IR 05000352/2013004

IR 05000352-13-004 and 05000353-13-004, July 1, 2013 - Sept 30, 2013, Limerick Generating Station, Integrated Inspection

ML13318A928
Person / Time
Site:	Limerick
Issue date:	11/14/2013
From:	Fred Bower Reactor Projects Region 1 Branch 4
To:	Pacilio M Exelon Generation Co, Exelon Nuclear
BOWER, FL
References
IR-13-004
Download: ML13318A928 (36)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ber 14, 2013

SUBJECT:

LIMERICK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000352/2013004 AND 05000353/2013004

Dear Mr. Pacilio:

On September 30, 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 October 11, 2013, 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 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.

This report documents two NRC-identified and one self-revealing findings of very low safety significance (Green). Two of these findings were determined to involve violations of NRC requirements. However, because of the very low safety significance, and because they are entered into your corrective action program, the NRC is treating these findings a non-cited violations (NCVs), consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest the NCVs in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at LGS. In addition, if you disagree with the cross-cutting aspect assigned to the finding 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 LGS.

In accordance with 10 Code of Federal Regulations (CFR) 2.390 of the NRCs 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 component of the NRCs Agencywide Documents Access 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/

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 05000352/2013004 and 05000353/2013004 w/Attachment: Supplemental Information

REGION I==

Docket Nos.: 50-352, 50-353 License Nos.: NPF-39, NPF-85 Report No.: 05000352/2013004 and 05000353/2013004 Licensee: Exelon Generation Company, LLC Facility: Limerick Generating Station, Units 1 & 2 Location: Sanatoga, PA 19464 Dates: July 1, 2013, through September 30, 2013 Inspectors: E. DiPaolo, Senior Resident Inspector J. Hawkins, Resident Inspector D. Aird, (Acting) Resident Inspector R. Nimitz, Senior Health Physicist J. Laughlin, Emergency Preparedness Inspector Approved By: Fred Bower, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

Inspection Report 05000352/2013004; 05000353/2013004; 07/01/2013-09/30/2013; Limerick

Generating Station, Units 1 and 2; Equipment Alignment, Maintenance Risk Assessments and Emergent Work Control, and Operability Determinations and Functionality Assessments.

This report covered a three-month period of inspection by resident inspectors, an announced inspection performed by a regional inspector, and an in-office review by a headquarters inspector. One self-revealing and two NRC-identified findings of very low safety significance (Green) were identified. Two of the findings involved violations of regulatory requirements and were determined to be non-cited violations (NCVs). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC)0609, Significance Determination Process(SDP), dated June 2, 2011. The cross-cutting aspects for the findings were determined using IMC 0310, Components Within The Cross-Cutting Areas, dated October 28, 2011. Findings for which the SDP does not apply may be Green, or be assigned a severity level after Nuclear Regulatory Commission (NRC)management review. All violations of NRC requirements are dispositioned in accordance with NRCs Enforcement Policy, dated January 28, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process (ROP), Revision 4, dated December 2006.

Cornerstone: Initiating Events

Green.

A self-revealing finding of very low safety significance was identified for Exelons failure to take adequate and timely corrective actions to address the inadvertent depressurization of the Unit 1 Instrument Air (IA) headers. This led to a repeat depressurization of the Unit 1 IA headers when the service air compressor tripped on July 7, 2013, causing the operators to enter ON-119, Loss of Instrument Air, and reduce reactor power by 20 percent until IA header pressure could be restored and maintained. Exelons corrective actions for this issue included replacing all of the IA dryer pre-filters, creating an activity to perform dryer performance monitoring prior to any IA maintenance outage, and recalibrating all of the IA dryer pre-filter differential pressure (D/P) switches. Exelon was also in the process of evaluating a replacement component for the IA dryer D/P switches and investigating the effectiveness of the prioritization of their maintenance backlog strategy. Exelon has entered this issue into their corrective action program (CAP) as Issue Report (IR) 1569901.

Exelons corrective actions to address the inadvertent depressurization of the Unit 1 IA headers on October 9, 2012, were ineffective and untimely, representing a performance deficiency that was within their ability to foresee and correct. This performance deficiency was determined to be more than minor because it affected the Equipment Performance attribute of the Initiating Events cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, unnecessary transients on the IA header increase the likelihood of a loss of IA, an unplanned down power or a potential rapid plant shutdown due to plant instability. The finding is of very low safety significance (Green) per IMC 0609, Appendix A,

Exhibit 1 - Initiating Events Screening Questions, because it did not involve the complete or partial loss of a support system that contributes to the likelihood of, or cause, an initiating event and affected mitigation equipment. The finding had a cross-cutting aspect in the area of Human Performance, Resources, because Exelon did not ensure that personnel, equipment, procedures, and other resources were adequate to assure nuclear safety.

Specifically, Exelon did not adequately maintain engineering and maintenance backlogs to support safety, which led to IRs (1426043 and 1426045) to check the operation of the Unit 1 IA dryer pre-filter D/P switches not being performed in a timely manner H.2(a). Exelon did not complete work associated with these IRs and failed to utilize internal operating experience concerning the creation of a time-based preventative maintenance (PM) in order to replace the pre-filters and functionally check the D/P switches prior to conducting maintenance. (Section 1R04)

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green NCV of Technical Specification (TS) 6.8.1.a,

Procedures and Programs, for Exelons failure to implement surveillance test procedures specified for the Primary Containment Instrument Gas (PCIG) system as required by Regulatory Guide (RG) 1.33, Quality Assurance Program Requirements. Specifically,

Exelons PCIG local leak rate procedures, ST-4-LLR-011-2 and ST-4-LLR-241-2, incorrectly credited the surveillance testing of the PCIG supply header B check primary containment isolation valve (059-2005B) in ST-6-059-201-2 PCIG Valve Test which resulted in entry into TS 4.0.3 for a missed surveillance. Exelons corrective actions included an extent of condition review and revising PCIG check valve surveillance testing to correct the crediting of the wrong check valves due to the successful completion of Local Leak Rate Testing (LLRT). Exelon has entered this issue into their CAP as IR 1554992 and 1569903.

The failure to perform the surveillance requirements specified for the PCIG system, specifically, incorrectly crediting the surveillance testing of PCIG check valve 059-2005B which resulted in a missed surveillance, is a performance deficiency. The performance deficiency was determined to be more than minor, because it adversely affected the Procedure Quality attribute of the Mitigating Systems cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences.

Specifically, Exelon failed to ensure that the PCIG system surveillance testing adequately tested and credited the successful completion of LLRT. The finding is of very low safety significance (Green) per IMC 0609, Appendix A, Exhibit 2 - Mitigating Systems Screening Questions, because the PCIG system was determined to maintain its operability and functionality, does not represent a loss of system and/or function and does not represent an actual loss of function of a single train for greater than its TS allowed outage time. The inspectors determined that the finding had a cross-cutting aspect in the area of PI&R, CAP, because Exelon did not thoroughly evaluate problems such that resolutions address causes and extent of conditions, including properly classifying, prioritizing, fully evaluated, and that actions are taken to address safety issues in a timely manner, commensurate with their safety significance P.1(c). Specifically, Exelon personnel did not adequately address, thoroughly evaluate, and prioritize IR 1498740 which documented potential deficiencies with Unit 2 PCIG check valve testing, in a timely manner. (Section 1R13)

Green.

The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, associated with Exelon staffs failure to correct a condition adverse to quality (CAQ) associated with defective material being reinstalled into a safety-related system after the component failed.

Specifically, Exelons corrective actions to address the defective material issues in both

Apparent Cause Evaluation (ACE) IR 900755 and Equipment Apparent Cause Evaluation (EACE) IR 1365093 did not prevent the installation of a previously failed circuit board into a safety-related system. This circuit board ultimately failed again, causing operators to declare the Redundant Reactivity Control System (RRCS) inoperable. Exelons corrective actions included revising procedural guidance for RRCS channel-checks, utilizing an alert system for continuous performance monitoring of al RRCS system parameters, conducting an extent of cause for all existing RRCS out-of-band log entries, revising the maintenance strategy to use new RRCS cards and a time-directed PM to replace failed or old cards and benchmarking the industry maintenance strategy for RRCS. Exelon is also revising material receipt procedures, training all warehouse personnel on the receipt inspection process and performing extent of conditions of all other repairable stock codes. Exelon has entered this issue into their CAP as IR 1569907.

The inspectors determined that Exelons corrective actions to address a CAQ associated with defective material issues in both ACE IR 900755 and EACE IR 1365093, was a performance deficiency that was within their ability to foresee and correct, and should have been prevented. The performance deficiency was determined to be more than minor because it affected the Procedure Quality and Human Performance attributes of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Further, if left uncorrected, the performance deficiency could have the potential to lead to a more significant safety concern. The performance deficiency was also similar to IMC 0612, Appendix E, example 4.g, in that Exelons corrective actions were inadequate and failed to correct a CAQ. The finding is of very low safety significance (Green) per IMC 0609, Appendix A, Exhibit 2 - Mitigating Systems Screening Questions, because RRCS was determined to maintain its operability and functionality, does not represent a loss of system and/or function and does not represent an actual loss of function of a single train for greater than its TS allowed outage time. The finding had a cross-cutting aspect in the area of PI&R, CAP, because Exelon did not take the appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with the safety significance P.1(d). Specifically, Exelon did not take appropriate corrective actions to address the use of new RRCS circuit boards and did not ensure the corrective actions for the D23 Emergency Diesel Generator (EDG) rectifier failure would ensure all failed components that are sent to the vendor for analysis and sent back to the site with no failure mode were evaluated by engineering prior to re-installation. (Section 1R15)

Other Findings

None.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at 100 percent power. During the inspection period, power was periodically lowered during periods of high condensate temperature due to environmental conditions (i.e., high outside temperature). On July 7, while at 98 percent power due to high condensate temperature, operators conducted an unplanned power reduction to approximately 80 percent due to lowering IA header pressure caused by the trip of an in-service air compressor combined with IA dryer filter high differential pressure. Following restoration of IA header pressure, operators returned power to 100 percent later that day. On September 15, 2013, operators conducted a planned power reduction to approximately 75 percent to facilitate main turbine valve testing, fuel channel distortion testing, and a control rod pattern adjustment.

Operators returned power to 100 percent on September 16. Operations conducted another planned power reduction to approximately 90 percent on September 29, to facilitate control rod scram time testing. Following testing, operators returned Unit 1 power to 100 percent later that day. The unit remained at or near 100 percent power for the remainder of the inspection period.

Unit 2 began the inspection period at 100 percent power. During the inspection period, power was periodically lowered during periods of high condensate temperature due to environmental condition (i.e., high outside temperature). On September 8, operators conducted a planned power reduction to approximately 82 percent to facilitate main turbine valve testing, control rod scram time testing, and a control rod pattern adjustment. Operators returned power to 100 percent on September

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Readiness for Seasonal Extreme Weather Conditions (71111.01 - 1 sample)

a. Inspection Scope

The inspectors performed a review of Exelons readiness for the onset of seasonal high temperatures. The review focused on the offsite and onsite power systems. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), TS, control room logs, and the corrective action program to determine what temperatures or other seasonal weather could challenge these systems, and to ensure Exelons personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including Exelons seasonal weather preparation procedure 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 hot weather conditions. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

EDG 22 when EDG 24 was unavailable due to maintenance on July 17, 2013 0B-V118 emergency switchgear and battery room fan when running the A control enclosure chiller (IR 1545221)

Residual heat removal service water and emergency service water spray pond pump house system alignment on August 29, 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, IRs, 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 plan for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

.2 Full System Walkdown

a. Inspection Scope

The inspectors performed a complete system walkdown of accessible portions of the Units 1 and 2 instrument and service air systems following the trip of the service air compressor and resultant IA header depressurization (IR 1533093) to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required functions. The inspectors also reviewed electrical power availability, equipment cooling, and the operability of support systems.

The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related IRs and work orders to ensure Exelon staff appropriately evaluated and resolved any deficiencies.

b. Findings

Inadequate and Untimely Corrective Actions Associated With the Unit 1 Instrument Air System

Introduction.

A self-revealing finding of very low safety significance was identified for Exelons failure to take adequate and timely corrective actions to address the inadvertent depressurization of the Unit 1 IA headers. This led to a repeat depressurization of the Unit 1 IA headers when the service air compressor tripped on July 7, 2013, causing the operators to enter ON-119, Loss of IA, and reduce reactor power by 20 percent until IA header pressure could be restored and maintained.

Description.

The design of the Exelon IA and service air systems includes two identical IA trains with each having its own supply header that can be interconnected through a common connection line. Each IA train consists of an air intake filter, a compressor, an after-cooler, an air receiver, two parallel pre-filters, a dryer and two parallel after-filters.

The service air compressor serves as a backup to the IA compressors. The consequences of a failure of one IA train is mitigated by the redundant nature of the IA system in that each IA header is connected to both of the IA trains and is able to be supplied by the operative IA train. The dual drying towers of each IA train dryer package (only one pre-filter/after-filter is normally in service) alternately remove moisture from the air in the system. When the in service filters become dirty, as indicated on the control panel by D/P switch and alarm in the control room as part of the dryer trouble alarm, the air flow is manually switched by operators to the clean pre-filter/after-filter.

On October 9, 2012, operators documented Unit 1 A IA dryer trouble alarm conditions due to uncontrolled swapping of the in-service dryer in IR 1424166. Due to this issue, Exelon added the alarm condition to their priority work list and while attempting to remove the 1 A IA dryer from service for troubleshooting, both IA header pressures lowered below the alarm set point of 85 psig causing operators to enter ON-119.

Operators restored IA header pressure and documented in IR 1424943 that they suspected one of the pre-filter D/P switches was broken and that a clogged pre-filter was causing the issues with maintaining IA header pressure. Exelon documented multiple IRs (1426043 and 1426045) to check the operation of the Unit 1 A and B IA dryer pre-filter D/P switches. These IRs were never completed because the work orders were incorrectly coded and backlogged in the stations maintenance strategy due to a human performance error. The inspectors determined that no IR was written at the time to address the potentially clogged IA dryer pre-filter.

On July 7, 2013, operators had tagged out the Unit 1 B IA compressor for maintenance.

With the service air compressor supplying the B IA header, the service air compressor tripped. Both IA headers lowered to 80 psig before the service air compressor was restarted, restoring pressure in both IA headers. During depressurization of the IA headers, operators entered ON-119 and reduced reactor power as directed by the procedure. Power was reduced by a total of 20 percent.

Exelons ACE (IR 1533093) determined that the service air compressor trip was caused by the compressors cooling water temperature switch being out of calibration due to unexpected instrument drift. The cause of the A IA compressors inability to supply the IA system during the service air compressor trip was due to the in-service IA dryer pre-filter being partially clogged. Exelon determined that the inability of the IA system to identify the clogged pre-filter was due to the pre-filter D/P switches not indicating the filter obstruction. The ACE found that these pre-filter D/P switches are only found to be in calibration (or reliable) 37 percent of the time.

Exelons evaluation determined that: 1. The design of the IA dryer pre-filter D/P switches is ineffective at identifying clogged filters; 2. The IA pre-filters, like the after-filters, should have a time-directed PM task for replacement based on system trending and vendor recommendations; 3. IR 1424166 from October 9, 2012, to check the operation of the 1 A and 1B IA dryer pre-filter D/P switches was incorrectly prioritized and never worked or investigated, and; 4. Previous internal operating experience was not utilized to create a time-based PM task in order to replace the pre-filters and functionally check the D/P switches prior to conducting maintenance.

The inspectors reviewed applicable IRs related to the IA and service air system, vendor documents, and the completed ACE. The inspectors also conducted a complete IA system walk down. The inspectors found that the IA dryer vendor manual recommends semi-annual inspection of the IA dryer pre-filter cartridges. In addition to Exelons evaluation, the inspectors determined that if trending of the IA dryer pre-filter replacements had occurred, the site should have had a basis for implementing a time-directed PM task to replace these filters vice a condition-based replacement using the D/P switches as an indicator.

Exelons corrective actions for this issue included replacing all of the IA dryer pre-filters, created an activity to perform dryer performance monitoring prior to any IA maintenance outage, and recalibrated all of the IA dryer pre-filter D/P switches. Exelon was also in the process of evaluating a replacement component for the IA dryer D/P switches and was investigating the effectiveness of the prioritization of their maintenance backlog strategy.

Analysis.

The inspectors determined that Exelons ineffective and untimely corrective actions to address the inadvertent depressurization of the Unit 1 IA headers on October 9, 2012, resulted in a repeat depressurization of the Unit 1 IA headers when the service air compressor tripped on July 7, 2013. The ineffective and untimely implementation of corrective actions for this prior occurrence was a performance deficiency (PD) that was within Exelons ability to foresee and correct. This caused the operators to enter ON-119, Loss of IA, and reduce reactor power by 20 percent until IA header pressure could be restored and maintained. Exelon has entered this issue into their CAP as IR 1569901. This PD was determined to be more than minor because it affected the Equipment Performance attribute of the Initiating Events cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, unnecessary transients on the IA header increase the likelihood of a loss of IA, an unplanned down power or a potential rapid plant shutdown due to plant instability. The finding is of very low safety significance (Green) per IMC 0609, Appendix A, Exhibit 1 - Initiating Events Screening Questions because it did not involve the complete or partial loss of a support system that contributes to the likelihood of, or cause, an initiating event and affected mitigation equipment.

The finding had a cross-cutting aspect in the area of Human Performance, Resources, because Exelon did not ensure that personnel, equipment, procedures, and other resources were adequate to assure nuclear safety. Specifically, Exelon did not adequately maintain engineering and maintenance backlogs to support safety, which led to IRs (1426043 and 1426045) to check the operation of the Unit 1 IA dryer pre-filter D/P switches not being performed in a timely manner H.2(a). Exelon did not complete work associated with these IRs and failed to utilize internal operating experience concerning the creation of a time-based preventative maintenance (PM) in order to replace the pre-filters and functionally check the D/P switches prior to conducting maintenance.

Enforcement.

There were no violations of regulatory requirements because IA is not safety-related. Exelon entered this issue into their CAP as 1569901. (FIN

===05000352/2013004-01: Inadequate and Untimely Corrective Actions Associated With the Unit 1 Instrument Air System)

1R05 Fire Protection

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 personnel 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.

Fire Area 2 - 13.2kV Switchgear and Battery Rooms, Rooms 336, 360, 361, 323, and 324 [F-A-336] on July 16, 2013 Fire Area 65 - Unit 2 Safeguard System Access Area, Rooms 279 and 287 [F-R-279] on July 31, 2013 IR 1556863, Fire Area 42A (CALC LF-008 Impairment/PR-65), Unit 1 SFGD System Access Area Room 200 and 209 on September 13, 2013 Fire Area 118 - Radioactive Waste Building Rooms 213, 227 - 248 [F-W-213] on September 25, 2013 Fire Area 116, Radioactive Waste Building Rooms 122 - 149 and 152 [F-W-122] on September 25, 2013

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review

a. Inspection Scope

The inspectors observed a graded simulator scenario for operating crew E on September 9, 2013. The scenario included an invalid containment isolation, an anticipated transient without a scram, and complications due to failures of safety systems. 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 classifications made by the shift manager. 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 licensed operator performance in the main control room during the period of September 7-8, 2013. The inspectors observed operator performance during the Unit 2 planned power reduction for main turbine valve testing, control rod scram time testing, and control rod pattern adjustment. The inspectors verified operator compliance and use of plant procedures, performance of procedure steps in the proper sequence, alarm response card response and proper TS usage. Pre-job briefs, the use of human error prevention techniques, communications between crew members, and supervision of activities were observed to verify that they were performed consistent with established plant practice.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, or component (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 personnel 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 personnel was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.

Unit 1 high pressure coolant injection system performance review and a(2)determination on July 10, 2013 Unit 2 emergency diesel generator performance review and Maintenance Rule a(1)determination on July 24, 2013 IR 1533093, IA (Unit 1 and Unit 2 IA/service air) system performance review due to service air compressor trip and instrument air header depressurizations on July 7, 2013

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

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 staff 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 staff 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 the assessment with the stations 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.

On-line risk profile on July 3, 2013, with the 20 auxiliary transformer unavailable due to failure of the transformer automatic voltage changer On-line risk profile on August 2, 2013, during replacement of the Unit 2 C safeguard battery On-line risk profile and risk assessment (IR 1554992) on September 6, 2013, for missed surveillance for reverse flow testing of PCIG check valve 59-2005B On-line risk change on September 11, 2013, due to Maximum Emergency Generation Action

b. Findings

Failure to Perform Technical Specification Surveillance Requirements on the Unit 2 Primary Containment Instrument Gas (PCIG) System

Introduction.

The inspectors identified a Green NCV of TS 6.8.1.a, Procedures and Programs, for failure to implement surveillance test procedures specified for the PCIG system as required by RG 1.33, Quality Assurance Program Requirements.

Specifically, Exelons PCIG local leak rate procedures, ST-4-LLR-011-2 and ST-4-LLR-241-2, incorrectly credited the surveillance testing of the PCIG supply header B check primary containment isolation valve (059-2005B) in ST-6-059-201-2, PCIG Valve Test, which resulted entry into TS 4.0.3 for a missed surveillance.

Description.

The design of the Exelon PCIG system is to provide instrument gas to the pneumatic devices located inside the drywell and suppression chamber as well as supply instrument gas for long-term Automatic Depressurization System (ADS) valve operation. The PCIG system takes suction directly from the drywell atmosphere preventing the build-up of pressure in containment. Check valve 059-2005B prevents reverse flow of instrument gas from the PCIG drywell supply header in the event of a loss of supply pressure or line break outside of containment. Exelon performs multiple surveillance tests of the PCIG system on a frequency of 2 years to verify the operability of the PCIG check valves in ADS accumulator charging lines.

During a system extent of condition review related to the adequacy of testing of Instrument Air (IA) system check valves on September 5, 2013, the inspectors identified an IR 1498740 written on April 7, 2013, documenting potential deficiencies with Unit 2 PCIG check valve testing. The IR recommended the performance of an engineering evaluation. The Operations Shift Manager review of the IR recommended conducting a review of past surveillance tests to determine if testing methodology was adequate or the potential for missed surveillances existed. The inspectors reviewed the CAP assignments for IR 1498740 and determined that no action had been taken to verify the testing requirements of PCIG system check valves and that no engineering evaluation had been performed as recommended by operations staff. Because the potential for missed surveillances still existed, the inspectors questioned both operations and engineering on September 5, 2013, as to the status of this recommended engineering evaluation and review of past surveillances.

Exelon conducted a detailed review of all PCIG surveillance testing to ensure all PCIG system check valves for both units (21 in all) were properly tested in both the forward and reverse direction. On September 6, 2013, Exelon initiated IR 1554992 for check valve 059-2005B not being tested in the reverse direction. Exelon determined that all Unit 1 and Unit 2 PCIG check valves, with the exception of Unit 2 check valve 059-2005B, had been satisfactorily tested and that no other concerns existed on either unit for any other missed surveillances during past refueling outages. Exelon conducted a risk assessment of the missed surveillance in accordance with TS 4.0.3 requirements which concluded that because this PCIG system line is less than 2 inches in diameter, it did not allow enough leakage to have a significant contribution to releases and that there was minimal risk impact from this missed surveillance.

The inspectors reviewed applicable PCIG surveillance tests, test results, IRs, engineering evaluations and the risk assessment. The inspectors conducted an extent of condition and risk review and determined that Exelons conclusions were adequate and appropriate. Exelons corrective actions included revising PCIG check valve surveillance testing correcting the crediting of check valve testing, due to the successful completion of local leak rate testing.

Analysis.

The failure to perform the surveillance requirements specified for the PCIG system, specifically, incorrectly crediting the surveillance testing of PCIG check valve 059-2005B which resulted in a missed surveillance, is a performance deficiency. Exelon has entered this issue into their CAP as IR 1554992 and 1569903. The performance deficiency was determined to be more than minor, because it adversely affected the Procedure Quality attribute of the Mitigating Systems cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Exelon failed to ensure that the PCIG system surveillance testing adequately tested and credited the successful completion of LLRT. The inspectors determined that this finding was of very low safety significance (Green) per IMC 0609, Appendix A, Exhibit 2 - Mitigating Systems Screening Questions, because the PCIG system was determined to maintain its operability and functionality, does not represent a loss of system and/or function and does not represent an actual loss of function of a single train for greater than its TS allowed outage time.

The inspectors determined that the finding had a cross-cutting aspect in the area of PI&R, CAP, because Exelon did not thoroughly evaluate problems such that resolutions address causes and extent of conditions, including properly classifying, prioritizing, fully evaluated, and that actions are taken to address safety issues in a timely manner, commensurate with their safety significance. Specifically, Exelon did not adequately address, thoroughly evaluate, and prioritize IR 1498740 which documented potential deficiencies with Unit 2 PCIG check valve testing, in a timely manner until questioned by the inspectors during an extent of condition review. P.1(c)

Enforcement.

TS 6.8.1.a requires, in part, that written procedures be implemented, covering applicable procedures recommended in RG 1.33, Revision 2, Appendix A, February 1978. Appendix A, Section 8.b, requires, in part, that procedures be established and maintained for TS surveillance testing. Contrary to the above, between October 26, 2010 and September 5, 2013, Exelons PCIG local leak rate procedures, ST-4-LLR-011-2, Revision 5, and ST-4-LLR-241-2, Revision 8, incorrectly credited the surveillance testing of PCIG supply header B check primary containment isolation valve (059-2005B). Exelon failed to perform surveillance testing specified for the PCIG system as required by TS 4.0.5, Surveillance Requirements for Inservice Inspection and Testing of ASME Code Class 1, 2, and 3 Components, on September 6, 2013.

Exelons corrective actions included an extent of condition review and revising PCIG check valve surveillance testing to correct the crediting of the wrong check valves due to the successful completion of LLRT. Because this violation was determined to be very low safety significance and has been entered into the licensees CAP in IR 1554992 and 1569903, it is being treated as an NCV consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000353/2013004-02, Failure to Perform Technical Specification Surveillance Requirements on the Unit 2 Primary Containment Instrument Gas System)

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:

IR 1531869, 20 bus high voltage alarm on July 2, 2013 IR 1533092, 20 transformer trouble alarm due to load tap changer off tap condition on July 7, 2013 IR 1543898, Incorrect amount of chemical added to EDG D13 jacket water on August 7, 2013 IR 1546800, Unit 1 Division 1 A Redundant Reactivity Control System (RRCS)pressure transmitter indication drift on August 15, 2013 IR 1544561, Unit 1 residual heat removal (RHR) heat exchanger bypass valve control relay timer did not actuate during surveillance testing on August 16, 2013 IR 1498740, Unit 2 PCIG valve test following Unit 2 refueling outage on August 4 through August 6, 2013 IR 1555524, Unit 2 control rod 30-15 scram time to position 45 >90% of TS limit on August 10, 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 completed evaluations 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. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

b. Findings

Failure to Correct a Condition Adverse to Quality associated with Defective Material Being Reinstalled into a Safety-Related System

Introduction.

The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, associated with Exelon staffs failure to correct a CAQ associated with defective material being reinstalled into a safety-related system without repair after the component failed. Specifically, Exelons corrective actions to address the defective material issues in both ACE IR 900755 and EACE IR 1365093 did not prevent the installation of a previously failed circuit board into a safety-related system. This circuit board ultimately failed again, causing operators to declare the RRCS inoperable.

Description.

The RRCS is a safety-related, solid-state control logic system designed to provide a redundant and diverse method of shutting down the reactor (i.e. alternate rod insertion, a reactor pump trip, the standby liquid control system or a feed water system runback). Each operating unit contains two RRCS divisions and each division has two channels, A and B. Either division of RRCS can accomplish all functions independently by 2 out of 2 taken once logic to initiate. Each channel of RRCS is automatically tested on-line by a microprocessor based self-test system.

During the week of August 14, 2013, while performing weekly monitoring of Unit 1 RRCS, a decreasing drift was identified on the A RRCS channel pressure indication.

Exelon personnel concluded through troubleshooting efforts that the degraded function of the A channel would impact the ability of RRCS Division 1 to perform its TS required function for high pressure. Operators declared Unit 1 RRCS inoperable and entered the associated 72-hour TS Action. The RRCS Analog Trip Module (ATM) board was determined to be degraded and was replaced with a refurbished board and returned to service on August 15, 2013. The as-left reading of reactor pressure following replacement of the ATM board indicated normal operating conditions. However within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, operators noticed the channel reading starting to drift again, requiring further troubleshooting. The ATM board was once again replaced on August 21, 2013, and the system was restored to service. Additional monitoring was performed for 10 days following the second ATM board replacement, during which the channel reading was consistent to the other channels of RRCS.

Exelon staff conducted an ACE (IR 1546800) and a Quick Human Performance Investigation (QHPI) (IR 1549475) to evaluate the initial ATM board failure and failure of the replacement ATM board, respectively. Exelons ACE determined that degrading conditions associated with the RRCS ATM board did not result in an IR initiation during the TS surveillance test performance and that the maintenance program allowed the use of refurbished boards for replacement when these refurbished boards were known to be unreliable, have a shorter life span, and fail 60 percent of the time. Exelons QHPI determined that procedural gaps existed in the stations receipt of items, management of repairable materials and receipt inspections. The QHPI also identified knowledge gaps with one material handlers understanding of the revisions to the procedures. The procedure revisions required the generation of an IR when a failed component is sent to the vendor for analysis and returned to the site with no failure mode identified. The new procedure required an IR to be generated to have engineering evaluate the returned component prior to re-installation into the plant.

In 2012, Exelon completed an EACE IR 1365093 investigating Unit 2 RRCS issues and determined that when the ATM cards were replaced with refurbished cards versus new cards, the frequency of failures was higher. Even though Exelons EACE determined that the RRCS maintenance strategy allowed the option to replace failed cards with new cards instead of using refurbished cards that may have previously failed, Exelon made the decision not to pursue a time-directed ATM card replacement and did not take corrective actions to replace failed RRCS ATM cards with new cards. The inspectors compared this EACE to ACE 1546800, which recommended the use of new cards for replacement activities based on a review conducted by Exelon of the history of ATM card failures. This review found 10 of 17 RRCS ATM card failures were repeat failures from refurbished cards. The inspectors determined this system history review should have been completed as part of the initial EACE IR 1365093, and represented a missed opportunity to identify and correct a CAQ associated with previously failed refurbished cards being reinstalled into the RRCS.

The inspectors also evaluated Exelons QHPI IR 1549475 conclusions. The inspectors noted that the QHPI discussed the material handlers lack of knowledge of a procedural revision to SM-AA-3010, Managing Repairable Material. The inspectors reviewed the bases behind the procedural revision that was completed in October 2012 and discovered that a similar event concerning safety-related unrepaired material occurred necessitating the procedure change. Specifically, on March 31, 2009, Exelon experienced a failure of the Emergency Diesel Generator (EDG) D23 voltage regulator rectifier bank during testing. This rectifier bank had previously failed in 1997, had been sent out to the vendor for failure analysis with no failure mode identified by the vendor, and was returned to Exelons material inventory. The rectifier was then reinstalled in EDG D23 in 2008. Exelons corrective actions documented in ACE IR 900755 for the EDG D23 failure on March 31, 2009 included developing a method to track parts and subparts that are installed or removed from the plant due to failure and where failure analysis did not identify a defect. Exelons QHPI IR 1549475 concluded, in part, that the receipt inspection check sheets used by the material handler conducting the receipt inspection should have included the requirement to generate an engineering review IR for failed components that are sent to the vendor for analysis and returned to the site with no failure mode identified. The inspectors determined this also represented a missed opportunity to identify and correct a CAQ associated with defective material being reinstalled into a safety-related system after the component failed.

The inspectors reviewed Exelons corrective actions for both the ACE and the QHPI.

Exelons corrective actions included revising procedural guidance for RRCS channel-checks, utilizing an alert system for continuous performance monitoring of all RRCS system parameters, conducting an extent of cause for all existing RRCS out-of-band log entries, revising the maintenance strategy to use new RRCS cards and a time-directed PM to replace failed or old cards and benchmarking the industry maintenance strategy for RRCS. Exelon is also revising material receipt procedures, training all warehouse personnel on the receipt inspection process and performing extent of conditions of all other repairable stock codes.

Analysis.

The inspectors determined that Exelons corrective actions to address a CAQ associated with defective material issues in both ACE IR 900755 and EACE IR 1365093, was a performance deficiency that was within Exelons ability to foresee and correct, and should have been prevented. Exelon has entered this issue into their CAP as IR 1569907. The performance deficiency was determined to be more than minor because it affected the Procedure Quality and Human Performance attributes of the Mitigating Systems cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e.,

core damage). The performance deficiency was also similar to IMC 0612, Appendix E, example 4.g, in that Exelons corrective actions were inadequate and failed to correct a CAQ. The finding is of very low safety significance (Green) per IMC 0609, Appendix A, Exhibit 2 - Mitigating Systems Screening Questions, because RRCS was determined to maintain its operability and functionality, does not represent a loss of system and/or function and does not represent an actual loss of function of a single train for greater than its TS allowed outage time.

The finding had a cross-cutting aspect in the area of PI&R, CAP, because Exelon did not take the appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with the safety significance. Specifically, Exelon did not take appropriate corrective actions to address the use of new RRCS ATM boards and did not ensure the corrective actions for the D23 EDG rectifier failure would ensure all failed components that are sent to the vendor for analysis and sent back to the site with no failure mode were evaluated by engineering prior to re-installation P.1(d).

Enforcement.

10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as defective material are promptly identified and corrected. Contrary to the above, between October 10, 2012 and August 21, 2013, Exelon failed to correct a CAQ associated with defective material being reinstalled into a safety-related system without repair after the component failed. Specifically, Exelons corrective actions to address the defective material issues in both ACE IR 900755 and EACE IR 1365093, did not prevent the installation of a previously failed and unrepaired circuit board into a safety-related system. This circuit board ultimately failed again on August 15, 2013, causing operators to declare the RRCS inoperable. Exelons corrective actions included revising procedural guidance, utilizing continuous performance monitoring, conducting an extent of cause, revising the maintenance strategy for these cards, and benchmarking the industry maintenance strategies. Exelon is also revising material receipt procedures, training all warehouse personnel on the receipt inspection process and performing extent of conditions of all other repairable stock codes. Because this finding is of very low safety significance and has been entered into the CAP as IR 1569907, this violation is being treated as a NCV consistent with Section 2.3.2 of the NRC Enforcement Policy.

(NCV 05000352/2013004-03, Failure to Correct a Condition Adverse to Quality associated with Defective Material Being Reinstalled into a Safety-Related System)

1R18 Plant Modifications

Permanent Modifications

a. Inspection Scope

On September 16, 2013, the inspectors reviewed Engineering Change Request 10-00461 which installed a dewatering system for safety-related electrical manholes. The inspectors performed the review to determine whether the modifications affected the safety functions of the electrical cables located in the manholes that are important to safety. The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results. The inspectors conducted field walkdowns of the modifications to verify that the modification did not degrade the design bases, licensing bases, and performance capability of the affected systems.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

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.

C0248312, Replace 20 regulatory transformer load tap changer automatic voltage changer on July 3, 2103 C0248513, Replace Unit 1 condensate makeup and reject coarse controller on July 22, 2013 R1251359, Replace Unit 2 C safeguard battery on August 2, 2013 C0249070, Unit 1 RRCS pressure instrument drift repair on August 21, 2013 R1194006, Unit 2 PCIG valve test to verify system operability post Unit 2 refueling outage on September 4, 2013 through September 6, 2013 C0248967-02, Unit 1 RRCS Division 1 analog trip module board replacement due to card failure (IR 1549475) on September 16, 2013 through September 18, 2013 C0236631, Inspection and repair of 052-2051B check valve and performance of post-maintenance test using in-service test ST-6-052-760-2 on September 18, 2013 through September 19, 2013

b. Findings

No findings were identified.

1R22 Surveillance Testing (71111.22 - 4 Routine, 1 In-Service Test, 1 Isolation Valve)

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:

RT-6-015-310-1, Instrument Air Compressor Capacity Check on July 11, 2013 ST-2-072-106-0, Refuel Floor Balance-of-Plant Logic System Functional and Standby Gas Treatment System Test on July 25, 2013 ST-2-051-105-2, Low Pressure Coolant Injection Logic System Functional Test on August 1, 2013 ST-1-107-491-2, Reactor Vessel Exposure Tracking (IR 1545679) on August 13, 2013 ST-4-LLR-031-2, Main Steam Line A Local Leak Rate Test (Isolation Valve) on August 20, 2013 ST-6-048-230-1, Standby Liquid Control Pump, Valve, and Flow Test (In-Service Test) on August 28, 2013

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

The Office of Nuclear Security and Incident Response headquarters staff performed an in-office review of the latest revisions of various Emergency Plan Implementing Procedures and the Emergency Plan located under ADAMS accession numbers ML13162A199 and ML13200A124 as listed in the Attachment.

The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, these revisions are subject to future inspection. The specific documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of three routine Exelon simulator-based emergency exercises conducted on August 5, August 19, and August 26, 2013, to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator, technical support center, and operations support center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the critique to compare inspector observations with those identified by Exelon staff in order to evaluate Exelons critique and to verify whether the Exelon staff was properly identifying weaknesses and entering them into the corrective action program.

b. Findings

No findings were identified.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

During the period July 8-11, 2013, the inspectors reviewed the following aspects of the radioactive gaseous and effluent control program.

The inspectors used the requirements in Technical Specifications (TS), applicable Industry standards, and licensee procedures as criteria for determining compliance.

a. Inspection Scope

Air Cleaning Systems The inspectors assessed whether surveillance test results for TS required ventilation effluent discharge systems complied with TS acceptance criteria.

b. Findings

No findings were identified.

2RS7 Radiological Environmental Monitoring Program

During the period July 8-11, 2013, the inspectors evaluated the radiological environmental monitoring program (REMP) to determine if it sufficiently validated the integrity of the radioactive gaseous and liquid effluent release program.

The inspectors used the requirements in 10 CFR Part 20; 10 CFR Part 50 Appendix A; 40 CFR Part 190; Regulatory Guides 1.23, 4.1, and RG 4.15; and NUREG 1302 as criteria for determining compliance.

a. Inspection Scope

Inspection Planning

The inspectors reviewed the following aspects, and associated documents, in the area of inspection planning:

ODCM and changes there to, sampling locations, and Land Use Census Annual Radiological Environmental Reports (2011, 2012)

Annual Radioactive Effluent Release Reports (2011, 2012)

Available Assessments and Audits, including vendor laboratory audits Waste stream analysis Site/Environmental Inspection The inspectors conducted the following independent inspection activities:

Walked down three air sampling stations (11S1/11S2, 14S1, 15D1), one surface water sampling station (24S1), one drinking water station(15F4), and three thermoluminescent dosimeter monitoring stations (11S1/11S2, 14S1,15D1) to determine location and equipment material condition.

Reviewed selected air samplers, composite water samples, and thermoluminescent dosimeter stations, calibration and maintenance records to verify that they demonstrate adequate operability for these components.

Assessment of alternate sampling of other appropriate media upon loss of a required sampling station.

Observation of the collection and preparation of environmental samples from different environmental media (air, water).

Assessment of meteorological instruments (operability and availability, calibration, maintenance, data readout).

Evaluated missed and/or anomalous environmental samples and results were identified and reported including corrective actions.

Reviewed the assessment of any environmental sample results detected above the lower limits of detection, associated evaluation, and associated radioactive effluent release data.

Evaluated various structures, systems, or components that involve or could reasonably involve licensed material to determine whether licensee implemented a sampling and monitoring program for detection of leakage to ground water.

Evaluated 10 CFR 50.75(g) decommissioning records of leaks, spills, and environmental remediation.

Reviewed changes to the ODCM including changes to sampling locations.

Assessed detection sensitivities for environmental samples, reviewed quality control charts for laboratory radiation measurement instrument, and reviewed the results of the vendors quality control program, including the inter-laboratory comparison.

Reviewed the results of inter-laboratory and intra-laboratory comparison program to verify the adequacy of environmental sample analyses.

Identification and Resolution of Problems The inspectors assessed whether problems, associated with the REMP, were being identified and corrective actions were assigned for resolution in the corrective action program.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

.1 Mitigating Systems Performance Index (2 samples)

a. Inspection Scope

The inspectors reviewed Exelons submittal of the Mitigating Systems Performance Index for Unit 1 and Unit 2 RHR systems for the period of July 1, 2012, through June 30, 2013. To determine the accuracy of the PI data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors also reviewed Exelons operator narrative logs, IRs, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findings

No findings were identified.

.2 Unplanned Scrams per 7000 Critical Hours (2 samples)

a. Inspection Scope

The inspectors reviewed Exelons submittals for the Unplanned Scrams per 7000 Critical Hours for both Unit 1 and Unit 2 for the period of July 1, 2012, through June 30, 2013.

To determine the accuracy of the PI data reported during those periods, inspectors used definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73." The inspectors reviewed Exelons operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, condition reports, event reports and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findings

No findings were identified.

.3 Unplanned Scrams with Complications (2 samples)

a. Inspection Scope

The inspectors reviewed Exelons submittals for the Unplanned Scrams with Complications for both Unit 1 and Unit 2 for the period of July 1, 2012, through June 30, 2013. To determine the accuracy of the PI data reported during those periods, inspectors used definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73." The inspectors reviewed Exelons operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, CRs, event reports and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Inspection Findings No findings were identified.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

Plant Events ===

a. Inspection Scope

The inspectors reviewed a Unit 1 plant event that involved an unplanned downpower to 80 percent on July 7, 2013, as a result of low IA header pressure (IR 1533093) as described in section 1R04 of this report. The inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant event to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that Exelon personnel made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed follow-up actions related to the events to assure that Exelon staff implemented appropriate corrective actions commensurate with their safety significance.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On October 11, 2013, the inspectors presented the inspection results to Mr. T. Dougherty, Site Vice President, and other members of the Exelon staff.

The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

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

A. Wasong, 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

R. Ruffe, Operations Training Manager

M. DiRado, Manager, Engineering Programs

D. Merchant, Radiation Protection Manager

C. Gerdes, Chemistry Manager

A. Varghese, System Manager, Radiation Instruments

T. Kan, License Coordinator

J. Risteter, Radiological Technical Manager

L. Birkmire, Manager, Environmental

S. Gamble, Regulatory Assurance Engineer

K. Nicely, Exelon Corporate Regulatory Assurance

R. Lance, Chemistry Manager

N. Harmon, Senior Technical Specialist

R. Woolverton, System Manager

M. McGill, Senior Engineer

C. Boyle, Instrument Chemist

P. Imm, Radiological Engineering Manager

T. Fritz, Engineer, Rad Monitors

M. Strawn, Training Manager

B. Nealis, Senior Effluent and Environmental Specialist

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

05000352/2013004-01 FIN Inadequate and Untimely Corrective Actions Associated With the Unit 1 Instrument Air System (Section 1R04.2)

05000353/2013004-02 NCV Failure to Perform Technical Specification Surveillance Requirements on the Unit 2 Primary Containment Instrument Gas System (Section 1R13)

05000352/2013004-03 NCV Failure to Correct a Condition Adverse to Quality associated with Defective Material Being Reinstalled into a Safety-Related System (Section 1R15)

Closed

None.

Discussed

None.