Text

IR 05000352-12-010 and 05000353-12-010; Limerick Generating Station - NRC Problem Identification and Resolution Inspection Report
	ML12353A086
Person / Time
Site:	Limerick
Issue date:	12/18/2012
From:	Krohn P G; Reactor Projects Region 1 Branch 4
To:	Pacilio M J; Exelon Nuclear
	Krohn P G
References
	IR-12-010
	Download: ML12353A086 (23)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BOULEVARD, SUITE 100 KING OF PRUSSIA, PENNSYLVANIA 19406-2713 December 18, 2012

Mr. Michael Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road

Warrenville, IL 60555

SUBJECT: LIMERICK GENERATING STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000352/2012010 AND 05000353/2012010

Dear Mr. Pacilio:

On November 9, 2012, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Limerick Generating Station (LGS) Units 1 and 2. The enclosed report documents the inspection results discussed with Tom Dougherty, Site Vice President, and other members of your staff.

This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commission's rules and regulations and conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

Based on the samples selected for review, the inspectors concluded that Exelon was generally effective in identifying, evaluating, and resolving problems. Exelon personnel identified problems and entered them into the corrective action program at a low threshold. Exelon prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner.

This report documents an NRC-identified finding of very low safety significance (Green). The finding was determined not to involve a violation of NRC requirements. If you disagree with the cross-cutting aspect assigned to the finding in this report, you should provide a response, within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at LGS.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/ Paul G. Krohn, Chief Projects Branch 4

Division of Reactor Projects

Docket Nos.: 50-352, 50-353 License Nos.: NPF-39, NPF-85

Enclosure:

Inspection Report 05000352/2012010 and 05000353/2012010

w/Attachment:

Supplemental Information

cc w/encl: Distribution via ListServ

ML12353A086 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE mmt RI/DRP RI/DRP RI/DRP NAME SShaffer/SS RPowell/RP PKrohn/PGK DATE 12/06 /12 12/ 17 /12 12/ 11 /12

1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION I

Docket Nos.: 50-352, 50-353

License Nos.: NPF-39, NPF-85

Report Nos.: 05000352/2012010 and 05000353/2012010

Licensee: Exelon Generation Company

Facility: Limerick Generating Station

Location: Sanatoga, PA 19464

Dates: October 22 - 26 and November 5 - 9, 2012

Team Leader: Steve Shaffer, Senior Project Engineer Inspectors: Anne DeFrancisco, Project Engineer Aaron Dugandzic, Project Engineer Justin Hawkins, Resident Inspector, Limerick Generating Station

Approved by: Paul G. Krohn, Chief Projects Branch 4 Division of Reactor Projects

2 Enclosure

SUMMARY OF FINDINGS

IR 05000352/2012010 and 05000353/2012010; October 22 - November 9, 2012; Limerick Generating Station (LGS); Biennial Baseline Inspection of Problem Identification and Resolution. The inspectors identified a finding in the area of prioritization and evaluation of issues.

This NRC team inspection was performed by three regional inspectors and one resident inspector. The inspectors identified a finding of very low safety significance (Green) during this inspection. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using NRC Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or assigned a severity level after NRC management review. Cross-cutting aspec ts associated with findings are determined using IMC 0310, "Components Within the Cross-Cutting Areas." The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Problem Identification and Resolution The inspectors concluded that Exelon was genera lly effective in identifying, evaluating, and resolving problems. Exelon personnel identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with their safety significance. In most cases, Exelon appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that Exelon typically implemented corrective actions to address the problems identified in the corrective action program in a timely manner. Notwithstanding, the inspectors identified one finding in the area of prioritization and evaluation of issues.

The inspectors concluded that, in general, Exelon adequately identified, reviewed, and applied relevant industry operating experience to LGS operations. In addition, based on those items selected for review, the inspectors determined that Exelon's self-assessments and audits were thorough.

Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues nor did they identify any conditions that could have had a negative impact on the site's safety conscious work environment.

Cornerstone: Initiating Events

Green.

The inspectors identified a finding of very low safety significance (Green) for Exelon's failure to complete an evaluation of the off-normal bus alignment prior to the summer period. Consequently, on July 18, 2012, LGS experienced a fault of the 124A load center (LC) transformer which led to an unplanned manual scram. Exelon's root cause evaluation for this event identified that a contributing cause was the electrical configuration being in an off-normal bus alignment (114A LC cross-tied to the 124A LC) for an extended period due to the failure of the 144D transformer, which placed more load on the degraded 124A connection and contributed to its failure. Exelon has entered the issue into the corrective action program (AR 1437657).

This finding was more than minor because it is similar to examples 4.f and 4.g of IMC 0612, Appendix E, "Examples of Minor Issues," in that operators inserted a manual scram per procedural requirements following the loss of the reactor recirculation pumps (RRP) associated with the 124A LC transformer failure. Additionally, the finding was more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. This finding was of very low safety significance (Green) because the finding did cause a reactor trip but did not cause a loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. This finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Exelon did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity P.1(d). Specifically, Exelon's failure to restore the normal 124A LC alignment or evaluate the effects of continuing the off-normal alignment during the summer period in a timely manner placed additional loading on the transformer contributing to the failure. (Section 4OA2.1.c)

REPORT DETAILS

OTHER ACTIVITIES (OA)

4OA2 Problem Identification and Resolution

Main article: IP 71152B

This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. All documents reviewed during this inspection are listed in the Attachment to this report.

.1 Assessment of Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures that described Exelon's corrective action

program at LGS.

To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in thes e areas to the requirements and standards contained in 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," and Exelon procedure LS-AA-125, "Corrective Action Program Procedure." For each of these areas, the inspectors considered risk insights from the station's risk analysis and reviewed

issue reports (IRs) selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. Additionally, the inspectors attended multiple Plan-of-the-Day, Station Ownership Committee, and Management Review Committee meetings. The inspectors selected items from the following functional areas for review:

engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, and oversight programs.

(1) Effectiveness of Problem Identification

In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports.

The inspectors also completed field walkdowns of various systems on site, such as the emergency diesel generators (EDGs), residual heat removal, core spray, and remote safe shutdown panels. Additionally, the inspectors reviewed a sample of IRs written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that Exelon entered conditions adverse to quality into their corrective action program as appropriate.

(2) Effectiveness of Prioritization and Evaluation of Issues

The inspectors reviewed the evaluation and prioritization of a sample of IRs issued since the last NRC biennial Problem Identification and Resolution inspection completed in November 2010. The inspectors also reviewed IRs that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors' review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.

(3) Effectiveness of Corrective Actions The inspectors reviewed Exelon's completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed and corrected the identified causes of the problems. The inspectors also reviewed IRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Exelon's timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of IRs associated with selected non-cited violations (NCVs) and findings to verify that Exelon personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate Exelon actions related to Units 1 & 2 480 volt safeguard motor control centers (MCCs) and non-safeguard MCCs.

b. Assessment

(1) Effectiveness of Problem Identification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Exelon identified problems and entered them into the corrective action program at a low threshold. Exelon staff at LGS initiated approximately 25,000 IRs between November 2010 and October 2012. The inspectors observed supervisors at the Plan-of-the-Day, Station Ownership Committee, and Management Review Committee meetings appropriately questioning and challenging IRs to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that Exelon trended equipment and programmatic issues, and appropriately identified problems in IRs. The inspectors verified that conditions adverse to quality identified through this review were entered into the corrective action program as appropriate. Additionally, inspectors concluded that personnel were identifying trends at low levels. In general, inspectors did not identify any significant issues or concerns that had not been appropriately entered into the corrective action program for evaluation and resolution. In response to several questions and minor equipment observations identified by the inspectors during plant walkdowns, Exelon personnel promptly initiated IRs and/or took immediate action to address the issues.

(2) Effectiveness of Prioritization and Evaluation of Issues

The inspectors determined that, in general, Exelon appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. Exelon screened IRs for operability and reportability, categorized the IRs by significance, and assigned actions to the appropriate department for evaluation and resolution. The IR screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impacts on the safety conscious work environment.

Based on the sample of IRs reviewed, the inspectors noted that the guidance provided by Exelon's corrective action program implementing procedures appeared sufficient to ensure consistency in categorization of issues. Operability and reportability determinations were generally performed when conditions warranted and, in most cases, the evaluations supported the conclusion. Causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue.

However, the inspectors identified one finding of more than minor significance for failure of LGS personnel to evaluate an off-normal condition of the 114A and 144D load centers cross-tied to their non-preferred power sources. This finding is documented in Section 4OA2.1.c. The inspectors also noted some observations in Exelon's prioritization and evaluation of the following issues:

Prioritization of Reactor Core Isolation Cooling (RCIC) Lube Oil System Relief Valve Replacements As part of the corrective actions from the failure of the D23 EDG at LGS in May 2010, Exelon reviewed other systems that had lube oil relief valves to ensure that preventive maintenance (PMs) were being performed correctly to prevent future equipment failures. Exelon identified that the RCIC lube oil filter bypass and equalizer pipe relief valves (4 total - 2 per unit) should have a 10 year replacement PM frequency. Exelon created a corrective action (AR 1065596-84) to process replacement PMs on a 10 year frequency for these relief valves with an original due date of July 1, 2011. The due date for this action was extended multiple times and was finally completed on September 30, 2011. The inspectors determined that the new replacement PMs were created and assigned for 2017 and 2018 coincident with other relief valve work in the RCIC systems on both units although 3 of the 4 valves have never been replaced during the life of the plant, a period of time exceeding 20 years.

Inspectors identified that the last system outage workweek on Unit 1 was the week of September 5, 2011. Due to the extensions of the action item due date, Exelon missed the opportunity to replace the Unit 1 RCIC relief valve (PSV-050-125). The inspectors determined that the prioritization of replacement for these valves was not timely and was a performance deficiency. However, the inspectors did not identify an impact on equipment performance. Therefore, the inspectors determined that the issue was of minor significance.

Prioritization of Procedure Change Requests for High Pressure Coolant Injection (HPCI) System Test and Operating Procedures In January 2011, Exelon documented an equipment apparent cause evaluation (EACE)for the HPCI turbine stop valve not resetting on Unit 1 (AR 1151354). Exelon generated corrective action assignments 31 and 32 (original due date of February 2012 and June 2012, respectively) to revise the HPCI system test and operating procedures. Inspectors identified that these due dates were rescheduled to March 2013. The inspectors determined that both of these assignments should have been prioritized and completed in a more timely manner based on the initial AR classification level. After the inspectors questioned the timeliness of the due dates for these actions, the operations department significantly changed the procedure change request action (PCRA) backlog process to prioritize backlog items to ensure that PCRAs initiated as corrective actions are prioritized ahead of routine change requests.

The inspectors determined that the untimely completion of the PCRAs for the HPCI system test and operating procedures was a performance deficiency. The inspectors determined this issue to be of minor significance because there have been no equipment failures or deficiencies associated with the HPCI procedures not being updated.

Prioritization of Special Plant Condition (SPC) Evaluation for the Long Path Recirculation Valve (HV-041-210)

In January 2012, Exelon documented a root cause evaluation (AR 1276176) for the NRC White finding for the Unit 2 RCIC system flow diversion event (05000353/2011004-01). As part of the corrective actions for this root cause, Exelon created a SPC condition assignment (AR 1276176-24) to test HV-041-210 valve at the first available opportunity.

The assignment was coded for the next Unit 2 refueling outage in the spring of 2013.

Exelon's justification for this scheduling is that the valve has been verified closed. The SPC was created to investigate the actual failure mode of the valve by going into the valve internals which could potentially change the root cause results.

The inspectors determined that the site did not prepare to perform this evaluation at the first available opportunity based on Exelon's current planning of the SPC and timing associated with parts availability. The inspectors also determined that because the results of the SPC could change the results of the root cause that Exelon should have prepared to conduct the SPC at the first available opportunity, including evaluating the performance of the SPC during one of the Unit 2 maintenance or forced (2M45, 2F47 or 2F48) outages earlier this year. The inspectors determined this issue to be of minor significance because there have been no equipment failures or deficiencies associated with not performing the SPC at the first available opportunity.

Remote Shutdown Panel Instrumentation Reliability Two indications on the U1/U2 remote shutdown panel have been demonstrating degraded performance over time and have not been prioritized for timely, permanent repair. Specifically:

Suppression Pool temperature TI-41-102 - Channel 'D' was inoperable for approximately eight months during 2012. Erratic indications on 'D' and 'H' channels have been documented in action requests since 1999, but component replacement is not scheduled for evaluation until August 2013; Reactor Pressure Vessel pressure PI-042-2R011 was documented as not being within its surveillance testing required calibration band during the 2009-2010 timeframe, when readings indicated greater than 1053 psig. Although the instrument was identified as requiring calibration to within the tolerance specified in ST-6-107-595-2 (<1053 psig), no repair evaluation existed to address the deficiency. The inspectors noted that recent checks during 2011 and 2012 indicate that the instrument is currently reading below 1053 psig thereby meeting the surveillance requirements.

The inspectors determined the two examples described above constitute a performance deficiency for not adequately prioritizing a correction of conditions adverse to quality commensurate with the risk-importance and potential operability / technical specification impact on remote shutdown instrumentation, despite the instruments having exhibited degraded performance. However, the inspectors did not identify an operability impact such that a technical specification limiting condition for operation was exceeded.

Specifically, TS 3.3.7.4 requires one channel to be operable and the inspectors verified compliance with this TS was maintained. Therefore, the inspectors determined that the issue was of minor significance, and not subject to enforcement action in accordance

with the NRCs Enforcement Policy.

(3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, Exelon identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC NCVs and findings since the last problem identification and resolution inspection were timely and effective. Notwithstanding, the inspectors did identify one finding of very low safety significance regarding failure to take adequate corrective actions associated with an off-normal electrical bus alignment. This finding is documented in Section 4OA2.1.c.

c. Findings

(1) Failure to Take Timely Corrective Actions to Address the 144D Load Center ODM Contingency Actions

Introduction.

The inspectors identified a finding of very low safety significance (Green) for Exelon's failure to complete an evaluation of the off-normal bus alignment prior to the summer period. Consequently, on July 18, 2012, LGS experienced a fault of the 124A LC transformer which led to unplanned manual scram. Exelon's root cause evaluation for this event identified that a contributing cause was the electrical configuration being in an off-normal bus alignment (114A LC cross-tied to the 124A LC) for an extended period due to the failure of the 144D transformer, which placed more load on the degraded 124A connection and contributed to its failure.

Description.

The inspectors performed a review of Exelon's causal evaluation (AR 1355888) that was generated in response to the Unit 1 scram due to the 144D LC transformer fault on April 19, 2012. Exel on created corrective action assignment number 10 to the 144D LC evaluation to document an ODM evaluation for startup with the 114A and the 144D LCs cross-tied to their non-preferred sources (124A and 244D respectively). This ODM evaluation was approved by Exelon management with a contingency requiring that prior to the summer period, the normal bus alignment would be restored. Exelon's corrective action program tracked completion of this ODM contingency under AR 1356794 assignment number 2 with a due date of May 30, 2012. Exelon documented the closure of AR 1356794 to AR 1371755 on May 29, 2012, because the transformer vendor advised the st ation to replace the 144D transformer instead of repairing it.

The inspectors identified that newly created AR 1371755 stated in part, "This AR is being generated to evaluate possible decisions and repair scenarios during summer operation." The inspectors noted that the original due date for this AR was June 1, 2012, but that the due date was extended three times.

Subsequently, on July 18, 2012, LGS experienced a fault of the 124A LC transformer which led to an unplanned manual scram. The root cause evaluation completed for the 124A LC failure stated in part that, "contributing to this event was the 114A LC being cross-tied to the 124A LC for an extended period due to a previous unrelated failure of the 144D transformer, which placed more load on the degraded (124A) connection and led to its failure." The inspectors determined that the 144D LC ODM contingency to restore normal bus alignment or fully evaluate the off-normal alignment prior to the summer period was not completed by Exelon management prior to the 124A LC transformer failure.

Allowing the corrective actions for the original ODM contingency to be extended multiple times without proper evaluation per the ODM and corrective action program processes is a performance deficiency.

Analysis.

The inspectors determined Exelon's failure to complete an evaluation of the off-normal bus alignment prior to the summer period was a performance deficiency that was within Exelon's ability to foresee and correct and should have been prevented. The inspectors determined that this issue was more than minor because it is similar to examples 4.f and 4.g of IMC 0612, Appendix E, "Examples of Minor Issues," in that operators inserted a manual scram per procedural requirements following the loss of the reactor recirculation pumps (RRPs) associated with the 124A LC transformer failure.

Additionally, the finding was more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. This finding was of very low safety significance (Green) because the finding did cause a reactor trip but did not cause a loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.

The inspectors determined that this finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Exelon did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity P.1(d). Specifically, Exelon's failure to restore the normal 124A LC alignment or evaluate the effects of continuing the off-normal alignment during the summer period in a timely manner placed additional loading on the transformer contributing to the failure.

Enforcement.

This finding does not involve enforcement action since no regulatory requirement violation was identified because Exelon's procedure, OP-AA-106-101-1006, Revision 011, "Operational Decision Making Process," is not required to be implemented as part of LGS's 10 CFR 50, Appendix B, Quality Assurance Program and the 124A LC transformer is not a safety related com ponent. Exelon has entered the issue into the corrective action program (AR 1437657). Because this finding does not involve a violation, it is identified as a finding (FIN). (FIN 05000352/2012010-01, Failure to Take Timely Corrective Actions to Address the 144D Load Center ODM Contingency Actions)

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed a sample of IRs associated with review of industry operating experience to determine whether Exelon appropriately evaluated the operating

experience information for applicability to LGS and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Exelon adequately considered the underlying problems associated with the issues for resolution via their corrective action program. In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.

b. Assessment The inspectors determined that Exelon appropriately considered industry operating

experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also observed that industry operating experience was routinely discussed and considered during the conduct of Plan-of-the-Day meetings and pre-job briefs. However, the inspectors noted some observations in Exelon's use of operating experience:

Reactor Recirculation Pump Seal Replacement PM Deferral and ODM In February 2012, Exelon personnel documented (AR 1299616-04), an ODM to defer the 6 year PM for replacement of the RRP seals. The ODM justified the decision by stating that the 1 'A' RRP seal was exhibiting good performance and Operating Experience (OE) from both Quad Cities (953714) and Dresden (1258322) technically supported deferral of the replacement PM past the 6 year point.

However, the inspectors identified that Exelon's PM deferral was not supported by the OE or the vendor recommendation cited in the ODM. Specifically, the Quad Cities OE

documented an approved ODM for exceeding the 6 year replacement PM but the site replaced the RRP seal prior to the 6 year point. In addition, the Dresden OE did not evaluate extending the seal replacement PM frequency past 6 years. Also, Exelon's use of LGS' 6 year replacement PM history with no failures was not a valid justification because the site only changed the PM frequency for replacement from 4 to 6 years in 2004 and the first RRP seal replacement on this new frequency occurred in April 2006, less than one replacement cycle from February 2012. Finally, the inspectors noted that while the vendor recommended deferral, Exelon did not support this recommendation in the approved ODM with any technical justification. Although the ODM approved operating the RRP seals beyond six years, the 1 'A' RRP seal experienced degradation in August of 2012 requiring replacement of the seal within the 6 year PM frequency.

The inspectors determined that the failure to adequately justify the ODM decision to defer the RRP seal replacement PM was a performance deficiency but was not a contributing cause of the 1 'A' RRP seal degradation in August 2012 (EACE AR 1392061). Therefore, the inspectors determined that the issue was of minor significance.

c. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, departmental self-assessments, and assessments performed by independent organizations. Inspectors performed these reviews to determine if Exelon entered problems identified through these assessments into the corrective action program, when appropriate, and whether Exelon initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.

b. Assessment The inspectors concluded that self-assessments, audits, and other internal Exelon assessments were generally critical, thorough, and effective in identifying issues. The inspectors observed that Exelon personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. Exelon completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. In general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance.

c. Findings

No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

During interviews with station personnel, the inspectors assessed the safety conscious work environment at LGS. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors also interviewed the station Employee Concerns Program coordinators to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns.

The inspectors reviewed the Employee Concerns Program files to ensure that Exelon entered issues into the corrective action program when appropriate.

b. Assessment During interviews, Exelon staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the corrective action program and the Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On November 9, 2012, the inspectors presented the inspection results to Tom Dougherty, Site Vice President and other members of the LGS staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

Also, on December 6, 2012, the inspectors presented additional information to Bob Dickinson, Regulatory Affairs Manager and other members of the LGS staff via teleconference.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Dougherty, Site Vice President

D. Lewis, Plant Manager

B. Schultz, Senior Reactor Operator

R. Kreider, Operations Director

M. Gillin, Shift Operations Superintendent

C. Gerdes, Manager, Chemistry

R. Webster, Employee Concerns Coordinator

C. Capriotti, Acting Manager, Maintenance

D. Doran, Engineering Director

J. Hunter, Work Management, Director

T. Wasong, Training, Director

B. Dickinson, Regulatory Assurance, Manager

J. Karkoska, Nuclear Oversight, Manager

R. Harding, Regulatory Assurance

M. Klick, Corrective Action Program, Manager

D. Semeter, Senior Manager Plant Engineering

M. Bonanno, Electrical Branch Manager

D. Merchant, Radiation Protection Manager

J. Issertell, Instrument & Controls Maintenance Manager

L. Murphy, Chemistry

M. Alexis, Component Specialist

M. Barth, System Engineer

J. Berg, System Engineer

M. Bonifanti, Engineering Manager

D. Cheung, System Engineer

I. Choudhry, Security Programs Lead

M. Dirado, Engineering Manager

A. Kopistansky, System Engineer

J. Mitman, Sr. Engineer

V. Patel, System Engineer

E. Purdy, System Engineer

C. Ramos, Operations Shift Supervisor

R. Rodgers, CMO Program Specialist (PCM/PAM)

N. Roy, System Engineer

B. Schultz, Manager Operations Support

D. Smolinsky, Technical Procurement Specialist

M. Crim, Emergency Response

C. Fritz, Operations

D. Wilbert, Operations

B. Sokso, Operations

S. Bakes, Operations

B. Gulbrandson, Operations

C. Ramos, Operations

Attachment

NRC Personnel

R. Powell, Chief of TSAB, Region I

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened and Closed

05000352/2012010-01 FIN Failure to Take Timely Corrective Actions to Address the 144D Load Center ODM

Contingency Actions

LIST OF DOCUMENTS REVIEWED

Section 4OA2: Problem Identification and Resolution

Audits and Self-Assessments

NOSA-LIM-11-04: Corrective Action Program Audit Report

NOSA-LIM-11-05: Engineering Design Control Audit Report, IR 1235172

NOSA-LIM-11-06: Radiation Protection Audit Report

NOSA-LIM-11-11: Maintenance Functional Area Increased Frequency Audit Report Executive Review of Exelon Nuclear's Learning Programs for December 2011

Executive Review of Exelon Nuclear's Learning Programs for April 2012

Executive Review of Exelon Nuclear's Learning Programs for August 2012 Functional Area Self-Assessment (FASA), Preparation for NRC Problem Identification and

FASA, Emergency Preparedness Program

FASA, Operations Standards

FASA, Operator Fundamentals

FASA,

NEI 08-07 for LGS Security, 2011,

IR 1140938

FASA, Generic Letter 89-13, 2011,

IR 1138044 FASA, Plant Improvement Process, 2011,

IR 1138055 Check-In Self-Assessment, Security Search Processes,

IR 1319500

Check-In Self-Assessment, EOC Engineering Performance Monitoring,

IR 1319766

Resolution Inspection, August 2012 (AR 01317145)

Check-In Self-Assessment, UFSAR Update Compliance Check-In (AR

131130 Check-In Self-Assessment, Safety Culture Survey Check-In plan & Approval Assignment OPEX

Program (AR 01137212)

Check-In Self-Assessment, CAP Quality

LMI Backlog Reduction: Maintenance

Attachment Issue Reports

(* indicates that condition report was generated as a result of this inspection)

0105608

0138075

219148

0644942

28111

0874599

0916037

0932781

0935522

0952219

0952695

0952910

0953032

0953714

1008113

1043440

1049144

1065596

1075848

1083732

1084172

1088044

1089704

1089777

1089945

1090043

1090672

1092186

1092190

1095500

1107986

1112160

1114118

1117397

1126485

29709

1138044

1142397

1144567

1148121

1148274

1151320

1151321

1151354

1151764

1152249

1152382

1152591

1153519

1156960

1158168

1160445

1164021

1166306

1166763

1166932

1167295

1167903

1168410

1170958

1173566

1181279

1186147

1189330

1200001

201717

203601

204897

1224283

1230409

230613

238874

239365

242426

1244969

1248979

258322

276176

290928

1296602

1297367

299616

1312492

1313443

1313897

1314434

1314807

20143

22653

24530

1327746

1327817

28562

28685

1331127

1332374

1334650

1335126

1336987

1337375

1337749

1337856

1341136

1342560

1343301

1345006

1346091

1346455

1347887

1347906

1351594

1352071

1352860

1352930

1353276

1353888

1356297

1356770

1357529

1365199

1366175

1366579

1368968

1371755

1374944

1375497

1378538

1381595

1382262

1384549

1384878

1386343

1390033

1391598

1392061

1392651

1392730

1392943

1402816

1402900

1406101

1406105

1406113

1406115

1406117

1406118

1412661

1412675

21857

1423970

1426057

26226

27060

28812

1429672

29761

1430132

1430233

1432872

1436439*

1437539*

1437638*

1437657*

1467777 A1076981 A1565999

A1566223

A1648156

Attachment

Action Requests

A1845735 A1435950 A1851320

A1211162

A1481462

A1695149

A1845735 A1743488 A1864995

A1851320

A1211162

A1481462 A1695149

00880889

00885591

00908974

00994647

01071136

01083732

01084172

01102717

01110466

01114118

01116115

01126485

01139033

01139385

01142397

01151354

01168410

01184333

213452

227977

231897

235013

01238043

01244969

01244990

01249109

254845

260861

269903

01297569

01310370

01319906

01320066

01320143

01328685

01334650

01343301

01346455

01353888

01359061

01371381

01377559

01380101

01384034

01385606

01386437

01388653

01401328

01405112

01407477

01411487

01411994

01425404

01757154

NCVs and Findings

NCV 2010-04-03, Failure to perform a PM required by the PCM template not implemented with subsequent failure of D23,

IR 1065596-50

FIN 2010-04-03, Failure to Identify Incorrectly Adjusted Control Power Relay Resulting in Unit 1 Manual Scram,

IR 1083732 16,17,18,19, 20

LER 2010-001-00, U2 Hi-Hi radiation alarm set point for the process radiation monitor on the reactor enclosure cooling water system (RECW), was discovered exceeding the TS value,

IR 1084172-08

NCV 2010-07-01, Failure to complete UFSAR updates within the required time interval,

IR 1442397-18

NCV 2010-07-02, Failure to perform increased unit cooler flushes per procedure when the unit cooler (1A RHR room) was running due to temperature controller deficiency,

IR 1142397-18

NCV 2010-402-02, Failure to provide adequate intrusion detection in the OCA,

IR 105608-09

and 10

NCV 2011-02-01, Unit 2 main steam line response time without corrective action,

IR 1167295-10, 21, and

IR 1168410-25

NCV 2011-02-02, Licensee Event Report 2011-001; Changed modes with a Unit 2 inoperable remote shutdown instrument (RHR heat exchanger bypass valve position indicator); AR

1167295/1168410

NCV 2011-05-001, Seismic Unusual Event notification; Failure to provide a timely Unusual Event notification for the August 23, 2011 seismic event;

AR 1254845

NCV 2011-06-01, Inadequate corrective actions for previous NRC finding for programmatic deficiencies in the preventative maintenance program,

IR 1114118-16

NCV 2011-503-01, Emergency Action Level HU6 non-conservative change; Failure to provide an adequate 50.54q review (reduction in effectiveness of the Emergency Plan for a 15 minute classification of a fire delay);

AR 1184333

NCV 2012-08-01, Failure to include in LER

2-2011-003 that HPCI was inoperable while RCIC was inoperable, TS 3.0.3 should have been entered,

IR 1377559-03

NCV 2012-401-01, Failure to perform a thorough search of an incoming vehicle in the sally port,

IR 1353276-07

Attachment

Procedures

8031-M1-B32-C001, Technical Manual for RCP, Revision 001

AD-LG-101-1002, Temporary Changes to Approved Documents and Partial Procedure Use, Revision 010

ARC-MCR-107/207 A2, Turbine Control Valve/Stop Valve/Stop Valve Scram Bypassed, Revision 004

ARC-MCR-111 A1, 'A' Recirculation Pump Seal Stage HI/LO Flow, Revision 000

CC-AA-112, Temporary Configuration, Revisions 17 & 18

CC-AA-4008, Engineer of Choice (EOC) Performance Monitoring and Improvement, Revision 001

CY-LG-120-852, Temporary Chemical Treatment of the Clarified Water System, Revision 4

E-011-00100, Sheet 029, Rev 0000, Layout Drawing MCC Cubicle

HV-051-1F024B

EI-AA-1, Safety Conscious Work Environment, Revision 3

EI-AA-101, Employee Concerns Program, Revision 10

EI-AA-101-1002, Employee Issues Trending, Revision 7

ER-AA-2002, System Health Monitoring, Revision 015

ER-AA-2003, System Performance Monitoring and Analysis, Revision 009

ER-AA-600, Risk Management, Revision 006

ER-AA-600-1011, Risk Management Program, Revision 011

HU-AA-104-101, Procedure Use and Adherence, Revision 5

HU-AA-1212, Technical Task Risk/Rigor Assessment, Pre-job Brief, Independent Third Party Review, and Post-job Brief, Revision 004

IC-11-02002, Emergency Diesel Generator Voltage Regulators, Revision 014

IER 11-3, Weakness in Operator Fundamentals

LS-AA-106, Plant Operations Review Committee (PORC), Revision 007

LS-AA-115, Operating Experience Program, Revision 17

LS-AA-115-1001, Processing of Level 1 OPEX Evaluations, Revision 5

LS-AA-115-1002, Processing of Level 2 OPEX Evaluations, Revision 3

LS-AA-115-1003, Processing of Level 3 OPEX Evaluations, Revision 2

LS-AA-115-1004, Processing of NERS and NNOES, Revision 002

LS-AA-120, Issue Identification and Screening Process, Revision 14

LS-AA-125, Corrective Action Program (CAP) Procedure, Revision 17

LS-AA-125-1001, Root Cause Analysis Manual, Revision 10

LS-AA-125-1002, Common Cause Analysis Manual, Revision 7

LS-AA-125-1003, Apparent Cause Evaluation Manual, Revision 010

LS-AA-125-1004, Effectiveness Review Manual, Revision 5

LS-AA-125-1005, Coding and Analysis Manual, Revision 8

LS-AA-126, Self-Assessment and Benchmarking Program, Revision 007

LS-AA-126-1001, Focused Area Self-Assessments, Revision 7

LS-AA-126-1005, Check-In Self-Assessments, Revision 5

LS-AA-126-1006, Self-Assessment and Bench (SAB) Program, Revision 3

LS-AA-127, Passport Action Tracking Management Procedure, Revision 10

LS-AA-1012, Safety Culture Monitoring, Revision 2

M-020-002, Fairbanks Morse Opposed Piston Diesel Engine Examination and General

Maintenance, Revision 006

M-043-013, Reactor Recirculation Pump N-7500 Mechanical Seal Test, Revision 003

M-200-037, Q Listed HVAC Heating and Cooling Coil Clean/Flush, Revision 008

MA-AA-716-010, Maintenance Planning, Revision 020

MA-AA-716-210, Performance Centered Maintenance (PCM) Process, Revision 014

MA-MA-716-009, Preventative Maintenance Deferral Justification Checklist, Revision 004

M-C-756-001, HPCI Turbine Inspection, Revision 28

Attachment

OP-AA-101-113, Operator Fundamentals, Revision 007

OP-AA-102-103-1001, Operator Burden and Plant Significant Decisions Impact Assessment Program, Revision 4

OP-AA-106-101-1001, Event Response Guidelines, Revision 019

OP-AA-106-101-1005, Quarantine of Areas, Equipment and Records, Revision 000

OP-AA-108-115, Operability Determinations, Revision 011

OP-AA-108-117, Protected Equipment Work Approval, Revision 002

OP-AA-109-101-1001, Clearance and Tagging HIT Team Performance Management Process, Revision 005

OP-LG-103-102-1000, Human Performance Continuing Good Practices, Revision 41

OP-LG-103-102-1002, Strategies for Successful Transient Mitigation, Revision 11

OP-LG-101-111-2000, On Shift Personnel Specific Procedure Use, Revision 8

PI-AA-1001, Performance Improvement Integrated Matrix, Revision 001

RT-1-012-390-0, RHR Heat Exchanger Heat Transfer Performance Computation Test, Revision 009

RT-6-055-330-1, HPCI Turbine Over-speed Mechanism Operability Check, Revision 020

RT-6-055-340-2, HPCI Turbine Hydraulic Control System Operability Check, Revision 9

RT-6-092-454-1, Procedure for De-energizing and Re-energizing the D14 Safeguard Bus during

a Refuel Outage, Revision 011 S43.3.A, Filling and Venting 'A' Recirculation Pump Loop and Seal, Revision 046 S94.2.A, By-Passing and Removing the 'A' RPS and UPS Static Inverter from Service, Revision 016

S94.9.A, Routine Inspection of 'A'(B) RPS UPS Static Inverter, Revision 015

Shift Training Documentation Doc Type 807

SO-11-013

ST-2-036-419-2, RPS - Electrical Power Monitoring Channel 'A' and 'C' Calibration/Functional Test, Revision 018

ST-6-022-252-0, Diesel Driven Fire Pump Flow Test, Revision 030

ST-6-049-202-1, RCIC Cold Shutdown Valve Test, Revision 24

ST-6-049-230-1, RCIC Pump, Valve and Flow Test, Revision 76

SY-AA-101-112, Exelon Security Search Process, Revision 025

SY-AA-101-112-F-01, Vehicle Search Place Keeping Aid, Revision 001

WC-AA-120, Preventative Maintenance (PM) Program Requirements, Revision 000