IR 05000373/2019004

Integrated Inspection Report 05000373/2019004 and 05000374/2019004

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

ary 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: NPF-11 and NPF-18 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 Enclosure

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 Report Aspect Section Initiating Events Green None (NPP) 71153 NCV 05000374/2019004-01 Open/Closed 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 Breakers Installed Beyond 71152 Closed 15001-04 Design Life

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.

71111.01 - Adverse Weather Protection External Flooding Sample (IP Section 03.04)

(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)

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) 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)

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.)

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) 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) 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) 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)

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)

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)

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)

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)

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) 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) 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) 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) The inspectors evaluated the maintenance of the emergency preparedness program.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation Engineering Controls (IP Section 02.01)

The inspectors evaluated airborne controls and radioactive monitoring.

(1) The inspectors reviewed the following:

Installed Ventilation Systems

• Control Room Emergency Ventilation 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)

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)

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) 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 Breakers Installed Beyond Design Life 71152 (Closed) URI 05000374,05000373/2015001-04

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 Report Aspect Section Initiating Events Green None (NPP) 71153 NCV 05000374/2019004-01 Open/Closed 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 Type Designation Description or Title Revision or

Procedure Date

71111.04Q Drawings Drawing M-145 P&ID Standby Liquid Control System AF

Miscellaneous LOP-SC-02E Unit 2 Standby Liquid Control System Electrical Checklist 12/16/1998

LOP-SC-02M Unit 2 Standby Liquid Control System Mechanical Checklist 05/19/2015

71111.05A Miscellaneous 19-01 Fire Drill Scenario 19-01, North Service Building Hot Shop 0

71111.11A Miscellaneous LaSalle Station Licensed Operator Requalification Annual 12/18/2019

Examination Summary Results for 2019

71111.11B Corrective Action AR 04280536 Simulator Fidelity Concern Identified During EP Exercise 09/19/2019

Documents

Engineering TQ-AA-306-F-03 LaSalle STEADY 1 Steady-State Performance Testing 5

Evaluations TQ-AA-306-F-03 Transient 10 Simultaneous Closure of all MSIVs Combined 6

with Single Stuck Open SRV with No Operator Actions

TQ-AA-306-F-03 Transient 10A Simultaneous Closure of All MSIVs Combined 0

with Single Stuck Open SRV with No Operator Actions -

Baseline Alternative

Miscellaneous JPM P-AP-04 DC Load Shed 5

JPM P-DG-05 0 DG Emergency Start 7

JPM P-HD-04 Recovery of Low Pressure Heater 4

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 OP-AA-105-102, Reactivation of License Log - Licensed Operator 14

Reactivations for 2018 and 2019

OP-LA-101-111- On-Shift Staffing Requirements 9

1001

OP_AA_105-102 Active License Tracking Log - 2nd and 3rd Quarters 2019 14

Records for Crew 'D'

TQ-AA-306-F-20 Scenario Based Testing for ESG 129 2

TQ-AA-306-F-20 Scenario Based Testing for ESG 101 2

TQ-AA-306-F-20 Scenario Based Testing for ESG 84 2

TQ-AA-306-F-20 Scenario Based Testing for ESG 128 2

TQ-AA-306-J002 Simulator Testing Report Template Job Aid - Fuel Cycle 11/11/2019

Testing Documentation

Inspection Type Designation Description or Title Revision or

Procedure Date

TQ-AA-306-J002 Simulator Testing Report Template Job Aid - Fuel Cycle 09/14/2018

Testing Documentation

Self-Assessments AR 04113409 Pre-NRC 71111.11 Inspection Licensed Operator 09/19/2019

Requalification Training Assessment

Work Orders SWR [Simulator Modify Simulator for New Gravity Drain Instrumentation and 01/18/2018

Work Request] Controls

0133878

SWR 0134726 FCVs Lockup on Insertion of MRC043 10/18/2018

71111.11Q Work Orders WO 1931093-02 Fire Damper Visual Inspection 09/24/2018

WO 1940578-01 Fire Damper Visual Inspection 06/18/2018

71111.13 Miscellaneous FN# LAS-0-SA-02 Supply compressed air for operating pneumatic equipment, 10/01/2019

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.

71111.15 Corrective Action AR 2635241 1E12-B001A 1A RHRWS Flow Low During PMT 03/03/2016

Documents AR 4286572 Computer Point Reads Lower than MCR Panel Indication 10/10/2019

Engineering EC 404987 1E12-B001A 1A RHRSW Flow Low During PMT 000

Changes

Miscellaneous LOP-RH-05 Operations Department Procedure 34

LOS-RH-Q1 RHR 1A Serv Wtr Flow 10/10/2019

LOS-RH-Q1 RHR (LPCI) an RHR Service Water Pump and Valve 94

Inservice Test for Modes 1, 2, 3, 4 and 5

71111.18 Engineering EC 351256 MR90 Temporary Configuration Change Evaluation for 0

Changes Plugging Floor Drain

EC 351256 MR90 Temporary Configuration Change Evaluation for 000

Plugging Floor Drain

EC 625173 Seismic Evaluation of Temporary Battery Rack 000

Procedures LEP-DC-116 Division 1 and 2 Switchgear Room 125 Volt Battery Cell 1

Replacement for Units 1 and 2

Work Orders WO 4865996-10 Install and Remove Temporary Floor Drain Plug/Cover for 10/10/2019

Floor Drain 0DA01 per EC 351256

71111.19 Work Orders WO 4584919-07 LRA (Finish) Eddy Current Test 2DG01A DG Cooling Water 11/19/2019

HX

Inspection Type Designation Description or Title Revision or

Procedure Date

WO 4587549-07 (LR) 2DG01A Inspect, Clean and Eddy Test D/G HX 11/19/2019

WO 4588910-02 Bench Test for IST 11/19/2019

WO 4855996-02 Coolant Leak Discovered on 'B' Diesel Fire Pump 11/07/2019

WO 4889411-02 0FP001B Check Valve Leaks 11/07/2019

WO 4907648-04 Replace Elastomer Hose on EDG Expansion Tank and 11/19/2019

Water Inlet

WO 4948253-07 U2 MDRFP OB Mechanical Seal Degrading 12/15/2019

WO 4953520-03 Flange Leak on 0FP051B 11/07/2019

71111.20 Corrective Action AR 4306237 RM - Three Rods Would Not Withdraw From Full In 12/27/2019

Documents AR 4306238 RM - RCMS Trouble Withdrawing Control Rods 12/26/2019

AR 4306287 Void Found During UT of 1B SDC Return 12/27/2019

AR 4306434 U1 Control Rod 38-59 Requires Elevated Pressure to 12/28/2019

Withdraw

Engineering EC 630387 Technical Evaluation of Control Rod Drive/Rod Control 0

Changes Management System Performance During L1M23

71111.22 Work Orders WO 4690199-01 IST Comprehensive Pump Test for 2DG01P 11/19/2019

WO 4854653-03 'B' Diesel Fire Pump Engine Annual Surveillance 11/07/2019

WO 4911590 FLEX Cummins DG 0FF01KA Semi-Annual Equipment 10/10/2019

Surveillance

WO 4969571-01 LOS-FP-M1 Fuel Oil Transfer Test to B DFP Day Tank 11/07/2019

WO 4969573-01 LRA LOS-FP-M6 Diesel Fire Pump Operational Check Att B 11/07/2019

WO 4969574-01 LOS-DC-M3 B Diesel Fire Pump Battery Att N 11/07/2019

WO 4971155-01 LRA LOS-DG-M2 2A Diesel Generator ATT 2A-Idle 11/20/2019

71114.02 Corrective Action AR 04101335 EP Siren Failure (LS32) 02/06/2018

Documents AR 04161980 EP Siren Failure (LS24) 08/06/2018

AR 04188815 EP Siren Failure (LS33) 10/29/2018

AR 04252247 EP Siren Failure (LS14) 05/28/2019

AR 04265971 EP Siren Failure (LS33) 07/22/2019

AR 04279874 EP Siren Failure (LS14) 09/17/2019

Miscellaneous Emergency Planning for the LaSalle Area - Important Safety 07/29/2019

Information for Your Community 2019/2020;

Siren Daily Operability Reports 04/01/2018 -

09/30/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

LaSalle Monthly Siren Availability Reports 04/01/2018 -

09/30/2019

Semi-Annual LaSalle Siren Reports - Siren Corrective and 10/01/2017 -

Preventative Maintenance 09/15/2019

KLD-TR-988 LaSalle County Generating Station Alert and Notification 09/19/2018

System (ANS) Design Report

Procedures EP-AA-1000 Exelon Nuclear Standardized Radiological Emergency Plan 33

EP-AA-1005 Exelon Nuclear Radiological Emergency Plan Annex for 41

LaSalle Station

71114.03 Corrective Action AR 04154847 2Q18 Drill Set TSC Demonstration Criteria Failures 07/11/2018

Documents AR 04192758 4Q Drill Set Facility and Equipment Issues 11/07/2018

AR 04219254 LORT DEP Failure Due to Untimely Classification 02/12/2019

AR 04219255 LORT DEP Failure Due to Inaccurate PARS 02/12/2019

AR 04238300 NOS ID: ERO Shift Communicators Were Not Qualified in 04/10/2019

LMS

AR 04256110 Unannounced Call-In Drill - Duty Team Member Did Not 06/11/2019

Respond

Miscellaneous LaSalle Station Emergency Response Organization Duty 12/10/2019

Team Roster

ERO Training Records - Initial and Requalification Training 12/11/2019

(Sample - 20 ERO Personnel)

Quarterly Unannounced Off-Hours Call-In Augmentation Drill 11/01/2017 -

Results 06/30/2019

2018 Drive-In and Off Hours Drill Final Report 12/11/2018

Procedures EP-AA-1000 Exelon Nuclear Standardized Radiological Emergency Plan 33

EP-AA-1005 Exelon Nuclear Radiological Emergency Plan Annex for 41

LaSalle Station

EP-AA-1005, LaSalle Station On-Shift Staffing Technical Basis 1

Addendum 1

EP-AA-112-100- ERO Notification or Augmentation W

F-06

EP-AA-120-F-02 EP Staff Initial Development Checklist H

EP-AA-122-100- Call-In Drill (CID) Checklist G

F-13

Inspection Type Designation Description or Title Revision or

Procedure Date

EP-AA-122-200 TSC Activation and Operation 12

EP-AA-122-200 Operations Support Center Activation and Operation 13

TQ-AA-113 ERO Training and Qualification 36

71114.05 Corrective Action AR 04118464 TSC Computers Need Replaced 03/23/2018

Documents AR 04126078 NOS ID: Replacement of KI Tablets in MCR not Tracked 04/12/2018

AR 04137154 Multiple Speakers Degraded EP Readiness Category 1 05/13/2018

AR 04141611 EP Readiness Category 1: Assembly Siren/Beacons not 05/27/2018

Working

AR 04144985 2Q Drill Set Facility and Equipment Issues 06/06/2018

AR 04146808 2Q Drill Set Facility and Equipment Issues 06/13/2018

AR 04154848 2Q18 Drill Set OSC Demonstration Criteria Failures 07/11/2018

AR 04175528 INPO ID: (Enhancement) Reevaluate Expectation for Plant 09/21/2018

PAs

AR 04226676 EP Readiness Category I Emergency Siren FE2-16A 03/06/2019

Inoperable

AR 04248384 EP Readiness Category 1 - Multiple Speakers Degraded 05/13/2019

AR 04261921 EP Readiness Category 1 - Multiple PA Speakers Degraded 07/04/2019

AR 04263351 Technical Support Center DC Failures During 2Q19 ERO 07/11/2019

Drills

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 07/19/2018

Report

LaSalle Emergency Worker Exposure Control Drill 12/20/2018

Evaluation Report

LaSalle 2018 Medical and Health Physics Drill Findings and 10/19/2018

Observations Report

LaSalle 2019 Medical and Health Physics Drill Findings and 06/06/2019

Observations Report

LaSalle Quarterly Performance Indicator Drill Evaluation 10/01/2017 -

Inspection Type Designation Description or Title Revision or

Procedure Date

Reports 06/30/2019

LaSalle Monthly EP Information Newsletters 07/01/2019 -

2/12/2019

Operations Support Center Inventory of RP Equipment 10/01/2018 -

Records 09/30/2019

Technical Support Center Inventory of RP Equipment 10/01/18 -

Records 09/30/19

Corporate Letters of Agreement (table) 12/03/2019

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 09/08/2018

Analysis

KLD TR- 932 LaSalle County Generating Station 2017 Population Update 09/09/2017

Analysis

Procedures EP-AA-1000 Exelon Nuclear Standardized Radiological Emergency Plan 33

EP-AA-1005 Exelon Nuclear Radiological Emergency Plan Annex for 41

LaSalle Station

EP-AA-1005, Evacuation Time Estimates for LaSalle County Generating 1

Addendum 2 Station Plume Exposure Pathway Emergency Plan

EP-AA-1005, Emergency Action Levels for LaSalle Station 3

Addendum 3

Self-Assessments AR 4113396 Pre-2019 NRC EP Routine-Program / PI Verification 08/21/2019

Inspection Self Assessment

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

71124.03 Corrective Action 04295768 Mask Fits Performed Using Protocol Not Yet Incorporated 11/08/2019

Documents into Approved Procedure

Resulting from

Inspection

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 Type Designation Description or Title Revision or

Procedure Date

Exelon LaSalle Posi3 USB Test Results - Airline Apparatus Test 05/22/2018

CR09

Exelon LaSalle Posi3 USB Test Results - Airline Apparatus Test 05/22/2019

CR09

Purchase Order Results from In-Place Testing of Nuclear Air Cleaning 05/30/2019

00685692 Systems for LaSalle Nuclear Station

Sample No. 17- Radioiodine Penetration / Efficiency Test Report - OVC01B 09/28/2017

018643

Sample No. 19- Radioiodine Penetration / Efficiency Test Report - OVC01SA 05/11/2019

019223

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 05/09/2019

Leak Test

04641820 01 Control Room Emergency Makeup Train "A" HEPA Filter 05/09/2019

Leak Test

71124.04 Miscellaneous Intake Investigation Form 07/26/2019

71124.06 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

71124.08 Procedures RP-AA-601 Surveying Radioactive Material Shipments 21

RP-AA-603 Inspection and Loading of Radioactive Material Shipments 10

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 04/01/2018 -

Performance Indicator 09/30/2019

Monthly Data Elements for NRC Drill/Exercise Performance 04/01/2018 -

(DEP) Performance Indicator 09/30/2019

Monthly Data Elements for NRC ANS Reliability 04/01/2018 -

Performance Indicator 09/30/2019

LaSalle 8 Year Cycle Drill and Exercise Initiating Conditions / 12/11/2019

Objectives Spreadsheet

CY-LA-170-3002 Total Dose Determination and Supporting Information July 2018

Inspection Type Designation Description or Title Revision or

Procedure Date

through

September

2019

Procedures EP-AA-125-1001 Performance Indicator Guidance 9

25