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
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.
February 7, 2022 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, 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:
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
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 Aspect Report Section Initiating Events Green FIN 05000373,05000374/2021004-01 Open/Closed None (NPP)71152 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 Aspect Report Section Initiating Events Green FIN 05000373,05000374/2021004-01 Open/Closed None (NPP)71152 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
Procedure
Type
Designation
Description or Title
Revision or
Date
LOA-CW-101
Unit 1 Circulating Water System Abnormal
Procedures
LOA-FLD-001
Flooding
Small Leakage from OTBD Side of RCIC Turbine
2/11/2015
U-2 RCIC Governor Valve has Steam Packing Leak
07/07/2017
U2 RCIC Turbine Outboard Seal Leak During Quarterly Run
07/07/2018
Outboard RCIC Steam Leak and Gland Seam Leakoff Out of
Spec
2/02/2020
Corrective Action
Documents
RCIC Turb Otbd Gland Stm Leakoff Ind Not at Required
Value
04/18/2021
LOP-DG-01
Preparation for Standby Operation of Diesel Generator
LOP-RH-01E
Unit 1 RHR Service Water System Electrical Checklist
LOP-RHWS-1BM
Unit 1 RHR Service Water System Mechanical Checklist
Procedures
LOP-RI-05
Preparation for Standby Operation of the Reactor
Core Isolation Cooling System
FZ 7C5
DG Bldg. 674'-0" Elev. U1 Division 2 RHR Service
Water Pump Room
FZ 7C6
DG Bldg. 674'-0" Elev. U1 Division 1 RHR Service
Water Pump Room
FZ-8B1
DG Bldg. 710'-0" Elev. U2 HPCS Diesel Generator Room
Fire Plans
Pre-Fire Plan
Lake Screen House, Elevation 714' and 683'
Engineering
Changes
Evaluation of the 1B DG Heat Exchanger Thermal
Performance Data Using Alternate (EPRI) Methodology
Procedures
LTS-200-11
Diesel Generator Cooling Heat Exchanger Thermal
Performance Monitoring
Work Orders
LRA Diesel Generator Heat Exchanger Thermal
Performance Monitoring
11/24/2021
Miscellaneous
Performance
Records
Licensed Operator Annual Examination Performance
Records
11/23/2021
Wrong Section of LES Performed with Load Bank Still on
Charger
11/12/2019
Corrective Action
Documents
LOS-FP-R4, FP Valve Not Cycled as Required During
Outage
2/27/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
1A DG Maintenance Switch Checked Without Calling MCR
06/11/2020
Wrong Quantity of Chemical Added to TBCCW System
06/17/2021
Attendance
Records
Licensed Operator Continuous Training Attendance Records
2019-2021
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
01/30/2016
Cycle 17 Testing
Reactivity Anomaly Test
04/26/2016
Cycle 17 Testing
BWR Shutdown Margin Determination
03/18/2016
Reactivation
Records
Various Reactivation Packages (Current Cycle)
2019-2021
Remediation
Records
Various Remediation Packages (Current Cycle)
2019-2021
Miscellaneous
Transient Testing
Transients 1, 2, 3, 4, 5a, 5b, 6, 7, 8, 9, and 10
09/29/2021-
10/01/2021
Operator Training Programs
Conduct of Simulator Training and Evaluation
Examination Security and Administration
Exelon Nuclear Training - Implementation Phase
TQ-AA-224-F100
Remedial Training Notification and Action on Failure
Procedures
Simulator Management
NF-AB-720-F-1
Control Rod Sequence Review and Approval Sheet
NF-LA-1-1000
Reactor Engineer Products Tri-Level Review and Site
Challenge Approval Sheet
Procedures
Reactivity Maneuver
RM-1C71A-K10C Failed to De-Energize During
LOS-RP-Q2
09/03/2017
RM - TSV #3 RPS Relay Failed Test
09/09/2018
Roll Up IR for RPS TSV Limit Switch Heat-Related Issues
09/10/2018
RM 1C71A-K10C Failed to De-Energize During
LOS-RP-Q2
03/23/2019
Corrective Action
Documents
RM-LOS-RP-SA4 1C71A-K10G Didn't De-Energize as
Expected
2/04/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
RM-LOS-RP-SA4 1C71A-K10C Didn't De-Energize as
Expected
2/04/2021
Engineering
Evaluations
LAS-02121
Failure Analysis of Limit Switch from LaSalle Station
08/17/2018
2VX01C Div 1 SWGT Rom SPLY Fan Trip
09/27/2021
Corrective Action
Documents
1A DG Trouble Alarm Low Engine Temp
10/19/2021
1A DG Trouble Alarm Low Engine Temp
10/19/2021
2E51-F010 Digital Point D911 NAVA
11/11/2021
Corrective Action
Documents
As Found Flow Low On @VY02A During LOS-DG-Q3
11/22/2021
Engineering
Changes
Alternate Acceptance Criteria for VY Coolers
000
Leak Check on 2DO11M Strainer
10/27/2021
Verify No Leaks at System Pressure
10/27/2021
No Leaks 2DO02T 2B DG Fuel Storage Tank Manway
10/27/2021
2E22-F319 HPCS DG Backwash Valve
10/27/2021
2E22-D300 HPCS DG Cooling Water Strainer
10/27/2021
Breaker Closes and Carries 'A' Load CUB 005 (2AP07E)
10/26/2021
2B DG 'B' Starting Air Press Regulating Valve
10/27/2021
2B DG 'A' Starting Air Press Regulating Valve
10/27/2021
No Leaks 2DO04T 2B DG Fuel Storage Tank Manway
10/27/2021
LRA OP LOS-DG-M3 U2 HPCS DG Fast Start ATT
10/27/2021
SAT Operation 2B DG 'A' Air Compressor
Unloader Valve
10/26/2021
Work Orders
1A DG Trouble Alarm Low Engine Temp
10/20/2021
Procedures
LOS-CS-SR2
Secondary Containment (VR) Damper Operability Test
EP-Siren Failure (LS10, LS24)
08/17/2020
EP-Siren Failure LS30
2/02/2021
EP-Siren Failure LS29
03/02/2021
EP-Siren Failure LS06
04/05/2021
Corrective Action
Documents
Siren Failure LS23
05/27/2021
Miscellaneous
Siren Daily Operability Reports
10/01/2019-
09/30/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
LaSalle Monthly Siren Availability Reports
10/01/2019-
09/30/2021
Semi-Annual LaSalle Siren Reports - Siren Corrective and
Preventative Maintenance
10/01/2019-
08/17/2021
21/2022 Emergency Planning for the LaSalle
Area - Important Safety Information for Your Community
05/19/2021
Exelon Nuclear Standardized Radiological Emergency Plan
Procedures
Exelon Nuclear Radiological Emergency Plan Annex for
LaSalle Station
Corrective Action
Documents
ERO Members Did Not Respond to Everbridge System
Call-In Drill
08/06/2021
ERO Training Records - Initial and Requalification Training
(Sample - 15 ERO Personnel)
10/26/2021
Quarterly Unannounced Off-Hours Call-In Augmentation Drill
Results
10/01/2019-
09/30/2021
Miscellaneous
LaSalle Station Emergency Response Organization Duty
Team Roster
10/12/2021
Addendum 1
LaSalle Station On-Shift Staffing Technical Basis
EP-AA-112-100-
F-06
ERO Notification Form
X
TSC Activation and Operation
Operations Support Center Activation and Operation
Emergency Operations Facility Activation and Operation
Procedures
ERO Training and Qualification
EP-Grundy County Sheriff NARS Phone Inoperable
11/15/2019
Mid-West Hospital Cabinet Inventory EP-AA-124-F-39
Issues
11/24/2020
Field Team Vans Inventory Deficiencies
2/31/2020
Corrective Action
Documents
LaSalle County EOC Phone Did Not Function
05/12/2021
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
Miscellaneous
Seneca Ambulance Service Letter of Agreement
11/17/2017
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Marseilles Fire Department Letter of Agreement
11/17/2017
Marseilles Area Ambulance Service Letter of Agreement
11/17/2017
4378294-01
21 EVAL - Emergency Preparedness; Off-Site Agency
Interface Annual Review
03/08/2021-
2/2021
EP-AA-124-1001-
F-02
Technical Support Center Inventory of RP
Equipment Records
10/01/2019-
09/30/2020
EP-AA-124-1001-
F-03
Operations Support Center Inventory of RP
Equipment Records
10/01/2019-
09/30/2020
EP-AA-124-F-01
Quarterly Emergency Response Data System (ERDS) Test
Records
10/01/2019-
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
Test Records
09/01/2020-
09/30/2021
EP-LA-124-F-09
LaSalle Monthly ENS Communications Test Records
10/01/2019-
10/30/2020
EP-MW-124-
1001-F-01
LaSalle Control Room/Simulator Inventory Records
10/01/2019-
09/30/2021
KLD TR-1178
LaSalle County Generating Station 2020
Population Update Analysis
09/05/2020
NOSA-LAS-19-03
LaSalle Station Emergency Preparedness Audit Report
04/17/2019
Exelon Nuclear Standardized Radiological
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
Emergency Response Facilities and
Equipment Readiness
Procedures
EP-AA-124-F-01
Quarterly Emergency Response Data System (ERDS) Test
10/01/2019-
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Records
09/30/2021
Monthly Data Elements for ERO Drill Participation
07/01/2020-
06/30/2021
Monthly Data Elements for NRC Drill/Exercise Performance
07/01/2020-
06/30/2021
Miscellaneous
Monthly Data Elements for NRC ANS Reliability
07/01/2020-
06/30/2021
71151
Procedures
Performance Indicator Guidance
Unit 1 Heater Drain Transient
01/18/2012
Single Point Vulnerability of the Heater Drain System
03/05/2015
Loss of Pump Forward Necessitates Rapid
Power Reduction
07/20/2021
PPC Troubleshooting Performed Without a
Work Order - IR #2
07/19/2021
AR 444092444092Misoriented Valve
09/01/2021
Unexpected MCR Alarm During LIS-CM-210
09/01/2021
Unexpected Alarm During LIS-CM-210
09/01/2021
Unexpected Alarm During LIS-CM-210
09/01/2021
Trend in Maintenance Performance
09/02/2021
Corrective Action
Documents
Trend in Maintenance Performance
09/02/2021
Equipment Reliability Process Description
Procedures
Equipment Reliability Program Description
5