ML11024A045
| ML11024A045 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/24/2011 |
| From: | Paul Krohn Reactor Projects Region 1 Branch 4 |
| To: | Pacilio M Exelon Generation Co |
| Krohn P | |
| References | |
| IR-10-005 | |
| Download: ML11024A045 (32) | |
See also: IR 05000352/2010005
Text
January 24, 2011
Mr. Michael J. Pacilio
Senior Vice President, Exelon Generation Company, LLC
President and Chief Nuclear Officer, Exelon Nuclear
4300 Winfield Rd.
Warrenville, IL 60555
SUBJECT:
LIMERICK GENERATING STATION - NRC INTEGRATED
INSPECTION REPORT 05000352/2010005 AND 05000353/2010005
Dear Mr. Pacilio:
On December 31, 2010, the U. S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Limerick Generating Station Units 1 and 2. The enclosed integrated
inspection report documents the inspection results which were discussed on January 7, 2011,
with Mr. W. Maguire and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel based on the results of the inspection, no findings were identified.
In accordance with 10 Code of Federal Regulations (CFR) Part 2.390 of the NRC's "Rules of
Practice," a copy of this letter, its enclosure, and your response (if any) will be available
electronically for public inspection in the NRC Public Document Room or from the Publicly
Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is
accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public
Electronic Reading Room).
Sincerely,
/RA/
Paul G. Krohn, Chief
Projects Branch 4
Division of Reactor Projects
Docket Nos: 50-352, 50-353
Enclosure:
Inspection Report 05000352/2010005 and 05000353/2010005
w/Attachment: Supplemental Information
cc w/encl:
Distribution via ListServ
M. Pacilio
2
Mr. Michael J. Pacilio
Senior Vice President, Exelon Generation Company, LLC
President and Chief Nuclear Officer, Exelon Nuclear
4300 Winfield Rd.
Warrenville, IL 60555
SUBJECT:
LIMERICK GENERATING STATION - NRC INTEGRATED
INSPECTION REPORT 05000352/2010005 AND 05000353/2010005
Dear Mr. Pacilio:
On December 31, 2010, the U. S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Limerick Generating Station Units 1 and 2. The enclosed integrated
inspection report documents the inspection results which were discussed on January 7, 2011,
with Mr. W. Maguire and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel based on the results of the inspection, no findings were identified.
In accordance with 10 CFR Part 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any) will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of the
NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Paul G. Krohn, Chief
Projects Branch 4
Division of Reactor Projects
Distribution w/encl:(via e-mail)
W. Dean, RA
D. Lew, DRA
J. Clifford, DRP
G. Dentel, DRP
D. Roberts, DRS
P. Wilson, DRS
P. Krohn, DRP
A. Rosebrook, DRP
E. Torres, DRP
S. Ibarrola, DRP
N. Sieller, DRP, RI
J. Trapp, RI, OEDO
RidsNrrPMLimerick Resource
RidsNrrDorlLpl1-2Resource
ROPreportsResource@nrc.gov
SUNSI Review Complete: _PGK___ (Reviewers Initials)
DOC NAME: G:\\DRP\\BRANCH4\\INSPECTION REPORTS\\LIMERICK\\2010\\LIM 2010 4TH QTR\\
LIM 2010-005 REV 1.DOCX
After declaring this document AAn Official Agency Record@ it will be released to the Public.
To receive a copy of this document, indicate in box"C" = Copy w/out attachment/enclosure "E" = Copy w/attachment/enclosure "N" = No copy
OFFICE mmt
RI/DRP
RI/DRP
RI/DRP
NAME
EDiPaolo/PGK for
ARosebrook/AAR
PKrohn/PGK
DATE
01/ 24 /11
01/ 24 /11
01/ 24 /11
OFFICIAL RECORD COPY
1
Enclosure
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket Nos:
50-352, 50-353
License Nos:
Report No:
05000352/2010005 and 05000353/2010005
Licensee:
Exelon Generation Company, LLC
Facility:
Limerick Generating Station, Units 1 & 2
Location:
Sanatoga, PA 19464
Dates:
October 1, 2010 through December 31, 2010
Inspectors:
E. DiPaolo, Senior Resident Inspector
N. Sieller, Resident Inspector
J. Hawkins, Acting Resident Inspector
A. Rosebrook, Senior Project Engineer
T. Moslak, Health Physicist
J.Caruso, Senior Operations Engineer (Section 1R11.2)
J. DAntonio, Senior Operations Engineer (Section 1R11.2)
J. Tomlinson, Operations Engineer (Section 1R11.2)
C. Crisden, Emergency Preparedness Specialist
Approved by:
Paul G. Krohn, Chief
Projects Branch 4
Division of Reactor Projects
2
Enclosure
TABLE OF CONTENTS
SUMMARY OF FINDINGS ......................................................................................................... 3
REPORT DETAILS ..................................................................................................................... 4
1.
REACTOR SAFETY ............................................................................................................ 4
1R01 System Seasonal Adverse Weather Protection ...................................................... 4
1R04
Equipment Alignment ............................................................................................. 5
1R05
Fire Protection ........................................................................................................ 5
1R06
Flood Protection Measures .................................................................................... 6
1R11
Licensed Operator Requalification Program ........................................................... 6
1R12 Maintenance Effectiveness ................................................................................... 8
1R13
Maintenance Risk Assessments and Emergent Work Control ............................... 8
1R15
Operability Evaluations .......................................................................................... 9
1R19
Post-Maintenance Testing ..................................................................................... 9
1R22
Surveillance Testing ............................................................................................ 10
1EP2
Alert and Notification System (ANS) Evaluation ................................................... 11
1EP3
Emergency Response Organization (ERO) Staffing and Augmentation System 11
1EP4
Emergency Action Level (EAL) and Emergency Plan Changes ........................... 11
1EP5
Correction of Emergency Preparedness Weaknesses ......................................... 12
2.
RADIATION SAFETY ........................................................................................................ 12
2RS01 Radiological Hazard Assessment and Exposure Controls .................................... 12
4.
OTHER ACTIVITIES ......................................................................................................... 13
4OA1
Performance Indicator (PI) Verification ................................................................. 13
4OA2
Identification and Resolution of Problems ............................................................. 15
4OA3
Event Follow-up ................................................................................................... 17
4OA5
Other Activities ..................................................................................................... 18
4OA6
Meetings, Including Exit ........................................................................................ 19
ATTACHMENT: SUPPLEMENTAL INFORMATION ................................................................ 19
SUPPLEMENTAL INFORMATION ......................................................................................... A-1
KEY POINTS OF CONTACT .................................................................................................. A-1
LIST OF ITEMS OPENED OR CLOSED ................................................................................ A-2
LIST OF DOCUMENTS REVIEWED ...................................................................................... A-2
LIST OF ACRONYMS .......................................................................................................... A-10
3
Enclosure
SUMMARY OF FINDINGS
IR 05000352/2010005; 05000353/2010005; 10/01/2010-12/31/2010; Limerick Generating
Station, Units 1 and 2; routine integrated report.
The report covered a three-month period of inspection by resident inspectors, a senior project
engineer, a health physicist, an emergency preparedness specialist, and an announced
inspection by operations engineers. The NRCs program for overseeing the safe operation of
commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight,"
Revision 4, dated December 2006.
No findings were identified.
4
Enclosure
REPORT DETAILS
Summary of Plant Status
Unit 1 began the inspection period operating at full rated thermal power (RTP). On
December 4, operators reduced power to approximately 94 percent to facilitate main turbine
valve testing, control rod scram time testing, a control rod pattern adjustment, and to perform
secondary plant maintenance. Power was restored to full RTP on December 5. Unit 1
remained at full RTP for the remainder of the inspection period.
Unit 2 began the inspection period operating at full RTP. On October 23, power was reduced
(unplanned) to approximately 50 percent as a result of the trip of the A recirculation pump
motor-generator set. Following troubleshooting and repairs to the generator voltage regulator,
power was further reduced on October 24 to approximately 33 percent to facilitate the restart of
the A recirculation pump. Power was restored to full RTP on October 25. On October 30,
operators reduced power to 85 percent to facilitate a follow up control rod pattern adjustment.
Power was restored to full RTP on October 31. A power reduction to 85 percent was performed
on November 20 to facilitate a control rod pattern adjustment. Full power was restored on
November 21. On December 3, power was reduced (unplanned) to approximately 58 percent
as a result of the trip of the A recirculation pump motor-generator set. Operators reduced
power to approximately 35 percent to facilitate the restart of the A recirculation pump following
troubleshooting and repairs to the recirculation pump motor-generator set generator voltage
regulator. Full RTP was restored on December 6. On December 18, operators reduced power
to approximately 80 percent to facilitate main turbine valve testing, fuel channel distortion
testing, and a control rod pattern adjustment. The unit was restored to full RTP on
December 19. Unit 2 remained at full RTP for the remainder of the inspection period.
1.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems and Barrier Integrity
1R01 System Seasonal Adverse Weather Protection (71111.01 - 1 seasonal sample)
a. Inspection Scope
The inspectors assessed the effectiveness of the licensees cold weather protection
program as it related to ensuring that equipment in the facilitys spray pond pump house
would remain functional and available in cold weather conditions. This equipment
includes the emergency service water (ESW) pumps, residual heat removal (RHR)
service water pumps, motor-operated valves associated with the spray pond, and
support electrical equipment. In addition to reviewing the licensees program-related
documents and procedures, walkdowns were conducted of the freeze protection
equipment (e.g., ventilation system dampers, building heating system, etc.) associated
with the above systems/components. The inspectors observed plant conditions and
evaluated those conditions against criteria documented in procedure GP-7, Cold
Weather Preparation and Operation. Licensee problem identification and resolution
associated with cold weather protection was also assessed. Documents reviewed are
listed in the Attachment.
5
Enclosure
b. Findings
No findings were identified.
1R04 Equipment Alignment
Partial Walkdown (71111.04Q - 3 samples)
a. Inspection Scope
The inspectors performed partial walkdowns of the plant systems listed below to verify
operability following realignment after a system outage window or while safety-related
equipment in the opposite train was inoperable, undergoing surveillance testing (ST), or
potentially degraded. The inspectors used Technical Specifications (TS), Exelon
operating procedures, plant piping and instrumentation diagrams (P&ID), and the
Updated Final Safety Analysis Report (UFSAR) as guidance for conducting partial
system walkdowns. The inspectors reviewed the alignment of system valves and
electrical breakers to ensure proper in-service or standby configurations as described in
plant procedures and drawings. During the walkdowns, the inspectors evaluated the
material condition and general housekeeping of the systems and adjacent spaces. The
documents reviewed are listed in the Attachment. The inspectors performed walkdowns
of the following areas:
Emergency diesel generator (EDG) D23 on October 21, 2010;
A control room emergency fresh air supply system following return-to-service on
November 3, 2010; and
Unit 2 high pressure coolant injection (HPCI) system when the B loop of emergency
service water was out-of-service (OOS) on December 2, 2010.
b. Findings
No findings were identified.
1R05 Fire Protection
Fire Protection - Tours (71111.05Q - 4 samples)
a. Inspection Scope
The inspectors conducted a tour of the four areas listed below to assess the material
condition and operational status of fire protection features. The inspectors verified that
combustible materials and ignition sources were controlled in accordance with Exelons
procedures. Fire detection and suppression equipment was verified to be available for
use, and passive fire barriers were verified to be maintained in good material condition.
The inspectors also verified that station personnel implemented compensatory measures
for OOS, degraded, or inoperable fire protection equipment in accordance with the
stations fire plan. The documents reviewed are listed in the Attachment. The
inspectors toured the following areas:
Spray Pond Pumphouse, Western Half (Fire Area 122);
Spray Pond Pumphouse, Eastern Half (Fire Area 123);
6
Enclosure
Control Room and Peripheral Rooms (Fire Area 24); and
Remote Shutdown Room (Fire Area 26).
b. Findings
No findings were identified.
1R06 Flood Protection Measures (71111.06 - 1 internal flooding sample)
a. Inspection Scope
The inspectors reviewed the UFSAR and related flood analysis documents to identify
areas that can be affected by internal flooding, to identify features designed to alert
operators of a flooding event, and to identify features designed for coping with internal
flooding. The inspectors performed a walkdown of the Main Control Room Chiller
Rooms (Reactor Enclosure, Elevation 200) and adjacent areas. The inspectors
observed flood protection features to assess their ability to minimize the impact of a
flooding event. The inspectors performed a review of operator actions contained in
off-normal procedures for flooding to verify that the actions can reasonably be used to
achieve the desired outcome. The documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1
Resident Inspector Quarterly Review (71111.11Q - 1 sample)
a. Inspection Scope
On November 9, 2010, the inspectors observed two annual licensed operator simulator
examinations (LSES-2004). The simulator scenarios tested the operators ability to
respond to operating equipment failures, reactivity transients, loss of drywell cooling, and
loss of coolant leaks in the drywell. The inspectors observed licensed operator
performance including operator critical tasks, which are required to ensure the safe
operation of the reactor and protection of the nuclear fuel and primary containment
barriers. The inspectors also assessed crew dynamics and supervisory oversight to
verify the ability of operators to properly identify and implement appropriate TS actions,
regulatory reports, emergency event declarations, and notifications. The inspectors
observed training instructor critiques and assessed whether appropriate feedback was
provided to the licensed operators. The documents reviewed are listed in the
Attachment.
b. Findings
No findings were identified.
.2
Biennial Requalification Program Review (71111.11B - 1 sample)
a. Inspection Scope
7
Enclosure
The following inspection activities were performed using NUREG 1021, Revision 9,
Supplement 1, Operator Licensing Examination Standards for Power Reactors,
Inspection Procedure Attachment 7111111, Licensed Operator Requalification
Program, Appendix A, Checklist for Evaluating Facility Testing Material, and
Appendix B, Suggested Interview Topics.
A review was conducted of recent operating history documentation found in inspection
reports, licensee event reports, the licensees corrective action program, and the most
recent, NRC plant issues matrix. The inspectors also reviewed specific events from the
licensees corrective action program which indicated possible training deficiencies to
verify that they had been appropriately addressed. The senior resident inspector was
also consulted for insights regarding licensed operators performance. These reviews did
not detect any operational events that were indicative of possible training deficiencies.
For the 2010 examination cycle, the biennial written examinations (i.e., administered in
2009) and annual operating tests administered for weeks three, four, and five were
reviewed for content, quality, and excessive overlap to ensure that these exams met the
criteria established in the Examination Standards and 10 CFR 55.59.
On December 10, 2010, the results of the annual operating tests for 2010 were reviewed
to determine if pass/fail rates were consistent with the guidance of NUREG-1021,
Revision 9, Supplement 1, Operator Licensing Examination Standards for Power
Reactors, and NRC Manual Chapter 0609, Appendix I, Operator Requalification
Human Performance Significance Determination Process, were also performed. The
review verified the following:
Crew pass rates were greater than 80 percent (Pass rate was 100 percent);
Individual pass rates on the written examination were greater than 80 percent (N/A -
Biennial written examination was not administered this year);
Individual pass rates on the job performance measures of the operating exam were
greater than 80 percent (Pass rate was 98 percent); and
More than 75 percent of the individuals passed all portions of the operating
examination (Pass rate was 98 percent).
Observations were made of the dynamic simulator examinations and job performance
measures (JPMs) administered during the week of November 15, 2010, for Operations
and Staff Crew C. These observations included facility evaluations of crew and
individual performance during the dynamic simulator examinations and individual
performance of JPMs.
The remediation plans for 22 out-of-the-box scenarios were reviewed to assess the
effectiveness of the remedial training. Two reactivations were reviewed to ensure that
10 CFR 55.53 license conditions and applicable program requirements were met.
Instructors and training/operation=s management were interviewed for feedback on their
training program.
A sample of ten operator medical examinations were also reviewed for compliance with
license conditions, including NRC regulations.
8
Enclosure
Simulator performance and fidelity were reviewed for conformance to the reference plant
control room. Selected simulator deficiency reports were reviewed to assess licensee
prioritization and timeliness of resolution. Simulator testing records were reviewed to
verify that scheduled tests were performed.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness (71111.12Q - 1 sample)
a. Inspection Scope
The inspectors evaluated Exelons work practices and follow-up corrective actions for
one issue within the scope of the maintenance rule. The inspectors reviewed the
performance history of these structures, systems, and components (SSCs) and
assessed the effectiveness of Exelons corrective actions, including any extent-of-
condition determinations to address potential common cause or generic implications.
The inspectors assessed Exelons problem identification and resolution actions for these
issues to evaluate whether Exelon had appropriately monitored, evaluated, and
dispositioned the issues in accordance with Exelon procedures and the requirements of
10 CFR Part 50.65, Requirements for Monitoring the Effectiveness of Maintenance. In
addition, the inspectors reviewed the maintenance rule classifications, performance
criteria, and goals for these SSCs and evaluated whether they appeared reasonable and
appropriate. The documents reviewed are listed in the Attachment. The inspectors
reviewed the following issue:
Issue Report (IR) 1137553 ESW pinhole leak repair - ESW loop B return piping
from Unit 2 RHR pump compartment unit cooler.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 6 samples)
a. Inspection Scope
The inspectors evaluated the effectiveness of Exelons maintenance risk assessments
required by 10 CFR Part 50.65(a)(4). This inspection included discussion with control
room operators and risk analysis personnel regarding the use of Exelons on-line risk
monitoring software. The inspectors reviewed equipment tracking documentation, daily
work schedules, and performed plant tours to gain assurance that the actual plant
configuration matched the assessed configuration. Additionally, the inspectors verified
that Exelons risk management actions, for both planned and emergent work, were
consistent with those described in Exelon procedure, ER-AA-600-1042, On-Line Risk
Management. The documents reviewed are listed in the Attachment. The inspectors
reviewed the following samples:
Units 1 and 2 on-line risk profile during the EDG D12 load reject test with the 20
offsite power source unavailable on October 6, 2010;
9
Enclosure
Unit 2 on-line risk profile while in single recirculation loop operations following A
motor generator (MG) trip October 22 - October 24, 2010;
Unit 1 on-line risk and compensatory measures during fire header partial outage
November 5 - November 8, 2010;
Units 1 and 2 on-line risk profile when the B control enclosure chiller was
discovered to be unavailable due to insufficient ESW flow on November 13, 2010;
Units 1 and 2 on-line risk profile when the 222 Plant Services bus was de-energized
November 24 - 25 due to a supply feeder cable fault; and
Unit 2 risk profile while in single recirculation loop operations following A MG trip
December 3, 2010 - December 5, 2010.
b. Findings
No findings were identified.
1R15 Operability Evaluations (71111.15 - 7 samples)
a. Inspection Scope
The inspectors assessed the technical adequacy of a sample of seven operability
evaluations to ensure that Exelon properly justified TS operability and verified that the
subject component or system remained available such that no unrecognized increase in
risk occurred. The inspectors reviewed the UFSAR to verify that the system or
component remained available to perform its intended safety function. In addition, the
inspectors reviewed compensatory measures implemented to ensure that the measures
worked and were adequately controlled. The inspectors also reviewed a sample of IRs
to verify that Exelon identified and corrected deficiencies associated with operability
evaluations. The documents reviewed are listed in the Attachment. The inspectors
reviewed the following evaluations:
IR 1120701, Radiation monitor failed check source functional test;
IR 1132289, Degraded wire connection on Unit 1 drywell floor drain sump level
monitor;
IR 1137553, ESW pinhole leak on B loop return piping from Unit 2 RHR pump
compartment unit cooler (OPE-10-008, Revision 08);
IR 1143600, ESW B loop flow balance issues;
IR 1143434, Unit 1 scram discharge volume (SDV) valve exceeded maximum
allowed stroke time;
IR 1151354, Unit 1 HPCI turbine mechanical overspeed will not reset; and
IR 1153065, EDG D14 fuel oil supply pressure fluxuations during operations.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing (71111.19 - 8 samples)
a. Inspection Scope
10
Enclosure
The inspectors reviewed eight post-maintenance tests to verify that procedures and test
activities ensured system operability and functional capability. The inspectors reviewed
Exelons test procedures to verify that the procedures adequately tested the safety
functions that may have been affected by the maintenance activity, and that the
acceptance criteria in the procedures were consistent with information in the licensing
and design basis documents. The inspectors also witnessed the test or reviewed test
data to verify that the results adequately demonstrated restoration of the affected safety
functions. The documents reviewed are listed in the Attachment. The inspectors
reviewed the following samples:
R1152057, Repair Unit 1 Division IV steam leak detection;
C0235528, Unit 2 A MG set voltage regulator dynamic testing after card
replacements;
C0235261, Troubleshoot and rework Technical Support Center emergency
ventilation system outside air damper;
C0231042, ESW B loop flow balance;
C0236019, Unit 2 A recirculation pump MG repair;
A1786977, Loss of power to Unit 2 outboard main steam isolation valve logic;
C0235392, Replace Unit 2 Division III emergency core cooling system inverter; and
C0236065, Adjust pressure regulator to Unit 1 SDV piping vent primary containment
isolation valve (XV-047-1F011).
b. Findings
No findings were identified.
1R22 Surveillance Testing (71111.22 - 7 samples; 5 routine surveillances, 1 in-service testing
(IST) and 1 reactor coolant system leakage)
a. Inspection Scope
The inspectors either witnessed the performance of, or reviewed test data, for seven
STs associated with risk-significant SSCs. The reviews verified that Exelon personnel
followed TS requirements and that acceptance criteria were appropriate. The inspectors
also verified that the station established proper test conditions, as specified in the
procedures, that no equipment preconditioning activities occurred, and that acceptance
criteria were met. The documents reviewed are listed in the Attachment. The inspectors
reviewed the following samples:
ST-6-052-760, Safeguard Piping Fill Quarterly Valve Test;
ST-6-060-460-1, Primary Containment Isolation Capability Check;
ST-6-092-323-1, D13 DG Loss of Coolant Accident Load Reject Testing and Fast
Start Operability Test Run;
ST-6-082-365-0, Inoperable Unit 1 Safeguard Power Supply Actions for Both Units;
ST-6-049-230-1, Reactor Core Isolation Cooling Pump, Valve & Flow IST;
ST-6-047-200-1, SDV Exercise Test; and
ST-6-107-596-2, Drywell Floor Drain Sump/ Equipment Drain Tank Surveillance Log/
OPCON 1, 2, 3 (reactor coolant system leakage).
11
Enclosure
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness (EP)
1EP2 Alert and Notification System (ANS) Evaluation (71114.02 - 1 sample)
a. Inspection Scope
An onsite review was conducted to assess the maintenance and testing of the current
Limerick ANS. The inspectors reviewed ANS procedures and the updated Limerick ANS
design report to ensure Exelons compliance with design report commitments for system
maintenance and testing. A sample of IRs pertaining to the ANS was reviewed for
causes, trends, and corrective actions. The inspectors observed the conduct of the
Limerick monthly siren test. During the inspection, the inspectors also interviewed the
Mid-Atlantic EP Manager in regards to the new ANS which is planned for approval in
April 2011. The inspection was conducted in accordance with NRC Inspection
Procedure 71114, Attachment 2. Planning Standard, 10 CFR 50.47(b)(5) and the
related requirements of 10 CFR 50, Appendix E, were used as reference criteria.
b. Findings
No findings were identified.
1EP3 Emergency Response Organization (ERO) Staffing and Augmentation System
(71114.03 - 1 sample)
a. Inspection Scope
The inspectors conducted a review of Limericks ERO augmentation staffing
requirements and the process for notifying and augmenting the ERO was conducted.
This was performed to ensure the readiness of key licensee staff to respond to an
emergency event and to ensure Exelons ability to activate their emergency facilities in a
timely manner. The inspectors reviewed the Limerick and corporate ERO rosters,
station and corporate augmentation reports since March 2009, and CRs related to the
ERO staffing augmentation system. The inspectors also reviewed a sampling of ERO
responders training records to ensure training and qualifications were up to date. The
inspection was conducted in accordance with NRC Inspection Procedure 71114,
Attachment 3. Planning Standard, 10 CFR 50.47(b)(2) and related requirements of
10 CFR 50, Appendix E, were used as reference criteria.
b. Findings
No findings were identified.
1EP4 Emergency Action Level (EAL) and Emergency Plan Changes (71114.04 - 1 sample)
a. Inspection Scope
12
Enclosure
Since the last NRC inspection of this program area, Exelon implemented various
changes to their Emergency Plan and implementing procedures. Exelon had
determined that, in accordance with 10 CFR 50.54(q), any change made to the Plan,
and its lower-tier implementing procedures, had not resulted in any decrease in
effectiveness of the Plan, and that the revised Plan continued to meet the standards in
50.47(b) and the requirements of 10 CFR 50, Appendix E. The inspectors reviewed all
Emergency Action Level changes, including changes to the security EALs as endorsed
by NEI 99-02, Revision 5. A sample of emergency plan changes including the changes
to lower-tier emergency plan implementing procedures, were evaluated for any potential
decreases in effectiveness of the Emergency Plan. However, this review by the
inspectors was not documented in an NRC Safety Evaluation Report and does not
constitute formal NRC approval of the changes. Therefore, these changes remain
subject to future NRC inspection in their entirety. The inspection was conducted in
accordance with NRC Inspection Procedure 71114, Attachment 4. The requirements in
10 CFR 50.54(q) were used as reference criteria.
b. Findings
No findings were identified.
1EP5 Correction of Emergency Preparedness Weaknesses (71114.05 - 1 sample)
a. Inspection Scope
The inspectors reviewed a sampling of self-assessment procedures and reports to
assess Exelons ability to evaluate their EP performance and programs. The inspectors
reviewed a sampling of CRs from March 2009 through December 2010, initiated by
Exelon at Limerick from drills and audits. Additionally, the inspectors reviewed 10 CFR
50.54(t) audits from 2009 and 2010; and self-assessment reports. This inspection was
conducted in accordance with NRC Inspection Procedure 71114, Attachment 5,
Planning Standard, 10 CFR 50.47(b)(14), and the related requirements of 10 CFR 50,
Appendix E, were used as reference criteria.
b. Findings
No findings were identified.
2.
RADIATION SAFETY
Cornerstones: Occupational and Public Radiation Safety
2RS01 Radiological Hazard Assessment and Exposure Controls (71124.01 - 1 sample)
a. Inspection Scope
During the period December 13 - 17, 2010, the inspectors conducted the following
activities to verify that the licensee was evaluating, monitoring, and controlling
radiological hazards for work performed in locked high radiation areas, including the
Independent Spent Fuel Storage Installation (ISFSI), and other radiological controlled
areas, and workers were adhering to these controls when working in these areas.
13
Enclosure
Implementation of these controls was reviewed against the criteria contained in 10 CFR
20, TSs, and Exelons procedures. The documents reviewed listed in the Attachment.
Radiological Hazards Assessment
The inspectors reviewed recent revisions to radiation protection procedures regarding
various radiation protection processes, including radiological postings, and
contamination monitoring. The inspectors determined that the new revisions did not
reduce the scope or effectiveness of previously established radiological controls.
Radiological Hazards Control and Work Coverage
The inspectors toured accessible radiological controlled areas in Units 1 & 2, including
the ISFSI, turbine buildings, and reactor buildings to confirm the accuracy of survey data
and the adequacy of postings and radiation work permits (RWP). The inspectors
reviewed survey maps for areas toured to determine the timeliness of survey data and
the adequacy of RWP controls.
Contamination and Radioactive Material Control
The inspectors observed workers surveying and releasing potentially contaminated
materials for unrestricted use. The inspectors verified that the counting instrumentation
was located in a low background area and that the instruments sensitivity was
appropriate for the type of contamination being measured.
Problem Identification and Resolution
Relevant IRs, associated with radiological controls, and electronic dosimeter dose/dose
rate alarm reports initiated between March through November 2010, were reviewed by
the inspectors. The inspectors discussed the IRs with licensee staff to determine if the
follow up activities were being conducted in an effective and timely manner,
commensurate with their safety significance.
b. Findings
No findings were identified.
4.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
.1
Barrier Integrity and Mitigating Systems Cornerstone PIs (71151 - 6 samples)
a. Inspection Scope
The inspectors sampled Exelons submittal of the Barrier Integrity cornerstone and
Mitigating Systems cornerstone PIs listed below to verify the accuracy of the data
recorded from October 2009 though September 2010. The inspectors utilized
performance indicator definitions and guidance contained in Nuclear Energy Institute
(NEI) 99-02, Regulatory Assessment Performance Indicator Guidelines, Revision 6,
to verify the basis in reporting for each data element. The inspectors reviewed various
14
Enclosure
documents, including portions of the main control room logs, issue reports, power history
curves, work orders, and system derivation reports. The inspectors also discussed the
method for compiling and reporting performance indicators with cognizant engineering
personnel and compared graphical representations from the most recent PI report to the
raw data to verify that the report correctly reflected the data. The documents reviewed
are listed in the Attachment.
Cornerstone: Barrier Integrity
Units 1 and 2 Reactor Coolant System Leak Rate (BI02); and
Units 1 and 2 Reactor Coolant System Activity (BI01).
Cornerstone: Mitigating Systems
Units 1 and 2 Mitigating System Performance Index, Cooling Water Systems (MS10).
b. Findings
No findings of significance were identified.
.2
Occupational Exposure Control Effectiveness PI (71151 - 1 sample)
a. Inspection Scope
The inspectors reviewed implementation of the licensees Occupational Exposure
Control Effectiveness PI Program (OR01). Specifically, the inspectors reviewed
electronic dosimetry alarm reports, IRs, and associated documents, for occurrences
involving locked high radiation areas, very high radiation areas, and unplanned
exposures against the criteria specified in NEI 99-02, Regulatory Assessment
Performance Indicator Guideline, Revision 6, to verify that all occurrences that met the
NEI criteria were identified and reported as performance indicators.
b. Findings
No findings were identified.
.3
RETS/ODCM Radiological Effluent Occurrences PI (71151 - 1 sample)
a. Inspection Scope
The inspectors reviewed relevant effluent release issue reports for the period October
2009 through November, 2010, for issues related to the public radiation safety
performance indicator, which measures radiological effluent release occurrences that
exceed 1.5 mrem/qtr whole body or 5.0 mrem/qtr organ dose for liquid effluents;
5mrads/qtr gamma air dose, 10 mrad/qtr beta air dose, and 7.5 mrads/qtr for organ dose
for gaseous effluents. The inspectors reviewed the following documents to ensure the
licensee met all requirements of the performance indicator (PR01):
Monthly projected dose assessment results due to radioactive liquid and gaseous
effluent releases;
15
Enclosure
Quarterly projected dose assessment results due to radioactive liquid and gaseous
effluent releases; and
Dose assessment procedures.
b. Findings
No findings were identified.
.4
Emergency Preparedness Cornerstone PIs (71151- 3 samples)
a. Inspection Scope
The inspectors reviewed data for Limericks EP PIs, which are: (1) Drill and Exercise
Performance (DEP) (EP01); (2) ERO Drill Participation (EP02); and, (3) ANS Reliability
(EP03). The inspectors reviewed the PI data and its supporting documentation from the
fourth quarter of 2009 through the third quarter of 2010 to verify the accuracy of the
reported data. The review of these PIs was conducted in accordance with NRC
Inspection Procedure 71151, using the acceptance criteria documented in NEI 99-02,
Regulatory Assessment Performance Indicator Guidelines, Revision 6.
b. Findings
No findings were identified.
4OA2 Identification and Resolution of Problems
.1
Review of Items Entered into the Corrective Action Program (CAP)
a. Inspection Scope
As required by Inspection Procedure 71152, Identification and Resolution of Problems,
and in order to help identify repetitive equipment failures or specific human performance
issues for follow-up, the inspectors screened all items entered into Limericks CAP. The
inspectors accomplished this by reviewing each new condition report, attending
management review committee meetings, and accessing Exelons computerized
database.
b. Findings
No findings were identified.
.2
Semi-Annual Review to Identify Trends (71152 - 1 trend sample)
a. Inspection Scope
The inspectors performed a semi-annual review of site issues, to identify trends that
might indicate the existence of more safety significant safety issues, as required by
Inspection Procedure 71152, Identification and Resolution of Problems. The
inspectors included in this review, repetitive or closely-related issues that may have
been documented by Exelon outside of the corrective action program, such as Plant
Health Committee reports including the Top Ten Equipment Issues List, the Plant Health
16
Enclosure
Committee Issues List, the Open Action Items List, and the Performance Improvement
Integration Matrix. The inspectors also reviewed Exelons corrective action database for
the third and fourth quarters of 2010, to assess IRs written in various subject areas (e.g.,
equipment problems, human performance issues, etc.), as well as individual issues
identified during the NRCs daily IR review (Section 4OA2.1).
b. Findings and Observations
No findings were identified. The inspectors assessed that Exelon was identifying issues
at a low threshold and entering the issues into the CAP for resolution.
Notwithstanding, the inspectors noted a recent negative trend concerning the health of
non-safety-related underground 13kV power supply cables. Within a 7-month period,
Limerick experienced three non-safety related cable failures. In two of the three cases,
the cables had previously been identified by Exelon as requiring repair or replacement
due to degraded insulation that was discovered during testing. Specifically:
On April 2, 2010, the 122 Plant Services Transformer supply cable faulted shortly
after being placed in service following maintenance (IR 1051496). Part of the
maintenance had been to repair a known, degraded section of cable insulation.
However, the fault occurred in a section of cable that had not been repaired, despite
being previously identified as degraded. At the time, Unit 1 was in a refueling outage
and therefore the effect on the plant was minimal.
On June 23, 2010, operators inserted a manual scram on Unit 1 as a result of the
loss of both recirculation pumps (IR 1083732). The initiator for the transient was the
fault of an underground portion of the 13kV power supply cable to the 144D
Technical Support Center Transformer. This, coupled with other non-related
equipment failures, resulted in the loss of the operating stator cooling water pump
and the tripping of the recirculation motor-generator sets. For more detail see FIN 05000352/2010004-02, Failure to Identify Incorrectly Adjusted Control Power Relay
Resulting in Unit 1 Manual Scram. This cable had not been tested, but had been
identified as requiring testing in the future.
On November 24, 2010, the 222 Plant Services Transformer supply cable faulted,
causing the loss of two of the three Unit 2 service water pumps (IR 1144472). This
cable was known to have degraded insulation resistance but had not been repaired.
Due to the ambient temperatures at the time of the loss (i.e. service water
temperatures were cool), Unit 2 was able to maintain full power operations using the
remaining service water pump.
The inspectors reviewed the extent of power supply cable insulation degradation at
Limerick. The inspectors noted that there were two other 13kV power supply cables that
testing had identified as degraded and requiring action in the near term. These cables
were associated with the Unit 1 A circulating water pump and the Unit 1 C circulating
water pump. Because of the recent failures, Exelon identified the need to expedite
replacement of known degraded cables and testing of the remaining cables. As a result,
a high impact team was established to coordinate cable replacements and other
corrective actions. At the close of the inspection period, cable replacements were
planned to commence in January 2011. In addition, Exelon planned to coordinate with
an industry research group to help determine the causes of cable failures and failure
mechanisms. The inspectors concluded that Exelon had identified this trend and
Exelons actions taken or planned to address the trend appeared to be comprehensive.
17
Enclosure
The inspectors determined this trend was not applicable to safety-related cables
because test results for the safety-related 4kV underground cables indicated they had
acceptable insulation resistance. This was primarily due to more favorable operating
conditions (e.g., lower operating voltage and intermittent operation of the load).
.3
Annual Sample: Underground Cable Vault Water Intrusion (71152 - 1 Annual sample)
a. Inspection Scope
The inspectors reviewed Limericks actions under IR 1056715, which was initiated to
track Exelon fleet-wide actions to improve long-term health of medium and low voltage
power cables routed in underground structures. The inspectors reviewed the corrective
actions taken or planned to assure the timeliness was commensurate with the potential
safety significance. The inspectors also interviewed plant personnel regarding the
identified issues and implemented corrective actions. Specific documents reviewed are
listed in the Attachment.
b. Findings and Observations
No findings were identified.
IR 1003826 was initiated by Limerick to track project actions necessary to establish and
maintain the underground manholes and conduits of both safety-related and non-safety-
related electrical manholes in a dry condition. As discussed in Section 4OA2.2 above,
the inspectors noted a recent negative trend concerning the health of non-safety-related
underground 13kV power supply cables. For all three non-safety-related power supply
cable failures experienced at Limerick in 2010, Exelon suspected that the wet
underground environment contributed to the failure. As a result, Exelon identified the
need to expedite replacement of known degraded cables and testing of cables that had
not been previously tested.
Exelons long-term action plan to improve underground cable reliability was still under
development at the time of this inspection. The long-term plan will be customized based
on the results of manhole inspections, water infiltration rates, and the risk ranking of
cables. The inspectors concluded, from review of the draft plan and discussions with
engineers, that the long-term plan will address appropriate factors including cable
testing, cable replacements, underground drainage system repairs and/ or modifications,
etc. For safety-related manholes and conduits, Exelon planned to install a pumping
system to maintain them dry. At the time of this inspection, the modification was
scheduled for installation by June 1, 2011. Based on a review of the key actions in IR
1056715 and IR 1003826 that have been taken to date, the inspectors concluded that
Exelons planned actions appeared to be timely and would improve long-term health of
the cables.
4OA3 Event Follow-up (71153 - 3 samples)
a. Inspection Scope
For the three plant events listed below, the inspectors reviewed and/or observed plant
parameters, reviewed personnel performance, and evaluated performance of mitigating
systems. The inspectors communicated the plant events to appropriate regional
18
Enclosure
personnel and compared the event details with criteria contained in Inspection Manual
Chapter 0309, Reactive Inspection Decision Basis for Reactors, for consideration of
potential reactive inspection activities. As applicable, the inspectors verified that Exelon
made appropriate emergency action classification assessments and properly reported
the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed
Exelons follow-up actions related to the events to assure that appropriate corrective
actions were implemented commensurate with their safety significance.
Unit 2 A recirculation pump trip on October 23, 2010;
Loss of Plant Services Bus 222 on November 24, 2010; and
Unit 2 A recirculation pump trip on December 3, 2010.
b. Findings
No findings were identified.
4OA5 Other Activities
.1
Independent Spent Fuel Storage Installation (ISFSI) Monitoring Controls
(71124.01/60855 - 1 sample)
a. Inspection Scope
The inspectors reviewed routine operations and monitoring of the ISFSI (Docket No.
72-1004). The inspectors walked down the ISFSI and with the assistance of a Senior
Radiation Protection Technician, performed independent dose rate measurements of the
storage modules, and confirmed module temperatures were within the required limits.
The inspectors also reviewed plant equipment operator logs for ISFSI surveillances,
relevant issue reports, and environmental ISFSI dosimetry records. Radiological control
activities for the ISFSI were evaluated against 10 CFR 20, ISFSI TSs, and the
licensees procedures.
The inspectors also reviewed the effectiveness of radiological controls for the most
recent loading and transfer of five (5) dry storage casks, that was conducted during the
June through August 2010 period. Actual worker dose was compared to forecasted
estimated exposure and determined be within a reasonable range (< 50% difference)
and cumulative exposure was less than 5 person-rem.
b. Findings
No findings were identified.
.2
(Closed) Unresolved Item (URI) 05000352/353/2009006-02, Technical Specification
Requirements for Motor-Operated Valve (MOV) Thermal Overload Bypass Feature
a. Inspection Scope
During the 2009 component design bases inspection (CDBI), a URI was opened to
determine if Exelon was meeting the intent of TS 3.8.4.2.b regarding the bypassing of
thermal overloads on certain manually operated MOVs during an accident condition.
Exelon entered the issue into the CAP. The inspectors reviewed the IR and corrective
19
Enclosure
actions initiated to address the URI, which included a technical evaluation of the issue.
The inspectors reviewed procedures OP-LG-108-101-1004, Valves, Revision 4, and
OP-LG-103-102-1002, Strategies for Successful Transient Mitigation, Revision 5, to
determine whether the operators were provided adequate guidance on manually
operated MOV operation and bypassing of the thermal overloads. The inspectors
interviewed training staff to ensure thermal overload bypass operation was part of the
long range training program, and that the appropriate training had been in place and
conducted prior to the CDBI. The inspectors also interviewed operators and observed
simulated operator actions in the simulator to assess operator knowledge on proper
valve stroke indication, thermal overload actuation indication, and thermal overload
bypass operation of the manually operated MOVs to ensure complete valve operation.
b. Findings
No performance deficiencies or findings were identified and the URI is closed.
4OA6 Meetings, Including Exit
On January 7, the inspectors presented the inspection results to Mr. W. Maguire and
other members his staff. The inspectors confirmed that proprietary information was not
included in the inspection report.
ATTACHMENT: SUPPLEMENTAL INFORMATION
A-1
Attachment
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel:
W. Maguire, Site Vice President
E. Callan, Plant Manager
S. Johnson, Assistant Plant Manager
R. Dickinson, Director of Training
P. Gardner, Director of Operations
R. Kreider, Director of Maintenance
C. Gerdes, Security Manager
D. Merchant, Radiation Protection Manager
D. Palena, Manager Nuclear Oversight
J. Hunter, Manager, Regulatory Assurance
S. Bobyock, Manager, Plant Engineering Programs
N. Dennin, Shift Operations Superintendent
R. McLaughlin, Operations Support Manager
W. Lewis, Senior Engineering Manager
M. Gillin, Balance of Plant Engineering Manager
K. Slough, Mechanical/Structural Engineering Design Manager
M. DiRado, Engineering Rapid Response Manager
J. Risteter, Radiation Protection Manager
R. Harding, Regulatory Assurance Engineer
C. Goff, Operations Training Manager
T. Carr, Maintenance Supervisor
R. Rhode - Licensed Operator Requalification Training Supervisor
V. Hydro, Simulator Supervisor
R. Forst, Annual Operating Exam Developer
S. Cohen, Annual Operating Exam Developer
J. Mihm, Biannual Written Developer
F. Burzynski, Systems Engineer
M. Barth, Systems Engineer
J. Brittain, Senior Staff Engineer
S. Deihm, Work Week Manager
M. Leahy, Procurement Engineer Supervisor
M. Minicozzi, System Engineer
B. Tracey, Systems Engineer
G. Weiss, Systems Engineer
P. Welch, Maintenance Planner QV Inspector
D. Zaharchuk, Systems Engineer
J. Commiskey, Radiological Engineer
D. Wahl, Environmental Scientist
NRC Personnel:
E. DiPaolo, Senior Resident Inspector
N. Sieller, Resident Inspector
J. Hawkins, Acting Resident Inspector
A. Rosebrook, Senior Project Engineer
C. Crisden, Emergency Preparedness Specialist
A-2
Attachment
LIST OF ITEMS OPENED OR CLOSED
Opened
None
Closed
05000352/353/2009006-02 URI
Technical Specification Requirements for
Motor Operated Valve Thermal Overload
Bypass Feature (Section 4OA5.2)
Opened and Closed
None
Discussed
None
LIST OF DOCUMENTS REVIEWED
Common References
Limerick Unit 1 and Unit 2 UFSAR
Limerick Unit 1 and Unit 2 TSs
Limerick Unit 1 and Unit 2 Technical Requirements Manual
Limerick Unit 1 and Unit 2 Operator Logs
Section 1R01: Adverse Weather Protection
Issue Reports
1091311
Procedures
WC-AA-107, Seasonal Readiness, Revision 8
ARC-MCR-02, E-5, Spray Pond Pump Station Temperature Trouble, Revision 2
GP-7, Cold Weather Preparation and Operation, Revision 43
Work Orders
R1156051, Plant Heating Steam and Auxiliary Steam System
Miscellaneous
Letter of Certification of 2010 Limerick Winter Readiness, dated November 15, 2010
Open Winter Readiness Work items List
Section 1R04: Equipment Alignment
Procedures
S92.9.N, Routine Inspection of the Diesel Generators, Revision 59
Miscellaneous
System Notebook, Diesel Generator and Auxiliary Systems
Diesel Generator System Health Report
A-3
Attachment
2S92.1.N (COL - 3), Equipment Alignment for 2C Diesel Generator, Revision 23
UFSAR Section 8.3.1.1.3, Standby Power System
Licensee Event Report 1-96-006, CREFAS Inoperable Requiring Entry into TS 3.0.3,
May 30, 1996
2S55.1.A (COL), Equipment Alignment for Automatic Operation of HPCI System, Revision 17
Section 1R05: Fire Protection
Issue Reports
1129649
Procedures
F-S-001, Pre-Fire Plan Strategy for Spray Pond Structure Western Half (Fire Area 122),
Revision 12
F-S-002, Pre-Fire Plan Strategy for Spray Pond Structure Eastern Half (Fire Area 123),
Revision 10
ARC-MCR-006Q3L Turbine 239/269 Cond. Area/ TB, Revision 4
OP-MA-201-007, Fire Protection System Impairment Control, Revision 6
S22.8.H, Inoperable Fire Protection Equipment Actions, Revision 24
ST-7-084-925-0, Fire Door Closing Mechanism Inspection, Revision 5
F-A-024, Control Room and Peripheral Rooms
F-A-026, Remote Shutdown Room
Miscellaneous
A1747020
A1780973
Section 1R06: Flood Protection
Issue Reports
1154883
Procedures
SE-4-1, Reactor Enclosure Flooding, Revision 8
Miscellaneous
A 0-817141, Evaluate Door Preventive Maintenance
Section 1R11: Licensed Operator Requalification Program
Issue Reports
1140582
Procedures
LSES - 2004, Simulation Scenario, Revision 7
TQ-AA-150: Operator Training Programs Revision 4
T-225, Startup and shutdown of Suppression Pool and Drywell Spray Operation, Revision 020
Miscellaneous
TQ-AA-150, Operator Training Programs, Revision 4
HR-AA-07-101 NRC Licensed Operator Medical Examination
LLOR1001B, Residual Heat Removal System Review, SDC and ADHR
LLOR1001I, 1 Refueling 13 Plant Modifications
OP-AA-105-102 NRC Active License Maintenance
A-4
Attachment
EPRI NP-5562 Analysis of Anticipated Transients without Scram in Severe BWR Accidents
Simulator Test Review Board Minutes 2009-4 7/29/2009
Job Performance Measures (JPMs)
058, 086, 098, 099, 103, 114, 129, 131,134, 150, 210, 232, 261,515, 523, 758
Scenarios
LSES-2004, LSES-2035, LSES-3003, LSES-3004, LSES-5002, LSES-5003, LSES-5005,
LSES-7008
Written Examinations
NRC-2009-03-RO, NRC-2009-03-SRO, NRC-2009-04-RO, NRC-2009-04-SRO, NRC-2009-05-
SRO, NRC-2009-05-SRO
Simulator Work Requests
SWR 2008093/11090, Excessive Lag in Bypass Valve Closure as Pressure Drops after a
SWR 2008094/11107, Discrepancy between Plant and Simulator Generator Output
SWR 2008144/11338, Following core update, SLC shutdown takes longer than GE analysis
time
SWR 2008133/11272, Incorrect FW Temperature Used in Modeling Feed-Water Rupture in
Containment
SWR 2008121/11192, Open Lamp and OHA for TBV Should Operate at Same Set-point
SWR 2008102/11130, During ATWS, Power Remains Too High as Level is Lowered
Transient Tests 7.01, Reactor Scram, May 30, 2009 (Baseline: actual plant trips, SRB evaluation)
7.02, Trip of All Feed-water Pumps, May 30, 2009
7.03, Closure of All MSIVs, May 30, 2009
7.04, Trip of Both Recirculation Pumps, May 30, 2009
Annual/Normal Evolution Tests 6.12, Steady State Performance/Drift Test at 100% Power, July 26, 2009
1.12, Simulator to Reference Plant Critical Parameter Comparison, March 25, 2008
6.09, Normal Operations Performance Test: Reactor Trip Followed by Recovery to Rated
Power, November 22, 2009
Malfunction Tests
3-MPC257, Suppression Pool Water Leak to Reactor Enclosure, July 11, 2010
3-MED250B, Failure of 24 VDC Power Supply E/S-X-10082, March 18, 2007
3-MED015B, Inadvertent Trip of Safeguard Feeder Breaker 201-D11, January 13, 2007
3-MRH562A, RHR Pump B Suction Strainer Clogs - Small, August 9, 2009
3-MVI529B, RPV Pressure Transmitter PT42-103A Fails Low, June 28, 2008
3-MVI232C, RPV Level Transmitter LT-42-1N080B Fails Upscale, August 23, 2008
Non ANSI Testing
10-002-X-A, Integrated Response to Isolation of Condensate to Feed-water String A,
November 16, 2009
10-002-VII-D, Integrated Response to Trip of Four Circulating Water Pumps,
November 16, 2009
Physical Fidelity Checks Panel 00C424, October 2, 2010
Physical Fidelity Checks Panel 10C201-Remote Shutdown Panel, October 2, 2010
A-5
Attachment
Section 1R12: Maintenance Effectiveness
Issue Reports
1137553
1565145
Procedures
ASME Sect. III Code 3 Case N-513-2 Evaluation Criteria for Temporary Acceptance of Flaws in
Moderate Energy Class 2 or 3 Piping Section XI, Division I
ER-AA-310, Implementation of the Maintenance Rule, Revision 8
ER-AA-310-1004, Maintenance Rule - Performance Monitoring, Revision 8
MA-AA-716-210, PCM Process, Revision 10
Miscellaneous
Action - A1782939
Engineering Change Request 03-00705
Operability Evaluation, OPE-10-008, Revision 08
Work Order C0235674
Work Order C0235822
Section 1R13: Maintenance Risk Assessments and Emergent Work Control
Issue Report
1010943
1051496
1055147
1100185
1129709
1131393
1144472
1148152
Procedures
WC-LG-101-1001, Guideline for the Performance of On-Line Work/ On-Line System Outages,
Revision 14
WC-LG-104-1001, Guideline for the Review, Screening and Execution of Operation Risk
Activities, Revision 3
OP-AA-108-117, Protected Equipment Program, Revision D
MA-AA716-004, Attachment 2 Complex Troubleshooting, Revision 10
ER-AA-3003 Cable Condition Monitoring Program, Revision 0
OP-AA-106-101-1006, Issue Resolution Documentation Form, Revision 8
OP-AA-101-113-1004, Equipment Prompt Verbal Report, Revision 17
OP-AA-108-117, Protected Equipment Program, Revision D
OP-LG-108-117-1000, Limerick Protected Equipment Program, Revision 1
WG-AA-101, Online Work Control Process, Revision. 17
WG-LG-101-1001, Guideline for the Performance of Online Work/Online System Outages,
Miscellaneous
Generic Letter 80-30, Clarification of the Term Operable as it Applies to Single Failure
Criterion for Safety Systems Required by Technical Specifications, April 10, 1980.
ECR 10-00458
OT-112
OT-104
Action Request
A1785133
A1751413
A1586003
A-6
Attachment
A1663427
A1535446
A1709610
A1786141
Work Order
C0236019
C0233546
C0233547
Section 1R15: Operability Evaluations
Issue Reports
0642968
0642968
0985994
1115912
1137523
1140448
1143434
1144238
1144249
1144292
1145979
1151354
1152249
Procedures
ST-2-026-360-0, General Atomics Digital Process Radiation Monitors, Revision 4
ASME Code Case N-513-2, Evaluation Criteria for Temporary Acceptance of Flaws in
Moderate Energy Class 2 or 3 Piping Section XI, Division 1
M-C-756-001 HPCI Turbine Inspection, Revision 26
OP-AA-108-115, Operability Determinations, Revision 9
OP-AA-108-115-1002 Attachment 1, Supplemental Considerations for On-Shift Immediate
Operability Determinations, Revision 002
RT-2-011-252-0 (251-0) A Loop (B Loop) ESW Loop B Flow Balance, Revision 21
RT-6055-330-1(2) HPCI Turbine Over-speed Mechanism Operability Check, Revision 20
S92.9.N Routine Inspection of Diesel Generators, Revision 59
ST-6-055-230-1 HPCI Pump, Valve and Flow Test, Revision 74
Miscellaneous
Operability Evaluation OPE-10-008, Revision 8
ASME Code (OM) 1990 Sect. ISTC 4.2.9 (b)
GE SIL 392 Rev. 1 Improved HPCI Turbine/Mechanical Over-speed Trip Design
Generic Letter 90-05, Guidance for Performing Temporary Non-Code Repair of ASME Code
Class 1, 2, and 3 Piping
LER 87-066-00 HPCI Inoperability Due to Malfunction of Hydraulic-Mechanical Over-speed Trip
Mechanism
Terry Turbine Maintenance Guide for HPCI Applications
Operability Evaluation
OL1 - Turbine Reservoir HPCI Turbine Oil Sample Results from Dec. 09 - Sept. 10
OPE-10-09, Revision 0
OPE-09-005
Action Request
A1643599
A1538528
A1522918, Evaluation 50
A1733595
A-7
Attachment
Work Order
C0231042
C0236115
Section 1R19: Post-Maintenance Testing
Issue Reports
1123479
0747229
0748913
0750139
0750404
0911901
0913964
0953751
0997302
1039893
1064929
1136029
1138439
1139723
1139996
1140214
1140215
1143600
1151949
Procedures
EP-MA-124-1001-F-02, Technical Support Center/Operational Support Center Equipment Test,
Revision E
ARC-MCR-222 F-5, Unit 2 Division 2 Safeguard Battery Ground, Revision 2
CC-MA-304, Establishing and Maintaining Component Classification, Revision 0
ER-AA-340-1001 GL 89-13 Program Implementation Instructional Guide, Revision 007
GP-8.4 U/1 (U/2) Attachment 1 Isolation Bypass, Revision 008
NE-C-211 CRL Control, Revision 011
NE-C-240 Component Identification and Descriptions, Revision 001
RT-2-011-254-0 ESW Loop B D/P and Flow Data Collection, Revision 022
ST-2-072-106-1 (2) 4 Div I Refuel Floor BOP Isolation LSF/SAA and SGTS Test, Revision 1
ST-6-092-365-0 Attachment 4 Inoperable Unit 1 Safeguard Power Supply Actions for Both
Units, Revision 38
T-228, Inerting and Purging Primary Containment, Revision 022 (1)
2S11.1.A (COL-2) Equipment Alignment of ESW Loop B System, Revision 33
Miscellaneous
Calculation 1001, Compartment Temperature Transients for Steam and Water Leaks,
Revision 4b
IN 86-82 Failures of Scram Discharge Volume Vent and Drain Valves
P&ID 8031-M-61, Liquid Radwaste Collection, Sheet 4, Revision. 15
2A RRP Voltage Regulator Action Plan 12/15/10
Engineering Change 09-00551, Permanent Setpoint Change for TIS-025-101/201 B & D
Technical Evaluation for IR 390341, Recommendations for PMT of CREFAS Isolation Valves
Troubleshooting, Rework and Testing 10-127, Investigate Changing Leakrate of U2 DW
Equipment Drain Sump Leak Rate
Action Request
A1606276, Technical Evaluation
Work Orders
C0217140
C0235528
C0217141
C0229269
Section 1R22: Surveillance Testing
Issue Reports
1134173
1132485
1117800
0836062
0844439
0884271
1052559
1123250
1133664
1133723
1137894
1137977
1138001
1138015
A-8
Attachment
Procedures
OP-AA-108-103, Locked Equipment Program, Revision 2
CC-MA-304 Establish and Maintaining Component Classification, Revision 0000
M-C-747-016 CRD Scram Vent and Drain Valve Examination and Maintenance, Revision 004
S32.8.A Placing Unit 1 Main Transformers and 11 Unit Aux Transformers in SVC, Revision 22
S92.9.N, Routine Inspection of the Diesel Generators, Revision 59
ST-4-LLR-361-1 Scram Discharge Volume Vent and Drain Valves, Revision 009
ST-6-047-200-1 SDV Valve Exercise Test, Revision 024
ST-6-049-230-1, RCIC Pump, Valve and Flow Test Revision 074
ST-6-052-760-1 Safeguard Piping Fill Quarterly Valve Test, Revision 017
ST-6-092-114-2, D24 Diesel Generator 24 Hour Endurance Test, Revision 29
ST-6-092-323-1 D13 DG LOCA/LOAD Reject Testing and Fast Start Operability Test Run,
Revision 019
ST-6-092-365-0, Inoperable Unit 1 Safeguard Power Supply Actions for Both Units, Revision 38
Action Request
A1684886
Work Order
C0232841
Section 1EP4:Drill Evaluation
Issue Reports
1096028
1098708
Procedures
EP-AA-112-100-F-01, Shift Emergency Director Check List, Revision. K
EP-AA-114-F-01, Release In Progress Determination Guidance, Revision. D
Limerick Station Annex Table LGS 3-1, Emergency Action Matrix, Revision. 18
Limerick 2010 Off-Year Exercise Evaluation Report
Section 2RS01: Radiological Hazard Assessment and Exposure Controls
Procedures
RP-AA- 376, Radiological Postings, Labeling, and Markings, Revision 5
RP-AA-376-1001, Radiological Postings, Labeling, and Marking Standard, Revision 5
RP-AA-503, Unconditional Release Survey Method, Revision 4
Section 4OA1: Performance Indicator Verification
Issue Reports
1136395
1137448
1096698
1098653
1102973
1090623
1090880
1092212
1094965
1080457
1080717
1081159
1081428
1039368
1053889
1051357
1002432
1005495
1051506
Procedures
ST-5-061-570-0, RadWaste Discharge Permit, Revision 43
ST-5-076-826-0, Monthly Gaseous Release Dose Calculations, Revision 14
LS-AA-2150, Monthly Data Elements for RETS/ODCM Radiological Effluent Occurrences,
Revision 5
A-9
Attachment
LS-AA-2140, Monthly Data Elements for NRC Occupational Exposure Control Effectiveness,
Revision 5
CY-LG-120-105; Obtaining Samples from and Operation of the Reactor Enclosure Sample
Station, Revision 11
CY-LG-120-110; Chemistry Sampling and Analysis, Revision 10
ER-AB-331-1006; BWR RCS Leakage Monitoring and Action Plan, Revision 2
LS-AA-2001; Collecting and Reporting of NRC Performance Indicator Data, Revision 13
LS-AA-2100, Monthly Data Elements for NRC Reactor Coolant (RCS) Leakage, Revision 5
LS-AA-2200; Mitigating System Performance Index Data Acquisition and Reporting, Revision 3
ST-5-041-885-1; Dose Equivalent I-131 Determination, Revision 19
ST-5-041-885-2; Dose Equivalent I-131 Determination, Revision 15
ST-6-107-596-1, Drywell Floor Drain Sump/Equipment Drain Tank Surveillance Log/OPCON
1,2,3, Revision 22
ST-6-107-596-2, Drywell Floor Drain Sump/Equipment Drain Tank Surveillance Log/OPCON
1,2,3, Revision 25
Miscellaneous
Main Control Room Operator Logs 11/1/2009-12/13/2010
NEI 99-02; Regulatory Assessment Performance Indicator Guideline, Revision 6
Reactor Oversight Program MSPI Basis Document, Limerick Generating Station, Revision 1
U1 MSPI Cooling Water System Unavailability and Unreliability Index for 2010
U2 MSPI Cooling Water System Unavailability and Unreliability Index for 2010
Section 4OA2: Problem Identification and Resolution
Issue Reports
1056715
1003826
Section 4OA3: Event Followup
Procedures
OT-1/2, Recirculation Pump Trip, Revision 45
Section 4OA5: Other Activities
Correction Action Documents
00985060
Evaluations
Limerick Position Paper on Compliance with Technical Specification 3.8.4.2 Motor Operated
Valves Thermal Overload, Revision 0
Procedures
OP-LG-108-101-1004, Valves, Revision 4
OP-LG-103-102-1002, Strategies for Successful Transient Mitigation, Revision 5
ST-6-107-590-0, Daily Surveillance Log/Common Plant - At all times, Revision 87
RP-AA-214, Area TLD Surveillance, Revision 3
A-10
Attachment
LIST OF ACRONYMS
Agencywide Documents Access Management System
Alert and Notification System
Corrective Action Program
Component Design Bases Inspection
CFR
Code of Federal Regulations
Drill and Exercise Performance
Emergency Action Level
Emergency Response Organization
Emergency Service Water
High Pressure Coolant Injection
IR
Issue Report
In-Service Testing
Independent Spent Fuel Storage Installation
Motor Generator
Motor-Operated Valve
NEI
Nuclear Energy Institute
NRC
Nuclear Regulatory Commission
Out of Service
Piping and Instrumentation Drawing
Performance Indicator
Publicly Available Records
Rated Thermal Power
Radiation Work Permits
Structure, System, Component
Surveillance Test
TS
Technical Specification
Updated Final Safety Analysis Report
Unresolved Item