Text

NRC Problem Identification and Resolution Inspection 05000352/2014008 and 05000353/2014008 Public Document
	ML14310A099
Person / Time
Site:	Limerick
Issue date:	11/05/2014
From:	Bower F L; Reactor Projects Region 1 Branch 4
To:	Pacilio M J; Exelon Generation Co, Exelon Nuclear
References
	IR 2014008
	Download: ML14310A099 (19)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PA 19406-2713 November 5, 2014 Mr. Michael Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO), Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT: LIMERICK GENERATING STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION 05000352/2014008 AND 05000353/2014008

Dear Mr. Pacilio:

On October 3, 2014, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Limerick Generating Station, Units 1 and 2. The enclosed report documents the inspection results discussed on October 3, 2014, with Mr. David Lewis, Plant Manager and other members of your staff.

This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commission's rules and regulations and conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

Based on the samples selected for review, the inspectors concluded that Exelon was generally effective in identifying, evaluating, and resolving problems. Exelon personnel identified problems and entered them into the corrective action program at a low threshold. Exelon prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were implemented in a timely manner.

The inspectors documented a minor violation containing security-related information, which is provided as Enclosure 2. This deficiency was promptly corrected or compensated for and the plant was in compliance with applicable physical protection and security requirements within the scope of this inspection, before the inspectors left the site. If you contest the minor violation or the team's observations in Enclosure 2, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Limerick Generating Station. As this information is security-related, please ensure your response is properly marked and handled.

Enclosure 2 contains Sensitive Unclassified Non-Safeguards Information. When separated from enclosure, the transmittal document is decontrolled. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document 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 1 (Public): Inspection Report 050000353/2014008 w/Attachment: Supplementary Information

Enclosure 2 (Non-Public): Inspection Report 05000353/2014008 w/Attachment: Supplementary Information (CONTAINS (OUO-SRI))

cc w/Enclosure 1; w/Enclosure 2; w/OUO-SRI K. Kemper, Manager, Site Security D. Allard, Director, PA DEP

cc w/Enclosure 1; w/o Enclosure 2; w/o OUO-SRI Distribution via ListServ In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document 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 1 (Public): Inspection Report 050000353/2014008 w/Attachment: Supplementary Information

Enclosure 2 (Non-Public): Inspection Report 05000353/2014008 w/Attachment: Supplementary Information (CONTAINS (OUO-SRI))

cc w/Enclosure 1; w/Enclosure 2; w/OUO-SRI K. Kemper, Manager, Site Security D. Allard, Director, PA DEP

cc w/Enclosure 1; w/o Enclosure 2; w/o OUO-SRI Distribution via ListServ Distribution w/Encl 1; w/Encl 2; w/OUO-SRI: (via email)

C. Bickett, DRP R. Powell, DRP F. Bower, DRP G. DiPaolo, DRP, SRI R. Albert, NSIR C. Johnson, NSIR S. Coker, NSIR B. Desai, DRS, RII R. Skokowski, DRS, RIII M. Haire, DRS, RIV Distribution w/Encl 1; w/o Encl 2; w/o OUO-SRI: (via email) D.Lew, Acting RA

V. Ordaz, Acting DRA H. Nieh, DRP M. Scott, DRP R. Lorson, DRS J. Trapp, DRS F. Bower, DRP R. Montgomery, DRP, RI N. Esch, DRP, AA J. Jandovitz, RI OEDO DOCUMENT NAME: G:\DRP\BRANCH3\Inspection\Reports\Draft\2014 (ROP15)\2014 Limerick PIR report_Final Public.docx ADAMS ACCESSION NUMBER:

ML14310A099 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE RI/DRP RI/DRS RI/DRP RI/DRP NAME RBarkley ADimitriadis RPowell FBower DATE 10/31 /14 11/3/14 11/5/14 11/5/14 1 Enclosure 1 U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket Nos.: 50-352; 50-353

License Nos.: NPF-39, NPF-85

Report Nos.: 05000352/2014008 and 05000353/2014008

Licensee: Exelon Generation Company, LLC

Facility: Limerick Units 1 and 2

Location: Sanatoga, Pennsylvania

Dates: September 15 - 19, 2014 September 29 - October 3, 2014

Team Leader: R. Barkley, PE, Senior Project Engineer

Inspectors: E. Andrews, Project Engineer B. Lin, Project Engineer R. Montgomery, Resident Inspector - Limerick

Approved by: Fred L. Bower, III, Chief Reactor Projects Branch 4 Division of Reactor Projects 2 Enclosure 1

SUMMARY OF FINDINGS

IR 05000352/2014008, 05000353/2014008, 09/15/2014 - 10/03/2014; Limerick Units 1 and 2;

Identification and Resolution of Problems.

This NRC team inspection was performed by one senior project engineer, two regional inspectors, and one resident inspector. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 5.

Problem Identification and Resolution The inspectors concluded that Exelon was genera lly effective in identifying, evaluating, and resolving problems. Exelon personnel typically identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with their safety significance. Exelon appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that Exelon implemented corrective actions to address the problems identified in the corrective action program in a timely manner.

The inspectors concluded that Exelon adequately identified, reviewed, and applied relevant industry operating experience to Limerick operations. In addition, based on those items selected for review, the inspectors determined that Exelon's self-assessments and audits were thorough.

Based on limited interviews of employees and contractors the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues nor did they identify any conditions that could have had a negative impact on the site's safety conscious work environment. 3 1

REPORT DETAILS

OTHER ACTIVITIES (OA)

4OA2 Problem Identification and Resolution

Main article: IP 71152B

This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. All documents reviewed during this inspection are listed in the Attachment to this report.

.1 Assessment of Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures that described Exelon's corrective action program at Limerick Unit 1 & 2. To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in these areas to the requirements and standards contained in Title 10 of the Code of Federal Regulations (10 CFR), Appendix B, Criterion XVI, "Corrective Action," and Exelon procedure PI-AA-125, Revision 0, "Corrective Action Program Procedure." For each of these areas, the inspectors considered risk insights from the station's risk analysis and reviewed issue reports (IRs) selected across the seven cornerstones of safety in the NRC's Reactor Oversight Process. Additionally, the inspectors attended plan-of-the-day, station ownership committee, and management review committee meetings. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, and oversight programs.

(1) Effectiveness of Problem Identification

In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports. The inspectors also completed field walkdowns of various buildings onsite, including the reactor, turbine, radwaste, and circulating water buildings as well as the spray pond pump house. Additionally, the inspectors reviewed a sample of IRs written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that Exelon entered conditions adverse to quality into their corrective action program as appropriate.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors reviewed the evaluation and prioritization of a sample of IRs issued since the last NRC biennial problem identification and resolution inspection completed in early November 2012. The inspectors also reviewed IRs that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors' review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.

(3) Effectiveness of Corrective Actions The inspectors reviewed Exelon's completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed IRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Exelon's timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of IRs associated with selected non-cited violations (NCVs) and findings to verify that Exelon personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate Exelon actions related to the condition of the 13 kV electrical system and the Residual Heat Removal Service Water (RHRSW)piping system.

b. Assessment

(1) Effectiveness of Problem Identification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Exelon identified problems and entered them into the corrective action program at a low threshold. Exelon staff at Limerick initiated nearly 30,000 IRs between November 2012 and September 2014. The inspectors observed supervisors at the plan-of-the-day, station ownership committee, and management review committee meetings appropriately questioning and challenging issue reports to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that Exelon trended equipment and programmatic issues, and appropriately identified problems in issue reports. The inspectors verified that conditions adverse to quality identified through these reviews were entered into the corrective action program as appropriate. Additionally, inspectors concluded that personnel were identifying trends at a low threshold.

With few exceptions, inspectors found that issues or concerns had been appropriately entered into the corrective action program for evaluation and resolution. However, in response to questions and equipment observations identified by the inspectors during plant walkdowns in the radwaste building and the spray pond pump house, Exelon personnel promptly initiated IRs and/or took prompt action to address the issues. The material condition of equipment in these two areas was distinctly different than the rest of the facility. In response, Limerick management noted an effort recently initiated to improve the material condition of the radwaste control room as well as the procedures governing its conduct of operations.

(2) Effectiveness of Prioritization and Evaluation of Issues

In general, the inspectors determined that Exelon appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem, with the exception of the issues documented in Enclosure 2. Exelon screened IRs for operability and reportability, categorized the issue reports by significance, and assigned actions to the appropriate department for evaluation and resolution. The IR screening process considered human performance issues, radiological and industrial safety concerns, repetitiveness, adverse trends, and the potential impact on the safety conscious work environment.

Based on the sample of issue reports reviewed, the inspectors noted that the guidance provided by Exelon corrective action program implementing procedures appeared sufficient to ensure consistency in categorization of issues. This was supported by the review of four SOC packages, attendance at two MRC meetings, and the review of approximately 200 IRs.

(3) Effectiveness of Corrective Actions

The inspectors concluded that corrective actions for identified deficiencies were typically timely and adequately implemented. For significant conditions adverse to quality, Exelon identified actions to prevent recurrence and corrective actions to address the sample of NRC NCVs, issued since the la st problem identification and resolution inspection, were also timely and effective.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed a sample of IRs associated with the review of industry operating experience to determine whether Exelon appropriately evaluated the operating

experience information for applicability to Limerick, and had taken appropriate actions when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Exelon adequately considered the underlying problems associated with the issues for resolution via their corrective action program. In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.

b. Assessment The inspectors determined that Limerick appropriately considered both Exelon-fleet and industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also observed that industry operating experience was routinely discussed and considered during daily meetings.

c. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed a sample of audits and self-assessments, including recent reviews of the corrective action program, selected departments, and assessments

performed by independent organizations. Ins pectors performed these reviews to determine if Exelon entered problems identified through these assessments into the corrective action program, when appropriate, and whether Exelon initiated corrective actions to address identified deficiencies.

b. Assessment The inspectors concluded that self-assessments, audits, and other internal Exelon assessments were critical, thorough, and effective in identifying issues. The inspectors observed that Exelon personnel knowledgeable in the subject completed these audits and self-assessments, and that individuals across the Exelon fleet were brought in to support these assessments and provide diverse and objective insights. Exelon completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. The station implemented corrective actions associated with the identified issues commensurate with their safety significance.

c. Findings

No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

During interviews station and contractor personnel, the inspectors assessed the safety conscious work environment at Limerick. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors also interviewed station Employee Concerns Program counselors to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns. The inspectors reviewed selected Employee Concerns Program files to ensure that Exelon entered issues into the corrective action program when appropriate, and that senior Limerick management was promptly informed of sensitive performance issues involving department supervisors or managers.

b. Assessment During interviews of staff conducted in multiple departments, Limerick staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no

one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the corrective action program and the Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.

One observation made during these interviews was passed onto Limerick management, specifically that the majority of employees interviewed thought that they could submit an IR anonymously in the CAP. While this process once existed, it was discontinued several years ago, although employees do have the option of providing such a concern to the ECP, or place it anonymously in an "Ask the SVP" drop box. Limerick management acknowledged the inspectors' observation and were evaluating how best to reemphasize to their employees the available avenues to communicate concerns anonymously.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On October 3, 2014, the inspectors presented the inspection results to Mr. David Lewis, Plant Manager, and other members of the Limerick staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

M. Arnosky, Shift Manager

J. Berg, System Engineer

J. Brittain, System Engineer

G. Broillet, EP Manager

G. Budock, Senior Regulatory Engineer

F. Burzynski, Fire Marshall

I. Choudhry, ECP Counselor

R. Dickinson, Manager - Regulatory Assurance

M. Gillen, Shift Operations Superintendent

C. Gulotta, Manager Site Security Operations

J. Karkoska, Nuclear Oversight Manager

M. Klick, Performance Improvement Director

L. Lail, Maintenance Engineer

A. Lambert, System Engineer

N. Lampe, System Engineer

A. Lopez, Security Shift Supervisor

J. MacDonald, EP Specialist

R. McCall, Principal Regulatory Engineer

J. Mills, System Engineer

L. Murphy, ECP Counselor

J. Murphy, Senior Operations Supervisor

R. Nealis, Chemistry Supervisor

D. Nugent, System Engineer

D. Poindexter, Security Program Lead

W. Pulford, Senior Reactor Operator

B. Shultz, Manager Operations Support

R. Smith, Operations Engineer

G. Sprissler, Chemistry analyst

J. Thoryk, Fire Protection Engineer

G. Weiss, NDE specialist

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

None A-2 Attachment

LIST OF DOCUMENTS REVIEWED

Section 4OA2: Problem Identification and Resolution

Action Requests

A0059917 A0117920

A0218375

A0239406

A0316095 A0514224 A0535205

A0558461

A0859101

A0826195 A0961772 A0993204

A1011891

A1062403

A1084700

A1188765 A1274351 A1295026 A1321733 A1334180 A1346798

A1358486

A1360280 A1366280

A1368222

A1370445

A1371755

A1390418 A1412661 A1438827

A1469144

A1511763

A1517485 A1525212 A1546800

A1548613

A1549475

A1592062

A1632606 A1633981 A1634017

A1635331

A1637448

A1647449 A1673115 A1682037 A1684387 A1691672

A1692284

A1696403

A1698299 A1699228 A1699909

A2236912

A2345103

A2382443 A2382446 A2382448

A2382452

A2382453

A2382830

A2384560 A2385027 A2385474

A2385504

A2386376

A2389068

Audits and Self-Assessments

FASA, CAP Process Quality Maintenance (1453872) FASA, Preparation for NRC Problem Identification and Resolution (PI&R) Inspection Procedure

71152 (1607113) FASA, Protective Strategy (IP. 71130.05), (1610339)

4.0 critiques - crew response to 124A LC Transformer Failure, (1390776)

NO-AA-10, Quality Topical Report (1486097) North Anna Lessons Learned (1266661)

NOS: ID - Operations Fundamental Deficiencies (1492631)

NOSA-LIM-13-02: Security Programs Audit Report (1451226)

NOSA-LIM-13-03, Emergency Preparedness Audit (1460475 & 1625239)

NOSA-LIM-13-04, Corrective Action Plan Audit Report (1486097)

NOSA-LIM-13-05, Engineering Design Control Audit (1520662)

PI-AA-126-1001-F-01, Focused Area Self-Assessment: Permanent Plant Modifications 50.59

(1605341)

PI-AA-126-1001-F-01, Focused Area Self-Assessment: Inservice Test Program (1605381)

A-3

Attachment

Issue Reports

2873

502066

536788

670949

859270

930525

958120

1033351

1040098

1042812

1065596

1080954

1083741

1112134

1132208

1153478

1156338

1164290

1197843

200464

25849

25955

27038

230257

1239155

1262728

1266661

1282048

1306455

1306713

1316885

1317145

1317228

25162

1337334

1337813

1338537

1355888

1356794

1359672

1363381

1369889

1371755

1382311

1390019

1390033

1418917 1419420

1419423

1433104

1433187

1434678

1436208

1437657 1438827

1439284

1441934

1442748

1447634

1448005

1448416

1450954

1451640 1451714

1452156

1452159

1452196

1453737

1455179

1456033

1456034

1458794

1459314

1459317

1461065

1462042

1469144

1473255

1473751

1478866

1481691 1482020

1486275

1486278

1490191

1490281

1490765

1492631

1493530

1493735

1496014

1496078

1503427

1507365

1509125

1511763

1511869

1512745

1514337

1514746

1515025

1516342

1516809

1517065

1517485

1518728

20662

23844

1524096

1524143

1524270

1524287

1524304

24310

1524313

1524318

1525474

1525669

1526780

28088

1529195

1529292

1534114

1535683

1535897

1543347

1543499

1545695

1547115

1547152

1547159

1548613

1549475

A-4

Attachment

1550706

1550721

1550818

1569907

1574357

1581024

1586340

1593110

1594739

1596974

1610339

1620364

1621417

1621964

1622015

23028

1623088

1625519

1627435

1629288 1633040

1633875

1633876

1633880

1633882 1639507

1646747

1649873

1656057

1680988

1687504

1698508 1656634

1659298

1665658

1675612

1777057

1777060

1942432 *223691 2*238244 3*238244 6*238244 8*238245 2*238245 3*2382911

238547 7*238550 4*238570 3 *2386376

2385634

2388643

2389170

2389173

(* indicates that condition report was generated as a result of this inspection)

Work Orders

247697

248463

251801

252445

253721

253808

253939

1214186 1241103

262455

1283427

1280331

1294703

1596973

NCVs

NCV 2012-05-02: Failure to revise EDG tank cleaning work instructions (IR 1453737)

NCV 2012-07-01: Inadequate evaluation of voltage of safety-related equipment with offsite power available (IR 1418917)

NCV 2013-07-02: Fire Safe Shutdown Transfer Switches Not Periodically Tested (1515025)

NCV 2013-02-01: Failure to adequately assess battery charger operability in a timely manner (IR 1486275)

NCV 2013-03-01: Failure to Identify and Correct a Condition Adverse to Quality Associated with EDG No. D24 (IR

1507365,

1509125,

1511869,

1512745,

1526780 & 1528088)

NCV 2012-10-01: Failure to take timely corrective actions to address the 144D load center ODM contingency actions. (IR 2012010)

NCV 2013-04-01: License Condition 2.C.3 - inadequate guidance for fire brigade transportation to the spray pond pump house. (IR 2013007)

NCV 2013-04-03: Failure to prevent installation of a defective card into the 1A Redundant Reactivity Control System (1569907)

A-5

Attachment

Procedures

ARC-BOP-1CC514 F3, F.O STR Diff Press Hi, Revision 2

CC-AA-102, Design Input and Configuration Change Impact Screening, Revision 27

E-1691, Sheet 1, Communication & Fire Alarm Layout Radwaste Enclosure Plan Above

EL. 217"-0', Revision 10

ER-AA-310-1005, Maintenance Rule - Dispositioning Between (a)(1) and (a)(2)

ER-AA-310-1005, (a)(1) Action Plan Development and Action Plan (Monitoring) Goal Setting Template (Attachment 3), Revision 6 (IR1639507 - Control Enclosure Chilled Water, System 090)

ER-AA-310-1005, (a)(1) Action Plan Development and Action Plan (Monitoring) Goal Setting Template, Revision 6 (IR

1449120 - Seismic Monitoring System, System 365) F-D-311A (Fire Area 79), D11 Diesel Generat or and Fuel Oil-Lube Oil Tank Room, Rooms 311A

and 312A (El217), Revision 10 F-D-311A (Fire Area 79), D11 Diesel Generat or and Fuel Oil-Lube Oil Tank Room, Rooms 311A

and 312A (El217), Revision 11 F-W-410, Common, Radwaste Control Room, Laboratories, Laundry, Decontamination and Change Area, Waste Drum Storage Room, and Cask Loading Area Rooms 410-424 (El 217), Revision 3 M-095-006, Preventive Maintenance Procedure for Battery Chargers, Revision 6

OP-AA-106-101-1005, Quarantine of Areas, Equipment, and Records, Revision 0

OP-AA-108-115-1002, Supplemental Consideration for On-Shift Immediate Operability Determinations (CM-1), Revision 2

OP-LG-201-008, Limerick Generating Station Fire Protection (F) Pre-Fire Plan Strategies, Revision 4

PI-AA-120, Issue Identification and Screening Process, Revision 0

PI-AA-125, Corrective Action Program (CAP) Procedure, Revision 0

PI-AA-125-1001, Root Cause Analysis Manual, Revision 0

PI-AA-125-1003, Apparent Cause Evaluation Manual, Revision 1

PI-AA-126-1001, Focused Area Self-Assessments, Revision 0

PI-AA-126, Self-Assessment and Benchmark Program, Revision 0

PI-AA-1001, Performance Improvement Integrated Matrix, Revision 2

S92.3.N Receiving Diesel Fuel Oil Delivery, Revision 37SE-8, Fire, Revision 50

SE-8 Fire, Revision 50

SE-8 Fire Hard Card, Revision 0

SE-23, Security Threat, Revision 24

ST-5-020-810-0, Diesel Generator Fuel Oil Receipt Analysis, Revision 29

ST-6-092-365-0, Inoperability Unit 1 Safeguard Power Supply Actions for Both Units, Revision 44

SY-AA-101-132, Security Assessment and Response to Unusual Activities, Revision 22

WC-AA-106, Work Screening and Processing, Revision 13

Root and Apparent Cause Evaluations

CCA leads to performance of an ACE (1452199) Increasing trend in ESW AOV failures (162780)

Ineffective Collective Effectiveness Review (1524693)

Oil leak discovered when HPCI shutdown (1490191)

NOS ID: Procedure for boiler chemical addition not performed as written (1473751)

A-6

Attachment

124A Load Center Tripped (1390033) Safety-Related Raw Water Treatment Program (1665658)

Generic Communications & Operating Experience Information Notice 85-30, Microbiologically Induced Corrosion of Containment Service Water Systems Information Notice 2013-01, Emergency Action Level Thresholds Outside the Range of Radiation Monitors Information Notice 2013-15, Willful Misconduct / Record Falsification & Nuclear Safety Culture

Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment Generic Letter 90-05, Guidance for Performing Temporary Non-Code Repairs of ASME Code Class 1, 2, and 3 Piping (A01635331) Generic Letter 2006-02: Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power OPEX Review of NRC

IN 2013-01, EAL Thresholds and Radiation Monitors (1481380) OPEX Evaluation - Information Notice 2013-15, Willful Misconduct (1592062) NUREG 1801, Generic Aging Lessons Learned

Miscellaneous

2014 Organizational Effectiveness Survey results covering SCWE (a)(1) Action Plan for Control Enclosure Chilled Water System (a)(1) Action Plan for Seismic Monitoring System Additional documentation related to (a)(2) status for RHRSW

AD-AA-101, Processing of Procedures and T&RMs

ASME Code Case N-513-2 Calculation

LF-0007, Fixed Combustible Loadi ng Data Sheet for room 423, Revision 2

Completed surveillances for RHRSW for April 15, 2014

Control Room Log Entries Report, 12/14/2012

CY-LG-120-1102, Outside chemistry/NPDES-related sampling and analysis schedule

CY-LG-120-1117, Spray Pond Chemistry Guide

CY-AA-170-300, Offsite Dose Calculation Manual Administration

CY-LG-170-301, Offsite Dose Calculation Manual, Revision 25

CY-AA-170-3100, Offsite Dose Calculation Manual Revisions

ECR-11-00418, 2012 Security FOF project, Revision 0

Engineering technical evaluation for Identification of Augmented Examination Locations for Residual Heat Removal Service Water Piping on

HBC-507 (1691672-07) Engineering technical evaluation for Identification of Augmented Examination Locations for Residual Heat Removal Service Water Piping on

HBC-507 (2385027-04)

EP-AA-1008, LGS EAL Technical Basis

ER-AA-310-1005, (a)(1) Action Plan Development and Action Plan (Monitoring) Goal Setting Template, Attachment 3 for IR1525669, Revision 5

ER-AA-5400-1001, Raw Water Corrosion Program Guide Event Summary for D23 Fire,

IR 1065596 FBP07, Emergency Response Training Fire Brigade Program, Revision 7

HU-AA-1101, Change Management

LIM-93935, Failure Evaluation of a 20" NPS, Schedule 20, carbon steel RHRSW piping leak on 2A RHRSW HX inlet from Unit 2

Limerick Safety Culture Monitoring Panel (3Q 2012 - 2Q 2014)

A-7

Attachment

Limerick Semi-Annual Senior Leadership Team Nuclear Safety Culture Health Review (3Q 2012

- 2Q 2014)

Limerick Generating Station Radwaste Hit Team Maintenance Rule Online Tracking System

MRC Package for Tuesday, September 16

MRC Package for Wednesday, September 17

OP-AA-201-002, Fire Event Report, Revision 4, for Limerick Unit 2 D23 Emergency Diesel Generator. 217' Elevation/Diesel Bay Room 315C fire on May 5, 2010 P&ID - Emergency Service Water (Unit 1 and Common) - 8031-M-11, Rev. 91

Radwaste Improvement Benchmark Report (016838777-02)

Reactor Operator Shift Turnover Checklist for Unit 1 and Unit 2 for September 26, 2014 Response to NRC Request for Additional Information, dated June 21, 2012, related to LGS License Renewal Application Request for Additional Information for the Review of the Limerick Unit 1 & 2 license renewal application, dated March 13, 2014 Root Cause associated with the Manual Reactor SCRAM on July 18, 2012 due to a Fault on the 124A Load Center Switchgear, Revision 10

Sally Port Vehicle Search Mentoring Expectations Spray Pond Monthly System Report

ST-2-010-400-1, Radiation Monitoring - SW Radiation Monitor Calibration/Functional Test

ST-2-012-404 and 405, Radiation Monitoring - RHR Service Water Radiation Monitor Division

1, Channel A/B

ST-4-095-966-1, Div. IV 1DD103 Safeguard Battery Charger 24 Month Load Test, Revision 4

ST-4-095-966-2, Div. IV 2DD103 Safeguard Battery Charger 24 Month Load Test, Revision 5

ST-6-090-230, Control Enclosure Chilled Water Pump Valve and Flow Test, Revision 35

ST-6-090-231-0, Control Enclosure Chilled Water Comprehensive Test, Revision 33

Station Ownership Committee Agenda for August 27, and September 09, 12 & 29, 2014 System Health Report 4/1/2014-6/30/2014 UFSAR, Appendix 9A, Revision 17

White Paper Comparing the Impact of Seismic Agitation of Diesel Day Tank Sediment to Mixing Caused by Refilling from Tank Bottom and Impacts on Diesel Generator Operability

A-8

Attachment