IR 05000352/2024010
| ML24075A095 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/18/2024 |
| From: | Jon Greives Division of Operating Reactors |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2024010 | |
| Download: ML24075A095 (1) | |
Text
March 18, 2024
SUBJECT:
LIMERICK GENERATING STATION, UNITS 1 AND 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000352/2024010 AND 05000353/2024010
Dear David Rhoades:
On February 16, 2024, 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 Michael Gillin, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations problem identification and resolution program to confirm that the station was complying with NRC regulations and licensee standards. Based on the samples reviewed, the team determined that your program complies with NRC regulations and applicable industry standards such that the Reactor Oversight Process can continue to be implemented.
The team also evaluated the stations effectiveness in identifying, prioritizing, evaluating, and correcting problems, reviewed licensee audits and self-assessments, and its use of industry and NRC operating experience information. The results of these evaluations are in the enclosure.
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 (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Jonathan E. Greives, Chief Projects Branch 4 Division of Operating Reactor Safety
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:
05000352/2024010 and 05000353/2024010
Enterprise Identifier: I-2024-010-0000
Licensee:
Constellation Energy Generation, LLC
Facility:
Limerick Generating Station, Units 1 and 2
Location:
Sanatoga, PA
Inspection Dates:
January 29, 2024 to February 16, 2024
Inspectors:
J. Ayala, Senior Reactor Inspector
L. Grimes, Resident Inspector
M. Hardgrove, Senior Project Engineer
M. Ordoyne, Physical Security Inspector
Approved By:
Jonathan E. Greives, Chief
Projects Branch 4
Division of Operating Reactor Safety
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, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of Unit 1 and Unit 2 residual heat removal systems. The corrective actions for the following non-cited violations (NCVs) and findings were evaluated as part of the assessment: NCV 05000352,05000353/2021004-01, NCV 05000352,05000353/2021004-02, FIN 05000352,05000353/2022011-01, NCV 05000352,05000353/2022004-01, FIN 05000352,05000353/2022004-02, FIN 05000352,05000353/2022004-03, NCV 05000352,05000353/2023002-01, and NCV 05000352/2023003-01.
- Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience,
- Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety conscious work environment.
INSPECTION RESULTS
Assessment 71152B Problem Identification and Resolution Program Effectiveness:
The inspectors determined that Constellation's problem identification and resolution program for Limerick was generally effective and adequately supported nuclear safety and security.
Identification: The team reviewed a sample of issues that have been processed through Constellation's problem identification and resolution program since the last biennial team inspection, including NCVs of regulatory requirements and other documented findings. The team determined that, in general, the station identified issues and entered them into the corrective action program at a low threshold and timely manner.
Prioritization and Evaluation: Based on the samples reviewed, the team determined Constellation was generally effective at prioritizing and evaluating issues commensurate with the safety significance of the identified problem. Inspectors observed that at station corrective action program meetings, issues were generally screened and prioritized at the appropriate level and that corrective actions were assigned to address the issues. However, the team noted that Constellation seems to be challenged with addressing lower-level issues in a timely manner and evaluation quality. Both observations are documented below.
Corrective Action: The team concluded that Constellation was generally effective in developing corrective actions that were appropriately focused to correct the identified problems.
Assessment 71152B Operating Experience:
The inspectors reviewed operating experience captured in the corrective action program and sampled operating experience from NRC, industry, vendors, and third-party groups. Overall, for the samples selected, the licensee was generally performing the appropriate assessments for station applicability.
Assessment 71152B Self-Assessment and Audits:
The inspectors determined that the licensee was adequately performing self-assessments and audits in accordance with licensee procedures and implementing corrective actions as needed.
Assessment 71152B Safety Conscious Work Environment:
The team interviewed a total of 20 individuals in one-on-one interviews. The purpose of these interviews was
- (1) to evaluate the willingness of the licensee staff to raise nuclear safety issues,
- (2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and
- (3) to evaluate the licensee's safety conscious work environment. The personnel interviewed were randomly selected by the inspectors from Engineering, Maintenance, Operations, Radiation Protection, Chemistry, Emergency Preparedness, and Security. To supplement these discussions, the team interviewed the Employee Concern Program (ECP) Coordinator to assess their perception of the site employees' willingness to raise nuclear safety concerns, and also reviewed the ECP case log and select case files.
All individuals interviewed indicated that they would raise safety concerns. Most 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 that they were adequately trained and proficient on initiating condition reports. Most interviewees were aware of the licensee's ECP, and all 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 culture issues were adequately implemented.
Observation: Lower-level issue resolution and parts availability challenges 71152B The station is adequately identifying issues at a low threshold and addressing the priority, risk significant items in a timely manner. However, the station seems to be challenged with addressing lower-level issues in a timely manner. Shorter refueling outages, as well as on-line risk management practices further challenges the ability to work through lower-level issues in a timely manner. During walkdowns, interviews, and general plant interactions, station staff expressed a perception that lower-level issues can go uncorrected for extended periods of time. Additionally, station staff expressed that challenges with procuring replacement parts are impacting the ability to resolve lower-level issues in a timely manner.
The unavailability of these parts ultimately leads to deferment of resolving those issues.
Examples of these issues include IR 04724308 for the Unit 2 217 elevation airlock door and longstanding building fan issues, deferring PMs, and recent IR 04705596 for the Unit 1 1B turbine supply fan thrown blades. These examples highlight lower-level issues that were entered into corrective action program, but challenges in procuring replacement parts and ultimate deferment of maintenance prolonged issue resolution.
Observation: Evaluation Quality 71152B The station, for the most part, adequately assesses and evaluates plant issues in their corrective action program products commensurate with the safety significance of the identified problem. However, the station at times as been challenged with quality related to work group evaluations. Examples include IR 04499745 for Unit 1 electrohydraulic control leak, IR 04472545 for Unit 2 reactor core isolation cooling trip reset latch issue, IR 4557807 for Unit 1 D11 diesel lube oil leak upstream of 092-1402A, and IR 04481385 for Unit 2 2G safety relief valve pilot indication and steam leak. Specifically, citing these examples, weaknesses in technical rigor in the evaluations and/or ineffective review for extent of condition can impact the stations ability to adequately trend equipment challenges and resolve issues.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On February 16, 2024, the inspectors presented the biennial problem identification and resolution inspection results to Michael Gillin, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
04486796
04489971
04489960
04490210
04490493
04490499
04490558
04492129
04493352
04493503
04493647
04494055
04494519
04494596
04494608
04494779
04494902
04494902
04495028
04495046
04496169
04496439
04496566
04496792
04496795
04498696
04499282
04499312
04499745
04500245
04501716
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
04504421
04504667
04504891
04504907
04505261
04505317
04506142
04507012
04507054
04507999
04508227
04508554
04510563
04510675
04510687
04511859
04513206
04516753
04520856
04523790
04525252
04526994
04527062
04527266
04530880
04531187
04534372
04537749
04537759
04538433
04544811
04547388
04554984
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
04557807
04559768
04559929
04560339
04563607
04564264
04564265
04666040
04670741
04674123
04675421
04675476
04676250
04676694
04677711
04678494
04678611
04679776
04680232
04680667
04687340
04689074
04689602
04697291
04697291
04697681
04697988
04698308
04698308
04700004
04700599
04700942
04701166
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
04701463
04701469
04701766
04702378
04703620
04704537
04712397
04714077
04715678
04996027
Engineering
Evaluations
04472545
04479540
04481385
04496027
04496439
04498218
04498218
04498696
04514473
04514625
04517181
04525252
04529011
04529359
04531742
04534372
04534372
04546089
045524972
04557807
04557807
04558075
04674834
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
04676542
04679480
04703688
047053450
Procedures
CONDUCT OF MAINTENANCE MANUAL
Revision 25
MAINTENANCE TECHNICAL SKILLS
Revision 5
FOREIGN MATERIAL EXCLUSION PROGRAM
Revision 17
WORK EXECUTION AND CLOSE OUT
Revision 28
POST MAINTENANCE TESTING
Revision 27
STATION REWORK REDUCTION PROGRAM
Revision 14
FIN TEAM PROCESS
Revision 14
PERFORMANCE IMPROVEMENT
PI MANAGEMENT REVIEW MEETINGS AND REPORTING
Revision 4
SAFETY CULTURE MONITORING
Revision 4
OPERATING EXPERIENCE PROGRAM
Revision 6
PROCESSING OF LEVEL 1 AND 2 OPEX EVALUATIONS
Revision 4
PROCESSING OF LEVEL 3 OPEX EVALUATIONS
Revision 7
ISSUE IDENTIFICATION AND SCREENING PROCESS
Revision 13
CORRECTIVE ACTION PROGRAM (CAP) PROCEDURE
Revision 8
CORRECTIVE ACTION PROGRAM EVALUATION MANUAL
Revision 7
PASSPORT ACTION TRACKING MANAGEMENT
PROCEDURE
Revision 4
NUCLEAR SAFETY CULTURE