IR 05000352/2010005

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IR 05000352-10-005, 05000353-10-005, on 10-01-2010 - 12-31-2010, Limerick Generating Station, NRC Integrated Inspection Report
ML110250035
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 01/24/2011
From: Krohn P G
Reactor Projects Region 1 Branch 4
To: Pacilio M J
Exelon Nuclear, Exelon Generation Co
Krohn P G
References
IR-10-005
Download: ML110250035 (31)


Text

January 24, 2OIIMr. Michael ]Senior Vice President, Exelon Generation Company, LLCPresident and Chief Nuclear Officer, Exelon Nuclear4300 Winfield Rd,Warrenville, lL 60555

SUBJECT: LIMERICK GENERATING STATION - NRC INTEGMTEDtNSPECTlON REPORT 05000352/201 0005 AND 05000353/201 0005

Dear Mr. Pacilio:

On December 31 ,2010, the U. S. Nuclear Regulatory Commission (NRC) completed aninspection at your Limerick Generating Station Units 1 and 2. The enclosed integratedinspection report documents the inspection results which were discussed on January 7 ,2011,with Mr. W. Maguire 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 anp with the conditions of your license.The inspectors reviewed selected procedures and records, -observed activities, and interviewedpersonnel based on the results of the inspection, no findings were identified.f n accordance with 10 Code of Federal Regulations (CFR) Part2.390 of the NRC's "Rules ofPractice," a copy of this letter, its enclosure, and your response (if any) will be availableelectronically for public inspection in the NRC Public Document Room or from the PubliclyAvailable Records (PARS) component of the NRC's document system (ADAMS). ADAMS isaccessible from the NRC Website at http://www.nrc.qov/readins-rm/adams.html (the PublicElectronic Reading Room).

Sincerely,Docket Nos:License Nos:

Enclosure:

cc w/encl:P*-z I Z*4-Paul G. Krohn, ChiefProjects Branch 4Division of Reactor Projects50-352, 50-353NPF-39, NPF-85Inspection Report 05000352/201 0005 and 05000353/201 0005

w/Attachment:

Supplemental I nformationDistribution via ListServ M. PacilioMr. Michael J. PacilioSenior Vice President, Exelon Generation Company, LLCPresident and Chief Nuclear Officer, Exelon Nuclear4300 Winfield Rd.Warrenville, lL 60555

SUBJECT: LIMERICK GENERATING STATION - NRC INTEGRATEDINSPECTTON REPORT 05000352/201 0005 AND 05000353/201 0005

Dear Mr. Pacilio:

On December 31 ,2010, the U. S. Nucfear Regufatory Commission (NRC) completed aninspection at your Limerick Generating Station Units 1 and 2. The enclosed integratedinspection report documents the inspection results which were discussed on January 7,2011,with Mr. W. Maguire 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 interviewedpersonnel based on the results of the inspection, no findings were identified.In accordance with 10 CFR Part 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 theNRC Public Document Room or from the Publicly Available Records (PARS) component of theNRC's document system (ADAMS). ADAMS is accessible from the NRC Website athttp://www.nrc.qov/readinq-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/Paul G. Krohn, ChiefProjects Branch 4Division of Reactor ProjectsDistribution Mencl: (via e-mail)W. Dean, RAD. Lew. DRAJ. Clifford, DRPG. Dentel, DRPD. Roberts, DRSP. Wilson, DRSP. Krohn, DRPA. Rosebrook, DRPE. Torres. DRPSUNSI Review Complete: PGK (Reviewer's Initials)ML110250035DOC NAME: G:\DRP\BRANCH4\INSPECTION REPORTS\LIMERlCKUO1O\LIM 2010 4TH QTR\LtM 2010-005 REV 1.DOCXAfter declaring this document "An Official Agency Record" it ygl!! be released to the Public.To receiveindicate in box"C' = Coov dout attachment/enclosure'E' =S. lbarrola, DRPE. DiPaoIo, DRP, SRIN. Sieller, DRP, RlN. Esch, DRP, AAJ. Trapp, Rl, OEDORidsNrrPM Limerick ResourceRidsNrrDorlLpl 1 -2ResourceRO P reports Resou rce@ n rc. g ovOFFICE mmt RI/DRPDATE 01t24 t1101t24 t1101t24 t11OFFICIAL RECORD Docket Nos:License Nos:Report No:Licensee:Facility:Location:Dates:Inspectors:Approved by:U. S. NUCLEAR REGULATORY COMMISSIONREGION I50-352,50-353NPF.39, NPF-8505000352/201 0005 and 05000353/201 0005Exelon Generation Company, LLCLimerick Generating Station, Units 1 & 2Sanatoga, PA 19464October 1, 2010 through December 31, 2010E. DiPaolo, Senior Resident InspectorN. Sieller, Resident InspectorJ. Hawkins, Acting Resident InspectorA. Rosebrook, Senior Project EngineerT. Moslak, Health PhysicistJ.Caruso, Senior Operations Engineer (Section 1R11.2)J. D'Antonio, Senior Operations Engineer (Section 1R1 1.2)J. Tomlinson, Operations Engineer (Section 1R1 1.2)C. Crisden, Emergency Preparedness SpecialistPaul G. Krohn, ChiefProjects Branch 4Division of Reactor ProjectsEnclosure 2

SUMMARY OF FINDINGS

lR 0500035212010005;05000353/2010005; 1010112010-1213112010; Limerick GeneratingStation, Units 1 and2; routine integrated report.The report covered a three-month period of inspection by resident inspectors, a senior projectengineer, a health physicist, an emergency preparedness specialist, and an announcedinspection by operations engineers. The NRC's program for overseeing the safe operation ofcommercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight,"Revision 4, dated December 2006.No findings were identified.Enclosure

4

REPORT DETAILS

Summarv of Plant StatusUnit 1 began the inspection period operating at full rated thermal power (RTP). OnDecember 4, operators reduced power to approximately 94 percent to facilitate main turbinevalve testing, control rod scram timg testing, a control rod pattern adjustment, and to performsegondary plant maintenance. Power was restored to full RTP on December 5. Unit 1 'remained at full RTP for the remainder of the inspection period.Unit 2 began the inspection period operating at full RTP. On October 23, power was reduced(unplanned) to approximately 50 percent as a result of the trip of the 'A' recirculation pumpmotor-generator set. Following troubleshooting and repairs to the generator voltage regulator,power was further reduced on October 24 to approximately 33 percent to facilitate the restart ofthe 'A' recirculation pump. Power was restored to full RTP on October 25. On October 30,operators reduced power to 85 percent to facilitate a follow up control rod pattern adjustment.Power was restored to full RTP on October 31. A power reduction to 85 percent was performedon November 20 to facilitate a control rod pattern adjustment. Full power was restored onNovember 21. On December 3, power was reduced (unplanned) to approximately 58 percentas a result of the trip of the 'A' recirculation pump motor-generator set. Operators reducedpower to approximately 35 percent to facilitate the restart of the 'A' recirculation pump followingtroubleshooting and repairs to the recirculation pump motor-generator set generator voltageregulator. Full RTP was restored on December 6. On December 18, operators reduced powerto approximately 80 percent to facilitate main turbine valve testing, fuel channel distortiontesting, and a control rod pattern adjuptment. The unit was restored to full RTP on IDecember 19. Unit 2 remained at full RTP for the remainder of the inspection period.1. REACTORSAFETYCornerstones: Initiating Events, Mitigating Systems and Barrier Integrity1R01 Svstem Seasonal Adverse Weather Protection (71111.01 - 1 seasonal sample)a. Inspection ScopeThe inspectors assessed the effectiveness of the licensee's cold weather protectionprogram as it related to ensuring that equipment in the facility's spray pond pump housewould remain functional and available in cold weather conditions. This equipmentincludes the emergency service water (ESW) pumps, residual heat removal (RHR)service water pumps, motor-operated valves associated with the spray pond, andsupport electrical equipment. ln addition to reviewing the licensee's program-relateddocuments and procedures, walkdowns were conducted of the lreeze protectionequipment (e.9., ventilation system dampers, building heating system, etc.) associatedwith the above systems/components. The inspectors observed plant conditions andevaluated those conditions against criteria documented in procedure GP-7, "ColdWeather Preparation and Operation." Licensee problem identification and resolutionassociated with cold weather protection was also assessed. Documents reviewed arelisted in the Attachment.Enclosure cb. FindinqsNo findings were identified.

1R04 EquipmentAliqnmentPartial Walkdown (71111.04Q - 3 samples)a. Inspection ScopeThe inspectors performed partial walkdowns of the plant systems listed below to verifyoperability following realignment after a system outage window or while safety-relatedequipment in the opposite train was inoperable, undergoing surveillance testing (ST), orpotentially degraded. The inspectors used Technical Specifications (TS), Exelonoperating procedures, plant piping and instrumentation diagrams (P&lD), and theUpdated Final Safety Analysis Report (UFSAR) as guidance for conducting partialsystem walkdowns. The inspectors reviewed the alignment of system valves andelectrical breakers to ensure proper in-service or standby configurations as described inplant procedures and drawings. During the walkdowns, the inspectors evaluated thematerial condition and general housekeeping of the systems and adjacent spaces. Thedocuments reviewed are listed in the Attachment. The inspectors performed walkdownsof the following areas:r Emergency diesel generator (EDG) D23 on October 21,2Q10;. 'A' control room emergency fresh air supply system following return-to-service onNovember 3,2010; ando Unit 2 high pressure coolant injection (HPCI) system when the 'B' loop of emergencyservice water was out-of-service (OOS) on December 2,201Q.b. FindinqsNo findings were identified.1R05 Fire ProtectionFire Protection - Tours (71111.05Q - 4 samples)a. Inspection ScopeThe inspectors conducted a tour of the four areas listed below to assess the materialcondition and operational status of fire protection features. The inspectors verified thatcombustible materials and ignition sources were controlled in accordance with Exelon'sprocedures. Fire detection and suppression equipment was verified to be available foruse, and passive fire barriers were verified to be maintained in good material condition.The inspectors also verified that station personnel implemented compensatory measuresfor OOS, degraded, or inoperable fire protection equipment in accordance with thestation's fire plan. The documents reviewed are listed in the Attachment. Theinspectors toured the following areas:. Spray Pond Pumphouse, Western Half (Fire Area 122);. Spray Pond Pumphouse, Eastern Half (Fire Area 123)',Enclosure

6. Control Room and Peripheral Rooms (Fire Area 24), and. Remote Shutdown Room (Fire Area 26).b. FindinqsNo findings were identified.I1R06 Flood Protecti6n Measures (71111.06 - 1 internal flooding sample)a. Inspection ScoPeThe inspectors reviewed the UFSAR and related flood analysis documents to identifyareas that can be affected by internal flooding, to identify features designed to alertoperators of a flooding event, and to identify features designed for coping with internalflooding. The inspectors performed a walkdown of the Main Control Room ChillerRoomJlneactor Enclosure, Elevation 200') and adjacent areas. The inspectorsobserved flood protection features to assess their ability to minimize the impact of aflooding event. The inspectors performed a review of operator actions contained inoff-normal procedures for flooding to verify that the actions can reasonably be used toachieve the desired outcome. The documents reviewed are listed in the Attachment.b. FindinqsNo findings were identified.t1R1 1.1a.b.Resident Inspector Quarterlv Review (71111.11Q - 1 sample)Inspection ScopeOn November g, 2010, the inspectors observed two annual licensed operator simulatorexaminations (LSE5-2004). The simulator scenarios tested the operators' ability torespond to operating equipment failures, reactivity transients, loss of drywell cooling, andloss of coolant leaks in the drywell. The inspectors observed licensed operatorperformance including operator critical tasks, which are required to ensure the safeoperation of the react,or and protection of the nuclear fuel and primary containmentbarriers. The inspectors also assessed crew dynamics and supervisory oversight toverify the ability of operators to properly identify and implement appropriate TS actions,reguiatory reports, emergency event declarations, and notifications. The inspectorsoOlerveO training instructor critiques and assessed whether appropriate feedback wasprovided to the licensed operators. The documents reviewed are listed in theAttachment.FindinqsNo findings were identified.Biennial Requalification Proqram Review (71111.118- 1 sample)Insoection Scope.zEnclosure

7The following inspection activities were performed using NUREG 1021, Revision 9,Supplement 1, "Operator Licensing Examination Standards for Power Reactors,"lnspection Procedure Attachment71111 1 1, "Licensed Operator RequalificationProgram," Appendix A, "Checklist for Evaluating Facility Testing Material," andAppendix B, "Suggested Interview Topics."A review was conducted of recent operating nistory documentation found in inspectionreports, licensee event reports, the licensee's corrective action program, and the mostrecent, NRC plant issues matrix. The inspectors also reviewed specific events from thelicensee's corrective action program which indicated possible training deficiencies toverify that they had been appropriately addressed. The senior resident inspector wasalso consulted for insights regarding licensed operators performance. These reviews didnot detect any operational events that were indicative of possible training deficiencies.For the 2010 examination cycle, the biennial written examinations (i.e., administered in2OOg) and annual operating tests administered for weeks three, four, and five werereviewed for content, quality, and excessive overlap to ensure that these exams met thecriteria established in the Examination Standards and 10 CFR 55.59'On December 10, 2010, the results of the annual operating tests for 2010 were reviewedto determine if pass/fail rates were consistent with the guidance of NUREG-1021,Revision 9, Supplement 1, "Operator Licensing Examination Standards for PowerReactors," and NRC Manual Chapter 0609, Appendix l, "Operator RequalificationHuman Performance Significance Determination Pilocess," were also performed. Thereview verified the following:. Crew pass rates were greater than 80 percent (Pass rate was 100 percent);. Individual pass rates on the written examination were greater than 80 percent (N/A -Biennial written examination was not administered this yeal;. Individual pass rates on the job performance measures of the operating exam weregreater than 80 percent (Pass rate was 98 percent); ando More than 75 percent of the individuals passed all portions of the operatingexamination (Pass rate was 98 percent).Observations were made of the dynamic simulator examinations and job performancemeasures (JPMs) administered during the week of November 15, 2010, for Operationsand Staff Crew C. These observations included facility evaluations of crew andindividual performance during the dynamic simulator examinations and individualperformance of JPMs.The remediation plans for 22 out-of{he-box scenarios were reviewed to assess theeffectiveness of the remedial training. Two reactivations were reviewed to ensure that10 CFR 55.53 license conditions and applicable program requirements were met.Instructors and training/operation's management were interviewed for feedback on theirtraining program.A sample of ten operator medical examinations were also reviewed for compliance withlicense conditions, including NRC regulations.Enclosure 8Simulator performance and fidelity were reviewed for conformance to the reference plantcontrol room. Selected simulator deficiency reports were reviewed to assess licenseeprioritization and timeliness of resolution. Simulator testing records were reviewed toverify that scheduled tests were performed.b. FindinqsNo findings were identified.

1R12 Maintenance Effectiveness (71111.12Q - 1 sample)a. Inspection ScopeThe inspectors evaluated Exelon's work practices and follow-up corrective actions forone issue within the scope of the maintenance rule. The inspectors reviewed theperformance history of these structures, systems, and components (SSCs) andassessed the effectiveness of Exelon's corrective actions, including any extent-of-condition determinations to address potential common cause or generic implications.The inspectors assessed Exelon's problem identification and resolution actions for theseissues to evaluate whether Exelon had appropriately monitored, evaluated, anddispositioned the issues in accordance with Exelon procedures and the requirements of1O CFR Part 50.65, "Requirements for Monitoring the Effectiveness of Maintenance." Inaddition, the inspectors reviewed the maintenance rule classifications, performancecriteria, and goals for these SSCs and evaluated whether they appeared reasonable andappropriate. The documents reviewed are listed in the Attachment. The inspectors treviewed the following issue: Io lssue Report (lR) 1 137553 ESW pinhole leak repair - ESW loop 'B' return pipingfrom Unit 2 RHR pump compartment unit cooler.b. FindinqsNo findings were identified.1R13 Maintenance RiskAssessments and EmeroentWork Control (71111.13 - 6 samples)a. Inspection ScoPeThe inspectors evaluated the effectiveness of Exelon's maintenance risk assessmentsrequired by 10 CFR Part 50.65(a)(4). This inspection included discussion with controlroom operitors and risk analysis personnel regarding the use of Exelon's on-line riskmonitoring software. The inspectors reviewed equipment tracking documentation, dailywork schedules, and per.formed plant tours to gain assurance that the actual plantconfiguration matched the assessed configuration. Additionally, the inspectors verifiedthat Exelon's risk management actions, for both planned and emergent work, wereconsistent with those described in Exelon procedure, ER-M-600-1042, "On-Line RiskManagement." The documents reviewed are listed in the Attachment. The inspectorsreviewed the following samPles:. Units 1 and 2 on-line risk profile during the EDG D12load reject test with the 20offsite power source unavailable on October 6' 2010;Enclosure

I. Unit 2 on-line risk profile while in single recirculation loop operations following 'A'motor generator (MG) trip October 22 - October 24,2010;o Unit 1 on-line risk and compensatory measures during fire header partial outageNovember 5 - November 8, 2010;. Units 1 and 2 on-line risk profile when the 'B' control enclosure chiller wasdiscovered to be unavailable due to insufficient ESW flow on November 13, 201Q;. Units 1 and 2 on-line risk profile when the 222 Plant Services bus was de-energizedNovember 24 - 25 due to a supply feeder cable fault; and. Unit 2 risk profile while in single recirculation loop operations following 'A' MG tripDecember 3.2010 - December 5, 2010.b. FindinosNo findings were identified.

1R15 Operabilitv Evaluations (71111.15 - 7 samples)a. lnsoection ScopeThe inspectors assessed the technical adequacy of a sample of seven operabilityevaluations to ensure that Exelon properly justified TS operability and verified that thesubject component or system remained available such that no unrecognized increase inrisk occurred. The inspectors reviewed the UFSAR to verify that the system orcomponent remained available to perform its intended safety function. In addition, theinspectors reviewed compensatory measures implemented to ensure that the measuresworked and were adequately controlled. The inspectors also reviewed a sample of lRsto verify that Exelon identified and corrected deficiencies associated with operabilityevaluations. The documents reviewed are listed in the Attachment. The inspectorsreviewed the following evaluations:. lR 1120701, Radiation monitor failed check source functional test;. lR 1132289, Degraded wire connection on Unit 1 drywellfloor drain sump levelmonitor;. lR 1137553, ESW pinhole leak on 'B' loop return piping from Unit 2 RHR pumpcompartment unit cooler (OPE-10-008, Revision 08);. lR 1143600, ESW'B' loop flow balance issues;. lR 1143434, Unit 1 scram discharge volume (SDV) valve exceeded maximumallowed stroke time;. lR 1151354, Unit 1 HPCI turbine mechanical overspeed will not reset; and. lR 1153065, EDG D14 fuel oil supply pressure fluxuations during operations.b. FindinqsNo findings were identified.1R19 Post-Maintenance Testinq (71111.19 - I samples)a. Inspection ScopeEnclosure

10The inspectors reviewed eight post-maintenance tests to verify that procedures and testactivities ensured system operability and functional capability. The inspectors reviewedExelon's test procedures to verify that the procedures adequately tested the safetyfunctions that may have been affected by the maintenance activity, and that theacceptance criteria in the procedures were consistent with information in the licensingand design basis documents. The inspectors also witnessed the test or reviewed testdata to verify that the results adequately demonstrated restoration of [he affected safetyfunctions. The documents reviewed are listed in the Attachment. The inspectorsreviewed the following samPles:. R1 152057, Repair Unit 1 Division lV steam leak detection;. C0235528, Unit 2 'A' MG set voltage regulator dynamic testing after cardreplacements;. C0235261, Troubleshoot and rework Technical Support Center emergencyventilation system outside air damper;. C0231042, ESW'B'loop flow balance;. C0236019, Unit 2'A' recirculation pump MG repair;. 41 786977 , Loss of power to Unit 2 outboard main steam isolation valve logic;. C0235392, Replace Unit 2 Division lll emergency core cooling system inverter; and. C0236065, Adjust pressure regulator to Unit 1 SDV piping vent primary containmentisolation valve (XV-O47 -1F01 1).b. FindinqsNo findings wpre identified. t1R22 SurveillanceTestinq (71111.22-7 samples; 5routinesurveillances, 1in-service testing(lST) and 1 reactor coolant system leakage)a. Inspection ScopeThe inspectors either witnessed the performance of, or reviewed test data, for sevenSTs associated with risk-significant SSCs. The reviews verified that Exelon personnelfollowed TS requirements and that acceptance criteria were appropriate. The inspectorsalso verified that the station established proper test conditions, as specified in theprocedures, that no equipment preconditioning activities occurred, and that acceptancecriteria were met. The documents reviewed are listed in the Attachment. The inspectorsreviewed the following samPles:. 5T-6-052-760, Safeguard Piping Fill Quarterly Valve Test;. 5T-6-060-460-1, Primary Containment lsolation Capability Check;. 5T-6-092-323-1, D13 DG Loss of Coolant Accident Load Reject Testing and FastStart Operability Test Run;. 5T-6-082-365-0, Inoperable Unit 1 Safeguard Power Supply Actions for Both Units;. 3T-6-049-230-1, Reactor Core lsolation Cooling Pump, Valve & Flow IST;. 5T-6-047-200-1, SDV Exercise Test; and. 5T-6-107-596-2, Drywell Floor Drain Sump/ Equipment Drain Tank Surveillance Log/OPCON 1, 2, 3 (reactor coolant system leakage).Enclosure 11b. FindinssNo findings were identified.Cornerstone: Emergency Preparedness (EP)1EP2 Alert and Notification Svstem (ANS) Evaluation.(71114.02 - 1 sample)a.An onsite review was conducted to assess the maintenance and testing of the currentLimerick ANS. The inspectors reviewed ANS procedures and the updated Limerick ANSdesign report to ensure Exelon's compliance with design report commitments for systemmaintenance and testing. A sample of lRs pertaining to the ANS was reviewed forcauses, trends, and corrective actions. The inspectors observed the conduct of theLimerick monthly siren test. During the inspection, the inspectors also interviewed theMid-Atlantic EP Manager in regards to the new ANS which is planned for approval inApril 201 1. The inspection was conducted in accordance with NRC InspectionProcedure 71114, Attachment 2. Planning Standard, 10 CFR 50.47(b)(5) and therelated requirements of 10 CFR 50, Appendix E, were used as reference criteria.b. FindinssNo findings were identified.1EP3 Emeroencv Response Oroanization (ERO\ Staffilq and Auomentation Svstem(71114.03 - 1 sample)a. lnspection ScopeThe inspectors conducted a review of Limerick's ERO augmentation staffingrequirements and the process for notifying and augmenting the ERO was conducted.This was performed to ensure the readiness of key licensee staff to respond to anemergency event and to ensure Exelon's ability to activate their emergency facilities in atimely manner. The inspectors reviewed the Limerick and corporate ERO rosters,station and corporate augmentation reports since March 2009, and CRs related to theERO staffing augmentation system. The inspectors also reviewed a sampling of EROresponder's training records to ensure training and qualifications were up to date. Theinspection was conducted in accordance with NRC Inspection Procedure 71114,Attachment 3. Planning Standard, 10 CFR 50.47(b)(2) and related requirements of10 CFR 50, Appendix E, were used as reference criteria.b. FindinqsNo findings were identified.1EP4 Emerqencv Action Level (EAL) and Emerqencv Plan Chanoes (71114.04 - 1 sample)a. Inspection ScopeEnclosure 12since the last NRC inspection of this program area, Exelon implemented variouschanges to their Emergency Plan and implementing procedures- Exelon haddetermined that, in acdordance with 1O CFR 50.54(q), any change made to the Plan'and its lower-tier implementing procedures' had not resulted in any decrease ineffectiveness of the Plan, and that the revised Plan continued to meet the standards in50.47(b) and the requirements of 10 cFR 50, Appendix E. The inspectors reviewed allEmergency Action Level changeg, including changes to the security EALs as endorsedby Ndl gg-02, Revision S. A simple of emergency plan changes including the chingesto lower-tier "r"if"n.y plan implementing procedures, were evaluated for any potentialdecreases in effeJtiveness of the Emergency Plan. However, this review by theinspectors was not documented in an tttRc satety Evaluation Report and does notconstitute forr"irunC approval of the changes. Therefore, these changes remainsubject to future NRC inspection in their entirety. The inspection was conducted inaccordance witn runc lnspection Procedure 71-114, Attachment 4' The requirements in1O CFR 50.5a(q)were used as reference criteria'b. FindinqsNo findings were identified.1EPs Correction of Emerqencv Preparedness Weaknesses (71114'05 - 1 sample)lnsoection ScopeThe inspectors reviewed a samplipg of self-assessment procedures and reports toassess Exelon's ability to evaluate their EP performance "nd-ptogr"ms. The inspebtorsreviewed a sampling or cnr from March 2009 through December 2010, initiated byExelon at Limerick fiom drills and audits. Additionally, the inspectors reviewed.l0 CFRso.s+1t) audits from 2009 and 2010; and self-assessment reports. This inspection wasconducted in accordance with NRC lnspection Procedure 71114, Attachment 5'Planning Standard, tO Cfn 50.47(b)(14), and the related requirements of 10 CFR 50'Appendix E, were used as reference criteria'FindinqsNo findings were identified'RADIATION SAFETYcornerstones: occupational and Public Radiation safety2RSO1 Radiolooical Hazard Assessment and Exposure controls (71124'01- 1 sample)a. Inspection ScoPeDuring the period December 13 - 17,2010, the inspectors conducted the followingactiviies to verify that the licensee was evaluating, monitoring, and controllingradiological hazards for work performed in locked high radiation areas, including theIndependent Spent Fuel Storage Installation (lSFSl), and other radiological controlledareas. and workers were adheiing to these controls when working in these areas'a.h2.Enclosure 13lmplementation of these controls was reviewed against the criteria contained in 10 CFR20, TS's, and Exelon's procedures. The documents reviewed listed in the Attachment.Radioloqical Hazards AssessmentThe inspectors reviewed recent revisions to radiation protection procedures regardingvarious radiation protection processes, including radiological postings, andcontamination monitoring. The inspectors determined that the new revisions did notreduce the scope or effectiveness of previously established radiological controls.Radioloqical Hazards Control and Work CoveraqeThe inspectors toured accessible radiological controlled areas in Units 1 &2, includingthe lSFSl, turbine buildings, and reactor buildings to confirm the accuracy of survey dataand the adequacy of postings and radiation work permits (RWP). The inspectorsreviewed survey maps for areas toured to determine the timeliness of survey data andthe adequacy of RWP controls.Contamination and Radioactive Material ControlThe inspectors observed workers surveying and releasing potentially contaminatedmaterials for unrestricted use. The inspectors verified that the counting instrumentationwas located in a low background area and that the instruments sensitivity wasappropriate for the type of contamination being measured.Problem ldentification and ResolutionRelevant lRs, associated with radiological controls, and electronic dosimeter dose/doserate alarm reports initiated between March through November 2010, were reviewed bythe inspectors. The inspectors discussed the lRs with licensee staff to determine if thefollow up activities were being conducted in an effective and timely manner,commensurate with their safety significance.b. FindinosNo findings were identified.4.

OTHER ACTIVITIES

4OA1 Performance lndicator (Pl) Verification

.1 Barrier lnteoritv and Mitioatinq Svstems Cornerstone Pls (71151- 6 samples)a. Inspection ScopeThe inspectors sampled Exelon's submittal of the Barrier lntegrity cornerstone andMitigating Systems cornerstone Pls listed below to verify the accuracy of the datarecorded from October 2009 though September 2010. The inspectors utilizedperformance indicator definitions and guidance contained in Nuclear Energy Institute(NEl) 99-02, "Regulatory Assessment Performance Indicator Guidelines," Revision 6,to verify the basis in reporting for each data element. The inspectors reviewed variousEnclosure

. Unitso Units14documents, including portions of the main control room logs, issue reports, power historycurves, work orders, and system derivation reports. The inspectors also discussed themethod for compiling and reporting performance indicators with cognizant engineeringpersonnel and compared graphical representations from the most recent Pl report to theraw data to verify that the report correctly reflected the data. The documents reviewedare listed in the Attachment.Cornerst6ne: Barrier lnteoritv1 and 2 Reactor Coolant System Leak Rate (8102); and1 and 2 Reactor Coolant System Activity (8101).Cornerstone: Mitiqating Svstemso Units 1 and 2 Mitigating System Performance Index, Cooling Water Systems (MS10).FindinqsNo findings of significance were identified.occupational Exposure control Effectiveness Pl (71151- 1 sample)lnspection ScopeThe inspeqtors reviewed implementation of the licensee's Occupational ExposureControl Effbctiveness Pl Program (ORO1). Specifically, the inspectors reviewedelectronic dosimetry alarm repofts, lRs, and associated documents, for occurrencesinvolving locked high radiation areas, very high radiation areas, and unplannedexposures against the criteria specified in NEI 99-02, "Regulatory Assessmentperformance Indicator Guideline, Revision 6," to verify that all occurrences that met theNEI criteria were identified and reported as performance indicators.FindinqsNo findings were identified.RETS/ODCM Radioloqical Effluent occurrences Pl (71151- 1 sample)Inspection ScopeThe inspectors reviewed relevant effluent release issue reports for the period October2009 thiough Novemb er, 2010, for issues related to the public radiation safetyperformanCe indicator, which measures radiological effluent release occurrences thatexceed 1.5 mrem/qtr whole body or 5.0 mrem/qtr organ dose for liquid effluents;Smrads/qtr gamma air dose, 10 mrad/qtr beta air dose, and 7.5 mrads/qtr for organ dosefor gaseoujeffluents. The inspectors reviewed the following documents to ensure thelicensee met all requirements of the performance indicator (PRQ1):. Monthly projected dose assessment results due to radioactive liquid and gaseouseffluent releases;b2.Jb.a.Enclosure

.4 b.a.b.a.15. Quarterly projected dose assessment results due to radioactive liquid and gaseouseffluent releases: and. Dose assessment procedures.FindinosNo findings were identified. ]Emerqencv Preparedness Cornerstone Pls (71151- 3 samples)Inspection ScopeThe inspectors reviewed data for Limerick's EP Pls, which are: (1) Drill and ExercisePerformance (DEP) (EP01); (2) ERO Drill Participation (EP02); and, (3) ANS Reliability(EP03). The inspectors reviewed the Pl data and its supporting documentation from thefourth quarter of 2009 through the third quarter of 2010 to verify the accuracy of thereported data. The review of these Pls was conducted in accordance with NRCInspection Procedure 71151, using the acceptance criteria documented in NEI 99-02,"Regulatory Assessment Performance lndicator Guidelines," Revision 6.FindinqsNo findings were identified.ldentification and Resolution of Problems tReview of ltems Entered into the Corrective Action Proqram (CAP)lnspection ScopeAs required by Inspection ProcedureTll52, "ldentification and Resolution of Problems,"and in order to help identify repetitive equipment failures or specific human performanceissues for follow-up, the inspectors screened all items entered into Limerick's CAP. Theinspectors accomplished this by reviewing each new condition report, attendingmanagement review committee meetings, and accessing Exelon's computerizeddatabase.FindinqsNo findings were identified.Semi-Annual Review to ldentifv Trends (71152 - 1 trend sample)Inspection ScopeThe inspectors performed a semi-annual review of site issues, to identify trends thatmight indicate the existence of more safety significant safety issues, as required byf nspection Procedure 71152, "ldentification and Resolution of Problems." Theinspectors included in this review, repetitive or closely-related issues that may havebeen documented by Exelon outside of the corrective action program, such as PlantHealth Committee reports including the Top Ten Equipment lssues List, the Plant Healthb.4c.42.1a..2Enclosure

16Committee lssues List, the Open Action ltems List, and the Performance lmprovementIntegration Matrix. The inspectors also reviewed Exelon's corrective action database forthe third and fourth quarters of 2010, to assess lRs written in various subject areas (e.9.,equipment problems, human performance issues, etc.), as well as individual issuesidentified during the NRC's daily lR review (Section 4042.1).Findinqs and Observations ]No findings were identified. The inspectors assessed that Exelon was identifying issuesat a low threshold and entering the issues into the CAP for resolution.Notwithstanding, the inspectors noted a recent negative trend concerning the health ofnon-safety-related underground 13kV power supply cables. Within a 7-month period,Limerick experienced three non-safety related cable failures. ln two of the three cases,the cables had previously been identified by Exelon as requiring repair or replacementdue to degraded insulation that was discovered during testing. Specifically:. On April 2, 2010, the 122 Plant Services Transformer supply cable faulted shortlyafter being placed in service following maintenance (lR 1051496). Part of themaintenance had been to repair a known, degraded section of cable insulation.However, the fault occurred in a section of cable that had not been repaired, despitebeing previously identified as degraded. At the time, Unit 1 was in a refueling outageand therefore the effect on the plant was minimal.. On June 23, 2010, operators insefted a manual scram on Unit 1 as a result of theloss of both recirculation pumps (lR 1083732). The initiator for the transient wastthefault of an underground portion of the 13kV power supply cable to the 144DTechnical Support Center Transformer. This, coupled with other non-relatedequipment failures, resulted in the loss of the operating stator cooling water pumpand the tripping of the recirculation motor-generator sets. For more detail see FIN05000352/2010004-02, "Failure to ldentify lncorrectly Adjusted Control Power RelayResulting in Unit 1 Manual Scram." This cable had not been tested, but had beenidentified as requiring testing in the future.. On November 24,201Q, the 222 Plant Services Transformer supply cable faulted,causing the loss of two of the three Unit 2 service water pumps (lR 1144472). Thiscable was known to have degraded insulation resistance but had not been repaired.Due to the ambient temperatures at the time of the loss (i.e. service watertemperatures were cool), Unit 2 was able to maintain full power operations using theremaining service water pumP.The inspectors reviewed the extent of power supply cable insulation degradation atLimerick. The inspectors noted that there were two other 13kV power supply cables thattesting had identified as degraded and requiring action in the near term. These cableswere issociated with the Unit 1 'A' circulating water pump and the Unit 1 'C'circulatingwater pump. Because of the recent failures, Exelon identified the need to expeditereplacement of known degraded cables and testing of the remaining cables. As a result,a high impact team was established to coordinate cable replacements and othercorrective actions. At the close of the inspection period, cable replacements wereplanned to commence in January 2011. ln addition, Exelon planned to coordinate withan industry research group to help determine the causes of cable failures and failuremechanisms. The inspectors concluded that Exelon had identified this trend andExelon's actions taken or planned to address the trend appeared to be comprehensive.Enclosure 17The inspectors determined this trend was not applicable to safety-related cablesbecause test results for the safety-related 4kV underground cables indicated they hadacceptable insulation resistance. This was primarily due to more favorable operatingconditions (e.9., lower operating voltage and intermittent operation of the load)..3 Annual Sample: Underqround Cable VaultWater Intrusion (71152 - 1 Annual sample)a. lnspection ScopeThe inspectors reviewed Limerick's actions under lR 1056715, which was initiated totrack Exelon fleet-wide actions to improve long-term health of medium and low voltagepower cables routed in underground structures, The inspectors reviewed the correctiveactions taken or planned to assure the timeliness was commensurate with the potentialsafety significance. The inspectors also interviewed plant personnel regarding theidentified issues and implemented corrective actions. Specific documents reviewed arelisted in the Attachment.b. Findinos and ObservationsNo findings were identified.lR 1003826 was initiated by Limerick to track project actions necessary to establish andmaintain the underground manholes and conduits of both safety-related and non-safety-related electrical manholes in a dry condition. As discussed in Section 4042.2 above,the inspectors noted a recent negative trend concerning the health of non-safety-relatedunderground 13kV power supply cables. For all three non-safety-related power supplycable failures experienced at Limerick in 2010, Exelon suspected that the wetunderground environment contributed to the failure. As a result, Exelon identified theneed to expedite replacement of known degraded cables and testing of cables that hadnot been previously tested.Exelon's long{erm action plan to improve underground cable reliability was still underdevelopment at lhe time of this inspection. The long-term plan will be customized basedon the results of manhole inspections, water infiltration rates, and the risk ranking ofcables. The inspectors concluded, from review of the draft plan and discussions withengineers, that the long-term plan will address appropriate factors including cabletesting, cable replacements, underground drainage system repairs and/ or modifications,etc. For safety-related manholes and conduits, Exelon planned to install a pumpingsystem to maintain them dry. At the time of this inspection, the modification wasscheduled for installation by June 1 ,2011. Based on a review of the key actions in lR1056715 and lR 1003826 that have been taken to date, the inspectors concluded thatExelon's planned actions appeared to be timely and would improve long-term health ofthe cables.4OA3 Event Follow-up (71153 - 3 samples)a. Inspection ScopeFor the three plant events listed below, the inspectors reviewed and/or observed plantparameters, reviewed personnel performance, and evaluated performance of mitigatingsystems. The inspectors communicated the plant events to appropriate regionalEnclosure 18personnel and compared the event details with criteria contained in Inspection ManualChapter 0309, "Reactive Inspection Decision Basis for Reactors," for consideration ofpotential reactive inspection activities. As applicable, the inspectors verified that Exelonmade appropriate emergency action classification assessments and properly reportedthe event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewedExelon's follow-up actions related to the events to assure that appropriate correctiveactions were implemented commensurate with their safety significancq,. Unit 2 'A' recirculation pump trip on October 23,2010',. Loss of Plant Services Bus 222 on November 24,2010; ando Unit 2 'A' recirculation pump trip on December 3,2010.b. FindinqsNo findings were identified.4OA5 Other Activities.1 Independent Spent Fuel Storaqe Installation (lSFSl) Monitorinq Controls(71124.01160855 - 1 sample)a. Inspection ScopeThe inspectors reviewed routine operations and monitoring of the ISFSI (Docket No.72-1004)., The inspectors walked down the ISFSI and with the assistan* of a SeniorRadiation'Protection Technician, performed independent dose rate measurements of thestorage modules, and confirmed module temperatures were within the required limits.The inspectors also reviewed plant equipment operator logs for ISFSI surveillances,relevant issue reports, and environmental ISFSI dosimetry records. Radiological controlactivities for the ISFSI were evaluated against 10 CFR 20, ISFSI TS's, and thelicensee's procedures.The inspectors also reviewed the effectiveness of radiological controls for the mostrecent loading and transfer of five (5) dry storage casks, that was conducted during theJune through August 2010 period. Actual worker dose was compared to forecastedestimated exposure and determined be within a reasonable range (< 50% difference)and cumulative exposure was less than 5 person-rem.b. FindinqsNo findings were identified..2 (Closed) Unresolved ltem (URl) 05000352/353/2009006-02, Technical SpecificationRequirements for Motor-Operated Valve (MOV) Thermal Overload Bvpass Featurea. Inspection ScopeDuring the 2009 component design bases inspection (CDBI), a URI was opened todetermine if Exelon was meeting the intent of TS 3.8.4.2.b regarding the bypassing ofthermal overloads on certain manually operated MOVs during an accident condition.Exelon entered the issue into the CAP. The inspectors reviewed the lR and correctiveEnclosure 1qactions initiated to address the URl, which included a technical evaluation of the issue.The inspectors reviewed procedures OP-LG-108-101-1004, "Valves," Revision 4, andOP-LG*103-102-1002, "Strategies for Successful Transient Mitigation," Revision 5, todetermine whether the operators were provided adequate guidance on manuallyoperated MOV operation and bypassing of the thermal overloads. The inspectorsinterviewed training staff to ensure thermal overload bypass operation was part of thelong range training program, and that the appropriate training had been in place andconducted prior to the CDBI. The inspectors also interviewed operators and observedsimulated operator actions in the simulator to assess operator knowledge on propervalve stroke indication, thermal overload actuation indication, and thermal overloadbypass operation of the manually operated MOVs to ensure complete valve operation.b. FindinssNo performance deficiencies or findings were identified and the URI is closed.4OAO Meetinqs. lncludinq ExitOn January 7, the inspectors presented the inspection results to Mr. W. Maguire andother members his staff. The inspectors confirmed that proprietary information was notincluded in the inspection report.ATTACHMENT: SUPPLEMENTAL I NFORMATIONEnclosure A-1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

W. Maguire, Site Vice President
E. Callan, Plant Manager !
S. Johnson, Assistant Plant Manager
R. Dickinson, Director of Training
P. Gardner, Director of Operations
R. Kreider, Director of Maintenance
C. Gerdes, Security Manager
D. Merchant, Radiation Protection Manager
D. Palena, Manager Nuclear Oversight
J. Hunter, Manager, Regulatory Assurance
S. Bobyock, Manager, Plant Engineering Programs
N. Dennin, Shift Operations Superintendent
R. McLaughlin, Operations Support Manager
W. Lewis, Senior Engineering Manager
M. Gillin, Balance of Plant Engineering Manager
K. Slough, Mechanical/Structural Engineering Design Manager
M. DiRado, Engineering Rapid Response Manager
J. Risteter, Radiation Protection Manager
R. Harding, Regulatory Assurance Engineer
C. Goff, Operations Training Manager t
T. Carr, Maintenance SupervisorR.V.R.S.J.F.Rhode - Licensed Operator Requalification Training SupervisorHydro, Simulator SupervisorForst, Annual Operating Exam DeveloperCohen, Annual Operating Exam DeveloperMihm, Biannual Written DeveloPerBuzynski, Systems EngineerBarth, Systems EngineerBrittain, Senior Staff EngineerDeihm, Work Week ManagerLeahy, Procurement Engineer SupervisorMinicozzi, System EngineerTracey, Systems EngineerWeiss, Systems EngineerWelch, Maintenance Planner QV InspectorZaharchuk, Systems EngineerCommiskey, Radiological EngineerWahl, Environmental Scientist

NRC Personnel

E. DiPaolo, Senior Resident Inspector
N. Sieller, Resident Inspector
J. Hawkins, Acting Resident Inspector
A. Rosebrook, Senior Project Engineer
C. Crisden, Emergency Preparedness SpecialistAttachment

AAA-Z

LIST OF ITEMS

OPENED OR CLOSEDOpenedNoneClosed05000352/353/2009006-02 URI Technical Specification Requirements forMotor Operated Valve Thermal OverloadBypass Feature (Section 4C45.2)Opened and ClosecNoneDiscussedNone

LIST OF DOCUMENTS REVIEWED

Common ReferencesLimerick Unit 1 and Unit 2 UFSARLimerick Unit 1 and Unit 2 TSsLimerick Unit 1 and Unit 2 Technical Requirements ManualLimerick Unit 1 and Unit 2 Operator Logs

Section 1R01: Adverse Weather Protectionlssue Reports1091311ProceduresWC-AA-107, Seasonal Readiness, Revision 8ARC-MCR-02,

E-5, Spray Pond Pump Station Temperature Trouble, Revision 2GP-7, Cold Weather Preparation and Operation, Revision 43Work OrdersR1
156051 , Plant Heating Steam and Auxiliary Steam SystemMiscellaneousLetlrr of Cedification of 2010 Limerick Winter Readiness, dated November 15, 2010Open Winter Readiness Work items List

Section 1R04: Equipment AliqnmentProceduresS92.9.N, Routine Inspection of the Diesel Generators, Revision 59MiscellaneousSystem Notebook, Diesel Generator and Auxiliary SystemsDiesel Generator System Health ReportAttachment

A-J2S92.1 .N (COL - 3), Equipment Alignment for 2C Diesel Generator, Revision 23UFSAR Section 8.3.1 .1.3, Standby Power SystemLicensee Event Reporl 1-96-006, CREFAS Inoperable Requiring Entry into TS 3.0.3,May 30, 19962555.1.A (COL), Equipment Alignment for Automatic Operation of HPCI System, Revision 17

==Section 1R05: Fire Protectionlssue Reports'1129649ProceduresF*{01, Pre-Fire Plan Strategy for Spray Pond Structure Western Half (Fire Area 122),Revision 12F-S-002, Pre-Fire Plan Strategy for Spray Pond Structure Eastern Half (Fire Area 123),Revision 10ARC-MCR-006Q31 Turbine

2391269 Cond. ArealTB, Revision 4OP-MA-201-007, Ftre Protection System lmpairment Control, Revision 6S22.8.H, Inoperable Fire Protection Equipment Actions, Revision 24sT-7-084-925-0, Fire Door Closing Mechanism Inspection, Revision 5F-A-024, Control Room and Peripheral RoomsF-A-026, Remote Shutdown RoomMiscellaneousA1747020A1 780973ISection 1R06: Flood Protectionlssue Reports1 1 54883ProceduresSE-4-1, Reactor Enclosure Flooding, Revision==
IMiscellaneousA 0-817141, Evaluate Door Preventive Maintenancelssue Reports1140582ProceduresLSES -2004, Simulation Scenario, Revision 7TQ-AA-150: Operator Training Programs Revision 4T-225, Startup and shutdown-of Suppression Pool and Drywell Spray Operation, Revision 020MiscellaneousTQ-AA-150, Operator Training Programs, Revision 4HR-M-07-101 NRC Licensed Operator Medical ExaminationLLORI OOl B, Residual Heat Removal system Review, sDc and ADHRLLOR1001l, 1 Refueling 13 Plant ModificationsOP-M-105-102 NRC Active License MaintenanceAttachment
A-4EPRI
NP-5562 Analysis of Anticipated Transients without Scram in Severe BWR AccidentsSimulator Test Review Board Minutes 2009-4 712912009Job Performance Measures (JPMs)058, 086, 098, 099, 103, 1 14, 129, 131,134,Scenarios150, 210, 232, 261,515, 523, 758LSES-2004,
LSES-2035,
LSE5-3003,
LSE5-3004,
LSE5-5002,
LSES-5003, LSES-s005,LSES-7008Written ExaminationsNRC-2009-03-RO,
NRC-2009-03-5RO,
NRC-2009-04-RO,
NRC-2009-04-SRO,
NRC-2009-05-sRo,
NRC-2009-05-5ROSimulator Work RequestsSWR 2008093/1 1090, Excessive Lag in Bypass Valve Closure as Pressure Drops after aTurbine TripSWR 2008094111107, Discrepancy between Plant and Simulator Generator OutputSWR 2008144111338, Following core update, SLC shutdown takes longer than GE analysistimeSWR 2008133111272,lncorrect FW Temperature Used in Modeling Feed-Water Rupture inContainmentSWR 2008121111192, Open Lamp and OHA for TBV Should Operate at Same Set-pointSWR 200S102111130, During ATWS, Power Remains Too High as Level is LoweredTransient Tests t7.0'1, Reactor Scram, May 30, 2009 (Baseline: actual plant trips, SRB evaluation)7.02,f rip of All Feed-water Pumps, May 30, 20097.03, Closure of All MSlVs, May 30, 20097.04, Trip of Both Recirculation Pumps, May 30, 2009Annual/Normal Evolution Tests6.12, Steady State Performance/Drift Test at 100% Power, July 26, 20091.12, Simulator to Reference Plant Critical Parameter Comparison, March 25,20086.09, Normal Operations Performance Test: Reactor Trip Followed by Recovery to RatedPower, November 22, 2009Malfunction Tests3-MPC257, Suppression Pool Water Leak to Reactor Enclosure, July 11,20103-MED250B, Failure of 24 YDC Power Supply E/S-X-10082, March 18, 20073-MED0158, lnadvertent Trip of Safeguard Feeder Breaker 201-D11 , January 13, 20Q73-MRH562A, RHR Pump B Suction Strainer Clogs - Small, August 9, 20093-MVl529B, RPV Pressure Transmitter Pf 42-1034 Fails Low, June 28,20083-MVf232C, RPV Level Transmitter
LT-42-1N0808 Fails Upscale, August 23,2008Non ANSI Testinq10-002-X-A, Integrated Response to lsolation of Condensate to Feed-water String A,November 16, 200910-002-Vll-D, Integrated Response to Trip of Four Circulating Water Pumps,November 16, 2009Physical Fidelity Checks Panel 00C424, October 2, 2010Physical Fidelity Checks Panel 10C201-Remote Shutdown Panel, October 2, 2010Attachment
A-5

Section 1R12: Maintenance Effectivenesslssue Reports'1 1375531565145ProceduresAS]ME Sect. lll code 3 case

N-513-2 Evaluation criteria for Temporary Acceptance of flaws inModerate Energy Class 2 or 3 Piping Section Xl, Division
IER-AA-310, lmplementation of the Maintenance Rule, Revision 8ER-AA-310-1004, Maintenance Rule - Performance Monitoring, Revision 8MA-AA-716-210, PCM Process, Revision 10MiscellaneousAction - A1782939Engineering Change Request 03-00705Operability Evaluation, OPE-'1 0-008, Revision 0BWork Order C0235674Work Order C0235822lssue Report1010943 10514961144472 1148152Procedures1055147
1100185
1129709 1131393WC-LG-101-1001, Guideline for theRevision 14WC-LG-104-1001, Guideline for theActivities, Revision 3OP-AA-108-117, Protected Equipment Program, Revision
DMA-AA716-004, Attachment 2 Complex Troubleshooting, Revision '10ER-AA-3003 Cable Condition Monitoring Program, Revision 0OP-AA-1 06-1 01 -1 006, lssue Resolution Documentation Form, Revision 8oP-M-101-1 1 3-1004, Equipmenl Prompt Verbal Report, Revision 1 7OP-M-108-1 17, Protected Equipment Program, Revision
DQP-LG-1 O8-117-1000, Limerick Protected Equipment Program, Revision 1WG-M-101, Online Work Control Process, Revision' 17WG-LG-101-,1001, Guideline for the Performance of Online Wort</Online System Outages'MiscellaneousGeneric Letfer g0-30, Clarification of the Term "Operable" as it Applies to Single FailureCriterion for Safety Systems Required by Technical Specifications, April 10, 1980'ECR 10-00458or-112oT-104Action RequestA1 7851 33A1751413A'1586003tPerformance of On-Line Work/ On-Line System Outages,Review, Screening and Execution of Operation RiskAttachment
A-6p.1663427A1 5354464170961041786141Work Orderc023601 9c0233546c0233547

==Section 1R15: Operabilitv Evaluationslssue Reports0642968

0642968
0985994 11159121143434
1144238
1144249 114429211522491137523 1140448114s979 1151354Procedures5T-2-026-360-0, GeneralAtomics Digital Process Radiation Monitors, Revision 4ASME Code Case==
N-513-2, Evaluation Criteria for Temporary Acceptance of Flaws inModerate Energy Class 2 or 3 Piping Section Xl, Division 1M-C-756-001 HPCI Turbine Inspection, Revision 26OP-M-108-1 15, Operability Determinations, Revision 9OP-M-1 08-1 1 5-1 002 Attachment 1, Supplemental Considerations for On-Shift lmmediateOperability Determinations, Revision 002RT-2-011-252-0 (251-0)A Loop (B Loop) ESW Loop B Flow Balance, Revision 21RT-6055-330-1(2) HPCI Turbine Over-speed Mechanism Operability Check, Revision 20S92.9.N Routine Inspection of Diesel Generators, Revision 59ST-6-055-230-1 HPCI Pump, Valve and Flow Test, RevisionT4MiscellaneousOperability Evaluation
OPE-10-008, Revision 8ASME Code (OM) 1990 Sect. ISTC 4.2.9 (b)GE
SIL 392 Rev. 1 lmproved HPCI Turbine/Mechanical Over-speed Trip DesignGeneric Letter 90-05, Guidance for Performing Temporary Non-Code Repair of ASME CodeClass 1,2, and 3 PipingLER 87-066-00 HPCI Inoperability Due to Malfunction of Hydraulic-Mechanical Over-speed TripMechanismTerry Turbine Maintenance Guide for HPCI ApplicationsOperabilitv EvaluationOL1 - Turbine Reservoir HPCI Turbine OilOPE-10-09, Revision 0oPE-09-005Action RequestA1643599A1 53852841522918, Evaluation 5041733595Sample Results from Dec. 09 - Sept. 10Attachment Work Orderc0231042c02361 1 s

==Section 1R19: Post-Maintenance Testinq!ssue Reports1123479

0747229 07489130913964.
0953751
09973021
138439
1139723 1 1399961151949A-70750139
0750404 091 19011039893
1064929 1 1360291140214
1140215 1 143600ProceduresF:p-y[Aa2a-1001-F-02, Technical Support CenteriOperational Support Center Equipment Test,Revision==
EARC-MCR-222F-5, Unit 2 Division 2 Safeguard Battery Ground, Revision 2CC-MA-304, Establishing and Maintaining Component Classification, Revision 0 -ER-AA-340-1001
GL 89-13 Program lmplementation Instructional Guide, Revision 007GP-8.4 Ul1 (Ul2) Attachment 1 lsolation Bypass, Revision 008NE-C-211 CRL Control, Revision 011NE-C-240 Component ldentification and Descriptions, Revision 001RT-2-01 1-254-0 ESW Loop B D/P and Flow Data Collection, Revision 022ST-2-0T2-106-1 (2) 4 Div I Refuel Floor BOP lsolation LSF/SAA and SGTS Test, Revision 15T-6-092-365-0 Attachment 4 Inoperable Unit 1 Safeguard Power Supply Actions for BothUnits, Revision 38T-228,Inerting and Purging Primary containment, Revision 022 (1)2511.1.A (QOL-2) Equipment Alignment of ESW Loop 'B' System, Revision 33 tMiscellaneousCalcul-dtton 1001 , Compartment Temperature Transients for Steam and Water Leaks,Revision 4blN 86-B2 Failures of Scram Discharge Volume Vent and Drain ValvesP&lD 8031-M-61, Liquid Radwaste collection, sheet 4, Revision. 1524 RRP Voltage Regulator Action Plan 12115110Engineering ChangiOg-00551, Permanent Setpoint Change for
TIS-025-1011201 B & DTechnical Evaluation for lR
390341, Recommendations for PMT of CREFAS lsolation ValvesTroubleshooting, Rework and Testing 10-127 ,Investigate Changing Leakrate of U2 DWEquipment Drain SumP Leak RateAction RequestA1 60627 6, Technical EvaluationWork Ordersc0217140e}?35528c0217 141c0229269

==Section 1R22: Surveillance Testinqlssue Reports11341731

0525591 '1380011132485 1 1 17800
0836062
0844439 08842711129250 1 1 33664
1133723
1137894 11379771138015Attachment==
A-8ProceduresOP-AA-108-103, Locked Equipment Program, Revision 2CC-MA-304 Establish and Maintaining Component Classification, Revision 0000M-C-747-016 CRD Scram Vent and Drain Valve Examination and Maintenance, Revision 004S32.8.A Placing Unit 1 Main Transformers and 11 Unit Aux Transformers in SVC, Revision 22S92.9.N, Routine Inspection of the Diesel Generators, Revision 59ST,4-LLR-361-1 Scram Discharge Volume Vent and Drain Valves, Revision 0093T-6-047-200-1 SDV Valve Exercise Test, Revision Q245T-6-049-230-1, RCIC Pump, Valve and Flow Test Revision 0745T-6-052-760-1 Safeguard Piping Fill Quarterly Valve Test, Revision 0175T-6-092-1 14-2, D24 Diesel Generator 24 Hour Endurance Test, Revision 295T-6-092-323-1 D13 DG LOCAJLOAD Reject Testing and Fast Start Operability Test Run,Revision 0195T-6-092-365-0, Inoperable Unit 1 Safeguard Power Supply Actions for Both Units, Revision 38Action RequestA1 684886Work Orderc0232841Section 1 EP4:Drill Evaluationlssue Reports1 0960281098708 tProceduresEP-M-1 12-100-F-01, Shift Emergency Director Check List, Revision.
KEP-AA-1 14-F-01, Release ln Progress Determination Guidance, Revision. DLimerick Station Annex Table LGS 3-1 , Emergency Action Matrix, Revision. 18Limerick 2010 Off-Year Exercise Evaluation ReportSection 2RS01: Radiological Hazard Assessment and Exposure ControlsProceduresRP-AA- 376, Radiological Postings, Labeling, and Markings, Revision 5RP-AA-376-1001, Radiological Postings, Labeling, and Marking Standard, Revision 5RP-AA-503, Unconditional Release Survey Method, Revision 4

==Section 4OA1: Performance lndicator Verificationlssue Reports1

136395
1137448
1096698
1098653
1102973 10906231090880
1092212
1094965
1080457
1080717 1081
1591081428
1039368
1053889
1051357
1002432
10054951 051 506ProceduresST-5-061-570-0, RadWaste Discharge Permit, Revision 435T-5-076-826-0, Monthly Gaseous Release Dose Calculations, Revision 14LS-AA-2150, Monthly Data Elements for==
RETS/ODCM Radiological Effluent Occurrences,Revision 5Attachment Station, Revision 11CY-LG-120-110,, Chemistry Sampling and Analysis, Revision 10ER-AB-331-1006; BWR RCS Leakage Monitoring and Action Plan, Revision 2LS-AA-2001; Colecting and Reporting of NRC Performance Indicator Data, Revision 13LS-AA-2100, Monthty 6ata Elements-for NRC Reactor Coolant (RCS) Leakage, Revision 5LS-M-2200; Mitigating System performance Index Data Acquisition and Reporling, Revision 3sT-5-041-885-1; Dose Equivalent l-131 Determination, Revision 19sT-5-041-885-2; Dose Equivalent l-131 Determination, Revision 15ST-6-107-596-1 , Ury*ett Ftoor" Drain Sump/Equipment Drain Tank Surveillanpe Log/OPCON1,2,3, Revision 22ST-6-107-596-2, Drywell Floor Drain Sump/Equipment Drain Tank Surveillance Log/oPCoN1,2,3, Revision 25Miscellaneousrviffinoom operator Logs 1 1 l I 12009-1 21 1312010NEI 99-02; Regulatory Assessm6nt Performance Indicator Guideline, Revision 6neacto, overs"rgtrt Program MSPI Basis Document, Limerick Generating station' Revision '1U1 MSpl Cooling WatJr System Unavailability and Unreliability Index for 2010U2 MSpt Cooling Water System Unavailability and Unreliability Index for 2010LS-AA-2140,Revision 5ANA-vMonthly Data Elements for NRC Occupational Exposure Control Effectiveness,CY-LG-1 20-1 05, ObtainingSamples from and operation of the Reactor Enclosure samplelssue Reports t66^ I1056715 1003826

Section 4OA3: Event FollowuPProceduresOf-tfa necirculation Pump Trip, Revision 45Section 4OA5: Other ActivitiesCorrection Action Documents00985060EvaluationsLimerick position paper on compriance with rechnicar specification 3.8.4.2 Motor operatedValves Thermal Overload, Revision 0Proceduresgpag-1 08 -101-1004, Valves, Revision 4OP-LG-1 O3-102-1OOZ, Strategies for Successful Transient Mitigation' Revision 55T-6-102-590-0, oaity surveiiiance Log/Common Plant - At all times, Revision 87RP-M-21 4, AreaTLD Surveillance, Revision 3Attachment

ADAMSANSCAPCDBICFRDEPEALEDGEPEROESWHPCIIRISTISFSIJPMMGMOVNEINRCoosP&IDPIPARSRHRRTPRWPSDVSSCSTTSUFSARURIA-10

LIST OF ACRONYMS

Agencywide Documents Access Management SystemAlert and Notification SystemCorrective Action ProgramComponent Design Bases InspectionCode of Federal RegulationsDrill and Exercise PerformanceEmergency Action LevelEmergency Diesel GeneratorEmergency PreparednessEmergency Response OrganizationEmergency Service WaterHigh Pressure Coolant Injectionlssue ReportIn-Service TestingIndependent Spent Fuel Storage InstallationJob Performance MeasuresMotor GeneratorMotor-Operated ValveNuclear Energy InstituteNuclear Regulatory CommissionOut of ServicePiping and Instrumentation DrawingPerformance lndicatorPublicly Available RecordsResidual Heat RemovalRated Thermal PowerRadiation Work PermitsScram Discharge VolumeStructure, System, ComPonentSurveillance TestTechnical SpecificationUpdated Final Safety Analysis ReportUnresolved ltemAttachment