IR 05000352/2013503

IR 05000352-13-503; 05000353-13-503; 11/18 to 22/2013; Limerick Generating Station, Units 1 and 2; Exercise Evaluation: Hostile Action (HA) Event; Exercise Evaluation, Scenario Review; Performance Indicator Verification

ML14002A026
Person / Time
Site:	Limerick
Issue date:	01/02/2014
From:	Anthony Dimitriadis Plant Support Branch 1
To:	Pacilio M J Exelon Generation Co, Exelon Nuclear
References
IR-13-503
Download: ML14002A026 (10)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BOULEVARD KING OF PRUSSIA, PENNSYLVANIA 19406 January 2, 2014 Mr. Michael Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT: LIMERICK GENERATING STATION UNITS 1 AND 2: NRC EVALUATED EMERGENCY PREPAREDNESS EXERCISE - INSPECTION REPORT 05000352/2013503 AND 05000353/2013503

Dear Mr. Pacilio:

On November 21, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of the November 19, 2013, evaluated emergency preparedness exercise at your Limerick Generating Station, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on November 21, 2013, with Mr. T. Dougherty, Site Vice President, and other members of your staff. The inspection examined activities conducted under your licenses as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your licenses. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Based on the results of this inspection, no findings were identified.

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

Sincerely,/RA/ Anthony Dimitriadis, Chief Plant Support Branch 1 Division of Reactor Safety

Docket Nos.: 50-352, 50-353 License Nos.: NPF-39, NPF-85

Enclosure:

NRC Inspection Report No. 05000352/2013503 and 05000353/2013503 cc w/encl: Distribution via ListServ G. Cannon, Director, PA Emergency Management Agency (PEMA) and Office of Homeland Security Advisor J. Price, RAC Chair (Acting), FEMA Region III Mr. Michael

SUMMARY OF FINDINGS

Inspection Report 05000352/2013503; 05000353/2013503; 11/18-22/2013; Limerick Generating Station, Units 1 and 2; Exercise Evaluation - Hostile Action (HA) Event; Exercise Evaluation - Scenario Review; Performance Indicator Verification.

This was an announced inspection conducted by five Region I-based inspectors, and one Headquarters-based inspector. No findings were identified during the inspection. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

A. NRC-Identified and Self-Revealing Findings

None.

B. Licensee-Identified Findings None.

REPORT DETAILS

REACTOR SAFETY

Cornerstone:

Emergency Preparedness (EP)1EP7 Exercise Evaluation - Hostile Action Event (71114.07 - 1 Sample)

a. Inspection Scope

Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix E,Section IV.F.2.j, requires in part that nuclear power reactor licensees, in each eight calendar year exercise cycle, provide the opportunity for their emergency response organization (ERO) to demonstrate proficiency in the key skills necessary to respond to a hostile action (HA) directed at the plant site. Exelon designed the November 19, 2013, Limerick EP exercise to satisfy that requirement, and the NRC inspected the Limerick HA event exercise to assess Exelon's ability to effectively implement the Limerick Emergency Plan during an HA event and adequately protect public health and safety. This overall exercise inspection activity represented the completion of one sample on a biennial cycle. The exercise evaluation consisted of the following review and assessment: The adequacy of Exelon ERO's performance in the biennial full-participation exercise regarding the implementation of the planning standards described in 10 CFR 50.47(b) (4), (5), (9), and (10), which are: emergency classification; offsite notification; radiological assessment; onsite protective actions, and public protective action recommendations, respectively.

The overall adequacy of Exelon's emergency response facilities with regard to Emergency Plan commitments. The facilities assessed were the Control Room Simulator, the Alternative Facility, the Central Alarm Station (CAS), the local county Tactical Operations Center (TOC), and the Emergency Operations Facility (EOF).

A review of other performance areas, such as the Exelon ERO's: recognition of abnormal plant conditions; command and control, including interactions with site security staff; intra- and inter-facility communications; prioritization of mitigating activities; utilization of repair and field monitoring teams; interface with offsite agencies, including local law enforcement agencies; staffing and procedure adequacy; and the overall implementation of the Emergency Plan and its implementing procedures.

A review of past performance issues from the last NRC Limerick exercise inspection report and recent Exelon Limerick EP drill reports, to determine the effectiveness of licensee corrective actions as demonstrated during the November 19, 2013, exercise and to ensure compliance with 10 CFR 50.47(b)(14).

The licensee's post-exercise critiques, to evaluate Exelon's self-assessment of its Limerick ERO performance during the November 19, 2013, exercise and to ensure compliance with 10 CFR Part 50, Appendix E, Section IV.F.2.g. The inspectors reviewed the documents listed in the attachment to this report.

b. Findings

No findings were identified. 1EP8 Exercise Evaluation - Scenario Review (71114.08 - 1 Sample)

a. Inspection Scope

Prior to the November 19, 2013, emergency preparedness exercise, the NRC inspectors conducted an in-office review of the exercise objectives and scenario, which Exelon had submitted to the NRC, to determine if the exercise would test major elements of the Limerick Emergency Plan as required by 10 CFR 50.47(b)(14). This overall exercise inspection activity represented the completion of one sample on a biennial cycle. The inspectors reviewed the documents listed in the attachment to this report.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification (71151 - 3 Samples)

a. Inspection Scope

The inspectors reviewed data for the Limerick EP Performance Indicators (PI), which are: (1) Drill and Exercise Performance (DEP) (EP01); (2) ERO Drill Participation (EP02); and, (3) Alert and Notification System (ANS) Reliability (EP03). The last NRC EP inspection at Limerick was conducted in the fourth calendar quarter of 2012, so the inspectors reviewed supporting documentation from EP drills and tests from the fourth calendar quarter of 2012 through the third calendar quarter of 2013, to verify the accuracy of the reported PI data. The review of these PIs was conducted in accordance with NRC Inspection Procedure 71151, using the acceptance criteria documented in NEI 99-02, "Regulatory Assessment Performance Indicator Guidelines," Revision 7. This inspection activity represented the completion of three samples.

b. Findings

No findings were identified.

4OA6 Meetings, including Exit

On November 21, 2013, the inspectors presented the results of this inspection to Mr. T. Dougherty, Limerick Site Vice President, and other members of the Exelon staff.

The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Dougherty, Site Vice President

V. Cwietniewicz, Exelon Mid-Atlantic Emergency Planning Manager

J. Broillet, Limerick Emergency Planning Manager

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

None.

Section 1EP7: Exercise Evaluation - Hostile Action (HA) Event

EP-AA-1000, Exelon Nuclear Standardized Emergency Plan (Revision 24)

EP-AA-1008, Limerick Generating Station Emergency Plan Annex (Revision 26)

Limerick Emergency Plan lmplementing Procedures Limerick November 19, 2013, Emergency Exercise Scenario Package

OP-TM-AOP-008, Security Threat/Intrusion (Revision 10)

Limerick Emergency Preparedness Drill Reports, January 2012 - March 2013

Condition Reports

generated as a result of the November 19, 2013, exercise (As documented in Limerick 2013 Graded Exercise Evaluation Report, dated

December 17, 2013)

Section 1EP8: Exercise Evaluation - Scenario Review

EP-AA-1000, Exelon Nuclear Standardized Emergency Plan (Revision 24)

EP-AA-1008, Limerick Generating Station Emergency Plan Annex (Revision 26)

Limerick November 19, 2013, Emergency Exercise Scenario Package

Section 4OA1: Performance Indicator (PI) Verification

LS-AA-2110, Monthly Data Elements for NRC Emergency Response Organization (ERO) Drill Participation (Revision 6)

LS-AA-2120, Monthly Data Elements for NRC Drill/Exercise Performance (Revision 4)

LS-AA-2130, Monthly Data Elements for NRC Alert and Notification System (ANS) Reliability (Revision 5)

EP-AA-125-1001, EP Performance Indicator Guidance (Revision 7) DEP PI data, October 2012 - September 2013 ERO Drill Participation PI data, October 2012 - September 2013

ANS Reliability PI data, October 2012 - September 2013

Attachment

LIST OF ACRONYMS

ADAMS Agencywide Documents Access and Management System

ANS Alert Notification System

CAS Central Alarm Station

CFR Code of Federal Regulations

DEP Drill and Exercise Performance

EOF Emergency Operations Facility

EP Emergency Preparedness

ERO Emergency Response Organization

HA Hostile Action

NRC Nuclear Regulatory Commission

PAR Protective Action Recommendation

PI Performance Indicator

RSPS Risk Significant Planning Standard

TOC Tactical Operations Center