IR 05000352/2011002

IR 05000352-11-002, 05000353-11-002, on 01/01/2011 - 03/31/2011, Limerick Generating Station, Unit 1 & 2, Problem Identification and Resolution

ML111170224
Person / Time
Site:	Limerick
Issue date:	04/27/2011
From:	Krohn P G Reactor Projects Region 1 Branch 4
To:	Pacilio M J Exelon Nuclear, Exelon Generation Co
Krohn P G
References
IR-11-002
Download: ML111170224 (30)

Text

with copies to the RegionalAdministration, Region l; the Director, Office of Enforcement, U. S. Nuclear RegulatoryCommission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Limerickfacility. lf you disagree with the cross-cutting aspect assigned to any finding in this report, youshould provide a response within 30 days of the date of this inspection report, with the basis foryour disagreement, to the RegionalAdministrator, Region I and the NRC Senior ResidentInspector at the Limerick facility. The information you provide will be considered in accordancewith Inspection Manual Chapter 0305.

M. PacilioIn accordance with 10 Code of Federal Regulations (CFR) Part 2.390 of the NRC's "Rules ofPractice," a copy of this letter, its enclosure, and your response (if any) will be availableelectronically for public inspection in the NRC Public Document Room or from the PubliclyAvailable Records (PARS) component of the NRC's document system (ADAMS). ADAMS isaccessible from the NRC Website at http://www.nrc.sov/readinq-rm/adams.html (the PublicElectronic Reading Room).

Sincerely,47"J,-*. APaul G. Krohn, Chief -uProjects Branch 4Division of Reactor ProjectsDocket Nos: 50-352, 50-353License Nos: NPF-39, NPF-85

Enclosure:

Inspection Report 05000352/2011002and 0500035312011002M

Attachment:

Supplemental Informationcc w/encl: Distribution via ListServ M. PacilioIn accordance with 10 Code of Federal Regulations (CFR) Part 2.390 of the NRC's "Rules ofPractice," a copy of this letter, its enclosure, and your response (if any) will be availableelectronically for public inspection in the NRC Public Document Room or from the PubliclyAvailable Records (PARS) component of the NRC's document system (ADAMS). ADAMS isaccessible from the NRC Website at http:l/www.nrc.qov/readinq-rm/adams.html (the PublicElectronic Reading Room).

Sincerely,/RA/Paul G. Krohn. ChiefProjects Branch 4Division of Reactor ProjectsDocketNos: 50-352,50-353License Nos: NPF-39, NPF-85

Enclosure:

Inspection Report 05000352/2011002and 0500035312011002W

Attachment:

Supplemental InformationDistribution w/encl: (via e-mail)W. Dean, RAD. Lew, DRAD. Roberts, DRPJ. Clifford, DRPC. Miller, DRSP. Wilson, DRSP. Krohn, DRPA. Rosebrook, DRPE. Torres. DRPS. lbarrola. DRPE. DiPaolo, DRP, SRIN. Sieller, DRP, RlN. Esch, DRP, AAS. Bush-Goddard, Rl, OEDORidsNrrPMLimerick ResourceRidsNrrDorlLpl 1 -2ResourceROPreportsResourceSUNSI Review Gomplete: PGK (Reviewer*s Initials)M1111170224DOC NAME: G:\DRP\BRANCH4\I NSPECTION REPORTS\LIMERICK\201 1 \LIM 1 STQ2011\LlM 2011-002 REV 0.DOCXAfter declaring this document "An Official Agency Record" it will be released to the Public.To receive a copy of this document, indicate in box"C- = Copy w/out atlachmenUenclosure "E' = Copy w/attachmenUenclosure "N' = No copyOFFICE mmtRI/DRPRI/DRPNAMEEDiPaolo/PGKPKrohn / PGKDATE0411411104125111ICIAL RECORD COPY U. S. NUCLEAR REGULATORY COMMISSIONREGION IDocket Nos: 50-352,50-353License Nos: NPF-39, NPF-85Report No: 05000352/2011002 and 0500035312011002Licensee: Exelon Generation Company, LLCFacility:Limerick Generating Station, Units 1 & 2Location: Sanatoga, PA 19464Dates:January 1,2Q11 through March 31,2011Inspectors: E. DiPaolo, Senior Resident InspectorN. Sieller, Resident InspectorT. Moslak, Health PhysicistApproved by: Paul G. Krohn, ChiefProjects Branch 4Division of Reactor ProjectsEnclosure 2

SUMMARY OF FINDINGS

I R 050003521201 1002; 05000353 l2V fiA2; 01 101 1201 1 -03131 1201 1 ; Limerick GeneratingStation, Units 1 and 2; Problem ldentification and Resolution.The report covered a three-month period of inspection by resident inspectors and a healthphysicist. One Green, non-cited violation (NCV) finding was identified. The significance of mostfindings is indicated by their color (Green, White, Yellow, Red) using lnspection Manual Chapter(lMC) 0609, "significance Determination Process (SDP)." Findings for which the SDP does notapply may be Green or be assigned a severity level after NRC management review. Cross-cutting aspects associated with findings were determined using IMC 0310, "Components withinthe Cross-Cutting Areas," dated February 2010. The NRC's program for overseeing the safeoperation of commercial nuclear power reactors is described in NUREG-1649, "ReactorOversight," Revision 4, dated December 2006.Gornerstone: Barrier Integrity.

Green.

The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B,Criterion XVl, "Corrective Action Program," because Exelon did not adequatelyevaluate and correct a condition adverse to quality regarding repeat failures of aTechnical Specification (TS) surveillance test (ST). Specifically, on July 13,2010,Exelon generated issue report (lR) 1091132to document that ST-2-041-909-2,theUnit 2 Main Seam Line (MSL) Flow - High Response Time Test, had failed its pasttwo performances. In both instances, in October 2008 and July 2010, multipleresponse time values exceeded the TS requirements, and Exelon had to replaceseveral relays to bring the values back into compliance. After the 2008 failureExelon performed an apparent cause evaluation (ACE) and generated one correctiveaction (CA) and several action items (AClTs) to address the causes. Following the2010 failure, Exelon did not evaluate the repeat failure or generate any additionalactions. The inspectors determined that the CA and ACITs from 2008 did notthoroughly address the MSL Flow - High test failure, and the repeat test failure in2010 was an opportunity for Exelon to re-evaluate the issue and pursue moreappropriate and timely corrective actions. Exelon's failure to evaluate and correct acondition adverse to quality regarding repeat failures of a TS surveillance test wasdetermined to be a performance deficiency (PD).The PD was determined to be more than minor because it was associated with theSystem, Structure, and Component & Barrier Performance attribute of the ReactorSafety - Barrier lntegrity cornerstone. The PD adversely atfected the cornerstoneobjective of providing reasonable assurance that physical design barriers protect thepublic from radionuclide releases caused by accidents or events. The finding wasdetermined to be of very low safety significance (Green) in accordance withInspection Manual Chapter 0609, Attachment 4, "Phase 1 - Initial Screening andCharacterization of Findings," because it did not represent an actual open pathway inthe physical integrity of reactor containment. The inspectors determined this findinghad a cross-cutting aspect in the area of Problem ldentification and Resolution,Corrective Action Program, because Exelon did not thoroughly evaluate the repeatMSL response time test failures to ensure the underlying causes were identified andresolved. P.1(c) (Section 40A2.2)

4Licensee-ldentified ViolationsA violation of very low safety significance, which was identified by the licensee, hasbeen reviewed by the inspectors. Corrective actions taken or planned by the licenseehave been entered into the licensee's corrective action program. This violation andcorrective actions are listed in Section 4OA7 of this report.Enclosure 5

REPORT DETAILS

Summarv of Plant StatusUnit 1 began the inspection period operating at full rated thermal power (RTP). On January 21,operators reduced power to approximately 40 percent to facilitate troubleshooting of the 'A' maingenerator stator cooling water (SCW) pump discharge check valve, conduct control rod scramtime testing, and conduct secondary plant maintenance. Power was returned to full RTP onJanuary 23. Operators performed a follow-up down power to approximately 80 percent tofacilitate a control rod pattern adjustment on January 28. The unit was returned to full RTP onJanuary 29. On March 3, operators reduced power to approximately 90 percent to facilitateclosing the #4 main turbine control valve following the discovery of an electro-hydraulic controlsystem leak from an instrument line. Following repairs, operators returned the unit to full RTPon March 5. On March 18, operators reduced power to approximately 22 percent to facilitateremoving the main turbine from service to perform extent-of-condition repairs on the EHCsystem and other secondary plant maintenance. The main generator was synchronized to thegrid on March 20 and full RTP was attained on March 24. Later on March 24, operatorsconducted a planned downpower to approximately 94 percent to facilitate main turbine valvetesting. Operators identified a secondary instrumentation power supply problem and performeda subsequent unplanned downpower to approximately 53 percent until repairs could becompleted. Power ascension commenced on March 26, and full RTP was attained on March28. Unit 1 remained at full RTP for the remainder of the inspection period.Unit 2 began the inspection period operating at full RTP. On January 2, operators reducedpower to approximately 88 percent to perform a control rod pattern adjustment. The unit wasrestored to full RTP later that day. On January 8, a planned downpower to approximately 90percent was performed to facilitate control rod scram time testing. The unit was returned to fullRTP later that day. On January 18, Unit 2 entered end-of-cycle coastdown and feedwatertemperature reduction operations, as planned, in advance of the Unit 2 refueling outage. OnFebruary 25, operators inserted an unplanned manual scram per procedural requirementsfollowing a main turbine runback and the loss of both reactor recirculation pumps (RRPs) due toa sensed high temperature condition on the main generator SCW system. On February 26operators placed Unit 2 in Operational Condition (OPCON) 4 (Cold Shutdown) to facilitatestarting the 'A' RRP. A reactor startup was commenced later that day, and the main generatorwas synchronized to the grid on February 28. Full RTP was attained on March 2. On March 3operators performed a follow-up downpower to approximately 75 percent to facilitate a controlrod pattern adjustment, and the unit was returned to full RTP later that day. On March 27,operators commenced a reactor shutdown from a maximum attainable power of 89 percent tocommence refueling outage 2R11. Unit 2 remained in the refueling outage for the remainder ofthe inspection period.1. REACTORSAFETYCornerstones: Initiating Events, Mitigating Systems and Barrier lntegrity1R01 Adverse Weather ProtectionSite lmminent Weather Conditions (71111.01 - 1 sample)Enclosure 6a. lnspection ScopeThe inspectors evaluated implementation of adverse weather preparation procedures asa result of a winter storm warning being issued for Montgomery County, Pennsylvaniafor February 1. The inspectors verified that Exelon entered the appropriate proceduresand conducted walkdowns of the site, as necessary, to ensure plant equipment wouldnot be affected by the adverse weather. The inspectors reviewed Exelon's plans toaddress the ramifications of potentially lasting effects that may have resulted from theadverse weather conditions. Documents reviewed are listed in the Attachment.b. FindinqsNo findings were identified.

1R04 EquipmentAlignment

.1 PartialWalkdown (71111.04Q - 3 samples)a. lnspection ScopeThe inspectors performed partial walkdowns of the plant systems listed below to verifyoperability following realignment after a system outage window or while safety-relatedequipment in the opposite train was inoperable, undergoing surveillance testing, waspotentially degraded. The inspectors used TS, Exelon operating procedures, plantpiping and instrumentation diagrams, and the Updated Final Safety Analysis Report(UFSAR) as guidance for conducting partial system walkdowns. The inspectorsreviewed the alignment of system valves and electrical breakers to ensure proper in-service or standby configurations as described in plant procedures and drawings.During the walkdowns, the inspectors evaluated the material condition and generalhousekeeping of the systems and adjacent spaces. The documents reviewed are listedin the Attachment, The inspectors performed walkdowns of the following areas:r Emergency dieselgenerator (EDG) D12 and D13 when otfsite source wasunavailable due to EDG D14 24-hour run on January 25;o Unit 2 'A' and 'C' low pressure coolant injection (LPCI) trains when 'D' LPCI was out-of-service (OOS); ando Unit 2'B' and'D' core spray (CS) system while protected during refueling outage(RFO) 2R11.b. FindinqsNo findings were identified..2 Complete Svstem Walkdowns (71111.04S - 1 sample)a. Inspection ScopeThe inspectors conducted one complete system walkdown of the Unit 2 CS system toverify that equipment was properly aligned and there were no apparent deficiencies thatcould affect the ability of the system to perform its functions. The walkdown included averification of valve positions, major system components, electrical power availability,Enclosure 7and general equipment condition. The inspectors also reviewed outstandingmaintenance work requests, outstanding design issues, a five year history of issuereports and equipment performance history to determine if there were any outstandingdeficiencies that could affect the ability of the system to perform its function. Thedocuments reviewed are listed in the Attachment.b. FindinqsNo findings were identified.

1R05 Fire ProtectionFire Protection - Tours (71111.05Q - 5 samples)a. Inspection ScopeThe inspectors conducted a tour of the five areas listed below to assess the materialcondition and operational status of fire protection features. The inspectors verified thatcombustible materials and ignition sources were controlled in accordance with Exelon'sprocedures. Fire detection and suppression equipment was verified to be available foruse, and passive fire barriers were verified to be maintained in good material condition.The inspectors also verified that station personnel implemented compensatory measuresfor out-of-service, degraded, or inoperable fire protection equipment in accordance withthe station's fire plan. The documents reviewed are listed in the Attachment. Theinspectors toured the following areas:. Remote Shutdown Room (Fire Area 26);o Unit 2 'B' and 'D' Residual Heat Removal (RHR) Heat Exchanger and Pump Room(Fire Area 55);o Unit 1 Refueling Area (Fire Area 78);. Unit 2 Refueling Area (Fire Area 78); ando Unit 2 High Pressure Coolant Injection (HPCI) Pump Room (Fire Area 57).b. FindinosNo findings were identified.1R06 Flood Protqction Measures (71111.06 - 1 sample)a. Inspection ScopeThe inspectors reviewed the UFSAR and related flood analysis documents to identifyareas that can be affected by internalflooding, to identify features designed to alertoperators of a flooding event, and to identify features designed for coping with internalflooding. The inspectors performed a walkdown of the Unit 2 RHR rooms. Theinspectors observed flood protection features to assess their ability to minimize theimpact of a flooding event and verified that important features (i.e., door seals and floordrain check valves) had scheduled periodic preventive maintenance. The inspectorsperformed a review of operator actions contained in off-normal procedures for flooding toEnclosure

8verify that the actions can reasonably be used to achieve the desired outcome. Thedocuments reviewed are listed in the Attachment.b. FindinosNo findings were identified.

1R11 Licensed Operator Requalification Program Quarterly Review (71111.11Q - 1 sample)a. lnspection ScopeOn January 25,2011, the inspectors observed a licensed operator requalificationsimulator training session. The simulator scenario, LSES-0071, tested the operators'ability to respond to operating equipment failures, a recirculation pump seal failure, anda leak from the reactor water clean-up system. The inspectors observed licensedoperator performance including operator criticaltasks, which are required to ensure thesafe operation of the reactor and protection of the nuclear fuel and primary containmentbarriers. The inspectors also assessed crew dynamics and supervisory oversight toverify the ability of operators to properly identify and implement appropriate TS actions,regulatory reports, emergency event declarations, and notifications. The inspectorsobserved training instructor critiques and assessed whether appropriate feedback wasprovided to the licensed operators.b. FindinqsNo findings were identified.1R12 Maintenance Effectiveness (71111.12Q - 2 samples)a. lnspection ScopeThe inspectors evaluated Exelon's work practices and follow-up corrective actions fortwo issues within the scope of the maintenance rule. The inspectors reviewed theperformance history of these systems, structures, and components (SSCs) andassessed the effectiveness of Exelon's corrective actions, including any extent-of-condition determinations to address potential common cause or generic implications.The inspectors assessed Exelon's problem identification and resolution actions for theseissues to evaluate whether Exelon had appropriately monitored, evaluated, anddispositioned the issues in accordance with Exelon procedures and the requirements of10 CFR Part 50.65, "Requirements for Monitoring the Etfectiveness of Maintenance." Inaddition, the inspectors reviewed the maintenance rule classifications, performancecriteria, and goals for these SSCs and evaluated whether they appeared reasonable andappropriate. The documents reviewed are listed in the Attachment. The inspectorsreviewed the following issues:. lR 1124563, Unit 2 CS inverter failure; ando Unit 1 and Unit 2 main steam line (MSL) response time test failures.b. FindinosNo findings were identified.Enclosure

91R13 Maintenance Risk Assessments and Emerqent Work Control (71111.13 - 6 samples)a. Inspection ScopeThe inspectors evaluated the effectiveness of Exelon's maintenance risk assessmentsrequired by 10 CFR Part 50.65(aX4). This inspection included discussion with controlroom operators and risk analysis personnel regarding the use of Exelon's on-line riskmonitoring software. The inspectors reviewed equipment tracking documentation, dailywork schedules, and performed plant tours to gain assurance that the actual plantconfiguration matched the assessed configuration. Additionally, the inspectors verifiedthat Exelon's risk management actions, for both planned and emergent work, wereconsistent with those described in Exelon procedure, ER-M-600-1042, "On-Line RiskManagement." The documents reviewed are listed in the Attachment. The inspectorsreviewed the following samples:o Unit 1 on-line risk with the 'B' SCW pump considered unavailable due to the 'A'SCW pump discharge check valve sticking open (lR 1154333);o Unit 1 on-line risk with 'A' RHR pump inoperable during EDG D22 run on January 3,2011;. Unit 1 load drop and troubleshooting the 'A' SCW discharge check valve on January22,2011;o Unit 2 on-line risk during emergent EDG D23 system outage window due toFairbanks Morse Parl2l notification from February 9 -16;o Emergent work activities, troubleshooting, and compensatory measures for Unit 2reactor enclosure degraded plant page system (lR 1 178554); and. Unit 2 on-line risk during emergent replacement of EHC system power supplyreplacement on February 28,2O11.b. FindinqsNo findings were identified.

1R15 Operability Evaluations (71111

.15 - 6 samples)a. Inspection ScopeThe inspectors assessed the technical adequacy of a sample of six operabilityevaluations to ensure that Exelon properly justified TS operability and verified that thesubject component or system remained available such that no unrecognized increase inrisk occurred. The inspectors reviewed the UFSAR to verify that the system orcomponent remained available to perform its intended safety function. In addition, theinspectors reviewed compensatory measures implemented to ensure that the measuresworked and were adequately controlled. The inspectors also reviewed a sample of lRsto verify that Exelon identified and corrected deficiencies associated with operabilityevaluations. The documents reviewed are listed in the Attachment. The inspectorsreviewed the following evaluations:. lR 1162162,'B' residual heat removal service water (RHRSW) return pipe supportfound out of tolerance;. lR 1164062, Elevated particle count on HPCI booster pump oil;Enclosure

10. lR 1089727, Technical Evaluation of HPCI system operation causing CS systemrelief valve (PSV-052-1(2)F0128) to lift;. lR 1162162, Excess gap on RHRSW pipe hanger;. lR 1172445, Technical Evaluation of EDG 23 during time period when defectivebearings were installed; and. lR 1191498, Main turbine stop valve failed to close during test.b. FindinosNo findings were identified.

1R18 Plant Modifications (7111.18 - 1 sample)a. Inspection ScopeThe inspectors reviewed permanent modifications associated with motor control centeropen and close contactor replacements (lR 1 165946) to ensure that installation of themodifications did not adversely affect systems important to safety. The inspectorscompared the modifications with the UFSAR and TS to verify that the modifications didnot atfect system operability, availability, or adversely affect plant operations. Theinspectors ensured that station personnel implemented the modifications, in accordancewith the configuration change process and verified that necessary training to operatorswere implemented. The impact on existing procedures was reviewed to verify Exelonmade appropriate revisions to reflect the changes. The documents reviewed are listedin the Attachment.b. FindinosNo findings were identified.1R19 Post-Maintenance Testins (71111.19 - 5 samples)a. lnspection ScopeThe inspectors reviewed five post-maintenance tests to verify that procedures and testactivities ensured system operability and functional capability. The inspectors reviewedExelon's test procedures to verify that the procedures adequately tested the safetyfunctions that may have been affected by the maintenance activity, and that theacceptance criteria in the procedures were consistent with information in licensing anddesign basis documents. The inspectors also witnessed the test or reviewed test data toverify that the results adequately demonstrated restoration of the affected safetyfunctions. The documents reviewed are listed in the Attachment. The inspectorsreviewed the following samples:o C0233933, Replace Unit 1 reactor protection system main turbine first stagepressure bypass trip unit (PlS-001-1N652B);o C0236457, Troubleshoot and repair Unit 1 scram discharge volume inboard ventisolation valve (XV-047-1F010) slow stroke time;. R1 156847, Place back-up voltage regulator rectifier back in service for EDG D14;Enclosure

11. C0236820, Replace EDG D23 engine bearings subject to Fairbanks Morse Part21;and. C0236624, lJnit 2 tuel pool seal rupture instrument repairs.b. FindinqsNo findings were identified.

1R20 Refueling and Other Outage Activities

.1 Unit 2 Refueling--Outaoe (RFO) (71111.20 - 1 partial sample)a. lnspection ScopeThe inspectors reviewed the station's work schedule and outage risk plan for theLimerick Unit 2 maintenance and refueling outage (2R11), which commenced onMarch 28,2011. The inspectors reviewed Exelon's development and implementation ofoutage plans and schedules to verify that risk, industry experience, previous site-specificprobiems, and defense-in-depth were considered. At the end of the inspection period,Unit2was in OPCON 5 (Refueling), with the reactor cavity flooded. This sample will becompleted in the second quarter ol2011 after Unit 2 returns to OPCON 1. Documentsreviewed are listed in the Attachment. During the outage, the inspectors observedportions of the shutdown and cooldown processes and monitored Exelon controlsassociated with the following outage activities:. Configuration management, including maintenance of defense-in-depth,commensurate with the outage plan for the key safety functions and compliance withthe applicable TS when taking equipment OOS;. Post-shutdown primary containment walkdown to identify any abnormal conditionsthat may have existed during the previous operating cycle;. lmplementation of clearance activities and confirmation that tags were properly hungand that equipment was appropriately configured to safely support the associatedwork or testing;o Installation and configuration of reactor coolant pressure, level, and temperatureinstruments to provide accurate indication and instrument error accounting;. Status and configuration of electrical systems and switchyard activities to ensure thatTS were met:o Monitoring of decay heat removal operations;. lmpact of outage work on the ability of the operators to operate the spent fuel poolcooling system;o Reactor water inventory controls, including flow paths, configurations, alternativemeans for inventory additions, and controls to prevent inventory loss;. Activities that could affect reactivity;o Maintenance of secondary containment as required by TS;o Refueling activities, including fuel handling and fuel receipt inspections; ando ldentification and resolution of problems related to refueling outage activities.b. FindinosNo findings were identified.Enclosure 12.2 Unit 1 Manual Scram Forced Outaqe (71111.20 - 1 Sample)a. lnspection ScopeThe inspectors evaluated the activities associated with the forced outage (2F43) thatoccurred as a result of a Unit 2 manual reactor scram on February 25,2011. Operatorsinserted a manual scram per procedural requirements in response to the trip of bothRRP motor-generator sets. The RRP motor-generators tripped as designed following amain turbine runback as a result sensed high temperature on the main generator SCWsystem. Unit 2 was taken to OPCON 4 (Cold Shutdown) to facilitate recovery from theforced outage. A reactor startup was commenced on February 26 following reviews andthe completion of other maintenance activities. The documents reviewed are listed inthe Attachment. From February 26 through March 3,2011, the inspectors monitored theactivities listed below:. Limerick's forced outage plan, including appropriate consideration of risk, industryoperating experience, and previous site-specific problems;. Plant Operations Review Committee and Outage Control Center meetings;o Reactor water inventory controls, including flow paths, configurations, alternativemeans for inventory additions, and controls to prevent inventory loss;o Monitoring of decay heat removal operations;. ldentification and resolution of problems related to refueling outage activities; and. Portions of the reactor startup and ascension to full-power operation.b. FindinqsNo findings were identified.

1R22 Surveillance Testino (71111.22 - 5 samples; 2 routine surveillances and 3 in-servicetesting (lST))a. lnspection ScopeThe inspectors either witnessed the performance of, or reviewed test data, for fivesurveillance tests (STs) associated with risk-significant SSCs. The reviews verified thatExelon personnelfollowed TS requirements and that acceptance criteria wereappropriate. The inspectors also verified that the station established proper testconditions, as specified in the procedures, that no equipment preconditioning activitiesoccurred, and that acceptance criteria were met. The documents reviewed are listed inthe Attachment. The inspectors reviewed the following samples:. 5T-6-012-231-0, 'A'Loop RHRSW Pump, Valve and Flow Test (lST);. 5T-6-055-200-1, Unit 1 HPCI Valve Test (lST);o 5T-6-092-324-1, D14 Diesel Generator LOCA/LOAD Reject Testing and Fast StartOperability Test Run;. PM 392607 , Perform loaded test of 8.5.b portable 125VDC power supply forsafety/relief valve operation; and. 5T-6-047-200-1, Scram Discharge Volume Valve Exercise Test (lST).Enclosure

13b. FindinqsNo findings were identified.Cornerstone: Emergency PreparednesslEPO Drill Evaluation (71114.06 - 1 sample)The inspectors observed a tabletop drill in the Technical Support Center conducted onFebruary 1, 2011 , to assess Exelon's emergency response organization's (ERO's)implementation of the Limerick emergency plan and implementing procedures. Theinspectors reviewed the ERO's response to simulated degraded plant conditions toidentify weaknesses and deficiencies in classification, notification, and protective actionrecommendation development activities. The inspectors observed Exelon's critiques ofthe drill to evaluate their ability to identify weaknesses and deficiencies at an appropriatethreshold. The inspectors verified that the licensee appropriately assessed EROperformance with regard to activities contributing to the Drill and Exercise performanceindicator (Pl) training evolution and drills.b. FindinosNo findings were identified.2.

RADIATION SAFETY

Cornerstone:

Occupational Radiation Safety2RS02 OccupationalALARA Planning and Controls (71124.02 - 1 partial sample)a. Inspection ScopeDuring the period January 10 - 14,2011, the inspector conducted the following activitiesto verify that the licensee was properly implementing operational, engineering, andadministrative controls to maintain personnel exposure as low as is reasonablyachievable (ALARA) in making preparations for the Unit 2 Spring RFO (2R11).lmplementation of this program was reviewed against the criteria contained in 10 CFR20, applicable industry standards, and the licensee's procedures. Documents reviewedare listed in the Attachment.Radioloqical Work PlanninsThe inspector reviewed the preparations being made for performing radiologicallysignificant tasks during the Spring 2011 Unit 2 RFO (2R11). Included in this review werethe ALARA Plans (AP) for alljobs whose dose was estimated to exceed 5 person-rem.These jobs included replacement of the 28 RHR heat exchanger (AP 2011-027), reactorcavity work platform activities (AP 2C11-A41\, reactor cavity decontamination (AP 2011-042), refuel floor middle activities (2011-039), and reactor reassembly (AP 2011-040).ln performing this review, the inspector evaluated contamination control measures, useof portable ventilation systems, use of temporary shielding, and the control of systemEnclosure 14drain-downs. Additionally, the inspector evaluated the departmental interfaces betweenradiation protection, operations, maintenance crafts, and engineering to identify missingALARA program elements and potential interface problems. The evaluation wasaccomplished by reviewing recent Station ALARA Council meeting minutes, NuclearOversight Objective Evidence Reports, and interviewing the site Radiation ProtectionManager and Radiological Engineering Manager regarding the 2R11 preparations.b. FindinqsNo findings were identified.2RS03 ln-Plant Airborne Radioactivity Control and Mitigation (71124.03 - 1 partial sample)a. lnspection ScopeDuring the period January 10 - 14,2011, the inspector conducted the following activitiesto verify that in-plant airborne concentrations of radioactive materials were beingcontrolled and monitored, and to verify that the practices and use of respiratoryprotection devices were properly implemented.lmplementation of these programs was evaluated against the criteria contained in10 CFR 20, applicable industry standards, and the licensee's procedures. Documentsreviewed are listed in the Attachment.Enqineerinq ControlsThe inspector verified that the licensee uses installed ventilation systems as part of itsengineering controls (in lieu of respiratory protection devices) to control airborneradioactivity. The inspector reviewed procedural guidance for use of an installedsystem, the control room emergency fresh air system (CREFAS) and determined thatthe system was operable. The inspector reviewed surveillance testing procedures andrelated data to confirm that the CREFAS airflow capacity, flow path, and charcoal/HEPAfilter efficiencies met regulatory criteria and are consistent with maintainingconcentrations of airborne radioactivity as low as practicable. The inspector verified thesystem configuration by walking down components with the cognizant system engineer.The inspector evaluated the use of in-plant continuous air monitors to determine if themonitors were appropriately located in areas where airborne radioactivity couldpotentially result from normal plant operations and that the systems were operable. Withthe assistance of a senior radiation technician, the inspector observed weekly sourcechecks of monitors located in the turbine buildings, fuel floor, reactor buildings, andtechnical support center, and determined that the alarm setpoints were appropriatelyestablished.Through review of relevant procedures and analytical data, the inspector determined thatthe licensee has established an alpha and transuranic radiation monitoring program.Included in this program were trigger points for conducting additional measurements toassure that the airborne concentrations were properly characterized and that bioassaymeasurements were taken. should the need arise.Enclosure 15Use of Respiratorv Protection DevicesThe inspector observed the respirator fit testing of four (4) individuals to determine if thetesting was appropriately conducted per the procedural guidance. Additionally, theinspector confirmed that the individuals tested had completed the requisite training andwere medically qualified to wear a respirator.The inspector examined various negative pressure, self-contained, and supplied airrespiratory protection devices and determined that these devices were certified for useby the National Institute for Occupational Safety and Health/Mine Safety and HealthAdministration.The inspector reviewed the records of air testing for supplied service air devices andself-contained breathing apparatus (SCBA). The air used in these devices appropriatelyexceeded the quality requirements for Grade D quality.Self-Contained Breathino Apparatus for Emeroencv UseThe inspector evaluated the adequacy of the respiratory protection program regardingthe maintenance and issuance of SCBA to emergency response personnel. Trainingand qualification records were reviewed for at least three (3) licensed operators fromeach of the operating shifts, and for selected radiation protection personnel who wouldwear SCBAs in the event of an emergency. The inspector observed technicians performfunctional inspections on three (3) SCBAs staged in the Control Room and two (2)SCBAs staged on the Unit 2 turbine deck. Maintenance, hydrostatic test records, andflow test records for selected SCBAs, staged in other plant areas, were reviewed. Themethod of refilling SCBA cylinders was evaluated and the compressor air sample resultswere reviewed to confirm that the air quality met CGA G-7.1, Grade E (2004) standards.Through review of training lesson plans and interviews, the inspector confirmed thatindividuals qualified to wear SCBAs were trained in replacing spent air cylinders.Problem ldentification and ResolutionThrough review of lRs and Nuclear Oversight audits and field observations, the inspectorverified that problems associated with the control and mitigation of in-plant airborneradioactivity are being identified at an appropriate threshold and are properly addressedfor resolution in the corrective action program.b. FindinosNo findings were identified.4.

4OA1 Performance Indicator (Pl) VerificationInitiatino Events and Mitisatinq Svstems Cornerstone Pls (71151- 6 samples)a. lnspection ScopeEnclosure

b.16The inspectors sampled Exelon's submittal of the Initiating Events cornerstone andMitigating Systems cornerstone Pls listed below to verify the accuracy of the datarecorded from January 2010 - December 2010. The inspectors utilized performanceindicator definitions and guidance contained in Nuclear Energy Institute (NEl) 99-02,"Regulatory Assessment Performance Indicator Guidelines," Revision 6, to verify thebasis in reporting for each data element. The inspectors reviewed various documents,including portions of the main control room logs, issue reports, power history curves,work orders, and system derivation reports. The inspectors also discussed the methodfor compiling and reporting performance indicators with cognizant engineering personneland compared graphical representations from the most recent Pl report to the raw datato verify that the report correctly reflected the data. The documents reviewed are listedin the Attachment.Cornerstone: lnitiatinq Events. Units 1 and 2 Unplanned Power Changes (1E03).Cornerstone: Mitiqatinq SvstemsUnits 1 and2 Mitigating System Performance lndex (MSPI) - High Pressure lnjectionSystem (MS07); andUnits 1 and2 MSPI - Heat Removal System (MS08).FindinosNo findings of significance were identified.fdentification and Resolution of Problems (71152 - 1 sample)Review of ltems Entered into the Corrective Action Proqram (CAP)Inspection ScopeAs required by lnspection Procedure 71152, "ldentification and Resolution of Problems,"and in order to help identify repetitive equipment failures or specific human performanceissues for follow-up, the inspectors screened all items entered into Limerick's CAP. Theinspectors accomplished this by reviewing each new condition report, attendingmanagement review committee meetings, and accessing Exelon's computerizeddatabase.FindinosNo findings were identified.Annual Sample: Main Steam Line Flow - Hiqh Response Time Test Repeat Failureslnspection ScopeThe inspectors reviewed Exelon's actions in response to a repeat failure of the Unit 2MSL Flow - High Response Time Test. The inspectors reviewed the originalfailure toassess the adequacy of Exelon's evaluation and corrective actions. The inspectors4c,F.2.1a,b..2Enclosure 17reviewed the repeat failure to determine whether Exelon appropriately evaluated the newinformation and assessed whether additional actions were warranted. The inspectorsinterviewed plant personnel, reviewed CAP documents, and held discussions withExelon management. Specific documents reviewed are listed in the Attachment.b. Findinss and ObservationsIntroduction. The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B,Criterion XVl, "Corrective Action Program," because Exelon did not adequately evaluateand correct a condition adverse to quality regarding repeat failures of a TS ST.Description. On July 13, 2010, Exelon generated lR 1091 132 to document thatST-2-041-909-2, the Unit 2 MSL Flow - High Response Time Test, Revision 9, had failedits past two performances. ln both instances, in October 2008 and July 2010, multipleresponse time values exceeded the TS requirements, and Exelon had to replace severalrelays to bring the values back into compliance. The lR stated that the Agastat relaysbeing acquired for this application appeared to be slower than the older Agastat relays.The lR recommended several actions to address the problem, including: working withthe vendor to determine if any changes were made to the manufacturing process;evaluating whether a license amendment could be submitted to change or eliminate theTS requirement; and considering procurement of a faster relay. Of these threerecommendations, Exelon generated a formal assignment to address only the first.Assignment 3 of lR 1091132 required Materials to work with the vendor to determine ifthere were any manufacturing differences that could account for the slower responsetimes. The assignment was closed on February 3,2011 stating: "The vendor hasreviewed the data and has deemed that their manufacturing of these relays has notchanged from the originals supplied and meets the industry standards for this type ofrelay."The inspectors reviewed lR 1091 1 32 and noted that Exelon had not thoroughlyevaluated the repeat test failure and had not developed any corrective actions. Tobetter understand the history of the issue, the inspectors researched the original failedST from October 2008. The inspectors discovered that an ACE had been performed byExelon at that time, under lR 830810. The ACE identified that the Agastat relays were,by design, too slow for the intended application. The TS required response time for theMSL Flow - High circuit was 145 msec, which was a cumulative response time for onetrip unit and three relays. However, adding up the individual maximum response timesspecified by the vendor for the trip unit and three Agastat relays yielded a response timeof 199 msec. The ACE therefore concluded that "the Tech Specs required responsetime was not quite compatible with the cumulative vendor specified response time of thetrip unit and the relays." The ACE also noted that the cumulative response time of testsperformed in 2006 and 2008 were comparatively higher than those performed in earlieryears, and concluded that "based on this observation, it is suspected that the newvintage relays are slower."The 2008 ACE resulted in one CA and severalAClTs. The CA was to increase relayreplacement frequency from every six years to every four years. This was based onExelon's determination that "as a natural phenomenon, the response time of relaycontacts may increase as the relays age." The ACITs included contacting the vendor toconfirm that changes were not made to the relays that could have impacted theresponse time, and evaluating whether a TS change should be pursued to increase theEnclosure 18response time to make it more compatible with the vendor specified relay responsetimes,The inspectors determined that the CA and ACITs from 2008 did not thoroughly addressthe MSL Flow - High test failure, and the repeat test failure in 2010 was an opportunityfor Exelon to re-evaluate the issue and pursue more appropriate and timely correctiveactions. Specific rationale is provided below:. The inspectors determined the 2008 CA was not appropriate to address the slowresponse time test. The action was to increase the relay replacement frequencyfrom six years to four years. However, the inspectors noted that after the 2008 testfailure, two separate relays were replaced by Exelon to bring the response time backinto compliance. Both relays were only three years and seven months old.Additionally, when the 2010 test failure occurred, all of the relays in the affectedcircuits were less than two years old. Therefore, a four year replacement periodicitywould not have prevented either ST failure. The 2010 test failure was an opportunityto identify this inconsistency and develop a more appropriate CA.. Regarding the 2008 ACIT to contact the vendor and determine if any changes hadbeen made to the relays, the inspectors noted that the ACIT was completed inJanuary 2009. The closure documentation stated that "the supplier has confirmedthat no changes have been made that would affect [relay] quality." Yet after the testfailure in2010, the only assignment created from lR 1091132was to contact thevendor and determine if any changes had been made to the relays. A thoroughevaluation in 2010 would have revealed that this action had already been pursued -with no success'in 2008.. Regarding the 2008 ACIT to consider a TS amendment to change the response timerequirements, the inspectors noted that this action was closed in February 2009 toanother lR, lR 644942. This lR had been created by Licensingin20OT to look intoremoving TS response time requirements. Despite lR644942 being generated in2007 , and the ACIT being closed to it in 2008, as of March 2011 no actions had beentaken by Exelon to initiate the TS amendment. A thorough evaluation in 2010 mayhave allowed Exelon to pursue this action in a more timely manner.The inspectors discussed the above issues with Exelon management, who agreed thatlR 1091 132 had not been properly evaluated in 2010. Exelon generated lR 1 186147 tocapture this deficiency and perform an ACE. Corrective actions for the repeat MainSteam Line Flow - High Response Time Test failures will be developed from the sameACE.Analvsis. The inspectors determined that Exelon's failure to evaluate and correct acondition adverse to quality regarding repeat failures of a TS surveillance test was aperformance deficiency (PD). The PD was determined to be more than minor because itwas associated with the SSC & Barrier Performance attribute of the Reactor Safety -Barrier lntegrity cornerstone. This attribute includes availability and reliability of SSCsneeded to maintain the containment barrier. The PD adversely affected the cornerstoneobjective of providing reasonable assurance that physical design barriers protect thepublic from radionuclide releases caused by accidents or events. Specifically, on twodifferent instances, in 2008 and 2010, the Unit 2 MSL Flow - High Response Time Testfailed to meet the response times required by the Limerick TS, which would impact theclosure time for the main steam isolation valves. The finding was determined to be ofEnclosure 4043.1a.19very low safety significance (Green) in accordance with Inspection Manual Chapter0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings,"because it did not represent an actual open pathway in the physical integrity of reactorcontainment.The inspectors determined this finding had a cross-cutting aspect in the area of Problemldentification and Resolution, Corrective Action Program, because Exelon did notthoroughly evaluate the repeat MSL response time test failures to ensure the underlyingcauses were identified and resolved. P.1(c) Specifically, because Exelon did notevaluate the repeat test failure in July 2010, they did not identify that the CA from the2008 ACE was inadequate to resolve the condition, and that the ACIT to consider a TSamendment was not being pursued in a timely manner.Enforcement. 10 CFR Part 50, Appendix B, Criterion XVl, "Corrective Action," requires,in part, that measures be established to assure that conditions adverse to quality, suchas failures, deficiencies, and non-conformances, are promptly identified and corrected.Contrary to this requirement, Exelon failed to correct a condition adverse to qualityassociated with repeat failures of ST-2-041-909-2, the U2 Main Seam Line Flow - HighResponse Time Test, on October 14,2008 and July 13,2010. Because this violationwas determined to be of very low safety significance and has been entered into theExelon Corrective Action Program as lR 1 186147, it is being treated as an NCV,consistent with section 2.3.2 of the Enforcement Policy. (NCV 05000352,353/2011001-01, Failure to Address Repeat TS Response Time Test Failures.)Event Follow-up (71153

• 3 samples)Plant EventsInspection ScopeFor the three plant events listed below, the inspectors reviewed and/or observed plantparameters, reviewed personnel performance, and evaluated performance of mitigatingsystems. The inspectors communicated the plant events to appropriate regionalpersonnel and compared the event details with criteria contained in lnspection ManualChapter 0309, "Reactive Inspection Decision Basis for Reactors," for consideration ofpotential reactive inspection activities. As applicable, the inspectors verified that Exelonmade appropriate emergency action classification assessments and properly reportedthe event in accordance with '10 CFR Parts 50.72 and 50.73. The inspectors reviewedExelon's follow-up actions related to the events to assure that appropriate correctiveactions were implemented commensurate with their safety significance.o Fairbanks Morse EDG Part 21 impact on EDG D23;o Unit 2 manual scram due to loss of recirculation pumps following a SCW runback onFebruary 25,2011; ando Unit 1 unplanned down power to 90 percent on March 3 due to electro-hydrauliccontrol system leak on #4 control valve instrument fitting.FindinqsNo findings were identified.b.Enclosure 20.2 Licensee Event Report (LER) 05000353/2011001-00: Condition Prohibited by TechnicalSpecifications due to lnoperable Remote Shutdown Panel lnstrument. On January 26,2011, during surveillance testing, Exelon identified that the Unit 2'A'RHR heatexchanger bypass valve position indication on the remote shutdown panelwasinoperable per TS LCO 3.3.7.4, "Remote Shutdown System Instrumentation andControls," due to excessive instrument drift. The investigation determined that the maincontrol room indication for the valve was identified as drifting out of tolerance on March20,2009. At the time of identification, operators did not identify that the loop transmitterwas the cause of the drifting indication. The transmitter is shared by the main controlroom and remote shutdown panelvalve indicators. Unit 2 entered OPCON 2 (Startup)on April 11,2009. Therefore, Unit 2 entered into an OPCON when LCO 3.3.7.4 was notmet which is contrary to TS LCO 3.0.4. The enforcement aspects of this issue arediscussed in Section 4OA7. The inspectors did not identify any new issues during thereview of the LER. This LER is closed.40A6 Meetinqs. Includino ExitOn April 8, the inspectors presented the inspection results to Mr. W. Maguire and othermembers his staff. The inspectors confirmed that proprietary information was notincluded in the inspection report.40.A7 Licensee-ldentified ViolationsThe following violation of very low safety significance (Green) was identified by Exelonand is a violation of NRC requirements which met the criteria of the NRC EnforcementPolicy for being dispositioned as an NCV.o Unit 2 TS LCO 3.0.4 requires that, when an LCO is not met, entry into an OPCON orother condition in the Applicability shall only be made if specified conditions in LCO3.0.4 were met. TS LCO 3.3.7.4 "Remote Shutdown System lnstrumentation andControls," requires the RHR Heat Exchanger Bypass Valve (HV-C-S1-2F048A)Position Indication (0-10070) [Table 3.3.7.4-1, Instrument 15]to be restored tooperable 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 /> withan Applicability in OPCONS 1 and 2. Contrary to LCO 3.0.4, on April 11, 2009, Unit2 entered OPCON 2 with the position indication for HV-C-51-2F048A inoperable andspecified conditions in LCO 3.0.4 were not met. The cause of the failure to meetLCO 3.0.4 was due to less than adequate administrative barriers being present toallow licensed operators to properly assess the TS impact of the deficiency. Also,operators did not use all available tools and resources at that time to validate theinitial operability determination. This issue was entered into Exelon's CAP as lR1168410. The finding was determined to have very low safety significance (Green)in accordance with NRC IMC 0609, Attachment 4, "Phase 1 - Initial Screening andCharacterization of Finding," Mitigating Systems, because the finding did notrepresent an actual loss of safety function or screen as potentially risk significant dueto a seismic, flooding, or severe weather initiating event.ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

W. Maguire, Site Vice President

P. Gardner, Plant Manager

S. Johnson, Assistant Plant Manager

R. Dickinson, Director of Training

E. Dennin, Director of Operations

R. Kreider, Director of Maintenance

P. Colgan, Director of Work Management

C. Gerdes, Security Manager

D. Merchant, Radiation Protection Manager

D. Palena, Manager Nuclear Oversight

J. Hunter, Manager, Regulatory Assurance

N. Dennin, Shift Operations Superintendent

J. Risteter, Manager, Technical Support Health Physics

R. Harding, Regulatory Assurance Engineer

R. Rhode - Licensed Operator Requalification Training SupervisorM. Barth, Systems EngineerJ, Bendyk, HVAC System Engineer

T. Donovan, Radiation Protection Technician, Respiratory Protection

D. Doran, Director of Engineering

J. Duskin, lnstrumentation Physicist

R. Gosby, Radiation Protection Technician, Instrumentation

C. Gray, Field Operations Manager, Radiation Protection

P. lmm, Manager, Radiological Engineering

M. McGill, Engineer, Limerick Engineering Response Team

L. Parlatore, Respiratory Protection Physicist

NRC Personnel

E. DiPaolo, Senior Resident Inspector

N. Sieller, Resident Inspector

A. Rosebrook, Senior Project Engineer

T. Moslak, Health PhysicistOther Personnel:

M. Murphy, Inspector, Commonwealth of PennsylvaniaAttachment

A_2

LIST OF ITEMS

OPENED OR CLOSEDOpenedNoneClosed05000353/201 1 001 -00Opened and

Closed

05000352, 353/201 1 001 -01DiscussedNoneLERCondition Prohibited by TechnicalSpecification due to lnoperable RemoteShutdown Panel Instrument (Section4OA3.2)Failure to Address Repeat TS ResponseTime Test Failures (Section 40422)NCV

LIST OF DOCUMENTS REVIEWED

Common ReferencesLimerick Unit 1 and Unit 2 UFSARLimerick Unit 1 and Unit 2 TSsLimerick Unit 1 and Unit 2 Technical Requirements ManualLimerick Unit 1 and Unit 2 Operator Logs

==Section 1R01: Adverse Weather ProtectionProceduresSE-g, Preparation for Severe Weather, Revision 27SE-14, Snow, Revision 14WC-M-101 , On-Line Work Control Process, Revision 17Section 1R04: Equipment Aliqnmentlssue Reports1166399 10097561115912Procedures392.9.N, Routine Inspection of the Diesel Generators, Revision

592551 .1 .A (COL-1), Equipment Alignment for Automatic Operation of the==

RHR System in theLPCI Mode, Revision 17OP-M-108-117, Protected Equipment Program, Revision 12552.1.A (COL-2), Equipment Alignment for Core Spray Loop 'B' Operation, Revision 82552.1.A (COL 1), Equipment Alignment for Core Spray Loop 'A' Operation, Revision 72S52.1.A (COL 2), Equipment Alignment for Core Spray Loop 'B' Operation, Revision 8L-S-44, Core Spray System, Revision 10Attachment

A-3MiscellaneousUFSAR Section 6.3, Emergency Core Cooling Systems, Revision 15

Section 1R05: Fire ProtectionProceduresF-A-540, Limerick Generating Station Pre-Fire Plan, Common, Remote Shutdown Room,Revision 9F-R-174, Limerick Generating Station Pre-Fire Plan, Unit 2,'B'and 'D'RHR Heat Exchangerand Pump Rooms, Revision 6F-R-700, Limerick Generating Station Pre-Fire Plan, Unit 1, Refueling Area Room, Revision 11F-R-708, Limerick Generating Station Pre-Fire Plan, Unit 2, Refueling Area, Revision 7F-R-180, Limerick Generating Station Pre-Fire Plan, Unit 2,

HPCI Pump Room, Revision 8

==Section 1R06: Flood Protection MeasuresProceduresUFSAR Section 9,3.3, Plant Drainage SystemL-T-09, Internal Hazards Topical Design Basis Document, Revision 5Drawing 8031-M-61, Liquid Radwaste CollectionSE-4-1, Reactor Enclosure Flooding, Revision 8Section 1 R12: Maintenance Effectivenesslssue Reports1090202

973821

688396 1124563MiscellaneousTechnical Evaluation

688396-07, Actual lmpact of Failure of lnvertersRegulatory Guide 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power PlantsA1315016-09,==

PM Deferral for E/S X-M1-21014, June 4,201041315016-10, PM Deferralfor E/S X-M1-21014, September 30, 2010ProceCuresER-LG-310-1010, Maintenance Rule lmplementation, Revision 14MA-M-7 1 6 -210, Perlormance Centered Maintenance Process, Revision 1 0MA-AA-716-009, Preventive Maintenance (PM) Work Order Process, Revision 5ER-AA-310-1004, Maintenance Rule - Performance Monitoring, Revision 8

Section 1Rl3: Maintenance Risk Assessments and Emerqent Work GontrolProceduresTroubleshooting, Rework, and Testing Control FormWC-LG-101-1001, Guideline for the Performance of On-Line Work/On-Line System Outages,Revision 14WC-LG-104-1001, Guideline for the Review, Screening and Execution of Operational RiskActivities, Revision 0EP-AA-1000, Exelon Nuclear Standardized Radiological Emergency Plan, Revision 20EP-AA-1008, Limerick Generating Station Annex, Revision 19MiscellaneousLG-CRM-O10, Units l and 2Paragon Yd Model Changes, Revision 0Work OrderC0237126, Replace Unit 2 electro-hydraulic control system power supplyAttachment

A-4

Section 1Rl5: Operabilitv Evaluationslssue Reports1164062ProceduresMA-AA-716-230-1001, Oil Analysis Interpretation Guide, Revision 12MiscellaneousCalculation

M-52-23, Core Spray System Flow Device and Pressure Relief Valve Design Data,Revision 0Calculation M-55-24, Total System Developed Head for Mode D Operation, Revision 1Calcuation M-52-32, Overpressure Protection Report for Core Spray System, Revision 1Part21 Notification-Turbine Control System lmpact on Transient Analysis, November 12,20Q4Engineering Safety Analysis Transmittal of Design lnformation ES0900029, December 17,2009Technical Evaluation of

EDG 23, March 8,2011

Section 1R18: Plant Modificationslssue Reports1 1 65946Work OrdersR0926125-02, Clean, Examine, and Calibrate

MCU D244-R-E-16

==Section 1R19: Post-Maintenance Testinqlssue Reports1 16351 1

1159144

993047

808401 1018647ProceduresST-6-092-934-1, D14 Diesel Generator Governor and Voltage Regulator Post MaintenanceTesting, Revision 65T-6-012-231-0,'A' Loop==

RHRSW Pump, Valve, and Flow Test, Revision 57RT-6-092-313-2,D23 Diesel Generator Run-ln, Revision 23MA-AA-716-012, Post Maintenance Testing, Revision 12MiscellaneousDrawing Number M-1-C71-1022, Elementary Diagram for Reactor Protection System, Revision24Drawing Number M-1-C71-1020-E-015, Elementary Diagram for Reactor Protection System,Revision 10Fairbanks Morse Part21 Notification Number 10-06Regulatory Guide 1.9, Application and Testing of Safety Related Diesel Generator in NuclearPower Plants, March 2007IEEE Standard 387-1995, Criteria for Diesel Generator Units as Standby Power Supplies forNuclear Power Generating StationsWork OrderC0228961, Replace

XV-047-1F010 air regulatorC0235902, Replace solenoid associated with

XV-047-1 F010R1108794-01, 'A' Loop RHRSW Pump, Valve, and Flow Test, October 4,2008R1113372-01, 'A' Loop RHRSW Pump, Valve, and Flow Test, December 28, 2008Attachment

A-5

Section 1R20: Refuelinq and Other Outase ActivitiesProceduresGP-18,

SCRAM/ATWS Event Review, Revision 58GP-2, Normal Plant Startup, Revision 136OU-AA-103, Shutdown Safety Management Program, Revision 112GP-6.1, Shutdown Operations-Refueling, Core Alterations and Core Off-Loading, Revision 21GP-3, Normal Plant Shutdown, Revision 129OU-AB-4001, BWR Fuel Handling Practices, Revision 5OP-AA-300-1520, Reactivity Management-Fuel Handling Storage and Refueling, Revision 3S97.0.M, Refueling Platform Operation, Revision 282R11 Shutdown Safety Plan

==Section 1R22: Surveillance Testinqlssue Reports1163684

1159672

1182533

1143434

736684 1178728ProceduresOP-LG-1 08-1 01 -1 004, Valves, Revision 4OP-AA-103-105, Limitorque motor- operated valve operations, Revision 25T-6-107-201-0,IST Valve Stroke for New Baseline, Revision 4TSG-4.1, Limerick Generating Station Operational Contingency Guidelines, Revision 9MiscellaneousC0236338, Torque packing and back seat Unit 1==

HPCI main steam supply outboard isolationvalve (HV-055-1F003)Calculation

LE-0069, Class 1E 125 Volt DC System Voltage Analysis, Revision 17Test Results Evaluation for 5T-6-092-324-1, February 22,2011Work OrdersR1

109568, D1 4 governor and voltage regulator post maintenance test, Janua ry 24, 2011R1118302, D14 LOCA/Load Reject Testing and Fast Start Operability Test Run, February 22,20112RS02 Occupational ALARA Plannins and Controls2R11 ALARA Plans (AP)AP 2011-010, lnstallation and Removal of Scaffolding, Unit 2 Drywell 2R11AP 2011-016, SRV Replacement 2R11 (14 planned)AP 2011-027, Replace 28 RHR Heat ExchangerAP 2011-034, Undervessel Control Rod Drive ExchangeAP 2011-039, 2R11 Refuel Floor Outage Middle ActivitiesAP 2011-040, Reactor ReassemblyAP 2011-041, Reactor Cavity Work Platform ActivitiesAP 2011-042, Reactor Cavity Decontamination2RS03 In-Plant Airborne Radioactivitv Control and Mitiqationlssue Reports0879950

0909005

0917008

0931820

0953303 09614860963706

1014292

1043823

1050097

1075743 10885021093113

1095677

1139033

1140518 1 154820Attachment

A-6ProceduresRP-M-220, Bioassay Program, Revision 7RP-LG-220-1002, Perform Calibration Checks and Whole Body Count on the FastScan,Revision 4RP-AA-302, Determination of Alpha Levels and Monitoring, Revision 3RP-M-870-1001, Set-up and Operation of Portable Air Filtration Equipment, Revison 2RP-AA-870-1002, Use of Vacuum Cleaners in Radiologically Controlled Areas, Revision 1RT-0-111-900-0, One Hour SCBA Cylinder Inspection and Functional Test, Revision 28RT-0-000-981-0, Routine Bioassay, Revision 7RP-AA-700-1301, Calibration, Source Check, Operation, and Set-up of the Eberline Beta AirMonitor,

AMS-4, Revision 0RP-AA-825-1011, lnspection and Use of the Mururoa V4 MTH2 and V$F1 Air Supplied Suits,Revision 2RP-M-825-1012,Inspection and Use of the Mururoa Blu Ethyfuge/PVC PAPR Suit, Revision 2RP-AA-443, Quantitative Respirator Fit Testing, Revision 8RT-0-01 1 1-900-0, One-Hour SCBA Cylinder Inspection and Functional Test, Revision 345T-4-078-801-0,'A' CREFAS Charcoal Analysis, Revision 65T-4-078-802-0,'B' CREFAS Charcoal Analysis, Revision 55T-2-078-301-0,'A' CREFAS Functional Test, Revision 105T-2-078-302-0,'B' CREFAS Functional Test, Revision 105T-4-078-731-0, 'A' CREFAS Charcoal Absorber/HEPA Filter Test, Revision 45T-4-078-732-0, 'B' CREFAS Charcoal Absorber/HEPA Filter Test, Revision 4Analvsis ReportsHP-00-11,

AMS-4 Operating and Alarm Parameters, Revision 1RP-11-01, CEDE Dose Assessment for HTM lsotopes for 2011, Revision 0Focused Area Self-Assessments lAuditsRadiation Protection Audit

NOSA-Llm-09-06Objective Evidence Report

NOSCPA-LG-1 0-1 5Nuclear Oversight Objective Evidence Report (AR 338414338414Calibrati.on Records ReviewedAMS-4 No. 076441SCBA Packs InspectedNos: 16,49,63,76,610Section 4OA1 : Performance Indicator Veri.ficationMiscellaneousLS-M-2001, Collecting and Reporting of NRC Performance Indicator Data, Revision 13NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6Exelon Pl Summaries for 1Q10-4Q10LG-MSPI-O01, "LGS MSPI Basis Document", Revision 3

==Section 4OA2: Problem ldentification and Resolutionlssue Reports1186147 1

186105

644942

777148 785462830810

1090202

831914

1091132 10496711050077

1052401

1053346 1053931Attachment==

A-7Section 4OA3: Event Followuplssue Reports1182842 1183330ProceduresGP-s, Steady State Operations, Revision 148

LIST OF ACRONYMS

ACE Apparent Cause EvaluationACIT Action ltemADAMS Agencywide Documents Access Management SystemAP

ALARA Plans

CA [[Corrective ActionCAP Corrective Action ProgramCFR Code of Federal RegulationsCREFAS Control Room Emergency Fresh Air SystemCS Core SprayDEP Drill and Exercise PerformanceEDG Emergency Diesel GeneratorERO Emergency Response OrganizationHPCI High Pressure Coolant InjectionIMC Inspection Manual ChaPterlR lssue ReportIST In-Service TestingLER Licensee Event ReportLPCI Low Pressure Coolant lnjectionMSL Main Seam LineMSPI Mitigating System Performance IndexNCV Non-Cited ViolationsNEI Nuclear Energy InstituteNRC Nuclear Regulatory CommissionOOS Out of ServiceOPCON Operational ConditionPD Performance DeficiencYPl Performance IndicatorPARS Publicly Available RecordsRRP Recirculation PumPRFO Refueling OutageRHR Residual Heat RemovalRHRSW Residual Heat Removal Service WaterRTP Rated Thermal PowerSCBA Self-Contained Breathing ApparatusSCW Stator Cooling WaterSDP Significance Determination ProcessSSC Structure, System, ComPonentST Surveillance TestTS Technical SpecificationUFSAR Updated Final Safety Analysis ReportAttachment]]