IR 05000352/2013002
| ML13133A342 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/13/2013 |
| From: | Mel Gray Reactor Projects Region 1 Branch 4 |
| To: | Pacilio M Exelon Nuclear, Exelon Generation Co |
| gray, mel | |
| References | |
| 1-2012-024 IR-13-002 | |
| Download: ML13133A342 (43) | |
Text
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION May 13, 2013
SUBJECT:
LIMERICK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000352/2013002 AND 05000353/2013002 and NRC OFFICE OF INVESTIGATIONS REPORT 1-2012-024
Dear Mr. Pacilio:
On March 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Limerick Generating Station, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on April 5, 2013 with Mr. T. Dougherty, Site Vice President, and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents one NRC-identified finding of very low safety significance (Green).
Additionally, a licensee-identified violation, which was determined to be of very low safety significance, is listed in this report. However, because of the very low safety significance, and because the issue has been entered into your corrective action program, the NRC is treating the licensee-identified violation as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Limerick Generating Station. In addition, 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 Limerick Generating Station. The inspection also reviewed actions regarding the identification of the failure to follow a Radiation Work Permit by an Instrumentation and Controls (I&C) technician on February 7, 2012. In response, the Region I Field Office, NRC Office of Investigations (OI), initiated an investigation on March 7, 2012, to determine whether the I&C technician deliberately entered a room posted as requiring neutron-monitoring dosimetry without obtaining the proper neutron dosimetry or having received a briefing from the Health Physics department prior to entry as required by the Radiation Work Permit. Based upon the evidence developed during the investigation, although the technician entered a room marked For entry: Neutron monitoring without having received a briefing from Health Physics or the proper neutron dosimetry, OI found insufficient evidence to conclude that the technicians actions were deliberate.
The failure to follow the Radiation Work Permit was determined to be a violation of regulatory requirements and was promptly entered into the corrective action program for evaluation and correction. The safety significance of the violation was evaluated by the NRC. The violation was found to be minor because: traditional enforcement did not apply; the violation did not have the potential to lead to a more significant safety concern; the violation did not relate to a performance indicator threshold; and, based on circumstances and radiological conditions present, the violation did not affect the applicable cornerstone objective.
Please note that final NRC documents, such as the Office of Investigations report described above, may be made available to the public under the Freedom of Information Act (FOIA) subject to redaction of information appropriate under FOIA. Requests under FOIA should be made in accordance with 10CFR 9.23, Request for Records.
In accordance with 10 Code of Federal Regulations (CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRCs document system Agency Wide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely, /RA/ Mel Gray, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos.: 50-352, 50-353 License Nos.: NPF-39, NPF-85
Enclosure:
Inspection Report 05000352/2013002 and 05000353/2013002 w/Attachment: Supplemental Information
REGION I== Docket Nos.: 50-352, 50-353 License Nos.: NPF-39, NPF-85 Report No.: 05000352/2013002 and 05000353/2013002 Licensee: Exelon Generation Company, LLC Facility: Limerick Generating Station, Units 1 & 2 Location: Sanatoga, PA 19464 Dates: January 1, 2013 through March 31, 2013 Inspectors: E. DiPaolo, Senior Resident Inspector J. Hawkins, Resident Inspector A. Rosebrook, Senior Project Engineer R. Nimitz, Senior Health Physicist E. Burket, Reactor Inspector Approved By: Mel Gray, Chief Reactor Projects Branch 4 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
Inspection Report 05000352/2013002; 05000353/2013002; 01/01/2013-03/31/2013; Limerick
Generating Station, Units 1 and 2; Operability Determinations and Functionality Assessments.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified one finding of very low safety significance (Green). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process. The cross-cutting aspects for the findings were determined using IMC 0310, Components Within Cross-Cutting Areas. Findings for which the Significance Determination Process does not apply may be Green, or be assigned a severity level after Nuclear Regulatory Commission (NRC) management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NRC technical report designation (NUREG)-1649, Reactor Oversight Process, Revision 4, dated December 2006.
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a Finding (FIN) of very low safety significance (Green) for the failure to adequately assess the operability of multiple safeguard battery chargers in a timely manner after an issue report (IR) was generated for battery charger testing concerns.
Specifically, although the IR documented as-found current limit settings for safeguard battery chargers that were below Technical Specification (TS) minimum values, the operability basis documented that no operability concern existed because the battery chargers had passed their most recent TS surveillance tests and no explanation for the unexpected test results was given. Following questions from the inspectors regarding the operability bases of the battery chargers, Exelon staff performed an in-depth operability determination which factored in battery charger maintenance history, preventive maintenance practices, past operating experience, and vendor input. Exelon personnel entered this issue into their corrective action plan (CAP) as IR1486275 and plan to perform an evaluation to address the shortcomings in the initial operability determination.
The performance deficiency was more than minor because it was associated with the Human Performance attribute of the Mitigation Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). This finding was also similar to examples 3.j and 3.k of IMC 0612, Appendix E. Specifically, in the absence of any further engineering evaluation, there was reasonable doubt of operability of multiple safeguard battery chargers at power operations. This finding was evaluated in accordance with NRC IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, and determined to be of very low safety significance (Green)because the finding does not affect the operability of the system, does not represent a loss of system and/or function, and does not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time.
The inspectors determined the finding has a crosscutting aspect in Human Performance, Decision-Making, because Exelon personnel did not make a safety-significant decision using a systematic process, especially when faced with uncertain or unexpected plant conditions, to ensure that safety was maintained. Specifically, Exelon personnel did not adequately assess the operability of multiple safeguard battery chargers in a timely manner after an IR was generated for battery charger testing concerns that called into question the operability of safeguard battery chargers [H.1(a)]. Enforcement action does not apply because the performance deficiency did not involve a violation of a regulatory requirement.
(Section 1R15)
Other Findings
A violation of very low safety significance that was identified by Exelon staff was reviewed by the inspectors. Corrective actions taken or planned by have been entered into Exelons corrective action program. This violation and corrective action tracking number are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Unit 1 began the inspection period at 100 percent power. On January 11, 2013, operators reduced power to approximately 63 percent to facilitate control rod scram time testing, a control rod pattern adjustment and to perform maintenance on the A2 moisture separator. Operators returned power to 100 percent on January 12. Power was reduce to approximately 95 percent on January 19 to facilitate a follow-up control rod pattern adjustment. Operators returned power to 100 percent later that day. On February 15, operators reduced power to approximately 92 percent to facilitate main turbine valve and main steam valve testing. Operators returned power to 100 percent on February 16. The unit remained at or near 100 percent power for the remainder of the inspection period.
Unit 2 began the inspection period at 100 percent power. On January 5, 2013 operators reduced power to approximately 60 percent to facilitate control rod scram time testing, a control rod pattern adjustment, and low pressure main turbine exhaust hood measurements. Operators returned power to 100 percent on January 6. Power was reduced to approximately 90 percent on January 12 to perform control rod scram time testing, a control rod pattern adjustment and to swap operating recirculation pump motor-generator set lubricating oil pumps. Operators returned power to 100 percent on January 13. On February 13, operators reduced power to approximately 86 percent to facilitate control rod scram time testing. Operators also removed the 6B feedwater heater from service and entered end-of-cycle coastdown and feedwater temperature reduction operations in advance of the Unit 2 refueling outage. Power was returned to 100 percent later that day. On February 10, operators reduced power to approximately 93 percent in response to a reactor pressure and power transient caused by the opening and closure of the main turbine bypass valves due to a momentary ground in the electrical system powering the electro-hydraulic control system. Following the implementation of a modification to the electro-hydraulic control system on February 12, power was returned to 100 percent. On March 24 operators commenced a reactor shutdown, from an initial maximum attainable power level of 97 percent, to commence refueling outage 2R12. At the end of inspection period Unit 2 was in Operational Condition 5 (Refueling).
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
Site Imminent Weather Conditions
a. Inspection Scope
On January 22-26, 2013, the inspectors reviewed Exelon staffs preparations in advance of and during a Cold Weather Alert issued by the National Weather Service for Montgomery County, Pennsylvania. The inspectors performed walkdowns of equipment that could be effected by the cold weather such as the emergency diesel generators (EDGs) and condensate storage tank instruments and verified that freeze protection equipment (e.g., heat trace) was in operation. The inspectors verified that Exelon personnel monitored freeze protection equipment performance and addressed emergent issues.
b. Findings
No findings were identified. ==1R04 Equipment Alignment
.1 Partial System Walkdowns
==
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems: Unit 1 high pressure coolant injection (HPCI) system when room cooler flow was secured from the B loop of emergency service water (ESW) system on January 31, 2013 (IR 1469581) Unit 1 reactor core isolation cooling (RCIC) system when room cooler flow was secured from the B loop of ESW system on January 31, 2013 (IR 1469581) EDG D23 when EDG D21 was out-of-service for unplanned maintenance on May 20, 2013 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis Report (UFSAR), TS, work orders, IRs, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Exelon staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
The inspectors performed a complete system walkdown of accessible portions of the Units 1 and 2 and safeguard direct-current (DC) power system to verify the existing equipment lineup was correct. This included Division I-IV safeguard batteries and battery chargers. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, equipment cooling, and the operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related IRs and work orders to ensure Exelon staff appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified. ==1R05 Fire Protection