IR 05000352/2022010
| ML22068A165 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/09/2022 |
| From: | Jon Greives Division of Operating Reactors |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| Haney S | |
| References | |
| IR 2022010 | |
| Download: ML22068A165 (12) | |
Text
March 9, 2022
SUBJECT:
LIMERICK GENERATING STATION, UNITS 1 AND 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000352/2022010 AND 05000353/2022010
Dear Mr. Rhoades:
On February 18, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Limerick Generating Station, Units 1 and 2 and discussed the results of this inspection with Mr. Michael Gillin, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No findings or violations of more than minor significance were identified during this inspection. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Jonathan E. Greives, Chief Projects Branch 4 Division of Operating Reactor Safety
Docket Nos. 05000352 and 05000353 License Nos. NPF-39 and NPF-85
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000352 and 05000353
License Numbers:
Report Numbers:
05000352/2022010 and 05000353/2022010
Enterprise Identifier: I-2022-010-0013
Licensee:
Constellation Energy Generation, LLC
Facility:
Limerick Generating Station, Units 1 and 2
Location:
Sanatoga, PA 19464
Inspection Dates:
January 31, 2022 to February 18, 2022
Inspectors:
L. Casey, Senior Project Engineer
L. Grimes, Resident Inspector
S. Haney, Senior Project Engineer
M. Hardgrove, Resident Inspector
Approved By:
Jonathan E. Greives, Chief
Projects Branch 4
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Limerick Generating Station, Units 1 and 2, in accordance with the Reactor Oversight Process.
The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Due to COVID-19 Public Health Emergency concerns, the inspection was performed using a hybrid approach, with some portions, where appropriate, were performed off-site. The inspection documented below met the objectives and requirements for completion of the IP.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The team performed a biennial assessment of the effectiveness of Constellation Energy Generation, LLCs (Constellations) problem identification and resolution program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Problem Identification and Resolution Effectiveness: The team assessed the effectiveness of Constellations problem identification and resolution program in identifying, prioritizing, evaluating, and correcting problems. The team also conducted a five-year review of Unit 1 and Unit 2 emergency diesel generator emergency start relay replacements and changes to Unit 1 and Unit 2 moisture carryover operating limit basis.
- Operating Experience: The team assessed the effectiveness of Constellation's processes for use of operating experience.
- Self-Assessments and Audits: The team assessed the effectiveness of Constellations identification and correction of problems identified through audits and self-assessments.
- Safety Conscious Work Environment: The team assessed the effectiveness of the stations programs to establish and maintain a safety conscious work environment.
INSPECTION RESULTS
Assessment 71152B Problem Identification and Resolution Program Effectiveness -
Problem Identification: The team determined that Constellation identified issues and entered them into the problem identification and resolution program at a low threshold.
Problem Prioritization and Evaluation: Based on the samples reviewed, the team determined that, in general, Constellation appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. In most cases, Constellation appropriately screened issue reports (IRs) for operability and reportability, categorized IRs by significance, and assigned actions to the appropriate department for evaluation and resolution.
However, the team identified two minor performance deficiencies regarding Constellation's prioritization and evaluation of issues. The first minor performance deficiency was related to the classification of Maintenance Rule functional failures as conditions adverse to quality in the problem identification and resolution program. The second minor performance deficiency was related to the stations evaluation of a low safety significant (LSS) trend in accordance with the Maintenance Rule program. Additional details about these minor performance deficiencies are included later in this report.
Corrective Actions: The team determined that the overall problem identification and resolution program performance related to resolving problems was effective. In general, Constellation implemented corrective actions to resolve problems in a timely manner.
Assessment 71152B Use of Operating Experience: The team determined that Constellation appropriately evaluated industry operating experience for its relevance to Limerick Generating Station.
Constellation appropriately incorporated both internal and external operating experience into plant procedures and processes, as well as lessons learned for training and pre-job briefs.
While the team determined the station appropriately evaluated industry and NRC operating experience, the team identified one observation related to the dissemination of operating experience for Maintenance Rule LSS trends externally to the industry.
Self-Assessments and Audits: The team reviewed a sample of self-assessments and audits to assess whether Constellation was identifying and addressing performance trends. The team concluded that Constellation had an effective self-assessment and audit process.
Assessment 71152B Safety Conscious Work Environment: The team interviewed approximately 24 individuals.
The purpose of these interviews was to evaluate the willingness of Constellation staff to raise nuclear safety issues; to evaluate the perceived effectiveness of the problem identification and resolution program at resolving identified problems; and to evaluate Constellation's safety conscious work environment. The personnel interviewed were randomly selected by the team from the Operations, Engineering, Maintenance, Security, Chemistry, Radiation Protection, and Emergency Preparedness work groups. To supplement these discussions, the team interviewed the Employee Concerns Program (ECP) representative to assess his perception of the site employees' willingness to raise nuclear safety concerns. The team also reviewed the ECP case log and select case files.
All individuals interviewed indicated that they would raise safety concerns. All individuals felt that their management was receptive to receiving safety concerns and generally addressed them promptly, commensurate with the significance of the concern. Interviewees indicated they were adequately trained and proficient on initiating condition reports. All interviewees were aware of Constellation's ECP, stated they would use the program if necessary, and expressed confidence that their confidentiality would be maintained if they brought issues to the ECP. When asked whether there have been any instances where individuals experienced retaliation or other negative reaction for raising safety concerns, all individuals interviewed stated that they had neither experienced nor heard of an instance of retaliation at the site.
The team determined that the processes in place to mitigate potential safety conscious work environment issues were adequately implemented.
Minor Performance Deficiency 71152B Minor Performance Deficiency: The team identified one minor performance deficiency related to the classification of Maintenance Rule functional failures as conditions adverse to quality in the problem identification and resolution program. Step 4.6.4.3 of procedure PI-AA-120, Issue Identification and Screening Process, directs the Station Ownership Committee to coordinate with line department representatives to identify programmatic or organizational impacts such as Maintenance Rule functional failures or potential Maintenance Rule functional failures. Further, Step 4.6.6.3 directs the Station Ownership Committee to determine the significance of corrective action program issues in accordance with Attachment 2, Issue Report Level and Class Criteria. In the Significance Level 3 guidance of Attachment 2, the Asset Management-Equipment Reliability examples list Maintenance Rule functional failure or potential Maintenance Rule a(1) Condition, in accordance with Maintenance Rule procedure.
Contrary to that PI-AA-120 guidance, the team identified two potential Maintenance Rule a(1)conditions that were classified as Significance Level 4. IR 4364623, written for a LSS trend in H2O2 analyzer calibration failures, and IR 4450131, written for a condition monitoring event due to a service air compressor trip, each documented potential Maintenance Rule (a)(1)conditions and should have been subsequently classified as Significance Level 3.
Screening: The inspectors determined the performance deficiency was minor. Because although those IRs were classified as Significance Level 4, existing work requests to address those issues would have been acceptable corrective actions to address the conditions adverse to quality. This minor performance deficiency is captured in IR 4478628.
Minor Performance Deficiency 71152B Minor Performance Deficiency: The team identified one minor performance deficiency related to the stations evaluation of a LSS trend in accordance with the Maintenance Rule program.
Step 4.2.5.1 and 4.2.5.5 of ER-AA-320-1004, Maintenance Rule 18-10 - Performance Monitoring and Dispositioning between (a)(1) and (a)(2), directs the system manager to obtain LSS events for monitoring and trending from station IRs and determine if an adverse trend in structure, system, or component performance is identified. Performance monitoring identified a LSS trend in H2O2 analyzer calibration failures as documented in IRs 4263434 and 4364623. Step 4.4.2. requires an (a)(1) determination when any of the conditions in step 4.4.1 exist. Step 4.4.1 lists LSS structure, system, or component exhibiting an unacceptable trend in performance. Contrary to the ER-AA-320-1004 guidance, the team identified the documented (a)(1) determination for IR 4364623 was not in compliance with the Maintenance Rule process in retaining the system in (a)(2) status based on the addition of preventive maintenance as recommended by the vendor.
Screening: The inspectors determined the performance deficiency was minor. The H2O2 analyzer system was appropriately in (a)(2) status, but not for the reasons determined in the (a)(1) determination. It was later determined during this inspection that an adverse LSS trend did not exist because one of the calibration failures did not result in a loss of function, and as such the (a)(1) determination was unnecessarily performed. This minor performance deficiency is captured in IR 4478628.
Observation: Maintenance Rule Low Safety Significant Trend Not Disseminated as Operating Experience 71152B The team identified one observation related to the dissemination of operating experience for Maintenance Rule LSS trends. Step 4.6.4.4.A of procedure PI-AA-120 directs the Station Ownership Committee to determine operating experience for Significance Level 1, 2, or 3 issues in accordance with PI-AA-115-1004. Step 4.2.1 of PI-AA-115-1004, Processing of NEB and IRIS Reports, states to screen plant events for sharing with the industry that meet INPO 19-002 reporting criteria, and that Form 3 of that procedure may be used as a guide. The criteria in Form 3, of PI-AA-115-1004-F-03, IRIS Report Screening Form, are derived from INPO 19-002, Industry Reporting and Information System (IRIS) Reporting Requirements, and list:
- All Maintenance Rule functional failures
- Maintenance Rule condition monitoring criteria exceeded
- Maintenance Rule plant-level monitoring criteria exceeded
INPO 19-002 and therefore Form 3 of PI-AA-115-1004 have not been updated to reflect a major revision to the Maintenance Rule program known as Maintenance Rule 2.0, so LSS trend, a fourth potential Maintenance Rule (a)(1) condition, is not listed. As a result, IR 4364623, written for a Maintenance Rule LSS trend in H2O2 analyzer calibration failures, did not have an IRIS Report generated to disseminate that operating experience.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On February 18, 2022, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Michael Gillin, Plant Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CAPE 4337800
Li1R18LL: Estimated Dose Impact of Co Carryover
07/08/2020
CAPE 4346892
Unit 1 Suppresion Pool High Oxygen Concentration
07/14/2020
CAPE 4372283
1B ASD Coolant Leak
11/19/2020
CAPE 4377981
Excavation work caused leak in 36 inch Service water pipe
2/24/2021
CAPE 4410585
Circulating Water Leak From Piping
01/06/2021
CAPE 4423923
2R16 WHR Violation
06/24/2021
CAPE 4437521
FME - "C" MSLP PM identified missing parts
09/16/2021
ECAPE 4145616
1B ASD Coolant System Leak
2/23/2021
ECAPE 4202624
Limerick U1 Fuel Cladding Defect Identified By Routine
Chemistry Offgas Sampling
2/02/2021
Issue Reports
(IRs)
4337001, 4364623, 4372283, 4391308, 4430911, 4443754,
4448242, 4450131
RCR 4337051
HV-051-1F024A Inoperable due to Foreign Material
06/15/2020
RCR 4384039
Unexpected Closure of 1B Inboard MSIV (HV-041-1F022B)
Resulted in Automatic High Reactor Pressure Scram
01/18/2021
RCR 4384739
Unit 1 HPCI and RCIC not Aligned for Service Per GP-2
01/08/2021
Corrective Action
Documents
Resulting from
Inspection
Issue Reports
(IRs)
4475545, 4475826, 4475858, 4475861, 4475863, 4475866,
4477463, 4476112, 4478242, 4478628
Engineering
Changes
25675
Unit 1 - ASD Obsolescence and Cooling Upgrades
25675
Unit 1 - ASD Obsolescence and Cooling Upgrades
25675
Unit 1 - ASD Obsolescence and Cooling Upgrades
Engineering
Evaluations
4343534
20 Maintenance Rule Periodic (a)(3) Assessment
Limerick GNF2 1C19 EOC MCO Operating Limit Increase
05/25/2021
Miscellaneous
LG-MRULE-005
LGS Maintenance Rule Risk Ranking
Procedures
Nuclear Risk Management Process
Configuration Control Process Description
Design Input and Configuration Change Impact Screening
Configuration Change Control for Permanent Physical Plant
Changes
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Configuration Change Control for Permanent Physical Plant
Changes
CC-AA-103-F-02
Engineering Change Material List
Maintenance Rule Implementation per NEI 18-10
Maintenance Rule 18-10 - Failure Definition
Maintenance Rule 18-10 - Performance Monitoring and
Dispositioning between (a)(1) and (a)(2)
ER-LG-310-1010
Maintenance Rule Implementation Limerick Generating
Station
IP-ENG-001
Common Design Package
Conduct of Maintenance Manual
Station Rework Reduction Program
Quality Assurance Topical Report
Nuclear Oversight Audit Handbook
Inspection Planning and Execution of Quality Inspection
Activities
Operator Work-Around Program
OP-AA-102-103-
1001
Operator Burden and Plant Significant Decisions Impact
Assessment Program
Refuel Outage Management
Forced Maintenance Outage Management
Performance Monitoring and Analysis Manual
Safety Culture Monitoring
Operating Experience Program
Processing of NEB and IRIS Reports
Issue Identification and Screening Process
Corrective Action Program (CAP) Procedure
Root Cause Analysis Manual
Corrective Action Program Evaluation Manual
Effectiveness Review Manual
Investigation Techniques Manual
Self-Assessments
Self-Assessments 4308207
Preparation for NRC Problem Identification & Resolution
05/14/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
(PI&R) NRC Inspection
4454542
Pre-PI&R Self Assessment
01/24/2022
NOSA-COMP-21-
21 Corrective Action Program Comparative Audit Report
10/29/2021
NOSA-LIM-21-05
Corrective Action Program Audit Report
09/01/2021
Work Orders
4965694