IR 05000352/2018002: Difference between revisions

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| number = ML18221A483
| number = ML18221A483
| issue date = 08/09/2018
| issue date = 08/09/2018
| title = Limerick Generating Station - Integrated Inspection Report 05000352/2018002 and 05000353/2018002
| title = Integrated Inspection Report 05000352/2018002 and 05000353/2018002
| author name = Greives J E
| author name = Greives J
| author affiliation = NRC/RGN-I/DRP/PB4
| author affiliation = NRC/RGN-I/DRP/PB4
| addressee name = Hanson B C
| addressee name = Hanson B
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| docket = 05000352, 05000353
| docket = 05000352, 05000353
| license number = NPF-039, NPF-085
| license number = NPF-039, NPF-085
| contact person = Greives J E
| contact person = Greives J
| document report number = IR 2018002
| document report number = IR 2018002
| document type = Inspection Report, Letter
| document type = Inspection Report, Letter
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:August 9, 2018
[[Issue date::August 9, 2018]]


Mr. Bryan Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
==SUBJECT:==
 
LIMERICK GENERATING STATION - INTEGRATED INSPECTION REPORT 05000352/2018002 AND 05000353/2018002
SUBJECT: LIMERICK GENERATING STATION - INTEGRATED INSPECTION REPORT 05000352/2018002 AND 05000353/2018002


==Dear Mr. Hanson:==
==Dear Mr. Hanson:==
On June 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Limerick Generating Station, Units 1 and 2. On July 23, 2018, the NRC inspectors discussed the results of this inspection with Mr. Frank Sturniolo, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.
On June 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Limerick Generating Station, Units 1 and 2. On July 23, 2018, the NRC inspectors discussed the results of this inspection with Mr. Frank Sturniolo, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.


NRC inspectors documented one finding of very low safety significance (Green) in this report. This finding involved a violation of NRC requirements. Additionally, NRC inspectors
NRC inspectors documented one finding of very low safety significance (Green) in this report.
 
documented one Severity Level IV violation with no associated finding. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the


Enforcement Policy.
This finding involved a violation of NRC requirements. Additionally, NRC inspectors documented one Severity Level IV violation with no associated finding. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.


If you contest the violations or significance of these NCVs, 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; and the NRC Resident Inspector at Limerick Generating Station.
If you contest the violations or significance of these NCVs, 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; and the NRC Resident Inspector at Limerick Generating Station.


In addition, if you disagree with a cross-cutting aspect assignment, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC, 20555-0001; with copies to the Regional Administrator, Region I, and the NRC Resident Inspector at Limerick Generating Station. This letter, its enclosure, and your response (if any) will be made available for public inspection  
In addition, if you disagree with a cross-cutting aspect assignment, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC, 20555-0001; with copies to the Regional Administrator, Region I, and the NRC Resident Inspector at Limerick Generating Station. 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 the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
 
and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."


Sincerely,/RA/ Jonathan E. Greives, Chief Reactor Projects Branch 4 Division of Reactor Projects
Sincerely,
/RA/  


Docket Nos. 50-352 and 50-353
Jonathan E. Greives, Chief Reactor Projects Branch 4 Division of Reactor Projects


License Nos. NPF-39 and NPF-85
Docket Nos. 50-352 and 50-353 License Nos. NPF-39 and NPF-85  


===Enclosure:===
===Enclosure:===
Inspection Report 05000352/2018002 and 05000353/2018002  
Inspection Report 05000352/2018002 and 05000353/2018002  


cc w/encl: Distribution via ListServ
==Inspection Report==
Docket Numbers:
50-352 and 50-353
 
License Numbers:
NPF-39 and NPF-85
 
Report Numbers:
05000352/2018002 and 05000353/2018002
 
Enterprise Identifier: I-2018-002-0065


ML18221A483 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE RI/DRP RI/DRP RI/DRP NAME SRutenkroger via email SBarber JGreives DATE 8/9/18 8/9/18 8/9/18
Licensee:
Exelon Generation Company, LLC


1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report
Facility:
Limerick Generating Station, Units 1 & 2


Docket Numbers: 50-352 and 50-353 License Numbers: NPF-39 and NPF-85
Location:
Sanatoga, PA 19464


Report Numbers: 05000352/2018002 and 05000353/2018002
Inspection Dates:
April 1, 2018 through June 30, 2018


Enterprise Identifier: I-2018-002-0065
Inspectors:
S. Rutenkroger, PhD, Senior Resident Inspector


Licensee: Exelon Generation Company, LLC
M. Henrion, Acting Resident Inspector


Facility: Limerick Generating Station, Units 1 & 2
C. Safouri, Acting Resident Inspector


Location: Sanatoga, PA 19464
S. Barber, Senior Project Engineer


Inspection Dates: April 1, 2018 through June 30, 2018
A. Turilin, Project Engineer


Inspectors: S. Rutenkroger, PhD, Senior Resident Inspector M. Henrion, Acting Resident Inspector C. Safouri, Acting Resident Inspector  
H. Anagnostopoulos, Senior Health Physicist
L. Andrews, Resident Inspector  


S. Barber, Senior Project Engineer A. Turilin, Project Engineer H. Anagnostopoulos, Senior Health Physicist L. Andrews, Resident Inspector N. Floyd, Reactor Inspector E. DiPaolo, Senior Reactor Inspector  
N. Floyd, Reactor Inspector  


Approved By: Jonathan E. Greives, Chief Reactor Projects Branch 4 Division of Reactor Projects
E. DiPaolo, Senior Reactor Inspector


2
Approved By:
Jonathan E. Greives, Chief


=SUMMARY=
Reactor Projects Branch 4
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Exelon's performance at Limerick Generating Station, Units 1 and 2 by conducting the baseline inspections described in this report in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC's program for overseeing the safe ope ration of commercial nuclear power reactors.


Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC-identified and self-revealing findings, violations, and additional items are summarized in the table below.
Division of Reactor Projects


List of Findings and Violations Failure to Conduct Adequate Radiation Surveys and Evaluate Potential Radiological Hazards Cornerstone Significance Cross-cutting Aspect Report Section Occupational
=SUMMARY=
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Exelons performance at


Radiation Safety
Limerick Generating Station, Units 1 and 2 by conducting the baseline inspections described in this report 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.


Green NCV 05000352/2018002-01
Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC-identified and self-revealing findings, violations, and additional items are summarized in the table below.


Opened/Closed H.11 -  Human Performance -  
===List of Findings and Violations===
Failure to Conduct Adequate Radiation Surveys and Evaluate Potential Radiological Hazards Cornerstone Significance Cross-cutting Aspect Report Section Occupational Radiation Safety


Challenge The Unknown 71124.01 A self-revealing Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 20.1501, "Surveys and Monitoring: General," was identified when Exelon failed to perform adequate loose surface contamination surveys of the Unit 1 reactor water clean up (RWCU) isolation valve room prior to authorizing work to hang shadow shielding near the HV-051-1F017A valve and also during the conduct of the work itself. Exelon also did not identify very high levels of loose surface contamination on overhead piping and structures which surrounded the work area. This resulted in unplanned internal radiation exposures to three personnel, including a radiation protection technician (RPT) who was assigned to monitor the radiological aspects of the work.
Green NCV 05000352/2018002-01 Opened/Closed H.11 - Human Performance -
Challenge The Unknown 71124.01 A self-revealing Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 20.1501, Surveys and Monitoring: General, was identified when Exelon failed to perform adequate loose surface contamination surveys of the Unit 1 reactor water clean up (RWCU) isolation valve room prior to authorizing work to hang shadow shielding near the HV-051-1F017A valve and also during the conduct of the work itself. Exelon also did not identify very high levels of loose surface contamination on overhead piping and structures which surrounded the work area. This resulted in unplanned internal radiation exposures to three personnel, including a radiation protection technician (RPT) who was assigned to monitor the radiological aspects of the work.


Unit 1 Core Spray Pump Failed to Start Resulting in Condition Prohibited by Technical Specifications Cornerstone Significance Cross-cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000352/2018002-02 Opened/Closed Not Applicable 71153 The inspectors identified a Severity Level IV NCV of Unit 1 Technical Specification 3.5.1 because one core spray subsystem was inoperable from July 17, 2017, until October 5, 2017.
Unit 1 Core Spray Pump Failed to Start Resulting in Condition Prohibited by Technical Specifications Cornerstone Significance Cross-cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000352/2018002-02 Opened/Closed Not Applicable 71153 The inspectors identified a Severity Level IV NCV of Unit 1 Technical Specification 3.5.1 because one core spray subsystem was inoperable from July 17, 2017, until October 5, 2017.


Specifically, the Unit 1 'C' core spray pump did not start upon demand during testing and was declared inoperable because the pump's associated 4 kilovolt (kV) circuit breaker closing charging springs were not charged.
Specifically, the Unit 1 C core spray pump did not start upon demand during testing and was declared inoperable because the pumps associated 4 kilovolt (kV) circuit breaker closing charging springs were not charged.


Additional Tracking Items Type Issue number Title Report Section Status LER 05000352/2017-004-00 and 05000352/2017-004-01 Core Spray Pump Failed to Start Resulting in Condition Prohibited by Technical Specifications 71153 Closed 3  TABLE OF CONTENTS
===Additional Tracking Items===
Type Issue number Title Report Section Status LER 05000352/2017-004-00 and 05000352/2017-004-01 Core Spray Pump Failed to Start Resulting in Condition Prohibited by Technical Specifications 71153 Closed  
 
TABLE OF CONTENTS


=PLANT STATUS=
=PLANT STATUS=
..................................................................................................................


==INSPECTION SCOPES==
==INSPECTION SCOPES==
.............................................................................................................
................................................................................................................


==REACTOR SAFETY==
==REACTOR SAFETY==
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...............................................................................................................
...............................................................................................................


==OTHER ACTIVITIES==
==OTHER ACTIVITIES - BASELINE==
- BASELINE ........................................................................................... 9INSPECTION RESULTS ............................................................................................................ 10THIRD PARTY REVIEWS ..........................................................................................................
...........................................................................................
18
 
==INSPECTION RESULTS==
............................................................................................................ 10 THIRD PARTY REVIEWS.......................................................................................................... 18


=DOCUMENTS REVIEWED=
=DOCUMENTS REVIEWED=
......................................................................................................... 19


......................................................................................................... 19
PLANT STATUS
PLANT STATUS Unit 1 began the inspection period shutdown for a planned refueling outage. The unit was restarted on April 15, 2018, and returned to 100 percent power on April 20, 2018. On June 9, 2018, the unit was downpowered to 33 percent in single loop operation due to an equipment
Unit 1 began the inspection period shutdown for a planned refueling outage. The unit was
issue with the '1B' adjustable speed drive. The unit was returned to rated thermal power on
restarted on April 15, 2018, and returned to 100 percent power on April 20, 2018. On June 9,
2018, the unit was downpowered to 33 percent in single loop operation due to an equipment
issue with the 1B adjustable speed drive. The unit was returned to rated thermal power on
June 11, 2018, and remained at or near rated thermal power for the remainder of the inspection
June 11, 2018, and remained at or near rated thermal power for the remainder of the inspection
period.
period.
Unit 2 began the inspection period at rated thermal power. On May 18, 2018, the unit was down powered to 64 percent to repair a main condenser tube leak and perform required valve testing
Unit 2 began the inspection period at rated thermal power. On May 18, 2018, the unit was down
powered to 64 percent to repair a main condenser tube leak and perform required valve testing
and summer readiness activities. The unit was returned to rated thermal power on May 21,
and summer readiness activities. The unit was returned to rated thermal power on May 21,
2018, and remained at or near rated thermal power for the remainder of the inspection period.
2018, and remained at or near rated thermal power for the remainder of the inspection period.
INSPECTION SCOPES
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
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
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 also performed plant status activities described
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
in IMC 2515, Appendix D, "Plant Status," and conducted routine reviews using IP 71152,  
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
"Problem Identification and Resolution."  The inspectors reviewed selected procedures and records, observed activities, and interview
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
ed personnel to assess Exelon's performance and compliance with Commission rules and regulations, license conditions, site procedures, and
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 also performed plant status activities described
in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152,
Problem Identification and Resolution. The inspectors reviewed selected procedures and
records, observed activities, and interviewed personnel to assess Exelons performance and
compliance with Commission rules and regulations, license conditions, site procedures, and
standards.
standards.
REACTOR SAFETY
REACTOR SAFETY
Line 136: Line 164:
The inspectors evaluated system configurations during partial walkdowns of the following
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:  
systems/trains:  
(1) Unit 1 'A' standby gas treatment system on April 4, 2018  
(1) Unit 1 A standby gas treatment system on April 4, 2018  
(2) Unit 1 'D11' and 'D14' emergency diesel generators on April 7, 2018
(2) Unit 1 D11 and D14 emergency diesel generators on April 7, 2018  
(3) Unit common '201' safeguard transformer, bus, and related switchgear on April 25, 2018  
(3) Unit common 201 safeguard transformer, bus, and related switchgear on April 25, 2018  
(4) Unit 1 automatic depressurization system on April 30 through May 3, 2018  
(4) Unit 1 automatic depressurization system on April 30 through May 3, 2018
 
Complete Walkdown (1 sample)
Complete Walkdown (1 sample)
The inspectors evaluated system configurations during a complete walkdown of the Unit 1 reactor core isolation cooling system.  
The inspectors evaluated system configurations during a complete walkdown of the Unit 1
reactor core isolation cooling system.  


71111.05A/Q - Fire Protection Annual/Quarterly
71111.05A/Q - Fire Protection Annual/Quarterly
Line 148: Line 176:
The inspectors evaluated fire protection program implementation in the following selected
The inspectors evaluated fire protection program implementation in the following selected
areas:  
areas:  
(1) Fire area 34, Unit 1 high pressure coolant injection room, elevation 177', on May 4, 2018  
(1) Fire area 34, Unit 1 high pressure coolant injection room, elevation 177, on May 4, 2018  
(2) Fire area 2, Unit common 13.2 kV switchgear, elevation 217', on May 11, 2018 (3) Fire area 83, Unit 2 'D21' emergency diesel generator and fuel oil day tank room, elevation 217', on May 21, 2018 (4) Fire areas 54 & 55, Unit 2 residual heat removal heat exchanger and pump rooms 173, 174, 280, and 281, elevations 177' and 201', on June 7, 2018 (5) Fire area 35, Unit 1 'A' core spray pump room, elevation 177', on June 12, 2018
(2) Fire area 2, Unit common 13.2 kV switchgear, elevation 217, on May 11, 2018  
(3) Fire area 83, Unit 2 D21 emergency diesel generator and fuel oil day tank room,
elevation 217, on May 21, 2018  
(4) Fire areas 54 & 55, Unit 2 residual heat removal heat exchanger and pump rooms 173,
174, 280, and 281, elevations 177 and 201, on June 7, 2018  
(5) Fire area 35, Unit 1 A core spray pump room, elevation 177, on June 12, 2018
Annual Inspection (1 sample)
Annual Inspection (1 sample)
The inspectors evaluated fire brigade performance on June 12, 2018.
The inspectors evaluated fire brigade performance on June 12, 2018.
71111.07 - Heat Sink Performance
71111.07 - Heat Sink Performance
Heat Sink (1 sample)
Heat Sink (1 sample)
The inspectors evaluated Exelon's monitoring and maintenance of the '1A' core spray room unit cooler heat exchanger system.
The inspectors evaluated Exelons monitoring and maintenance of the 1A core spray room
unit cooler heat exchanger system.
71111.08 - Inservice Inspection Activities (1 sample)
71111.08 - Inservice Inspection Activities (1 sample)
The inspectors evaluated Exelon's non-destructive examination and welding activities of Unit 1 by reviewing the following activities and programs from April 2 to April 6, 2018:  
The inspectors evaluated Exelons non-destructive examination and welding activities of
 
Unit 1 by reviewing the following activities and programs from April 2 to April 6, 2018:  
(1) Volumetric Examinations
(1) Volumetric Examinations
a) Manual ultrasonic testing of main steam loop 'D' nozzle to safe-end weld, APE-1MS-
a) Manual ultrasonic testing of main steam loop D nozzle to safe-end weld, APE-1MS-
LD N3D b) Manual ultrasonic testing of feedwater elbow-to-elbow and elbow-to-pipe welds, FWA-039 and -040 c) Radiography testing of RWCU pipe-to-pipe welds, FW-56 and FW-58 which involved welding activities associated with a pressure boundary risk significant system  
LD N3D
(2) Visual Examinations
b) Manual ultrasonic testing of feedwater elbow-to-elbow and elbow-to-pipe welds,
a) In-vessel visual inspection of jet pump components, top guide beams, and feedwater piping structural attachments b) Underwater visual inspection in the suppression pool of the core spray 'C' suction strainer and floor panels c) General visual examination of the drywell liner  
FWA-039 and -040
(3) The inspectors reviewed the welding activities associated with the replacement of degraded piping on line DBB-105-01 in the RWCU system  
c) Radiography testing of RWCU pipe-to-pipe welds, FW-56 and FW-58 which involved
welding activities associated with a pressure boundary risk significant system  
(2) Visual Examinations
a) In-vessel visual inspection of jet pump components, top guide beams, and feedwater
piping structural attachments
b) Underwater visual inspection in the suppression pool of the core spray C suction
strainer and floor panels
c) General visual examination of the drywell liner  
(3) The inspectors reviewed the welding activities associated with the replacement of
degraded piping on line DBB-105-01 in the RWCU system  


71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
Operator Requalification (1 sample)
Operator Requalification (1 sample)
The inspectors observed and evaluated licensed operator simulator training scenarios on
The inspectors observed and evaluated licensed operator simulator training scenarios on
May 14, 2018.  
May 14, 2018.
 
Operator Performance (1 sample)
Operator Performance (1 sample)
The inspectors observed reactor startup of Unit 1 on April 15, 2018.
The inspectors observed reactor startup of Unit 1 on April 15, 2018.
71111.12 - Maintenance Effectiveness
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness  
Routine Maintenance Effectiveness (2 samples)
(2 samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:  
with the following equipment and/or safety significant functions:  
(1) Unit 1 high pressure coolant injection on May 3, 2018  
(1) Unit 1 high pressure coolant injection on May 3, 2018  
(2) Unit 2 high pressure coolant injection on May 3, 2018
(2) Unit 2 high pressure coolant injection on May 3, 2018
Quality Control  
Quality Control (2 samples)
(2 samples)
The inspectors evaluated maintenance and quality control activities associated with the
The inspectors evaluated maintenance and quality control activities associated with the following equipment performance issues:  
following equipment performance issues:  
(1) Unit 2 'D23' emergency diesel generator planned maintenance overhaul on February 12
(1) Unit 2 D23 emergency diesel generator planned maintenance overhaul on February 12
to 16, 2018 (2) Unit 1 high pressure coolant injection main pump gear end outboard mechanical seal replacement on April 30 to May 1, 2018
to 16, 2018  
(2) Unit 1 high pressure coolant injection main pump gear end outboard mechanical seal
replacement on April 30 to May 1, 2018
71111.13 - Maintenance Risk Assessments and Emergent Work Control (5 samples)
71111.13 - Maintenance Risk Assessments and Emergent Work Control (5 samples)
The inspectors evaluated the risk assessments for the following planned and emergent
The inspectors evaluated the risk assessments for the following planned and emergent
work activities:  
work activities:  
(1) Unit 1 'D11' 4 kV bus unavailable for planned refueling outage maintenance on April 1, 2018 (2) Unit 1 'D11' emergency diesel generator loss of coolant accident/loss of offsite power test on April 5, 2018 (3) Unit 1 initial plant startup from a planned refueling outage with the containment de-inerted on April 15, 2018 (4) Unit common 'B' standby gas treatment system unavailable during testing on April 26, 2018 (5) Unit 1 high pressure coolant injection maintenance outage from April 30 to May 2, 2018
(1) Unit 1 D11 4 kV bus unavailable for planned refueling outage maintenance on April 1,
2018  
(2) Unit 1 D11 emergency diesel generator loss of coolant accident/loss of offsite power
test on April 5, 2018  
(3) Unit 1 initial plant startup from a planned refueling outage with the containment de-
inerted on April 15, 2018  
(4) Unit common B standby gas treatment system unavailable during testing on April 26,
2018  
(5) Unit 1 high pressure coolant injection maintenance outage from April 30 to May 2, 2018  


71111.15 - Operability Determinations and Functionality Assessments (5 samples)
71111.15 - Operability Determinations and Functionality Assessments (5 samples)
The inspectors evaluated the following operability determinations and functionality assessments:  
The inspectors evaluated the following operability determinations and functionality
(1) Unit 1 bypass valve number two indicat
assessments:  
ed opening to only 97 percent following Unit 1
(1) Unit 1 bypass valve number two indicated opening to only 97 percent following Unit 1
main turbine trip on March 26, 2018
main turbine trip on March 26, 2018  
(2) Unit common 'B' standby gas treatment system filter heater trip on April 4, 2018  
(2) Unit common B standby gas treatment system filter heater trip on April 4, 2018  
(3) Unit 1 reactor pressure vessel head vent flange indications on April 12, 2018 (4) Unit 1 'C' low pressure coolant injection valve leakby during operational pressure test on April 13, 2018 (5) Unit 1 high pressure coolant injection pump leakage from main pump gearbox end outboard seal on April 17, 2018
(3) Unit 1 reactor pressure vessel head vent flange indications on April 12, 2018  
(4) Unit 1 C low pressure coolant injection valve leakby during operational pressure test on
April 13, 2018  
(5) Unit 1 high pressure coolant injection pump leakage from main pump gearbox end
outboard seal on April 17, 2018
71111.18 - Plant Modifications (2 samples)
71111.18 - Plant Modifications (2 samples)
The inspectors evaluated the following temporary or permanent modifications:  
The inspectors evaluated the following temporary or permanent modifications:  
 
(1) Engineering change package 618876, Unit 1 and Unit 2 carbon dioxide system
(1) Engineering change package 618876, Unit 1 and Unit 2 carbon dioxide system modification and abandonment (2) Engineering chage request 1200019, Unit 1 and Unit 2 main turbine control valve and reactor protection system channel functional test procedure change
modification and abandonment  
(2) Engineering chage request 1200019, Unit 1 and Unit 2 main turbine control valve and
reactor protection system channel functional test procedure change
71111.19 - Post Maintenance Testing (9 samples)
71111.19 - Post Maintenance Testing (9 samples)
The inspectors evaluated post maintenance testing for the following maintenance/repair
The inspectors evaluated post maintenance testing for the following maintenance/repair
activities:  
activities:  
(1) Unit common '11-1011' service water supply check valve planned maintenance on April 2, 2018 (2) Unit 1 'A' low pressure coolant injection outboard injection valve maintenance
(1) Unit common 11-1011 service water supply check valve planned maintenance on
on April 3, 2018 (3) Unit common 220 kV transmission lock substation testing and maintenance on April 25, 2018 (4) Unit 1 high pressure coolant injection pump mechanical seal replacement on May 3, 2018 (5) Unit 1 'B' residual heat removal pump motor inspection and oil change on May 8, 2018 (6) Unit 1 'A' residual heat removal heat exchanger inlet cross-tie valve breaker cleaning and inspection on May 16, 2018 (7) Unit 1 'A' core spray pump room unit cooler cleaning and inspection on June 14, 2018 (8) Unit 1 high pressure coolant injection pump maintenance on April 18, 2018
April 2, 2018  
(9) Unit common '101' safeguards transformer and bus following installation of third off-site power source on June 11, 2018
(2) Unit 1 A low pressure coolant injection outboard injection valve maintenance on April 3,
2018  
(3) Unit common 220 kV transmission lock substation testing and maintenance on April 25,
2018  
(4) Unit 1 high pressure coolant injection pump mechanical seal replacement on May 3,
2018  
(5) Unit 1 B residual heat removal pump motor inspection and oil change on May 8, 2018  
(6) Unit 1 A residual heat removal heat exchanger inlet cross-tie valve breaker cleaning
and inspection on May 16, 2018  
(7) Unit 1 A core spray pump room unit cooler cleaning and inspection on June 14, 2018  
(8) Unit 1 high pressure coolant injection pump maintenance on April 18, 2018  
(9) Unit common 101 safeguards transformer and bus following installation of third off-site
power source on June 11, 2018
71111.20 - Refueling and Other Outage Activities (1 sample)
71111.20 - Refueling and Other Outage Activities (1 sample)
The inspectors evaluated Unit 1 refueling outage activities from April 1 to April 18, 2018. The following portions of the inspection procedure were not performed during this period.  
The inspectors evaluated Unit 1 refueling outage activities from April 1 to April 18, 2018.
(1) Outage Plan  
The following portions of the inspection procedure were not performed during this period.  
(2) Shutdown
(1) Outage Plan  
(2) Shutdown  
 
71111.22 - Surveillance Testing
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
The inspectors evaluated the following surveillance tests:
Routine (2 samples)  
Routine (2 samples)  
(1) ST-2-074-629-1, Unit 1 average power range monitor number 4 functional check on April 24, 2018 (2) ST-2-088-324-2, Unit 2 remote shutdown system division '2' residual heat removal test on June 20, 2018
(1) ST-2-074-629-1, Unit 1 average power range monitor number 4 functional check on
April 24, 2018  
(2) ST-2-088-324-2, Unit 2 remote shutdown system division 2 residual heat removal test
on June 20, 2018
In-Service (4 samples)  
In-Service (4 samples)  
(1) ST-6-092-115-1, Unit 1 'D11' emergency diesel generator loss of coolant accident/loss of offsite power test on April 5, 2018 (2) ST-6-092-312-1, Unit 1 'D12' emergency diesel generator slow start operability test run on April 23, 2018 (3) ST-6-051-234-2, Unit 2 'D' residual heat removal pump, valve, and flow test on May 23, 2018 (4) ST-6-092-314-1, Unit 1 'D14' emergency diesel generator slow start operability test run on June 18, 2018
(1) ST-6-092-115-1, Unit 1 D11 emergency diesel generator loss of coolant accident/loss
of offsite power test on April 5, 2018  
(2) ST-6-092-312-1, Unit 1 D12 emergency diesel generator slow start operability test run
on April 23, 2018  
(3) ST-6-051-234-2, Unit 2 D residual heat removal pump, valve, and flow test on May 23,
2018  
(4) ST-6-092-314-1, Unit 1 D14 emergency diesel generator slow start operability test run
on June 18, 2018
RADIATION SAFETY
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
71124.01 - Radiological Hazard Assessment and Exposure Controls
Line 220: Line 302:
The inspectors evaluated radiological hazards assessments and controls.
The inspectors evaluated radiological hazards assessments and controls.
Instructions to Workers (1 sample)
Instructions to Workers (1 sample)
The inspectors evaluated worker instructions.  
The inspectors evaluated worker instructions.
 
Contamination and Radioactive Material Control (1 sample)
Contamination and Radioactive Material Control (1 sample)
The inspectors evaluated contamination and radioactive material controls.
The inspectors evaluated contamination and radioactive material controls.
Line 230: Line 311:
controls.
controls.
Radiation Worker Performance and Radiation Protection Technician Proficiency (1 sample)
Radiation Worker Performance and Radiation Protection Technician Proficiency (1 sample)
The inspectors evaluated radiation worker performance and RPT proficiency.  
The inspectors evaluated radiation worker performance and RPT proficiency.  


71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls
71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls
Implementation of ALARA and Radiological Work Controls (1 sample)
Implementation of ALARA and Radiological Work Controls (1 sample)
The inspectors reviewed ALARA practices and radiological work controls by reviewing the following activities:  
The inspectors reviewed ALARA practices and radiological work controls by reviewing the
 
following activities:  
(1) ALARA Plan 18-009  
(1) ALARA Plan 18-009  
(2) ALARA Plan 18-011 (3) ALARA Plan 18-025 (4) ALARA Plan 18-035  
(2) ALARA Plan 18-011  
(3) ALARA Plan 18-025  
(4) ALARA Plan 18-035  
(5) ALARA Plan 18-036  
(5) ALARA Plan 18-036  
(6) ALARA Plan 18-043
(6) ALARA Plan 18-043
Line 244: Line 327:
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Engineering Controls (1 sample)
Engineering Controls (1 sample)
The inspectors evaluated airborne controls and monitoring.  
The inspectors evaluated airborne controls and monitoring.
 
Use of Respiratory Protection Devices (1 sample)
Use of Respiratory Protection Devices (1 sample)
The inspectors evaluated respiratory protection.  
The inspectors evaluated respiratory protection.
 
Self-Contained Breathing Apparatus for Emergency Use (1 sample)
Self-Contained Breathing Apparatus for Emergency Use (1 sample)
The inspectors evaluated the Exelon self-contained breathing apparatus program.
The inspectors evaluated the Exelon self-contained breathing apparatus program.
OTHER ACTIVITIES - BASELINE
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
71151 - Performance Indicator Verification
The inspectors verified Exelon's performance indicator submittals listed below for the period
The inspectors verified Exelons performance indicator submittals listed below for the period
April 1, 2017, through March 31, 2018. (4 samples)  
April 1, 2017, through March 31, 2018. (4 samples)  
(1) Unit 1 and Unit 2 safety system functional failures  
(1) Unit 1 and Unit 2 safety system functional failures  
(2) Unit 1 and Unit 2 emergency alternating current power
(2) Unit 1 and Unit 2 emergency alternating current power
71152 - Problem Identification and Resolution
71152 - Problem Identification and Resolution
Semiannual Trend Review (1 sample)
Semiannual Trend Review (1 sample)
The inspectors reviewed Exelon's corrective action program for trends that might be
The inspectors reviewed Exelons corrective action program for trends that might be
indicative of a more significant safety issue.  
indicative of a more significant safety issue.  


Annual Follow-up of Selected Issues (2 samples)
Annual Follow-up of Selected Issues (2 samples)
The inspectors reviewed Exelon's implementation of its corrective action program related to the following issues:  
The inspectors reviewed Exelons implementation of its corrective action program related to
(1) Issue Report (IR) 4024190, Unit 2 main steam line high radiation alarm likely due to insufficient foreign material exclusion controls (2) IR 4059470, Unit 1 'C' core spray pump failed to start on October 5, 2017 due to circuit breaker failing to close
the following issues:  
(1) Issue Report (IR) 4024190, Unit 2 main steam line high radiation alarm likely due to
insufficient foreign material exclusion controls  
(2) IR 4059470, Unit 1 C core spray pump failed to start on October 5, 2017 due to circuit
breaker failing to close
71153 - Follow-up of Events and Notices of Enforcement Discretion
71153 - Follow-up of Events and Notices of Enforcement Discretion
Licensee Event Reports (1 sample)
Licensee Event Reports (1 sample)
The inspectors evaluated the following licensee event report:  
The inspectors evaluated the following licensee event report:  
(1) Licensee Event Report 05000352/2017-004-00 and 0500352/2017-004-01, Core Spray Failed to Start Resulting in Condition Prohibited by Technical Specifications.
(1) Licensee Event Report 05000352/2017-004-00 and 0500352/2017-004-01, Core
The circumstances surrounding this licensee event report are documented in report Section "Inspection Results."
Spray Failed to Start Resulting in Condition Prohibited by Technical Specifications.
The circumstances surrounding this licensee event report are documented in report
Section Inspection Results.
Personnel Performance (1 sample)
Personnel Performance (1 sample)
The inspectors evaluated response during the following non-routine evolution:  
The inspectors evaluated response during the following non-routine evolution:  
(1) Unit 1 unplanned downpower to 30 percent for single loop operation on June 9, 2018, due to Unit 1 'B' adjustable speed drive coolant leak on a flexible hose fitting
(1) Unit 1 unplanned downpower to 30 percent for single loop operation on June 9,
2018, due to Unit 1 B adjustable speed drive coolant leak on a flexible hose fitting
INSPECTION RESULTS
INSPECTION RESULTS
Failure to Conduct Adequate Radiation Surveys and Evaluate Potential Radiological Hazards Cornerstone Significance Cross-Cutting Aspect Report Section Occupational
Failure to Conduct Adequate Radiation Surveys and Evaluate Potential Radiological Hazards
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Occupational
Radiation Safety
Radiation Safety
Green NCV 05000352/2018002-01
Green
Closed H.11 - Human Performance -
NCV 05000352/2018002-01
Closed
H.11 - Human
Performance -
Challenge The
Challenge The
Unknown 71124.01 A self-revealing Green finding and associated NCV of 10 CFR 20.1501, "Surveys and Monitoring: General," was identified when Exelon failed to perform adequate loose surface
Unknown
contamination surveys of the Unit 1 RWCU isolation valve room prior to authorizing work to hang shadow shielding near the HV-051-1F017A valve, and also during the conduct of the
71124.01
work itself. Exelon also did not identify very high levels of loose surface contamination on overhead piping and structures which surrounded the work area. This failure resulted in unplanned internal radiation exposures to three personnel, including an RPT who was
A self-revealing Green finding and associated NCV of 10 CFR 20.1501, Surveys and
Monitoring: General, was identified when Exelon failed to perform adequate loose surface
contamination surveys of the Unit 1 RWCU isolation valve room prior to authorizing work to
hang shadow shielding near the HV-051-1F017A valve, and also during the conduct of the
work itself. Exelon also did not identify very high levels of loose surface contamination on
overhead piping and structures which surrounded the work area. This failure resulted in
unplanned internal radiation exposures to three personnel, including an RPT who was
assigned to monitor the radiological aspects of the work.
assigned to monitor the radiological aspects of the work.
Description: The HV-44-1F040 valve ("40 valve") in the Unit 1 RWCU isolation valve room developed a steam leak in June of 2016. The leak became more pronounced over time. This
Description: The HV-44-1F040 valve (40 valve) in the Unit 1 RWCU isolation valve room
leak, from a system which is known to contain high levels of radioactive activation products, resulted in the spread of significant levels of loose surface contamination within the room.
developed a steam leak in June of 2016. The leak became more pronounced over time. This
The valve was repaired in September of 2017. The room was not decontaminated at that time due to very high area dose rates.  
leak, from a system which is known to contain high levels of radioactive activation products,
resulted in the spread of significant levels of loose surface contamination within the room.  


During the period of the steam leak, the HV-051-1F017A valve ("17 valve") developed
The valve was repaired in September of 2017. The room was not decontaminated at that
problems in its remote operation with indication of a ground in the direct current system. Contaminated water from the 40 valve, which is located directly above the 17 valve, affected the motor actuator for the 17 valve, necessitating a repair. The repair was scheduled for the
time due to very high area dose rates.
next scheduled refueling outage (1R17).  
During the period of the steam leak, the HV-051-1F017A valve (17 valve) developed
 
problems in its remote operation with indication of a ground in the direct current system.
ALARA Plan 18-043 was developed to control the radiological aspects of the repair to the 17 valve motor/actuator and was approved for use on March 15, 2018. The plan identified that decontamination may be required, that surface contamination levels could approach 400
Contaminated water from the 40 valve, which is located directly above the 17 valve, affected
the motor actuator for the 17 valve, necessitating a repair. The repair was scheduled for the
next scheduled refueling outage (1R17).
ALARA Plan 18-043 was developed to control the radiological aspects of the repair to the 17
valve motor/actuator and was approved for use on March 15, 2018. The plan identified that
decontamination may be required, that surface contamination levels could approach 400
mrad/hr per 100 centimeters squared (about 20,000,000 dpm per 100 centimeters squared),
mrad/hr per 100 centimeters squared (about 20,000,000 dpm per 100 centimeters squared),
and that the room was classified as "Alpha Level II."  This level of loose surface contamination
and that the room was classified as Alpha Level II. This level of loose surface contamination
is radiologically significant and presents a potential for unplanned internal radiation exposure. An ALARA evaluation indicated that respiratory protection was not warranted for the planned
is radiologically significant and presents a potential for unplanned internal radiation exposure.
An ALARA evaluation indicated that respiratory protection was not warranted for the planned
work.
work.
A limited decontamination was performed of the tr
A limited decontamination was performed of the travel path from the rooms entrance to the
avel path from the room's entrance to the 17 valve, the immediate area around the valve, and a light fixture (at head level) near the
valve, the immediate area around the valve, and a light fixture (at head level) near the
valve, on March 27, 2018, in support of the planned repairs. A personal air sampler worn during the decontamination work showed a localized airborne radioactivity of 0.38 derived air concentration, indicating that the decontamination caused some loose surface contamination
valve, on March 27, 2018, in support of the planned repairs. A personal air sampler worn
during the decontamination work showed a localized airborne radioactivity of 0.38 derived air
concentration, indicating that the decontamination caused some loose surface contamination
to be suspended in the air. A post-decontamination radiological survey (2018-008466) was
to be suspended in the air. A post-decontamination radiological survey (2018-008466) was
performed to assess the conditions at the valve, and indicated maximum loose surface
performed to assess the conditions at the valve, and indicated maximum loose surface
contamination levels of 60,000 dpm per 100 centimeters squared on the light fixture.
contamination levels of 60,000 dpm per 100 centimeters squared on the light fixture.
On March 29, 2018, radiation shielding was installed near the 17 valve as part of the ALARA plan. The crew consisted of two iron-workers and a senior RPT who was assigned to provide
On March 29, 2018, radiation shielding was installed near the 17 valve as part of the ALARA
plan. The crew consisted of two iron-workers and a senior RPT who was assigned to provide
continuous radiological coverage of the work. Installing the shielding included hanging steel
continuous radiological coverage of the work. Installing the shielding included hanging steel
chains from structures in the overhead areas above the 17 valve, from which the shielding
chains from structures in the overhead areas above the 17 valve, from which the shielding
would then be affixed. These overhead areas had not been decontaminated and were not included in the loose surface contamination survey two days earlier. Personnel in the room were not required to wear respiratory protection.  
would then be affixed. These overhead areas had not been decontaminated and were not
 
included in the loose surface contamination survey two days earlier. Personnel in the room
were not required to wear respiratory protection.
During the work, a hanging light fixture needed to be repositioned several times. When the
During the work, a hanging light fixture needed to be repositioned several times. When the
fixture was moved, dust was observed to fall from the light fixture. The iron-workers did not
fixture was moved, dust was observed to fall from the light fixture. The iron-workers did not
believe that the dust was a concern due to the protective clothing that they were wearing, and thus did not notify the RPT of the unexpected condition. The RPT, therefore, was not prompted to obtain additional smear samples of the dusty areas in order to assess the
believe that the dust was a concern due to the protective clothing that they were wearing, and
radiological impact.  
thus did not notify the RPT of the unexpected condition. The RPT, therefore, was not
 
prompted to obtain additional smear samples of the dusty areas in order to assess the
The crew attempted to exit the radiologically controlled area after the completion of their work, and alarmed the personal contamination monitors. Follow-up assessments, including a series of whole body counts revealed unplanned internal radiation exposures at a small fraction of the annual occupational exposure limits. IR 04120372 was written to document the event,
radiological impact.
The crew attempted to exit the radiologically controlled area after the completion of their work,
and alarmed the personal contamination monitors. Follow-up assessments, including a series
of whole body counts revealed unplanned internal radiation exposures at a small fraction of
the annual occupational exposure limits. IR 04120372 was written to document the event,
which included an event investigation by supervisory staff.
which included an event investigation by supervisory staff.
On March 30, 2018, at 1536, an additional radiological survey of the room was performed. This more comprehensive effort identified very high levels of loose surface contamination on
On March 30, 2018, at 1536, an additional radiological survey of the room was performed.
overhead piping in the room, including areas near the shadow-shielding work area. These ranged from about 400,000 to 2,000,000 dpm per 100 centimeters-squared.
This more comprehensive effort identified very high levels of loose surface contamination on  


Corrective Actions: Exelon restricted access to the area, conducted additional radiological
overhead piping in the room, including areas near the shadow-shielding work area. These
ranged from about 400,000 to 2,000,000 dpm per 100 centimeters-squared.
Corrective Actions: Exelon restricted access to the area, conducted additional radiological
surveys, and conducted an investigation. Exelon entered the issue into their corrective action
surveys, and conducted an investigation. Exelon entered the issue into their corrective action
program. Corrective Action Reference: IR 04120372 Performance Assessment:
program.
Performance Deficiency: 10 CFR 20.1003 defines a survey as "an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release,
Corrective Action Reference: IR 04120372
Performance Assessment:
Performance Deficiency: 10 CFR 20.1003 defines a survey as an evaluation of the
radiological conditions and potential hazards incident to the production, use, transfer, release,
disposal, or presence of radioactive material or other sources of radiation. When appropriate,
disposal, or presence of radioactive material or other sources of radiation. When appropriate,
such an evaluation includes a physical survey of the location of radioactive material and
such an evaluation includes a physical survey of the location of radioactive material and
measurements or calculations of levels of radiation, or concentrations or quantities of radioactive material present."
measurements or calculations of levels of radiation, or concentrations or quantities of
radioactive material present.
CFR 20.1501 requires that each licensee make or cause to be made surveys that may be
CFR 20.1501 requires that each licensee make or cause to be made surveys that may be
necessary for the licensee to comply with the regulations in Part 20 and that are reasonable
necessary for the licensee to comply with the regulations in Part 20 and that are reasonable
under the circumstances to evaluate the magnitude and extent of radiation levels, concentrations or quantities of residual radioactivity, and the potential hazards of the radiation levels and residual radioactivity detected.
under the circumstances to evaluate the magnitude and extent of radiation levels,
concentrations or quantities of residual radioactivity, and the potential hazards of the radiation
levels and residual radioactivity detected.
CFR 20.1701 specifies that the licensee shall use, to the extent practical, processes or
CFR 20.1701 specifies that the licensee shall use, to the extent practical, processes or
other engineering controls (e.g., containment, decontamination, or ventilation) to control the
other engineering controls (e.g., containment, decontamination, or ventilation) to control the
concentration of radioactive material in air.
concentration of radioactive material in air.
The post-decontamination radiological survey of the Unit 1 RWCU isolation valve room was necessary to adequately assess the existing radiological conditions and to subsequently
The post-decontamination radiological survey of the Unit 1 RWCU isolation valve room was
necessary to adequately assess the existing radiological conditions and to subsequently
demonstrate compliance with 10 CFR 20.1701. The March 27, 2018, decontamination effort
demonstrate compliance with 10 CFR 20.1701. The March 27, 2018, decontamination effort
and subsequent loose surface contamination survey were focused on the immediate working
and subsequent loose surface contamination survey were focused on the immediate working
area around the 17 valve, but did not consider the need to access the areas in the overhead above the 17 valve to hang radiation shielding, which was the next major step in the work
area around the 17 valve, but did not consider the need to access the areas in the overhead
above the 17 valve to hang radiation shielding, which was the next major step in the work
process.
process.
When work to hang radiation shielding was authorized by Radiation Protection on March 29,
When work to hang radiation shielding was authorized by Radiation Protection on March 29,
2018, the supervisor failed to identify that the work would include locations in which there had
2018, the supervisor failed to identify that the work would include locations in which there had
been no decontamination and in which loose surface contamination levels had not been assessed. Those contamination levels exceeded the discontinue work criteria of the ALARA plan as provided in item 4, "contamination level > 200,000 dpm/100cm2 Post Decon."  These
been no decontamination and in which loose surface contamination levels had not been
assessed. Those contamination levels exceeded the discontinue work criteria of the ALARA
plan as provided in item 4, contamination level > 200,000 dpm/100cm2 Post Decon. These
levels and the tight confines of the work location would also likely warrant a re-evaluation of
levels and the tight confines of the work location would also likely warrant a re-evaluation of
the respiratory protection requriements as indicated in the ALARA plan item 8, "Airborne
the respiratory protection requriements as indicated in the ALARA plan item 8, Airborne
Radioactivity Mitigation," number 3, "RP to evaluate respiratory protection on other activities based upon radiological conditions and type of work."
Radioactivity Mitigation, number 3, RP to evaluate respiratory protection on other activities
based upon radiological conditions and type of work.
During conduct of the work, in-process loose surface contamination surveys were not
During conduct of the work, in-process loose surface contamination surveys were not
performed by the RPT, and the work was not paused to allow a radiological re-assessment of
performed by the RPT, and the work was not paused to allow a radiological re-assessment of
working conditions, when dust was seen to fall from a light fixture. This was contrary to the ALARA plan, which also included a discontinue work criteria of when "radiological conditions are not as expected."
working conditions, when dust was seen to fall from a light fixture. This was contrary to the
 
ALARA plan, which also included a discontinue work criteria of when radiological conditions
In addition, the RPT allowed a light fixture to be repositioned several times during the work, which was not within the authorized scope of work as provided in the pre-job briefing and was
are not as expected.  
contrary to the ALARA plan, item 16, "Contingency Plans," which states "Changes in work
scope: notify RPS and Rad Engineering prior to deviating form the original plan/work scope."
These failures were within Exelon's ability to foresee and correct, and should have been prevented, and therefore are performance deficiencies. The deficiencies represent multiple failed radiation protection barriers.  


Screening: This finding is more than minor because it is associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and affected the cornerstone objective to ensure the adequate protection of the worker health and safety from
In addition, the RPT allowed a light fixture to be repositioned several times during the work,
exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, loose surface contamination levels were not adequately assessed on
which was not within the authorized scope of work as provided in the pre-job briefing and was
contrary to the ALARA plan, item 16, Contingency Plans, which states Changes in work
scope: notify RPS and Rad Engineering prior to deviating form the original plan/work scope.
These failures were within Exelons ability to foresee and correct, and should have been
prevented, and therefore are performance deficiencies. The deficiencies represent multiple
failed radiation protection barriers.
Screening: This finding is more than minor because it is associated with the Program &
Process attribute of the Occupational Radiation Safety cornerstone and affected the
cornerstone objective to ensure the adequate protection of the worker health and safety from
exposure to radiation from radioactive material during routine civilian nuclear reactor
operation. Specifically, loose surface contamination levels were not adequately assessed on
multiple occasions, discontinue work criteria were exceeded, and work outside of the planned
multiple occasions, discontinue work criteria were exceeded, and work outside of the planned
scope was allowed. Thus multiple radiation safety barriers were defeated as described in IMC 0612, Section 6 "Health Physics," "General Screening Criteria."
scope was allowed. Thus multiple radiation safety barriers were defeated as described in
Significance: Using IMC 0609.04, "Initial Characterization of Findings," issued October 7, 2016, and IMC 0609, Appendix C, "Occupational Radiation Safety Significance Determination
IMC 0612, Section 6 Health Physics, General Screening Criteria.
Process," issued August 19, 2008, the inspection finding was not related to ALARA practices (Step 1), did not result in an overexposure (Step 5), did not represent a substantial potential for overexposure (Step 11), and did not compromise Exelon's ability to assess dose (Step
Significance: Using IMC 0609.04, Initial Characterization of Findings, issued October 7,
14). As a result, this finding was determined to be of very low safety significance (Green).  
2016, and IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination
 
Process, issued August 19, 2008, the inspection finding was not related to ALARA practices  
Cross-Cutting Aspect: This finding has a cross-cutting aspect in the area of Human
(Step 1), did not result in an overexposure (Step 5), did not represent a substantial potential
Performance, Challenge the Unknown, in that Exelon did not ensure that individuals stop when faced with uncertain conditions and ensure risks are evaluated and managed before proceeding. Specifically, the RPTs involved in assessing radiological conditions and controlling work (and their supervisor) did not adequately evaluate the potential for very high
for overexposure (Step 11), and did not compromise Exelons ability to assess dose (Step
14). As a result, this finding was determined to be of very low safety significance (Green).
Cross-Cutting Aspect: This finding has a cross-cutting aspect in the area of Human
Performance, Challenge the Unknown, in that Exelon did not ensure that individuals stop
when faced with uncertain conditions and ensure risks are evaluated and managed before
proceeding. Specifically, the RPTs involved in assessing radiological conditions and
controlling work (and their supervisor) did not adequately evaluate the potential for very high
levels of loose surface contamination in the RWCU isolation valve room following a significant
levels of loose surface contamination in the RWCU isolation valve room following a significant
leak and prior to working in overhead areas, and did not reassess conditions when dust fell
leak and prior to working in overhead areas, and did not reassess conditions when dust fell
from a light fixture. [H.11]
from a light fixture. [H.11]
Enforcement:
Enforcement:
Violation: 10 CFR 20.1003 defines a survey. 10 CFR 20.1501(a)(1) requires that each
Violation: 10 CFR 20.1003 defines a survey. 10 CFR 20.1501(a)(1) requires that each
licensee make or cause to be made surveys that may be necessary for the licensee to comply
licensee make or cause to be made surveys that may be necessary for the licensee to comply
with the regulations of Part 20.
with the regulations of Part 20.
Contrary to the above, on March 27 and March 29, 2018, Exelon did not perform adequate loose surface contamination surveys in the Unit 1 RWCU isolation valve room following a
Contrary to the above, on March 27 and March 29, 2018, Exelon did not perform adequate
loose surface contamination surveys in the Unit 1 RWCU isolation valve room following a
decontamination effort (and prior to authorizing work to hang radiation shielding), and
decontamination effort (and prior to authorizing work to hang radiation shielding), and
following the observation of dust falling from a light fixture in the immediate work area. These
following the observation of dust falling from a light fixture in the immediate work area. These
surveys were necessary to demonstrate compliance with 10 CFR 20.1701, ALARA Plan 18-
surveys were necessary to demonstrate compliance with 10 CFR 20.1701, ALARA Plan 18-
043, and its associated respiratory protection ALARA evaluation. As a result, three personnel received unplanned internal radiation exposures.
043, and its associated respiratory protection ALARA evaluation. As a result, three personnel
Disposition: This violation is being treated as an NCV, consistent with Section 2.3.2 of the
received unplanned internal radiation exposures.
NRC Enforcement Policy.
Disposition: This violation is being treated as an NCV, consistent with Section 2.3.2 of the
NRC Enforcement Policy.  


Unit 1 Core Spray Pump Failed to Start Resulting in Condition Prohibited by Technical Specifications
Unit 1 Core Spray Pump Failed to Start Resulting in Condition Prohibited by Technical
Specifications
Cornerstone
Cornerstone
Severity Cross-Cutting Aspect Report
Severity
Section Not Applicable Severity Level IV NCV 05000352/2018002-02
Cross-Cutting Aspect
Closed Not Applicable 71153 The inspectors identified a Severity Level IV NCV of Unit 1 Technical Specification 3.5.1 because one core spray subsystem was inoperable from July 17, 2017, until October 5, 2017.
Report
Specifically, the Unit 1 'C' core spray pump did not start upon demand during testing and was declared inoperable because the pump's associated circuit breaker closing charging springs
Section
were not charged. Description: On October 5, 2017, the Unit 1 'C' core spray pump failed to start during surveillance testing due to the associated circuit breaker failing to close. An initial investigation identified that the switch contact inside the circuit breaker control device which energizes the breaker's closing springs charging motor became dislodged. With the switch
Not Applicable
Severity Level IV
NCV 05000352/2018002-02
Closed
Not Applicable
71153
The inspectors identified a Severity Level IV NCV of Unit 1 Technical Specification 3.5.1
because one core spray subsystem was inoperable from July 17, 2017, until October 5, 2017.
Specifically, the Unit 1 C core spray pump did not start upon demand during testing and was
declared inoperable because the pumps associated circuit breaker closing charging springs
were not charged.
Description: On October 5, 2017, the Unit 1 C core spray pump failed to start during
surveillance testing due to the associated circuit breaker failing to close. An initial
investigation identified that the switch contact inside the circuit breaker control device which
energizes the breakers closing springs charging motor became dislodged. With the switch
contact unable to maintain the circuit, the charging motor did not energize long enough to fully
contact unable to maintain the circuit, the charging motor did not energize long enough to fully
charge the closing springs during the breaker's previous closing operation. This condition
charge the closing springs during the breakers previous closing operation. This condition
existed since the last time the Unit 1 'C' core spray pump was in service on July 17, 2017, until the discovery on October 5, 2017. This issue constituted a violation of Technical Specification 3.5.1, "Emergency Core Cooling System - Operating," because the pump was
existed since the last time the Unit 1 C core spray pump was in service on July 17, 2017,
until the discovery on October 5, 2017. This issue constituted a violation of Technical
Specification 3.5.1, Emergency Core Cooling System - Operating, because the pump was
out-of-service for greater than the allowed outage time of 7 days. This issue was reported to
out-of-service for greater than the allowed outage time of 7 days. This issue was reported to
the NRC in Licensee Event Report 05000352/2017-004-00, dated December 4, 2017, and
the NRC in Licensee Event Report 05000352/2017-004-00, dated December 4, 2017, and
supplemented by Licensee Event Report 05000352/2017-004-01, dated March 13, 2018.
supplemented by Licensee Event Report 05000352/2017-004-01, dated March 13, 2018.
Failure analysis of the control device identified that the cause of the switch contact becoming dislodged was due to arcing and welding of the switch contact eventually resulting in
Failure analysis of the control device identified that the cause of the switch contact becoming
dislodged was due to arcing and welding of the switch contact eventually resulting in
displacement of the switch contact. The most probable cause of the initial degradation that
displacement of the switch contact. The most probable cause of the initial degradation that
eventually led to arcing and welding was due to undervoltage testing of the closing springs
eventually led to arcing and welding was due to undervoltage testing of the closing springs
charging motor. This testing was performed during periodic circuit breaker inspections and overhauls. The test subjects the control device switch contacts and charging springs motor to lower than normal voltage which results in higher than normal current. The circuit breaker
charging motor. This testing was performed during periodic circuit breaker inspections and
overhauls. The test subjects the control device switch contacts and charging springs motor to
lower than normal voltage which results in higher than normal current. The circuit breaker
was last overhauled and subjected to undervoltage testing in June 2014. The circuit breaker
was last overhauled and subjected to undervoltage testing in June 2014. The circuit breaker
was operated a minimum of 9 times between June 2014 and the discovery of the failure in
was operated a minimum of 9 times between June 2014 and the discovery of the failure in
October 2017. There was no evidence of degraded performance in the breaker closing
October 2017. There was no evidence of degraded performance in the breaker closing
springs charging motor circuit prior to failure. The inspectors noted that there were no previous circuit breaker control device failures at Limerick due to switch contact issues. Also, a review of industry and vendor operating experience did not reveal any similar failures of switch contacts displacing due to arcing and welding.  
springs charging motor circuit prior to failure. The inspectors noted that there were no
 
previous circuit breaker control device failures at Limerick due to switch contact issues. Also,
Corrective Actions: Immediate corrective action was taken to replace the associated 4 kV circuit breaker control device and return the Unit 1 'C' core spray pump to an operable status. An extent-of-condition review was performed to verify that the charging spring indicators for
a review of industry and vendor operating experience did not reveal any similar failures of
the site's 2.3 kV, 4 kV, and 13.2 kV switchgear circuit breakers showed that the charging
switch contacts displacing due to arcing and welding.
Corrective Actions: Immediate corrective action was taken to replace the associated 4 kV
circuit breaker control device and return the Unit 1 C core spray pump to an operable status.
An extent-of-condition review was performed to verify that the charging spring indicators for
the sites 2.3 kV, 4 kV, and 13.2 kV switchgear circuit breakers showed that the charging
springs were charged. Exelon revised maintenance procedures to conduct the charging
springs were charged. Exelon revised maintenance procedures to conduct the charging
motor undervoltage test prior to disassembly of the control device during circuit breaker
motor undervoltage test prior to disassembly of the control device during circuit breaker
overhauls so that the associated electrical contacts on the switch will be inspected for damage/overheating following the test.
overhauls so that the associated electrical contacts on the switch will be inspected for
Corrective Action Reference: IR 4059470
damage/overheating following the test.
 
Corrective Action Reference: IR 4059470  
Performance Assessment:  The inspectors determined that the failure of the Unit 1 'C' core spray pump to start on October 5, 2017, was not within Exelon's ability to foresee and prevent. As a result, no performance deficiency was identified. Therefore, this violation will
not be considered in the assessment process or the NRC's Action Matrix. Enforcement:  This issue is considered within the traditional enforcement process because there was no performance deficiency associated with the violation of NRC requirements and the Reactor Oversight Process' significance determination process does not specifically consider violations without performance deficiencies in its assessment of licensee performance. Therefore, it is necessary to address this violation using traditional
enforcement to adequately deter non-compliance. 


Violation: Technical Specification 3.5.1, "Emergency Core Cooling System - Operating," requires in part, that emergency core cooling systems shall be operable with the core spray system consisting of two subsystems with each subsystem comprised of two operable core spray pumps and an OPERABLE flow path capable of taking suction from the suppression
Performance Assessment: The inspectors determined that the failure of the Unit 1 C core
spray pump to start on October 5, 2017, was not within Exelons ability to foresee and
prevent. As a result, no performance deficiency was identified. Therefore, this violation will
not be considered in the assessment process or the NRCs Action Matrix.
Enforcement: This issue is considered within the traditional enforcement process because
there was no performance deficiency associated with the violation of NRC requirements and
the Reactor Oversight Process significance determination process does not specifically
consider violations without performance deficiencies in its assessment of licensee
performance. Therefore, it is necessary to address this violation using traditional
enforcement to adequately deter non-compliance.
Violation: Technical Specification 3.5.1, Emergency Core Cooling System - Operating,
requires in part, that emergency core cooling systems shall be operable with the core spray
system consisting of two subsystems with each subsystem comprised of two operable core
spray pumps and an OPERABLE flow path capable of taking suction from the suppression
chamber and transferring the water through the spray sparger to the reactor vessel. If there
chamber and transferring the water through the spray sparger to the reactor vessel. If there
is one core spray subsystem inoperable, provided that at least two low pressure coolant
is one core spray subsystem inoperable, provided that at least two low pressure coolant
injection subsystems are operable, Technical Specification 3.5.1 limiting condition for operation action statement requires restoring the inoperable core spray subsystem to operable status within 7 days or be in at least Hot Shutdown within the next 12 hours and in
injection subsystems are operable, Technical Specification 3.5.1 limiting condition for
Cold Shutdown within the next 24 hours.
operation action statement requires restoring the inoperable core spray subsystem to
 
operable status within 7 days or be in at least Hot Shutdown within the next 12 hours and in
Contrary to the above, from July 17, 2017, until October 5, 2017, one Unit 1 core spray subsystem was inoperable, and Exelon did not restore the core spray subsystem to operable status within 7 days, and did not place Unit 1 in at least Hot shutdown within 12 hours or in
Cold Shutdown within the next 24 hours.
Cold Shutdown within 24 hours. Specifically, the Unit 1 'C' core spray pump did not start
Contrary to the above, from July 17, 2017, until October 5, 2017, one Unit 1 core spray
upon demand during testing and was declared inoperable because the pump's associated
subsystem was inoperable, and Exelon did not restore the core spray subsystem to operable
status within 7 days, and did not place Unit 1 in at least Hot shutdown within 12 hours or in
Cold Shutdown within 24 hours. Specifically, the Unit 1 C core spray pump did not start
upon demand during testing and was declared inoperable because the pumps associated
circuit breaker closing charging springs were not charged.
circuit breaker closing charging springs were not charged.
Severity/Significance: The NRC Enforcement
Severity/Significance: The NRC Enforcement Policy, Section 2.2.1 states, in part, that,
Policy, Section 2.2.1 states, in part, that, whenever possible, the NRC uses risk informati
whenever possible, the NRC uses risk information in assessing the safety significance of
on in assessing the safety significance of violations. The inspectors evaluated the issue using IMC 0609.04, "Initial Characterization of
violations. The inspectors evaluated the issue using IMC 0609.04, Initial Characterization of
Finding," and IMC 0609, Appendix A, Exhibit 2, "Mitigating Systems Screening Questions."  The inspectors determined that the issue required a detailed risk evaluation because the failure of the Unit 1 'C' core spray pump to start on October 5, 2017, represented an actual loss of function of at least a single train for greater than its technical specification allowed outage time. A Region I senior reactor analyst completed the detailed risk evaluation and
Finding, and IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions.
The inspectors determined that the issue required a detailed risk evaluation because the
failure of the Unit 1 C core spray pump to start on October 5, 2017, represented an actual
loss of function of at least a single train for greater than its technical specification allowed
outage time. A Region I senior reactor analyst completed the detailed risk evaluation and
estimated the increase in core damage frequency associated with this issue to be below E-
estimated the increase in core damage frequency associated with this issue to be below E-
7/year or of very low safety significance (G
7/year or of very low safety significance (Green). To perform the detailed risk evaluation to
reen). To perform the detailed risk evaluation to gather insights on safety significance, the senior reactor analyst used the Systems Analysis Programs for Hands-On Evaluation (SAPHIRE) Revision 8.1.6, Standardized Plant Analysis
gather insights on safety significance, the senior reactor analyst used the Systems Analysis
Programs for Hands-On Evaluation (SAPHIRE) Revision 8.1.6, Standardized Plant Analysis
Risk Model, version 8.50 for Limerick Generating Station Unit 1. The inspectors determined
Risk Model, version 8.50 for Limerick Generating Station Unit 1. The inspectors determined
that the issue is of very low safety significance and concluded that the violation would be best
that the issue is of very low safety significance and concluded that the violation would be best
characterized as Severity Level IV.
characterized as Severity Level IV.
Enforcement Action:
Enforcement Action: The violation is being treated as an NCV consistent with Section 2.3.2
The violation is being treated as an NCV consistent with Section 2.3.2
of the Enforcement Policy.  
of the Enforcement Policy.


Observations:
Observations:
71152 Semiannual Trend Review The inspectors reviewed and assessed two adverse trends in human performance and
71152 Semiannual Trend
Review
The inspectors reviewed and assessed two adverse trends in human performance and
equipment reliability, last discussed in the 2017 fourth quarter integrated inspection report  
equipment reliability, last discussed in the 2017 fourth quarter integrated inspection report  
(ADAMS Accession No. ML18032A569). The inspectors reviewed Exelon's continued actions, issues, and indicators related to improving human performance and determined that Exelon's efforts were sufficiently effective and sustained to not warrant continued focus by the inspectors.
(ADAMS Accession No. ML18032A569). The inspectors reviewed Exelons continued
actions, issues, and indicators related to improving human performance and determined that
Exelons efforts were sufficiently effective and sustained to not warrant continued focus by the
inspectors.
Regarding equipment reliability, the inspectors noted a number of additional examples
Regarding equipment reliability, the inspectors noted a number of additional examples
evaluated during the period that impacted operations: diesel generator elevated combustion air temperature, pump seal failures, diesel generator auto-start logic circuit issue, isolation valve failure, control enclosure chiller trips, and adjustable speed drive coolant leakage. The inspectors documented two findings in the 2018 first quarter integrated inspection report  
evaluated during the period that impacted operations: diesel generator elevated combustion
(ADAMS Accession No. ML18131A015) related to equipment reliability. Further inspection will be performed during subsequent licensee event report reviews and/or during other
air temperature, pump seal failures, diesel generator auto-start logic circuit issue, isolation
valve failure, control enclosure chiller trips, and adjustable speed drive coolant leakage. The
inspectors documented two findings in the 2018 first quarter integrated inspection report  
(ADAMS Accession No. ML18131A015) related to equipment reliability. Further inspection
will be performed during subsequent licensee event report reviews and/or during other
baseline inspection samples focusing on equipment reliability. Otherwise, during this
baseline inspection samples focusing on equipment reliability. Otherwise, during this
inspection, the inspectors did not identify a new performance deficiency or violation and/or determined that the issues were of minor safety significance. The inspectors noted a related issue identified by Exelon regarding unplanned entries into technical specification limiting conditions for operation and discussed the trend with Exelon personnel. The inspectors
inspection, the inspectors did not identify a new performance deficiency or violation and/or
determined that the issues were of minor safety significance. The inspectors noted a related
issue identified by Exelon regarding unplanned entries into technical specification limiting
conditions for operation and discussed the trend with Exelon personnel. The inspectors
concluded that a continued inspection focus on equipment reliability is warranted and
concluded that a continued inspection focus on equipment reliability is warranted and
discussed Exelon's continued actions to improve equipment reliability which included challenging repair scheduling for critical components, resolving long-standing and/or repetitive equipment problems, and focusing efforts to improve reliability of systems critical to station
discussed Exelons continued actions to improve equipment reliability which included
safety and reliability.  
challenging repair scheduling for critical components, resolving long-standing and/or repetitive
 
equipment problems, and focusing efforts to improve reliability of systems critical to station
Based on the overall results of the semi-annual trend review, the inspectors did not identify additional trends not recognized by Exelon and determined that Exelon was appropriately identifying and entering issues into the corrective action program, adequately evaluating the
safety and reliability.
Based on the overall results of the semi-annual trend review, the inspectors did not identify
additional trends not recognized by Exelon and determined that Exelon was appropriately
identifying and entering issues into the corrective action program, adequately evaluating the
issues, and properly identifying adverse trends before they became more safety significant
issues, and properly identifying adverse trends before they became more safety significant
problems.
problems.
Line 451: Line 654:
IR 4024190
IR 4024190
71152 Annual Follow-up of
71152 Annual Follow-up of
Selected Issues The inspectors reviewed the IR which documented Exelon's corrective actions to address the
Selected Issues
The inspectors reviewed the IR which documented Exelons corrective actions to address the
Unit 2 main steam line high radiation alarm that occurred on June 21, 2018. Because of a
Unit 2 main steam line high radiation alarm that occurred on June 21, 2018. Because of a
lack of an apparent cause, Exelon's initial evaluation identified and eliminated a number of likely causes, but did include the possibility of the introduction of foreign material as a potential cause. Their evaluation also considered the extent of condition and cause, potential generic implications and common cause, and previous occurrences. The corrective actions
lack of an apparent cause, Exelons initial evaluation identified and eliminated a number of
were classified and prioritized in accordance with Exelon's corrective action program
likely causes, but did include the possibility of the introduction of foreign material as a
guidance, and the inspectors concluded that Exelon's corrective actions were implemented
potential cause. Their evaluation also considered the extent of condition and cause, potential
generic implications and common cause, and previous occurrences. The corrective actions
were classified and prioritized in accordance with Exelons corrective action program
guidance, and the inspectors concluded that Exelons corrective actions were implemented
commensurate with the safety impact of the cause, and were appropriately focused to correct
commensurate with the safety impact of the cause, and were appropriately focused to correct
the problem. Exelon implemented enhanced foreign material exclusion controls during the current refueling outage and the inspectors observed their implementation during field walkdowns. No additional issues were identified.  
the problem. Exelon implemented enhanced foreign material exclusion controls during the
current refueling outage and the inspectors observed their implementation during field
walkdowns. No additional issues were identified.  


Observations:
Observations:
IR 4059470 71152 Annual Follow-up of Selected Issues The inspectors reviewed IR 4059470 which documented Exelon's actions regarding the Unit 1  
IR 4059470
'C' core spray pump failing to start during surveillance testing on October 5, 2017, due to the
71152 Annual Follow-up
pump's circuit breaker failing to close. The description of the event, corrective actions, and enforcement aspects of this event are documented in the finding above.
of Selected Issues
The inspectors identified that although the failure of the circuit breaker to close was classified as a critical component failure by the station ownership committee, the critical component
The inspectors reviewed IR 4059470 which documented Exelons actions regarding the Unit 1
clock was not reset as expected by ER-AA-1200, "Critical Component Failure Clock."  The
C core spray pump failing to start during surveillance testing on October 5, 2017, due to the
pumps circuit breaker failing to close. The description of the event, corrective actions, and
enforcement aspects of this event are documented in the finding above.
The inspectors identified that although the failure of the circuit breaker to close was classified
as a critical component failure by the station ownership committee, the critical component
clock was not reset as expected by ER-AA-1200, Critical Component Failure Clock. The
inspectors noted that the critical component clock is used only as an equipment reliability
inspectors noted that the critical component clock is used only as an equipment reliability
indicator and site awareness tool and, therefore, not resetting the clock for the event was considered a minor issue.  
indicator and site awareness tool and, therefore, not resetting the clock for the event was
considered a minor issue.  


Exelon performed a work group evaluation for the issue. This is the lowest level of review
Exelon performed a work group evaluation for the issue. This is the lowest level of review
specified by corrective action program procedures. The corrective action program procedural
specified by corrective action program procedures. The corrective action program procedural
guidance for events involving a critical component failure or requiring the submittal of a
guidance for events involving a critical component failure or requiring the submittal of a
licensee event report to the NRC recommended t
licensee event report to the NRC recommended the performance of at least a corrective
he performance of at least a corrective action program evaluation which is a higher level of investigation than a work group evaluation. Work group evaluations are allowed if the cause of the failure is known and if
action program evaluation which is a higher level of investigation than a work group
evaluation. Work group evaluations are allowed if the cause of the failure is known and if
proper approvals are obtained. The initial site investigation determined the failure to be due to
proper approvals are obtained. The initial site investigation determined the failure to be due to
a deformed control device switch contact which led to the switch contact being dislodged
a deformed control device switch contact which led to the switch contact being dislodged
inside the control device. Based on the cause of the failure presumed to be determined in the initial investigation, proper approvals were obtained to perform a work group evaluation versus a corrective action program evaluation. The control device was sent to a failure
inside the control device. Based on the cause of the failure presumed to be determined in the
initial investigation, proper approvals were obtained to perform a work group evaluation
versus a corrective action program evaluation. The control device was sent to a failure
analysis laboratory for review. The laboratory analysis determined that the cause of the
analysis laboratory for review. The laboratory analysis determined that the cause of the
failure to be associated with welding of the switch contacts eventually resulting in the switch
failure to be associated with welding of the switch contacts eventually resulting in the switch
displacing. The final work group evaluation concluded that the "most probable cause" of the initial degradation that eventually led to arcing and welding was due to undervoltage testing of the closing springs charging motor. The undervoltage testing subjects the switch contacts to
displacing. The final work group evaluation concluded that the most probable cause of the
initial degradation that eventually led to arcing and welding was due to undervoltage testing of
the closing springs charging motor. The undervoltage testing subjects the switch contacts to
higher than normal current which Exelon believed resulted in the initial degradation of the
higher than normal current which Exelon believed resulted in the initial degradation of the
switch contact.  
switch contact.
 
The inspectors questioned why the investigation class was not upgraded to a corrective action
The inspectors questioned why the investigation class was not upgraded to a corrective action program evaluation when the laboratory failure analysis identified a cause of the failure that was different than the initial investigation of the work group evaluation. In addition, the final
program evaluation when the laboratory failure analysis identified a cause of the failure that
work group evaluation only determined undervoltage testing was the "most probable cause" of
was different than the initial investigation of the work group evaluation. In addition, the final
work group evaluation only determined undervoltage testing was the most probable cause of
the initial degradation which led to the failure. Because the cause could not be definitively
the initial degradation which led to the failure. Because the cause could not be definitively
determined, Exelon should have performed a corrective action program evaluation. However, the inspectors concluded that the actions ultimately taken by Exelon were adequate and not upgrading the investigation class after receiving the laboratory failure analysis was a minor
determined, Exelon should have performed a corrective action program evaluation. However,
the inspectors concluded that the actions ultimately taken by Exelon were adequate and not
upgrading the investigation class after receiving the laboratory failure analysis was a minor
issue. This was based on the revisions and additional actions added to the work group
issue. This was based on the revisions and additional actions added to the work group
evaluation (e.g., performance of a risk assessment) following two reviews of IR 4059470 by
evaluation (e.g., performance of a risk assessment) following two reviews of IR 4059470 by
the management review committee and one review by the plant operations review committee.
the management review committee and one review by the plant operations review committee.
The inspectors' observed an action taken outside of the corrective action process that should have been established as an action in IR 4059470. Following the failure, operations
The inspectors observed an action taken outside of the corrective action process that should
management issued Operations Standing Order 17-14, "Operations Expectations for 4 Kilo-
have been established as an action in IR 4059470. Following the failure, operations
Volt Equipment Starts," to perform checks to observe closing spring indicators on 4 kV circuit
management issued Operations Standing Order 17-14, Operations Expectations for 4 Kilo-
breakers following breaker operation. The standing order was not added as an action item in IR 4059470 even though it was issued as a compensatory measure for the issue. The
Volt Equipment Starts, to perform checks to observe closing spring indicators on 4 kV circuit
standing order was intended to stay in place until applicable operations procedures were revised to include direction to perform these inspections routinely following breaker operation.
breakers following breaker operation. The standing order was not added as an action item in
IR 4059470 even though it was issued as a compensatory measure for the issue. The  
 
standing order was intended to stay in place until applicable operations procedures were
revised to include direction to perform these inspections routinely following breaker operation.
Based on further review of the issue, the action to revise the operations procedures was
Based on further review of the issue, the action to revise the operations procedures was
canceled in IR 4059470 on March 1, 2018. The inspectors noted that as of May 16, 2018,
canceled in IR 4059470 on March 1, 2018. The inspectors noted that as of May 16, 2018,
Standing Order 17-14 was still active and operations management was unaware that the action item to revise the procedures had been canceled. The inspectors concluded that issuing the standing order outside of the corrective action program process was a minor issue
Standing Order 17-14 was still active and operations management was unaware that the
action item to revise the procedures had been canceled. The inspectors concluded that
issuing the standing order outside of the corrective action program process was a minor issue
because there were no potential adverse consequences as a result of continuing to perform
because there were no potential adverse consequences as a result of continuing to perform
the checks.
the checks.
Exelon acknowledged the inspectors' observations discussed above and entered the issues into the corrective action program as IR 4140088.
Exelon acknowledged the inspectors observations discussed above and entered the issues
EXIT MEETINGS AND DEBRIEFS Unless otherwise noted, no proprietary information was retained by the inspectors or documented in this report.
into the corrective action program as IR 4140088.
On July 23, 2018, the inspectors presented the inspection results to Mr. Frank Sturniolo, Plant Manager, and other members of the Exelon staff.
EXIT MEETINGS AND DEBRIEFS
Unless otherwise noted, no proprietary information was retained by the inspectors or
documented in this report.  
 
On July 23, 2018, the inspectors presented the inspection results to Mr. Frank Sturniolo,
Plant Manager, and other members of the Exelon staff.
THIRD PARTY REVIEWS
THIRD PARTY REVIEWS
Inspectors reviewed Institute of Nuclear Power Operations reports that were issued during the inspection period.  
Inspectors reviewed Institute of Nuclear Power Operations reports that were issued during the
inspection period.  


DOCUMENTS REVIEWED
DOCUMENTS REVIEWED
71111.04 Procedures
71111.04
0S78.1.D, Valve Alignment for Normal Operati
Procedures
on of Standby Gas Treatment Room Ventilation, Revision 5 1S50.1.A (COL), Equipment Alignment of the ADS and Main Steam Relief Valves for Normal
0S78.1.D, Valve Alignment for Normal Operation of Standby Gas Treatment Room Ventilation,
Revision 5
1S50.1.A (COL), Equipment Alignment of the ADS and Main Steam Relief Valves for Normal
Operation, Revision 7
Operation, Revision 7
1S76.1.C, Equipment Alignment of Standby Gas Treatment System Reactor Enclosure Air Recirculation System for Automatic Initiation, Revision 12 1S92.1.N (COL-1), Equipment Alignment for 1A Diesel Generator Operation, Revision 34
1S76.1.C, Equipment Alignment of Standby Gas Treatment System Reactor Enclosure Air
Recirculation System for Automatic Initiation, Revision 12
1S92.1.N (COL-1), Equipment Alignment for 1A Diesel Generator Operation, Revision 34
1S92.1.N (COL-4), Equipment Alignment for 1D Diesel Generator Operation, Revision 31
1S92.1.N (COL-4), Equipment Alignment for 1D Diesel Generator Operation, Revision 31
Condition Reports
Condition Reports
22755 Work Orders
22755
Work Orders
4768620-02
4768620-02
Drawings E-484, Reactor Enclosure SGTS Filter Electrical Heaters Common, Revision 21
Drawings
E-484, Reactor Enclosure SGTS Filter Electrical Heaters Common, Revision 21
M-0078, Control Enclosure PI&D, Sheet 4, Revision 22
M-0078, Control Enclosure PI&D, Sheet 4, Revision 22
71111.04S
71111.04S
Procedures 1S49.1.A (COL), Valve Alignment to Assure Availability of the RCIC System, Revision 17 MA-716-230-1001, Oil Analysis Interpretation Guideline, Revision 20
Procedures
MA-AA-716-230, Predictive Maintenance Program, Revision 11 S52.1.C, Operation of Safeguard Piping Fill System, Revision 11 ST-6-049-230-1, RCIC Pump, Valve and Flow Test, Revision 90
1S49.1.A (COL), Valve Alignment to Assure Availability of the RCIC System, Revision 17
MA-716-230-1001, Oil Analysis Interpretation Guideline, Revision 20
MA-AA-716-230, Predictive Maintenance Program, Revision 11
S52.1.C, Operation of Safeguard Piping Fill System, Revision 11
ST-6-049-230-1, RCIC Pump, Valve and Flow Test, Revision 90
ST-6-052-760-1, Safeguard Piping Fill Quarterly Valve Test, Revision 20
ST-6-052-760-1, Safeguard Piping Fill Quarterly Valve Test, Revision 20
Condition Reports
Condition Reports
2653613 2656660 2697980 3956044 4078992 4086156
2653613
71111.05 Procedures CC-AA-211, Fire Protection Program, Revision 8
2656660
F-A-336, Pre-Fire Plan, Fire Area 2 13.2KV Switchgear Room 336 (Elev. 217'), Revision 15 F-A-361, Pre-Fire Plan, Fire Area 6, Unit 2, Class 1E Battery Room 361 (Elev. 217'), Revision 7
2697980
F-D-315A, D21 Diesel Generator and Fuel Oil - Lube Oil Tank Room, Rooms 315A and 316A (El 217), Revision 9 F-R-109, Pre-Fire Plan, Unit 1 HPCI Pump Room 109, Revision 10
3956044
F-R-110, Pre-Fire Plan, Unit 1 Core Spray Pump Room A, Revision 8 F-R-173, Unit 2, A and C RHR Heat Exchanger and Pump Rooms 173 and 280 (EL 177 and
4078992
201), Revision 6 F-R-174, Unit 2, B and D RHR Heat Exchanger and Pump Rooms 174 and 281 (EL 177 and
4086156
71111.05
Procedures
CC-AA-211, Fire Protection Program, Revision 8
F-A-336, Pre-Fire Plan, Fire Area 2 13.2KV Switchgear Room 336 (Elev. 217), Revision 15
F-A-361, Pre-Fire Plan, Fire Area 6, Unit 2, Class 1E Battery Room 361 (Elev. 217), Revision 7
F-D-315A, D21 Diesel Generator and Fuel Oil - Lube Oil Tank Room, Rooms 315A and 316A  
(El 217), Revision 9
F-R-109, Pre-Fire Plan, Unit 1 HPCI Pump Room 109, Revision 10
F-R-110, Pre-Fire Plan, Unit 1 Core Spray Pump Room A, Revision 8
F-R-173, Unit 2, A and C RHR Heat Exchanger and Pump Rooms 173 and 280 (EL 177 and
201), Revision 6
201), Revision 6
OP-AA-201-009, Control of Transient Combustible Material, Revision 20 OP-LG-201-008, Limerick Generating Station Fire Protection (F) Pre-Fire Plan Strategies, Revision 5
F-R-174, Unit 2, B and D RHR Heat Exchanger and Pump Rooms 174 and 281 (EL 177 and
201), Revision 6
 
OP-AA-201-009, Control of Transient Combustible Material, Revision 20
OP-LG-201-008, Limerick Generating Station Fire Protection (F) Pre-Fire Plan Strategies,
Revision 5
71111.05A
71111.05A
Procedures F-R-284, Pre-Fire-Plan, Unit 2 Reactor Enclosure Cooling Water Heat Exchanger Area Rooms 284 and 286 (EL 201), Revision 7
Procedures
OP-AA-201-003, Fire Drill Performance, Revision 16 ST-6-022-551-0, Fire Drill, Revision 13  
F-R-284, Pre-Fire-Plan, Unit 2 Reactor Enclosure Cooling Water Heat Exchanger Area Rooms
 
284 and 286 (EL 201), Revision 7
OP-AA-201-003, Fire Drill Performance, Revision 16
ST-6-022-551-0, Fire Drill, Revision 13
Condition Reports:
Condition Reports:
4084529 Miscellaneous Fire Drill Scenario No.: F-R-284, Unit 2, Reactor Enclosure Cooling Water Heat Exchanger Area Rooms 284 and 286 (EL 201), June 12, 2018 OP-AA-201-003 Attachment 1, Fire Drill Record, completed June, 12 2018  
4084529
 
Miscellaneous
71111.07 Procedures M-200-037, Q Listed HVAC Heating & Cooling Coil Clean/Flush, Revision 10 RP-LG-350-1006, Hydrolasing, Revision 1 RT-2-011-394-1, 1EV211 Core Spray Room Cooler Air to Water Heat Transfer Test,
Fire Drill Scenario No.: F-R-284, Unit 2, Reactor Enclosure Cooling Water Heat Exchanger Area
Rooms 284 and 286 (EL 201), June 12, 2018
OP-AA-201-003 Attachment 1, Fire Drill Record, completed June, 12 2018
71111.07
Procedures
M-200-037, Q Listed HVAC Heating & Cooling Coil Clean/Flush, Revision 10
RP-LG-350-1006, Hydrolasing, Revision 1
RT-2-011-394-1, 1EV211 Core Spray Room Cooler Air to Water Heat Transfer Test,
Revision 10
Revision 10
Work Orders
Work Orders
4309052
4309052
71111.08
71111.08
Procedures 100-RT-001, Radiographic Examination in Accordance with ASME Section V, Article 2, Revision 13 GEH-PDI-UT-1, PDI Generic Procedure for the Ultrasonic Examination of Ferritic Welds, Revision 12 GEH-UT-311, Procedure for Manual Ultrasonic Examination of Nozzle Inner Radius, Bore and Selected Nozzle to Vessel Regions, Revision 19 WPS 1-1-GTSM-PWHT, Welding Procedure Specification for P1 to P1 Manual GTAW and SMAW Welds, Revision 2
Procedures
100-RT-001, Radiographic Examination in Accordance with ASME Section V, Article 2,
Revision 13
GEH-PDI-UT-1, PDI Generic Procedure for the Ultrasonic Examination of Ferritic Welds,
Revision 12
GEH-UT-311, Procedure for Manual Ultrasonic Examination of Nozzle Inner Radius, Bore and
Selected Nozzle to Vessel Regions, Revision 19
WPS 1-1-GTSM-PWHT, Welding Procedure Specification for P1 to P1 Manual GTAW and
SMAW Welds, Revision 2
Condition Reports
Condition Reports
22585
22585
Work Orders
Work Orders
4179424
4179424
Miscellaneous ER-LG-330-1001, ISI Program Plan Fourth Ten-Year Inservice Inspection Interval, Revision 15
Miscellaneous
UT-18-017, UT Examination Report for APE-1MS-LD N3D (Summary No. LIM-1-602760), dated April 4, 2018 VT Examination Report for Suppression Pool Internal Surfaces, dated April 4, 2018 UT-18-011, UT Examination Report for FWA-039 (Summary No. LIM-1-233390), dated April 4, 2018 UT-18-012, UT Examination Report for FWA-040 (Summary No. LIM-1-233400), dated April 4, 2018 RT Examination Report for FW-56 on Line DBB-105-1, dated April 2, 2018
ER-LG-330-1001, ISI Program Plan Fourth Ten-Year Inservice Inspection Interval, Revision 15  
RT Examination Report for FW-58 on Line DBB-105-1, dated April 2, 2018


71111.11 Procedures
UT-18-017, UT Examination Report for APE-1MS-LD N3D (Summary No. LIM-1-602760),
dated April 4, 2018
VT Examination Report for Suppression Pool Internal Surfaces, dated April 4, 2018
UT-18-011, UT Examination Report for FWA-039 (Summary No. LIM-1-233390), dated
April 4, 2018
UT-18-012, UT Examination Report for FWA-040 (Summary No. LIM-1-233400), dated
April 4, 2018
RT Examination Report for FW-56 on Line DBB-105-1, dated April 2, 2018
RT Examination Report for FW-58 on Line DBB-105-1, dated April 2, 2018
71111.11
Procedures
GP-2, Normal Plant Startup, Revision 172
GP-2, Normal Plant Startup, Revision 172
71111.12 Procedures ER-AA-310-1002, Maintenance Rule Functions - Safety Significance Classification, Revision 3 ER-AA-310-1003, Maintenance Rule - Performance Criteria Selection, Revision 5
71111.12
Procedures
ER-AA-310-1002, Maintenance Rule Functions - Safety Significance Classification, Revision 3
ER-AA-310-1003, Maintenance Rule - Performance Criteria Selection, Revision 5
ER-AA-310-1004, Maintenance Rule - Performance Monitoring, Revision 14
ER-AA-310-1004, Maintenance Rule - Performance Monitoring, Revision 14
ER-AA-310-1005, Maintenance Rule - Dispositioning Between (a)(1) and (a)(2), Revision 7
ER-AA-310-1005, Maintenance Rule - Dispositioning Between (a)(1) and (a)(2), Revision 7
M-056-001, Replacement of Mechanical Seals on the High Pressure Coolant Injection Main Pump - P204, Revision 1 OP-LG-108-117-1000, Limerick Protected Equipment Program, Revision 6 SM-AA-300-1001, Procurement Engineering Process and Responsibilities, Revision 23
M-056-001, Replacement of Mechanical Seals on the High Pressure Coolant Injection Main
Pump - P204, Revision 1
OP-LG-108-117-1000, Limerick Protected Equipment Program, Revision 6
SM-AA-300-1001, Procurement Engineering Process and Responsibilities, Revision 23
Condition Reports
Condition Reports
2652839 2653173 2681816 2682469 2683662 2686466
2652839
2686469 2690284 2695292 2697334 2704684 2705628
2653173
2713214 2718916 2718965 2718986 2719515 2725822
2681816
27759 3948230 3951442 3952680 3953586 3983220
2682469
4001894 4002391 4015662 4123699 4127144 4127674
2683662
4136634 Work Orders
2686466
4308237 4773946
2686469
Miscellaneous A/R A0733443, O-ring, F/Basket Strainer on Diesel Fuel Oil system, 4/7/93 Eval: 114-38109, EDG Gasket Material - Evaluate Alternate, 1/25/13 INSP NO: 0101903 PEEVAL 211748, Commercial Grade Dedication Plan for KTN-R-10 Fuse, Revision 1
2690284
2695292
2697334
2704684
2705628
2713214
2718916
2718965
2718986
2719515
25822
27759
3948230
3951442
3952680
3953586
3983220
4001894
4002391
4015662
23699
27144
27674
4136634
Work Orders
4308237
4773946
Miscellaneous
A/R A0733443, O-ring, F/Basket Strainer on Diesel Fuel Oil system, 4/7/93
Eval: 114-38109, EDG Gasket Material - Evaluate Alternate, 1/25/13
INSP NO: 0101903
PEEVAL 211748, Commercial Grade Dedication Plan for KTN-R-10 Fuse, Revision 1
Ref. No.: 114-38070, Gasket, Crankcase, 7/27/89
Ref. No.: 114-38070, Gasket, Crankcase, 7/27/89
Ref. No.: 11592850, Gaskets, Manifolds, 5/16/90
Ref. No.: 11592850, Gaskets, Manifolds, 5/16/90
71111.13 Procedures
71111.13
ER-AA-600-1042, On-Line Risk Management, Revision 10 OP-AA-108-117, Protected Equipment Program, Revision 5
Procedures
OP-LG-108-117-1000, Limerick Protected Equipment Program, Revision 6 ST-2-072-107-1, Div II Reactor Enclosure BOP Isolation LSF/SAA and RERS, SGTS Test, Revision 16 ST-6-092-115-1, D11 Diesel Generator 4KV SFGD Loss of Power LSF/SAA and Outage Testing, Revision 25 WC-AA-101-1006, On-Line Risk Management and Assessment, Revision 2
ER-AA-600-1042, On-Line Risk Management, Revision 10
OP-AA-108-117, Protected Equipment Program, Revision 5  


OP-LG-108-117-1000, Limerick Protected Equipment Program, Revision 6
ST-2-072-107-1, Div II Reactor Enclosure BOP Isolation LSF/SAA and RERS, SGTS Test,
Revision 16
ST-6-092-115-1, D11 Diesel Generator 4KV SFGD Loss of Power LSF/SAA and Outage
Testing, Revision 25
WC-AA-101-1006, On-Line Risk Management and Assessment, Revision 2
Miscellaneous
Miscellaneous
Operations Protected Equipment Log 4/5/18  
Operations Protected Equipment Log 4/5/18
 
71111.15
71111.15 Procedures NRC IN 2017-003, Anchor Darling Double Disk Gate Valve Wedge Pin and Stem-Disc
Procedures
OT-102, Reactor High Pressure, Revision 27 S57.1.C, Drywell Purge Fan Operation, Revision 8
NRC IN 2017-003, Anchor Darling Double Disk Gate Valve Wedge Pin and Stem-Disc
ST-6-001-761-1, Main Turbine Bypass Valve Exercising, Revision 30  
OT-102, Reactor High Pressure, Revision 27
 
S57.1.C, Drywell Purge Fan Operation, Revision 8
ST-6-001-761-1, Main Turbine Bypass Valve Exercising, Revision 30
Condition Reports
Condition Reports
0412345 1175540 2590938 4119016 4122755 4126091
0412345
1175540
2590938
4119016
22755
26091
27674
27674
Work Orders
Work Orders
4768620 Drawings E-484, Reactor Enclosure SGTS Filter Electrical Heaters Common, Revision 21 M-0076, Reactor Enclosure and Refueling Area HVAC, Sheet 6, Revision 33
4768620
Drawings
E-484, Reactor Enclosure SGTS Filter Electrical Heaters Common, Revision 21
M-0076, Reactor Enclosure and Refueling Area HVAC, Sheet 6, Revision 33
M-0078, Control Enclosure PI&D, Sheet 4, Revision 22
M-0078, Control Enclosure PI&D, Sheet 4, Revision 22
71111.18
71111.18
Procedures 8031-M-0022, Sheet 6, Fire Protection (Unit 1, Unit 2 and Common), Revision 24 8031-M-0028, Sheet 1, Generator H
Procedures
Cooling and CO
8031-M-0022, Sheet 6, Fire Protection (Unit 1, Unit 2 and Common), Revision 24
Purge (Unit 1 and Common), Revision
8031-M-0028, Sheet 1, Generator H2 Cooling and CO2 Purge (Unit 1 and Common), Revision
8031-M-0028, Sheet 2, Generator H
8031-M-0028, Sheet 2, Generator H2 Cooling and CO2 Purge (Unit 2), Revision 23
Cooling and CO
CC-AA-211, Fire Protection Program, Revision 8
Purge (Unit 2), Revision 23 CC-AA-211, Fire Protection Program, Revision 8
L-S-51, Fire Protection System, Revision 7
L-S-51, Fire Protection System, Revision 7
LS-AA-104, Exelon 50.59 Review Process, Revision 10
LS-AA-104, Exelon 50.59 Review Process, Revision 10
LS-AA-104-1001, 50.59 Review Coversheet Form, Revision 4 PPC-LGS-1, Preparedness, Prevention and Contingency Plan for Limerick Generating Station, Revision 3 ST-6-001-766-1, Main Turbine Control Valve Exercise & RPS Channel Functional Test, OPCON 4, 5, Revision 19, 20 and 21
LS-AA-104-1001, 50.59 Review Coversheet Form, Revision 4
PPC-LGS-1, Preparedness, Prevention and Contingency Plan for Limerick Generating Station,
Revision 3
ST-6-001-766-1, Main Turbine Control Valve Exercise & RPS Channel Functional Test, OPCON
4, 5, Revision 19, 20 and 21
Condition Reports
Condition Reports
29080 4126850
29080
26850


Miscellaneous EC 618876, LGS U1 and U2 Carbon Dioxide System Modification and Abandonment,
Miscellaneous
Revision 2 LG-2017S029, 50.59 Screening for LGS U1 and U2 Carbon Dioxide System Modification and   Abandonment, Revision 0 ECR 1200019 and ECR 1200024, Electro-Hydraulic Control (EHC) System Upgrades,
EC 618876, LGS U1 and U2 Carbon Dioxide System Modification and Abandonment,
Revision 2
LG-2017S029, 50.59 Screening for LGS U1 and U2 Carbon Dioxide System Modification and
Abandonment, Revision 0
ECR 1200019 and ECR 1200024, Electro-Hydraulic Control (EHC) System Upgrades,
Revision 3
Revision 3
71111.19
71111.19
Procedures M-056-001, Replacement of Mechanical Seals on the High Pressure Coolant Injection Main Pump - P204, Revision 0 M-056-004, Overhaul of the High Pressure Coolant Injection Main Pump - P204, Revision 3 M-200-037, Q Listed HVAC Heating & Cooling Coil Clean/Flush, Revision 10 RP-LG-350-1006, Hydrolasing, Revision 1
Procedures
M-056-001, Replacement of Mechanical Seals on the High Pressure Coolant Injection Main
Pump - P204, Revision 0
M-056-004, Overhaul of the High Pressure Coolant Injection Main Pump - P204, Revision 3
M-200-037, Q Listed HVAC Heating & Cooling Coil Clean/Flush, Revision 10
RP-LG-350-1006, Hydrolasing, Revision 1
RT-6-051-206-1, 1C RHR-SDC Crosstie Valve Test, Revision 5
RT-6-051-206-1, 1C RHR-SDC Crosstie Valve Test, Revision 5
S12.1.A, RHR Service Water System Dual Loop Startup Hard Card, Revision 2
S12.1.A, RHR Service Water System Dual Loop Startup Hard Card, Revision 2
S12.2.A, Shutdown of RHR Service Water Pumps and System, Revision 35 S51.5.A, Flushing of the RHR System Heat Exchanger Tube Side with Demineralized Water, Revision 25 S51.8.A Appendix 1, Placing RHR SP Cooling in Service During a Plant Event, Revision 2
S12.2.A, Shutdown of RHR Service Water Pumps and System, Revision 35
S51.5.A, Flushing of the RHR System Heat Exchanger Tube Side with Demineralized Water,
Revision 25
S51.8.A Appendix 1, Placing RHR SP Cooling in Service During a Plant Event, Revision 2
S55.1.A, Normal HPCI Line-up for Automatic Operation, Revision 37
S55.1.A, Normal HPCI Line-up for Automatic Operation, Revision 37
S55.1.D Appendix 1, Starting HPCI for Pressure Control During a Plant Event, Revision 0
S55.1.D Appendix 1, Starting HPCI for Pressure Control During a Plant Event, Revision 0
S55.3.A, HPCI Fill and Vent, Revision 36 S55.9.A, Routine Inspection of HPCI System, Revision 43 S93.0.C, 480 VAC Safeguard MCC Compartment Installation, Revision 35
S55.3.A, HPCI Fill and Vent, Revision 36
S55.9.A, Routine Inspection of HPCI System, Revision 43
S93.0.C, 480 VAC Safeguard MCC Compartment Installation, Revision 35
ST-6-011-231-0, A Loop ESW Pump, Valve & Flow Test, Revision 75
ST-6-011-231-0, A Loop ESW Pump, Valve & Flow Test, Revision 75
ST-6-051-202-1, A LOOP RHR Cold Shutdown Valve Test, Revision 22
ST-6-051-202-1, A LOOP RHR Cold Shutdown Valve Test, Revision 22
ST-6-051-232-1, B RHR Pump, Valve, and Flow Test, Revision 87 ST-6-055-230-1, HPCI Pump, Valve and Flow Test, Revision 86 ST-6-107-594-1, Weekly Surveillance Log, Revision 84
ST-6-051-232-1, B RHR Pump, Valve, and Flow Test, Revision 87
ST-6-055-230-1, HPCI Pump, Valve and Flow Test, Revision 86
ST-6-107-594-1, Weekly Surveillance Log, Revision 84
ST-6-107-594-2, Weekly Surveillance Log, Revision 73
ST-6-107-594-2, Weekly Surveillance Log, Revision 73
Condition Reports
Condition Reports
27674 4145984 4146145
27674
4145984
4146145
Work Orders
Work Orders
239418 4240873 4267351
239418
4309052 4309629
240873
4313481 4614983 4710009 4728774 4747597
267351
4758920 4763312
4309052
4763312 4767181 4773946 4773946
4309629
Drawings 06KPX883678, Sheet 1, HPCI Pump, Revision D
4313481
71111.22 Procedures ST-2-074-629-1, Functional Check of Average Power Range Monitor 4 (APRM 4), Revision 17 ST-2-088-324-2, Remote Shutdown System Div 2 RHR Operability Test, Revision 7
4614983
ST-6-051-234-2, D RHR Pump, Valve and Flow Test, Revision 58
4710009
28774
4747597
4758920
4763312
4763312
4767181
4773946
4773946
Drawings
06KPX883678, Sheet 1, HPCI Pump, Revision D
71111.22
Procedures
ST-2-074-629-1, Functional Check of Average Power Range Monitor 4 (APRM 4), Revision 17
ST-2-088-324-2, Remote Shutdown System Div 2 RHR Operability Test, Revision 7
ST-6-051-234-2, D RHR Pump, Valve and Flow Test, Revision 58  


ST-6-092-115-1, D11 Diesel Generator 4KV SFGD Loss of Power LSF/SAA and Outage Testing, Revision 25 ST-6-092-312-1, D12 Diesel Generator Slow Start Operability Test Run, Revision 103
ST-6-092-115-1, D11 Diesel Generator 4KV SFGD Loss of Power LSF/SAA and Outage
Testing, Revision 25
ST-6-092-312-1, D12 Diesel Generator Slow Start Operability Test Run, Revision 103
ST-6-092-314-1, D14 Diesel Generator Slow Start Operability Test Run, Revision 104
ST-6-092-314-1, D14 Diesel Generator Slow Start Operability Test Run, Revision 104
Condition Reports
Condition Reports
4149666
4149666
Work Order
Work Order
266199 4324924 4325189 4761182 4325189
266199
 
24924
Drawings M-071-00048 Sheet 1, Schematic Engine Control D11 Diesel Generator, Revision 30
25189
71124.01 Procedures HU-AA-101, Human Performance Tools and Verification Practices, Revision 9
4761182
HU-AA-1211, Pre-Job Briefings, Revision 11 NISP-RP-002, Radiation and Contamination Surveys, Revision 0 NISP-RP-003, Radiological Air Sampling, Revision 0
25189
Drawings
M-071-00048 Sheet 1, Schematic Engine Control D11 Diesel Generator, Revision 30
71124.01
Procedures
HU-AA-101, Human Performance Tools and Verification Practices, Revision 9
HU-AA-1211, Pre-Job Briefings, Revision 11
NISP-RP-002, Radiation and Contamination Surveys, Revision 0
NISP-RP-003, Radiological Air Sampling, Revision 0
RP-AA-300, Radiological Survey Program, Revision 16
RP-AA-300, Radiological Survey Program, Revision 16
RP-AA-301, Radiological Air Sampling Program, Revision 11
RP-AA-301, Radiological Air Sampling Program, Revision 11
RP-AA-401, Operational ALARA Planning and Controls, Revision 23
RP-AA-401, Operational ALARA Planning and Controls, Revision 23
RP-AA-441, TEDE ALARA Evaluation, Revision 9
RP-AA-441, TEDE ALARA Evaluation, Revision 9
Miscellaneous ALARA Briefing / Attendance Form, RP-AA-401 Attachment 3, for ALARA Plan 18-043, dated 3/27/2018 at 1030 and 3/28/2018 at 2000 ALARA Plan 18-043
Miscellaneous
ALARA Briefing / Attendance Form, RP-AA-401 Attachment 3, for ALARA Plan 18-043, dated
3/27/2018 at 1030 and 3/28/2018 at 2000
ALARA Plan 18-043
AR04120372
AR04120372
Radiation Work Permit LG-0-18-00625, Revision 0
Radiation Work Permit LG-0-18-00625, Revision 0
Line 645: Line 1,034:
Radiological Survey 2018-008466
Radiological Survey 2018-008466
Radiological Survey 2018-008547
Radiological Survey 2018-008547
Radiological Survey 2018-008552 Radiological Survey 2018-008594 Radiological Survey 2018-008690
Radiological Survey 2018-008552
Radiological Survey 2018-008594
Radiological Survey 2018-008690
TEDE ALARA Screening and Evaluation for plan 18-043
TEDE ALARA Screening and Evaluation for plan 18-043
71151 Procedures LS-AA-2200, Emergency AC Power Function, Attachment 5 data (April 2017 through April 2018)
71151
71152 Procedures ER-AA-1200, Critical Component Failure Clock, Revision 12 M-200-002, 2.3 KV and 4 KV Power Circuit Breaker Overhaul, Revision 10
Procedures
M-200-011, 13.2 KY and 2.3 KV Switchgear Maintenance, Revision 4
LS-AA-2200, Emergency AC Power Function, Attachment 5 data (April 2017 through April 2018)
MA-AA-716-004, Revision 15 MA-AA-716-008, Foreign Material Exclusion Program, Revision 13
71152
PI-AA-120, Issue Identification and Screening Process, Revision 8 PI-AA-125, Corrective Action Program Procedure, Revision 8 PI-AA-125-1003, Corrective Action Program Evaluation Manual, Revision 4
Procedures
ER-AA-1200, Critical Component Failure Clock, Revision 12
M-200-002, 2.3 KV and 4 KV Power Circuit Breaker Overhaul, Revision 10
M-200-011, 13.2 KY and 2.3 KV Switchgear Maintenance, Revision 4  
 
MA-AA-716-004, Revision 15
MA-AA-716-008, Foreign Material Exclusion Program, Revision 13
PI-AA-120, Issue Identification and Screening Process, Revision 8
PI-AA-125, Corrective Action Program Procedure, Revision 8
PI-AA-125-1003, Corrective Action Program Evaluation Manual, Revision 4
Condition Reports
Condition Reports
22252 4024190 4118994 4119397 4121951 4122429
22252
22755 4122806 4123146 4123855 4124233 4126850
24190
27674 4127870 4133876 4133876 4135378 4140085
4118994
4141279 4141283  
4119397
 
21951
22429
22755
22806
23146
23855
24233
26850
27674
27870
4133876
4133876
4135378
4140085
4141279
4141283
Miscellaneous
Miscellaneous
ECAPE 4024190-14 Equipment Operator Initial Training, Modul
ECAPE 4024190-14
e LEOT0229, AC Circuit Breakers, Revision 007 LIM-0-2018-0099, 4 Kilo-Volt Breaker Springs Failure Risk Assessment, dated 04/25/2018
Equipment Operator Initial Training, Module LEOT0229, AC Circuit Breakers, Revision 007
LIM-0-2018-0099, 4 Kilo-Volt Breaker Springs Failure Risk Assessment, dated 04/25/2018
LIM-60226, Failure Analysis of a Contact Assembly, dated 12/18/2017
LIM-60226, Failure Analysis of a Contact Assembly, dated 12/18/2017
Non-Conformance Report 94-00009, Calculation LE-069 Inadequate Voltage at 4 KV Switchgear Spring Charging Motor, dated 2/19/1994 Operations Standing Order 17-14, Operations Expectations for 4 Kilo-Volt Equipment Starts, dated 12/20/2017
Non-Conformance Report 94-00009, Calculation LE-069 Inadequate Voltage at 4 KV
71153 Procedures GP-5 Appendix 2, Rx Maneuvering Without Shutdown, Revision 102
Switchgear Spring Charging Motor, dated 2/19/1994
Operations Standing Order 17-14, Operations Expectations for 4 Kilo-Volt Equipment Starts,
dated 12/20/2017
71153
Procedures
GP-5 Appendix 2, Rx Maneuvering Without Shutdown, Revision 102
Condition Reports
Condition Reports
4145616 4145647 4145655 4145666 4145776 4146236
4145616
4145647
4145655
4145666
4145776
4146236
}}
}}

Latest revision as of 15:10, 5 January 2025

Integrated Inspection Report 05000352/2018002 and 05000353/2018002
ML18221A483
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 08/09/2018
From: Jon Greives
Reactor Projects Region 1 Branch 4
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
Greives J
References
IR 2018002
Download: ML18221A483 (28)
v • d • e


Text

August 9, 2018

SUBJECT:

LIMERICK GENERATING STATION - INTEGRATED INSPECTION REPORT 05000352/2018002 AND 05000353/2018002

Dear Mr. Hanson:

On June 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Limerick Generating Station, Units 1 and 2. On July 23, 2018, the NRC inspectors discussed the results of this inspection with Mr. Frank Sturniolo, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. Additionally, NRC inspectors documented one Severity Level IV violation with no associated finding. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or significance of these NCVs, 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; and the NRC Resident Inspector at Limerick Generating Station.

In addition, if you disagree with a cross-cutting aspect assignment, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC, 20555-0001; with copies to the Regional Administrator, Region I, and the NRC Resident Inspector at Limerick Generating Station. 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 the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Jonathan E. Greives, Chief Reactor Projects Branch 4 Division of Reactor Projects

Docket Nos. 50-352 and 50-353 License Nos. NPF-39 and NPF-85

Enclosure:

Inspection Report 05000352/2018002 and 05000353/2018002

Inspection Report

Docket Numbers:

50-352 and 50-353

License Numbers:

NPF-39 and NPF-85

Report Numbers:

05000352/2018002 and 05000353/2018002

Enterprise Identifier: I-2018-002-0065

Licensee:

Exelon Generation Company, LLC

Facility:

Limerick Generating Station, Units 1 & 2

Location:

Sanatoga, PA 19464

Inspection Dates:

April 1, 2018 through June 30, 2018

Inspectors:

S. Rutenkroger, PhD, Senior Resident Inspector

M. Henrion, Acting Resident Inspector

C. Safouri, Acting Resident Inspector

S. Barber, Senior Project Engineer

A. Turilin, Project Engineer

H. Anagnostopoulos, Senior Health Physicist

L. Andrews, Resident Inspector

N. Floyd, Reactor Inspector

E. DiPaolo, Senior Reactor Inspector

Approved By:

Jonathan E. Greives, Chief

Reactor Projects Branch 4

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Exelons performance at

Limerick Generating Station, Units 1 and 2 by conducting the baseline inspections described in this report 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. NRC-identified and self-revealing findings, violations, and additional items are summarized in the table below.

List of Findings and Violations

Failure to Conduct Adequate Radiation Surveys and Evaluate Potential Radiological Hazards Cornerstone Significance Cross-cutting Aspect Report Section Occupational Radiation Safety

Green NCV 05000352/2018002-01 Opened/Closed H.11 - Human Performance -

Challenge The Unknown 71124.01 A self-revealing Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 20.1501, Surveys and Monitoring: General, was identified when Exelon failed to perform adequate loose surface contamination surveys of the Unit 1 reactor water clean up (RWCU) isolation valve room prior to authorizing work to hang shadow shielding near the HV-051-1F017A valve and also during the conduct of the work itself. Exelon also did not identify very high levels of loose surface contamination on overhead piping and structures which surrounded the work area. This resulted in unplanned internal radiation exposures to three personnel, including a radiation protection technician (RPT) who was assigned to monitor the radiological aspects of the work.

Unit 1 Core Spray Pump Failed to Start Resulting in Condition Prohibited by Technical Specifications Cornerstone Significance Cross-cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000352/2018002-02 Opened/Closed Not Applicable 71153 The inspectors identified a Severity Level IV NCV of Unit 1 Technical Specification 3.5.1 because one core spray subsystem was inoperable from July 17, 2017, until October 5, 2017.

Specifically, the Unit 1 C core spray pump did not start upon demand during testing and was declared inoperable because the pumps associated 4 kilovolt (kV) circuit breaker closing charging springs were not charged.

Additional Tracking Items

Type Issue number Title Report Section Status LER 05000352/2017-004-00 and 05000352/2017-004-01 Core Spray Pump Failed to Start Resulting in Condition Prohibited by Technical Specifications 71153 Closed

TABLE OF CONTENTS

PLANT STATUS

INSPECTION SCOPES

................................................................................................................

REACTOR SAFETY

.................................................................................................................

RADIATION SAFETY

...............................................................................................................

OTHER ACTIVITIES - BASELINE

...........................................................................................

INSPECTION RESULTS

............................................................................................................ 10 THIRD PARTY REVIEWS.......................................................................................................... 18

DOCUMENTS REVIEWED

......................................................................................................... 19

PLANT STATUS

Unit 1 began the inspection period shutdown for a planned refueling outage. The unit was

restarted on April 15, 2018, and returned to 100 percent power on April 20, 2018. On June 9,

2018, the unit was downpowered to 33 percent in single loop operation due to an equipment

issue with the 1B adjustable speed drive. The unit was returned to rated thermal power on

June 11, 2018, and remained at or near rated thermal power for the remainder of the inspection

period.

Unit 2 began the inspection period at rated thermal power. On May 18, 2018, the unit was down

powered to 64 percent to repair a main condenser tube leak and perform required valve testing

and summer readiness activities. The unit was returned to rated thermal power on May 21,

2018, and remained at or near rated thermal power for the remainder of the inspection period.

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 also performed plant status activities described

in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152,

Problem Identification and Resolution. The inspectors reviewed selected procedures and

records, observed activities, and interviewed personnel to assess Exelons performance and

compliance with Commission rules and regulations, license conditions, site procedures, and

standards.

REACTOR SAFETY

71111.04 - Equipment Alignment

Partial Walkdown (4 samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) Unit 1 A standby gas treatment system on April 4, 2018

(2) Unit 1 D11 and D14 emergency diesel generators on April 7, 2018

(3) Unit common 201 safeguard transformer, bus, and related switchgear on April 25, 2018

(4) Unit 1 automatic depressurization system on April 30 through May 3, 2018

Complete Walkdown (1 sample)

The inspectors evaluated system configurations during a complete walkdown of the Unit 1

reactor core isolation cooling system.

71111.05A/Q - Fire Protection Annual/Quarterly

Quarterly Inspection (5 samples)

The inspectors evaluated fire protection program implementation in the following selected

areas:

(1) Fire area 34, Unit 1 high pressure coolant injection room, elevation 177, on May 4, 2018

(2) Fire area 2, Unit common 13.2 kV switchgear, elevation 217, on May 11, 2018

(3) Fire area 83, Unit 2 D21 emergency diesel generator and fuel oil day tank room,

elevation 217, on May 21, 2018

(4) Fire areas 54 & 55, Unit 2 residual heat removal heat exchanger and pump rooms 173,

174, 280, and 281, elevations 177 and 201, on June 7, 2018

(5) Fire area 35, Unit 1 A core spray pump room, elevation 177, on June 12, 2018

Annual Inspection (1 sample)

The inspectors evaluated fire brigade performance on June 12, 2018.

71111.07 - Heat Sink Performance

Heat Sink (1 sample)

The inspectors evaluated Exelons monitoring and maintenance of the 1A core spray room

unit cooler heat exchanger system.

71111.08 - Inservice Inspection Activities (1 sample)

The inspectors evaluated Exelons non-destructive examination and welding activities of

Unit 1 by reviewing the following activities and programs from April 2 to April 6, 2018:

(1) Volumetric Examinations

a) Manual ultrasonic testing of main steam loop D nozzle to safe-end weld, APE-1MS-

LD N3D

b) Manual ultrasonic testing of feedwater elbow-to-elbow and elbow-to-pipe welds,

FWA-039 and -040

c) Radiography testing of RWCU pipe-to-pipe welds, FW-56 and FW-58 which involved

welding activities associated with a pressure boundary risk significant system

(2) Visual Examinations

a) In-vessel visual inspection of jet pump components, top guide beams, and feedwater

piping structural attachments

b) Underwater visual inspection in the suppression pool of the core spray C suction

strainer and floor panels

c) General visual examination of the drywell liner

(3) The inspectors reviewed the welding activities associated with the replacement of

degraded piping on line DBB-105-01 in the RWCU system

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 sample)

The inspectors observed and evaluated licensed operator simulator training scenarios on

May 14, 2018.

Operator Performance (1 sample)

The inspectors observed reactor startup of Unit 1 on April 15, 2018.

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness (2 samples)

The inspectors evaluated the effectiveness of routine maintenance activities associated

with the following equipment and/or safety significant functions:

(1) Unit 1 high pressure coolant injection on May 3, 2018

(2) Unit 2 high pressure coolant injection on May 3, 2018

Quality Control (2 samples)

The inspectors evaluated maintenance and quality control activities associated with the

following equipment performance issues:

(1) Unit 2 D23 emergency diesel generator planned maintenance overhaul on February 12

to 16, 2018

(2) Unit 1 high pressure coolant injection main pump gear end outboard mechanical seal

replacement on April 30 to May 1, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control (5 samples)

The inspectors evaluated the risk assessments for the following planned and emergent

work activities:

(1) Unit 1 D11 4 kV bus unavailable for planned refueling outage maintenance on April 1,

2018

(2) Unit 1 D11 emergency diesel generator loss of coolant accident/loss of offsite power

test on April 5, 2018

(3) Unit 1 initial plant startup from a planned refueling outage with the containment de-

inerted on April 15, 2018

(4) Unit common B standby gas treatment system unavailable during testing on April 26,

2018

(5) Unit 1 high pressure coolant injection maintenance outage from April 30 to May 2, 2018

71111.15 - Operability Determinations and Functionality Assessments (5 samples)

The inspectors evaluated the following operability determinations and functionality

assessments:

(1) Unit 1 bypass valve number two indicated opening to only 97 percent following Unit 1

main turbine trip on March 26, 2018

(2) Unit common B standby gas treatment system filter heater trip on April 4, 2018

(3) Unit 1 reactor pressure vessel head vent flange indications on April 12, 2018

(4) Unit 1 C low pressure coolant injection valve leakby during operational pressure test on

April 13, 2018

(5) Unit 1 high pressure coolant injection pump leakage from main pump gearbox end

outboard seal on April 17, 2018

71111.18 - Plant Modifications (2 samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Engineering change package 618876, Unit 1 and Unit 2 carbon dioxide system

modification and abandonment

(2) Engineering chage request 1200019, Unit 1 and Unit 2 main turbine control valve and

reactor protection system channel functional test procedure change

71111.19 - Post Maintenance Testing (9 samples)

The inspectors evaluated post maintenance testing for the following maintenance/repair

activities:

(1) Unit common 11-1011 service water supply check valve planned maintenance on

April 2, 2018

(2) Unit 1 A low pressure coolant injection outboard injection valve maintenance on April 3,

2018

(3) Unit common 220 kV transmission lock substation testing and maintenance on April 25,

2018

(4) Unit 1 high pressure coolant injection pump mechanical seal replacement on May 3,

2018

(5) Unit 1 B residual heat removal pump motor inspection and oil change on May 8, 2018

(6) Unit 1 A residual heat removal heat exchanger inlet cross-tie valve breaker cleaning

and inspection on May 16, 2018

(7) Unit 1 A core spray pump room unit cooler cleaning and inspection on June 14, 2018

(8) Unit 1 high pressure coolant injection pump maintenance on April 18, 2018

(9) Unit common 101 safeguards transformer and bus following installation of third off-site

power source on June 11, 2018

71111.20 - Refueling and Other Outage Activities (1 sample)

The inspectors evaluated Unit 1 refueling outage activities from April 1 to April 18, 2018.

The following portions of the inspection procedure were not performed during this period.

(1) Outage Plan

(2) Shutdown

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (2 samples)

(1) ST-2-074-629-1, Unit 1 average power range monitor number 4 functional check on

April 24, 2018

(2) ST-2-088-324-2, Unit 2 remote shutdown system division 2 residual heat removal test

on June 20, 2018

In-Service (4 samples)

(1) ST-6-092-115-1, Unit 1 D11 emergency diesel generator loss of coolant accident/loss

of offsite power test on April 5, 2018

(2) ST-6-092-312-1, Unit 1 D12 emergency diesel generator slow start operability test run

on April 23, 2018

(3) ST-6-051-234-2, Unit 2 D residual heat removal pump, valve, and flow test on May 23,

2018

(4) ST-6-092-314-1, Unit 1 D14 emergency diesel generator slow start operability test run

on June 18, 2018

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (1 sample)

The inspectors evaluated radiological hazards assessments and controls.

Instructions to Workers (1 sample)

The inspectors evaluated worker instructions.

Contamination and Radioactive Material Control (1 sample)

The inspectors evaluated contamination and radioactive material controls.

Radiological Hazards Control and Work Coverage (1 sample)

The inspectors evaluated radiological hazards control and work coverage.

High Radiation Area and Very High Radiation Area Controls (1 sample)

The inspectors evaluated risk-significant high radiation area and very high radiation area

controls.

Radiation Worker Performance and Radiation Protection Technician Proficiency (1 sample)

The inspectors evaluated radiation worker performance and RPT proficiency.

71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls

Implementation of ALARA and Radiological Work Controls (1 sample)

The inspectors reviewed ALARA practices and radiological work controls by reviewing the

following activities:

(1) ALARA Plan 18-009

(2) ALARA Plan 18-011

(3) ALARA Plan 18-025

(4) ALARA Plan 18-035

(5) ALARA Plan 18-036

(6) ALARA Plan 18-043

Radiation Worker Performance (1 sample)

The inspectors evaluated radiation worker and RPT performance.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Engineering Controls (1 sample)

The inspectors evaluated airborne controls and monitoring.

Use of Respiratory Protection Devices (1 sample)

The inspectors evaluated respiratory protection.

Self-Contained Breathing Apparatus for Emergency Use (1 sample)

The inspectors evaluated the Exelon self-contained breathing apparatus program.

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified Exelons performance indicator submittals listed below for the period

April 1, 2017, through March 31, 2018. (4 samples)

(1) Unit 1 and Unit 2 safety system functional failures

(2) Unit 1 and Unit 2 emergency alternating current power

71152 - Problem Identification and Resolution

Semiannual Trend Review (1 sample)

The inspectors reviewed Exelons corrective action program for trends that might be

indicative of a more significant safety issue.

Annual Follow-up of Selected Issues (2 samples)

The inspectors reviewed Exelons implementation of its corrective action program related to

the following issues:

(1) Issue Report (IR) 4024190, Unit 2 main steam line high radiation alarm likely due to

insufficient foreign material exclusion controls

(2) IR 4059470, Unit 1 C core spray pump failed to start on October 5, 2017 due to circuit

breaker failing to close

71153 - Follow-up of Events and Notices of Enforcement Discretion

Licensee Event Reports (1 sample)

The inspectors evaluated the following licensee event report:

(1) Licensee Event Report 05000352/2017-004-00 and 0500352/2017-004-01, Core

Spray Failed to Start Resulting in Condition Prohibited by Technical Specifications.

The circumstances surrounding this licensee event report are documented in report

Section Inspection Results.

Personnel Performance (1 sample)

The inspectors evaluated response during the following non-routine evolution:

(1) Unit 1 unplanned downpower to 30 percent for single loop operation on June 9,

2018, due to Unit 1 B adjustable speed drive coolant leak on a flexible hose fitting

INSPECTION RESULTS

Failure to Conduct Adequate Radiation Surveys and Evaluate Potential Radiological Hazards

Cornerstone

Significance

Cross-Cutting

Aspect

Report

Section

Occupational

Radiation Safety

Green

NCV 05000352/2018002-01

Closed

H.11 - Human

Performance -

Challenge The

Unknown

71124.01

A self-revealing Green finding and associated NCV of 10 CFR 20.1501, Surveys and

Monitoring: General, was identified when Exelon failed to perform adequate loose surface

contamination surveys of the Unit 1 RWCU isolation valve room prior to authorizing work to

hang shadow shielding near the HV-051-1F017A valve, and also during the conduct of the

work itself. Exelon also did not identify very high levels of loose surface contamination on

overhead piping and structures which surrounded the work area. This failure resulted in

unplanned internal radiation exposures to three personnel, including an RPT who was

assigned to monitor the radiological aspects of the work.

Description: The HV-44-1F040 valve (40 valve) in the Unit 1 RWCU isolation valve room

developed a steam leak in June of 2016. The leak became more pronounced over time. This

leak, from a system which is known to contain high levels of radioactive activation products,

resulted in the spread of significant levels of loose surface contamination within the room.

The valve was repaired in September of 2017. The room was not decontaminated at that

time due to very high area dose rates.

During the period of the steam leak, the HV-051-1F017A valve (17 valve) developed

problems in its remote operation with indication of a ground in the direct current system.

Contaminated water from the 40 valve, which is located directly above the 17 valve, affected

the motor actuator for the 17 valve, necessitating a repair. The repair was scheduled for the

next scheduled refueling outage (1R17).

ALARA Plan 18-043 was developed to control the radiological aspects of the repair to the 17

valve motor/actuator and was approved for use on March 15, 2018. The plan identified that

decontamination may be required, that surface contamination levels could approach 400

mrad/hr per 100 centimeters squared (about 20,000,000 dpm per 100 centimeters squared),

and that the room was classified as Alpha Level II. This level of loose surface contamination

is radiologically significant and presents a potential for unplanned internal radiation exposure.

An ALARA evaluation indicated that respiratory protection was not warranted for the planned

work.

A limited decontamination was performed of the travel path from the rooms entrance to the

valve, the immediate area around the valve, and a light fixture (at head level) near the

valve, on March 27, 2018, in support of the planned repairs. A personal air sampler worn

during the decontamination work showed a localized airborne radioactivity of 0.38 derived air

concentration, indicating that the decontamination caused some loose surface contamination

to be suspended in the air. A post-decontamination radiological survey (2018-008466) was

performed to assess the conditions at the valve, and indicated maximum loose surface

contamination levels of 60,000 dpm per 100 centimeters squared on the light fixture.

On March 29, 2018, radiation shielding was installed near the 17 valve as part of the ALARA

plan. The crew consisted of two iron-workers and a senior RPT who was assigned to provide

continuous radiological coverage of the work. Installing the shielding included hanging steel

chains from structures in the overhead areas above the 17 valve, from which the shielding

would then be affixed. These overhead areas had not been decontaminated and were not

included in the loose surface contamination survey two days earlier. Personnel in the room

were not required to wear respiratory protection.

During the work, a hanging light fixture needed to be repositioned several times. When the

fixture was moved, dust was observed to fall from the light fixture. The iron-workers did not

believe that the dust was a concern due to the protective clothing that they were wearing, and

thus did not notify the RPT of the unexpected condition. The RPT, therefore, was not

prompted to obtain additional smear samples of the dusty areas in order to assess the

radiological impact.

The crew attempted to exit the radiologically controlled area after the completion of their work,

and alarmed the personal contamination monitors. Follow-up assessments, including a series

of whole body counts revealed unplanned internal radiation exposures at a small fraction of

the annual occupational exposure limits. IR 04120372 was written to document the event,

which included an event investigation by supervisory staff.

On March 30, 2018, at 1536, an additional radiological survey of the room was performed.

This more comprehensive effort identified very high levels of loose surface contamination on

overhead piping in the room, including areas near the shadow-shielding work area. These

ranged from about 400,000 to 2,000,000 dpm per 100 centimeters-squared.

Corrective Actions: Exelon restricted access to the area, conducted additional radiological

surveys, and conducted an investigation. Exelon entered the issue into their corrective action

program.

Corrective Action Reference: IR 04120372

Performance Assessment:

Performance Deficiency: 10 CFR 20.1003 defines a survey as an evaluation of the

radiological conditions and potential hazards incident to the production, use, transfer, release,

disposal, or presence of radioactive material or other sources of radiation. When appropriate,

such an evaluation includes a physical survey of the location of radioactive material and

measurements or calculations of levels of radiation, or concentrations or quantities of

radioactive material present.

CFR 20.1501 requires that each licensee make or cause to be made surveys that may be

necessary for the licensee to comply with the regulations in Part 20 and that are reasonable

under the circumstances to evaluate the magnitude and extent of radiation levels,

concentrations or quantities of residual radioactivity, and the potential hazards of the radiation

levels and residual radioactivity detected.

CFR 20.1701 specifies that the licensee shall use, to the extent practical, processes or

other engineering controls (e.g., containment, decontamination, or ventilation) to control the

concentration of radioactive material in air.

The post-decontamination radiological survey of the Unit 1 RWCU isolation valve room was

necessary to adequately assess the existing radiological conditions and to subsequently

demonstrate compliance with 10 CFR 20.1701. The March 27, 2018, decontamination effort

and subsequent loose surface contamination survey were focused on the immediate working

area around the 17 valve, but did not consider the need to access the areas in the overhead

above the 17 valve to hang radiation shielding, which was the next major step in the work

process.

When work to hang radiation shielding was authorized by Radiation Protection on March 29,

2018, the supervisor failed to identify that the work would include locations in which there had

been no decontamination and in which loose surface contamination levels had not been

assessed. Those contamination levels exceeded the discontinue work criteria of the ALARA

plan as provided in item 4, contamination level > 200,000 dpm/100cm2 Post Decon. These

levels and the tight confines of the work location would also likely warrant a re-evaluation of

the respiratory protection requriements as indicated in the ALARA plan item 8, Airborne

Radioactivity Mitigation, number 3, RP to evaluate respiratory protection on other activities

based upon radiological conditions and type of work.

During conduct of the work, in-process loose surface contamination surveys were not

performed by the RPT, and the work was not paused to allow a radiological re-assessment of

working conditions, when dust was seen to fall from a light fixture. This was contrary to the

ALARA plan, which also included a discontinue work criteria of when radiological conditions

are not as expected.

In addition, the RPT allowed a light fixture to be repositioned several times during the work,

which was not within the authorized scope of work as provided in the pre-job briefing and was

contrary to the ALARA plan, item 16, Contingency Plans, which states Changes in work

scope: notify RPS and Rad Engineering prior to deviating form the original plan/work scope.

These failures were within Exelons ability to foresee and correct, and should have been

prevented, and therefore are performance deficiencies. The deficiencies represent multiple

failed radiation protection barriers.

Screening: This finding is more than minor because it is associated with the Program &

Process attribute of the Occupational Radiation Safety cornerstone and affected the

cornerstone objective to ensure the adequate protection of the worker health and safety from

exposure to radiation from radioactive material during routine civilian nuclear reactor

operation. Specifically, loose surface contamination levels were not adequately assessed on

multiple occasions, discontinue work criteria were exceeded, and work outside of the planned

scope was allowed. Thus multiple radiation safety barriers were defeated as described in

IMC 0612, Section 6 Health Physics, General Screening Criteria.

Significance: Using IMC 0609.04, Initial Characterization of Findings, issued October 7,

2016, and IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination

Process, issued August 19, 2008, the inspection finding was not related to ALARA practices

(Step 1), did not result in an overexposure (Step 5), did not represent a substantial potential

for overexposure (Step 11), and did not compromise Exelons ability to assess dose (Step

14). As a result, this finding was determined to be of very low safety significance (Green).

Cross-Cutting Aspect: This finding has a cross-cutting aspect in the area of Human

Performance, Challenge the Unknown, in that Exelon did not ensure that individuals stop

when faced with uncertain conditions and ensure risks are evaluated and managed before

proceeding. Specifically, the RPTs involved in assessing radiological conditions and

controlling work (and their supervisor) did not adequately evaluate the potential for very high

levels of loose surface contamination in the RWCU isolation valve room following a significant

leak and prior to working in overhead areas, and did not reassess conditions when dust fell

from a light fixture. [H.11]

Enforcement:

Violation: 10 CFR 20.1003 defines a survey. 10 CFR 20.1501(a)(1) requires that each

licensee make or cause to be made surveys that may be necessary for the licensee to comply

with the regulations of Part 20.

Contrary to the above, on March 27 and March 29, 2018, Exelon did not perform adequate

loose surface contamination surveys in the Unit 1 RWCU isolation valve room following a

decontamination effort (and prior to authorizing work to hang radiation shielding), and

following the observation of dust falling from a light fixture in the immediate work area. These

surveys were necessary to demonstrate compliance with 10 CFR 20.1701, ALARA Plan 18-

043, and its associated respiratory protection ALARA evaluation. As a result, three personnel

received unplanned internal radiation exposures.

Disposition: This violation is being treated as an NCV, consistent with Section 2.3.2 of the

NRC Enforcement Policy.

Unit 1 Core Spray Pump Failed to Start Resulting in Condition Prohibited by Technical

Specifications

Cornerstone

Severity

Cross-Cutting Aspect

Report

Section

Not Applicable

Severity Level IV

NCV 05000352/2018002-02

Closed

Not Applicable

71153

The inspectors identified a Severity Level IV NCV of Unit 1 Technical Specification 3.5.1

because one core spray subsystem was inoperable from July 17, 2017, until October 5, 2017.

Specifically, the Unit 1 C core spray pump did not start upon demand during testing and was

declared inoperable because the pumps associated circuit breaker closing charging springs

were not charged.

Description: On October 5, 2017, the Unit 1 C core spray pump failed to start during

surveillance testing due to the associated circuit breaker failing to close. An initial

investigation identified that the switch contact inside the circuit breaker control device which

energizes the breakers closing springs charging motor became dislodged. With the switch

contact unable to maintain the circuit, the charging motor did not energize long enough to fully

charge the closing springs during the breakers previous closing operation. This condition

existed since the last time the Unit 1 C core spray pump was in service on July 17, 2017,

until the discovery on October 5, 2017. This issue constituted a violation of Technical Specification 3.5.1, Emergency Core Cooling System - Operating, because the pump was

out-of-service for greater than the allowed outage time of 7 days. This issue was reported to

the NRC in Licensee Event Report 05000352/2017-004-00, dated December 4, 2017, and

supplemented by Licensee Event Report 05000352/2017-004-01, dated March 13, 2018.

Failure analysis of the control device identified that the cause of the switch contact becoming

dislodged was due to arcing and welding of the switch contact eventually resulting in

displacement of the switch contact. The most probable cause of the initial degradation that

eventually led to arcing and welding was due to undervoltage testing of the closing springs

charging motor. This testing was performed during periodic circuit breaker inspections and

overhauls. The test subjects the control device switch contacts and charging springs motor to

lower than normal voltage which results in higher than normal current. The circuit breaker

was last overhauled and subjected to undervoltage testing in June 2014. The circuit breaker

was operated a minimum of 9 times between June 2014 and the discovery of the failure in

October 2017. There was no evidence of degraded performance in the breaker closing

springs charging motor circuit prior to failure. The inspectors noted that there were no

previous circuit breaker control device failures at Limerick due to switch contact issues. Also,

a review of industry and vendor operating experience did not reveal any similar failures of

switch contacts displacing due to arcing and welding.

Corrective Actions: Immediate corrective action was taken to replace the associated 4 kV

circuit breaker control device and return the Unit 1 C core spray pump to an operable status.

An extent-of-condition review was performed to verify that the charging spring indicators for

the sites 2.3 kV, 4 kV, and 13.2 kV switchgear circuit breakers showed that the charging

springs were charged. Exelon revised maintenance procedures to conduct the charging

motor undervoltage test prior to disassembly of the control device during circuit breaker

overhauls so that the associated electrical contacts on the switch will be inspected for

damage/overheating following the test.

Corrective Action Reference: IR 4059470

Performance Assessment: The inspectors determined that the failure of the Unit 1 C core

spray pump to start on October 5, 2017, was not within Exelons ability to foresee and

prevent. As a result, no performance deficiency was identified. Therefore, this violation will

not be considered in the assessment process or the NRCs Action Matrix.

Enforcement: This issue is considered within the traditional enforcement process because

there was no performance deficiency associated with the violation of NRC requirements and

the Reactor Oversight Process significance determination process does not specifically

consider violations without performance deficiencies in its assessment of licensee

performance. Therefore, it is necessary to address this violation using traditional

enforcement to adequately deter non-compliance.

Violation: Technical Specification 3.5.1, Emergency Core Cooling System - Operating,

requires in part, that emergency core cooling systems shall be operable with the core spray

system consisting of two subsystems with each subsystem comprised of two operable core

spray pumps and an OPERABLE flow path capable of taking suction from the suppression

chamber and transferring the water through the spray sparger to the reactor vessel. If there

is one core spray subsystem inoperable, provided that at least two low pressure coolant

injection subsystems are operable, Technical Specification 3.5.1 limiting condition for

operation action statement requires restoring the inoperable core spray subsystem to

operable status within 7 days or be in at least Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in

Cold Shutdown within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Contrary to the above, from July 17, 2017, until October 5, 2017, one Unit 1 core spray

subsystem was inoperable, and Exelon did not restore the core spray subsystem to operable

status within 7 days, and did not place Unit 1 in at least Hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or in

Cold Shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Specifically, the Unit 1 C core spray pump did not start

upon demand during testing and was declared inoperable because the pumps associated

circuit breaker closing charging springs were not charged.

Severity/Significance: The NRC Enforcement Policy, Section 2.2.1 states, in part, that,

whenever possible, the NRC uses risk information in assessing the safety significance of

violations. The inspectors evaluated the issue using IMC 0609.04, Initial Characterization of

Finding, and IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions.

The inspectors determined that the issue required a detailed risk evaluation because the

failure of the Unit 1 C core spray pump to start on October 5, 2017, represented an actual

loss of function of at least a single train for greater than its technical specification allowed

outage time. A Region I senior reactor analyst completed the detailed risk evaluation and

estimated the increase in core damage frequency associated with this issue to be below E-

7/year or of very low safety significance (Green). To perform the detailed risk evaluation to

gather insights on safety significance, the senior reactor analyst used the Systems Analysis

Programs for Hands-On Evaluation (SAPHIRE) Revision 8.1.6, Standardized Plant Analysis

Risk Model, version 8.50 for Limerick Generating Station Unit 1. The inspectors determined

that the issue is of very low safety significance and concluded that the violation would be best

characterized as Severity Level IV.

Enforcement Action: The violation is being treated as an NCV consistent with Section 2.3.2

of the Enforcement Policy.

Observations:

71152 Semiannual Trend

Review

The inspectors reviewed and assessed two adverse trends in human performance and

equipment reliability, last discussed in the 2017 fourth quarter integrated inspection report

(ADAMS Accession No. ML18032A569). The inspectors reviewed Exelons continued

actions, issues, and indicators related to improving human performance and determined that

Exelons efforts were sufficiently effective and sustained to not warrant continued focus by the

inspectors.

Regarding equipment reliability, the inspectors noted a number of additional examples

evaluated during the period that impacted operations: diesel generator elevated combustion

air temperature, pump seal failures, diesel generator auto-start logic circuit issue, isolation

valve failure, control enclosure chiller trips, and adjustable speed drive coolant leakage. The

inspectors documented two findings in the 2018 first quarter integrated inspection report

(ADAMS Accession No. ML18131A015) related to equipment reliability. Further inspection

will be performed during subsequent licensee event report reviews and/or during other

baseline inspection samples focusing on equipment reliability. Otherwise, during this

inspection, the inspectors did not identify a new performance deficiency or violation and/or

determined that the issues were of minor safety significance. The inspectors noted a related

issue identified by Exelon regarding unplanned entries into technical specification limiting

conditions for operation and discussed the trend with Exelon personnel. The inspectors

concluded that a continued inspection focus on equipment reliability is warranted and

discussed Exelons continued actions to improve equipment reliability which included

challenging repair scheduling for critical components, resolving long-standing and/or repetitive

equipment problems, and focusing efforts to improve reliability of systems critical to station

safety and reliability.

Based on the overall results of the semi-annual trend review, the inspectors did not identify

additional trends not recognized by Exelon and determined that Exelon was appropriately

identifying and entering issues into the corrective action program, adequately evaluating the

issues, and properly identifying adverse trends before they became more safety significant

problems.

Observations:

IR 4024190

71152 Annual Follow-up of

Selected Issues

The inspectors reviewed the IR which documented Exelons corrective actions to address the

Unit 2 main steam line high radiation alarm that occurred on June 21, 2018. Because of a

lack of an apparent cause, Exelons initial evaluation identified and eliminated a number of

likely causes, but did include the possibility of the introduction of foreign material as a

potential cause. Their evaluation also considered the extent of condition and cause, potential

generic implications and common cause, and previous occurrences. The corrective actions

were classified and prioritized in accordance with Exelons corrective action program

guidance, and the inspectors concluded that Exelons corrective actions were implemented

commensurate with the safety impact of the cause, and were appropriately focused to correct

the problem. Exelon implemented enhanced foreign material exclusion controls during the

current refueling outage and the inspectors observed their implementation during field

walkdowns. No additional issues were identified.

Observations:

IR 4059470

71152 Annual Follow-up

of Selected Issues

The inspectors reviewed IR 4059470 which documented Exelons actions regarding the Unit 1

C core spray pump failing to start during surveillance testing on October 5, 2017, due to the

pumps circuit breaker failing to close. The description of the event, corrective actions, and

enforcement aspects of this event are documented in the finding above.

The inspectors identified that although the failure of the circuit breaker to close was classified

as a critical component failure by the station ownership committee, the critical component

clock was not reset as expected by ER-AA-1200, Critical Component Failure Clock. The

inspectors noted that the critical component clock is used only as an equipment reliability

indicator and site awareness tool and, therefore, not resetting the clock for the event was

considered a minor issue.

Exelon performed a work group evaluation for the issue. This is the lowest level of review

specified by corrective action program procedures. The corrective action program procedural

guidance for events involving a critical component failure or requiring the submittal of a

licensee event report to the NRC recommended the performance of at least a corrective

action program evaluation which is a higher level of investigation than a work group

evaluation. Work group evaluations are allowed if the cause of the failure is known and if

proper approvals are obtained. The initial site investigation determined the failure to be due to

a deformed control device switch contact which led to the switch contact being dislodged

inside the control device. Based on the cause of the failure presumed to be determined in the

initial investigation, proper approvals were obtained to perform a work group evaluation

versus a corrective action program evaluation. The control device was sent to a failure

analysis laboratory for review. The laboratory analysis determined that the cause of the

failure to be associated with welding of the switch contacts eventually resulting in the switch

displacing. The final work group evaluation concluded that the most probable cause of the

initial degradation that eventually led to arcing and welding was due to undervoltage testing of

the closing springs charging motor. The undervoltage testing subjects the switch contacts to

higher than normal current which Exelon believed resulted in the initial degradation of the

switch contact.

The inspectors questioned why the investigation class was not upgraded to a corrective action

program evaluation when the laboratory failure analysis identified a cause of the failure that

was different than the initial investigation of the work group evaluation. In addition, the final

work group evaluation only determined undervoltage testing was the most probable cause of

the initial degradation which led to the failure. Because the cause could not be definitively

determined, Exelon should have performed a corrective action program evaluation. However,

the inspectors concluded that the actions ultimately taken by Exelon were adequate and not

upgrading the investigation class after receiving the laboratory failure analysis was a minor

issue. This was based on the revisions and additional actions added to the work group

evaluation (e.g., performance of a risk assessment) following two reviews of IR 4059470 by

the management review committee and one review by the plant operations review committee.

The inspectors observed an action taken outside of the corrective action process that should

have been established as an action in IR 4059470. Following the failure, operations

management issued Operations Standing Order 17-14, Operations Expectations for 4 Kilo-

Volt Equipment Starts, to perform checks to observe closing spring indicators on 4 kV circuit

breakers following breaker operation. The standing order was not added as an action item in

IR 4059470 even though it was issued as a compensatory measure for the issue. The

standing order was intended to stay in place until applicable operations procedures were

revised to include direction to perform these inspections routinely following breaker operation.

Based on further review of the issue, the action to revise the operations procedures was

canceled in IR 4059470 on March 1, 2018. The inspectors noted that as of May 16, 2018,

Standing Order 17-14 was still active and operations management was unaware that the

action item to revise the procedures had been canceled. The inspectors concluded that

issuing the standing order outside of the corrective action program process was a minor issue

because there were no potential adverse consequences as a result of continuing to perform

the checks.

Exelon acknowledged the inspectors observations discussed above and entered the issues

into the corrective action program as IR 4140088.

EXIT MEETINGS AND DEBRIEFS

Unless otherwise noted, no proprietary information was retained by the inspectors or

documented in this report.

On July 23, 2018, the inspectors presented the inspection results to Mr. Frank Sturniolo,

Plant Manager, and other members of the Exelon staff.

THIRD PARTY REVIEWS

Inspectors reviewed Institute of Nuclear Power Operations reports that were issued during the

inspection period.

DOCUMENTS REVIEWED

71111.04

Procedures

0S78.1.D, Valve Alignment for Normal Operation of Standby Gas Treatment Room Ventilation,

Revision 5

1S50.1.A (COL), Equipment Alignment of the ADS and Main Steam Relief Valves for Normal

Operation, Revision 7

1S76.1.C, Equipment Alignment of Standby Gas Treatment System Reactor Enclosure Air

Recirculation System for Automatic Initiation, Revision 12

1S92.1.N (COL-1), Equipment Alignment for 1A Diesel Generator Operation, Revision 34

1S92.1.N (COL-4), Equipment Alignment for 1D Diesel Generator Operation, Revision 31

Condition Reports

22755

Work Orders

4768620-02

Drawings

E-484, Reactor Enclosure SGTS Filter Electrical Heaters Common, Revision 21

M-0078, Control Enclosure PI&D, Sheet 4, Revision 22

71111.04S

Procedures

1S49.1.A (COL), Valve Alignment to Assure Availability of the RCIC System, Revision 17

MA-716-230-1001, Oil Analysis Interpretation Guideline, Revision 20

MA-AA-716-230, Predictive Maintenance Program, Revision 11

S52.1.C, Operation of Safeguard Piping Fill System, Revision 11

ST-6-049-230-1, RCIC Pump, Valve and Flow Test, Revision 90

ST-6-052-760-1, Safeguard Piping Fill Quarterly Valve Test, Revision 20

Condition Reports

2653613

2656660

2697980

3956044

4078992

4086156

71111.05

Procedures

CC-AA-211, Fire Protection Program, Revision 8

F-A-336, Pre-Fire Plan, Fire Area 2 13.2KV Switchgear Room 336 (Elev. 217), Revision 15

F-A-361, Pre-Fire Plan, Fire Area 6, Unit 2, Class 1E Battery Room 361 (Elev. 217), Revision 7

F-D-315A, D21 Diesel Generator and Fuel Oil - Lube Oil Tank Room, Rooms 315A and 316A

(El 217), Revision 9

F-R-109, Pre-Fire Plan, Unit 1 HPCI Pump Room 109, Revision 10

F-R-110, Pre-Fire Plan, Unit 1 Core Spray Pump Room A, Revision 8

F-R-173, Unit 2, A and C RHR Heat Exchanger and Pump Rooms 173 and 280 (EL 177 and

201), Revision 6

F-R-174, Unit 2, B and D RHR Heat Exchanger and Pump Rooms 174 and 281 (EL 177 and

201), Revision 6

OP-AA-201-009, Control of Transient Combustible Material, Revision 20

OP-LG-201-008, Limerick Generating Station Fire Protection (F) Pre-Fire Plan Strategies,

Revision 5

71111.05A

Procedures

F-R-284, Pre-Fire-Plan, Unit 2 Reactor Enclosure Cooling Water Heat Exchanger Area Rooms

284 and 286 (EL 201), Revision 7

OP-AA-201-003, Fire Drill Performance, Revision 16

ST-6-022-551-0, Fire Drill, Revision 13

Condition Reports:

4084529

Miscellaneous

Fire Drill Scenario No.: F-R-284, Unit 2, Reactor Enclosure Cooling Water Heat Exchanger Area

Rooms 284 and 286 (EL 201), June 12, 2018

OP-AA-201-003 Attachment 1, Fire Drill Record, completed June, 12 2018

71111.07

Procedures

M-200-037, Q Listed HVAC Heating & Cooling Coil Clean/Flush, Revision 10

RP-LG-350-1006, Hydrolasing, Revision 1

RT-2-011-394-1, 1EV211 Core Spray Room Cooler Air to Water Heat Transfer Test,

Revision 10

Work Orders

4309052

71111.08

Procedures

100-RT-001, Radiographic Examination in Accordance with ASME Section V, Article 2,

Revision 13

GEH-PDI-UT-1, PDI Generic Procedure for the Ultrasonic Examination of Ferritic Welds,

Revision 12

GEH-UT-311, Procedure for Manual Ultrasonic Examination of Nozzle Inner Radius, Bore and

Selected Nozzle to Vessel Regions, Revision 19

WPS 1-1-GTSM-PWHT, Welding Procedure Specification for P1 to P1 Manual GTAW and

SMAW Welds, Revision 2

Condition Reports

22585

Work Orders

4179424

Miscellaneous

ER-LG-330-1001, ISI Program Plan Fourth Ten-Year Inservice Inspection Interval, Revision 15

UT-18-017, UT Examination Report for APE-1MS-LD N3D (Summary No. LIM-1-602760),

dated April 4, 2018

VT Examination Report for Suppression Pool Internal Surfaces, dated April 4, 2018

UT-18-011, UT Examination Report for FWA-039 (Summary No. LIM-1-233390), dated

April 4, 2018

UT-18-012, UT Examination Report for FWA-040 (Summary No. LIM-1-233400), dated

April 4, 2018

RT Examination Report for FW-56 on Line DBB-105-1, dated April 2, 2018

RT Examination Report for FW-58 on Line DBB-105-1, dated April 2, 2018

71111.11

Procedures

GP-2, Normal Plant Startup, Revision 172

71111.12

Procedures

ER-AA-310-1002, Maintenance Rule Functions - Safety Significance Classification, Revision 3

ER-AA-310-1003, Maintenance Rule - Performance Criteria Selection, Revision 5

ER-AA-310-1004, Maintenance Rule - Performance Monitoring, Revision 14

ER-AA-310-1005, Maintenance Rule - Dispositioning Between (a)(1) and (a)(2), Revision 7

M-056-001, Replacement of Mechanical Seals on the High Pressure Coolant Injection Main

Pump - P204, Revision 1

OP-LG-108-117-1000, Limerick Protected Equipment Program, Revision 6

SM-AA-300-1001, Procurement Engineering Process and Responsibilities, Revision 23

Condition Reports

2652839

2653173

2681816

2682469

2683662

2686466

2686469

2690284

2695292

2697334

2704684

2705628

2713214

2718916

2718965

2718986

2719515

25822

27759

3948230

3951442

3952680

3953586

3983220

4001894

4002391

4015662

23699

27144

27674

4136634

Work Orders

4308237

4773946

Miscellaneous

A/R A0733443, O-ring, F/Basket Strainer on Diesel Fuel Oil system, 4/7/93

Eval: 114-38109, EDG Gasket Material - Evaluate Alternate, 1/25/13

INSP NO: 0101903

PEEVAL 211748, Commercial Grade Dedication Plan for KTN-R-10 Fuse, Revision 1

Ref. No.: 114-38070, Gasket, Crankcase, 7/27/89

Ref. No.: 11592850, Gaskets, Manifolds, 5/16/90

71111.13

Procedures

ER-AA-600-1042, On-Line Risk Management, Revision 10

OP-AA-108-117, Protected Equipment Program, Revision 5

OP-LG-108-117-1000, Limerick Protected Equipment Program, Revision 6

ST-2-072-107-1, Div II Reactor Enclosure BOP Isolation LSF/SAA and RERS, SGTS Test,

Revision 16

ST-6-092-115-1, D11 Diesel Generator 4KV SFGD Loss of Power LSF/SAA and Outage

Testing, Revision 25

WC-AA-101-1006, On-Line Risk Management and Assessment, Revision 2

Miscellaneous

Operations Protected Equipment Log 4/5/18

71111.15

Procedures

NRC IN 2017-003, Anchor Darling Double Disk Gate Valve Wedge Pin and Stem-Disc

OT-102, Reactor High Pressure, Revision 27

S57.1.C, Drywell Purge Fan Operation, Revision 8

ST-6-001-761-1, Main Turbine Bypass Valve Exercising, Revision 30

Condition Reports

0412345

1175540

2590938

4119016

22755

26091

27674

Work Orders

4768620

Drawings

E-484, Reactor Enclosure SGTS Filter Electrical Heaters Common, Revision 21

M-0076, Reactor Enclosure and Refueling Area HVAC, Sheet 6, Revision 33

M-0078, Control Enclosure PI&D, Sheet 4, Revision 22

71111.18

Procedures

8031-M-0022, Sheet 6, Fire Protection (Unit 1, Unit 2 and Common), Revision 24

8031-M-0028, Sheet 1, Generator H2 Cooling and CO2 Purge (Unit 1 and Common), Revision

8031-M-0028, Sheet 2, Generator H2 Cooling and CO2 Purge (Unit 2), Revision 23

CC-AA-211, Fire Protection Program, Revision 8

L-S-51, Fire Protection System, Revision 7

LS-AA-104, Exelon 50.59 Review Process, Revision 10

LS-AA-104-1001, 50.59 Review Coversheet Form, Revision 4

PPC-LGS-1, Preparedness, Prevention and Contingency Plan for Limerick Generating Station,

Revision 3

ST-6-001-766-1, Main Turbine Control Valve Exercise & RPS Channel Functional Test, OPCON

4, 5, Revision 19, 20 and 21

Condition Reports

29080

26850

Miscellaneous

EC 618876, LGS U1 and U2 Carbon Dioxide System Modification and Abandonment,

Revision 2

LG-2017S029, 50.59 Screening for LGS U1 and U2 Carbon Dioxide System Modification and

Abandonment, Revision 0

ECR 1200019 and ECR 1200024, Electro-Hydraulic Control (EHC) System Upgrades,

Revision 3

71111.19

Procedures

M-056-001, Replacement of Mechanical Seals on the High Pressure Coolant Injection Main

Pump - P204, Revision 0

M-056-004, Overhaul of the High Pressure Coolant Injection Main Pump - P204, Revision 3

M-200-037, Q Listed HVAC Heating & Cooling Coil Clean/Flush, Revision 10

RP-LG-350-1006, Hydrolasing, Revision 1

RT-6-051-206-1, 1C RHR-SDC Crosstie Valve Test, Revision 5

S12.1.A, RHR Service Water System Dual Loop Startup Hard Card, Revision 2

S12.2.A, Shutdown of RHR Service Water Pumps and System, Revision 35

S51.5.A, Flushing of the RHR System Heat Exchanger Tube Side with Demineralized Water,

Revision 25

S51.8.A Appendix 1, Placing RHR SP Cooling in Service During a Plant Event, Revision 2

S55.1.A, Normal HPCI Line-up for Automatic Operation, Revision 37

S55.1.D Appendix 1, Starting HPCI for Pressure Control During a Plant Event, Revision 0

S55.3.A, HPCI Fill and Vent, Revision 36

S55.9.A, Routine Inspection of HPCI System, Revision 43

S93.0.C, 480 VAC Safeguard MCC Compartment Installation, Revision 35

ST-6-011-231-0, A Loop ESW Pump, Valve & Flow Test, Revision 75

ST-6-051-202-1, A LOOP RHR Cold Shutdown Valve Test, Revision 22

ST-6-051-232-1, B RHR Pump, Valve, and Flow Test, Revision 87

ST-6-055-230-1, HPCI Pump, Valve and Flow Test, Revision 86

ST-6-107-594-1, Weekly Surveillance Log, Revision 84

ST-6-107-594-2, Weekly Surveillance Log, Revision 73

Condition Reports

27674

4145984

4146145

Work Orders

239418

240873

267351

4309052

4309629

4313481

4614983

4710009

28774

4747597

4758920

4763312

4763312

4767181

4773946

4773946

Drawings

06KPX883678, Sheet 1, HPCI Pump, Revision D

71111.22

Procedures

ST-2-074-629-1, Functional Check of Average Power Range Monitor 4 (APRM 4), Revision 17

ST-2-088-324-2, Remote Shutdown System Div 2 RHR Operability Test, Revision 7

ST-6-051-234-2, D RHR Pump, Valve and Flow Test, Revision 58

ST-6-092-115-1, D11 Diesel Generator 4KV SFGD Loss of Power LSF/SAA and Outage

Testing, Revision 25

ST-6-092-312-1, D12 Diesel Generator Slow Start Operability Test Run, Revision 103

ST-6-092-314-1, D14 Diesel Generator Slow Start Operability Test Run, Revision 104

Condition Reports

4149666

Work Order 266199

24924

25189

4761182

25189

Drawings

M-071-00048 Sheet 1, Schematic Engine Control D11 Diesel Generator, Revision 30

71124.01

Procedures

HU-AA-101, Human Performance Tools and Verification Practices, Revision 9

HU-AA-1211, Pre-Job Briefings, Revision 11

NISP-RP-002, Radiation and Contamination Surveys, Revision 0

NISP-RP-003, Radiological Air Sampling, Revision 0

RP-AA-300, Radiological Survey Program, Revision 16

RP-AA-301, Radiological Air Sampling Program, Revision 11

RP-AA-401, Operational ALARA Planning and Controls, Revision 23

RP-AA-441, TEDE ALARA Evaluation, Revision 9

Miscellaneous

ALARA Briefing / Attendance Form, RP-AA-401 Attachment 3, for ALARA Plan 18-043, dated

3/27/2018 at 1030 and 3/28/2018 at 2000

ALARA Plan 18-043

AR04120372

Radiation Work Permit LG-0-18-00625, Revision 0

Radiological Survey 2018-003677

Radiological Survey 2018-008466

Radiological Survey 2018-008547

Radiological Survey 2018-008552

Radiological Survey 2018-008594

Radiological Survey 2018-008690

TEDE ALARA Screening and Evaluation for plan 18-043

71151

Procedures

LS-AA-2200, Emergency AC Power Function, Attachment 5 data (April 2017 through April 2018)

71152

Procedures

ER-AA-1200, Critical Component Failure Clock, Revision 12

M-200-002, 2.3 KV and 4 KV Power Circuit Breaker Overhaul, Revision 10

M-200-011, 13.2 KY and 2.3 KV Switchgear Maintenance, Revision 4

MA-AA-716-004, Revision 15

MA-AA-716-008, Foreign Material Exclusion Program, Revision 13

PI-AA-120, Issue Identification and Screening Process, Revision 8

PI-AA-125, Corrective Action Program Procedure, Revision 8

PI-AA-125-1003, Corrective Action Program Evaluation Manual, Revision 4

Condition Reports

22252

24190

4118994

4119397

21951

22429

22755

22806

23146

23855

24233

26850

27674

27870

4133876

4133876

4135378

4140085

4141279

4141283

Miscellaneous

ECAPE 4024190-14

Equipment Operator Initial Training, Module LEOT0229, AC Circuit Breakers, Revision 007

LIM-0-2018-0099, 4 Kilo-Volt Breaker Springs Failure Risk Assessment, dated 04/25/2018

LIM-60226, Failure Analysis of a Contact Assembly, dated 12/18/2017

Non-Conformance Report 94-00009, Calculation LE-069 Inadequate Voltage at 4 KV

Switchgear Spring Charging Motor, dated 2/19/1994

Operations Standing Order 17-14, Operations Expectations for 4 Kilo-Volt Equipment Starts,

dated 12/20/2017

71153

Procedures

GP-5 Appendix 2, Rx Maneuvering Without Shutdown, Revision 102

Condition Reports

4145616

4145647

4145655

4145666

4145776

4146236

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