IR 05000352/2014008
| ML14310A099 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/05/2014 |
| From: | Fred Bower Reactor Projects Region 1 Branch 4 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2014008 | |
| Download: ML14310A099 (19) | |
Text
UNITED STATES vember 5, 2014
SUBJECT:
LIMERICK GENERATING STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION 05000352/2014008 AND 05000353/2014008
Dear Mr. Pacilio:
On October 3, 2014, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Limerick Generating Station, Units 1 and 2. The enclosed report documents the inspection results discussed on October 3, 2014, with Mr. David Lewis, Plant Manager and other members of your staff.
This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commissions rules and regulations and conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.
Based on the samples selected for review, the inspectors concluded that Exelon was generally effective in identifying, evaluating, and resolving problems. Exelon personnel identified problems and entered them into the corrective action program at a low threshold. Exelon prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were implemented in a timely manner.
The inspectors documented a minor violation containing security-related information, which is provided as Enclosure 2. This deficiency was promptly corrected or compensated for and the plant was in compliance with applicable physical protection and security requirements within the scope of this inspection, before the inspectors left the site. If you contest the minor violation or the teams observations in Enclosure 2, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Limerick Generating Station. As this information is security-related, please ensure your response is properly marked and handled.
Enclosure 2 contains Sensitive Unclassified Non-Safeguards Information. When separated from enclosure, the transmittal document is decontrolled. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, of the NRCs Rules of Practice, a copy of this letter, 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 (ADAMS).
ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Fred L. Bower, III, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos.: 50-352; 50-353 License Nos.: NPF-39, NPF-85 Enclosure 1 (Public):
Inspection Report 050000353/2014008
w/Attachment:
Supplementary Information Enclosure 2 (Non-Public):
Inspection Report 05000353/2014008 w/Attachment: Supplementary Information (CONTAINS (OUO-SRI))
REGION I==
Docket Nos.: 50-352; 50-353 License Nos.: NPF-39, NPF-85 Report Nos.: 05000352/2014008 and 05000353/2014008 Licensee: Exelon Generation Company, LLC Facility: Limerick Units 1 and 2 Location: Sanatoga, Pennsylvania Dates: September 15 - 19, 2014 September 29 - October 3, 2014 Team Leader: R. Barkley, PE, Senior Project Engineer Inspectors: E. Andrews, Project Engineer B. Lin, Project Engineer R. Montgomery, Resident Inspector - Limerick Approved by: Fred L. Bower, III, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure 1 2
SUMMARY OF FINDINGS
IR 05000352/2014008, 05000353/2014008, 09/15/2014 - 10/03/2014; Limerick Units 1 and 2;
Identification and Resolution of Problems.
This NRC team inspection was performed by one senior project engineer, two regional inspectors, and one resident inspector. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
Problem Identification and Resolution The inspectors concluded that Exelon was generally effective in identifying, evaluating, and resolving problems. Exelon personnel typically identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with their safety significance. Exelon appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that Exelon implemented corrective actions to address the problems identified in the corrective action program in a timely manner.
The inspectors concluded that Exelon adequately identified, reviewed, and applied relevant industry operating experience to Limerick operations. In addition, based on those items selected for review, the inspectors determined that Exelons self-assessments and audits were thorough.
Based on limited interviews of employees and contractors the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues nor did they identify any conditions that could have had a negative impact on the sites safety conscious work environment.
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REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. All documents reviewed during this inspection are listed in the Attachment to this report.
.1 Assessment of Corrective Action Program Effectiveness
a. Inspection Scope
The inspectors reviewed the procedures that described Exelons corrective action program at Limerick Unit 1 & 2. To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in these areas to the requirements and standards contained in Title 10 of the Code of Federal Regulations (10 CFR), Appendix B, Criterion XVI, Corrective Action, and Exelon procedure PI-AA-125, Revision 0, Corrective Action Program Procedure. For each of these areas, the inspectors considered risk insights from the stations risk analysis and reviewed issue reports (IRs) selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. Additionally, the inspectors attended plan-of-the-day, station ownership committee, and management review committee meetings. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, and oversight programs.
- (1) Effectiveness of Problem Identification In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports. The inspectors also completed field walkdowns of various buildings onsite, including the reactor, turbine, radwaste, and circulating water buildings as well as the spray pond pump house.
Additionally, the inspectors reviewed a sample of IRs written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that Exelon entered conditions adverse to quality into their corrective action program as appropriate.
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- (2) Effectiveness of Prioritization and Evaluation of Issues The inspectors reviewed the evaluation and prioritization of a sample of IRs issued since the last NRC biennial problem identification and resolution inspection completed in early November 2012. The inspectors also reviewed IRs that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.
- (3) Effectiveness of Corrective Actions The inspectors reviewed Exelons completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed IRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Exelons timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of IRs associated with selected non-cited violations (NCVs) and findings to verify that Exelon personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate Exelon actions related to the condition of the 13 kV electrical system and the Residual Heat Removal Service Water (RHRSW)piping system.
b.
Assessment
- (1) Effectiveness of Problem Identification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Exelon identified problems and entered them into the corrective action program at a low threshold. Exelon staff at Limerick initiated nearly 30,000 IRs between November 2012 and September 2014. The inspectors observed supervisors at the plan-of-the-day, station ownership committee, and management review committee meetings appropriately questioning and challenging issue reports to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that Exelon trended equipment and programmatic issues, and appropriately identified problems in issue reports. The inspectors verified that conditions adverse to quality identified through these reviews were entered into the corrective action program as appropriate. Additionally, inspectors concluded that personnel were identifying trends at a low threshold.
1 5 With few exceptions, inspectors found that issues or concerns had been appropriately entered into the corrective action program for evaluation and resolution. However, in response to questions and equipment observations identified by the inspectors during plant walkdowns in the radwaste building and the spray pond pump house, Exelon personnel promptly initiated IRs and/or took prompt action to address the issues. The material condition of equipment in these two areas was distinctly different than the rest of the facility. In response, Limerick management noted an effort recently initiated to improve the material condition of the radwaste control room as well as the procedures governing its conduct of operations.
- (2) Effectiveness of Prioritization and Evaluation of Issues In general, the inspectors determined that Exelon appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem, with the exception of the issues documented in Enclosure 2. Exelon screened IRs for operability and reportability, categorized the issue reports by significance, and assigned actions to the appropriate department for evaluation and resolution. The IR screening process considered human performance issues, radiological and industrial safety concerns, repetitiveness, adverse trends, and the potential impact on the safety conscious work environment.
Based on the sample of issue reports reviewed, the inspectors noted that the guidance provided by Exelon corrective action program implementing procedures appeared sufficient to ensure consistency in categorization of issues. This was supported by the review of four SOC packages, attendance at two MRC meetings, and the review of approximately 200 IRs.
- (3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were typically timely and adequately implemented. For significant conditions adverse to quality, Exelon identified actions to prevent recurrence and corrective actions to address the sample of NRC NCVs, issued since the last problem identification and resolution inspection, were also timely and effective.
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors reviewed a sample of IRs associated with the review of industry operating experience to determine whether Exelon appropriately evaluated the operating experience information for applicability to Limerick, and had taken appropriate actions when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Exelon adequately considered the underlying problems associated with the issues for 1 6 resolution via their corrective action program. In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.
b. Assessment The inspectors determined that Limerick appropriately considered both Exelon-fleet and industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also observed that industry operating experience was routinely discussed and considered during daily meetings.
c. Findings
No findings were identified.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors reviewed a sample of audits and self-assessments, including recent reviews of the corrective action program, selected departments, and assessments performed by independent organizations. Inspectors performed these reviews to determine if Exelon entered problems identified through these assessments into the corrective action program, when appropriate, and whether Exelon initiated corrective actions to address identified deficiencies.
b. Assessment The inspectors concluded that self-assessments, audits, and other internal Exelon assessments were critical, thorough, and effective in identifying issues. The inspectors observed that Exelon personnel knowledgeable in the subject completed these audits and self-assessments, and that individuals across the Exelon fleet were brought in to support these assessments and provide diverse and objective insights. Exelon completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. The station implemented corrective actions associated with the identified issues commensurate with their safety significance.
c. Findings
No findings were identified.
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.4 Assessment of Safety Conscious Work Environment
a. Inspection Scope
During interviews station and contractor personnel, the inspectors assessed the safety conscious work environment at Limerick. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors also interviewed station Employee Concerns Program counselors to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns. The inspectors reviewed selected Employee Concerns Program files to ensure that Exelon entered issues into the corrective action program when appropriate, and that senior Limerick management was promptly informed of sensitive performance issues involving department supervisors or managers.
b. Assessment During interviews of staff conducted in multiple departments, Limerick staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the corrective action program and the Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.
One observation made during these interviews was passed onto Limerick management, specifically that the majority of employees interviewed thought that they could submit an IR anonymously in the CAP. While this process once existed, it was discontinued several years ago, although employees do have the option of providing such a concern to the ECP, or place it anonymously in an Ask the SVP drop box. Limerick management acknowledged the inspectors observation and were evaluating how best to reemphasize to their employees the available avenues to communicate concerns anonymously.
c. Findings
No findings were identified.
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4OA6 Meetings, Including Exit
On October 3, 2014, the inspectors presented the inspection results to Mr. David Lewis, Plant Manager, and other members of the Limerick staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
- M. Arnosky, Shift Manager
- J. Berg, System Engineer
- J. Brittain, System Engineer
- G. Broillet, EP Manager
- G. Budock, Senior Regulatory Engineer
- F. Burzynski, Fire Marshall
- I. Choudhry, ECP Counselor
- R. Dickinson, Manager - Regulatory Assurance
- M. Gillen, Shift Operations Superintendent
- C. Gulotta, Manager Site Security Operations
- J. Karkoska, Nuclear Oversight Manager
- M. Klick, Performance Improvement Director
- L. Lail, Maintenance Engineer
- A. Lambert, System Engineer
- N. Lampe, System Engineer
- A. Lopez, Security Shift Supervisor
- J. MacDonald, EP Specialist
- R. McCall, Principal Regulatory Engineer
- J. Mills, System Engineer
- J. Murphy, Senior Operations Supervisor
- R. Nealis, Chemistry Supervisor
- D. Nugent, System Engineer
- D. Poindexter, Security Program Lead
- W. Pulford, Senior Reactor Operator
- B. Shultz, Manager Operations Support
- R. Smith, Operations Engineer
- G. Sprissler, Chemistry analyst
- J. Thoryk, Fire Protection Engineer
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
None A-2