IR 05000352/2012005

IR 05000352-12-005 and 05000353-12-005; on 10/01/2012 - 12/31/2012 Limerick Generating Station, Units 1 and 2; Licensed Operator Requalification and Post-Maintenance Testing

ML13036A364
Person / Time
Site:	Limerick
Issue date:	02/05/2013
From:	Mel Gray Reactor Projects Region 1 Branch 4
To:	Pacilio M Exelon Nuclear, Exelon Generation Co
GRAY, MEL
References
IR-12-005
Download: ML13036A364 (56)

Text

{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION ary 5, 2013

SUBJECT:

LIMERICK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000352/2012005 AND 05000353/2012005

Dear Mr. Pacilio:

On December 31, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Limerick Generating Station, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on January 11, 2013 with Mr. T.

Dougherty, Site Vice President, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents two findings of very low safety significance (Green). One of these findings was determined to involve a violation of NRC requirements. Additionally, two licensee-identified violations, which were determined to be of very low safety significance, are listed in this report. However, because of the very low safety significance, and because they are entered into your corrective action program, the NRC is treating these findings as non cited violations (NCVs), consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest any NCVs in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Limerick Generating Station. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at Limerick Generating Station.

In accordance with 10 Code of Federal Regulations (CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs 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/ Mel Gray, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos.: 50-352, 50-353 License Nos.: NPF-39, NPF-85

Enclosure:

Inspection Report 05000352/2012005 and 05000353/2012005 w/Attachment: Supplemental Information

REGION I== Docket Nos.: 50-352, 50-353 License Nos.: NPF-39, NPF-85 Report No.: 05000352/2012005 and 05000353/2012005 Licensee: Exelon Generation Company, LLC Facility: Limerick Generating Station, Units 1 & 2 Location: Sanatoga, PA 19464 Dates: October 1, 2012 through December 31, 2012 Inspectors: E. DiPaolo, Senior Resident Inspector J. Hawkins, Resident Inspector A. Rosebrook, Senior Project Engineer J. Caruso, Senior Operations Engineer R. Nimitz, Senior Health Physicist P. Kaufman, Senior Reactor Inspector S. Barr, Senior Emergency Preparedness Specialist C. Newport, Operations Engineer J. DeMarshall, Senior Operations Engineer (In-Training) Approved By: Mel Gray, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000352/2012005; 05000353/2012005; 10/01/2012 - 12/31/2012; Limerick Generating

Station, Units 1 and 2; Licensed Operator Requalification and Post-Maintenance Testing.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The inspectors identified two findings of very low safety significance, one of which was a non-cited violation (NCV). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). The cross-cutting aspects for the findings were determined using IMC 0310, Components Within Cross-Cutting Areas. Findings for which the SDP does not apply may be Green, or be assigned a severity level after NRC management review. 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, dated December 2006.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green finding of Exelon procedure TQ-AA-150, Operator Training Programs, and TQ-AA-155, Conduct of Simulator Training and Evaluation, based on a determination that the minimum number of scenarios required for simulator re-examination was not administered following a crew failure of the dynamic simulator scenario portion of the annual operating exam during week two of the 2012 Licensed Operator Requalification Training (LORT) Annual Operating Test. Exelon staff entered this finding into their corrective action program (CAP) (IR 1437839), conducted a prompt investigation, assigned an action to complete the annual operating exam scenario set for the crew in question, and initiated an Apparent Cause Evaluation (ACE).

The inspectors determined that the finding was more than minor because it was associated with the Human Performance attribute of the Mitigation Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).

The risk importance of this issue was evaluated using IMC 0609, Appendix I, Licensed Operator Requalification Significance Determination Process (SDP). Based on this screening criteria, the finding (inadequate retest) was characterized by the SDP as having very low safety significance (Green) because crew remediation was conducted and a partial re-evaluation performed. This finding had a cross-cutting aspect in the area of Human Performance, Work Practices, because Exelon did not ensure that personnel followed procedures [H.4(b)]. Specifically, the simulator scenario re-exam administered following a failed Annual Operating Test did not meet procedure requirements for number of scenarios.

   [H.4(b)]. (Section 1R11.3)

Green.

A self-revealing Green NCV of Technical Specification 6.8.1, Administrative Controls-Procedures, was identified because Exelon did not implement procedure use and adherence requirements when workers changed the scope of work on emergency diesel generator (EDG) fuel oil day tanks and did not revise the work instructions when they determined that work could not be performed as written. This resulted in EDG D13 accruing approximately 40 hours of unplanned unavailability between December 14 and 16, 2012.

Exelon entered the issue into their CAP as IR 1453737, conducted a human performance review board, drained and flushed the tank to restore fuel oil quality, and initiated an ACE.

This finding was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was determined to be self-revealing because it was revealed through the receipt of alarms during operation which required no active and deliberate observation by the Exelon staff. The finding was determined to be of very low safety significance (Green) in accordance with Section A of Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings at Power, because the finding did not represent an actual loss of function a single train for greater than the TS allowed outage time.

This finding had a cross-cutting aspect in the area of Human Performance, Work Practices, because Exelon did not ensure that personnel followed procedures [H.4(b)]. Specifically, work order procedural steps to clean the fuel oil tank were not completed as directed by the work order and a procedurally required change to written work instructions was not implemented when station personnel determined that the fuel oil tank cleaning would be based on the need to clean the tank as determined by tank inspection results. (Section 1R19)

Other Findings

Two violations of very low safety significance that were identified by Exelon personnel were reviewed by the inspectors. Corrective actions taken or planned by Exelon have been entered into Exelons CAP. These violations and corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at 100 percent power. On October 29, during a period of high winds due to Storm Sandy, operators reduced power to approximately 49 percent in response to lowering main condenser vacuum and high grid voltage. Operators returned the unit to 100 percent power on October 30. Power was reduced to approximately 87 percent on October 31 to facilitate a follow-up control rod pattern adjustment. Power was returned to 100 percent on November 1. An additional power reduction to 93 percent and follow-up control rod pattern adjustment was performed on November 3. Operators returned power to 100 percent on November 4. On November 12, power automatically reduced to approximately 70 percent when single loop operation was entered following the trip of the A reactor recirculation pump.

The cause of the trip was the loss of the pumps adjustable speed drive (ASD) due to solid state controller failures. Operators further reduced power to approximately 36 percent per procedural requirements. Following troubleshooting and repair of the adjustable speed drive, operators restarted the A reactor recirculation pump on November 15 and restored power to 100 percent later that day. A power reduction to approximately 80 percent was performed on November 16 to facilitate a follow-up control rod pattern adjustment and power was returned to 100 percent later that day. On December 7, operators reduced power to approximately 20 percent to remove the main turbine from service (Maintenance Outage 1M53) to facilitate repairs to stop a steam leak on the 1A2 moisture separator manway cover, repairs to the main generator hydrogen seal system and repairs to a low pressure turbine bleeder trip valve. Following the repairs, the main turbine was returned to service and the generator was synchronized to the grid on December 9. Unit 1 was returned to 100 percent power on December 10. 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 October 5, operators reduced power to approximately 65 percent to facilitate planned main condenser circulating water box cleaning, control rod scram time testing, and a control rod pattern adjustment. Operators returned power to 100 percent on October 6. Power was reduced to approximately 90 percent on October 12 to facilitate a follow-up control rod pattern adjustment. Power was returned to 100 percent later that day. On October 29, during a period of high winds due to Storm Sandy, operators reduced power to approximately 21 percent in response to lowering main condenser vacuum and high grid voltage. Operators returned the unit to 100 percent power on October 31.

An additional power reduction to approximately 80 percent and follow-up control rod pattern adjustment was performed on November 1. Power was returned to 100 percent later that day.

Operators reduced power to approximately 90 percent on November 16 to facilitate a control rod pattern adjustment. Operators restored power to 100 percent later that day. On December 16, operators reduced power to approximately 81 percent facilitate main turbine valve testing, control rod fuel channel distortion testing, and to perform a control rod exercise. Unit 2 was returned to 100 percent on December 17. Unit 2 remained at or near 100 percent power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Site Imminent Weather Conditions

a. Inspection Scope

During the approach of Storm Sandy to Montgomery County area, the inspectors attended storm preparation status meetings, reviewed site preparations for adverse weather, and reviewed preparations for plant damage assessment. The inspectors toured risk-significant and susceptible plant areas to verify the implementation of adverse weather preparation procedures and compensatory measures before the onset of adverse weather conditions. From October 29 until October 30, the inspectors observed plant response to the adverse weather and monitored Exelons damage assessment, review of emergency response capabilities, and corrective actions as a result of the storm. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified. ==1R04 Equipment Alignment

.1 Partial System Walkdowns

==

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems: EDG D14 following return-to-service for a two year overhaul B control room emergency fresh air system when A control room emergency fresh air system was out-of-service for testing on December 11, 2012 Unit 1 scram discharge volume level transmitters with LT-047-1N012C found out-of-calibration (Issue Report (IR) 1447377) Unit 1 seismic monitoring accelerometers with channel 1 failed (IR 1449120) 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 Updated Final Safety Analysis Report (UFSAR), technical specifications (TS), work orders, IRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable.

The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Exelon staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

.2 Full System Walkdown

a. Inspection Scope

The inspectors performed a complete system walkdown of accessible portions of the Unit 2 fuel pool cooling system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hangar and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related IRs and work orders to ensure Exelon appropriately evaluated and resolved any deficiencies.

b. Findings

No findings were identified. ==1R05 Fire Protection