UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BOULEVARD, SUITE 100 KING OF PRUSSIA, PENNSYLVANIA 19406-2713 March 4, 2013 Mr. Michael J. Pacilio Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Rd. Warrenville, IL 60555 SUBJECT: ANNUAL ASSESSMENT LETTER FOR LIMERICK GENERATING STATION UNITS 1 AND 2 (REPORT 05000352/2012001 AND 05000353/2012001) Dear Mr. Pacilio: On February 12, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed its end-ofcycle performance review of the Limerick Generating Station (Limerick) Units 1 and 2. The NRC reviewed the most recent quarterly performance indicators in addition to inspection results and enforcement actions from January 1, 2012 through December 31, 2012. This letter informs you of the NRC's assessment of your facility during this period and its plans for future inspections at your facility. The NRC determined that overall, Limerick Units 1 and 2 operated in a manner that preserved public health and safety and met all cornerstone objectives. Limerick Unit 2 was in the Regulatory Response Column of the NRC's Reactor Oversight Process Action Matrix until the end of the second quarter, due to a white finding issued in the third quarter of 2011. The white finding involved a failure to ensure proper technical guidance was contained in operating procedures to ensure two Main Feedwater system motor operated valves were fully shut. This resulted in a primary containment isolation valve and the Reactor Core Isolation Cooling system being inoperable. Limerick Unit 2 transitioned back to the Licensee Response Column effective July 1, 2012, following completion of a supplemental inspection on June 28, 2012, using NRC Inspection Procedure (IP) 95001, "Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area." This transition was documented in NRC Inspection Report and Assessment Follow Up Letter dated August 2, 2012 (ML12215A272). The NRC determined the performance at Limerick Units 1 and 2 during the most recent quarter was within the Licensee Response Column because all inspection findings had very low (i.e., green) safety significance and all performance indicators demonstrated that your performance was within the nominal, expected range (i.e., green). Therefore, the NRC plans to conduct Reactor Oversight Process baseline inspections at your facility. The NRC evaluates cross-cutting themes to determine whether a substantive cross-cutting issue exists in a particular area and to encourage licensees to take appropriate actions before more significant performance issues emerge. The NRC identified a cross-cutting theme in the Human Performance Area. Specifically, the NRC identified four findings during 2012 with a documented cross-cutting aspect of H.4(b) Work Practices-Procedural Compliance. M. Pacilio 2 The NRC determined that a substantive cross-cutting issue associated with H.4(b) does not exist because the NRC does not have a concern with your staff's scope of effort and progress in addressing the cross-cutting theme. Exelon has recognized the cross-cutting theme and has initiated action to conduct a root cause evaluation and develop appropriate corrective actions. The NRC will continue to monitor your staff's effort and progress in addressing the theme until the theme criteria are no longer met. The enclosed inspection plan lists the inspections scheduled through June 30, 2014. Routine inspections performed by resident inspectors are not included in the inspection plan. The inspections listed during the last nine months of the inspection plan are tentative and may be revised at the mid-cycle performance review. In addition to baseline inspections, the NRC will perform IP 60855, "Operation of an Independent Spent Fuel Storage Installation at Operating Plants," IP 92702, "Follow-up on Corrective Actions for Violations and Deviations," and Temporary Instruction (TI) 182, "Review of the Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks." The NRC provides the inspection plan to allow for the resolution of any scheduling conflicts and personnel availability issues. The NRC will contact you as soon as possible to discuss changes to the inspection plan should circumstances warrant any changes. This inspection plan does not include security related inspections, which will be sent via separate, non-publicly available correspondence. From September 2011 to August 2012, the NRC issued three severity level IV traditional enforcement violations associated with impeding the regulatory process. Therefore, the NRC plans to conduct an inspection using IP 92723, "Follow-up Inspection of Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period," to followup on these violations during the first quarter 2013. In addition, the NRC plans to complete inspections using IP 92702, "Follow-up on Corrective Actions for Violations and Deviations," for a severity level IV traditional enforcement violation related to willful misconduct documented in a NRC letter, dated October 18, 2012 (ML12292A140) and for a Green Notice of Violation documented in a NRC Inspection Report dated November 1, 2012 (ML12306A397). In accordance with 10 CFR 2.390 of the NRC=s ARules of Practice,@ a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Please contact Mel Gray at (610) 337-5209 with any questions you have regarding this letter. Sincerely, /RA/ Darrell J. Roberts, Director Division of Reactor Projects Docket Nos.: 50-352, 50-353 License Nos.: NPF-39 and NPF-85 Enclosure: Limerick Generating Station Inspection Plan cc w/encl: Distribution via ListServ M. Pacilio 2 The NRC determined that a substantive cross-cutting issue associated with H.4(b) does not exist because the NRC does not have a concern with your staff's scope of effort and progress in addressing the cross-cutting theme. Exelon has recognized the cross-cutting theme and has initiated action to conduct a root cause evaluation and develop appropriate corrective actions. The NRC will continue to monitor your staff's effort and progress in addressing the theme until the theme criteria are no longer met. The enclosed inspection plan lists the inspections scheduled through June 30, 2014. Routine inspections performed by resident inspectors are not included in the inspection plan. The inspections listed during the last nine months of the inspection plan are tentative and may be revised at the mid-cycle performance review. In addition to baseline inspections, the NRC will perform IP 60855, "Operation of an Independent Spent Fuel Storage Installation at Operating Plants," IP 92702, "Follow-up on Corrective Actions for Violations and Deviations," and Temporary Instruction (TI) 182, "Review of the Implementation of the Industry Initiative to Control Degradation of Underground Piping and Tanks." The NRC provides the inspection plan to allow for the resolution of any scheduling conflicts and personnel availability issues. The NRC will contact you as soon as possible to discuss changes to the inspection plan should circumstances warrant any changes. This inspection plan does not include security related inspections, which will be sent via separate, non-publicly available correspondence. From September 2011 to August 2012, the NRC issued three severity level IV traditional enforcement violations associated with impeding the regulatory process. Therefore, the NRC plans to conduct an inspection using IP 92723, "Follow-up Inspection of Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period," to followup on these violations during the first quarter 2013. In addition, the NRC plans to complete inspections using IP 92702, "Follow-up on Corrective Actions for Violations and Deviations," for a severity level IV traditional enforcement violation related to willful misconduct documented in a NRC letter, dated October 18, 2012 (ML12292A140) and for a Green Notice of Violation documented in a NRC Inspection Report dated November 1, 2012 (ML12306A397). In accordance with 10 CFR 2.390 of the NRC=s ARules of Practice,@ a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Please contact Mel Gray at (610) 337-5209 with any questions you have regarding this letter. Sincerely, /RA/ Darrell J. Roberts, Director Division of Reactor Projects Docket Nos.: License Nos.: 50-352, 50-353 NPF-39 and NPF-85 Enclosure: Limerick Generating Station Inspection Plan cc w/encl: Distribution via ListServ DOCUMENT NAME: S/ROP-13 Review/Branch 4/LIM/LIM AAL .docx ADAMS ACCESSION NUMBER: ML13063A127 ; SUNSI Review OFFICE NAME DATE RI/DRP ARosebrook/AAR 02/ 15/13 ; ? Non-Sensitive Sensitive RI/DRP RI/DRP MGray/MG DRoberts/DJR 02/28 /13 02/ 28 /13 OFFICIAL RECORD COPY ; ? Publicly Available Non-Publicly Available M. Pacilio Distribution w/encl: W. Dean, RA D. Lew, DRA D. Roberts, DRP M. Layton, DRP C. Miller, DRS J. Clifford, DRS M. Gray, DRP A. Rosebrook, DRP J. Ayala, DRP A. Turilin, DRP E. DiPaolo, DRP, SRI J. Hawkins, DRP, RI N. Esch, DRP, AA J. Cassidy, RI, OEDO DRS Branch Chiefs (6) N. McNamara, RI, SLO D. Tifft, RI. SLO D. Screnci, RI, PAO N. Sheehan, RI, PAO RidsNrrDirslpab Resource ROPassessment Resource RidsNrrPMLimerick Resource RidsNrrDorlLpl1-2 Resource ROPreports Resource 3 .wm.=.fimooE :onumqwE umocsoccm Ucm mtw?o 2:0 musoaw :89 2: .1 .8u_>_Um Ucm 0&7: go: wwob team: mi: Eo>w 95.; :omo< Emma: - wwmo._m.xm B3 Smas S. 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