IR 05000352/2013503

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

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

Text

UNITED STATES ary 2, 2014

SUBJECT:

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

Dear Mr. Pacilio:

On November 21, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of the November 19, 2013, evaluated emergency preparedness exercise at your Limerick Generating Station, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on November 21, 2013, with Mr. T. Dougherty, Site Vice President, and other members of your staff.

The inspection examined activities conducted under your licenses as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your licenses. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, no findings were identified.

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

Sincerely,

/RA/

Anthony Dimitriadis, Chief Plant Support Branch 1 Division of Reactor Safety Docket Nos.: 50-352, 50-353 License Nos.: NPF-39, NPF-85

Enclosure:

NRC Inspection Report No. 05000352/2013503 and 05000353/2013503

REGION I==

Docket Nos.: 50-352, 50-353 License Nos.: NPF-39, NPF-85 Report Nos.: 05000352/2013503 and 05000353/2013503 Licensee: Exelon Generation Company, LLC Facility: Limerick Generating Station, Units 1 & 2 Location: Sanatoga, PA 19464 Dates: November 18-22, 2013 Inspectors: S. Barr, Sr. Emergency Preparedness Inspector, DRS, Region I (Lead)

E. Burket, Emergency Preparedness Inspector, DRS, Region I D. Silk, Senior Operations Inspector, DRS, Region I J. Patel, Reactor Inspector, DRS, Region I J. Laughlin, Emergency Preparedness Specialist, DPR, NSIR A. Dimitriadis, Branch Chief, DRS, Region I Approved By: Anthony Dimitriadis, Chief Plant Support Branch 1 Division of Reactor Safety i Enclosure

SUMMARY OF FINDINGS

Inspection Report 05000352/2013503; 05000353/2013503; 11/18-22/2013; Limerick Generating

Station, Units 1 and 2; Exercise Evaluation - Hostile Action (HA) Event; Exercise Evaluation -

Scenario Review; Performance Indicator Verification.

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

NRC-Identified and Self-Revealing Findings

None.

B. Licensee-Identified Findings None.

ii

REPORT DETAILS

REACTOR SAFETY

Cornerstone: Emergency Preparedness (EP)

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

a. Inspection Scope

Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix E, Section IV.F.2.j, requires in part that nuclear power reactor licensees, in each eight calendar year exercise cycle, provide the opportunity for their emergency response organization (ERO) to demonstrate proficiency in the key skills necessary to respond to a hostile action (HA) directed at the plant site. Exelon designed the November 19, 2013, Limerick EP exercise to satisfy that requirement, and the NRC inspected the Limerick HA event exercise to assess Exelons ability to effectively implement the Limerick Emergency Plan during an HA event and adequately protect public health and safety.

This overall exercise inspection activity represented the completion of one sample on a biennial cycle.

The exercise evaluation consisted of the following review and assessment:

The adequacy of Exelon EROs performance in the biennial full-participation exercise regarding the implementation of the planning standards described in 10 CFR 50.47(b) (4), (5), (9), and (10), which are: emergency classification; offsite notification; radiological assessment; onsite protective actions, and public protective action recommendations, respectively.

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

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

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

The licensees post-exercise critiques, to evaluate Exelons self-assessment of its Limerick ERO performance during the November 19, 2013, exercise and to ensure compliance with 10 CFR Part 50, Appendix E, Section IV.F.2.g.

The inspectors reviewed the documents listed in the attachment to this report.

b. Findings

No findings were identified.

1EP8 Exercise Evaluation - Scenario Review (71114.08 - 1 Sample)

a. Inspection Scope

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

The inspectors reviewed the documents listed in the attachment to this report.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification (71151 - 3 Samples)

a. Inspection Scope

The inspectors reviewed data for the Limerick EP Performance Indicators (PI), which are:

(1) Drill and Exercise Performance (DEP) (EP01);

(2) ERO Drill Participation (EP02); and,

(3) Alert and Notification System (ANS) Reliability (EP03). The last NRC EP inspection at Limerick was conducted in the fourth calendar quarter of 2012, so the inspectors reviewed supporting documentation from EP drills and tests from the fourth calendar quarter of 2012 through the third calendar quarter of 2013, to verify the accuracy of the reported PI data. The review of these PIs was conducted in accordance with NRC Inspection Procedure 71151, using the acceptance criteria documented in NEI 99-02, Regulatory Assessment Performance Indicator Guidelines, Revision 7.

This inspection activity represented the completion of three samples.

b. Findings

No findings were identified.

4OA6 Meetings, including Exit

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

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

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Dougherty, Site Vice President

V. Cwietniewicz, Exelon Mid-Atlantic Emergency Planning Manager

J. Broillet, Limerick Emergency Planning Manager

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

None.