IR 05000352/2020010

Title 10 of the Code of Federal Regulations 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components Inspection Report 05000352/2020010 and 05000353/2020010

ML20073H282
Person / Time
Site:	Limerick
Issue date:	03/11/2020
From:	Glenn Dentel Engineering Region 1 Branch 2
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Dentel G
References
IR 2020010
Download: ML20073H282 (9)

Text

March 11, 2020

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 - TITLE 10 OF THE CODE OF FEDERAL REGULATIONS 50.69 RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS, AND COMPONENTS INSPECTION REPORT 05000352/2020010 AND 05000353/2020010

Dear Mr. Hanson:

On February 27, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Limerick Generating Station, Units 1 and 2, and discussed the results of this inspection with Mr. Frank Sturniolo, Site Vice President, and other members of your staff.

The results of this inspection are documented in the enclosed report.

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,

/RA/

Glenn T. Dentel, Chief Engineering Branch 2 Division of 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:

NPF-39 and NPF-85

Report Numbers:

05000352/2020010 and 05000353/2020010

Licensee:

Exelon Generation Company, LLC

Facility:

Limerick Generating Station, Units 1 and 2

Location:

Sanatoga, PA 19464

Inspection Dates:

February 10, 2020 to February 27, 2020

Inspectors:

E. DiPaolo, Senior Reactor Inspector (Team Lead)

F. Arner, Senior Reactor Analyst

S. Haney, Resident Inspector

A. Patel, Senior Reactor Inspector

Approved By:

Glenn T. Dentel, Chief

Engineering Branch 2

Division of Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Title 10 of the Code of Federal Regulations (10 CFR) 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components 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 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.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

===37060 - 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components Inspection

10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components Inspection===

(1) The inspectors reviewed the licensees program and procedures associated with 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors, license amendment described in the plant safety evaluation and Updated Final Safety Analysis Report, and documented in the staffs Safety Evaluation Report (ADAMS Accession No. ML18165A162). The inspectors reviewed the licensees 10 CFR 50.69 categorization process and alternate treatment requirements completed on the following systems:

• Emergency Diesel Generator

• Residual Heat Removal Service Water

• Emergency Service Water

• Residual Heat Removal

• High Pressure Coolant Injection

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

• On February 27, 2020, the inspectors presented the 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components Inspection results to Mr. Frank Sturniolo, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

37060

Calculations

1-09-059

Pipe Stress Analysis

Corrective Action

Documents

3984984

4159984

214649

214654

24273

231629

232738

244378

244380

244440

250921

255997

256574

259201

267276

268323

271437

276932

287925

288001

288385

298778

299068

4312075

Corrective Action

Documents

Resulting from

Inspection

4172733-40, 41

4317285

4319388

21736

21932

Engineering

Changes

Engineering

Change 629220

A Spray Pond Spray Network Piping Replacement Flange

Addition and Strut Modification

PMC-18-114354

Change Drywell HVAC Fan Motor Rebuild Frequency (EQ)

and Condition Based (Non EQ)

2/27/2019

PMC-18-115736

Standby Liquid Control Pump Relief Valve Frequency

Extension

09/10/2019

PMC-19-116197

Alternative Treatment Maintenance Strategy for Core Spray

RISC-3 Check Valve Inspection Preventive Maintenance

2/03/2019

PMC-19-116869

RISC-3 Electric O-ring EEQ for System 57

10/09/2019

PMC-19-117859

RISC-3 System 052 (Core Spray) Motor Operated Valves

Alternate Treatment

01/03/2020

PMC-19-117911

Alternative Treatment for Core Spray RISC-3 Components

09/06/2019

PMC-19-119782

Alternate Treatment for System 20 Diesel Generator, Diesel

Generator Fuel Oil Storage Transfer, and Diesel Generator

Heating, Ventilation and Air Conditioning RISC-3

Components

10/07/2019

Engineering

Evaluations

LG-5060-012-003

CFR 50.59 System Categorization Document-Residual

Heat Removal Service Water System

LG-5069-011-003

CFR 50.69 System Categorization Document-Emergency

Service Water System

LG-5069-020-

081-092-003

CFR 50.69 System Categorization Document-Diesel

Generator

LG-5069-051-003

CFR 50.69 System Categorization Document-Residual

Heat Removal System

LG-5069-052-19-

IM-01

CFR 50.69 Immediate Review of the Core Spray System

2/05/2019

LG-5069-055-

056-003

CFR 50.69 System Categorization Document-HPCI

System

LG-MISC-035

NRC 10 CFR 50.69 Inspection Support for Limerick

Generating Station

N-00E-117-00010

CFR 50.69 Success Path Components Lists for Limerick

Generating Station Units 1 and 2

Miscellaneous

Exelon letter to

U.S. NRC, Limerick Generating Station, Units

and 2, Application to Adopt 10 CFR 50.69, Risk-Informed

Categorization and Treatment of Structures, Systems, and

Components for Nuclear Power Plants

06/28/2017

Exelon letter to

U.S. NRC, Limerick Generating Station, Units

08/14/2017

and 2, Supplement to Application to Adopt 10 CFR 50.69,

Risk-Informed Categorization and Treatment of Structures,

Systems, and Components for Nuclear Power Plants

Exelon letter to

U.S. NRC, Limerick Generating Station, Units

and 2, Response to Request for Additional Information,

Application to Adopt 10 CFR 50.69, Risk-Informed

Categorization and Treatment of Structures, Systems, and

Components for Nuclear Power Plants

01/19/2018

Exelon letter to

U.S. NRC, Limerick Generating Station, Units

and 2, Response to Request for Additional Information,

Application to Adopt 10 CFR 50.69, Risk-Informed

Categorization and Treatment of Structures, Systems, and

Components for Nuclear Power Plants

04/23/2018

Exelon letter to

U.S. NRC, Limerick Generating Station, Units

and 2, Supplement to Application to Adopt 10 CFR 50.69,

Risk-Informed Categorization and Treatment of Structures,

Systems, and Components for Nuclear Power Plants

07/27/2018

U.S. NRC Issuance of Amendments Nos. 230 and 193 to

Adopt Title 10 of the Code of Federal Regulations Section

50.69, Risk-Informed Categorization and Treatment of

Structures, Systems and Components for Nuclear Power

Reactor

07/31/2018

Entergy Response to Request to NRC Request for Additional

Information Regarding Alternative ANO2-R&R-004 Revision

08/06/2007

LG-5060-055-

056-19-04

Integrated Decision Making Panel Meeting Minutes for

06/25/2019

LG-5069-078-

090-19-012

50.69 Integrated Decision-Making Panel Meeting Minutes for

05/04/2019

LG-5069-078-

090-19-012,

50.69 Integrated Decision Making Panel Meeting Minutes for

05/04/2019

Regulatory Guide 1.200

An Approach for Determining the Technical Adequacy of

Probabilistic Risk Assessment Results for Risk-Informed

Activities

Shift Order 19-

001

License Amendment Implementing 10 CFR 50.69

Miscellaneous

Shift Order-19-

050

CFR 50.69 Supplement-Issue Report Screening

Procedures

ER-AA-569

CFR 50.69 Program

ER-AA-569-1001

CFR 50.69 Active Component Risk Significance Insights

ER-AA-569-1002

CFR 50.69 Passive Component Categorization

ER-AA-569-1003

CFR 50.69 Risk Informed Categorization for Structures,

Systems, and Components

ER-AA-569-1003-

F-01

CFR 50.69 System Categorization Document

ER-AA-569-1004

CFR 50.69 Alternative Treatment Implementation Process

ER-AA-569-1005

Integrated Decision-Making Panel for Risk Informed SSC

Categorization Duties and Responsibilities

ER-AA-569-1006

Requirements for Immediate, Interim, and Periodic

Performance Monitoring Reviews

ER-AA-569-1007

Job Familiarization of 50.69 Project Team and Site Personnel

LS-AA-1110

Exelon Reportabilty Reference Manual

T-300

FLEX Pump Setup at Spray Pond

Self-Assessments

IR 4276932

Limerick February 2020 50.69 NRC Inspection Self-

Assessment

11/18/2019

NOSA-LM-19-05

Engineering Design Control Audit Report

08/07/2019

Report 032362-

RPT-10

PRA Focused-Scope Peer Review and Finding Level Fact

and Observation Independent Assessment

0