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{{Adams
#REDIRECT [[IR 05000352/2013005]]
| number = ML14037A370
| issue date = 02/06/2014
| title = IR 05000352-13-005, 05000353-13-005; 10/1/2013 - 12/31/2013; Limerick Generating Station (Lgs), Units 1 and 2; Followup of Events and Notices of Enforcement Discretion
| author name = Bower F
| author affiliation = NRC/RGN-I/DRP/PB4
| addressee name = Pacilio M
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| docket = 05000352, 05000353
| license number = NPF-039, NPF-085
| contact person = BOWER, FL
| document report number = IR-13-005
| document type = Inspection Report, Letter
| page count = 43
}}
See also: [[see also::IR 05000353/2013005]]
 
=Text=
{{#Wiki_filter:UNITED STATES                        NUCLEAR REGULATORY COMMISSION                                                      REGION I                            2100 RENAISSANCE BOULEVARD, SUITE 100                          KING OF PRUSSIA, PENNSYLVANIA 19406-2713                  February 6, 2014    Mr. Michael J. Pacilio Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road Warrenville, IL  60555  SUBJECT: LIMERICK GENERATING STATION  NRC INTEGRATED INSPECTION REPORT 05000352/2013005 AND 05000353/2013005  Dear Mr. Pacilio:    On December 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Limerick Generating Station (LGS), Units 1 and 2.  The enclosed inspection report documents the inspection results, which were discussed on January 10, 2014, with  Mr. T. Dougherty, Site Vice President, and other members of your staff.  The inspection examined activities conducted under your license as they relate to safety and h the conditions of your license.  The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.  NRC inspectors identified one self-revealing finding of very low safety significance (Green) during this inspection.  The finding did not involve a violation of NRC requirements.  If you disagree with the 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 Inspector at the LGS.  As a result of the Safety Culture Common Language Initiative, the terminology and coding of cross-cutting aspects were revised beginning in calendar year 2014.  New cross-cutting aspects identified in calendar year 2014 will be coded under the latest revision to Inspection Manual Chapter (IMC) 0310.  Cross-cutting aspects identified in the last six months of 2013 using  the previous terminology will be converted to the latest revision in accordance with the cross-reference in IMC 0310.  The revised cross-cutting aspects will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the calendar year 2014 mid-cycle assessment review.  In accordance with 10 Code of Federal Regulations electronically for public inspection in the NRC Public Document Room or from the Publicly   
M. Pacilio 2    ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).  Sincerely,  /RA/  Fred L. Bower, III, Chief  Reactor Projects Branch 4  Division of Reactor Projects  Docket Nos.:  50-352, 50-353    License Nos.: NPF-39, NPF-85  Enclosure: Inspection Report 05000352/2013005 and 05000353/2013005  w/Attachment: Supplemental Information  cc w/encl: Distribution via ListServ   
 
  ML14037A370 X  SUNSI Review  Non-Sensitive  Sensitive  Publicly Available  Non-Publicly Available  OFFICE RI/DRP RI/DRP RI/DRP  NAME  mmt EDiPaolo/  FLB for SBarber/ GSB FBower/ FLB    DATE 02/06/14    by telecon 02/06/14 02/06/14   
1  Enclosure  U.S. NUCLEAR REGULATORY COMMISSION  REGION I    Docket Nos.:  50-352, 50-353  License Nos.:  NPF-39, NPF-85  Report No.:  05000352/2013005 and 05000353/2013005  Licensee:  Exelon Generation Company, LLC  Facility:  Limerick Generating Station, Units 1 & 2  Location:  Sanatoga, PA  19464  Dates:  October 1, 2013 through December 31, 2013  Inspectors:  E. DiPaolo, Senior Resident Inspector    J. Hawkins, Resident Inspector    J. Ayala, Resident Inspector (Acting)    R. Nimitz, Senior Health Physicist    K. Mangan, Senior Reactor Inspector    T. Burns, Reactor Inspector    J.    B. Fuller, Senior Operations Engineer    S. Chaudhary, Reactor Inspector  Approved By:  Fred Bower, Chief    Reactor Projects Branch 4    Division of Reactor Projects   
2  Enclosure TABLE OF CONTENTS  SUMMARY ................................................................................................................................ 3 1. REACTOR SAFETY ........................................................................................................... 5 1R01 Adverse Weather Protection  .................................................................................... 5 1R04 Equipment Alignment ............................................................................................... 6 1R05 Fire Protection .......................................................................................................... 7 1R06 Flood Protection Measures  ...................................................................................... 8 1R07 Heat Sink Performance  ........................................................................................... 8 1R11 Licensed Operator Requalification Program ............................................................. 8 1R12 Maintenance Effectiveness  .....................................................................................10 1R13 Maintenance Risk Assessments and Emergent Work Control  ................................11 1R15 Operability Determinations and Functionality Assessments  ....................................11 1R18 Plant Modifications ..................................................................................................12 1R19 Post-Maintenance Testing  ......................................................................................13 1R22 Surveillance Testing  ...............................................................................................13  ......................................................................................................14  ......................................14      ................................................................................................................................16  - ............................................17  .............................................................................18  .....................................................................19  ..............................................21 4. OTHER ACTIVITIES ..........................................................................................................22 4OA1  ...................................................................22 4OA2 Problem Identification and Resolution  ....................................................................24 4OA3 Follow-Up of Events and Notices of Enforcement Discretion  ..................................27 4OA5 Other Activities ........................................................................................................30 4OA6 Meetings, Including Exit ...........................................................................................30 ATTACHMENT: SUPPLEMENTARY INFORMATION ...............................................................30 SUPPLEMENTARY INFORMATION ....................................................................................... A-1 KEY POINTS OF CONTACT .................................................................................................. A-1 LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED .................................... A-1 LIST OF DOCUMENTS REVIEWED ....................................................................................... A-2 LIST OF ACRONYMS ........................................................................................................... A-10 
3  Enclosure SUMMARY  IR 05000352/2013005, 05000353/2013005; 10/1/2013-12/31/2013; Limerick Generating Station (LGS), Units 1 and 2; Followup of Events and Notices of Enforcement Discretion.  This report covered a three month period of inspection by resident inspectors and announced inspections performed by regional inspectors.  Inspectors identified one finding of very low safety significance (Green).  The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual -cutting aspects are determine-October 28, 2011.  All violations of Nuclear Regulatory Commission (NRC) requirements are gram for overseeing the safe operation of commercial nuclear power reactors is described in NRC Technical Report Designation (NUREG)-Revision 4.  Cornerstone:  Barrier Integrity  Green.  The inspectors identified a self-revealing finding (FIN) of very low safety significance degraded Unit 2 magnetic switch for a secondary containment airlock door in accordance with Exelon procedure WC-AA-airlock doors being opened simultaneously due to equipment degradation and resulted in a momentary loss of reactor enclosure secondary containment integrity.  The failure of the station to properly prioritize the work order for the defective magnetic -to-reactor building air supply room ability to foresee and correct and could have been prevented.  This was caused by not also determined to be more than minor because it was associated with the Barrier Integrity cornerstone attribute of structures, systems, and components (SSC) and Barrier Performance (doors and instrumentation) and affected the cornerstone objective of providing reasonable assurance that physical design barriers (secondary containment) protect the public from radionuclide releases caused by accidents or events.  Specifically, opening two reactor building airlock doors at the same time did not maintain reasonable assurance that the secondary containment would be capable of performing its safety function in the event of a reactor accident.  The finding was determined to be self-revealing because it was revealed through the receipt of an alarm in the main control room which required no active and deliberate observation by Exelon personnel.  The finding was determined to be of very low safety significance (Green) in accordance with Appendix A  of IMC 0609, "Significance Determination Process for Findings At-Power."  Specifically, the finding only represents a degradation of the radiological barrier function provided by the secondary containment airlock doors.  Exelon entered the issue into the corrective action program (CAP) as Issue Report (IR) 1553563.  Corrective actions performed or planned included repairing the magnetic switch, verifying that the corrective maintenance backlog did not contain any other issues involving the airlock door indicating lights, developing a periodic 
4  Enclosure routine test of the airlock door indicating circuits, and performing a site impact review of the changes in NUREG 1022, Revision 3.  This finding had a cross-cutting aspect in the area of Human Performance, Resources, because Exelon did not ensure that resources were available to minimize preventative maintenance deferrals and ensure maintenance and engineering backlogs were low enough to ensure that safety is maintained [H.2(a)].  Specifically, Exelon deferred implementation  of the work order several times over a three year period which resulted in secondary containment becoming inoperable on September 3, 2013.  (Section 4OA3)  Other Findings  None.   
5  Enclosure REPORT DETAILS  Summary of Plant Status  Unit 1 began the inspection period at 100 percent power.  On December 12, 2013, operators conducted a planned power reduction to approximately 60 percent to facilitate main steam valve testing, main turbine valve testing, control rod scram time testing, fuel channel distortion testing, unit to 100 percent power on December 16, 2013, and Unit 1 remained at or near 100 percent power for the remainder of the inspection period.  Unit 2 began the inspection period at 100 percent power.  On December 7, 2013, operators conducted a planned power reduction to approximately 92 percent to facilitate main turbine valve testing.  Operators returned the unit to 100 percent power on December 8, 2013, and  Unit 2 remained at or near 100 percent power for the remainder of the inspection period.  1. REACTOR SAFETY  Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity  1R01 Adverse Weather Protection (71111.01  2 samples)  .1 Readiness for Seasonal Extreme Weather Conditions  a. Inspection Scope  onset of seasonal cold weather.  generators (EDGs) emergency service water and residual heat removal service water pumps).  The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), Technical Specifications (TS), control room logs, and the corrective action program to determine what temperatures or other seasonal weather could challenge these systems, and to ensure Exelon personnel had adequately prepared for these challenges.  The inspectors reviewed station procedures, includprocedure and applicable operating procedures.  The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during cold weather conditions.  Documents reviewed for each section of this inspection report are listed in the Attachment.  b. Findings  No findings were identified.  .2 Readiness for Impending Adverse Weather Conditions  a. Inspection Scope  On October 7, 2013, the iand during a Tornado Watch issued by the National Weather Service for Montgomery County, Pennsylvania.  The inspectors performed walkdowns of equipment that could be 
6  Enclosure  effected by high winds including the main transformer areas and the EDGs to verify that potential missile objects were secure.  The inspectors verified that Exelon personnel performed preparations in accordance with severe weather procedures.  b. Findings  No findings were identified.  1R04 Equipment Alignment    Partial System Walkdowns (71111.04  5 samples)  a. Inspection Scope  The inspectors performed partial walkdowns of the following systems:    Unit 2 high pressure coolant injection (HPCI) system (risk significant system) following the discovery of a degraded system flexible conduit (IR 1564080) on October 2, 2013  10 bus and 101 offsite power source when the 20 bus and 201 offsite source were out-of-service for planned maintenance on October 7, 2013  Unit 2 reactor core isolation cooling (RCIC) system when Unit 2 HPCI system was unavailable due to a flow controller issue (IR 1572132) on October 21, 2013  Unit 1 RCIC system (risk significant system) following return to service following RCIC vacuum breaker testing on November 26, 2013  Unit 2 HPCI system (risk significant system) following return to service following HPCI system simulated automatic actuation testing on December 19, 2013  The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected.  The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, TS, work orders, issue reports (IR), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions.  The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable.  The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies.  The inspectors also reviewed whether Exelon staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.  b. Findings  No findings were identified.   
7  Enclosure  1R05 Fire Protection  .1 Resident Inspector Quarterly Walkdowns (71111.05Q  5 samples)  a. Inspection Scope  The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features.  The inspectors verified that Exelon controlled combustible materials and ignition sources in accordance with administrative procedures.  The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition.  The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded,  or inoperable fire protection equipment, as applicable, in accordance with procedures.    Unit 1 Fire Area 45  Control Rod Drive (CRD) Hydraulic Equipment Area and  Unit 2 Fire Area 45  CRD Hydraulic Equipment Area and Neutron Monitoring S  Unit 1 Fire Area 13    Unit 1 Fire Area 22  November 22, 2013  Common Fire Area 25  November 26, 2013  b. Findings  No findings were identified.  .2 Fire Protection  Drill Observation (71111.05A  1 sample)  a. Inspection Scope  On November 14, 2013, the inspectors observed multiple fire drills for plant fire brigade members at the Philadelphia Electric Company Fire Training Facility in Conshohocken, Pennsylvania.  The inspectors observed pre-job briefs, fire brigade assembly and donning of protective equipment, fire brigade performance, and communications between the fire brigade leader and simulated control room.  The inspectors observed instructor critiques and assessed whether appropriate feedback was provided to the fire brigade.  b. Findings  No findings were identified.   
8  Enclosure 1R06 Flood Protection Measures (71111.06  2 samples)  Internal Flooding Review  a. Inspection Scope  The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures  to assess susceptibilities involving internal flooding.  The inspectors also reviewed the corrective action program to determine if Exelon identified and corrected flooding problems and whether operator actions for coping with flooding were adequate.  The inspectors performed walkdowns of the areas listed below to verify the adequacy of equipment seals located below the flood line, floor and water penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and temporary or removable flood barriers.    involving degraded silicone hatch sealant October 25, 2013  Units 1 and 2 HPCI and RCIC rooms on November 20, 2013  b. Findings  No findings were identified.  1R07 Heat Sink Performance (711111.07A  1 sample)  a. Inspection Scope  heat removal heat exchanger testing to determine its readiness and availability to perform its safety functions.  The inspectors reviewed the design basis for the -13.  The inspectors reviewed IR 1569110 which documented an issue involving abandoned  heat exchanged vent valves.  The inspectors discussed the results of the most recent inspection with engineering staff and reviewed pictures of the as-found and as-left conditions.  The inspectors verified that Exelon initiated appropriate corrective actions  for identified deficiencies.  The inspectors also verified that the number of tubes plugged within the heat exchanger did not exceed the maximum amount allowed.  b. Findings  No findings were identified.  1R11 Licensed Operator Requalification Program  .1 Quarterly Review of Licensed Operator Requalification Testing and Training (71111.11Q  1 sample)  a. Inspection Scope  The inspectors observed two licensed operator annual simulator examination scenarios on October 29, 2013.  One scenario included an unisolable steam leak outside of containment and other equipment malfunction.  The other scenario included a loss 
9  Enclosure of safety-related bus power, a scram due to plant equipment failure, safety-related mitigating equipment failures, and a small break loss of coolant accident.  The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures.  The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor.  The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the TS action statements entered by the operating crew.  Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.  b. Findings  No findings were identified.  .2 Quarterly Review of Licensed Operator Performance in the Main Control Room (71111.11Q  1 sample)  a. Inspection Scope  The inspectors observed and reviewed licensed operator performance in the main control room during a planned Unit 1 downpower to 60 percent power on December 14, 2013.  The downpower was performed to facilitate main steam and main turbine valve testing, control rod scram time testing, fuel channel distortion testing, and to repair a -evolution briefing for the planned downpower and reactivity control briefings to verify  that the briefings met established plant practices.  The inspectors observed operator performance during the downpower to verify that procedure use, alarm response card response, TS usage, crew communications and coordination of activities were in accordance with established expectations and standards.    b. Findings  No findings were identified.  .3 Limited Senior Reactor Operator Requalification Examination Results (71111.11A  1 sample)  a. Inspection Scope  On December 9, 2013 one NRC region-based inspector conducted an in-office review of results of licensee-administered requalification examination results for Senior Reactor Operator Limited to Fuel Handling license holders.  The inspection assessed whether pass rates were consistent with the guidance of NRC Inspection Manual Chapter 0609,  Overall pass rate among individuals for all portions of the exam was greater than or equal to 80%.  (Overall pass rate was 100%) 
10  Enclosure b. Findings  No findings were identified.  .4 Licensed Operator Requalification Examination Results (71111.11A  1 sample)  a. Inspection Scope  On December 18, 2013, one NRC region-based inspector conducted an in-office review of results of licensee-administered annual operating tests for 2013, for Limerick Units 1 and 2 licensed operators.  Comprehensive written exams were administered in the last quarter of 2013 and will be reviewed during the next requalification program inspection in November 2014.  The inspection assessed whether pass rates were consistent with the    Individual pass rate on the dynamic simulator test was greater than 80 percent. (Pass rate was 100 percent)    Individual pass rate on the job performance measures of the operating exam was greater than 80 percent. (Pass rate was 100 percent)  More than 80 percent of the individuals passed all portions of the requalification exam.  (Pass rate was 100 percent)    Crew pass rate was greater than 80 percent.  (Pass rate was 100 percent)  b. Findings    No findings were identified.  1R12 Maintenance Effectiveness (71111.12Q  3 samples)  a. Inspection Scope  The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on SSC performance and reliability.  The inspectors reviewed system health reports, corrective action program documents, maintenance work orders, and maintenance rule basis documents to ensure that Exelon was identifying and properly evaluating performance problems within the scope of the maintenance rule.  For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by Exelon staff was reasonable.  As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2).  Additionally, the inspectors ensured that Exelon staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.    IR 1568795, containment vent motor-operated valve (HV-060-111/112/114) preventive maintenance and performance criteria issues on October 8, 2013 through October 11, 2013  IR 1569198, abnormal noise from a Unit 1 HPCI system instrumentation power supply on October 4, 2013 through October 18, 2013 
11  Enclosure  IR 1573005, Unit 2 redundant reactivity control system Maintenance Rule (a)(1) determination on October 21, 2013 through October 25, 2013  b. Findings  No findings were identified.  1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13  5 samples)  a. Inspection Scope  The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Exelon performed the appropriate risk assessments prior to removing equipment for work.  The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones.  As applicable for each activity, the inspectors verified that Exelon personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete.  When Exelon performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk.  The inspectors reviewed the scope of maintenance work and discussed the results of s probabilistic risk analyst to verify plant conditions  were consistent with the risk assessment.  The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.    IR 1542786, Abnormal Unit 1 HPCI system stop valve movement during pump startup on October 2, 2013  Unit 1 and Unit 2 elevated online risk (Yellow) due to the 20 bus and 201 offsite source being out-of-service on October 7, 2013  IR 1572412, Unit 1 oscillation power range monitor/average power range monitor #3 non-critical self-test fault (risk assessment, operability, and troubleshooting) on October 21, 2013  Unit 2 on-line risk during one-half reactor protection system scram testing with EDG -of-service on December 9, 2013  Unit 2, on-line risk during HPCI system automatic actuation testing on December 18, 2013  b. Findings  No findings were identified.  1R15 Operability Determinations and Functionality Assessments (71111.15  4 samples)  a. Inspection Scope  The inspectors reviewed operability determinations for the following degraded or non-conforming conditions: 
12  Enclosure  IR 1564080 and 1561625, Unit 2 HPCI system testing aborted following discovery of a broken conduit supporting the system oil system on October 2, 2013  IR 1569198, Unit 1 HPCI system power supply abnormal noise on October 9, 2013  IR 1588352, Void discover in Unit 1 Cable Spread Room cable penetration fire seal on November 25, 2013  IR 1597676 and 1597369, Unit 1 control rods 02-27 and 34-59 high friction due to fuel channel distortion on December 19, 2013  The inspectors selected these issues based on the risk significance of the associated components and systems.  The inspectors evaluated the technical adequacy of the operability determinations to assess whether technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred.  The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and UFSAR to tions to determine whether the components or systems were operable.  Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Exelon.  The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.  b. Findings  No findings were identified. 1R18 Plant Modifications    Permanent Modifications (71111.18  1 sample)  a. Inspection Scope  low pressure turbine exhaust hood (Engineering Change Request 12-00482) to determine whether the modification adversely affected the safety-related structures at LGS.  These structures include the reactor buildings, diesel generator buildings, the control structure, and the spray pond pump house.  Adverse effects to these structures from changes in turbine missile protection could result in a loss of the capability to function in a manner necessary to meet 10 CFR 100 requirements.  The inspectors verified that the design bases, licensing bases, and performance capability of the affected components or safety-related structures were not degraded by the modification.  The inspectors reviewed the UFSAR, the safety evaluation of the turbine hood change package, and the design specification for the replacement of the main turbine exhaust hood with a modified design, and the work orders for the installation of the new turbine exhaust hood.    b. Findings  No findings were identified.   
13  Enclosure 1R19 Post-Maintenance Testing (71111.19  7 samples)  a. Inspection Scope  The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability.  The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved.  The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.  IR 1572132, Unit 2 HPCI system flow controller repair on October 15, 2013    C0250043, Troubleshoot and repair Unit 1 oscillation power range/average power range monitor channel trouble alarm on October 30, 2013  C0250544, Repair Unit 1 Cable Spread Room Cable penetration fire seal (0457-E003E) on November 26, 2013  Unit 2 RCIC system post maintenance testing following system outage window from December 4 until December 6, 2013  IR 1583879, Replace Unit 2 residual heat removal system injection valve low delta-pressure permissive relay on November 13, 2013  due to flow oscillations  b. Findings  No findings were identified.  1R22 Surveillance Testing (71111.22  3 Routine, 1 In-Service Test and 1 Reactor Coolant System Leak Test)    a. Inspection Scope  The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied technical specifications, the UFSAR, and Exelon procedure requirements.  The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied.  Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions.  The inspectors reviewed the following surveillance tests:  ST-2-052-802-2013  ST-6-048-231-1, SLC Pump, Comprehensive Test on November 19, 2013 (In-service Test) 
14  Enclosure  ST-6-092-316-2, D22 Diesel Generator Fast Start Operability Test Run on  November 25, 2013  ST-6-107-590-1, Daily Surveillance Log/Operational Conditions 1,2, and 3 (including reactor coolant system leak rate measurement) for week of December 8, 2013  ST-2-055-100-2, HPCI Logic System Functional Simulated Automatic Actuation on December 18, 2013  Findings  No findings were identified.        -  -  a.        -  -    - 
15  Enclosure                -    -  -       
16  Enclosure  b.  No findings were identified.  -  -  a.      -    ----  -     
17  Enclosure    b.    --  the period November 18-21  a.      -      --   
18  Enclosure        -  - b.    -  -  a.           
19  Enclosure  -              b.    -  -    a.   
20  Enclosure    -            -      b.   
21  Enclosure  -  -                - -      -- 
22  Enclosure          b. Findings  4. OTHER ACTIVITIES  4OA1    .1 Occupational Exposure Control Effectiveness  a.  --  -- 
23  Enclosure  - b.  .2 Mitigating Systems Performance Index (2 samples)  a. Inspection Scope  Index for the following systems for the period of October 1, 2012 through September 30, 2013:  Unit 1 Cooling Water (MS10)  Unit 2 Cooling Water (MS10)  To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, alperformance index derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.  b. Findings  No findings were identified.  .3 Reactor Coolant System (RCS) Specific Activity and RCS Leak Rate (4 samples)  a. Inspection Scope  rate performance indicators for both Unit 1 and Unit 2 for the period of October 1, 2012 through September 30, 2013.  To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-Indicator room logs of daily measurements of RCS leakage, and compared that information to the data reported by the performance indicator.     
24  Enclosure  b. Inspection Findings  No findings were identified.  4OA2 Problem Identification and Resolution (71152)  .1 Routine Review of Problem Identification and Resolution Activities  a. Inspection Scope  the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Exelon entered issues into the corrective action program at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends.  In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the corrective action program and periodically attended condition report screening and management review committee meetings.  b. Findings  No findings were identified.  .2 Semi-Annual Trend Review  a. Inspection Scope  The inspectors performed a semi-annual review of site issues, as required by Inspection indicate the existence of more significant safety issues.  In this review, the inspectors included repetitive or closely-related issues that may have been documented by Exelon outside of the corrective action program, such as trend reports, performance indicators, major equipment problem lists, system health reports, maintenance rule assessments, and maintenance or corrective action program backlogs.  The inspectors also reviewed assess IRs written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily condition report review (Section 4OA2.1).  The inspectors reviewed Exelon quarterly trend meeting information report for the third quarter of 2013, conducted under LS-AA-125-1005, Coding and Analysis Manual, Revision 8, to verify that Exelon personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures.  b. Findings and Observations  No findings were identified.  The review did not reveal any new trends that could indicate a more significant safety issue.  The inspectors assessed that Exelon personnel were identifying issues at a low 
25  Enclosure threshold and entering issues into the CAP for resolution.  The inspectors continued to monitor a previously identified negative trend associated with plant issues related to preventive maintenance of plant equipment discussed in NRC Inspection Report 05000352, 353/2013003.  During this period, the inspectors did not identify any plant events, transients, or major plant issues related to preventive maintenance.  .3 Annual Sample:  Emergency Diesel Generator D24 Lubricating Oil Pipe Failure  a. Inspection Scope  The inspectors performed an in-depth review of Exelonactions associated with failures of the D24 EDG lubricating oil pipe on November 13, 2012 and April 27, 2013.  In both cases the EDG was declared inoperable and Exelon remained in the Action Statement of Technical Specification 3.8.1.1 until the pipe was replaced.  After the second failure Exelon completed an engineering assessment of the event and determined that the probable cause of the pipe failure was due to vibration induced high cycle fatigue.  Exelon identified a defective support bracket and concluded that the missing support allowed the excessive vibration to occur.  -of-condition review, completed and proposed corrective actions, and the prioritization and timeliness of actions to evaluate whether the corrective actions were appropriate.  The inspectors actions taken to ensure they met the requirements of the corrective action program.  bracket inspections were incorporated into the preventative maintenance (PM) program and deficiencies identified by Exelon during walkdowns of the EDGs had been adequately addressed in the corrective action program.  The inspectors reviewed the results of vibration data, collected at the location of the piping failure for several of the EDGs, to assess whether corrective actions had sufficiently reduced vibrations so that displacement due to vibration were below cyclic failure limits.  Finally, the inspectors walked down the EDGs to evaluate the material condition of the supports for the EDG auxiliary systems.  b. Findings and Observations  No findings were identified.  evaluation and extent-of-condition review were thorough, and the probable and contributing causes were appropriately identified.  However, vibration data was not taken at the piping prior to correcting the deficient hanger, therefore, conclusive proof of a high vibration condition could not be verified.  The inspectors also determined that the corrective actions were evaluation identified that the pipe failures in 2012 and in 2013 were caused by high vibration fatigue failure due to a missing grommet used to support the piping.  -of-condition review of all the EDGs found other instances  of missing grommets and loose clamps that were installed to support EDG auxiliary piping.  Immediate corrective actions for these deficiencies included installing grommets and tightening clamps to ensure that the rigidity of the piping was adequate to minimize 
26  Enclosure vibration amplitudes.  Additionally, Exelon revised PMs to include inspection and replacement of grommets and clamps.  Finally, Exelon determined that the installed configuration of the EDG auxiliary systems was not uniform and has long term corrective actions in place to determine and correct the configurations of the piping supports for each EDG.  Following the repair Exelon compared the vibration data for the piping on each of the EDGs and determined that the vibration readings on the D24 EDG were in line with the other EDGs installed at Limerick.  The inevaluation and corrective action efforts associated with this event were appropriate and thorough.  .4 Residual Heat Removal Service Water Reduced Flow Rate  a. Inspection Scope  The inspectors performed an in-depth review of Exelonactions performed to correct a reduction in the flow below design limits of cooling water to components in the residual heat removal service water (RHRSW) and emergency service water (ESW) systems.  Exelon identified during flow balance testing of the EDGs could not be met.  Exelon declared the two EDGs inoperable and entered the Action Statement for Technical Specification 3.8.1.1.  Additionally, during trouble-shooting on November 19, 2011, Exelon determined that the design flow rate for RHRSW to the residual heat removal (RHR) heat exchangers could not be met in certain system configurations.  Exelon performed an operability assessment and following an evaluation of the actual system conditions of the RHR heat exchanger, ESW system loads and spray pond spray network determined that the ESW, RHRSW, and EDGs were operable but both service water systems were degraded.    Subsequently, Exelon completed an apparent cause analysis and determined that the probable cause of the flow degradation was a result of increased corrosion in the RHRSW/ESW common return piping and spray pond spray network piping.  Exelon concluded that corrosion on the interiosmaller pipe diameters and increased flow resistance which resulted in lower flow rates the interior piping and nozzles in the spray network, reanalyzing the spray pond flow requirements, reanalyzing the RHR heat exchanger flow requirements and revising operating procedures to limit the RHRSW flow rates to the RHR heat exchanger.  luation, extent-of-condition review, completed and proposed corrective actions, and the prioritization and timeliness of actions to evaluate whether the corrective actions were appropriate (IRs1292570 and 1346780).  The inspectors interviewed engineers and the issue and corrective actions taken to ensure they met the requirements of their corrective action program and addressed the degraded conditions.  Specifically, the r the actions taken to clean the pipe were effective; reanalysis of the spray network and spray pond was in accordance with the UFSAR; and testing and operating procedures had been correctly revised to ensure the systems were operated within the new design assumptions.   
27  Enclosure b. Findings and Observations  No findings were identified.  evaluation and extent of condition review were thorough and that the probable and contributing causes were appropriately identified.  The inspectors also determined that the corrective actions  were reasonable and addressed the probable and contributing causes for the degraded condition.  The inspectors noted Exelon had identified corrosion in the piping; however, the corrective actions to monitor the impact of the corrosion had focused on the nozzles in the spray pond spray network.  In response to the degraded flow Exelon created a recurring PM program to clean all of the spray pond piping and monitor the effect corrosion had on RHRSW and ESW system flow.  The inspectors found that following the initial cleaning of the piping network flow was restored to system components.  The inspectors also noted that procedure modifications made to the system operating and testing procedures were adequate  such that RHRSW and ESW system flows were controlled to assure flow to all system components was maintained.  Finally, the inspectors found that the actions taken to licensing basis requirements and additional margin to design limits had been realized.  The inspectors concluded that Exassociated with this event were appropriate and thorough.  4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153  2 samples)  .1 (Closed) Licensee Event Report (LER) 05000353/2013-002-00:  Inoperable Reactor Enclosure Secondary Containment Integrity Due to Open Airlock  Introduction.  The inspectors identified a self-revealing finding (FIN) of very low  s associated with a degraded Unit 2 magnetic switch for a secondary containment  airlock door in accordance with Exelon procedure WC-AA-resulted in a loss of reactor enclosure secondary containment integrity.  Description.  On Tuesday, September 3, 2013, the main control room received an alarm for reactor enclosure low differential pressure when Exelon personnel were moving equipment through the 313-to-reactor building air supply room access airlock doors.  Both airlock doors were inadvertently opened causing the reactor enclosure pressure to drop to 0.18 inch of vacuum water gauge which is below the Technical Specification minimum value of 0.25 inch of vacuum water gauge.  An indicating light is located at each entrance door leading to the airlock; one on the reactor building side and one on the turbine building side.  When either door is open (e.g., turbine building side), the indicating lights illuminate warning those personnel that are potentially attempting to enter the airlock from the opposite side (e.g., reactor building side), that the opposite side airlock door is open.  Plant workers are expected to not proceed through an airlock door when the indicating light is on so as to not create a loss of secondary containment integrity.  On September 3, after verifying that the indicating light was not illuminated, workers proceeded to open the airlock door.  Upon opening 
28  Enclosure the door they discovered that the opposite side airlock door was already open and proceeded to close both doors.  Once both airlock doors were closed, secondary containment pressure was restored to its normal pressure of 0.33 inch of vacuum water gauge.  The failure of the indicating light to warn the maintenance workers that the airlock door (Door 559) was open was due to a defective magnetic position switch.  Exelon had identified that the switch was defective on October 12, 2010, and entered the issue into the CAP under IR 1125544.  The inoperable magnetic switch caused the indication feature to be non-functional.  At the time, Exelon personnel did not consider the simultaneous opening of two airlock doors to be a loss of safety function.  As a result, the work order to repair the magnetic switch was given a routine (Priority 5) work priority that should be worked following the normal scheduling process.  Because of the low priority, four times in 2013 Exelon staff deferred the work order once in 2010, three times in 2012, and four times in 2013.  In January 2013, the NRC made a revision (Revision 3) to the guidance provided in NUREG-licensees were required to make a 10 CFR 50.72 and 50.73 notification for an SSC being declared inoperable when required by a specific TS defined operating mode.  Following the guidance of Revision 3, a loss of secondary containment integrity as a result of both airlock doors being opened at the same time would be reportable.  The NUREG was revised and issued in January 2013 with an effective date of July 1, 2013.  On July 1, 2013, Exelon issued Revision 19 to procedure LS-AA-1110, Exelon Reportability Reference Manual, which implemented the requirements of NUREG 1022, Revision 3.  Operations personnel (Operations Support, Operations Manage-ment, and licensed operators) were informed of the changes.  The procedure change checklist did not specify a site impact review.  The work order to replace the magnetic switch was deferred twice after the issuance of the new guidance and two additional times after the effective date of NUREG-1022, Revision 3 and LS-AA-1110, Revision 19 on July 1, 2013.  mergency the revision to LS-AA-1110 contributed to the event because no site impact review was performed for the change.  A site impact review should have performed a review of degraded equipment potentially affected by the change and identified that the indicating light was inoperable.  As a result, the work order to repair the magnetic switch would have been given a higher priority in the work scheduling process.  The inspectors reviewed Exelon procedure WC-AA-and concluded that the work order would have been given a Priority 4.  This is because it e, if additional given priority 4 should be scheduled and started within five weeks  Analysis.  The failure of the station to properly prioritize the work order for the defective -to-reactor building air supply room access airlock doors was a performance deficiency that was reasonably  This was caused by not performing a site impact review of reportability clarifications made by 
29  Enclosure g and processing.  The finding was determined to be more than minor because it was associated with the Barrier Integrity cornerstone attribute of SSC and Barrier Performance (doors and instrumentation) and affected the cornerstone objective of providing reasonable assurance that physical design barriers (secondary containment) protect the public from radionuclide releases caused by accidents or events.  Specifically, opening two reactor building airlock doors at the same time did not maintain reasonable assurance that the secondary containment would be capable of performing its safety function in the event of a reactor accident.  The finding was determined to be self-revealing because it was revealed through the receipt of an alarm in the main control room which required no active and deliberate observation by Exelon personnel.  The finding was determined to be of very low safety significance (Green) in accordance with Appendix A of IMC 0609, "Significance Determination Process for Findings At-Power."  Specifically, the finding only represents a degradation of the radiological barrier function provided by the secondary containment airlock doors.  Exelon entered the issue into the CAP as IR 1553563.  Corrective actions performed or planned included repairing the magnetic switch, verifying that the corrective maintenance backlog did not contain any other issues involving the airlock door indicating lights, developing a periodic routine test of the airlock door indicating circuits, and performing a site impact review of the changes make by NUREG 1022, Revision 3.  This finding had a cross-cutting aspect in the area of Human Performance, Resources, because Exelon did not ensure that resources were available to minimize preventative maintenance deferrals and ensure maintenance and engineering backlogs were low enough to ensure that safety is maintained [H.2(a)].  Specifically, Exelon deferred implementation of the work order several times over a three year period which resulted in secondary containment becoming inoperable on September 3, 2013.  Enforcement.  This finding does not involve enforcement action because no regulatory requirement violation was identified.  Exelon entered this issue into their corrective action program as IR 1553563.  Because this finding does not involve a violation and has very low safety significance, it was identified as a finding.  (FIN 05000353/2013005-01, Failure to Properly Plan Work for Failed Airlock Door Magnetic Switch)  .2 (Closed) LER 05000352, 353/2013-002-00:  Condition that could have Prevented Fulfillment of the Offsite Power Safety Function  On August 5, 2013, 201-D23 bus source undervoltage relay calibration/functional testing was being performed in conjunction with monthly D23 EDG testing.  During EDG monthly testing, the D23 EDG is declared inoperable per the surveillance test.  The the test was placed in manual which renders that offsite power source inoperable.  During the undervoltage test, EDG D23 was paralleled with safeguard bus transformer 101.  As-found testing revealed that 201-D23 bus undervoltage relay was inoperable due to exceeding the reset setpoint upper acceptance limit.  Technicians were not able to recalibrate the relay within TS Limiting Condition for Operation 3.3.3, Emergency Core Cooling System Actuation Instrumentation, action requirement of 1 hour.  As a result, the 201-D23 breaker was racked out to comply with TS requirements.  This resulted in Unit 2 entering Limiting Condition for Operation 3.0.3 due to the EDG D23, the 101 Offsite 
30  Enclosure source, and the 201 offsite source being inoperable.  This condition was exited 17 minutes later when EDG testing was aborted which restored EDG D23 and the 101 offsite source to operable status.  The cause of the undervoltage relay inoperability was setpoint drift.  The relay was recalibrated successfully.  Exelon revised the EDG operating procedures to add specific guidance to place the offsite safeguard transformer tap changer to automatic if under-voltage testing is being performed in conjunction with the EDG being run in parallel with the offsite source.  The inspectors did not identify any performance deficiency as a result of reviewing the issue.  This LER is closed.  4OA5 Other Activities  Temporary Instruction (TI) 2515/182, Phase 2, Buried Piping (1 sample)  a. Inspection Scope  in accordance with paragraph 03.02.a of the TI 2515/182.  The inspectors confirmed that activities completed subsequent to the Phase 1 inspection were completed by the program specified completion dates.    in accordance with paragraph 03.02.b of the TI and responses to specific questions found in http:www.nrc.gov/reactors/operating/ops-experience/buried-pipe-ti-phase-2-insp-req-2011-11-16.pdf were submitted to NRC headquarters staff.  b. Findings  No findings were identified  4OA6 Meetings, Including Exit  On January 10, 2013, the inspectors presented the inspection results to  Mr. Tom Dougherty, Site Vice President, and other members of the LGS staff.  The inspectors verified that no proprietary information was retained by the inspectors  or documented in this report.  ATTACHMENT: SUPPLEMENTARY INFORMATION 
A-1  Attachment  SUPPLEMENTARY INFORMATION  KEY POINTS OF CONTACT  Licensee Personnel  T. Dougherty, Site Vice President D. Lewis, Plant Manager  R. Kreider, Director of Operations D. Doran, Director of Engineering F. Sturniolo, Director of Maintenance J. Hunter, Director of Work Management K. Kemper, Security Manager R. Dickinson, Manager, Regulatory Assurance J. Karkoska, Manager, Nuclear Oversight R. Ruffe, Training Director M. Gillin, Shift Operations Superintendent. Manager, Engineering Systems M. Bonifanti, Manager, ECCS Systems G. Budock, Regulatory Assurance Engineer D. Molteni, Licensed Operator Requalification Training Supervisor M. DiRado, Manager, Engineering Programs    T. Kan, License Coordinator J. Risteter, Radiological Technical Manager L. Birkmire, Manager, Environmental S. Gamble, Regulatory Assurance Engineer K. Nicely, Exelon Corporate Regulatory Assurance N. Harmon, Senior Technical Specialist R. Woolverton, System Manager M. McGill, Senior Engineer  C. Boyle, Instrument Chemist P. Imm, Radiological Engineering Manager      LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED  Opened/Closed  05000353/2013-005-01 FIN Failure to Properly Plan Work for Failed Airlock Door Magnetic Switch (Section 4OA3.1)  Opened  None. 
A-2  Attachment  Closed  05000353/2013-002-00 LER Inoperable Reactor Enclosure Secondary Containment Integrity Due to Open Airlock (Section 4OA3.1)  05000352,353/2013-002-00 LER Condition That Could Have Prevented Fulfillment of the Offsite Power Safety Function (Section 4OA3.2)        LIST OF DOCUMENTS REVIEWED  Section 1R01: Adverse Weather Protection  Procedures SE-9, Preparation for Severe Weather, Revision 31 OP-AA-108-111-1001, Severe Weather and Natural Disaster Guidelines, Revision 12 SY-AA-101-146, Severe Weather Preparation and Response, Revision 0  Miscellaneous Severe Weather  Tornado Watch forecasted by National Weather Service, October 7, 2013, 9:00 a.m.  5:00 p.m. Limerick OCC Logs, October 7, 2013  Section 1R04: Equipment Alignment  Issue Reports 1564080 1554192 1457192 1233147 1182212 1561625 1561176 1572132 642008 620861  Procedures ST-6-055-230-2, HPCI Pump Valve and Flow Test, Revision 73 OP-AA-108-115, Operability Determinations (CM-1), Revision 11 OP-AA-108-115-1002, Supplemental Consideration for On-shift Immediate Operability Determinations (CM-1), Revision 2 ST-6-055-230-2, HPCI Pump, Valve, and Flow Test, Revision 73 ST-6-055-321-2, HPCI Operability Verification, Revision 21 ST-2-055-100-2, HPCI Logic System Functional Simulated Automatic Actuation, Revision 11  Miscellaneous R1141166 Limerick Generating Station Protected System and Barrier Report, 10/14/13  Section 1R05: Fire Protection  Issue Reports 1566587 779739 1568364 1588352   
A-3  Attachment  Procedures OP-LG-102-106, Operator Response Time Program at Limerick Station, Revision 2 OP-AA-201-001, Fire Marshall Tours, Revision 5 SE-8, Fire, Revision 049 SE-8 Appendix 1, Fire Hard Card, Revision 0 ST-6-022-551-0, Fire Drill, Revision 10 F-A-449, LGS Pre-Fire Plan, Common, Unit 1 Cable Spreading Room, Revision 13  Miscellaneous FSSG-3045E, U1 (U2) Fire Area 045E Fire Guide CRD Hydraulic Equipment Area and Neutron  LF-0016-045E, Fire Area 045E Fire Safe Shutdown Analysis, Revision 0 F-R-402, Fire Area 45 Pre-Fire Plan, Revision 16 F-A-435, Fire Area 13 Pre-Fire Plan, Revision 13  Section 1R06: Flood Protection Measures  Issue Reports 1515259 1506355  Procedures SE-4-1, Reactor Enclosure Flooding, Revision 8 ARC-MCR-216, RCIC Pump Room Flood, Revision 1 ARC-MCR-117, HPCI Pump Room Flood, Revision 1 SE-4-1, Reactor Enclosure Flooding, Revision 8  Miscellaneous A16110225 B-130-VC-00002, Report M-003 Summary of Requirements for Flooding, Sht. 001, Revision 0000 C0247913 A1909257 UFSAR Section 3.6, Protection Against Dynamic Effects Associated with Postulated Rupture of Piping Limerick Generating Station, Individual Plant Examination  Section 1R07: Heat Sink Performance  Issue Reports 1569110 1564625  Procedures RT-2-012-391-2, 2B-E205 RHR Heat Exchanger Heat Transfer Test, Revision 007  Miscellaneous M-0051, Sht. 8 A1925367   
A-4  Attachment  Section 1R11: Licensed Operator Requalification Program  Procedures TQ-AA-155, Conduct of Simulator Training and Evaluation, Revision 2  Section 1R11: Licensed Operator Performance  Procedures GP- ARC-MCR-125 BI, Revision 10  Section 1R12: Maintenance Effectiveness  Issue Reports 1568795 1395808 1276176 1569198 791944 367586 840421 728581 839237 844130 1052796 1573005 1546800 1365093 1496636 1510281  Procedures ER-AA-300, M.O.V. Program Administrative Procedure, Revision 6 ER-AA-302-1006, M.O.V. Maintenance and Testing Guideline, Revision 12 ER-AA-302, M.O.V. Program Engineering Procedure, Revision 5 ER-LG-302-1000, Limerick Specific MOV Program Document, Revision 0 LS-AA-120, Issue Identification and Screening Process, Revision 15 ER-AA-310-1005, Maintenance Rule  Dispositioning Between (a)(1) and (a)(2), Revision 6 ER-AA-600-1042, On-Line Risk Management, Revision 5  Miscellaneous R0841468 R0841467 R0841469 A1685772 C08002166 C0232867 PM 357110 PM 357149 R1032412 DBD L-S-03, High Pressure Coolant Injection, Revision 19 LGS-PRA-005.01, LGS PRA, HPCI System Notebook  Section 1R13: Maintenance Risk Assessments and Emergent Work Control  Issue Reports 1542786 1572412 1434804 1408218 217947 1517229  Procedures WC-AA-101, On-Line Work Control Process, Revision 20 WC-AA-104, Integrated Risk Management, Revision 20 OP-AA-108-111-1001, Severe Weather and Natural Disaster Guidelines, Revision 11 ST-6-055-230-1, HPCI Pump Valve and Flow Test, Revision 79 RT-6-055-340-1, HPCI Turbine Hydraulic Control System Operability Check, Revision 13 
A-5  Attachment  ER-AA-1200, Critical Component Failure Clock, Revision 10 ST-2-074-627-1, Functional Check of Average Power Range Monitor 2 average power range monitor (APRM 2), Revision 15 ST-2-074-100-1, Logic System Functional Test of RPS APRM 2-Out-of-4 Voter, Revision 7 IC-11-00740, Calibration and Alignment of Numac Power Range Neutron Monitor, Revision 12 G-080-VC-00052, Numac 2/4 Logic Module O&M Manual ARC-MCR-108 A5, OPRM/APRM Trouble, Revision 5 WC-AA-101-1006, On-Line Risk Management and Assessment, Revision 0 WC-LG-101-1001, Guideline for the performance of On-Line Work/On-Line System Outages, Revision 22 ST-2-055-100-2, HPCI Logic System Functional Simulated Automatic Actuation, Revision 11  Miscellaneous C0236073 R1164521 C0217605 A1558170  Section 1R15: Operability Determinations and Functionality Assessments  Issue Reports 1564080 1554192 1457192 1233147 1182212 1561625 1561176 1569198 791944 367586 840421 728581 839237 844130 1052796  Procedures ST-6-055-230-2, HPCI Pump Valve and Flow Test, Revision 73 OP-AA-108-115, Operability Determinations (CM-1), Revision 11 OP-AA-108-115-1002, Supplemental Consideration for On-shift Immediate Operability Determinations (CM-1), Revision 2 LS-AA-120, Issue Identification and Screening Process, Revision 15 ER-AA-310-1005, Maintenance Rule  Dispositioning Between (a)(1) and (a)(2), Revision 6 ER-AA-600-1042, On-Line Risk Management, Revision 5 RT-3-042-640-1, Fuel Channel Distortion Monitoring, Revision 22 NF-AB-730, Cell Friction Computations Using FORCE 01P, Revision 1  Miscellaneous A1685772 C08002166 C0232867 PM 357110 PM 357149 R1032412 DBD L-S-03, High Pressure Coolant Injection, Revision 19 LGS-PRA-005.01, LGS PRA, HPCI System Notebook  Section 1R18: Modifications  Miscellaneous 50.59 Evaluation for Replacement of 2A Low Pressure Turbine Exhaust Hood Replacement Modification 
A-6  Attachment  ECR LG12-00482 package containing Reasons for Modification, Modification Design and Analyses, Vendor Recommendations, Work-Order, and other supporting documentation  Section 1R19: Post-Maintenance Testing  Issue Reports 1572132 1323527 1551106 1368737 1572412  Procedures ST-6-048-230-1, SLC Pump, Valve, and Flow Test, Revision 41 ST-2-074-629-1, Functional Check of Average Power Range Monitor 4 (APRM 4), Revision 13 ST-6-049-230-2, RCIC Pump, Valve and Flow Test, Revision 72  Miscellaneous R114166 A1723650, Evaluation to use non-safety related component in HPCI system flow controller A1912629, Evaluation is for preventive maintenance frequency evaluation for Bailey controllers A1928421 C0250043 R1121514 M1931754 A1929819  Section 1R22: Surveillance Testing  Issue Reports 1573485 1573565 1573854  Procedures ST-2-052-802- WC-AA-111, Surveillance Program Requirements, Revision 4 ST-2-055-100-2, HPCI Logic System Functional Simulated Automatic Actuation, Revision 11  Calculations M-55-38, CST Vortex Limit for HPCI/RCIC Operation, Revision 1 M-55-33, HPCI/RCIC Automatic Pump Suction Transfer Relay Timer, Revision 6  Miscellaneous R1232776 Test Results Evaluation, ST-2-052-802-1 on 10/17/13    -- ---     
A-7  Attachment          -- --- --      -  -  -- --- -- -- -- -- --- --            -- --- --- -- --     
A-8  Attachment          --- -- --- --- --- --- --- ---      -    -- --- --- --- --- --- ----      -            - 
A-9  Attachment      1439284 1480323 1507365 1557701 1559494 1559499 1559507 1563120 1563125 1563130 1566317 1566319 1185865 1346780 1297766 1292570 1089111 1596364  Miscellaneous (a)(1) Action Plan Development and Action Plan for Emergency Diesel Generators and Auxiliaries/System 092A/ Function 92A-01, dated 9/13/13 J.C. Wachel and J.D. Tison, Vibrations in Reciprocating Machinery and Piping Systems, 1988 EDG 24 Vibration Data, dated 6/22/13, 5/1/13 and 5/12/13 EDG 23 Vibration Data, dated 5/1/13 EDG 12 Vibration Data, dated 5/11/13 EDG 21 Vibration Data, dated 6/24/13 RHRSW System Health Report, 3rd Quarter 2013 S11.1A, ESW System Startup, Revision 33 S12.1.A, RHR Service Water System Startup, Revision 52 RT-2-011-252- RT-2-011-251- M-012, P&ID  Emergency Service Water/RHR SW Overview, Revision 9 LM-0383, Post LOCA Spray Pond Performance Analysis, Revision 8 DCP-11-00539, SPARTA Version 4.10 DTSQA Documentation, Revision 0    Program Documents ER-AA-1003, Buried and Raw Water Corrosion Program Performance Indicators Revision 4 ER-AA-5400, Buried Piping and Raw Water Corrosion Program BPRWCP Guide, Revision 5 ER-AA-5400-1002, Underground Piping and Tank Examination Guide- provides management of aging effects on piping and tanks, Revision 5 ER-AA-335-004, Ultrasonic (UT) Measurement of Material Thickness and Interfering Conditions, Revision 6  Miscellaneous Documents NRC Temporary Instruction 2515/182, Issue 11/17/11 and 8/8/13; Review of the Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks NEI 09-14 Initial Issue, November 2009 Guideline for the Management of Underground Piping and Tank Integrity NEI 09-14, December 2010 Guideline for the Management of Underground Piping and Tank Integrity, Revision 1 NEI 09-14, Guideline for the Management of Underground Piping and Tank Integrity, Revision 3 EPRI-2010-409, Inspection Methodologies for Buried Piping and Tanks CEP-UPT-0100, Underground Piping and Tanks Inspection and Monitoring, Revision 1 CEP-BPT-0100, Buried Piping and Tanks Inspection and Monitoring, Revision 0 SEP-UIP-VTY, Underground Components Inspection Plan, Revision 4 EN-DC-343, Nuclear Management Manual, Underground Piping and Tanks Inspection and Monitoring Program, Revision 8 National Association of Corrosion Engineers SPO 169-2007 Control of External Corrosion on Underground or Submerged Metallic Piping Systems-Standard Practice 
A-10  Attachment  2013 Buried Piping Inspections (11/20/2012) Examination Test Results of Selected Piping Non-Destructive Test Samples System Health Reports for Circ Water, 009 Unit 2, Circ Water 009 Unit 1 and RHRSW 012 Common to Reflect Programmatic Health AM1765-371360, RHR Service Water Line 30 inch Guided Wave Ultrasonic Exam  C0247746-13 Ultrasonic Examination Report Raw Water System (wall thickness) C0247745 Visual Inspection of Heating Steam Buried and Underground Piping    LIST OF ACRONYMS  ADAMS  Agency wide Documents Access and Management System            CFR  Code of Federal Regulations CRD  Control Rod Drive CY  Calendar Year EDG  Emergency Diesel Generator ESW  Emergency Service Water        -    IMC  Inspection Manual Chapter IR  Issue Report        NEI    NRC  Nuclear Regulatory Commission NUREG  NRC Technical Report Designation                          RHRSW  Residual Heat Removal Service Water        -  SSC  Structure, System, or Component TS  Technical Specifications UFSAR    Updated Final Safety Analysis Report
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