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| ML14037A370 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/06/2014 |
| From: | Fred Bower Reactor Projects Region 1 Branch 4 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| BOWER, FL | |
| References | |
| IR-13-005 | |
| Download: ML14037A370 (43) | |
See also: IR 05000353/2013005
Text
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
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.
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 (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
M. Pacilio 2
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
Enclosure: Inspection Report 05000352/2013005 and 05000353/2013005
w/Attachment: Supplemental Information
cc w/encl: Distribution via ListServ
X SUNSI Review
Non-Sensitive Publicly Available
Sensitive 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
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket Nos.: 50-352, 50-353
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. DAntonio, Senior Operations Engineer
B. Fuller, Senior Operations Engineer
S. Chaudhary, Reactor Inspector
Approved By: Fred Bower, Chief
Reactor Projects Branch 4
Division of Reactor Projects
Enclosure
2
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
2. RADIATION SAFETY ......................................................................................................14
2RS1 Radiological Hazard Assessment and Exposure Controls ......................................14
2RS2 Occupational As Low As is Reasonably Achievable (ALARA) Planning and Controls
................................................................................................................................16
2RS3 In-Plant Airborne Radioactivity Control and Mitigation ............................................17
2RS4 Occupational Dose Assessment .............................................................................18
2RS5 Radiation Monitoring Instrumentation .....................................................................19
2RS6 Radioactive Gaseous and Liquid Effluent Treatment ..............................................21
4. OTHER ACTIVITIES ..........................................................................................................22
4OA1 Performance Indicator (PI) Verification ...................................................................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
Enclosure
3
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
Chapter (IMC) 0609, Significance Determination Process, dated June 2, 2011. Cross-cutting
aspects are determined using IMC 0310, Components Within Cross-Cutting Areas, dated
October 28, 2011. All violations of Nuclear Regulatory Commission (NRC) requirements are
dispositioned in accordance with the NRCs Enforcement Policy, dated January 28. 2013. The
NRCs program for overseeing the safe operation of commercial nuclear power reactors is
described in NRC Technical Report Designation (NUREG)-1649, Reactor Oversight Process,
Revision 4.
Cornerstone: Barrier Integrity
Green. The inspectors identified a self-revealing finding (FIN) of very low safety significance
(Green) for Exelons failure to appropriately prioritize work activities associated with a
degraded Unit 2 magnetic switch for a secondary containment airlock door in accordance
with Exelon procedure WC-AA-106, Work Screening and Processing. This resulted in both
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
switch for the Unit 2 313 elevation reactor building-to-reactor building air supply room
access airlock doors was a performance deficiency that was reasonably within Exelons
ability to foresee and correct and could have been prevented. This was caused by not
performing a site impact review of reportability clarifications made by NUREG 1022, Event
Report Guidelines 10 CFR 50.72 and 50.73, Revision 3. The performance deficiency was
also contrary to Exelons procedure for work screening and processing. The finding was
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
Enclosure
4
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.
Enclosure
5
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,
and to repair a cooling water leak on the A main condensate pump. Operators returned the
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
On December 11, 2013, the inspectors performed a review of Exelons readiness for the
onset of seasonal cold weather. The review focused on the sites emergency diesel
generators (EDGs) and equipment located in the sites Spray Pond Pump House (ie.,
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, 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 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 inspectors reviewed Exelon staffs preparations in advance of
and during a Tornado Watch issued by the National Weather Service for Montgomery
County, Pennsylvania. The inspectors performed walkdowns of equipment that could be
Enclosure
6
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.
Enclosure
7
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
Neutron Monitoring System Area (Elevation 253) the week of October 7, 2013
Unit 2 Fire Area 45 - CRD Hydraulic Equipment Area and Neutron Monitoring
System Area (Elevation 253) the week of October 7, 2013
Unit 1 Fire Area 13 - D11 4kV Room (Elevation 239) the week of October 21, 2013
Unit 1 Fire Area 22 - Unit 1 Cable Spreading Room (Elevation 254) on
November 22, 2013
Common Fire Area 25 - Auxiliary Equipment Room 542 (Elevation 289) on
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.
Enclosure
8
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.
Units 1 and 2 reactor enclosure Elevation 217 including review of IR 1515259
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
During the week of October 21, 2013, the inspectors reviewed the Unit 2 B residual
heat removal heat exchanger testing to determine its readiness and availability to
perform its safety functions. The inspectors reviewed the design basis for the
component and verified Exelons commitments to NRC Generic Letter 89-13. 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
Enclosure
9
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
cooling water leak on the A main condensate pump. The inspectors observed the pre-
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,
Appendix I, and Operator Requalification Human Performance Significance
Determination Process. The inspectors verified that:
Overall pass rate among individuals for all portions of the exam was greater than or
equal to 80%. (Overall pass rate was 100%)
Enclosure
10
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
guidance of NRC Manual Chapter 0609, Appendix I, and Operator Requalification
Human Performance Significance Determination Process. The inspector verified that:
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
Enclosure
11
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
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.
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
D24, HPCI system, and A control room emergency fresh air system out-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:
Enclosure
12
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
Exelons 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 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
The inspectors evaluated the permanent plant modification associated with the Unit 2 A
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
replacement modification, the design analysis included in the licensees engineering
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.
Enclosure
13
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
C0249338, Unit 1 A standby liquid control pump rebuild on October 16, 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
IR 1576428, Troubleshoot and repair B control room emergency fresh air system
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-2-052-802-1, LOOP B Core Spray System Response Time Test on October 31,
2013
ST-6-048-231-1, SLC Pump, Comprehensive Test on November 19, 2013 (In-service
Test)
Enclosure
14
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.
2. RADIATION SAFETY
Cornerstone: Occupational and Public Radiation Safety
2RS1 Radiological Hazard Assessment and Exposure Controls (71124.01 - 1 sample)
During the period November 18-21, 2013, the inspectors reviewed and assessed
Exelons performance in assessing and controlling radiological hazards in the workplace.
The review considered criteria contained in 10 CFR Part 20, TSs, applicable Regulatory
Guides, and Exelon procedures for determining compliance.
a. Inspection Scope
Inspection Planning
The inspectors reviewed 2013 performance indicators for the occupational exposure
cornerstone, radiation protection (RP) program audits, corrective action documents, and
reports of operational occurrences in occupational radiation safety since the last
inspection.
Radiological Hazard Assessment
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Reviewed changes in radiological hazards for onsite workers or members of the
public and potential impact of the changes.
Conducted walk-downs and made independent radiation measurements and
reviewed survey documentation to determine thoroughness and frequency of the
surveys.
Reviewed risk-significant work activities including radiological surveys performed to
identify and quantify the radiological hazard and to establish adequate protective
measures.
Instructions to Workers
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Reviewed labeling of non-exempt licensed radioactive materials containers.
Enclosure
15
Contamination and Radioactive Material Control
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Observed various locations where potentially contaminated material were monitored
and released from the radiological control area and inspected methods used for
control, survey, and release.
Observed the performance of personnel surveying and releasing material for
unrestricted use and evaluated whether the work was performed in accordance with
plant procedures.
Assessed whether the radiation monitoring instrumentation used for equipment
release and personnel contamination surveys had appropriate detection sensitivity.
Reviewed sealed source inventory audits and assessed whether the sources were
accounted for and were tested for loose surface contamination.
Reviewed recent transactions involving nationally tracked sources.
Radiological Hazards Control and Work Coverage
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Evaluated radiological conditions and performed independent radiation
measurements during walk-downs of the facility.
Reviewed the application of dosimetry to monitor personnel working in significant
dose rate gradients.
Reviewed posting and physical controls for high radiation areas (HRAs), locked high
radiation areas and very high radiation areas (VHRA).
Risk-Significant HRA and VHRA Controls
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Discussed with the radiation protection manager and supervisors controls and
procedures for high-risk HRAs and VHRAs including any changes to relevant
procedures.
Radiation Worker Performance and RP Technician Proficiency
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Observed the performance of radiation workers and RP technicians with respect to
procedure requirements and awareness of radiological conditions.
Reviewed available radiological problem reports since the last inspection.
Enclosure
16
Problem Identification and Resolution
The inspectors evaluated whether problems associated with radiation monitoring and
exposure control were being identified at an appropriate threshold and placed in the
corrective action program.
b. Findings
No findings were identified.
2RS2 Occupational As Low As is Reasonably Achievable (ALARA) Planning and Controls
(71124.02 - 1 sample)
During the period November 18-21, 2013, the inspectors assessed performance with
respect to maintaining occupational individual and collective radiation exposures ALARA.
The inspectors used the criteria in 10 CFR 20, applicable Regulatory Guides, TSs, and
Exelon procedures for determining compliance.
a. Inspection Scope
Inspection Planning
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Reviewed pertinent information regarding collective dose history, current exposure
trends, ongoing and planned activities, and the plants three year rolling average
collective exposure.
Reviewed any changes in the radioactive source term, and reviewed site-specific
procedures associated with maintaining occupational exposures ALARA.
Radiological Work Planning
The inspectors conducted inspection and reviewed the following ALARA aspects and
associated documentation:
Compared the results achieved for completed work with the intended dose in ALARA
planning for these work activities, reviewed work-in-progress and post job reviews
and compared the planned person-hour estimates versus actual person-hours,
evaluated the accuracy of these estimates, assessed the reasons for any
inconsistencies.
Determined whether post-job reviews were conducted to identify lessons learned.
Source Term Reduction and Control
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Discussed source term reduction and reviewed records to determine the historical
trends and current status of plant source term.
Enclosure
17
Reviewed and discussed the current 10 CFR 61 waste stream source term data.
Problem Identification and Resolution
The inspectors evaluated whether problems associated with ALARA planning and
controls were being identified at an appropriate threshold and were placed in the
corrective action program.
b. Findings
No findings were identified.
2RS3 In-Plant Airborne Radioactivity Control and Mitigation (71124.03 - 1 sample)
During the period November 18-21, 2013, the inspectors selectively reviewed controls
for work in airborne radioactivity areas and the use of respiratory protection devices.
The inspectors used the criteria in 10 CFR Part 20, the guidance in applicable
Regulatory Guides, TSs, and Exelon procedures for determining compliance.
a. Inspection Scope
Inspection Planning
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Reviewed use of the respiratory protection program and a description of the types of
devices used including location and adequacy of storage facility and quantity of
respiratory protection devices stored.
Reviewed selected procedures for maintenance, inspection, storage, and use of
respiratory protection equipment including self-contained breathing apparatus
(SCBA).
Reviewed reported performance indicators to identify any related to unintended dose
resulting from intakes of radioactive material including during use of respiratory
protective devices.
Engineering Controls
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Assessed whether the Exelon had established threshold criteria for evaluating levels
of airborne beta-emitting and alpha-emitting radionuclides.
Use of Respiratory Protection Devices
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Enclosure
18
Chose various respiratory protection devices staged and ready for use in the plant
and assessed the storage and physical condition of the device components and
reviewed records of equipment inspection for each type of equipment.
Reviewed equipment storage, maintenance, and quality assurance including training
of onsite personnel conducting maintenance and repair of such equipment.
SCBA for Emergency Use
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Inspected and reviewed procedures for surveillance of SCBAs staged in-plant for use
during emergencies.
Problem Identification and Resolution
The inspectors evaluated whether problems associated with the control and mitigation of
in-plant airborne radioactivity were being identified at an appropriate threshold and were
placed in the corrective action program.
b. Findings
No findings were identified.
2RS4 Occupational Dose Assessment (71124.04 - 1 sample)
During the periods November 18-21, 2013, the inspectors reviewed the monitoring,
assessment, and reporting of occupational dose. The inspectors used the criteria in
10 CFR 20, applicable Regulatory Guides, TSs, and Exelon procedures for determining
compliance.
a. Inspection Scope
Inspection Planning
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Radiation protection program audits.
Procedures associated with dosimetry operations, including issuance/use of external
dosimetry, and assessments of dose for radiological incidents.
Available dosimetry occurrence reports and corrective action program documents for
adverse trends related to electronic personal dosimeters.
Enclosure
19
Internal Dosimetry
Routine Bioassay (In-Vivo)
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Reviewed procedures to assess dose from internally deposited radionuclides
including the release of contaminated individuals.
Reviewed available worker dose assessments.
Internal Dose Assessment - Whole Body Count Analyses
The inspectors conducted inspection and reviewed dose assessments performed using
the results of whole body count analyses.
Special Dosimetric Situations
The inspectors conducted inspection and reviewed training on the risks of radiation
exposure, regulatory aspects of declaring a pregnancy, exposure controls, and the
specific process to be used for voluntarily declaring a pregnancy.
Shallow Dose Equivalent
The inspectors conducted inspection and reviewed dose assessments for shallow dose
equivalent, including associated documentation.
Problem Identification and Resolution
The inspectors assessed whether problems associated with occupational dose
assessment were being identified an appropriate threshold and were placed in the
corrective action program.
b. Findings
No findings were identified.
2RS5 Radiation Monitoring Instrumentation (71124.05 - 1 sample)
During the period November 18-21, 2013, the inspectors reviewed the accuracy and
operability of radiation monitoring instruments that were used to protect occupational
workers and members of the public. The review considered criteria contained in
10 CFR Part 20, 10 CFR Part 50, 40 CFR 190, applicable Regulatory Guides and
industry standards, TSs/Offsite Dose Calculation Manual (ODCM), and Exelon station
procedures for determining compliance.
a. Inspection Scope
Inspection Planning
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Enclosure
20
Reviewed procedures that govern instrument source checks and calibrations.
Reviewed effluent monitor alarm set-points and the calculation methods provided in
the ODCM.
Walkdowns and Observations
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Selected various portable survey instruments in use and assessed calibration and
source check stickers for currency, as well as, instrument material condition and
operability.
Compared monitor response (via local readout or remote control room indications)
with actual area radiological conditions for consistency.
Selected various personnel contamination monitors, portal monitors, Small Article
Monitors, and bag monitor to evaluate whether the periodic source checks and
calibrations were performed in accordance with requirements.
Calibration and Testing Program
Portal Monitors, Personnel Contamination Monitors, and Small Article Monitors
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Selected various types of instruments in use (e.g. radioactivity analysis and
quantification instrumentation) and verified that the alarm set-point values were
reasonable to ensure that licensed material is not released from the site.
Reviewed calibration documentation for each instrument selected and reviewed the
calibration methods with respect to requirements.
Calibration and Check Sources
The inspectors reviewed the Exelons source term or waste stream characterization per
10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste, to
assess whether calibration sources used were representative of the types and energies
of radiation encountered in the plant.
Problem Identification and Resolution
The inspectors evaluated whether problems associated with radiation monitoring
instrumentation were being identified by the Exelon at an appropriate threshold and were
placed in the corrective action program.
b. Findings
No findings were identified.
Enclosure
21
2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06 - 1 sample)
During the period November 18-21, 2013, the inspectors reviewed monitoring and
evaluation of gaseous and liquid effluents. The review considered criteria contained in
10 CFR Part 20, 10 CFR Part 50, 40 CFR 190, applicable Regulatory Guides and
industry standards, TSs/ODCM, and Exelon station procedures for determining
compliance.
a. Inspection Scope
Inspection Planning and Program Reviews
Event Report and Effluent Report Reviews
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Reviewed the 2012 Radioactive Effluent Release Report to determine if the reports
were submitted as required including anomalous results, unexpected trends, and
abnormal releases that were identified.
Determined if abnormal effluent results were evaluated, were entered in the
corrective action program, and were adequately resolved.
ODCM and Final Safety Analysis Report Review
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Reviewed changes to the ODCM made since the last inspection.
Reviewed the technical basis or evaluations of any changes and determined whether
they were technically justified and maintained effluent releases ALARA.
Walk-downs and Observations
The inspectors walked-down the standby gas treatment ventilation trains and Reactor
Building Recirculation air cleaning systems to review material conditions for Unit 1 and
Unit 2.
Procedures, Special Reports, and Other Documents
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Reviewed Exelon event reports and/or special reports related to the effluent program
issued since the previous inspection.
Sampling and Analyses
The inspectors reviewed and discussed inter-laboratory and intra-laboratory comparison
program to verify the quality of the radioactive effluent sample analyses.
Enclosure
22
Dose Calculations
The inspectors conducted inspection and reviewed the following aspects and associated
documentation:
Reviewed significant changes in reported dose values compared to the previous
radioactive effluent release report to evaluate the factors which may have resulted in
the change.
Reviewed changes in methodology for offsite dose calculations since the last
inspection. The inspectors reviewed and discussed meteorological dispersion and
deposition factors used in the ODCM and effluent dose calculations.
Reviewed the latest Land Use Census to verify changes have been incorporated into
the effluent release and environmental programs.
Problem Identification and Resolution
Inspectors assessed whether problems associated with the effluent monitoring and
control program were being identified by the Exelon at an appropriate threshold and
placed in the corrective action program.
b. Findings
No findings were identified.
4. OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification (71151)
.1 Occupational Exposure Control Effectiveness
a. Inspection Scope
During the period November 18-21, 2013, the inspectors reviewed various corrective
action documents covering the past four quarters to determine if issues met the report
threshold for the occupational exposure control effectiveness PI or the threshold for the
public exposure control effectiveness PI. The inspectors used PI definitions and
guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory
Assessment Performance Indicator Guideline, Revision 7, dated August 31, 2013, to
determine the accuracy of the PI data reported.
Occupational Exposure Control Effectiveness (1 sample)
During the period November 18-21, 2013, the inspectors reviewed the scope and
breadth of the Exelon data review and the results of those reviews. The inspectors
reviewed electronic personal dosimeter dose alarms, dose reports, and dose
assignments for any intakes that occurred during the past four quarters to determine if
there were any potentially unrecognized PI occurrences. The inspector also conducted
walk-downs of accessible locked high and very high radiation area entrances to
determine the adequacy of the controls in place for these areas.
Enclosure
23
RETS/ODCM Radiological Effluent Occurrences (1 sample)
During the period November 18-21, 2013, the inspectors reviewed the corrective action
report database and selected individual reports covering the past four quarters to identify
any potential occurrences such as unmonitored, uncontrolled, or improperly calculated
effluent releases that may have impacted offsite dose. The inspectors reviewed
gaseous and liquid effluent summary data and the results of associated offsite dose
calculations to determine if indicator results were accurately reported. The inspectors
also reviewed methods for quantifying gaseous and liquid effluents and determining
effluent dose.
b. Findings
No Findings were identified.
.2 Mitigating Systems Performance Index (2 samples)
a. Inspection Scope
The inspectors reviewed Exelons submittal of the Mitigating Systems Performance
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,
Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors
also reviewed Exelons operator narrative logs, condition reports, 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.
.3 Reactor Coolant System (RCS) Specific Activity and RCS Leak Rate (4 samples)
a. Inspection Scope
The inspectors reviewed Exelons submittal for the RCS specific activity and RCS leak
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 99-02, Regulatory Assessment Performance Indicator
Guideline, Revision 7. The inspectors also reviewed RCS sample analysis and control
room logs of daily measurements of RCS leakage, and compared that information to the
data reported by the performance indicator.
Enclosure
24
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
As required by Inspection Procedure 71152, Problem Identification and Resolution,
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
Procedure 71152, Problem Identification and Resolution, to identify trends that might
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
Exelons corrective action program database for the third and fourth quarters of 2013 to
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
Enclosure
25
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 Exelons evaluation and corrective
actions 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.
The inspectors assessed Exelons engineering evaluation, extent-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
interviewed engineers and reviewed Exelons evaluation of the issue and corrective
actions taken to ensure they met the requirements of the corrective action program.
Specifically, the inspectors reviewed Exelons actions to evaluate whether support
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.
The inspectors determined that Exelons apparent cause 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
reasonable and addressed the probable and contributing causes. Exelons engineering
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.
Additionally, Exelons extent-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
Enclosure
26
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 inspectors concluded that Exelons
evaluation 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 Exelons evaluation and corrective
actions 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
RHRSW and ESW B loop on November 18, 2011 that ESW design flow rates to two
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 interior of the systems carbon steel piping created
smaller pipe diameters and increased flow resistance which resulted in lower flow rates
to RHR and ESW system components. Exelons corrective actions included cleaning
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.
The inspectors assessed Exelons apparent cause evaluation, 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 reviewed Exelons evaluation of
the issue and corrective actions taken to ensure they met the requirements of their
corrective action program and addressed the degraded conditions. Specifically, the
inspectors reviewed Exelons actions to evaluate whether 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.
Enclosure
27
b. Findings and Observations
No findings were identified.
The inspectors determined that Exelons apparent cause 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
reevaluate the design requirements of the system maintained the systems design and
licensing basis requirements and additional margin to design limits had been realized.
The inspectors concluded that Exelons evaluation and corrective action efforts
associated 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
safety significance (Green) for Exelons failure to appropriately prioritize work activities
associated with a degraded Unit 2 magnetic switch for a secondary containment
airlock door in accordance with Exelon procedure WC-AA-106, Work Screening and
Processing. This contributed to both airlock doors being opened simultaneously and
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 elevation reactor building-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
Enclosure
28
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
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-1022, Event Report Guidelines 10 CFR 50.72 and 50.73, that clarified that
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.
Exelon subsequently reported the degraded condition via the NRCs Emergency
Notification. System. Exelons investigation concluded that the sites implementation of
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-106, Work Screening and Processing, Revision 13
and concluded that the work order would have been given a Priority 4. This is because it
satisfied the criteria that the loss of equipment causes or will cause, if additional
redundant equipment degrades, a reduction in generation or loss of function. Issues
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
magnetic switch for the Unit 2 313 elevation reactor building-to-reactor building air
supply room access airlock doors was a performance deficiency that was reasonably
within Exelons ability to foresee and correct and could have been prevented. This was
caused by not performing a site impact review of reportability clarifications made by
NUREG 1022, Event Report Guidelines 10 CFR 50.72 and 50.73, Revision 3. The
Enclosure
29
performance deficiency was also contrary to Exelons procedure for work screening 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
associated safeguard transformers tap changer that the EDG is paralleled with during
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 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. 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
Enclosure
30
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
The licensees buried piping and underground piping and tanks program was inspected
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.
The licensees buried piping and underground piping and tanks program was inspected
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
Enclosure
A-1
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
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
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
J. Zellmer, LSRO Requal Coordinator
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.
Attachment
A-2
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
Attachment
A-3
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
Monitoring System Area (EL 253), Revision 17 (Revision 2)
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
Attachment
A-4
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-5 Appendix 2, Planned Rx Maneuvering without Shutdown, Revision 74
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 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
Attachment
A-5
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 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
Attachment
A-6
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-2-052-802-1, Loop B Core Spray System Response Time Test, Revision 18
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
Section 2RS01: Access Control to Radiologically Significant Areas
Procedures
LG-13-001, Annual Isotopic Mix Analysis, Revision 0
RP-AA-800-101, Nationally Tracked Source Program
Documents
Radiological Program Assessments (source control, ALARA, work controls, alpha monitoring,
remote monitoring, High Radiation Area control))
Corrective Action Documents (ARs - various)
Attachment
A-7
10 CFR 61 Waste Stream Report - 2012
Dose Records
Contamination Control - Personnel Contamination Data
Performance Indicator Data
Section 2RS02: Occupational ALARA Planning and Controls
Procedures
RP-AA-301, Radiological Air sampling Program, Revision 5
RP-LG-300-101, Radiation Survey Program and Documentation, Revision 12
RP-AA-401, Operational ALARA Planning, Revision 15
Documents
2R12 Radiation Protection Outage Report
Station Daily Updates (various)
Station ALARA Council Meeting Minutes (various)
Corrective Action Documents (ARs - various)
Section 2RS03: In-plant Airborne Radioactivity Control and Mitigation
Procedures
RP-AA-301, Radiological Air Sampling Program, Revision 5
RP-LG-300-101, Radiation Survey Program and Documentation, Revision 12
RP-AA-410, Selection, Use and Control of Protective Clothing, Revision 2
RP-AA-441, Evaluation and Selection Process for Radiological Respirator Use, Revision 4
RP-AA-440, Respiratory Protection Program, Revision 10
RP-AA-825, Maintenance, Care, and Inspection of Respiratory Protection Equipment, Revision
6
RP-AA-825-1014, Operation and Inspection of the 3M Versaflow, Revision 1
RP-825-1020, Operation and Use of Airline Supplied Respirators, Revision 0
Documents
National Institute for Occupational Safety and Health Traceability for Scott SCBA Equipment
SCBA Respirator Qualification Records (training, medial certification)
Corrective Action Documents (various)
Airborne Radioactivity Intake Assessments
Respiratory Equipment Inventory
Section 2RS04: Occupational Dose Assessment
Procedures
LG-13-001, Annual Isotopic Mix Analysis, Revision 0
RT-0-000-981, Routine Bioassay, Revision 8
RP-LG-300-101, Radiation Survey Program and Documentation, Revision 12
RP-AA-350, Personnel Contamination Monitoring, Decontamination, and Reporting, Revision 10
RP-AA-605, Waste Stream Results Review, Revision 4
Documents
10 CFR 61 Reports
Exposure Control and Dose Records
Dosimtery placement data (Effective Dose Equivalent)
Attachment
A-8
General Source Term Data
Personnel Contamination Event Logs
Personnel Intake Investigations
Corrective Action Documents (various)
Section 2RS05: Radiation Monitoring Instrumentation
Procedures
RP-LG-700-1019, Operation and Calibration of the Cronos 11 Contamination Monitor, Revision
0
RP-AA-700, Controls for Radiation Protection Instrumentation, Revision 3
CY-AA-130-200, Quality Control, Revision 12
CY-AA-130-201 Radiochemistry Quality Control, Revision 2
CY-AA-130-300, Gamma Spectroscopy, Revision 5
CY-AA-130-3000, Gamma Isotopic Review, Revision 4
CY-LG-130-102, Operation of the Isolo Alpha/Beta Counting System, Revision 1
CY-LG-130-1320, Packard Liquid Scintillation Counter, Revision 0
Documents
Electronic Dosimeter Calibration Data
Instrument Calibration Data
General Source Term Data
Corrective Action Documents (ARs - various)
Section 2RS06: Radioactive Gaseous and Liquid Effluent Treatment
Procedures
RP-AA-700, Controls for Radiation Protection Instrumentation, Revision 3
CY-AA-130-200, Quality Control, Revision 12
CY-AA-130-201, Radiochemistry Quality Control, Revision 2
CY-AA-130-300, Gamma Spectroscopy, Revision 5
CY-AA-130-3000, Gamma Isotopic Review, Revision 4
ST-5-076-815, North Stack and Hot Machine Shop Weekly Iodine and Particulate Analysis
ST-5-076-821-0, North Stack/Hot Maintenance Shop Monthly Composite Analysis
Documents
Performance Indicator data
General source term data
Public dose projections
Corrective Action Documents (ARs - various)
Section 4OA1: Performance Indicator Verification
Documents
Performance Indicator data
General source term data
Public dose projections
Radiation worker dose assessments
Radiation Dosimetry data
Effluent Release Reports
Radiation Work Permit Dose Limits
Corrective Action Documents (ARs - various)
Attachment
A-9
Section 4OA2: Identification and Resolution of Problems
Issue Reports
1588791 1596702 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-2-011-252-0, ESW Loop B Flow Balance, performed 7/2/13
RT-2-011-251-0, ESW Loop A Flow Balance, performed 9/10/13
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
Section 4OA5: Other Activities
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
Attachment
A-10
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
Work Orders
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
ALARA As Low As is Reasonably Achievable
APRM Average Power Range Monitor
CAP Corrective Action Program
CFR Code of Federal Regulations
CRD Control Rod Drive
CY Calendar Year
EDG Emergency Diesel Generator
ESW Emergency Service Water
FIN Finding
HPCI High-Pressure Coolant Injection
IMC Inspection Manual Chapter
IR Issue Report
LER Exelon Event Report
LGS Limerick Generating Station
NEI Nuclear Energy Institute
NRC Nuclear Regulatory Commission
NUREG NRC Technical Report Designation
ODCM Offsite Dose Calculation Manual
PI Performance Indicators
PM Preventive Maintenance
RCIC Reactor Core Isolation Coolant
RHRSW Residual Heat Removal Service Water
RP Radiation Protection
SCBA Self-Contained Breathing Apparatus
SSC Structure, System, or Component
TS Technical Specifications
UFSAR Updated Final Safety Analysis Report
VHRA Very High Radiation Area
Attachment