IR 05000373/2021013
| ML22019A284 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 01/20/2022 |
| From: | Kenneth Riemer NRC/RGN-III/DRP/B1 |
| To: | Rhoades D Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2021013 | |
| Download: ML22019A284 (15) | |
Text
January 20, 2022
SUBJECT:
LASALLE COUNTY STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000373/2021013 AND 05000374/2021013
Dear Mr. Rhoades:
On December 20, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your LaSalle County Station and discussed the results of this inspection with Mr. Van Fleet, and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No findings or violations of more than minor significance were identified during this inspection. 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 01/20/22 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: 05000373/2021013 and 05000374/2021013 Enterprise Identifier: I-2021-013-0017 Licensee: Exelon Generation Company, LLC Facility: LaSalle County Station Location: Marseilles, IL Inspection Dates: November 29, 2021 to December 17, 2021 Inspectors: J. Bozga, Senior Reactor Inspector G. Hansen, Sr. Emergency Preparedness Inspector G. Hausman, Senior Reactor Inspector P. Smagacz, Resident Inspector 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 a biennial problem identification and resolution 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
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
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 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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the 125V DC systems and Core Standby Cooling systems.
Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.
Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Based on the samples reviewed, the team determined that the licensees' performance in each of these areas adequately supported nuclear safety.
Effectiveness of Problem Identification:
Overall, the licensee was effective at identifying issues at a low threshold and was properly entering them into the Corrective Action Program (CAP) as required by procedures. The inspectors determined that the station was generally effective at identifying negative trends that could potentially impact nuclear safety, at an appropriate threshold and at a healthy rate, team interviewed personnel, reviewed documents, walked down portions of the plant, and assessed licensee problem identification. Staff were encouraged to identify issues and felt comfortable raising concerns with management. However, there were numerous descriptions of the workforce feeling that very low-level items never get fixed, even though numerous condition reports are entered year after year or every time certain surveillances are performed.
The inspectors reviewed root cause and apparent cause evaluations and determined those evaluations were adequate. The inspectors noted that adding more detail to the event timelines will aid in an independent reviewer understanding all known facts. For example, during the review of the root cause report for the refuel bridge mast foreign material issue (AR 4407109), a statement troubleshooting was performed, and fuel moves recommenced was made. This statement could have been expounded upon and detailed the troubleshooting efforts, what was or was not identified, and the criteria for recommencing with fuel moves. Also, detailed descriptions on the actual physical limitations of the refuel mast after each failure would have aided an independent reviewer.
Effectiveness of Prioritization and Evaluation of Issues:
In depth reviews of a risk-informed sampling of Action Requests (ARs), work orders (WOs),and cause evaluations were completed, including 5-year reviews of issues associated with the 125V DC Battery Systems and Core Standby Cooling Systems. The inspectors identified that the licensee generally, appropriately prioritized and evaluated issues for resolution.
The inspectors also noted that while issue evaluations were generally sound, there were several examples where additional research was needed to understand the technical basis, primarily due to a lack of clear documentation. This theme had previously been identified in earlier licensee self-assessments and CAP audits and continued to be a concern.
Effectiveness of Corrective Actions:
The inspectors concluded that the licensee was generally effective in developing Corrective Actions that were appropriately focused to correct the identified problem and correct conditions adverse to quality. For issues considered significant conditions adverse to quality, the licensee took action to address the root and contributing causes and to preclude repetition. Corrective actions were generally completed in a timely manner and in accordance with procedural requirements commensurate with the safety significance of the issue.
5-year Reviews of the 125V DC Systems and Core Standby Cooling Systems:
The inspectors performed an expanded 5-year review of the Units 1 and 2 125 Vdc system; specifically, by performing system walk-downs and evaluating condition reports, engineering changes, and work orders. The inspectors also interviewed the system engineer responsible for this system. Overall, the inspectors determined that the licensee was effectively managing issues associated with this system.
As part of the review of the Core Standby Cooling System, the team identified a condition report (AR 4406388) which was associated with the use of operability limits (ASME Section III Appendix F) for determination of pressure boundary integrity/continued operation of FAC component 2RA023, a 4" tee in the reactor bottom head drain line 2RR28B-4. The inspection of this condition report will continue as a Selected Issue for Follow-Up (71152 inspection procedure) during NRC inspections in 2022.
Operating Experience, Self-Assessment and Audits:
The inspectors reviewed operating experience captured in the CAP and sampled operating experience from NRC, industry, vendors, and third-party groups. Overall, for the samples selected, the licensee was generally performing the appropriate assessments for station applicability. Through interviews and observations at selected station meetings, the inspectors also concluded that operating experience was being appropriately used in daily plant activities.
The inspectors determined that the licensee was adequately performing self-assessments and audits in accordance with licensee procedures and implementing corrective actions as needed. The inspectors did note not all self-assessment templates developed included sufficient guidance to ensure consistent evaluations. This was specifically identified in security self-assessments where one assessment included a discussion on the quantity of records reviewed, but other assessments contained blanket statements of passing.
Safety Conscious Work Environment:
As part of the NRCs safety conscious work environment evaluation during the PI&R biennial inspection, NRC inspectors completed a limited scope inspection sample of an assessment performed by the licensee that evaluated human performance behaviors exhibited during the recent refueling outage, L1R18, and the potential impact on safety conscious work environment at the site. The inspectors performed an independent review that evaluated the licensees internal assessment of the sites SCWE program and the actions that were developed and implemented in response to the licensees identified areas for improvement to promote a healthy organizational safety conscious work environment. The NRC inspectors reviewed licensee evaluation records, internal organizational assessment survey results, training plans, and conducted interviews with the Employee Concerns Program Manager, Organizational Effectiveness Manager, and management staff from various departments.
No violations or findings were identified.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On December 20, 2021, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Van Fleet, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Calculations L-003447 LaSalle Units 1 and 2, 125Vdc System Analysis Dated 002
June 11, 2020
Corrective Action 04062322 Replace Battery 2DC18E Cell 44 10/12/2017
Documents 04114041 Replace or Retest 1DC07E 03/12/2018
04144731 Generate Forced Outage Work Order for Battery 06/06/2018
Replacement
203137 U2 Division 1 Battery Replacement 12/14/2018
04455972 Request WR to Replace 2DC16E K306 Relay 10/26/2021
04455973 Request WR to Replace 2DC23E K306 Relay 10/26/2021
1337255 TRM Appendix G, Table 2 Enhancements Needed 03/01/2012
141231 VR Supply Duct Access Repair Patch Not Installed Per 01/27/2003
Design
1518242 Ops Crew 6 4/17/13 LOOP Lessons Learned 04/17/2013
2387941 2E22-F369A Relief Valve Failed As-Found Test 09/29/2014
2530386 FAC Program - OE Review of Davis Besse Steam Rupture 05/19/2015
2618561 Degraded Condition Observed on CSCS Piping Line 01/28/2016
3990967 Degraded Condition Observed on CSCS Piping Line 03/29/2017
4048633 RM - 1C71A-K10C Failed to De-Energize During LOS-RP-Q2 09/03/2017
4099862 Limitation For 2HP55BB Per EC 403264 Flaw Evaluation 02/01/2018
4172339 Unit 2 LPCS Motor Cooler Inlet Pipe 2DG22A-1.5" is 09/12/2018
Degraded
4192778 2018 WANO AFI ER.2 11/06/2018
21635 VT-3 Exams Specified on Supports Exempted from 02/19/2019
Examination
25076 ACB 1414 Had a Lockout Trip While Performing LOS-AP-R2 03/01/2019
28241 Low Power TIP Set not Completed Due to TIPs OOS 03/10/2019
251021 Review Code Requirements for Replacement VY Cooling 05/22/2019
Coils
252624 Code Non-Conformance Identified For VY Coolers 05/29/2019
1(2)VY03A
Inspection Type Designation Description or Title Revision or
Procedure Date
257366 4.0 Critique IR on Tendon Surveillances 06/17/2019
258604 Late Surveillance (LIS-OG-408) 06/21/2019
261844 Cardox Tank Compressor Tripped on Thermal Overloads 07/04/2019
262090 NRC ID - Dry Pipe FP Lines not Sloped Per NFPA13 07/05/2019
265814 1RE026 Closed Light Did Not Illuminate During LOS-PC-Q1 07/21/2019
265960 Large Steam Leak Found Downstream of 1G33-F040 07/22/2019
266264 Performance Level 3 OPEX Review of ICES 456532 for 08/23/2019
Applicability to LaSalle
267062 MSIV Pilot Solenoid Leads Crossed 07/25/2019
267121 PCE Level 1 07/25/2019
270252 Historical 2C51-J004C App J Leakage Evaluations not Found 08/07/2019
271342 Unexpected MCR Alarm: Unit 1 Hydrogen Panel Trouble 08/12/2019
273172 Part 21 Flowserve Unqualified NDE Performance of 08/20/2019
Component
273349 NER NC-19-010-Y OE Review- Potential LaSalle 08/20/2019
Vulnerability
276944 Part 21 Contactors Failing to Release/Open When 09/05/2019
De-Energized
277173 NRC IN 2019-05: Over Pressurization of Alpha Sources 09/06/2019
280047 AT 04257366-04 Needs to be Reevaluated 09/17/2019
281169 LOS-SY-SR1 Revision Needed 09/22/2019
284443 Through Wall Leak on ST Piping in U2 Div 1 CSCS Pump 10/02/2019
Room
286161 Unacceptable Trend Identified on MSIV Timing Per 10/08/2019
LOS-PC-Q2
288235 NRC IN 2019-08 OPEX Regarding FAC Causing RX Scrams 10/16/2019
288344 NRC ID: NRC Question on 1G33-F040 10/16/2019
288357 Replace Piping 1DG23B-6" 10/16/2019
294984 NRC IN 19-09: Spent Fuel Cask Movement Issues 10/30/2019
295415 Revise EC 363524 to Extend VY Fan SBM C\S Replacement 11/07/2019
PM's
4305470 Biennial Safety Culture Self-Assessment 02/04/2020
4306254 Level 3 OPEX Review Requested #465166 Diablo Canyon 12/27/2019
Inspection Type Designation Description or Title Revision or
Procedure Date
Unit 2
4306904 1B RR Pump Lower Oil Reservoir Hi Level 12/30/2019
4307124 Level 3 OPEX Review Requested #464385 Salem Unit 2 12/31/2019
4307131 Level 3 OPEX Review Requested #458702 Hatch Unit 2 12/31/2019
4318198 L1R18 FAC; 1RH006 Low Wall Thickness 02/15/2020
4319242 L1R18 FAC; Component 1RH014 Low Wall Thickness 02/19/2020
22219 1ES010B Indicating Closed 02/28/2020
22221 1ES010C Indicating Closed 02/28/2020
28259 P21- Potential Deviation of Pressure Transmitters 03/20/2020
4330162 Rosemount Transmitters Part 21 for Changes in Heat Rise 03/27/2020
4343229 Flex Generator Issue at Quad: LaSalle has Similar Generator 05/14/2020
4357505 U1 EHC Pressure Low in Band with New Discharge Filter 07/18/2020
4362593 NRC Question on 2CW03A Piping Support 08/10/2020
4365890 RM - Step Change Reduction in U2 Jet Pump 15 Flow 08/27/2020
4366965 Degraded Piping Support 09/02/2020
4368035 LR Inspection of 2LP13B-3" Piping 09/08/2020
4368037 LR Inspection of 2LP23AA-1/2" Piping 09/08/2020
4368040 LR Inspection for 2LP19A-3" Piping 09/08/2020
4380329 SR 3.4.3.1 Jet Pump# 15 Curve No Conservative Change 10/28/2020
4382365 B DFP High Discharge Pressure 11/05/2020
4383488 2A RHR Seal Cooler Flow Low 11/10/2020
4389292 RM - JP 5/6 ACMP Flow Mismatch 12/10/2020
4391800 Loss of U2 Div 3 Water Leg Pump 12/23/2020
4391803 NRC IN 2020-04 - FP Mn Yard Buried Cast Iron Piping 12/17/2020
Failures
4404161 L2R18 FAC Component 2HJ016 Low Wall Thickness 02/23/2021
4404521 L2R18 FAC; 2RH004, Low Wall Thickness 02/24/2021
4404903 2DG01A Heat Exchanger Tubes Material Degradation 02/24/2021
4404903 2DG01A Heat Exchanger Tubes Material Degradation 02/26/2021
4405141 Unanticipated Does Rate Alarm in High Radiation Area 02/27/2021
4406388 FAC Inspection on 2RA023 not Performed 03/03/2021
4406519 NRC ID Failure to Write IR in Heat Exchanger Program 03/03/2021
4406519 NRC ID Failure to Write IR in Heat Exchanger Program 03/04/2021
Inspection Type Designation Description or Title Revision or
Procedure Date
4406544 NRC ID LR Selective Leaching Program Perf. Deficiencies 03/01/2021
4406555 L2R18 FAC; 2MS66B-RT-01, Low Wall Thickness 03/04/2021
4407109 Unit 2 Refuel Bridge Mast Issue During Fuel Moves 03/07/2021
4407109 Unit 2 Refuel Bridge Mast Issue During Fuel Moves 03/07/2021
4407388 "L" SRV Drop Test Failure 03/08/2021
4407915 "L" SRV Failed LOS-MS-R& Drop Test 03/10/2021
4407917 "R" SRV Failed Regulated Header Drop Test 03/10/2021
4409413 NRC Identified-NRC Questioned Weld Procedure 03/15/2021
Qualification
4417755 RM - Unit 2 Jet Pump #6 is not Within Jet Pump Curves 04/20/2021
22004 FAC RWCU Bottom Head Drain Lessons Learned 05/06/2021
23071 NRC IN 2021-01: Design Bases LLed Power Operated 05/11/2021
Valves
26705 RM - 2A RPS M/G Set Output Breaker Tripped 05/31/2021
27494 2A RPS MG Set Voltage Adjustment Pot Bad 06/04/2021
28890 L1R19 Class 1 Small Bore Pipe Socket Welds 06/11/2021
4433739 Tendon Grease Cap Area Unit 2 Concrete Inspections 07/07/2021
4441741 2021 PI&R SA Gap: OBJ 3A 08/20/2021
44447160 No Flow Thru U1 EHC Fullers Earth Filters Via Hydraulic 09/17/2021
Pump
4448905 10CFR Part 21. Ametek Equalize Relay 09/27/2021
Corrective Action 4465190 NRC ID- 2HP54A-4" UT Inspection Results Per WO-4621240 12/07/2021
Documents 4466247 NRC Identified Issue With L-003447 Rev. 002 12/13/2021
Resulting from 4466816 NRC ID - 2DG22A-1.5" Min Wall Design Limit 12/15/2021
Inspection 4467017 NRC Observation - 2021 PI&R - CR Type AR Generation 12/16/2021
4467039 NRC Observation - PI&R 2021 - Security Self-Assessments 12/16/2021
4467111 NRC Observation - PI&R 2021 - Enhancement Opportunity 12/16/2021
for RCR
Engineering 403264 Minimum Wall Thickness for Unit 2 Division 3 VY Cooler 1
Changes Piping for Extent of Condition
403264 Minimum Wall Thickness for Unit 2 Division 3 VY Cooler 2
Piping for Extent of Condition
28380 L2R18 FAC Min Wall Evaluation 4
Inspection Type Designation Description or Title Revision or
Procedure Date
28380 L2R18 FAC Min Wall Evaluation 5
Engineering LAS-02121 Failure Analysis of Limit Switch from LaSalle Station 08/14/2018
Evaluations LAS-24193 Failure Analysis of a Namco Limit Switch from LaSalle 11/16/2018
Station
LAS-62503 Failure Analysis of a Namco limit Switch from Lasalle Station 05/03/2019
LAS-93383 Failure Analysis of a NAMCO Limit Switch Assembly 06/13/2012
Miscellaneous 4405141 Rad Worker Behaviors Root Cause 05/27/2021
4407109 Root Cause Investigation Report for Unit 2 Refuel Bridge 06/25/2021
Mast Issue During Fuel Moves
IEEE STD 485- IEEE Recommended Practice for Sizing Lead-Acid Batteries 09/11/2003
1997 for Stationary Applications
IEEE STD 946- IEEE Recommended Practice for the Design of 03/21/1985
1985 Safety-Related DC Auxiliary Power Systems for Nuclear
Power Generating Stations
NOSA-LAS-19-05 Engineering Design Control Audit Report 07/10/2019
NOSA-LAS-20-05 Engineering Programs Audit Report 07/15/2020
NOSA-LAS-21-05 LaSalle Corrective Action Program Audit Report 09/01/2021
OPEX Evaluation ICES 318466, Pin Hole Leak at Residual Heat Removal 11/25/2015
2570259-02 Service Water (RHRSW) Pipe Elbow
OPEX Evaluation LER 2017-003, Division 2 Residual Heat Removal Service 11/09/2017
4056244-02 Water System (RHRSW) Inoperable Due to an Inoperable
RHRSW Flow Control Valve (FCV) (Fermi 2)
OPEX Evaluation ESW Inop Due to Silt Buildup 04/29/2020
430760
NDE Reports20-141 Ultrasonic Exam of 2DG22A-1 1/2 09/08/2020
Procedures EI-AA-101 Employee Concerns Program 11
ER-AA-320 Maintenance Rule Implementation Per NEI 18-10 0
NISP-PI-02 Conduct of Self-Assessments and Benchmarks 0
NO-AA-10 Quality Assurance Topical Report 97
PI-AA-101 Conduct of Performance Improvement 2
PI-AA-1012 Safety Culture Monitoring 3
PI-AA-115 Operating Experience Program 5
PI-AA-120 Issue ID and Screening Process 11
Inspection Type Designation Description or Title Revision or
Procedure Date
PI-AA-120 Issue Identification and Screening Process 11
PI-AA-125-1001 Root Cause Analysis Manual 6
PI-AA-125-1003 Corrective Action Program Evaluation Manual 6
PI-AA-126-1001 Self-Assessments 5
Self-Assessments 4091749 RP Personnel Knowledge SA Report Assignment 07/02/2019
4113395 NRC SY Baseline Inspect-SA Report PASSPORT 06/06/2019
Assignment
4113396 NRC EP Baseline Inspect-SA Report PASSPORT 09/05/2019
Assignment
4192133 SA Report - M&TE Inventory Control, Access, & Handling 10/08/2019
4192133 Self-Assessment M&TE Inventory Control, Access, & 11/06/2018
Handling
4192145 SA Report Assignment - M&T Effectiveness of ACAD 17-01 10/02/2019
4192182 SA Report Assignment - NRC SY Baseline Inspection 12/18/2019
257452 Self-Assessment of SA/BM NISP-PI-02 Implementation 05/14/2020
4305470 Biennial Safety Culture Self-Assessment 02/04/2020
29347 LaSalle Pre-NRC Triennial Heat Sink 02/24/2021
29367 SA Report - Security Baseline Inspection 07/21/2021
29672 SA Report - RP Baseline Inspection 07/16/2021
29675 SA Report - EP Baseline Inspection/Performance Indicator 10/01/2021
Verification
4343239 Cyber Security Program Effectiveness Self-Assessment 05/14/2020
4362946 LaSalle M&T Comprehensive Self-Assessment Report 06/30/2021
4378794 2020 INPO Performance Based Evaluation Results 09/23/2021
4430137 2021 Preparation for NRC Problem Identification and 08/23/2021
Resolution (PI&R) Inspection
LaSalle Station Fleet Assessment Special Assessment Report 02/24/2020
01/27-31/2020
LaSalle Station Fleet Assessment T-6 Assessment Report (Maintenance) 04/16/2020
03/23-27/2020
LaSalle Station Fleet Assessment T-18 Assessment Report (Maintenance) 06/14/2021
05/17-21/2021
LaSalle Station Fleet Assessment Mid-Cycle Assessment Report 09/18/2019
Inspection Type Designation Description or Title Revision or
Procedure Date
08/16-28/2019 (Maintenance)
LaSalle Station Fleet Assessment Midcycle Assessment Debrief 11/15/2021
Work Orders 4866827 Unit 2 Refuel Bridge Contingency Repairs 03/07/2021
2