IR 05000352/2019010
| 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
July 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:
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
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
Procedure
Type
Designation
Description or Title
Revision or
Date
2515/191
Calculations
LM-0710
Refueling Floor Air Space Transient Temperature Profile
following ELAP
Corrective Action
Documents
03990423, 03995403, 04111121, 04144866, 04178941,
217474, 04224354, 04229319, 04233213
Corrective Action
Documents
Resulting from
Inspection
256267, 04256357, 04256547
Drawings
Site Plan Flooding Control Areas
Engineering
Changes
- 13-00414
Westinghouse Spent Fuel Pool Instrumentation System
(SFPIS) Documents
Engineering
Evaluations
617968
Determine Time to Boil for High Heat Load/Low Volume
Periods
Miscellaneous
LLOW1901FLEX
Limerick Licensed Operator Requalification
PES-P-006
Diesel Fuel Oil
Purchase Order
10564072
Diesel Fuel Oil
TI0191
BDBEE Mitigating Strategies (FLEX) Spent Fuel Pool Level
Instrument Staffing and EP Communications
June 10,
2019
Procedures
ARC-MCR-112 I5
Fuel Pool Storage Hi/Lo Level,
ARC-MCR-212 I5
Fuel Pool Storage Hi/Lo Level
CC-LG-118
Site Implementation of Diverse and Flexible Coping
Strategies (FLEX), Spent Fuel Pool Instrumentation and
Hardened Containment Vent (HCVS) Program
CC-LG-118-1002
Congested Area Flight Plan for Limerick Generating Station
CC-LG-118-1003
Limerick Generating Station Units 1 and 2 Final Integrated
Plan Document
E-1
Loss of all AC Power (Station Blackout)
E-10/20
On-Shift Dose Assessment
EP-AA-112-400-
F-10
Security Coordinator (EOF) Checklist
H
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
EP-AA-124-F-03
FLEX Communications Equipment Testing and Inventorying
of the Site and Site-Specific EOF Fixed and Portable Satellite
Systems
C
IC-11-00339
Calibration and Testing of Guided Wave Radar Spent Fuel
Pool Level Instruments
M-097-009
Limerick Generating Station Cask Pit Gate Removal,
Installation, Maintenance and Movement of Fuel Pool Gates
Between Storage/Repair Locations
MA-LG-716-026-
1001
Additional Guidance for In-Plant/Yard Storage and
Housekeeping at Limerick
NF-LG-310-2000
Spent Nuclear Material and Core Component Movement
ON-125
Loss of Fuel Pool Cooling
OP-LG-102-102-
1001
Augmented Operator Field Rounds
OP-LG-115-1004
Transfer of Fuel To/From the FLEX Building Storage Tank
(00-T527)
OU-LG-104
Shutdown Safety Management Program
PSTG-T-103-SCC Exelon Nuclear Limerick Generating Station Plant Specific
Technical Guideline Secondary Containment Control
S15.3A
Inflation of Reactor Well, Fuel Pool Gate, Fuel Pool Stop Log
- 15, Cask Handling Pit Gate and Steam Dryer and Separator
Stop Log Seals
S20.10.B
Ordering and Accepting Delivery of Fuel Oil
S53.0A
Normal Makeup/Response to Low Level in Fuel Storage Pool
or Reactor Well
T-300 Appendix 1
Godwin HL 130M Flex Pump Operation Hard Card
T-301 U1
RPV Injection from Spray Pond
T-301 U2
RPV Injection from Spray Pond
T-322 U1
SFP Makeup and Spray from Spray Pond
T-322 U2
SFP Makeup and Spray from Spray Pond
T-346
Refuel Floor Alignment for SFP Makeup Spray and
Ventilation
T-364
Communication Systems Alternate Power
T-365
SFP Level Instrumentation Backup Power
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
T-370 U1
Primary and Alternate Instrumentation During ELAP
T-370 U2
Primary and Alternate Instrumentation During ELAP
FLEX Event Resource Management Guidelines
Work Orders
04840087
FLEX Generator Fuel Oil Tank Heater Not Controlling
Properly
04920434
Perform Maintenance on Portable Diesel Pump
0