IR 05000352/2019010

Temporary Instruction 2515/191 Inspection Report 05000352/2019010 and 05000353/2019010

ML19207A083
Person / Time
Site:	Limerick
Issue date:	07/26/2019
From:	Matt Young NRC/RGN-I/DRP/PB6
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Young M
References
IR 2019010
Download: ML19207A083 (10)

Text

uly 26, 2019

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 - TEMPORARY INSTRUCTION 2515/191 INSPECTION REPORT 05000352/2019010 AND 05000353/2019010

Dear Mr. Hanson:

On June 13, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Limerick Generating Station, Units 1 and 2 and discussed the results of this inspection with Mr. Matthew Bonanno, Director Site Operations and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspectors did not identify any finding or violation 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 at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Matthew R. Young, Chief Reactor Projects Branch 6 Division of Reactor Projects Docket Nos. 05000352 and 05000353 License Nos. NPF-39 and NPF-85

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000352 and 05000353 License Numbers: NPF-39 and NPF-85 Report Numbers: 05000352/2019010 and 05000353/2019010 Enterprise Identifier: I-2019-010-0020 Licensee: Exelon Generation Company, LLC Facility: Limerick Generating Station, Units 1 and 2 Location: Sanatoga, PA Inspection Dates: June 10, 2019 to June 14, 2019 Inspectors: C. Cahill, Senior Reactor Analyst S. Haney, Senior Project Engineer C. Lally, Operations Engineer G. Stock, Resident Inspector Approved By: Matthew R. Young, Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Temporary Instruction (TI) 2515/191 inspection at Limerick Generating Station, Units 1 and 2 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations No findings or violations of more than minor significance were identified.

Additional Tracking Items None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter 2515, Light-Water Reactor Inspection Program -

Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 2515/191 - Inspection of Licensee's Responses to Order EA-12-049, EA-12-051 & Emergency

Preparedness (EP) Info Request March 12, 2012 (1 Sample)

(1) The inspectors verified plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (ADAMS Accession No. ML12056A045) and EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, (ADAMS Accession No. ML12054A679) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter (ADAMS Accession No. ML12053A340) and multi-unit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 (ADAMS Accession No. ML12339A262).

1. Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the Diverse and Flexible Coping Strategies (FLEX) as described in the plant specific submittals and the associated safety evaluation (ADAMS Accession No. ML18113A334) and determined that the licensee is in compliance with NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events. The inspectors verified the licensee satisfactorily:

a. Developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events b. Integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs were clear when using existing plant procedures c. Protected FLEX equipment from site-specific hazards d. Developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability e. Trained their staff to assure personnel proficiency in the mitigation of beyond-design basis events f. Developed the means to ensure the necessary off-site FLEX equipment would be available from off-site locations

2. Based on samples selected for review, the inspectors verified that the licensee

satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation (ADAMS Accession No. ML18113A334) and determined that the licensee is in compliance with NRC Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation. (ADAMS Accession No.

ML12054A679). The inspectors verified the licensee satisfactorily:

a. Installed the spent fuel pool (SFP) instrumentation sensors, cabling, and power supplies to provide physical and electrical separation as described in the plant specific submittals and safety evaluation b. Installed the SFP instrumentation display in the location, environmental conditions, and accessibility as described in the plant specific submittals c. Trained their staff to ensure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation d. Developed and issued procedures for maintenance, testing, and use of the reliable SFP instrumentation 3. The inspectors reviewed information provided in the licensees multi-unit dose submittal and in response to the NRCs March 12, 2012, request for information letter (ADAMS Accession No. ML12053A340),and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all AC power to all site units and impedes access to the site. The inspectors verified the following:

a. The licensee satisfactorily implemented required staffing changes to support a multi-unit extended loss of AC power (ELAP) scenario b. EP communications equipment and facilities are sufficient for dealing with a multi-unit ELAP scenario c. The licensee implemented multi-unit dose assessment capabilities (including releases from SFPs) using the licensees site-specific dose assessment software and approach The inspectors verified that non-compliances with requirements and standards identified during the inspection were entered into the licensee's corrective action program as appropriate.

This TI is considered closed.

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On June 13, 2019, the inspectors presented the TI 2515/191 inspection results to Mr. Matthew Bonanno, Director Site Operations and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

2515/191 Calculations LM-0710 Refueling Floor Air Space Transient Temperature Profile 0

following ELAP

Corrective Action 03990423, 03995403, 04111121, 04144866, 04178941,

Documents 04217474, 04224354, 04229319, 04233213

Corrective Action 04256267, 04256357, 04256547

Documents

Resulting from

Inspection

Drawings SK-C-378 Site Plan Flooding Control Areas 5

Engineering #13-00414 Westinghouse Spent Fuel Pool Instrumentation System 2

Changes (SFPIS) Documents

Engineering 617968 Determine Time to Boil for High Heat Load/Low Volume 0

Evaluations Periods

Miscellaneous LLOW1901FLEX Limerick Licensed Operator Requalification 0

PES-P-006 Diesel Fuel Oil 11

Purchase Order Diesel Fuel Oil 0

10564072

TI0191 BDBEE Mitigating Strategies (FLEX) Spent Fuel Pool Level June 10,

Instrument Staffing and EP Communications 2019

Procedures ARC-MCR-112 I5 Fuel Pool Storage Hi/Lo Level, 5

ARC-MCR-212 I5 Fuel Pool Storage Hi/Lo Level 3

CC-LG-118 Site Implementation of Diverse and Flexible Coping 7

Strategies (FLEX), Spent Fuel Pool Instrumentation and

Hardened Containment Vent (HCVS) Program

CC-LG-118-1002 Congested Area Flight Plan for Limerick Generating Station 2

CC-LG-118-1003 Limerick Generating Station Units 1 and 2 Final Integrated 0

Plan Document

E-1 Loss of all AC Power (Station Blackout) 55

E-10/20 Loss of Offsite Power 57

EP-AA-110-201 On-Shift Dose Assessment 6

EP-AA-112-400- Security Coordinator (EOF) Checklist H

F-10

Inspection Type Designation Description or Title Revision or

Procedure Date

EP-AA-124-F-03 FLEX Communications Equipment Testing and Inventorying C

of the Site and Site-Specific EOF Fixed and Portable Satellite

Systems

IC-11-00339 Calibration and Testing of Guided Wave Radar Spent Fuel 1

Pool Level Instruments

M-097-009 Limerick Generating Station Cask Pit Gate Removal, 24

Installation, Maintenance and Movement of Fuel Pool Gates

Between Storage/Repair Locations

MA-LG-716-026- Additional Guidance for In-Plant/Yard Storage and 22

1001 Housekeeping at Limerick

NF-LG-310-2000 Spent Nuclear Material and Core Component Movement 17

ON-125 Loss of Fuel Pool Cooling 16

OP-LG-102-102- Augmented Operator Field Rounds 10

1001

OP-LG-115-1004 Transfer of Fuel To/From the FLEX Building Storage Tank 1

(00-T527)

OU-LG-104 Shutdown Safety Management Program 16

PSTG-T-103-SCC Exelon Nuclear Limerick Generating Station Plant Specific 20

Technical Guideline Secondary Containment Control

S15.3A Inflation of Reactor Well, Fuel Pool Gate, Fuel Pool Stop Log 31

1. 15, Cask Handling Pit Gate and Steam Dryer and Separator

Stop Log Seals

S20.10.B Ordering and Accepting Delivery of Fuel Oil 31

S53.0A Normal Makeup/Response to Low Level in Fuel Storage Pool 28

or Reactor Well

T-300 Appendix 1 Godwin HL 130M Flex Pump Operation Hard Card 2

T-301 U1 RPV Injection from Spray Pond 5

T-301 U2 RPV Injection from Spray Pond 6

T-322 U1 SFP Makeup and Spray from Spray Pond 3

T-322 U2 SFP Makeup and Spray from Spray Pond 5

T-346 Refuel Floor Alignment for SFP Makeup Spray and 3

Ventilation

T-364 Communication Systems Alternate Power 1

T-365 SFP Level Instrumentation Backup Power 2

Inspection Type Designation Description or Title Revision or

Procedure Date

T-370 U1 Primary and Alternate Instrumentation During ELAP 2

T-370 U2 Primary and Alternate Instrumentation During ELAP 3

TSG-1.3 FLEX Event Resource Management Guidelines 1

Work Orders 04840087 FLEX Generator Fuel Oil Tank Heater Not Controlling 0

Properly

04920434 Perform Maintenance on Portable Diesel Pump 0

8