IR 05000352/2020010

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Title 10 of the Code of Federal Regulations 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components Inspection Report 05000352/2020010 and 05000353/2020010
ML20073H282
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 03/11/2020
From: Glenn Dentel
Engineering Region 1 Branch 2
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
Dentel G
References
IR 2020010
Download: ML20073H282 (9)


Text

March 11, 2020 Mr. Bryan Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 SUBJECT: LIMERICK GENERATING STATION, UNITS 1 AND 2 - TITLE 10 OF THE CODE OF FEDERAL REGULATIONS 50.69 RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS, AND COMPONENTS INSPECTION REPORT 05000352/2020010 AND 05000353/2020010

Dear Mr. Hanson:

On February 27, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Limerick Generating Station, Units 1 and 2, and discussed the results of this inspection with Mr. Frank Sturniolo, Site Vice President, and other members of your staff.

The results of this inspection are documented in the enclosed report.

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

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Glenn T. Dentel, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 05000352 and 05000353 License Nos. NPF-39 and NPF-85

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000352 and 05000353 License Numbers: NPF-39 and NPF-85 Report Numbers: 05000352/2020010 and 05000353/2020010 Enterprise Identifier: I-2020-010-0008 Licensee: Exelon Generation Company, LLC Facility: Limerick Generating Station, Units 1 and 2 Location: Sanatoga, PA 19464 Inspection Dates: February 10, 2020 to February 27, 2020 Inspectors: E. DiPaolo, Senior Reactor Inspector (Team Lead)

F. Arner, Senior Reactor Analyst S. Haney, Resident Inspector A. Patel, Senior Reactor Inspector Approved By: Glenn T. Dentel, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Title 10 of the Code of Federal Regulations (10 CFR) 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components Inspection at Limerick Generating Station, Units 1 and 2, in accordance with the Reactor Oversight Process.

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

List of Findings and Violations No findings or violations of more than minor significance were identified.

Additional Tracking Items None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter 2515, Light-Water Reactor Inspection Program -

Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

37060 - 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components Inspection 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components Inspection

(1) The inspectors reviewed the licensees program and procedures associated with 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors, license amendment described in the plant safety evaluation and Updated Final Safety Analysis Report, and documented in the staffs Safety Evaluation Report (ADAMS Accession No. ML18165A162). The inspectors reviewed the licensees 10 CFR 50.69 categorization process and alternate treatment requirements completed on the following systems:

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

  • On February 27, 2020, the inspectors presented the 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components Inspection results to Mr. Frank Sturniolo, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

37060 Calculations 1-09-059 Pipe Stress Analysis 12

Corrective Action 3984984

Documents 4159984

214649

214654

24273

231629

232738

244378

244380

244440

250921

255997

256574

259201

267276

268323

271437

276932

287925

288001

288385

298778

299068

4312075

Corrective Action 4172733-40, 41

Documents 4317285

Resulting from 4319388

Inspection 4321736

21932

Engineering Engineering A Spray Pond Spray Network Piping Replacement Flange 2

Changes Change 629220 Addition and Strut Modification

PMC-18-114354 Change Drywell HVAC Fan Motor Rebuild Frequency (EQ) 02/27/2019

and Condition Based (Non EQ)

PMC-18-115736 Standby Liquid Control Pump Relief Valve Frequency 09/10/2019

Extension

PMC-19-116197 Alternative Treatment Maintenance Strategy for Core Spray 12/03/2019

RISC-3 Check Valve Inspection Preventive Maintenance

PMC-19-116869 RISC-3 Electric O-ring EEQ for System 57 10/09/2019

PMC-19-117859 RISC-3 System 052 (Core Spray) Motor Operated Valves 01/03/2020

Alternate Treatment

PMC-19-117911 Alternative Treatment for Core Spray RISC-3 Components 09/06/2019

PMC-19-119782 Alternate Treatment for System 20 Diesel Generator, Diesel 10/07/2019

Generator Fuel Oil Storage Transfer, and Diesel Generator

Heating, Ventilation and Air Conditioning RISC-3

Components

Engineering LG-5060-012-003 10 CFR 50.59 System Categorization Document-Residual 1

Evaluations Heat Removal Service Water System

LG-5069-011-003 10 CFR 50.69 System Categorization Document-Emergency 1

Service Water System

LG-5069-020- 10 CFR 50.69 System Categorization Document-Diesel 1

081-092-003 Generator

LG-5069-051-003 10 CFR 50.69 System Categorization Document-Residual 1

Heat Removal System

LG-5069-052-19- 10 CFR 50.69 Immediate Review of the Core Spray System 02/05/2019

IM-01

LG-5069-055- 10 CFR 50.69 System Categorization Document-HPCI 1

056-003 System

LG-MISC-035 NRC 10 CFR 50.69 Inspection Support for Limerick 0

Generating Station

N-00E-117-00010 10 CFR 50.69 Success Path Components Lists for Limerick 0

Generating Station Units 1 and 2

Miscellaneous Exelon letter to

U.S. NRC, Limerick Generating Station, Units 06/28/2017

and 2, Application to Adopt 10 CFR 50.69, Risk-Informed

Categorization and Treatment of Structures, Systems, and

Components for Nuclear Power Plants

Exelon letter to

U.S. NRC, Limerick Generating Station, Units 08/14/2017

and 2, Supplement to Application to Adopt 10 CFR 50.69,

Risk-Informed Categorization and Treatment of Structures,

Systems, and Components for Nuclear Power Plants

Exelon letter to

U.S. NRC, Limerick Generating Station, Units 01/19/2018

and 2, Response to Request for Additional Information,

Application to Adopt 10 CFR 50.69, Risk-Informed

Categorization and Treatment of Structures, Systems, and

Components for Nuclear Power Plants

Exelon letter to

U.S. NRC, Limerick Generating Station, Units 04/23/2018

and 2, Response to Request for Additional Information,

Application to Adopt 10 CFR 50.69, Risk-Informed

Categorization and Treatment of Structures, Systems, and

Components for Nuclear Power Plants

Exelon letter to

U.S. NRC, Limerick Generating Station, Units 07/27/2018

and 2, Supplement to Application to Adopt 10 CFR 50.69,

Risk-Informed Categorization and Treatment of Structures,

Systems, and Components for Nuclear Power Plants

U.S. NRC Issuance of Amendments Nos. 230 and 193 to 07/31/2018

Adopt Title 10 of the Code of Federal Regulations Section

50.69, Risk-Informed Categorization and Treatment of

Structures, Systems and Components for Nuclear Power

Reactor

Entergy Response to Request to NRC Request for Additional 08/06/2007

Information Regarding Alternative ANO2-R&R-004 Revision

LG-5060-055- Integrated Decision Making Panel Meeting Minutes for

056-19-04 06/25/2019

LG-5069-078- 50.69 Integrated Decision-Making Panel Meeting Minutes for

090-19-012 05/04/2019

LG-5069-078- 50.69 Integrated Decision Making Panel Meeting Minutes for

090-19-012, 05/04/2019

Regulatory Guide An Approach for Determining the Technical Adequacy of 2

1.200 Probabilistic Risk Assessment Results for Risk-Informed

Activities

Shift Order 19- License Amendment Implementing 10 CFR 50.69

001

Miscellaneous Shift Order-19- 10 CFR 50.69 Supplement-Issue Report Screening

050

Procedures ER-AA-569 10 CFR 50.69 Program 3

ER-AA-569-1001 10 CFR 50.69 Active Component Risk Significance Insights 3

ER-AA-569-1002 10 CFR 50.69 Passive Component Categorization 2

ER-AA-569-1003 10 CFR 50.69 Risk Informed Categorization for Structures, 5

Systems, and Components

ER-AA-569-1003- 10 CFR 50.69 System Categorization Document 5

F-01

ER-AA-569-1004 10 CFR 50.69 Alternative Treatment Implementation Process 3

ER-AA-569-1005 Integrated Decision-Making Panel for Risk Informed SSC 5

Categorization Duties and Responsibilities

ER-AA-569-1006 Requirements for Immediate, Interim, and Periodic 2

Performance Monitoring Reviews

ER-AA-569-1007 Job Familiarization of 50.69 Project Team and Site Personnel 4

LS-AA-1110 Exelon Reportabilty Reference Manual 29

T-300 FLEX Pump Setup at Spray Pond 3

Self-Assessments IR 4276932 Limerick February 2020 50.69 NRC Inspection Self- 11/18/2019

Assessment

NOSA-LM-19-05 Engineering Design Control Audit Report 08/07/2019

Report 032362- PRA Focused-Scope Peer Review and Finding Level Fact 0

RPT-10 and Observation Independent Assessment

7