ML23297A172

Request for Information for a Biennial Problem Identification and Resolution Inspection; Inspection Report 05000352/2024010 and 05000353/2024010

ML23297A172
Person / Time
Site:	Limerick
Issue date:	10/24/2023
From:	Sarah Elkhiamy NRC/RGN-I/DORS
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
IR 2024010
Download: ML23297A172 (1)

See also: IR 05000352/2024010

Text

October 24, 2023

David P. Rhoades

Senior Vice President

Constellation Energy Generation, LLC

President and Chief Nuclear Officer (CNO)

Constellation Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: LIMERICK GENERATING STATION, UNITS 1 AND 2 - REQUEST FOR

INFORMATION FOR A BIENNIAL PROBLEM IDENTIFICATION AND

RESOLUTION INSPECTION; INSPECTION REPORT 05000352/2024010 AND

05000353/2024010

Dear David Rhoades:

The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)

Region I staff will conduct a biennial problem identification and resolution inspection at

Limerick Generating Station, Units 1 and 2. Matthew Hardgrove, a Senior Project Engineer from

the NRCs Region I office, will lead the inspection team. The inspection will be conducted in

accordance with Inspection Procedure 71152, Problem Identification and Resolution, dated

December 14, 2021 (ADAMS Accession No. ML21281A181).

The inspection will assess the effectiveness of your problem identification and resolution

program in identifying, prioritizing, evaluating, and correcting problems, including the use of

operating experience, assessments, and audits. This inspection will also assess your program

for raising concerns under the established safety conscious work environment.

The onsite inspection is scheduled for the weeks of January 29 and February 12, 2024.

In order to minimize the inspection impact on the site and to ensure a productive inspection for

both parties, we have enclosed a request for information needed for the inspection. It is

important that all of these documents are up-to-date and complete in order to minimize the

number of additional documents requested during the preparation and/or the onsite portions of

the inspection. Insofar as possible, this information should be provided electronically to the lead

inspector by December 1, 2024.

If there are any questions about the inspection or the material requested in the enclosure,

please contact the lead inspector at 610-337-5142 or via email at matthew.hardgrove@nrc.gov.

D. Rhoades 2

This letter does not contain new or amended information collection requirements subject to the

Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection

requirements were approved by the Office of Management and Budget, Control Number 3150-

0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a

request for information or an information collection requirement unless the requesting document

displays a currently valid Office of Management and Budget Control Number.

This letter and its enclosure will be made available for public inspection and copying at

http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in

accordance with Title 10 of the Code of Federal Regulations, Part 2.390, Public Inspections,

Exemptions, Requests for Withholding.

Sincerely,

Digitally signed by Sarah

Sarah H. H. Elkhiamy

Date: 2023.10.24

Elkhiamy 12:42:09 -04'00'

Sarah Elkhiamy, Acting Chief

Projects Branch 4

Division of Operating Reactor Safety

Docket No. 05000352 and 05000353

License No. NPF-39 and NPF-85

Enclosure:

Request for Information for Biennial

Problem Identification and Resolution

cc w/ encl: Distribution via ListServ

ML23297A172

x Non-Sensitive x Publicly Available

x SUNSI Review

Sensitive Non-Publicly Available

OFFICE RI/DORS RI/DORS

NAME MHardgrove SElkhiamy

DATE 10/24/2023 10/24/2023

REQUEST FOR INFORMATION

BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION

Inspection Report: 05000352/2024010 and 05000353/2024010

Onsite Inspection Dates: January 29, through February 2, 2024; and

February 12, through February 16, 2024

Inspection Procedure: 71152, Problem Identification and Resolution,

dated December 14, 2021

Lead Inspector: Matthew Hardgrove, Senior Project Engineer

610-337-5142

matthew.hardgrove@nrc.gov

The following information is requested by December 1, 2024, or sooner, to facilitate inspection

preparation. The requested information is for the period from April 1, 2022 through

January 29, 2024 (Present), which covers the timeframe since the previous problem

identification and resolution (PI&R) inspection. The inspection procedure also specifies a five-

year review for a subset of selected program, system, or component issues. The selected

samples for this five-year review will be provided at a future date.

An information gathering trip is currently scheduled for the week of December 11, 2023. The

purpose of this trip is for the team lead to familiarize their self with the site organization including

meetings with department managers and overview of the corrective action program and to

finalize remaining administrative arrangements for the inspection.

Feel free to contact the lead inspector as soon as possible if you have any questions regarding

this information request. Please provide the information electronically in pdf files, Excel, or

other searchable formats, preferably on an internet database system (e.g., OneDrive) The files

should contain descriptive names, be indexed, and hyperlinked to facilitate ease of use.

Information in lists should contain enough information to be easily understood by someone

who has knowledge of light water reactor technology.

I. General

1. Organization charts, phone list, and list of system engineers.

2. List of system numbers/designations and a list of system engineers assigned to those

systems.

3. Access to a hardcopy set of system prints (P&IDs) and operator training manuals for the

team room. These will be returned at the end of the inspection.

4. Technical Requirements Manual (TRM) including the bases.

5. Copy of the Quality Assurance Manual and Quality Assurance Topical Report.

6. A schedule of the date/time/location of meetings associated with implementation of the

correction action program such as Plan-of-the-Day, Station Ownership Committee

(SOC), Management Review Committee (MRC), etc.

Enclosure

REQUEST FOR INFORMATION

BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION

7. PRA risk-ranking of systems, including a chart with highest risk systems/components.

II. Corrective Actions

1. Copy of procedures related to the corrective action program, including issue

identification, cause evaluations, corrective actions, trending, self-assessments, audits,

operability determinations, work management, operating experience, etc.

2. List of all corrective action program deficiency reports (IRs, ARs, etc.) initiated after

April 1, 2022 (last PI&R inspection) - in electronic spreadsheet format - include the

following (as applicable): system number/designation, date initiated, significance level,

status (open or closed), title/short description, department, date closed or due, and if

possible, the number of due date extensions.

3. Separate list of all corrective action program documents (IRs, ARs, etc.) initiated before

April 1, 2022 (last PI&R inspection) that remain open - in electronic spreadsheet format

- include the following (as applicable): system number/designation, date initiated,

significance level, status (open or closed), title/short description, department, date

closed or due, and if possible, the number of due date extensions.

4. List of all root cause evaluations (RCE), apparent cause evaluations (ACE), common

cause evaluations (CCE), and work group evaluations (WGE), performed after

April 1, 2022 (last PI&R inspection) - include number, title, eval type, and date

completed.

5. Matrix of the total number of condition report IRs generated annually and monthly for all

of 2022 and 2023, and to date for 2024 by department.

6. For all notice of violations (NOVs), non-cited violations (NCVs), and findings (FIN) issued

since April 1, 2022 (last PI&R inspection) - provide copies of the associated IRs

including all supporting information such as closeout documentation.

7. For all licensee event reports (LERs) issued since April 1, 2022 (last PI&R inspection) -

provide copies of the associated IRs including all supporting information such as

closeout documentation.

8. List of open temporary modifications, operability determinations, control room

deficiencies and operator workarounds\challenges, and adverse condition monitoring

plans - in electronic spreadsheet format - include tracking no., system id., title/short

description, date initiated, and date corrective action(s) due/work order(s) scheduled.

9. List of rework and repeat maintenance items, and a list of maintenance performance

metrics including the backlog of corrective and elective maintenance issues - include

tracking no., unit/system id, work order no., title/short description, date initiated, date

corrective action(s) due/work order(s) scheduled, and department.

10. Copies of the system health reports for all (a)(1) systems and all systems pending

maintenance rule expert panel review for (a)(1) status determination.

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REQUEST FOR INFORMATION

BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION

11. List of all maintenance rule systems, include risk significance of system (high or low) and

whether the system is considered an (a)(1) or (a)(2). The list should indicate the trend in

overall system performance since the last PI&R inspection. For all (a)(1) systems,

please include a copy of the Action Plan and expert panel minutes.

III. Operating Experience

1. List of operating experience reviews, including Part 21s and NRC generic

communications (i.e., Information Notices, Generic Letters, Bulletins) initiated since the

last PI&R inspection. Provide tracking number, title/short description, date initiated, date

due or closer, significance level, evaluation class/type, status, department, and, if

possible, the number of due date extensions.

2. List of industry operating experience issues (nuclear steam supply system (NSSS)

vendor reports, EPRI Reports, and Operating Experience (OPEX) reports from other

facilities) entered into the corrective action program for review since the last PI&R

inspection. Provide tracking number, title/short description, date initiated, date due or

closed, significance level, evaluation class/type, status, department, and, if possible, the

number of due date extensions.

3. Provide list of correction action program tracking items generated as a result of issues

identified during the OPEX reviews and assessment. Provide tracking number, title/short

description, date initiated, date due or closer, significance level, evaluation class/type,

status, department, and, if possible, the number of due date extensions.

IV. Audits and Assessments

1. Copy of all quality assurance (QA) reviews (audits, assessments, etc.) and self-

assessments of the corrective action program performed since the last PI&R inspection.

2. List of all QA reviews, self-assessments, and safety culture reviews since last PI&R

inspection.

3. Copy of the corrective action program trend reports and performance indicators used by

management since the last PI&R inspection.

4. A list of IRs generated as a result of identified trends (either by station or department)

initiated since the last PI&R inspection. Provide IR number, title, and open/closed status.

5. List of reports or specific issues identified by safety review committees (such as PORC,

NSRB, etc.) or other management oversight mechanisms since the last PI&R inspection.

Indicate whether these items are being tracked in the corrective action program or other

means.

6. Most recent PI&R functional area self-assessment (FASA) that was performed in

preparation for the upcoming PI&R inspection.

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REQUEST FOR INFORMATION

BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION

7. Hardcopy of last completed Institute of Nuclear Power Operations (INPO) evaluation and

assistance report. (Will be reviewed onsite to maintain confidentiality)

V. Safety Conscious Work Environment and Employee Concerns Program (ECP)

1. Procedures related to the ECP.

2. Procedures related to the Safety Conscious Work Environment and the stations

management of related issues.

3. Access to a list of all ECP cases and contacts initiated since the last PI&R inspection.

Include a list of IRs generated as a result of these reviews. (Will be reviewed onsite to

maintain confidentiality)

4. A copy of all safety culture reviews (audits, assessments, surveys, trend review, etc.)

initiated since the last PI&R inspection. Include a list of any IRs generated as a result of

these reviews. (Will be reviewed onsite to maintain confidentiality)

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