ML14037A370

IR 05000352-13-005, 05000353-13-005; 10/1/2013 - 12/31/2013; Limerick Generating Station (Lgs), Units 1 and 2; Followup of Events and Notices of Enforcement Discretion

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

License Nos.: NPF-39, NPF-85

Enclosure: Inspection Report 05000352/2013005 and 05000353/2013005

w/Attachment: Supplemental Information

cc w/encl: Distribution via ListServ

ML14037A370

X SUNSI Review

Non-Sensitive 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

License Nos.: NPF-39, NPF-85

Report No.: 05000352/2013005 and 05000353/2013005

Licensee: Exelon Generation Company, LLC

Facility: Limerick Generating Station, Units 1 & 2

Location: Sanatoga, PA 19464

Dates: October 1, 2013 through December 31, 2013

Inspectors: E. DiPaolo, Senior Resident Inspector

J. Hawkins, Resident Inspector

J. Ayala, Resident Inspector (Acting)

R. Nimitz, Senior Health Physicist

K. Mangan, Senior Reactor Inspector

T. Burns, Reactor Inspector

J. 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

gauge.

The failure of the indicating light to warn the maintenance workers that the airlock door

(Door 559) was open was due to a defective magnetic position switch. Exelon had

identified that the switch was defective on October 12, 2010, and entered the issue into

the CAP under IR 1125544. The inoperable magnetic switch caused the indication

feature to be non-functional. At the time, Exelon personnel did not consider the

simultaneous opening of two airlock doors to be a loss of safety function. As a result,

the work order to repair the magnetic switch was given a routine (Priority 5) work priority

that should be worked following the normal scheduling process. Because of the low

priority, four times in 2013 Exelon staff deferred the work order once in 2010, three times

in 2012, and four times in 2013.

In January 2013, the NRC made a revision (Revision 3) to the guidance provided in

NUREG-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 357110

PM 357149

R1032412

DBD L-S-03, High Pressure Coolant Injection, Revision 19

LGS-PRA-005.01, LGS PRA, HPCI System Notebook

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Issue Reports

1542786 1572412 1434804 1408218 217947 1517229

Procedures

WC-AA-101, On-Line Work Control Process, Revision 20

WC-AA-104, Integrated Risk Management, Revision 20

OP-AA-108-111-1001, Severe Weather and Natural Disaster Guidelines, Revision 11

ST-6-055-230-1, HPCI Pump Valve and Flow Test, Revision 79

RT-6-055-340-1, HPCI Turbine Hydraulic Control System Operability Check, Revision 13

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 357110

PM 357149

R1032412

DBD L-S-03, High Pressure Coolant Injection, Revision 19

LGS-PRA-005.01, LGS PRA, HPCI System Notebook

Section 1R18: Modifications

Miscellaneous

50.59 Evaluation for Replacement of 2A Low Pressure Turbine Exhaust Hood Replacement

Modification

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

HRA High Radiation Area

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

RCS Reactor Coolant System

RHR Residual Heat Removal

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