IR 05000373/2019004
| ML20031D289 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 01/31/2020 |
| From: | Dave Hills NRC/RGN-III |
| To: | Bryan Hanson Exelon Generation Co |
| References | |
| IR 2019004 | |
| Download: ML20031D289 (28) | |
Text
January 31, 2020
SUBJECT:
LASALLE COUNTY STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000373/2019004 AND 05000374/2019004
Dear Mr. Hanson:
On December 31, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at LaSalle County Station, Units 1 and 2. On January 8, 2020, the NRC inspectors discussed the results of this inspection with Mr. J. Washko, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at LaSalle County Station, Units 1 and 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 at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
David E. Hills, Chief Branch 1 Division of Reactor Projects
Docket Nos. 05000373 and 05000374 License Nos. NPF-11 and NPF-18
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000373 and 05000374
License Numbers:
Report Numbers:
05000373/2019004 and 05000374/2019004
Enterprise Identifier: I-2019-004-0068
Licensee:
Exelon Generation Company, LLC
Facility:
LaSalle County Station, Units 1 and 2
Location:
Marseilles, IL
Inspection Dates:
October 01, 2019 to December 31, 2019
Inspectors:
R. Baker, Senior Operations Engineer
J. Benjamin, Senior Reactor Inspector
J. Cassidy, Senior Health Physicist
G. Hansen, Sr. Emergency Preparedness Inspector
J. Havertape, Resident Inspector
J. Park, Reactor Inspector
D. Sargis, Resident Inspector
W. Schaup, Senior Resident Inspector
A. Shaikh, Senior Reactor Inspector
C. Zoia, Senior Operations Engineer
R. Zuffa, Illinois Emergency Management Agency
Approved By:
David E. Hills, Chief
Br 1
Division of Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at LaSalle County Station, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Design Review Did Not Identify Neutral Required To Be Switched When Field Change Was Performed Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000374/2019004-01 Open/Closed None (NPP)71153 The inspectors identified a finding of very low safety significance and an associated violation of Title 10 CFR Part 50, Appendix B, Criteria III, "Design Control," for the licensee's failure to verify the adequacy of design during the performance of a design review. Specifically, while performing a field change to correct wiring configurations made during replacement of Unit 2 MSIVs pilot valves in 1999, reviews of the field change failed to identify the need to additionally swap the neutral connections for the pilot valves resulting in a circuit configuration different than the licensee's schematics and drawings and inadvertent MSIV closure when a pilot solenoid lead was lifted in 2019.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000374,05000373/20 15001-04 Breakers Installed Beyond Design Life 71152 Closed
PLANT STATUS
Unit 1 began the inspection period at rated thermal power. On November 2, 2019, the unit was down powered to approximately 83 percent power to perform a rod sequence exchange and channel distortion testing. The unit was returned to full power on November 3, 2019. On December 14, 2019, the unit was down powered to approximately 85 percent to perform governor testing on the 1A and 1B turbine driven feedwater pumps, turbine control valve testing, and channel distortion testing. The unit was returned to full power on December 15, 2019. On December 26, 2019, the unit was taken off line and entered Mode 4 to replace reactor recirculation pump seals on the 'A' and 'B' reactor recirculation pumps. The unit was returned to full power on December 31, 2019, and remained at or near rated thermal power for the inspection period.
Unit 2 began the inspection period at rated thermal power. On December 7, 2019, the unit was down powered to approximately 85 percent to perform governor testing on the 1A and 1B turbine driven feedwater pumps, turbine control valve testing, and channel distortion testing.
The unit was returned to full power on December 8, 2019, and remained at or near rated thermal power for the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
External Flooding Sample (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated readiness to cope with external flooding for the following areas:
- lake screen house
- Unit 1 Division 1 core standby cooling system pump room
- Unit 1 Division 2 core standby cooling system pump room
- Unit 2 Division 2 core standby cooling system pump room
71111.04Q - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1 Division 2 residual heat removal service water system with Division 1 unavailable on October 7, 2019
- (2) Unit 2 standby gas treatment system on October 31, 2019
- (3) Unit 2 standby liquid control system on November 15, 2019
71111.05A - Fire Protection (Annual)
Annual Inspection (IP Section 03.02) (1 Sample)
- (1) The inspectors observed fire drill scenario 19-01 in Fire Zones 9C1 and 9C2 on October 22, 2019.
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01) (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Fire Zone 8C5, diesel building, elevation 674', Unit 2 Division 1 residual heat removal service water pump room on October 4, 2019
- (2) Fire Zone 8C4, diesel building, elevation 674', Unit 2 Division 2 residual heat removal service water pump room on October 4, 2019
- (3) Fire Zone 8C3, diesel building, elevation 674', Unit 2 high pressure core spray cooling water pump room on October 4, 2019 (4)lake screen house, elevations 714' and 683' on November 7, 2019
- (5) Fire Zone 7C6, diesel building, elevation 674', Unit 1 Division 1 residual heat removal service water pump room on November 18, 2019
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 02.02a.) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Unit 2 Division 2 and Division 3 core standby cooling system pump rooms
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification biennial written examinations and annual operating tests administered from October 14 through November 15, 2019.
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
- (1) Biennial Requalification Written Examinations
The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on November 15, 2019.
Annual Requalification Operating Tests
The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.
Administration of an Annual Requalification Operating Test
The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.
Requalification Examination Security
The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.
Remedial Training and Re-examinations
The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.
Operator License Conditions
The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.
Control Room Simulator
The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.
Problem Identification and Resolution
The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during down power activities on Unit 1 on December 7, 2019.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated annual re-qualification examination ESG 86 on October 30, 2019.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (3 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
- (1) Unit 1 high pressure core spray diesel generator heat exchanger
- (2) Unit common service air and instrument air system (3)environmental qualification of primary containment isolation valves in the outboard main steam isolation valve room
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
(1)observed functional run of the temporary diesel driven air compressor and reviewed the contingency plan for the Unit 1 station air compressor replacement under Work Order 996355 on October 8, 2019
- (2) Unit 1 online risk elevated to Yellow due to emergent issue on high pressure core spray diesel generator, Action Request 4296452, "HPCS [high pressure core spray]
DG [diesel generator] Room Temperature Controller (1TCU-VD003) Reading Down Scale" on November 12, 2019
- (3) Unit 2 online risk elevated to Yellow due to planned maintenance on the Division 2 emergency diesel on November 18, 2019
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 02.02) (2 Samples)
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Unit 1 Division 1 residual heat removal service water flow low during quarterly operability run of 'A' residual heat removal pump
- (2) Unit 1 reactor core isolation cooling pump low suction pressure alarm during quarterly operability run
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1)temporary modification of the Unit 2 Division 1 switchgear room for replacement of the 125 Vdc battery, installation of seismic rack and floor drain plugs
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the following post-maintenance tests:
(1)
'B' diesel driven fire pump after seasonal maintenance on November 7, 2019
- (2) Unit 2 Division 2 emergency diesel generator heat exchanger (2DG01A) on November 11, 2019
- (3) Unit 2 motor driven reactor feed pump on December 15, 2019
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated Unit 1 maintenance outage, L1M23, activities from December 26 - 31, 2019. The purpose of the maintenance outage was to replace the
'A' and 'B' reactor recirculation pump seals.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
(1)testing of the 'B' diesel driven fire pump on November 7, 2019 (2)testing of the Unit 2 diesel generator cooling water pump (biennial comprehensive pump test) on November 19, 2019
FLEX Testing (IP Section 03.02) (1 Sample)
- (1) surveillance testing of the 'A' flex diesel generator of October 10, 2019
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated the following maintenance and testing of the alert and notification system:
- Alert Notification System (siren) inspection and maintenance (corrective and preventative) records for the period from October 2017 to October 2019
- Alert Notification System (siren) tests for the period from April 2018 to October 2019
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
- (1) The inspectors evaluated the readiness of the Emergency Preparedness Organization.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the maintenance of the emergency preparedness program.
RADIATION SAFETY
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Engineering Controls (IP Section 02.01) (1 Sample)
The inspectors evaluated airborne controls and radioactive monitoring.
- (1) The inspectors reviewed the following:
Installed Ventilation Systems
Temporary Ventilation System Setups
- None were available during this inspection.
Portable or Installed Monitoring Systems
- AMS-4 in Interim Radwaste Storage Facility
Self-Contained Breathing Apparatus for Emergency Use (IP Section 02.03) (1 Sample)
The inspectors evaluated self-contained breathing apparatus program implementation.
- (1) The inspectors reviewed the following:
Status and Surveillance Records for Self-Contained Breathing Apparatus
- Exelon LaSalle - 08
- Exelon LaSalle - 24
- Exelon LaSalle - CR09
Self-Contained Breathing Apparatus Fit for On-Shift Operators
- 3 on-shift operators Crew D
Self-Contained Breathing Apparatus Maintenance Check
- Exelon LaSalle - 08
- Exelon LaSalle - 24
- Exelon LaSalle - CR09
71124.04 - Occupational Dose Assessment
Special Dosimetric Situations (IP Section 02.04) (1 Sample)
The inspectors evaluated the following special dosimetric situation:
- (1) Licensees implementation of requirements to manage radiation protection of declared pregnant workers for 2 workers and application of NRC-approved external dosimetry methods.
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Instrumentation and Equipment (IP Section 02.04) (1 Sample)
The inspectors reviewed the following radioactive effluent discharge system surveillance test results:
(1)
- Stand-By Gas Treatment Filter Flow
- Stand-By Gas Treatment Charcoal Sample
71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,
and Transportation
Radioactive Material Storage (IP Section 02.01)
The inspectors evaluated radioactive material storage.
- (1) The inspectors toured the following areas:
- Interim Radwaste Storage Facility
- Building 20 The inspectors performed a container check (e.g., swelling, leakage and deformation)on the following containers:
- 10 Drums in Building 20
Radioactive Waste System Walkdown (IP Section 02.02) (1 Sample)
The inspectors evaluated the following radioactive waste processing systems and processes during plant walkdowns:
- (1) Liquid or Solid Radioactive Waste Processing Systems
- Advanced Liquid Processing System
Radioactive Waste Resin and/or Sludge Discharges Processes
- Advanced Liquid Processing System Resin
Waste Characterization and Classification (IP Section 02.03) (1 Sample)
The inspectors evaluated the radioactive waste characterization and classification for the following waste streams:
(1)
- Spent Resin
- Anion Resin
Shipment Preparation (IP Section 02.04) (1 Sample)
The inspectors evaluated and observed the following radioactive material shipment preparation processes:
- (1) LW19-039
Shipping Records (IP Section 02.05) (1 Sample)
The inspectors evaluated the following non-excepted package shipment records:
- (1) LW19-039 LW19-052 LW19-003 LW18-058
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
EP01: Drill/Exercise Performance (IP Section 02.12)===
(1)04/01/2018 - 09/30/2019
EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)
- (1) 04/01/2018 - 09/30/2019
EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)
- (1) 04/01/2018 - 09/30/2019
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (2 Samples)
- (1) Unit 1 (10/01/2018 - 09/30/2019)
- (2) Unit 2 (10/01/2018 - 09/30/2019)
MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)
- (1) Unit 1 (10/01/2018 - 09/30/2019)
- (2) Unit 2 (10/01/2018 - 09/30/2019)
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)
- (1) Unit 1 (10/01/2018 - 09/30/2019)
- (2) Unit 2 (10/01/2018 - 09/30/2019)
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
(1)07/01/2018 - 09/30/2019
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in the area of human performance during maintenance that might be indicative of a more significant safety issue.
Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Action Request 4276516, "Work Hour Rule Violation and Emergency Preparedness Minimum Staffing" (2)unresolved item service life issue on molded case breakers
INSPECTION RESULTS
Unresolved Item (Closed)
Breakers Installed Beyond Design Life URI 05000374,05000373/2015001-04 71152
Description:
On May 1, 2015, the NRC issued Integrated Inspection Report 05000373/2015001; 05000374/2015001 documenting Unresolved Item (URI)05000373/2015001-04; 05000374/2015001-04. This URI was associated with safety-related Westinghouse HFB molded case circuit breakers installed in mild environments with a service life of 20 years that had been installed in the plant for more than 30 years. Records provided showed that failures of this type of breaker were attributed to manufacturing defects and none were attributed to age-degradation; however, it was not clear that a lack of age-degradation failures provided an adequate basis for extension to the previously established design life.
Since then, the NRC undertook efforts, such as training, to assist inspectors to disposition issues related to how long safety-related components remain in service and to clarify the application of various regulations and industry standards. As part of this effort, the NRC determined current Agency regulations require the establishment of quality assurance programs and supporting procedures that, among other things, set preventative maintenance schedules for the inspection or replacement of parts having a specified lifetime.
During the NRC's previous inspection, the inspectors determined that the licensee had monitored the breaker performance and tested these breakers routinely; however, it was not clear that the preventative maintenance or replacement strategy basis for extension beyond the 20-year service life was adequate. After the inspectors reviewed additional information, the inspectors determined that based on the original information provided to the licensee by the vendor when the breakers were first installed, the lack of age-degradation failures, and a sufficient preventative maintenance strategy based on the original vendor recommendations, the actions taken by the licensee reasonably ensured the continued quality of the breakers beyond 20 years. Additionally, after receiving additional information from Westinghouse in 2014 about potential breaker failures due to grease hardening and discussing the potential service life issue with the NRC, the licensee began replacement of all Westinghouse HFB molded case breakers on site. The licensee's efforts provide reasonable assurance of adequate protection of public health and safety.
Based on the above, no performance deficiency or violation of regulatory requirements was identified.
Additionally the inspectors reviewed Action Request 1662697, "OPEX Evaluation for Westinghouse Technical Bulletin 14-2 Aging Issues," and Action Request 2429133, "Request for HFB Breaker Operating History," for the following performance attributes:
- complete and accurate identification of the problem in a timely manner commensurate with its safety significance and ease of discovery;
- consideration of the extent of condition, generic implications, common cause, and previous occurrences;
- evaluation and disposition of operability/functionality/reportability issues;
- classification and prioritization of the resolution of the problem commensurate with safety significance;
- identification of corrective actions, which were appropriately focused to correct the problem; and
- completion of corrective actions in a timely manner commensurate with the safety significance of the issue.
The inspectors determined that the licensee had appropriately followed station procedures and the station's corrective action program to ensure all elements inspected were adequately addressed. One item of note was the operability determination performed for Action Request 2429133. In lieu of a documented operability determination in the description section of the action request, an action item was used to provide an evaluation for justification for continued use of HFB breakers for greater than the 20-year service life. Station process would typically have the shift manager document that an operability evaluation was requested and engineering would provide the evaluation as an engineering change. The inspectors determined that an operability determination was made and was documented in the action request which technically meets the stations procedure; however, it did not follow the normal process for such determinations.
Corrective Action References(s): Action Requests 1662697 and 2429133
Minor Violation 71152 Minor Violation: The inspectors determined that a self-revealed violation of Title 10 Code of Federal Regulations (CFR) 26.205 for the licensee's failure to schedule and control work hours for personnel subject to work hour controls was minor. Specifically, the licensee failed to appropriately schedule and control work hours for a radiation protection technician (RPT)who was providing covered work as a designated emergency response organization (ERO)duty RPT as defined in station procedure OP-LA-101-11-1001, "On-Shift Staffing Requirements."
Screening: The inspectors determined the performance deficiency was minor. Since the issue was similar to minor example 9.b. of Inspection Manual Chapter 0612, Appendix E, where the failure occurred only twice and was made by the same individual that did not become associated with a cornerstone attribute or did not adversely affect the cornerstone objective.
Enforcement:
This failure to comply with Title 10 CFR 26.205 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
Observation: Selected Issue for Follow Up - Work Hour Rule Violation 71152 The inspectors reviewed Action Request 4276516 "Work Hour Rule violation," and Action Request 4279116, "Extent of Condition Review From Work Hour Rule Violation," for the following performance attributes:
- complete and accurate identification of the problem in a timely manner commensurate with its safety significance and ease of discovery;
- consideration of the extent of condition, generic implications, common cause, and previous occurrences;
- evaluation and disposition of operability/functionality/reportability issues;
- classification and prioritization of the resolution of the problem commensurate with safety significance;
- identification of corrective actions, which were appropriately focused to correct the problem; and
- completion of corrective actions in a timely manner commensurate with the safety significance of the issue.
The inspectors determined that the licensee had appropriately followed station procedures and the station's corrective action program to ensure all elements inspected were adequately addressed. The inspectors determined there was a minor violation of NRC requirements that was documented separately in this report.
Observation: Semiannual Review for Trends 71152 Based on the trend identified and documented in NRC Integrated Inspection Report 05000373/2019002; 05000374/2019002 in the area of human performance fundamental behavior, in the instrument maintenance department, the inspectors continued to monitor the licensee performance and actions in the human performance area. Human performance behaviors continued to be a problem at the station and occurred across all maintenance disciplines and in the operations department. Action Request 4301021 was written by the station to address concerns in this area. Additionally, a new trend was identified in the area of personnel failing to notify the control room staff of activities occurring in the plant. These activities resulted in multiple occasions of the control room receiving unexpected control room alarms and in one instance entry into an emergency operating procedure. The inspectors briefed the licensee of the trend during the fourth quarter exit. The individual occurrences were documented in the corrective action program and Action Request 4310639 was written to document the trend.
None of the issues identified by the inspectors or licensee were more than minor.
Design Review Did Not Identify Neutral Required To Be Switched When Field Change Was Performed Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events
Green NCV 05000374/2019004-01 Open/Closed
None (NPP)71153 The inspectors identified a finding of very low safety significance and an associated violation of Title 10 CFR Part 50, Appendix B, Criteria III, "Design Control," for the licensee's failure to verify the adequacy of design during the performance of a design review. Specifically, while performing a field change to correct wiring configurations made during replacement of Unit 2 MSIVs pilot valves in 1999, reviews of the field change failed to identify the need to additionally swap the neutral connections for the pilot valves resulting in a circuit configuration different than the licensee's schematics and drawings and inadvertent MSIV closure when a pilot solenoid lead was lifted in 2019.
Description:
On July 24, 2019, during operator rounds, an equipment operator found the indication light for the Unit 2 inboard 'C' MSIV 'A' solenoid valve (P3) not lit at the 2H13-P622 panel. This light provide indication that the solenoid was energized. Additional checks were done and troubleshooting was performed to confirm that the P3 solenoid valve was de-energized. Each MSIV had two solenoid valves that were energized to keep the MSIV open; if power was lost to both valves, the MSIV would close. If one pilot valve was already de-energized and the other pilot valve failed, the MSIV would close, causing a plant transient that would likely result in a reactor plant trip.
Later that day, the unit was down powered to 85 percent reactor power to support troubleshooting the 'C' MSIV pilot valve. The following day, monitoring equipment was installed on the conductor side of the circuit, and troubleshooting began. As part of the troubleshooting, lead CC-54, the neutral for the P3 solenoid valve circuit, was lifted to isolate the P3 solenoid, and the 'C' MSIV closed unexpectedly. Control room operators responded to the transient to stabilize the reactor and further reduced power to 75 percent to meet TS and the requirements of the core operating limits report. Troubleshooting activities were stopped and the licensee began an investigation into why the 'C' MSIV closed.
As part of the licensee investigation of the history of the MSIV pilot valve, it was discovered that during replacement of the valve in 1999 a field change request was processed that required the conductor wires for the 'C' inboard MSIV 'A' and 'B' solenoid valve to be swapped, but the neutral wires were not, such that when the neutral wire on the 'A' solenoid was lifted the 'B' solenoid was de-energized. The field change was evaluated, reviewed, approved, and stated to update the applicable drawings to reflect the conductor wire swap.
Additionally, the extent of condition review determined that each inboard MSIV on Unit 2 was in this configuration and that Unit 1 was not impacted. This was documented in action request AR 04273972 with no additional actions taken.
The inspectors reviewed the applicable work history, station procedures that were applicable at the time the field change request was made and the evaluation to support the field change performed by the licensee determined the following. Station procedure LAP-1300-5, "Field Change Requests," Revision 14 Step E.1, stated that the use of a field change request is limited to the review, evaluation, approval, and distribution of minor design changes (as defined in Q.P. 3-2 [Quality Assurance Manual]) which occur subsequent to engineering change notices or equivalent being issued for construction for design changes requiring engineering assistance.
The quality assurance manual stated in the section for change control that "Changes to final designs, field changes, modifications to operating facilities, and nonconforming items dispositioned use-as-is or repair shall be justified and subject to design control measures with those applied to the original design." This statement is consistent with Title 10 CFR Part 50, Appendix B, Criteria III, Design Control, that states, in part, "Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design".
The inspectors review of the information determined that the evaluation performed by the licensee to support the field change failed to check the adequacy of the design when it did not consider the effect on the circuit by leaving the neutrals in the same positions.
Corrective Actions: The licensee made updates to the applicable drawings and generated work orders to correct the wiring in the next refueling outage in the spring of 2021.
Corrective Action References: Action Requests 4267062 and 4273972
Performance Assessment:
Performance Deficiency: The inspectors determined that failing to check the adequacy of the design as required by station procedure LAP-1300-5, Field Change Requests, was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, not evaluating the effect on the MSIV pilot valve circuit by leaving the neutrals in the same positions after swapping the conductor wires resulted in a plant transient when one of the pilot valve neutrals was lifted during troubleshooting.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors screened the issue against the Initiating Events questions and determined that the finding was of very low safety significance (Green) because the finding did not result in a reactor trip.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. Specifically, because the design change occurred more than 3 years ago.
Enforcement:
Violation: Title 10 Code of Federal Regulations Part 50, Appendix B, Criterion III, "Design Control," requires, in part, that the licensee provide for verifying or checking the adequacy of design, such as by the performance of design reviews, the use of alternate or simplified calculation methods, or by the performance of a suitable testing program.
Contrary to the above, on February 29, 1999, the licensee failed to verify the adequacy of the design change to the 'C' MSIV's associated 'A' and 'B' pilot solenoid valves. Specifically, the design review performed when the field change was implemented failed to identify that the neutral connections had to also be swapped to ensure the final design was correct.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 8, 2020, the inspectors presented the integrated inspection results to Mr. J. Washko, Site Vice President, and other members of the licensee staff.
- On November 15, 2019, the inspectors presented the Licensed Operator Requalification program biennial inspection results inspection results to Mr. P. Hansett, Plant Manager, and other members of the licensee staff.
- On December 12, 2019, the inspectors presented the emergency preparedness baseline inspection results to Mr. J. Washko, Site Vice President, and other members of the licensee staff.
- On December 19, 2019, the inspectors presented the radiation protection inspection results inspection results to Mr. J. Moser, Radiation Protection Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.04Q Drawings
Drawing M-145
P&ID Standby Liquid Control System
Miscellaneous
LOP-SC-02E
Unit 2 Standby Liquid Control System Electrical Checklist
2/16/1998
LOP-SC-02M
Unit 2 Standby Liquid Control System Mechanical Checklist
05/19/2015
Miscellaneous
19-01
Fire Drill Scenario 19-01, North Service Building Hot Shop
Miscellaneous
LaSalle Station Licensed Operator Requalification Annual
Examination Summary Results for 2019
2/18/2019
Corrective Action
Documents
Simulator Fidelity Concern Identified During EP Exercise
09/19/2019
Engineering
Evaluations
TQ-AA-306-F-03
LaSalle STEADY 1 Steady-State Performance Testing
TQ-AA-306-F-03
Transient 10 Simultaneous Closure of all MSIVs Combined
with Single Stuck Open SRV with No Operator Actions
TQ-AA-306-F-03
Transient 10A Simultaneous Closure of All MSIVs Combined
with Single Stuck Open SRV with No Operator Actions -
Baseline Alternative
Miscellaneous
JPM P-AP-04
DC Load Shed
JPM P-DG-05
DG Emergency Start
JPM P-HD-04
Recovery of Low Pressure Heater
SEG 17-1-1
ILT NRC 2017 Scenario Based Testing
07/10/2018
SEG 17-1-3
ILT NRC 2017 Scenario Based Testing
07/10/2018
SEG 17-1-4
ILT NRC 2017 Scenario Based Testing
07/09/2018
Procedures
Reactivation of License Log - Licensed Operator
Reactivations for 2018 and 2019
OP-LA-101-111-
1001
On-Shift Staffing Requirements
OP_AA_105-102
Active License Tracking Log - 2nd and 3rd Quarters 2019
Records for Crew 'D'
TQ-AA-306-F-20
Scenario Based Testing for ESG 129
TQ-AA-306-F-20
Scenario Based Testing for ESG 101
TQ-AA-306-F-20
Scenario Based Testing for ESG 84
TQ-AA-306-F-20
Scenario Based Testing for ESG 128
TQ-AA-306-J002
Simulator Testing Report Template Job Aid - Fuel Cycle
Testing Documentation
11/11/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
TQ-AA-306-J002
Simulator Testing Report Template Job Aid - Fuel Cycle
Testing Documentation
09/14/2018
Self-Assessments AR 04113409
Pre-NRC 71111.11 Inspection Licensed Operator
Requalification Training Assessment
09/19/2019
Work Orders
SWR [Simulator
Work Request]
0133878
Modify Simulator for New Gravity Drain Instrumentation and
Controls
01/18/2018
FCVs Lockup on Insertion of MRC043
10/18/2018
71111.11Q Work Orders
Fire Damper Visual Inspection
09/24/2018
Fire Damper Visual Inspection
06/18/2018
Miscellaneous
FN# LAS-0-SA-02 Supply compressed air for operating pneumatic equipment,
air operated controls, maintenance services and
interruptable equipment such as tank mixing air spargers,
automatic controls systems outside the drywell, and various
instrumentation outside the drywell.
10/01/2019
Corrective Action
Documents
1E12-B001A 1A RHRWS Flow Low During PMT
03/03/2016
Computer Point Reads Lower than MCR Panel Indication
10/10/2019
Engineering
Changes
1E12-B001A 1A RHRSW Flow Low During PMT
000
Miscellaneous
LOP-RH-05
Operations Department Procedure
LOS-RH-Q1
RHR 1A Serv Wtr Flow
10/10/2019
LOS-RH-Q1
RHR (LPCI) an RHR Service Water Pump and Valve
Inservice Test for Modes 1, 2, 3, 4 and 5
Engineering
Changes
MR90 Temporary Configuration Change Evaluation for
Plugging Floor Drain
MR90 Temporary Configuration Change Evaluation for
Plugging Floor Drain
000
Seismic Evaluation of Temporary Battery Rack
000
Procedures
LEP-DC-116
Division 1 and 2 Switchgear Room 125 Volt Battery Cell
Replacement for Units 1 and 2
Work Orders
Install and Remove Temporary Floor Drain Plug/Cover for
Floor Drain 0DA01 per EC 351256
10/10/2019
Work Orders
LRA (Finish) Eddy Current Test 2DG01A DG Cooling Water
11/19/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
(LR) 2DG01A Inspect, Clean and Eddy Test D/G HX
11/19/2019
Bench Test for IST
11/19/2019
Coolant Leak Discovered on 'B' Diesel Fire Pump
11/07/2019
0FP001B Check Valve Leaks
11/07/2019
Replace Elastomer Hose on EDG Expansion Tank and
Water Inlet
11/19/2019
U2 MDRFP OB Mechanical Seal Degrading
2/15/2019
Flange Leak on 0FP051B
11/07/2019
Corrective Action
Documents
RM - Three Rods Would Not Withdraw From Full In
2/27/2019
RM - RCMS Trouble Withdrawing Control Rods
2/26/2019
Void Found During UT of 1B SDC Return
2/27/2019
U1 Control Rod 38-59 Requires Elevated Pressure to
Withdraw
2/28/2019
Engineering
Changes
Technical Evaluation of Control Rod Drive/Rod Control
Management System Performance During L1M23
Work Orders
IST Comprehensive Pump Test for 2DG01P
11/19/2019
'B' Diesel Fire Pump Engine Annual Surveillance
11/07/2019
FLEX Cummins DG 0FF01KA Semi-Annual Equipment
Surveillance
10/10/2019
LOS-FP-M1 Fuel Oil Transfer Test to B DFP Day Tank
11/07/2019
LRA LOS-FP-M6 Diesel Fire Pump Operational Check Att B
11/07/2019
LOS-DC-M3 B Diesel Fire Pump Battery Att N
11/07/2019
LRA LOS-DG-M2 2A Diesel Generator ATT 2A-Idle
11/20/2019
Corrective Action
Documents
2/06/2018
08/06/2018
10/29/2018
05/28/2019
07/22/2019
09/17/2019
Miscellaneous
Emergency Planning for the LaSalle Area - Important Safety
Information for Your Community 2019/2020;
07/29/2019
Siren Daily Operability Reports
04/01/2018 -
09/30/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
LaSalle Monthly Siren Availability Reports
04/01/2018 -
09/30/2019
Semi-Annual LaSalle Siren Reports - Siren Corrective and
Preventative Maintenance
10/01/2017 -
09/15/2019
KLD-TR-988
LaSalle County Generating Station Alert and Notification
System (ANS) Design Report
09/19/2018
Procedures
Exelon Nuclear Standardized Radiological Emergency Plan
Exelon Nuclear Radiological Emergency Plan Annex for
LaSalle Station
Corrective Action
Documents
2Q18 Drill Set TSC Demonstration Criteria Failures
07/11/2018
4Q Drill Set Facility and Equipment Issues
11/07/2018
LORT DEP Failure Due to Untimely Classification
2/12/2019
LORT DEP Failure Due to Inaccurate PARS
2/12/2019
NOS ID: ERO Shift Communicators Were Not Qualified in
04/10/2019
Unannounced Call-In Drill - Duty Team Member Did Not
Respond
06/11/2019
Miscellaneous
LaSalle Station Emergency Response Organization Duty
Team Roster
2/10/2019
ERO Training Records - Initial and Requalification Training
(Sample - 20 ERO Personnel)
2/11/2019
Quarterly Unannounced Off-Hours Call-In Augmentation Drill
Results
11/01/2017 -
06/30/2019
2018 Drive-In and Off Hours Drill Final Report
2/11/2018
Procedures
Exelon Nuclear Standardized Radiological Emergency Plan
Exelon Nuclear Radiological Emergency Plan Annex for
LaSalle Station
Addendum 1
LaSalle Station On-Shift Staffing Technical Basis
EP-AA-112-100-
F-06
ERO Notification or Augmentation
W
EP-AA-120-F-02
EP Staff Initial Development Checklist
H
EP-AA-122-100-
F-13
Call-In Drill (CID) Checklist
G
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
TSC Activation and Operation
Operations Support Center Activation and Operation
ERO Training and Qualification
Corrective Action
Documents
TSC Computers Need Replaced
03/23/2018
NOS ID: Replacement of KI Tablets in MCR not Tracked
04/12/2018
Multiple Speakers Degraded EP Readiness Category 1
05/13/2018
EP Readiness Category 1: Assembly Siren/Beacons not
Working
05/27/2018
2Q Drill Set Facility and Equipment Issues
06/06/2018
2Q Drill Set Facility and Equipment Issues
06/13/2018
2Q18 Drill Set OSC Demonstration Criteria Failures
07/11/2018
INPO ID: (Enhancement) Reevaluate Expectation for Plant
09/21/2018
EP Readiness Category I Emergency Siren FE2-16A
03/06/2019
EP Readiness Category 1 - Multiple Speakers Degraded
05/13/2019
EP Readiness Category 1 - Multiple PA Speakers Degraded
07/04/2019
Technical Support Center DC Failures During 2Q19 ERO
Drills
07/11/2019
Miscellaneous
Seneca Fire Department Letter of Agreement
11/17/2017
Seneca Ambulance Service Letter of Agreement
11/17/2017
Marseilles Fire Department Letter of Agreement
11/17/2017
Marseilles Area Ambulance Service Letter of Agreement
11/17/2017
LaSalle 1st Quarter Performance Indicator Drill Evaluation
Report
07/19/2018
LaSalle Emergency Worker Exposure Control Drill
Evaluation Report
2/20/2018
LaSalle 2018 Medical and Health Physics Drill Findings and
Observations Report
10/19/2018
LaSalle 2019 Medical and Health Physics Drill Findings and
Observations Report
06/06/2019
LaSalle Quarterly Performance Indicator Drill Evaluation
10/01/2017 -
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Reports
06/30/2019
LaSalle Monthly EP Information Newsletters
07/01/2019 -
2/12/2019
Operations Support Center Inventory of RP Equipment
Records
10/01/2018 -
09/30/2019
Technical Support Center Inventory of RP Equipment
Records
10/01/18 -
09/30/19
Corporate Letters of Agreement (table)
2/03/2019
Morris Hospital Letter of Agreement
11/17/2017
LaSalle County Sheriff Letter of Agreement
11/17/2017
KLD TR-1003
LaSalle County Generating Station 2018 Population Update
Analysis
09/08/2018
KLD TR-932
LaSalle County Generating Station 2017 Population Update
Analysis
09/09/2017
Procedures
Exelon Nuclear Standardized Radiological Emergency Plan
Exelon Nuclear Radiological Emergency Plan Annex for
LaSalle Station
Addendum 2
Evacuation Time Estimates for LaSalle County Generating
Station Plume Exposure Pathway Emergency Plan
Addendum 3
Emergency Action Levels for LaSalle Station
Self-Assessments AR 4113396
Pre-2019 NRC EP Routine-Program / PI Verification
Inspection Self Assessment
08/21/2019
NOSA-LAS-18-03
LaSalle Station Emergency Preparedness Audit Report
04/18/2018
NOSA-LAS-19-03
LaSalle Station Emergency Preparedness Audit Report
04/17/2019
Corrective Action
Documents
Resulting from
Inspection
295768
Mask Fits Performed Using Protocol Not Yet Incorporated
into Approved Procedure
11/08/2019
Miscellaneous
Exelon LaSalle 08 Posi3 USB Test Results - Complete SCBA Test
05/22/2018
Exelon LaSalle 08 Posi3 USB Test Results - Complete SCBA Test
05/22/2019
Exelon LaSalle 24 Posi3 USB Test Results - Complete SCBA Test
05/20/2019
Exelon LaSalle 24 Posi3 USB Test Results - Complete SCBA Test
05/21/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Exelon LaSalle
CR09
Posi3 USB Test Results - Airline Apparatus Test
05/22/2018
Exelon LaSalle
CR09
Posi3 USB Test Results - Airline Apparatus Test
05/22/2019
Purchase Order
00685692
Results from In-Place Testing of Nuclear Air Cleaning
Systems for LaSalle Nuclear Station
05/30/2019
Sample No. 17-
018643
Radioiodine Penetration / Efficiency Test Report - OVC01B
09/28/2017
Sample No. 19-
019223
Radioiodine Penetration / Efficiency Test Report - OVC01SA
05/11/2019
Work Orders
01918632 02
Unit 2 Charcoal Sample From Standby Gas Treatment
04/18/2018
01925828 01
Unit 2 Standby Gas Treatment Filter Flow
03/20/2018
04641819
Control Room Emergency Makeup Train "A" Charcoal Filter
Leak Test
05/09/2019
04641820 01
Control Room Emergency Makeup Train "A" HEPA Filter
Leak Test
05/09/2019
Miscellaneous
Intake Investigation Form
07/26/2019
Work Orders
01918632-02
Charcoal Sample from Stand-By Gas Treatment
04/18/2018
01925825-01
Stand-By Gas Treatment Filter Flow
03/20/2018
Procedures
Surveying Radioactive Material Shipments
Inspection and Loading of Radioactive Material Shipments
Shipping Records LW18-058
Tri-Nuke Filters in RT-100 Cask
10/02/2018
LW19-003
Velocity Limiters to Clive as Waste
01/24/2019
LW19-039
Dewatered Spent Resin
10/29/2019
LW19-052
21-300 WE Septa Liner in a 21-300 Cask
09/04/2019
71151
Miscellaneous
Monthly Data Elements for ERO Drill Participation
Performance Indicator
04/01/2018 -
09/30/2019
Monthly Data Elements for NRC Drill/Exercise Performance
(DEP) Performance Indicator
04/01/2018 -
09/30/2019
Monthly Data Elements for NRC ANS Reliability
Performance Indicator
04/01/2018 -
09/30/2019
LaSalle 8 Year Cycle Drill and Exercise Initiating Conditions /
Objectives Spreadsheet
2/11/2019
CY-LA-170-3002
Total Dose Determination and Supporting Information
July 2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
through
September
2019
Procedures
Performance Indicator Guidance
9