IR 05000352/2014403

IR 05000352/2014403, 05000353/2014403; 6/16/2014 to 6/20/2014; Limerick Generating Station, Units 1 and 2; Access Control, Protective Strategy and Performance Evaluation Program Letter Only

ML14211A077
Person / Time
Site:	Limerick
Issue date:	07/29/2014
From:	James Trapp Division of Reactor Safety I
To:	Pacilio M Exelon Generation Co, Exelon Nuclear
References
EA-14-0111 IR-14-403
Download: ML14211A077 (6)

Text

uly 29, 2014

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 - NRC SECURITY INSPECTION REPORT 05000352/2014403 AND 05000353/2014403 AND PRELIMINARY GREATER THAN GREEN FINDING

Dear Mr. Pacillo:

On June 20, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed a security inspection at your Limerick Generating Station, Units 1 and 2. The NRC inspectors discussed the results of this inspection with Mr. Thomas Dougherty, Site Vice President and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

The attached report documents one or more findings that have preliminarily been determined to have greater than very low security significance that may require additional inspections, regulatory actions, and oversight. Each finding was assessed based on the best available information, using the Physical Protection Significance Determination Process (SDP). The deficiencies were promptly corrected or compensated for, and the plant was in compliance with applicable physical protection and security requirements within the scope of this inspection before the team arrived onsite. The NRC will inform you in writing when the final significance has been determined.

The finding is also an apparent violation of NRC requirements and is being considered for escalated enforcement action in accordance with the Enforcement Policy, which appears on the NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html.

We intend to complete and issue our final safety significance determination within 90 days from the date of this letter. The NRCs SDP is designed to encourage an open dialogue between your staff and the NRC; however, the dialogue should not affect the timeliness of our final determination.

Enclosure contains Sensitive Unclassified Non-Safeguards Information. When separated from enclosure, the transmittal document is decontrolled. M. Pacilio 2 Before the NRC makes a final decision, we are providing you an opportunity to provide your perspective on this matter, including the significance, causes, and corrective actions, as well as any additional information that you believe the NRC should take into consideration.

Accordingly, you may notify us of your decision within 10 days to: (1) request a regulatory conference to meet with the NRC and provide your views in person; (2) submit your position on the finding in writing; or (3) accept the finding as characterized in the enclosed inspection report.

If you choose to request a regulatory conference, the meeting should be held in the NRC Region I office within 30 days of the date of this letter. We encourage you to submit supporting documentation at least one week prior to the conference in an effort to make the conference more efficient and effective. In the interest of protecting sensitive, security-related information, if a regulatory conference is held, it will not be open for public observation. If you decide to submit only a written response, such submittal should be sent to the NRC within 30 days of your receipt of this letter.

If you elect to accept the finding as characterized in this letter and the inspection report, the NRC will proceed with its regulatory decision. However, if you choose not to request a regulatory conference or submit a written response, you will not be allowed to appeal the NRCs final significance determination.

Please contact Anthony Dimitriadis at (610) 337-6953, and in writing, within 10 days from the issue date of this letter to notify the NRC of your intentions. If we have not heard from you within 10 days, we will continue with our significance determination and enforcement decision.

Because the NRC has not made a final determination in this matter, no notice of violation is being issued for this inspection finding at this time. In addition, please be advised that the number and characterization of the apparent violation may change based on further NRC review.

Additionally, NRC inspectors documented one NRC identified finding of very low safety significance (Green) in this report. The deficiency was promptly corrected or compensated for, and the plant was in compliance with applicable physical protection and security requirements within the scope of this inspection before the inspectors left the area.

Further, inspectors documented a licensee-identified violation which was determined to be of very low safety significance. The NRC is treating this violation as a non-cited violation (NCV)

consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Limerick Generating Station, Units 1 and 2. M. Pacilio 3 Two cross-cutting aspects were assigned to the findings in the area of Human Performance.

Specifically, because Exelon failed to use a consistent, systematic approach to make decisions (H-13), and failed to use decision making-practices that emphasize prudent choices over those that are simply allowable (H-14). If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I; and the NRC Resident Inspectors at the Limerick Generating Station, Units 1 and 2.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) 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).

However, the material enclosed herewith contains Security-Related Information in accordance with 10 CFR 2.390(d)(1) and its disclosure to unauthorized individuals could present a security vulnerability. Therefore, the material in the enclosure will not be made available electronically for public inspection in the NRC Public Document Room or from the PARS component of NRC's ADAMS. If you choose to provide a response and Security-Related Information is necessary to provide an acceptable response, please mark your entire response Security-Related Information-Withhold from public disclosure under 10 CFR 2.390 in accordance with 10 CFR 2.390(d)(1) and follow the instructions for withholding in 10 CFR 2.390(b)(1). In accordance with 10 CFR 2.390(b)(1)(ii), the NRC is waiving the affidavit requirements for your response.

Sincerely,

/RA/

James M. Trapp, Acting Director Division of Reactor Safety M. Pacilio 3 Two cross-cutting aspects were assigned to the findings in the area of Human Performance.

Specifically, because Exelon failed to use a consistent, systematic approach to make decisions (H-13), and failed to use decision making-practices that emphasize prudent choices over those that are simply allowable (H-14). If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I; and the NRC Resident Inspectors at the Limerick Generating Station, Units 1 and 2.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) 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).

However, the material enclosed herewith contains Security-Related Information in accordance with 10 CFR 2.390(d)(1) and its disclosure to unauthorized individuals could present a security vulnerability. Therefore, the material in the enclosure will not be made available electronically for public inspection in the NRC Public Document Room or from the PARS component of NRC's ADAMS. If you choose to provide a response and Security-Related Information is necessary to provide an acceptable response, please mark your entire response Security-Related Information-Withhold from public disclosure under 10 CFR 2.390 in accordance with 10 CFR 2.390(d)(1) and follow the instructions for withholding in 10 CFR 2.390(b)(1). In accordance with 10 CFR 2.390(b)(1)(ii), the NRC is waiving the affidavit requirements for your response.

Sincerely,

/RA/

James M. Trapp, Acting Director Division of Reactor Safety Distribution: See Next Page Non-Public Designation Category: MD 3.4 Non-Public A.3 DOCUMENT NAME: G:\DRS\Plant Support Branch 1\Security\2014 IR Draft\Limerick\Limerick 2014403 Rev 3.docx ADAMS ACCESSION NO.: ML14211A077 (Cover letter)

ADAMS ACCESSION NO.: ML14211A090 (Cover letter w/encl)

Cover Letter X Non-Sensitive X Publicly Available X SUNSI Review Sensitive Non-Publicly Available Cover Letter w/Enclosure Non-Sensitive Publicly Available X SUNSI Review X Sensitive X Non-Publicly Available OFFICE RI/DRS RI/DRS RI/DRP RI/DRS RIV/DRS NAME JBream/JC JCherubini FBower/SB WSchmidt JRollins/via email DATE 7/10/14 7/10/14 7/22/14 7/23/14 7/10/14 OFFICE NSIR/SPEB RI/DRS RI/ORA RI/DRS RI/DRS NAME TBarry via email ADimitriadis BBickett/NW PKrohn JTrapp DATE 7/10/14 7/24/14 7/21/14 7/29/14 7/29/14 OFFICIAL RECORD COPY M. Pacilio 4 Docket Nos. 50-352, 50-353 License Nos. NPF-39, NPF-85 Enclosure:

Inspection Report 05000352/2014403, 05000353/2014403 w/Attachment: Supplemental Information (OUO-SRI)

cc w/o encl; w/o OUO-SRI: Distribution via ListServ cc w/encl; w/OUO-SRI:

K. Kemper, Manager, Site Security D. Allard, Director, PA DEP M. Pacilio 4 Distribution w/o encl; w/o OUO-SRI:

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 G. DiPaolo, DRP, SRI R. Montgomery, DRP, RI N. Esch, DRP, AA A. Bowers, RI OEDO RidsNrrPMLimerick Resource RidsNrrDorlLpl1-2 Resource ROPreports Resource Distribution w/encl; w/OUO-SRI:

A. Dimitriadis, DRS J. Cherubini, DRS N. Simonian, NSIR E. Wharton, NSIR C. Johnson, NSIR F. Bower, DRP G. DiPaolo, SRI B. Desai, DRS, RII R. Skokowski, DRS, RIII M. Haire, DRS, RIV