IR 05000352/2018002
| ML18221A483 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/09/2018 |
| From: | Jon Greives Reactor Projects Region 1 Branch 4 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| Greives J | |
| References | |
| IR 2018002 | |
| Download: ML18221A483 (28) | |
Text
ust 9, 2018
SUBJECT:
LIMERICK GENERATING STATION - INTEGRATED INSPECTION REPORT 05000352/2018002 AND 05000353/2018002
Dear Mr. Hanson:
On June 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Limerick Generating Station, Units 1 and 2. On July 23, 2018, the NRC inspectors discussed the results of this inspection with Mr. Frank Sturniolo, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
This finding involved a violation of NRC requirements. Additionally, NRC inspectors documented one Severity Level IV violation with no associated finding. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Limerick Generating Station.
In addition, if you disagree with a cross-cutting aspect assignment, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC, 20555-0001; with copies to the Regional Administrator, Region I, and the NRC Resident Inspector at Limerick Generating Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Jonathan E. Greives, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 50-352 and 50-353 License Nos. NPF-39 and NPF-85
Enclosure:
Inspection Report 05000352/2018002 and 05000353/2018002
Inspection Report
Docket Numbers: 50-352 and 50-353 License Numbers: NPF-39 and NPF-85 Report Numbers: 05000352/2018002 and 05000353/2018002 Enterprise Identifier: I-2018-002-0065 Licensee: Exelon Generation Company, LLC Facility: Limerick Generating Station, Units 1 & 2 Location: Sanatoga, PA 19464 Inspection Dates: April 1, 2018 through June 30, 2018 Inspectors: S. Rutenkroger, PhD, Senior Resident Inspector M. Henrion, Acting Resident Inspector C. Safouri, Acting Resident Inspector S. Barber, Senior Project Engineer A. Turilin, Project Engineer H. Anagnostopoulos, Senior Health Physicist L. Andrews, Resident Inspector N. Floyd, Reactor Inspector E. DiPaolo, Senior Reactor Inspector Approved By: Jonathan E. Greives, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Exelons performance at
Limerick Generating Station, Units 1 and 2 by conducting the baseline inspections described in this report in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors.
Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC-identified and self-revealing findings, violations, and additional items are summarized in the table below.
List of Findings and Violations Failure to Conduct Adequate Radiation Surveys and Evaluate Potential Radiological Hazards Cornerstone Significance Cross-cutting Report Aspect Section Occupational Green H.11 - Human 71124.01 Radiation Safety NCV 05000352/2018002-01 Performance -
Opened/Closed Challenge The Unknown A self-revealing Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 20.1501, Surveys and Monitoring: General, was identified when Exelon failed to perform adequate loose surface contamination surveys of the Unit 1 reactor water clean up (RWCU) isolation valve room prior to authorizing work to hang shadow shielding near the HV-051-1F017A valve and also during the conduct of the work itself. Exelon also did not identify very high levels of loose surface contamination on overhead piping and structures which surrounded the work area. This resulted in unplanned internal radiation exposures to three personnel, including a radiation protection technician (RPT) who was assigned to monitor the radiological aspects of the work.
Unit 1 Core Spray Pump Failed to Start Resulting in Condition Prohibited by Technical Specifications Cornerstone Significance Cross-cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71153 NCV 05000352/2018002-02 Opened/Closed The inspectors identified a Severity Level IV NCV of Unit 1 Technical Specification 3.5.1 because one core spray subsystem was inoperable from July 17, 2017, until October 5, 2017.
Specifically, the Unit 1 C core spray pump did not start upon demand during testing and was declared inoperable because the pumps associated 4 kilovolt (kV) circuit breaker closing charging springs were not charged.
Additional Tracking Items Type Issue number Title Report Status Section LER 05000352/2017-004-00 and Core Spray Pump Failed to Start 71153 Closed 05000352/2017-004-01 Resulting in Condition Prohibited by Technical Specifications
TABLE OF CONTENTS
PLANT STATUS
INSPECTION SCOPES
................................................................................................................
REACTOR SAFETY
.................................................................................................................
RADIATION SAFETY
...............................................................................................................
OTHER ACTIVITIES - BASELINE
...........................................................................................
INSPECTION RESULTS
............................................................................................................ 10 THIRD PARTY REVIEWS .......................................................................................................... 18
DOCUMENTS REVIEWED
......................................................................................................... 19
PLANT STATUS
Unit 1 began the inspection period shutdown for a planned refueling outage. The unit was
restarted on April 15, 2018, and returned to 100 percent power on April 20, 2018. On June 9,
2018, the unit was downpowered to 33 percent in single loop operation due to an equipment
issue with the 1B adjustable speed drive. The unit was returned to rated thermal power on
June 11, 2018, and remained at or near rated thermal power for the remainder of the inspection
period.
Unit 2 began the inspection period at rated thermal power. On May 18, 2018, the unit was down
powered to 64 percent to repair a main condenser tube leak and perform required valve testing
and summer readiness activities. The unit was returned to rated thermal power on May 21,
2018, and remained at or near rated thermal power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors also performed plant status activities described
in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152,
Problem Identification and Resolution. The inspectors reviewed selected procedures and
records, observed activities, and interviewed personnel to assess Exelons performance and
compliance with Commission rules and regulations, license conditions, site procedures, and
standards.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown (4 samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) Unit 1 A standby gas treatment system on April 4, 2018
(2) Unit 1 D11 and D14 emergency diesel generators on April 7, 2018
(3) Unit common 201 safeguard transformer, bus, and related switchgear on April 25, 2018
(4) Unit 1 automatic depressurization system on April 30 through May 3, 2018
Complete Walkdown (1 sample)
The inspectors evaluated system configurations during a complete walkdown of the Unit 1
reactor core isolation cooling system.
71111.05A/Q - Fire Protection Annual/Quarterly
Quarterly Inspection (5 samples)
The inspectors evaluated fire protection program implementation in the following selected
areas:
(1) Fire area 34, Unit 1 high pressure coolant injection room, elevation 177, on May 4, 2018
(2) Fire area 2, Unit common 13.2 kV switchgear, elevation 217, on May 11, 2018
(3) Fire area 83, Unit 2 D21 emergency diesel generator and fuel oil day tank room,
elevation 217, on May 21, 2018
(4) Fire areas 54 & 55, Unit 2 residual heat removal heat exchanger and pump rooms 173,
174, 280, and 281, elevations 177 and 201, on June 7, 2018
(5) Fire area 35, Unit 1 A core spray pump room, elevation 177, on June 12, 2018
Annual Inspection (1 sample)
The inspectors evaluated fire brigade performance on June 12, 2018.
71111.07 - Heat Sink Performance
Heat Sink (1 sample)
The inspectors evaluated Exelons monitoring and maintenance of the 1A core spray room
unit cooler heat exchanger system.
71111.08 - Inservice Inspection Activities (1 sample)
The inspectors evaluated Exelons non-destructive examination and welding activities of
Unit 1 by reviewing the following activities and programs from April 2 to April 6, 2018:
(1) Volumetric Examinations
a) Manual ultrasonic testing of main steam loop D nozzle to safe-end weld, APE-1MS-
LD N3D
b) Manual ultrasonic testing of feedwater elbow-to-elbow and elbow-to-pipe welds,
FWA-039 and -040
c) Radiography testing of RWCU pipe-to-pipe welds, FW-56 and FW-58 which involved
welding activities associated with a pressure boundary risk significant system
(2) Visual Examinations
a) In-vessel visual inspection of jet pump components, top guide beams, and feedwater
piping structural attachments
b) Underwater visual inspection in the suppression pool of the core spray C suction
strainer and floor panels
c) General visual examination of the drywell liner
(3) The inspectors reviewed the welding activities associated with the replacement of
degraded piping on line DBB-105-01 in the RWCU system
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
Operator Requalification (1 sample)
The inspectors observed and evaluated licensed operator simulator training scenarios on
May 14, 2018.
Operator Performance (1 sample)
The inspectors observed reactor startup of Unit 1 on April 15, 2018.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness (2 samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated
with the following equipment and/or safety significant functions:
(1) Unit 1 high pressure coolant injection on May 3, 2018
(2) Unit 2 high pressure coolant injection on May 3, 2018
Quality Control (2 samples)
The inspectors evaluated maintenance and quality control activities associated with the
following equipment performance issues:
(1) Unit 2 D23 emergency diesel generator planned maintenance overhaul on February 12
to 16, 2018
(2) Unit 1 high pressure coolant injection main pump gear end outboard mechanical seal
replacement on April 30 to May 1, 2018
71111.13 - Maintenance Risk Assessments and Emergent Work Control (5 samples)
The inspectors evaluated the risk assessments for the following planned and emergent
work activities:
(1) Unit 1 D11 4 kV bus unavailable for planned refueling outage maintenance on April 1,
2018
(2) Unit 1 D11 emergency diesel generator loss of coolant accident/loss of offsite power
test on April 5, 2018
(3) Unit 1 initial plant startup from a planned refueling outage with the containment de-
inerted on April 15, 2018
(4) Unit common B standby gas treatment system unavailable during testing on April 26,
2018
(5) Unit 1 high pressure coolant injection maintenance outage from April 30 to May 2, 2018
71111.15 - Operability Determinations and Functionality Assessments (5 samples)
The inspectors evaluated the following operability determinations and functionality
assessments:
(1) Unit 1 bypass valve number two indicated opening to only 97 percent following Unit 1
main turbine trip on March 26, 2018
(2) Unit common B standby gas treatment system filter heater trip on April 4, 2018
(3) Unit 1 reactor pressure vessel head vent flange indications on April 12, 2018
(4) Unit 1 C low pressure coolant injection valve leakby during operational pressure test on
April 13, 2018
(5) Unit 1 high pressure coolant injection pump leakage from main pump gearbox end
outboard seal on April 17, 2018
71111.18 - Plant Modifications (2 samples)
The inspectors evaluated the following temporary or permanent modifications:
(1) Engineering change package 618876, Unit 1 and Unit 2 carbon dioxide system
modification and abandonment
(2) Engineering chage request 1200019, Unit 1 and Unit 2 main turbine control valve and
reactor protection system channel functional test procedure change
71111.19 - Post Maintenance Testing (9 samples)
The inspectors evaluated post maintenance testing for the following maintenance/repair
activities:
(1) Unit common 11-1011 service water supply check valve planned maintenance on
April 2, 2018
(2) Unit 1 A low pressure coolant injection outboard injection valve maintenance on April 3,
2018
(3) Unit common 220 kV transmission lock substation testing and maintenance on April 25,
2018
(4) Unit 1 high pressure coolant injection pump mechanical seal replacement on May 3,
2018
(5) Unit 1 B residual heat removal pump motor inspection and oil change on May 8, 2018
(6) Unit 1 A residual heat removal heat exchanger inlet cross-tie valve breaker cleaning
and inspection on May 16, 2018
(7) Unit 1 A core spray pump room unit cooler cleaning and inspection on June 14, 2018
(8) Unit 1 high pressure coolant injection pump maintenance on April 18, 2018
(9) Unit common 101 safeguards transformer and bus following installation of third off-site
power source on June 11, 2018
71111.20 - Refueling and Other Outage Activities (1 sample)
The inspectors evaluated Unit 1 refueling outage activities from April 1 to April 18, 2018.
The following portions of the inspection procedure were not performed during this period.
(1) Outage Plan
(2) Shutdown
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Routine (2 samples)
(1) ST-2-074-629-1, Unit 1 average power range monitor number 4 functional check on
April 24, 2018
(2) ST-2-088-324-2, Unit 2 remote shutdown system division 2 residual heat removal test
on June 20, 2018
In-Service (4 samples)
(1) ST-6-092-115-1, Unit 1 D11 emergency diesel generator loss of coolant accident/loss
of offsite power test on April 5, 2018
(2) ST-6-092-312-1, Unit 1 D12 emergency diesel generator slow start operability test run
on April 23, 2018
(3) ST-6-051-234-2, Unit 2 D residual heat removal pump, valve, and flow test on May 23,
2018
(4) ST-6-092-314-1, Unit 1 D14 emergency diesel generator slow start operability test run
on June 18, 2018
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (1 sample)
The inspectors evaluated radiological hazards assessments and controls.
Instructions to Workers (1 sample)
The inspectors evaluated worker instructions.
Contamination and Radioactive Material Control (1 sample)
The inspectors evaluated contamination and radioactive material controls.
Radiological Hazards Control and Work Coverage (1 sample)
The inspectors evaluated radiological hazards control and work coverage.
High Radiation Area and Very High Radiation Area Controls (1 sample)
The inspectors evaluated risk-significant high radiation area and very high radiation area
controls.
Radiation Worker Performance and Radiation Protection Technician Proficiency (1 sample)
The inspectors evaluated radiation worker performance and RPT proficiency.
71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls
Implementation of ALARA and Radiological Work Controls (1 sample)
The inspectors reviewed ALARA practices and radiological work controls by reviewing the
following activities:
(1) ALARA Plan 18-009
(2) ALARA Plan 18-011
(3) ALARA Plan 18-025
(4) ALARA Plan 18-035
(5) ALARA Plan 18-036
(6) ALARA Plan 18-043
Radiation Worker Performance (1 sample)
The inspectors evaluated radiation worker and RPT performance.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Engineering Controls (1 sample)
The inspectors evaluated airborne controls and monitoring.
Use of Respiratory Protection Devices (1 sample)
The inspectors evaluated respiratory protection.
Self-Contained Breathing Apparatus for Emergency Use (1 sample)
The inspectors evaluated the Exelon self-contained breathing apparatus program.
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified Exelons performance indicator submittals listed below for the period
April 1, 2017, through March 31, 2018. (4 samples)
(1) Unit 1 and Unit 2 safety system functional failures
(2) Unit 1 and Unit 2 emergency alternating current power
71152 - Problem Identification and Resolution
Semiannual Trend Review (1 sample)
The inspectors reviewed Exelons corrective action program for trends that might be
indicative of a more significant safety issue.
Annual Follow-up of Selected Issues (2 samples)
The inspectors reviewed Exelons implementation of its corrective action program related to
the following issues:
(1) Issue Report (IR) 4024190, Unit 2 main steam line high radiation alarm likely due to
insufficient foreign material exclusion controls
(2) IR 4059470, Unit 1 C core spray pump failed to start on October 5, 2017 due to circuit
breaker failing to close
71153 - Follow-up of Events and Notices of Enforcement Discretion
Licensee Event Reports (1 sample)
The inspectors evaluated the following licensee event report:
(1) Licensee Event Report 05000352/2017-004-00 and 0500352/2017-004-01, Core
Spray Failed to Start Resulting in Condition Prohibited by Technical Specifications.
The circumstances surrounding this licensee event report are documented in report
Section Inspection Results.
Personnel Performance (1 sample)
The inspectors evaluated response during the following non-routine evolution:
(1) Unit 1 unplanned downpower to 30 percent for single loop operation on June 9,
2018, due to Unit 1 B adjustable speed drive coolant leak on a flexible hose fitting
INSPECTION RESULTS
Failure to Conduct Adequate Radiation Surveys and Evaluate Potential Radiological Hazards
Cornerstone Significance Cross-Cutting Report
Aspect Section
Occupational Green H.11 - Human 71124.01
Radiation Safety NCV 05000352/2018002-01 Performance -
Closed Challenge The
Unknown
A self-revealing Green finding and associated NCV of 10 CFR 20.1501, Surveys and
Monitoring: General, was identified when Exelon failed to perform adequate loose surface
contamination surveys of the Unit 1 RWCU isolation valve room prior to authorizing work to
hang shadow shielding near the HV-051-1F017A valve, and also during the conduct of the
work itself. Exelon also did not identify very high levels of loose surface contamination on
overhead piping and structures which surrounded the work area. This failure resulted in
unplanned internal radiation exposures to three personnel, including an RPT who was
assigned to monitor the radiological aspects of the work.
Description: The HV-44-1F040 valve (40 valve) in the Unit 1 RWCU isolation valve room
developed a steam leak in June of 2016. The leak became more pronounced over time. This
leak, from a system which is known to contain high levels of radioactive activation products,
resulted in the spread of significant levels of loose surface contamination within the room.
The valve was repaired in September of 2017. The room was not decontaminated at that
time due to very high area dose rates.
During the period of the steam leak, the HV-051-1F017A valve (17 valve) developed
problems in its remote operation with indication of a ground in the direct current system.
Contaminated water from the 40 valve, which is located directly above the 17 valve, affected
the motor actuator for the 17 valve, necessitating a repair. The repair was scheduled for the
next scheduled refueling outage (1R17).
ALARA Plan 18-043 was developed to control the radiological aspects of the repair to the 17
valve motor/actuator and was approved for use on March 15, 2018. The plan identified that
decontamination may be required, that surface contamination levels could approach 400
mrad/hr per 100 centimeters squared (about 20,000,000 dpm per 100 centimeters squared),
and that the room was classified as Alpha Level II. This level of loose surface contamination
is radiologically significant and presents a potential for unplanned internal radiation exposure.
An ALARA evaluation indicated that respiratory protection was not warranted for the planned
work.
A limited decontamination was performed of the travel path from the rooms entrance to the
valve, the immediate area around the valve, and a light fixture (at head level) near the
valve, on March 27, 2018, in support of the planned repairs. A personal air sampler worn
during the decontamination work showed a localized airborne radioactivity of 0.38 derived air
concentration, indicating that the decontamination caused some loose surface contamination
to be suspended in the air. A post-decontamination radiological survey (2018-008466) was
performed to assess the conditions at the valve, and indicated maximum loose surface
contamination levels of 60,000 dpm per 100 centimeters squared on the light fixture.
On March 29, 2018, radiation shielding was installed near the 17 valve as part of the ALARA
plan. The crew consisted of two iron-workers and a senior RPT who was assigned to provide
continuous radiological coverage of the work. Installing the shielding included hanging steel
chains from structures in the overhead areas above the 17 valve, from which the shielding
would then be affixed. These overhead areas had not been decontaminated and were not
included in the loose surface contamination survey two days earlier. Personnel in the room
were not required to wear respiratory protection.
During the work, a hanging light fixture needed to be repositioned several times. When the
fixture was moved, dust was observed to fall from the light fixture. The iron-workers did not
believe that the dust was a concern due to the protective clothing that they were wearing, and
thus did not notify the RPT of the unexpected condition. The RPT, therefore, was not
prompted to obtain additional smear samples of the dusty areas in order to assess the
radiological impact.
The crew attempted to exit the radiologically controlled area after the completion of their work,
and alarmed the personal contamination monitors. Follow-up assessments, including a series
of whole body counts revealed unplanned internal radiation exposures at a small fraction of
the annual occupational exposure limits. IR 04120372 was written to document the event,
which included an event investigation by supervisory staff.
On March 30, 2018, at 1536, an additional radiological survey of the room was performed.
This more comprehensive effort identified very high levels of loose surface contamination on
overhead piping in the room, including areas near the shadow-shielding work area. These
ranged from about 400,000 to 2,000,000 dpm per 100 centimeters-squared.
Corrective Actions: Exelon restricted access to the area, conducted additional radiological
surveys, and conducted an investigation. Exelon entered the issue into their corrective action
program.
Corrective Action Reference: IR 04120372
Performance Assessment:
Performance Deficiency: 10 CFR 20.1003 defines a survey as an evaluation of the
radiological conditions and potential hazards incident to the production, use, transfer, release,
disposal, or presence of radioactive material or other sources of radiation. When appropriate,
such an evaluation includes a physical survey of the location of radioactive material and
measurements or calculations of levels of radiation, or concentrations or quantities of
radioactive material present.
CFR 20.1501 requires that each licensee make or cause to be made surveys that may be
necessary for the licensee to comply with the regulations in Part 20 and that are reasonable
under the circumstances to evaluate the magnitude and extent of radiation levels,
concentrations or quantities of residual radioactivity, and the potential hazards of the radiation
levels and residual radioactivity detected.
CFR 20.1701 specifies that the licensee shall use, to the extent practical, processes or
other engineering controls (e.g., containment, decontamination, or ventilation) to control the
concentration of radioactive material in air.
The post-decontamination radiological survey of the Unit 1 RWCU isolation valve room was
necessary to adequately assess the existing radiological conditions and to subsequently
demonstrate compliance with 10 CFR 20.1701. The March 27, 2018, decontamination effort
and subsequent loose surface contamination survey were focused on the immediate working
area around the 17 valve, but did not consider the need to access the areas in the overhead
above the 17 valve to hang radiation shielding, which was the next major step in the work
process.
When work to hang radiation shielding was authorized by Radiation Protection on March 29,
2018, the supervisor failed to identify that the work would include locations in which there had
been no decontamination and in which loose surface contamination levels had not been
assessed. Those contamination levels exceeded the discontinue work criteria of the ALARA
plan as provided in item 4, contamination level > 200,000 dpm/100cm2 Post Decon. These
levels and the tight confines of the work location would also likely warrant a re-evaluation of
the respiratory protection requriements as indicated in the ALARA plan item 8, Airborne
Radioactivity Mitigation, number 3, RP to evaluate respiratory protection on other activities
based upon radiological conditions and type of work.
During conduct of the work, in-process loose surface contamination surveys were not
performed by the RPT, and the work was not paused to allow a radiological re-assessment of
working conditions, when dust was seen to fall from a light fixture. This was contrary to the
ALARA plan, which also included a discontinue work criteria of when radiological conditions
are not as expected.
In addition, the RPT allowed a light fixture to be repositioned several times during the work,
which was not within the authorized scope of work as provided in the pre-job briefing and was
contrary to the ALARA plan, item 16, Contingency Plans, which states Changes in work
scope: notify RPS and Rad Engineering prior to deviating form the original plan/work scope.
These failures were within Exelons ability to foresee and correct, and should have been
prevented, and therefore are performance deficiencies. The deficiencies represent multiple
failed radiation protection barriers.
Screening: This finding is more than minor because it is associated with the Program &
Process attribute of the Occupational Radiation Safety cornerstone and affected the
cornerstone objective to ensure the adequate protection of the worker health and safety from
exposure to radiation from radioactive material during routine civilian nuclear reactor
operation. Specifically, loose surface contamination levels were not adequately assessed on
multiple occasions, discontinue work criteria were exceeded, and work outside of the planned
scope was allowed. Thus multiple radiation safety barriers were defeated as described in
IMC 0612, Section 6 Health Physics, General Screening Criteria.
Significance: Using IMC 0609.04, Initial Characterization of Findings, issued October 7,
2016, and IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination
Process, issued August 19, 2008, the inspection finding was not related to ALARA practices
(Step 1), did not result in an overexposure (Step 5), did not represent a substantial potential
for overexposure (Step 11), and did not compromise Exelons ability to assess dose (Step
14). As a result, this finding was determined to be of very low safety significance (Green).
Cross-Cutting Aspect: This finding has a cross-cutting aspect in the area of Human
Performance, Challenge the Unknown, in that Exelon did not ensure that individuals stop
when faced with uncertain conditions and ensure risks are evaluated and managed before
proceeding. Specifically, the RPTs involved in assessing radiological conditions and
controlling work (and their supervisor) did not adequately evaluate the potential for very high
levels of loose surface contamination in the RWCU isolation valve room following a significant
leak and prior to working in overhead areas, and did not reassess conditions when dust fell
from a light fixture. [H.11]
Enforcement:
Violation: 10 CFR 20.1003 defines a survey. 10 CFR 20.1501(a)(1) requires that each
licensee make or cause to be made surveys that may be necessary for the licensee to comply
with the regulations of Part 20.
Contrary to the above, on March 27 and March 29, 2018, Exelon did not perform adequate
loose surface contamination surveys in the Unit 1 RWCU isolation valve room following a
decontamination effort (and prior to authorizing work to hang radiation shielding), and
following the observation of dust falling from a light fixture in the immediate work area. These
surveys were necessary to demonstrate compliance with 10 CFR 20.1701, ALARA Plan 18-
043, and its associated respiratory protection ALARA evaluation. As a result, three personnel
received unplanned internal radiation exposures.
Disposition: This violation is being treated as an NCV, consistent with Section 2.3.2 of the
Unit 1 Core Spray Pump Failed to Start Resulting in Condition Prohibited by Technical
Specifications
Cornerstone Severity Cross-Cutting Aspect Report
Section
Not Applicable Severity Level IV Not Applicable 71153
Closed
The inspectors identified a Severity Level IV NCV of Unit 1 Technical Specification 3.5.1
because one core spray subsystem was inoperable from July 17, 2017, until October 5, 2017.
Specifically, the Unit 1 C core spray pump did not start upon demand during testing and was
declared inoperable because the pumps associated circuit breaker closing charging springs
were not charged.
Description: On October 5, 2017, the Unit 1 C core spray pump failed to start during
surveillance testing due to the associated circuit breaker failing to close. An initial
investigation identified that the switch contact inside the circuit breaker control device which
energizes the breakers closing springs charging motor became dislodged. With the switch
contact unable to maintain the circuit, the charging motor did not energize long enough to fully
charge the closing springs during the breakers previous closing operation. This condition
existed since the last time the Unit 1 C core spray pump was in service on July 17, 2017,
until the discovery on October 5, 2017. This issue constituted a violation of Technical Specification 3.5.1, Emergency Core Cooling System - Operating, because the pump was
out-of-service for greater than the allowed outage time of 7 days. This issue was reported to
the NRC in Licensee Event Report 05000352/2017-004-00, dated December 4, 2017, and
supplemented by Licensee Event Report 05000352/2017-004-01, dated March 13, 2018.
Failure analysis of the control device identified that the cause of the switch contact becoming
dislodged was due to arcing and welding of the switch contact eventually resulting in
displacement of the switch contact. The most probable cause of the initial degradation that
eventually led to arcing and welding was due to undervoltage testing of the closing springs
charging motor. This testing was performed during periodic circuit breaker inspections and
overhauls. The test subjects the control device switch contacts and charging springs motor to
lower than normal voltage which results in higher than normal current. The circuit breaker
was last overhauled and subjected to undervoltage testing in June 2014. The circuit breaker
was operated a minimum of 9 times between June 2014 and the discovery of the failure in
October 2017. There was no evidence of degraded performance in the breaker closing
springs charging motor circuit prior to failure. The inspectors noted that there were no
previous circuit breaker control device failures at Limerick due to switch contact issues. Also,
a review of industry and vendor operating experience did not reveal any similar failures of
switch contacts displacing due to arcing and welding.
Corrective Actions: Immediate corrective action was taken to replace the associated 4 kV
circuit breaker control device and return the Unit 1 C core spray pump to an operable status.
An extent-of-condition review was performed to verify that the charging spring indicators for
the sites 2.3 kV, 4 kV, and 13.2 kV switchgear circuit breakers showed that the charging
springs were charged. Exelon revised maintenance procedures to conduct the charging
motor undervoltage test prior to disassembly of the control device during circuit breaker
overhauls so that the associated electrical contacts on the switch will be inspected for
damage/overheating following the test.
Corrective Action Reference: IR 4059470
Performance Assessment: The inspectors determined that the failure of the Unit 1 C core
spray pump to start on October 5, 2017, was not within Exelons ability to foresee and
prevent. As a result, no performance deficiency was identified. Therefore, this violation will
not be considered in the assessment process or the NRCs Action Matrix.
Enforcement: This issue is considered within the traditional enforcement process because
there was no performance deficiency associated with the violation of NRC requirements and
the Reactor Oversight Process significance determination process does not specifically
consider violations without performance deficiencies in its assessment of licensee
performance. Therefore, it is necessary to address this violation using traditional
enforcement to adequately deter non-compliance.
Violation: Technical Specification 3.5.1, Emergency Core Cooling System - Operating,
requires in part, that emergency core cooling systems shall be operable with the core spray
system consisting of two subsystems with each subsystem comprised of two operable core
spray pumps and an OPERABLE flow path capable of taking suction from the suppression
chamber and transferring the water through the spray sparger to the reactor vessel. If there
is one core spray subsystem inoperable, provided that at least two low pressure coolant
injection subsystems are operable, Technical Specification 3.5.1 limiting condition for
operation action statement requires restoring the inoperable core spray subsystem to
operable status within 7 days or be in at least Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in
Cold Shutdown within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Contrary to the above, from July 17, 2017, until October 5, 2017, one Unit 1 core spray
subsystem was inoperable, and Exelon did not restore the core spray subsystem to operable
status within 7 days, and did not place Unit 1 in at least Hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or in
Cold Shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Specifically, the Unit 1 C core spray pump did not start
upon demand during testing and was declared inoperable because the pumps associated
circuit breaker closing charging springs were not charged.
Severity/Significance: The NRC Enforcement Policy, Section 2.2.1 states, in part, that,
whenever possible, the NRC uses risk information in assessing the safety significance of
violations. The inspectors evaluated the issue using IMC 0609.04, Initial Characterization of
Finding, and IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions.
The inspectors determined that the issue required a detailed risk evaluation because the
failure of the Unit 1 C core spray pump to start on October 5, 2017, represented an actual
loss of function of at least a single train for greater than its technical specification allowed
outage time. A Region I senior reactor analyst completed the detailed risk evaluation and
estimated the increase in core damage frequency associated with this issue to be below E-
7/year or of very low safety significance (Green). To perform the detailed risk evaluation to
gather insights on safety significance, the senior reactor analyst used the Systems Analysis
Programs for Hands-On Evaluation (SAPHIRE) Revision 8.1.6, Standardized Plant Analysis
Risk Model, version 8.50 for Limerick Generating Station Unit 1. The inspectors determined
that the issue is of very low safety significance and concluded that the violation would be best
characterized as Severity Level IV.
Enforcement Action: The violation is being treated as an NCV consistent with Section 2.3.2
of the Enforcement Policy.
Observations: 71152 Semiannual Trend
Review
The inspectors reviewed and assessed two adverse trends in human performance and
equipment reliability, last discussed in the 2017 fourth quarter integrated inspection report
(ADAMS Accession No. ML18032A569). The inspectors reviewed Exelons continued
actions, issues, and indicators related to improving human performance and determined that
Exelons efforts were sufficiently effective and sustained to not warrant continued focus by the
inspectors.
Regarding equipment reliability, the inspectors noted a number of additional examples
evaluated during the period that impacted operations: diesel generator elevated combustion
air temperature, pump seal failures, diesel generator auto-start logic circuit issue, isolation
valve failure, control enclosure chiller trips, and adjustable speed drive coolant leakage. The
inspectors documented two findings in the 2018 first quarter integrated inspection report
(ADAMS Accession No. ML18131A015) related to equipment reliability. Further inspection
will be performed during subsequent licensee event report reviews and/or during other
baseline inspection samples focusing on equipment reliability. Otherwise, during this
inspection, the inspectors did not identify a new performance deficiency or violation and/or
determined that the issues were of minor safety significance. The inspectors noted a related
issue identified by Exelon regarding unplanned entries into technical specification limiting
conditions for operation and discussed the trend with Exelon personnel. The inspectors
concluded that a continued inspection focus on equipment reliability is warranted and
discussed Exelons continued actions to improve equipment reliability which included
challenging repair scheduling for critical components, resolving long-standing and/or repetitive
equipment problems, and focusing efforts to improve reliability of systems critical to station
safety and reliability.
Based on the overall results of the semi-annual trend review, the inspectors did not identify
additional trends not recognized by Exelon and determined that Exelon was appropriately
identifying and entering issues into the corrective action program, adequately evaluating the
issues, and properly identifying adverse trends before they became more safety significant
problems.
Observations: 71152 Annual Follow-up of
IR 4024190 Selected Issues
The inspectors reviewed the IR which documented Exelons corrective actions to address the
Unit 2 main steam line high radiation alarm that occurred on June 21, 2018. Because of a
lack of an apparent cause, Exelons initial evaluation identified and eliminated a number of
likely causes, but did include the possibility of the introduction of foreign material as a
potential cause. Their evaluation also considered the extent of condition and cause, potential
generic implications and common cause, and previous occurrences. The corrective actions
were classified and prioritized in accordance with Exelons corrective action program
guidance, and the inspectors concluded that Exelons corrective actions were implemented
commensurate with the safety impact of the cause, and were appropriately focused to correct
the problem. Exelon implemented enhanced foreign material exclusion controls during the
current refueling outage and the inspectors observed their implementation during field
walkdowns. No additional issues were identified.
Observations: 71152 Annual Follow-up
IR 4059470 of Selected Issues
The inspectors reviewed IR 4059470 which documented Exelons actions regarding the Unit 1
C core spray pump failing to start during surveillance testing on October 5, 2017, due to the
pumps circuit breaker failing to close. The description of the event, corrective actions, and
enforcement aspects of this event are documented in the finding above.
The inspectors identified that although the failure of the circuit breaker to close was classified
as a critical component failure by the station ownership committee, the critical component
clock was not reset as expected by ER-AA-1200, Critical Component Failure Clock. The
inspectors noted that the critical component clock is used only as an equipment reliability
indicator and site awareness tool and, therefore, not resetting the clock for the event was
considered a minor issue.
Exelon performed a work group evaluation for the issue. This is the lowest level of review
specified by corrective action program procedures. The corrective action program procedural
guidance for events involving a critical component failure or requiring the submittal of a
licensee event report to the NRC recommended the performance of at least a corrective
action program evaluation which is a higher level of investigation than a work group
evaluation. Work group evaluations are allowed if the cause of the failure is known and if
proper approvals are obtained. The initial site investigation determined the failure to be due to
a deformed control device switch contact which led to the switch contact being dislodged
inside the control device. Based on the cause of the failure presumed to be determined in the
initial investigation, proper approvals were obtained to perform a work group evaluation
versus a corrective action program evaluation. The control device was sent to a failure
analysis laboratory for review. The laboratory analysis determined that the cause of the
failure to be associated with welding of the switch contacts eventually resulting in the switch
displacing. The final work group evaluation concluded that the most probable cause of the
initial degradation that eventually led to arcing and welding was due to undervoltage testing of
the closing springs charging motor. The undervoltage testing subjects the switch contacts to
higher than normal current which Exelon believed resulted in the initial degradation of the
switch contact.
The inspectors questioned why the investigation class was not upgraded to a corrective action
program evaluation when the laboratory failure analysis identified a cause of the failure that
was different than the initial investigation of the work group evaluation. In addition, the final
work group evaluation only determined undervoltage testing was the most probable cause of
the initial degradation which led to the failure. Because the cause could not be definitively
determined, Exelon should have performed a corrective action program evaluation. However,
the inspectors concluded that the actions ultimately taken by Exelon were adequate and not
upgrading the investigation class after receiving the laboratory failure analysis was a minor
issue. This was based on the revisions and additional actions added to the work group
evaluation (e.g., performance of a risk assessment) following two reviews of IR 4059470 by
the management review committee and one review by the plant operations review committee.
The inspectors observed an action taken outside of the corrective action process that should
have been established as an action in IR 4059470. Following the failure, operations
management issued Operations Standing Order 17-14, Operations Expectations for 4 Kilo-
Volt Equipment Starts, to perform checks to observe closing spring indicators on 4 kV circuit
breakers following breaker operation. The standing order was not added as an action item in
IR 4059470 even though it was issued as a compensatory measure for the issue. The
standing order was intended to stay in place until applicable operations procedures were
revised to include direction to perform these inspections routinely following breaker operation.
Based on further review of the issue, the action to revise the operations procedures was
canceled in IR 4059470 on March 1, 2018. The inspectors noted that as of May 16, 2018,
Standing Order 17-14 was still active and operations management was unaware that the
action item to revise the procedures had been canceled. The inspectors concluded that
issuing the standing order outside of the corrective action program process was a minor issue
because there were no potential adverse consequences as a result of continuing to perform
the checks.
Exelon acknowledged the inspectors observations discussed above and entered the issues
into the corrective action program as IR 4140088.
EXIT MEETINGS AND DEBRIEFS
Unless otherwise noted, no proprietary information was retained by the inspectors or
documented in this report.
On July 23, 2018, the inspectors presented the inspection results to Mr. Frank Sturniolo,
Plant Manager, and other members of the Exelon staff.
THIRD PARTY REVIEWS
Inspectors reviewed Institute of Nuclear Power Operations reports that were issued during the
inspection period.
DOCUMENTS REVIEWED
Procedures
0S78.1.D, Valve Alignment for Normal Operation of Standby Gas Treatment Room Ventilation,
Revision 5
1S50.1.A (COL), Equipment Alignment of the ADS and Main Steam Relief Valves for Normal
Operation, Revision 7
1S76.1.C, Equipment Alignment of Standby Gas Treatment System Reactor Enclosure Air
Recirculation System for Automatic Initiation, Revision 12
1S92.1.N (COL-1), Equipment Alignment for 1A Diesel Generator Operation, Revision 34
1S92.1.N (COL-4), Equipment Alignment for 1D Diesel Generator Operation, Revision 31
Condition Reports
22755
Work Orders
4768620-02
Drawings
E-484, Reactor Enclosure SGTS Filter Electrical Heaters Common, Revision 21
M-0078, Control Enclosure PI&D, Sheet 4, Revision 22
Procedures
1S49.1.A (COL), Valve Alignment to Assure Availability of the RCIC System, Revision 17
MA-716-230-1001, Oil Analysis Interpretation Guideline, Revision 20
MA-AA-716-230, Predictive Maintenance Program, Revision 11
S52.1.C, Operation of Safeguard Piping Fill System, Revision 11
ST-6-049-230-1, RCIC Pump, Valve and Flow Test, Revision 90
ST-6-052-760-1, Safeguard Piping Fill Quarterly Valve Test, Revision 20
Condition Reports
2653613 2656660 2697980 3956044 4078992 4086156
Procedures
CC-AA-211, Fire Protection Program, Revision 8
F-A-336, Pre-Fire Plan, Fire Area 2 13.2KV Switchgear Room 336 (Elev. 217), Revision 15
F-A-361, Pre-Fire Plan, Fire Area 6, Unit 2, Class 1E Battery Room 361 (Elev. 217), Revision 7
F-D-315A, D21 Diesel Generator and Fuel Oil - Lube Oil Tank Room, Rooms 315A and 316A
(El 217), Revision 9
F-R-109, Pre-Fire Plan, Unit 1 HPCI Pump Room 109, Revision 10
F-R-110, Pre-Fire Plan, Unit 1 Core Spray Pump Room A, Revision 8
F-R-173, Unit 2, A and C RHR Heat Exchanger and Pump Rooms 173 and 280 (EL 177 and
201), Revision 6
F-R-174, Unit 2, B and D RHR Heat Exchanger and Pump Rooms 174 and 281 (EL 177 and
201), Revision 6
OP-AA-201-009, Control of Transient Combustible Material, Revision 20
OP-LG-201-008, Limerick Generating Station Fire Protection (F) Pre-Fire Plan Strategies,
Revision 5
Procedures
F-R-284, Pre-Fire-Plan, Unit 2 Reactor Enclosure Cooling Water Heat Exchanger Area Rooms
284 and 286 (EL 201), Revision 7
OP-AA-201-003, Fire Drill Performance, Revision 16
ST-6-022-551-0, Fire Drill, Revision 13
Condition Reports:
4084529
Miscellaneous
Fire Drill Scenario No.: F-R-284, Unit 2, Reactor Enclosure Cooling Water Heat Exchanger Area
Rooms 284 and 286 (EL 201), June 12, 2018
OP-AA-201-003 Attachment 1, Fire Drill Record, completed June, 12 2018
Procedures
M-200-037, Q Listed HVAC Heating & Cooling Coil Clean/Flush, Revision 10
RP-LG-350-1006, Hydrolasing, Revision 1
RT-2-011-394-1, 1EV211 Core Spray Room Cooler Air to Water Heat Transfer Test,
Revision 10
Work Orders
4309052
Procedures
100-RT-001, Radiographic Examination in Accordance with ASME Section V, Article 2,
Revision 13
GEH-PDI-UT-1, PDI Generic Procedure for the Ultrasonic Examination of Ferritic Welds,
Revision 12
GEH-UT-311, Procedure for Manual Ultrasonic Examination of Nozzle Inner Radius, Bore and
Selected Nozzle to Vessel Regions, Revision 19
WPS 1-1-GTSM-PWHT, Welding Procedure Specification for P1 to P1 Manual GTAW and
Condition Reports
22585
Work Orders
4179424
Miscellaneous
ER-LG-330-1001, ISI Program Plan Fourth Ten-Year Inservice Inspection Interval, Revision 15
UT-18-017, UT Examination Report for APE-1MS-LD N3D (Summary No. LIM-1-602760),
dated April 4, 2018
VT Examination Report for Suppression Pool Internal Surfaces, dated April 4, 2018
UT-18-011, UT Examination Report for FWA-039 (Summary No. LIM-1-233390), dated
April 4, 2018
UT-18-012, UT Examination Report for FWA-040 (Summary No. LIM-1-233400), dated
April 4, 2018
RT Examination Report for FW-56 on Line DBB-105-1, dated April 2, 2018
RT Examination Report for FW-58 on Line DBB-105-1, dated April 2, 2018
Procedures
GP-2, Normal Plant Startup, Revision 172
Procedures
ER-AA-310-1002, Maintenance Rule Functions - Safety Significance Classification, Revision 3
ER-AA-310-1003, Maintenance Rule - Performance Criteria Selection, Revision 5
ER-AA-310-1004, Maintenance Rule - Performance Monitoring, Revision 14
ER-AA-310-1005, Maintenance Rule - Dispositioning Between (a)(1) and (a)(2), Revision 7
M-056-001, Replacement of Mechanical Seals on the High Pressure Coolant Injection Main
Pump - P204, Revision 1
OP-LG-108-117-1000, Limerick Protected Equipment Program, Revision 6
SM-AA-300-1001, Procurement Engineering Process and Responsibilities, Revision 23
Condition Reports
2652839 2653173 2681816 2682469 2683662 2686466
2686469 2690284 2695292 2697334 2704684 2705628
2713214 2718916 2718965 2718986 2719515 2725822
27759 3948230 3951442 3952680 3953586 3983220
4001894 4002391 4015662 4123699 4127144 4127674
4136634
Work Orders
4308237 4773946
Miscellaneous
A/R A0733443, O-ring, F/Basket Strainer on Diesel Fuel Oil system, 4/7/93
Eval: 114-38109, EDG Gasket Material - Evaluate Alternate, 1/25/13
INSP NO: 0101903
PEEVAL 211748, Commercial Grade Dedication Plan for KTN-R-10 Fuse, Revision 1
Ref. No.: 114-38070, Gasket, Crankcase, 7/27/89
Ref. No.: 11592850, Gaskets, Manifolds, 5/16/90
Procedures
ER-AA-600-1042, On-Line Risk Management, Revision 10
OP-AA-108-117, Protected Equipment Program, Revision 5
OP-LG-108-117-1000, Limerick Protected Equipment Program, Revision 6
ST-2-072-107-1, Div II Reactor Enclosure BOP Isolation LSF/SAA and RERS, SGTS Test,
Revision 16
ST-6-092-115-1, D11 Diesel Generator 4KV SFGD Loss of Power LSF/SAA and Outage
Testing, Revision 25
WC-AA-101-1006, On-Line Risk Management and Assessment, Revision 2
Miscellaneous
Operations Protected Equipment Log 4/5/18
Procedures
NRC IN 2017-003, Anchor Darling Double Disk Gate Valve Wedge Pin and Stem-Disc
OT-102, Reactor High Pressure, Revision 27
S57.1.C, Drywell Purge Fan Operation, Revision 8
ST-6-001-761-1, Main Turbine Bypass Valve Exercising, Revision 30
Condition Reports
0412345 1175540 2590938 4119016 4122755 4126091
27674
Work Orders
4768620
Drawings
E-484, Reactor Enclosure SGTS Filter Electrical Heaters Common, Revision 21
M-0076, Reactor Enclosure and Refueling Area HVAC, Sheet 6, Revision 33
M-0078, Control Enclosure PI&D, Sheet 4, Revision 22
Procedures
8031-M-0022, Sheet 6, Fire Protection (Unit 1, Unit 2 and Common), Revision 24
8031-M-0028, Sheet 1, Generator H2 Cooling and CO2 Purge (Unit 1 and Common), Revision
8031-M-0028, Sheet 2, Generator H2 Cooling and CO2 Purge (Unit 2), Revision 23
CC-AA-211, Fire Protection Program, Revision 8
L-S-51, Fire Protection System, Revision 7
LS-AA-104, Exelon 50.59 Review Process, Revision 10
LS-AA-104-1001, 50.59 Review Coversheet Form, Revision 4
PPC-LGS-1, Preparedness, Prevention and Contingency Plan for Limerick Generating Station,
Revision 3
ST-6-001-766-1, Main Turbine Control Valve Exercise & RPS Channel Functional Test, OPCON
4, 5, Revision 19, 20 and 21
Condition Reports
29080 4126850
Miscellaneous
EC 618876, LGS U1 and U2 Carbon Dioxide System Modification and Abandonment,
Revision 2
LG-2017S029, 50.59 Screening for LGS U1 and U2 Carbon Dioxide System Modification and
Abandonment, Revision 0
ECR 1200019 and ECR 1200024, Electro-Hydraulic Control (EHC) System Upgrades,
Revision 3
Procedures
M-056-001, Replacement of Mechanical Seals on the High Pressure Coolant Injection Main
Pump - P204, Revision 0
M-056-004, Overhaul of the High Pressure Coolant Injection Main Pump - P204, Revision 3
M-200-037, Q Listed HVAC Heating & Cooling Coil Clean/Flush, Revision 10
RP-LG-350-1006, Hydrolasing, Revision 1
RT-6-051-206-1, 1C RHR-SDC Crosstie Valve Test, Revision 5
S12.1.A, RHR Service Water System Dual Loop Startup Hard Card, Revision 2
S12.2.A, Shutdown of RHR Service Water Pumps and System, Revision 35
S51.5.A, Flushing of the RHR System Heat Exchanger Tube Side with Demineralized Water,
Revision 25
S51.8.A Appendix 1, Placing RHR SP Cooling in Service During a Plant Event, Revision 2
S55.1.A, Normal HPCI Line-up for Automatic Operation, Revision 37
S55.1.D Appendix 1, Starting HPCI for Pressure Control During a Plant Event, Revision 0
S55.3.A, HPCI Fill and Vent, Revision 36
S55.9.A, Routine Inspection of HPCI System, Revision 43
S93.0.C, 480 VAC Safeguard MCC Compartment Installation, Revision 35
ST-6-011-231-0, A Loop ESW Pump, Valve & Flow Test, Revision 75
ST-6-051-202-1, A LOOP RHR Cold Shutdown Valve Test, Revision 22
ST-6-051-232-1, B RHR Pump, Valve, and Flow Test, Revision 87
ST-6-055-230-1, HPCI Pump, Valve and Flow Test, Revision 86
ST-6-107-594-1, Weekly Surveillance Log, Revision 84
ST-6-107-594-2, Weekly Surveillance Log, Revision 73
Condition Reports
27674 4145984 4146145
Work Orders
239418 4240873 4267351 4309052 4309629 4313481
4614983 4710009 4728774 4747597 4758920 4763312
4763312 4767181 4773946 4773946
Drawings
06KPX883678, Sheet 1, HPCI Pump, Revision D
Procedures
ST-2-074-629-1, Functional Check of Average Power Range Monitor 4 (APRM 4), Revision 17
ST-2-088-324-2, Remote Shutdown System Div 2 RHR Operability Test, Revision 7
ST-6-051-234-2, D RHR Pump, Valve and Flow Test, Revision 58
ST-6-092-115-1, D11 Diesel Generator 4KV SFGD Loss of Power LSF/SAA and Outage
Testing, Revision 25
ST-6-092-312-1, D12 Diesel Generator Slow Start Operability Test Run, Revision 103
ST-6-092-314-1, D14 Diesel Generator Slow Start Operability Test Run, Revision 104
Condition Reports
4149666
Work Order 266199 4324924 4325189 4761182 4325189
Drawings
M-071-00048 Sheet 1, Schematic Engine Control D11 Diesel Generator, Revision 30
Procedures
HU-AA-101, Human Performance Tools and Verification Practices, Revision 9
HU-AA-1211, Pre-Job Briefings, Revision 11
NISP-RP-002, Radiation and Contamination Surveys, Revision 0
NISP-RP-003, Radiological Air Sampling, Revision 0
RP-AA-300, Radiological Survey Program, Revision 16
RP-AA-301, Radiological Air Sampling Program, Revision 11
RP-AA-401, Operational ALARA Planning and Controls, Revision 23
RP-AA-441, TEDE ALARA Evaluation, Revision 9
Miscellaneous
ALARA Briefing / Attendance Form, RP-AA-401 Attachment 3, for ALARA Plan 18-043, dated
3/27/2018 at 1030 and 3/28/2018 at 2000
ALARA Plan 18-043
Radiation Work Permit LG-0-18-00625, Revision 0
Radiological Survey 2018-003677
Radiological Survey 2018-008466
Radiological Survey 2018-008547
Radiological Survey 2018-008552
Radiological Survey 2018-008594
Radiological Survey 2018-008690
TEDE ALARA Screening and Evaluation for plan 18-043
71151
Procedures
LS-AA-2200, Emergency AC Power Function, Attachment 5 data (April 2017 through April 2018)
Procedures
ER-AA-1200, Critical Component Failure Clock, Revision 12
M-200-002, 2.3 KV and 4 KV Power Circuit Breaker Overhaul, Revision 10
M-200-011, 13.2 KY and 2.3 KV Switchgear Maintenance, Revision 4
MA-AA-716-004, Revision 15
MA-AA-716-008, Foreign Material Exclusion Program, Revision 13
PI-AA-120, Issue Identification and Screening Process, Revision 8
PI-AA-125, Corrective Action Program Procedure, Revision 8
PI-AA-125-1003, Corrective Action Program Evaluation Manual, Revision 4
Condition Reports
22252 4024190 4118994 4119397 4121951 4122429
22755 4122806 4123146 4123855 4124233 4126850
27674 4127870 4133876 4133876 4135378 4140085
4141279 4141283
Miscellaneous
ECAPE 4024190-14
Equipment Operator Initial Training, Module LEOT0229, AC Circuit Breakers, Revision 007
LIM-0-2018-0099, 4 Kilo-Volt Breaker Springs Failure Risk Assessment, dated 04/25/2018
LIM-60226, Failure Analysis of a Contact Assembly, dated 12/18/2017
Non-Conformance Report 94-00009, Calculation LE-069 Inadequate Voltage at 4 KV
Switchgear Spring Charging Motor, dated 2/19/1994
Operations Standing Order 17-14, Operations Expectations for 4 Kilo-Volt Equipment Starts,
dated 12/20/2017
Procedures
GP-5 Appendix 2, Rx Maneuvering Without Shutdown, Revision 102
Condition Reports
4145616 4145647 4145655 4145666 4145776 4146236