IR 05000352/2016008
| ML17018A231 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/17/2017 |
| From: | Daniel Schroeder Reactor Projects Region 1 Branch 4 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| Schroeder D | |
| References | |
| IR 2016008 | |
| Download: ML17018A231 (15) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ary 17, 2017
SUBJECT:
LIMERICK GENERATING STATION - PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000352/2016008 AND 05000353/2016008
Dear Mr. Hanson:
On December 15, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at the Limerick Generating Station, Units 1 and 2. The NRC inspection team discussed the results of this inspection with Mr. M. Herr, Assistant Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
In all of the areas reviewed, the NRC inspectors did not identify any findings or violations of more than minor significance. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Daniel L. Schroeder, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 50-352 and 50-353 License Nos. NPF-39 and NPF-85
Enclosure:
Inspection Report 05000352/2016008 and 05000353/2016008 w/Attachment: Supplementary Information
REGION I==
Docket Nos.: 50-352 and 50-353 License Nos.: NPF-39 and NPF-85 Report Nos.: 05000352/2016008 and 05000353/2016008 Licensee: Exelon Generation Company, LLC Facility: Limerick Generating Station, Units 1 and 2 Location: Sanatoga, PA 19464 Dates: November 28 - December 2, 2016 December 12 -15, 2016 Team Leader: Thomas Setzer, PE, Senior Project Engineer Inspectors: Peter Boguszewski, Project Engineer Matthew Fannon, Resident Inspector Mark Henrion, Project Engineer Approved by: Daniel L. Schroeder, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY
IR 05000352/2016008 and 05000353/2016008; 11/28/2016 - 12/15/2016;
Limerick Generating Station; Biennial Baseline Inspection of Problem Identification and Resolution.
This NRC team inspection was performed by three regional inspectors and one resident inspector. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6.
Problem Identification and Resolution The inspectors concluded that Exelon was effective in identifying, evaluating, and resolving problems. Exelon personnel identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with their safety significance.
Exelon appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that Exelon implemented corrective actions to address the problems identified in the corrective action program in a timely manner.
The inspectors concluded that Exelon adequately identified, reviewed, and applied relevant industry operating experience to Limerick operations. In addition, based on those items selected for review, the inspectors determined that Exelons self-assessments and audits were thorough.
Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues nor did they identify any conditions that could have had a negative impact on the sites safety conscious work environment.
No findings were identified.
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. All documents reviewed during this inspection are listed in the Attachment to this report.
.1 Assessment of Corrective Action Program Effectiveness
a. Inspection Scope
The inspectors reviewed the procedures that described Exelons corrective action program at Limerick. To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in these areas to the requirements and standards contained in 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, and Exelon procedure PI-AA-125, Corrective Action Program (CAP) Procedure. For each of these areas, the inspectors considered risk insights from the stations risk analysis and reviewed CAP issue reports selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. Additionally, the inspectors attended multiple Station Ownership Committee meetings. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, Maintenance Rule, and oversight programs.
- (1) Effectiveness of Problem Identification In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports. The inspectors also completed field walkdowns of various systems in both Units 1 and 2, which included the high pressure coolant injection (HPCI), reactor core isolation cooling (RCIC), core spray (CS), and residual heat removal (RHR) systems. Additionally, the inspectors reviewed a sample of CAP issue reports written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that Exelon entered conditions adverse to quality into their corrective action program as appropriate.
- (2) Effectiveness of Prioritization and Evaluation of Issues The inspectors reviewed the evaluation and prioritization of a sample of CAP issue reports issued since the last NRC biennial problem identification and resolution inspection completed in October 2014. The inspectors also reviewed CAP issue reports that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution.
The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, Licensee Event Reports, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.
- (3) Effectiveness of Corrective Actions The inspectors reviewed Exelons completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed CAP issue reports for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Exelons timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of CAP issue reports associated with selected non-cited violations and findings to verify that Exelon personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate Exelons actions related to the reactor enclosure recirculation system for both Units 1 and 2.
b. Assessment
- (1) Effectiveness of Problem Identification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Exelon, in general, identified problems and entered them into the corrective action program at a low threshold.
Exelon staff at Limerick initiated approximately 24,000 CAP issue reports between October 2014 and November 2016. The inspectors observed supervisors at the Station Ownership Committee meetings appropriately questioning and challenging CAP issue reports to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that Exelon trended equipment and programmatic issues, and appropriately identified problems in CAP issue reports. The inspectors verified that conditions adverse to quality identified through this review were entered into the corrective action program as appropriate. Additionally, inspectors concluded that personnel were identifying trends at low levels.
During a plant walkdown of safety significant areas in Units 1 and 2, the inspectors identified two minor issues that had not been entered into the corrective action program.
Specifically, the inspectors identified an oil leak on the Unit 1 HPCI suction valve from the condensate storage tank. Additionally, the inspectors identified an uncapped pipe that penetrated the floor in the Unit 1 RCIC room. Both of these issues were considered performance deficiencies because Exelon failed to identify the conditions adverse to quality and enter them into the CAP. Exelon promptly entered the issues into the corrective action program (IRs 3948230 and 3948821) and evaluated the issues to determine if there were any adverse effects upon the availability or operability of the HPCI or RCIC systems. Exelon determined that neither issue affected operability, and took corrective action to address the issues. The inspectors determined that the issues did not affect the availability, reliability, or capability of the HPCI and RCIC systems.
Therefore, the performance deficiencies were determined to be minor and not subject to enforcement action in accordance with the NRCs Enforcement Policy.
- (2) Effectiveness of Prioritization and Evaluation of Issues The inspectors determined that Exelon appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. Exelon screened CAP issue reports for operability and reportability, categorized the CAP issue reports by significance, and assigned actions to the appropriate department for evaluation and resolution. The issue report screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.
Based on the sample of CAP issue reports reviewed, the inspectors noted that the guidance provided by Exelon CAP implementing procedures appeared sufficient to ensure consistency in categorization of issues. Operability and reportability determinations were generally performed when conditions warranted and in most cases, the evaluations supported the conclusion. Causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue.
The inspectors noted one observation concerning the stations management of the oldest Action Items (ACITs). The inspectors requested a list of all corrective action program CAP issue reports initiated before the last PI&R inspection (October 2014) and that remain open. Exelon provided a list of approximately 600 items ranging from two to ten-years old. The inspectors reviewed this list of items and determined that there were no issues of safety significance; however, the due dates were not assigned in accordance with the intent of the corrective action procedure, and had in some cases been extended numerous times. Specifically, many items were extended due to lack of resources or higher priority work, and these items were then extended multiple times for the exact same reason. The inspectors noted that Exelon recently began monitoring this list but had not ensured that the due dates for the items were set according to priorities and resources. This was not considered a performance deficiency since Exelon procedures allow ACIT due dates to be extended multiple times; however, the inspectors noted that this practice would not ensure that the items get completed.
- (3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, Exelon identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC non-cited violations and findings since the last problem identification and resolution inspection were timely and effective.
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors reviewed a sample of CAP issue reports associated with review of industry operating experience to determine whether Exelon appropriately evaluated the operating experience information for applicability to Limerick and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Exelon adequately considered the underlying problems associated with the issues for resolution via their corrective action program.
In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.
Assessment The inspectors determined that Exelon appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable.
b. Findings
No findings were identified.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, departmental self-assessments, and assessments performed by independent organizations. Inspectors performed these reviews to determine if Exelon entered problems identified through these assessments into the corrective action program, when appropriate, and whether Exelon initiated corrective actions to address identified deficiencies.
Assessment The inspectors concluded that self-assessments, audits, and other internal Exelon assessments were generally critical, thorough, and effective in identifying issues. The inspectors observed that Exelon personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. Exelon completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. In general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance.
b. Findings
No findings were identified.
.4 Assessment of Safety Conscious Work Environment
a. Inspection Scope
During interviews with station personnel, the inspectors assessed the safety conscious work environment at Limerick. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns.
The inspectors reviewed the Employee Concerns Program files to ensure that Exelon entered issues into the corrective action program when appropriate.
Assessment During interviews, Limerick staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the corrective action program and the Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On December 15, 2016, the inspectors presented the inspection results to Mr. M. Herr, Assistant Plant Manager, and other members of the Limerick staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- R. Libra, Site Vice President
- D. Lewis, Plant General Manager
- M. Herr, Assistant Plant Manager
- I. Chaudry, ECP Coordinator
- S. Desimone, Security Manager
- T. Fritz, System Manager
- N. Lampe, Engineer
- W. Levis, Branch Manager
- C. Mattson, System Manager
- J. Mills, System Manager
- T. Ray, Security CAPCO
- E. Rosa, System Manager
- J. Somers, System Manager
- J. Thoryk, System Manager
- M. Trexler, Site Maintenance Rule Coordinator
- B. Weingard, Engineering Supervisor
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened and Closed
None