IR 05000373/2024010
| ML24150A143 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 05/29/2024 |
| From: | Sanchez Santiago E NRC/RGN-III/DORS/EB1 |
| To: | Rhoades D Constellation Energy Generation |
| References | |
| IR 2024010 | |
| Download: ML24150A143 (1) | |
Text
SUBJECT:
LASALLE COUNTY STATION - COMMERCIAL GRADE DEDICATION INSPECTION REPORT 05000373/2024010 AND 05000374/2024010
Dear David P. Rhoades:
On May 3, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at LaSalle County Station and discussed the results of this inspection with John Van Fleet, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation 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 29, 2024 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, Elba M. Sanchez Santiago, Acting Branch Chief Engineering 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:
05000373/2024010 and 05000374/2024010
Enterprise Identifier:
I-2024-010-0040
Licensee:
Constellation Nuclear
Facility:
LaSalle County Station
Location:
Marseilles, IL
Inspection Dates:
April 15, 2024 to May 03, 2024
Inspectors:
M. Gangewere, Reactor Inspector
B. Jose, Senior Reactor Inspector
C. Padilla, Reactor Inspector
L. Rodriguez, Senior Reactor Inspector
Approved By:
Elba M. Sanchez Santiago, Acting Branch Chief
Engineering Branch 1
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a commercial grade dedication 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 Establish Acceptance Criteria for ECCS Service Water Strainer Inspections Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000373,05000374/2024010-01 Open/Closed
[H.6] - Design Margins 71111.21N.
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) Part 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to include appropriate acceptance criteria in a procedure to determine important activities had been satisfactorily accomplished. Specifically, the licensee failed to include appropriate quantitative or qualitative acceptance criteria in Procedure LMP-GM-25, Revision 13,
Emergency Core Cooling System (ECCS) Service Water Strainer Maintenance, for performing ECCS service water strainer inspections.
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.
REACTOR SAFETY
===71111.21N.03 - Commercial Grade Dedication The inspectors reviewed the implementation of the licensees process for dedicating commercial-grade items (CGI) as basic components and for procuring safety-related (SR)components for the following samples:
Commercial Grade Dedication===
- (1) Catalog ID 23348-2; 150 Ohm, 225 Watt, Wire Wound Resistor (CGI Dedication)
- (2) Catalog ID 39467-2; 5 Micro Farad, 660 Volt Alternating Current (Vac) Capacitor (CGI Dedication)
- (3) Catalog ID 41719-2; Reverse 800 Volt (V), 100 Ampere Rectifier/Diode (CGI Dedication)
- (4) Catalog ID 42457-2; Temperature Element Assembly (CGI Dedication)
- (5) Catalog ID 43405-2; Room Temperature Vulcanizing (RTV) 734 Sealant/Adhesive (CGI Dedication)
- (6) Catalog ID 44315-2; Ceramalloy CL+ Repair Compound (CGI Dedication)
- (7) Catalog ID 45136-2; Relief Check Valve (CGI Dedication)
- (8) Catalog ID 687201-2; Poro-Edge Tube (CGI Dedication)
- (9) Catalog ID 1419122-2; Diesel Fuel (CGI Dedication)
- (10) Catalog ID 1705923-2; Mobilgard 410 Lubricant Oil (CGI Dedication)
- (11) Catalog ID 1824208-2; Male Connector (CGI Dedication)
- (12) Catalog ID 8175-1; Explosive Valve Replacement Kit for the Standby Liquid Control (SBLC) System (SR Procurement)
- (13) Catalog ID 47462-1; Heat Exchanger Channel End (SR Procurement)
- (14) Catalog ID 1438384-1; Starter Motor for Emergency Diesel Engine (SR Procurement)
INSPECTION RESULTS
Failure to Establish Acceptance Criteria for ECCS Service Water Strainer Inspections Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000373,05000374/2024010-01 Open/Closed
[H.6] - Design Margins 71111.21N.0 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) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to include appropriate acceptance criteria in a procedure to determine important activities had been satisfactorily accomplished. Specifically, the licensee failed to include appropriate quantitative or qualitative acceptance criteria in Procedure LMP-GM-25, Revision 13, Emergency Core Cooling System (ECCS) Service Water Strainer Maintenance, for performing ECCS service water strainer inspections.
Description:
LaSalle County Power Station had residual heat removal (RHR) service water (SW) strainers in the core standby cooling system-equipment cooling water systems (CSCS-ECWS).
Updated final safety analysis report (UFSAR) section 9.2.1 described the function of the CSCS-ECWS to circulate lake water from the ultimate heat sink for cooling of the RHR heat exchangers and diesel-generator coolers. Section 9.2.1.1.1.d stated, in part, Strainers are provided to prevent plugging of cooled component heat transfer passages. Additionally, section 9.2.1.2 paragraph 10 stated, in part, An automatic backwashing strainer is installed in the discharge line of each diesel-generator cooling water pump and each pair of RHR service water pumps The strainers have stainless steel edge type strainer baskets with a 1/16-inch particle retention capability.
The inspectors reviewed the commercial grade dedication of the strainer basket Poro-Edge tubes (Catalog ID 687201-2) performed under Procurement Evaluation (PE) 20773. The strainer tubes filtered and collected undesirable particulates in the SW (raw water) systems to prevent plugging of downstream components and to ensure adequate flow was maintained.
Since the PE referenced maintenance procedure LMP-GM-25, the inspectors requested the last completed work order (WO) of the procedure. The inspectors reviewed safety-related WO 1039029, LR - Replace or Overhaul Strainer (See Scope), which stated the work scope was to overhaul the 2B RHR SW strainer (2E12-D300B). The WO included step E.3.1.1 of LMP-GM-25, which required an examination of the strainer tube assembly and completion of B, ECCS Service Water Strainer Inspection Report.
The inspectors noted Action Request (AR) 4522159 was initiated for abbreviated maintenance of the strainer due to severe corrosion buildup which did not allow the tubes to be removed as required for inspection and cleaning. However, the WO was marked as satisfactory (SAT) and the as-found and as-left surveillance/preventative maintenance were marked as being within acceptance criteria. The inspectors questioned what acceptance criteria was used to determine the SAT results. The inspectors also noted LMP-GM-25, step E.3.1.1 was marked SAT for the tube assembly examination and completion of Attachment B.
However, the inspectors could not identify what acceptance criteria was used to draw this conclusion. The inspectors interviewed licensee personnel and concluded there was no quantitative or qualitative acceptance criteria established to determine whether the inspection results were SAT or UNSAT.
The inspectors also reviewed WO 1598755, LRA Overhaul Strainer 2DG01F, which performed a similar inspection of the 2A diesel-generator cooling water (DGCW) strainer.
This WO was marked complete with portions UNSAT and step E.3.1.1 was marked UNSAT due to degradation of the strainer. The 2A DGCW strainer was replaced due to the UNSAT conditions. Therefore, the inspectors concluded the lack of acceptance criteria led to inconsistent determinations of SAT and UNSAT for similar ECCS strainer inspection results.
Corrective Actions: The licensee entered this issue into their corrective action program and planned to establish qualitative or quantitative acceptance criteria for Procedure LMP-GM-25.
In addition, the site planned to change completion of WO 1039029-01 for the 2B RHR SW Strainer from Complete SAT - Credit predefine to Complete with portions UNSAT - Credit predefine. The licensee determined the strainer was still capable of performing its safety function and planned to replace the strainer in 2025.
Corrective Action References: AR 4770807, NRC ID: Recommended Changes to WO 01039029-01
Performance Assessment:
Performance Deficiency: The licensees failure to include appropriate acceptance criteria in procedure LMP-GM-25 for performing ECCS service water strainer inspections was contrary to 10 CFR 50 Appendix B, Criterion V, Instructions, Procedures, and Drawings, and was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to establish appropriate acceptance criteria for ECCS service water strainer inspections did not ensure the strainers would remain capable of performing their safety functions until their next scheduled inspections.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the finding was of very low safety significance (Green) because they answered No to all the questions in exhibit 2, Mitigating Systems Screening Questions.
Cross-Cutting Aspect: H.6 - Design Margins: The organization operates and maintains equipment within design margins. Margins are carefully guarded and changed only through a systematic and rigorous process. Special attention is placed on maintaining fission product barriers, defense-in-depth, and safety related equipment. Specifically, the licensee failed to guard the ECCS SW strainer design margins when performing inspections to ensure the as left condition of the strainers would continue to support their operability until their next scheduled inspections.
Enforcement:
Violation: Title 10 CFR 50 Appendix B, Criterion V, Instructions, Procedures, and Drawings requires, in part, that activities affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and be accomplished in accordance with those instructions, procedures, or drawings. In addition, it requires that those instructions, procedures, or drawings include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
The licensee established LMP-GM-25, Revision 13, Emergency Core Cooling System (ECCS) Service Water Strainer Maintenance, as the implementing procedure for ECCS service water strainer inspections, an activity affecting quality.
Contrary to the above, as of May 3, 2024, the licensee failed to include appropriate quantitative or qualitative acceptance criteria in a procedure for an activity affecting quality to determine that important activities had been satisfactorily accomplished. Specifically, the licensee failed to include appropriate acceptance criteria in procedure LMP-GM-25, Revision 13, to determine ECCS service water strainer inspections were satisfactorily accomplished.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On May 3, 2024, the inspectors presented the commercial grade dedication inspection results to John Van Fleet, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
Add Seismic and Function Qualification of ESI EDG Starter
Motor Assembly Review via Parts Engineering IEE for
CID 1438384-1
03/15/2016
22159
Abbreviated Maintenance 2B RHR Strainer
09/13/2022
22453
Replace 2B RHR-WS Strainer End Cover
09/14/2022
Corrective Action
Documents
21626
CRD Charging Nipple Parts Eval Required Actions
2/05/2023
4767379
DG Air Dryer Alarm
04/18/2024
4767522
NRC ID - Responses Required During Walkdown
04/18/2024
4769832
NRC IDd: SQUIB Valve Kit Storage Requirements
04/26/2024
4770807
NRC ID: Recommended Changes to WO 01039029-01
04/30/2024
4770817
NRC Identified: Enhancement to CC-AA-320-2006
04/30/2024
4770844
NRC ID: Procurement Engineering Evaluation Admin Errors
04/30/2024
4771124
Procedure Not Updated and IR Not Closed Properly
05/01/2024
4771135
NRC Identified: Undocumented Justification for Storage
Level
05/01/2024
Corrective Action
Documents
Resulting from
Inspection
4771577
NRC ID - Controls for Issued Materials
05/02/2024
Drawings
B51266
Return End Channel - Model RB1807-2521 S&T Heat
Exchanger
Engineering
Changes
2108
Design Engineering Review of ESI Functional Qualification
Report 124245-QR-1 and Seismic Report SR-08-01 for
DG Air Start Motors, CID 1438384-1
06/28/2016
L-1997-0121-000
SI#819D23, Heat Exchanger Channel
L-93-003-0127
LaSalle County Parts Group Evaluation Instruction Sheet:
All Service Water Strainer Parts
10/16/1992
M-1993-663-1
Strainer, Adams, Spare Parts
and 1
M-1994-677-3
Belzona Epoxy - Hardcopy
M-1995-228-1
Relief Check Valve, SI#815C32
and 1
M-1997-784-01
Heat Exchanger Channel
M-92-04-0832-00
Commercial Grade Dedication Evaluation (CGDE) for
Reverse 800 V, 100 Ampere Rectifier/Diode
71111.21N.03
Engineering
Evaluations
M-93-0874-02
Dow Corning RTV 734
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
PE 18526
Procurement Evaluation for Heat Exchanger Channel
End - Catalog ID: 47108-2
08/13/2002
PE 20773
Procurement Evaluation for Poro-Edge Tube - Catalog
ID: 687201-2
01/13/2003
PE 250584
Procurement Evaluation for Temperature Element
Assembly - Catalog ID: 42457-2
07/15/2020
PE 257722
Procurement Evaluation for Mobilgard 410 Oil
Lubricant - Catalog ID: 1705923-2
2/23/2022
PE 265044
Procurement Evaluation for Diesel Fuel - Catalog
ID: 1419122-2
10/11/2021
PE 272228
Procurement Evaluation for Male Connector - Catalog
ID: 1824208-2
07/05/2022
PE 283041
Procurement Evaluation for Male Connector - Catalog
ID: 1824208-2
06/26/2023
PE 286594
Procurement Evaluation for Male Connector - Catalog
ID: 1824208-2
10/13/2023
PE 50579
Procurement Evaluation for Heat Exchanger Channel
End - Catalog ID: 47462-2
05/18/2006
PE 63353
Procurement Evaluation for Compound - Catalog
ID: 44315-2
10/07/2008
PE 65406
Procurement Evaluation for Compound - Catalog
ID: 44315-2
04/21/2009
PE 6946
Procurement Evaluation for Sealant - Catalog ID: 43405-2
08/16/2000
PE 74175
Procurement Evaluation for Relief Check Valve - Catalog
ID: 45136-2
11/07/2011
PE 7434
Procurement Evaluation for 5 MFD, 660 Vac
Capacitor - Catalog ID: 39467-2
09/25/2000
PE 74404
Procurement Evaluation for Starter Motor - Catalog
ID: 1438384-1
2/07/2011
PE 77411
Procurement Evaluation for SBLC System Explosive Valve
Replacement Kit - Catalog ID: 8175-1
08/23/2012
PE 78094
Procurement Evaluation for Starter Motor - Catalog
ID: 1438384-1
11/15/2012
PE 87844
Procurement Evaluation for 150 Ohm, 225 Watt
2/24/2015
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Resistor - Catalog ID: 23348-2
PE 99481
Procurement Evaluation for Heat Exchanger Channel
End - Catalog ID: 47462-1
01/11/2017
153026
Quality Receipt Inspection Package for Heat Exchanger
Channel End - Catalog ID: 47462-1
05/04/2010
28342
Quality Receipt Inspection Package for Starter
Motor - Catalog ID: 1438384-1
03/08/2018
24630
NUPIC Audit/Survey: ExxonMobil Fuel & Lubricants
Company
10/10/2018
250180
Quality Receipt Inspection Package for Sealant - Catalog
ID: 43405-2
09/10/2020
251170
Quality Receipt Inspection Package for Report for 150 Ohm,
25 Watt Resistor - Catalog ID: 23348-2
11/02/2020
25132
NUPIC Audit/Survey: ExxonMobil Fuel & Lubricants
Company
07/30/2021
251516
Quality Receipt Inspection Package for Capacitor - Catalog
ID: 39467-2
10/29/2020
253804
Quality Receipt Inspection Package for Oil
Lubricant - Catalog ID: 1705923-2
2/10/2021
254447
Quality Receipt Inspection Package for Relief Check
Valve - Catalog ID: 45136-2
2/22/2021
256493
Quality Receipt Inspection Package for
Compound - Catalog ID: 44315-2
05/05/2021
259997
Quality Receipt Inspection Package for Temperature
Element Assembly - Catalog ID: 42457-2
2/01/2022
261098
Quality Receipt Inspection Package for SBLC System
Explosive Valve Replacement Kit - Catalog ID: 8175-1
01/26/2022
264355
Quality Receipt Inspection Package for Poro-Edge
Tube - Catalog ID: 687201-2
05/18/2022
265340
Quality Receipt Inspection Package for 100 Ampere
Rectifier/Diode - Catalog ID: 41661-2
08/25/2022
268001
Quality Receipt Inspection Package for Diesel
Fuel - Catalog ID: 1419122-2
11/01/2022
Miscellaneous
271233
Quality Receipt Inspection Package for Male
2/22/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Connector - Catalog ID: 1824208-2
275474
Quality Receipt Inspection Package for Mobilgard 410 Oil
Lubricant - Catalog ID: 1705923-2
09/25/2023
277700
Quality Receipt Inspection Package for
Sealant - Catalog ID: 43405-2
2/06/2023
IST-LAS-PLAN
IST Program Plan, LaSalle County Station Units 1 & 2,
Fourth Interval
10/12/2017
LAS-07044
Exelon Power Labs Test Report for 100 Ampere
Rectifier/Diode - Catalog ID: 41661-2
09/28/2022
LAS-11-0098
(103917)
CSCS Health Improvement Project - LAS
06/04/2003
LAS-66956
Exelon Power Labs Test Report for Temperature Element
Assembly - Catalog ID: 42457-2
2/11/2022
LAS-76519
Exelon Power Labs Test Report for Capacitor - Catalog
ID: 39467-2
11/02/2020
LAS-92542
Exelon Power Labs Test Report for 150 Ohm, 225 Watt
Resistor - Catalog ID: 23348-2
2/15/2021
NDIT BYR97-
251-1
Evaluation of Ceramalloy CL+3 & CP+3 (Ultra
Coat)/CL+&CP+ on RCFC Channel Head Internals
09/26/1997
PO 1427568
Purchase Order for Male Connector - Catalog
ID: 1824208-2
Dynamic Screens Alphabetic U Through Z
ASME Section XI Repair/Replacement Program
LEP-SC-01
Testing Standby Liquid Control (SLC) Explosive Valves
LMP-GM-25
Emergency Core Cooling System (ECCS) Service Water
Strainer Maintenance
LOR-1H13-P603-
A503
Plant 1 CRD Hydraulic Accumulator Trouble Alarm Actions
LOR-2H13-P603-
A503
Plant 2 CRD Hydraulic Accumulator Trouble Alarm Actions
LOS-DO-SR2
Diesel Fuel Oil Analysis Verification (New Fuel Oil)
Facilities Maintenance Process
Procedures
MA-AA-716-230-
1001
Oil Analysis Interpretation Guideline
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Commercial Grade Surveys
PES-P-005
Oil & Grease Lubricants
PES-P-006
Diesel Fuel Oil
PES-S-002
Shelf Life
PES-S-003
In-Storage Maintenance of Nuclear Material
Warehouse Operations
Procurement Engineering Process and Responsibilities
1039029
LR - Replace or Overhaul Strainer
09/12/2022
1374432-1
B: ECCS Service Water Strainer Inspection
Report
04/20/2015
1598755
LRA Overhaul Strainer 2DG01F
2/22/2023
4578852
Perform 1A Diesel Generator Inspection per LMS-DG-01
04/01/2019
4631709
Replace Division 2 Battery Charger Internal Components
11/16/2020
4890794
Replace Exciter Diodes in Unit 1, HPCS EDG Excitation
Cabinet
09/21/2021
4902457
Replace Limit Switch
03/01/2021
4906822
Perform 1A Diesel Generator Inspection per LMS-DG-01
08/30/2021
4962227-5
EWP MM 0WR01A Contingency Internal Coating Repairs
07/15/2022
5108671
Perform 2A EDG Inspection per LMS-DG-01
10/13/2022
5460463-1
Diesel Fuel Oil Analysis Verification (New Fuel Oil)
01/31/2024
5519168-1
Leak on Charging Connection - U1 HCU 4611
03/20/2024
Work Orders
556284
Need to Install New Floating End of HX Erosion/Corrosion
05/15/2007