IR 05000352/2020012
| ML20210M087 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/28/2020 |
| From: | Jon Greives Reactor Projects Region 1 Branch 4 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| Greives J | |
| References | |
| IR 2020012 | |
| Download: ML20210M087 (13) | |
Text
July 28, 2020
SUBJECT:
LIMERICK GENERATING STATION, UNITS 1 AND 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000352/2020012 AND 05000353/2020012
Dear Mr. Hanson:
On June 26, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Limerick Generating Station, Units 1 and 2 and discussed the results of this inspection with Matthew Arnao, Organizational Performance and Regulatory Director, 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.
No findings or violations of more than minor significance were identified during this inspection. 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, X /RA/
Signed by: Jonathan E. Greives
Jonathan E. Greives, Chief Reactor Projects Branch 4 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:
05000352/2020012 and 05000353/2020012
Enterprise Identifier: I-2020-012-0003
Licensee:
Exelon Generation Company, LLC
Facility:
Limerick Generating Station, Units 1 and 2
Location:
Sanatoga, PA 19464
Inspection Dates:
June 8, 2020 to June 26, 2020
Inspectors:
L. Casey, Senior Project Engineer
L. Cline, Senior Project Engineer
J. DeBoer, Reactor Inspector
S. Haney, Resident Inspector
Approved By:
Jonathan E. Greives, Chief
Reactor Projects Branch 4
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution 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 (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, conducted plant walkdowns, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards. Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), regional inspectors were directed to begin telework. The inspection documented below was determined that the objectives and requirements stated in the IP could be completed remotely.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees problem identification and resolution performance in the following areas:
- Corrective Action Program Effectiveness in problem identification, prioritization, evaluation, and corrective action, which also included a review of corrective actions for issues identified in the Unit 1 and Unit 2 fire water systems, and the Unit 1 and Unit 2 residual heat removal and emergency service water systems in the last five years
- Use of Operating Experience
- Completed Self-Assessments and Audits
- Health of the Safety Conscious Work Environment.
INSPECTION RESULTS
Assessment 71152B Corrective Action Program Effectiveness
Problem Identification: The inspectors determined that, in general, the licensee identified issues and entered them into the corrective action program at a low threshold.
Problem Prioritization and Evaluation: Based on the samples reviewed, the inspectors determined that, in general, the licensee appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. The licensee appropriately screened issue reports (IRs) for operability and reportability, categorized IRs by significance, and assigned actions to the appropriate department for evaluation and resolution.
Corrective Actions: The inspectors determined that the overall corrective action program performance related to resolving problems was effective. In most cases, the licensee implemented corrective actions to resolve problems in a timely manner.
However, the inspectors identified one minor performance deficiency regarding the licensee's inadequate trending and corrective action for a corroded baseplate identified in the spray pond pump house in 2017. The details of the minor performance deficiency are documented in the applicable section below.
Assessment 71152B Use of Operating Experience
The team determined that the licensee appropriately evaluated industry operating experience for its relevance to the facility. The licensee appropriately incorporated both internal and external operating experience into plant procedures and processes, as well as lessons learned for training and pre-job briefs.
Self-Assessments and Audits
The team reviewed a sample of self-assessments and audits to assess whether the licensee was identifying and addressing performance trends. The team concluded that the licensee had an effective self-assessment and audit process.
Assessment 71152B Safety Conscious Work Environment
The team interviewed a total of 25 individuals. The purpose of these interviews was to evaluate the willingness of the licensee staff to raise nuclear safety issues; to evaluate the perceived effectiveness of the corrective action program at resolving identified problems; and to evaluate the licensee's safety-conscious work environment. The personnel interviewed were randomly selected by the inspectors from the Operations, Engineering, Maintenance, Security, and Radiation Protection work groups. To supplement these discussions, the team interviewed the Employee Concerns Program (ECP) representative to assess his perception of the site employees' willingness to raise nuclear safety concerns. The team also reviewed the ECP case log and select case files.
All individual interviewed indicated that they would raise safety concerns. All individuals felt that their management was receptive to receiving safety concerns and generally addressed them promptly, commensurate with the significance of the concern. Most interviewees indicated they were adequately trained and proficient on initiating condition reports. All interviewees were aware of the licensee's ECP, stated they would use the program if necessary, and expressed confidence that their confidentiality would be maintained if they brought issues to the ECP. When asked whether there have been any instances where individuals experienced retaliation or other negative reaction for raising safety concerns, all individuals interviewed stated that they had neither experienced nor heard of an instance of retaliation at the site. The team determined that the processes in place to mitigate potential safety conscious work environment issues were adequately implemented.
Minor Performance Deficiency 71152B Minor Performance Deficiency: The team identified one minor performance deficiency due to the licensee's inadequate trending and corrective actions for a degraded residual heat removal service water pipe support base plate. During performance of Exelon surveillance procedure, ST-1-012-901-0, Spray Pond Structural Inspection, on November 22, 2017, the licensee identified a degraded pipe support baseplate, HBC-507-H162, and initiated IR 04077339 to document the identified condition. The IR stated that if the baseplate was not fixed in the near future, it could corrode to the point where the pipe support would be unable to perform its design function and that the identified condition required engineering to monitor and assess the degradation until repairs could be completed. The inspectors determined that IR 04077339 was then closed to work request 01373448, as allowed by the corrective action program procedures and that, as of the date of this inspection, no work order to complete repairs was created and no repairs were completed. The inspectors also determined that ST-1-012-901-0 was completed again on February 27, 2019, but the results of the inspection did not identify any observations or discussion of the corrosion previously identified on HBC-507-H162. The inspectors concluded that this was contrary to the procedure requirements and was a performance deficiency because: Step 4.4 required the performer to obtain a copy of the results of the last inspection and pay particular attention to areas where evidence of damage had been identified; Step 4.5 required that a written description and photograph of any damage noted during the inspection be included in the completed inspection results; and that Step 4.6 required that changes in degraded conditions from prior inspections, such as extent of corrosion, be trended until it was evident that corrosion was no longer occurring, or until corrective actions were completed.
Screening: The inspectors determined the performance deficiency was minor. Using NRC Inspection Manual Chapter 0612, Appendices B and E, the inspectors determined the performance deficiency was minor because, although the condition of the baseplate was not documented in the February 2019 inspection and had not been corrected, based on licensee inspections of the baseplate completed on June 26, 2020, the baseplate conditions were similar to what was identified in 2017 and it remained functional. The licensee documented this minor performance deficiency in IR
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On June 26, 2020, the inspectors presented the biennial problem identification and resolution inspection results to Matthew Arnao, Organizational Performance and Regulatory Director, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CAPE 04201280
D23 Lube Oil Keepwarm Failure
2/27/2019
CAPE 04212649
D24 Emergency Diesel Generator Lube Oil leak at pressure
sensing line
04/29/2019
CAPE 04224095
Inaccurate System Availability Assessments
05/22/2019
CAPE 04246432
Open Manway on Water box Causing Flooding during 2R15
06/08/2019
CAPE 04335499
1N SRV Main Seat Leak
05/20/2020
ECAPE
04193290-08
0A-P548 ESW Pump SPPH Roof Plug Lifting Eyebolt Failure
01/07/2019
ECAPE
202624
Limerick U1 Fuel Cladding Defect Identified by Routine
Chemistry Offgas Sampling
2/08/2019
Issue Reports
(IRs)
01510494 02453874 02522420 02542205 02576904
2585422 02650502 02673386 02686844 02704781
2735374 03944364 03944871 03982133 04035159
04061086 04077339 04081882 04082181 04106334
04112004 04127674 04163928 04193458 04193541
04194270 04194843 04196295 04199902 04201128
201812 04205949 04208628 04209746 04212993
217125 04218660 04220123 04226368 04226462
227982 04235661 04242429 04251477 04257856
257953 04258142 04263306 04264194 04265494
265645 04266423 04266929 04270530 04270530
274846 04275140 04280018 04281729 04283856
284354 04286381 04294685 04294907 04296755
04303755 04313201 04313899 04313985 04316600
04321933 04323304 04323304 04334999 04335036
04337850 04340911 04346095 04346159 04346343
RCR 04254212
Limerick Unit 2 Manual SCRAM Due to Loss of Main
Condenser Vacuum
07/23/2019
RCR 04266201-
Emergent Shutdown of D24 Emergency Diesel Generator
due to lube oil leak from threaded connection
10/04/2019
Corrective Action
Documents
Issue Reports
(IRs)
04349514 04349515 04349516 04349518 04349918
04350684 04350858 04352290 04352529 04353840
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Resulting from
Inspection
Engineering
Evaluations
214904-18
Operating
Experience
Evaluation
ICES 447825 Diesel Generator Exhaust Fire
214904-35
Operating
Experience
Evaluation
ICES 450628 Emergency Diesel Generator Jacket Water
Leak
214904-43
Operating
Experience
Evaluation
ICES 453406 "C" High Pressure Injection Pump failed to start
during scheduled pump rotation due to bent stop pin supply
breaker
214904-46
Operating
Experience
Evaluation
ICES 453781 Instrument Air Compressor Tripped on High
Intercooler Pressure
214904-47
Operating
Experience
Evaluation
ICES 454955 Standby Temporary Diesel Powered Air
Compressor Automatic Shutdown during scheduled
Surveillance
214904-57
Operating
Experience
Evaluation
ICES 460066 Control Room Refrigeration Unit Tripped on
Low Suction Pressure & ICES 457968 Loss of Control Room
Emergency Air Temperature Control System
214904-58
Operating
Experience
Evaluation
ICES 461533 Instrument Air Compressor Trip
214904-76
Operating
Experience
Evaluation
IRIS 464859 Buried Pipe Leak Results in Isolation of a fire
protection header
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
214904-91
Operating
Experience
Evaluation
IRIS 471628 Service Air Compressor Tripped
Miscellaneous
Safety Culture Analysis - 2019 - Limerick
09/20/2019
Nuclear Safety Culture Meeting - 11/18/2019 - Limerick
Generating Station
03/16/2020
Health Group Report (Engage Health) Limerick -
20/92/81(EDG - Diesel Generator/Fuel Oil/EDG HVAC)
05/27/2020
Limerick Generating Station Nuclear Safety Review Board
Meeting - February 19 and 20, 2019
03/14/2019
Limerick Generating Station Nuclear Safety Review Board
Meeting - February 19 and 20, 2020
03/03/2020
Health Group Report (Engage Health) Limerick -
49/55/56(HPI - High Pressure Injection)
05/27/2020
Health Group Report (Engage Health) Limerick - 76/77/78
(SVT - SR Ventilation)
05/27/2020
Health Group Report (Engage Health) Limerick - 11/12
(SRW-ESW/RHRSW)
05/27/2020
Procedures
Nuclear Risk Management Process
Employee Concerns Program
Revision 11
Employee Concerns Program Process
Revision 15
Foreign Material Exclusion Program
Revision 14
Quality Assurance Topical Report (QATR)
Nuclear Oversight Regulatory Audit Procedure
Revision 10
Nuclear Oversight Audit Handbook
Nuclear Oversight Audit Templates
Safety Culture Monitoring
Revision 3
Operating Experience Program
Revision 5
Processing of Level 3 OPEX Evaluations
Issue Identification and Screening Process
Revision 10
Corrective Action Program Procedure
Revision 7
Root Cause Analysis Manual
Revision 5
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action Program Evaluation Manual
Revision 5
Investigation Techniques Manual
Revision 4
Self-Assessments
Revision 3
Self-Assessments 04098308
Preparation for NRC Problem Identification and Resolution
(PI&R) Inspection
08/17/2018
219354
Operator Fundamentals
11/22/2019
219982
Pre-NRC Inspection Self-Assessment: Access Control,
Equipment Performance, Testing/Maintenance, Training, &
Performance Indicator Verification
05/16/2019
219984
Dewatering of Manholes
08/23/2019
231645
Lab Safety/Hygiene
2/31/2019
248960-09
Biennial Safety Culture Self Assessment
01/29/2020
283555
Access Authorization and Fitness for Duty
2/13/2019
04308207
Preparation for NRC Problem Identification & Resolution
(PI&R) Inspection
06/08/2020
NOSA-LIM-19-04
(04223372)
Corrective Action Program Audit Report - Limerick
Generating Station - March 25 to April 5, 2019
04/10/2019
NOSA-LIM-19-05
(04250402)
Engineering Design Control Audit Report
08/07/2019
NOSA-LIM-19-06
(04254186)
Radiation Protection Audit Report
07/10/2019
NOSA-LIM-19-08
(04270127)
Operations Functional Area Audit Report
09/18/2019
NOSA-LIM-20-01
(04307853)
Maintenance Functional Area Audit Report
03/11/2020
NOSA-LIM-20-02
(04307787)
Security Programs Audit Report
2/12/2020
NOSA-LIM-20-03
(04323231)
Emergency Preparedness Audit Report
04/29/2020
NOSA-LIM-20-04
(04323264)
Chemistry, Radwaste, Effluent and Environmental Monitoring
Audit Report
05/07/2020
Work Orders
04318924-01
Completed ST-6-012-401-0 - A Loop RHRSW Pump Auto
Actuation Test
05/30/2018
04320498-01
Completed ST-6-012-402-0 - B Loop RHRSW Pump Auto
08/11/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Actuation Test
04590782-01
Completed - ST-6-012-233-0, A Loop RHRSW Pump
Comprehensive Test
01/17/2019
04600953-01
Completed ST-6-012-234-0 - B Loop RHRSW Pump
Comprehensive Test
2/18/2019
04984481-01
Completed ST-6-012-231-0 - A Loop RHRSW Pump, Valve
and Flow Test
2/27/2020
05011722-01
Completed ST-6-012-232-0 - B Loop RHRSW Pump, Valve
and Flow Test
05/20/2020
05031022-01
Completed ST-6-012-452-0 - B Loop RHRSW Lineup
Verification
05/18/2020
Action Requests
(ARs)
04170638 04175446 04320716 04606586 04609591
04619162 04629455 04637808 04661001 04729716
04739174 04766729 04780167 04818460 04840936
04844659 04857990 04861321 04874159 04886457
04939362 04939776 04945574 04973815 04987103
04993021