IR 05000352/2011502

IR 05000352-11-502 and 05000353-11-502: 11/14/2011 - 11/17/2011; Limerick Generating Station; Exercise Evaluation; Emergency Action Level and Emergency Plan Changes; Emergency Prepared Ness Performance Indicators

ML11343A618
Person / Time
Site:	Limerick
Issue date:	12/08/2011
From:	Trapp J M Plant Support Branch 1
To:	Pacilio M J Exelon Generation Co
References
IR-11-502
Download: ML11343A618 (11)

Text

UNITED STATES NUCLEAR REGU LATORY COMMISSION REGION I 475 ALLENDALE ROAD KING OF PRUSSlA, PA 19406-1415 December 8, 2011 Mr. Michael Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Rd.Warrenville, lL 60555

SUBJECT: LIMERICK GENERATING STATION _ NRC EVALUATED EMERGENCY PREPAREDNESS EXERCISE - INSPECTION REPORT NOS.05000352/201 1 502 AN D 050003531 201 1 502

Dear Mr. Pacilio:

On November 17,2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of the November 15,2011, evaluated emergency preparedness exercise at your Limerick Generating Station. The enclosed inspection report documents the inspection results, which were discussed on November 17, 2011, with Mr. W. Maguire, Site Vice President, and other members of your staff.The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

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

ln accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure and your response (if any) will be available electronicalty for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system, Agencynrvide 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,AA 9r JN ++-U James M. Trapp, Chief Plant Support Branch 1 Division of Reactor Safety December 8,2011 Mr. MichaelJ.

Pacilio Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Rd.Warrenville.

lL 60555

SUBJECT: LIMERICK GENERATING STATION - NRC EVALUATED EMERGENCY PREPAREDNESS EXERCISE - INSPECTION REPORT NOS.05000352/201 1 502 AN D 050003531201 1 502

Dear Mr. Pacilio:

On November 17, 2011,the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of the November 15,2011, evaluated emergency preparedness exercise at your Limerick Generating Station. The enclosed inspection report documents the inspection results, which were discussLd on November 17,2Q11, with Mr. W. Maguire, Site Vice President, and other members of your staff.The inspection examined activities conducted under your license as they relate to safety and compliance w1h the Commission's rules and regulations and with the conditions of your license.The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

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

ln accordance with 10 CFR 2.390 of the NRC's "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 NRC's document system, Agencywide Documents Access and Management System (ADAIVIS)'

ADAMS is accessible from tne ruifC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,IRAI James M. Trapp, Chief Plant Support Branch 1 Division of Reactor SafetY ADAMS Accession No: ML11343A618 Docket Nos.: 50-352, 50-353 License Nos.: NPF-39. NPF-85

Enclosure:

NRC lnspection Report Nos. 05000352/2011502 and 0500035312011502 cc Mencl: G. Cannon, Director, PA Emergency Management Agency (PEMA)and Homeland Security Advisor cc w/encl: Distribution via ListServ Distribution wiencl: W. Dean, RA (RIORAMAIL Resource)D. Lew, DRA (RIORAMAIL Resource)D. Roberts, DRP (RIDRPMAlL Resource)D. Ayres, DRP (RIDRPMAIL Resource)C. Miller, DRP (RlDRSMail Resource)P. Wilson, DRS (RlDRSMail Resource)P. Krohn, DRP A. Rosebrook, DRP S. lbarrola, DRP E. Miller, DRP E. DiPaolo, DRP, SRI N. Sieller, DRP, Rl N. Esch, DRP, Admin Asst.M. Franke, Rl, OEDO RidsNrrPM Limerick Resource Rids N rrDorlLpll

-2 Resou rce ROPreports Resource D. Bearde, DRS R. Kahler, NSIR/EPD S. LaVie, NSIFYEPD S. Barr, DRS J. Trapp, DRS U.S. NUCLEAR REGULATORY COMMISSION REGION I Docket Nos.: 05000352,05000353 License Nos.: NPF-39, NPF-85 Report No.: 05000352i2Q11502,05000353/2011502 Licensee:

Exelon Generation Company, LLC Facility:

Limerick Generating Station, Units 1 and 2 Location:

Sanatoga, PA 19464 Dates: November 14 - 17,2011 lnspectors:

S. Barr, Sr. Emergency Preparedness lnspector, Division of Reactor Safety (DRS), Region I (Lead)M. Roberts, Senior Health Physicist, Division of Nuclear Materials (DNMS), Region I E. DiPaolo, Senior Resident lnspector, Division of Reactor Prolects (DRP), Region I E. Miller, Project Engineer, DRP, Region I N. Floyd, Reactor Engineer, DRP, Region I C. Crisden, Emergency Preparedness lnspector, DRS, Region I Approved by: James M. Trapp, Chief Plant Support Branch 1 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

lR 0500035212011502 and 0500035312011502:1111412011 - 1111712011;

Limerick Generating Station; Exercise Evaluation;

Emergency Action Level and Emergency Plan Changes;Emergency Prepared ness Perfo rma nce I nd icators.This was an announced inspection conducted by six region-based inspectors.

No findings were identified.

The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Cornerstone: Emergency

Preparedness No findings were identified.

REPORT DETAILS

1. REACTOR SAFEW Cornerstone:

Emergency Preparedness (EP)1EP1 Exercise Evaluation (71114.01 - 1 Sample)a. Inspection Scope Prior to the November 15, 2011, 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 Title 10 of the Code of Federal Regulations (10 CFR) 50.47(bX14).

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's performance in the biennial full-participation exercise regarding the implementation of the risk-significant planning standards (RSPS)described in 10 CFR 50.47(bX4), (5), (9), and (10), which are: emergency classification; offsite notification; radiological assessment; and protective action recommendations, respectively.

o The overall adequacy of Exelon's Limerick emergency response facilities with regard to NUREG-0696, "Functional Criteria for Emergency Response Facilities," and Emergency Plan commitments.

The facilities assessed were the Control Room Simulator, Operations Support Center (OSC),Technical Support Center (TSC), Emergency Operations Facility (EOF), and the Joint Information Center (JlC).o A review of other performance areas, such as: the Limerick emergency response organization's (ERO) recognition of abnormal plant conditions; command and control; intra- and inter-facility communications; prioritization of mitigating activities; utilization of repair and field monitoring teams; interface with offsite agencies;staffing and procedure adequacy; and the overall implementation of the emergency plan and its implementing procedures.

r A review of past performance issues from the last NRC Limerick EP exercise inspection report and Exelon's Limerick EP drill reports, to determine the effectiveness of licensee corrective actions as demonstrated during the November 15, 2011, exercise and to ensure compliance with 10 CFR 50.47(b)(14).

o The licensee's post-exercise critiques, to evaluate Exelon's self-assessment of its ERO performance during the November 15, 2011, Limerick exercise and to ensure compliance with 10 CFR Part 50, Appendix E, Section lV.F.2.g.Enclosure 2 The inspectors reviewed the documents listed in the attachment to this report.b. Findinqs No findings were identified.

1EP4 Emerqencv Action Level and Emeroencv Plan Changes (71114.04 - 1 Sample)a. lnspection Scope Since the last NRC inspection of this program area, in December 2010, Exelon implemented various revisions of the different sections of the Limerick Emergency Plan.Exelon had determined that, in accordance with 10 CFR 50.54(q), any change made to the Plan, and its lower-tier implementing procedures, had not resulted in any decrease in effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The inspectors reviewed all emergency action level (EAL) changes that Exelon had made since December 2010, and conducted a sampling review of other Emergency Plan changes, including the changes to lowertier erfiergency plan implementing procedures, to evaluate for any potential decreases in effectiveness of the Emergency Plan. However, this review was not documented in an NRC Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety.b. Findinqs No findings were identified.

4. OTHER ACTTVTTIES (OA)4OA1 Performance

Indicator Verification (71151- 3 Samples)a. Inspection Scope The inspectors reviewed data for the Limerick EP Pls, which are:

(1) Drill and Exercise Performance (DEP);

(2) ERO Drill Participation; and,

(3) Alert and Notification System (ANS) Reliability.

The last NRC EP inspection at Limerick was conducted in the fourth quarter of 2010, so the inspectors reviewed supporting documentation from EP drills, training records, and equipment tests from the fourth calendar quarter of 2010 through the third quarter of 2011, to verify the accuracy of the reported performance indicator (Pl) data. The review of these Pls was conducted in accordance with NRC Inspection Procedure 71151, using the acceptance criteria documented in NEI 99-02, "Regulatory Assessment Performance Indicator Guidelines," Revision 6.This inspection activity represented the completion of three samples on an annual cycle.Enclosure 3 b. Findinss No findings were identified.

4OAO Meetinqs.

includino Exit On November 17,2011, the inspectors presented the results of this inspection to Mr. W. Maguire, Site Vice President, and other members of the Exelon staff. No proprietary information was provided to the inspectors during this inspection.

A-1 ATTACHMENT

=SUPPLEMENTAL

INFORMATION=

KEY POINTS OF CONTACT

Licensee Personnel

W. Maguire, Limerick Site Vice President

V. Cwietniewicz, Exelon Mid-Atlantic

Emergency

Preparedness

Manager

M. Crim, Limerick Emergency

Preparedness

Manager

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

None.

LIST OF DOCUMENTS

REVIEWED

Section 1EPl: Exercise Evaluation

EP-M-1000, Exelon Nuclear Standardized Emergency Plan (Revision

20)EP-M-1008, Limerick Generating Station Emergency Plan Annex (Revision

20)Exelon Nuclear Emergency Plan lmplementing

Procedures

Limerick November 15,2011, Emergency Exercise Scenario Package Limerick Emergency Preparedness Drill Reports, January 2010 - October 2011 Condition Reports generated as a result of the November 15,2011, Exercise (As documented in Limerick 2011 Graded Exercise Evaluation Report, dated December 8,2011)

Section 1EB4: Emergencv

Action Level and Emerqencv Plan Chanses

EP-AA-1000, Exelon Nuclear Standardized Emergency Plan (Revision

20)EP-AA-1008, Limerick Generating Station Emergency Plan Annex (Revision

20)EP-AA-120, Emergency Plan Administration (Revision

13)EP-

AA-120-1001, 10

CFR 50.5a(q)Change Evaluation (Revision

6)LS-AA-104, Exelon 50.59 Review Process (Revision

6)Emergency Plan Change Packages: 11-07;1 1-09; 11-18: 11-25; 11-40; 11-43; 11-46; 11-47; 11-51; 11-54;1 1-58; 11-64 Section 4OA1 : Performa nce I ndicator Verification

EP-AA-125-1001, EP Performance Indicator Guidance (Revision

6)Alert Notification System Pl data, October 2010 - September

2011 DEP Pl data, October 2010 - September

2011 ERO Drill Participation Pl data, October 2010 - September

2011 Attachment

ADAMS ANS CR DEP DNMS DRP DRS EAL EOF EP ERO Jrc NEI NRC NSIR osc PARS PEMA PI RSPS TSC A-2

LIST OF ACRONYMS

Agencyrvide

Documents

Access and Management

System Alert Notification

System Condition

Report Drill and Exercise Performance

Division of Nuclear Materials

Safety Division of Reactor Projects Division of Reactor Safety Emergency

Action Level Emergency

Operations

Facility Emergency

Preparedness

Emergency

Response Organization

Joint lnformation

Center Nuclear Energy Institute Nuclear Regulatory

Commission

Office of Nuclear Security and Incident Response Operations

Support Center Publicly Available

Records PA Emergency

Management

Agency Performance

Indicator Risk Significant

Planning Standard Technical

Support Center Attachment