IR 05000352/2020012

Generation Station, Units 1 and 2 - Biennial Problem Identification and Resolution Inspection Report 05000352/2020012 and 05000353/2020012

ML20210M087
Person / Time
Site:	Limerick
Issue date:	07/28/2020
From:	Jon Greives Reactor Projects Region 1 Branch 4
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Greives J
References
IR 2020012
Download: ML20210M087 (13)

Text

July 28, 2020

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000352/2020012 AND 05000353/2020012

Dear Mr. Hanson:

On June 26, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Limerick Generating Station, Units 1 and 2 and discussed the results of this inspection with Matthew Arnao, Organizational Performance and Regulatory Director, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.

Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

No findings or violations of more than minor significance were identified during this inspection. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, X /RA/

Signed by: Jonathan E. Greives Jonathan E. Greives, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 05000352 and 05000353 License Nos. NPF-39 and NPF-85

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000352 and 05000353 License Numbers: NPF-39 and NPF-85 Report Numbers: 05000352/2020012 and 05000353/2020012 Enterprise Identifier: I-2020-012-0003 Licensee: Exelon Generation Company, LLC Facility: Limerick Generating Station, Units 1 and 2 Location: Sanatoga, PA 19464 Inspection Dates: June 8, 2020 to June 26, 2020 Inspectors: L. Casey, Senior Project Engineer L. Cline, Senior Project Engineer J. DeBoer, Reactor Inspector S. Haney, Resident Inspector Approved By: Jonathan E. Greives, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Limerick Generating Station, Units 1 and 2, in accordance with the Reactor Oversight Process.

The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, conducted plant walkdowns, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards. Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), regional inspectors were directed to begin telework. The inspection documented below was determined that the objectives and requirements stated in the IP could be completed remotely.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)

(1) The inspectors performed a biennial assessment of the licensees problem identification and resolution performance in the following areas:

• Corrective Action Program Effectiveness in problem identification, prioritization, evaluation, and corrective action, which also included a review of corrective actions for issues identified in the Unit 1 and Unit 2 fire water systems, and the Unit 1 and Unit 2 residual heat removal and emergency service water systems in the last five years

• Use of Operating Experience

• Completed Self-Assessments and Audits

• Health of the Safety Conscious Work Environment.

INSPECTION RESULTS

Assessment 71152B Corrective Action Program Effectiveness Problem Identification: The inspectors determined that, in general, the licensee identified issues and entered them into the corrective action program at a low threshold.

Problem Prioritization and Evaluation: Based on the samples reviewed, the inspectors determined that, in general, the licensee appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. The licensee appropriately screened issue reports (IRs) for operability and reportability, categorized IRs by significance, and assigned actions to the appropriate department for evaluation and resolution.

Corrective Actions: The inspectors determined that the overall corrective action program performance related to resolving problems was effective. In most cases, the licensee implemented corrective actions to resolve problems in a timely manner.

However, the inspectors identified one minor performance deficiency regarding the licensee's inadequate trending and corrective action for a corroded baseplate identified in the spray pond pump house in 2017. The details of the minor performance deficiency are documented in the applicable section below.

Assessment 71152B Use of Operating Experience The team determined that the licensee appropriately evaluated industry operating experience for its relevance to the facility. The licensee appropriately incorporated both internal and external operating experience into plant procedures and processes, as well as lessons learned for training and pre-job briefs.

Self-Assessments and Audits The team reviewed a sample of self-assessments and audits to assess whether the licensee was identifying and addressing performance trends. The team concluded that the licensee had an effective self-assessment and audit process.

Assessment 71152B Safety Conscious Work Environment The team interviewed a total of 25 individuals. The purpose of these interviews was to evaluate the willingness of the licensee staff to raise nuclear safety issues; to evaluate the perceived effectiveness of the corrective action program at resolving identified problems; and to evaluate the licensee's safety-conscious work environment. The personnel interviewed were randomly selected by the inspectors from the Operations, Engineering, Maintenance, Security, and Radiation Protection work groups. To supplement these discussions, the team interviewed the Employee Concerns Program (ECP) representative to assess his perception of the site employees' willingness to raise nuclear safety concerns. The team also reviewed the ECP case log and select case files.

All individual interviewed indicated that they would raise safety concerns. All individuals felt that their management was receptive to receiving safety concerns and generally addressed them promptly, commensurate with the significance of the concern. Most interviewees indicated they were adequately trained and proficient on initiating condition reports. All interviewees were aware of the licensee's ECP, stated they would use the program if necessary, and expressed confidence that their confidentiality would be maintained if they brought issues to the ECP. When asked whether there have been any instances where individuals experienced retaliation or other negative reaction for raising safety concerns, all individuals interviewed stated that they had neither experienced nor heard of an instance of retaliation at the site. The team determined that the processes in place to mitigate potential safety conscious work environment issues were adequately implemented.

Minor Performance Deficiency 71152B Minor Performance Deficiency: The team identified one minor performance deficiency due to the licensee's inadequate trending and corrective actions for a degraded residual heat removal service water pipe support base plate. During performance of Exelon surveillance procedure, ST-1-012-901-0, Spray Pond Structural Inspection, on November 22, 2017, the licensee identified a degraded pipe support baseplate, HBC-507-H162, and initiated IR 04077339 to document the identified condition. The IR stated that if the baseplate was not fixed in the near future, it could corrode to the point where the pipe support would be unable to perform its design function and that the identified condition required engineering to monitor and assess the degradation until repairs could be completed. The inspectors determined that IR 04077339 was then closed to work request 01373448, as allowed by the corrective action program procedures and that, as of the date of this inspection, no work order to complete repairs was created and no repairs were completed. The inspectors also determined that ST-1-012-901-0 was completed again on February 27, 2019, but the results of the inspection did not identify any observations or discussion of the corrosion previously identified on HBC-507-H162. The inspectors concluded that this was contrary to the procedure requirements and was a performance deficiency because: Step 4.4 required the performer to obtain a copy of the results of the last inspection and pay particular attention to areas where evidence of damage had been identified; Step 4.5 required that a written description and photograph of any damage noted during the inspection be included in the completed inspection results; and that Step 4.6 required that changes in degraded conditions from prior inspections, such as extent of corrosion, be trended until it was evident that corrosion was no longer occurring, or until corrective actions were completed.

Screening: The inspectors determined the performance deficiency was minor. Using NRC Inspection Manual Chapter 0612, Appendices B and E, the inspectors determined the performance deficiency was minor because, although the condition of the baseplate was not documented in the February 2019 inspection and had not been corrected, based on licensee inspections of the baseplate completed on June 26, 2020, the baseplate conditions were similar to what was identified in 2017 and it remained functional. The licensee documented this minor performance deficiency in IR

EXIT MEETINGS AND DEBRIEFS

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

• On June 26, 2020, the inspectors presented the biennial problem identification and resolution inspection results to Matthew Arnao, Organizational Performance and Regulatory Director, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Corrective Action CAPE 04201280 D23 Lube Oil Keepwarm Failure 02/27/2019

Documents CAPE 04212649 D24 Emergency Diesel Generator Lube Oil leak at pressure 04/29/2019

sensing line

CAPE 04224095 Inaccurate System Availability Assessments 05/22/2019

CAPE 04246432 Open Manway on Water box Causing Flooding during 2R15 06/08/2019

CAPE 04335499 1N SRV Main Seat Leak 05/20/2020

ECAPE 0A-P548 ESW Pump SPPH Roof Plug Lifting Eyebolt Failure 01/07/2019

04193290-08

ECAPE Limerick U1 Fuel Cladding Defect Identified by Routine 02/08/2019

202624 Chemistry Offgas Sampling

Issue Reports 01510494 02453874 02522420 02542205 02576904

(IRs) 02585422 02650502 02673386 02686844 02704781

2735374 03944364 03944871 03982133 04035159

04061086 04077339 04081882 04082181 04106334

04112004 04127674 04163928 04193458 04193541

04194270 04194843 04196295 04199902 04201128

201812 04205949 04208628 04209746 04212993

217125 04218660 04220123 04226368 04226462

227982 04235661 04242429 04251477 04257856

257953 04258142 04263306 04264194 04265494

265645 04266423 04266929 04270530 04270530

274846 04275140 04280018 04281729 04283856

284354 04286381 04294685 04294907 04296755

04303755 04313201 04313899 04313985 04316600

04321933 04323304 04323304 04334999 04335036

04337850 04340911 04346095 04346159 04346343

RCR 04254212 Limerick Unit 2 Manual SCRAM Due to Loss of Main 07/23/2019

Condenser Vacuum

RCR 04266201- Emergent Shutdown of D24 Emergency Diesel Generator 10/04/2019

due to lube oil leak from threaded connection

Corrective Action Issue Reports 04349514 04349515 04349516 04349518 04349918

Documents (IRs) 04350684 04350858 04352290 04352529 04353840

Inspection Type Designation Description or Title Revision or

Procedure Date

Resulting from

Inspection

Engineering 4214904-18 ICES 447825 Diesel Generator Exhaust Fire

Evaluations Operating

Experience

Evaluation

214904-35 ICES 450628 Emergency Diesel Generator Jacket Water

Operating Leak

Experience

Evaluation

214904-43 ICES 453406 "C" High Pressure Injection Pump failed to start

Operating during scheduled pump rotation due to bent stop pin supply

Experience breaker

Evaluation

214904-46 ICES 453781 Instrument Air Compressor Tripped on High

Operating Intercooler Pressure

Experience

Evaluation

214904-47 ICES 454955 Standby Temporary Diesel Powered Air

Operating Compressor Automatic Shutdown during scheduled

Experience Surveillance

Evaluation

214904-57 ICES 460066 Control Room Refrigeration Unit Tripped on

Operating Low Suction Pressure & ICES 457968 Loss of Control Room

Experience Emergency Air Temperature Control System

Evaluation

214904-58 ICES 461533 Instrument Air Compressor Trip

Operating

Experience

Evaluation

214904-76 IRIS 464859 Buried Pipe Leak Results in Isolation of a fire

Operating protection header

Experience

Evaluation

Inspection Type Designation Description or Title Revision or

Procedure Date

214904-91 IRIS 471628 Service Air Compressor Tripped

Operating

Experience

Evaluation

Miscellaneous Safety Culture Analysis - 2019 - Limerick 09/20/2019

Nuclear Safety Culture Meeting - 11/18/2019 - Limerick 03/16/2020

Generating Station

Health Group Report (Engage Health) Limerick - 05/27/2020

20/92/81(EDG - Diesel Generator/Fuel Oil/EDG HVAC)

Limerick Generating Station Nuclear Safety Review Board 03/14/2019

Meeting - February 19 and 20, 2019

Limerick Generating Station Nuclear Safety Review Board 03/03/2020

Meeting - February 19 and 20, 2020

Health Group Report (Engage Health) Limerick - 05/27/2020

49/55/56(HPI - High Pressure Injection)

Health Group Report (Engage Health) Limerick - 76/77/78 05/27/2020

(SVT - SR Ventilation)

Health Group Report (Engage Health) Limerick - 11/12 05/27/2020

(SRW-ESW/RHRSW)

Procedures AD-AA-3000 Nuclear Risk Management Process 5

EI-AA-101 Employee Concerns Program Revision 11

EI-AA-101-1001 Employee Concerns Program Process Revision 15

MA-AA-716-008 Foreign Material Exclusion Program Revision 14

NO-AA-10 Quality Assurance Topical Report (QATR) 94

NO-AA-210 Nuclear Oversight Regulatory Audit Procedure Revision 10

NO-AA-210-1001 Nuclear Oversight Audit Handbook 22

NO-AA-210-1002 Nuclear Oversight Audit Templates 10

PI-AA-1012 Safety Culture Monitoring Revision 3

PI-AA-115 Operating Experience Program Revision 5

PI-AA-115-1003 Processing of Level 3 OPEX Evaluations 5

PI-AA-120 Issue Identification and Screening Process Revision 10

PI-AA-125 Corrective Action Program Procedure Revision 7

PI-AA-125-1001 Root Cause Analysis Manual Revision 5

Inspection Type Designation Description or Title Revision or

Procedure Date

PI-AA-125-1003 Corrective Action Program Evaluation Manual Revision 5

PI-AA-125-1006 Investigation Techniques Manual Revision 4

PI-AA-126-1001 Self-Assessments Revision 3

Self-Assessments 04098308 Preparation for NRC Problem Identification and Resolution 08/17/2018

(PI&R) Inspection

219354 Operator Fundamentals 11/22/2019

219982 Pre-NRC Inspection Self-Assessment: Access Control, 05/16/2019

Equipment Performance, Testing/Maintenance, Training, &

Performance Indicator Verification

219984 Dewatering of Manholes 08/23/2019

231645 Lab Safety/Hygiene 12/31/2019

248960-09 Biennial Safety Culture Self Assessment 01/29/2020

283555 Access Authorization and Fitness for Duty 12/13/2019

04308207 Preparation for NRC Problem Identification & Resolution 06/08/2020

(PI&R) Inspection

NOSA-LIM-19-04 Corrective Action Program Audit Report - Limerick 04/10/2019

(04223372) Generating Station - March 25 to April 5, 2019

NOSA-LIM-19-05 Engineering Design Control Audit Report 08/07/2019

(04250402)

NOSA-LIM-19-06 Radiation Protection Audit Report 07/10/2019

(04254186)

NOSA-LIM-19-08 Operations Functional Area Audit Report 09/18/2019

(04270127)

NOSA-LIM-20-01 Maintenance Functional Area Audit Report 03/11/2020

(04307853)

NOSA-LIM-20-02 Security Programs Audit Report 02/12/2020

(04307787)

NOSA-LIM-20-03 Emergency Preparedness Audit Report 04/29/2020

(04323231)

NOSA-LIM-20-04 Chemistry, Radwaste, Effluent and Environmental Monitoring 05/07/2020

(04323264) Audit Report

Work Orders 04318924-01 Completed ST-6-012-401-0 - A Loop RHRSW Pump Auto 05/30/2018

Actuation Test

04320498-01 Completed ST-6-012-402-0 - B Loop RHRSW Pump Auto 08/11/2018

Inspection Type Designation Description or Title Revision or

Procedure Date

Actuation Test

04590782-01 Completed - ST-6-012-233-0, A Loop RHRSW Pump 01/17/2019

Comprehensive Test

04600953-01 Completed ST-6-012-234-0 - B Loop RHRSW Pump 02/18/2019

Comprehensive Test

04984481-01 Completed ST-6-012-231-0 - A Loop RHRSW Pump, Valve 02/27/2020

and Flow Test

05011722-01 Completed ST-6-012-232-0 - B Loop RHRSW Pump, Valve 05/20/2020

and Flow Test

05031022-01 Completed ST-6-012-452-0 - B Loop RHRSW Lineup 05/18/2020

Verification

Action Requests 04170638 04175446 04320716 04606586 04609591

(ARs) 04619162 04629455 04637808 04661001 04729716

04739174 04766729 04780167 04818460 04840936

04844659 04857990 04861321 04874159 04886457

04939362 04939776 04945574 04973815 04987103

04993021

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