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05000352/FIN-2018010-01Minor Violation2018Q3During this inspection, the team reviewed the details and status of Exelons corrective actions. Relative to EDG voltage, the TSs specified a lower limit of 4160 Vac; however, Exelons existing analysis determined the lower EDG voltage limit should be 4235 Vac. Exelon determined that this higher voltage value was necessary in order to ensure full EDG operability and qualification when considering a specific criteria (voltage drop during the loading sequence) as per NRC Regulatory Guide 1.9, Application and Testing of Safety-Related Diesel Generators in Nuclear Power Plants. The team determined that there was not an operability concern because Exelon determined that, although the voltage drop during the starting of the largest electrical load was slightly below the Regulatory Guide 1.9 value, all required loads would, in fact, successfully start and run as designed when started at the 4160 Vac level. Further, the EDG voltage regulators are designed and calibrated to operate the EDGs at 4235 Vac. Notwithstanding, the team identified that the associated EDG surveillance procedures did not contain the higher, administrative limit of 4235 Vac as an acceptance criterion (4160 Vac was specified). The team reviewed this issue using Inspection Manual Chapter 0612, Appendix B, Issue Screening, and determined that the use of non-conservative acceptance criterion was a minor procedure violation because the EDGs were controlled and operated to maintain voltage at 4235 Vac (and 4160 Vac does not render the EDGs inoperable), and EDG reliability or availability were not adversely affected. Exelon entered this minor violation in their corrective action program as IR 4164579 to document and correct this deficiency. For EDG frequency, the TSs allowed an acceptance band (58.8 61.2 Hertz), which is a range typical of EDG transient loading conditions. However, as described in WCAP-17308-NP, and as determined by Exelon engineering staff, a more narrow band (59.9 60.2 Hertz) is the appropriate operating range for steady state EDG operation. Exelon has appropriately maintained the narrow band as the acceptance criteria in the associated EDG surveillance procedures (compensatory action until TSs are revised). However, during this inspection, the team identified that in 2016, Exelon had slightly widened the acceptable band a one-tenth hertz to 59.8 60.2 Hertz. Further review by the team identified that this change was not properly evaluated in accordance with Exelons procedure change process. In particular, the procedure change received a less rigorous review than a 10 CFR 50.59 screen would have provided; and the team concluded that this screen should have been performed. In response, Exelon evaluated past surveillance results and analyzed the lower frequency value of 59.8 Hertz, and determined there to be no adverse consequence at 59.8 Hertz. The team reviewed Exelons analysis and similarly concluded that there was no adverse safety impact. The team reviewed this issue using Inspection Manual Chapter 0612, Appendix B, Issue Screening, and determined that the improper procedure change was a minor procedure violation because there were no adverse consequences and EDG reliability or availability were not adversely affected. Exelon entered this minor violation in there corrective action program as IR 4160819 and IR 4161542 to document and correct this deficiency.
05000352/FIN-2018003-02Failure to Correct Adverse Environmental Conditions Impacting Low Pressure Coolant Injection Outboard Primary Containment Isolation Valve2018Q3A self-revealed Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI was identified when Exelon failed to correct adverse environmental conditions affecting the Unit 1 LPCI outboard PCIV actuator that resulted in long term water intrusion, corrosion, and failure of the valve to stroke closed.
05000352/FIN-2018003-01Failure to Assess and Manage Risk Associated with Fuel Oil Storage Tank Maintenance2018Q3An NRC-identified Green NCV of 10 CFR 50.65(a)(4) was identified when Exelon failed to assess and manage risk associated with fuel oil storage tank maintenance by not properly evaluating and establishing compensatory actions for maintaining availability of associated EDGs
05000352/FIN-2018002-02Unit 1 Core Spray Pump Failed to Start Resulting in Condition Prohibited by Technical Specifications2018Q2The inspectors identified a Severity Level IV NCV of Unit 1 Technical Specification 3.5.1 because one core spray subsystem was inoperable from July 17, 2017, until October 5, 2017. Specifically, the Unit 1 C core spray pump did not start upon demand during testing and was declared inoperable because the pumps associated circuit breaker closing charging springs were not charged.
05000352/FIN-2018002-01Failure to Conduct Adequate Radiation Surveys and Evaluate Potential Radiological Hazards2018Q2A self-revealing Green finding and associated NCV of 10 CFR 20.1501, Surveys and Monitoring: General, was identified when Exelon failed to perform adequate loose surface contamination surveys of the Unit 1 RWCU isolation valve room prior to authorizing work to hang shadow shielding near the HV-051-1F017A valve, and also during the conduct of the work itself. Exelon also did not identify very high levels of loose surface contamination on overhead piping and structures which surrounded the work area. This failure resulted in unplanned internal radiation exposures to three personnel, including an RPT who was assigned to monitor the radiological aspects of the work.
05000352/FIN-2018001-02Emergency Diesel Generator Combustion Air Overheating2018Q1A self-revealed Green NCV of LGS Unit 1 TS 6.8.1 and TS 3.8.1.1 was identified when Exelon failed to properly maintain an operating procedure to maintain a fail-safe design feature for the EDGs which led to the D12 EDG combustion air overheating and caused the EDG to be inoperable for greater than its TS allowed outage time.
05000353/FIN-2018001-01Failure of Emergency Diesel Generator Lube Oil Pipe Nipple Fitting2018Q1A self-revealed Green non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, and LGS Unit 2 technical specification (TS) 3.8.1.1 was identified when Exelon failed to correct a degraded lube oil pipe nipple fitting on the D22 emergency diesel generator (EDG) when maintenance was performed to address leakage which caused inoperability of the EDG for greater than its TS allowed outage time.
05000353/FIN-2017004-01Unplanned HPCI Inoperability Due to Isolating All Suction Sources During Post-Maintenance Te s t i n g2017Q4The inspectors identified a self-revealing Green non-cited violation (NCV) of 10 Code of Federal Regulations (CFR) 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for Exelons failure to adequately establish post-maintenance testing instructions for a relay replacement for the Unit 2 high pressure coolant injection (HPCI) system. Specifically, implementing the instructions caused a loss of all suction sources and unplanned inoperability of the Unit 2 HPCI system. Exelon initiated a condition report (issue report (IR) 4036417) and conducted a technical human performance (THU) workshop with the maintenance planning department to increase awareness of THU tools and added THU behavior discussion topics to weekly maintenance planning department all hands meetings.This finding is more than minor because it adversely affected the configuration control attribute of the mitigating systems cornerstone to ensure the availability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, HPCI was made inoperable when it was planned to remain operable. Using IMC 0609, Appendix A, Exhibit 2, the inspectors determined that this finding required a detailed risk assessment because it represented a loss of the single train systems function. The Regional Senior Reactor Analyst performed a detailed risk evaluation using the Limerick Generating Station (LGS) Unit 2 Standardized Plant Analysis Risk Model. The issue was modeled with a HPCI failure to start due to the suction valves being closed. The change in core damage frequency per year was determined to be in the low E-9 range due to the very short duration that both suction sources were isolated. Therefore the issue was determined to be of very low safety significance (Green). The inspectors determined that this finding has a cross-cutting aspect in the area of Human Performance, Work Management, because the work process did not ensure individuals were aware of plant status and the changes in the plan of work were not effectively implemented. (H.5)
05000352/FIN-2017007-01Failure to Document Technical Basis for Service Temperature Changes for Limitorque Motor Operated Valve Limit Switches2017Q4The inspection team identified a Green non- cited violation of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion III, Design Control, because Exelons design control measures did not provide for verifying or checking the adequacy of design of the inboard high pressure coolant injection ( HPCI ) steam supply primary containment isolation valve from environmental effects. Specifically, as part of extending component life for license renewal, Exelon changed the normal service temperature of the valve limit switches from 145F to 135F without suff icient technical justification. Exelon documented this issue in their corrective action program as issue report 4076939, and changed the qualified life of the limit switches back to 41 years. Exelon also plans to evaluate the impacts of process fluid tem perature on the qualified life of the limit switches. The inspection team determined that the performance deficiency was more than minor because it was associated with the design control attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective of ensuring that physical design barriers (containment) protect the public from radionuclide releases caused by accidents or events. Specifically, using incorrect service temperatures resulted in inappropriately extending qualified service life of the HPCI inboard containment isolation valve limit switches . The inspection team evaluated this finding in accordance with IMC 0609, Appendix A, The Significance Determination Process for Findings at Power, Exhibit 3, Barrier Integrity Screening Questions. The inspection team determined the finding was of very low safety significance (Green) because it was a design deficiency confirmed not to result in an actual open pathway in the physical integrity of reactor containment and did not involve an actual reduction in function of hydrogen igniters in the reactor containment. The finding had a cross -cutting aspect in the area of Human Performance, Design Margins, because Exelon did not evaluate issues to ensure that margins are carefully guarded and changed only through a systematic and rigorous process. Specifically, Exelon c hanged the service temperature for the Limitorque motor operated valves inside containment in 2014 that extended the qualified service life of the most limiting component beyond 60 years. (H.6)
05000352/FIN-2017003-02Licensee-Identified Violation2017Q3LGS Unit 1 Renewed Facility Operating License, NPF- 39, and LGS Unit 2 Renewed Facility Operating License, NPF- 85, License Condition 2.C.(3) requires , in part, that Exelon Generation Company shall implement and maintain all provisions of the approved Fire Protection Program as described in the UFSAR. LGS Unit 1 and Unit 2 UFSAR Chapter 9A requires compliance with Branch Technical Position, Chemical Engineering Branch 9.5- 1, guideline C.5.b(1), to limit fire damage so that one train of systems necessary to achieve and maintain cold shutdown conditions from either the control room or emergency control station can be repaired within 72 hours. Contrary to the above, from July 2014 to December 2016, an unanalyzed condition existed in which an abnormal ESW system alignment placed two Fire Areas in noncompliance with the FSSD analysis described in the UFSAR. Specifically, in July 2014, ESW to RHRSW flow return valve, HV -011 -015A was de- energized and tagged closed following ESW system testing. With on ly one RHRSW return path available to the A ESW loop, a postulated fire in Fire Area 12 or Fire Area 18 could cause a single spurious valve operation of either spray pond bypass valves HV -012- 031A or HV -012 -031C, when the ESW system is aligned in the spray pond winter bypass mode. This condition would result in no return flow path for the A loop of ESW, which would in turn result in loss of cooling water to EDGs aligned to the A ESW cooling loop. The affected EDGs would be inoperable until the ESW system could be realigned to provide cooling water flow. This condition coupled with a loss of offsite power assumed in FSSD analysis would result in a loss of power to SRVs needed to transition both LGS units from hot shutdown conditions to cold shutdown conditions. Following the depletion of station batteries after 4 hours, until offsite power is assumed to be restored after 72 hours, direct current power would be lost to SRVs that are necessary to reduce plant pressure low enough to place the shutdown cooling system into service and establish cold shutdown plant temperatures. The failure to have a cold shutdown repair that could be implemented within 72 hours in accordance with the FSSD analysis described in the UFSAR, was a performance deficiency. 24 The performance deficiency was more than minor because it was associated with the protection against external factors (fire) attribute of the mitigating systems cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined that the finding was of very low safety significance (Green ), based on IMC 0609, Appendix F, Fire Protection Significance Determination Process , Attachment 1, Part 1: Fire Protection Significance Determination Process Phase 1 Worksheet, dated September 2013. The finding screened to Green based upon task 1.3.1 screening question A, since the inspectors determined that for conditions evaluated by Appendix F the reactors were able to reach and maintain hot shutdown. Specifically, LGS Units 1 and 2 would have been able to achieve and maintain hot shutdown during the period the unanalyzed condition existed. This would have been accomplished by using HPCI and SRVs for pressure and level control. Both units would have been capable of maintaining hot shutdown conditions with postulated fire damage until offsite power could be restored. Because this issue was of very low safety significance (Green) and Exelon entered the issue into the corrective action program as IR 3955705, this finding is being treated as a licensee identified NCV , consistent with Section 2.3.2.a of the Enforcement Policy.
05000353/FIN-2017003-01Operational Condition Mode Change from Startup to Run was Made with RCIC Inoperable2017Q3The inspectors identified a Green NCV of Unit 2 technical specification (TS) 3.0.4, when Exelon changed the operating condition of Unit 2 from mode 2 (startup) to mode 1 (run) with reactor core isolation cooling ( RCIC ) inoperable for surveillance testing. Specifically, the TS 3.7.3 limiting condition for operation (LCO) for RCIC was not met, a mode change from startup to run was made, and none of the allowances, TS 3.0.4.a, TS 3.0.4.b, or TS 3.0.4.c, were met to allow the mode change in that condition. Exelon entered this issue into the corrective action program with issue report (IR) 4057128. The inspectors determined that the change in operating condition of LGS Unit 2 from startup to run with RCIC inoperable was reasonably within Exelons ability to foresee and correct and should have been prevented and therefore was a performance deficiency. This finding is more than minor because it adversely affected the configuration control attribute of the mitigating systems cornerstone to ensure the availability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, RCIC was inoperable during the time it was required to be operable, i.e. the mode change from startup to run. Additionally, this finding was similar to example 2.g of IMC 0612, Appendix E, in that a mode change was made without all required equipment being operable. Using IMC 0609, Appendix A, Exhibit 2, the inspectors determined that this finding was of very low safety significance (Green). Specifically, the finding did not represent a loss of function and did not represent the loss of a single train for greater than technical specification allowed outage times or greater than 24 hours. The inspectors determined that this finding has a cross - cutting aspect in the area of Human Performance, Documentation, because with respect to TS 3/4.7.3 Exelon did not create and maintain complete and accurate documentation of the correct usage of TS 3.0.4 that was more fully explained in the applicable safety evaluation. (H.7)
05000352/FIN-2017002-03Licensee-Identified Violation2017Q2LER 05000352/2017-003-00 Condition Prohibited by Technical Specifications Due to an Inoperable Rod Position Indication System. TS 3.1.3.7 requires, in part, with one or more control rod position indicators inoperable, within 1 hour, determine the position of the control rod by using an alternate method, or otherwise, be in at least hot shutdown within the next 12 hours. Contrary to the above, on March 16, 2017, a power supply for the Unit 1 rod position indication system rendered position indication for 83 control rods inoperable for approximately 19.5 hours until the power supply was replaced. Exelon incorrectly used the full core display to verify control rod position for 81 of the 83 rods. The power supply failure rendered the full core display incapable of updating in response to a rod position change and was, therefore, not a valid means to determine rod position. Exelon initiated condition report IR 3988302 to document the TS violation. The inspectors evaluated the significance of this finding using IMC 0609 Appendix A, Significance Determination Process for Findings at Power, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that this finding was of very low safety significance (Green) because the issue did not affect a single reactor protection system trip signal or the function of the other redundant trips or diverse methods of reactor shutdown, did not involve addition of positive reactivity, and did not result in mismanagement of reactivity by operators. Because this issue was of very low safety significance (Green) and Exelon entered the issue into the corrective action program (IR 3988302), this finding is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy.
05000352/FIN-2017002-02Follow -Up of Events and Notices of Enforcement Discretion2017Q2Inspection Scope On March 20, 2016, Limerick Unit 1 was performing a planned shutdown to support a refueling outage. The drywell leak inspection team identified a 0.5 gallons per minute reactor coolant system (RCS) pressure boundary leak on the shutdown cooling equalizing line. The apparent cause evaluation determined that the 34 inch A RHR shutdown cooling return check valve equalizing line developed a crack at the toe of the weld due to high cyclic fatigue induced by vibration from the reactor recirculation system. This check valve was previously replaced in 2006, and the equalizing line came pre - fabricated to the valve body. The affected section of the piping was replaced with a new socket weld with a 2x1 overlay to improve the pipe stability and minimize stresses. The Unit 1 B RHR shutdown cooling return check valve equalizing line weld was also reworked using the 2x1 weld method during the Unit 1 refueling out age in April 2016. The similar Unit 2 welds on the equalizing lines were examined and reinforced during the May 2017 refueling outage. The LER and associated evaluations and follow -up actions were reviewed for accuracy, the appropriateness of corrective actions, violations of requirements, and potential generic issues. This LER is closed. b. Findings Description. On March 20, 2016, Limerick Unit 1 was performing a planned shutdown to support a refueling outage. The drywell leak inspection team identified a 0.5 gallons per minute RCS pressure boundary leak on the shutdown cooling equalizing line. Additionally, Exelon determined that this leakage constituted a violation of the Unit 1, TS 3.4.3.2. Operational Leakage that requires the RCS leakage to be limited to no pressure boundary leakage. The condition was reported in event notification 51809 as required by 10 CFR 50.72(b)(3)(ii)(A ) because it represented a degradation of a principal safety barrier. Exelon evaluated the flaw and determined the cause of the RCS pressure boundary leakage was that the 34 inch A RHR shutdown cooling return check valve equalizing line developed a crack at the toe of the weld due to high cyclic fatigue induced by vibration from the reactor recirculation system. The inspectors reviewed the LER and Exelons apparent cause evaluation of the event. The inspectors reviewed the event information and leakage data over the previous cycle and concluded that reactor pressure boundary leakage reasonably began on an unknown date that was more than 36 hours before March 20, 2016. However, the inspectors determined that the existence of R CS pressure boundary leakage was not within Exelons ability to foresee and correct and therefore was not a performance deficiency. In particular, the RHR shutdown cooling return check valve was replaced on the recommended periodicity, and the equalizing line that developed the crack came pre- fabricated to the valve body when replaced in 2006. For information, the inspectors screened the significance of the condition using IMC 0609, Appendix A, The Significance Determination Process For Findings At -Power , and determined that the condition represented very low safety significance (Green) because it would not result in exceeding the RCS leak rate for a small LOCA and would not have likely affected other systems used to mitigate a LOCA. 19 Enforcement. TS 3.4.3.2 requires, in part, that RCS operational leakage shall be limited to no pressure boundary leakage. If pressure boundary leakage exists, the TS 3.4.3.2 limiting condition for operation action statement requires Unit 1 to be in at least hot shutdown within 12 hours and in cold shutdown within the next 24 hours. Contrary to the above, for a period that began on an unknown date that was very likely more than 36 hours before March 20, 2016, and ending on March 20, 2016, RCS pressure boundary leakage existed, and Exelon did not place Unit 1 in at least hot shutdown within 12 hours and in cold shutdown within the next 24 hours. This issue is considered within the traditional enforcement process because there was no performance deficiency associated with the violation of NRC requirements. Inspection Manual Chapter 0612, Power Reactor Inspection Reports, Section 03.22 states, in part, that traditional enforcement is used to disposition violations receiving enforcement discretion or violations without a performance deficiency. The NRC Enforcement Policy, Section 2.2.1 states, in part, that, whenever possible, the NRC uses risk information in assessing the safety significance of violations. Accordingly, after considering that the condition represented very low safety significance, the inspectors concluded that the violation would be best characterized as Severity Level IV under the traditional enforcement process. However, the NRC is exercising enforcement discretion (EA- 17- 076) in accordance with Section 3.10 of the NRC Enforcement Policy which states that the NRC may exercise discretion for violations of NRC requirements by reactor licensees for which there are no associated performance deficiencies. In reaching this decision, the NRC determined that the issue was not within the licensees ability to foresee and correct; the licensees actions did not contribute to the degraded condition; and the actions taken were reasonable to identify and address the condition. Furthermore, because the licensees actions did not contribute to this violation, it will not be considered in the assessment process or the NRCs Action Matrix.
05000353/FIN-2017002-01Inadequate Design Control of the Drywell Unit Cooler Condensate Flow Rate Monitoring System2017Q2Green . A self -revealing Green NCV of 10 Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion III, Design Control, occurred when Exelon failed to verify or check the adequacy of design of a new Unit 2 drywell unit cooler condensate flow rate monitoring system. Specifically, the design did not identify that the low conductivity of the drain fluid affected the ability of the flow elements to accurately detect drain flow. In addition to this, LGS staff did not assure adequate post modification acceptance test ing in accordance with CC- AA- 107- 1001, Post Modification A cceptance Testing. This inadequately designed and tested modification also resulted in a violation of technical specification (TS) 3.4.3.1, Leakage Detection Systems , because the system was inoperable and unavailable to perform its function following t he Unit 2 April 2015 refueling outage, and the TS 3.4.3.1 action statement was not met until the system was decl ared inoperable on December10, 2015. In response to this issue, Exelon initiated a condition report, IR 2598308, performed an apparent cause investigation, and replaced the Rosemount drywell unit cooler condensate flow rate monitoring system with a modified ver sion of the previously used system. The inspectors determined that the failure to verify the adequacy of the newly installed Rosemount dr ywell unit cooler condensate flow rate monitoring was within Exelons ability to foresee and correct and should have been prevented and therefore w as a performance deficiency . This issue is more than minor because it adversely affected the design control attribute of the barrier integrity cornerstone to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the Unit 2 drywell unit cooler condensate flow rate monitoring system was inoperable and unavailable to perform its function as part of the reactor coolant leakage detection system following the Unit 2 April 2015 refueling outage . This issue was evaluated in accordance with IMC 0609, Appendix A, "Significance Determination Process for Findings At-Power, using Exhibit 3, Barrier Integrity Screening Questions, Section B, Reactor Containment . The finding was determined to be of very low safety significance (Green) because the finding did not represent an actual open pathway in the physical integrity of the reactor containment and did not involve an actual reduction in function of hydrogen ig niters in the reactor containment. The inspectors determined that this finding has a cross -cutting aspect in the area of Human Performance, Conservative Bias , because LGS staff ma de inappropriate decisions based on informal vendor input and a successful implementation of the modification at another facility . (H.1 4)
05000352/FIN-2017403-01Licensee-Identified Violation2017Q2
05000352/FIN-2017003-00Licensee-Identified Violation2017Q2LER 05000352/2017- 003 -00 Condition Prohibited by Technical Specifications Due to an Inoperable Rod Position Indication System . TS 3.1.3.7 requires, in part, with one or more control rod position indicators inoperable, within 1 hour, determine the position of the control rod by using an alternate method, or otherwise, be in at least hot shutdown within the next 12 hours. Contrary to the above, on March 16, 2017, a power supply for the Unit 1 rod position indication system rendered position indication for 83 control rods inoperable for approximately 19.5 hours until the power supply was replaced. Exelon incorrectly used the full core display to verify control rod position for 81 of the 83 rods. The power supply failure rendered the full core display incapable of updating in response to a rod position change and was, therefore, not a valid means to determine rod position. Exelon initiated condition report IR 3988302 to document the TS violation. The inspectors evaluated the significance of this findi ng using IMC 0609 Appendix A , Significance Determination Process for Findings at Power, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that this finding was of very low safety significance (Green) because the issue did not affect a single reactor protection system trip signal or the function of the ot her redundant trips or diverse methods of reactor shutdown, did not involve addition of positive reactivity, and did not result in mismanagement of reactivity by operators. Because this issue was of very low safety significance (Green) and Exelon entered the issue into the corrective action program (IR 3988302), this finding is being treated as a non- cited violation, consistent with Section 2.3.2 .a of the NRC Enforcement Policy.
05000352/FIN-2017001-02Failure to Implement Human Performance Tools Results in Draining of Emergency Diesel Generator Jacket Water System2017Q1Green. The inspectors identified a Green self-revealing finding for the failure of Exelon personnel to follow procedures related to human performance tools which resulted in the inadvertent opening of a valve on the D13 emergency diesel generator (EDG). Specifically, Exelon personnel did not correctly identify and maintain a distance barrier from the diesel generator jacket water drain valve during a maintenance activity which resulted in the draining of the jacket water system and unplanned inoperability and unavailability of the D13 EDG. Exelon refilled the jacket water system, restored D13 EDG to an operable condition, and entered the issue into the corrective action program as IR 3986305. This finding is more than minor because it adversely affected the configuration control attribute of the mitigating systems cornerstone to ensure the availability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the valve mispositioning caused the D13 EDG to be inoperable and unavailable. Using IMC 0609, Appendix A, Exhibit 2, the inspectors determined that this finding was of very low safety significance (Green). Specifically, the finding did not represent a loss of system or function and did not represent the loss of a single train for greater than technical specification allowed outage times or greater than 24 hours. The inspectors determined that this finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because Exelon personnel did not properly implement error reduction tools. (H.12)
05000353/FIN-2017001-01Inadequate Work Instructions for Staging of Equipment and Routing of Temporary Power Cables2017Q1Green. The inspectors identified a Green NCV of 10 Code of Federal Regulations (CFR) 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for Exelons failure to establish instructions appropriate to the circumstances to properly stage equipment and route temporary power cables. Specifically, during cell replacement of the Class 1E 2A2 125/250 volts direct current (Vdc) safeguards battery, a portable battery charger was staged adjacent to operable 2A1 battery cells and not restrained to prevent potential tipping and shorting of exposed battery cell terminals and a non-safety related extension cord was routed in near contact with exposed safety related cables in an open cable tray. Exelon moved the portable battery charger, removed and rerouted extension cords, and entered the issues into the corrective action program as issue report (IR) 3980217; IR 3980203; and IR 3983203. This finding is more than minor because it adversely affected the configuration control attribute of the mitigating systems cornerstone to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the portable battery charger was adjacent to the 2A1 battery rack and oriented such that it was susceptible to tipping over and causing electrical shorting, and a non-safety related temporary power cable connected to a non-safety related power source was routed in near contact with safety related cables in an open cable tray which introduced a potential to damage and disable safety related equipment. Using IMC 0609, Appendix A, Exhibit 2, the inspectors determined that this finding was of very low safety significance (Green). Specifically, the finding did not represent a loss of system or function and did not represent the loss of a single train for greater than technical specification allowed outage times or greater than 24 hours. The inspectors determined that this finding has a cross-cutting aspect in the area of Human Performance, Training, because Exelon did not provide sufficient training to maintain a knowledgeable workforce and instill nuclear safety values associated with the staging of material and equipment. (H.9)
05000352/FIN-2016004-02Control Structure Chiller Unit Trip Caused by Failure to Properly Implement Procedures2016Q4Green. A self-revealing Green NCV of LGS Units 1 and 2 technical specification 6.8.1 was identified when Exelon did not properly implement a surveillance procedure. Specifically, operators secured cooling water to the operating A control structure chilled water system (CSCWS) chiller unit which resulted in the unit automatically tripping to prevent damage. Operators subsequently restored cooling water flow in accordance with procedures. Exelon entered the issue into the corrective action program as IR 2720374. This finding is more than minor because it is associated with the human performance attribute of the mitigating systems cornerstone to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the loss of cooling water to the A CSCWS chiller unit resulted in a trip of the unit on high condenser pressure and rendered the chiller unavailable. Using IMC 0609, Appendix A, Exhibit 2, the inspectors determined that this finding was of very low safety significance (Green). Specifically, the finding did not represent a loss of system or function and did not represent the loss of a single train for greater than technical specification allowed outage times or greater than 24 hours. The inspectors determined that this finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because operators did not recognize and plan for the possibility of mistakes and inherent risk and did not use appropriate error reduction tools. (H.12)
05000352/FIN-2016004-01Failure to Demonstrate Effective Preventive Maintenance Under 50.65(a)(2) for the Instrument Air System2016Q4Green. The inspectors identified a Green NCV of 10 Code of Federal Regulations (CFR) 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," because Exelon did not demonstrate that the performance of the Unit 1 instrument air system had been effectively controlled through the performance of appropriate preventive maintenance and did not monitor against licensee-established goals in accordance with 10 CFR 50.65(a)(1). Specifically, the inspectors identified that the instrument air system reliability performance monitoring did not properly account for instrument air compressor failures such that the system exceeded the performance criteria established by Exelons procedures. Exelon entered the issue into the corrective action program (CAP) as IR 3961244. This issue is more than minor because it adversely affected the equipment performance attribute of the mitigating systems cornerstone to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the instrument air system reliability performance monitoring did not accurately account for multiple functional failures that resulted in the system exceeding the performance criteria established by Exelons procedures. Additionally, this finding was similar to example 7.d of IMC 0612, Appendix E, in that appropriate preventive maintenance under 10 CFR 50.65 (a)(2) was not demonstrated. Using IMC 0609, Appendix A, Exhibit 2, the inspectors determined that this finding was of very low safety significance (Green). Specifically, the finding did not represent a loss of system or function and did not represent the loss of a single train for greater than technical specification allowed outage times or greater than 24 hours. The inspectors determined that the finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because Exelons staff did not adequately implement the procedures for reliability performance criteria evaluation. Specifically, Exelon did not verify that the established performance criteria for train reliability accurately monitored the scope of the function and demonstrated the effectiveness of maintenance when performing functional failure determinations and the periodic 10 CFR 50.65(a)(3) assessment. (H.8)
05000352/FIN-2016003-02Licensee-Identified Violation2016Q3The following violation of very low safety significance (Green) was identified by Exelon and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a non-cited violation. 10 CFR 50.54(q)(2), Emergency Plans, requires, in part, that a holder of a licensee under this part shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E to this part, and for nuclear power reactor licensees, the planning standards of 50.47(b). 10 CFR 50.47(b)(4) requires that a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee. Contrary to the above, from April 25, 2016, until August 3, 2016, the spent fuel pool level emergency action level (EAL) RG2/RS2 threshold of Limericks Emergency Plan for a General Emergency and Site Area Emergency did not meet the requirements of Appendix E and the planning standards of 10 CFR 50.47(b). Specifically, Exelon identified that the spent fuel pool level for RG2/RS2 threshold was 0.08 feet, and the correct threshold value was 0.8 feet. The spent fuel pool EAL threshold values for a lowering water level for an Alert and Unusual Event were correct at 10.20 feet and less than 22 feet, respectively. The normal spent fuel pool water level is over 23 feet. The inspectors evaluated this finding using IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, Table 5.4-1. This Table indicates, in part, that the following should be assessed as low safety significance (White): an EAL has been rendered ineffective such that any General Emergency would not be declared for a particular off-normal event, but because of other EALs, an appropriate declaration could be made in a degraded manner (e.g. delayed), and, an EAL that has been rendered ineffective such that any Site Area Emergency would not be declared for a particular off-normal event. However, the inspectors confirmed that the spent fuel pool level instrumentation at LGS goes off scale at approximately 0.635 feet, and the Limerick Emergency Plan, in Addendum 3, directs any Emergency Director to assume the EAL threshold has been exceeded if the associated parameter goes off scale. In addition, the NEI recommended and NRC endorsed value for this EAL threshold would have been at nominally 0.0 feet, the level at which the fuel remains covered and actions to implement make-up water addition should no longer be deferred. Although the LGS threshold for declaration at 0.8 feet would have been exceeded, the inspectors concluded that the event would have been classified when the SFP level dropped below 0.635 feet, sufficiently above the NEI recommended level. Because the event would have been declared with margin to the actual water level needed for protection of the public, i.e. the spent fuel would still be fully covered by water at the time of the EAL declaration(s), the inspectors concluded that this performance deficiency was most similar to the Table 5.4-1 branches representing very low safety significance (Green). Exelons corrective actions included revising EP-AA-1008, Addendum 3, with the correct spent fuel pool level EAL RG2/RS2 threshold of 0.8 feet. Because this issue was of very low safety significance (Green) and Exelon entered the issue into the corrective action program (IR 2700440), this finding is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy.
05000353/FIN-2016003-01Inadequate Design Control of Plant Processing Computer Modification2016Q3A self-revealing finding of very low safety significance (Green) was identified when Exelon did not implement their engineering design control procedures during the plant processing computer (PPC) modification. Specifically, Exelon did not fully address effects of the modification on other plant systems and did not establish a testing boundary that encompassed all components whose operation was altered by the modification. As a result, the PPC modification had a wiring design error that resulted in the trip of both reactor recirculation pumps (RRPs) which required a manual reactor trip of Unit 2. In response to this issue, Exelon initiated IR 2676712, investigated the cause of the trip, fixed the wiring design error, performed a root cause evaluation, and performed an extent of condition review. This issue is more than minor because it adversely affected the design control attribute of the initiating events cornerstone to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the PPC modification process had a wiring design error that resulted in the trip of both RRPs which required a manual reactor trip of Unit 2. The issue was evaluated in accordance with IMC 0609, Appendix A, "Significance Determination Process for Findings At-Power, using Exhibit 1, "Initiating Events Screening Questions, Section B, Transient initiators. The finding was determined to be of very low safety significance (Green) because the finding did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. The inspectors determined that this finding has a cross-cutting aspect in the area of Human Performance, Challenge the Unknown, because LGS staff did not stop when faced with uncertain conditions, and risks were not evaluated and managed before proceeding. Specifically, Exelon did not stop and reevaluate the risks and effects on plant systems when changes were made to the PPC design modification package. (H.11)
05000352/FIN-2016001-07Licensee-Identified Violation2016Q1The following violation of very low safety significance (Green) was identified by Exelon and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a NCV. From 2010 to 2014, Exelon made a total of 16 shipments of radioactive material which contained category 2 quantities of radioactive material. Exelon did not implement a transportation security plan for any of these shipments, which is contrary to the requirements of 49 CFR 172, Subpart I, Safety and Security Plans. This performance deficiency adversely affected the Public Radiation Safety cornerstone attribute of Program and Process based on inadequate procedures associated with the transportation of radioactive materials. The finding was determined to be of very low safety significance (Green) because the transportation of radioactive material issue did not involve: (1) a radiation limit that was exceeded; (2) a breach of package during transport; (3) a certificate of compliance issue; (4) a low level burial ground nonconformance; or (5) a failure to make notifications or provide emergency information. This issue was documented in Exelons corrective action program as IR 2490592. Corrective actions included contracting with a vendor to receive regular, prompt notifications of potentially applicable rule changes in the Federal Register.
05000353/FIN-2016001-06Failure to Implement Procedures for Control of Potentially Contaminated Clean Systems2016Q1The inspectors identified a Green NCV of technical specification 6.8.1 because Exelon failed to implement procedure CY-AA-170-210, Potentially Contaminated System Control Program, for the evaluation and control of potentially cross-contaminated systems. Specifically, Exelon did not implement CY-AA-170-210 for the evaluation and control of a potentially cross-contaminated system when samples collected from the Unit 2 service air system, a non-contaminated system, indicated the potential presence of contamination on June 16, 2015. Exelon entered this issue into the corrective action program (IR 2556568), restricted use of the service air system, conducted a 10 CFR 50.59 screening and radiological evaluation of the system, conducted bounding radiation dose analyses for both occupational workers and members of the public, conducted an extent of condition review, decontaminated the system, and subsequently modified operation of the service air system to preclude re-contamination. This finding is more-than-minor because it is associated with the program and process attributes of the occupational and public radiation safety cornerstones and adversely affected both cornerstone objectives to ensure adequate protection of worker and public health and safety from exposure to radioactive material. Specifically, during the time the service air system was contaminated but not recognized as such and not restricted in use, the potential existed to inadvertently contaminate workers and release radioactive material to the environment. Using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the inspectors determined that this finding was of very low safety significance (Green) because the finding did not involve an as low as is reasonably achievable (ALARA) issue, was not an overexposure, did not result in a substantial potential for an overexposure, and did not compromise the ability to assess dose. In addition, using IMC 0609, Appendix D, Public Radiation Safety Significance Determination Process, the inspectors determined that the issue did not involve a substantial failure to implement the effluent release program and did not result in public doses exceeding 10 CFR 50, Appendix I or 10 CFR 20.1301 (e) and thus was of very low safety significance (Green). The inspectors determined this finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Resolution, because Exelon did not take effective corrective actions when service air system issues were identified.
05000353/FIN-2016001-05Main Turbine Digital Electrohydraulic Control System Modification Failed to Revise the Plant Startup Procedure2016Q1A self-revealing Green NCV of LGS Unit 2 technical specification 6.8.1 was identified because Exelon failed to maintain a plant startup procedure. Specifically, the implementing procedure for normal plant startup from hot shutdown or cold shutdown to rated power was not maintained when a modification to the Unit 2 turbine electrohydraulic control system was performed and required changes to the plant startup procedure were not identified and implemented. Exelon initiated issue report (IR) 2602637, revised the startup procedure to properly incorporate the software changes made at the factory acceptance test, validated the software changes that were made were technically correct, trained all operators on the new procedural changes, and reviewed operating procedures for extent of condition. This finding is more than minor because it is associated with the procedure quality attribute of the initiating events cornerstone and affected the objective to limit the likelihood of events that upset plant stability during power operations. Specifically, the procedure directed actions intended in the software for rapid reactor depressurization that resulted in a reactor trip. Using IMC 0609, Significance Determination Process, Appendix A, Exhibit 1, Initiating Events Screening Questions, the inspectors determined that this finding was of very low safety significance (Green) because the finding did not cause both a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. Specifically, although the finding caused a Level 8 trip of the feedwater pumps followed by a reactor trip, the rate of water injection from the condensate pumps was sufficient when the reactor was tripped to safely shutdown and operators were able to reset the feedwater pumps. The inspectors determined that this finding has a cross-cutting in the area of Human Performance, Change Management, because leaders did not use a systematic process for implementing the modification so that nuclear safety remained the overriding priority.
05000352/FIN-2016001-04Entry into a High Radiation Area without Radiological Briefing and Complying with the RWP2016Q1A self-revealing Green NCV of LGS Unit 1 technical specification 6.12.1 was identified involving improper entry of two workers into the Unit 1 reactor drywell on March 22, 2016. Specifically, the workers entered the drywell, an area controlled as a Locked High Radiation Area, without obtaining the required access radiological conditions briefing. Further, one of the two workers entered under the control of an RWP that did not authorize access into High Radiation Areas. Exelon initiated IR 2644005, restricted the workers from further radiological controlled area access, re-configured the access area, conducted an extent of condition and human performance review, issued a site communication, and performed a staff stand down. This finding is more than minor because it is associated with the programs and process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure adequate protection of workers from radiation exposure. In addition, this example is similar to example 6.h of IMC 0612, Appendix E. Specifically, the workers did not receive a brief and did not review surveys prior to entering a work area with radiation levels that exceeded 100 mrem/hr at 30 cm. Using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the inspectors determined the finding was of very low safety significance (Green) because: 1) it was not an as low as is reasonably achievable (ALARA) finding, 2) there was no overexposure, 3) there was no substantial potential for an overexposure, and 4) the ability to assess dose was not compromised. The inspectors determined that this finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because the individuals failed to follow verbal work instructions. (H.8)
05000352/FIN-2016001-03Inadequate Work Staging and Housekeeping Walkdowns During PreOutage Preparations2016Q1The inspectors identified a Green NCV of technical specification 6.8.1 for Exelons failure to properly control, store, and stage material in accordance with station procedures within Class I buildings during refueling outage preparation. Specifically, Exelon personnel did not secure numerous rolling carts staged in both units, did not secure welding blankets in the common pipe tunnel to prevent blocking floor drains, and did not properly build scaffolds to include engineering approval for scaffold procedure deviations. In addition, Exelons housekeeping and material condition program did not identify and resolve these conditions through the corrective action process during a time of increased activities in the plant. Exelon restrained the carts and other rolling equipment, removed the weld blankets, and removed, reworked, and evaluated scaffolding. This finding is more than minor because it adversely affected the protection against external factors (flood and seismic hazards) attribute of the mitigating systems cornerstone to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the loose unattended welding blankets would have blocked the pipe tunnel floor drains during an analyzed internal flooding event which would result in structural failures if not identified and corrected by operations personnel; the unrestrained carts would translate and rotate during a seismic event which could potentially impact safety related equipment and challenge the function or barrier; and the scaffold clearance and attachment issues could potentially cause impact with ductwork, cable trays, hangers, and structural supports during a seismic event. In addition, the performance deficiency is similar to the more-than-minor example described in IMC 0612, Appendix E, example 4.A, in that Exelon routinely failed to perform engineering evaluations on similar issues. Using IMC 0609, Appendix A, Exhibit 2, the inspectors determined that this finding was of very low safety significance (Green). Specifically, the finding is a deficiency affecting the design or qualification of mitigating structures, systems, and components, and the actual functions of the structures, systems, and components were maintained. The inspectors determined that this finding has a cross-cutting aspect in the area of Human Performance, Training, because the organization did not provide sufficient training to maintain a knowledgeable workforce with respect to proper material handling and storage, awareness of flood hazards and floor drains, and scaffolding requirements. (H.9)
05000352/FIN-2016001-02Seismic Qualification of Safety Related Battery not Maintained2016Q1The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion III, Design Control, and technical specification 3.8.2, D.C. Sources, because Exelon failed to ensure the design control measures for field changes impacting the seismic support of station batteries were commensurate with those applied to the original design requirements. Specifically, during cell replacement of the Class 1E 1A1 125/250 volts direct current (Vdc) safeguards battery, removal of adjacent cells and restraint barriers left the battery in a state in which the seismic qualification was not maintained. Exelon initiated IR 2624349, stopped the battery cell replacement work, and performed a technical evaluation to determine the requirements to maintain the seismic qualification during the cell replacement process. This finding is more than minor because it adversely affected the protection against external factors (seismic) attribute of the mitigating systems cornerstone to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, during cell replacement of the Class 1E 1A1 125/250 Vdc safeguards battery, removal of adjacent cells and restraint barriers left the battery in a state in which the seismic qualification was not maintained. In accordance with IMC 0609, Appendix A, Exhibit 4, External Event Screening Questions, the inspectors determined that a detailed risk evaluation was required because the loss of this equipment by itself during the seismic event it was intended to mitigate would degrade one or more trains of a system that supports a risk significant function. The Region I Senior Reactor Analyst referenced the Limerick External Events Notebook to assess the potential increase in plant risk associated with this condition. As referenced in the Notebook, the initiating event frequency for the safe shutdown earthquake (SSE) is approximately 5E-4/year. Based upon the inspectors review of operations logs, the five battery replacement activities that occurred over the past 12 months ranged in duration from between one to six days. Assuming the seismic qualification was compromised the entire duration of these maintenance activities, the consequential increase in risk for any single event would be in the low to mid E-9 delta core damage frequency range. The dominant core damage sequences involve an SSE that results in a loss of offsite power and the subsequent failure to remove heat from containment (via the multi-train residual heat removal system and associated service water cooling trains). This estimated small increase in core damage frequency represents a condition of very low safety significance (Green). The inspectors determined that this finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because Exelon did not recognize and plan for the possibility of latent issues associated with the battery replacement process. (H.12)
05000352/FIN-2016001-01Reactor Enclosure Recirculation System Design Change not Evaluated2016Q1A self-revealing Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) Part 50 (10 CFR 50), Appendix B, Criterion III, Design Control, was identified because Exelon did not properly maintain the design of the LGS Unit 1 reactor enclosure recirculation system (RERS). Specifically, Exelon replaced the Unit 1 1A RERS flow straightener assembly using thinner material than was originally qualified and did not evaluate the change in design. Exelon initiated IR 2563872 and implemented a temporary configuration change that removed the flow straightener assembly from the system and restored Unit 1 RERS to operability on October 5, 2015. Exelon also initiated corrective actions to install a new flow straightener assembly with correctly sized honeycomb material. This finding is more than minor because it adversely affected the design control attribute of the barrier integrity cornerstone to provide reasonable assurance that physical design barriers (secondary containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the inadequate 1A RERS flow straightener assembly installed in 2012 resulted in degraded performance and then unplanned unavailability of 1A RERS from October 1 to 5, 2015. Using IMC 0609, Appendix A, Exhibit 3, the inspectors determined that this finding was of very low safety significance (Green). Specifically, the degraded 1A RERS performance and associated unavailability only represented a degradation of the radiological barrier function provided for the standby gas treatment system and screened to Green. The inspectors determined that the finding did not have cross-cutting aspect because the performance deficiency did not occur within the last three years, and the inspectors did not conclude that the primary cause of the performance deficiency represented present Exelon performance.
05000352/FIN-2015004-02Licensee-Identified Violation2015Q4Technical Specification 3.6.5.3, Standby Gas Treatment System Common System, requires with one SGTS subsystem, restore the inoperable subsystem to operable status within 7 days, or be in at least hot shutdown within the next 12 hours and in cold shutdown within the following 24 hours. Contrary to Technical Specification 3.6.5.3, SGTS subsystem B was inoperable for Unit 1 from August 27, 2015, to September 4, 2015, for a time of 8 days 18 hours, and Exelon did not place Unit 1 in hot shutdown or cold shutdown. Exelon entered this issue into the corrective action program as IR 2517538. The inspectors evaluated this finding using IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, Exhibit 3, Barrier Integrity Screening Questions. The inspectors determined that the finding was of very low safety significance (Green) because the finding only represented a degradation of the radiological barrier function of the SGTS. In addition, the inoperable condition would have resulted in a flowrate exceeding the analyzed 2500 cfm with a differential pressure greater than the minimum 0.25 inches of vacuum water gauge. However, the condition did not represent a larger pathway through secondary containment and SGTS retained radiological filtering capability.
05000352/FIN-2015004-01Seismic Qualification of Safety Related Block Wall Not Maintained2015Q4The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design Control, because Exelon did not properly store circuit breakers and ground trucks in accordance with the established design in order to maintain the seismic qualification of safety-related structures. Specifically, Exelon personnel attached stored circuit breakers and ground trucks to safety-related concrete block walls but did not evaluate the greater weight of circuit breakers, did not maintain the required separation distances, and did not attach all equipment to required attachment points. Exelon initiated issue report (IR) 2592543, removed all stored circuit breakers from the location, rearranged ground trucks to attach them only to designated wall anchors that maintained the required separation distance, and required refresher training of all operators and electrical maintenance personnel on proper spacing and restraint of circuit breakers and ground trucks. This finding is more than minor because it adversely affected the protection against external factors (seismic) attribute of the mitigating systems cornerstone to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the improper storage of the circuit breakers and ground trucks affected the seismic qualification of the concrete block walls separating the switchgear of the emergency diesel generators (EDG) which had potential to damage the block walls during a seismic event. Using IMC 0609, Appendix A, Exhibit 4, the inspectors determined that this finding was of very low safety significance (Green). Specifically, the inspectors determined that the performance deficiency only affected the seismic qualification of the concrete block wall, the loss of the concrete wall by itself would not necessarily cause an initiating event or degradation of the EDG system, and the finding did not involve the total loss of any safety function. Furthermore, the inspectors consulted a Senior Risk Analyst regarding the risk screening and determined that a failure of the walls would not necessarily result in the degradation or failure of the EDG systems. Specifically, for screening purposes, assuming total failure of the concrete masonry walls only introduces a potential of degraded performance since the switchgear are anchored to the concrete floor. As such, Exhibit 4 provides a reasonable basis for screening the finding as Green. The inspectors determined that this finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because equipment operators did not follow the established work instructions (posted signs).
05000353/FIN-2015003-01Inadequate Procedure for RWCU Backwashing Operations2015Q3A self-revealing Green NCV of Technical Specification (TS) 6.8.1.a, Procedures and Programs, occurred because Exelon failed to establish, implement, and maintain an adequate procedure for the control of radioactivity and limiting personnel exposure during operation of a solid radioactive waste system. Specifically, the procedure for the conduct of reactor water cleanup (RWCU) filter media backwashing and collection was inadequate to ensure a sufficient receiving tank volume prior to transferring waste media. On June 28, 2015, this resulted in the overflow of a Unit 2 RWCU collection tank and back up of the reactor building floor drain system, causing high levels of radioactive contamination in accessible portions of the Unit 2 reactor building, and resulting in radioactive contamination of personnel. Exelon controlled access, decontaminated affected areas and personnel, conducted bounding dose assessments, performed extent of condition reviews, and revised affected procedures to address the issue. Exelon placed this issue into the corrective action program as issue report (IR) 2520732. This issue is more-than-minor because if left uncorrected, it had the potential to lead to a more significant safety concern. Specifically, the failure to effectively control and manage radioactive material could result in significant unplanned, unintended occupational radiation exposure of workers. Using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the inspectors determined that this finding was of very low safety significance (Green) because the finding did not involve an as low as is reasonable achievable (ALARA) issue, was not an overexposure, did not result in a substantial potential for an overexposure, and did not compromise the ability to assess dose. The inspectors determined this finding has a cross-cutting aspect in the area of Human Performance, Avoiding Complacency, because Exelon did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes, and therefore did not implement appropriate error reduction tools. Specifically, Exelon operated the backwash receiving tank (BWRT) to routinely accept high level alarms with associated potential for system overflow. Consequently, although this mode of operation of the system was longstanding, the issue reflects present performance.
05000352/FIN-2015201-02Security2015Q3
05000352/FIN-2015201-01Security2015Q3
05000353/FIN-2015003-02Inadequate Preventive Maintenance of the HPCI System Motor Control Center2015Q3A self-revealing Green NCV of TS 6.8.1.a, Procedures and Programs, occurred when Exelon inadequately maintained and implemented a preventive maintenance (PM) task for the 2DB-1-14 high pressure coolant injection (HPCI) direct current (DC) motor control center (MCC) cubicle. Specifically, PM procedure M-095-002, 250 VDC Westinghouse MCU Maintenance, Revision 6, was performed on the main compartment but was not performed on the auxiliary compartment of the 2DB-1-14 MCC cubicle. Subsequently, the 1A timetactor failed due to lack of cleaning and inspection, which led to a fire in the HPCI DC MCC. Exelons corrective actions included initiating issue report (IR) 2480166, replacing the affected components, and revising the PM task to perform future preventive maintenance on both the main and auxiliary compartments of the 2DB-1-14 cubicle. Exelon also conducted immediate extent of condition reviews and scheduled further reviews to ensure no similar conditions exist. This issue is more than minor because it was associated with the procedures quality attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, PM procedure M-095-002, 250 VDC Westinghouse MCU Maintenance, Revision 6, was not performed on both compartments of the 2DB-1-14 cubicle and caused the fire in the HPCI DC MCC that had the potential to affect HPCI system operation. Using IMC 0609, Significance Determination Process, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined that this finding was of very low safety significance (Green) because the finding was not a deficiency affecting the design or qualification of the HPCI system and the system maintained operability and functionality. Specifically, the affected portions of the HPCI system were a part of the HPCI vacuum tank condensate pump that is not required to ensure operability or functionality. The inspectors determined that the finding did not have a cross-cutting aspect because the PM task change did not occur within the last three years, and the inspectors did not conclude that the causal factors represented present Exelon performance.
05000352/FIN-2015007-02Failure to Verify Adequate Voltage Available for DC Equipment2015Q3The team identified a finding of very low safety significance involving a non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, Design Control, in that Exelons design control measures did not verify the adequacy of the design regarding adequate direct current voltage (Vdc). Specifically, Exelon did not ensure that adequate voltage existed to emergency diesel generator (EDG) relays and output breaker spring charging motors. Additionally, the team determined that the overall impact to voltage drop calculations was not adequately assessed when the temporary battery cart is used. Following identification of the issue, Exelon entered it into their corrective action program and evaluated the operability of the batteries, concluding that the affected DC components would function at the current battery capacities. The teams review of the evaluation determined it to be reasonable. The finding was more than minor because it was similar to Example 3.j of NRC IMC 0612, Appendix E, and was associated with the Design Control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.The team determined the finding was of very low safety significance because it was a design deficiency affecting the safetyrelated batteries that did not result in the loss of operability or functionality. The team determined this finding had a cross-cutting aspect in the area of Human Performance, (Documentation, Aspect H.7) because the battery sizing calculation was revised on March 15, 2014, which provided an opportunity to identify the inaccuracies of the battery calculations.
05000352/FIN-2015007-01Failure to Verify Adequacy of EDG Voltage to Start Safety-Related Motors2015Q3The team identified a finding of very low safety significance involving a non-cited violation (NCV) of the 10 CFR Part 50, Appendix B, Criterion III, Design Control, in that Exelon did not verify and assure in design basis calculations, that adequate voltage would be available for starting Class 1E accident mitigating motors when the safeguards buses are powered by the emergency diesel generators (EDG). Specifically, in the calculation performed to evaluate voltage available to individual motors when they are powered by the EDGs, Exelon assumed that the generator output voltage would be 4285 Volts, alternating current (Vac), rather than the minimum voltage allowed by station technical specifications (4160 Vac). Additionally, the electrical ratings of loads powered by the EDG were not adjusted for the maximum frequency allowed by station technical specifications (61.2 hertz (Hz)). As a result, the starting voltage for some of the safetyrelated motors would not have been acceptable under EDG generator voltage and frequency limiting conditions. In response, Exelon entered the issue into their corrective action program and performed evaluation that determined that EDG actual test results demonstrated the EDGs to be operable. The team review of the evaluation determined it to be reasonable. This finding was more than minor because it was similar to Example 3.j of NRC IMC 0612, Appendix E, and was associated with the Design Control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The team determined the finding was of very low safety significance because it was a design deficiency confirmed not to result in a loss of safety-related motor operability or functionality. The team determined this finding had a cross-cutting aspect in the area of Problem Identification and Resolution (Identification, Aspect P.1), because during a calculation revision in 2014, Exelon did not recognize that the limits of voltage and frequency allowed by the station technical specifications affected the calculation results and, therefore, did not completely and accurately identify the issue and revise the calculation in accordance with the stations corrective action program requirements.
05000352/FIN-2015002-01Design Requirements Not Met for Installed Instrument Gas Tubing Fitting2015Q2A self-revealing Green NCV of 10 CFR 50, Appendix B, Criterion III, Design Control, was identified because Exelon failed to control the proper design configuration of installed plant equipment in Unit 1. Specifically, a fitting used in the safety-related primary containment instrument gas (PCIG) tubing supplying the 1C inboard main steam isolation valve (MSIV) was not installed in accordance with the specified quality standard and this deviation was not controlled. Subsequently, the fitting failed due to high cycle fatigue and caused a reactor trip. Exelons corrective actions included initiating condition report IR 2458005, installing approved tubing and fittings on February 24, 2015, on the 1C inboard MSIV which maintained wall thicknesses greater than original specifications, and verifying that current maintenance practice, training, and knowledge would preclude substitution of a different style fitting without further evaluation. This finding is more than minor because it is associated with the design control attribute of the initiating events cornerstone and affected the objective to limit the likelihood of events that upset plant stability during power operations. Specifically, the inadvertent closure of the 1C inboard MSIV resulted in a reactor trip. Using IMC 0609, Significance Determination Process, Appendix A, Exhibit 1, Initiating Events Screening Questions, the inspectors determined that this finding was of very low safety significance (Green) because the finding did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition (e.g. loss of condenser, loss of feedwater). Specifically, the finding caused the loss of one steam line to the main condenser but three steam lines remained available. The inspectors determined that the finding did not have cross-cutting aspect because the installation of the fitting that failed did not occur within the last three years, and the inspectors did not conclude that the causal factors represented present Exelon performance.
05000352/FIN-2015001-03Operability of High Pressure Coolant Injection and Entries into Operational Conditions at Low Reactor Pressures with High Reactor Water Level Trip Actuated2015Q1On February 23, 2015, LGS Unit 1 automatically shut down and remained in the hot shutdown operational condition (i.e. mode 3) for equipment repair and restart. Based on a lit overhead annunciator and indicating light in the main control room, the inspectors noted that the HPCI high reactor water level trip (Level 8, trip setpoint 54 inches) was actuated with normal reactor water level being maintained using the reactor water level narrow range instruments (35 inches). This annunciator provided indication that HPCI was potentially inoperable. The inspectors noted that Exelon had been tracking the HPCI system as operable. The inspectors questioned the ability of the high drywell pressure instruments to fulfill the function required by TS to actuate the HPCI system with the high water level trip actuated. Technical specification 3.3.3 requires that the emergency core cooling system actuation channels shown in Table 3.3.3-1 be operable. Table 3.3.3-1, trip function 3.b, drywell pressure high, requires four operable channels during operating modes 1, 2, and 3 (Power Operation, Startup, and Hot Shutdown) when reactor pressure is greater than 200 psig. With more than one channel inoperable, the HPCI system must be declared inoperable. With a Level 8 trip present, the logic circuitry prevents actuation of the HPCI system by tripping its urbine stop valve closed. In addition, to prevent undue cycling of the HPCI system, when the reactor water level drops below the Level 8 trip signal setpoint, a sealin circuit prevents actuation of the HPCI system until the Level 8 trip relays are reset, either by a manual reset pushbutton or when reactor water level drops to the reactor vessel water level low-low (Level 2, actuation setpoint -38 inches) actuation setpoint. The operators did not declare HPCI inoperable because procedure GP-2, Normal Plant Startup, contained a note that stated HPCI systems have been determined operable by engineering evaluation with a high level trip setpoint actuated. Exelon determined that the note was added to Revision 56 of GP-2, approved on December 18, 1995. However, Exelon was unable to find the referenced engineering evaluation that justified this conclusion. The inspectors determined that at normal operating reactor pressure the TS required the high drywell pressure channels be declared inoperable when the channels were incapable of automatically actuating the HPCI system and the procedural note was not supported by an associated evaluation. Therefore, the lack of an adequate evaluation supporting the procedural note represented a performance deficiency and violation of regulatory requirements. However, in consultation with staff from the Technical Specifications and Reactor Systems Branches in the NRC Office of Nuclear Reactor Regulation, the inspectors determined that Exelons conclusion that the operability and safety function of the HPCI system was maintained at lower reactor pressures with the Level 8 trip actuated required further information in order to determine if that issue of concern was a performance deficiency and violation.
05000352/FIN-2015001-02Startup Procedure Considered High Pressure Coolant Injection Operable with High Reactor Water Level Trip Actuated Preventing High Drywell Pressure Automatic Actuation2015Q1The inspectors identified an NCV of Title 10 of the Code of Federal Regulations (10 CFR), Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Exelon prescribed a procedure affecting quality with instructions which were not appropriate to the circumstances. Specifically, procedure GP-2, Normal Plant Startup, contained a note that stated high pressure coolant injection (HPCI) systems have been determined operable by engineering evaluation with a high level trip setpoint actuated. The inspectors determined that the note was inconsistent with Units 1 and 2 technical specifications (TS) and was not supported by an adequate engineering basis. Exelons corrective actions included briefing staff to ensure HPCI system operability is appropriately assessed when implementing GP-2, initiating condition report IR 2464416, completing a procedure revision to reference an interim evaluation contained in the condition report, and initiating an action to complete an engineering evaluation. This finding is more than minor because it is associated with the procedure quality attribute of the mitigating systems cornerstone and affected the objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, procedure GP-2 stated that the HPCI system was operable with a Level 8 trip present without the ability to automatically actuate upon a high drywell pressure without an engineering evaluation which was inconsistent with the existing safety analysis performed at normal operating reactor pressure and temperature. Using IMC 0609, Significance Determination Process, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined that this finding was of very low safety significance (Green) because the finding did not represent an actual loss of the HPCI system or function to inject high pressure emergency core cooling water. Specifically, the note in GP-2 allowed considering the HPCI system operable at normal operating reactor pressures with the HPCI system tripped. However, the HPCI system was not tripped at normal operating reactor pressures. The inspectors determined that the finding did not have cross-cutting aspect because the procedure development performance deficiency did not occur within the last three years, and the inspectors did not conclude that the causal factors represented present Exelon performance.
05000352/FIN-2015001-01Fire Safe Shutdown Diesel Generator Maintenance Program Did Not Account for Cold Temperatures due to Inadequate Specification for Fuel Oil Cloud Point2015Q1The inspectors identified an NCV of LGS Units 1 and 2 operating license condition 2.C(3), Fire Protection, because Exelon did not implement and maintain in effect all provisions of the NRC approved fire protection program. Specifically, Exelon did not implement and maintain a maintenance program to ensure the operability of the fire safe shutdown diesel (FSSD) generator by not ensuring a fuel oil supply specified or protected for typical winter cold temperatures. Exelons corrective actions included adding a fuel oil additive (modifiers which inhibit wax crystal growth) to improve low temperature flow and pour characteristics at a time when ambient temperatures were greater than the cloud point and initiating condition report IR 2463216. This finding is more than minor because it adversely affected the protection against external factors (fire) attribute of the mitigating systems cornerstone to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the failure to ensure the cloud point of the diesel fuel oil was below the temperature of the surrounding air would impact the reliable operation of the equipment during low temperature conditions. Using IMC 0609, Appendix F, Fire Protection Significance Determination Process, the inspectors determined that this finding was of very low safety significance (Green) because the finding did not impact the ability of LGS Units 1 and 2 to achieve safe shutdown. Specifically, the cloud point of diesel fuel delivered onsite by the vendor was substantially lower than Exelons specification, unavailability of the FSSD generator would not by itself prevent LGS from reaching and maintaining safe shutdown, and the need for powered ventilation given a loss of normal HVAC during cold weather would be less than during hot weather. The inspectors determined that this finding has a cross-cutting aspect in the area of Human Performance, Resources, because Exelon did not ensure that cold weather preparedness procedures were adequate to support nuclear safety. Specifically, Exelon relied upon the cold weather procedures to establish reliable equipment operation during cold temperatures, but the procedures did not address diesel fuel cloud point for equipment stored and/or operated outdoors.
05000352/FIN-2014005-01Unplanned Manual Power Reduction to 90% on Unit 12014Q4A self-revealing, Green non-cited violation (NCV) of Technical Specification (TS) 6.8.1.b, Administrative Controls, was identified for LGS failure to properly implement station procedure MA-AA-716-100, Maintenance Alterations Process, during troubleshooting and calibration associated with the Unit 1 condensate filter (CF) system. As a result, on September 9, 2014, one of two Instrument Maintenance (IM) technicians inadvertently mispositioned the air supply valve to the 1G CF flow transmitter causing an unplanned plant transient. The inspectors determined that the failure to properly implement station procedure MA-AA-716-100, Maintenance Alterations Process, during troubleshooting of CF system instrumentation, was a performance deficiency. LGS promptly performed an investigation, verified the plant alignment and safely returned the Unit 1 reactor to 100 percent power. LGS entered the issue into their corrective action program (CAP) as issue report (IR) 2116233 This self-revealing finding is more than minor because it affected the human performance attribute of the Initiating Events Cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions. This resulted in elevated main steam line radiation levels which required operators to reduce reactor power in accordance with abnormal operating procedures. The inspectors evaluated the finding using inspection manual chapter (IMC) 0609, Appendix A, The Significance Determination Process for Findings At-Power, to IMC 0609, Significance Determination Process. This finding was determined to be of very low safety significance (Green) because it was associated with a transient initiator, but didnt cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. The finding has a cross-cutting aspect in the area of Human Performance, because LGS maintenance management did not ensure supervisory and management oversight of work activities (H.2).
05000352/FIN-2014008-01Security2014Q4
05000352/FIN-2014004-02Licensee-Identified Violation2014Q3The following violation of very low safety significance (Green) was identified by LGS and is a violation of NRC requirements which met the criteria of the NRC Enforcement Policy for being dispositioned as a NCV. LGS Unit 1 and 2 TS 6.8.1 require that written procedures be established, implemented, and maintained including an ODCM. LGS Procedure CY-LG-170-301, Revision 26, ODCM, requires in Table 3.3-1, that continuous airborne radioactivity samplers be placed in three locations close to the site boundary (in different sectors) of the highest calculated annual average ground level deposition (D/Q). Contrary to the above, there was no sampler close to the site boundary location in the southeast sector with the highest ground level D/Q. That air sampler located in the southeast sector was at a distance of 3 miles beyond the site boundary. This matter was identified by LGS in late 2012 and placed in the CAP. At the time of this inspection, LGS was installing a new air sampling station near the site boundary location in the southeast sector. LGS evaluated the impact of the lack of this station and concluded there was no radiological impact in that: air monitoring stations near the site boundary in adjoining sectors had not detected radioactivity attributable to plant operations; analysis of samples of broadleaf vegetation in the specific sector did not identify any radioactivity attributable to station operations; and routine effluent sampling did not identify any abnormal airborne effluent releases. The issue was determined to be more than minor because it adversely affected the program and process attribute of the Public Radiation Safety cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain. The inspectors determined that the finding was of very low safety significance (Green) because the finding was in the radiological environmental monitoring program and was contrary to TS. Because this finding is of very low safety significance, and the issue was entered into LGS' CAP (IRs 1390579, 1668838), this violation is being treated as a Green NCV consistent with the NRC Enforcement Policy.
05000352/FIN-2014004-01Inadequate Evacuation Time Estimate Submittals2014Q3The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (CFR) 50.54(q)(2), 10 CFR 50.47(b)(10), and 10 CFR Part 50, Appendix E, Section IV.4, for not maintaining the effectiveness of the LGS, Units 1 and 2, emergency plan as a result of failing to provide the station evacuation time estimate (ETE) to the responsible offsite response organizations (OROs) by the required date. Exelon entered this issue into their corrective action process (CAP) as issue reports (IR) 1525923 and 1578649. Additionally, Exelon re-submitted a new revision of the LGS ETE to the NRC on January 31, 2014. This performance deficiency is more than minor because it is associated with the emergency preparedness cornerstone attribute of procedure quality and adversely affected the cornerstone objective of ensuring that LGS is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The finding was determined to be of very low safety significance (Green) because it was a failure to comply with a non-risk significant portion of 10 CFR 50.47(b)(10). The cause of the finding is related to the cross-cutting element of Human Performance, Documentation, because LGS did not appropriately create and maintain complete, accurate and, up-to-date documentation.
05000353/FIN-2014003-01Inadequate Corrective Actions Following Repeat Test Failures of a High Pressure Coolant Injection System Level Instrument2014Q2The inspectors identified a Green NCV of 10 Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, for the failure to adequately evaluate and correct repeat calibration test failures in April 2012 and in February 2014 on the Unit 2 high pressure coolant injection (HPCI) system suppression pool level transmitter LT-055- 2N062F. This resulted in LT-055-2N062F, a technical specification (TS) required instrument, being in a degraded and unreliable condition. The inspectors determined that failure to adequately evaluate and correct the condition was reasonably within the ability to foresee and correct, and should have been prevented. LGS personnel promptly replaced the instrumentation and returned the HPCI system to an operable status prior to the Unit 2 startup. LGS also entered the issue into their corrective action program (CAP) for resolution as Issue Reports (IRs) 1646041, 1651480, and 1659171. This NRC-identified finding is more than minor because it affected the Barrier Integrity cornerstone attribute of the reliability and availability of structures, systems, or components to maintain the functionality of containment and affected the cornerstone objective to provide reasonable assurance that physical design barriers (containment) protect the public from radionuclide releases caused by accidents or events. The inspectors evaluated the finding using Appendix A, The Significance Determination Process for Findings At-Power, to IMC 0609, Significance Determination Process. This finding was determined to be of very low safety significance (Green) because it was associated with the functionality of the reactor containment but didnt represent an actual open pathway in the physical integrity of containment, the containment isolation system, and heat removal components and, the finding did not involve an actual reduction in function of hydrogen igniters. In addition, the logic for the HPCI pump suction transfer from the condensate storage tank to the suppression pool on high level in the suppression pool is a one-out-of-two logic. The inspectors determined that this function was available because the other channel which performs the function was not affected by the finding and was available during the time period in question with the exception of during brief testing periods. The finding has a cross-cutting aspect in Problem Identification and Resolution, Evaluation, because LGS personnel did not thoroughly evaluate the issue to ensure that resolutions addressed the causes and extent of conditions commensurate with their safety significance.
05000352/FIN-2014404-03Licensee-Identified Violation2014Q2
05000352/FIN-2014404-02Licensee-Identified Violation2014Q2
05000352/FIN-2014404-01Security2014Q2
05000352/FIN-2014403-03Licensee-Identified Violation2014Q2
05000352/FIN-2014002-01Failure to Adhere to Technical Specifications When Making Change to ODCM2014Q1The NRC identified a non-cited violation of Technical Specification (TS) 6.14, Offsite Dose Calculation Manual (ODCM), for failure to evaluate and provide sufficient information to support a change to the ODCM. Specifically, LGS revised the ODCM to allow the residual heat removal service water (RHRSW) monitors to be non-functional due to loss of flow for a period of up to 4 hours before they were required to be declared inoperable and did not provide sufficient information to support the change including a determination that the change would maintain the level of radioactive effluent release control. LGS entered the issue into their corrective action program (CAP) as Issue Report (IR) 1639697 and revised the applicable alarm response card (ARC-MRC-010 E4) to declare the monitor inoperable under similar conditions. A dose calculation was also completed that indicated no significant public dose consequences associated with the monitors inoperable status. The failure to evaluate and provide sufficient information to support a change to the ODCM, in accordance with the requirements of TS 6.14 is a performance deficiency. This performance deficiency is more than minor because it affected the Public Radiation Safety Cornerstone attribute of Plant Facilities/Equipment and Instrumentation. Using Inspection Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination Process, dated February 12, 2008, the inspectors determined this to be a finding of very low safety significance (Green) because: the finding was in the effluent release program; was not a substantial failure to implement the effluent program; and the dose to the public did not exceed the 10 Code of Federal Regulations (CFR) Part 50 Appendix I criterion or 10 CFR 20.1301(e) limits. This finding was associated with a cross cutting aspect of Human Performance, Design Margins. Specifically, LGS did not conduct a sufficiently rigorous review of a change in the operability status of a safety-related radiation monitor (RHRSW radiation monitors) to ensure that the change would not adversely impact the level of radioactive effluent release control.
05000352/FIN-2013005-01Failure to Properly Plan Work for Failed Airlock Door Magnetic Switch2013Q4The inspectors identified a self-revealing finding (FIN) of very low safety significance (Green) for Exelons failure to appropriately prioritize work activities associated with a degraded Unit 2 magnetic switch for a secondary containment airlock door in accordance with Exelon procedure WC-AA-106, Work Screening and Processing. This resulted in both airlock doors being opened simultaneously due to equipment degradation and resulted in a momentary loss of reactor enclosure secondary containment integrity. The failure of the station to properly prioritize the work order for the defective magnetic switch for the Unit 2 313 elevation reactor building-to-reactor building air supply room access airlock doors was a performance deficiency that was reasonably within Exelons ability to foresee and correct and could have been prevented. This was caused by not performing a site impact review of reportability clarifications made by NUREG 1022, Event Report Guidelines 10 CFR 50.72 and 50.73, Revision 3. The performance deficiency was also contrary to Exelons procedure for work screening and processing. The finding was determined to be more than minor because it was associated with the Barrier Integrity cornerstone attribute of structures, systems, and components (SSC) and Barrier Performance (doors and instrumentation) and affected the cornerstone objective of providing reasonable assurance that physical design barriers (secondary containment) protect the public from radionuclide releases caused by accidents or events. Specifically, opening two reactor building airlock doors at the same time did not maintain reasonable assurance that the secondary containment would be capable of performing its safety function in the event of a reactor accident. The finding was determined to be self-revealing because it was revealed through the receipt of an alarm in the main control room which required no active and deliberate observation by Exelon personnel. The finding was determined to be of very low safety significance (Green) in accordance with Appendix A of IMC 0609, Significance Determination Process for Findings At-Power. Specifically, the finding only represents a degradation of the radiological barrier function provided by the secondary containment airlock doors. Exelon entered the issue into the corrective action program (CAP) as Issue Report (IR) 1553563. Corrective actions performed or planned included repairing the magnetic switch, verifying that the corrective maintenance backlog did not contain any other issues involving the airlock door indicating lights, developing a periodic routine test of the airlock door indicating circuits, and performing a site impact review of the changes in NUREG 1022, Revision 3. This finding had a cross-cutting aspect in the area of Human Performance, Resources, because Exelon did not ensure that resources were available to minimize preventative maintenance deferrals and ensure maintenance and engineering backlogs were low enough to ensure that safety is maintained (H.2(a)). Specifically, Exelon deferred implementation of the work order several times over a three year period which resulted in secondary containment becoming inoperable on September 3, 2013.
05000352/FIN-2013004-03Failure to Correct a Condition Adverse to Quality associated with Defective Material Being Reinstalled into a Safety-Related System2013Q3The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, associated with Exelon staffs failure to correct a condition adverse to quality (CAQ) associated with defective material being reinstalled into a safety-related system after the component failed. Specifically, Exelons corrective actions to address the defective material issues in both Apparent Cause Evaluation (ACE) IR 900755 and Equipment Apparent Cause Evaluation (EACE) IR 1365093 did not prevent the installation of a previously failed circuit board into a safety-related system. This circuit board ultimately failed again, causing operators to declare the Redundant Reactivity Control System (RRCS) inoperable. Exelons corrective actions included revising procedural guidance for RRCS channel-checks, utilizing an alert system for continuous performance monitoring of al RRCS system parameters, conducting an extent of cause for all existing RRCS out-of-band log entries, revising the maintenance strategy to use new RRCS cards and a time-directed PM to replace failed or old cards and benchmarking the industry maintenance strategy for RRCS. Exelon is also revising material receipt procedures, training all warehouse personnel on the receipt inspection process and performing extent of conditions of all other repairable stock codes. Exelon has entered this issue into their CAP as IR 1569907. The inspectors determined that Exelons corrective actions to address a CAQ associated with defective material issues in both ACE IR 900755 and EACE IR 1365093, was a performance deficiency that was within their ability to foresee and correct, and should have been prevented. The performance deficiency was determined to be more than minor because it affected the Procedure Quality and Human Performance attributes of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Further, if left uncorrected, the performance deficiency could have the potential to lead to a more significant safety concern. The performance deficiency was also similar to IMC 0612, Appendix E, example 4.g, in that Exelons corrective actions were inadequate and failed to correct a CAQ. The finding is of very low safety significance (Green) per IMC 0609, Appendix A, Exhibit 2 - Mitigating Systems Screening Questions, because RRCS was determined to maintain its operability and functionality, does not represent a loss of system and/or function and does not represent an actual loss of function of a single train for greater than its TS allowed outage time. The finding had a cross-cutting aspect in the area of PI&R, CAP, because Exelon did not take the appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with the safety significance (P.1(d)). Specifically, Exelon did not take appropriate corrective actions to address the use of new RRCS circuit boards and did not ensure the corrective actions for the D23 Emergency Diesel Generator (EDG) rectifier failure would ensure all failed components that are sent to the vendor for analysis and sent back to the site with no failure mode were evaluated by engineering prior to re-installation.
05000352/FIN-2013004-02Failure to Perform Technical Specification Surveillance Requirements on the Unit 2 Primary Containment Instrument Gas System2013Q3The inspectors identified a Green NCV of Technical Specification (TS) 6.8.1.a, Procedures and Programs, for Exelons failure to implement surveillance test procedures specified for the Primary Containment Instrument Gas (PCIG) system as required by Regulatory Guide (RG) 1.33, Quality Assurance Program Requirements. Specifically, Exelons PCIG local leak rate procedures, ST-4-LLR-011-2 and ST-4-LLR-241-2, incorrectly credited the surveillance testing of the PCIG supply header B check primary containment isolation valve (059-2005B) in ST-6-059-201-2 PCIG Valve Test which resulted in entry into TS 4.0.3 for a missed surveillance. Exelons corrective actions included an extent of condition review and revising PCIG check valve surveillance testing to correct the crediting of the wrong check valves due to the successful completion of Local Leak Rate Testing (LLRT). Exelon has entered this issue into their CAP as IR 1554992 and 1569903. The failure to perform the surveillance requirements specified for the PCIG system, specifically, incorrectly crediting the surveillance testing of PCIG check valve 059-2005B which resulted in a missed surveillance, is a performance deficiency. The performance deficiency was determined to be more than minor, because it adversely affected the Procedure Quality attribute of the Mitigating Systems cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Exelon failed to ensure that the PCIG system surveillance testing adequately tested and credited the successful completion of LLRT. The finding is of very low safety significance (Green) per IMC 0609, Appendix A, Exhibit 2 - Mitigating Systems Screening Questions, because the PCIG system was determined to maintain its operability and functionality, does not represent a loss of system and/or function and does not represent an actual loss of function of a single train for greater than its TS allowed outage time. The inspectors determined that the finding had a cross-cutting aspect in the area of PI&R, CAP, because Exelon did not thoroughly evaluate problems such that resolutions address causes and extent of conditions, including properly classifying, prioritizing, fully evaluated, and that actions are taken to address safety issues in a timely manner, commensurate with their safety significance (P.1(c)). Specifically, Exelon personnel did not adequately address, thoroughly evaluate, and prioritize IR 1498740 which documented potential deficiencies with Unit 2 PCIG check valve testing, in a timely manner.
05000352/FIN-2013004-01Inadequate and Untimely Corrective Actions Associated With the Unit 1 Instrument Air System2013Q3A self-revealing finding of very low safety significance was identified for Exelons failure to take adequate and timely corrective actions to address the inadvertent depressurization of the Unit 1 Instrument Air (IA) headers. This led to a repeat depressurization of the Unit 1 IA headers when the service air compressor tripped on July 7, 2013, causing the operators to enter ON-119, Loss of Instrument Air, and reduce reactor power by 20 percent until IA header pressure could be restored and maintained. Exelons corrective actions for this issue included replacing all of the IA dryer pre-filters, creating an activity to perform dryer performance monitoring prior to any IA maintenance outage, and recalibrating all of the IA dryer pre-filter differential pressure (D/P) switches. Exelon was also in the process of evaluating a replacement component for the IA dryer D/P switches and investigating the effectiveness of the prioritization of their maintenance backlog strategy. Exelon has entered this issue into their corrective action program (CAP) as Issue Report (IR) 1569901. Exelons corrective actions to address the inadvertent depressurization of the Unit 1 IA headers on October 9, 2012, were ineffective and untimely, representing a performance deficiency that was within their ability to foresee and correct. This performance deficiency was determined to be more than minor because it affected the Equipment Performance attribute of the Initiating Events cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, unnecessary transients on the IA header increase the likelihood of a loss of IA, an unplanned down power or a potential rapid plant shutdown due to plant instability. The finding is of very low safety significance (Green) per IMC 0609, Appendix A, Exhibit 1 - Initiating Events Screening Questions, because it did not involve the complete or partial loss of a support system that contributes to the likelihood of, or cause, an initiating event and affected mitigation equipment. The finding had a cross-cutting aspect in the area of Human Performance, Resources, because Exelon did not ensure that personnel, equipment, procedures, and other resources were adequate to assure nuclear safety. Specifically, Exelon did not adequately maintain engineering and maintenance backlogs to support safety, which led to IRs (1426043 and 1426045) to check the operation of the Unit 1 IA dryer pre-filter D/P switches not being performed in a timely manner (H.2(a)). Exelon did not complete work associated with these IRs and failed to utilize internal operating experience concerning the creation of a time-based preventative maintenance (PM) in order to replace the pre-filters and functionally check the D/P switches prior to conducting maintenance.
05000352/FIN-2013007-03Licensee-Identified Violation2013Q2License Condition 2.C.(3) for Limerick Generating Station Unit 1 and Unit 2 states that, Exelon Nuclear shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the UFSAR. Appendix 9A, Section 9A.3.1.1, Item 72 states, Fire damage should be limited so that one train of systems necessary to achieve and maintain hot shutdown conditions . . . is free of fire damage. Contrary to the above, until November 3, 2012, the D22 output breaker control circuit would potentially be damaged by a fire in area 67W and the D22 output breaker was credited for safe shutdown in area 67W. Exelon entered this issue into the CAP (IR 1422043). The issue was more than minor because it was associated with the protection against external events (fire) attribute of the mitigating systems cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The team determined that the finding was of very low safety significance (Green), based on IMC 0609, Appendix F, Fire Protection Significance Determination Process (SDP), Phase 2 screening, task number 2.3.5 because the cable was routed in conduit predominately through a transient combustible free zone. Additionally, the cable was not routed near a credible fire ignition source in the fire area.
05000352/FIN-2013007-02Failure to Establish Preventive Maintenance for Safe Shutdown Transfer/Isolation Switches2013Q2The NRC identified a Green finding for the failure to establish a preventive maintenance strategy for fire safe shutdown transfer/isolation switches in accordance with the Exelon procedure ER-AA-200, Preventive Maintenance Program. As a result, Exelon failed to ensure that the local control circuits for several 4KV breakers would be isolated from the effects of fire damage. In response to this issue, Exelon generated IR 01515025, and initiated actions to evaluate the switches and implement appropriate maintenance programs. This finding was more than minor because it was associated with the protection against external factors (fire) attribute of the mitigating systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, by failing to establish a preventive maintenance strategy for fire safe shutdown transfer/isolation switches, Exelon did not ensure that the local control circuits for several 4KV breakers would be isolated from the effects of fire damage. The team determined that the finding was of very low safety significance (Green), based on IMC 0609, Appendix F, Fire Protection Significance Determination Process, task number 1.3.1 because Exelon had demonstrated a reasonable expectation of functionality for these switches by recently testing comparable switches. The finding did not have a crosscutting aspect because it was not indicative of current performance.
05000352/FIN-2013007-01Inadequate Fire Brigade Transportation2013Q2The NRC identified a Green, Non-Cited Violation (NCV) of License Condition 2.C.(3) of the Limerick Generating Station operating license, in that Exelon did not provide adequate procedural guidance for transporting the fire brigade and equipment to the spray pond pump house. Specifically, the existing fire procedure had incorrect guidance which would have needlessly delayed the fire brigade response. In response to this issue, Exelon initiated IR 1511763 and took prompt action to revise the affected procedures. The finding was more than minor because it negatively affected the protection against external factors (fire) attribute of the mitigating systems cornerstone as related to the objective of ensuring the reliability and availability of the Essential Service Water pumps and Residual Heat Removal Service Water pumps. The finding was determined to be of very low safety significance (Green) in accordance with Section D of Exhibit 2 in Appendix A of IMC 0609, The Significance Determination Process for Findings at Power, because the fire brigades response time was mitigated by other defense-in-depth elements such as: area combustible loading limits were not exceeded, installed fire detection systems were functional, and alternate means of safe shutdown were not impacted. The finding did not have a cross-cutting aspect because it was not indicative of current performance.
05000352/FIN-2013003-03Failure to Follow Partial Procedure Change Process2013Q2A self-revealing Green finding of TS 6.8, Procedures and Programs , was identified because Exelon personnel did not implement procedure use and adherence requirements when operators changed the scope of work for surveillance testing of main turbine stop and control valves. This resulted in a reactor protection system automatic scram on April 16, 2013. This issue was identified in the Exelon CAP as IRs 1503749 and 1525552. The failure of station operators to follow the partial procedure performance process during the performance of two TS required surveillances was a performance deficiency that was reasonably within Exelons ability to foresee and correct and could have been prevented. The performance deficiency was also contrary to Exelons procedure use and adherence requirements. This finding was more than minor because, if improper implementation of the partial procedure performance process is left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern such as a more severe plant transient or engineered safeguard system actuation or malfunction. Additionally, this issue is similar to example 4.b in IMC 0612, Appendix E, Examples of Minor Issues, in that the procedural error resulted in a reactor scram or other transient. The finding was determined to be self-revealing because it was revealed through the receipt of a scram signal during performance of a surveillance test which required no active and deliberate observation by Exelon personnel. The finding was determined to be of very low safety significance (Green) in accordance with Appendix G of IMC 0609, Shutdown Operations Significance Determination Process, because the finding did not require a quantitative assessment. A quantitative assessment was not required because the finding did not increase the likelihood of a loss of reactor coolant system inventory or degrade the ability to recover decay heat removal if it was lost. This finding had a cross-cutting aspect in the area of Human Performance, Decision Making, because Exelon did not ensure that personnel made safety-significant or risk-significant decisions using a systematic process to ensure that safety is maintained (H.1(a)). Specifically, the partial procedure performance process was not properly implemented which resulted in plant conditions that were improper for the next evolution. This resulted in a reactor protection system automatic scram on April 16, 2013.
05000352/FIN-2013003-02Failure to adhere to radiation protection procedures for evacuation of the Unit 2 upper drywell in preparation for irradiated component moves2013Q2The inspectors identified a self-revealing finding of very low safety significance associated with failure to comply with TS 6.8, Procedures and Programs. Specifically, the inspectors identified Exelon personnel failed to implement radiation protection procedure requirements associated with clearance of personnel from the upper levels of the Unit 2 reactor drywell in preparation for removal and movement of irradiated core component from the Unit 2 reactor vessel. Exelon personnel entered this issue into their CAP as IR 1495585. The failure to adhere to TS required radiation protection procedures for personnel exposure control related to irradiated core component movement is a performance deficiency. The performance deficiency was determined to be more than minor because it was related to the Programs and Process attribute of the Occupational Radiation Safety Cornerstone, and adversely affected the cornerstone objective to ensure adequate protection of worker health and safety from exposure to radiation from radioactive material during routine reactor operation. Further, if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern if personnel were locked in the area and irradiated hardware dropped above their work location. The finding was not subject to traditional enforcement because it was not associated with a violation that impacted the regulatory process and did not contribute to actual safety consequences. The finding was assessed using IMC 0609, Appendix C, 2 Enclosure Occupational Radiation Safety SDP, dated August 19, 2008, and was determined to be of very low safety significance (Green) because it was not related to As-Low-As-Is-Reasonably-Achievable (ALARA), did not result in an overexposure or a substantial potential for overexposure, and did not compromise the licensee\'s ability to assess dose. This finding was associated with the Work Control aspect of the Human Performance cross-cutting component. Specifically, Exelon staff did not effectively coordinate this work activity by incorporating actions to address the impact of the work on different job activities, and the need for work groups to maintain interfaces and communicate, coordinate, and cooperate with each other during activities in which interdepartmental coordination is necessary to assure plant and human performance.
05000352/FIN-2013003-01Failure to Identify and Correct a Condition Adverse to Quality Associated with Emergency Diesel Generator D242013Q2The inspectors identified a Green NCV of 10 Code of Federal Regulation (CFR) 50, Appendix B, Criterion XVI, Corrective Action , because Exelon personnel did not identify and correct a condition adverse to quality associated with emergency diesel generator (EDG) D24 lubricating oil pipe fitting supports. This resulted in EDG D24 being in a degraded condition from November 2012 until the condition was corrected in May 2013. Exelon personnel entered this issue into the corrective action program (CAP) as issue reports (IRs) 1507365, 1509125, 1511869, 1512745, 1526780, and 1528088. The failure of Exelon personnel to identify and correct the degraded instrument line pipe fitting support and insert on EDG D24s lubricating oil supply pressure sensing line following the failure of a pipe fitting on November 13, 2012 is a performance deficiency that was reasonably within Exelons ability to foresee and correct. The IR written to document the issue (IR 1439284) was inappropriately classified as not a critical component failure. This resulted in the issue receiving a lower level of investigation (work group evaluation versus an apparent cause or root cause evaluation). This NRC-identified finding was more than minor because it is associated with equipment performance and affected the Mitigating System cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating event to prevent undesirable consequences. The inspectors evaluated the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power, to IMC 0609, Significance Determination Process. Exelon personnel conducted vibration testing which determined that the pipe fitting crack initiation and propagation occurred during engine slow start speed acceleration. This was based vibration data which showed two vibration peaks at speeds during the acceleration. Also, the crack did not propagate during normal speed operation based on the fact that the leak size did not increase during monthly testing on April 27, 2013. The inspectors determined this finding did not represent an actual loss of function of a single train for greater than it Technical Specification Allowed Outage Time. Therefore, the inspectors determined the finding to be of very low safety significance.
05000352/FIN-2013002-02Licensee-Identified Violation2013Q110 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, states, in part, that, In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. Contrary to the above, Exelon staff completed corrective actions in response to previously identified pre-conditioning concerns with the collection of the safeguard battery charger TS ST as-found data that was ineffective at precluding reoccurrence of the safeguard battery charger preconditioning. Specifically, the corrective action to revise the safeguard battery charger maintenance procedure did not ensure the as-found current limit setpoint was recorded prior to the cleaning, inspection and potential manipulation of the control circuit cards, which can have a significant impact on the as-found current limit setpoint. This ineffective corrective action lead the site to repeat the potential preconditioning of the safeguard battery chargers for nearly 10 years and called into question whether or not the safeguard battery chargers would perform satisfactorily when in service. Exelon personnel entered the issue into the corrective action program as IR 1478866 and have revised the maintenance procedure to include recording the as-found current limit setpoint prior to any other battery charger manipulation. Because the violation was of very low safety significance (Green) and it was entered into Exelons corrective action program, the violation is being treated as a non-cited violation.
05000352/FIN-2013002-01Failure to Adequately Assess Battery Charger Operability in a Timely Manner2013Q1The inspectors identified a Finding (FIN) of very low safety significance (Green) for the failure to adequately assess the operability of multiple safeguard battery chargers in a timely manner after an issue report (IR) was generated for battery charger testing concerns. Specifically, although the IR documented as-found current limit settings for safeguard battery chargers that were below Technical Specification (TS) minimum values, the operability basis documented that no operability concern existed because the battery chargers had passed their most recent TS surveillance tests and no explanation for the unexpected test results was given. Following questions from the inspectors regarding the operability bases of the battery chargers, Exelon staff performed an in-depth operability determination which factored in battery charger maintenance history, preventive maintenance practices, past operating experience, and vendor input. Exelon personnel entered this issue into their corrective action plan (CAP) as IR1486275 and plan to perform an evaluation to address the shortcomings in the initial operability determination. The performance deficiency was more than minor because it was associated with the Human Performance attribute of the Mitigation Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). This finding was also similar to examples 3.j and 3.k of IMC 0612, Appendix E. Specifically, in the absence of any further engineering evaluation, there was reasonable doubt of operability of multiple safeguard battery chargers at power operations. This finding was evaluated in accordance with NRC IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, and determined to be of very low safety significance (Green) because the finding does not affect the operability of the system, does not represent a loss of system and/or function, and does not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time. The inspectors determined the finding has a crosscutting aspect in Human Performance, Decision-Making, because Exelon personnel did not make a safety-significant decision using a systematic process, especially when faced with uncertain or unexpected plant conditions, to ensure that safety was maintained. Specifically, Exelon personnel did not adequately assess the operability of multiple safeguard battery chargers in a timely manner after an IR was generated for battery charger testing concerns that called into question the operability of safeguard battery chargers (H.1(a)). Enforcement action does not apply because the performance deficiency did not involve a violation of a regulatory requirement.
05000352/FIN-2012005-03Failure to Follow Radiation Protection Procedures for Personnel Monitoring2012Q4NRC Letter, dated October 18, 2012 (ML12292A140), documented an NRC Office of Investigation review to determine whether a contract foreman deliberately failed to follow procedures on the use of electronic dosimetry while at Limerick (NRC Investigation Report Number 1-2012-030). The NRC concluded that the contract foreman deliberately failed to follow an NRCrequired procedure (RP-AA-1008) regarding the use of dosimetry and that the issue was being treated as an NCV. In order to facilitate entering this issue into the NRCs Plant Issues Matrix and assessment process this issue is identified as NCV 05000352, 353/2012005-03, Failure to Follow Radiation Protection Procedures for Personnel Monitoring.
05000352/FIN-2012010-01Failure to Take Timely Corrective Actions to Address the 144D Load Center ODM Contingency Actions2012Q4The inspectors identified a finding of very low safety significance (Green) for Exelons failure to complete an evaluation of the off-normal bus alignment prior to the summer period. Consequently, on July 18, 2012, LGS experienced a fault of the 124A load center (LC) transformer which led to an unplanned manual scram. Exelons root cause evaluation for this event identified that a contributing cause was the electrical configuration being in an off-normal bus alignment (114A LC cross-tied to the 124A LC) for an extended period due to the failure of the 144D transformer, which placed more load on the degraded 124A connection and contributed to its failure. Exelon has entered the issue into the corrective action program (AR 1437657). This finding was more than minor because it is similar to examples 4.f and 4.g of IMC 0612, Appendix E, Examples of Minor Issues, in that operators inserted a manual scram per procedural requirements following the loss of the reactor recirculation pumps (RRP) associated with the 124A LC transformer failure. Additionally, the finding was more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. This finding was of very low safety significance (Green) because the finding did cause a reactor trip but did not cause a loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. This finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Exelon did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity (P.1(d)). Specifically, Exelons failure to restore the normal 124A LC alignment or evaluate the effects of continuing the off-normal alignment during the summer period in a timely manner placed additional loading on the transformer contributing to the failure.
05000352/FIN-2012007-02480V Motor Control Circuit Breaker Overcurrent Protection2012Q4The team identified a finding of very low safety significance (Green) involving a non-cited violation of Limerick Generating Station License Condition 2.C.(3), Fire Protection, which states Exelon Generation Company shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the UFSAR. Specifically, the team found that Exelon\'s multiple high impedance fault (MHIF) analysis, developed to verify that post-fire safe shutdown equipment would remain available, used non-conservative over current trip set points for 480 volt over current protection devices. Specifically, the team found that molded case circuit breaker over current protection did not protect against all possible faults currents that could be present on downstream equipment. As a result, fault current greater than that assumed in the MHIF analysis could propagate past the circuit breaker and trip upstream equipment. Exelon entered the issue into their corrective action program and performed an analysis that showed credited equipment would be available. The team concluded the results of the work performed were reasonable. The team determined that Exelon\'s selection of breaker trip values for use in the MHIF analysis was non-conservative and was a performance deficiency. Specifically, the post-fire safe shutdown MHIF analysis did not use worst case or maximum fault current to verify that fire induced fault currents that propagated past branch feeder circuit breakers would not cause the motor control center source breaker to overload and trip. This issue was more than minor because it was similar to IMC 0612, Appendix E, Examples of Minor issues, Example 3.j, in that the design analysis deficiency resulted in a condition where the team had reasonable doubt of operability of the MCC during a fire. In addition, this issue was associated with the Fire Protection attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The team determined the finding was of very low safety significance (Green) because the finding affected the post-fire safe shutdown category and it had a low degradation rating. This finding did not have a cross-cutting aspect because the design requirements of the breakers had not changed from initial startup and therefore it does not reflect current licensee performance.
05000352/FIN-2012007-01Inadequate Evaluation of Voltage to Safety-Related Equipment with Offsite Power Available2012Q4The team identified a non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion lll, Design Control, which states, in part, design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculation methods, or by the performance of a suitable testing program. The team determined that Exelon did not verify that adequate voltages would be available to safety related equipment powered from the 4kV, 480vac, and 120Yac distribution systems during a design basis loss-of-coolant accident with offsite power available. Specifically, the team found that Exelon assumed a non-conservative offsite power voltage at the start of the event, used a non-conservative assumption for motor starting times, and did not have calculations that determined the minimum voltage level for the 480 Vac and 120Yac distribution level during post event electrical transients. Following questions from the team Exelon entered the issue into their corrective action program, revised existing calculations, performed new calculations, and completed evaluations to ensure that the minimum voltage level that would be reached during an event would be adequate at all three voltage levels. The team reviewed these calculations and evaluations and concluded the results of the work performed during the inspection were reasonable. The team determined that the failure to verify adequate voltages at all voltage levels to safety-related equipment during a design basis loss-of-coolant accident was a performance deficiency. This issue was more than minor because it was similar to IMC 0612, Appendix E, Examples of Minor issues, Example 3.j, in that the design analysis deficiency resulted in a condition where the team had reasonable doubt of operability of the safety-related busses. In addition, it was associated with the design control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The team determined the finding was of very low safety significance (Green) because it was a design or qualification deficiency confirmed not to result in loss of operability or functionality. This finding had a crosscutting aspect in the area of Human Performance, Resources, because Exelon did not provide complete, accurate and up-to-date design documentation to plant personnel and because these calculations had been recently revised.
05000352/FIN-2012005-05Licensee-Identified Violation2012Q410 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis for those structures, systems, and components to which the appendix applies are correctly translated into specifications. Contrary to Criterion III, Exelon failed to correctly translate the design basis for 15 PCIVs on Unit 1 and 15 PCIVs on Unit 2 into specification for the motor operators for the valves. This resulted in the valves not being able to perform their intended safety function under certain conditions following a loss of coolant accident with offsite power remaining available. Exelon entered this issue into the CAP as IR 1402693 and 1416070. The inspectors determined that the finding was of very low safety significance (Green) in accordance with Section B of Exhibit 3 of NRC IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, because it did not represent an actual open pathway in the physical integrity of reactor containment. In addition, all of the effected penetrations, with the exception of two, had another primary containment isolation valve that was not impacted by the design issue. Conservatively processing the two penetrations that did not contain a non-effected valve through NRC IMC 0609, Appendix H, Containment Integrity Significance Determination Process, determined that they were not risk significant from a large early release frequency standpoint. One penetration (suppression pool clean-up suction line) did not connect with the drywell atmosphere or reactor coolant system. The other penetration (reactor water cleanup suction line) is a closed system and the design error would not have affected the ability of the systems primary containment isolation valves to isolate following their design basis event (intersystem loss of coolant accident outside of containment).
05000352/FIN-2012005-04Licensee-Identified Violation2012Q4Technical Specification 6.8.1 states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures as recommended in NRC Regulatory Guide 1.33, Appendix A, Revision 2, February 1978. NRC Regulatory Guide 1.33, Appendix A, Section 8.b requires procedures for surveillance tests. Limerick Unit 2 ST-6-107-590-2, Daily Surveillance Log/OPCONS 1, 2, 3, Table 2, Revision 128, contained the redundant reactivity control system TS surveillance channel checks for the reactor pressure vessel pressure instruments associated with the Anticipated Transient Without Scram Recirculation Pump Trip System Instrumentation. Contrary to TS 6.8.1, ST-6-107- 590-2 acceptance criteria for channel checks associated with these instruments were not adequately established. This resulted in the Unit 2, Division II Anticipated Transient Without Scram Recirculation Pump Trip System Instrumentation being inoperable due to instrument drift from September 8, 2011 until May 10, 2012 which is longer than allowed by TS. Exelon entered this issue into the CAP as IR 1365093. The inspectors determined that the finding was of very low safety significance (Green) in accordance with Section C of Exhibit 2 of NRC IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, because the finding did not affect both a single reactor protection system trip signal to initiate a reactor scram and the function of other redundant trips or diverse methods of reactor shutdown.
05000352/FIN-2012005-02Failure to Revise EDG Tank Cleaning Work Instructions2012Q4A self-revealing Green NCV of Technical Specification 6.8.1, Administrative Controls-Procedures, was identified because Exelon did not implement procedure use and adherence requirements when workers changed the scope of work on emergency diesel generator (EDG) fuel oil day tanks and did not revise the work instructions when they determined that work could not be performed as written. This resulted in EDG D13 accruing approximately 40 hours of unplanned unavailability between December 14 and 16, 2012. Exelon entered the issue into their CAP as IR 1453737, conducted a human performance review board, drained and flushed the tank to restore fuel oil quality, and initiated an ACE. This finding was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was determined to be self-revealing because it was revealed through the receipt of alarms during operation which required no active and deliberate observation by the Exelon staff. The finding was determined to be of very low safety significance (Green) in accordance with Section A of Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings at Power, because the finding did not represent an actual loss of function a single train for greater than the TS allowed outage time. This finding had a cross-cutting aspect in the area of Human Performance, Work Practices, because Exelon did not ensure that personnel followed procedures (H.4(b)). Specifically, work order procedural steps to clean the fuel oil tank were not completed as directed by the work order and a procedurally required change to written work instructions was not implemented when station personnel determined that the fuel oil tank cleaning would be based on the need to clean the tank as determined by tank inspection results.
05000352/FIN-2012005-01Failure to Administer an NRC Annual Operating Test Simulator Scenario Re-examination That Met Procedural Requirements2012Q4The inspectors identified a Green finding of Exelon procedure TQ-AA-150, Operator Training Programs, and TQ-AA-155, Conduct of Simulator Training and Evaluation, based on a determination that the minimum number of scenarios required for simulator re-examination was not administered following a crew failure of the dynamic simulator scenario portion of the annual operating exam during week two of the 2012 Licensed Operator Requalification Training (LORT) Annual Operating Test. Exelon staff entered this finding into their corrective action program (CAP) (IR 1437839), conducted a prompt investigation, assigned an action to complete the annual operating exam scenario set for the crew in question, and initiated an Apparent Cause Evaluation (ACE). The inspectors determined that the finding was more than minor because it was associated with the Human Performance attribute of the Mitigation Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The risk importance of this issue was evaluated using IMC 0609, Appendix I, Licensed Operator Requalification Significance Determination Process (SDP). Based on this screening criteria, the finding (inadequate retest) was characterized by the SDP as having very low safety significance (Green) because crew remediation was conducted and a partial re-evaluation performed. This finding had a cross-cutting aspect in the area of Human Performance, Work Practices, because Exelon did not ensure that personnel followed procedures (H.4(b)). Specifically, the simulator scenario re-exam administered following a failed Annual Operating Test did not meet procedure requirements for number of scenarios.
05000352/FIN-2012012-01Failure to provide complete and accurate decommissioning status reports2012Q4During an NRC investigation completed on November 22, 2011, and a supplemental investigation completed on October 10, 2012, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below: 10 CFR 50.75(a) establishes requirements for indicating to the NRC how a licensee will provide reasonable assurance that funds will be available for the decommissioning process and states that for power reactor licensees, reasonable assurance consists of a series of steps as provided in paragraphs (b), (c), (e), and (f) of 10 CFR 50.75. 10 CFR 50.75(f)(2) states, in part, that power reactor licensees shall report at least every 2 years on the status of its decommissioning funding for each reactor or part of a reactor that it owns; and, that the information in this report must include, at a minimum, the amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c). 10 CFR 50.75(b)(1) states, in part, that for a holder of an operating license under 10 CFR Part 50, financial assurance for decommissioning shall be provided in an amount which may be more, but not less, than the amount stated in the table in paragraph (c)(1) adjusted using a rate at least equal to that stated in paragraph (c)(2). 10 CFR 50.75(c)(1) states the minimum amount required to demonstrate reasonable assurance of funds for decommissioning by reactor type and power level. 10 CFR 50.75(c)(2) requires, in part, that an adjustment factor be applied, which is based on escalation factors for labor and energy, and waste burial. 10 CFR 50.9(a) states, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on March 31, 2005, March 31, 2006, March 31, 2007, and March 31,2009, Exelon Generation Company, LLC (Exelon) provided information on the status of its decommissioning funding that was not complete and accurate in all material respects, when it submitted the decommissioning funding status (DFS) reports pursuant to 10 CFR 50.75. Specifically, the March 31, 2005, March 31, 2007, March 31, 2006, and March 31, 2009, DFS reports stated that the decommissioning funds estimated to be required for each of the reactors, as listed in the report, were determined in accordance with 10 CFR 50.75(b) and the applicable formulas of 10 CFR 50.75(c). However, in multiple instances, the amount reported was a discounted value that was less than the minimum required amount specified by 10 CFR 50.75(b) and (c). This is a Severity Level IV violation.
05000352/FIN-2012004-06Licensee-Identified Violation2012Q3Limerick Unit 1 and Unit 2 TS 6.8.4.d. required that: 1) a Radioactive Effluent Controls Program be provided for the control of radioactive effluents, 2) the program be contained in the ODCM, and 3) that the program be implemented. Limerick Station ODCM, Revision 25, Section 4.2.2.3, requires that cumulative organ doses due to iodine, tritium, and particulates with half-lives greater than 8 days, be determined at least once per 31 days. Contrary to TS 6.8.4 and the ODCM, cumulative total dose to organs was not calculated during the period of approximately November 23, 2010 through October 2011, due to loss of dose factors from a software package. Exelon subsequently calculated bounding dose values after re-loading the factors and determined the projected doses to be well within applicable dose limits. Exelon also provided an update to its 2010 annual effluent release report. This finding was assessed for significance using IMC 0609, Appendix D, Public Radiation Safety Significance Determination Process, and determined to be of very low safety significance because: there was no spill or release event; the issue was contrary to Technical Specifications and a radioactive effluent release program deficiency; secondary radioactive effluent monitoring and controls program elements provided for control of effluents releases; although organ doses were slightly underestimated, projected doses did not exceed applicable limits, including ALARA design specifications of 10 CFR 50, Appendix I; there was no effluent monitor calibration issue; and the licensee had data by which to assess dose to a member of the public. Because this issue was determined to be of very low risk significance (Green), and Exelon has entered this issue into the CAP as IR 1297197, this issue is being characterized as a licensee identified NCV.
05000352/FIN-2012004-05Licensee-Identified Violation2012Q3Technical Specification 6.8, Procedures and Programs states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures as recommended in NRC RG 1.33, Appendix A, February 1978. NRC RG 1.33, Appendix A, Section 8, requires procedures for the performance of surveillance tests. Contrary to the above, on July 19, 2012, Surveillance Test ST-6-047-471, Pre-control Rod Withdrawal Check and CRD Exercise OPCONs 3 and 4 with No Core Alterations, was not properly implemented. Specifically, surveillance steps which verified that the source range and intermediate range nuclear instruments were within their required test frequency were completed incorrectly. This resulted in the reactor mode switch being placed in the Refuel position without all the required TS surveillance tests being within their required frequency. Exelon entered this issue into the CAP as IR 1390866. The inspectors determined that the finding was of very low safety significance (Green) in accordance with NRC IMC 0609, Appendix G, Shutdown Operations Significance Determination Process, because the finding did not represent a finding that required quantitative assessment.
05000352/FIN-2012004-04Failure to Establish and Perform Adequate Preventive Maintenance on 480VAC Load Center Power Transformers2012Q3A self-revealing NCV of Limerick Technical Specification (TS) 6.8, Procedures and Programs, was identified for failure to establish and perform adequate preventive maintenance (PM) activities to routinely inspect the 480 volt-alternating current (VAC) load center power transformers. As a result, Limerick experienced a transformer related fault that could have been prevented by PM which resulted in a manual reactor scram of Unit 1 on July 18, 2012. Corrective actions implemented by Limerick as a result of this transformer failure included advancing the thermography window installation schedule to align with each transformers feeder breaker trip test calibration. Limerick also performed thermography inspections on the other load center transformers and developed corrective actions (Issue Report (IR) 1355930 and 1390033) to reinstitute the clean and inspect PM on all load center transformers at an increased frequency of 8 years vice 20 years. The finding was determined to be more than minor because it was associated with the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The finding was determined to be of very low safety significance because the finding caused a reactor trip but not the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. This finding was determined to have a cross-cutting aspect because, although the performance deficiency occurred more than three years ago, the performance characteristic associated with ineffective PM implementation continues to exist within Limericks PM program and is indicative of present performance. The cross-cutting aspect associated with this performance deficiency is in the Resources component of the Human Performance area because the licensee did not ensure that personnel, equipment, procedures and other resources were adequate to assure long term plant safety through maintenance and the minimization of long-standing equipment issues
05000352/FIN-2012004-03Inadequate Post Maintenance Testing Following Circuit Breaker Replacement2012Q3A self-revealing NCV of TS 6.8, Procedures and Programs, was identified because Exelon did not maintain adequate maintenance procedures associated with work performed on the Unit 2 B residual heat removal (RHR) pump motor circuit breaker. Specifically, Exelon did not perform appropriate post maintenance testing following the replacement of the Unit 2 B RHR pump breaker on November 30, 2011. Despite the circuit breaker replacement affecting necessary pump support equipment operation due to circuit breaker dimensional differences, the procedure did not require a check to assure the support equipment was not adversely affected following the installation. As a result, the Unit 2 B RHR pump was inoperable for the low pressure coolant injection function when the pump was operating in the suppression pool cooling mode because the pumps minimum flow valve would not have opened automatically following the receipt of a loss of coolant accident signal. This condition existed from November 30, 2011 until the condition was corrected on June 27, 2012. This issue was entered into the Exelon CAP as IR 1381792. This self-revealing finding was determined to be more than minor because it is associated with the procedure quality attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was determined to be of very low safety significance (Green) because it did not represent a loss of system function and did not represent an actual loss of function for two separate safety systems out-of-service for greater than its TS Allowed Outage Time. The finding had a cross-cutting aspect in the area of Human Performance, Resources, because Exelon did not provide work packages with sufficient detailed instructions to assure nuclear safety
05000352/FIN-2012004-02Failure to Immediately Reduce Reactor Power Per Alarm Response Procedure2012Q3The inspectors identified a cited violation of very low safety significance (Green) of TS 6.8, Procedures and Programs, because Limerick operators did not adequately follow an alarm response procedure when responding to a MCR alarm on July 11, 2012. Specifically, the operators failed to immediately reduce power per the alarm response card (ARC) procedure, ARC-MCR-107-A2, Turbine Control Valve / Stop Valve Scram Bypassed, after the MCR received the alarm condition. The operators decided to delay the immediate reduction in reactor power to validate the control room alarm indication. Overall, it took operators one hour and forty-nine minutes to commence reducing reactor power per procedure. This finding is being cited because not all of the criteria specified in Section 2.3.2.a of the NRC Enforcement Policy for a non-cited violation were satisfied in that Exelon failed to restore compliance within a reasonable amount of time after the violation was identified. Specifically, the violation was communicated to Exelon Management by the inspectors on August 22, 2012. However, this violation was not entered into the Exelon CAP, as IR 1429761, until October 22, 2012 and no interim corrective actions were identified until Standing Order 12-08 was issued on October 22, 2012 to provide operator guidance, 103 days after the initial event. The finding was determined to be more than minor because it affected the human performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, it resulted in operators not reducing reactor power immediately as required for reactor protection. The inspectors determined this finding did affect a single RPS trip signal but did not affect the function of other redundant trips or diverse methods of reactor shutdown, did not involve control manipulations that unintentionally added positive reactivity, and did not result in a mismanagement of reactivity by operators. Therefore, the inspectors determined the finding to be of very low safety significance (Green). This finding had a cross-cutting aspect in the area of Human Performance, Work Practices, because operators did not follow procedures
05000352/FIN-2012004-01Failure to Enter Technical Specifications in a Timely Manner2012Q3The inspectors identified a NCV of very low safety significance (Green) of TS 3.3.1.1, Reactor Protection System (RPS) Instrumentation, because Limerick operators did not enter the required TS action in a timely manner in response to an RPS instrumentation line failure. Specifically, following the main control room (MCR) receipt of the Unit 1 Turbine Control Valve / Stop Valve Scram Bypassed alarm and equipment operator verification that the C and D channels of RPS circuitry were potentially bypassed indicating a possible loss of RPS function, action by the MCR operators to enter the applicable TS action statement was delayed by over an hour while RPS electrical prints were reviewed to verify inputs to the RPS circuitry. This issue was entered into Exelons CAP as IR 1387851 and an apparent cause evaluation was conducted. The finding was determined to be more than minor because it is associated with the human performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, operators did not reduce thermal power within 15 minutes as required for reactor protection. The inspectors determined this finding did affect a single RPS trip signal but did not affect the function of other redundant trips or diverse methods of reactor shutdown, did not involve control manipulations that unintentionally added positive reactivity, and did not result in a mismanagement of reactivity by operators. Therefore, the inspectors determined the finding to be of very low safety significance (Green). This finding had a cross-cutting aspect in the area of Human Performance, Decision-Making, because operators did not use conservative assumptions in decision making and promptly apply readily available information contained in the ARC, TS Bases, and equipment operator reports to determine TS applicability for the alarm condition
05000353/FIN-2012008-02Violation of TS 3.5.1 and 3.0.32012Q2The inspectors determined that the failure to revise LER 05000353/2011-003-00 within 60 days of July 21, 2011, to include the violations of TS 3.5.1 and 3.0.3 in accordance with 10 CFR Part 50.73 was a performance deficiency that was reasonably within Exelons ability to foresee and correct, and should have been prevented. Because the issue impacted the regulatory process, in that a violation of Technical Specifications was not reported to the NRC within the required timeframe and the NRCs opportunity to review the matter in its entirety was delayed, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process. Using example 6.9.d.9 from the NRC Enforcement Policy, the inspectors determined that the performance deficiency was a SL-IV violation, because Exelon personnel failed to make a report required by 10 CFR Part 50.73 when information that the report was required had been reasonably within their ability to have identified. The significance of the associated performance deficiency was screened against the ROP per the guidance of IMC 0612, Appendix B, and the inspectors determined it to be minor because it was not similar to Appendix E examples, was not a precursor to a significant event, did not cause a PI to exceed a threshold, did not adversely affect cornerstone objectives, and if left uncorrected would not have lead to a more significant safety concern. As such, no ROP finding was identified and no crosscutting aspect was assigned.
05000352/FIN-2012403-01Security2012Q2
05000352/FIN-2012003-01Failure to Conduct Timely Corrective Actions to Replace Age Degraded Relays2012Q2The inspectors identified that a Green NCV of 10 Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, occurred because the licensee did not conduct timely corrective actions to address age-related degradation of direct current motor operated valve (DC MOV) relays. Specifically, Limerick experienced multiple age-related failures of ARD type relays that were known to be susceptible to age-related degradation and were beyond their vendor recommended lifetime. The licensee did not prioritize replacement of the relays which led to the relay replacement preventative maintenance (PM) to be scheduled as much as eight years past their vendor recommended lifetime. The inspectors determined that the licensee not conducting timely corrective actions to address age degradation of safety-related DC MOV relays was a performance deficiency. The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The finding was determined to be of very low safety significance (Green) using Attachment 4 to IMC 0609, Significance Determination Process, because the untimely corrective actions did not result in an actual loss of safety function. The finding has a cross-cutting aspect in the corrective action component of the problem identification and resolution area because the licensee did not thoroughly evaluate problems such that the resolutions address causes and extent of conditions, as necessary, including properly classifying, prioritizing, and evaluating for operability and reportability conditions adverse to quality.
05000353/FIN-2012008-01Failure to Submit an LER Revision for Conditions Prohibited by TS Associated with the HPCI and RCIC Systems2012Q2The inspectors identified a SL-IV non-cited violation (NCV) of 10 CFR Part 50.73, Licensee Event Report System, because violations of Technical Specifications (TS) 3.5.1 and 3.0.3 for the condition of the high pressure coolant injection (HPCI) and RCIC systems being simultaneously inoperable were not reported to the NRC within 60 days of discovery. After this was identified by the inspectors, the issue was entered into Exelons Corrective Action Program (CAP) as IR 1377559. The inspectors determined that the failure to revise Licensee Event Report (LER) 05000353/2011-003-00 within 60 days of initial issuance on July 21, 2011 to include the violations of TS 3.5.1 and 3.0.3 in accordance with 10 CFR Part 50.73 was a performance deficiency that was reasonably within Exelons ability to foresee and correct, and should have been prevented. Because the issue impacted the regulatory process, in that a violation of Technical Specifications was not reported to the NRC within the required timeframe and the NRCs opportunity to review the matter in its entirety was delayed, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process. Using example 6.9.d.9 from the NRC Enforcement Policy, the inspectors determined the performance deficiency was a SL-IV violation, because Exelon personnel did not make a report required by 10 CFR Part 50.73. The significance of the associated performance deficiency was screened against the ROP per the guidance of IMC 0612, Appendix B, and the inspectors determined it to be minor because it was not similar to Appendix E examples, was not a precursor to a significant event, did not cause a performance indicator (PI) to exceed a threshold, did not adversely affect cornerstone objectives, and if left uncorrected would not have lead to a more significant safety concern. As such, no ROP finding was identified and no cross-cutting aspect was assigned.
05000352/FIN-2012002-03Licensee-Identified Violation2012Q1A violation of Limerick Unit 2 Technical Specification 6.12.2, which states, in part: For High Radiation Areas with dose rates greater than 1.0 rem/hr (at 30 cm), but less than 500 rad/hr (at 1 meter) shall be controlled as follows: a. Each accessible entryway to such an area shall be conspicuously posted as a High Radiation Area and shall be provided with a locked door, gate, or guard that prevents unauthorized entry. RP-AA-460, Controls for High and Locked High Radiation Areas, implements this requirement. Attachment 6 of RP-AA-460, states, in part: 1). Item 1: REMAIN outside the assigned area and MAINTAIN direct line-ofsight surveillance of the access to the LHRA... 2). Item 7: Prior to transferring Access Control Guard responsibilities, verify that the individual has a signed copy of this form (for a non-RP relief individual) and that the new Access Control Guard is aware of the conditions of the work area. Contrary to the above, on April 14, 2011, a technician filling the role of a LHRA access control guard for the LHRA associated with the Unit 2 drywell equipment hatch, left the post unguarded for several minutes. An OI investigation determined that the technicians actions did not constitute deliberate misconduct; however, the NRC confirmed that the TS had been violated. The violation is similar to IMC 0612, Appendix E, example 6g which states an HRA access not controlled in accordance with procedures is more than minor if a radiation area of greater than 100mrem/hr at 30 cm actually existed in the area. This violation is of very low safety significance since, there is no evidence anyone attempt to gain access while the access point was unguarded was short, the duration of time the access was unguarded, and the presence of cameras which allowed for remote monitoring. Exelon enter the issue into their CR process as IR 1202506.
05000352/FIN-2012002-02Licensee-Identified Violation2012Q110 CFR 50.54(q) requires, in part, that a power reactor licensee follow an Emergency Plan that meets the requirements of 10 CFR 50.47(b). 10 CFR 50.47(b) requires, in part, that a standard emergency classification and action level scheme, the bases of which includes facility system and effluent parameters, is in use by the licensee. Contrary to the above, between May 2011 and February 2012, Exelon did not have a documented basis for a useable parameter for the declaration of a General Emergency (GE) using the LGS South Stack effluent radiation monitor. In May 2007, Exelon implemented Revision 11 of EP-AA-1008, Radiological Emergency Plan Annex for Limerick Generating Station, which updated the station emergency action levels (EALs) to the NEI 99-01, Revision 4, standard. The new LGS EAL scheme changed the South Stack GE declaration threshold from 8.84E-2 uCi/cc to 2.71E-1 uCi/cc, yet the Updated Final Safety Analysis Report listed the upper limit of that monitor as 1E-1 uCi/cc. Exelon discovered the discrepancy on February 9, 2012, and entered it into their CAP as IR 1324991. Exelon implemented immediate corrective actions by lowering the GE declaration threshold to 9E-2 uCi/cc, and by contacting the monitor vendor to determine the actual indicating capability of the monitor. The vendor informed Exelon that it believed the monitor was capable of displaying an accurate indication through the entire decade of 1E-1 uCi/cc, that 1E-1 was not the upper limit of indication. Exelon developed a work order and conducted an electronic test of the monitor itself on February 14, 2012, and a system test of the sensor and monitor using a calibrated radioactive source on February 16, 2012. The results of those tests indicated that the monitor was capable of accurately indicating 2.71E-1 uC/cc. The inspectors determined that the finding was of very low safety significance (Green) in accordance with NRC IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, Sheet 1, because, although the licensee had not maintained their EALs as required by 10 CFR 50.47(b), the resultant failure would not have precluded the declaration of any GE event.
05000352/FIN-2012002-01Failure to Make a 10 CFR 50.72 (b)(2)(xi) Notification2012Q1The inspectors identified a Severity Level (SL) IV NCV of 10 Code of Federal Regulations (CFR) 50.72(b)(2)(xi) because the NRC Operations Center was not notified via the Emergency Notification System (ENS) within four hours of a reportable event related to the health and safety of the public and protection of the environment for which notification to other government agencies was made. Exelon did make a courtesy notification to the NRC resident inspection staff. However, Exelon did not formally report, to the NRC Operations Center, the notification of other government agencies regarding an abnormal radioactive liquid release, from the Limerick Generating Station common cooling tower blow down line on March 19, 2012. Inspectors performed system walkdowns and conducted an event follow-up inspection on March 20, 2012 to assess the impacts of the overflow event. This deficiency was evaluated using the traditional enforcement process since the failure to make a required report could adversely impact the NRCs ability to carry out its regulatory mission. The deficiency was evaluated using the criteria contained in Section 6.9(d)(9) of the NRCs Enforcement Policy and determined to meet the criteria for disposition as a SL IV NCV. Exelon took immediate corrective actions pertaining to the abnormal release, including suspension of effluent releases via the cooling tower blow down line and initiation of actions to evaluate the cause and preclude recurrence, as well as the conduct of public dose calculations. Additionally, upon identification by the NRC that the issue was reportable, Exelon subsequently reported the event to the NRC Operations Center on April 11, 2012. Exelon also entered this issue into its corrective action program (IR 1347829). This violation involved a failure to make a required report to the NRC and is considered to impact the regulatory process. Such violations are dispositioned using the traditional enforcement process instead of the Significance Determination Process. Using the Enforcement Policy Section 6.9, lnaccurate and Incomplete Information or Failure to Make a Required Report, example (d)(9), which states, A licensee fails to make a report required by 10 CFR 50.72 or 10 CFR 50.73, the NRC determined that this violation is more than minor and categorized as a SL lV violation. Because this violation involves the traditional enforcement process with no underlying technical violation that would be considered more than minor in accordance with IMC 0612, a cross-cutting aspect is not assigned to this violation.
05000352/FIN-2011007-01Failure to Evaluate Station Blackout Timeline for EDG Availability2011Q4The team identified a non-cited violation of 10 CFR 50.63, Loss of All Alternating Current (AC) Power, because Exelon did not demonstrate that the alternate AC (AAC) source could provide acceptable capability to withstand a station blackout (SBO) within the analyzed coping timeline. Specifically, Exelon\'s evaluation of the Limerick Generating Station\'s excess emergency diesel generator (EDG) capacity did not analyze the effects of the loss of an operating emergency service water (ESW) pump following a single failure on the non-blacked out unit. The loss of the ESW pump would result in loss of cooling to one of the three credited EDGs and a subsequent high temperature trip of the EDG. The team determined the time delay to reset this trip had not been evaluated and that Exelon had not performed the timed test required by 10 CFR 50.63 to show that actions required to provide power to the blacked-out unit from the AAC could be performed within the analysis requirements. As a result, the team concluded that Exelon did not demonstrate that the MC source would have the required availability and capability within the analyzed timeline. Exelon entered the issue into their corrective action program for evaluation and resolution. This issue was more than minor because it is associated with the design control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The team determined the finding was of very low safety significance because it was a design or qualification deficiency confirmed not to result in a loss of functionality. The finding had a cross-cutting aspect in the area in the area of Problem ldentification and Resolution, Corrective Action Program Component, because Exelon did not thoroughly evaluate problems such that resolutions address causes and extent of conditions and did not conduct effectiveness reviews to ensure problems are resolved. Specifically, Exelon\'s recent safety evaluation did not evaluate problems associated with a loss of an EDG due to a high temperature condition and the impact on the SBO AAC power source availability.
05000352/FIN-2011005-01Inadequate Corrective Actions for a Previous NRC Finding for Programmatic Deficiencies in the Preventive Maintenance Program2011Q4The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for failure to implement adequate corrective actions for a previous NRC-identified finding. The previous finding involved a failure to perform adequate preventive maintenance (PM) on an emergency diesel generator (EDG) due to site engineers not being fully aware of new PM requirements developed by Exelon corporate. The lack of proper PM led to a failure of an EDG in May 2010. In response to the previous finding, Limerick performed an apparent cause evaluation (ACE) and developed actions to address the causes and extent of condition. However, the inspectors identified that the actions were not properly implemented, and, as a result, the deficiency identified by the inspectors was not fully resolved. Exelon entered the issue in the Corrective Action Program (CAP) for resolution. The inspectors determined that the failure to implement adequate corrective actions for a previous NRC-identified finding was a performance deficiency. The issue is more than minor because, if left uncorrected, it could become a more significant safety concern. Specifically, the issues identified by the inspectors impacted Limerick\'s ability to establish and implement appropriate PM for equipment relied on for safe operation of the plant. Until the issues are fully resolved, Limerick continues to be vulnerable to gaps in their PM program. This issue affects all sites in the Exelon fleet. The finding was determined to be of very low safety significance (Green) using Attachment 4 to IMC 0609, Significance Determination Process, because the incomplete corrective actions did not result in an actual loss of safety function. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because Exelon failed to implement appropriate corrective actions for a previous NRC-identified finding in timely manner.
05000352/FIN-2011503-02Changes to EAL Basis Decreased the Effectiveness of the Plan without Prior NRC Approval.2011Q3The inspector identified a finding of very low safety significance involving a Severity Level IV NCV of 10 CFR 50.54(q) for failing to obtain prior approval for an emergency plan change which decreased the effectiveness of the plan. Specifically, the licensee modified the Emergency Action Level (EAL) Basis in EAL HU6, Revision 13, which indefinitely extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm. This change decreased the effectiveness of the emergency plan by reducing the capability to perform a risk significant planning function in a timely manner. The violation affected the NRC\\\'s ability to perform its regulatory function because it involved implementing a change that decreased the effectiveness of the emergency plan without NRC approval. Therefore, this issue was evaluated using Traditional Enforcement. The NRC determined that a Severity Level IV violation was appropriate due to the reduction of the capability to perform a risk significant planning standard function in a timely manner. The licensee entered this issue into its corrective action program and revised the EAL basis to restore compliance. The finding was more than minor using IMC 0612, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Therefore, the performance deficiency was a finding. Using IMC 0609, Appendix B, the inspector determined that the finding had a very low safety significance because the finding is a failure to comply with 10 CFR 50.54(q) involving the risk significant planning standard 50.47(b)(4), which, in this case, met the example of a Green finding because it involved one Unusual Event classification Due to the age of this issue, it was not determined to be reflective of current licensee performance and therefore a cross-cutting aspect was not assigned to this finding.
05000352/FIN-2011004-04Licensee-Identified Violation2011Q310 CFR 50.54(q) requires, in part, that a power reactor licensee follow an emergency plan that meets the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. Contrary to the above, Exelon did not make timely notification when the emergency action level threshold was met for HU5, Natural and Destructive Phenomena Affecting the Protected Area. Specifically, Exelon operators did not declare an Unusual Event within the required fifteen minutes of the earthquake felt onsite on August 23. The actual declaration was nine minutes late. At 1:51 PM, control room operators received a Seismic Monitor System Recording Activated alarm coincident with reports of seismic activity felt by station personnel. The seismic monitoring system at Limerick had previously been declared inoperable due to problems with its power supply, so operators began the compensatory measures which directed the operators to contact the United States Geological Survey to confirm the epicenter and magnitude of the seismic event prior to event classification. The United States Geological Survey has a call queue system to answer inquiries in an orderly manner, and Exelon was on hold until 2:11 PM. Exelon declared the Unusual Event at 2:15 PM and made all appropriate state and local notifications. Exelon entered the untimely event declaration into their corrective action program as IR 1254845. The inspectors determined that the finding was of very low safety significance (Green) in accordance with NRC IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, Sheet 2, because this was related to an actual event implementation problem for a Notice of Unusual Event.
05000352/FIN-2011004-03Test Equipment Interference Resulting in Reactor Scram2011Q3A Green, self-revealing NCV of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, occurred when Exelon did not adequately assess the potential impacts of test equipment on turbine trip circuitry. This resulted in an automatic reactor scram of Unit 1 when the main turbine high reactor water level trip relay inadvertently energized during a surveillance test on June 3, 2011. This test is a quarterly surveillance, designed to verify proper operation of the Digital Feed Water Level Control System (DFWLCS) which initiates a turbine trip on high reactor level. The DFWLCS has a 1 out of 2 twice logic to energize the trip relay, so each channel is tested separately to eliminate the possibility of inadvertent actuation. As an additional precaution, the surveillance procedure contains steps for the technician to verify the other channels are free of closed trip contacts prior to beginning the test. Exelon used a Simpson 260 Volt/Ohm Meter (VOM) to perform this verification by demonstrating a nominal voltage difference between each side of the contact and station ground. During this verification step, Exelon inadvertently established a direct current loop from station ground, to the floating battery ground from the 125V power supply, to the trip circuit. This completed the circuit, energized the main turbine high reactor water level trip relay, which tripped the main turbine and caused the reactor to scram. Exelon revised the test procedure to change the requirements for test instrumentation to prevent this from recurring and entered the issue into the corrective action program as IR 1224283. The inspectors determined that the performance deficiency was more than minor in accordance with IMC 0612, Appendix B, Issue Screening, because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone and affected the objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during power operation. Specifically, by not considering the impact of maintenance and test equipment (M&TE) during multiple revisions of the surveillance procedure, Exelon failed to recognize a vulnerability which could lead to a plant transient. In accordance with IMC 0609, Attachment 4, Phase 1 - Initial Screen and Characterization of Findings, the finding was determined to be of very low safety significance (Green) because the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. The inspectors determined that this performance deficiency did not reflect current performance, as the last revision to the surveillance procedure that affected M&TE requirements was greater than three years ago. As a result, the inspectors did not assign a cross-cutting aspect to this finding.
05000352/FIN-2011004-02Failure to Provide Adequate Restoration Instructions for Turbine Control Valve Online Maintenance2011Q3A Green, self-revealing finding was identified because Exelon did not provide adequate instructions for restoration of the Limerick Unit 2 number three turbine control valve (CV #3) following maintenance. During a fill and vent activity of the electro-hydraulic control (EHC) supply line for CV #3, a void in the system piping resulted in a low pressure condition at the next-in-series control valve, CV #1. The pressure drop actuated a relayed emergency trip system (RETS) pressure switch, generating a reactor protection system (RPS) 'S' side half scram signal. Combined with an 'A' side half scram signal that was previously inserted into RPS due to the CV #3 being maintained closed, an automatic reactor scram resulted. The inspectors determined that Exelon's failure to provide adequate instructions for restoration of CV #3 from maintenance was a performance deficiency. The issue was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events cornerstone, and it affected the cornerstone objective of limiting the likelihood of events that upset plant stability. Specifically, on May 29, 2011, Limerick Unit 2 experienced an automatic reactor scram during restoration of turbine CV #3 from maintenance. The restoration instructions in the work order (WO) did not provide sufficient guidance to address the presence of a large air void in the EHC system that had the potential to cause EHC pressure fluctuations and resulted in a reactor scram. The finding was determined to be of very low safety significance (Green) in accordance with IMC 0609 Attachment 4, Phase 1Initial Screen and Characterization of Findings, because the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. This finding had a cross-cutting aspect in the area of Human Performance, Decision-Making, because Exelon did not use a systematic process to make a risk-significant decision when faced with uncertain or unexpected plant conditions. Specifically, Exelon did not recognize the potential risk of the CV #3 EHC fill and vent restoration activity, and they failed to conduct a thorough technical review of the restoration plan.
05000352/FIN-2011503-01(Traditional Enforcement) Changes to EAL Basis Decreased the Effectiveness of the Plan without Prior NRC Approval2011Q3The inspector identified a finding of very low safety significance involving a Severity Level IV NCV of 10 CFR 50.54(q) for failing to obtain prior approval for an emergency plan change which decreased the effectiveness of the plan. Specifically, the licensee modified the Emergency Action Level (EAL) Basis in EAL HU6, Revision 13, which indefinitely extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm. This change decreased the effectiveness of the emergency plan by reducing the capability to perform a risk significant planning function in a timely manner. The violation affected the NRC\\\'s ability to perform its regulatory function because it involved implementing a change that decreased the effectiveness of the emergency plan without NRC approval. Therefore, this issue was evaluated using Traditional Enforcement. The NRC determined that a Severity Level IV violation was appropriate due to the reduction of the capability to perform a risk significant planning standard function in a timely manner. The licensee entered this issue into its corrective action program and revised the EAL basis to restore compliance. The finding was more than minor using IMC 0612, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Therefore, the performance deficiency was a finding. Using IMC 0609, Appendix B, the inspector determined that the finding had a very low safety significance because the finding is a failure to comply with 10 CFR 50.54(q) involving the risk significant planning standard 50.47(b)(4), which, in this case, met the example of a Green finding because it involved one Unusual Event classification Due to the age of this issue, it was not determined to be reflective of current licensee performance and therefore a cross-cutting aspect was not assigned to this finding.
05000353/FIN-2011004-01Failure of Feedwater MOV Resulting in RCIC Inoperability for Longer than Allowed by Technical Specifications2011Q3A self-revealing preliminary white finding and apparent violation of Technical Specification (TS) 3.7.3, Reactor Core Isolation Cooling System and TS 3.6.3, Primary Containment Isolation Valves, was identified. The inspectors determined that the failure by Exelon to ensure sufficient technical guidance was contained in operating procedures to: 1) ensure that a Main Feedwater system (FW) motor-operated valve (MOV) could close against expected system differential pressures and 2) prevent operators from attempting to close FW MOVs out of sequence resulting in differential pressures for which they are not designed; is a performance deficiency. This resulted in the Reactor Core Isolation Cooling system (RCIC) and a Primary Containment Isolation Valve (PCIV) being inoperable from April 23 to May 23, 2011, due to FW MOVs HV-041-209B and HV-041-210 failing to fully shut. As a result, both safety related systems were inoperable for greater than their Technical Specification allowed outage times. Specifically, operations procedures did not contain adequate technical guidance to ensure that operations personnel operated HV-041209 A&B and HV-041-210 in the proper sequence to remain within valve design limitations. This resulted in the HV-041-209B and HV-041-210 valves failing to fully close on April 22, 2011, although they indicated closed in the Main Control Room. Upon identification, Limerick operations staff fully closed the valves restoring RCIC and PCIV operability, entered the issue into the CAP as issue report (IR) 1219476 and conducted a cause evaluation. Subsequent corrective actions included an extent-of-condition review, revisions to the operating procedure, and revisions to maintenance and testing procedures. The inspectors determined that this finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, operating procedures, maintenance and testing were not adequately implemented to ensure that the design capability of HV-041-209B and HV-041-210 to close against expected system differential pressures was maintained. The finding was evaluated using NRC Inspection Manual Chapter 0609 Appendix A, User Guidance for Significance Determination of Reactor Inspection Findings for At-Power Situations. Phase I, II, and III evaluations were conducted. The NRC total estimated L\\\\CDF in this preliminary assessment is Low E-6/yr (WHITE) and the NRC total estimated Large Early Release Frequency (LiLERF) in this preliminary assessment is 3.6E-9/yr (GREEN). The inspectors also determined that this issue has a cross-cutting aspect in the area of Human Performance, Resources, because Exelon did not ensure long term plant safety by maintaining design margins and minimizing preventive maintenance deferrals (H.2. (a)). Specifically, design limitations of the HV-041209 A & B valves were not adequately captured in the procedural guidance, which contributed to the operators continuing on in the procedures for securing the FW long path recirculation line up when problems with the HV-041-21 0 valve were encountered. Additionally preventive maintenance activities which could potentially have prevented this issue were deferred without an appropriate evaluation.
05000352/FIN-2011008-01Station Blackout Licensing Basis Assumed Alternate AC Power Source.2011Q2The inability to satisfy the licensing basis assumed alternate AC power source (i.e., three EDG\\\'s on the non-blacked out unit without using recovery procedures) during a certain Unit 1 station blackout event requires further review to determine compliance with 10 CFR Part 50.63, Loss of AllAlternate Current Power. The licensee entered this issue into the CAP as lR 1208490, Potential Station Blackout Procedure Bases Licensing lssue. This unresolved item (URl) is identified as URI 05000352, 35312011008-01, Station Blackout Licensing Basis Assumed Alternate AC Power Source.
05000352/FIN-2011003-04Licensee-Identified Violation2011Q2Limerick Unit2 TS 6.8,1, Procedures and Programs, requires, in part, that procedure be established and implemented covering the applicable activities in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1,33, Appendix A, Section 9.a, requires procedures for performing maintenance. Procedure M-C-756-001, HPCI Turbine Inspection, Revision 26, contained instructions for the HPCI turbine oil system cleaning and inspection. Contrary to TS 6.8.1, Procedure M-C-756-001 was inadequate because it did not direct disassembly of the overspeed trip device for further inspection and cleaning in the event that foreign material was identified at pipe connection points. As a result, the Unit 2 HPCI system was rendered inoperable and nonfunctional on December 12,2010, because the overspeed trip mechanism failed to reset during periodic testing due to foreign material in the oil turbine oil system. Because this issue was determined to be of very low risk significance (Green), and Exelon has entered this issue into the CAP as lR 1151354, this issue is being characterized as a Licensee identified NCV.
05000352/FIN-2011003-03Failure to ldentify Adverse Trend regarding Out-of-Calibration lnstrumentation2011Q2A Green self-revealing finding was identified for Exelon\'s failure to identify and correct an adverse trend regarding out-of-calibration temperature switches in the Unit 1 and Unit 2 station cooling water (SCW) systems. Specifically, between 1990 and 201 1 the SCW outlet temperature switches were checked by Exelon on a two year frequency and found to be out-of-calibration approximately 50 percent of the time. Since 2005, the switches were found out-of-calibration nearly 70 percent of the time, often by a significant amount. Each time the switches were found out-of-calibration, they were recalibrated within acceptable limits, but the adverse trend was not recognized. The inspectors determined that Exelon\'s failure to identify and correct the adverse trend of out of calibration SCW outlet temperature switches was a performance deficiency which was reasonably within the licensee\'s ability to foresee and prevent. Specifically, Exelon\'s Performance Monitoring Program, described in ER-AA-2003, should have identified the trend during the system engineer\'s annual review of cause and repair codes for completed work orders. Exelon entered the issue into the CAP for resolution. The finding was more than minor because it was associated with the equipment performance attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of events that upset plant stability. Specifically, on February 25,2011, the\'out of calibration SCW outlet temperature switches resulted in a SCW runback and manual scram of Limerick Unit 2 when the outlet temperature switches actuated 15 degrees lower than their intended set point. The finding was determined to be of very low safety significance (Green) in accordance with Phase 1 of IMC 0609, significance Determination Process, because the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. The inspectors determined that this finding had a cross-cutting aspect in the area of Problem ldentification and Resolution, Corrective Action Program, because Exelon did not identify the trend of out-of-calibration temperature switches in a timely manner. Exelon relied on the implementation of a thorough Performance Monitoring Program to supplement their CAP in the specific area of instrument performance monitoring and trending, and this program failed to detect the adverse trend in instrument performance.
05000352/FIN-2011003-01Failure to Position Recirculation lsolation Valves in Accordance with Clearance2011Q2A Green, self-revealing NCV of Technical Specification (TS) 6.8.1, Procedures and Programs, was identified for failure to position the Unit 2 recirculation loop isolation valves in accordance with the clearance instruction. As a result, the decay heat removal 1ow path, as provided by Unit 2 \'A\' residual heat removal (RHR), was in a degraded condition from April 6,2011 until April 1 2,2011, when the valve mispositioning was corrected. In addition, if the RHR system had been aligned to the Shutdown Cooling mode with the valves mispositioned in the open position, a large portion of the cooling flow would have bypassed the core, significantly impacting decay heat removal capability. Exelon entered the issue into the Corrective Action Program (CAP) for resolution. The inspectors determined that the failure to position the Unit 2 \'A\' loop recirculation pump suction and discharge valves to the closed positions in accordance with a clearance is a performance deficiency. This issue is more than minor because it was associated with the Configuration Control attribute of the Initiating Events cornerstone (i.e., shutdown equipment lineup), and it affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. This finding was determined to be of very tow safety significance (Green) using IMC 0609, significance Determination Process, Appendix G, Shutdown Operations Significance Determination Process, because the finding did not require quantitative assessment (i.e., the finding did not degrade the ability to recover decay heat removal once lost). Exelon entered this issue into the CAP for resolution. Corrective actions included remediating the reactor operator who applied the main control room tag and revising the cross check program to require a concurrent verification check on clearance applications for valves being de-energized with main control room indicators. The inspectors determined that this issue has a cross-cutting aspect in the area of Human Performance, Work Practices, because Exelon did not properly use human error prevention techniques (e.g., self and peer checking), commensurate with the risk of the assigned task.
05000352/FIN-2011002-02None2011Q1Unit 2 TS LCO 3.0.4 requires that, when an LCO is not met, entry into an OPCON or other condition in the Applicability shall only be made if specified conditions in LCO 3.0.4 were met. TS LCO 3.3.7.4 Remote Shutdown System lnstrumentation and Controls, requires the RHR Heat Exchanger Bypass Valve (HV-C-S1-2F048A) Position Indication (0-10070) (Table 3.3.7.4-1, Instrument 15)to be restored to operable within 7 days or be in at least Hot Shutdown within the next 12 hours with an Applicability in OPCONS 1 and 2. Contrary to LCO 3.0.4, on April 11, 2009, Unit 2 entered OPCON 2 with the position indication for HV-C-51-2F048A inoperable and specified conditions in LCO 3.0.4 were not met. The cause of the failure to meet LCO 3.0.4 was due to less than adequate administrative barriers being present to allow licensed operators to properly assess the TS impact of the deficiency. Also, operators did not use all available tools and resources at that time to validate the initial operability determination. This issue was entered into Exelon\'s CAP as lR 1168410. The finding was determined to have very low safety significance (Green) in accordance with NRC IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Finding, Mitigating Systems, because the finding did not represent an actual loss of safety function or screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event.
05000352/FIN-2011002-01Failure to Address Repeat TS Response Time Test Failures2011Q1The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVl, Corrective Action Program, because Exelon did not adequately evaluate and correct a condition adverse to quality regarding repeat failures of a Technical Specification (TS) surveillance test (ST). Specifically, on July 13,2010, Exelon generated issue report (lR) 1091132to document that ST-2-041-909-2,the Unit 2 Main Seam Line (MSL) Flow - High Response Time Test, had failed its past two performances. In both instances, in October 2008 and July 2010, multiple response time values exceeded the TS requirements, and Exelon had to replace several relays to bring the values back into compliance. After the 2008 failure Exelon performed an apparent cause evaluation (ACE) and generated one corrective action (CA) and several action items (AClTs) to address the causes. Following the 2010 failure, Exelon did not evaluate the repeat failure or generate any additional actions. The inspectors determined that the CA and ACITs from 2008 did not thoroughly address the MSL Flow - High test failure, and the repeat test failure in 2010 was an opportunity for Exelon to re-evaluate the issue and pursue more appropriate and timely corrective actions. Exelon\'s failure to evaluate and correct a condition adverse to quality regarding repeat failures of a TS surveillance test was determined to be a performance deficiency (PD). The PD was determined to be more than minor because it was associated with the System, Structure, and Component & Barrier Performance attribute of the Reactor Safety - Barrier lntegrity cornerstone. The PD adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The finding was determined to be of very low safety significance (Green) in accordance with Inspection Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, because it did not represent an actual open pathway in the physical integrity of reactor containment. The inspectors determined this finding had a cross-cutting aspect in the area of Problem ldentification and Resolution, Corrective Action Program, because Exelon did not thoroughly evaluate the repeat MSL response time test failures to ensure the underlying causes were identified and resolved.
05000352/FIN-2010403-01Security2010Q4
05000352/FIN-2010007-02Three of Four RHR Unit Coolers Unreliable due to Planned and Unplanned Conditions (Silting)2010Q4The inspectors identified a violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, in that Exelon failed to correct a condition adverse to quality for a safety related support system that was essential to successful mitigating system operation. Specifically, for a six and one half day period during July 2008, three of four residual heat removal unit coolers were either unavailable or made unreliable due to a series of planned and unplanned conditions (silting). The inspectors determined that the failure to correct a condition adverse to quality in accordance with 10 CFR 50 Appendix B, Criterion XVI, during the timeframe of June 1, 2008 to September 14, 2008, contributed to the unreliability of the 1C-V21 0 unit cooler and was a performance deficiency. Specifically, Exelon did not initiate bi-weekly flushing per RT-6-011603- 0 of the 1C-V21 0 unit cooler to minimize the effects of silt build up. This finding is more than minor because it affected the equipment performance attribute of the Mitigating System cornerstone and the associated cornerstone objective of ensuring the reliability and availability of systems that respond to initiating events to prevent undesirable consequences. This issue was also similar to example 3.j. in NRC IMC 0612, Appendix E, Examples of Minor Issues, in that it resulted in a condition where there was a reasonable doubt on the operability of the 1C-V210 unit cooler. The inspectors assessed this finding in accordance with IMe 0609, Attachment 4, Phase 1, Initial Screening and Characterization of Findings, and determined that it was of very low safety significance (Green) since it was determined that the error did not result in a loss of the system\\\'s safety function. The inspectors determined that this violation had a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, in that Exelon did not take appropriate corrective actions to address a condition adverse to quality in a timely manner, commensurate with its safety significance and complexity. Specifically, Exelon failed to take appropriate actions to initiate bi-weekly flushes of the 1C-V21 0 unit cooler, upon discovery of conditions conducive to silt buildup during June through September 2008
05000352/FIN-2010007-01Failure to Update UFSAR Consistent With Plant Conditions as Required2010Q4The inspectors identified a Severity Level IV (SLlV) NCV of 10 CFR Part 50.71 (e) in that Exelon failed on multiple occasions to revise the Updated Final Safety Analysis Report (UFSAR) with information consistent with plant conditions. Specifically, Exelon personnel failed to incorporate four previously identified UFSAR inconsistencies into the September 2010 UFSAR update as required. The inspectors determined that the failure to update the UFSAR in accordance with 10 CFR 50.71 (e) was a performance deficiency that was reasonably within Exelon\\\'s ability to foresee and correct, and should have been prevented. Because the issue had the potential to affect the NRC\\\'s ability to perform its regulatory function, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process. Using example 6.1.d.3 from the NRC Enforcement Policy, the inspectors determined that the violation was a SLiV (more than minor concern that resulted in no or relatively inappreciable potential safety or security consequence) violation, because the information that was not updated in the UFSAR was not used to make an unacceptable change in the facility nor did it impact a licensing or safety decision by the NRC
05000352/FIN-2010004-04Licensee-Identified Violation2010Q3TS 3.3.7.1, Radiation Monitoring Instrumentation, requires one operable RECW radiation monitor channel at all times. With the radiation monitor inoperable, Table 3.3.7.1-1, Action 72 requires obtaining and analyzing RECW grab samples every 24 hours. Contrary to TS 3.3.7.1, the RECW radiation monitor was inoperable from March 19, 2010, until April 22, 2010, and the required grab samples were not obtained. The cause of the inoperability was due to an incorrect method for calculating the monitor\'s Hi-Hi Alarm setpoint; the test incorrectly directed use of the background radiation level from the previous month\'s test. This issue was entered into Exelon\'s CAP as IR 1063446. The finding was determined to have very low safety significance (Green) in accordance with NRC IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, Containment Barrier, because the finding did not represent a degradation of a radiological barrier, a degradation of the barrier function of the control room against smoke or a toxic atmosphere, or an actual open pathway in the physical integrity of reactor containment, containment isolation system, or heat removal components.
05000352/FIN-2010004-03Failure to Perform Adequate PM on EDGs2010Q3The inspectors identified a Green NCV of Limerick Unit 2 Technical Specification (TS) 6.8.1, Procedures and Programs, in that Exelon did not provide an adequate procedure for preventive maintenance (PM) of the Limerick Emergency Diesel Generator (EOG) lube oil (LO) filter bypass valves. As a result, Exelon did not identify that the EOG 023 LO filter bypass valves were degraded and allowed oil to bypass the filter during engine operation. This condition, combined with historical foreign material in the LO system, led to the failure of the EOG 023 number 5 upper piston assembly during a 24-hour endurance test run on May 5,2010. Corrective actions implemented included repairing the damage to D23, performing a flush of the D23 LO system, revising the applicable PM procedure to include specific instructions for inspecting the LO filter bypass valves, and revising performance monitoring guidance to ensure spuriously lifting LO filter bypass valves would be identified in the future. The finding was more than minor because it was associated with the Equipment Performance attribute of the Mitigating System cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was determined to be of very low safety significance (Green) in accordance with Inspection Manual Chapter (IMC) 0609, Appendix A, Determining the Significance of Reactor Inspection Findings for At-Power Situations, using SDP Phases 1, 2, and 3. This finding has a cross-cutting aspect in the area of Human Performance, Resources, because Exelon did not provide complete, accurate and up-to-date design documentation, procedures, and work packages (H.2(c)). Specifically, Exelon did not provide site engineers with complete and accurate resources to ensure performance centered maintenance (PCM) template revisions were thoroughly reviewed and implemented.
05000352/FIN-2010004-01Failure to Take Compensatory Action for Inoperable Fire Door2010Q3The inspectors identified a Green NCV of Limerick Generating Station operating License Condition 2.C.3, in that Exelon failed to take compensatory actions for an inoperable fire door. Specifically, on two occasions a required fire door was found in a condition where the latching mechanism did not function. Although issue reports (IRs) were written which identified this door to be a Technical Requirements Manual (TRM) fire door, actions were not taken to station the required hourly fire watch. Corrective actions included setting the required hourly fire watches, distributing guidance to all senior licensed operators, and implementing procedural changes to clarify the requirements of fire doors for future operability determinations. The finding was more than minor because it was associated with the protection against external events (fire) attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. This issue was found to be of very low safety significance (Green) based upon a Phase 2 SOP screening. The inspectors determined that this finding did not have a cross-cutting because the incorrect operability decisions were based on a 1999 engineering evaluation and, therefore, was not reflective of current licensee performance.
05000352/FIN-2010402-02Security2010Q3
05000352/FIN-2010004-02Failure to Identify Incorrectly Adjusted Control Power Relay Resulting in Unit 1 Manual Scram2010Q3A self-revealing Green finding was identified for the failure to identify that the latching mechanism on a bus 114A1124A control power auxiliary relay (27X) was incorrectly adjusted during prior post-maintenance testing activities. Specifically, proper post-maintenance testing activities in 1992 and 2004 should have identified that the latching mechanism was incorrectly adjusted. The incorrectly adjusted latching mechanism prevented the automatic swap of control power to the alternate source (bus 124A) when preferred power (bus 114A) was lost due to an electrical fault. This resulted in a loss of stator water cooling run back signal that would have caused the trip of both recirculation motor-generator sets and resulted in operators having to manually initiate a reactor scram. Exelon\'s corrective actions taken or planned included verifying the latching mechanism adjustment on the site\'s other Similarly designed control power auxiliary relays, testing the automatic undervoltage transfer circuit on a periodic basis, and performing a failure analysis on the faulted underground supply cable which initiated the event. The finding was more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The finding was determined to have very low safety significance (Green) in accordance with NRC IMC 0609, Attachment 4, Phase 1- Initial Screening and Characterization of Findings, because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigating equipment or function would not be available. Because the opportunities to identify the incorrectly adjusted latching relay occurred in 1992 and 2004, the inspectors determined that this finding was not reflective of current licensee performance, and, therefore, did not have a crosscutting aspect. Enforcement action does not apply because the performance deficiency did not involve a violation of regulatory requirements.
05000352/FIN-2009005-03Licensee-Identified Violation2009Q410 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that all applicable regulatory requirements and the design basis for structures, systems, and components are correctly translated into specifications, drawings, procedures and instructions. Contrary to the above, inadequate isolation actuation instrumentation setpoints were translated into Units 1and 2 Technical Specification 3.2.2, Isolation Actuation Instrumentation, Table 3.3.2-2, Isolation Actuation Instrument Setpoints, Item 4.e, HPCI Equipment Room Temperature - High. This condition existed from January 1995, when Technical Specification Amendments 85 and 46 were issued, until the condition was discovered on August 27, 2009. This issue was identified during a review of the steam leak detection system calculations and was identified in Exelon\'s CAP as IR 958587. Upon discovery, appropriate compensatory actions (i.e., disabling of the room coolers) were implemented to return the system to an operable status. This finding was determined to have very low safety significance (Green) using NRC IMC 0609, Appendix H, Containment Integrity Significance Determination Process, because it did not represent a finding of greater significance for LERF using Table 6.2, Phase 2 Risk Significance-Type B Findings at Full Power.
05000352/FIN-2009005-02Failure to Identify Degraded Instrument Line in Emergency Service Water System2009Q4The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for Exelon\'s failure to identify a condition adverse to quality associated with the \'A\' ESW pump discharge pressure instrument line. Specifically, Exelon had previous opportunity to identify and repair a degraded \'A\' ESW instrument line following a leak on a similar instrument Iine in August 2008. However, the degraded condition of the \'A\' instrument line was not detected until it resulted in a through-wall leak on November 7,2009. In response to the leak, Exelon was required to isolate the \'A\' ESW pump and enter the associated 45-day TS action statement. Exelon entered this issue into their corrective action program as Issue Report (IR) 990204 and IR 993012. Corrective actions included performing an investigation and scheduling extent of condition testing on the remaining 18similar instrument lines. The finding is more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone, and it impacted the cornerstone objective of ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. Specifically, upon discovery of the through-wall leak, Exelon was required to isolate the \'A\' ESW pump and enter the associated 45 day TS action statement. The finding is of very low safety significance because it did not represent the loss of a TS train for greater than its allowed outage time. This finding has a cross-cutting aspect of Problem Identification and Resolution, Corrective Action Program, because Exelon did not take appropriate corrective actions to address a safety issue regarding corrosion in the ESW instrument lines P.1(d). Specifically, although Exelon directed non-destructive examination (NDE) be performed to identify degraded ESW instrument lines, Exelon failed to ensure the scope of the NDE was sufficient to identify the degraded condition in the \'A\'ESW pump instrument line
05000352/FIN-2009006-01Failure to Verify Battery Capacity to Recover from Station Blackout2009Q4The team identified a finding of very low safety significance involving a noncited violation of 10 CFR 50.63, Loss of All Alternating Current (AC) Power, because Exelon\'s coping analysis did not determine whether the battery capability and capacity was sufficient to recover AC power at the end of the required coping period. Specifically, Exelon\'s battery sizing and station blackout (SSO) load profile calculation did not include those loads necessary to recover AC power, such as starting an emergency diesel generator (EDG) or closing 4 kV switchgear breakers. As a result, the calculation did not verify there was adequate direct current (DC). voltage available to critical equipment during the SSO coping period. Exelon entered the issue into their corrective action program and performed and operability assessment which determined the battery was operable. This issue was more than minor because it is associated with the design control. attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events. The team determined the finding was of very low safety significance because it was a design deficiency subsequently confirmed not to result in a loss of operability or functionality. The finding did not have a cross-cutting aspect because it was determined to be a legacy issue not considered to be indicative of current licensee performance.
05000352/FIN-2009006-02TS Requirements for MOV Thermal Overload Bypass Feature2009Q4An unresolved item (URI) was identified because additional NRC review and evaluation is needed to determine if Exelon is meeting Technical Specification (TS)3.8.4.2b. and/or TS Surveillance Requirement (SR) 4.8.4.2.2. The team questioned whether Exelon was meeting the licensing requirements for bypassing thermal overloads for all Class 1E MOV\'s with spring-to-normal control switches during an accident and/or whether testing used to satisfy the requirements for a Channel Function Test of the MOV circuit was adequate related to alarm testing. TS Section 3.8.4.2b states that the thermal overload protection of all Class1E MOVs shall be bypassed under accident conditions for all valves with spring-to normal control switches. The team referenced Regulatory Guide (RG) 1.106, Thermal Overload Protection for Electric Motors on Motor-Operated Valves, which describes acceptable methods to ensure that thermal overload devices will not prevent MOVs from performing their safety related function. An acceptable method to ensure completion of a safety related function is to ensure that thermal overload protection devices that are normally in place during plant operation be bypassed under accident conditions and should be tested periodically. Section 8.1.6.1.19 of the UFSAR states that RG 1.106 is not applicable to Exelon per the implementation section, but concludes Exelon is in conformance with RG 1.106. In addition, Section 8.1.6.1.19a states that MOVs with spring-to-return control switches, during manual operation, the thermal overload is normally in the trip circuit; however, the thermal overload can be bypassed by holding the control switch in the appropriate open or close position. The team verified that operators were not expected to hold the switch in order to bypass the thermal overload during an accident condition. The team questioned if Exelon was meeting the intent of TS 3.8.4.2 because thermal overloads are not bypassed during an accident unless the overloads have been actuated and operators reposition the switch and hold it in the open or closed position. Exelon initiated issue report (IR) 985060 to review the issue and concluded in a position paper that they are in compliance with TS 3.8.4.2b. Additionally, the team questioned the adequacy of testing of the thermal overload bypasses for spring-to-return control switches for manually operated Class 1E MOVs in accordance with SR 4.8.4.2.2. The surveillance requires a Channel Functional Test to be performed to verify that the thermal overload protection will be bypassed under accident conditions. Exelon\'s TS, Section 1.6a, defines Channel Functional Test for analog channels as the injection of a simulated signal into the channel as close to the sensor as practicable to verify operability including alarm and/or trip functions. The test performed to satisfy the SR cycles the valve remotely with the control switch to check the continuity of the bypass circuitry but does not verify operation of the alarm associated with a thermal overload condition. The team questioned whether Exelon was required to verify the alarm function associated with the thermal overloads. In response to the team\'s questions, Exelon supported a position that standard operating practice includes verification of valve position by the operators using valve indication lights and that the alarm function does not need to be tested. This issue will be opened as a URI pending further NRC review in order to determine if LGS Units 1 & 2 are in compliance with their TS section 3.8.4.2 and SR 4.8.4.2.2 for thermal overload bypass operation in accident conditions and testing of the thermal overload alarm function. (URI 05000352,353/2009006-02, TS Requirements for MOV Thermal Overload Bypass Feature)
05000352/FIN-2009005-01Failure to Ensure Adequate Cooling Water Flow to Residual Heat Removal Room Unit Cooler2009Q4The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XI, \\\'Test Control, for improperly positioning the Emergency Service Water (ESW) throttle valve to the Unit 1 \\\'A\\\' Residual Heat Removal (RHR) room unit cooler during an ESW flow balance surveillance test in April 2008. During the test, Exelon failed to adequately evaluate ESW flow data, and established ESW flow to the unit cooler at less than the minimum required. This rendered the \\\'A\\\' RHR room unit cooler incapable of removing its design heat load for a period of approximately 13 months. Exelon entered this issue into their corrective action program for resolution. This finding is more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone, and it impacted the cornerstone objective of ensuring the availability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Exelon\\\'s failure to accurately evaluate test data resulted in an inadequate ESW flow rate through the \\\'A\\\' RHR room unit cooler, rendering it incapable of removing its design heat load. The finding is of very low safety significance because it did not represent a loss of safety function of a TS train or risk significant non-TS train. This finding has a cross-cutting aspect of Human Performance, Work Practices, because Exelon personnel did not utilize adequate human error prevention techniques, such as self and peer checking, to ensure work activities were performed properly (H.4(a)). Specifically, Exelon personnel did not utilize human error prevention techniques to ensure an accurate flow calculation in April 2008.
05000352/FIN-2009004-03Licensee-Identified Violation2009Q3TS LCO 3.7.8, Main Turbine Bypass System, requires the main turbine bypass system to be operable when in Operational Condition 1, when thermal power is greater than or equal to 25 percent of rated thermal power. With the main turbine bypass system inoperable, TS 3.7.8 requires restoration of the system to an operable status within 1 hour or take the action required by TS 3.2.3.c. TS 3.2.3.c requires that Minimum Critical Power Ratio (MCPR) be determined to be greater than or equal to the rated MCPR limit specified in the Core Operating Limits Report Main Turbine Bypass Valve Inoperable Curve. Contrary to TS 3.7.8, Unit 2 operated in Operational Condition 1 with thermal power greater than 25 percent with the main turbine bypass system inoperable for greater than 1 hour and the action required by TS 3.2.3.c was not performed. Specifically, during troubleshooting and surveillance test activities on February 15, 2008, May 24, 2008, September 13, 2008, and December 14, 2008, the main turbine bypass system was rendered inoperable for greater than one hour and the MCPR was not determined to be greater than or equal to the rated MCPR limit specified in the Core Operating Limits Report. The issue was entered into Exelons CAP as IR 917231. The finding was determined to have very low safety significance (Green) using NRC IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, Fuel Barrier, because operation with MCPR less than the rated MCPR limit specified in the Core Operating Limits Report could potentially only affect the fuel barrier and the condition did not represent a loss of the pressure mitigating function of the main turbine bypass system or affect the spent fuel pool
05000352/FIN-2009004-02Failure to Correct 480V Breaker Thermography2009Q3The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for failing to correct a condition adverse to quality associated with the performance of thermography on safety-related breakers. Specifically, although Exelon identified that the failure to perform thermography on breakers in a loaded condition was a causal factor for an electrical fault that occurred in January 2009, Exelon did not implement proper corrective actions to ensure that applicable future thermography examinations would be conducted while the equipment was in a loaded condition. Exelon entered this issue into the CAP as IR 874599, Assignment 58. Corrective actions included adding 48 breakers to the list of breakers that will be loaded prior to thermography and creating an assignment to formally assess the remaining breakers that may not receive routine thermography due to not being in a loaded condition. The finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors assessed the finding using Phase 1 of IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings and determined the finding to be of very low safety significance because it was not a design or qualification deficiency, did not represent a loss of system safety function, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because Exelon did not take appropriate corrective actions to address a safety issue (P.1(d)). Specifically, although the failure to perform thermography on breakers in loaded conditions was identified as a causal factor for an electrical fault, actions were not taken in a timely manner to ensure loaded conditions for applicable future thermography examinations
05000352/FIN-2009004-01Failure to Adequately Test 480 Volt Motor Control Unit Circuit Breakers2009Q3The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, for failure to establish a test program for all safety-related 480 volt motor control unit (MCU) circuit breakers to assure that necessary testing was performed to demonstrate that they would perform the safety-related function in service. Specifically, in 2004, Exelon inappropriately classified certain safety-related 480 volt molded-case circuit breakers as run-to-failure in the Performance Centered Maintenance (PCM) process, which resulted in the breakers receiving no planned preventive maintenance or testing. Exelon entered this issue into the Corrective Action Program (CAP) for resolution as Issue Report (IR) 948232. Exelons corrective actions included: reclassifying all safety-related 480 volt MCUs as either critical or non-critical, a formal review of the vendors technical bulletin for applicability; and an extent-of-condition review of all direct current MCUs and 4 kilovolt circuit breakers. Also, preventive maintenance and testing was planned for all in-service 480 volt MCUs that had gone overdue because they were inappropriately classified as run-to-failure. This finding is more than minor because, if left uncorrected, the performance deficiency would lead to a more significant safety concern. Specifically, the installed molded case circuit breakers classified as run-to-failure had received no periodic planned maintenance or tests and were beyond the manufacturers design life. Based on operating experience, this would result in a breaker being slow to trip or sticking in the on position after an over-current condition. The inspectors assessed the finding using Phase 1 of IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings and determined the finding to be of very low safety significance because the issue was a qualification deficiency confirmed not to result in loss of operability per Part 9900, Technical Guidance, Operability Determination Process for Operability and Functional Assessment. Since the change to the PCM process was made in 2004, the inspectors determined that this finding was not reflective of current licensee performance and, therefore, did not have a cross-cutting aspect
05000352/FIN-2009003-02Licensee-Identified Violation2009Q2TS LCO 3.3.7.5, Accident Monitoring Instrumentation, Item 13, requires two channels of Neutron Flux Instruments to be operable in OPCON 1. With less than the required number of operable channels, TS 3.3.7.5 requires restoration of the inoperable channels with 7 days or be in at least Hot Shutdown within the next 12hours. With no operable channels, TS 3.3.7.5 requires restoration of the inoperable channels within 48 hours or be in at least Hot Shutdown within the next 12 hours. Contrary to TS 3.3.7.5, Unit 1 operated in OPCON 1 for periods longer than allowed without the required number of operable Neutron Flux Instruments due to inoperable Source Range Monitors. Specifically, during the periods from October 5, 2006 to December 18, 2006, and December 14, 2006 to April 21, 2007, less than the required number of operable channels of Neutron Flux Instruments were operable. During the periods from January 20, 2006 to February 20, 2006, December 14, 2006to December 18, 2006, and February 20, 2007 to April 21, 2007, no operable channels of Neutron Flux Instruments were operable. The issue was entered into Exelons CAP as IR 867666. The finding was determined to have very low safety significance (Green) using IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria, because the SRMs only provide indications to operators following an accident and other instrumentation (i.e., intermediate range monitors and average power range monitors) were available during the time periods in question to ensure the reactor would remain in a safe, shutdown condition.
05000352/FIN-2009003-01Failure to Adequately Assess Erratic Time Delay Relay Operation on Unit 2 HPCI Operability2009Q2The inspectors identified a Green finding associated with the failure to adequately assess erratic time delay relay operation on Unit 2 High Pressure Coolant Injection (HPCI) system operability in a timely manner commensurate with the potential safety significance. Following a failed surveillance test, the Unit 2 HPCI system was considered operable despite erratic operation of a system time delay relay and the operators failure to adequately address the relays design basis function. Exelon placed this issue in the CAP (IR 933745). Exelons corrective actions included: performing operations shift crew briefings on the issue; emphasizing the need for applying a questioning attitude; and requesting timely engineering support for emergent Technical Specifications (TS) equipment issues. Also, a structured operability determination template was added to the corrective action program IR form. This finding is more than minor because it was associated with the human performance attribute of the Mitigating Systems cornerstone, and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors assessed the finding using IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings and determined the finding to be of very low safety significance (Green)because it did not represent a loss of safety function of a single train for greater than the TS allowed outage time; was not associated with a design or qualification deficiency; and did not screen as risk significant due to seismic, flooding, or severe weather events. This finding has a crosscutting aspect in Human Performance, Decision-Making, because Exelon did not make a safety-significant decision using a systematic process, especially when faced with uncertain or unexpected plant conditions, to ensure safety is maintained (H.1(a)). Specifically, Exelon did not obtain timely interdisciplinary input and review on a safety significant decision in that site engineering did not review the operations decision and operations did not implement the subsequent engineering recommendation until two days after the failed surveillance.
05000352/FIN-2009007-02Lead maintenance technician deliberately falsified clearance and tagging records2009Q2Title 10 of the Code of Federal Regulations, Part 50.9, Completeness and Accuracy of Information, requires, in part, that information required by statute or by the Commissions regulations, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects. Exelon Procedure OP-MA-109-101, Step 13.2.5.2 states, The Lead Worker or First Line Supervisor shall perform the Worker Tagout per the Worker Tagout Clearance Form. Step 13.2.7.5 states that when the work is complete, the Lead Worker or First Line Supervisor shall complete the Worker Tagout Clearance Form and return it to the workgroup Supervisor to be retained/recorded in the work package. Contrary to the above, between January and July 2007 and in February 2008, a lead maintenance technician, when documenting worker tagouts on Worker Tagout Clearance Forms, created information maintained by the licensee that was not complete and accurate in all material respects. Specifically, the lead maintenance technician falsified Worker Tagout Clearance Forms by forging the initials of qualified maintenance technicians, indicating that they had conducted the clearance and tagging activities when, in fact, the activities had been performed by unqualified contractors.
05000352/FIN-2009007-01Lead maintenance technician deliberately permitted unqualified contractors to open breakers and hang clearance tags2009Q2Limerick Generating Station Technical Specifications 6.8, Procedures and Programs, requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Revision 2, Appendix A, February 1978, recommends administrative activities, including equipment control (i.e. locking and tagging), be covered by written procedures. Exelon Procedure OP-MA-109-101, Clearance and Tagging, Revision 6, Section 13, Worker Tagout Process, Step 13.1.3 states, Personnel using worker tagout tags shall be qualified in the clearance and tagging process. Contrary to the above, between January and July 2007 and in February 2008, the licensee failed to implement a procedure required by Technical Specification 6.8 when worker tagout tags were used by personnel at Limerick Generating Station who were not qualified in the clearance and tagging process. Specifically, a lead maintenance technician with oversight responsibilities for a contractor group deliberately permitted unqualified contractors to open breakers and hang worker tagout tags
05000352/FIN-2009002-03Licensee-Identified Violation2009Q1Technical Specification 6.8.1.g, Procedures and Programs, requires that written procedures shall be established, implemented, and maintained covering fire protection program implementation. Contrary to this requirement, Exelon failed to establish an adequate remote shutdown procedure to align RCIC pump suction to the suppression pool as assumed and analyzed in the fire safe shutdown analysis. Specifically, Exelon did not ensure that procedure SE-1.Remote Shutdown, contained the proper steps to align the RCIC pump suction to the suppression pool while operating the system at the remote shutdown panel for a fire in the main control room or the cable spreading room. The issue was entered into Exelons corrective action program as IR 843591. The finding was more than minor because it is associated with the procedural quality attribute of the Mitigating Systems Cornerstone and affects the cornerstone objective of ensuring the availability and reliability of the RCIC system under postulated fire safe-shutdown conditions. The inspectors determined that the finding was of very low safety significance (Green), based on IMC 0609, Appendix F, Fire Protection Significance Determination Process, Phase 2 screening, Task Number 2.3.5, because no credible fire ignition source scenarios were identified
05000352/FIN-2009002-01Failure to Maintain Design Control for Reactor Building Temperatures2009Q1The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion III, Design Control, for the failure to translate minimum room temperatures assumed in an isolation actuation instrumentation setpoint calculation into Unit 1 and 2 procedures such that reactor building room temperatures were maintained above the minimum assumed. As a result, the reactor enclosure and refueling area ventilation systems were not operated to assure that room temperatures were maintained above the minimum assumed in design basis calculations. Exelon entered the issue into the Corrective Action Program (CAP) for resolution. This finding was more than minor because it was associated with the Design Control attribute of the Barrier Integrity cornerstone, and affected the Barrier Integrity cornerstone objective to provide reasonable assurance that physical design barriers, including containment, protect the public from radionuclide releases caused by accidents or event. This finding was determined to be of very low safety significance because it did not represent an actual open pathway in the physical integrity of reactor containment, containment isolation system, and heat removal components. This finding has a crosscutting aspect in Human Performance, Decision Making, because the licensee did not make a safety significant decision using a systematic process to ensure safety was maintained H.1(a). Specifically, the decision to operate the reactor buildings at lower temperatures was made using an informal process within operations, therefore interdisciplinary input and a review by engineering and other support organizations was not obtaine
05000352/FIN-2009002-02Failure to Obtain License Amendment for TS Bases Change2009Q1The inspectors identified a Severity Level IV NCV of 10 CFR 50.59, Changes, Test, and Experiment, for failing to obtain a Technical Specification (TS)license amendment for a change made to the TS Bases concerning offsite power source operability. Changes made to TS Bases 3/4.8.1 required a change in the TS, because the change caused the bases to be in direct conflict with the requirements of TS Limiting Condition for Operation 3.8.1, AC Sources Operating, through the application of associated TS surveillance requirements. Exelon entered this issue into the CAP and issued night orders to operators which required declaring an offsite power supply inoperable when an offsite power supply feeder breaker became unavailable to an emergency bus. Because this was a violation of 10 CFR 50.59, it was considered to be a violation which potentially impedes or impacts the regulatory process. Therefore, such violations are characterized using the traditional enforcement process. In this case, the licensee failed to perform an adequate safety evaluation in accordance with 10 CFR 50.59 because the approved change to the technical specification basis was in conflict with the TS surveillance requirements. This change required prior approval from the NRC before its implementation. Comparing this item to the examples in NUREG 1600, Supplement I, Reactor Operations, this finding is more than minor because NRC approval would have been required. The inspectors completed a Significance Determination Review using NRC IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings. Using the Phase I Screening worksheet the finding was determined to be of very low safety significance (Green) since the finding did not represent an actual loss of safety function for greater than the TS allowed outage time. Comparing this item to the examples in NUREG 1600, Supplement I, this finding is similar to Item D.5, Violations of10 CFR 50.59 that result in conditions evaluated as having very low safety significance(i.e., Green) by the SDP. This is an example of a Severity Level IV violation. Since the TS Bases change was made in 2000, the inspectors determined that this finding was not reflective of current licensee performance and, therefore, did not have a cross-cutting aspect
05000352/FIN-2008005-02Inadequate Post-Maintenance Test following Containment Isolation System Relay Replacement2008Q4The inspectors identified a NCV of Technical Specification 6.8.1, Administrative Controls-Procedures, because Exelon did not maintain adequate maintenance procedures associated with work performed on the Unit 2 Nuclear Steam Supply Shutoff System (NSSSS). Specifically, the procedures, which performed system relay replacements, did not contain adequate post-maintenance testing (PMT) to demonstrate that the Technical Specification required response times of all circuits affected by the maintenance were satisfied. The inspectors determined that this finding was more than minor because it was associated with the procedure quality attribute of the Mitigating System cornerstone, and affected the Mitigating System cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. As a result of the inadequate PMT, additional unavailability was accrued, and an engineering evaluation was required to demonstrate satisfactory response times. The finding was determined to be of very low safety significance(Green) because it did not represent a loss of safety function. The inspectors determined this finding had a cross-cutting aspect in Human Performance, Resources, because Exelon did not provide complete and accurate work packages to assure nuclear safety. Specifically, the NSSSS was returned to service without all the required post-maintenance testing being performed to demonstrate operability. (IMC 0305 aspect:H.2(c)) (Section 1R19
05000352/FIN-2008005-01Changes to Technical Specification 3.8.1 Bases2008Q4On September 30, 2008, operators racked out one of the two offsite power supply feeder breakers to 4kV Emergency Bus D11 (201-D11) for maintenance. The inspectors noted that although one of the two offsite power sources was not available to4kV Emergency Bus D11, operators did not declare the associated offsite power circuit(201 Circuit) inoperable and enter into TS Limiting Condition for Operation (LCO)3.8.1.1, AC Sources V Operating, Action f, which requires, in part, performing Surveillance Requirement (SR) 4.8.1.1.a within one hour and also entails entering a 72hour LCO shutdown action statement. The inspector noted that TS SR 4.8.1.1.1.b could not be met if one of the two offsite power source breakers was racked out. That SR states Each of the above required independent circuits between the offsite transmission network and the onsite Class 1E distribution system shall be demonstrated OPERABLE in accordance with the Surveillance Frequency Control Program by transferring, manually and automatically, unit power supply from the normal circuit to the alternate circuit. With an offsite power supply feeder breaker racked out and unavailable to a nonsite 4kV emergency bus, manual and automatic transfer was not possible. In addition, TS 4.0.1 states, in part, that, Failure to meet a Surveillance, whether such failure is experienced during the performance of a Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation. The inspectors referenced TS Bases 3/4.8.1, which described that an offsite circuit is considered to be inoperable if it is not capable of supplying at least three, Unit 1 4kVemergency buses. Recognizing that the TS Bases 3/4.8.1 appeared to conflict with the SR, the inspectors questioned the history of the bases. Exelon informed the inspectors that the bases were modified in 2000 to define an operable offsite source as one capable of supplying power to three of the four emergency buses in the unit, through Engineering Change Request (ECR) LGS ECR 99-00682.The inspectors reviewed LGS ECR 99-00682 and found that Exelons 10 CFR 50.59screening for the TS bases change concluded that the change was an enhancement, and, as such, a change to the TS was not required. The ECR described the change as taking advantage of system redundancy similar to the design of the EDGs. Specifically, section 8.3.1.1.2.2 of the UFSAR provides results of a single failure analysis (focused on the EDGs but also applicable to the 4kV emergency buses) that concludes that any combination of three-out-of-four buses could withstand a single failure and still safely shut down the plant. The inspectors reviewed the Limerick licensing basis and found several conflicts with Exelons conclusion. Namely, the TS bases change:FnConflicted with the facility as described in the UFSAR Sections 8.2.1, Offsite Power Sources. Section 8.2.1.1 describes that Both offsite sources are available continuously to the Class 1E buses; andFnConflicted with the description of the onsite emergency power system description as documented in NUREG-0991, Safety Evaluation Report Related to the Operation of Limerick Generating Station, Units 1 and 2, dated August 1983. Section 8.3.1 of the Safety Evaluation Report stated that Each 4.16-kV ESF (Engineered Safety Feature) bus is normally connected to two offsite power sources, designated as preferred and alternate power supplyK; and,FnAlthough the ECR described the change as taking advantage of system redundancy similar to the design of the EDGs, the inspector noted that a TS Action is required to be entered for one EDG being inoperable. The inspectors determined that the modification of the TS bases appeared to be in conflict with the requirements of TS LCO 3.8.1.1 through the application of SR4.8.1.1.1.b. Therefore, it appeared that the change should have required a change to the TS, which would have required NRC review. Making the TS bases change without changing the TS appeared to be contrary to 10 CFR 50.59 (c)(1)(i) which states that a licensee may make changes in the facility as described in the final safety analysis reportKwithout obtaining a license amendment pursuant to (paragraph) 50.90 only if a change to the technical specifications incorporated in the license is not required. In addition, the changes made to the TS bases appeared to be contrary to TS 6.8.4.h,Technical Specification Bases Control Program, which contains similar requirements. Exelon acknowledged the inspectors observations and agreed to provide additional information to show that the changes made to the TS bases did not require prior NRC approval. Pending the review of the additional information to be provided by Exelon, this issue is unresolved
05000352/FIN-2008006-01Failure to Implement a Maintenance Activity for the Reactor Building Crane2008Q3A Green non-cited violation (NCV) of 10CFR Part 50, Appendix B, Criterion III, Design Control was identified. The NCV was related to Exelons failure to implement a preventative maintenance requirement described in a design calculation used to upgrade the 125 ton reactor building bridge crane. The finding is more than minor because, if left uncorrected, it could become a more significant safety concern if the crane components were allowed to degrade in an undetected manner. Specifically, the failure to develop the specified preventative maintenance practice could lead to operation of the crane in a degraded condition. The inspectors used Inspection Manual Chapter 0609 Appendix M, Significance Determination Process Using Qualitative Criteria, because other significance determination process guidance was not suited to provide reasonable estimates of the significance of this inspection finding. With the assistance of Region I management, the inspectors determined that the finding was of very low safety significance (Green) because there was no actual crane operational problem during the spent fuel handling activities.
05000352/FIN-2008004-01Inadequate Secondary Containment Control Procedure2008Q3The inspectors identified a NCV of Technical Specification (TS) 6.8.1, Administrative Controls Procedures, because Exelon did not maintain adequate procedures in that Emergency Operating Procedure T-103, Secondary Containment Control, contained an inappropriate high maximum safe operating flooding level for the Unit 2 High Pressure Coolant Injection (HPCI) room. The inspectors determined that this finding was greater than minor because it affected the procedure quality attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring availability, reliability, and capability of the HPCI system. Emergency Operating Procedure T-103, Secondary Containment Control, delineated an incorrect value of 40 inches for the Unit 2 HPCI room maximum safe operating (MSO) flooding level. Water at this height in the Unit 2 HPCI room would submerge the auxiliary oil pump and would render the HPCI system inoperable. This finding is of very low safety significance because it did not represent a design or qualification deficiency, a loss of safety system function, an actual loss of safety function of a single train for greater than its TS allowed outage time, or a total loss of any safety function that contributes to external event-initiated core damage sequences. The inspectors determined that this violation has a crosscutting aspect in the area of problem identification and resolution because Limerick did not perform a thorough extent-of-condition review following a 2005 NCV for a similar issue for the Unit 1 RCIC room MSO level (NCV 05000352/2005003-01). Although the station identified that the Unit 2 HPCI auxiliary oil pump and its associated junction box were located below the MSO level during the review, Limerick did not thoroughly evaluate the impact of the elevation difference on the operation of the HPCI system (P.1(c)). (Section 1R06)
05000352/FIN-2008009-01Failure to Complete Bleeder Trip Valve Testing2008Q3The inspectors identified a finding of very low safety significance for Exelons failure to complete the testing described in the Updated Final Safety Analysis Report (UFSAR) for one of the third stage feedwater heater bleeder trip valves. Exelon entered this issue into the corrective action program under issue reports (IRs) 772753, 812344, 817399, and 817443, and on August 28, 2008, started testing bleeder trip valve XV-002- 108B at the desired frequency stated in the UFSAR. The inspectors determined that this finding is greater than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and has the potential to adversely affect the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Not testing the bleeder trip valves in accordance with the statements in the LGS UFSAR adversely impacted the assumptions in LGSs turbine missile probability analysis thereby potentially increasing the probability for damage to safety-related plant equipment caused by the release of high-energy turbine components. The inspectors evaluated this finding using IMC 0609, Attachment 4, Initial Screening and Characterization of Findings, and determined the finding is of very low safety significance. The inspectors also determined that this issue has a problem identification and resolution cross-cutting aspect in the corrective action area because LGS did not thoroughly evaluate the potential impact of an identified problem on the operability of safety-related equipment. Specifically, Exelon did not evaluate the impact that deferred bleeder trip valve testing may have had on the probability that the operability of safety related equipment could have been impacted by turbine missiles. (P.1(c))
05000352/FIN-2008003-02Licensee-Identified Violation2008Q2Technical Specification 3.3.7.1, Monitoring Instrumentation Radiation Monitoring Instrumentation, requires one operable reactor enclosure cooling water (RECW) system radiation monitor channel at all times. Action 72 of Table 3.3.7.1-1 requires obtaining a grab sample every 24 hours with the required monitor inoperable. Contrary to TS 3.3.7.1, the required RECW Radiation Monitor was inoperable in Unit 2 from March 24, 2008 until April 15, 2008 without obtaining a grab sample every 24 hours. The event is documented in Exelons CAP as IR 763510. The finding was of very low safety significance because it does not represent an open pathway in the physical integrity of reactor containment
05000352/FIN-2008003-01Failure to Correct Adverse Condition Associated with Motor Operated Valves2008Q2The inspectors identified an NCV of Title 10 of the Code of Federal Regulations, Part 50 (10CFR50), Appendix B, Criterion XVI, Corrective Action, for not correcting a condition adverse to quality associated with safety-related motor operated valve motor control center auxiliary contact switches in a timely manner following the failure of the Unit 1 Core Spray Loop A test bypass primary containment isolation valve (HV-052-1F015A) to close on August 3, 2006. As a result, the Unit 2 Reactor Core Isolation Cooling (RCIC) turbine exhaust line vacuum breaker outboard primary containment isolation valve (HV-049-2F080) experienced a similar failure to close on June 4, 2008. The finding was more than minor because it was associated with the structures, systems, and components and barrier containment performance attribute of the Barrier Integrity cornerstone and affected the objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents and events. The inspector assessed the finding using Phase 1 of IMC 0609, Appendix A, Significance Determination Process for Reactor Inspection Findings for At-Power Situations and determined the finding to be of very low safety significance (Green) because the finding did not represent an actual open pathway in the physical integrity of reactor containment. This finding has a crosscutting aspect of Problem Identification and Resolution because Exelon did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with the safety significance and complexity (P.1(d))
05000352/FIN-2008003-03Licensee-Identified Violation2008Q2Technical Specification 3.9.2, Refueling Operations - Instrumentation, requires an operable source range monitor (SRM) in the quadrant where core alterations are being performed when in Operational Condition 5 (OPCON 5). If this requirement is not satisfied, the operators are required to immediately suspend all operations involving core alterations and insert all insertable control rods. Contrary to TS 3.9.2, on March 16, 2008, with Unit 1 in OPCON 5, a control rod was withdrawn with the required source range monitor in the affected core quadrant inoperable. The event is documented in Exelons CAP as IR 750227. The finding is of very low safety significance because the finding did not require quantitative assessment per Checklist 7 of Attachment 1 to IMC 0609, Appendix G, Shutdown Operations Significance Determination Process
05000352/FIN-2008002-01Inadequate Maintenance Procedure for the 2A Main Transformer2008Q1A self-revealing finding was identified for an inadequate maintenance procedure regarding electrical connections associated with the Unit 2A Main Transformer bushings. The procedure was not clear as to the appropriate method to prepare the surface for an aluminum bushing terminal and did not provide adequate information on torque requirements and the use of anti-oxidant grease. This resulted in the failure of the bushing connection and a Unit 2 reactor scram on February 1, 2008. Exelon entered this issue into the corrective action program (CAP), performed repairs, and revised the procedure to reflect the appropriate information to successfully assemble the connection. The issue is more that minor because it is associated with procedure quality attribute of the Initiating Events cornerstone and affected the objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. The inspectors evaluated the finding using Phase 1 of IMC 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations. This finding was determined to be of very low safety significance (Green) because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would be unavailable
05000352/FIN-2008002-03Failure to Promptly Implement Actions for a LOW Sst Level2008Q1Inspectors identified a Green non-cited violation (NCV) of Technical Specification (TS) 6.8.1 for failure to promptly implement actions to recover the Unit 1 skimmer surge tank (SST) level during the 1R12 Unit 1 refueling outage. Prompt action by the operators would have prevented entrainment of the air into the residual heat removal (RHR) system, elevated radiation levels on the refuel floor, and subsequent entry into off-normal procedure ON-120, Fuel Handling Problems. Exelon entered this issue into their CAP for resolution. This finding is more than minor because it affects the human performance attribute of the Initiating Events cornerstone and the objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors evaluated this finding using IMC 0609, Appendix G, Shutdown Operations Significance Determination Process, Attachment 1. This finding is of very low safety significance (Green) because the finding did not require quantitative assessment per Checklist 7 of Attachment 1 to IMC 0609 Appendix G. The reactor time-to-boil during this event was approximately 26 hours and adequate time was available to vent and restart the affected RHR pump in the Alternate Decay Heat Removal (ADHR) mode of operation. Additionally, during the time that ADHR was secured, natural circulation provided reactor coolant flow. This finding has a human performance cross-cutting aspect in the area of work practices. Specifically, operators did not follow OP-AA-103-102, Watchstanding Practices, in that they did not promptly implement actions required by the applicable alarm response procedure to recover SST level following receipt of the associated control room alarm (H.4(b))
05000352/FIN-2008002-02Failure to Correct Main Turbine Bypass Valve Adverse Condition2008Q1The inspectors identified a Green finding for failure to identify corrective actions for an adverse condition associated with unsatisfactory performance of a Unit 1 main turbine bypass valve following an automatic scram event on March 22, 2008. As a result, an appropriate operability determination was not performed and the issue was not considered by the Plant Operations Review Committee during a restart meeting on March 23, 2008. Exelon entered the issue into the CAP for resolution. The finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was assessed using Phase 1 of IMC 0609, Appendix A, Significance Determination for Reactor Inspection Findings for At-Power Situations, and determined to be of very low safety significance (Green) because the finding did not represent an actual loss of safety function of single train for greater than its TS allowed outage time. This finding has a cross-cutting aspect of Problem Identification and Resolution (PI&R) because Exelon did not thoroughly evaluate the problem such that the resolution addressed the cause of the condition or the effect the condition had on system operability (P.1(c))
05000352/FIN-2003004-04DID Not Retain a Record of the 10 CFR 50.54(Q) Review of the Deleted Portions of the Emergency Plan2003Q3The inspector identified a SL IV non-cited violation of 10 CFR 50.54(q). During the implementation of a new Standard Emergency Plan, Exelon did not retain a record that determined whether a decrease-in-effectiveness had or had not occurred when Exelon generated the new Standard Emergency Plan that deleted portions of the previous Combined Limerick/Peach Bottom Emergency Plan Changing emergency plan provisions without documentation impacts the NRC's ability to perform its regulatory function and is therefore processed through traditional enforcement as specified in Section IV.A.3 of the Enforcement Policy, issued May 1, 2000 (65 FR 25388). According to Supplement VIII of the Enforcement Policy, this finding was determined to be a SLl IV because it involved a failure to meet a requirement not directly related to assessment and notification.
05000352/FIN-2003004-03DID Not Perform a 10 CFR 50.54(Q) Review Resulting in Removal of a Provision Without Prior NRC Approval2003Q3The inspector identified a SL IV NCV of 10 CFR 50.54(q) because the licensee decreased the effectiveness of its emergency plan in one area by removing a provision to provide volunteer bus drivers to two school districts within the 10 mile Emergency Planning Zone for evacuating students during a radiological event. The change was implemented without NRC approval Changing emergency plan provisions without prior NRC approval impacts the NRC's ability to perform its regulatory function and is therefore processed through traditional enforcement as specified in Section IV.A.3 of the Enforcement Policy, issued May 1, 2000 (65 FR 25388). According to Supplement VIII of the Enforcement Policy, this finding was determined to be a SL IV violation because it involved a failure to meet a requirement not directly related to assessment and notification. This NCV was also determined to have very low safety significance since Exelon had maintained a list of volunteers that would have been able to perform the function if needed.
05000352/FIN-2003006-0110CFR50.54(Q) Violation for Decreasing the Effectiveness of the Plan by Changing Eals That Address Toxic Gas Without Prior NRC Approval2003Q1The licensee changed its emergency action level schemes such that there would e a reduction in declarable events as the emphasis shifted from personnel safety to equipment status. The changes were determined to be a decrease in the effectiveness of the emergency plans. Decreases in the effectiveness of an emergency plan must receive NRC review prior to implementation. The changes were implemented without NRC approval. The finding was determined to be more than minor as its significance was related to the impact it would have on the mobilization of the emregency response organization and preclude offsite agencies from being aware of adverse conditions on site. The licensee accepted the NRC's position and entered this issue into its corrective action program (Condition Report 139997) and will change the emergency action levels back to the original wording. The implementation of the changes which decreased the effectiveness of the emergency plans, without NRC review, is being treated as a non-cited violation consistent with Section VI.A. of the Enforcement Policy, issued on May 1, 2000 (65 FR 25388). (NCV 50-277; 50-278/03-008-01 and 50-352;50-353/03-006)
05000352/FIN-2000005-01an NCV of 10 CFR 50, Appendix B, Criterion V Was Identified Associated with Five Examples of Failure to Implement the Written Procedures of the Corrective Action Program2000Q2A Non-cited Violation of 10 CFR 50, Appendix B, Criterion V, wa identified associated with five examples of failure to implement the written procedures o the corrective action program, an activity affecting quality. Four examples involve failure to properly classify adverse trend corrective action items as required by th corrective action program procedure LR-CG-10. The adverse trend items wer associated with various topics including component mis-positioning, procedur adherence, and reactor downpower events. The fifth example of failure to implemen LR-CG-10 involved failure to conduct an operability evaluation of emergency diese generators (EDGs) in April 2000, when PECO determined that 70 of 88 flexcouplin clamps on the cooling water systems of its EDGs were over tightened. The failure t implement the procedures of the corrective action program is considered more than minor violation in that it suggests a programmatic problem that has a credible potentia to impact safety and involved more than an isolated occurrence. (4OA2.3)
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