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
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.
January 20, 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:
05000373/2021013 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
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
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
LaSalle Units 1 and 2, 125Vdc System Analysis Dated
June 11, 2020
2
04062322
Replace Battery 2DC18E Cell 44
10/12/2017
04114041
Replace or Retest 1DC07E
03/12/2018
04144731
Generate Forced Outage Work Order for Battery
Replacement
06/06/2018
203137
U2 Division 1 Battery Replacement
2/14/2018
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
Design
01/27/2003
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
2/01/2018
4172339
Unit 2 LPCS Motor Cooler Inlet Pipe 2DG22A-1.5" is
Degraded
09/12/2018
4192778
11/06/2018
21635
VT-3 Exams Specified on Supports Exempted from
Examination
2/19/2019
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
Coils
05/22/2019
Corrective Action
Documents
252624
Code Non-Conformance Identified For VY Coolers
1(2)VY03A
05/29/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
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
Applicability to LaSalle
08/23/2019
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
Component
08/20/2019
273349
NER NC-19-010-Y OE Review-Potential LaSalle
Vulnerability
08/20/2019
276944
Part 21 Contactors Failing to Release/Open When
De-Energized
09/05/2019
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
Room
10/02/2019
286161
Unacceptable Trend Identified on MSIV Timing Per
LOS-PC-Q2
10/08/2019
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
PM's
11/07/2019
4305470
Biennial Safety Culture Self-Assessment
2/04/2020
4306254
Level 3 OPEX Review Requested #465166 Diablo Canyon
2/27/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Unit 2
4306904
1B RR Pump Lower Oil Reservoir Hi Level
2/30/2019
4307124
Level 3 OPEX Review Requested #464385 Salem Unit 2
2/31/2019
4307131
Level 3 OPEX Review Requested #458702 Hatch Unit 2
2/31/2019
4318198
L1R18 FAC; 1RH006 Low Wall Thickness
2/15/2020
4319242
L1R18 FAC; Component 1RH014 Low Wall Thickness
2/19/2020
22219
1ES010B Indicating Closed
2/28/2020
22221
1ES010C Indicating Closed
2/28/2020
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
2/10/2020
4391800
Loss of U2 Div 3 Water Leg Pump
2/23/2020
4391803
NRC IN 2020-04 - FP Mn Yard Buried Cast Iron Piping
Failures
2/17/2020
4404161
L2R18 FAC Component 2HJ016 Low Wall Thickness
2/23/2021
4404521
L2R18 FAC; 2RH004, Low Wall Thickness
2/24/2021
4404903
2DG01A Heat Exchanger Tubes Material Degradation
2/24/2021
4404903
2DG01A Heat Exchanger Tubes Material Degradation
2/26/2021
4405141
Unanticipated Does Rate Alarm in High Radiation Area
2/27/2021
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
Procedure
Type
Designation
Description or Title
Revision or
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
Qualification
03/15/2021
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
Valves
05/11/2021
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
08/20/2021
44447160
No Flow Thru U1 EHC Fullers Earth Filters Via Hydraulic
Pump
09/17/2021
4448905
10CFR Part 21. Ametek Equalize Relay
09/27/2021
4465190
NRC ID-2HP54A-4" UT Inspection Results Per WO-4621240
2/07/2021
4466247
NRC Identified Issue With L-003447 Rev. 002
2/13/2021
4466816
NRC ID - 2DG22A-1.5" Min Wall Design Limit
2/15/2021
4467017
NRC Observation - 2021 PI&R - CR Type AR Generation
2/16/2021
4467039
NRC Observation - PI&R 2021 - Security Self-Assessments
2/16/2021
Corrective Action
Documents
Resulting from
Inspection
4467111
NRC Observation - PI&R 2021 - Enhancement Opportunity
for RCR
2/16/2021
403264
Minimum Wall Thickness for Unit 2 Division 3 VY Cooler
Piping for Extent of Condition
403264
Minimum Wall Thickness for Unit 2 Division 3 VY Cooler
Piping for Extent of Condition
Engineering
Changes
28380
L2R18 FAC Min Wall Evaluation
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
28380
L2R18 FAC Min Wall Evaluation
LAS-02121
Failure Analysis of Limit Switch from LaSalle Station
08/14/2018
LAS-24193
Failure Analysis of a Namco Limit Switch from LaSalle
Station
11/16/2018
LAS-62503
Failure Analysis of a Namco limit Switch from Lasalle Station
05/03/2019
Engineering
Evaluations
LAS-93383
Failure Analysis of a NAMCO Limit Switch Assembly
06/13/2012
4405141
Rad Worker Behaviors Root Cause
05/27/2021
4407109
Root Cause Investigation Report for Unit 2 Refuel Bridge
Mast Issue During Fuel Moves
06/25/2021
IEEE STD 485-
1997Property "IEEE" (as page type) with input value "IEEE 485-</br></br>1997" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.
IEEE Recommended Practice for Sizing Lead-Acid Batteries
for Stationary Applications
09/11/2003
IEEE STD 946-
1985Property "IEEE" (as page type) with input value "IEEE 946-</br></br>1985" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.
IEEE Recommended Practice for the Design of
Safety-Related DC Auxiliary Power Systems for Nuclear
Power Generating Stations
03/21/1985
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
2570259-02
ICES 318466, Pin Hole Leak at Residual Heat Removal
Service Water (RHRSW) Pipe Elbow
11/25/2015
OPEX Evaluation
4056244-02
LER 2017-003, Division 2 Residual Heat Removal Service
Water System (RHRSW) Inoperable Due to an Inoperable
RHRSW Flow Control Valve (FCV) (Fermi 2)
11/09/2017
Miscellaneous
OPEX Evaluation
430760
ESW Inop Due to Silt Buildup
04/29/2020
Ultrasonic Exam of 2DG22A-1 1/2
09/08/2020
Employee Concerns Program
Maintenance Rule Implementation Per NEI 18-10
NISP-PI-02
Conduct of Self-Assessments and Benchmarks
Quality Assurance Topical Report
Conduct of Performance Improvement
Safety Culture Monitoring
Operating Experience Program
Procedures
Issue ID and Screening Process
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Issue Identification and Screening Process
Root Cause Analysis Manual
Corrective Action Program Evaluation Manual
Self-Assessments
4091749
RP Personnel Knowledge SA Report Assignment
07/02/2019
4113395
NRC SY Baseline Inspect-SA Report PASSPORT
Assignment
06/06/2019
4113396
NRC EP Baseline Inspect-SA Report PASSPORT
Assignment
09/05/2019
4192133
SA Report - M&TE Inventory Control, Access, & Handling
10/08/2019
4192133
Self-Assessment M&TE Inventory Control, Access, &
Handling
11/06/2018
4192145
SA Report Assignment - M&T Effectiveness of ACAD 17-01
10/02/2019
4192182
SA Report Assignment - NRC SY Baseline Inspection
2/18/2019
257452
Self-Assessment of SA/BM NISP-PI-02 Implementation
05/14/2020
4305470
Biennial Safety Culture Self-Assessment
2/04/2020
29347
LaSalle Pre-NRC Triennial Heat Sink
2/24/2021
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
Verification
10/01/2021
4343239
Cyber Security Program Effectiveness Self-Assessment
05/14/2020
4362946
LaSalle M&T Comprehensive Self-Assessment Report
06/30/2021
4378794
20 INPO Performance Based Evaluation Results
09/23/2021
4430137
21 Preparation for NRC Problem Identification and
Resolution (PI&R) Inspection
08/23/2021
LaSalle Station
01/27-31/2020
Fleet Assessment Special Assessment Report
2/24/2020
LaSalle Station
03/23-27/2020
Fleet Assessment T-6 Assessment Report (Maintenance)
04/16/2020
LaSalle Station
05/17-21/2021
Fleet Assessment T-18 Assessment Report (Maintenance)
06/14/2021
Self-Assessments
LaSalle Station
Fleet Assessment Mid-Cycle Assessment Report
09/18/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
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