IR 05000352/2015001

NRC Integrated Inspection Report 05000352/2015001 and 05000353/2015001 (January 1 - March 31, 2015)

ML15133A242
Person / Time
Site:	Limerick
Issue date:	05/14/2015
From:	Fred Bower Reactor Projects Region 1 Branch 4
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
BOWER, FL
References
05000352/2015001; 05000353/2015001 IR 2015001
Download: ML15133A242 (35)

Text

{{#Wiki_filter:May 14, 2015

SUBJECT:

Limerick Generating Station - NRC INTEGRATED INSPECTION REPORT 05000352/2015001 AND 05000353/2015001

Dear Mr. Hanson:

On March 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Limerick Generating Station, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on April 10, 2015, with Mr. D. Lewis, Plant Manager, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents two NRC-identified violations of NRC requirements, both of which were of very low safety significance (Green). However, because of the very low safety significance, and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations, consistent with Section 2.3.2.a of the NRC Enforcement Policy.

If you contest any non-cited violations in this report, 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. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at Limerick Generating Station.

B.Hanson 2 In accordance with Title 10 of the Code of Federal Regulations (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 NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access Management 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:

Inspection Report 05000352/2015001 and 05000353/2015001 w/Attachment: Supplementary Information

REGION I== Docket Nos.: 50-352, 50-353 License Nos.: NPF-39, NPF-85 Report No.: 05000352/2015001 and 05000353/2015001 Licensee: Exelon Generation Company, LLC Facility: Limerick Generating Station (LGS), Units 1 & 2 Location: Sanatoga, PA Dates: January 1, 2015 through March 31, 2015 Inspectors: S. Rutenkroger, PhD, Senior Resident Inspector G. DiPaolo, Senior Resident Inspector R. Montgomery, Resident Inspector R. Nimitz, Senior Health Physicist E. Burket, Emergency Preparedness Inspector M. Fannon, Project Engineer B. Lin, Project Engineer A. Turilin, Project Engineer Approved By: Fred L. Bower III, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure

SUMMARY

IR 05000352/2015001, 05000353/2015001; 01/01/2015 - 03/31/2015; Limerick Generating

Station (LGS) Units 1 and 2; Operability Determinations and Functionality Assessments and Refueling and Other Outage Activities.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified two findings of very low safety significance (Green), which were non-cited violations (NCVs). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects Within The Cross-Cutting Areas, dated December 4, 2014. All violations of Nuclear Regulatory commission (NRC) requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated February 4, 2015. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5, dated February 2014.

Cornerstone: Mitigating Systems

Green.

The 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 [H.1]. (Section 1R15)

Green.

The 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. (Section 1R20)

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at 100 percent power. On January 9, 2015, operators reduced power to 77 percent for control rod scram time testing and pattern adjustment.

Operators returned the unit to 100 percent power the following day. On February 23, 2015, the unit scrammed automatically on a valid high reactor pressure signal caused by an inadvertent closure of the 1C inboard main steam isolation valve. Following repairs, operators returned the unit to 100 percent power on February 27. The unit remained at or near 100 percent power for the remainder of the inspection period.

Unit 2 began the inspection period at 100 percent power. Unit 2 power began coasting down as it approached the end of the operating cycle beginning January 8, 2015. The unit remained at or near its maximum achievable power for the remainder of the inspection period, reaching approximately 83 percent power by March 31,

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

The inspectors reviewed Exelons preparations in advance of and during a winter storm warning issued by the National Weather Service for Montgomery County, Pennsylvania for January 26, 2015. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during this adverse weather condition.

The inspectors performed walkdowns of equipment that could be effected by high winds including the main transformer areas and the emergency diesel generators (EDGs) to verify that potential missile objects were secure. The inspectors verified that operator actions defined in Exelons adverse weather procedure maintained the readiness of essential systems.

b. Findings

No findings were identified. ==1R04 Equipment Alignment

.1 Partial System Walkdowns

==

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems: B Standby gas treatment system (SGTS) when A SGTS was out-of-service for planned maintenance on January 21, 2015 A reactor enclosure recirculation system (RERS) when B RERS was out of service for planned maintenance on February 9, 2015 Spray pond pump house alignment for A and C residual heat removal service water (RHRSW)/emergency service water (ESW) pumps on February 11, 2015 Spray pond pump house alignment for B and D RHRSW/ESW pumps on February 11, 2015 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the updated final safety analysis report (UFSAR), TS, work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether LGS staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

.2 Full System Walkdown

a. Inspection Scope

On February 12, 2015, the inspectors performed a complete system walkdown of accessible portions of the high pressure coolant injection system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hanger and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the system to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related condition reports and work orders to ensure Exelon appropriately evaluated and resolved any deficiencies.

b. Findings

No findings were identified. ==1R05 Fire Protection