IR 05000352/2024010

Biennial Problem Identification and Resolution Inspection Report 05000352/2024010 and 05000353/2024010

ML24075A095
Person / Time
Site:	Limerick
Issue date:	03/18/2024
From:	Jon Greives NRC/RGN-I/DORS
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
IR 2024010
Preceding documents:	ML23297A172 (24 October 2023)
Download: ML24075A095 (1)

Text

March 18, 2024

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000352/2024010 AND 05000353/2024010

Dear David Rhoades:

On February 16, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed a p roblem identification and resolution inspection at your Limerick Generating Station, Units 1 and 2 and discussed the results of this inspection with Michael Gillin, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations problem identification and resolution program to confirm that the station was complying with NRC regulations and licensee standards. Based on the samples reviewed, the team determined that your program complies with NRC regulations and applicable industry standards such that the Reactor Oversight Process can continue to be implemented.

The team also evaluated the stations effectiveness in identifying, prioritizing, evaluating, and correcting problems, reviewed licensee audits and self-assessments, and its use of industry and NRC operating experience information. The results of these evaluations are in the enclosure.

Finally, the team reviewed the stations programs to establish and maintain a safety conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

No findings or violations of more than minor significance were identified during this inspection. This letter, its enclosure, and your response (if any) 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 (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Jonathan E. Greives, Chief Projects Branch 4 Division of Operating Reactor Safety

Docket Nos. 05000352 and 05000353 License Nos. NPF-39 and NPF-85

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000352 and 05000353

License Numbers: NPF-39 and NPF-85

Report Numbers: 05000352/2024010 and 05000353/2024010

Enterprise Identifier: I-2024-010- 0000

Licensee: Constellation Energy Generation, LLC

Facility: Limerick Generating Station, Units 1 and 2

Location: Sanatoga, PA

Inspection Dates: January 29, 2024 to February 16, 2024

Inspectors: J. Ayala, Senior Reactor Inspector L. Grimes, Resident Inspector M. Hardgrove, Senior Project Engineer M. Ordoyne, Physical Security Inspector

Approved By: Jonathan E. Greives, Chief Projects Branch 4 Division of Operating Reactor Safety

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Limerick Generating Station, Units 1 and 2, in accordance with the Reactor Oversight Process.

The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.

Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)

(1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety conscious work environment.

• Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five -year review of Unit 1 and Unit 2 residual heat removal systems. The corrective actions for the following non-cited violations (NCVs) and findings were evaluated as part of the assessment: NCV 05000352,05000353/2021004- 01, NCV 05000352,05000353/2021004-02, FIN 05000352,05000353/2022011- 01, NCV 05000352,05000353/2022004-01, FIN 05000352,05000353/2022004- 02, FIN 05000352,05000353/2022004-03, NCV 05000352,05000353/2023002- 01, and NCV 05000352/2023003- 01.

• Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience,

• Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.

• Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety conscious work environment.

INSPECTION RESULTS

Assessment 71152B Problem Identification and Resolution Program Effectiveness:

The inspectors determined that Constellation's problem identification and resolution program for Limerick was generally effective and adequately supported nuclear safety and security.

Identification: The team reviewed a sample of issues that have been processed through Constellation's problem identification and resolution program since the last biennial team inspection, including NCVs of regulatory requirements and other documented findings. The team determined that, in general, the station identified issues and entered them into the corrective action program at a low threshold and timely manner.

Prioritization and Evaluation: Based on the samples reviewed, the team determined Constellation was generally effective at prioritizing and evaluating issues commensurate with the safety significance of the identified problem. Inspectors observed that at station corrective action program meetings, issues were generally screened and prioritized at the appropriate level and that corrective actions were assigned to address the issues. However, the team noted that Constellation seems to be challenged with addressing lower -level issues in a timely manner and evaluation quality. Both observations are documented below.

Corrective Action: The team concluded that Constellation was generally effective in developing corrective actions that were appropriately focused to correct the identified problems.

Assessment 71152B Operating Experience:

The inspectors reviewed operating experience captured in the corrective action program and sampled operating experience from NRC, industry, vendors, and third-party groups. Overall, for the samples selected, the licensee was generally performing the appropriate assessments for station applicability.

Assessment 71152B Self-Assessment and Audits:

The inspectors determined that the licensee was adequately performing self -assessments and audits in accordance with licensee procedures and implementing corrective actions as needed.

Assessment 71152B Safety Conscious Work Environment:

The team interviewed a total of 20 individuals in one-on-one interviews. The purpose of these interviews was

(1) to evaluate the willingness of the licensee staff to raise nuclear safety issues,

(2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and

(3) to evaluate the licensee's safety conscious work environment. The personnel interviewed were randomly selected by the inspectors from Engineering, Maintenance, Operations, Radiation Protection, Chemistry, Emergency Preparedness, and Security. To supplement these discussions, the team interviewed the Employee Concern Program (ECP) Coordinator to assess their perception of the site employees' willingness to raise nuclear safety concerns, and also reviewed the ECP case log and select case files.

All individuals interviewed indicated that they would raise safety concerns. Most individuals felt that their management was receptive to receiving safety concerns and generally addressed them promptly, commensurate with the significance of the concern. Most interviewees indicated that they were adequately trained and proficient on initiating condition reports. Most interviewees were aware of the licensee's ECP, and all stated they would use the program if necessary and expressed confidence that their confidentiality would be maintained if they brought issues to the ECP. When asked whether there have been any instances where individuals experienced retaliation or other negative reaction for raising safety concerns, all individuals interviewed stated that they had neither experienced nor heard of an instance of retaliation at the site. The team determined that the processes in place to mitigate potential safety culture issues were adequately implemented.

Observation: Lower-level issue resolution and parts availability challenges 71152B The station is adequately identifying issues at a low threshold and addressing the priority, risk significant items in a timely manner. However, the station seems to be challenged with addressing lower-level issues in a timely manner. Shorter refueling outages, as well as on-line risk management practices further challenges the ability to work through lower-level issues in a timely manner. During walkdowns, interviews, and general plant interactions, station staff expressed a perception that lower-level issues can go uncorrected for extended periods of time. Additionally, station staff expressed that challenges with procuring replacement parts are impacting the ability to resolve lower-level issues in a timely manner.

The unavailability of these parts ultimately leads to deferment of resolving those issues.

Examples of these issues include IR 04724308 for the Unit 2 217 elevation airlock door and longstanding building fan issues, deferring PMs, and recent IR 04705596 for the Unit 1 1B turbine supply fan thrown blades. These examples highlight lower-level issues that were entered into c orrective action program, but challenges in procuring replacement parts and ultimate deferment of maintenance prolonged issue resolution.

Observation: Evaluation Quality 71152B The station, for the most part, adequately assesses and evaluates plant issues in their corrective action program products commensurate with the safety significance of the identified problem. However, the station at times as been challenged with quality related to work group evaluations. Examples include IR 04499745 for Unit 1 electrohydraulic control leak, IR 04472545 for Unit 2 reactor core isolation cooling trip reset latch issue, IR 4557807 for Unit 1 D11 diesel lube oil leak upstream of 092-1402A, and IR 04481385 for Unit 2 2G safety relief valve pilot indication and steam leak. Specifically, citing these examples, weaknesses in technical rigor in the evaluations and/or ineffective review for extent of condition can impact the stations ability to adequately trend equipment challenges and resolve issues.

EXIT MEETINGS AND DEBRIEFS

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

• On February 16, 2024, the inspectors presented the biennial problem identification and resolution inspection results to Michael Gillin, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Corrective Action 04486796

Documents 04489971

04489960

04490210

04490493

04490499

04490558

04492129

04493352

04493503

04493647

04494055

04494519

04494596

04494608

04494779

04494902

04494902

04495028

04495046

04496169

04496439

04496566

04496792

04496795

04498696

04499282

04499312

04499745

04500245

04501716

Inspection Type Designation Description or Title Revision or

Procedure Date

04504421

04504667

04504891

04504907

04505261

04505317

04506142

04507012

04507054

04507999

04508227

04508554

04510563

04510675

04510687

04511859

04513206

04516753

04520856

04523790

04525252

04526994

04527062

04527266

04530880

04531187

04534372

04537749

04537759

04538433

04544811

04547388

04554984

Inspection Type Designation Description or Title Revision or

Procedure Date

04557807

04559768

04559929

04560339

04563607

04564264

04564265

04666040

04670741

04674123

04675421

04675476

04676250

04676694

04677711

04678494

04678611

04679776

04680232

04680667

04687340

04689074

04689602

04697291

04697291

04697681

04697988

04698308

04698308

04700004

04700599

04700942

04701166

Inspection Type Designation Description or Title Revision or

Procedure Date

04701463

04701469

04701766

04702378

04703620

04704537

04712397

04714077

04715678

04996027

Engineering 04472545

Evaluations 04479540

04481385

04496027

04496439

04498218

04498218

04498696

04514473

04514625

04517181

04525252

04529011

04529359

04531742

04534372

04534372

04546089

045524972

04557807

04557807

04558075

04674834

Inspection Type Designation Description or Title Revision or

Procedure Date

04676542

04679480

04703688

047053450

Procedures MA-AA-1000 CONDUCT OF MAINTENANCE MANUAL Revision 25

MA-AA-1002 MAINTENANCE TECHNICAL SKILLS Revision 5

MA-AA-716-008 FOREIGN MATERIAL EXCLUSION PROGRAM Revision 17

MA-AA-716-011 WORK EXECUTION AND CLOSE OUT Revision 28

MA-AA-716-012 POST MAINTENANCE TESTING Revision 27

MA-AA-716-017 STATION REWORK REDUCTION PROGRAM Revision 14

MA-AA-716-234 FIN TEAM PROCESS Revision 14

PI-AA-1 PERFORMANCE IMPROVEMENT

PI-AA-101-1002 PI MANAGEMENT REVIEW MEETINGS AND REPORTING Revision 4

PI-AA-1012 SAFETY CULTURE MONITORING Revision 4

PI-AA-115 OPERATING EXPERIENCE PROGRAM Revision 6

PI-AA-115-1001 PROCESSING OF LEVEL 1 AND 2 OPEX EVALUATIONS Revision 4

PI-AA-115-1003 PROCESSING OF LEVEL 3 OPEX EVALUATIONS Revision 7

PI-AA-120 ISSUE IDENTIFICATION AND SCREENING PROCESS Revision 13

PI-AA-125 CORRECTIVE ACTION PROGRAM (CAP) PROCEDURE Revision 8

PI-AA-125-1003 CORRECTIVE ACTION PROGRAM EVALUATION MANUAL Revision 7

PI-AA-127 PASSPORT ACTION TRACKING MANAGEMENT Revision 4

PROCEDURE

PI-AA-3 NUCLEAR SAFETY CULTURE

10