 to confirm that no individual exposure exceeded the regulatory limit, or met the performance indicator reporting guideline.

Jobs-In-Progress The inspectors observed various jobs-in-progress to evaluate the effectiveness of dose control measures. Jobs observed included Unit 1 reactor cavity decontamination and drywell demobilization. As part of this evaluation, the inspectors reviewed the RWP, survey maps, and contamination control measures, and determined that workers were properly wearing dosimetry and were knowledgeable of RWP requirements. The inspectors attended the pre-job briefing for cavity decontamination. The inspectors also attended Station ALARA Committee meetings in which the management and staff discussed 1R13 outage ALARA performance, including snubber testing emergent dose, recirculation system drain valve replacement, and cavity draindown ALARA measures.

Source Term Control The inspectors reviewed the status and historical trends for the Unit 1 source term. By reviewing survey data for reactor coolant system piping (BRAC measurements) and interviewing the Radiation Protection Manager, the inspectors evaluated the recent source term measurements and control strategies. Specific strategies employed by the licensee included performing a reactor soft shutdown, system flushes, installation of permanent and temporary shielding in the drywell, vacuuming the seal plate, hydro-lazing of reactor nozzles, and increasing the capacity of the reactor cavity filtration system.

Problem Identification and Resolution The inspectors reviewed elements of the licensee's corrective action program related to implementing ALARA program controls, including issue reports, Nuclear Oversight Objective Evidence reports, dose/dose rate alarm reports, and Station ALARA Committee meeting minutes, to determine if problems were being entered at a conservative threshold and resolved in a timely manner.

b. Findings

No findings of significance were identified.

2RS03 In-Plant Airborne Radioactivity Control and Mitigation (71124.03 - 1 partial sample)

a. Inspection Scope

During the period April 5 - 9, 2010, the inspectors conducted the following activities to verify that the licensee was properly monitoring in-plant airborne radioactivity concentrations, implementing engineering controls to limit the uptake by workers, and appropriately using respiratory protection devices to maintain personnel exposure ALARA for tasks performed during the Unit 1 refueling outage 1R13. Implementation of these controls was reviewed against the criteria contained in 10 CFR Part 20, applicable industry standards, and the licensee's procedures.

Engineering Controls The inspectors reviewed the ALARA Plans for various tasks to determine if appropriate ventilation controls and airborne concentration "Stop work" criteria were specified to limit airborne contamination at the job site. Included in this review were control rod drive replacements, suppression pool platform activities, and reactor cavity decontamination.

For these activities, the inspectors reviewed the TEDE ALARA evaluation screening work sheet, to determine if the use of respiratory protection was appropriately evaluated.

The inspectors reviewed the air sample analysis sheets for various projects to evaluate the effectiveness of engineering controls in minimizing airborne contamination levels at the job site. The inspectors determined that the appropriate sampling technique was used in making airborne radioactivity measurements. Sampling methods used included breathing zone lapel samplers, and high/low volume samplers. Projects reviewed, that required air sampling, included weld preparations/flange replacement on the RHR system, inspections of main steam isolation valve internals, replacement of the fuel pool gate seal, reactor head inspections, installation of reactor head "0" rings, and turbine blade sand blasting.

During plant tours, the inspectors verified that continuous air monitors were operating and were representatively sampling work areas located in the drywell, turbine building, and reactor building.

Use of Respiratory Protection Devices The inspectors evaluated the use of respiratory protection devices for those tasks where it was impractical to employ engineering controls to minimize airborne radioactivity. The inspectors reviewed the use of respirators for reactor cavity decontamination and control rod drive replacement.

b. Findings

No findings of significance were identified.

2RS04 Occupational Dose Assessment (71124.04 - 1 partial sample)

a. Inspection Scope

During the period April 5 - 9, 2010, the inspectors conducted the following activities to verify that the licensee was properly monitoring occupational dose, that personal exposure monitoring devices were operable and accurately monitoring work dose, and that worker total effective dose equivalent was accurately determined for tasks performed during the Unit 1 refueling outage (1 R13). Implementation of these controls was reviewed against the criteria contained in 10 CFR Part 20, applicable industry standards, and the licensee's procedures.

External Dosimetry The inspectors verified that selected individuals were appropriately wearing thermoluminescent dosimeters and electronic dosimeters while the workers were performing tasks in radiological controlled areas. The inspectors reviewed dose and dose rate alarm logs and associated issue reports to determine if the cause of the alarm was appropriately determined and that the worker took prompt action upon receiving the alarm.

The inspectors reviewed the licensee's procedure for measuring personnel exposure using the effective dose equivalent (EDE) method. The inspectors confirmed that the method was approved by the NRC and that the implementing procedure appropriately specified the placement of whole body and extremity dosimeters on the worker. Tasks in which the EDE method was used included control rod drive replacement and suppression pool diving activities.

The inspectors reviewed the dose/dose rate alarm reports, dose extension authorizations, and exposure data for selected individuals receiving the highest TEDE for refueling outage 1R13, to confirm that no individual exposure exceeded the regulatory limit, or met the performance indicator reporting guideline.

Intemal Dosimetry The inspectors reviewed and assessed the adequacy of the results of whole body counting for personnel that had potential exposure to internally deposited contamination and determined that no individual received a recordable committed effective dose equivalent (CEDE) of greater than 10 millirem. The inspectors determined that the personnel were properly monitored with calibrated equipment, and that the data was properly analyzed.

Declared Pregnant Workers The inspectors verified that no declared pregnant workers were employed to work in radiologically controlled areas during refueling outage 1R13.

b. Findings

No findings of significance were identified.

2PS2 Radioactive Material Processing and Transportation (71124.08 - 1 sample)

a. Inspection Scope

During the period June 7 - 14, 2010, the inspectors conducted the following activities to verify that the licensee's radioactive material processing and transportation programs complied with the requirements of 10 CFR Parts 20, 61 and 71; and Department of Transportation (DOT) regulations 49 CFR Parts 170-189.

Radioactive Waste Systems Walkdown The inspectors walked down accessible portions of the radioactive liquid processing systems and site radwaste storage areas with the Radwaste Systems Engineer and a Radiation Protection Specialist, respectively. During the tour, the inspectors evaluated if the systems and facilities were consistent with the descriptions contained in the UFSAR and the Process Control Program, evaluated the general material conditions of the systems and facilities, and identified any changes to the systems. The inspectors reviewed the current processes for transferring radioactive resin/sludge to shipping containers, and the subsequent de-watering process.

Also during this tour, the inspectors walked down portions of radwaste systems that are no longer in service or abandoned in place, and discussed the status of administrative and physical controls for these systems including components of the radwaste evaporators and centrifuges.

The inspectors visually inspected various radioactive material storage locations with the Radiation Protection Specialist, including areas of the Radwaste Building, outside yard locations within the Protected Area, and the on-site disposal site (10 CFR Part 20.2002 area) to evaluate material conditions.

Waste Characterization and Classification The inspection included a selective review of the waste characterization and classification program for regulatory compliance, including:

• The radio-chemical sample analytical results for various radioactive waste streams;

• The development of scaling factors for hard-to-detect radio-nuclides from radio-chemical data;

• The methods and practices to detect changes in waste streams; and

• The characterization and classification of waste relative to 10 CFR Part 61.55 and the determination of DOT shipment subtype per 49 CFR Part 173.

Shipment Preparation The inspection included a review of radioactive waste program records, shipment preparation procedures, training records, and observations of jobs-in-progress, including:

• Reviewing radwaste and radioactive material shipping logs for calendar years 2009 and 2010;

• Verifying that training was provided to appropriate personnel responsible for classifying handling, and shipping radioactive materials, in accordance with Bulletin 79-19 and 49 CFR 172 Subpart H;

• Verifying that appropriate NRC (or agreement state) license authorization was current for shipment recipients for recent shipments; and

• Observing a RadWaste Shipping Supervisor prepare a shipment of metal specimens from the non-regenerative heat exchanger MM-10-067.

Shipment Records The inspectors selected and reviewed records associated with five

(5) shipments of radioactive material made since the last inspection of this area. The shipments were Nos. MW-10-009, MW-10-021 , MW-10-015, MW-10-003, and MW-10-002. The following aspects of the radioactive waste packaging and shipping activities were reviewed:

• Implementation of applicable shipping requirements including proper completion of manifests;

• Verification that dewatering criteria was met;

• Classification of radioactive materials relative to 10 CFR Parts 61.55 and 49 and 10 CFR Part 173;

• Labeling of containers relative to package dose rates;

• Radiation and contamination surveys of the packages;

• Placarding of transport vehicles;

• Conduct of vehicle inspections;

• Providing of emergency instructions to the driver;

• Completion of shipping papers; and

• Notification by the reCipient that the radioactive materials have been received.

Identification and Resolution of Problems The inspectors reviewed the 2009 Annual Radioactive Effluent Release Report, relevant Issue Reports, a Nuclear Oversight Audit, a self-assessment report, resin liner inspection records, and recent Yard Area Rad Material inspection reports. Through this review, the inspectors assessed the license's threshold for identifying problems, and the promptness and effectiveness of the resulting corrective actions. Additionally, the inspectors confirmed that the licensee was routinely verifying the integrity of radwaste containers that were placed in storage. This review was conducted against the criteria contained in 10 CFR Part 20.1101(c) and the licensee's procedures.

b. Findings

No findings of significance were identified.

4. OTHER ACTIVITES

40A1 Performance Indicator (PI) Verification

a. Inspection Scope

(71151 - 4 samples)

The inspectors sampled Exelon's submittal of the Mitigating Systems comerstone Pis listed below to verify the accuracy of the data recorded from April 2009 through March 2010. The inspectors utilized performance indicator definitions and guidance contained in Nuclear Energy Institute 99-02, "Regulatory Assessment Performance Indicator Guidelines," Revision 6, to verify the basis in reporting for each data element. The inspectors reviewed various documents, including portions of the main control room logs, IRs, 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 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

• Unit 1 and Unit 2 Safety System Functional Failures (MS05);

• Unit 1 and Unit 2 Emergency AC Power System (MS06).

b. Findings

No findings of significance were identified.

40A2 Identification and Resolution of Problems (71152 - 3 Samples)

.1 Review of Items Entered into the Corrective Action Program (CAP)

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 Limerick's CAP. The inspectors accomplished this by reviewing each new condition report, attending management review committee meetings, and accessing Exelon's computerized database.

b. Findings

No findings of significance were identified .

.2 Review of Items Associated with Inservice Inspectioon Activties

a. Inspection Scope

The extent of oversight of ISI/NDE activities including the topics of current lSI oversight and surveillance were reviewed. The inspector reviewed a sample of condition reports shown in Attachment 1 to confirm that identified problems were being documented for evaluation and proper resolution.

b. Findings

No findings of significance were identified .

.3 Semi-Annual Review to Identify Trends

a. Inspection Scope

As required by Inspection Procedure 71152, "Identification and Resolution of Problems,"

the inspectors performed a review of Exelon's CAP and associated documents to identify whether trends existed that would indicate a more significant safety issue. The review considered the period of January through June 2010 and was focused on repetitive equipment issues. The results of routine inspector CAP item screening, Exelon's trending efforts, and human performance results were also considered. The inspectors reviewed issues documented outside the normal CAP such as Plant Health Committee reports including the Top Ten Equipment Issues List, the Plant Health Committee Issues List, the Open Action Items List, and the Performance Improvement Integration Matrix.

b. Findings and Observations

No findings of significance were identified. The review did not reveal any trends that could indicate a more significant safety issue. The inspectors assessed that Exelon was identifying issues at a low threshold and entering the issues into the CAP for resolution.

The inspectors reviewed Exelon's actions in response to a negative trend identified in NRC Inspection Report 05000352/2009005, 05000353/2009005 related to corrective actions. The inspector identified issues where implemented corrective actions in the field differed from the intent of the Management Review Committee (MRC) approved CAP products. Three issues, two of which were Green non-cited violations, where implemented corrective action in the field differed from the intent of the MRC (i.e., motor control center thermography, emergency service water system instrument piping corrosion, and cobalt-60 in sewage sample). Exelon entered the issue into the CAP as IR 987707.

As a result of the NRC-identified trend and a review of IRs generated during the fourth quarter 2009, Exelon identified an issue with CAP quality and timeliness across multiple organizations at Limerick. As a result, Exelon developed a performance improvement action plan. Corrective actions included MRC review of corrective actions associated with past root cause evaluations, additional training and review of CAP requirements with root cause qualified personnel and performance improvement analysts, development of a comprehensive CAP investigation guide, and other actions to improve CAP program performance improvement. The inspectors concluded that Exelon's actions, taken or planned, to address the trend appeared to be comprehensive .

.4 Annual Sample: Review of Operator Workarounds

a. Inspection Scope

The inspectors performed an in-depth annual review of plant operator workarounds as documented in Exelon's operator workaround program and corrective action documents.

This review was performed to verify that the licensee identified operator workarounds at an appropriate threshold, ehtered the issues into the CAP, and planned or implemented appropriate corrective actions. The documents reviewed are listed in the Attachment.

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 .

.5 Annual Sample: EDG D23 Failure. Extent-of-Condition, and Restoration to Operable

Status (71152 - 1 sample)

a. Inspection Scope

The inspectors observed field activities, reviewed documents, and interviewed personnel to review the circumstances surrounding the failure of the D23 EDG during surveillance testing on May 5, 2010.

The inspectors assessed Exelon's troubleshooting plan, damage assessment, cause analyses, extent of condition reviews, operability determinations, and the prioritization of corrective actions to determine whether Exelon was appropriately identifying, characterizing, and prioritizing problems and whether the planned or completed corrective actions were appropriate to prevent recurrence. The inspectors also interviewed cognizant plant personnel regarding the identified issues and implemented corrective actions. Specific documents reviewed are listed in the Attachment to this report.

b. Findings and Observations

No findings of significance were identified.

The inspectors determined that Exelon properly implemented their corrective action process regarding the initial discovery of the emergency diesel generator failure. The issue report packages were complete and included cause evaluations, operability determinations, extent of condition reviews, review of operating experience, and corrective actions completed and planned. Additionally, the elements of the condition reports were detailed and thorough. The inspectors determined that corrective actions included replacing the failed components, performing appropriate post maintenance testing, and surveillance testing to ensure operability of the newly rebuilt diesel generator.

Additionally, Exelon contracted with the diesel generator vendor for support for the failure analysis, damage assessment, and rework/refurbishment. Exelon had not completed the root cause analysis at the time of this inspection. The final failure analysis is expected to be completed in early July 2010. The results of this analysis may require additional corrective actions to ensure reliable diesel generator operation. Long term corrective actions included enhanced engine monitoring during surveillance testing, inspections of engine internal parts, and enhanced oil sampling and testing. Exelon plans to evaluate the effectiveness of corrective actions following a year of the enhanced monitoring.

40A3 Event Follow-up (71153 - 4 sarnples)

a. Inspection Scope

For the four plant events listed below, the inspectors reviewed andlor observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional personnel and compared the event details with criteria contained in Inspection Manual Chapter 0309, "Reactive Inspection DeciSion Basis for Reactors," for consideration of potential reactive inspection activities. As applicable, the inspectors verified that Exelon made appropriate emergency action classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Exelon's follow-up actions related to the events to assure that appropriate corrective actions were implemented commensurate with their safety significance.

• IR 1058046, Unit 1 unplanned down power to 65 percent due to electro-hydrauliC control system leak on main turbine control valve #2, April 17, 2010;

• IR 1065596, EDG D23 failure and fire, May 5,2010;

• Sixty-day Emergency Notification System Report, due to an invalid actuation of various Unit 1 containment isolation valves caused by loss of power to system logic relays; and

• Unit 1 manual scram due to loss of recirculation pump motor-generator sets on June 23, 2010.

b. Findinqs No findings of significance were identified.

40A5 Other Activities (Closed) NRC Temporarv Instruction (Til 2515/179. Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10. Code of Federal Regulations. Part 20.2207 (10 CFR Part 20.2207)

a. Inspection Scope

During the period June 7 - 14, 2010, the inspector conducted the following activities to confirm the inventories of materials possessed at Limerick were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR Part 20.2207.

Inspection Planning

• The inspectors retrieved a copy of Limerick's NSTS inventory from Limerick's NSTS account via Regional staff with NSTS access.

Inventorv Verification

• The inspectors performed a physical inventory of the sources listed on Limerick's inventory and visually identified each source listed on the inventory.

• The inspectors verified the presence of the nationally tracked sources by having a radiation protection supervisor perform a survey with a radiation survey instrument.

• The inspectors examined the physical condition of the source containers, evaluated the effectiveness of the procedures for secure storage and handling, discussed Limerick's maintenance of the device including source leak tests, and verified the posting and labeling of the source was appropriate.

• The inspectors reviewed Limerick's records for the source and compared the records with the data from the NSTS inventory. The inspectors evaluated the effectiveness of Limerick's procedures for updating the inventory records.

Determine the Location of Unaccounted-for Nationally Tracked Source(s)

• The inspectors verified Limerick has no unaccounted-for source(s).

Review of Other Administrative Information

• The inspectors reviewed the administrative information contained in the NSTS inventory printout with Limerick personnel. All administrative information, mailing address, docket number, and license number, was verified to be correct.

b. Findings

No findings of significance were identified.

This completes the Region I inspection requirements for this TI.

40A6 Meetings, Including Exit On July 9, 2010, the inspectors presented the inspection results to Mr. W. Maguire and other members his staff. The inspectors confirmed that proprietary information was not included in the inspection report.

ATIACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

W. Maguire, Site Vice President

E. Callan, Plant Manager

S. Johnson, Assistant Plant Manager

D. Merchant, Radiation Protection Manager

R. Dickinson, Director of Training

P. Gardner, Director of Operations

R. Kreider, Director of Maintenance

D. Palena, Manager Nuclear Oversight

J. Hunter, Manager, Regulatory Assurance

C. Gray, Radiological Engineering Manager

R. Harding, Regulatory Assurance

T. Leddy, Radwaste Radiation Protection Technician

H. Miller, RadWaste Shipper

B. Landis, Sr. Radiation Protection Technician

C. Hawkins, NDE Engineer

L. Parlatore, Health Physicist

J. Risteter, Radiation Protection Manager

C. Smith, RadWaste Specialist, Chemistry

J. Trofe, Radiation Protection Supervisor

J. Kirkpatrick, Health Physics Supervisor

R. Harding, Regulatory Assurance Engineer

D. Kern, Sr. Radiation Protection Technician

G. Budock, lSI Program Engineer

M. Karasek, IWI Program Engineer

N. Harmon, Health Physicist

S. Bobyock, Manager, Plant Engineering

NRC Personnel

T. Moslak, Health Physicist, Region I

E. DiPaolo, Senior Resident Inspector

J. Bream, Project Engineer, Region I

N. Sieller, Resident Inspector

LIST OF ITEMS

OPENED OR CLOSED

Opened

None

Closed

2515/179 TI Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System, Pursuant to Title 10, Code of Federal Regulations, Part 20.2207 (10 CFR Part 20.2207) (Section 40A5).

Opened and Closed

None.

Discussed

None.