IR 05000352/2014002

IR 05000352-14-002, 05000353-14-002; 01/01/2014 - 03/31/2014; Limerick Generating Station (Lgs), Units 1 and 2; Radioactive Gaseous and Liquid Effluent Treatment

ML14127A496
Person / Time
Site:	Limerick
Issue date:	05/07/2014
From:	Fred Bower Reactor Projects Region 1 Branch 4
To:	Pacilio M Exelon Generation Co, Exelon Nuclear
Bower F
References
IR 14-002
Download: ML14127A496 (42)

Text

May 7, 2014

SUBJECT:

LIMERICK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000352/2014002 AND 05000353/2014002

Dear Mr. Pacilio:

On March 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Limerick Generating Station (LGS), Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on April 16, 2014, with Mr. T Dougherty, Site Vice President, and other members of your staff.

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

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

This report documents one violation of NRC requirements which was determined to be of very low safety significance (Green). However, because of the very low safety significance, and because the issue is entered into your corrective action program, the NRC is treating this finding as non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest the non-cited violations in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at LGS. In addition, if you disagree with the cross-cutting aspect assigned to the finding, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at LGS.

Additionally, as we informed you in the most recent NRC integrated inspection report, cross-cutting aspects identified in the last six months of 2013 using the previous terminology were being converted in accordance with the cross-reference in Inspection Manual Chapter (IMC) 0310. Section 4OA5 of the enclosed report documents the conversion of these cross-cutting aspects which will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review. If you disagree with the cross cutting aspect assigned, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at LGS.

In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Fred L. Bower, III, Chief Reactor Projects Branch 4 Division of Reactor Projects

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

Enclosure:

Inspection Report 05000352/2014002 and 05000353/2014002

w/ Attachment: Supplementary Information

REGION I==

Docket Nos.

50-352 and 50-353

License Nos.

NPF-39 and NPF-85

Report Nos.

05000352/2014002 and 05000353/2014002

Licensee:

Exelon Generation Company, LLC

Facility:

Limerick Generating Station, Units 1 & 2

Location:

Sanatoga, PA 19464

Dates:

January 1, 2014 through March 31, 2014

Inspectors:

E. DiPaolo, Senior Resident Inspector

J. Ayala, Resident Inspector (Acting)

R. Montgomery, Resident Inspector

R. Nimitz, Senior Health Physicist

R. Fuhrmeister, Senior Reactor Inspector

J. Furia, Senior Health Physicist

P. Kaufman, Senior Reactor Inspector

E. Burket, Emergency Preparedness Inspector

Approved By:

Fred L. Bower, III, Chief

Reactor Projects Branch 4

Division of Reactor Projects

Enclosure

SUMMARY

IR 05000352/2014002, 05000353/2014002; 01/01/2014 - 03/31/2014; Limerick Generating

Station (LGS), Units 1 and 2; Radioactive Gaseous and Liquid Effluent Treatment.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified one finding of very low safety significance (Green), which was a non-cited violation (NCV). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Components Within Cross-Cutting Areas, dated December 19, 2013. All violations of Nuclear Regulatory Commission (NRC) requirements were dispositioned in accordance with the NRCs Enforcement Policy, dated January 28, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NRC Technical Report Designation (NUREG)-1649, Reactor Oversight Process, Revision 5.

Cornerstone: Public Radiation Safety

Green: The NRC identified a non-cited violation of Technical Specification (TS) 6.14, Offsite Dose Calculation Manual (ODCM), for failure to evaluate and provide sufficient information to support a change to the ODCM. Specifically, LGS revised the ODCM to allow the residual heat removal service water (RHRSW) monitors to be non-functional due to loss of flow for a period of up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> before they were required to be declared inoperable and did not provide sufficient information to support the change including a determination that the change would maintain the level of radioactive effluent release control. LGS entered the issue into their corrective action program (CAP) as Issue Report (IR) 1639697 and revised the applicable alarm response card (ARC-MRC-010 E4) to declare the monitor inoperable under similar conditions. A dose calculation was also completed that indicated no significant public dose consequences associated with the monitors inoperable status.

The failure to evaluate and provide sufficient information to support a change to the ODCM, in accordance with the requirements of TS 6.14 is a performance deficiency. This performance deficiency is more than minor because it affected the Public Radiation Safety Cornerstone attribute of Plant Facilities/Equipment and Instrumentation. Using Inspection Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination Process, dated February 12, 2008, the inspectors determined this to be a finding of very low safety significance (Green) because: the finding was in the effluent release program; was not a substantial failure to implement the effluent program; and the dose to the public did not exceed the 10 Code of Federal Regulations (CFR) Part 50 Appendix I criterion or 10 CFR 20.1301(e) limits. This finding was associated with a cross cutting aspect of Human Performance, Design Margins.

Specifically, LGS did not conduct a sufficiently rigorous review of a change in the operability status of a safety-related radiation monitor (RHRSW radiation monitors) to ensure that the change would not adversely impact the level of radioactive effluent release control (H.6).

(Section 2RS6)

Other Findings

None.

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at 100 percent power. On January 11, operators reduced power to approximately 70 percent to facilitate a control rod pattern adjustment and to perform fuel channel distortion testing. Operators returned the unit to 100 percent power on January 12.

On February 20, operators reduced power to approximately 95 percent power to remove the 6B feedwater heater from service and entered end-of-cycle coastdown and reduced feedwater temperature operations in advance of the Unit 1 refueling outage. On March 24, with initial power at 98 percent due to coastdown, operators conducted a rapid plant shutdown and manually scrammed the reactor per procedure following the closure of the main turbine intercept valves due to a failure in the turbine electro-hydraulic control system. Unit 1 entered refueling outage (1R15) earlier than originally scheduled to conduct main low pressure turbine blade inspections. Operational Condition (OPCON) 4 (Cold Shutdown) was entered on March 5. On March 15, Unit 1 entered OPCON 5 (Refueling). At the end of the inspection period Unit 1 was in OPCON 5 (Refueling) with the reactor cavity flooded.

Unit 2 began the inspection period at 100 percent power. On January 17, operators reduced power to approximately 82% due to the isolation of the 3C, 4C, 5C, and 6C feedwater heaters from equipment issues associated with feedwater level controls on the 3C feedwater heater. Operators returned the unit to 100 percent power later that day. Power was reduced to approximately 83 percent on February 1 to facilitate planned main steam and main turbine valve testing, control rod scram time testing, and a control rod pattern adjustment. Operators returned power to 100 percent on February 2. Unit 2 remained at or near 100 percent power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Site Imminent Weather Conditions

a. Inspection Scope

On January 21, 2014, the inspectors reviewed LGS staffs preparations in advance of and during a Winter Storm Warning issued by the National Weather Service for Montgomery County, Pennsylvania. The inspectors reviewed LGSs preparations for the adverse weather to verify compliance with weather preparation procedures including operator actions to maintain readiness of essential systems before the onset of adverse weather. The inspectors also verified that preparations were made to assure adequate staffing of required on-shift personnel. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified.

==1R04 Equipment Alignment

Partial System Walkdowns (71111.04 - 3 samples)

a. Inspection Scope

==

The inspectors performed partial walkdowns of the following systems:

Unit 1 A and B standby liquid control pumps while C pump was out-of-service for testing on February 18, 2014

Motor-driven and diesel-driven fire pumps during removal of one water source (Unit 1 cooling tower basin) from service on March 18, 2014

Spray pond pump house alignment for the protected B and D RHRSW and emergency service water (ESW) pumps when loop components (i.e., A and C RHRSW and ESW pump) were out-of-service for maintenance on March 25, 2014

The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), TSs, work orders, issue reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether LGS staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

==1R05 Fire Protection

Resident Inspector Quarterly Walkdowns (71111.05Q - 7 samples)

==

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that LGS controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

Unit 2 Class 1E Battery Room 426 and 454, Fire Area 10 on February 11, 2014

Unit 2 High Pressure Coolant Injection (HPCI) Pump Rooms, Fire Area 57 on February 11, 2014 Unit 2 B and D Residual Heat Removal (RHR) Heat Exchanger and Pump Rooms 174 and 281, Fire Area 55 on February 11, 2014

Unit 1 Class 1E Battery Room 425, Fire Area 8 on February 11, 2014

Unit 1, Safeguard System Access Area Room 304, Fire Area 44 on February 13, 2014

Unit 2, Control Rod Drive Equipment and Neutron Monitoring Area Rooms 402, 403, 404 and 406, Fire Area 45 on March 24, 2014

Unit 1, Drywell Area Room 400, Fire Area 30 on March 24, 2014

b. Findings

No findings were identified.

1R06 Flood Protection Measures

Internal Flooding Review

a. Inspection Scope

The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to assess susceptibilities involving internal flooding. The inspectors also reviewed the corrective action program to determine if LGS identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors performed walkdowns of the Spray Pond Pump House (including the RHRSW and ESW pump areas) on March 12, 2014, to verify the adequacy of equipment seals located below the flood line, floor and water penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and temporary or removable flood barriers.

b. Findings

No findings were identified.

1R08 In-Service Inspection Limerick Unit 1

a. Inspection Scope

The inspectors conducted a review of LGSs implementation of an in-service inspection program for monitoring degradation of the reactor coolant system boundary, risk significant piping and components, and containment systems during the Limerick Generating Station, Unit 1, Refueling Outage 1R15. The sample selection was based on the inspection procedure objectives and risk priority of those pressure retaining components in these systems where degradation would result in a significant increase in risk. This inspection was to verify that the non-destructive examination activities performed were conducted in accordance with the requirements of American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI, 2001 Edition, 2003 Addenda.

Non-destructive Examination (NDE) Activities and Welding Activities Inspection Manual Chapter (IMC) Section 02.01

The inspectors observed portions of the following NDE activities and reviewed completed examination data records.

ASME Code Required Examinations

Activities inspected included observations of ultrasonic testing (UT), magnetic particle testing, visual testing (VT), and calibration practices. The inspectors reviewed the applicable NDE procedures, qualification certification for the personnel and procedures, and confirmed that relevant indications were properly documented and dispositioned.

The inspectors observed portions of the following in-process examinations and post-test inspection results: Unit 1 reactor vessel safe-end-to-nozzle dissimilar metal welds DCA-318-2N17A RHR system, VRR-1RD-1A N2H, and VRR-1RD-1B N2C reactor recirculation pumps discharge piping system which were examined with automated encoded phased array UT; automated UT of Unit 1 reactor in-vessel core spray system down comer outer sleeve welds; and, magnetic particle testing of Unit 1 reactor pressure vessel top closure head to flange weld.

Other Augmented or Industry Initiative Examinations

The inspectors observed portions of the remote visual inspections, videos, and pictures of in-vessel visual inspections of the Unit 1 boiling water reactor (BWR) pressure vessel internals jet pumps, steam separator, and core spray system piping to verify that LGS is inspecting and monitoring in-vessel components in accordance with BWR Vessel and Internals Project guidelines. The inspectors performed an independent visual inspection of accessible areas of the Unit 1 drywell liner to assess the material condition of the protective coating. In addition the inspectors reviewed photographs of the Unit 1 suppression pool carbon steel liner coating/spot recoating repair activities performed during the 1R15 refueling outage to verify that LGS is inspecting and monitoring the coatings per Specification NE-101, Suppression Pool Coatings requirements and Limerick license renewal aging management program commitment for protective coating monitoring maintenance program.

Re-examination of an Indication Previously Accepted For Service After Analysis The inspectors reviewed one volumetric examination that involved examinations with relevant indications that had been analytically evaluated and accepted by LGS for continued service following the previous Limerick Unit 1 (1R14) outage. The inspectors observed portions of the in-process automated encoded phased array ultrasonic testing of the Unit 1 reactor vessel safe-end-to-nozzle dissimilar metal weld VRR-1RD-1A N2H reactor recirculation pump discharge piping system which had a previous inside diameter connected flaw that was inspected using the same NDE technique during 1R14 that was evaluated as acceptable for continued service. The inspectors reviewed the examination data results from this 1R15 outage against the previous 1R14 outage examination data results to verify that the previously identified flaw had not propagated and was acceptable per the ASME Code for continued service.

Modification/Repair/Replacements Consisting of Welding on Pressure Boundary Risk Significant Systems

The inspectors reviewed repair/replacement activity associated with the replacement of ASME Class 2, core spray loop B relief valve PSV-052-1FO12B inlet/outlet flanges, per engineering change request (ECR) 11-00091. The NDE liquid penetrant examination data sheets were also reviewed. The review was performed to evaluate welding specifications and control of the welding process detailed in the work order, to determine that qualified weld procedures and welders were used for the welding, and that weld examinations were performed in accordance with the ASME Code requirements.

Identification and Resolution of Problems

The inspectors reviewed a sample of Limerick Issue reports (IRs), which identified NDE indications, deficiencies and other nonconforming conditions since the previous refueling outage. The inspectors verified that nonconforming conditions were properly identified, characterized, evaluated, corrective actions identified and dispositioned, and appropriately entered into the corrective action program.

b. Findings

No findings were identified.

==1R11 Licensed Operator Requalification Program

==

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

(71111.11Q - 1 sample)

a. Inspection Scope

The inspectors observed licensed operator annual simulator training on January 31, 2014. Operators performed hands-on training associated with the planned Unit 1 digital electro-hydraulic control system modification. The inspectors evaluated operator performance during the various simulated evolutions including heat-up, main turbine startup and shutdown, plant cool down using turbine bypass valves, and various plant transients including system equipment failures. The inspectors verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

b. Findings

No findings were identified.

.2 Quarterly Review of Licensed Operator Performance in the Main Control Room

(71111.11Q - 1 sample)

a. Inspection Scope

The inspectors observed and reviewed licensed operator performance in the main control room during an unplanned Unit 2 down power to 82 percent power on January 17, 2014 due to a feedwater heater isolation caused by equipment failure. The inspectors verified operator compliance and use of plant procedures, performance of procedure steps in the proper sequence, alarm response card response and proper TS usage. Pre-job briefs, the use of human error prevention techniques, communications between crew members, and supervision of activities were also observed to verify that they were performed consistent with established plant practices.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structures, systems and component (SSC) performance and reliability. The inspectors reviewed system health reports, corrective action program documents, maintenance work orders, and maintenance rule basis documents to ensure that LGS was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by LGS staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that LGS staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.

IR 1583879, Failure of Agastat EGP relay in the RHR system valve control circuitry on January 17, 2014

Residual heat removal service water radiation monitor low flow condition following RHRSW/ESW pump starts on March 14, 2014

b. Findings

No findings were identified during review of the first sample. The second sample resulted in a finding which is discussed further in Section 2RS6.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that LGS performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that LGS personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When LGS performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk.

The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

Units 1 and 2 Yellow online risk due to a Maximum Emergency Generation Action being issued by the grid operator (PJM Interconnection) on January 7, 2014 Units 1 and 2 Yellow online risk due to a Maximum Emergency Generation Action being issued by the grid operator on January 30, 2014

Unit 1 online risk change to Yellow as a result of the emergent unavailability of the A electro-hydraulic control pump on February 28, 2014

Unit 2 Yellow online risk during B loop of RHRSW return piping being unavailable during maintenance activities from March 15-16, 2014

Unit 2 Yellow online risk during Unit 1 A ESW return header being unavailable due to ESW piping replacement on March 30, 2014

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:

IR 1607979, Unit 1 reactor building elevation 269 airlock doors were inadvertently opened simultaneously on January 14, 2014

IR 1611986, Emergency diesel generator (EDG) D11 air start system tubing discovered to be cracked on January 27, 2014

IR 1618204, Unit 1 B RHR pump failed comprehensive in-service test due to low pump differential pressure on February 10, 2014

IR 1617461, Unit 2 B automatic depressurization system backup nitrogen bottle pressure lowering due to relief valve leakage on February 12, 2014

IR1633981, ESW return isolation valve to RHRSW return line was discovered to have excessive leakage on March 17, 2014

The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and UFSAR to LGSs evaluations to determine whether the components or systems were operable.

Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by LGS. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

b. Findings

No findings were identified.

==1R18 Plant Modifications

Temporary Modifications (71111.18 - 1 sample)

a. Inspection Scope

==

The inspectors evaluated the temporary plant modification associated with the refueling floor crane gear (ECR 14-00088) to determine whether the modification adversely affected the safety functions of systems that are important to safety. The inspectors review 10 CFR 50.59 documentation, design modification documentation, and post-maintenance testing results to verify that the temporary modification did not degrade the design bases, licensing bases, and performance capability of the refueling floor crane.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.

C0251104, Replace broken EDG D21 air start tubing on January 20, 2014

C0251206, Repair cracked tubing in EDG D11 air start tubing on January 28, 2014

A1942966, Technical Support Center emergency ventilation system failure to actuate on February 19, 2014

A1870700, Spray Pond Pump House sump pump repairs on March 16, 2014

C0251885, Unit 1 A RHR loop testable check valve failure to operate on March 10, 2014

A1946819, Unit 2 reactor water cleanup differential timer failure to operate on March 18, 2014

b. Findings

No findings were identified.

==1R20 Refueling and Other Outage Activities (71111.20 - partial sample)

a. Inspection Scope

==

The inspectors reviewed the stations work schedule and outage risk plan for the Unit 1 maintenance and refueling outage (1R15), which commenced on March 4, 2014. The inspectors reviewed LGSs development and implementation of outage plans and schedules to verify that risk, industry experience, previous site-specific problems, and defense-in-depth were considered. At the end of the inspection period, Unit 1 was in OPCON 5 (Refueling), with the reactor cavity flooded. This sample will be completed in the second quarter of 2014 after Unit 1 returns to OPCON 1. During the outage, the inspectors observed portions of the shutdown and cooldown processes and monitored controls associated with the following outage activities:

Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable Technical Specifications when taking equipment out of service

Implementation of clearance activities and confirmation that tags were properly hung and that equipment was appropriately configured to safely support the associated work or testing

Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication and instrument error accounting

Status and configuration of electrical systems and switchyard activities to ensure that Technical Specifications were met

Monitoring of decay heat removal operations

Impact of outage work on the ability of the operators to operate the spent fuel pool cooling system

Reactor water inventory controls, including flow paths, configurations, alternative means for inventory additions, and controls to prevent inventory loss

Activities that could affect reactivity

Maintenance of secondary containment as required by Technical Specifications

Refueling activities, including fuel handling and fuel receipt inspections

Fatigue management

Identification and resolution of problems related to refueling outage activities

b. Findings

No findings were identified.

==1R22 Surveillance Testing (71111.22 - 2 Routine, 2 In-Service Test (IST) and 1 Isolation Valve)

==

a. Inspection Scope

The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied technical specifications, the UFSAR, and Exelon procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:

ST-6-092-324-2, D24 Diesel Generator Load Reject Testing on February 4, 2014

ST-6-051-235-2, Unit 2 A RHR Pump Comprehensive Test on January 21, 2014 (IST)

ST-6-020-233-2, D23 Diesel Generator Fuel Oil Transfer Pump, Valve and Flow Test on February 11, 2014 (IST)

ST-4-LLR-031-1, Main Steam Line A Local Leak Rate Test performed on Unit 1 during RFO 1R15 (Isolation Valve)

ST-6-097-630-1, Core Alteration Testing for Offloading, Shuffling and Reloading the Core, performed on Unit 1 during RFO 1R15 on March 15, 2014

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

Exelon implemented various changes to the Limerick Emergency Action Levels (EALs),

Emergency Plan, and Implementing Procedures. Exelon had determined that, in accordance with 10 CFR 50.54(q)(3), any change made to the EALs, Emergency Plan, and its lower-tier implementing procedures, had not resulted in any reduction in effectiveness of the Plan, and that the revised Plan continued to meet the standards in 50.47(b) and the requirements of 10 CFR 50 Appendix E.

The inspectors performed an in-office review of all EAL and Emergency Plan changes submitted by Exelon as required by 10 CFR 50.54(q)(5), including the changes to lower-tier emergency plan implementing procedures, to evaluate for any potential reductions in effectiveness of the Emergency Plan. This review by the inspectors was not documented in an NRC Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The requirements in 10 CFR 50.54(q) were used as reference criteria.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Occupational and Public Radiation Safety

2RS0 1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

During February 24-28, 2014 and March 24-28, 2014, the inspectors reviewed LGSs performance in assessing and controlling radiological hazards in the workplace. The inspectors used the criteria in 10 CFR 20, applicable Regulatory Guides, TSs, and applicable Exelon procedures for determining compliance.

Inspection Planning

The inspectors reviewed the stations performance indicators for the occupational exposure cornerstone, reviewed available radiation protection (RP) program audits and reviewed any reports of operational occurrences.

Radiological Hazard Assessment

The inspectors reviewed the adequacy and effectiveness of LGSs radiological hazard assessments. The review included walk-downs during the Unit 1 outage and independent radiation measurements in the facility. Areas reviewed included: changes to plant operations and new significant radiological hazards; radiological surveys; radiological risk-significant work activities; work in potential airborne radioactivity areas including use of air monitors, proper evaluation of air samples and the program for monitoring levels of loose surface contamination.

Instructions to Workers

The inspectors reviewed the adequacy and effectiveness of LGSs instructions to workers. Areas reviewed included: labelling and control of radioactive material containers; radiation work permits; exposure control methods; malfunctioned or alarms of electronic personal dosimeters changes in work conditions or requirements; and briefing workers of radiological conditions and radiological controls.

Contamination and Radioactive Material Control

The inspectors reviewed the adequacy and effectiveness of LGSs contaminated and radioactive material controls. Areas reviewed included: locations where potentially contaminated material was monitored leaving the radiological control area; methods to control, survey, and release the materials; radiation monitoring instrumentation; personnel contamination surveys; and criteria for the survey and release of potentially contaminated material.

The inspectors reviewed the adequacy and effectiveness of LGSs radiological hazards control and work coverage. Areas reviewed included: ambient radiological conditions and adequacy of posted surveys; radiation work permits and associated worker briefings; radiation protection job coverage; personal radiation monitoring devices; monitoring in significant dose rate gradients; work in airborne radioactivity areas; controls for highly activated or contaminated materials stored within storage pools; and posting and physical controls for selected high radiation areas, locked high radiation areas and very high radiation areas.

Radiation Worker Performance and RP Technician Proficiency

The inspectors reviewed the adequacy and effectiveness of LGS radiation worker and RP technician performance including performance of radiation workers and radiation protection technicians with respect to stated RP work requirements, controls and limits as well as awareness of radiological conditions present.

Problem Identification and Resolution

The inspectors evaluated whether problems associated with radiation monitoring and exposure control were being identified at an appropriate threshold and were properly addressed for resolution. The inspectors assessed the process for applying operating experience.

b. Findings

No findings were identified.

2RS0 2 Occupational ALARA Planning and Controls

a. Inspection Scope

During February 24-28, 2014 and March 24-28, 2014, the inspectors assessed performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspectors used the requirements in 10 CFR 20, applicable Regulatory Guides, and LGSs TSs and procedures for determining compliance.

Inspection Planning

The inspectors conducted inspection planning and reviewed Exelon site-specific trends in collective exposures; changes in the radioactive source term; and procedures associated with maintaining occupational exposures ALARA.

Radiological Work Planning

The inspectors reviewed the adequacy and effectiveness of LGSs radiological work planning including: planning for high exposure work activities; ALARA work activity evaluations, exposure estimates, and exposure reduction requirements; and results achieved (dose rate reductions, actual dose).

Verification of Dose Estimates and Exposure Tracking Systems

The inspectors reviewed LGSs dose estimates and exposure tracking assumptions and bases; and method of adjusting exposure estimates, or re-planning work (e.g., changes in scope or emergent work).

Source Term Reduction and Control

The inspectors assessed contingency plans for potential changes in the source term.

Radiation Worker and Radiation Protection Performance

The inspectors observed radiation worker and RP technician performance during work activities being performed in radiation areas, airborne radioactivity areas, and high radiation areas.

Problem Identification and Resolution

The inspectors evaluated whether problems associated with ALARA planning and controls were being identified at an appropriate threshold and corrected.

b. Findings

No findings were identified.

2RS0 3 In-Plant Airborne Radioactivity Control and Mitigation

a. Inspection Scope

During February 24-28, 2014 and March 24-28, 2014, the inspectors verified that various potential in-plant airborne sources were being controlled consistent with ALARA principles and the use of respiratory protection devices, as appropriate. The inspectors used the requirements in 10 CFR 20, the guidance in applicable Regulatory Guides, and LGSs TSs and procedures for determining compliance.

Inspection Planning

The inspectors reviewed reported performance indicators to identify any related to unintended dose resulting from intakes of radioactive material.

Engineering Controls

The inspectors reviewed the adequacy and effectiveness of LGSs engineering controls for airborne radioactivity including: use of ventilation; and threshold criteria for evaluating levels of airborne beta-emitting, alpha-emitting radionuclides, and other hard-to-detect radionuclides.

Use of Respiratory Protection Devices

The inspectors reviewed the adequacy and effectiveness of LGSs use of respiratory protection devices including: use of respiratory protection devices; means to determine level of protection (protection factor) provided; and use of certified respiratory protection devices including qualifications of individuals to use respiratory protection devices.

Problem Identification and Resolution

The inspectors evaluated whether problems associated with the control and mitigation of in-plant airborne radioactivity were being identified by the licensee and placed in the corrective action program with appropriate corrective actions planned or implemented.

b. Findings

No findings were identified.

2RS0 4 Occupational Dose Assessment

a. Inspection Scope

During February 24-28, 2014 and March 24-28, 2014, the inspectors evaluated the monitoring, assessment and reporting of occupational dose. The inspectors used the requirements in 10 CFR 20, the guidance in various Regulatory Guides, and requirements in LGSs TSs and procedures.

Inspection Planning

The inspectors reviewed procedures associated with dosimetry operations, including issuance/use of external dosimetry, and assessments of external and internal dose for radiological incidents.

External Dosimetry

The inspectors reviewed the adequacy and effectiveness LGSs external dosimetry including: use of National Voluntary Laboratory Accreditation Program accredited dosimetry; use of electronic personal dosimeters to determine the use of a correction factor; dosimetry occurrence reports and corrective actions; and available skin dose assessment reports.

Internal Dosimetry

Routine Bioassay (In Vivo)

The inspectors reviewed procedures used to assess the dose from internally deposited radionuclides using whole body count (WBC) equipment.

Internal Dose Assessment - WBC Analyses

The inspectors reviewed available dose assessments performed using the results of WBC analyses.

Special Dosimetric Situations

Declared Pregnant Workers

The inspectors reviewed training on the risks of radiation exposure to the embryo/fetus, the regulatory aspects of declaring a pregnancy, the process used for (voluntarily)declaring a pregnancy, and associated exposure controls.

Dosimeter Placement and Assessment of Effective Dose Equivalent for External Exposures

The inspectors reviewed the methodology for monitoring external dose in non-uniform radiation fields or where large dose gradients exist.

Shallow Dose Equivalent

The inspectors reviewed available dose assessments for shallow dose equivalent for adequacy. The inspectors evaluated the method (e.g., VARSKIN or similar code) for calculating shallow dose equivalent from distributed skin contamination or discrete radioactive particles.

Problem Identification and Resolution

The inspectors assessed whether problems associated with occupational dose assessment were identified at an appropriate threshold, were placed in the corrective action program, and whether corrective actions, for a selected sample of problems, were appropriate.

b. Findings

No findings were identified.

2RS0 5 Radiation Monitoring Instrumentation

a. Inspection Scope

During February 24-28, 2014 and March 24-28, 2014, the inspectors reviewed the accuracy and operability of radiation monitoring instruments that were used to protect occupational workers. The inspectors used the requirements in 10 CFR 20, the guidance in applicable Regulatory Guides, and LGSs TSs and procedures for determining compliance.

Inspection Planning

The inspectors reviewed available third-party evaluation reports of the radiation monitoring program since the last inspection including evaluations of offsite calibration facilities or services, if applicable.

Walk-downs and Observations

The inspectors selected various portable survey instruments in use or available for issuance and assessed calibration and source check stickers for currency, as well as, instrument material condition and operability.

Calibration and Testing Program

Laboratory Instrumentation

The inspectors assessed laboratory analytical instruments used for radiological analyses to determine whether daily performance checks and calibration data indicate that the frequency of the calibrations is adequate and there were no indications of degraded performance.

Whole Body Counter

The inspectors reviewed methods and sources used for whole body counter calibration and functional checks.

Portal Monitors, Personnel Contamination Monitors, and Small Article Monitors

The inspectors selected several of each type of these instruments (e.g., Personnel Contamination Monitor 1-C, Small Article Monitors 12) and verified that the alarm set-point values are reasonable under the circumstances to ensure that licensed material is not released from the site.

Portable Survey Instruments, Area Radiation Monitors (ARMs), Electronic Dosimetry, and Air Samplers/Continuous Air Monitors (CAMs)

The inspectors selected various portable survey instruments that did not meet acceptance criteria during calibration or source checks to assess whether the licensee had taken appropriate corrective action for instruments found significantly out of calibration. The inspectors evaluated whether the licensee had evaluated the possible consequences associated with the use of an instrument that is out-of calibration since the last successful calibration or source check. The inspectors reviewed source checking of instruments (RO-2, Telepole) with a calibrator.

Instrument Calibrator

The inspectors reviewed the current radiation output values for the licensees portable survey and ARM instrument calibrator unit(s). The inspectors assessed whether the licensee periodically verifies calibrator output over the range of the exposure rates/dose rates using an ion chamber/electrometer.

The inspectors assessed whether the measuring devices had been calibrated by a facility using National Institute of Standards and Technology (NIST) traceable sources and whether decay corrective factors for these measuring devices were properly applied by the licensee in its output verification.

Calibration and Check Sources

The inspectors reviewed the licensees source term or waste stream characterization per 10 CFR 61, Licensing Requirements for Land Disposal of Radioactive Waste, to assess whether calibration sources used were representative of the types and energies of radiation encountered in the plant.

Problem Identification and Resolution

The inspectors evaluated whether problems associated with radiation monitoring instrumentation were being identified by the licensee at an appropriate threshold, the issues were placed in the corrective action program, and appropriate corrective actions were taken based on a review of selected problems.

b. Findings

No findings were identified.

2RS0 6 Radioactive Gaseous and Liquid Effluent Treatment

.1 RHR Service Water Monitor Issues

a. Inspection Scope

During the period March 24-28, 2014, the inspectors reviewed operability issues associated with the A/B RHR Service Water Radiation Monitors. The review was against criteria contained in 10 CFR Part 20, 10 CFR Part 50, 40 CFR 190, applicable Regulatory Guides and industry standards, TSs/ODCM, and LGS station procedures for determining compliance.

b. Findings

Introduction:

The NRC identified a Green non-cited violation of Technical Specification 6.14, ODCM, for failure to evaluate and provide sufficient information to support a change to the ODCM. Specifically, LGS revised the ODCM to allow the residual heat removal service water (RHRSW) monitors to be non-functional due to loss of flow for a period of up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> before they were required to be declared inoperable and did not provide sufficient information to support the change including a determination that the change would maintain the level of radioactive effluent control.

Description:

At Limerick, each RHRSW return header, which directs emergency service water and RHRSW back to the sites Spray Pond, is equipped with an RHRSW radiation monitor. UFSAR Section 9.2.3, RHR Service Water System, describes that the radiation monitors are provided in the return headers and that high radioactivity causes an alarm and the RHRSW pumps, associated with each header, trip to stop liquid radioactive release to the environment via the Spray Pond. Limerick Design Basis Document L-S-43, Radiation Monitoring System, Revision 4, states that the RHRSW radiation monitors perform the safety-related function of monitoring the return header for radiation to detect a leak in an RHR heat exchanger which could result in contamination of the Spray Pond. The design basis document further states that contamination of the Spray Pond could cause an uncontrolled release of radioactive material to the environment.

Limerick ODCM, Revision 26, states that the RHRSW Radiation Monitors (RISH-12-0K619A, RISH-12-0K619B) provide alarm and automatic termination of radioactive material release from the RHRSW system, as required by ODCM Control 3.1.1, Radioactive Liquid Effluent Monitoring Instrumentation. While the RHRSW system is not a normal radioactive liquid effluent release pathway, the monitors are listed in the ODCM as effluent monitors. The Spray Pond is sampled monthly for radioactivity and does blowdown to the river. ODCM Control 3.1.1 states that for the radioactive liquid effluent monitoring instrumentation channels shown in Table 3.1-1, the monitors shall be OPERABLE with their Alarm/Trip Set-points set to ensure that the limits of Control 3.2.1.1, Liquid Effluent Concentration, are not exceeded. ODCM Control 3.1.1 states that with a radioactive liquid effluent monitoring instrumentation channel Alarm/Trip Setpoint less conservative than required by the above control, immediately suspend the release of radioactive liquid effluents monitored by the affected channel, or declare the channel inoperable, or change the setpoint so it is acceptably conservative. With no sample flow to the monitor, the trip setpoint is not operative.

On May 4, 2010, LGS placed the RHRSW radiation monitors in Maintenance Rule (a)(1)status due to reliability issues caused mainly by radiation monitor low sample flow conditions. Due to the sample line piping arrangement, the common header shared between the RHRSW and ESW system, and the fact that the sample pump is not self-priming, the RHRSW radiation monitor frequently became non-functional following RHRSW and/or ESW pump starts. The pump starts caused trapped air in the system to reach the sample pump suction and air-bind the pump causing loss of sample flow to the monitors and loss of functional capability. This loss of flow causes low flow alarms and required operator action to vent the pump to restore functionality.

In October 2011, LGS made a revision

(25) to its ODCM Table 3.1-1 Action statement for loss of minimum required channels of A/B RHR Service Water Effluent line to provide a second definition of the term Operable in the ODCM. Specifically, the new action statement stated that, for the RHRSW radiation monitor, clearing a HI/LO flow alarm within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the alarm annunciation meets the requirements of Definition 1.5, Continuous Sampling. As a result, LGS no longer declared the radiation monitor inoperable (non-functional) even though the condition of the monitors did not meet the definition of Operable in ODCM Section 1.10 or ODCM Action Control 3.1.1.

Specifically, the monitor was incapable of performing its intended function to detect and trip RHR service water pumps on high radioactivity. LGS had also revised the control room alarm response card (ARC)-MCR-010 E4, RHRSW Sample Hi/Lo Flow, to only declare the RHRSW radiation monitor inoperable due to low flow only if inadequate flow existed for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and only initiate an IR if the monitor is declared inoperable.

The Units 1 and 2 Technical Specification 6.14 requires a determination be made that an ODCM change maintains the level of radioactive effluent control required by 10 CFR 20.1302, 40 CFR 190, 10 CFR 50.36a, and 10 CFR Part 50, Appendix I, and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.

Although LGS had conducted an evaluation of the loss of the monitor, the evaluation principally focused on the ability to obtain a grab sample within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of the monitor first losing flow rather than the potential radiological implications and possible dose consequences to the public on loss of the monitors isolation capability. The loss is of particular importance in that the functional capability of the monitor could be lost on initial system startup due to air-binding of the sample pump.

The inspectors performed a review of operator logs from January 1, 2014 to February 27, 2014. The inspectors found that RHRSW radiation monitor low flow alarms were received 15 times during the time period and inadequate flow to support the radiation monitors functionality (<.5 gpm flow) occurred on 8 of these instances.

Because the condition was cleared within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, no IRs were generated. No samples were collected through LGSs procedure (ST-5-026-571-0) because the flow was restored before declaring the monitor inoperable.

The inspectors reviewed the change package for the changes to CY-LG-170-301, Limerick Offsite Dose Calculation Manual, Revision 25 (October 2011), which implemented the changes. The change package had no information regarding the loss of functional capability of the monitor due to low flow and the potential dose to members of the public associated with monitors inability to detect and trip the RHRSW pumps.

The evaluation indicated the change was an administrative change to clarify that compensatory sampling of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> would not need to be implemented if the alarm can be cleared by venting the flow line within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. If flow could not be obtained within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, then 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action would remain to obtain a compensatory sample. The evaluation did not determine if the change maintained the required level of radioactive effluent control as specified in the ODCM on loss of the monitors isolation capability before it was eventually declared inoperable.

Analysis:

Failure to evaluate and provide sufficient information to support a change to the ODCM in accordance with the requirements of Technical Specification 6.14 is a performance deficiency. Specifically, LGS changed the ODCM (Revision 25) to allow the RHRSW monitors to be non-functional due to loss of flow, for a period of up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, before the monitors were declared inoperable and appropriate surveillance requirements are invoked. LGS did not provide sufficient information to support the change, including a determination that the change would maintain the level of radioactive effluent control required by 10 CFR 20.1302, 40 CFR 190, 10 CFR 50.36a, and 10 CFR Part 50, Appendix I, and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.

The finding was not willful, was not subject to traditional enforcement because it was not associated with a violation that impacted the regulatory process, and did not contribute to actual safety consequences. The finding was assessed using IMC 0609, Appendix D, Public Radiation Safety Significance Determination Process, dated February 12, 2008.

This performance deficiency is more than minor because it affected the Public Radiation Safety Cornerstone attribute of Plant Facilities/Equipment and Instrumentation.

Specifically, LGS did not evaluate and provide sufficient information to support a change to the ODCM associated with loss of functional capability of RHRSW radiation monitors including a determination that the change would maintain the level of radioactive effluent control. The inspectors determined this to be a finding of very low safety significance (Green) because: the finding was in the effluent release program; was not a substantial failure to implement the effluent program; and the dose to the public did not exceed the 10 CFR Part 50, Appendix I criterion or 10 CFR 20.1301(e) limits. This finding was associated with a cross cutting aspect of Human Performance, Design Margins.

Specifically, LGS did not conduct a sufficiently rigorous review of a change in the operability status of a safety-related radiation monitor (RHRSW radiation monitors) to ensure that the change would not adversely impact the level of radioactive effluent control (H.6).

Enforcement:

The Limerick Units 1 and 2 Technical Specification 6.14, ODCM, requires that the licensee evaluate and provide sufficient information to support changes to the ODCM. Contrary to this requirement, between October 2011 and March 28, 2014, LGS made a change to the ODCM (Revision 25) that effectively delayed declaring a loss of function of RHRSW radiation monitors for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Further, an evaluation, with sufficient information, was not conducted to include a determination that the change would maintain the level of radioactive effluent control. The violation did not have any actual or potential safety consequence in that RHRSW was not contaminated, no unplanned releases occurred, and the spray pond and RHR system were periodically sampled.

LGS was collecting and analyzing samples monthly from the RHRSW system and the Spray Pond for isotopic analysis and quarterly from the Spray Pond for tritium. LGS staff placed this issue into the Corrective Action Program (CAP) and issued a revision to ARC-MRC-010 E4 on March 28, 2014, to declare the monitor inoperable upon loss of flow. LGS also conducted bounding dose calculations which indicated no significant public dose consequences associated with RHRSW operation with the radiation monitors in an undeclared inoperable status. Because this violation was determined to be of very low safety significance and has been entered into the corrective action program (IR 1639697) this violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy. (NCV 05000352/2014002-01; 05000353/2014002-01, Failure to Evaluate ODCM Change in Accordance with Technical Specification 6.14)

.2 Discontinuation of Burning of Waste Contaminated Oil

a. Inspection Scope

The inspectors reviewed changes to the Limerick Station ODCM associated with discontinuation of burning of contaminated waste oil in the Limerick Stations Auxiliary Boilers. The inspectors reviewed ODCM Revisions 24, 25, and 26 including the associated change evaluation which removed burning of contaminated waste oil from the ODCM. The review was with respect to applicable TS and Exelon Procedure requirements for conducting ODCM changes.

b. Findings

No findings were identified.

The inspectors determined that LGS made a change to its ODCM (Revision 25) via change determination CY-AA-170-3100, dated October 4, 2011. The revision removed ODCM Sections 3.2.2.6 and 2.3.5 which provided effluent control methodology for incineration of contaminated waste oil. The basis for the change was LGSs decision to no longer burn contaminated oil at the Limerick station. The change effectively removed the effluent controls required by Technical Specification 6.8.4 d, Radioactive Effluent Control Program, for burning of waste contaminated oil which were deemed no longer needed.

2RS08 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation (71124.08 - 1 sample)

a. Inspection Scope

During the week of February 10-14, 2014, the inspectors verified the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material. The inspectors used the requirements of 10 CFR 20, 61, and 71, and 10 CFR 50, Appendix A - Criterion 63 - Monitoring Fuel and Waste Storage, and licensee procedures required by the Technical Specifications/Process Control Program, as criteria for determining compliance.

The inspectors reviewed the solid radioactive waste system description in the UFSAR, the Process Control Program (PCP), and the recent radiological effluent release report for information on the types, amounts, and processing of radioactive waste disposed.

The inspectors reviewed the scope, the results, and the adequacy of the licensees corrective actions of quality assurance audits performed for this area since the last inspection.

Radioactive Material Storage

The inspectors inspected areas where containers of radioactive waste were stored.

The inspectors verified that the radioactive materials storage areas were controlled and posted as appropriate.

The inspectors verified that the licensee had established a process for monitoring the impact of long-term storage (e.g., buildup of any gases produced by waste decomposition, chemical reactions, container deformation, loss of container integrity, or re-release of free-flowing water). The inspectors verified that there were no signs of swelling, leakage, or deformation.

Radioactive Waste System Walkdown

The inspectors walked down accessible portions of liquid and solid radioactive waste processing systems to verify and assess that the current system configuration and operation agree with the descriptions in the UFSAR, Offsite Dose Calculation Manual, and PCP.

The inspectors identified radioactive waste processing equipment that was not operational and/or was abandoned in place, and verified that the licensee had established administrative and/or physical controls for the protection of personnel from unnecessary personnel exposure.

The inspectors reviewed the adequacy of any changes made to the radioactive waste processing systems since the last inspection. The inspectors verified that changes from what was described in the UFSAR were reviewed and documented.

The inspectors identified processes for transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers. The inspectors verified that the waste stream mixing, sampling procedures, and methodology for waste concentration averaging were consistent with the PCP, and provided representative samples of the waste product for the purposes of waste classification.

For those systems that provide tank recirculation, the inspectors verified that the tank recirculation procedure provided sufficient mixing.

The inspectors verified that the licensees PCP correctly described the current methods and procedures for dewatering waste.

Waste Characterization and Classification

The inspectors identified radioactive waste streams, and verified that the licensees radiochemical sample analysis results were sufficient to support radioactive waste characterization. The inspectors verified that the licensees use of scaling factors and calculations to account for difficult-to-measure radionuclides was technically sound and based on current analyses.

The inspectors verified that changes to plant operational parameters were taken into account to

(1) maintain the validity of the waste stream composition data between the annual or biennial sample analysis update, and

(2) verified that waste shipments continued to meet applicable requirements.

The inspectors verified that the licensee had established and maintained an adequate quality assurance program to ensure compliance with applicable waste classification and characterization requirements.

Shipment Preparation

The inspectors reviewed the records of shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and licensee verification of shipment readiness. The inspectors verified that the requirements of any applicable transport cask certificate of compliance had been met. The inspectors verified that the receiving licensee was authorized to receive the shipment packages

The inspectors determined that the shippers were knowledgeable of the shipping regulations and that shipping personnel demonstrated adequate skills to accomplish the package preparation requirements for public transport. The inspectors verified that the licensees training program provided training to personnel responsible for the conduct of radioactive waste processing and radioactive material shipment preparation activities.

Shipping Records

The inspectors identified non-excepted package shipment records and verified that the shipping documents indicate the proper shipper name; emergency response information and a 24-hour contact telephone number; accurate curie content and volume of material; and appropriate waste classification, transport index, and international shipping identification number. The inspectors verified that the shipment placarding was consistent with the information in the shipping documentation.

Identification and Resolution of Problems

The inspectors verified that problems associated with radioactive waste processing, handling, storage, and transportation, were being identified by the licensee at an appropriate threshold, were properly characterized, and verified the appropriateness of the corrective actions for a selected sample of problems. The licensee generated six condition reports to document material condition deficiencies identified during this inspection.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

.1 Unplanned Power Changes (2 samples)

a. Inspection Scope

The inspectors reviewed Exelons submittals for the following Initiating Events Cornerstone performance indicators for the period of January 1, 2013, through December 31, 2013.

Unit 1 Unplanned Power Changes (IE03)

Unit 2 Unplanned Power Changes (IE03)

To determine the accuracy of the performance indicator data reported during those periods, inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors reviewed LGSs operator narrative logs, maintenance planning schedules, condition reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index - Heat Removal System (4 samples)

a. Inspection Scope

The inspectors reviewed submittal of the Mitigating Systems Performance Index for the following systems for the period of January 1, 2013 through December 31, 2013:

Units 1 and 2 High Pressure Injection System (MS07)

Units 1 and 2 Heat Removal System (MS08)

To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors also reviewed LGSs operator narrative logs, IRs, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that LGS entered issues into the corrective action program at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the corrective action program and periodically attended condition report screening and Management Review Committee meetings.

b. Findings

No findings were identified.

.2 Annual Sample: Review of the Operator Workaround Program

a. Inspection Scope

The inspectors reviewed the cumulative effects of the existing operator workarounds, operator burdens, existing operator aids and disabled alarms, and open main control room deficiencies to identify any effect on emergency operating procedure operator actions, and any impact on possible initiating events and mitigating systems. The inspectors evaluated whether station personnel had identified, assessed, and reviewed operator workarounds as specified in Exelon procedure OP-AA-102-103, Operator Work-Around Program, Revision 3, and OP-AA-102-103-1001, Operator Burden and Plant Significant Decision Impact Assessment Program, Revision 4.

The inspectors reviewed Exelons process to identify, prioritize and resolve main control room distractions to minimize operator burdens. The inspectors reviewed the system used to track these operator workarounds and recent LGS self-assessments of the program. The inspectors also toured the control room and discussed the current operator workarounds with the operators to ensure the items were being addressed on a schedule consistent with their relative safety significance.

b. Findings and Observations

No findings were identified.

The inspectors determined that the issues reviewed did not adversely affect the capability of the operators to implement abnormal or emergency operating procedures.

The inspectors also verified that LGS personnel entered operator workarounds and burdens into the CAP at an appropriate threshold and planned or implemented corrective actions commensurate with their safety significance.

.3 Annual Sample: Potential Preconditioning of Safety Related Battery Chargers

a. Inspection Scope

As a follow-up to FIN 05000352/2013002-01, the inspectors performed an in-depth review of LGSs evaluation and corrective actions associated with potential pre-conditioning of safety-related battery chargers prior to surveillance testing. TS 4.8.2.1.d.1 requires battery chargers to be load tested to the rated output every two years. This is accomplished by the performance of 24 month surveillance tests ST-4-095-961-1, -962-1, -963-1, -964-1, -965-1, -966-1, -961-2, -962-2, -963-2, -964-2, -

965-2 and -966-2. Just prior to the test, the chargers undergo a preventive maintenance (PM) item that, among other things, adjusts the current limit setpoint of the charger.

During the PM, the current limit setpoint could be found below the TS requirement and adjusted back above the TS band. A low current limit setpoint could prevent the charger from meeting the TS required current. This issue was first identified in 2003, and documented in IR 162284. At that time, procedural controls were implemented to generate an IR when the as-found value of the current limit was found out of tolerance.

NRC Inspection Manual Part 9900 - Technical Guidance, Maintenance - Preconditioning of Structures, Systems, And Components Before Determining Operability, states that the NRC expects surveillance and testing processes of SSCs to be evaluated in an as-found condition. Section C.1.c describes unacceptable preconditioning. The definition states, in part: The alteration, variation, manipulation, or adjustment of the physical condition of the SSCs that will alter one or more of an SSCs operational parameters which results in acceptable test results.

During some two year PMs, a ten year PM is also performed to replace components, including the limit board, control board, and balancing boards. In four of the seven PMs performed in the past six years, charger components were replaced during the PM resulting in as-found setpoints reflecting the initial setting of the cards from the manufacturer. The value at which the charger operated during the prior two years is not known and cannot be determined because the data was never taken. In February 2013, during a review of previously performed PMs, the system manager recognized the potential for preconditioning and generated IR 1478866 to document the issue and drive actions to correct the condition.

During review, the inspector noted that LGSs apparent cause evaluation determined that unacceptable preconditioning occurred because the as-found current limit data was not taken prior to performing the PM cleaning and examination activities. LGS determined that all battery chargers serviced using PM procedure M-095-006, Preventive Maintenance Procedure for Battery Chargers, Revision 4 (and previous revisions), were susceptible to pre-conditioning as a result of the sequence of steps.

LGS has revised the PM to require recording the as-found current limit setpoint before making any adjustments or replacing any components. LGS reviewed the surveillance testing scheduled for the upcoming outage to ensure that PMs were not being performed prior to surveillance testing.

b. Findings and Observations

No findings were identified.

The inspector determined that LGSs apparent cause evaluation and extent of condition review were thorough, and the probable and contributing causes were appropriately identified. The corrective actions completed, and those planned for the future, appeared to be timely and appropriate to resolve the problem. The inspector considered these actions sufficient to address the concerns documented in FIN 05000352/2013002-01.

.4 Identification and Resolution of Problems (71124.01, 71124.02, 71124.03, 71124.04,

and 71124.05)

a. Inspection Scope

The inspectors reviewed available audits, assessments, and corrective action program documents in the occupational radiation safety program.

b. Findings

No findings were identified.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

Plant Events

a. Inspection Scope

For the plant events listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that LGS made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed LGSs follow-up actions related to the events to assure that LGS implemented appropriate corrective actions commensurate with their safety significance.

Unit 1 reactor enclosure secondary containment integrity inoperability due to airlock doors being open on January 14, 2014

Unit 1 reactor enclosure secondary containment integrity inoperability due to airlock doors being open on February 6, 2014

Unit 1 manual scram on March 5, 2014 due to closure of main turbine intercept valve caused by an electro-hydraulic control system failure

b. Findings

No findings were identified.

4OA5 Other Activities

The table below provides a cross-reference for findings and cross-cutting aspects identified in the last six months of 2013 to the new cross-cutting aspects in Inspection Manual Chapter (IMC) 0310 resulting from the common language initiative. These aspects and any others identified since January 2014 will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review.

Finding Old Cross-Cutting Aspect

New Cross-Cutting Aspect

05000352/2013004-01 H.2(a)

H.6 05000353/2013004-02 P.1(c)

P.2 05000353/2013004-03 P.1(d)

P.3 05000353/2013005-01 H.2(a)

H.6

4OA6 Meetings, Including Exit

On April 16, 2014 the inspectors presented the inspection results to Mr. T. Dougherty, Site Vice President, and other members of the LGS staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Dougherty, Site Vice President

D. Lewis, Plant Manager

R. Kreider, Director of Operations

D. Doran, Director of Engineering

F. Sturniolo, Director of Maintenance

J. Hunter, Director of Work Management

K. Kemper, Security Manager

R. Dickinson, Manager, Regulatory Assurance

J. Karkoska, Manager, Nuclear Oversight

R. Ruffe, Training Director

M. Gillin, Shift Operations Superintendent. Manager, Engineering Systems

G. Budock, Regulatory Assurance Engineer

D. Molteni, Licensed Operator Requalification Training Supervisor

M. DiRado, Manager, Engineering Programs

D. Merchant, Radiation Protection Manager

C. Gerdes, Manager, Chemistry, Environmental and Radioactive Waste

N. Harmon, Senior Technical Specialist

P. Imm, Radiological Engineering Manager

B. Nealis, Senior Effluent and Environmental Specialist

H. Miller, Radwaste Shipper

C. Smith, Chemistry Radwaste

J. Broillet, Emergency Preparedness Manager

B. Pinkham, NDE Manager

C. Hawkins, NDE Level III

M. Karasek, In-Vessel Visual Inspections Program Engineer

J. Martin, NDE Specialist Peach Bottom

M. Weis, In-service Inspection Program Engineer

P. Bonnett, Regulatory Assurance

J. Debrosse, Senior Chemist

P. Dix, Radiological Engineering Manager

L. Paralatore, Respirator Physicist

C. Boyle, Radiochemist

J. Duskin, Instrument Physicist

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

05000352, 353/2014002-01 NCV Failure to Adhere to Technical Specifications When Making Change to ODCM (Section 4OA5.2)

Opened

None

Closed

None