IR 05000373/2023002
| ML23213A046 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 08/01/2023 |
| From: | Robert Ruiz NRC/RGN-III/DORS/RPB3 |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2023002 | |
| Download: ML23213A046 (1) | |
Text
SUBJECT:
LASALLE COUNTY STATION - INTEGRATED INSPECTION REPORT 05000373/2023002 AND 05000374/2023002
Dear David Rhoades:
On June 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at LaSalle County Station. On July 11, 2023, the NRC inspectors discussed the results of this inspection with John VanFleet, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
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, 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:
05000373/2023002 and 05000374/2023002
Enterprise Identifier:
I-2023-002-0055
Licensee:
Constellation Nuclear
Facility:
LaSalle County Station
Location:
Marseilles, IL
Inspection Dates:
April 01, 2023 to June 30, 2023
Inspectors:
J. Benjamin, Senior Resident Inspector
J. Cassidy, Senior Health Physicist
N. Shah, Senior Project Engineer
P. Smagacz, Senior Resident Inspector (acting)
J. Steffes, Senior Resident Inspector
A. Tran, Resident Inspector (acting)
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
No findings or violations of more than minor significance were identified.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000373,05000374/
2023002-01 Clarification of the Dew Point Specification for the MSA Firehawk M7 SCBA System 71124.03 Open
PLANT STATUS
Unit 1 Unit 1 began the inspection period at rated thermal power. On April 30, 2023, the unit was down powered to approximately 40 percent for testing and the unit was subsequently returned to full-rated thermal power. With the exception of other minor power reductions for rod pattern adjustments and turbine and control valve testing, Unit 1 operated at or near rated thermal power for the remainder of the inspection period.
Unit 2 With the exception of minor power reductions for rod pattern adjustments and turbine and control valve testing, Unit 2 operated at or near rated thermal power for the entire 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
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated site readiness for seasonal extreme weather conditions prior to the onset of seasonal high temperatures of summer for the ultimate heat sink and service water May 30 through June 2, 2023.
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather, including thunderstorms and high winds, on April 4, 2023.
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 3 emergency diesel generator following technical surveillance test on April 24, 2023
- (2) Unit 1 division 1 diesel cooling water pump following planned maintenance on May 10, 2023
- (3) Unit 2 division 2 emergency diesel generator following surveillance test on May 10, 2023
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (7 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 8C5, diesel building, elevation 674-0", Unit 2 division 1 residual heat removal (RHR) service water pump room
- (2) Fire Zone 4A, auxiliary building, elevation 815'-0", upper ventilation equipment floor
- (3) Fire Zone 4E4, auxiliary building, elevation 731'-0", Unit 2 division 2 essential switchgear room
- (4) Fire Zone 4E1, auxiliary building reactor building, elevation 731'-0", Unit 1 auxiliary equipment room
- (5) Fire Zone 4F1, auxiliary building, elevation 710'-0", Unit 1 division 1 essential switchgear room
- (6) Fire Zone 4F2, auxiliary building, elevation 710'-0", Unit 2 divisional 1 essential switchgear room
- (7) Fire Zone Area 1, reactor building, elevation 843'-6", Unit 1 and Unit 2 refuel floor
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated internal flooding mitigation protections in the Units 1 and 2 core standby cooling system pump rooms.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operators in the simulator on June 27, 2023.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 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) Planned Action Green risk associated with 'B' and 'C' RHR pumps out of service April 12-13, 2023
- (2) Green risk condition, Unit 1 low-pressure core spray inoperable but available (Action Request [AR] 4670636, "Min Flow Valve Issue")
- (3) Planned Action Green risk, Unit 2 division 3 unavailability due to battery replacement on April 26, 2023
- (4) Planned Action Green risk, common diesel cooling water pump maintenance on May 8, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)scram discharge volume level calibration
- (2) AR 4671649, "2DC18E Unit 2 Division 3 Battery 24 Cracked on Top"
- (3) AR 4561332, "RM-Control Rod Drive Hydraulic Temperature High Alarm"
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) (1 Sample)
- (1) Unit 2 reactor core isolation cooling post-maintenance testing after breaker and EG-R maintenance on June 3, 2023
Surveillance Testing (IP Section 03.01) (1 Sample)
- (1) Unit 1 1B RHR pump testing on April 18, 2023
Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)
- (1) Work Order 4788817, "RCIC [reactor core isolation cooling] Turbine Exhaust Vacuum Breakers Isolation Valves Local Leak Rate Test"
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (2 Samples)
The inspectors evaluated:
(1)emergency preparedness drill in the control room simulator on June 13, 2023 (2)emergency preparedness drill on May 30,
RADIATION SAFETY
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (1 Sample)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
(1)standby gas treatment - Unit 2
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.
71124.04 - Occupational Dose Assessment
Internal Dosimetry (IP Section 03.03) (1 Sample)
The inspectors evaluated the following internal dose assessments:
- (1) internal dose assessment on radiation work permit 549, task 4 from April 6, 2021
Special Dosimetric Situations (IP Section 03.04) (1 Sample)
The inspectors evaluated the following special dosimetric situations:
- (1) declared pregnant worker - EID 121074, July 22,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===
- (1) Unit 1 (October 1, 2022, through March 31, 2023)
- (2) Unit 2 (October 1, 2022, through March 31, 2023)
BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)
- (1) Unit 1 (April 1, 2022, through March 31, 2023)
- (2) Unit 2 (April 1, 2022, through March 31, 2023)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) October 1, 2022, through March 31, 2023 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) October 1, 2022, through March 31,
INSPECTION RESULTS
Unresolved Item (Open)
Clarification of the Dew Point Specification for the MSA Firehawk M7 SCBA System URI 05000373,05000374/2023002-01 71124.03
Description:
In Subpart H of 10 CFR Part 20, the NRC established oversight of respiratory protection programs used for radiation protection purposes by NRC licensees. Nuclear Regulatory Commission regulations require that NRC licensees use NIOSH approved equipment in their respiratory protection programs, or that they obtain approval from the USNRC to use equipment that has not been approved by NIOSH. NIOSH regulations and guidance state that user instructions are included as part of the NIOSH approval.
The inspectors identified that the FireHawk M7 cylinders were filled with Grade D air with a dew point of -50 ºF. Upon review of the user instructions that pertain to the FireHawk M7 SCBA system, the inspectors identified several inconsistencies regarding the specification that applies to dew point. In general, the user instructions direct users to use Grade D quality air, as defined by the Compressed Gas Association, Commodity Specification for Air, (or better); however, in certain locations a further specification is added that the dew point of the supplied air be -65 ºF.
The specification of a dew point value in the user instructions that differs from the dew point guidance that applies to Grade D air implies that it is an additional restriction that is required to satisfy the NIOSH certification requirements that pertain to the equipment. However, the licensee has obtained guidance from an MSA sales representative that supplied air with a dew point of -50 ºF is of sufficient quality to operate the FireHawk M7 SCBA in accordance with the NIOSH approval (the -50 ºF dew point would align with the guidance that applies to Grade D air). This is problematic because vendors are not allowed to authorize use of their equipment outside of the bounds of the NIOSH approval. At this point, it is not clear if the NIOSH approval is contingent upon the dew point guidance that applies to Grade D air, or a dew point of -65 ºF. It does not appear that there is an immediate safety concern with the continued use of these SCBAs based on their environment of use. However, continued long-term use without clarification of this issue does not seem tenable because the user instructions are not clear on the specifications that apply to certified safe use of the equipment and might be in violation of NRC regulations for the use of respiratory protection.
Planned Closure Actions: NRC Program office (NRR/DRA/ARCB) will work with the FireHawk M7 vendor, MSA, and, potentially, NIOSH to clarify the dew point requirement for the FireHawk M7 SCBA system and assess the impact of the differing air quality descriptions in the user instructions for the FireHawk M7 SCBA system on compliance with NRC requirements.
Licensee Actions: No action is required at this time.
Corrective Action References: AR
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On July 11, 2023, the inspectors presented the integrated inspection results to John VanFleet, Site Vice President, and other members of the licensee staff.
On June 23, 2023, the inspectors presented the radiation protection inspection results to John VanFleet, Site Vice President, and other members of the licensee staff.
THIRD PARTY REVIEWS Inspectors reviewed the WANO Peer Review Report dated December 2022.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Certification of 2023 Summer Readiness
05/15/2023
Procedures
LOA-TORN-001
High Winds/Tornado
Fire Plans
FZ AREA 1
RX BLDG 843'-6" Elev. U1 & U2 Refuel Floor
Corrective Action
Documents
2DT02PA Sump Pump Trips When Started
05/21/2017
Procedures
LOA-FLD-001
Operating Abnormal Operating Procedure: Flooding
Perform Inspection of Magnetrol for the RHR A&B Service
07/06/2022
Perform Inspection of Magnetrol for the RHR C&D Service
07/11/2022
EWP-Unit 2 ECS/CSCS Watertight Doors
01/26/2023
Work Orders
EWP-Op Unit 1 ECCS/CSCS Watertight Doors
04/12/2023
Miscellaneous
23 OBE 3
LaSalle County Station LORT Dynamic Simulator Scenario
Guide
06/14/2023
LTS-1100-4 Revision Needed for GE SIL 173 Supplement 1,
Revision 1
04/18/2010
RM-U2 Rod 38-39 Temperature Monitoring
04/06/2023
Corrective Action
Documents
AR 515420515420Lessons Learned for Actions on High Temp CRDMs
08/01/2006
Electrical Evaluation
Division 3 Battery 2DC18E Cell 56 Cover Crack Impact on
Ability of Cell to Perform Its Design Function
09/06/2005
Engineering
Changes
Nuclear Fuels Recommendations to Address the Issue
Identified in GE SIL 173 for LaSalle Units 1 and 2
10/18/2006
Miscellaneous
GE Service
Information Letter
(SIL) 173
Control Rod Drive High Operating Temperature
03/28/1976
Operability
Evaluations03-004
1DC18E and 2DC18E Surface Cracks
LIP-GM-902
General Requirements for Performance of Instrument
Maintenance Department Procedures
LOR-2H13-P603-
A403
Control Rod Hydraulic Temperature High
LOS-RD-SR12
Scram Insertion Times (Notes on Page 12 of Procedure)
Procedures
WO-AA-120-F-01
Monday Shift 1 Review/Submit NSO CR Rounds
04/30/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
IM LIS-RD-103 U1 Control Rod Drive Scram Discharge
Level Calibration
11/10/2022
EWP: Replace 2DC06E-5C Cubicle Components
05/31/2023
RCIC Turbine Lube Oil Filter Diff Press
06/03/2023
2/17/2023
Work Orders
OP RCIC Operability LOS-RI-R4 Att 2A (2E51-F030)
06/03/2023
Miscellaneous
LaSalle 2Q2023
Drill Guide
LaSalle 2Q2023 Drill Guide
06/13/2023
Corrective Action
Documents
Resulting from
Inspection
NRC ID: URI for SCBA Dewpoint Issue
06/22/2023
RP-LA-826 Pneumatic/Air Systems Quality Surveillance
Records
various
FireHawk M7 Air
Mask, 4500 PR14
S/N: LAB270746
Posi3 USB Test Results
05/01/2023
FireHawk M7 Air
Mask, 4500 PR14
S/N: LAB270746
Posi3 USB Test Results
05/10/2022
PremAire Cadet
Escape 3000
S/N: PAC300055
Posi3 USB Test Results
05/09/2022
Miscellaneous
PremAire Cadet
Escape 3000
S/N: PAC300055
Posi3 USB Test Results
05/02/2023
Procedures
RP-LA-826
Pneumatic/Air System Quarterly Surveillance
IM EWP-2VG016 SBGT Train Upstream HEPA Filter D/P
Loop Cal
03/15/2022
EM LES-VG-01 U-2 SBGT Duct Heater
06/16/2021
LRA Standby Gas Treatment Charcoal Filter Leak Test
10/13/2022
Work Orders
Standby Gas Treatment HEPA Filter Test
10/13/2022
Corrective Action
Documents
Region 3 NRC Inspector Observations
06/21/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Resulting from
Inspection
EID 121074
Prenatal Radiation Exposure Package
04/19/2022
Miscellaneous
EID/SSN 8108
Intake Investigation Package
04/13/2021
Dosimetry Issue, Usage, and Control
Prenatal Radiation Exposure
Procedures
Access Controls during Drywell Power Entries
CY-AA-130-3010-
F-01
Unit 1 Dose Equivalent Iodine Determination
various
CY-AA-130-3010-
F-01
Unit 2 Dose Equivalent Iodine Determination
various
Monthly Data Elements for NRC ROP RETS/ODCM
Radiological Effluent Occurrences
various
Miscellaneous
LS-AA02140,
Monthly Data Elements for NRC Performance Indicator
Occupational Exposure Control Effectiveness
various
Monthly Data Elements for NRC ROP Indicator - Reactor
Coolant System (RCS) Leakage
71151
Procedures
Monthly Data Elements for NRC ROP RETS/ODCM
Radiological Effluent Occurrences
7