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B. Hanson

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I 2100 RENAISSANCE BLVD.

KING OF PRUSSIA, PA 19406-2713

May 11, 2017 Mr. Bryan C. Hanson Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 SUBJECT: LIMERICK GENERATING STATION – INTEGRATED INSPECTION REPORT

05000352/2017001 AND 05000353/2017001 Dear Mr. Hanson: On March 31, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Limerick Generating Station (LGS), Units 1 and 2. On April 7, 2017, the NRC inspectors discussed the results of this inspection with Mr. Dave Lewis, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report. NRC inspectors documented two findings of very low safety significance (Green) in this report. One of these findings involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Limerick Generating Station. In addition, if you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 U. S. Nuclear Regulatory Commission, ATTN: Regional Administrator, Region I, and the NRC Resident Inspector at Limerick Generating Station.

B. Hanson 2 This letter, its enclosure, and your response, (if any), will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC’s Public Document Room in accordance with 10 Code of Federal Regulations (CFR) 2.390, “Public Inspections, Exemptions, Requests for Withholding.”

Sincerely, /RA/

Daniel L. Schroeder, Chief Reactor Projects Branch 4 Division of Reactor Projects

Docket Nos. 50-352 and 50-353 License Nos. NPF-39 and NPF-85 Enclosure: Inspection Report 05000352/2017001 and 05000353/2017001 w/Attachment: Supplementary Information cc w/encl: Distribution via ListServ

http://www.nrc.gov/reading-rm/adams.html

B. Hanson 3 SUBJECT: LIMERICK GENERATING STATION – INTEGRATED INSPECTION REPORT

05000352/2017001 AND 05000353/2017001 DATED MAY 11, 2017 DISTRIBUTION (via email) DDorman, RA DLew, DRA MScott, DRP DPelton, DRP RLorson, DRS JYerokun, DRS DSchroeder, DRP SBarber, DRP ATurilin, DRP SRutenkroger, DRP, SRI MFannon, DRP, RI NEsch, DRP, AA JBowen, RI, OEDO RidsNrrPMLimerick Resource RidsNrrDorlLpl1 Resource ROPreports Resource

DOCUMENT NAME: C:\Users\gxc\Desktop\Documents\LGS Inspection Report 2017-001 Final.docx ADAMS ACCESSION NUMBER: ML17131A008 SUNSI Review

Non-Sensitive Sensitive

Publicly Available Non-Publicly Available

OFFICE RI/DRP RI/DRP RI/DRP

NAME SRutenkroger SBarber DSchroeder DATE 05/03/17 05/04/17 05/11/17

OFFICIAL RECORD COPY

mailto:[email protected]

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Enclosure

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket Nos.: 50-352 and 50-353 License Nos.: NPF-39 and NPF-85 Report No.: 05000352/2017001 and 05000353/2017001 Licensee: Exelon Generation Company, LLC Facility: Limerick Generating Station, Units 1 & 2 Location: Sanatoga, PA 19464 Dates: January 1, 2017 through March 31, 2017 Inspectors: S. Rutenkroger, PhD, Senior Resident Inspector M. Fannon, Resident Inspector H. Anagnostopoulos, Senior Health Physicist J. Kulp, Senior Reactor Inspector, Team Leader

H. Gray, Senior Reactor Inspector J. Brand, Reactor Inspector

Approved By: Daniel L. Schroeder, Chief Reactor Projects Branch 4 Division of Reactor Projects

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TABLE OF CONTENTS

SUMMARY ................................................................................................................................ 1

1. REACTOR SAFETY ........................................................................................................... 3

1R01 Adverse Weather Protection ..................................................................................... 3 1R04 Equipment Alignment ............................................................................................... 3 1R05 Fire Protection .......................................................................................................... 9 1R07 Heat Sink Performance ............................................................................................ 9 1R11 Licensed Operator Requalification Program and Licensed Operator Performance ..10 1R12 Maintenance Effectiveness ......................................................................................11 1R13 Maintenance Risk Assessments and Emergent Work Control .................................11 1R15 Operability Determinations and Functionality Assessments .....................................12 1R17 Evaluations of Changes, Tests, or Experiments ......................................................12 1R18 Plant Modifications ..................................................................................................13 1R19 Post-Maintenance Testing .......................................................................................14 1R22 Surveillance Testing ................................................................................................14

2. RADIATION SAFETY.........................................................................................................15

2RS2 Occupational ALARA Planning and Controls ...........................................................15 2RS3 In-Plant Airborne Radioactivity Control and Mitigation .............................................15 2RS4 Occupational Dose Assessment ..............................................................................16 2RS5 Radiation Monitoring Instrumentation ......................................................................16

4. OTHER ACTIVITIES ..........................................................................................................17

4OA1 Performance Indicator Verification ...........................................................................17 4OA2 Problem Identification and Resolution .....................................................................18 4OA5 Other Activities ........................................................................................................19 4OA6 Meetings, Including Exit ...........................................................................................21

SUPPLEMENTARY INFORMATION ....................................................................................... A-1

KEY POINTS OF CONTACT .................................................................................................. A-1

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED .................................... A-2

LIST OF DOCUMENTS REVIEWED ....................................................................................... A-2

LIST OF ACRONYMS ........................................................................................................... A-14

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Enclosure

SUMMARY IR 05000352/2017001 and 05000353/2017001; 1/1/2017 – 3/31/2017; Limerick Generating Station (LGS), Units 1 and 2; Equipment Alignment. This report covered a three-month period of inspection by resident inspectors and announced baseline inspections performed by regional inspectors. The inspectors identified two findings, of which one was a non-cited violation, all of which were of very low safety significance (Green and/or Severity Level IV). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, “Significance Determination Process”, dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, “Aspects Within Cross-Cutting Areas,” dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRC’s Enforcement Policy, dated November 1, 2016. The NRC’s program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, “Reactor Oversight Process,” Revision 6. Cornerstone: Mitigating Systems • Green. The inspectors identified a Green NCV of 10 Code of Federal Regulations (CFR) 50,

Appendix B, Criterion V, “Instructions, Procedures, and Drawings,” for Exelon’s failure to establish instructions appropriate to the circumstances to properly stage equipment and route temporary power cables. Specifically, during cell replacement of the Class 1E ‘2A2’ 125/250 volts direct current (Vdc) safeguards battery, a portable battery charger was staged adjacent to operable ‘2A1’ battery cells and not restrained to prevent potential tipping and shorting of exposed battery cell terminals and a non-safety related extension cord was routed in near contact with exposed safety related cables in an open cable tray. Exelon moved the portable battery charger, removed and rerouted extension cords, and entered the issues into the corrective action program as issue report (IR) 3980217; IR 3980203; and IR 3983203.

This finding is more than minor because it adversely affected the configuration control attribute of the mitigating systems cornerstone to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the portable battery charger was adjacent to the ‘2A1’ battery rack and oriented such that it was susceptible to tipping over and causing electrical shorting, and a non-safety related temporary power cable connected to a non-safety related power source was routed in near contact with safety related cables in an open cable tray which introduced a potential to damage and disable safety related equipment. Using IMC 0609, Appendix A, Exhibit 2, the inspectors determined that this finding was of very low safety significance (Green). Specifically, the finding did not represent a loss of system or function and did not represent the loss of a single train for greater than technical specification allowed outage times or greater than 24 hours. The inspectors determined that this finding has a cross-cutting aspect in the area of Human Performance, Training, because Exelon did not provide sufficient training to maintain a knowledgeable workforce and instill nuclear safety values associated with the staging of material and equipment. [H.9] (Section 1R04)

• Green. The inspectors identified a Green self-revealing finding for the failure of Exelon

personnel to follow procedures related to human performance tools which resulted in the inadvertent opening of a valve on the ‘D13’ emergency diesel generator (EDG). Specifically, Exelon personnel did not correctly identify and maintain a distance barrier from the diesel generator jacket water drain valve during a maintenance activity which resulted in the draining of the jacket water system and unplanned inoperability and unavailability of the ‘D13’ EDG. Exelon refilled the jacket water system, restored ‘D13’ EDG to an operable condition, and entered the issue into the corrective action program as IR 3986305.

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This finding is more than minor because it adversely affected the configuration control attribute of the mitigating systems cornerstone to ensure the availability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the valve mispositioning caused the ‘D13’ EDG to be inoperable and unavailable. Using IMC 0609, Appendix A, Exhibit 2, the inspectors determined that this finding was of very low safety significance (Green). Specifically, the finding did not represent a loss of system or function and did not represent the loss of a single train for greater than technical specification allowed outage times or greater than 24 hours. The inspectors determined that this finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because Exelon personnel did not properly implement error reduction tools. [H.12] (Section 1R04)

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REPORT DETAILS Summary of Plant Status Unit 1 began the inspection period at 100 percent power. On January 21, 2017, operators reduced power to approximately 75 percent to perform scram time testing and a rod sequence exchange. Operators returned the unit to 100 percent on January 22, 2017. 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. The unit ended the inspection period in end of cycle coastdown at 91 percent power. 1. REACTOR SAFETY Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1R01 Adverse Weather Protection (71111.01 – 2 samples) .1 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

The inspectors reviewed Exelon’s preparations for the onset of winter weather on February 8 and March 13, 2017. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during this adverse weather condition. The inspectors walked down the EDGs, switchgear, and transformers and reviewed switchyard conditions to ensure system availability. The inspectors verified that operator actions defined in Exelon’s adverse weather procedure maintained the readiness of essential systems. The inspectors discussed readiness and staff availability for adverse weather response with operations, maintenance, and work control personnel.

b. Findings

No findings were identified.

1R04 Equipment Alignment Partial System Walkdowns (71111.04 – 5 samples)

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems: • Unit 1 ‘D13’ EDG during the ‘D11’ EDG maintenance outage on February 3, 2017 • Unit 2 safeguard batteries ‘2A’ and ‘2B’ during division 1 safeguard battery ‘2A2’ cell

replacements on February 13 through 17, 2017 • Unit 2 ‘B’ residual heat removal (RHR) during the ‘A’ RHR maintenance outage on

March 3, 2017

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• Unit 2 reactor core isolation cooling (RCIC) and automatic depressurization system during the high pressure coolant injection (HPCI) maintenance outage on March 9, 2017

• Unit common ‘B’ control enclosure (CE) chiller during ‘A’ CE chiller maintenance on March 16 and 17, 2017

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), technical specifications, work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted the system’s performance of its 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 corrective action program for resolution with the appropriate significance characterization.

b. Findings

Introduction. The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion V, “Instructions, Procedures, and Drawings,” for Exelon’s failure to establish instructions appropriate to the circumstances to properly stage equipment and route temporary power cables. Specifically, during cell replacement of the Class 1E ‘2A2’ 125/250 Vdc safeguards battery, a portable battery charger was staged adjacent to operable ‘2A1’ battery cells and not restrained to prevent potential tipping and shorting of exposed battery cell terminals. Additionally, a non-safety related extension cord was routed in near contact with exposed safety related cables in an open cable tray.

Description. The ‘2A’ battery is part of the direct current (DC) power system used to provide electrical power to safety related loads during normal operation, shutdown, and accident scenarios. The ‘2A1’ battery in conjunction with the ‘2A2’ battery and their associated battery chargers make up Division 1 of the Unit 2 Class 1E DC system. There are four independent divisions for each unit. Divisions 1 and 2 provide power to the 125/250 Vdc portions of the system while Divisions 3 and 4 provide power to the 125 Vdc portion.

On February 17, 2017, the inspectors observed replacement of group 2 cells (#19 through #30) of the ‘2A2’ battery in accordance with M-095-005, “Replacement of Station Battery Cells.” The battery replacement was performed in segments from February 13 through 19, 2017. During the maintenance, temporary battery carts were connected to replace the capacity lost by the cells being exchanged. A portable battery charger was staged on February 10, 2017, adjacent to the temporary battery carts to maintain the temporary battery cart cells fully charged during times the temporary cells were not connected to the ‘2A2’ battery. A non-safety related extension cord was plugged into a non-safety related power outlet and routed through the ‘2B’ battery room into the ‘2A’ battery room to supply power to the portable battery charger on February 8, 2017.

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Regarding the portable battery charger, Exelon’s procedure MA-LG-716-026-1001, “Additional Guidance for In-Plant/Yard Storage and Housekeeping at Limerick,” requires that unsecured equipment that is taller than it is wide shall be located at least two feet greater than its height from safety related equipment. The procedure requires that exceptions to this be approved and documented by engineering. The portable battery charger is taller than it is wide and is designed to tip over its single set of wheels for rolling. During the cell replacement activities with the ‘2A1’ and ‘2A2’ batteries operable, the inspectors identified that the portable charger was unsecured, staged adjacent to the ‘2A1’ battery (i.e. not at least two feet greater than its height from the safety related equipment), and lined up with the battery rack such that it was susceptible to tipping over its wheels causing the metal handle to contact exposed battery cell posts. Specifically, if tipped, the metal handle of the charger would contact and bridge the exposed battery cell posts of two battery cells. This exception was not approved and documented by engineering.

Regarding the extension cord, Exelon personnel routed and tied the extension cord across the underside of an open cable tray containing exposed safety related cables such that the cord was in near contact with the cables. The inspectors questioned the routing of the extension cord based on industry operating experience involving failures of extension cords. Exelon personnel responded that the associated procedures regarding temporary power cords, including extension cords, only required cords to not be routed within cable trays. The inspectors reviewed LGS design specifications and identified that 8031-E-412, “Wire & Cable Notes & Details,” section 11.1.2.d.2, required that temporary power cables, including extension cords, that are less than or equal to #4/0 AWG shall remain at least six inches from exposed Class 1E cables and that if this separation cannot be met that the cables be wrapped per the requirements for dropout cables. The extension cord was not wrapped. The inspectors interviewed Exelon personnel and determined that the personnel were not aware of this specification. The inspectors also reviewed Exelon’s procedures applicable to temporary power cables and confirmed that the procedures did not require the separation described in design specification 8031-E-1412. The inspectors performed a followup walkdown of the site on March 8, 2017, and identified a second temporary cord routed in the proximity of safety related cables with less than six inches separation and not wrapped.

The inspectors reviewed the work order package for the ‘2A2’ battery replacement. The inspectors noted that the applicable requirements for the staging of equipment as contained in the applicable procedure and design specification were not described. For the portable battery charger, Exelon personnel initially insulated the metal handle and then moved the portable battery charger and initiated condition report IR 3980217. For the extension cords, Exelon subsequently removed and rerouted cables to maintain the required separation and initiated IR 3980203 and IR 3983203. These activities were completed by March 8, 2017.

Analysis. The inspectors determined that the failure to establish instructions appropriate to the circumstances to properly stage equipment and route temporary power cables was reasonably within Exelon’s ability to foresee and correct and should have been prevented and therefore was a performance deficiency. This finding is more than minor because it adversely affected the configuration control attribute of the mitigating systems cornerstone to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the portable battery charger was adjacent to the ‘2A1’ battery rack and oriented such that it was susceptible to tipping over and causing electrical shorting, and a non-safety related temporary power cable connected to a non-safety related power source was routed in near contact with safety related cables in an open cable tray which introduced a potential to damage and disable safety related equipment.

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Using IMC 0609, Appendix A, Exhibit 2, the inspectors determined that this finding was of very low safety significance (Green). Specifically, the finding did not represent a loss of system or function and did not represent the loss of a single train for greater than technical specification allowed outage times or greater than 24 hours.

The inspectors determined that this finding has a cross-cutting aspect in the area of Human Performance, Training, because Exelon did not provide sufficient training to maintain a knowledgeable workforce and instill nuclear safety values associated with the staging of material and equipment. [H.9]

Enforcement. 10 CFR 50, Appendix B, Criterion V, “Instructions, Procedures, and Drawings,” states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances. Contrary to the above, from February 8 through March 8, 2017, Exelon did not prescribe documented instructions of a type appropriate to the circumstances for activities affecting quality. Specifically, work order instructions for the staging of equipment and routing of temporary power cables did not contain sufficient detail to ensure applicable requirements were maintained. In particular, procedure MA-LG-716-026-1001 requires that unsecured equipment that is taller than it is wide shall be located at least two feet greater than its height from safety related equipment and that exceptions to this be approved and documented by engineering. Contrary to this, on February 8, 2017, a portable battery charger was staged that is taller than it is wide and was unsecured and not located at least two feet greater than its height from safety related equipment, and this exception was not approved and documented by engineering. In addition, LGS design specification 8031-E-412 requires that temporary power cables that are less than or equal to #4/0 AWG shall remain at least six inches from exposed Class 1E cables and that if this separation cannot be met that the cables be wrapped per the requirements for dropout cables. Contrary to this, from February 8 to March 8, 2017, temporary power cables that were less than or equal to #4/0 AWG were not at least six inches from exposed Class 1E cables and were not wrapped per the requirements for dropout cables. Exelon moved the portable battery charger and removed and rerouted temporary cables. Because this violation was of very low safety significance (Green) and was entered into Exelon’s corrective action program (IR 3980217; IR 3980203; and IR 3983203), the violation is being treated as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000353/2017001-01, Inadequate Work Instructions for Staging of Equipment and Routing of Temporary Power Cables)

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.2 Full System Walkdown (71111.04S – 1 sample)

a. Inspection Scope

From March 22 through March 31, 2017, the inspectors performed a complete system walkdown of accessible portions of the D11 and D13 EDGs to verify the existing equipment lineups and material condition, handling, and storage. The inspectors reviewed operating procedures, equipment check-off lists, and the UFSAR to verify the systems were aligned and maintained properly. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, cable tray, hanger, and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and material condition of the components and examined structures and materials to verify that there were no deficiencies. For identified degradation the inspectors confirmed the degradation was appropriately managed by the applicable aging management program. Additionally, the inspectors reviewed a sample of related condition reports and work orders to ensure Exelon appropriately evaluated and resolved any deficiencies.

b. Findings

Introduction. The inspectors identified a Green self-revealing finding for the failure of Exelon personnel to follow procedures related to human performance tools which resulted in the inadvertent opening of the jacket water heat exchanger shell side drain valve for the ‘D13’ EDG. Specifically, Exelon personnel did not correctly identify and maintain a distance barrier from a diesel jacket water drain valve during maintenance activity which resulted in the draining of the jacket water system and unplanned unavailability.

Description. The EDG systems are safety related standby emergency power systems for Limerick Generating Station Units 1 and 2. The EDG systems consist of four diesel generator sets per unit. Each EDG has a cooling water system which consists of two cooling loops: the jacket water cooling loop which removes the excess heat of combustion and the air cooler coolant loop which removes the excess heat of compression. An expansion tank provides a positive static suction head for the pumps in each loop as well as maintaining each cooling loop and the associated components full of water. The expansion tank is connected to the non-safety related makeup and demineralized water system to permit filling and replenishing of the cooling water system. Proper operation of the jacket water cooling system is essential for the EDG to function.

On March 17, 2017, at 7:54 a.m., the main control room received an annunciator indicating a potential issue with the ‘D13’ EDG. A local alarm panel at ‘D13’ EDG indicated a low level in the jacket water expansion tank. An equipment operator identified that the tank was empty and found the jacket water heat exchanger shell side drain valve to be open. Exelon declared ‘D13’ EDG to be inoperable and unavailable. Exelon determined that shortly before receipt of the alarms that technicians had performed work in the area next to the valve to ensure manometer gauges were full prior to a scheduled run of ‘D13’ EDG.

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Since jacket water would rapidly drain to a hard-piped drain, Exelon determined through interviews, simulated activity at the area, and calculated drain time that technicians inadvertently mispositioned the valve during the manometer fill activity. Exelon determined the primary cause of the event to be inadequate action taken by the technicians to prevent contact with the drain valve. Although the technicians performed a 2-Minute Drill, they did not recognize their actual proximity to the valve and did not take further action(s) to prevent contact in accordance with procedure HU-AA-101, “Human Performance Tools and Verification Practices.” HU-AA-101 requires that work within two feet of positionable components be discussed as part of a pre-job brief or be evaluated at the job site using the 2 Minute Drill. The 2 Minute Drill requires the worker(s) to check for, understand, and mitigate hazards associated with the activity. The technicians did not adequately mitigate the hazard associated with a positionable component. Exelon also determined that the valve was not properly restrained because the restraints were not installed to restrict valve movement.

The inspectors reviewed and discussed the issue with Exelon personnel and determined that Exelon’s conclusions were justified and appropriate. The inspectors noted that the valve mispositioning violated procedure 1S92.1.N (COL-3), “Equipment Alignment for 1C Diesel Generator Operation,” which requires the jacket water heat exchanger shell side drain valve to be closed and restrained so that ‘D13’ EDG is aligned for automatic operation.

Exelon subsequently closed the valve, refilled the jacket water system, restored ‘D13’ to an operable condition at 3:30 p.m., and initiated IR 3986305.

Analysis. The inspectors determined that the failure to correctly identify and maintain a distance barrier from a diesel generator jacket water drain valve during maintenance activity was reasonably within Exelon’s ability to foresee and correct and should have been prevented and therefore was a performance deficiency. This finding is more than minor because it adversely affected the configuration control attribute of the mitigating systems cornerstone to ensure the availability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the valve mispositioning caused the ‘D13’ EDG to be inoperable and unavailable.

Using IMC 0609, Appendix A, Exhibit 2, the inspectors determined that this finding was of very low safety significance (Green). Specifically, the finding did not represent a loss of system or function and did not represent the loss of a single train for greater than technical specification allowed outage times or greater than 24 hours.

The inspectors determined that this finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because Exelon personnel did not properly implement human error reduction tools. [H.12]

Enforcement. The inspectors did not identify a violation of regulatory requirements for the failure of Exelon personnel to follow procedures related to human performance tools. (FIN 05000352/2017001-02, Failure to Implement Human Performance Tools Results in Draining of Emergency Diesel Generator Jacket Water System)

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1R05 Fire Protection .1 Resident Inspector Quarterly Walkdowns (71111.05Q – 5 samples)

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Exelon controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures. • Fire area 47, Unit 1 standby liquid control (SLC) and general equipment areas,

elevation 283’, on January 31, 2017 • Fire area 79, Unit 1 D11 diesel generator and fuel oil day tank room, elevation 217’,

on February 24, 2017 • Fire area 70, Unit 2 SLC and general equipment areas, elevation 283’, on

March 15, 2017 • Fire area 33, Unit 1 RCIC pump room, elevation 177’, on March 21, 2017 • Fire area F-CWP-001, Unit common circulating water pump house and fire pump

room, elevation 217’, on March 31, 2017

b. Findings

No findings were identified. 1R07 Heat Sink Performance (711111.07A – 1 sample)

a. Inspection Scope The inspectors reviewed the Unit common ‘B’ CE chiller condenser (heat exchanger) readiness and availability to perform its safety functions. The inspectors reviewed the design basis for the component and verified Exelon’s commitments to NRC Generic Letter 89-13, “Service Water System Requirements Affecting Safety-Related Equipment.” The inspectors observed inspections of the heat exchanger internals, observed in-progress coating repairs, and reviewed the results of previous testing and inspections of the ‘B’ CE chiller heat exchanger. The inspectors discussed the results of the most recent inspection with maintenance and engineering staff. The inspectors verified that Exelon initiated appropriate corrective actions for identified deficiencies. The inspectors also verified that the number of tubes plugged within the heat exchanger did not exceed the maximum amount allowed.

b. Findings


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1R11 Licensed Operator Requalification Program and Licensed Operator Performance (71111.11Q – 2 samples)

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed licensed operator simulator training scenarios on March 13, 2017. The scenarios included failed open safety-relief valve, high vibrations on the ‘B’ condensate pump, and a reactor coolant system leak in the drywell, and a feedwater line break. The scenarios were complicated by a trip of the ‘A’ RHR service water pump, HPCI failing with RCIC out of service, and an anticipated transient without a scram. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classifications made by the shift manager and the technical specification action statements entered by the shift technical advisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

b. Findings


.2 Quarterly Review of Licensed Operator Performance in the Main Control Room

a. Inspection Scope

The inspectors observed and reviewed licensed operator performance in the main control room during the performance of the Unit 1 reduction in power and associated activities on January 21, 2017. The inspectors observed infrequently performed test or evolution briefings and reactivity control briefings to verify that the briefings met the criteria specified in Exelon’s Operations and Administrative Procedures. Additionally, the inspectors observed test performance to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards.

b. Findings


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1R12 Maintenance Effectiveness (71111.12Q – 3 samples)

a. Inspection Scope The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, and component (SSC) performance and reliability. The inspectors reviewed system health reports, corrective action program documents, maintenance work orders, and maintenance rule basis documents to ensure that Exelon was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the structure, system, or component was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by Exelon staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that Exelon staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries. • Unit 1 ‘B’ instrument air on January 13, 2017 • Unit 2 ‘B’ instrument air on January 13, 2017 • March 2016 Periodic 10 CFR 50.65(a)(3) Assessment on February 10, 2017

b. Findings

No findings were identified. 1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 – 5 samples)

a. Inspection Scope The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Exelon performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Exelon personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Exelon performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the station’s probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. • Unit 1 HPCI maintenance outage on January 11, 2017 • Unit 2 division 1 safeguard battery ‘2A2’ cell replacement on February 13 through

February 17, 2017 • Unit 2 ‘B’ reactor enclosure recirculation system (RERS) maintenance outage on

February 23, 2017 • Unit 2 ‘A’ RHR maintenance outage on March 3, 2017 • Unit 1 ‘D13’ EDG unavailable on March 17, 2017

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b. Findings


1R15 Operability Determinations and Functionality Assessments (71111.15 – 5 samples)

a. Inspection Scope The inspectors reviewed operability determinations for the following degraded or non-conforming conditions based on the risk significance of the associated components and systems: • Unit common reactor enclosure roof structural analyses did not correctly consider all

aspects of as-built construction on October 25, 2016 • Unit 2 HPCI main steam supply outboard primary containment isolation valve closed

stroke time approached its upper stroke time limit on December 15, 2016 • Unit 1 ‘A’ RERS fan failed to start when placed in standby on February 15, 2017 • Unit 1 ‘D12’ EDG high crankcase pressure on March 9, 2017 • Unit 1 ‘D12,’ ‘D13,’ and ‘D14’ EDGs jacket water heat exchanger shell side drain

valves found slightly open on March 18, 2017 The inspectors evaluated the technical adequacy of the operability determinations to assess whether technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and UFSAR to Exelon’s evaluations to determine whether the components or systems were operable. The inspectors confirmed, where appropriate, compliance with bounding limitations associated with the evaluations. Where compensatory measures were required to maintain operability, such as in the case of operator workarounds, the inspectors determined whether the measures in place would function as intended and were properly controlled by Exelon.

b. Findings


1R17 Evaluations of Changes, Tests, or Experiments (IP 71111.17T - 29 samples)

a. Inspection Scope

Three inspectors from the NRC Region I Office completed an inspection March 6 through 9, 2017 at LGS to verify Exelon staff performed screens and evaluations of changes and tests in accordance with regulatory requirements and Exelon implementing guidance. The team specifically reviewed three safety evaluations to evaluate whether the changes to the facility or procedures, as described in the UFSAR, had been reviewed and documented in accordance with 10 CFR 50.59 requirements. The safety evaluations were sampled from those completed by Exelon staff since the last NRC inspection of this area and had not been previously reviewed by NRC inspectors. In addition, the team evaluated whether Exelon staff had been required to obtain NRC approval prior to implementing the changes. The team interviewed Exelon staff and reviewed supporting information including calculations, analyses, design change documentation, procedures, the UFSAR, the technical specifications, and plant drawings to assess the adequacy of the safety evaluations.

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The team compared the safety evaluations and supporting documents to the guidance and methods provided in Nuclear Energy Institute (NEI) 96-07, “Guidelines for 10 CFR 50.59 Evaluations,” as endorsed by NRC Regulatory Guide 1.187, “Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments,” to determine the adequacy of the safety evaluations.

The team also reviewed a sample of twenty-six 10 CFR 50.59 screenings and applicability determinations for which Exelon staff had concluded that a safety evaluation was not required to be performed. These reviews were performed to assess whether Exelon‘s threshold for performing safety evaluations was consistent with 10 CFR 50.59. The sample included design changes, calculations, and procedure changes. The screenings and applicability determinations were selected based on the safety significance, risk significance, and complexity of the change to the facility.

In addition, the team compared Exelon’s implementing administrative procedures used to control the screening, preparation, review, and approval of safety evaluations to the guidance in NEI 96-07 to evaluate whether those procedures adequately implemented the requirements of 10 CFR 50.59. The reviewed safety evaluations, screenings, and applicability determinations are listed in the Attachment.

The team verified that Exelon staff entered significant performance issues concerning their 50.59 program into their corrective action program. The team verified that Exelon staff developed appropriate corrective actions to address those issues. A list of documents reviewed is provided in the Attachment to this report.

b. Findings


1R18 Plant Modifications (71111.18 – 1 sample) Permanent Modifications

a. Inspection Scope

The inspectors evaluated a modification that installed a portion of the Unit 2 hardened containment vent system implemented by engineering change package 2016-00012, “2R14 Mod – Fukushima Hardened Vent – Online Work.” The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification. In addition, the inspectors reviewed modification documents associated with the upgrade and design change, including scaffolding evaluations, penetrations created in secondary containment, temporary seals, and interim piping configurations and supports. The inspectors reviewed work packages, observed work in the field, reviewed design drawings and calculations, and interviewed maintenance and engineering personnel.

b. Findings


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1R19 Post-Maintenance Testing (71111.19 – 8 samples)

a. Inspection Scope The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure were consistent with the information in the applicable licensing basis and/or design basis documents, and that the test results were properly reviewed and accepted and problems were appropriately documented. The inspectors also walked down the affected job site, observed the pre-job brief and post-job critique where possible, confirmed work site cleanliness was maintained, and witnessed the test or reviewed test data to verify quality control hold points were performed and checked, and that results adequately demonstrated restoration of the affected safety functions. • Unit 1 HPCI following scheduled maintenance on January 12, 2017 • Unit 2 reactor enclosure core bores and installation of temporary seals for the

hardened containment ventilation system installation on February 3, 2017 • Unit 1 ‘D11’ EDG maintenance outage on February 4, 2017 • Unit 1 reactor enclosure low differential pressure isolation actuation instrumentation

channel ‘B’ following plant process computer modifications on February 5, 2017 • Unit 1 turbine bypass valve #9 servo card replacement on February 13, 2017 • Unit 2 division 1 safeguard battery ‘2A2’ cell replacements on February 17, 2017 • Unit 1 HPCI auxiliary oil pump relay replacement on March 22, 2017 • Unit 2 ‘D24’ EDG air compressor time delay relay installation on March 30, 2017

b. Findings


1R22 Surveillance Testing (71111.22 – 4 samples)

a. Inspection Scope The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied technical specifications, the UFSAR, and Exelon procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests: • ST-6-092-324-2, Unit 2 ‘D24’ EDG load reject and fast start operability test on

January 24, 2017 • ST-6-051-234-2, Unit 2 ‘D’ RHR pump, valve, and flow test on February 22, 2017

(in-service test) • ST-6-055-200-2, Unit 2 HPCI valve test on March 28, 2017 (in-service test) • ST-6-055-230-2, Unit 2 HPCI pump, valve, and flow test on March 28, 2017

(in-service test)

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b. Findings

No findings were identified. 2. RADIATION SAFETY

Cornerstone: Occupational and Public Radiation Safety 2RS2 Occupational As Low As is Reasonably Achievable (ALARA) Planning and Controls (71124.02 – 1 sample)

a. Inspection Scope

The inspectors assessed Exelon’s performance with respect to maintaining occupational individual and collective radiation exposures ALARA. The inspectors used the requirements contained in 10 CFR 20, Regulatory Guides (RG) 8.8 and 8.10, technical specifications, and procedures required by technical specifications as criteria for determining compliance.

Verification of Dose Estimates and Exposure Tracking Systems (1 sample)

The inspectors reviewed the current annual collective dose estimate; basis methodology; and measures to track, trend, and reduce occupational doses for ongoing work activities. The inspectors evaluated the adjustment of exposure estimates, or re-planning of work. The inspectors reviewed post-job ALARA evaluations of excessive exposure.

b. Findings


2RS3 In-Plant Airborne Radioactivity Control and Mitigation (71124.03 – 2 samples)

a. Inspection Scope The inspectors reviewed the control of in-plant airborne radioactivity and the use of

respiratory protection devices in these areas. The inspectors used the requirements in 10 CFR 20, RG 8.15, RG 8.25, NUREG/CR-0041, technical specifications, and procedures required by technical specifications as criteria for determining compliance.

Use of Respiratory Protection Devices (1 sample) The inspectors reviewed the adequacy of Exelon’s use of respiratory protection devices in the plant to include applicable ALARA evaluations, respiratory protection device certification, respiratory equipment storage, air quality testing records, and individual qualification records. Self-Contained Breathing Apparatus (SCBA) for Emergency Use (1 sample) The inspectors reviewed the following: the status and surveillance records for three SCBAs staged in-plant for use during emergencies, Exelon’s SCBA procedures, maintenance and test records, the refilling and transporting of SCBA air bottles, SCBA mask size availability, and the qualifications of personnel performing service and repair of this equipment.

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b. Findings No findings were identified.

2RS4 Occupational Dose Assessment (71124.04 – 2 samples)

a. Inspection Scope The inspectors reviewed the monitoring, assessment, and reporting of occupational

dose. The inspectors used the requirements in 10 CFR 20, RGs 8.9 and 8.34, technical specifications, and procedures required by technical specifications as criteria for determining compliance.

External Dosimetry (1 sample) The inspectors reviewed dosimetry National Voluntary Laboratory Accreditation Program (NVLAP) accreditation, onsite storage of dosimeters, the use of “correction factors” to align electronic personal dosimeter results with NVLAP dosimetry results, dosimetry occurrence reports, and Corrective Action Program documents for adverse trends related to external dosimetry.

Special Dosimetric Situations (1 sample)

The inspectors reviewed Exelon’s worker notification of the risks of radiation exposure to the embryo/fetus, the dosimetry monitoring program for declared pregnant workers, external dose monitoring of workers in large dose rate gradient environments, and dose assessments performed since the last inspection that used multi-badging, skin dose or neutron dose assessments.

b. Findings


2RS5 Radiation Monitoring Instrumentation (71124.05 – 1 sample)

a. Inspection Scope

The inspectors reviewed performance in assuring the accuracy and operability of radiation monitoring instruments used to protect occupational workers during plant operations and from postulated accidents. The inspectors used the requirements in 10 CFR 20, RGs, American National Standards Institute 323A, N323D, and N42.14, and procedures required by technical specifications as criteria for determining compliance.

Calibration and Testing Program (1 sample) For the following radiation detection instrumentation, the inspectors reviewed the current detector and electronic channel calibration, functional testing results alarm set-points and the use of scaling factors: laboratory analytical instruments, whole body counter, containment high-range monitors, portal monitors, personnel contamination monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air samplers and continuous air monitors. The inspectors reviewed the calibration standards used for portable instrument calibrations and response checks to verify that instruments were calibrated by a facility that used National Institute of Science and Technology traceable sources.

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b. Findings


4. OTHER ACTIVITIES 4OA1 Performance Indicator Verification (71151 – 6 samples)

.1 Unplanned Scrams, Unplanned Power Changes, and Unplanned Scrams with

Complications (2 samples)

a. Inspection Scope

The inspectors reviewed LGS’s submittals for the following Initiating Events Cornerstone performance indicators for the period of January 1 through December 31, 2016.

• Unit 1 Unplanned Power Changes • Unit 2 Unplanned Power Changes

To determine the accuracy of the performance indicator data reported during those periods, inspectors used definitions and guidance contained in NEI 99-02, “Regulatory Assessment Performance Indicator Guideline,” Revision 7. The inspectors reviewed LGS’s operator narrative logs, maintenance planning schedules, condition reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findings


.2 Mitigating Systems Performance Index (4 samples)

a. Inspection Scope

The inspectors reviewed LGS’s submittal of the Mitigating Systems Performance Index for the following systems for the period of January 1 through December 31, 2016.

• Unit 1 High Pressure Injection System • Unit 2 High Pressure Injection System • Unit 1 Heat Removal System • Unit 2 Heat Removal System

To determine the accuracy of the performance indicator data reported during those periods, inspectors used definitions and guidance contained in NEI 99-02, “Regulatory Assessment Performance Indicator Guideline,” Revision 7. The inspectors also reviewed Exelon’s operator narrative logs, condition reports, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findings


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4OA2 Problem Identification and Resolution (71152 – 1 sample) .1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure 71152, “Problem Identification and Resolution,” the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify Exelon entered issues into the corrective action program at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the corrective action program and periodically attended condition report screening meetings. The inspectors also confirmed, on a sampling basis, that, as applicable, for identified defects and non-conformances, Exelon performed an evaluation in accordance with 10 CFR Part 21.

b. Findings

No findings were identified. .2 Annual Sample: Unit 2 HPCI Trip Unit Failure

a. Inspection Scope

The inspectors performed an in-depth review of Exelon’s work group evaluation and corrective actions associated with condition report IR 2523623 which was written in response to a Unit 2 HPCI steam line flow trip unit failure on July 3, 2015. The inspectors assessed Exelon’s problem identification threshold, cause analyses, extent of condition reviews, compensatory actions, and the prioritization and timeliness of Exelon’s corrective actions to determine whether Exelon was appropriately identifying, characterizing, and correcting problems associated with this issue and whether the planned or completed corrective actions were appropriate. The inspectors compared the actions taken to the requirements of Exelon’s corrective action program and 10 CFR 50, Appendix B. In addition, the inspectors interviewed engineering personnel to assess the effectiveness of the implemented corrective actions.

b. Findings and Observations No findings were identified. Exelon determined the most probable cause of the HPCI steam line flow trip unit failure was age related since the component was approaching its end of qualified life. The trip unit is a Rosemount 710DU0TS trip unit. The trip units are on a 24-year replacement as required by the preventive maintenance template. The vendor recommends that the trip units be replaced on a 30-year periodicity. The preventive maintenance template is established on a 24-year periodicity to allow for a standard 25 percent grace period while still meeting the 30-year qualified life cycle. The Unit 2 HPCI steam line flow trip unit was at 25 years in service and scheduled to be replaced in 2016 before failing on July 3, 2015.

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The inspectors reviewed Exelon’s corrective actions to address the failed trip unit. The inspectors determined Exelon conducted a thorough technical review of the issue. Corrective actions for the failed trip unit included replacing the affected component, reviewing similar trip units to determine susceptibility to age related failure, and reporting the trip unit failure to the corporate circuit card working group for assessment and tracking. The inspectors concluded that Exelon’s overall response to the HPCI steam line flow trip unit failure was commensurate with the safety significance, was timely, and included appropriate compensatory measures.

4OA5 Other Activities .1 Temporary Instruction (TI) 2515/192: Inspection of the Licensee’s Interim

Compensatory Measures Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems

a. Inspection Scope

The objective of this performance based TI is to verify implementation of interim compensatory measures associated with an open phase condition (OPC) design vulnerability in electric power system for operating reactors. The inspectors conducted an inspection to determine if Exelon had implemented the following interim compensatory measures. These compensatory measures are to remain in place until permanent automatic detection and protection schemes are installed and declared operable for OPC design vulnerability. The inspectors verified the following:

• Exelon had identified and discussed with plant staff the lessons-learned from the OPC

events at the US operating plants including the Byron station OPC event and its consequences. This includes conducting operator training for promptly diagnosing, recognizing consequences, and responding to an OPC event.

• Exelon had updated plant operating procedures to help operators promptly diagnose and respond to OPC events on off-site power sources credited for safe shutdown of the plant.

• Exelon had established and continues to implement periodic walkdown activities to inspect switchyard equipment such as insulators, disconnect switches, and transmission line and transformer connections associated with the offsite power circuits to detect a visible OPC.

• Exelon had ensured that routine maintenance and testing activities on switchyard

components have been implemented and maintained. As part of the maintenance and testing activities, Exelon assessed and managed plant risk in accordance with 10 CFR 50.65(a)(4) requirements.

b. Findings and Observations:

No findings of significance were identified. The inspectors verified the criteria were met.

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.2 (Closed) Unresolved Item (URI) 05000352; 05000353/2015001-03: Operability of High Pressure Coolant Injection and Entries into Operational Conditions at Low Reactor Pressures with High Reactor Water Level Trip Actuated

In the first quarter of 2015 integrated inspection report, ADAMS Accession No. ML15133A242, a URI was opened because more information was required to determine if a performance deficiency and violation existed for an issue of concern related to Exelon’s determination that the operability and safety function of the HPCI system was maintained at reactor pressures lower than normal operating pressure but above 200 psig which would prevent automatic HPCI system actuation on high drywell pressure. By application dated April 4, 2016, ADAMS Accession No. ML 16095A275, Exelon submitted a license amendment request for LGS, Units 1 and 2. The proposed amendments were to modify the HPCI system and RCIC system actuation instrumentation technical specification requirements by adding a footnote indicating that the injection functions of drywell pressure-high (HPCI only) and manual initiation (HPCI and RCIC) are not required to be operable under low reactor pressure conditions. The NRC issued license amendments dated February 28, 2017, ADAMS Accession No. ML16356A272, that revised the technical specification requirements for the HPCI system and RCIC system actuation instrumentation as proposed by Exelon. The NRC staff confirmed Exelon’s determination that the consequences of off-calibration of the wide range level instrumentation at low pressure are not significant and do not affect the core cooling analysis results. The NRC staff determined that the consequences of wide range reactor vessel water level off-calibration do not lead to a more severe reactor condition when low pressure conditions are considered. The effect of pressure on water density results in comparable mass inventory above the lower instrument tap; therefore, the wide range off-calibration condition has a minimal effect on the reactor water inventory available for core cooling. This capability is consistent with general design criterion (GDC) 13 of 10 CFR 50, Appendix A. The NRC staff confirmed that a postulated loss of coolant accident (LOCA) at full power and normal operating pressure is bounding for a LOCA in the 200-550 psig range. Therefore, the staff concluded that the proposed footnote had no impact on the LGS licensing basis for ECCS response to a LOCA as indicated by high drywell pressure actuation and concluded that the proposed footnote to technical specifications was consistent with the plant design and licensing basis, and complied with GDC 13 of Appendix A to 10 CFR Part 50 and 10 CFR 50.36. The inspectors reviewed Exelon’s submittal and the approved safety evaluation. The inspectors determined that a license amendment request was submitted by Exelon and approved by the NRC to modify the technical specifications to clarify and describe that the injection functions of drywell pressure-high (HPCI only) and manual initiation (HPCI and RCIC) are not required to be operable under low reactor pressure conditions. The inspectors confirmed that Exelon did not implement, nor was required to implement, a design and/or operational modification to address the issue. Therefore, the issue of concern was an inconsistency in the NRC-approved technical specifications and was not more than minor because the issue was not a design change implemented by Exelon, involved a failure to clearly describe the facility in the UFSAR and technical specifications, and did not have a material impact on safety or licensed activities (NRC Enforcement Manual, Revision 10, Part 1 – Sections 2.1.B and 2.1.C, and Part II – Sections 2.1.3.D and 2.1.3.E). The inspectors concluded that no finding existed. No additional deficiencies were identified during review of this URI. URI 05000352/05000353/2015001-03 is closed.

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4OA6 Meetings, Including Exit

On April 7, 2017, the inspectors presented the inspection results to Dave Lewis, Plant Manager, and other members of the LGS staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT: SUPPLEMENTARY INFORMATION

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Attachment

SUPPLEMENTARY INFORMATION KEY POINTS OF CONTACT

Licensee Personnel R. Libra, Site Vice President D. Lewis, Plant Manager M. Herr, Assistant Plant Manager F. Sturniolo, Director of Operations J. Murphy, Director of Engineering D. Palena, Director of Maintenance M. Bonifanti, Director of Work Management J. McGee, Security Manager R. Dickinson, Manager, Regulatory Assurance K. Kemper, Training Director C. Giambrone, Shift Operations Superintendent A. Hightower, Emergency Preparedness Manager G. Budock, Regulatory Assurance Engineer D. Merchant, Radiation Protection Manager C. Gerdes, Manager, Chemistry, Environmental and Radioactive Waste J. Mercurio, Licensed Operator Requalification Training Lead T. Fritz, System Manager E. Kriner, Electrical Equipment Component Specialist N. Lampe, Systems Manager R. Rowcotsky, Electrical Design Engineer J. Kriczky, Mechanical Design Engineer R. Weingard, Electrical Engineer G. Curtin, Staff Engineer D. Cronomiz, Design Engineer 3 M. Lui, Electrical Design Engineer J. Mittura, Electrical Design Engineer T. Avram, System Manager O. Becker, Jr., Maintenance Manager D. Molteni, Senior Manager Operations Support and Services J. Mead, Work Week Manager N. Ruggeri, Maintenance Supervisor L. Bell, Nuclear Maintenance Technician E. Kuhn, Nuclear Maintenance Technician J. Ott, Nuclear Maintenance Technician W. Bulafka, Senior Reactor Operator F. Burzynski, Fire Marshall J. Dailey, Radiation Protection Technician A. Davis, Radiation Protection Technical Support Manager P. Imm, Radiation Protection Field Operations Manager J. Kirkpatrick, Radiation Protection Supervisor C. Mattson, System Engineer D. McGrath, Mechanical Maintenance A. Shank, Reactor Services M. Tufillaro, Respiratory Protection Physicist

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LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED Opened/Closed 05000353/2017001-01 NCV Inadequate Work Instructions

for Staging of Equipment and Routing of Temporary Power Cables (Section 1R04)

05000352/2017001-02

FIN Failure to Implement Human

Performance Tools Results in Draining of Emergency Diesel Generator Jacket Water System (Section 1R04)

Closed 05000352, 353/2015-001-03 URI Operability of High Pressure

Coolant Injection and Entries into Operational Conditions at Low Reactor Pressures with High Reactor Water Level Trip Actuated (Section 4OA5)

LIST OF DOCUMENTS REVIEWED Section 1R01: Adverse Weather Protection Procedures GP-7, Cold Weather Preparation and Operation, Revision 52 SE-14, Snow, Revision 21 Condition Reports 2617084 3977568 3981065 3982673 Miscellaneous ASC/SEI 37-14, Design Loads on Structures during Construction, 2015 ASCE/SEI 7-10, Minimum Design Loads for Buildings and Other Structures, 2013 EC 0000618682, Evaluate Impacts Due to Wind Loads on Scaffold Secured to 10 Transformer,

Revision 0 Wind Loads: Guide to the Wind Load Provisions of ASCE 7-10, 2013

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Section 1R04: Equipment Alignment Procedures 1S92.1.N (COL03), Equipment Alignment for 1C Diesel Generator Operation, Revision 32 2S49.1.A (COL), Valve Alignment to Assure Availability of the RCIC System, Revision 14 2S50.1.A (COL), Equipment Alignment of the ADS and Main Steam Safety Relief Valves for

Normal Operation, Revision 3 2S51.1.A (COL-2), Equipment Alignment for Automatic Operation of the RHR System in the

LPCI Mode – “B” Subsystem, Revision 20 2S51.1.A (COL-4), Equipment Alignment for Automatic Operation of the RHR System in the

LPCI Mode – “D” Subsystem, Revision 8 CC-AA-211, Fire Protection Program, Revision 8 CC-LG-201, Hazard Barrier Control Program, Revision 5 M-200-014, Installation and Removal of Temporary Power Cables, Revision 9 MA-AA-716-007, Support of Miscellaneous Items, Revision 6 MA-AA-716-026, Station Housekeeping / Material Condition Program, Revision 15 MA-LG-716-026-1001, Additional Guidance for In-Plant/Yard Storage and Housekeeping at

Limerick, Revision 21 OP-AA-201-009, Control of Transient Combustible Material, Revision 18 S49.9.A, Routine Inspection of the RCIC System, Revision 29 S50.1.A, ADS and Main Steam Safety Relief Valve Line-Up, Revision 8 S51.9.A, Routine Inspection of RHR System, Revision 16 S90.1.A, Start Up of the Control Enclosure Chilled Water System, Revision 56 S92.9.N, Routine Inspection of the Diesel Generators, Revision 72 SA-AA-129-2118, Management and Control of Temporary Power, Revision 9 Condition Reports 3980203 3980217 3983203 3985345 3985364 3985366 Drawings 8031-E-1406, Conduit Notes and Details, Revision 75 8031-E-1412, Wire & Cable Notes & Details, Revision 58 Work Orders 04325185 Section 1R04S: Full System Walkdown Procedures 1S92.1.N (COL-1), Equipment Alignment for 1A Diesel Generator Operation, Revision 34 1S92.1.N (COL-3), Equipment Alignment for 1C Diesel Generator Operation, Revision 32 S92.1.N, Diesel Generator Set Up For Automatic Operation Following Maintenance, Revision 41 S92.8.B, Alternative Fuel Oil Sampling Method, Revision 7 ST-6-020-811-1, D11 Diesel Generator Fuel Oil Analysis, Revision 22 Condition Reports 3983575 3985268 3986699 3986750 3986751

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Section 1R05: Fire Protection Procedures F-CWP-001, Pre-Fire Plan, Circulating Water Pump House, Revision 3 F-D-311A, Pre-Fire Plan, D11 Diesel Generator and Fuel Oil-Lube Oil Tank Rooms 311A and

312A, Revision 11 F-P-001, Pre-Fire Plan, Diesel Driven Fire Pump Room, Revision 11 F-R-108, Pre-Fire Plan, Unit 1 RCIC Pump Room 108, Revision 10 F-R-500, Pre-Fire Plan, Unit 1 Standby Liquid Control and General Equipment Areas, Rooms

500 through 511, Revision 18 F-R-574, Pre-Fire Plan, Unit 2 Standby Liquid Control and General Equipment Areas, Rooms

574 through 585, Revision 15 Section 1R07: Heat Sink Performance Procedures RT-1-011-391-0, MCR Chiller Heat Transfer Performance Calculation Test, Revision 2 RT-2-011-392-0, ‘B’ MCR Chiller Heat Transfer Test, Revision 4 RT-2-011-392-0, ‘B’ MCR Chiller Heat Transfer Test, Revision 6 Condition Reports: 3986419 Work Orders R1001457 R1001458 R1048857 R1127523 R1133494 R1133530 R1134750 R1135331 R1272877 Miscellaneous A0770896, Determine % Thru Wall and % of Tubes that Can Be Plugged, 1/3/1994 A1480416, Stock Codes / Dedication Plan for Ceramalloy Coatings, 5/6/2005 ECR LG 04-00453, Spec for Safety-Related Coatings Outside Containment, Revision 0 QA Records Package for Service Level III, Safety Related CeramAlloy Coating Repair of B MCR Chiller Interior at Limerick Generating Station, 3/7/2017 Section 1R11: Licensed Operator Requalification Program Procedures GP-5, Steady State Operations, Revision 181 OP-AA-103-102, Watch-Standing Practices, Revision 16 OP-AA-104-101, Communications, Revision 3 OT-101, High Drywell Pressure, Revision 37 OT-114, Inadvertent Opening of a Relief Valve, Revision 37 ST-6-107-790-1, Control Rod Scram Timing, Revision 31 T-101, RPV Control Flow Chart, Revision 23 T-103, Secondary Containment Control Flow Chart, Revision 23 T-112, Emergency Blowdown Flow Chart, Revision 15 Condition Reports 3965295 3965300 Miscellaneous Simulator Evaluation Guide 5008E, Revision 1

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Section 1R12: Maintenance Effectiveness Procedures ER-AA-310, Implementation of the Maintenance Rule, Revision 9 ER-AA-310-1003, Maintenance Rule – Performance Criteria Selection, Revision 5 ER-AA-310-1004, Maintenance Rule – Performance Monitoring, Revision 13 ER-AA-310-1007, Maintenance Rule – Periodic (a)(3) Assessment, Revision 4 ER-AA-310, Implementation of the Maintenance Rule, Revision 9 ER-AA-310-1007, Maintenance Rule – Periodic (a)(3) Assessment, Revision 4 Condition Reports 1144697 1282661 1426043 1533093 1616421 2399897 2406894 2419740 2421975 2435417 2436257 2458009 2470790 2517874 2529147 2529337 2538445 2556492 2557681 2566567 2575862 2580385 2605468 2611234 2612138 2615843 2623359 2635516 2635953 2644438 2652425 2653332 2709766 2715183 2724017 2726056 2726788 Miscellaneous ECR 13-00517 Instrument Air Maintenance Rule System Basis Document Instrument Air System Health Reports L-S-18, Instrument Air and Nitrogen Systems, Revision 15 March 2014 Periodic (a)(3) Assessment March 2016 Periodic (a)(3) Assessment Section 1R13: Maintenance Risk Assessments and Emergent Work Control Procedures OP-AA-108-117, Protected Equipment Program, Revision 4 OP-LG-108-117-1000, Limerick Protected Equipment Program, Revision 5 WC-AA-101, Online Work Control Process, Revision 26 Condition Reports 2592543 3961769 Miscellaneous 022.002L061, Block Wall Re-Evaluation Wall 756.35 (ACI), Revision 7 Operations Protected Equipment Log 1/11/2017 Operations Protected Equipment Log 2/23/2017 Operations Protected Equipment Log 3/2/2017 and 3/3/2017 Section 1R15: Operability Determinations and Functionality Assessments Procedures CY-LG-120-154, Balance of Plant Sampling, Revision 16 OP-AA-108-115, Operability Determinations (CM-1), Revision 19 ST-2-072-106-1, Div I Reactor Enclosure BOP Isolation LSF/SAA and RERS, SGTS Test,

Revision 17 ST-6-055-200-2, HPCI Valve Test, Revision 56 ST-6-092-316-1, D12 Diesel Generator Fast Start Operability Test Run, Revision 54 ST-6-020-811-1, D11 Diesel Generator Fuel Oil Analysis, Revision 22

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Condition Reports: 2707433 2732416 3970007 3974452 3983575 3985268 3986699 3986750 3986751 Drawings E-470, Sheet 1, Schematic Diagram Reactor Enclosure Air Recirculation Fan & Auxiliary Control

1 & 2 Units, Revision 30 Work Order 4609591 Miscellaneous 8031-G-19, Specification for General Project Requirements for Design Assessment and

Qualification of Seismic Category I Equipment and Equipment Supports and HVAC/Electrical Support Reassessment for Seismic and Hydrodynamic Loads for the Limerick Generating Station Units 1 and 2, 4/8/86

A/R 02492527-28, Functionality Evaluation of the Reactor Enclosure Roof, 10/26/16 Calculation 021.001, Reactor Building Roof Design, Revision 4 Calculation 022.004S, Reactor Building Roof at Elevation 412’, Revision 5 Calculation 029.015.006, Assessment of Roof System, Revision 0 Calculation 2006, Compartment Pressure and Temperature Analysis Due to Pipe Break in

Reactor Enclosure, Revision 8 Failure Mode Tree Analysis Troubleshooting Log Section 1R17: Evaluations of Changes, Tests, or Experiments Procedures E-1, Loss of All AC Power (Station Blackout), Revision 46 GP-22, Tech Spec 3.3.1 and 3.3.2 Instrument Guidance, Revision 0 LS-AA-104, Exelon 50.59 Review Process, Revision 10 LS-AA-104-1000, Exelon 50.59 Resource Manual, Revision 10 LS-AA-104-1001, 50.59 Review Coversheet Form, Revision 4 LS-AA-104-1002, 50.59 Applicability Review Form, Revision 5 LS-AA-104-1003, 50.59 Screening Form, Revision 4 LS-AA-104-1004, 50.59 Evaluation Form, Revision 6 LS-AA-104-1006, Exelon 50.59 Training and Qualification, Revision 4 10 CFR 50.59 Evaluations LG2015E001, Transition to GNF2 Fuel - Impact on EAB, LPZ, and CR Doses, Revision 0 LG2015E002, On-Line NobleChem (OLNC) Injection Process, Revision 0 LG2016E001, XR-042-1R623A & 623B Recorder Replacement, Revision 0 10 CFR 50.59 Screened-out Evaluations LG2012S037, ECR to Replace "A" RHRSW Loop Return Piping - 2R13, Revision 3 LG2014S049, Actions to Obtain RHRSW Piping Margin, Revision 1 LG2014S050, ECR To Update HPCI and RCIC HELB Calculation, Revision 0 LG2015S005, Replacement of B-PH and C-PH CCVT, Revision 0 LG2015S007, Transition to GNF2 Fuel - Impact on EAB, LPZ, and CR Doses, Revision 0 LG2015S008, Design Changes To Support MSIV Response Time LAR, Revision 0 LG2015S023, UFSAR sections 9.1 and 9.3 need revision to reflect the Methodology for testing

Instrument Air and Instrument Gas, Revision 0

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LG2015S024, Loss of All AC Power (Station Blackout), Revision 0 LG2015S027, U2 Cycle 14 Core Reload Design, Revision 0 LG2015S030, Primary Containment Control, Revision 0 LG2015S034, Emergency Blowdown, Revision 0 LG2015S042, UFSAR Change to Appendix A, License Renewal Supplement, for

BWR Water Chemistry Guidelines, Revision 0 LG2015S045, Install Groundwater Diversions at RHRSW Piping In SPPH, Revision 0 LG2015S053, ECR 14-00206: UNIT 1 SFP Make-Up Hose Connection RHR to SFP Cooling,

Revision 0 LG2015S056, Spray Pond Analysis Update, Revision 0 LG2015S057, TSTF-523 Convert TE into Design Analysis, Revision 0 LG2015S061, UFSAR Change 2015-011, Revision 0 LG2015S067, SLC Return Line High Accuracy Flowmeter Mod - UNIT 2, Revision 0 LG2016S004, RHR Alternate Decay Heat Removal, Revision 0 LG2016S012, ECR to Allow Storage of PIP in Drywell during Operation, Revision 0 LG2016S014, 1R16 Core Shroud Inspection and U2 Analysis for Addl Cycles, Revision 0 LG2016S029, Delete requirement to submit special report to NRC for inoperable seismic

monitoring instrumentation, Revision 0 LG2016S031, 2R14 MOD - Fukushima Hardened Vent - Online Work, Revision 0 LG2016S032, UNIT 1 and 2 LLRT Valve Reduction, Revision 0 LG2016S036, U1 Fuel Pool Cooling Vulnerability Resolution, Revision 0 LG2016S041, Tech Spec 3.3.1 and 3.3.2 Instrument Guidance, Revision 0 Condition Reports 1351161 2440439 2448149 2527356 2541733 2581484 2656825 2657862 3983326 3983512 Work Orders 4329863 Miscellaneous 02462724-02, UFSAR Change Request, dated September 29, 2015 10 CFR 50 Appendix J, Primary Reactor Containment Leakage Testing for Water-Cooled

Power Reactors, dated January 3, 2017 2481144, Technical Evaluation-Cyber Security Evaluation of SQAD-7 Exceptions for

Yokogawa Recorders, dated April 22, 2015 2631529, Check-in Self-Assessment, Exelon 10 CFR 50.59 Review Process, dated

June 16, 2016 3964828, Check-in Self-Assessment, Pre-NRC Inspection 71111.17T- 50.59, dated

February 27, 2017 E-80-101, HPCI and RCIC Pipe Break Outside of Containment and Steel Structure Temperature

Analysis, Revision 4 EC 423270, Spray Pond Analysis Update, Revision 0 ECR 16-00189, Unit 1 and 2 LLRT Valve Reduction, Revision 0 EQ Binder No. EQ-LGS-023, Environmental Qualification-AVCO Air Manifold Pilot AC and DC

Solenoids, Revision 0 EQ Binder No. EQ-LGS-051, Environmental Qualification-GE Radiation Elements, Model

237X731G001, Revision 0 EQ Binder No. EQ-LGS-057, Environmental Qualification-PYCO Temperature Elements,

Revision 0 EQ Binder No. EQ-LGS-074A, Limitorque Valve Operators with AC Motors (Insulation Class

RH), Revision 0

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EQ Binder No. EQ-LGS-075A, Environmental Qualification-ASCO NP8320 Series Solenoid Valves and Model NP X8018A4 Solenoid Operator Assembly, Revision 0

EQ Binder No. EQ-LGS-076B, Environmental Qualification-ASCO Tri-Point Pressure Switch/Transducer Assembly, Revision 0

EQ Binder No. EQ-LGS-079B, Environmental Qualification-NAMCO Limit Switch EA740 Series, Revision 0

Exelon OLNC Change evaluation comparison of BWRVIP-190, Revision 0 dated 2008 to the Revision 1 dated 2014

GEK-39469G, Hydraulic Control Unit Operation and Maintenance, dated November 1989 LG 14-00307, ECR to Update HPCI and RCIC HELB Calculation, dated December 22, 2014 LG 15-00291, SLC Return Line High Accuracy Flowmeter Mod – Unit 2, Revision 1 LG 16-00011, 2R14 Mod – Fukushima Hardened Vent – Online Work, Revision 1 Limerick Generating Station Updated Final Safety Analysis Report, Revision 18 LM-0350, Post LOCA Spray Pond Heat Load Analysis, Revision 0 LM-0642, Suppression Pool pH Calculation for Alternative Source Terms, Revision 2 LM-0645, Re-analysis of Fuel Handling Accident (FHA) Using Alternative Source Terms,

Revision 4 LM-0719, Design Analysis-Reactor Core Isolation Cooling (RCIC) Gas Void Acceptance Criteria,

Revision 0 L-S-15, Control Rod Drive System Design Baseline Document, Revision 11 L-S-15-003, Letter from N.J. Biglieri to F. F. Smith, Reduction in Scram Velocity, dated

November 20, 1969 L-S-15-21, GE ECA #00731-01, Reduction in Accumulator Precharge in HCU High Power

Density Plant, dated July 31, 1970 M-11-13, Spray Pond Thermal and Water Loss Analysis – Heat Load from ESW System,

Revision 6 NEDC-786P, GEH On-Line NobleChem (OLNC) Application, Technical Safety Evaluation for

Limerick Generating Station Unit 1, Revision 0 NEI 94-01, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50,

Appendix J, Revision 0 NUREG 800, SRP-15.0.1, Radiological Consequence Analyses Using Alternative Source

Terms, Revision 0 RG 1.163, Performance-Based Containment Leak-Test Program, dated November 1995 RT-6-000-900-0, Semiannual Inspection of Safe Shutdown Equipment, dated February 2, 2017 T-102, Primary Containment Control - Bases, Revision 25 Technical Report 3002002623 as applicable to the Limerick Station and Table Differences

BWR-VIP Revision 1 (2014) vs. Revision 0 (2008) Comparisons 1 thru 15. UFSAR, Appendix A, Section A.2.1.33, 10 CFR Part 50, Appendix J, Revision 18 Unit 1 Technical Specification 3/4.7.1.3, Ultimate Heat Sink, Amendment 186 Unit 1 Technical Specification 6.8.4.g, Primary Containment Leakage Rate Testing Program,

Amendment 190 Unit 2 Technical Specification 3/4.6.5, Secondary Containment, Amendment 182 Unit 2 Technical Specification 3/4.7.1.3, Ultimate Heat Sink, Amendment 147 Section 1R18: Plant Modifications Work Orders 04180921 04180957 04181324 R1260465

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Miscellaneous A2027307, Evaluate Scaffold 16-5019 in Room 370, 11/18/2016 EC 0000426872, Req the Use of Temp Seal Detail M-10049 Sht’s 53 & 54 without Commodity’s

in All Penetrations, 1/31/2017 ECR LG 16-00012, 2R14 Mod – Fukushima Hardened Vent – Online Work, Revision 1 Section 1R19: Post-Maintenance Testing Procedures M-095-005, Replacement of Station Battery Cells, Revision 9 MA-LG-716-026, Station Housekeeping / Material Condition Program, Revision 15 MA-LG-716-026-1001, Additional guidance for In-Plant/Yard Storage and Housekeeping at

Limerick, Revision 21 RT-2-076-401-1, NSSSS – Outside Atmosphere to Reactor Enclosure Differential Pressure –

Low; Channel B Calibration/Functional Test (PDT-76-498B, PDTSHL-76-198B, KS-76-198B), Revision 8

RT-6-092-315-1, D11 Diesel Generator Abbreviated Run-In, Revision 16 ST-4-095-902-2, Division I 2A2D101 Visual Inspection Cell to Cell and Terminal Tightness and

Resistance Check, Revision 8 ST-6-001-761-1, Main Turbine Bypass Valve Exercising, Revision 28 ST-6-020-234-2, D24 Diesel Generator Fuel Oil Transfer Pump, Valve, and Flow Test,

Revision 40 ST-6-076-310-2, SGTS Reactor Enclosure Secondary Containment Integrity Test, Revision 19 ST-6-092-315-1, D11 Diesel Generator Fast Start Operability Test Run, Revision 9 Condition Reports 1178259 2657640 2695320 3954199 3958326 3958331 3958495 3962561 3967691 3968582 3969667 3969966 3970116 3970291 3974809 3980217 Work Orders R1260465 4177909 4180921 4180957 4181055 4181262 4181324 4292477 4325185 4584380 4584984 4585248 4585252 Drawings 8031-M-10049, Sheet 53, Typical 3-Hour Fire Barrier Penetrations Temporary Fire Seals for

Small Openings, Revision 2 Miscellaneous EC 617542, Barrier Breach Evaluation for Penetrations 0184Z808, 0184Z809, 0184-Z810, and

0184-I002 in Support of HCVS Installation, 12/28/2016 Procedures CC-AA-103-2001, Setpoint Change Control, Revision 3 ST-6-055-230-1, HPCI Pump, Valve and Flow Test, Revision 83

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Section 1R22: Surveillance Testing Procedures ST-6-051-234-2, D RHR Pump, Valve, and Flow Test, Revision 56 ST-6-055-200-2, HPCI Valve Test, Revision 56 ST-6-055-230-2, HPCI Pump, Valve and Flow Test, Revision 77 ST-6-092-324-2, D24 Diesel Generator LOCA-Load Reject Testing and Fast Start Operability

Test Run, Revision 21 Condition Reports 2680576 3966142 3977045 Work Orders 4274168 4329178 4588413 4588416 Section 2RS2: Occupational ALARA Planning and Controls Procedures RP-AA-401, “Operational ALARA Planning and Controls”, Revision 22 Condition Reports 02607101 02613393 02620231 02638844 02642110 02642889 02676698 02682150 Section 2RS3: In-plant Airborne Radioactivity Control and Mitigation Procedures RP-AA-825, “Maintenance, Care and Inspection of Respiratory Protective Equipment”,

Revision 8 RP-LG-825-101, “Breathing Air Analysis”, Revision 9 Condition Reports 02612596 02612996 02632749 02646081 02686149 02737119 02742310 03944733 Work Order 04570988 04583965 Miscellaneous ALARA Plan 2016-081, dated 3/24/2016 Analysis Results, Compressed Air/Gas Quality Testing, TRI Air Testing Inc., Service Air and

Hagemeyer North America Bauer air compressor, 1/1/2015 to Present. Certificate, Scott Air Supplied Products Maintenance and Overhaul, for Bobby Belfiglio

(Hagemeyer North America), dated 3/17/2016 Certificate, Scott Air Supplied Products Maintenance and Overhaul, for Doug Watkins

(Hagemeyer North America), dated 3/17/2016 List, respirators currently used at Limerick Generating Station Radiation Work Permit 00331, dated 6/26/2015, Revision 00 Radiation Work Permit 00331, dated 7/202016, Revision 01 Radiation Work Permit 00331, dated 8/08/2016, Revision 02 Radiation Work Permit LG-0-17-00304, Revision 00

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Records, respirator training, fit testing, and medical clearance, EIDs 019353; 004717; 004909; 027769; 021272; 102902; 008816; 127416; 037778; 107863 Records, SCBA maintenance and annual testing, Hagemeyer North America, 2014 to 2016

TEDE ALARA Evaluation for RWP 16-331, dated 8/15/2016 Section 2RS4: Occupational Dose Assessment Procedures RP-AA-203-1001, “Personnel Exposure Investigations”, Revision 9 RP-AA-210, “Dosimetry Issue, Usage, and Control”, Revision 27 RP-AA-210-1001, Attachment 6, “Neutron Dose Tracking Log”, Revision 10 RP-AA-210-1001, “Dosimetry Logs and Forms”, Revision 10 RP-AA-270, “Prenatal Radiation Exposure”, Revision 8 Condition Reports 02608503 02643470 0264609 02646323 02649432 Miscellaneous Certificate of Accreditation, NVLAP, Landauer, Inc., dated through 12/31/2015 Certificate of Accreditation, NVLAP, Landauer, Inc., dated through 12/31/2016 Certificate of Accreditation, NVLAP, Landauer, Inc., dated through 12/31/2017 EDE Dosimetry Evaluation Sheets, RP-AA-210-1001 Attachment 12, for RWP 00513, for EIDs

C183006; X8380; C166977; C151142; C112650; C187704 “External Dose Assessment”, RP-AA-250 Attachment 1, IR 2520970, dated 7/9/2015 Lesson plan, “NANTeL Generic Radiation Worker Training Content Document”,

dated 11/19/2016 “Multiple Dosimetry EDE Evaluation Sheet”, RP-AA-210-1001, for ALARA Plan 2016-010,

dated 3/7/2016 Personnel Exposure Investigation, RP-AA-2-3-1001, Attachment 1, for EIDs 127581l; C34553;

106123; 109813 Radiation Work Permit 00513, dated 3/20/2016, Revision 1 Section 2RS5: Radiation Monitoring Instrumentation Condition Reports 00767328 02619199 02624681 02653433 02655272 02703300 03762200 Work Orders 1193843 1222954 1222956 1222957 1257090 1257091 1286360 1286361 1318458 1342782-01 4329148-01 4572109-01 4578505-01 4578506-01 4587751-01 4587752-01 Miscellaneous Calibration report, ACCUSCAN II, Limerick Generating Station, dated 1/26/2016 Calibration report, ACCUSCAN II, Limerick Generating Station, dated 1/26/2017 Calibration report, FASTSCAN, Limerick Generating Station, dated 6/11/2015 Calibration report, FASTSCAN, Limerick Generating Station, dated 1/26/2016 Calibration report, FASTSCAN, Limerick Generating Station, dated 1/25/2017

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Certificate of Calibration, Beta Monitor AMS-4, ID 334838, dated 10/28/2016 Certificate of Calibration, Eberline RM-14 ID 079320 dated 10/8/2016 Certificate of Calibration, Eberline RO-2A, ID 333198, dated 2/12/2017 Certificate of Calibration, MGP Telepole ID 078238 dated 5/19/2016 Certificate of Calibration, Portable Gooseneck Air Sampler, ID 332317, dated 6/30/2016 Certificate of Radioactivity Calibration, Cs-137 #71093-8 (RT-11 Source) Facility Operating License, Limerick Generating Station, NFP-39 and amendments. Section 4OA1: Performance Indicator Verification Procedures LS-AA-2200, Mitigating System Performance Index Data Acquisition and Reporting, Revision 5 NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7 Miscellaneous MSPI Data Operation Narrative Logs Power History Graphs Section 4OA2: Problem Identification and Resolution Condition Reports 2523623 2543042 Work Orders A1780731 A1812664 C0257799 C0258685 R1199524 Miscellaneous PCM Template Circuit Cards – Rosemount Trip Units Rosemount Qualification Report DB200037 System IQ Review Reports Section 4OA5: Other Activities Procedures ARC-BOP-220SUB C1, 10 SA XFMR Loss of Phase, Revision 2 ARC-BOP-500SUB A2, 20 REG XFMR Loss of Phase, Revision 1 ARC-MCR-008 D5, 10 SA XFMR Loss of Phase, Revision 2 ARC-MCR-125 D4, 101 SFGD XFMR Loss of Phase, Revision 1 ARC-MCR-225 C4, 201 SFGD XFMR Loss of Phase, Revision 1 ARC-MCR-225 G5, 20 REG XFMR Loss of Phase, Revision 1 OP-AA-108-111-1001, Severe Weather and Natural Disaster Guidelines, Revision 15 SE-17, Loss of Single Phase From Offsite Source, Revision 3 SE-9-7, Expected High Winds, Tornado, Hurricane or Site Flooding, Revision 0

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WC-AA-104, Integrated Risk Management, Revision 24 WC-AA-8000, Interface Procedure Between BGE/COMED/PECO and Exelon Generation

(Nuclear/Power) for Construction and Maintenance Activities, Revision 9 Condition Reports 3951246 3977568 Work Orders 04242084 04322573 Miscellaneous LGSOPS2000, Event/Special Events Procedures, Revision 2 SO1-12-031, Byron Switch Yard Loss of Off-Site Power, 3/29/12 SO-12-041, Follow-up Information on Byron Loss of Phase Event Resulting in a Loss of Off-site

Power, 4/27/12

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LIST OF ACRONYMS ALARA As Low As is Reasonably Achievable CE control enclosure CFR Code of Federal Regulations DC direct current EDG emergency diesel generator GDC General Design Criterion HPCI high pressure coolant injection IMC Inspection Manual Chapter IR issue report LGS Limerick Generating Station LOCA loss of coolant accident NCV non-cited violation NEI Nuclear Energy Institute NRC Nuclear Regulatory Commission NVLAP National Voluntary Laboratory Accreditation Program OPC open phase condition RCIC reactor core isolation cooling RERS reactor enclosure recirculation system RG Regulatory Guide RHR residual heat removal SCBA Self-Contained Breathing Apparatus SLC standby liquid control SSC structure, system and component TI Temporary Instruction UFSAR Updated Final Safety Analysis Report URI unresolved item Vdc volts direct current

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