IR 05000373/2021004
| ML22038A096 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 02/07/2022 |
| From: | Reimer K NRC/RGN-III/DRP/B1 |
| To: | Rhoades D Constellation Energy Generation |
| References | |
| IR 2021004 | |
| Download: ML22038A096 (22) | |
Text
February 7, 2022
SUBJECT:
LASALLE COUNTY STATION - INTEGRATED INSPECTION REPORT 05000373/2021004 AND 05000374/2021004
Dear Mr. Rhoades:
On December 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at LaSalle County Station. On January 12, 2022, the NRC inspectors discussed the results of this inspection with Mr. P. Hansett, 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 did not involve a violation of NRC requirements.
If you disagree with a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at LaSalle County Station. 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, Signed by Riemer, Kenneth on 02/07/22 Kenneth R. Riemer, 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: 05000373/2021004 and 05000374/2021004 Enterprise Identifier: I-2021-004-0100 Licensee: Constellation Nuclear Facility: LaSalle County Station Location: Marseilles, IL Inspection Dates: October 01, 2021 to December 31, 2021 Inspectors: W. Schaup, Senior Resident Inspector B. Bartlett, Senior Operations Engineer R. Elliott, Resident Inspector G. Hansen, Senior Emergency Preparedness Inspector E. Sanchez Santiago, Senior Reactor Inspector T. Wingfield, Operations Engineer R. Zuffa, Illinois Emergency Management Agency Approved By: Kenneth R. Riemer, Chief Branch 1 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at LaSalle County Station, 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
Failure to Implement the Equipment Reliability Program Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green None (NPP) 71152 FIN 05000373,05000374/2021004-01 Open/Closed The inspectors identified a finding of very low safety significance for the licensee's failure to properly implement the station's equipment reliability program for an operational critical component 1LY-HD066, a current to pressure signal converter (I/P), by not eliminating the converter as a single point vulnerability when it was identified after a failure of the 1LC-HD066-1 circuit card in 2012. Consequently, on July 20, 2021, the Unit 1 signal converter failed, requiring operators to enter off-normal procedure LOA-HD-101, "Heater Drain System Trouble," due to a loss of pump forward flow. Operators were required to rapidly down power the unit to prevent an automatic reactor shutdown by reducing flow through the reactor with a combination of recirculation flow and insertion of one CRAM rod. Operators were able to stabilize the reactor at 70 percent power.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 began the inspection period at full power. On October 8, 2021, the unit was downpowered to 80 percent for a rod pattern adjustment. The unit was returned to full power the same day. On November 4, 2021, the unit was downpowered to 82 percent for a rod pattern adjustment. The unit was returned to full power on November 5, 2021. On December 4, 2021, the unit was downpowered to 70 percent for turbine control valve testing, scram time testing, channel distortion testing and a rod sequence exchange. The unit was returned to full power on December 5, 2021. On December 17, 2021, the unit was downpowered to 77 percent for the final rod pattern adjustment for the cycle. The unit was returned to full power the same day and remained at or near full power for the remainder of the inspection period.
Unit 2 began the inspection period at full power. On December 18, 2021, the unit was downpowered to 82 percent for a rod sequence exchange and channel distortion testing. The unit was returned to full power on December 16, 2021 and remained at or near full power for the remainder of 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 activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities, and completed on-site portions of IPs. 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.
On February 1, 2022, the operating license for LaSalle, held by Exelon Generation Company, LLC was transferred to Constellation Energy Generation, LLC (Constellation) as documented in the associated license amendments (ML22021B660). While some or all of the inspection documented in this report was performed while the license was held by Exelon Generation Company, LLC, this report will refer to the licensee as Constellation throughout.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
External Flooding Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on October 5, 2021.
The following areas were walked down:
Lake screen house Unit 1 Unit common core standby cooling system pump room Unit 1 Division 2 core standby cooling system pump room
71111.04 - 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 2 Division 2 diesel generator with the Unit 1 Division 2 diesel generator out for emergent work on October 20, 2021
- (2) Unit 2 reactor core isolation cooling with the high-pressure core spray system out for maintenance on October 25 - 26, 2021
- (3) Unit 2 2A residual heat removal system after maintenance on November 9, 2021
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 1 1B residual heat removal system after biennial comprehensive test on November 29 - December 3, 2021
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Lake screen house, elevations 683' and 714' on October 5, 2021
- (2) Unit 2 Division 2 diesel generator room on October 20, 2021
- (3) Unit 2 Division 3 diesel generator room on October 25-26, 2021
- (4) Unit 1 Division 2 residual heat removal service water pump room on December 2, 2021
- (5) Unit 1 Division 1 residual heat removal service water pump room on December 2, 2021
71111.07A - Heat Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) Unit 1 Division 2 diesel generator heat exchanger during the thermal performance test
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 annual operating tests and biennial written examinations administered from October 11, 2021, through November 19, 2021.
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 between October 11, 2021, and November 19, 2021.
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 Unit 2 downpower for rod sequence exchange on December 18, 2021.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated ESG-98, NRC 31, Revision 4 on October 27, 2021.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (3 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Action Request 4380605, "Unit 1 High Pressure Core Spray System Minimum Flow Valve Failed to Cycle," on October 29, 2020
- (2) Action Request 4448936, "Unit 2 2VX01C Division 1 Switchgear Room Supply Fan Trip," on September 27, 2021
- (3) Action Request 4232438, "Failure of Turbine Stop Valve Closure Reactor Protection System A2 Scram Limit Switch," on December 29, 2021
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Emergent work on Unit 1 Division 2 diesel generator due to a degraded circulating oil pump on October 20, 2021
- (2) Unit 2 Action Green for high pressure core spray system out for maintenance on October 25, 2021
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Action Request 4454071, "Unit 1 Division 2 Diesel Generator Alarm Low Engine Temperature"
- (2) Action Request 4460259, "2E51-F010, Unit 2 Condensate Storage Tank Isolation Valve, Digital Point D911 NAVA"
- (3) Action Request 4464960, "LOS-DG-SR5, 1VY04A DP High"
- (4) Unit 2 Division 1 Switchgear Operable in Accordance with LOP-VX-02 during maintenance on room cooling fan
- (5) Action Request 4462580, "Unit 2 Low Flow of Core Standby Cooling System During LOS-DG-Q3"
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Post-Maintenance Testing of The Unit 1 Division 2 Circulating Oil Pump Skid on October 20, 2021
- (2) Post-Maintenance Testing of The Unit 2 Division 3 Diesel Generator on October 27, 2021
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Secondary Containment Damper Test on November 10, 2021
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:
Annual siren inspection and maintenance records for the period from October 2019 to October 2021 Monthly alert notification system (siren) tests for the period from October 2019 to October 2021
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.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===
- (1) Unit 1 (October 1, 2020 through September 30, 2021)
- (2) Unit 2 (October 1, 2020 through September 30, 2021)
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
- (1) Unit 1 (October 1, 2020 through September 30, 2021)
- (2) Unit 2 (October 1, 2020 through September 30, 2021)
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)
- (1) Unit 1 (October 1, 2020 through September 30, 2021)
- (2) Unit 2 (October 1, 2020 through September 30, 2021)
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
- (1) Unit 1 July 01, 2020 through June 30, 2021 Unit 2 July 01, 2020 through June 30, 2021 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13)
(1 Sample)
- (1) Unit 1 July 01, 2020 through June 30, 2021 Unit 2 July 01, 2020 through June 30, 2021 EP03: Alert and Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
- (1) Unit 1 July 01, 2020 through June 30, 2021 Unit 2 July 01, 2020 through June 30, 2021
71152 - Problem Identification and Resolution (PI&R)
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends and did not identify any that might be indicative of a more significant safety issue.
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Action Request 4436121, "Loss of pump forward necessitates rapid power reduction"
INSPECTION RESULTS
Failure to Implement the Equipment Reliability Program Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green None (NPP) 71152 FIN 05000373,05000374/2021004-01 Open/Closed The inspectors identified a finding of very low safety significance for the licensee's failure to properly implement the station's equipment reliability program for an operational critical component 1LY-HD066, a current to pressure signal converter (I/P), by not eliminating the converter as a single point vulnerability when it was identified after a failure of the 1LC-HD066-1 circuit card in 2012. Consequently, on July 20, 2021, the Unit 1 signal converter failed, requiring operators to enter off-normal procedure LOA-HD-101, "Heater Drain System Trouble," due to a loss of pump forward flow. Operators were required to rapidly down power the unit to prevent an automatic reactor shutdown by reducing flow through the reactor with a combination of recirculation flow and insertion of one CRAM rod.
Operators were able to stabilize the reactor at 70 percent power.
Description:
On July 20, 2021, Unit 1 received multiple alarms on 1PM03J indicating a loss of pump forward flow in the feedwater system. Control room operators entered operating abnormal procedure LOA-HD-101, "Heater Drain System Trouble," and rapidly reduced power by lowering reactor recirculation pump flow using ganged control of the reactor recirculation flow control valves. Additionally, one CRAM rod was inserted by the operators which left the reactor stable at 70 percent power. Based on high heater drain tank level, operators determined that reactor power should be further reduced, and with concurrence of nuclear engineering performed reverse rod sequencing to lower power to 63 percent. The licensee documented the event in Action Request (AR) 04436121.
The licensee performed a work group evaluation for AR 04436121 that documented the following:
"The likely cause of the loss of pump forward was a failure of the current to pressure signal converter (I/P), 1IY-HD066. The extent of condition applies to the 1HD066 and 2HD066 loops. The I/Ps in these loops are 1IY-HD066 and 2IY-HD066. Previous initiatives identified that all three pump forward valves are supplied by the same I/P for both units with no redundancy." The components are operational critical components.
The inspectors reviewed records of a similar occurrence in 2012, and the licensee's program for equipment reliability, and identified the following:
On January 18, 2012, heater drain pump forward flow was lost on Unit 1, requiring a rapid lowering of power to stabilize the reactor at approximately 64 percent. The event was documented in action request AR 01315078. The licensee performed an equipment apparent cause evaluation (EACE) that determined the loss of heater drain pump forward flow was due to a fuse failure on the heater drain tank card 1LC-HD066-1 that is part of the control circuit.
When the card failed, the heater drain pump forward valves all closed, reducing flow to zero.
Additionally, the EACE stated that, "The current circuit design has single point vulnerabilities including the single channel card design affecting multiple functions in the 1(2)PA06J panel, the control card itself and a single transmitter controls the both the pump forward and pump back control." At this time the license addressed the card failure by increasing card replacement from every 10 years to every 6 years and took no actions to eliminate the single point vulnerabilities.
On March 5, 2015, operations personnel identified that the heater drain tank level control was not redundant, and the loss of level transmitter signal would cause a scram due to a loss of both the normal and emergency level control loops. This was documented in AR 02463789.
The description section discusses that a relatively inexpensive modification could be made to provide an additional independent transmitter and associated cards that would make a completely redundant normal and emergency loop. An action was taken as part of the AR to create engineering changes (ECs) 402362 and 402363, to make the modification in the next scheduled refueling outages.
On January 6, 2017, the licensee's Project Review Committee (PRC) concurred with cancelling the engineering changes and requested the subject matter expert to take the issue back to the Plant Health Committee with an alternate solution. Two proposed solutions were presented to the Plant Health Committee:
1. Do nothing, continuing with current preventative maintenance.
2. Add an additional transmitter and I/Ps to make the heater drain pump forward and pump backward separate controls, similar to the heater level controls.
On January 16, 2018, the Plant Health Committee approved the do-nothing option.
Station procedure ER-AA-20, Equipment Reliability Program Description, states the following:
Step 1.2, states in part, "The objectives of the program are
- (to) identify operational critical equipment failures and establish measures to prevent future failures."
2, Intolerance to critical component failures - Addressing degraded conditions, provides two paths for resolution: one path to perform an operational decision making to document the decision to minimize risk, and one path that uses the corrective action program to eliminate risk.
Station procedure ER-AA-10, Equipment Reliability Process Description, states the following:
Step 1.3 states, "The goal of the equipment reliability process is to embrace a culture within the nuclear workforce of a zero tolerance for unexpected critical equipment failures."
Step 1.5.4 states, "Failures and failures causes of concern are identified for critical equipment and measures are established to prevent such failures."
Step 1.5.13 states," When unexpected critical equipment failures do occur, they are investigated, understood and corrective actions are put into place to prevent recurrence.
Work groups aggressively work together to identify the cause for failure and develop plans to resolve the issue and prevent recurrence in accordance with the corrective action and work control processes."
Based on the information identified above, the inspectors determined the licensee had failed to implement the station's equipment reliability program for the operational critical component 1LY-HD066.
Corrective Actions: The senior leadership team aligned with removing the mechanical vulnerability in the L1R19 and L2R19 outages. Engineering changes EC 635124 and EC 635125 have been created to eliminate the mechanical vulnerabilities. This was documented in AR 04426121-06.
Corrective Action References: AR 04436121
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensee's failure to implement the station's equipment reliability program in accordance with station procedure ER-AA-20, "Equipment Reliability Program Description," for the operational critical component 1LY-HD066 was a performance deficiency. Specifically, ER-AA-20, step 1.2 states, in part, that "The objectives of the program are
- (to) identify operational critical equipment failures and to establish measures to prevent future failures." Contrary to, the licensee failed to establish measures to prevent future failures when the actions of Action Request 2463789 were not implemented.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance 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, the failure to implement action items developed after the event in 2012 (AR 01315078) to remove the single point vulnerability, and again in response to AR 02463789, written in 2015, resulted in 1LY-HD-066 failing, causing a loss of pump forward flow on Unit 1. Operators were required to enter off-normal procedures and take immediate actions to reduce power to approximately 70 percent to prevent a reactor trip.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was screened against the Initiating Event cornerstone and determined to be of very low safety significance (Green) because the reactor did not trip during the event.
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.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
Observation: Semi-Annual Trend Review 71152 The inspectors reviewed action requests entered into the corrective action program for the following:
Complete, accurate, and timely documentation of the issue identified in the corrective action program Evaluation and timely disposition of operability and reportability issues Consideration of extent of condition and cause, generic implications, common cause, and previous occurrences Classification and prioritization of the problems resolution commensurate with the safety significance Identification of corrective actions that are appropriately focused to correct the problem Completion of corrective actions in a timely manner commensurate with the safety significance of the issue Identification of negative trends associated with human or equipment performance that can potentially impact nuclear safety Operating experience is adequately evaluated for applicability, and applicable lessons learned are communicated to appropriate organizations and implemented For the inspection period, the inspectors continued to review a trend in the area of human performance issues across multiple departments associated with activities at the site. Two additional issues occurred in early September 2021, including installation of an emergency diesel generator air start check valve backwards (AR 04444092), and maintenance personnel connecting to signal terminals instead of test terminals during an instrument calibration (AR 04444205). The trend was captured in AR 04444416. Lessons learned from the events were incorporated into the previous corrective actions and the nuclear safety culture action.
The resident staff has reviewed the effectiveness of the corrective actions taken by the licensee with input from the recent biennial problem identification and resolution team that was here in December of 2021. With no significant human performance issues in the last 4 months of 2021, the inspectors determined that the licensee has improved in this area and the resident office will consider the trend closed. Additionally, the resident office reviewed the inputs to the biennial problem identification and resolution for safety conscious work environment and agree with the conclusions in the report and will not continue to track items that were associated with the refueling outage on Unit 2 in 2021.
No significant trends were identified in any other areas.
Observation: Loss of Pump Forward Necessitates Rapid Power Reduction 71152 The inspectors reviewed Action Request 4436121, "Loss of pump forward necessitates rapid power reduction," as a sample for annual selected issue(s) for follow-up focusing on the following performance attributes of IP 71152:
Complete, accurate, and timely documentation in the corrective action program Evaluation and timely disposition of operability and reportability issues Consideration of the extent of condition and cause, generic implications, common cause, and previous occurrences Evaluation and timely disposition of operability and 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 Completion of corrective actions in a timely manner commensurate with the safety significance of the issue Identification of negative trends associated with human or equipment performance that can potentially impact nuclear safety Operating experience is adequately evaluated for applicability and applicable lesson learned are communicated to appropriate organizations and implemented The inspectors determined that the licensee had appropriately followed station procedures in the station's corrective action program to ensure all elements inspected were adequately addressed. As part of the review, the inspectors determined that the licensee failed to implement their equipment reliability program by eliminating the single point vulnerability that caused the event. This issue was dispositioned as a Finding in this report.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On January 12, 2022, the inspectors presented the integrated inspection results to Mr. P. Hansett, Site Vice President, and other members of the licensee staff.
On October 22, 2021, the inspectors presented the Biennial Licensed Operator Requalification Program inspection results to Mr. P. Hansett, Site Vice President, and other members of the licensee staff.
On November 1, 2021, the inspectors presented the emergency preparedness inspection results to Mr. P. Hansett, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.01 Procedures LOA-CW-101 Unit 1 Circulating Water System Abnormal 26
LOA-FLD-001 Flooding 22
71111.04 Corrective Action AR 2599114 Small Leakage from OTBD Side of RCIC Turbine 12/11/2015
Documents AR 4029601 U-2 RCIC Governor Valve has Steam Packing Leak 07/07/2017
AR 4153839 U2 RCIC Turbine Outboard Seal Leak During Quarterly Run 07/07/2018
AR 4387672 Outboard RCIC Steam Leak and Gland Seam Leakoff Out of 12/02/2020
Spec
AR 4417424 RCIC Turb Otbd Gland Stm Leakoff Ind Not at Required 04/18/2021
Value
Procedures LOP-DG-01 Preparation for Standby Operation of Diesel Generator 41
LOP-RH-01E Unit 1 RHR Service Water System Electrical Checklist 8
LOP-RHWS-1BM Unit 1 RHR Service Water System Mechanical Checklist 0
LOP-RI-05 Preparation for Standby Operation of the Reactor 39
Core Isolation Cooling System
71111.05 Fire Plans FZ 7C5 DG Bldg. 674'-0" Elev. U1 Division 2 RHR Service 2
Water Pump Room
FZ 7C6 DG Bldg. 674'-0" Elev. U1 Division 1 RHR Service 1
Water Pump Room
FZ-8B1 DG Bldg. 710'-0" Elev. U2 HPCS Diesel Generator Room 3
Pre-Fire Plan Lake Screen House, Elevation 714' and 683' 1
71111.07A Engineering EC 635577 Evaluation of the 1B DG Heat Exchanger Thermal 0
Changes Performance Data Using Alternate (EPRI) Methodology
Procedures LTS-200-11 Diesel Generator Cooling Heat Exchanger Thermal 18
Performance Monitoring
Work Orders WO 04906137 LRA Diesel Generator Heat Exchanger Thermal 11/24/2021
Performance Monitoring
71111.11A Miscellaneous Performance Licensed Operator Annual Examination Performance 11/23/2021
Records Records
71111.11B Corrective Action AR 4303168 Wrong Section of LES Performed with Load Bank Still on 11/12/2019
Documents Charger
AR 4322012 LOS-FP-R4, FP Valve Not Cycled as Required During 02/27/2020
Outage
Inspection Type Designation Description or Title Revision or
Procedure Date
AR 4349607 1A DG Maintenance Switch Checked Without Calling MCR 06/11/2020
AR 4429904 Wrong Quantity of Chemical Added to TBCCW System 06/17/2021
Miscellaneous Attendance Licensed Operator Continuous Training Attendance Records 2019-2021
Records
Cycle 17 Testing BWR Critical Conditions for Cold Startup 01/31/2016
Cycle 17 Testing BWR Power Coefficient of Reactivity and Control Rod Worth 01/30/2016
Cycle 17 Testing BWR Xenon Worth 01/30/2016
Cycle 17 Testing Reactivity Anomaly Test 04/26/2016
Cycle 17 Testing BWR Shutdown Margin Determination 03/18/2016
Reactivation Various Reactivation Packages (Current Cycle) 2019-2021
Records
Remediation Various Remediation Packages (Current Cycle) 2019-2021
Records
Transient Testing Transients 1, 2, 3, 4, 5a, 5b, 6, 7, 8, 9, and 10 09/29/2021-
10/01/2021
Procedures TQ-AA-150 Operator Training Programs 20
TQ-AA-155 Conduct of Simulator Training and Evaluation 11
TQ-AA-201 Examination Security and Administration 18
TQ-AA-224 Exelon Nuclear Training - Implementation Phase 14
TQ-AA-224-F100 Remedial Training Notification and Action on Failure 9
TQ-AA-306 Simulator Management 10
71111.11Q Procedures NF-AB-720-F-1 Control Rod Sequence Review and Approval Sheet 1
NF-LA-1-1000 Reactor Engineer Products Tri-Level Review and Site 2
Challenge Approval Sheet
OP-AB-300-1003 Reactivity Maneuver 18
71111.12 Corrective Action AR 4048633 RM- 1C71A-K10C Failed to De-Energize During 09/03/2017
Documents LOS-RP-Q2
AR 4171148 RM - TSV #3 RPS Relay Failed Test 09/09/2018
AR 4171578 Roll Up IR for RPS TSV Limit Switch Heat-Related Issues 09/10/2018
AR 4232438 RM 1C71A-K10C Failed to De-Energize During 03/23/2019
LOS-RP-Q2
AR 4464775 RM- LOS-RP-SA4 1C71A-K10G Didn't De-Energize as 12/04/2021
Expected
Inspection Type Designation Description or Title Revision or
Procedure Date
AR 4464776 RM- LOS-RP-SA4 1C71A-K10C Didn't De-Energize as 12/04/2021
Expected
Engineering LAS-02121 Failure Analysis of Limit Switch from LaSalle Station 08/17/2018
Evaluations
71111.13 Corrective Action AR 4448936 2VX01C Div 1 SWGT Rom SPLY Fan Trip 09/27/2021
Documents AR 4454071 1A DG Trouble Alarm Low Engine Temp 10/19/2021
71111.15 Corrective Action AR 4454071 1A DG Trouble Alarm Low Engine Temp 10/19/2021
Documents AR 4460259 2E51-F010 Digital Point D911 NAVA 11/11/2021
AR 4462580 As Found Flow Low On @VY02A During LOS-DG-Q3 11/22/2021
Engineering EC 634052 Alternate Acceptance Criteria for VY Coolers 000
Changes
71111.19 Work Orders WO 1934822-04 Leak Check on 2DO11M Strainer 10/27/2021
WO 1945714-03 Verify No Leaks at System Pressure 10/27/2021
WO 4654353-12 No Leaks 2DO02T 2B DG Fuel Storage Tank Manway 10/27/2021
WO 4674956-02 2E22-F319 HPCS DG Backwash Valve 10/27/2021
WO 4674957-02 2E22-D300 HPCS DG Cooling Water Strainer 10/27/2021
WO 4729428-03 Breaker Closes and Carries 'A' Load CUB 005 (2AP07E) 10/26/2021
WO 4731719-03 2B DG 'B' Starting Air Press Regulating Valve 10/27/2021
WO 4731720-03 2B DG 'A' Starting Air Press Regulating Valve 10/27/2021
WO 4819501-04 No Leaks 2DO04T 2B DG Fuel Storage Tank Manway 10/27/2021
WO 5148411-01 LRA OP LOS-DG-M3 U2 HPCS DG Fast Start ATT 10/27/2021
WO 5187182-02 SAT Operation 2B DG 'A' Air Compressor 10/26/2021
Unloader Valve
WO 5197584-02 1A DG Trouble Alarm Low Engine Temp 10/20/2021
71111.22 Procedures LOS-CS-SR2 Secondary Containment (VR) Damper Operability Test 4
71114.02 Corrective Action AR 04363552 EP-Siren Failure (LS10, LS24) 08/17/2020
Documents AR 04399754 EP-Siren Failure LS30 02/02/2021
AR 04405954 EP-Siren Failure LS29 03/02/2021
AR 04414176 EP-Siren Failure LS06 04/05/2021
AR 04425963 Siren Failure LS23 05/27/2021
Miscellaneous Siren Daily Operability Reports 10/01/2019-
09/30/2021
Inspection Type Designation Description or Title Revision or
Procedure Date
LaSalle Monthly Siren Availability Reports 10/01/2019-
09/30/2021
Semi-Annual LaSalle Siren Reports - Siren Corrective and 10/01/2019-
Preventative Maintenance 08/17/2021
21/2022 Emergency Planning for the LaSalle 05/19/2021
Area - Important Safety Information for Your Community
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 04439443 ERO Members Did Not Respond to Everbridge System 08/06/2021
Documents Call-In Drill
Miscellaneous ERO Training Records - Initial and Requalification Training 10/26/2021
(Sample - 15 ERO Personnel)
Quarterly Unannounced Off-Hours Call-In Augmentation Drill 10/01/2019-
Results 09/30/2021
LaSalle Station Emergency Response Organization Duty 10/12/2021
Team Roster
Procedures EP-AA-1005, LaSalle Station On-Shift Staffing Technical Basis 2
Addendum 1
EP-AA-112-100- ERO Notification Form X
F-06
EP-AA-112-200 TSC Activation and Operation 14
EP-AA-112-300 Operations Support Center Activation and Operation 14
EP-AA-112-400 Emergency Operations Facility Activation and Operation 15
TQ-AA-113 ERO Training and Qualification 36
71114.05 Corrective Action AR 04297536 EP-Grundy County Sheriff NARS Phone Inoperable 11/15/2019
Documents AR 04386194 Mid-West Hospital Cabinet Inventory EP-AA-124-F-39 11/24/2020
Issues
AR 04391915 Field Team Vans Inventory Deficiencies 12/31/2020
AR 04421056 LaSalle County EOC Phone Did Not Function 05/12/2021
Miscellaneous Morris Hospital Letter of Agreement 11/17/2017
LaSalle County Sheriff Letter of Agreement 11/17/2017
Seneca Fire Department Letter of Agreement 11/17/2017
Seneca Ambulance Service Letter of Agreement 11/17/2017
Inspection Type Designation Description or Title Revision or
Procedure Date
Marseilles Fire Department Letter of Agreement 11/17/2017
Marseilles Area Ambulance Service Letter of Agreement 11/17/2017
4378294-01 2021 EVAL - Emergency Preparedness; Off-Site Agency 03/08/2021-
Interface Annual Review 12/2021
EP-AA-124-1001- Technical Support Center Inventory of RP 10/01/2019-
F-02 Equipment Records 09/30/2020
EP-AA-124-1001- Operations Support Center Inventory of RP 10/01/2019-
F-03 Equipment Records 09/30/2020
EP-AA-124-F-01 Quarterly Emergency Response Data System (ERDS) Test 10/01/2019-
Records 09/30/2021
EP-LA-124-F-02 LaSalle Technical Support Center Inventory Records 10/01/2020-
09/30/2021
EP-LA-124-F-03 LaSalle Operations Support Center Inventory Records 10/01/2020-
09/30/2021
EP-LA-124-F-08 LaSalle Monthly/Yearly NARS Communications 09/01/2020-
Test Records 09/30/2021
EP-LA-124-F-09 LaSalle Monthly ENS Communications Test Records 10/01/2019-
10/30/2020
EP-MW-124- LaSalle Control Room/Simulator Inventory Records 10/01/2019-
1001-F-01 09/30/2021
KLD TR- 1178 LaSalle County Generating Station 2020 09/05/2020
Population Update Analysis
NOSA-LAS-19-03 LaSalle Station Emergency Preparedness Audit Report 04/17/2019
Procedures EP-AA-1000 Exelon Nuclear Standardized Radiological 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
EP-AA-121 Emergency Response Facilities and 19
Equipment Readiness
EP-AA-124-F-01 Quarterly Emergency Response Data System (ERDS) Test 10/01/2019-
Inspection Type Designation Description or Title Revision or
Procedure Date
Records 09/30/2021
71151 Miscellaneous LS-AA-2110 Monthly Data Elements for ERO Drill Participation 07/01/2020-
06/30/2021
LS-AA-2120 Monthly Data Elements for NRC Drill/Exercise Performance 07/01/2020-
06/30/2021
LS-AA-2130 Monthly Data Elements for NRC ANS Reliability 07/01/2020-
06/30/2021
Procedures EP-AA-125-1001 Performance Indicator Guidance 9
71152 Corrective Action AR 01315078 Unit 1 Heater Drain Transient 01/18/2012
Documents AR 02463789 Single Point Vulnerability of the Heater Drain System 03/05/2015
AR 04436121 Loss of Pump Forward Necessitates Rapid 07/20/2021
Power Reduction
AR 4436193 PPC Troubleshooting Performed Without a 07/19/2021
Work Order - IR #2
AR 444092 Misoriented Valve 09/01/2021
AR 4444205 Unexpected MCR Alarm During LIS-CM-210 09/01/2021
AR 4444205 Unexpected Alarm During LIS-CM-210 09/01/2021
AR 4444391 Unexpected Alarm During LIS-CM-210 09/01/2021
AR 4444416 Trend in Maintenance Performance 09/02/2021
AR 4444416 Trend in Maintenance Performance 09/02/2021
Procedures ER-AA-10 Equipment Reliability Process Description 9
ER-AA-20 Equipment Reliability Program Description 5
19