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05000352/FIN-2000005-01an NCV of 10 CFR 50, Appendix B, Criterion V Was Identified Associated with Five Examples of Failure to Implement the Written Procedures of the Corrective Action Program2000Q2A Non-cited Violation of 10 CFR 50, Appendix B, Criterion V, wa identified associated with five examples of failure to implement the written procedures o the corrective action program, an activity affecting quality. Four examples involve failure to properly classify adverse trend corrective action items as required by th corrective action program procedure LR-CG-10. The adverse trend items wer associated with various topics including component mis-positioning, procedur adherence, and reactor downpower events. The fifth example of failure to implemen LR-CG-10 involved failure to conduct an operability evaluation of emergency diese generators (EDGs) in April 2000, when PECO determined that 70 of 88 flexcouplin clamps on the cooling water systems of its EDGs were over tightened. The failure t implement the procedures of the corrective action program is considered more than minor violation in that it suggests a programmatic problem that has a credible potentia to impact safety and involved more than an isolated occurrence. (4OA2.3)
05000352/FIN-2003004-03DID Not Perform a 10 CFR 50.54(Q) Review Resulting in Removal of a Provision Without Prior NRC Approval2003Q3The inspector identified a SL IV NCV of 10 CFR 50.54(q) because the licensee decreased the effectiveness of its emergency plan in one area by removing a provision to provide volunteer bus drivers to two school districts within the 10 mile Emergency Planning Zone for evacuating students during a radiological event. The change was implemented without NRC approval Changing emergency plan provisions without prior NRC approval impacts the NRC's ability to perform its regulatory function and is therefore processed through traditional enforcement as specified in Section IV.A.3 of the Enforcement Policy, issued May 1, 2000 (65 FR 25388). According to Supplement VIII of the Enforcement Policy, this finding was determined to be a SL IV violation because it involved a failure to meet a requirement not directly related to assessment and notification. This NCV was also determined to have very low safety significance since Exelon had maintained a list of volunteers that would have been able to perform the function if needed.
05000352/FIN-2003004-04DID Not Retain a Record of the 10 CFR 50.54(Q) Review of the Deleted Portions of the Emergency Plan2003Q3The inspector identified a SL IV non-cited violation of 10 CFR 50.54(q). During the implementation of a new Standard Emergency Plan, Exelon did not retain a record that determined whether a decrease-in-effectiveness had or had not occurred when Exelon generated the new Standard Emergency Plan that deleted portions of the previous Combined Limerick/Peach Bottom Emergency Plan Changing emergency plan provisions without documentation impacts the NRC's ability to perform its regulatory function and is therefore processed through traditional enforcement as specified in Section IV.A.3 of the Enforcement Policy, issued May 1, 2000 (65 FR 25388). According to Supplement VIII of the Enforcement Policy, this finding was determined to be a SLl IV because it involved a failure to meet a requirement not directly related to assessment and notification.
05000352/FIN-2003006-0110CFR50.54(Q) Violation for Decreasing the Effectiveness of the Plan by Changing Eals That Address Toxic Gas Without Prior NRC Approval2003Q1The licensee changed its emergency action level schemes such that there would e a reduction in declarable events as the emphasis shifted from personnel safety to equipment status. The changes were determined to be a decrease in the effectiveness of the emergency plans. Decreases in the effectiveness of an emergency plan must receive NRC review prior to implementation. The changes were implemented without NRC approval. The finding was determined to be more than minor as its significance was related to the impact it would have on the mobilization of the emregency response organization and preclude offsite agencies from being aware of adverse conditions on site. The licensee accepted the NRC's position and entered this issue into its corrective action program (Condition Report 139997) and will change the emergency action levels back to the original wording. The implementation of the changes which decreased the effectiveness of the emergency plans, without NRC review, is being treated as a non-cited violation consistent with Section VI.A. of the Enforcement Policy, issued on May 1, 2000 (65 FR 25388). (NCV 50-277; 50-278/03-008-01 and 50-352;50-353/03-006)
05000352/FIN-2008002-01Inadequate Maintenance Procedure for the 2A Main Transformer2008Q1A self-revealing finding was identified for an inadequate maintenance procedure regarding electrical connections associated with the Unit 2A Main Transformer bushings. The procedure was not clear as to the appropriate method to prepare the surface for an aluminum bushing terminal and did not provide adequate information on torque requirements and the use of anti-oxidant grease. This resulted in the failure of the bushing connection and a Unit 2 reactor scram on February 1, 2008. Exelon entered this issue into the corrective action program (CAP), performed repairs, and revised the procedure to reflect the appropriate information to successfully assemble the connection. The issue is more that minor because it is associated with procedure quality attribute of the Initiating Events cornerstone and affected the objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. The inspectors evaluated the finding using Phase 1 of IMC 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations. This finding was determined to be of very low safety significance (Green) because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would be unavailable
05000352/FIN-2008002-02Failure to Correct Main Turbine Bypass Valve Adverse Condition2008Q1The inspectors identified a Green finding for failure to identify corrective actions for an adverse condition associated with unsatisfactory performance of a Unit 1 main turbine bypass valve following an automatic scram event on March 22, 2008. As a result, an appropriate operability determination was not performed and the issue was not considered by the Plant Operations Review Committee during a restart meeting on March 23, 2008. Exelon entered the issue into the CAP for resolution. The finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was assessed using Phase 1 of IMC 0609, Appendix A, Significance Determination for Reactor Inspection Findings for At-Power Situations, and determined to be of very low safety significance (Green) because the finding did not represent an actual loss of safety function of single train for greater than its TS allowed outage time. This finding has a cross-cutting aspect of Problem Identification and Resolution (PI&R) because Exelon did not thoroughly evaluate the problem such that the resolution addressed the cause of the condition or the effect the condition had on system operability (P.1(c))
05000352/FIN-2008002-03Failure to Promptly Implement Actions for a LOW Sst Level2008Q1Inspectors identified a Green non-cited violation (NCV) of Technical Specification (TS) 6.8.1 for failure to promptly implement actions to recover the Unit 1 skimmer surge tank (SST) level during the 1R12 Unit 1 refueling outage. Prompt action by the operators would have prevented entrainment of the air into the residual heat removal (RHR) system, elevated radiation levels on the refuel floor, and subsequent entry into off-normal procedure ON-120, Fuel Handling Problems. Exelon entered this issue into their CAP for resolution. This finding is more than minor because it affects the human performance attribute of the Initiating Events cornerstone and the objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors evaluated this finding using IMC 0609, Appendix G, Shutdown Operations Significance Determination Process, Attachment 1. This finding is of very low safety significance (Green) because the finding did not require quantitative assessment per Checklist 7 of Attachment 1 to IMC 0609 Appendix G. The reactor time-to-boil during this event was approximately 26 hours and adequate time was available to vent and restart the affected RHR pump in the Alternate Decay Heat Removal (ADHR) mode of operation. Additionally, during the time that ADHR was secured, natural circulation provided reactor coolant flow. This finding has a human performance cross-cutting aspect in the area of work practices. Specifically, operators did not follow OP-AA-103-102, Watchstanding Practices, in that they did not promptly implement actions required by the applicable alarm response procedure to recover SST level following receipt of the associated control room alarm (H.4(b))
05000352/FIN-2008003-01Failure to Correct Adverse Condition Associated with Motor Operated Valves2008Q2The inspectors identified an NCV of Title 10 of the Code of Federal Regulations, Part 50 (10CFR50), Appendix B, Criterion XVI, Corrective Action, for not correcting a condition adverse to quality associated with safety-related motor operated valve motor control center auxiliary contact switches in a timely manner following the failure of the Unit 1 Core Spray Loop A test bypass primary containment isolation valve (HV-052-1F015A) to close on August 3, 2006. As a result, the Unit 2 Reactor Core Isolation Cooling (RCIC) turbine exhaust line vacuum breaker outboard primary containment isolation valve (HV-049-2F080) experienced a similar failure to close on June 4, 2008. The finding was more than minor because it was associated with the structures, systems, and components and barrier containment performance attribute of the Barrier Integrity cornerstone and affected the objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents and events. The inspector assessed the finding using Phase 1 of IMC 0609, Appendix A, Significance Determination Process for Reactor Inspection Findings for At-Power Situations and determined the finding to be of very low safety significance (Green) because the finding did not represent an actual open pathway in the physical integrity of reactor containment. This finding has a crosscutting aspect of Problem Identification and Resolution because Exelon did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with the safety significance and complexity (P.1(d))
05000352/FIN-2008003-02Licensee-Identified Violation2008Q2Technical Specification 3.3.7.1, Monitoring Instrumentation Radiation Monitoring Instrumentation, requires one operable reactor enclosure cooling water (RECW) system radiation monitor channel at all times. Action 72 of Table 3.3.7.1-1 requires obtaining a grab sample every 24 hours with the required monitor inoperable. Contrary to TS 3.3.7.1, the required RECW Radiation Monitor was inoperable in Unit 2 from March 24, 2008 until April 15, 2008 without obtaining a grab sample every 24 hours. The event is documented in Exelons CAP as IR 763510. The finding was of very low safety significance because it does not represent an open pathway in the physical integrity of reactor containment
05000352/FIN-2008003-03Licensee-Identified Violation2008Q2Technical Specification 3.9.2, Refueling Operations - Instrumentation, requires an operable source range monitor (SRM) in the quadrant where core alterations are being performed when in Operational Condition 5 (OPCON 5). If this requirement is not satisfied, the operators are required to immediately suspend all operations involving core alterations and insert all insertable control rods. Contrary to TS 3.9.2, on March 16, 2008, with Unit 1 in OPCON 5, a control rod was withdrawn with the required source range monitor in the affected core quadrant inoperable. The event is documented in Exelons CAP as IR 750227. The finding is of very low safety significance because the finding did not require quantitative assessment per Checklist 7 of Attachment 1 to IMC 0609, Appendix G, Shutdown Operations Significance Determination Process
05000352/FIN-2008004-01Inadequate Secondary Containment Control Procedure2008Q3The inspectors identified a NCV of Technical Specification (TS) 6.8.1, Administrative Controls Procedures, because Exelon did not maintain adequate procedures in that Emergency Operating Procedure T-103, Secondary Containment Control, contained an inappropriate high maximum safe operating flooding level for the Unit 2 High Pressure Coolant Injection (HPCI) room. The inspectors determined that this finding was greater than minor because it affected the procedure quality attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring availability, reliability, and capability of the HPCI system. Emergency Operating Procedure T-103, Secondary Containment Control, delineated an incorrect value of 40 inches for the Unit 2 HPCI room maximum safe operating (MSO) flooding level. Water at this height in the Unit 2 HPCI room would submerge the auxiliary oil pump and would render the HPCI system inoperable. This finding is of very low safety significance because it did not represent a design or qualification deficiency, a loss of safety system function, an actual loss of safety function of a single train for greater than its TS allowed outage time, or a total loss of any safety function that contributes to external event-initiated core damage sequences. The inspectors determined that this violation has a crosscutting aspect in the area of problem identification and resolution because Limerick did not perform a thorough extent-of-condition review following a 2005 NCV for a similar issue for the Unit 1 RCIC room MSO level (NCV 05000352/2005003-01). Although the station identified that the Unit 2 HPCI auxiliary oil pump and its associated junction box were located below the MSO level during the review, Limerick did not thoroughly evaluate the impact of the elevation difference on the operation of the HPCI system (P.1(c)). (Section 1R06)
05000352/FIN-2008005-01Changes to Technical Specification 3.8.1 Bases2008Q4On September 30, 2008, operators racked out one of the two offsite power supply feeder breakers to 4kV Emergency Bus D11 (201-D11) for maintenance. The inspectors noted that although one of the two offsite power sources was not available to4kV Emergency Bus D11, operators did not declare the associated offsite power circuit(201 Circuit) inoperable and enter into TS Limiting Condition for Operation (LCO)3.8.1.1, AC Sources V Operating, Action f, which requires, in part, performing Surveillance Requirement (SR) 4.8.1.1.a within one hour and also entails entering a 72hour LCO shutdown action statement. The inspector noted that TS SR 4.8.1.1.1.b could not be met if one of the two offsite power source breakers was racked out. That SR states Each of the above required independent circuits between the offsite transmission network and the onsite Class 1E distribution system shall be demonstrated OPERABLE in accordance with the Surveillance Frequency Control Program by transferring, manually and automatically, unit power supply from the normal circuit to the alternate circuit. With an offsite power supply feeder breaker racked out and unavailable to a nonsite 4kV emergency bus, manual and automatic transfer was not possible. In addition, TS 4.0.1 states, in part, that, Failure to meet a Surveillance, whether such failure is experienced during the performance of a Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation. The inspectors referenced TS Bases 3/4.8.1, which described that an offsite circuit is considered to be inoperable if it is not capable of supplying at least three, Unit 1 4kVemergency buses. Recognizing that the TS Bases 3/4.8.1 appeared to conflict with the SR, the inspectors questioned the history of the bases. Exelon informed the inspectors that the bases were modified in 2000 to define an operable offsite source as one capable of supplying power to three of the four emergency buses in the unit, through Engineering Change Request (ECR) LGS ECR 99-00682.The inspectors reviewed LGS ECR 99-00682 and found that Exelons 10 CFR 50.59screening for the TS bases change concluded that the change was an enhancement, and, as such, a change to the TS was not required. The ECR described the change as taking advantage of system redundancy similar to the design of the EDGs. Specifically, section 8.3.1.1.2.2 of the UFSAR provides results of a single failure analysis (focused on the EDGs but also applicable to the 4kV emergency buses) that concludes that any combination of three-out-of-four buses could withstand a single failure and still safely shut down the plant. The inspectors reviewed the Limerick licensing basis and found several conflicts with Exelons conclusion. Namely, the TS bases change:FnConflicted with the facility as described in the UFSAR Sections 8.2.1, Offsite Power Sources. Section 8.2.1.1 describes that Both offsite sources are available continuously to the Class 1E buses; andFnConflicted with the description of the onsite emergency power system description as documented in NUREG-0991, Safety Evaluation Report Related to the Operation of Limerick Generating Station, Units 1 and 2, dated August 1983. Section 8.3.1 of the Safety Evaluation Report stated that Each 4.16-kV ESF (Engineered Safety Feature) bus is normally connected to two offsite power sources, designated as preferred and alternate power supplyK; and,FnAlthough the ECR described the change as taking advantage of system redundancy similar to the design of the EDGs, the inspector noted that a TS Action is required to be entered for one EDG being inoperable. The inspectors determined that the modification of the TS bases appeared to be in conflict with the requirements of TS LCO 3.8.1.1 through the application of SR4.8.1.1.1.b. Therefore, it appeared that the change should have required a change to the TS, which would have required NRC review. Making the TS bases change without changing the TS appeared to be contrary to 10 CFR 50.59 (c)(1)(i) which states that a licensee may make changes in the facility as described in the final safety analysis reportKwithout obtaining a license amendment pursuant to (paragraph) 50.90 only if a change to the technical specifications incorporated in the license is not required. In addition, the changes made to the TS bases appeared to be contrary to TS 6.8.4.h,Technical Specification Bases Control Program, which contains similar requirements. Exelon acknowledged the inspectors observations and agreed to provide additional information to show that the changes made to the TS bases did not require prior NRC approval. Pending the review of the additional information to be provided by Exelon, this issue is unresolved
05000352/FIN-2008005-02Inadequate Post-Maintenance Test following Containment Isolation System Relay Replacement2008Q4The inspectors identified a NCV of Technical Specification 6.8.1, Administrative Controls-Procedures, because Exelon did not maintain adequate maintenance procedures associated with work performed on the Unit 2 Nuclear Steam Supply Shutoff System (NSSSS). Specifically, the procedures, which performed system relay replacements, did not contain adequate post-maintenance testing (PMT) to demonstrate that the Technical Specification required response times of all circuits affected by the maintenance were satisfied. The inspectors determined that this finding was more than minor because it was associated with the procedure quality attribute of the Mitigating System cornerstone, and affected the Mitigating System cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. As a result of the inadequate PMT, additional unavailability was accrued, and an engineering evaluation was required to demonstrate satisfactory response times. The finding was determined to be of very low safety significance(Green) because it did not represent a loss of safety function. The inspectors determined this finding had a cross-cutting aspect in Human Performance, Resources, because Exelon did not provide complete and accurate work packages to assure nuclear safety. Specifically, the NSSSS was returned to service without all the required post-maintenance testing being performed to demonstrate operability. (IMC 0305 aspect:H.2(c)) (Section 1R19
05000352/FIN-2008006-01Failure to Implement a Maintenance Activity for the Reactor Building Crane2008Q3A Green non-cited violation (NCV) of 10CFR Part 50, Appendix B, Criterion III, Design Control was identified. The NCV was related to Exelons failure to implement a preventative maintenance requirement described in a design calculation used to upgrade the 125 ton reactor building bridge crane. The finding is more than minor because, if left uncorrected, it could become a more significant safety concern if the crane components were allowed to degrade in an undetected manner. Specifically, the failure to develop the specified preventative maintenance practice could lead to operation of the crane in a degraded condition. The inspectors used Inspection Manual Chapter 0609 Appendix M, Significance Determination Process Using Qualitative Criteria, because other significance determination process guidance was not suited to provide reasonable estimates of the significance of this inspection finding. With the assistance of Region I management, the inspectors determined that the finding was of very low safety significance (Green) because there was no actual crane operational problem during the spent fuel handling activities.
05000352/FIN-2008009-01Failure to Complete Bleeder Trip Valve Testing2008Q3The inspectors identified a finding of very low safety significance for Exelons failure to complete the testing described in the Updated Final Safety Analysis Report (UFSAR) for one of the third stage feedwater heater bleeder trip valves. Exelon entered this issue into the corrective action program under issue reports (IRs) 772753, 812344, 817399, and 817443, and on August 28, 2008, started testing bleeder trip valve XV-002- 108B at the desired frequency stated in the UFSAR. The inspectors determined that this finding is greater than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and has the potential to adversely affect the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Not testing the bleeder trip valves in accordance with the statements in the LGS UFSAR adversely impacted the assumptions in LGSs turbine missile probability analysis thereby potentially increasing the probability for damage to safety-related plant equipment caused by the release of high-energy turbine components. The inspectors evaluated this finding using IMC 0609, Attachment 4, Initial Screening and Characterization of Findings, and determined the finding is of very low safety significance. The inspectors also determined that this issue has a problem identification and resolution cross-cutting aspect in the corrective action area because LGS did not thoroughly evaluate the potential impact of an identified problem on the operability of safety-related equipment. Specifically, Exelon did not evaluate the impact that deferred bleeder trip valve testing may have had on the probability that the operability of safety related equipment could have been impacted by turbine missiles. (P.1(c))
05000352/FIN-2009002-01Failure to Maintain Design Control for Reactor Building Temperatures2009Q1The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion III, Design Control, for the failure to translate minimum room temperatures assumed in an isolation actuation instrumentation setpoint calculation into Unit 1 and 2 procedures such that reactor building room temperatures were maintained above the minimum assumed. As a result, the reactor enclosure and refueling area ventilation systems were not operated to assure that room temperatures were maintained above the minimum assumed in design basis calculations. Exelon entered the issue into the Corrective Action Program (CAP) for resolution. This finding was more than minor because it was associated with the Design Control attribute of the Barrier Integrity cornerstone, and affected the Barrier Integrity cornerstone objective to provide reasonable assurance that physical design barriers, including containment, protect the public from radionuclide releases caused by accidents or event. This finding was determined to be of very low safety significance because it did not represent an actual open pathway in the physical integrity of reactor containment, containment isolation system, and heat removal components. This finding has a crosscutting aspect in Human Performance, Decision Making, because the licensee did not make a safety significant decision using a systematic process to ensure safety was maintained H.1(a). Specifically, the decision to operate the reactor buildings at lower temperatures was made using an informal process within operations, therefore interdisciplinary input and a review by engineering and other support organizations was not obtaine
05000352/FIN-2009002-02Failure to Obtain License Amendment for TS Bases Change2009Q1The inspectors identified a Severity Level IV NCV of 10 CFR 50.59, Changes, Test, and Experiment, for failing to obtain a Technical Specification (TS)license amendment for a change made to the TS Bases concerning offsite power source operability. Changes made to TS Bases 3/4.8.1 required a change in the TS, because the change caused the bases to be in direct conflict with the requirements of TS Limiting Condition for Operation 3.8.1, AC Sources Operating, through the application of associated TS surveillance requirements. Exelon entered this issue into the CAP and issued night orders to operators which required declaring an offsite power supply inoperable when an offsite power supply feeder breaker became unavailable to an emergency bus. Because this was a violation of 10 CFR 50.59, it was considered to be a violation which potentially impedes or impacts the regulatory process. Therefore, such violations are characterized using the traditional enforcement process. In this case, the licensee failed to perform an adequate safety evaluation in accordance with 10 CFR 50.59 because the approved change to the technical specification basis was in conflict with the TS surveillance requirements. This change required prior approval from the NRC before its implementation. Comparing this item to the examples in NUREG 1600, Supplement I, Reactor Operations, this finding is more than minor because NRC approval would have been required. The inspectors completed a Significance Determination Review using NRC IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings. Using the Phase I Screening worksheet the finding was determined to be of very low safety significance (Green) since the finding did not represent an actual loss of safety function for greater than the TS allowed outage time. Comparing this item to the examples in NUREG 1600, Supplement I, this finding is similar to Item D.5, Violations of10 CFR 50.59 that result in conditions evaluated as having very low safety significance(i.e., Green) by the SDP. This is an example of a Severity Level IV violation. Since the TS Bases change was made in 2000, the inspectors determined that this finding was not reflective of current licensee performance and, therefore, did not have a cross-cutting aspect
05000352/FIN-2009002-03Licensee-Identified Violation2009Q1Technical Specification 6.8.1.g, Procedures and Programs, requires that written procedures shall be established, implemented, and maintained covering fire protection program implementation. Contrary to this requirement, Exelon failed to establish an adequate remote shutdown procedure to align RCIC pump suction to the suppression pool as assumed and analyzed in the fire safe shutdown analysis. Specifically, Exelon did not ensure that procedure SE-1.Remote Shutdown, contained the proper steps to align the RCIC pump suction to the suppression pool while operating the system at the remote shutdown panel for a fire in the main control room or the cable spreading room. The issue was entered into Exelons corrective action program as IR 843591. The finding was more than minor because it is associated with the procedural quality attribute of the Mitigating Systems Cornerstone and affects the cornerstone objective of ensuring the availability and reliability of the RCIC system under postulated fire safe-shutdown conditions. The inspectors determined that the finding was of very low safety significance (Green), based on IMC 0609, Appendix F, Fire Protection Significance Determination Process, Phase 2 screening, Task Number 2.3.5, because no credible fire ignition source scenarios were identified
05000352/FIN-2009003-01Failure to Adequately Assess Erratic Time Delay Relay Operation on Unit 2 HPCI Operability2009Q2The inspectors identified a Green finding associated with the failure to adequately assess erratic time delay relay operation on Unit 2 High Pressure Coolant Injection (HPCI) system operability in a timely manner commensurate with the potential safety significance. Following a failed surveillance test, the Unit 2 HPCI system was considered operable despite erratic operation of a system time delay relay and the operators failure to adequately address the relays design basis function. Exelon placed this issue in the CAP (IR 933745). Exelons corrective actions included: performing operations shift crew briefings on the issue; emphasizing the need for applying a questioning attitude; and requesting timely engineering support for emergent Technical Specifications (TS) equipment issues. Also, a structured operability determination template was added to the corrective action program IR form. This finding is more than minor because it was associated with the human performance attribute of the Mitigating Systems cornerstone, and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors assessed the finding using IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings and determined the finding to be of very low safety significance (Green)because it did not represent a loss of safety function of a single train for greater than the TS allowed outage time; was not associated with a design or qualification deficiency; and did not screen as risk significant due to seismic, flooding, or severe weather events. This finding has a crosscutting aspect in Human Performance, Decision-Making, because Exelon did not make a safety-significant decision using a systematic process, especially when faced with uncertain or unexpected plant conditions, to ensure safety is maintained (H.1(a)). Specifically, Exelon did not obtain timely interdisciplinary input and review on a safety significant decision in that site engineering did not review the operations decision and operations did not implement the subsequent engineering recommendation until two days after the failed surveillance.
05000352/FIN-2009003-02Licensee-Identified Violation2009Q2TS LCO 3.3.7.5, Accident Monitoring Instrumentation, Item 13, requires two channels of Neutron Flux Instruments to be operable in OPCON 1. With less than the required number of operable channels, TS 3.3.7.5 requires restoration of the inoperable channels with 7 days or be in at least Hot Shutdown within the next 12hours. With no operable channels, TS 3.3.7.5 requires restoration of the inoperable channels within 48 hours or be in at least Hot Shutdown within the next 12 hours. Contrary to TS 3.3.7.5, Unit 1 operated in OPCON 1 for periods longer than allowed without the required number of operable Neutron Flux Instruments due to inoperable Source Range Monitors. Specifically, during the periods from October 5, 2006 to December 18, 2006, and December 14, 2006 to April 21, 2007, less than the required number of operable channels of Neutron Flux Instruments were operable. During the periods from January 20, 2006 to February 20, 2006, December 14, 2006to December 18, 2006, and February 20, 2007 to April 21, 2007, no operable channels of Neutron Flux Instruments were operable. The issue was entered into Exelons CAP as IR 867666. The finding was determined to have very low safety significance (Green) using IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria, because the SRMs only provide indications to operators following an accident and other instrumentation (i.e., intermediate range monitors and average power range monitors) were available during the time periods in question to ensure the reactor would remain in a safe, shutdown condition.
05000352/FIN-2009004-01Failure to Adequately Test 480 Volt Motor Control Unit Circuit Breakers2009Q3The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, for failure to establish a test program for all safety-related 480 volt motor control unit (MCU) circuit breakers to assure that necessary testing was performed to demonstrate that they would perform the safety-related function in service. Specifically, in 2004, Exelon inappropriately classified certain safety-related 480 volt molded-case circuit breakers as run-to-failure in the Performance Centered Maintenance (PCM) process, which resulted in the breakers receiving no planned preventive maintenance or testing. Exelon entered this issue into the Corrective Action Program (CAP) for resolution as Issue Report (IR) 948232. Exelons corrective actions included: reclassifying all safety-related 480 volt MCUs as either critical or non-critical, a formal review of the vendors technical bulletin for applicability; and an extent-of-condition review of all direct current MCUs and 4 kilovolt circuit breakers. Also, preventive maintenance and testing was planned for all in-service 480 volt MCUs that had gone overdue because they were inappropriately classified as run-to-failure. This finding is more than minor because, if left uncorrected, the performance deficiency would lead to a more significant safety concern. Specifically, the installed molded case circuit breakers classified as run-to-failure had received no periodic planned maintenance or tests and were beyond the manufacturers design life. Based on operating experience, this would result in a breaker being slow to trip or sticking in the on position after an over-current condition. The inspectors assessed the finding using Phase 1 of IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings and determined the finding to be of very low safety significance because the issue was a qualification deficiency confirmed not to result in loss of operability per Part 9900, Technical Guidance, Operability Determination Process for Operability and Functional Assessment. Since the change to the PCM process was made in 2004, the inspectors determined that this finding was not reflective of current licensee performance and, therefore, did not have a cross-cutting aspect
05000352/FIN-2009004-02Failure to Correct 480V Breaker Thermography2009Q3The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for failing to correct a condition adverse to quality associated with the performance of thermography on safety-related breakers. Specifically, although Exelon identified that the failure to perform thermography on breakers in a loaded condition was a causal factor for an electrical fault that occurred in January 2009, Exelon did not implement proper corrective actions to ensure that applicable future thermography examinations would be conducted while the equipment was in a loaded condition. Exelon entered this issue into the CAP as IR 874599, Assignment 58. Corrective actions included adding 48 breakers to the list of breakers that will be loaded prior to thermography and creating an assignment to formally assess the remaining breakers that may not receive routine thermography due to not being in a loaded condition. The finding was more than minor because it was associated with the equipment 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 inspectors assessed the finding using Phase 1 of IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings and determined the finding to be of very low safety significance because it was not a design or qualification deficiency, did not represent a loss of system safety function, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because Exelon did not take appropriate corrective actions to address a safety issue (P.1(d)). Specifically, although the failure to perform thermography on breakers in loaded conditions was identified as a causal factor for an electrical fault, actions were not taken in a timely manner to ensure loaded conditions for applicable future thermography examinations
05000352/FIN-2009004-03Licensee-Identified Violation2009Q3TS LCO 3.7.8, Main Turbine Bypass System, requires the main turbine bypass system to be operable when in Operational Condition 1, when thermal power is greater than or equal to 25 percent of rated thermal power. With the main turbine bypass system inoperable, TS 3.7.8 requires restoration of the system to an operable status within 1 hour or take the action required by TS 3.2.3.c. TS 3.2.3.c requires that Minimum Critical Power Ratio (MCPR) be determined to be greater than or equal to the rated MCPR limit specified in the Core Operating Limits Report Main Turbine Bypass Valve Inoperable Curve. Contrary to TS 3.7.8, Unit 2 operated in Operational Condition 1 with thermal power greater than 25 percent with the main turbine bypass system inoperable for greater than 1 hour and the action required by TS 3.2.3.c was not performed. Specifically, during troubleshooting and surveillance test activities on February 15, 2008, May 24, 2008, September 13, 2008, and December 14, 2008, the main turbine bypass system was rendered inoperable for greater than one hour and the MCPR was not determined to be greater than or equal to the rated MCPR limit specified in the Core Operating Limits Report. The issue was entered into Exelons CAP as IR 917231. The finding was determined to have very low safety significance (Green) using NRC IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, Fuel Barrier, because operation with MCPR less than the rated MCPR limit specified in the Core Operating Limits Report could potentially only affect the fuel barrier and the condition did not represent a loss of the pressure mitigating function of the main turbine bypass system or affect the spent fuel pool
05000352/FIN-2009005-01Failure to Ensure Adequate Cooling Water Flow to Residual Heat Removal Room Unit Cooler2009Q4The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XI, \\\'Test Control, for improperly positioning the Emergency Service Water (ESW) throttle valve to the Unit 1 \\\'A\\\' Residual Heat Removal (RHR) room unit cooler during an ESW flow balance surveillance test in April 2008. During the test, Exelon failed to adequately evaluate ESW flow data, and established ESW flow to the unit cooler at less than the minimum required. This rendered the \\\'A\\\' RHR room unit cooler incapable of removing its design heat load for a period of approximately 13 months. Exelon entered this issue into their corrective action program for resolution. This finding is more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone, and it impacted the cornerstone objective of ensuring the availability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Exelon\\\'s failure to accurately evaluate test data resulted in an inadequate ESW flow rate through the \\\'A\\\' RHR room unit cooler, rendering it incapable of removing its design heat load. The finding is of very low safety significance because it did not represent a loss of safety function of a TS train or risk significant non-TS train. This finding has a cross-cutting aspect of Human Performance, Work Practices, because Exelon personnel did not utilize adequate human error prevention techniques, such as self and peer checking, to ensure work activities were performed properly (H.4(a)). Specifically, Exelon personnel did not utilize human error prevention techniques to ensure an accurate flow calculation in April 2008.
05000352/FIN-2009005-02Failure to Identify Degraded Instrument Line in Emergency Service Water System2009Q4The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for Exelon\'s failure to identify a condition adverse to quality associated with the \'A\' ESW pump discharge pressure instrument line. Specifically, Exelon had previous opportunity to identify and repair a degraded \'A\' ESW instrument line following a leak on a similar instrument Iine in August 2008. However, the degraded condition of the \'A\' instrument line was not detected until it resulted in a through-wall leak on November 7,2009. In response to the leak, Exelon was required to isolate the \'A\' ESW pump and enter the associated 45-day TS action statement. Exelon entered this issue into their corrective action program as Issue Report (IR) 990204 and IR 993012. Corrective actions included performing an investigation and scheduling extent of condition testing on the remaining 18similar instrument lines. The finding is more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone, and it impacted the cornerstone objective of ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. Specifically, upon discovery of the through-wall leak, Exelon was required to isolate the \'A\' ESW pump and enter the associated 45 day TS action statement. The finding is of very low safety significance because it did not represent the loss of a TS train for greater than its allowed outage time. This finding has a cross-cutting aspect of Problem Identification and Resolution, Corrective Action Program, because Exelon did not take appropriate corrective actions to address a safety issue regarding corrosion in the ESW instrument lines P.1(d). Specifically, although Exelon directed non-destructive examination (NDE) be performed to identify degraded ESW instrument lines, Exelon failed to ensure the scope of the NDE was sufficient to identify the degraded condition in the \'A\'ESW pump instrument line
05000352/FIN-2009005-03Licensee-Identified Violation2009Q410 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that all applicable regulatory requirements and the design basis for structures, systems, and components are correctly translated into specifications, drawings, procedures and instructions. Contrary to the above, inadequate isolation actuation instrumentation setpoints were translated into Units 1and 2 Technical Specification 3.2.2, Isolation Actuation Instrumentation, Table 3.3.2-2, Isolation Actuation Instrument Setpoints, Item 4.e, HPCI Equipment Room Temperature - High. This condition existed from January 1995, when Technical Specification Amendments 85 and 46 were issued, until the condition was discovered on August 27, 2009. This issue was identified during a review of the steam leak detection system calculations and was identified in Exelon\'s CAP as IR 958587. Upon discovery, appropriate compensatory actions (i.e., disabling of the room coolers) were implemented to return the system to an operable status. This finding was determined to have very low safety significance (Green) using NRC IMC 0609, Appendix H, Containment Integrity Significance Determination Process, because it did not represent a finding of greater significance for LERF using Table 6.2, Phase 2 Risk Significance-Type B Findings at Full Power.
05000352/FIN-2009006-01Failure to Verify Battery Capacity to Recover from Station Blackout2009Q4The team identified a finding of very low safety significance involving a noncited violation of 10 CFR 50.63, Loss of All Alternating Current (AC) Power, because Exelon\'s coping analysis did not determine whether the battery capability and capacity was sufficient to recover AC power at the end of the required coping period. Specifically, Exelon\'s battery sizing and station blackout (SSO) load profile calculation did not include those loads necessary to recover AC power, such as starting an emergency diesel generator (EDG) or closing 4 kV switchgear breakers. As a result, the calculation did not verify there was adequate direct current (DC). voltage available to critical equipment during the SSO coping period. Exelon entered the issue into their corrective action program and performed and operability assessment which determined the battery was operable. This issue was more than minor because it is associated with the design control. 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. The team determined the finding was of very low safety significance because it was a design deficiency subsequently confirmed not to result in a loss of operability or functionality. The finding did not have a cross-cutting aspect because it was determined to be a legacy issue not considered to be indicative of current licensee performance.
05000352/FIN-2009006-02TS Requirements for MOV Thermal Overload Bypass Feature2009Q4An unresolved item (URI) was identified because additional NRC review and evaluation is needed to determine if Exelon is meeting Technical Specification (TS)3.8.4.2b. and/or TS Surveillance Requirement (SR) 4.8.4.2.2. The team questioned whether Exelon was meeting the licensing requirements for bypassing thermal overloads for all Class 1E MOV\'s with spring-to-normal control switches during an accident and/or whether testing used to satisfy the requirements for a Channel Function Test of the MOV circuit was adequate related to alarm testing. TS Section 3.8.4.2b states that the thermal overload protection of all Class1E MOVs shall be bypassed under accident conditions for all valves with spring-to normal control switches. The team referenced Regulatory Guide (RG) 1.106, Thermal Overload Protection for Electric Motors on Motor-Operated Valves, which describes acceptable methods to ensure that thermal overload devices will not prevent MOVs from performing their safety related function. An acceptable method to ensure completion of a safety related function is to ensure that thermal overload protection devices that are normally in place during plant operation be bypassed under accident conditions and should be tested periodically. Section 8.1.6.1.19 of the UFSAR states that RG 1.106 is not applicable to Exelon per the implementation section, but concludes Exelon is in conformance with RG 1.106. In addition, Section 8.1.6.1.19a states that MOVs with spring-to-return control switches, during manual operation, the thermal overload is normally in the trip circuit; however, the thermal overload can be bypassed by holding the control switch in the appropriate open or close position. The team verified that operators were not expected to hold the switch in order to bypass the thermal overload during an accident condition. The team questioned if Exelon was meeting the intent of TS 3.8.4.2 because thermal overloads are not bypassed during an accident unless the overloads have been actuated and operators reposition the switch and hold it in the open or closed position. Exelon initiated issue report (IR) 985060 to review the issue and concluded in a position paper that they are in compliance with TS 3.8.4.2b. Additionally, the team questioned the adequacy of testing of the thermal overload bypasses for spring-to-return control switches for manually operated Class 1E MOVs in accordance with SR 4.8.4.2.2. The surveillance requires a Channel Functional Test to be performed to verify that the thermal overload protection will be bypassed under accident conditions. Exelon\'s TS, Section 1.6a, defines Channel Functional Test for analog channels as the injection of a simulated signal into the channel as close to the sensor as practicable to verify operability including alarm and/or trip functions. The test performed to satisfy the SR cycles the valve remotely with the control switch to check the continuity of the bypass circuitry but does not verify operation of the alarm associated with a thermal overload condition. The team questioned whether Exelon was required to verify the alarm function associated with the thermal overloads. In response to the team\'s questions, Exelon supported a position that standard operating practice includes verification of valve position by the operators using valve indication lights and that the alarm function does not need to be tested. This issue will be opened as a URI pending further NRC review in order to determine if LGS Units 1 & 2 are in compliance with their TS section 3.8.4.2 and SR 4.8.4.2.2 for thermal overload bypass operation in accident conditions and testing of the thermal overload alarm function. (URI 05000352,353/2009006-02, TS Requirements for MOV Thermal Overload Bypass Feature)
05000352/FIN-2009007-01Lead maintenance technician deliberately permitted unqualified contractors to open breakers and hang clearance tags2009Q2Limerick Generating Station Technical Specifications 6.8, Procedures and Programs, requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Revision 2, Appendix A, February 1978, recommends administrative activities, including equipment control (i.e. locking and tagging), be covered by written procedures. Exelon Procedure OP-MA-109-101, Clearance and Tagging, Revision 6, Section 13, Worker Tagout Process, Step 13.1.3 states, Personnel using worker tagout tags shall be qualified in the clearance and tagging process. Contrary to the above, between January and July 2007 and in February 2008, the licensee failed to implement a procedure required by Technical Specification 6.8 when worker tagout tags were used by personnel at Limerick Generating Station who were not qualified in the clearance and tagging process. Specifically, a lead maintenance technician with oversight responsibilities for a contractor group deliberately permitted unqualified contractors to open breakers and hang worker tagout tags
05000352/FIN-2009007-02Lead maintenance technician deliberately falsified clearance and tagging records2009Q2Title 10 of the Code of Federal Regulations, Part 50.9, Completeness and Accuracy of Information, requires, in part, that information required by statute or by the Commissions regulations, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects. Exelon Procedure OP-MA-109-101, Step 13.2.5.2 states, The Lead Worker or First Line Supervisor shall perform the Worker Tagout per the Worker Tagout Clearance Form. Step 13.2.7.5 states that when the work is complete, the Lead Worker or First Line Supervisor shall complete the Worker Tagout Clearance Form and return it to the workgroup Supervisor to be retained/recorded in the work package. Contrary to the above, between January and July 2007 and in February 2008, a lead maintenance technician, when documenting worker tagouts on Worker Tagout Clearance Forms, created information maintained by the licensee that was not complete and accurate in all material respects. Specifically, the lead maintenance technician falsified Worker Tagout Clearance Forms by forging the initials of qualified maintenance technicians, indicating that they had conducted the clearance and tagging activities when, in fact, the activities had been performed by unqualified contractors.
05000352/FIN-2010004-01Failure to Take Compensatory Action for Inoperable Fire Door2010Q3The inspectors identified a Green NCV of Limerick Generating Station operating License Condition 2.C.3, in that Exelon failed to take compensatory actions for an inoperable fire door. Specifically, on two occasions a required fire door was found in a condition where the latching mechanism did not function. Although issue reports (IRs) were written which identified this door to be a Technical Requirements Manual (TRM) fire door, actions were not taken to station the required hourly fire watch. Corrective actions included setting the required hourly fire watches, distributing guidance to all senior licensed operators, and implementing procedural changes to clarify the requirements of fire doors for future operability determinations. The finding was more than minor because it was associated with the protection against external events (fire) 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. This issue was found to be of very low safety significance (Green) based upon a Phase 2 SOP screening. The inspectors determined that this finding did not have a cross-cutting because the incorrect operability decisions were based on a 1999 engineering evaluation and, therefore, was not reflective of current licensee performance.
05000352/FIN-2010004-02Failure to Identify Incorrectly Adjusted Control Power Relay Resulting in Unit 1 Manual Scram2010Q3A self-revealing Green finding was identified for the failure to identify that the latching mechanism on a bus 114A1124A control power auxiliary relay (27X) was incorrectly adjusted during prior post-maintenance testing activities. Specifically, proper post-maintenance testing activities in 1992 and 2004 should have identified that the latching mechanism was incorrectly adjusted. The incorrectly adjusted latching mechanism prevented the automatic swap of control power to the alternate source (bus 124A) when preferred power (bus 114A) was lost due to an electrical fault. This resulted in a loss of stator water cooling run back signal that would have caused the trip of both recirculation motor-generator sets and resulted in operators having to manually initiate a reactor scram. Exelon\'s corrective actions taken or planned included verifying the latching mechanism adjustment on the site\'s other Similarly designed control power auxiliary relays, testing the automatic undervoltage transfer circuit on a periodic basis, and performing a failure analysis on the faulted underground supply cable which initiated the event. The finding was more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The finding was determined to have very low safety significance (Green) in accordance with NRC IMC 0609, Attachment 4, Phase 1- Initial Screening and Characterization of Findings, because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigating equipment or function would not be available. Because the opportunities to identify the incorrectly adjusted latching relay occurred in 1992 and 2004, the inspectors determined that this finding was not reflective of current licensee performance, and, therefore, did not have a crosscutting aspect. Enforcement action does not apply because the performance deficiency did not involve a violation of regulatory requirements.
05000352/FIN-2010004-03Failure to Perform Adequate PM on EDGs2010Q3The inspectors identified a Green NCV of Limerick Unit 2 Technical Specification (TS) 6.8.1, Procedures and Programs, in that Exelon did not provide an adequate procedure for preventive maintenance (PM) of the Limerick Emergency Diesel Generator (EOG) lube oil (LO) filter bypass valves. As a result, Exelon did not identify that the EOG 023 LO filter bypass valves were degraded and allowed oil to bypass the filter during engine operation. This condition, combined with historical foreign material in the LO system, led to the failure of the EOG 023 number 5 upper piston assembly during a 24-hour endurance test run on May 5,2010. Corrective actions implemented included repairing the damage to D23, performing a flush of the D23 LO system, revising the applicable PM procedure to include specific instructions for inspecting the LO filter bypass valves, and revising performance monitoring guidance to ensure spuriously lifting LO filter bypass valves would be identified in the future. The finding was more than minor because it was associated with the Equipment Performance attribute of the Mitigating System 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 of very low safety significance (Green) in accordance with Inspection Manual Chapter (IMC) 0609, Appendix A, Determining the Significance of Reactor Inspection Findings for At-Power Situations, using SDP Phases 1, 2, and 3. This finding has a cross-cutting aspect in the area of Human Performance, Resources, because Exelon did not provide complete, accurate and up-to-date design documentation, procedures, and work packages (H.2(c)). Specifically, Exelon did not provide site engineers with complete and accurate resources to ensure performance centered maintenance (PCM) template revisions were thoroughly reviewed and implemented.
05000352/FIN-2010004-04Licensee-Identified Violation2010Q3TS 3.3.7.1, Radiation Monitoring Instrumentation, requires one operable RECW radiation monitor channel at all times. With the radiation monitor inoperable, Table 3.3.7.1-1, Action 72 requires obtaining and analyzing RECW grab samples every 24 hours. Contrary to TS 3.3.7.1, the RECW radiation monitor was inoperable from March 19, 2010, until April 22, 2010, and the required grab samples were not obtained. The cause of the inoperability was due to an incorrect method for calculating the monitor\'s Hi-Hi Alarm setpoint; the test incorrectly directed use of the background radiation level from the previous month\'s test. This issue was entered into Exelon\'s CAP as IR 1063446. The finding was determined to have very low safety significance (Green) in accordance with NRC IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, Containment Barrier, because the finding did not represent a degradation of a radiological barrier, a degradation of the barrier function of the control room against smoke or a toxic atmosphere, or an actual open pathway in the physical integrity of reactor containment, containment isolation system, or heat removal components.
05000352/FIN-2010007-01Failure to Update UFSAR Consistent With Plant Conditions as Required2010Q4The inspectors identified a Severity Level IV (SLlV) NCV of 10 CFR Part 50.71 (e) in that Exelon failed on multiple occasions to revise the Updated Final Safety Analysis Report (UFSAR) with information consistent with plant conditions. Specifically, Exelon personnel failed to incorporate four previously identified UFSAR inconsistencies into the September 2010 UFSAR update as required. The inspectors determined that the failure to update the UFSAR in accordance with 10 CFR 50.71 (e) was a performance deficiency that was reasonably within Exelon\\\'s ability to foresee and correct, and should have been prevented. Because the issue had the potential to affect the NRC\\\'s ability to perform its regulatory function, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process. Using example 6.1.d.3 from the NRC Enforcement Policy, the inspectors determined that the violation was a SLiV (more than minor concern that resulted in no or relatively inappreciable potential safety or security consequence) violation, because the information that was not updated in the UFSAR was not used to make an unacceptable change in the facility nor did it impact a licensing or safety decision by the NRC
05000352/FIN-2010007-02Three of Four RHR Unit Coolers Unreliable due to Planned and Unplanned Conditions (Silting)2010Q4The inspectors identified a violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, in that Exelon failed to correct a condition adverse to quality for a safety related support system that was essential to successful mitigating system operation. Specifically, for a six and one half day period during July 2008, three of four residual heat removal unit coolers were either unavailable or made unreliable due to a series of planned and unplanned conditions (silting). The inspectors determined that the failure to correct a condition adverse to quality in accordance with 10 CFR 50 Appendix B, Criterion XVI, during the timeframe of June 1, 2008 to September 14, 2008, contributed to the unreliability of the 1C-V21 0 unit cooler and was a performance deficiency. Specifically, Exelon did not initiate bi-weekly flushing per RT-6-011603- 0 of the 1C-V21 0 unit cooler to minimize the effects of silt build up. This finding is more than minor because it affected the equipment performance attribute of the Mitigating System cornerstone and the associated cornerstone objective of ensuring the reliability and availability of systems that respond to initiating events to prevent undesirable consequences. This issue was also similar to example 3.j. in NRC IMC 0612, Appendix E, Examples of Minor Issues, in that it resulted in a condition where there was a reasonable doubt on the operability of the 1C-V210 unit cooler. The inspectors assessed this finding in accordance with IMe 0609, Attachment 4, Phase 1, Initial Screening and Characterization of Findings, and determined that it was of very low safety significance (Green) since it was determined that the error did not result in a loss of the system\\\'s safety function. The inspectors determined that this violation had a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, in that Exelon did not take appropriate corrective actions to address a condition adverse to quality in a timely manner, commensurate with its safety significance and complexity. Specifically, Exelon failed to take appropriate actions to initiate bi-weekly flushes of the 1C-V21 0 unit cooler, upon discovery of conditions conducive to silt buildup during June through September 2008
05000352/FIN-2010402-02Security2010Q3
05000352/FIN-2010403-01Security2010Q4
05000352/FIN-2011002-01Failure to Address Repeat TS Response Time Test Failures2011Q1The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVl, Corrective Action Program, because Exelon did not adequately evaluate and correct a condition adverse to quality regarding repeat failures of a Technical Specification (TS) surveillance test (ST). Specifically, on July 13,2010, Exelon generated issue report (lR) 1091132to document that ST-2-041-909-2,the Unit 2 Main Seam Line (MSL) Flow - High Response Time Test, had failed its past two performances. In both instances, in October 2008 and July 2010, multiple response time values exceeded the TS requirements, and Exelon had to replace several relays to bring the values back into compliance. After the 2008 failure Exelon performed an apparent cause evaluation (ACE) and generated one corrective action (CA) and several action items (AClTs) to address the causes. Following the 2010 failure, Exelon did not evaluate the repeat failure or generate any additional actions. The inspectors determined that the CA and ACITs from 2008 did not thoroughly address the MSL Flow - High test failure, and the repeat test failure in 2010 was an opportunity for Exelon to re-evaluate the issue and pursue more appropriate and timely corrective actions. Exelon\'s failure to evaluate and correct a condition adverse to quality regarding repeat failures of a TS surveillance test was determined to be a performance deficiency (PD). The PD was determined to be more than minor because it was associated with the System, Structure, and Component & Barrier Performance attribute of the Reactor Safety - Barrier lntegrity cornerstone. The PD adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The finding was determined to be of very low safety significance (Green) in accordance with Inspection Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, because it did not represent an actual open pathway in the physical integrity of reactor containment. The inspectors determined this finding had a cross-cutting aspect in the area of Problem ldentification and Resolution, Corrective Action Program, because Exelon did not thoroughly evaluate the repeat MSL response time test failures to ensure the underlying causes were identified and resolved.
05000352/FIN-2011002-02None2011Q1Unit 2 TS LCO 3.0.4 requires that, when an LCO is not met, entry into an OPCON or other condition in the Applicability shall only be made if specified conditions in LCO 3.0.4 were met. TS LCO 3.3.7.4 Remote Shutdown System lnstrumentation and Controls, requires the RHR Heat Exchanger Bypass Valve (HV-C-S1-2F048A) Position Indication (0-10070) (Table 3.3.7.4-1, Instrument 15)to be restored to operable within 7 days or be in at least Hot Shutdown within the next 12 hours with an Applicability in OPCONS 1 and 2. Contrary to LCO 3.0.4, on April 11, 2009, Unit 2 entered OPCON 2 with the position indication for HV-C-51-2F048A inoperable and specified conditions in LCO 3.0.4 were not met. The cause of the failure to meet LCO 3.0.4 was due to less than adequate administrative barriers being present to allow licensed operators to properly assess the TS impact of the deficiency. Also, operators did not use all available tools and resources at that time to validate the initial operability determination. This issue was entered into Exelon\'s CAP as lR 1168410. The finding was determined to have very low safety significance (Green) in accordance with NRC IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Finding, Mitigating Systems, because the finding did not represent an actual loss of safety function or screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event.
05000352/FIN-2011003-01Failure to Position Recirculation lsolation Valves in Accordance with Clearance2011Q2A Green, self-revealing NCV of Technical Specification (TS) 6.8.1, Procedures and Programs, was identified for failure to position the Unit 2 recirculation loop isolation valves in accordance with the clearance instruction. As a result, the decay heat removal 1ow path, as provided by Unit 2 \'A\' residual heat removal (RHR), was in a degraded condition from April 6,2011 until April 1 2,2011, when the valve mispositioning was corrected. In addition, if the RHR system had been aligned to the Shutdown Cooling mode with the valves mispositioned in the open position, a large portion of the cooling flow would have bypassed the core, significantly impacting decay heat removal capability. Exelon entered the issue into the Corrective Action Program (CAP) for resolution. The inspectors determined that the failure to position the Unit 2 \'A\' loop recirculation pump suction and discharge valves to the closed positions in accordance with a clearance is a performance deficiency. This issue is more than minor because it was associated with the Configuration Control attribute of the Initiating Events cornerstone (i.e., shutdown equipment lineup), and it affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. This finding was determined to be of very tow safety significance (Green) using IMC 0609, significance Determination Process, Appendix G, Shutdown Operations Significance Determination Process, because the finding did not require quantitative assessment (i.e., the finding did not degrade the ability to recover decay heat removal once lost). Exelon entered this issue into the CAP for resolution. Corrective actions included remediating the reactor operator who applied the main control room tag and revising the cross check program to require a concurrent verification check on clearance applications for valves being de-energized with main control room indicators. The inspectors determined that this issue has a cross-cutting aspect in the area of Human Performance, Work Practices, because Exelon did not properly use human error prevention techniques (e.g., self and peer checking), commensurate with the risk of the assigned task.
05000352/FIN-2011003-03Failure to ldentify Adverse Trend regarding Out-of-Calibration lnstrumentation2011Q2A Green self-revealing finding was identified for Exelon\'s failure to identify and correct an adverse trend regarding out-of-calibration temperature switches in the Unit 1 and Unit 2 station cooling water (SCW) systems. Specifically, between 1990 and 201 1 the SCW outlet temperature switches were checked by Exelon on a two year frequency and found to be out-of-calibration approximately 50 percent of the time. Since 2005, the switches were found out-of-calibration nearly 70 percent of the time, often by a significant amount. Each time the switches were found out-of-calibration, they were recalibrated within acceptable limits, but the adverse trend was not recognized. The inspectors determined that Exelon\'s failure to identify and correct the adverse trend of out of calibration SCW outlet temperature switches was a performance deficiency which was reasonably within the licensee\'s ability to foresee and prevent. Specifically, Exelon\'s Performance Monitoring Program, described in ER-AA-2003, should have identified the trend during the system engineer\'s annual review of cause and repair codes for completed work orders. Exelon entered the issue into the CAP for resolution. The finding was more than minor because it was associated with the equipment performance attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of events that upset plant stability. Specifically, on February 25,2011, the\'out of calibration SCW outlet temperature switches resulted in a SCW runback and manual scram of Limerick Unit 2 when the outlet temperature switches actuated 15 degrees lower than their intended set point. The finding was determined to be of very low safety significance (Green) in accordance with Phase 1 of IMC 0609, significance Determination Process, because the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. The inspectors determined that this finding had a cross-cutting aspect in the area of Problem ldentification and Resolution, Corrective Action Program, because Exelon did not identify the trend of out-of-calibration temperature switches in a timely manner. Exelon relied on the implementation of a thorough Performance Monitoring Program to supplement their CAP in the specific area of instrument performance monitoring and trending, and this program failed to detect the adverse trend in instrument performance.
05000352/FIN-2011003-04Licensee-Identified Violation2011Q2Limerick Unit2 TS 6.8,1, Procedures and Programs, requires, in part, that procedure be established and implemented covering the applicable activities in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1,33, Appendix A, Section 9.a, requires procedures for performing maintenance. Procedure M-C-756-001, HPCI Turbine Inspection, Revision 26, contained instructions for the HPCI turbine oil system cleaning and inspection. Contrary to TS 6.8.1, Procedure M-C-756-001 was inadequate because it did not direct disassembly of the overspeed trip device for further inspection and cleaning in the event that foreign material was identified at pipe connection points. As a result, the Unit 2 HPCI system was rendered inoperable and nonfunctional on December 12,2010, because the overspeed trip mechanism failed to reset during periodic testing due to foreign material in the oil turbine oil system. Because this issue was determined to be of very low risk significance (Green), and Exelon has entered this issue into the CAP as lR 1151354, this issue is being characterized as a Licensee identified NCV.
05000352/FIN-2011004-02Failure to Provide Adequate Restoration Instructions for Turbine Control Valve Online Maintenance2011Q3A Green, self-revealing finding was identified because Exelon did not provide adequate instructions for restoration of the Limerick Unit 2 number three turbine control valve (CV #3) following maintenance. During a fill and vent activity of the electro-hydraulic control (EHC) supply line for CV #3, a void in the system piping resulted in a low pressure condition at the next-in-series control valve, CV #1. The pressure drop actuated a relayed emergency trip system (RETS) pressure switch, generating a reactor protection system (RPS) 'S' side half scram signal. Combined with an 'A' side half scram signal that was previously inserted into RPS due to the CV #3 being maintained closed, an automatic reactor scram resulted. The inspectors determined that Exelon's failure to provide adequate instructions for restoration of CV #3 from maintenance was a performance deficiency. The issue was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events cornerstone, and it affected the cornerstone objective of limiting the likelihood of events that upset plant stability. Specifically, on May 29, 2011, Limerick Unit 2 experienced an automatic reactor scram during restoration of turbine CV #3 from maintenance. The restoration instructions in the work order (WO) did not provide sufficient guidance to address the presence of a large air void in the EHC system that had the potential to cause EHC pressure fluctuations and resulted in a reactor scram. The finding was determined to be of very low safety significance (Green) in accordance with IMC 0609 Attachment 4, Phase 1Initial Screen and Characterization of Findings, because the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. This finding had a cross-cutting aspect in the area of Human Performance, Decision-Making, because Exelon did not use a systematic process to make a risk-significant decision when faced with uncertain or unexpected plant conditions. Specifically, Exelon did not recognize the potential risk of the CV #3 EHC fill and vent restoration activity, and they failed to conduct a thorough technical review of the restoration plan.
05000352/FIN-2011004-03Test Equipment Interference Resulting in Reactor Scram2011Q3A Green, self-revealing NCV of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, occurred when Exelon did not adequately assess the potential impacts of test equipment on turbine trip circuitry. This resulted in an automatic reactor scram of Unit 1 when the main turbine high reactor water level trip relay inadvertently energized during a surveillance test on June 3, 2011. This test is a quarterly surveillance, designed to verify proper operation of the Digital Feed Water Level Control System (DFWLCS) which initiates a turbine trip on high reactor level. The DFWLCS has a 1 out of 2 twice logic to energize the trip relay, so each channel is tested separately to eliminate the possibility of inadvertent actuation. As an additional precaution, the surveillance procedure contains steps for the technician to verify the other channels are free of closed trip contacts prior to beginning the test. Exelon used a Simpson 260 Volt/Ohm Meter (VOM) to perform this verification by demonstrating a nominal voltage difference between each side of the contact and station ground. During this verification step, Exelon inadvertently established a direct current loop from station ground, to the floating battery ground from the 125V power supply, to the trip circuit. This completed the circuit, energized the main turbine high reactor water level trip relay, which tripped the main turbine and caused the reactor to scram. Exelon revised the test procedure to change the requirements for test instrumentation to prevent this from recurring and entered the issue into the corrective action program as IR 1224283. The inspectors determined that the performance deficiency was more than minor in accordance with IMC 0612, Appendix B, Issue Screening, because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone and affected the objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during power operation. Specifically, by not considering the impact of maintenance and test equipment (M&TE) during multiple revisions of the surveillance procedure, Exelon failed to recognize a vulnerability which could lead to a plant transient. In accordance with IMC 0609, Attachment 4, Phase 1 - Initial Screen and Characterization of Findings, the finding was determined to be of very low safety significance (Green) because the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. The inspectors determined that this performance deficiency did not reflect current performance, as the last revision to the surveillance procedure that affected M&TE requirements was greater than three years ago. As a result, the inspectors did not assign a cross-cutting aspect to this finding.
05000352/FIN-2011004-04Licensee-Identified Violation2011Q310 CFR 50.54(q) requires, in part, that a power reactor licensee follow an emergency plan that meets the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. Contrary to the above, Exelon did not make timely notification when the emergency action level threshold was met for HU5, Natural and Destructive Phenomena Affecting the Protected Area. Specifically, Exelon operators did not declare an Unusual Event within the required fifteen minutes of the earthquake felt onsite on August 23. The actual declaration was nine minutes late. At 1:51 PM, control room operators received a Seismic Monitor System Recording Activated alarm coincident with reports of seismic activity felt by station personnel. The seismic monitoring system at Limerick had previously been declared inoperable due to problems with its power supply, so operators began the compensatory measures which directed the operators to contact the United States Geological Survey to confirm the epicenter and magnitude of the seismic event prior to event classification. The United States Geological Survey has a call queue system to answer inquiries in an orderly manner, and Exelon was on hold until 2:11 PM. Exelon declared the Unusual Event at 2:15 PM and made all appropriate state and local notifications. Exelon entered the untimely event declaration into their corrective action program as IR 1254845. The inspectors determined that the finding was of very low safety significance (Green) in accordance with NRC IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, Sheet 2, because this was related to an actual event implementation problem for a Notice of Unusual Event.
05000352/FIN-2011005-01Inadequate Corrective Actions for a Previous NRC Finding for Programmatic Deficiencies in the Preventive Maintenance Program2011Q4The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for failure to implement adequate corrective actions for a previous NRC-identified finding. The previous finding involved a failure to perform adequate preventive maintenance (PM) on an emergency diesel generator (EDG) due to site engineers not being fully aware of new PM requirements developed by Exelon corporate. The lack of proper PM led to a failure of an EDG in May 2010. In response to the previous finding, Limerick performed an apparent cause evaluation (ACE) and developed actions to address the causes and extent of condition. However, the inspectors identified that the actions were not properly implemented, and, as a result, the deficiency identified by the inspectors was not fully resolved. Exelon entered the issue in the Corrective Action Program (CAP) for resolution. The inspectors determined that the failure to implement adequate corrective actions for a previous NRC-identified finding was a performance deficiency. The issue is more than minor because, if left uncorrected, it could become a more significant safety concern. Specifically, the issues identified by the inspectors impacted Limerick\'s ability to establish and implement appropriate PM for equipment relied on for safe operation of the plant. Until the issues are fully resolved, Limerick continues to be vulnerable to gaps in their PM program. This issue affects all sites in the Exelon fleet. The finding was determined to be of very low safety significance (Green) using Attachment 4 to IMC 0609, Significance Determination Process, because the incomplete corrective actions did not result in an actual loss of safety function. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because Exelon failed to implement appropriate corrective actions for a previous NRC-identified finding in timely manner.
05000352/FIN-2011007-01Failure to Evaluate Station Blackout Timeline for EDG Availability2011Q4The team identified a non-cited violation of 10 CFR 50.63, Loss of All Alternating Current (AC) Power, because Exelon did not demonstrate that the alternate AC (AAC) source could provide acceptable capability to withstand a station blackout (SBO) within the analyzed coping timeline. Specifically, Exelon\'s evaluation of the Limerick Generating Station\'s excess emergency diesel generator (EDG) capacity did not analyze the effects of the loss of an operating emergency service water (ESW) pump following a single failure on the non-blacked out unit. The loss of the ESW pump would result in loss of cooling to one of the three credited EDGs and a subsequent high temperature trip of the EDG. The team determined the time delay to reset this trip had not been evaluated and that Exelon had not performed the timed test required by 10 CFR 50.63 to show that actions required to provide power to the blacked-out unit from the AAC could be performed within the analysis requirements. As a result, the team concluded that Exelon did not demonstrate that the MC source would have the required availability and capability within the analyzed timeline. Exelon entered the issue into their corrective action program for evaluation and resolution. This issue was more than minor because it is associated with the design control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The team determined the finding was of very low safety significance because it was a design or qualification deficiency confirmed not to result in a loss of functionality. The finding had a cross-cutting aspect in the area in the area of Problem ldentification and Resolution, Corrective Action Program Component, because Exelon did not thoroughly evaluate problems such that resolutions address causes and extent of conditions and did not conduct effectiveness reviews to ensure problems are resolved. Specifically, Exelon\'s recent safety evaluation did not evaluate problems associated with a loss of an EDG due to a high temperature condition and the impact on the SBO AAC power source availability.
05000352/FIN-2011008-01Station Blackout Licensing Basis Assumed Alternate AC Power Source.2011Q2The inability to satisfy the licensing basis assumed alternate AC power source (i.e., three EDG\\\'s on the non-blacked out unit without using recovery procedures) during a certain Unit 1 station blackout event requires further review to determine compliance with 10 CFR Part 50.63, Loss of AllAlternate Current Power. The licensee entered this issue into the CAP as lR 1208490, Potential Station Blackout Procedure Bases Licensing lssue. This unresolved item (URl) is identified as URI 05000352, 35312011008-01, Station Blackout Licensing Basis Assumed Alternate AC Power Source.
05000352/FIN-2011503-01(Traditional Enforcement) Changes to EAL Basis Decreased the Effectiveness of the Plan without Prior NRC Approval2011Q3The inspector identified a finding of very low safety significance involving a Severity Level IV NCV of 10 CFR 50.54(q) for failing to obtain prior approval for an emergency plan change which decreased the effectiveness of the plan. Specifically, the licensee modified the Emergency Action Level (EAL) Basis in EAL HU6, Revision 13, which indefinitely extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm. This change decreased the effectiveness of the emergency plan by reducing the capability to perform a risk significant planning function in a timely manner. The violation affected the NRC\\\'s ability to perform its regulatory function because it involved implementing a change that decreased the effectiveness of the emergency plan without NRC approval. Therefore, this issue was evaluated using Traditional Enforcement. The NRC determined that a Severity Level IV violation was appropriate due to the reduction of the capability to perform a risk significant planning standard function in a timely manner. The licensee entered this issue into its corrective action program and revised the EAL basis to restore compliance. The finding was more than minor using IMC 0612, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Therefore, the performance deficiency was a finding. Using IMC 0609, Appendix B, the inspector determined that the finding had a very low safety significance because the finding is a failure to comply with 10 CFR 50.54(q) involving the risk significant planning standard 50.47(b)(4), which, in this case, met the example of a Green finding because it involved one Unusual Event classification Due to the age of this issue, it was not determined to be reflective of current licensee performance and therefore a cross-cutting aspect was not assigned to this finding.
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