IR 05000352/2022010: Difference between revisions

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==SUBJECT:==
==SUBJECT:==
LIMERICK GENERATING STATION, UNITS 1 A ND 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000352/2022010 AND 05000353/2022010
LIMERICK GENERATING STATION, UNITS 1 AND 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000352/2022010 AND 05000353/2022010


==Dear Mr. Rhoades:==
==Dear Mr. Rhoades:==
On February 18, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a p roblem identification and r esolution inspection at your Limerick Generating Station, Units 1 and 2 and discussed the results of this inspection with Mr. Michael Gillin, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.
On February 18, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Limerick Generating Station, Units 1 and 2 and discussed the results of this inspection with Mr. Michael Gillin, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.


The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the sta tion was complying with NRC regulations and licensee standards for problem identification and resolution programs.
The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.


Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.


The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self -assessments.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.


Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.


Finally, the team reviewed the stations programs to establish and maintain a safety -conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety -conscious work environment.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.


Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.


No findings or violations of more than minor significance were identified during this inspection. This letter, its enclosure, and your response (if any) will be m ade available for public inspection and copying at http://www.nrc.gov/ reading-rm /a dam s.h tm l and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
No findings or violations of more than minor significance were identified during this inspection. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.


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


Docket Nos. 05000352 and 05000353 License Nos. NPF-39 and NPF-85
Docket Nos. 05000352 and 05000353 License Nos. NPF-39 and NPF-85  


===Enclosure:===
===Enclosure:===
As stated
As stated  


==Inspection Report==
==Inspection Report==
Docket Numbers: 05000352 and 05000353
Docket Numbers:
05000352 and 05000353  


License Numbers: NPF-39 and NPF -85
License Numbers:
NPF-39 and NPF-85  


Report Numbers: 05000352/2022010 and 05000353/2022010
Report Numbers:
05000352/2022010 and 05000353/2022010  


Enterprise Identifier: I-2022- 010-0013
Enterprise Identifier: I-2022-010-0013  


Licensee: Constellation Energy Generation, LLC
Licensee:
Constellation Energy Generation, LLC  


Facility: Limerick Generating Station, Units 1 and 2
Facility:
Limerick Generating Station, Units 1 and 2  


Location: Sanatoga, PA 19464
Location:
Sanatoga, PA 19464  


Inspection Dates: January 31, 2022 to February 18, 2022
Inspection Dates:
January 31, 2022 to February 18, 2022  


Inspectors: L. Casey, Senior Project Engineer L. G rim e s, Resident Inspector S. Haney, Senior Project Engineer M. Hardgrove, Resident Inspector
Inspectors:
L. Casey, Senior Project Engineer  


Approved By: Jonathan E. Greives, Chief Projects Bran ch 4 Division of Operating Reactor Safety
L. Grimes, Resident Inspector


Enclosure
S. Haney, Senior Project Engineer
 
M. Hardgrove, Resident Inspector
 
Approved By:
Jonathan E. Greives, Chief
Projects Branch 4
Division of Operating Reactor Safety


=SUMMARY=
=SUMMARY=
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licens ees performance by conducting a biennial problem identification and resolution inspection at Limerick Generating Station, Units 1 and 2, in accordance with the Reactor Oversight Process.
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Limerick Generating Station, Units 1 and 2, in accordance with the Reactor Oversight Process.


The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
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.
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=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 their attached revision histories are located on the public website at http://www.nrc.gov/reading -
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 reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
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 reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Due to COVID-19 Public Health Emergency concerns, the inspection was performed using a hybrid approach, with some portions, where appropriate, were performed off-site. The inspection documented below met the objectives and requirements for completion of the IP.
Due to COVID -19 Public Health Emergency concerns, the inspection was performed using a hybrid approach, with some portions, where appropriate, were performed off -site. Th e inspection documented below met the objectives and requirements for completion of the IP.


==OTHER ACTIVITIES - BASELINE==
==OTHER ACTIVITIES - BASELINE==
===71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)===
===71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)===
{{IP sample|IP=IP 71152|count=1}}
{{IP sample|IP=IP 71152|count=1}}
: (1) The team performed a biennial assessment of the effectiveness of Constellation Energy Generation, LLCs (Constellations) problem identification and resolution program, use of operating experience, self -assessments and audits, and safety conscious work environm ent.
: (1) The team performed a biennial assessment of the effectiveness of Constellation Energy Generation, LLCs (Constellations) problem identification and resolution program, use of operating experience, self-assessments and audits, and safety conscious work environment.
* Problem Identification and Resolution Effectiveness: The team assessed the effectiveness of Constellations problem identification and resolution program in identifying, prioritizing, evaluating, and correcting problems. The team also conducted a five-year review of Unit 1 and Unit 2 emergency diesel generator emergency start relay replacements and changes to Unit 1 and Unit 2 moisture carryover operating limit basis.
* Problem Identification and Resolution Effectiveness: The team assessed the effectiveness of Constellations problem identification and resolution program in identifying, prioritizing, evaluating, and correcting problems. The team also conducted a five-year review of Unit 1 and Unit 2 emergency diesel generator emergency start relay replacements and changes to Unit 1 and Unit 2 moisture carryover operating limit basis.
* Operating Experience: The team assessed the effectiveness of Constellation's processes for use of operating experience.
* Operating Experience: The team assessed the effectiveness of Constellation's processes for use of operating experience.
* Self-Assessments and Audits: The team assessed the effectiveness of Constellations identification and correction of problems identified through audits and self -assessments.
* Self-Assessments and Audits: The team assessed the effectiveness of Constellations identification and correction of problems identified through audits and self-assessments.
* Safety Conscious Work Environment: The team assessed the effectiveness of the stations programs to establish and maintain a safety conscious work environm ent.
* Safety Conscious Work Environment: The team assessed the effectiveness of the stations programs to establish and maintain a safety conscious work environment.


==INSPECTION RESULTS==
==INSPECTION RESULTS==
Assessment 71152B Problem Identification and Resolution Program Effectiveness -
Assessment 71152B Problem Identification and Resolution Program Effectiveness -  
 
Problem Identification : The team determ ined that Constellation identified issues and entered them into the problem identification and resolution program at a low threshold.


Problem Prioritization and Evaluation: Based on the samples reviewed, the team det erm ined that, in general, Constellation appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem.
Problem Identification: The team determined that Constellation identified issues and entered them into the problem identification and resolution program at a low threshold.


In most cases, Constellation appropriately screened issue reports (IRs) for operability and reportability, categorized IRs by significance, and assigned actions to the appropriate department for evaluation and resolution.
Problem Prioritization and Evaluation: Based on the samples reviewed, the team determined that, in general, Constellation appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. In most cases, Constellation appropriately screened issue reports (IRs) for operability and reportability, categorized IRs by significance, and assigned actions to the appropriate department for evaluation and resolution.


However, the team identified two minor performance deficiencies regarding Constellation's prioritization and evaluation of issues. The first minor performance deficiency was related to the classification of Maintenance Rule functional failures as conditions adverse to quality in the problem identification and resolution program. The second minor performance deficiency was related to the stations evaluation of a low safety significant (LSS) trend in accordance with the Maintenance Rule program. Additional details about these minor performance deficiencies are included later in this report.
However, the team identified two minor performance deficiencies regarding Constellation's prioritization and evaluation of issues. The first minor performance deficiency was related to the classification of Maintenance Rule functional failures as conditions adverse to quality in the problem identification and resolution program. The second minor performance deficiency was related to the stations evaluation of a low safety significant (LSS) trend in accordance with the Maintenance Rule program. Additional details about these minor performance deficiencies are included later in this report.


Corrective Actions : The team determined that the overall problem identification and resolution program performance related to resolving problems was effective.
Corrective Actions: The team determined that the overall problem identification and resolution program performance related to resolving problems was effective. In general, Constellation implemented corrective actions to resolve problems in a timely manner.
 
In general, Constellation implemented corrective actions to resolve problems in a timely manner.


Assessment 71152B Use of Operating Experience: The team determined that Constellation appropriately evaluated industry operating experience for its relevance to Limerick Generating Station.
Assessment 71152B Use of Operating Experience: The team determined that Constellation appropriately evaluated industry operating experience for its relevance to Limerick Generating Station.
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While the team determined the station appropriately evaluated industry and NRC operating experience, the team identified one observation related to the dissemination of operating experience for Maintenance Rule LSS trends externally to the industry.
While the team determined the station appropriately evaluated industry and NRC operating experience, the team identified one observation related to the dissemination of operating experience for Maintenance Rule LSS trends externally to the industry.


Self-Assessments and Audits: The team reviewed a sample of self -assessments and audits to assess whether Constellation was identifying and addressing performance trends. The team concluded that Constellation had an effective self -assessment and audit process.
Self-Assessments and Audits: The team reviewed a sample of self-assessments and audits to assess whether Constellation was identifying and addressing performance trends. The team concluded that Constellation had an effective self-assessment and audit process.


Assessment 71152B Safety Conscious Work Environment: The team interviewed approximately 24 individuals.
Assessment 71152B Safety Conscious Work Environment: The team interviewed approximately 24 individuals.
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The purpose of these interviews was to evaluate the willingness of Constellation staff to raise nuclear safety issues; to evaluate the perceived effectiveness of the problem identification and resolution program at resolving identified problems; and to evaluate Constellation's safety conscious work environment. The personnel interviewed were randomly selected by the team from the Operations, Engineering, Maintenance, Security, Chemistry, Radiation Protection, and Emergency Preparedness work groups. To supplement these discussions, the team interviewed the Employee Concerns Program (ECP) representative to assess his perception of the site employees' willingness to raise nuclear safety concerns. The team also reviewed the ECP case log and select case files.
The purpose of these interviews was to evaluate the willingness of Constellation staff to raise nuclear safety issues; to evaluate the perceived effectiveness of the problem identification and resolution program at resolving identified problems; and to evaluate Constellation's safety conscious work environment. The personnel interviewed were randomly selected by the team from the Operations, Engineering, Maintenance, Security, Chemistry, Radiation Protection, and Emergency Preparedness work groups. To supplement these discussions, the team interviewed the Employee Concerns Program (ECP) representative to assess his perception of the site employees' willingness to raise nuclear safety concerns. The team also reviewed the ECP case log and select case files.


All individuals interviewed indicated that they would raise safety concerns. All individuals felt that their management was receptive to receiving safety concerns and generally addressed them promptly, commensurate with the significance of the concern. Interviewees indicated they were adequately trained and proficient on initiating condition reports. All interviewees were aware of Constellation's ECP, stated they would use the program if necessary, and expressed confidence that their confidentiality would be maintained if they brought issues to the ECP. When asked whether there have been any instances where individuals experienced retaliation or other negative reaction for raising safety concerns, all individuals interviewed stated that they had neither experienced nor heard of an instance of retaliati on at the site.
All individuals interviewed indicated that they would raise safety concerns. All individuals felt that their management was receptive to receiving safety concerns and generally addressed them promptly, commensurate with the significance of the concern. Interviewees indicated they were adequately trained and proficient on initiating condition reports. All interviewees were aware of Constellation's ECP, stated they would use the program if necessary, and expressed confidence that their confidentiality would be maintained if they brought issues to the ECP. When asked whether there have been any instances where individuals experienced retaliation or other negative reaction for raising safety concerns, all individuals interviewed stated that they had neither experienced nor heard of an instance of retaliation at the site.


The team determined that the processes in place to mitigate potential safety conscious work environment issues were adequately implemented.
The team determined that the processes in place to mitigate potential safety conscious work environment issues were adequately implemented.


Minor Performance Deficiency 71152B Minor Performance Deficiency: The team identified one minor performance deficiency related to the classification of Maintenance Rule functional failures as conditions adverse to quality in the problem identification and resolution program.
Minor Performance Deficiency 71152B Minor Performance Deficiency: The team identified one minor performance deficiency related to the classification of Maintenance Rule functional failures as conditions adverse to quality in the problem identification and resolution program. Step 4.6.4.3 of procedure PI-AA-120, Issue Identification and Screening Process, directs the Station Ownership Committee to coordinate with line department representatives to identify programmatic or organizational impacts such as Maintenance Rule functional failures or potential Maintenance Rule functional failures. Further, Step 4.6.6.3 directs the Station Ownership Committee to determine the significance of corrective action program issues in accordance with Attachment 2, Issue Report Level and Class Criteria. In the Significance Level 3 guidance of Attachment 2, the Asset Management-Equipment Reliability examples list Maintenance Rule functional failure or potential Maintenance Rule a(1) Condition, in accordance with Maintenance Rule procedure.
 
Step 4.6.4.3 of procedure PI-AA-120, Issue I dentification and Screening Process, directs the Station Ownership Committee to coordinate with line department representatives to identify programmatic or organizational impacts such as Maintenance Rule functional failures or potential Maintenance Rule functional failures.
 
Further, Step 4.6.6.3 directs the Station Ownership Committee to determine the significance of corrective action program issues in accordance with Attachment 2, Issue Report Level and Class Criteria. In the Significance Level 3 guidance of Attachm ent 2, the Asset Management -Equipment Reliability examples list Maintenance Rule functional failure or potential Maintenance Rule a(1) Condition, in accordance with Maintenance Rule procedure.
 
Contrary to that PI-AA-120 guidance, the team i dentified two potential Maintenance Rule a(1)conditions that were classified as Significance Level 4. IR 4364623, written for a LSS trend in H2O2 analyzer calibration failures, and IR 4450131, written for a condition monitoring event due to a service air compressor trip, each documented potential Maintenance Rule (a)(1)conditions and should have been subsequently classified as S ignificance Level 3.


Screening: The inspectors determined the performance deficiency was minor.
Contrary to that PI-AA-120 guidance, the team identified two potential Maintenance Rule a(1)conditions that were classified as Significance Level 4. IR 4364623, written for a LSS trend in H2O2 analyzer calibration failures, and IR 4450131, written for a condition monitoring event due to a service air compressor trip, each documented potential Maintenance Rule (a)(1)conditions and should have been subsequently classified as Significance Level 3.


Because although those IRs wer e classified as S ignificance Level 4, existing work requests to address those issues would have been acceptable corrective actions to address the conditions adverse to quality. This minor performance deficiency is captured in IR 4478628.
Screening: The inspectors determined the performance deficiency was minor. Because although those IRs were classified as Significance Level 4, existing work requests to address those issues would have been acceptable corrective actions to address the conditions adverse to quality. This minor performance deficiency is captured in IR 4478628.


Minor Performance Deficiency 71152B Minor Performance Deficiency: The team identified one minor performance deficiency related to the stations evaluation of a LSS trend in accordance with the Maintenance Rule program.
Minor Performance Deficiency 71152B Minor Performance Deficiency: The team identified one minor performance deficiency related to the stations evaluation of a LSS trend in accordance with the Maintenance Rule program.


Step 4.2.5.1 and 4.2.5.5 of ER -AA-320-1004, Mainte nance Rule 18-10 - Performance Monitoring and Dispositioning between (a)(1) and (a)(2), directs the system manager to obtain LSS events for monitoring and trending from station IRs and determine if an adverse trend in structure, system, or component performance is identified. Performance monitoring identified a LSS trend in H2O2 analyzer calibration failures as documented in IRs 4263434 and 4364623. Step 4.4.2. requires an (a)(1) determination when any of the conditions in step 4.4.1 exist. Step 4.4.1 lists LSS structure, system, or component exhibiting an unacceptable trend in performance. Contrary to the ER-AA-320-1004 guidance, the team identified the documented (a)(1) determination for IR 4364623 was not in compliance with the Maintenance Rule process in retaining the system in (a)(2) status based on the addition of preventiv e maintenance as recommended by the vendor.
Step 4.2.5.1 and 4.2.5.5 of ER-AA-320-1004, Maintenance Rule 18-10 - Performance Monitoring and Dispositioning between (a)(1) and (a)(2), directs the system manager to obtain LSS events for monitoring and trending from station IRs and determine if an adverse trend in structure, system, or component performance is identified. Performance monitoring identified a LSS trend in H2O2 analyzer calibration failures as documented in IRs 4263434 and 4364623. Step 4.4.2. requires an (a)(1) determination when any of the conditions in step 4.4.1 exist. Step 4.4.1 lists LSS structure, system, or component exhibiting an unacceptable trend in performance. Contrary to the ER-AA-320-1004 guidance, the team identified the documented (a)(1) determination for IR 4364623 was not in compliance with the Maintenance Rule process in retaining the system in (a)(2) status based on the addition of preventive maintenance as recommended by the vendor.


Screening: The inspectors determined the performance deficiency was minor.
Screening: The inspectors determined the performance deficiency was minor. The H2O2 analyzer system was appropriately in (a)(2) status, but not for the reasons determined in the (a)(1) determination. It was later determined during this inspection that an adverse LSS trend did not exist because one of the calibration failures did not result in a loss of function, and as such the (a)(1) determination was unnecessarily performed. This minor performance deficiency is captured in IR 4478628.


The H2O2 analyzer system was appropriately in (a)(2) status, but not for the reasons determined in the (a)(1) determination. It was later determined during this inspection that an adverse LSS trend did not exist because one of the calibration failures did not result in a loss of function, and as such the (a)(1) determination was unnecessarily performed. This minor performance deficiency is captured in IR 4478628.
Observation: Maintenance Rule Low Safety Significant Trend Not Disseminated as Operating Experience 71152B The team identified one observation related to the dissemination of operating experience for Maintenance Rule LSS trends. Step 4.6.4.4.A of procedure PI-AA-120 directs the Station Ownership Committee to determine operating experience for Significance Level 1, 2, or 3 issues in accordance with PI-AA-115-1004. Step 4.2.1 of PI-AA-115-1004, Processing of NEB and IRIS Reports, states to screen plant events for sharing with the industry that meet INPO 19-002 reporting criteria, and that Form 3 of that procedure may be used as a guide. The criteria in Form 3, of PI-AA-115-1004-F-03, IRIS Report Screening Form, are derived from INPO 19-002, Industry Reporting and Information System (IRIS) Reporting Requirements, and list:
 
* All Maintenance Rule functional failures
Observation: Maintenance Rule Low Safety Significant Trend Not Disseminated 71152B as Operating Experience The team identified one observation related to the dissemination of operating experience for Maintenance Rule LSS trends. Step 4.6.4.4.A of procedure PI-AA-120 directs the Station Ownership Committee to determine operating experience for Significance Level 1, 2, or 3 issues in accordance with PI -AA-115-1004. Step 4.2.1 of PI -AA-115-1004, Processing of NEB and IRIS Reports, states to screen plant events for sharing with the industry that meet INPO 19-002 reporting criteria, and that Form 3 of that procedure may be used as a guide. The criteria in Form 3, of PI -AA-115-1004-F- 03, IRIS Report Screening Form, are derived from INPO 19-002, Industry Reporting and Information System (IRIS) Reporting Requirements, and list:
* All Maintenance Rule funct ional failures
* Maintenance Rule condition monitoring criteria exceeded
* Maintenance Rule condition monitoring criteria exceeded
* Maintenance Rule plant -level monitoring criteria exceeded
* Maintenance Rule plant-level monitoring criteria exceeded  


INPO 19-002 and therefore Form 3 of PI -AA-115-1004 have not been updated to reflect a major revision to the Maintenance Rule program known as Maintenance Rule 2.0, so LSS trend, a fourth potential Maintenance Rule (a)(1) condition, is not listed. As a result, IR 4364623, written for a Maintenance Rule LSS trend in H 2O2 analyzer calibration failures, did not have an IRIS Report generated to disseminate that operating experience.
INPO 19-002 and therefore Form 3 of PI-AA-115-1004 have not been updated to reflect a major revision to the Maintenance Rule program known as Maintenance Rule 2.0, so LSS trend, a fourth potential Maintenance Rule (a)(1) condition, is not listed. As a result, IR 4364623, written for a Maintenance Rule LSS trend in H2O2 analyzer calibration failures, did not have an IRIS Report generated to disseminate that operating experience.


==EXIT MEETINGS AND DEBRIEFS==
==EXIT MEETINGS AND DEBRIEFS==
The inspectors verified no proprietary information was retained or documented in this report.
The inspectors verified no proprietary information was retained or documented in this report.
* On February 18, 2022, the inspector s presented the biennial problem identification and resolution inspection results to Mr. Michael Gillin, Plant Manager, and other members of the licensee staff.
* On February 18, 2022, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Michael Gillin, Plant Manager, and other members of the licensee staff.


=DOCUMENTS REVIEWED=
=DOCUMENTS REVIEWED=


Inspection Type Designation Description or Title Revision or
Inspection
Procedure Date
Procedure
71152B Corrective Action CAPE 4337800 Li1R18LL: Estimated Dose Impact of Co Carryover 07/08/2020
Type
Docum ents CAPE 4346892 Unit 1 Suppresion Pool High Oxygen Concentration 07/14/2020
Designation
CAPE 4372283 1B ASD Coolant Leak 11/19/2020
Description or Title
CAPE 4377981 Excavation work caused leak in 36 inch Service water pipe 02/24/2021
Revision or
CAPE 4410585 Circulating Water Leak From Piping 01/06/2021
Date
CAPE 4423923 2R16 WHR Violation 06/24/2021
71152B
CAPE 4437521 FME - "C" MSLP PM identified missing parts 09/16/2021
Corrective Action
ECAPE 4145616 1B ASD Coolant System Leak 02/23/2021
Documents
ECAPE 4202624 Limerick U1 Fuel Cladding Defect Identified By Routine 02/02/2021
CAPE 4337800
Li1R18LL: Estimated Dose Impact of Co Carryover
07/08/2020
CAPE 4346892
Unit 1 Suppresion Pool High Oxygen Concentration
07/14/2020
CAPE 4372283
1B ASD Coolant Leak
11/19/2020
CAPE 4377981
Excavation work caused leak in 36 inch Service water pipe
2/24/2021
CAPE 4410585
Circulating Water Leak From Piping
01/06/2021
CAPE 4423923
2R16 WHR Violation
06/24/2021
CAPE 4437521
FME - "C" MSLP PM identified missing parts
09/16/2021
ECAPE 4145616
1B ASD Coolant System Leak
2/23/2021
ECAPE 4202624
Limerick U1 Fuel Cladding Defect Identified By Routine
Chemistry Offgas Sampling
Chemistry Offgas Sampling
Issue Reports 4337001, 4364623, 4372283, 4391308, 4430911, 4443754,
2/02/2021
(IRs) 4448242, 4450131
Issue Reports  
RCR 4337051 HV-051-1F024A Inoperable due to Foreign Material 06/15/2020
(IRs)
RCR 4384039 Unexpected Closure of 1B Inboard MSIV (HV-041-1F022B) 01/18/2021
4337001, 4364623, 4372283, 4391308, 4430911, 4443754,
4448242, 4450131
RCR 4337051
HV-051-1F024A Inoperable due to Foreign Material
06/15/2020
RCR 4384039
Unexpected Closure of 1B Inboard MSIV (HV-041-1F022B)
Resulted in Automatic High Reactor Pressure Scram
Resulted in Automatic High Reactor Pressure Scram
RCR 4384739 Unit 1 HPCI and RCIC not Aligned for Service Per GP-2 01/08/2021
01/18/2021
Corrective Action Issue Reports 4475545, 4475826, 4475858, 4475861, 4475863, 4475866,
RCR 4384739
Docum ents (IRs) 4477463, 4476112, 4478242, 4478628
Unit 1 HPCI and RCIC not Aligned for Service Per GP-2
01/08/2021
Corrective Action
Documents
Resulting from
Resulting from
Inspection
Inspection
Engineering 625675 Unit 1 - ASD Obsolescence and Cooling Upgrades 1
Issue Reports
Changes 625675 Unit 1 - ASD Obsolescence and Cooling Upgrades 2
(IRs)
25675 Unit 1 - ASD Obsolescence and Cooling Upgrades 3
4475545, 4475826, 4475858, 4475861, 4475863, 4475866,
Engineering 4343534 2020 Maintenance Rule Periodic (a)(3) Assessment 0
4477463, 4476112, 4478242, 4478628
Evaluations AR 4425565 Limerick GNF2 1C19 EOC MCO Operating Limit Increase 05/25/2021
Engineering
Miscellaneous LG-MRULE-005 LGS Maintenance Rule Risk Ranking 4
Procedures AD-AA-3000 Nuclear Risk Management Process 5
CC-AA-10 Configuration Control Process Description 10
CC-AA-102 Design Input and Configuration Change Impact Screening 33
CC-AA-103 Configuration Change Control for Permanent Physical Plant 33
Changes
Changes
25675
Unit 1 - ASD Obsolescence and Cooling Upgrades
25675
Unit 1 - ASD Obsolescence and Cooling Upgrades
25675
Unit 1 - ASD Obsolescence and Cooling Upgrades
Engineering
Evaluations
4343534
20 Maintenance Rule Periodic (a)(3) Assessment
AR 4425565
Limerick GNF2 1C19 EOC MCO Operating Limit Increase
05/25/2021
Miscellaneous
LG-MRULE-005
LGS Maintenance Rule Risk Ranking
Procedures
AD-AA-3000
Nuclear Risk Management Process
CC-AA-10
Configuration Control Process Description
CC-AA-102
Design Input and Configuration Change Impact Screening
CC-AA-103
Configuration Change Control for Permanent Physical Plant
Changes


Inspection Type Designation Description or Title Revision or
Inspection
Procedure Date
Procedure
CC-AA-103-100 Configuration Change Control for Permanent Physical Plant 2
Type
Designation
Description or Title
Revision or
Date
CC-AA-103-100
Configuration Change Control for Permanent Physical Plant
Changes
Changes
CC-AA-103-F-02 Engineering Change Material List 1
CC-AA-103-F-02
ER-AA-320 Maintenance Rule Implementation per NEI 18-10 0
Engineering Change Material List
ER-AA-320-1003 Maintenance Rule 18-10 - Failure Definition 0
ER-AA-320
ER-AA-320-1004 Maintenance Rule 18-10 - Performance Monitoring and 1
Maintenance Rule Implementation per NEI 18-10
ER-AA-320-1003
Maintenance Rule 18-10 - Failure Definition
ER-AA-320-1004
Maintenance Rule 18-10 - Performance Monitoring and
Dispositioning between (a)(1) and (a)(2)
Dispositioning between (a)(1) and (a)(2)
ER-LG-310-1010 Maintenance Rule Implementation Limerick Generating 23
ER-LG-310-1010
Maintenance Rule Implementation Limerick Generating
Station
Station
IP-ENG-001 Common Design Package 1
IP-ENG-001
MA-AA-1000 Conduct of Maintenance Manual 23
Common Design Package
MA-AA-716-017 Station Rework Reduction Program 11
MA-AA-1000
NO-AA-10 Quality Assurance Topical Report 97
Conduct of Maintenance Manual
NO-AA-210-1001 Nuclear Oversight Audit Handbook 26
MA-AA-716-017
NO-AA-300 Inspection Planning and Execution of Quality Inspection 6
Station Rework Reduction Program
NO-AA-10
Quality Assurance Topical Report
NO-AA-210-1001
Nuclear Oversight Audit Handbook
NO-AA-300
Inspection Planning and Execution of Quality Inspection
Activities
Activities
OP-AA-102-103 Operator Work-Around Program 5
OP-AA-102-103
OP-AA-102-103-Operator Burden and Plant Significant Decisions Impact 8
Operator Work-Around Program
1001 Assessment Program
OP-AA-102-103-
OU-AA-101 Refuel Outage Managem ent 28
1001
OU-AA-102 Forced Maintenance Outage Managem ent 12
Operator Burden and Plant Significant Decisions Impact
PI-AA-101-1001 Performance Monitoring and Analysis Manual 3
Assessment Program
PI-AA-1012 Safety Culture Monitoring 3
OU-AA-101
PI-AA-115 Operating Experience Program 5
Refuel Outage Management
PI-AA-115-1004 Processing of NEB and IRIS Reports 8
OU-AA-102
PI-AA-120 Issue Identification and Screening Process 11
Forced Maintenance Outage Management
PI-AA-125 Corrective Action Program (CAP) Procedure 7
PI-AA-101-1001
PI-AA-125-1001 Root Cause Analysis Manual 6
Performance Monitoring and Analysis Manual
PI-AA-125-1003 Corrective Action Program Evaluation Manual 6
PI-AA-1012
PI-AA-125-1004 Effectiveness Review Manual 2
Safety Culture Monitoring
PI-AA-125-1006 Investigation Techniques Manual 5
PI-AA-115
PI-AA-126-1001 Self-A sse ssm en t s 5
Operating Experience Program
Self-A sse ssm en t s 4308207 Preparation for NRC Problem Identification & Resolution 05/14/2020
PI-AA-115-1004
Processing of NEB and IRIS Reports
PI-AA-120
Issue Identification and Screening Process
PI-AA-125
Corrective Action Program (CAP) Procedure
PI-AA-125-1001
Root Cause Analysis Manual
PI-AA-125-1003
Corrective Action Program Evaluation Manual
PI-AA-125-1004
Effectiveness Review Manual
PI-AA-125-1006
Investigation Techniques Manual
PI-AA-126-1001
Self-Assessments
Self-Assessments 4308207
Preparation for NRC Problem Identification & Resolution
05/14/2020  


Inspection Type Designation Description or Title Revision or
Inspection
Procedure Date
Procedure
(PI&R) NRC Inspection
Type
4454542 Pre-PI&R Self Assessment 01/24/2022
Designation
NOSA-COMP-21-2021 Corrective Action Program Comparative Audit Report 10/29/2021
Description or Title
Revision or
Date  
(PI&R) NRC Inspection
4454542
Pre-PI&R Self Assessment
01/24/2022
NOSA-COMP-21-
  (AR 4378299)
  (AR 4378299)
NOSA-LIM-21-05 Corrective Action Program Audit Report 09/01/2021
21 Corrective Action Program Comparative Audit Report
(AR 4435732)
10/29/2021
Work Orders 4965694
NOSA-LIM-21-05  
 
(AR 4435732)
9
Corrective Action Program Audit Report
09/01/2021
Work Orders
4965694
}}
}}

Latest revision as of 17:49, 27 November 2024

Biennial Problem Identification and Resolution Inspection Report 05000352/2022010 and 05000353/2022010
ML22068A165
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 03/09/2022
From: Jon Greives
Division of Operating Reactors
To: Rhoades D
Constellation Energy Generation, Constellation Nuclear
Haney S
References
IR 2022010
Download: ML22068A165 (12)
v • d • e


Text

March 9, 2022

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000352/2022010 AND 05000353/2022010

Dear Mr. Rhoades:

On February 18, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Limerick Generating Station, Units 1 and 2 and discussed the results of this inspection with Mr. Michael Gillin, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.

Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

No findings or violations of more than minor significance were identified during this inspection. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

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

Docket Nos. 05000352 and 05000353 License Nos. NPF-39 and NPF-85

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000352 and 05000353

License Numbers:

NPF-39 and NPF-85

Report Numbers:

05000352/2022010 and 05000353/2022010

Enterprise Identifier: I-2022-010-0013

Licensee:

Constellation Energy Generation, LLC

Facility:

Limerick Generating Station, Units 1 and 2

Location:

Sanatoga, PA 19464

Inspection Dates:

January 31, 2022 to February 18, 2022

Inspectors:

L. Casey, Senior Project Engineer

L. Grimes, Resident Inspector

S. Haney, Senior Project Engineer

M. Hardgrove, Resident Inspector

Approved By:

Jonathan E. Greives, Chief

Projects Branch 4

Division of Operating Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Limerick Generating Station, Units 1 and 2, in accordance with the Reactor Oversight Process.

The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Due to COVID-19 Public Health Emergency concerns, the inspection was performed using a hybrid approach, with some portions, where appropriate, were performed off-site. The inspection documented below met the objectives and requirements for completion of the IP.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)

Main article: IP 71152
(1) The team performed a biennial assessment of the effectiveness of Constellation Energy Generation, LLCs (Constellations) problem identification and resolution program, use of operating experience, self-assessments and audits, and safety conscious work environment.
  • Problem Identification and Resolution Effectiveness: The team assessed the effectiveness of Constellations problem identification and resolution program in identifying, prioritizing, evaluating, and correcting problems. The team also conducted a five-year review of Unit 1 and Unit 2 emergency diesel generator emergency start relay replacements and changes to Unit 1 and Unit 2 moisture carryover operating limit basis.
  • Operating Experience: The team assessed the effectiveness of Constellation's processes for use of operating experience.
  • Self-Assessments and Audits: The team assessed the effectiveness of Constellations identification and correction of problems identified through audits and self-assessments.
  • Safety Conscious Work Environment: The team assessed the effectiveness of the stations programs to establish and maintain a safety conscious work environment.

INSPECTION RESULTS

Assessment 71152B Problem Identification and Resolution Program Effectiveness -

Problem Identification: The team determined that Constellation identified issues and entered them into the problem identification and resolution program at a low threshold.

Problem Prioritization and Evaluation: Based on the samples reviewed, the team determined that, in general, Constellation appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. In most cases, Constellation appropriately screened issue reports (IRs) for operability and reportability, categorized IRs by significance, and assigned actions to the appropriate department for evaluation and resolution.

However, the team identified two minor performance deficiencies regarding Constellation's prioritization and evaluation of issues. The first minor performance deficiency was related to the classification of Maintenance Rule functional failures as conditions adverse to quality in the problem identification and resolution program. The second minor performance deficiency was related to the stations evaluation of a low safety significant (LSS) trend in accordance with the Maintenance Rule program. Additional details about these minor performance deficiencies are included later in this report.

Corrective Actions: The team determined that the overall problem identification and resolution program performance related to resolving problems was effective. In general, Constellation implemented corrective actions to resolve problems in a timely manner.

Assessment 71152B Use of Operating Experience: The team determined that Constellation appropriately evaluated industry operating experience for its relevance to Limerick Generating Station.

Constellation appropriately incorporated both internal and external operating experience into plant procedures and processes, as well as lessons learned for training and pre-job briefs.

While the team determined the station appropriately evaluated industry and NRC operating experience, the team identified one observation related to the dissemination of operating experience for Maintenance Rule LSS trends externally to the industry.

Self-Assessments and Audits: The team reviewed a sample of self-assessments and audits to assess whether Constellation was identifying and addressing performance trends. The team concluded that Constellation had an effective self-assessment and audit process.

Assessment 71152B Safety Conscious Work Environment: The team interviewed approximately 24 individuals.

The purpose of these interviews was to evaluate the willingness of Constellation staff to raise nuclear safety issues; to evaluate the perceived effectiveness of the problem identification and resolution program at resolving identified problems; and to evaluate Constellation's safety conscious work environment. The personnel interviewed were randomly selected by the team from the Operations, Engineering, Maintenance, Security, Chemistry, Radiation Protection, and Emergency Preparedness work groups. To supplement these discussions, the team interviewed the Employee Concerns Program (ECP) representative to assess his perception of the site employees' willingness to raise nuclear safety concerns. The team also reviewed the ECP case log and select case files.

All individuals interviewed indicated that they would raise safety concerns. All individuals felt that their management was receptive to receiving safety concerns and generally addressed them promptly, commensurate with the significance of the concern. Interviewees indicated they were adequately trained and proficient on initiating condition reports. All interviewees were aware of Constellation's ECP, stated they would use the program if necessary, and expressed confidence that their confidentiality would be maintained if they brought issues to the ECP. When asked whether there have been any instances where individuals experienced retaliation or other negative reaction for raising safety concerns, all individuals interviewed stated that they had neither experienced nor heard of an instance of retaliation at the site.

The team determined that the processes in place to mitigate potential safety conscious work environment issues were adequately implemented.

Minor Performance Deficiency 71152B Minor Performance Deficiency: The team identified one minor performance deficiency related to the classification of Maintenance Rule functional failures as conditions adverse to quality in the problem identification and resolution program. Step 4.6.4.3 of procedure PI-AA-120, Issue Identification and Screening Process, directs the Station Ownership Committee to coordinate with line department representatives to identify programmatic or organizational impacts such as Maintenance Rule functional failures or potential Maintenance Rule functional failures. Further, Step 4.6.6.3 directs the Station Ownership Committee to determine the significance of corrective action program issues in accordance with Attachment 2, Issue Report Level and Class Criteria. In the Significance Level 3 guidance of Attachment 2, the Asset Management-Equipment Reliability examples list Maintenance Rule functional failure or potential Maintenance Rule a(1) Condition, in accordance with Maintenance Rule procedure.

Contrary to that PI-AA-120 guidance, the team identified two potential Maintenance Rule a(1)conditions that were classified as Significance Level 4. IR 4364623, written for a LSS trend in H2O2 analyzer calibration failures, and IR 4450131, written for a condition monitoring event due to a service air compressor trip, each documented potential Maintenance Rule (a)(1)conditions and should have been subsequently classified as Significance Level 3.

Screening: The inspectors determined the performance deficiency was minor. Because although those IRs were classified as Significance Level 4, existing work requests to address those issues would have been acceptable corrective actions to address the conditions adverse to quality. This minor performance deficiency is captured in IR 4478628.

Minor Performance Deficiency 71152B Minor Performance Deficiency: The team identified one minor performance deficiency related to the stations evaluation of a LSS trend in accordance with the Maintenance Rule program.

Step 4.2.5.1 and 4.2.5.5 of ER-AA-320-1004, Maintenance Rule 18-10 - Performance Monitoring and Dispositioning between (a)(1) and (a)(2), directs the system manager to obtain LSS events for monitoring and trending from station IRs and determine if an adverse trend in structure, system, or component performance is identified. Performance monitoring identified a LSS trend in H2O2 analyzer calibration failures as documented in IRs 4263434 and 4364623. Step 4.4.2. requires an (a)(1) determination when any of the conditions in step 4.4.1 exist. Step 4.4.1 lists LSS structure, system, or component exhibiting an unacceptable trend in performance. Contrary to the ER-AA-320-1004 guidance, the team identified the documented (a)(1) determination for IR 4364623 was not in compliance with the Maintenance Rule process in retaining the system in (a)(2) status based on the addition of preventive maintenance as recommended by the vendor.

Screening: The inspectors determined the performance deficiency was minor. The H2O2 analyzer system was appropriately in (a)(2) status, but not for the reasons determined in the (a)(1) determination. It was later determined during this inspection that an adverse LSS trend did not exist because one of the calibration failures did not result in a loss of function, and as such the (a)(1) determination was unnecessarily performed. This minor performance deficiency is captured in IR 4478628.

Observation: Maintenance Rule Low Safety Significant Trend Not Disseminated as Operating Experience 71152B The team identified one observation related to the dissemination of operating experience for Maintenance Rule LSS trends. Step 4.6.4.4.A of procedure PI-AA-120 directs the Station Ownership Committee to determine operating experience for Significance Level 1, 2, or 3 issues in accordance with PI-AA-115-1004. Step 4.2.1 of PI-AA-115-1004, Processing of NEB and IRIS Reports, states to screen plant events for sharing with the industry that meet INPO 19-002 reporting criteria, and that Form 3 of that procedure may be used as a guide. The criteria in Form 3, of PI-AA-115-1004-F-03, IRIS Report Screening Form, are derived from INPO 19-002, Industry Reporting and Information System (IRIS) Reporting Requirements, and list:

  • All Maintenance Rule functional failures
  • Maintenance Rule condition monitoring criteria exceeded
  • Maintenance Rule plant-level monitoring criteria exceeded

INPO 19-002 and therefore Form 3 of PI-AA-115-1004 have not been updated to reflect a major revision to the Maintenance Rule program known as Maintenance Rule 2.0, so LSS trend, a fourth potential Maintenance Rule (a)(1) condition, is not listed. As a result, IR 4364623, written for a Maintenance Rule LSS trend in H2O2 analyzer calibration failures, did not have an IRIS Report generated to disseminate that operating experience.

EXIT MEETINGS AND DEBRIEFS

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

  • On February 18, 2022, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Michael Gillin, Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71152B

Corrective Action

Documents

CAPE 4337800

Li1R18LL: Estimated Dose Impact of Co Carryover

07/08/2020

CAPE 4346892

Unit 1 Suppresion Pool High Oxygen Concentration

07/14/2020

CAPE 4372283

1B ASD Coolant Leak

11/19/2020

CAPE 4377981

Excavation work caused leak in 36 inch Service water pipe

2/24/2021

CAPE 4410585

Circulating Water Leak From Piping

01/06/2021

CAPE 4423923

2R16 WHR Violation

06/24/2021

CAPE 4437521

FME - "C" MSLP PM identified missing parts

09/16/2021

ECAPE 4145616

1B ASD Coolant System Leak

2/23/2021

ECAPE 4202624

Limerick U1 Fuel Cladding Defect Identified By Routine

Chemistry Offgas Sampling

2/02/2021

Issue Reports

(IRs)

4337001, 4364623, 4372283, 4391308, 4430911, 4443754,

4448242, 4450131

RCR 4337051

HV-051-1F024A Inoperable due to Foreign Material

06/15/2020

RCR 4384039

Unexpected Closure of 1B Inboard MSIV (HV-041-1F022B)

Resulted in Automatic High Reactor Pressure Scram

01/18/2021

RCR 4384739

Unit 1 HPCI and RCIC not Aligned for Service Per GP-2

01/08/2021

Corrective Action

Documents

Resulting from

Inspection

Issue Reports

(IRs)

4475545, 4475826, 4475858, 4475861, 4475863, 4475866,

4477463, 4476112, 4478242, 4478628

Engineering

Changes

25675

Unit 1 - ASD Obsolescence and Cooling Upgrades

25675

Unit 1 - ASD Obsolescence and Cooling Upgrades

25675

Unit 1 - ASD Obsolescence and Cooling Upgrades

Engineering

Evaluations

4343534

20 Maintenance Rule Periodic (a)(3) Assessment

AR 4425565

Limerick GNF2 1C19 EOC MCO Operating Limit Increase

05/25/2021

Miscellaneous

LG-MRULE-005

LGS Maintenance Rule Risk Ranking

Procedures

AD-AA-3000

Nuclear Risk Management Process

CC-AA-10

Configuration Control Process Description

CC-AA-102

Design Input and Configuration Change Impact Screening

CC-AA-103

Configuration Change Control for Permanent Physical Plant

Changes

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CC-AA-103-100

Configuration Change Control for Permanent Physical Plant

Changes

CC-AA-103-F-02

Engineering Change Material List

ER-AA-320

Maintenance Rule Implementation per NEI 18-10

ER-AA-320-1003

Maintenance Rule 18-10 - Failure Definition

ER-AA-320-1004

Maintenance Rule 18-10 - Performance Monitoring and

Dispositioning between (a)(1) and (a)(2)

ER-LG-310-1010

Maintenance Rule Implementation Limerick Generating

Station

IP-ENG-001

Common Design Package

MA-AA-1000

Conduct of Maintenance Manual

MA-AA-716-017

Station Rework Reduction Program

NO-AA-10

Quality Assurance Topical Report

NO-AA-210-1001

Nuclear Oversight Audit Handbook

NO-AA-300

Inspection Planning and Execution of Quality Inspection

Activities

OP-AA-102-103

Operator Work-Around Program

OP-AA-102-103-

1001

Operator Burden and Plant Significant Decisions Impact

Assessment Program

OU-AA-101

Refuel Outage Management

OU-AA-102

Forced Maintenance Outage Management

PI-AA-101-1001

Performance Monitoring and Analysis Manual

PI-AA-1012

Safety Culture Monitoring

PI-AA-115

Operating Experience Program

PI-AA-115-1004

Processing of NEB and IRIS Reports

PI-AA-120

Issue Identification and Screening Process

PI-AA-125

Corrective Action Program (CAP) Procedure

PI-AA-125-1001

Root Cause Analysis Manual

PI-AA-125-1003

Corrective Action Program Evaluation Manual

PI-AA-125-1004

Effectiveness Review Manual

PI-AA-125-1006

Investigation Techniques Manual

PI-AA-126-1001

Self-Assessments

Self-Assessments 4308207

Preparation for NRC Problem Identification & Resolution

05/14/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

(PI&R) NRC Inspection

4454542

Pre-PI&R Self Assessment

01/24/2022

NOSA-COMP-21-

(AR 4378299)

21 Corrective Action Program Comparative Audit Report

10/29/2021

NOSA-LIM-21-05

(AR 4435732)

Corrective Action Program Audit Report

09/01/2021

Work Orders

4965694

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