IR 05000352/2007004

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November 13, 2007

Mr. Charles G. PardeePresident and CNO Exelon Nuclear Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348

SUBJECT: LIMERICK GENERATING STATION - NRC INTEGRATED INSPECTIONREPORT 05000352/2007004 AND 05000353/2007004

Dear Mr. Pardee:

On September 30, 2007, the U. S. Nuclear Regulatory Commission (NRC) completed aninspection at your Limerick Generating Station Units 1 and 2. The enclosed integrated inspection report documents the inspection results which were discussed on October 15, 2007, with Mr. E. Callan and other members of your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.Based on the results of this inspection, no findings of significance were identified.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/Paul G. Krohn, ChiefProjects Branch 4 Division of Reactor ProjectsDocket Nos: 50-352, 50-353License Nos: NPF-39, NPF-85

Enclosure:

Inspection Report 05000352/2007004 and 05000353/2007004

w/Attachment:

Supplemental Information

SUMMARY OF FINDINGS

......................................................iii

REPORT DETAILS

............................................................1

REACTOR SAFETY

...........................................................11R01Adverse Weather Protection .........................................1

1R04 Equipment Alignment ..............................................1

1R05 Fire Protection....................................................2

1R06 Flood Protection Measures ..........................................31R11Licensed Operator Requalification Program .............................3

1R12 Maintenance Effectiveness ..........................................41R13Maintenance Risk Assessments and Emergent Work Control................41R15Operability Evaluations .............................................51R19Post-Maintenance Testing ..........................................51R22Surveillance Testing ...............................................6

1R23 Temporary Plant Modifications .......................................6

1EP6Drill Evaluation

OTHER ACTIVITIES

..........................................................84OA1Performance Indicator (PI) Verification .................................8 4OA3Event Followup ...................................................9 4OA6Meetings, Including Exit............................................11ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

..................................................A-1

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

.............................A-1

LIST OF DOCUMENTS REVIEWED

.......................................................................................... A-2

LIST OF ACRONYMS

........................................................A-8

iiiSUMMARY

OF [[]]

FINDINGSIR 05000352/2007-004, 05000353/2007-004; 07/01/2007 - 09/30/2007; Limerick GeneratingStation, Units 1 and 2; Routine Integrated Report.The report covered a three-month period of inspection by resident inspectors and announcedinspections by reactor inspectors. The NRC's program for overseeing the safe operation of

commercial nuclear power reactors is described in

NUR [[]]

EG-1649, "Reactor Oversight," Revision

4, dated December

2006.A.N [[]]
RC -Identified and Self-Revealing FindingsNo findings of significance were identified.B. Licensee-Identified ViolationsNone.
REPORT [[]]

DETAILSSummary of Plant StatusUnit 1 began this inspection period operating at full rated thermal power. On August 16, 2007,reactor power was reduced to 20 percent and the main generator was removed from service to

repair the generator output number 11 disconnect switch. On August 17, 2007, the disconnect

switch repairs were completed and the main generator was returned to service. Unit 1 returned

to 100 percent power on August 18, 2007. With the exception of a planned end of summer load

drop to 85 percent power on September 8, 2007, Unit 1 remained at full power for the remainder

of the period.

Unit 2 began this inspection period operating at full rated thermal power. On August 6, 2007,

reactor power decreased to 75 percent due to an unplanned speed reduction on the 2B reactor

recirculation pump. The pump speed change was due to a recirculation motor generator

electronic card failure. The card was replaced and Unit 2 was returned to 100 percent power

later in the day. With the exception of a planned end of summer load drop to 60 percent power

on September 15, 2007, Unit 2 remained at full power for the remainder of the period. 1.

REACTO R

SAFETYCornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity1R01Adverse Weather Protection (71111.01 - 1 system sample) a.Inspection ScopeThe inspectors evaluated Exelon's preparations and protection for summer weather. OnJuly 10, 2007, the inspectors walked down Unit 1 and Unit 2 main generators and main

transformers during hot weather and a grid heavy load voltage condition. The

documents reviewed are listed in the Attachment. b.FindingsNo findings of significance were identified.1R04Equipment Alignment (71111.04) .1 Partial Walkdown (71111.04Q - 4 samples) a.Inspection ScopeThe inspectors performed four partial walkdowns of plant systems to verify the operabilityof redundant or diverse trains and components when safety equipment in the opposite

train was either inoperable, undergoing surveillance testing, or potentially degraded. The

inspectors used plant Technical Specifications (TS), Exelon operating procedures, plantpiping and instrumentation drawings (P&IDs), and the Updated Final Safety Analysis

Report (USFAR) as guidance for conducting partial system walkdowns. The inspectors

reviewed the alignment of system valves and electrical breakers to ensure proper

in-service or standby configurations as described in plant procedures and drawings.

2Enclosure During the walkdown, the inspectors evaluated material condition and generalhousekeeping of the system and adjacent spaces. The documents reviewed are listed in

the Attachment. The inspectors performed walkdowns of the following systems:*Unit 1 High Pressure Coolant Injection (HPCI) system;*Unit 1 D-13 Emergency Diesel Generator (EDG);

  • Unit 1 Reactor Core Isolation Cooling (RCIC)..2Complete System Walkdown (71111.04S - 1 sample)The inspectors conducted one complete walkdown of the Unit 1 and Unit 2 Control RodDrive (CRD) systems to verify functional capability of the system. The inspectors used

plant

TS , Exelon operating procedures, P&
ID s, the
UFS [[]]

AR, and past surveillance tests

as guidance for conducting the complete system walkdown. The inspectors reviewed the

alignment of system valves, position of electrical breakers and settings of the system flow

controller to ensure proper system configuration as described in plant procedures and

drawings. During the walkdown, the inspectors evaluated the material condition and

general housekeeping of the system and open issue reports associated with the system.

The walkdown also included an evaluation of system piping, supports, and component

foundations to ensure they were not degraded. The documents reviewed are listed in the

Attachment. b.FindingsNo findings of significance were identified.1R05Fire Protection.1Fire Protection - Tours (71111.05Q - 8 samples) a.Inspection Scope The inspectors conducted a tour of the eight areas listed below to assess the materialcondition and operational status of fire protection features. The inspectors verified that

combustibles and ignition sources were controlled in accordance with Exelon's

administrative procedures, fire detection and suppression equipment was available for

use, and that passive fire barriers were maintained in good material condition. The

inspectors also verified that station personnel implemented compensatory measures for

out-of-service, degraded, or inoperable fire protection equipment in accordance with

Exelon's fire plan. The documents reviewed are listed in the Attachment. The inspectors

performed the following samples:*Main Control Room and peripheral rooms;*Unit 1 Refuel Floor;

  • Unit 2 Refuel Floor;
  • Unit 1 and Unit 2 Static Inverter compartments;

3Enclosure *Control Room Structure fan room, Elevation 304; and*Unit 1 D14 Diesel Generator Room..2Fire Protection - Drill Observation (71111.05A - 1 sample) a.Inspection ScopeThe inspectors observed one unannounced fire drill conducted in the Unit 1 aircompressor, electro-hydraulic control (EHC) power unit, and turbine lubricating oil

storage tank area on September 26, 2007. The inspectors observed the drill to evaluate

the readiness of the plant fire brigade to fight fires. The documents reviewed are listed in

the Attachment. Specific attributes evaluated were:*Proper donning of fire fighting turnout gear and self-contained breathingapparatus (SCBA); *Proper use and layout of fire hoses;

  • Employment of appropriate fire fighting techniques;
  • Sufficient fire fighting equipment brought to the scene;
  • Effectiveness of fire brigade leader communications, command, and control;
  • Search for victims and propagation of fire into other plant areas;
  • Smoke removal operations;
  • Utilization of pre-planned strategies;
  • Adherence to the pre-planned drill scenario; and
  • Drill objectives. b.FindingsNo findings of significance were identified.1R06Flood Protection Measures (71111.06 - 1 sample)Internal Flooding a.Inspection Scope The inspectors reviewed documents and inspected structures, systems, and components(SSCs) relative to the adequacy of internal flood protection measures for the Unit
1 HP [[]]

CI

room. The inspectors performed walkdowns of the relevant areas to verify the adequacy

of flood mitigation doors and barriers, drainage systems, and other flood protection

features. The documents reviewed are listed in the Attachment. b.Findings No findings of significance were identified.1R11Licensed Operator Requalification Program (71111.11Q - 1 sample)Resident Inspector Quarterly Review (1 sample) a.Inspection Scope

4Enclosure On August 28, 2007, the inspectors observed a licensed operator requalificationsimulator scenario. The scenario included a simulated spurious Division 1 Loss of

Coolant Accident (LOCA) signal with failure of the D11 EDG to start and an unisolablereactor water cleanup leak, which resulted in a manual scram and emergency blowdown.

The inspectors observed the performance of two operating crews responding to the

same scenario. The inspectors assessed licensed operator performance, including

operator critical tasks that measure operator actions required to ensure the safe

operation of the reactor and protection of the nuclear fuel and primary containment

barriers. The inspectors observed the training evaluators' critiques at the conclusion of

each simulation. The documents reviewed are listed in the Attachment. b.FindingsNo findings of significance were identified.1R12Maintenance Effectiveness (71111.12 - 3 samples) a.Inspection Scope The inspectors evaluated Exelon's work practices and follow-up corrective actions forSSCs and identified issues to assess the effectiveness of Exelon's maintenance

activities. The inspectors reviewed the performance history of risk significant SSCs and

assessed Exelon's extent-of-condition determinations for those issues with potential

common cause or generic implications to evaluate the adequacy of the station's

corrective actions. The inspectors assessed Exelon's problem identification and

resolution actions for these issues to evaluate whether Exelon had appropriately

monitored, evaluated, and dispositioned the issues in accordance with Exelon

procedures and the requirements of 10 CFR 50.65, "Requirements for Monitoring the

Effectiveness of Maintenance." In addition, the inspectors reviewed selected SSC

classifications, performance criteria and goals, and Exelon's corrective actions that were

taken or planned, to evaluate whether the actions were reasonable and appropriate. The

documents reviewed are listed in the Attachment. The inspectors performed the

following samples:*1A post

LO [[]]

CA recombiner maintenance rule (a)(1) determination;*2B Turbine Enclosure Cooling Water heat exchanger system outage window; and

  • Unit 2 High Pressure Coolant Injection maintenance rule (a)(1) determination.1R13Maintenance Risk Assessments and Emergent Work Control (71111.13 - 8 samples) a.Inspection Scope The inspectors evaluated the effectiveness of Exelon's maintenance risk assessmentsrequired by 10 CFR 50.65 (a)(4). This inspection included discussion with control room

operators and risk analysis personnel regarding the use of Exelon's on-line risk

monitoring software. The inspectors reviewed equipment tracking documentation, daily

work schedules, and performed plant tours to gain assurance that the actual plant

configuration matched the assessed configuration. Additionally, the inspectors verified

that Exelon's risk management actions, for both planned and emergent work, were

5Enclosure consistent with those described in Exelon procedure,

ER -

AA-600-1042, "On-Line RiskManagement." The documents reviewed are listed in the Attachment. Inspectors

reviewed risk assessments for the following issues:*Incorrect interpretation of

ASME Code Case N-435-1;*Unit 1

HPCI room temperature high;

  • Unit 2 Reactor Recirculation Motor Generator runback to minimum speed;
  • Unit 1 Main Generator Disconnect high temperatures;
  • Unit 1 Main Generator Disconnect phases A and C jumper installation;
  • Large
VAR (Volt-Ampere Reactive) swings during

EDG run;

  • Unit 1 "D" Safety Relief Valve position indicator converter module replacement. b.FindingsNo findings of significance were identified.1R15Operability Evaluations (71111.15 - 5 samples) a.Inspection ScopeFor the five operability evaluations described below, the inspectors assessed thetechnical adequacy of the evaluations to ensure that Exelon properly justified TS

operability and verified that the subject component or system remained available such

that no unrecognized increase in risk occurred. The inspectors reviewed the

UFS [[]]

AR to

verify that the system or component remained available to perform its intended safety

function. In addition, the inspectors reviewed compensatory measures implemented to

ensure that the measures worked and were adequately controlled. The inspectors also

reviewed a sample of issue reports (IRs) to verify that Exelon identified and corrected

deficiencies associated with operability evaluations. The documents reviewed are listed

in the Attachment. The inspectors reviewed operability evaluations for the following

components:*Unit

2 HPCI [[]]
HV -055-2F006;*Unit
1 HP [[]]

CI Room Cooler;

  • Unit
2 HP [[]]

CI Oil Pressure; and

  • Unit 2B Reactor Circulation Pump mechanical seal. b.FindingsNo findings of significance were identified.1R19Post-Maintenance Testing (71111.19 - 8 samples) a. Inspection ScopeThe inspectors reviewed the eight post-maintenance tests (PMTs) listed below to verifythat procedures and test activities ensured system operability and functional capability.

The inspectors reviewed Exelon's test procedures to verify that the procedures

6Enclosure adequately tested the safety functions that may have been affected by the maintenanceactivity, and that the applicable criteria in the procedures were consistent with information

in the licensing and design basis documents. The inspectors also witnessed the test or

reviewed test data to verify that the results adequately demonstrated restoration of the

affected safety functions. The documents reviewed are listed in the Attachment. The

inspectors reviewed post-maintenance tests for the following systems and components:*"C" Residual Heat Removal Service Water pump;*"2A" RHR Suppression Pool Cooling Valve;

  • D21 Diesel Generator;
  • Unit 2 Redundant Reactivity Control System (RRCS). b.FindingsNo findings of significance were identified.1R22Surveillance Testing (71111.22 - 5 samples) a.Inspection ScopeThe inspectors witnessed the performance and reviewed test data for five surveillancetests that are associated with selected risk-significant SSCs. The review verified that

Exelon personnel followed TS requirements and that acceptance criteria were

appropriate. The inspectors also verified that the station established proper test

conditions, as specified in the procedures, that no equipment preconditioning activities

occurred, and that acceptance criteria had been met. The documents reviewed are listed

in the Attachment. The inspectors reviewed the surveillance tests for the following

systems and components:*Unit 2 D24 EDG;*Unit 2 Division 2 Lower Pressure Coolant Injection;

  • Unit 1 High Pressure Coolant Injection. b. FindingsNo findings of significance were identified.1R23Temporary Plant Modifications (71111.23 - 1 sample) a.Inspection ScopeThe inspectors reviewed and compared the temporary modification listed below with theUFSAR and TS to verify that the modification did not affect operability or availability of

the Unit 1 reactor recirculation motor generator. The inspectors ensured that station

7Enclosure personnel implemented the modification in accordance with the applicable temporaryconfiguration change process. The inspectors also reviewed the impact on existing

procedures to verify appropriate revisions were made to reflect the temporary

configuration change. Additionally, the inspectors evaluated the adequacy of proposed

testing upon removal of the change. The documents reviewed are listed in the

Attachment. The inspectors performed the following sample:*TRT-D7-164, Install 1B Reactor Recirculation Pump Motor Generator TemporaryMechanical Stop. b. FindingsNo findings of significance were identified.

Cornerstone: Emergency Preparedness (EP)1EP6Drill Evaluation (71114.06 - 2 samples).1General Emergency Classification due to Simulated Fuel Failure Coincident with FailedOpen Main Steam Line Isolation Valves a.Inspection ScopeOn June 19, 2007, the inspectors observed an

EP training drill in the control roomsimulator. The inspectors assessed Exelon's emergency response organization's (

ERO)

implementation of the Limerick emergency plan and implementing procedures, and the

ERO's response to simulated degraded plant conditions to identify weaknesses and

deficiencies in classification, notification, and protective action recommendation (PAR)

development activities. In addition, the inspectors assessed licensed operator

performance required to ensure the safe operation of the reactor and the protection of

the nuclear fuel and primary containment barriers. The inspectors reviewed Exelon's

training evaluators' critiques and the formal critique report, dated July 31, 2007,

associated with the EP drill, to evaluate Exelon's identification of weaknesses and

deficiencies. The inspectors compared inspector observed weaknesses with those

identified in Exelon's formal drill critique to verify whether Exelon adequately identified

weaknesses and deficiencies at an appropriate threshold. The documents reviewed are

listed in the Attachment. b.FindingsNo findings of significance were identified..2Site Area Emergency Classification Due to a Simulated Reactor Coolant System Leak inthe Reactor Building a.Inspection ScopeThe inspectors observed a licensed operator requalification simulator exercise evaluationto identify the timing and adequacy of classification, notification, and PAR development

activities. During the simulator evaluation, the inspectors reviewed checklists and forms

8Enclosure used for classification and notification activities, and compared them to the criteria inExelon's Emergency Plan,

EP -

MA-114-100-F-01, "State/Local Event Notification Form,"

and supporting procedures. The documents reviewed are listed in the Attachment. b.FindingsNo findings of significance were identified.2.OTHER

ACTIVI [[]]
TIES [[]]
4OA 1Performance Indicator (

PI) Verification (71151- 8 samples) 1. Inspection ScopeThe inspector sampled Exelon's submittal of the performance indicators listed below toverify the accuracy of the data recorded from the third quarter of 2006 through the third

quarter of 2007. The inspectors utilized performance indicator definitions and guidance

contained in Nuclear Energy Institute (NEI) 99-02, "Regulatory Assessment Performance

Indicator Guideline," Revision 5, to verify the basis in reporting for each data element.

The inspectors reviewed various documents, including portions of main control room

logs, issue reports, power history curves, work orders, and system derivation reports.

The inspectors also discussed the method for compiling and reporting performance

indicators with cognizant engineering personnel and compared graphical representations

from the most recent PI report to the raw data to verify that the report correctly reflected

the data. The documents reviewed are listed in the Attachment. Cornerstone: Initiating Events (2 samples)*Unit 1 Unplanned Power Changes per 7000 Critical Hours; and*Unit 2 Unplanned Power Changes per 7000 Critical Hours.Cornerstone: Mitigating Systems (6 samples)*Unit 1 High Pressure Coolant Injection system;*Unit 2 High Pressure Coolant Injection system;

  • Unit 2 Emergency Diesel Generators. b.FindingsNo findings of significance were identified.4OA2Identification and Resolution of Problems (71152)Review of Items Entered into the Corrective Action Program (CAP)

9Enclosure As required by Inspection Procedure 71152, "Identification and Resolution of Problems,"and in order to help identify repetitive equipment failures or specific human performance

issues for follow-up, the inspectors performed a screening of all items entered into

Limerick's CAP. The inspectors accomplished this by reviewing the description of each

new issue report and accessing Exelon's computerized database. The documents

reviewed are listed in the Attachment. b. FindingsNo findings of significance were identified. The inspectors observed that issues selectedfor review were appropriately categorized and prioritized in accordance with Exelon's

corrective action process.4OA3Event Followup (71153).1Unit 1 Main Generator Output Switchyard Disconnect Removal from Service due to HighTemperature a.Inspection ScopeOn August 16, 2007, the inspectors responded to the plant due to a high temperature onthe Unit 1 main generator output disconnect. The inspectors discussed the switchyard

disconnect problem with operations personnel, engineering personnel, and Exelon

management to gain an understanding of Exelon's response and follow-up actions. The

inspectors reviewed troubleshooting activities, the disconnect temperature surveillance

monitoring, and the planned actions to repair and correct the disconnect high

temperature condition. The number 11 disconnect is located on the output of the Unit 1 main transformers and isphysically located in the Unit 1 220 kilovolt (kV) switchyard. The disconnect is comprised

of three individual disconnects and associated bus bars. The disconnect "B" phase

temperature reached a maximum value of 375 degrees Celsius and resulted in reactor

power reductions to lower the temperature. The location of the elevated temperature

was at the movable hinged section of the disconnect. The "A" and "C" phase

temperatures were 95 to 100 degrees Celsius. The "B" phase high temperature was

discovered during ongoing monthly temperature monitoring. In response to the high temperature, operators reduced reactor power from 100 percentdown to 25 percent to reduce the disconnect temperature and support removal of the

main generator and disconnect from service to perform repairs. The inspectors observed

"just-in-time training" in the simulator that was given to the operators prior to removing

the main generator and disconnect from service. The inspectors also observed the

operators' removal of the main generator and disconnect from service to support repairs.

After removal from service, the "B" phase disconnect was rebuilt and tested satisfactorily

prior to being returned to service. The main generator was placed back in service and

the plant was returned to 100 percent power. The documents reviewed are listed in the

Attachment. b.Findings

10Enclosure No findings of significance were identified..2(Closed) LER 05000353/02007-001, Scram Discharge Volume Vent and Drain Valves Failed Open Due to Clearance Tagging ErrorOn March 10, 2007, Limerick Unit 2 was in hot shutdown and depressurized toapproximately 25 psig for the 2R09 refueling outage. A full scram signal was present

and the scram discharge volume (SDV) was isolated, as designed. Operators were in

the process of applying a clearance in preparation for planned maintenance on the

Reactor Protection System and the scram air header. As part of this clearance,

operators removed the Reactor Protection System backup scram fuses which ultimately

resulted in the

SDV vent and drain valves opening unexpectedly. Water from the

SDV

began to vent through these open valves into the plant drain system. Station personnel

discovered the condition and closed the SDV vent and drain valves, stopping the source

of the water. Further investigation by the station determined that the inadvertent opening

of the

SDV vent and drain valves was due to an improperly written clearance. A non-cited violation (

NCV) associated with this issue was documented in Section 1R20of NRC integrated inspection report 05000352/2007002 and 05000353/2007002. The

inspectors reviewed this LER and did not identify any additional findings of significance.

Exelon documented this event and associated corrective actions in IR 602042. The

documents reviewed are listed in the Attachment. This

LER is closed..3(Closed)

LER 05000353/02007-002, Valid Actuation of Main Condenser Low Vacuum Isolation Logic During OutageOn March 12, 2007, operators were in the process of lowering vacuum on Limerick Unit 2as part of refueling outage activities in accordance with procedure S07.2.A, "Shutdown of

the Steam Jet Air Ejector and Breaking Main Condenser Vacuum." During this evolution,

the main condenser low vacuum main steam isolation valve (MSIV) isolation logic

actuated unexpectedly. Further investigation revealed that due to a procedural execution

error, station personnel had only bypassed two of the required four channels of the

isolation logic. Even though this resulted in actuation of two channels of logic when

vacuum was lowered, no valves actually repositioned since the

MS [[]]

IVs and other affected

valves were closed earlier as required by procedure. This failure to comply with

procedure S07.2.A constitutes a violation of minor significance that is not subject to

enforcement action in accordance with Section

IV of the

NRC's enforcement policy. The

inspectors reviewed this LER and did not identify any additional findings of significance.

Exelon documented this event and associated corrective actions in

IR 602921. This
LER [[is closed. .4(Closed) LER 05000353/02007-003, Automatic Actuation of the Reactor ProtectionSystem at PowerOn April 24, 2007, the Unit 2 Reactor Protection System automatically actuated whenreactor water level decreased from +35 inches to +12.5 inches. All control rods fullyinserted. When reactor level decreased to the low-low level setpoint of -38 inches, both]]
HPCI and
RCIC systems initiated and injected into the vessel.
HPCI and

RCIC were

placed in manual mode when flow oscillations were observed on both systems. Both

systems were automatically secured when reactor level increased to +54 inches.

11Enclosure Exelon's investigation determined that a circuit card in Redundant Reactivity ControlSystem (RRCS) Division 1, channel "B" spuriously actuated while channel "A" was in a

tripped condition due to planned surveillance testing. This resulted in a feedwater

runback. The feedwater runback reduced reactor level as expected.Exelon's investigation determined that

HPCI and

RCIC flow oscillations were due to flowcontrol loop tuning settings that did not properly account for differences in flow path

testing conditions and vessel injection flow conditions. Station personnel replaced and

successfully tested the affected

RRCS circuit card. In addition the
HPCI and
RC [[]]

IC flow

controller gain and reset settings were adjusted to be consistent with Unit 1 settings,

which are consistent with industry values and similar to previous Unit 2 settings when

stable flow was demonstrated during Unit 2 initial startup testing. The procedure for

tuning of

HPCI and

RCIC flow controls was revised to specify the required gain and reset

settings.The inspectors reviewed Exelon's apparent cause investigation, Unit

2 TS , andnotification requirements. The apparent cause investigation determined that the
HPCI and
RC [[]]

IC gain and reset settings were changed during system tuning in May 1999;

therefore, this condition existed for approximately 8 years. This resulted in a condition

that could have prevented the safety function of Unit

2 HPCI. A non-cited violation (

NCV)

associated with this issue was documented in Section

IR 19 of

NRC integrated inspection

report 05000352/2007003 and 05000353/2007003. Exelon documented this issue and

its corrective actions in IR 620861. The review determined that Unit 1 was not affected.

The inspectors reviewed the corrective actions, including revised procedures, and found

no additional findings or unresolved issues. The documents reviewed are listed in the

Attachment. This

LER is closed.4

OA6Meetings, Including ExitExit Meeting SummaryOn October 15, 2007, the resident inspectors presented the inspection results toMr. E. Callan and other members of his staff. The inspectors confirmed that proprietary

information was not included in the inspection report.

ATTACH [[]]
MENT [[:]]
SUPPLE [[]]
MENTAL [[]]
INFORM [[]]
ATION A-1AttachmentSUPPLEMENTAL
INFORM [[]]
ATIONK EY
POINTS [[]]
OF [[]]
CONTAC [[]]

TExelon Generation CompanyC. Mudrick, Site Vice PresidentE. Callan, Plant Manager

D. DiCello, Radiation Protection Manager

R. Dickinson, Director Engineering
J. Berg, System Manager,
HPCI and
RC [[]]

IC

J. George, System Manager, Remote Shutdown Panel

M. Gift, System Manager, Radiation Monitoring Systems

R. Gosby, Radiation Protection Technician, Instrumentation

R. Harding, Engineer, Regulatory Assurance

R. Kreider, Manager, Regulatory Assurance

D. Malinowski, Simulator Instructor

B. Tracy, System Manager
P. Tarpinian,

PRA Engineer

D. Boylan, Summer Readiness Coordinator

R. Newmaster, Manager - Emergency Preparedness, Limerick
J. Broillet, Operations Shift Manager
LIST [[]]
OF [[]]
ITEMS [[]]
OPENED ,
CLOSED ,
AND [[]]

DISCUSSEDClosed05000353/2007-001-0LERScram Discharge Volume Vent and DrainValves Failed Open due to Clearance

Tagging Error (Section 40A3.2)05000353/2007-002-0LERValid Actuation of Main Condenser LowVacuum Isolation Logic During Outage

(Section 40A3.3) 05000353/2007-003LERAutomatic Actuation of the ReactorProtection System at Power (Section

40A3.4) DiscussedNone

A-2AttachmentLIST

OF [[]]
DOCUME NTS
REVIEW [[]]

EDSection 1R01: Adverse Weather ProtectionProceduresOP-AA-108-107-1001, "Station Response to Grid Capacity Conditions," Revision 2S32.3.A, "Main Generator Inspection During Heavy Grid Load," Revision 7Section 1R04: Equipment AlignmentProceduresTechnical Specification 3/4 8.1, "A.C. Sources"S92.9.N, "Routine Inspection of the Diesel Generators," Revision 53

1S46.1.A (COL), "Valve and Breaker Alignment for Start-up of the Control Rod Drive Hydraulic

Supply System for Service"

ST -6-048-230-1, "

SLC Pump, Valve, and Flow Test"

S49.3.A, "RCIC Fill and Vent," Revision 17

Troubleshooting, Rework, and Testing Control Form,

TRT No.07-174,

RCIC Fill and VentSection 1R05: Fire ProtectionProceduresARC-MCR-006 B1L, Fire Alarm Response Card, Revision 2F-A-452, "Unit 1 Static Inverter Room, Fire Area 20," Revision 7

F-A-453, "Unit 2 Static Inverter Room, Fire Area 20," Revision 4

F-A-533, "Control Room 533 and Peripheral Rooms 530 to 535 (EL. 269) Fire Area 24," Revision 10F-A-619, "Control Structure Fan Room (EL. 304) Fire Area 27," Revision 6

F-A-624, "Standby Gas Treatment Area Rooms 624 & 625, Fire Area 28," Revision 6

F-D-311D, "D14 Diesel Generator Room and Fuel Oil and Lube Oil Tank Room Rooms 311Dand 312D (EL. 217) Fire Area 82," Revision 5F-T-328, "Unit 1 Air Compressor,

EHC Power Unit, and Turbine Lube Oil Storage Tank AreasRooms 328, 330, and 331 (
EL. 217) Fire Area 93," Revision
5OP -

AA-201-003, "Fire Drill Performance," Revision 8

SE -8, "Fire," Revision 31
ST -6-022-551-0, "Fire Drill," Revision 8, conducted on 9/26/07Issue Reports and Action Requests (
AR s)IR 676038, "Fire Brigade Member
EO Key Ring"A1261436, "Evaluate Propping Open of Doors"Miscellaneous
UFSAR Appendix
9AS ection 1R06: Flood Protection MeasuresProcedures

SE-4, "Flood," Revision 5SE-4-1, "Reactor Enclosure Flooding," Revision 8

A-3AttachmentIssue Reports and Action RequestsIR 634795, "Floor Drain Clogged in U/1

HPCI Room"Miscellaneous
BLP -31981, "Moderate Energy Pipe Break (MEPB) Analysis," dated February 1984NPB-14, "Moderate Energy Line Break," Revision 4
NPB -32, "Flooding of
ECCS Compartments from the Suppression Pool," Revision
3NPB -33, "Moderate Energy Pipe Break Report," Revision 3Section 1R11: Licensed Operator Requalification ProgramProcedures

EOP T-101, "RPV Control," Revision 20 EOP T-103, "Secondary Containment Control," Revision 17

EOP T-112, "Emergency Blowdown," Revision 12
EOP T-270, "Terminate and Prevent injection into
RPV ," Revision 12Section 1R12: Maintenance EffectivenessProceduresER-AA-310, "Implementation of the Maintenance Rule," Revision
6ER -
AA -310-1004, "Maintenance Rule - Performance Monitoring," Revision 5
ER -
AA -310-1003, "Maintenance Rule - Performance Criteria Selection," Revision 3
ER -
AA -310-1005, "Maintenance Rule - Dispositioning Between (a)(1) and (a)(2)," Revision 5
ER -
LG -310-1010, "Maintenance Rule Implementation," Revision 7
ER -
AA -310, "Implementation of the Maintenance Rule," Revision 6Issue Reports and Action RequestsIR 483496, "TECW Unavailability Issues"IR 637270, "Possible Maintenance Rule (a)(1) for Excessive
TE [[]]
CW System Outage Window"
IR 642006, "2B
TECW Heat Exchanger Unavailability Hours Exceeded"
IR 667927, "Document Unit 2

HPCI Maintenance Rule (a)(1) Determination"

IR 506692, "Points 3 & 5 Failing"
IR 546231, "1A Recombiner Valve
FV -DO-101A Failed to Open"
IR 551504, "1A Post
LOCA Recombiner
MR ule

FF (A)(1) Determination"MiscellaneousMaintenance Rule Expert Panel Meeting Minutes, dated 11/01/2006, 11/30/2006Maintenance Rule Expert Panel Meeting Minutes, dated 09/14/2000, 02/15/2001, 04/20/2006,

06/19/2007Section 1R13: Maintenance Risk Assessments and Emergent Work ControlProceduresER-AA-600-1045, "Risk Assessments of Missed or Deficient Surveillances," Revision 0S07.6.A, "Placing Alternate Steam Jet Air Ejector In Service," Revision 27

ST -2-041-661-1, "Safety Relief Valves - Safety Relief Valve Position Indicators Functional Test,"Revision 12Issue Reports and Action Requests

IR 598489, "D11 - Adjust Voltage Regulator Droop to 3% - 5%"

A-4AttachmentIR 601471, "ISI Inspection Volume for Code Case N-435"IR 649698, "Incorrect Interpretation of

AS [[]]
ME Code Case N-435-1"
IR 657596, "2B Reactor Recirculation
MG Set Runback to Min Speed"
IR 668047, "Large

VAR Swings During D12 D/G/ Run"IR 674591, "SRV 'D' Position Indicator Functional Test Failed"

A1456726, "Excursion in

KVAR and

KW"

A1600437, "D12 Voltage Regulator VAR Swings When Paralleled to Offsite"

A1628762, "IR for Generation of Activity to Swap Unit

2 SJ [[]]

AE"

A1631597, "Repair/Replace/Recal Loop Component," Dated 09/24/2007MiscellaneousOperator Logs dated 07/13/2007Limerick Generating Station On-Line Work Schedule, 09/14/2007-09/16/2007Section 1R15: OperabilityIssue Reports and Action RequestsIR 060981, "HPCI Turbine Steam Supply Valve Position Relay Contacts Failed"IR 101384, "Inappropriate Conclusions in Disp

PEP I0012531/
CR 00060981"
IR 641784, "
HPCI Aux Oil Pump Did Not Stop per PV&F"
IR 642617, "
HV -055-2F006 Failed to Stroke Open"
IR 658690, "Unit 2
RCIC OOS/Gross Fail Alarm"
IR 658931, "
RCIC Pump Suction HI Press Alarm Came in While Swapping Suction Valves"
IR 658950, "

HPCI Oil Pressure Lower Than Desired Band"

A1626638, "HPCI Oil Pressure Lower Than Desired Band"

IR 651187, "
HPCI Higher than Normal Unit
1 HP [[]]
CI Pump Room Temperature"
IR 664065, "Unit 2 Recirculation Pump #2 Seal Pressure Drop"MiscellaneousLimerick Generating Station

UFSAR Section 6.3LEAM-0008, "HPCI Flow to RPV w/Single Discharge Path Open," Revision 0

M-48-12, "SLCS Boron Injection Delay Time," Revision 4

M-55-10, "HPCI Line Sizing Check," Revision 4

M-55-26, "ATWS 3A

HPCI Flow Split Calculation to Size a Flow Orifice for Branch to CoreSpray," Revision 6
ECR [[]]
LG 01-01152, "
HPCI Failed Injection Valve - Provide Quality Docs"Section 1R19: Post Maintenance TestingProceduresST-2-042-638-2, "ATWS - Reactor Vessel Water Level - Low Low, Functional Test," Revision
12ST -6-051-231-2, "A
RHR Pump, Valve and Flow Test," Revision 52
ST -6-012-231-0, "A Loop
RHRSW Pump, Valve and Flow Test", Revision 54
ST -6-048-230-1, "
SLC Pump, Valve and Flow Test", Revision 32
ST -6-107-201-0,"

IST Valve Stroke for New Baseline," Revision 4

M-C-792-001, "Fairbanks Morse Opposed Piston Diesel Engine Examination and GeneralMaintenance," Revision 4Issue Reports and Action RequestsIR 338368, "Unit

2 RCIC Small Packing Leak from
HV -049-2F008
OUTBD [[]]
PCIV "IR 381319, "Unit
2 RCIC [[]]

HV-049-2F008 Packing Leak"

A-5AttachmentIR 654021,"D22 Diesel Lube Oil Circ Pump Making Excess Noise"IR 654041, "Dual Indication for HV-51-2F024A During Stroke Close"

IR 663431, "D21: Brush Holder Cable Replacement Not Identical to Original"

IR 664060, "D21 Diesel Rapid Shutdown Due to Cylinder Leak"

IR 664291, "D21 Emergency Stop Alarm Failed to Annunciate"

IR 676024, "Indicating Lights did not Illuminate"

A1178453, "Disassemble and Inspection 20" Manual Check Valve, 012-0001C"

A1624433, "Replace

RRCS [[]]

HPII/HPOI Cards"A1628140, "D21 Over Excitation During Break-In Run"

A1628023, "Alarms on D21 Still Annunciated and Will Not Clear"

A1628302, "D21 Diesel Rapid Shutdown Due to Cylinder Leak"

A1630245, "Unit

2 RCIC Steam Line Outboard

PCIV"Work OrdersR1005988, "D21 24 Month Diesel Inspection Per M-C-792-001"

MiscellaneousLimerick Generating Station On-Line Work Schedule 08/23/2007-08/26/2007Operator Logs dated 08/23/2007

Safety Relief Valve Technical Specification Accident Monitoring Instrumentation Table 3.3.7.5-1Section 1R22: Surveillance TestingProceduresST-2-051-802-2, "Division

2 LPCI System Response Time Testing," Revision 8
ST -2-055-810-1, "HPCI System Response Time Testing," Revision 11, completed 09/18/2007
ST -6-055-230-1, "
HPCI Pump, Valve, and Flow Test," Revision 65, completed 09/18/2007
ST -6-092-314-2, "D24 Diesel Generator Slow Start Operability Test Run," Revision 61,completed 07/16/07
ST -6-107-790-2, "Control Rod Scram Timing," Revision 11, completed 09/20/2007Issue Reports and Action RequestsA1614302, "U2
HCU 46-47 Has No Full Out Position Indication on Full Core Display"
IR 671836, "Blue Scram Light Failed to Light During
ST -6-107-790-2"Section 1R23: Temporary Plant ModificationsProcedures

CC-AA-112, "Temporary Configuration Changes," Revision 12S43.0.C, "Clearing an Electrical or Mechanical Stop," Revision 18MiscellaneousTRT-D7-164, "Install 1B Reactor Recirculation Pump Motor Generator Temporary Mechanical Stop"C0221920, "Install Temporary Mechanical High Speed Stop in XY-M1-1S001B"

Limerick Generating Station

UFS [[]]

AR Section 5.4

Limerick Generating Station Technical Specifications 3/4.4.1Issue Reports and Action RequestsIR 631119, "1B Recirc Pump Speed Changes"IR 654530, "Emergent

PRA - Need New

AR Created to Install Travel Limiter"

A1616738, "1B Recirc Pump Speed Changes"

A-6AttachmentA1625008, "Need New

AR Created to Install Travel Limiter"Section 1

EP6: Drill EvaluationProceduresEOP T-117, "Level/Power Control," Revision 15EOP T-104, "Radioactivity Release Control," Revision 12

EOP T-103, "Secondary Containment Control," Revision 17
EOP T-270, "Terminate and Prevent Injection Into
RPV ," Revision 12
EP -
AA -122, "Drills and Exercises," Revision 7
EP -
AA -122-F-01, "Drill and Exercise Evaluation Criteria," Revision B
EP -
AA -122-1001, "Drill and Exercise Scheduling, Development, and Conduct," Revision 8
EP -
AA -122-1002-F-02, "Drill and Exercise Objective Evaluation Data Tables," Revision B
LS -

AA-120, "Issue Identification and Screening Process," Revision 7

T-103, "Secondary Containment Control," Revision 17MiscellaneousIR 437320IR 670538

Limerick [EP] Training Drill Series Evaluation Report, dated 07-31-2007

LS [[]]
ES -8020, "Licensed Operator Training Simulator Evaluation Scenario," Revision 0
NRC [[]]
IR 50-352&353/2005009Section
4OA 1: Performance Indicator (
PI ) VerificationProceduresS92.6.N, "Diesel Oil Storage Tank Lineup to Fill Other than its Associated Day Tank," Revision 10Issue Reports and Action RequestsIR 556902, "Minor Leakby of 049-2F014 Discovered During
ST -2-049-601-2"
IR 565800, "HV-049-1F019
RCIC Min Flow Shows Dual Indication at 600
GPM "
IR 620861, "
GP -18 Review
HPCI /
RCIC Oscillations"
IR 628573, "
RCIC [[]]
MOV Overload or Power Loss
DS 14"
IR 628579, "Inadvertent
RCIC OOS Annunciator"
IR 628600, "2

DA-09 Tripped on Thermals"

IR 642618, "Valve Stroke Time Outside Acceptable Range"
IR 652846, "

RCIC Overspeed Test Potentiometers Possibly Not Locked"

A1238085, "Determine if

HP [[]]

CI is Operable With Temperature Instrumentation Installed"

A1295250, "FI-49-1R600-1 Spiking"

A1304397, "Revise the

ML -008 Spec to Correctly Reflect the Safety Classification of the
RCICM in Flow Line"MiscellaneousNEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5Reactor Oversight Program
MS [[]]
PI Bases Document, Limerick Generating Station, Revision 1
MSPI Derivation Reports for
HPCI ,
RCIC , and

EDGs

Operator Logs dated 07/01/2007 through 07/31/2007

Maintenance Rule Failure Reports for

HPCI ,
RCIC , and EDGs
LG 01-00170, "Classification of the

RCIC Min Flow Line"Section 4OA2: Other

A-7AttachmentIssue Reports and Action RequestsA16106882C-P501 Packing Leakoff Excessive (Complete)A16159402C Circ Pump Step Change in Vibration

A1620985Spray Pond Level/Temp Alarming Before Setpoints Reached

A16219922C-P501 Excessive Packing Leakage (Complete)

A1622672Control Rod 22-35 Temp at 305 Deg F

A1628676Spray Pond Hi Temp Alarms Early

C02212742C-P501-DR Inspect or Replace Motor Bearings

IR 6120832C-P501 Packing Leakoff Excessive
IR 612647Drive Mechanism Temperature for

HCU 30-35 is @429 Degrees F

IR 6275952C Circ Pump Surge Capacitor Damaged

IR 6289652C Circ Pump Step Change in Vibration

IR 639934"Spray Pond Lo Level/Hi Temp" Alarm Locked In

IR 643596Spray Pond Level/Temp Alarming Before Setpoints Reached

IR 6454662C-P501 Excessive Packing Leakage

IR 648107Control Rod 22-35 Temp at 305 Deg F (Completed)

IR 649388Hairline Crack Identified on Yoke
IR 6498062C-P501-

DR Temp Cooling

IR 654068Hairline Crack Identified on Yoke

IR 654070Hairline Crack Identified on Yoke

IR 665262Spray Pond Hi Temp Alarms Early

IR 6723152C-P501 High Packing Leak OffOther DocumentsPlant Health Committee System Presentation: Circ Water, June, 2007Plant Health Committee System Presentation: Control Rod Drive Supply, June, 2007

Plant Health Committee System Presentation: EDG, June, 2007

Plant Health Committee System Presentation:

RHR [[]]
SW , June, 2007
SH [[]]
IP Chronic Problem Report: Circ Water, June, 2007
SHIP Chronic Problem Report:

EDG, June, 2007

System Health Overview Report: Circ Water, June, 2007

System Health Overview Report: Control Rod Drive Supply, June, 2007

System Health Overview Report: EDG, June, 2007

System Health Overview Report:

RHR [[]]

SW, June, 2007

System Health Overview Report: Circ Water, Sept, 2007

System Health Overview Report: Control Rod Drive Supply, Sept, 2007

System Health Overview Report: EDG, Sept, 2007

System Health Overview Report:

RHRSW , Sept, 2007Section 4
OA 3: Event FollowupProceduresOP-LG-109-101-1001, "Limerick System Specific Tagging Guides," Revision 15Issue Reports and Action RequestsIR 601910, "Drainage System Clogged"IR 602042, "Unit 2 SDV Vent/Drain Valves Open With Scram Signal Present"
IR 602921, "Division 1 and 4

MSIV Isolation Logic Alarms"

A-8AttachmentMiscellaneousLER 2007-001, "Scram Discharge Volume Vent and Drain Valves Failed Open Due to ClearanceTagging Error"LER 2007-002, "Valid Actuation of Main Condenser Low Vacuum Isolation Logic During Outage"

LER 2007-003, "Automatic Actuation Of The Reactor Protection System at Power"
LIST [[]]
OF [[]]
ACRONY MSADAMSAgencywide Documents Access Management SystemARaction request
ASM [[]]
EA merican Society of Mechanical Engineers
CA [[]]
PC orrective Action Program
CF [[]]

RCode of Federal Regulations

CRDcontrol rod drive

EDGemergency diesel generator

EHCelectro-hydraulic control

EP emergency preparedness
ER [[]]
OE mergency Response Organization
HP [[]]

CIhigh pressure coolant injection

IRissue report

kVkilo volt

LE [[]]
RL icensee Event Report
LO [[]]
CA loss of coolant accident
MS [[]]

IVmain steam isolation valve

NCV non-cited violation
NE [[]]
IN uclear Energy Institute
NR [[]]

CNuclear Regulatory Commission

OAother activities

PAR protective action recommendation
PAR [[]]

SPublicly Available Records

PI performance indicator
P& [[]]

IDpiping and instrumentation drawing

PMT post-maintenance test
RC [[]]

ICreactor core isolation cooling

RHR residual heat removal
RR [[]]
CS redundant reactivity control system
SC [[]]

BAself-contained breathing apparatus

SDV scram discharge volume
SH [[]]

IPsystem health indicator program

SSC structure, system, component

TS technic al specification
UFS [[]]
AR updated final safety analysis report