IR 05000352/2014006

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ROP-15 Mid-Cycle Performance Review and Inspection Plan Report 05000352/2014006 and 05000353/2014006
ML14239A190
Person / Time
Site: Limerick  
Issue date: 09/02/2014
From: Fred Bower
Reactor Projects Region 1 Branch 4
To: Pacilio M
Exelon Generation Co, Exelon Nuclear
bower, fl
References
IR-2014-006
Download: ML14239A190 (5)


Text

September 2, 2014

SUBJECT:

MID-CYCLE ASSESSMENT LETTER FOR LIMERICK GENERATING STATION, UNITS 1 AND 2 (REPORT 05000352/2014006 AND 05000353/2014006)

Dear Mr. Pacilio:

On August 13, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed its mid-cycle performance review of Limerick Generating Station Units 1 and 2. The NRC reviewed the most recent quarterly performance indicators in addition to inspection results and enforcement actions from July 1, 2013 through June 30, 2014. This letter informs you of the NRCs assessment of your facility during this period and its plans for future inspections at your facility.

The NRC determined that overall, Limerick Generating Station (LGS) Units 1 and 2 was operated in a manner that preserved public health and safety and met all cornerstone objectives. The NRC also determined the performance at LGS Units 1 and 2 during the most recent quarter was within the Licensee Response Column of the NRCs Reactor Oversight Process Action Matrix because all inspection findings had very low (i.e., green) safety significance, and all performance indicators demonstrated that your performance was within the nominal, expected range (i.e, green). Therefore, the NRC plans to conduct Reactor Oversight Process baseline inspections at your facility.

Although plant performance was within the Licensee Response Column, the NRC has not yet finalized the significance of an apparent violation that has preliminarily been determined to have greater than very low security significance. Additional information on this apparent violation was documented in NRC inspection reports (IR) 05000352/2014403 and 05000353/2014403 (ML14211A077). We note that your staff chose to request a regulatory conference, as described in the above referenced IR, and the meeting will be held in the NRC Region I office on September 18, 2014. This meeting has been announced in Notice 2014-016, (ML14237A362). However, in the interest of protecting sensitive, security-related information, this regulatory conference will not be open for public observation. The final security significance determination may affect the NRCs assessment of plant performance, regulatory actions and oversight, and the enclosed inspection plan.

As a result of the Safety Culture Common Language Initiative, the terminology and coding of cross-cutting aspects were revised. All cross-cutting aspects identified during inspections conducted in calendar year 2014 reflect this revision to Inspection Manual Chapter (IMC) 0310.

Cross-cutting aspects identified in 2013 using the 2013 terminology were converted to the latest revision in accordance with the cross-reference in IMC 0310 during the mid-cycle assessment review and evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305. The enclosed inspection plan lists the inspections scheduled through December 31, 2015.

Routine inspections performed by resident inspectors are not included in the inspection plan.

The inspections listed during the last nine months of the inspection plan are tentative and may be revised at the end-of-cycle performance review. The NRC provides the inspection plan to allow for the resolution of any scheduling conflicts and personnel availability issues. The NRC will contact you as soon as possible to discuss changes to the inspection plan should circumstances warrant any changes. This inspection plan does not include security-related inspections, which will be sent via separate, non-publicly available correspondence.

In response to the accident at Fukushima, the Commission issued Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, which requires licensees to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities following a beyond-design-basis external event. Additionally, the Commission issued Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, which requires licensees to have a reliable means of remotely monitoring wide-range Spent Fuel Pool levels to support effective prioritization of event mitigation and recovery actions in the event of a beyond-design-basis external event. The NRC is conducting audits of licensee efforts towards compliance with these Orders. This audit includes an onsite component in order for the NRC to evaluate licensee plans for complying with the Orders, as described in site-specific submittals, and to receive and review information relative to associated open items. This onsite activity will occur in the months prior to a declaration of compliance for the first unit at each site, and will aid staff in development of an ultimate Safety Evaluation for the site. The date for the onsite component at your site has been coordinated with your staff and has been scheduled for the week of October 27, 2014. A site-specific audit plan for the visit will be provided in advance to allow sufficient time for preparations.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 2.390 of the NRCs Rules of Practice, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRC's Agencywide Documents Access and Management system (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Please contact me at (610) 337-5200 with any questions you have regarding this letter.

Sincerely,

/RA/

Fred L. Bower, III, Chief Division of Reactor Projects Project Branch 4

Docket Nos.: 50-352. 50-353 License Nos.: NPF-39, NPF-85

Enclosure: Limerick Generating Station Inspection/Activity Plan

cc w/encl: Distribution via ListServ

ML14239A190 SUNSI Review

Non-Sensitive

Sensitive

Publicly Available

Non-Publicly Available

OFFICE RI/DRP RI/DRP RI/DRS RI/DRP

NAME EDiPaolo/GSB for SBarber/ GSB ADimitriadis/ JRC for FBower/ FLB

DATE 08/22 /14 08/22 /14 08/25 /14 09/02/14 Distribution w/encl:

W. Dean, RA D. Lew, DRA H. Nieh, DRP M. Scott, DRP J. Trapp, DRS P. Krohn, DRS F. Bower, DRP S. Barber, DRP A. Turilin, DRP B. Lin, DRP E. DiPaolo, DRP, SRI R. Montgomery, DRP, RI N. Esch, DRP, AA A. Bowers, RI, OEDO DRS Branch Chiefs (6)

N. McNamara, RI, SLO D. Tifft, RI. SLO D. Screnci, RI, PAO N. Sheehan, RI, PAO RidsNrrPMLimerick Res RidsNrrDorlLpl1-2 Res ROPReports Res RidsNrrDirslpab Res ROPassessment Res

Page 1 of 3 08/27/2014 15:30:24 Report 22 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Limerick Inspection / Activity Plan 07/01/2014 - 12/31/2015 7111111B

- LSRO REQ INSP WITH P/F RESULTS

1, 2 IP Licensed Operator Requalification Program 7111111B 06/02/2014 12/31/2014 INSP

- RADIATION PROTECTION

1, 2 IP Radiological Hazard Assessment and Exposure Controls 71124.01 07/07/2014 07/11/2014 1, 2 IP Occupational ALARA Planning and Controls 71124.02 07/07/2014 07/11/2014 1, 2 IP In-Plant Airborne Radioactivity Control and Mitigation 71124.03 07/07/2014 07/11/2014 1, 2 IP Occupational Dose Assessment 71124.04 07/07/2014 07/11/2014 1, 2 IP Radiation Monitoring Instrumentation 71124.05 07/07/2014 07/11/2014 71152B

- PI&R BIENNIAL

1, 2 IP Problem Identification and Resolution 71152B 09/15/2014 09/20/2014 1, 2 IP Problem Identification and Resolution 71152B 09/29/2014 10/03/2014 10/6EXAM

- INITIAL OL EXAM

1 FY15-LIMERICK INITIAL OPERATOR LICENSING EXAM U01892 12/15/2014 12/19/2014

FY15-LIMERICK INITIAL OPERATOR LICENSING EXAM U01892 01/12/2015 01/21/2015 INSP

- RADIATION PROTECTION

1, 2 IP Radiological Hazard Assessment and Exposure Controls 71124.01 09/08/2014 09/12/2014 1, 2 IP Occupational ALARA Planning and Controls 71124.02 09/08/2014 09/12/2014 1, 2 IP In-Plant Airborne Radioactivity Control and Mitigation 71124.03 09/08/2014 09/12/2014 1, 2 IP Occupational Dose Assessment 71124.04 09/08/2014 09/12/2014 1, 2 IP Radiation Monitoring Instrumentation 71124.05 09/08/2014 09/12/2014 1, 2 IP Performance Indicator Verification 71151 09/08/2014 09/12/2014 7111107T

- TRIENNIAL HEAT SINK

1, 2 IP Heat Sink Performance 7111107T 09/29/2014 10/03/2014 MODS

- PERMANENT PLANT MODIFICATIONS

1, 2 IP Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications 7111117T 11/03/2014 11/07/2014 1, 2 IP Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications 7111117T 11/17/2014 11/21/2014 EP PROG

- EP PROGRAM INSPECTION

1, 2 IP Alert and Notification System Testing 7111402 12/01/2014 12/05/2014 1, 2 IP Emergency Preparedness Organization Staffing and Augmentation System 7111403 12/01/2014 12/05/2014 1, 2 IP Correction of Emergency Preparedness Weaknesses and Deficiencies 7111405 12/01/2014 12/05/2014 71124

- RADIATION PROTECTION

1, 2 IP Radiological Hazard Assessment and Exposure Controls 71124.01 03/16/2015 03/20/2015 1, 2 IP Occupational ALARA Planning and Controls 71124.02 03/16/2015 03/20/2015 This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Page 2 of 3 08/27/2014 15:30:24 Report 22 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Limerick Inspection / Activity Plan 07/01/2014 - 12/31/2015 71124

- RADIATION PROTECTION

1, 2 IP In-Plant Airborne Radioactivity Control and Mitigation 71124.03 03/16/2015 03/20/2015 1, 2 IP Occupational Dose Assessment 71124.04 03/16/2015 03/20/2015 1, 2 IP Radiation Monitoring Instrumentation 71124.05 03/16/2015 03/20/2015 7111108G

- U2 INSERVICE INSPECTION

2 IP Inservice Inspection Activities - BWR 7111108G 04/13/2015 04/17/2015 71124

- RADIATION PROTECTION

1, 2 IP Radiological Hazard Assessment and Exposure Controls 71124.01 04/13/2015 04/17/2015 1, 2 IP Occupational ALARA Planning and Controls 71124.02 04/13/2015 04/17/2015 1, 2 IP In-Plant Airborne Radioactivity Control and Mitigation 71124.03 04/13/2015 04/17/2015 1, 2 IP Occupational Dose Assessment 71124.04 04/13/2015 04/17/2015 1, 2 IP Radiation Monitoring Instrumentation 71124.05 04/13/2015 04/17/2015 ISFSI

- ISFSI LOADING INSPECTION

1, 2 IP Operation Of An ISFSI 60855 06/01/2015 08/31/2015 1, 2 IP Operation of an Independent Spent Fuel Storage Installation at Operating Plants 60855.1 06/01/2015 08/31/2015 CDBI

- COMPONENT DESIGN BASIS INSPECTION

1, 2 IP Component Design Bases Inspection 7111121 06/08/2015 06/12/2015 1, 2 IP Component Design Bases Inspection 7111121 06/22/2015 06/26/2015 1, 2 IP Component Design Bases Inspection 7111121 07/06/2015 07/10/2015 71124

- REMP

1, 2 IP Radiological Environmental Monitoring Program 71124.07 07/13/2015 07/17/2015 12/7EXAM

- INITIAL OL EXAM

1 FY16 - LIMERICK INITIAL OPERATOR LICENSING EXAM U01912 12/07/2015 12/11/2015 71124

- RADIATION PROTECTION

1, 2 IP Radiological Hazard Assessment and Exposure Controls 71124.01 09/04/2015 09/08/2015 1, 2 IP Occupational ALARA Planning and Controls 71124.02 09/04/2015 09/08/2015 1, 2 IP In-Plant Airborne Radioactivity Control and Mitigation 71124.03 09/04/2015 09/08/2015 1, 2 IP Occupational Dose Assessment 71124.04 09/04/2015 09/08/2015 1, 2 IP Radiation Monitoring Instrumentation 71124.05 09/04/2015 09/08/2015 1, 2 IP Performance Indicator Verification 71151 09/04/2015 09/08/2015 7111111B

- REQUAL INSP W/ P/F RESULTS

1, 2 IP Licensed Operator Requalification Program 7111111B 11/16/2015 11/20/2015 This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Page 3 of 3 08/27/2014 15:30:24 Report 22 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Limerick Inspection / Activity Plan 07/01/2014 - 12/31/2015 EP

- EP EXERCISE

1, 2 IP Exercise Evaluation 7111401 11/16/2015 11/20/2015 1, 2 IP Exercise Evaluation - Scenario Review 7111408 11/16/2015 11/20/2015 This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.