IR 05000373/2023001
| ML23130A218 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 05/10/2023 |
| From: | Robert Ruiz NRC/RGN-III/DORS/RPB1 |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2023001 | |
| Download: ML23130A218 (1) | |
Text
SUBJECT:
LASALLE COUNTY STATION - INTEGRATED INSPECTION REPORT 05000373/2023001 AND 05000374/2023001
Dear David P. Rhoades:
On March 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at LaSalle County Station. On April 12, 2023, the NRC inspectors discussed the results of this inspection with John VanFleet, acting Site Vice President, and other members of your staff.
The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at LaSalle County Station.
If you disagree with a cross-cutting aspect assignment 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.
May 10, 2023 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, Robert Ruiz, Chief Reactor Projects Branch 1 Division of Operating Reactor Safety 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:
05000373/2023001 and 05000374/2023001
Enterprise Identifier:
I-2023-001-0060
Licensee:
Constellation Nuclear
Facility:
LaSalle County Station
Location:
Marseilles, IL
Inspection Dates:
January 01, 2023 to March 31, 2023
Inspectors:
J. Benjamin, Senior Resident Inspector
J. Cassidy, Senior Health Physicist
G. Edwards, Senior Enforcement Specialist
E. Magnuson, Reactor Inspector
J. Park, Reactor Inspector
J. Reed, Health Physicist
E. Rosario, Reactor Inspector
A. Tran, Resident Inspector
R. Zuffa, Illinois Emergency Management Agency
Approved By:
Robert Ruiz, Chief
Reactor Projects Branch 1
Division of Operating Reactor Safety
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 Assure Charpy V-Notch Impact Test Conformed to American Society of Mechanical EngineersSection III Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000374/2023001-01 Open/Closed
[H.12] - Avoid Complacency 71111.08G The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50,
Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services, for the licensees failure to establish measures to assure that purchased material, equipment, and services through contractors conformed to the procurement documents. Specifically, the licensee failed to assure the Charpy V-Notch impact test conducted by its contractor for pipe material used for residual heat removal (RHR) system piping repair/replacement conformed to American Society of Mechanical Engineers (ASME)Section III, 1974 Edition, as specified in their procurement documents.
Failure to Secure Category 2 Quantity of Radioactive Material not Under Direct Control and Constant Surveillance Cornerstone Significance Cross-Cutting Aspect Report Section Public Radiation Safety Green NCV 05000374,05000373/2023001-02 Open/Closed
[H.12] - Avoid Complacency 71124.01 The inspectors reviewed a self-revealed Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 37.53 when the licensee failed to physically secure a mobile device containing category 2 levels of radioactive material.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000374/2022-003-01 LER 2022-003-01 for LaSalle County Station,
Unit 2, Manual Scram due to lsophase Bus Duct Fire followed by 2A RPS Normal Power Supply Trip 71153 Closed LER 05000374/2022-003-00 LER 2022-003-00 for LaSalle County Station,
Unit 2, Manual Scram Due to Isophase Bus Duct Fire and 2A RPS Normal Power Supply Trip 71153 Closed
PLANT STATUS
Unit 1 operated at or near rated thermal power for the entire inspection period.
Unit 2 began the inspection period at rated thermal power. On February 13, 2023, the unit was shut down to support refueling outage L2R19. The unit was returned to rated thermal power on March 11, 2023, and remained at or near rated thermal 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, 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.
REACTOR SAFETY
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 2A emergency diesel generator (EDG) with 2B EDG inoperable on January 23, 2023
- (2) Unit 2 high-pressure core spray (HPCS) return to service on February 22, 2023
- (3) Unit 2 2A EDG following return to service on March 15, 2023
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) Fire Zone 212, reactor building, elevation 673'-4", Unit 1 HPCS cubicle
- (2) Fire Zone 7B2, diesel building, elevation 710'-0", Unit 1 division 2 standby diesel generator room
- (3) Fire Zone 2H4, reactor building, elevation 694'-6", Unit 1 reactor core isolation cooling/low-pressure core spray cubicle
- (4) Fire Zone 8B1, diesel building, elevation 710'-0", Unit 2 HPCS system diesel generator room
- (5) Fire Zone 7C1, diesel building, elevation 674-0", Unit 1 HPCS diesel fuel tank room
71111.08G - Inservice Inspection Activities (BWR)
The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from February 13, 2023 to March 16, 2023.
BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding
Activities (IP Section 03.01) (1 Sample)
The inspectors verified that the following nondestructive examination and welding activities were performed appropriately:
- (1) The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from February 13, 2023, to March 16, 2023:
03.01.a - Nondestructive Examination and Welding Activities
1. Ultrasonic testing (UT) of component IDs IRH-2005-28 and -29, Cat. R-A,
Item R1.16, augmented
2. UT of component ID 2-NIR-N10A, Cat. B-D, Item B3.100
3. Magnetic particle exam of component ID FW02-2851S, Cat. B-K, Item B10.20
4. Weld repair/replacement of Unit 2 bottom head drain line, 1st installation,
Work Order (WO) 5237886-18, Weld #7
5. Weld repair/replacement of Unit 2 bottom head drain line, 2nd installation,
WO 5237886-19, Welds #1 and #17
6. Weld repair/replacement of 2RH03CB-12" downstream of Valve 2E12-F053B,
WO 5042338-67, Welds #1 and #2
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during reactor shutdown for L2R19 on February 13, 2023.
- (2) The inspectors observed and evaluated licensed operator performance in the control room during reactor startup for L2R19 on March 6 and March 7, 2023.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated shutdown operations training on January 25, 2023.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Replacement of Eaton full voltage reversing contactors to address failure mode identified in Westinghouse in a Part 21 issued on April 11, 2022 (ML22140A208)
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 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) Unit 1 action Green risk 1B EDG out of service for maintenance on January 25, 2023
- (2) Scheduled readiness certification meeting and risk management for work week 2243 (02/06/2023 - 02/12/2023) on January 30, 2023
- (3) Unit 2 planned Yellow risk for refueling outage reactor coolant system drain down on February 13, 2023
- (4) Unit 2 planned Yellow risk for refueling outage division 2 battery replacement on February 17, 2023
- (5) Risk informed completion time evaluation of Unit 1 B1 reactor protection system relay 1C71A-K8B (turbine control valve #2 RETS pressure switch) degraded on February 18, 2023
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 (AR) 4549216, "1RE024, Unit 1 Drywell Equipment Drain Inboard Isolation Valve, Primary Containment Isolation Valve Failed to Open"
- (2) AR 4549032, "FLEX Diesel Fuel Sample did not Meet Spec"
- (3) AR 4551562, "Unit 1 1A Emergency Diesel Generator Speed Control Governor not Responding"
- (4) AR 4553493 "2A/2B RHR [residual heat removal] WS PMP Cubicle Cooler Fan 2VY05C Auto Trip"
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Engineering Change 638423, "Seismic Evaluation of the LaSalle Unit 2 Bottom Head Drain Plug"
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated Unit 2 refueling outage 2R19 activities from February 12, 2023 to March 6, 2023.
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (4 Samples)
(1)1B diesel generator and HPCS operability run after breaker replacement on January 26, 2023
- (2) Unit 2 HPCS system operability and inservice test after HPCS outage window on February 21, 2023 (3)2A diesel generator (DG) post cooling water and strainer replacement on February 23, 2023
- (4) WO 5042338-67, "Unit 2 2E12-F053B Pipe Section Replacement Completed"
Surveillance Testing (IP Section 03.01) (6 Samples)
- (1) Unit 2 2B diesel generator operability test on January 23, 2023
- (2) WO 5134693, "Integrated Division II ECCS [emergency core cooling system]
Response Time 2A EDG"
- (3) Unit 2 Group 4 inboard isolation logic system functional test on March 1, 2023
- (4) Unit 2 valve 2E12-F053B motor-operated valve testing completed on March 3, 2023
- (5) Unit 2 L2R19 American Society of Mechanical Engineers (ASME)Section XI hydrostatic and associated VT-2 visual examinations completed on March 3, 2023
- (6) Unit 2 primary containment integrated leak rate test completed on March 7, 2023
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) Emergency preparedness drill in the technical support center and outage support center on January 17,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) Workers utilizing the tool and equipment monitors and the whole-body contamination monitors while exiting the radiologically controlled area (RCA) during the Unit 2 refueling outage
- (2) Radiation protection technicians performing doffing surveys and supplied air suit removal for work control rod drive work during the Unit 2 refueling outage
Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
- (1) Control rod drive exchange (2)2B33-F067A repairs/inspections
- (3) Bottom head drain cut out/replace (4)2G33-F001 valve work activities High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (4 Samples)
The inspectors evaluated licensee controls of the following high radiation areas and very high radiation areas:
- (1) Unit 2 drywell
- (2) Unit 2 under vessel control rod drive exchange areas (3)layout of temporary hoses used for chemical decontamination on multiple elevations in the Unit 2 reactor building
- (4) Refuel floor reactor cavity work cavity work platform Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Temporary Ventilation Systems (IP Section 03.02) (1 Sample)
The inspectors evaluated the configuration of the following temporary ventilation systems:
- (1) Temporary breathing box setup for control rod drive exchange
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.
Special Dosimetric Situations (IP Section 03.04) (1 Sample)
The inspectors evaluated the following special dosimetric situations:
- (1) Use of effective dose equivalent from external exposure methodology utilizing multiple dosimetry for control rod drive exchange work
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===
- (1) Unit 1 (January 1, 2022, through December 31, 2022)
- (2) Unit 2 (January 1, 2022, through December 31, 2022)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (2 Samples)
- (1) Unit 1 (January 1, 2022, through December 31, 2022)
- (2) Unit 2 (January 1, 2022, through December 31, 2022)
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)
- (1) Unit 1 (January 1, 2022, through December 31, 2022)
- (2) Unit 2 (January 1, 2022, through December 31, 2022)
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
- (1) The inspectors reviewed the licensees implementation of its corrective action program related to elevated collective radiation exposure during the L2R18 refueling outage.
- (2) AR 4539324, "ACT Trip Reference Cards in Average Power Range Monitors and Rod Block Monitors are Failing"
- (3) AR 4543774, "Unit 1 1B Diesel Generator Lockout on Differential Current"
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Follow-up (IP section 03.01)
- (1) The inspectors evaluated Operations response to Unit 2 scram actuation during L2R19 shutdown conditions on March 4, 2023.
Event Report (IP section 03.02) (2 Samples)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000374/2022-003-00 for LaSalle County Station, Unit 2, "Manual Scram due to lsophase Bus Duct Fire followed by 2A RPS Normal Power Supply Trip,"
(ADAMS Accession No. ML22319A015). The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements.
- (2) LER 05000374/2022-003-01 for LaSalle County Station, Unit 2, "Manual Scram due to lsophase Bus Duct Fire followed by 2A RPS Normal Power Supply Trip,"
(ADAMS Accession No. ML23040A104). The inspectors reviewed the updated LER submittal. The previous LER submittal was reviewed in NRC Integrated Inspection Report 05000373/2023001 AND 05000374/2023001.
INSPECTION RESULTS
Failure to Assure Charpy V-Notch Impact Test Conformed to American Society of Mechanical EngineersSection III Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000374/2023001-01 Open/Closed
[H.12] - Avoid Complacency 71111.08G The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services, for the licensees failure to establish measures to assure that purchased material, equipment, and services through contractors conformed to the procurement documents. Specifically, the licensee failed to assure the Charpy V-Notch impact test conducted by its contractor for pipe material used for residual heat removal (RHR) system piping repair/replacement conformed to American Society of Mechanical Engineers (ASME)Section III, 1974 Edition, as specified in their procurement documents.
Description:
The licensees ASME Section XI repair/replacement plan for the RHR piping replacement activity under Work Order (WO) 5042338-67 delineated ASME Section III, 1974 Edition, as the construction code of record. The repair/replacement plan also delineated the subject pipe component as ASME Code Class 1. The replacement pipe was 12-inch nominal pipe size (NPS) Schedule 120, made of SA-333, Grade 6. This material was required to be impact tested in accordance with ASME Section III, 1974 Edition, Paragraph NB-2311, Materials for Which Impact Testing Is Required, to verify the material fracture toughness requirements were satisfied. The licensee elected Charpy V-Notch as the method to conduct the test in preparation for the repair/replacement activity. The licensees Purchase Order (PO) 1366400, Revision 3, specified ASME Section III, 1974 Edition, no addenda, as the code of record to which the impact test requirements were to be satisfied.
During review of the test report, the inspectors identified the Charpy V-Notch test was conducted using a set of three 5 x 10 millimeter
- (mm) subsize test specimens. This was not in accordance with ASME Section III, 1974 Edition, Paragraph NB-2321.2, Charpy V-Notch Tests, which specifically required a set of standard full-size 10 x 10 mm test specimens. The paragraph also referenced Specification SA-370, Specification for Methods and Definitions for Mechanical Testing of Steel Products, for conducting the test. Specification SA-370, Section 19, Test Specimens, Subsection 19.2, Size and Type, stipulated the subsize test specimens such as those used by the licensee through their contractor were to be utilized when the material thickness was less than 7/16 inch (0.438 inch). The nominal thickness of pipe material subject to the repair/replacement activity was 1.000 inch, which required the full-size 10 x 10 mm specimens.
Corrective Actions: The licensee entered this issue into their corrective action program as Action Request (AR) 4560929. The licensee re-performed the Charpy V-Notch testing with a set of full-size specimens that conformed to the requirements. The results of this testing were satisfactory.
Corrective Action References: AR 4560929, "NRC ID Vendor Charpy Test on the Incorrect Specimen Size"
Performance Assessment:
Performance Deficiency: The licensee's failure to assure the Charpy V-Notch impact testing performed in support of pipe repair/replacement activity under WO 5042338-67 conformed to ASME Section III, 1974 Edition, Paragraph NB-2321.2, "Charpy V-Notch Tests," was contrary to 10 CFR Part 50, Appendix B, Criterion VII and was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Reactor Coolant System (RCS) Equipment and Barrier Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, using the non-conforming impact test specimens did not provide reasonable assurance the pipe base material possessed the minimum required fracture toughness to prevent potential brittle fracture.
Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Specifically, the inspectors answered "no" to the question in Exhibit 3.B. The licensee re-performed the Charpy V-Notch testing with specimens that conformed to the requirements. The results of this testing provided reasonable assurance the minimum material fracture toughness requirements were satisfied such that the replaced piping material would perform its required safety functions.
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, licensee individuals did not thoroughly review contractor's test plan and results, but instead, relied on contractor expertise and past successes perceived as satisfactory.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services, requires, in part, that measures be established to assure purchased material, equipment, and services purchased through contractors conform to the procurement documents.
Contrary to the above, on November 23, 2022, the licensee failed to assure purchased material, equipment, and services conformed to the procurement documents. Specifically, the licensees PO 1366400, Revision 3, specified ASME Section III, 1974 Edition, no addenda, as the code of record to which the impact test requirements were to be satisfied. The licensee elected Charpy V-Notch as the method to perform the impact test. ASME Section III, 1974 Edition, Paragraph NB-2321.2, Charpy V-Notch Tests, requires, in part, that a test consists of a set of three full-size 10 x 10 mm specimens. However, the Charpy V-Notch test was conducted using a set of three 5 x 10 mm subsize specimens.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Secure Category 2 Quantity of Radioactive Material not Under Direct Control and Constant Surveillance Cornerstone Significance Cross-Cutting Aspect Report Section Public Radiation Safety Green NCV 05000374,05000373/2023001-02 Open/Closed
[H.12] - Avoid Complacency 71124.01 The inspectors reviewed a self-revealed Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 37.53 when the licensee failed to physically secure a mobile device containing category 2 levels of radioactive material.
Description:
To comply with 10 CFR 37.53, licensees that possess mobile devices containing category 1 or category 2 quantities of radioactive material must have two independent physical controls that form tangible barriers to secure the material from unauthorized removal when the device is not under direct control and constant surveillance by the licensee. For nuclear power plants, the established protected area boundary satisfies the requirement for one of the independent physical controls. The other physical control could take the form of a locked cage or room, a wheel lock, physical restraint of the device, or other means that are not easily defeated to disable the mobile device.
On October 17, 2022, the locking mechanism intended to render the device immobile was discovered to be deficient before starting the annual calibration of their Model 89 gamma calibrator. This condition would not have prevented the unauthorized movement or diversion.
Specifically, a chain was wrapped around the frame of the calibrator, so it appeared secure, but the padlock necessary for securing the chain was found unlocked by a technician supporting the annual calibration.
The device was secured upon discovery and Action request (AR) 4530043 was written to document the condition in the corrective action program. The cause of the issue of concern was reasonably within the licensees ability to foresee and correct and should have been prevented.
Corrective Actions: The licensee secured the mobile device via a chain and lock.
Corrective Action References: AR 4530043, "Shepherd Calibrator Unsecured"
Performance Assessment:
Performance Deficiency: The licensee failed to physically secure a mobile device containing category 2 levels of radioactive material as required by 10 CFR 37.53.
Screening: The inspectors determined the performance deficiency was more than minor because it could reasonably be viewed as a precursor to a significant event. Specifically, the failure to secure the padlock on the chain to immobilize the radioactive material diminished assurance that the security of category 2 quantities of radioactive material was protected from theft or diversion.
Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609 Appendix D, Public Radiation Safety SDP. The inspectors determined that there was not an actual loss of material, access was not granted to an individual who was not trustworthy and reliable, and there was not an ineffective security zone. However, inspectors did determine there was a deficient security zone and therefore this finding is of very low safety significance (Green).
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, the licensee's existing processes and human performance tools were not effective to ensure the mobile device was physically secured.
Enforcement:
Violation: Title 10 CFR 37.53 requires in part that each licensee that possesses mobile devices containing category 1 or category 2 quantities of radioactive material must have two independent physical controls that form tangible barriers to secure the material from unauthorized removal when the device is not under direct control and constant surveillance by the licensee. The licensee utilized the protected area boundary and a locking mechanism on the mobile device to provide the two independent physical controls.
Contrary to the above, on October 17, 2022, a mobile device containing category 2 quantities of radioactive material was found not to have two independent physical controls to form tangible barriers to secure the material from unauthorized removal, and the device was not under direct control and constant surveillance by the licensee. Specifically, the required lock to ensure physical control of the device was attached in such a way that the device was not physically secured and was mobile.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Review of Source Term Reduction Actions 71152A In 2021, the licensee failed to survey to ensure occupational doses were as low as reasonably achievable (ALARA). This was documented in NRC Integrated Inspection Report 05000373/2021003; 05000374/2021003 and 07200070/2021001. The licensee evaluated this issue in Root Cause Evaluation (RCE) Report 4417704.
The inspectors reviewed RCE 4417704 to ensure that the licensee identified corrective actions commensurate with the significance of the identified issues. This evaluation determined the root cause was an increased source term due to cobalt intrusion into the reactor vessel and ancillary systems from foreign material originating from degraded reactor recirculation flow control valves. A contributing cause was determined to be the station did not evaluate or fully understand the consequences to material conditions, plant source term and Collective Radiation Exposure from identified foreign material. The licensee developed multiple corrective actions including Implementing a mitigation strategy for cobalt intrusion to reactor vessel (CAPR 4417704-15), performing high efficiency - ultrasonic fuel cleaning (HE-UFC), and bottom nozzle cleaning to recover foreign material from reactor vessel (CA 4417704-17).
The inspectors also observed the conduct of multiple jobs during the subsequent refueling outage (L2R19) that the licensee characterized as high radiological risk to evaluate how the actions were implemented. These jobs included:
- Control rod drive exchange
- 2B33-F067A repairs/inspections
- Bottom head drain cut out/replace
- 2G33-F001 valve work activities
- Chemical decontamination
- High efficiency ultrasonic fuel cleaning The licensee developed a comprehensive plan, including multiple examples of first use technologies, for removing cobalt from multiple locations at LaSalle Unit 2. The inspectors observed a high level of support (resources, time, and full-scale mock-ups) to complete the large number of activities to reduce source term needed to lower occupational doses. In general, the technicians performing the work and the radiation protection technicians covering the work activities appeared to understand the tasks to be completed, knowledgeable of the radiological hazards present in the work area and engaged in the work activities.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On April 12, 2023, the inspectors presented the integrated inspection results to John VanFleet, acting Site Vice President, and other members of the licensee staff.
On March 8, 2023, the inspectors presented the radiation protection inspection results to Deb McBreen, Organizational Performance and Regulatory Director, and other members of the licensee staff.
On March 16, 2023, the inspectors presented the inservice inspection results to Phil Hansett, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
NRC-Identified Fire Door Issue
2/21/2023
Procedures
OP-DG-01
Preparation for Standby Operations of Diesel Generators
Foreign Material Found in JP 15 (GE INR L2R18 IVVI-21-01)
2/25/2021
Corrective Action
Documents
L2R19 IVVI Scope Change
01/12/2023
NRC Identified - NRC Questioned Weld Procedure
Specification
2/15/2023
NRC Identified Open Task in WO from L2R18
2/15/2023
Corrective Action
Documents
Resulting from
Inspection
NRC ID Vendor Charpy Test on the Incorrect Specimen Six
03/10/2023
1366400
Purchase Order
2974
ASME Section XI Repair/Replacement Plan for
11/04/2022
2975
ASME Section XI Repair/Replacement Plan for
08/30/2022
2991
ASME Section XI Repair/Replacement Plan for
11/22/2022
LTI Order No.
CO22034975
Laboratory Report for Charpy V-Notch Impact Testing
11/02/2022
LTI Order No.
CO23008515
Laboratory Report for Charpy V-Notch Impact Testing
03/15/2023
PQR No. 1-50C
Procedure Qualification Record ASME Section IX
01/03/1984
PQR No. A-001
Procedure Qualification Record ASME Section IX
10/19/1998
PQR No. A-002
Procedure Qualification Record ASME Section IX
03/09/1999
PQR No. W-
2009-001
ASME Welding Procedure Qualification Record
08/25/2009
Miscellaneous
PQR No. W-
2009-002
ASME Welding Procedure Qualification Record
08/25/2009
23-090
TOPAZ Encoded Phased Array Examination for Component
ID 2RT01B-6 FW-17 R1
03/12/2023
23-092
TOPAZ Encoded Phased Array Examination for Component
ID 2RR28B-3 FW-1 R3
03/10/2023
TOPAZ Encoded Phased Array Examination for Component
03/11/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ID 2RH03CB-12 FW-1 R1
23-094
TOPAZ Encoded Phased Array Examination for Component
ID 2RH03CB-12 FW-2 R1
03/14/2023
23-200
TOPAZ Encoded Phased Array Examination for Component
ID 2RR28A-2 FW-7
03/10/2023
MT Report for Component ID FW02-2851S
2/22/2023
UT Report for Component ID IRH-2005-29
2/19/2023
UT Report for Component ID IRH-2005-28
2/19/2023
UT Report for Component ID 2-NIR-N10A
2/22/2023
No. 1
Radiographic Examination Interpretation Report for
WO 05237886-18, Weld No. 1, 2, 3, and 4
2/21/2023
Magnetic Particle (MT) Examination
GEH-PDI-UT-2
PDI Generic Procedure for the Ultrasonic Examination of
Austenitic Pipe Welds
GEH-UT-257
Procedure for Ultrasonic Examination in Lieu of Radiography
for Welds in Ferritic or Austenitic Pipe Section XI, Division 1
GEH-UT-311
Procedure for Manual Ultrasonic Examination of Nozzle
Inner Radius, Bore, and Selected Nozzle to Vessel Regions
WPS 1-1-GT-
PWHT-IQ2
ASME Welding Procedure Specification Record
Procedures
WPS 1-1-GTSM-
ASME Welding Procedure Specification Record
Work Orders
Disassemble/Inspect/Reassemble 2B33-F060B
04/16/2021
Receipt of Part 21 for 480 V FRV Contactors
04/11/2022
2E12-F009 Valve Took Multiple Attempts to Open
2/13/2023
Corrective Action
Documents
L2R19 Add for Eaton Breaker Mechanical Interlock
Replacement
2/18/2023
Engineering
Changes
Upgrade Eaton Bucket Contactor Mechanical Interlock
from Rev. 1 to Rev 3.
LAS-0-2-2023-
0041
ODM - Eaton Contractor Binding
Miscellaneous
LAS-0-2022-0030
Eaton FVR Contactor
Miscellaneous
L2R19 SDS
Unit 2 L2R19 Refueling Outage Shutdown Safety Plant
Procedures
LEP-DC-113
Installation and Removal of Temporary Battery Chargers
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
OU-LA-104
Shutdown Safety Management Program
AR 4515624515621A DG Speed Control Governor not Responding
01/31/2023
U1 Div 2 Ground Caused by 1A DG Speed Control Switch
01/30/2023
Corrective Action
Documents
U1 Div 2 Ground During LOS-DG-M2, 1A DG Run
01/31/2023
Engineering
Changes
Seismic Evaluation of the LaSalle Unit 2 Bottom
Head Drain Plug
Calculations
Alternate Decay Heat Removal (ADHR) System Qual
for L2R19 Outage
Alternate Decay Heat Removal (ADHR) System Qual
for L2R19 Outage
Engineering
Changes
L2R19 Decay Heat and Related Computations
Miscellaneous
L2R19 SDS Plan
L2R19 Shutdown Safety Plan
Procedures
LOP-WIC-01
Reactor Pressure Vessel Water Inventory Control
Corrective Action
Documents
2B RHR Partition Plate Condition
2/19/2023
Engineering
Changes
Evaluation of Unit 2B RHR Heat Exchanger Thermal
Performance Data Using Alternate (ERPI) Methodology
LOS-HP-08
HPCS System Full Flow Test
01/26/2023
2A DG Cooling Water System Flow Balance
2/22/2023
Verify Performance of 2DG01P per LOS-DG-Q2
2/22/2023
U-2 GROUP 4 I/B Isol Act Logic Sys Func Test
03/01/2023
LOS-HP-Q4 ATT A, U1 HPCS SYSTEM
01/26/2023
LOS-HP-Q1 U2 HPCS ATT 2A
2/21/2023
LOS-DG-M3 2B DG IDLE START ATT 2B-IDLE
01/23/2023
Work Orders
LRA LOS-DG-M3 1B DG IDLE START ATT 1B-IDLE
01/26/2023
Miscellaneous
LaSalle 1Q23
PI Drill Report
LaSalle 1Q23 PI Drill Report
2/03/2023
Shepherd Calibrator Unsecured
10/17/2022
Main Access Facility Portal Monitor Alarm Response
2/17/2023
Corrective Action
Documents
Higher Than Anticipated Airborne Activity in U2 Drywell
2/24/2023
Miscellaneous
23 Electronic
Dosimeter Alarm
Log
Listing of all Electronic Dosimeter Alarms for
2/13/23 - 02/20/23
2/21/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
L2R19 SAC #2
Station ALARA Committee Meeting Notes
2/19/2023
L2R19 SAC #3
Station ALARA Committee Meeting Notes
2/20/2023
Procedures
CFR PART 37 Material Accountability Program
23-186741
740' Drywell Bottom Head Drain Shielding Survey
2/16/2023
23-186881
740' Drywell Bottom Head Drain Cut Out Survey
2/18/2023
23-186893
Drywell 740' Elevation
2/18/2023
Radiation
Surveys
23-186922
740' Drywell General Area
2/18/2023
LA-02-23-00513
L2R19 DW Control Rod Drive (CRD) Exchange
LA-02-23-00548
L2R19 DW 2B33-F067A Repairs/Inspections
LA-02-23-00551
L2R19 DW RWCU 2G33-F001 Valve Work Activities
LA-2-23-00544
L2R19 DW Bottom Head Drain Cut Out/Replace
Radiation Work
Permits (RWPs)
LA002-23-00414
L2R19 RB/DW Chem Decon Project
Corrective Action
Documents
Resulting from
Inspection
Collected Samples Not Taken to Chemistry for Analysis
2/23/2023
Engineering
Evaluations
RWP:
LA-02-23-00513
Multiple Dosimetry EDE Evaluation Sheet for
Control Rod Drive Exchange
2/07/2023
Miscellaneous
Multiple
Dosimetry Issue
Log for Work on
Multiple Dosimetry Issue Log for Use of EDEX from
2/18/2023 - 02/21/2023 for RWP 548-02
2/18/2023
Unit 1 Initiating
Events Report
Unit 1 Initiating Events Report
01/23/2022
71151
Miscellaneous
Unit 2 Initiating
Events Report
Unit 2 Initiating Events Report
01/24/2023
Corrective Action
Documents
Root Cause Investigation Report - Elevated Collective
Radiation Exposure on Unit 2 Resulting in a Total Outage
Dose of 664.718 Rem on an Original L2R18 Business Plan
Dose Goal of 235 Rem.
06/17/2021
Miscellaneous
LAS-1-2022-0250
Risk Assessment - 1B DG Lockout Trip
2/21/2022