IR 05000352/2014006

ROP-15 Mid-Cycle Performance Review and Inspection Plan Report 05000352/2014006 and 05000353/2014006

ML14239A190
Person / Time
Site:	Limerick
Issue date:	09/02/2014
From:	Fred Bower Reactor Projects Region 1 Branch 4
To:	Pacilio M Exelon Generation Co, Exelon Nuclear
bower, fl
References
IR-2014-006
Download: ML14239A190 (5)

Text

UNITED STATES ber 2, 2014

SUBJECT:

MID-CYCLE ASSESSMENT LETTER FOR LIMERICK GENERATING STATION, UNITS 1 AND 2 (REPORT 05000352/2014006 AND 05000353/2014006)

Dear Mr. Pacilio:

On August 13, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed its mid-cycle performance review of Limerick Generating Station Units 1 and 2. The NRC reviewed the most recent quarterly performance indicators in addition to inspection results and enforcement actions from July 1, 2013 through June 30, 2014. This letter informs you of the NRCs assessment of your facility during this period and its plans for future inspections at your facility.

The NRC determined that overall, Limerick Generating Station (LGS) Units 1 and 2 was operated in a manner that preserved public health and safety and met all cornerstone objectives. The NRC also determined the performance at LGS Units 1 and 2 during the most recent quarter was within the Licensee Response Column of the NRCs Reactor Oversight Process Action Matrix because all inspection findings had very low (i.e., green) safety significance, and all performance indicators demonstrated that your performance was within the nominal, expected range (i.e, green). Therefore, the NRC plans to conduct Reactor Oversight Process baseline inspections at your facility.

Although plant performance was within the Licensee Response Column, the NRC has not yet finalized the significance of an apparent violation that has preliminarily been determined to have greater than very low security significance. Additional information on this apparent violation was documented in NRC inspection reports (IR) 05000352/2014403 and 05000353/2014403 (ML14211A077). We note that your staff chose to request a regulatory conference, as described in the above referenced IR, and the meeting will be held in the NRC Region I office on September 18, 2014. This meeting has been announced in Notice 2014-016, (ML14237A362). However, in the interest of protecting sensitive, security-related information, this regulatory conference will not be open for public observation. The final security significance determination may affect the NRCs assessment of plant performance, regulatory actions and oversight, and the enclosed inspection plan.

As a result of the Safety Culture Common Language Initiative, the terminology and coding of cross-cutting aspects were revised. All cross-cutting aspects identified during inspections conducted in calendar year 2014 reflect this revision to Inspection Manual Chapter (IMC) 0310.

Cross-cutting aspects identified in 2013 using the 2013 terminology were converted to the latest revision in accordance with the cross-reference in IMC 0310 during the mid-cycle assessment review and evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305. The enclosed inspection plan lists the inspections scheduled through December 31, 2015.

Routine inspections performed by resident inspectors are not included in the inspection plan.

The inspections listed during the last nine months of the inspection plan are tentative and may be revised at the end-of-cycle performance review. The NRC provides the inspection plan to allow for the resolution of any scheduling conflicts and personnel availability issues. The NRC will contact you as soon as possible to discuss changes to the inspection plan should circumstances warrant any changes. This inspection plan does not include security-related inspections, which will be sent via separate, non-publicly available correspondence.

In response to the accident at Fukushima, the Commission issued Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, which requires licensees to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities following a beyond-design-basis external event. Additionally, the Commission issued Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, which requires licensees to have a reliable means of remotely monitoring wide-range Spent Fuel Pool levels to support effective prioritization of event mitigation and recovery actions in the event of a beyond-design-basis external event. The NRC is conducting audits of licensee efforts towards compliance with these Orders. This audit includes an onsite component in order for the NRC to evaluate licensee plans for complying with the Orders, as described in site-specific submittals, and to receive and review information relative to associated open items. This onsite activity will occur in the months prior to a declaration of compliance for the first unit at each site, and will aid staff in development of an ultimate Safety Evaluation for the site. The date for the onsite component at your site has been coordinated with your staff and has been scheduled for the week of October 27, 2014. A site-specific audit plan for the visit will be provided in advance to allow sufficient time for preparations.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 2.390 of the NRCs Rules of Practice, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRC's Agencywide Documents Access and Management system (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Please contact me at (610) 337-5200 with any questions you have regarding this letter.

Sincerely,

/RA/

Fred L. Bower, III, Chief Division of Reactor Projects Project Branch 4 Docket Nos.: 50-352. 50-353 License Nos.: NPF-39, NPF-85 Enclosure: Limerick Generating Station Inspection/Activity Plan cc w/encl: Distribution via ListServ

ML14239A190 Non-Sensitive Publicly Available SUNSI Review Sensitive Non-Publicly Available OFFICE RI/DRP RI/DRP RI/DRS RI/DRP NAME EDiPaolo/GSB for SBarber/ GSB ADimitriadis/ JRC for FBower/ FLB DATE 08/22 /14 08/22 /14 08/25 /14 09/02/14 Distribution w/encl:

W. Dean, RA D. Lew, DRA H. Nieh, DRP M. Scott, DRP J. Trapp, DRS P. Krohn, DRS F. Bower, DRP S. Barber, DRP A. Turilin, DRP B. Lin, DRP E. DiPaolo, DRP, SRI R. Montgomery, DRP, RI N. Esch, DRP, AA A. Bowers, RI, OEDO DRS Branch Chiefs (6)

N. McNamara, RI, SLO D. Tifft, RI. SLO D. Screnci, RI, PAO N. Sheehan, RI, PAO RidsNrrPMLimerick Res RidsNrrDorlLpl1-2 Res ROPReports Res RidsNrrDirslpab Res ROPassessment Res

Page 1 of 3 Limerick 08/27/2014 15:30:24 Inspection / Activity Plan Report 22 07/01/2014 - 12/31/2015 Unit Planned Dates No. of Staff Number Start End Inspection Activity Title on Site 7111111B - LSRO REQ INSP WITH P/F RESULTS 2 1, 2 06/02/2014 12/31/2014 IP 7111111B Licensed Operator Requalification Program INSP - RADIATION PROTECTION 1 1, 2 07/07/2014 07/11/2014 IP 71124.01 Radiological Hazard Assessment and Exposure Controls 1, 2 07/07/2014 07/11/2014 IP 71124.02 Occupational ALARA Planning and Controls 1, 2 07/07/2014 07/11/2014 IP 71124.03 In-Plant Airborne Radioactivity Control and Mitigation 1, 2 07/07/2014 07/11/2014 IP 71124.04 Occupational Dose Assessment 1, 2 07/07/2014 07/11/2014 IP 71124.05 Radiation Monitoring Instrumentation 71152B - PI&R BIENNIAL 4 1, 2 09/15/2014 09/20/2014 IP 71152B Problem Identification and Resolution 1, 2 09/29/2014 10/03/2014 IP 71152B Problem Identification and Resolution 10/6EXAM - INITIAL OL EXAM 4 1 12/15/2014 12/19/2014 U01892 FY15-LIMERICK INITIAL OPERATOR LICENSING EXAM 1 01/12/2015 01/21/2015 U01892 FY15-LIMERICK INITIAL OPERATOR LICENSING EXAM INSP - RADIATION PROTECTION 1 1, 2 09/08/2014 09/12/2014 IP 71124.01 Radiological Hazard Assessment and Exposure Controls 1, 2 09/08/2014 09/12/2014 IP 71124.02 Occupational ALARA Planning and Controls 1, 2 09/08/2014 09/12/2014 IP 71124.03 In-Plant Airborne Radioactivity Control and Mitigation 1, 2 09/08/2014 09/12/2014 IP 71124.04 Occupational Dose Assessment 1, 2 09/08/2014 09/12/2014 IP 71124.05 Radiation Monitoring Instrumentation 1, 2 09/08/2014 09/12/2014 IP 71151 Performance Indicator Verification 7111107T - TRIENNIAL HEAT SINK 1 1, 2 09/29/2014 10/03/2014 IP 7111107T Heat Sink Performance MODS - PERMANENT PLANT MODIFICATIONS 6 1, 2 11/03/2014 11/07/2014 IP 7111117T Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications 1, 2 11/17/2014 11/21/2014 IP 7111117T Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications EP PROG - EP PROGRAM INSPECTION 2 1, 2 12/01/2014 12/05/2014 IP 7111402 Alert and Notification System Testing 1, 2 12/01/2014 12/05/2014 IP 7111403 Emergency Preparedness Organization Staffing and Augmentation System 1, 2 12/01/2014 12/05/2014 IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies 71124 - RADIATION PROTECTION 1 1, 2 03/16/2015 03/20/2015 IP 71124.01 Radiological Hazard Assessment and Exposure Controls 1, 2 03/16/2015 03/20/2015 IP 71124.02 Occupational ALARA Planning and Controls This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Page 2 of 3 Limerick 08/27/2014 15:30:24 Inspection / Activity Plan Report 22 07/01/2014 - 12/31/2015 Unit Planned Dates No. of Staff Number Start End Inspection Activity Title on Site 71124 - RADIATION PROTECTION 1 1, 2 03/16/2015 03/20/2015 IP 71124.03 In-Plant Airborne Radioactivity Control and Mitigation 1, 2 03/16/2015 03/20/2015 IP 71124.04 Occupational Dose Assessment 1, 2 03/16/2015 03/20/2015 IP 71124.05 Radiation Monitoring Instrumentation 7111108G - U2 INSERVICE INSPECTION 1 2 04/13/2015 04/17/2015 IP 7111108G Inservice Inspection Activities - BWR 71124 - RADIATION PROTECTION 1 1, 2 04/13/2015 04/17/2015 IP 71124.01 Radiological Hazard Assessment and Exposure Controls 1, 2 04/13/2015 04/17/2015 IP 71124.02 Occupational ALARA Planning and Controls 1, 2 04/13/2015 04/17/2015 IP 71124.03 In-Plant Airborne Radioactivity Control and Mitigation 1, 2 04/13/2015 04/17/2015 IP 71124.04 Occupational Dose Assessment 1, 2 04/13/2015 04/17/2015 IP 71124.05 Radiation Monitoring Instrumentation ISFSI - ISFSI LOADING INSPECTION 1 1, 2 06/01/2015 08/31/2015 IP 60855 Operation Of An ISFSI 1, 2 06/01/2015 08/31/2015 IP 60855.1 Operation of an Independent Spent Fuel Storage Installation at Operating Plants CDBI - COMPONENT DESIGN BASIS INSPECTION 7 1, 2 06/08/2015 06/12/2015 IP 7111121 Component Design Bases Inspection 1, 2 06/22/2015 06/26/2015 IP 7111121 Component Design Bases Inspection 1, 2 07/06/2015 07/10/2015 IP 7111121 Component Design Bases Inspection 71124 - REMP 1 1, 2 07/13/2015 07/17/2015 IP 71124.07 Radiological Environmental Monitoring Program 12/7EXAM - INITIAL OL EXAM 4 1 12/07/2015 12/11/2015 U01912 FY16 - LIMERICK INITIAL OPERATOR LICENSING EXAM 71124 - RADIATION PROTECTION 1 1, 2 09/04/2015 09/08/2015 IP 71124.01 Radiological Hazard Assessment and Exposure Controls 1, 2 09/04/2015 09/08/2015 IP 71124.02 Occupational ALARA Planning and Controls 1, 2 09/04/2015 09/08/2015 IP 71124.03 In-Plant Airborne Radioactivity Control and Mitigation 1, 2 09/04/2015 09/08/2015 IP 71124.04 Occupational Dose Assessment 1, 2 09/04/2015 09/08/2015 IP 71124.05 Radiation Monitoring Instrumentation 1, 2 09/04/2015 09/08/2015 IP 71151 Performance Indicator Verification 7111111B - REQUAL INSP W/ P/F RESULTS 2 1, 2 11/16/2015 11/20/2015 IP 7111111B Licensed Operator Requalification Program This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Page 3 of 3 Limerick 08/27/2014 15:30:24 Inspection / Activity Plan Report 22 07/01/2014 - 12/31/2015 Unit Planned Dates No. of Staff Number Start End Inspection Activity Title on Site EP - EP EXERCISE 5 1, 2 11/16/2015 11/20/2015 IP 7111401 Exercise Evaluation 1, 2 11/16/2015 11/20/2015 IP 7111408 Exercise Evaluation - Scenario Review This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.