IR 05000373/2017007

NRC Problem Identification and Resolution Inspection Report 05000373/2017007; 05000374/2017007

ML17277A210
Person / Time
Site:	LaSalle
Issue date:	10/03/2017
From:	Karla Stoedter NRC/RGN-III
To:	Bryan Hanson Exelon Generation Co
References
IR 2017007
Download: ML17277A210 (20)

Text

UNITED STATES ber 3, 2017

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000373/2017007; 05000374/2017007

Dear Mr. Hanson:

On September 27, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) biennial inspection at your LaSalle County Station, Units 1 and 2. The NRC inspection team discussed the results of this inspection with Mr. H. Vinyard and other members of your staff. The inspection team documented the results of this inspection in the enclosed inspection report.

This inspection was an examination of activities conducted under your license as they relate to problem identification and resolution and compliance with the Commissions rules and regulations and the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the inspection samples, the inspection team determined that your staffs implementation of the corrective action program (CAP) supported nuclear safety. In reviewing your CAP, the team assessed how well your staff identified problems at a low threshold, your staffs implementation of the stations process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station to resolve these problems. In each of these areas, the team determined that your staffs performance was adequate to support nuclear safety.

The team also evaluated other processes your staff used to identify issues for resolution. These included your use of audits and self-assessments to identify latent problems and your incorporation of lessons-learned from industry operating experience into station programs, processes, and procedures. The team determined that your stations performance in each of these areas supported nuclear safety.

Finally, the team determined that your stations management maintains a safety-conscious work environment adequate to support nuclear safety. Based on the teams observations, your employees are willing to raise concerns related to nuclear safety through of several means. 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Karla Stoedter, Chief Branch 1 Division of Reactor Projects Docket Nos. 50-373; 50-374 License Nos. NPF-11 and NPF-18 Enclosure:

IR 05000373/2017007; 05000374/2017007 cc: Distribution via LISTSERV

SUMMARY

Inspection Report 05000373/2017007, 05000374/2017007; 07/31/2017 - 09/27/2017;

LaSalle County Station, Units 1 and 2; Biennial Problem Identification and Resolution (PI&R)

Inspection.

This inspection was performed by three U.S. Nuclear Regulatory Commission (NRC) regional inspectors, the resident inspector, and the Illinois Emergency Management Agency resident inspector. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5, dated February 2015.

Problem Identification and Resolution On the basis of the samples selected for review, the team concluded that implementation of the corrective action program (CAP) at LaSalle County Station was effective. The licensee had a low threshold for identifying problems and entering them into the CAP. Items entered into the CAP were screened and prioritized in a timely manner using established criteria; were properly evaluated commensurate with their safety significance; and corrective actions for conditions adverse to quality were generally implemented in a timely manner, commensurate with their safety significance. Operating experience was entered into the CAP and appropriately evaluated for applicability to station activities and equipment. The use of operating experience was integrated into daily activities. Audits and self-assessments were performed at appropriate frequencies and at an appropriate level to identify issues. The assessments reviewed were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. On the basis of interviews conducted during the inspection, workers at the site expressed freedom to raise safety concerns without fear of retaliation. The inspectors did not identify any impediments to the health of the safety-conscious work environment at LaSalle County Station.

NRC-Identified

and Self-Revealed Violations None

Licensee-Identified Violations

None

REPORT DETAILS

4OA2 Problem Identification and Resolution

The activities documented in Sections

.1 through .4 constituted one biennial sample of

problem identification and resolution as defined in Inspection Procedure 71152.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the licensees CAP implementing procedures and attended CAP meetings to assess the implementation of the CAP by site personnel.

The inspectors reviewed risk and safety significant issues in the licensees CAP since the last U.S. NRC problem identification and resolution inspection in May 2015. The selection of issues ensured an adequate review of issues across NRC cornerstones.

The inspectors used issues identified through NRC generic communications, department self-assessments, licensee audits, operating experience reports, and NRC documented findings as sources to select issues. Additionally, the inspectors reviewed action requests (ARs) generated as a result of facility personnels performance in daily plant activities. The inspectors also reviewed ARs and a selection of completed causal evaluations from the licensees various investigation methods, which included root cause, apparent cause, equipment apparent cause, and work group evaluations.

An expanded review, encompassing five years, was performed to assess the performance of the corrective action program for issues that are age dependent. The inspectors selected the High Pressure Core Spray (HPCS) and the Emergency Core Cooling (ECCS) Ventilation System for this detailed review.

During the reviews, the inspectors determined whether the licensee staffs actions were in compliance with the facilitys CAP and Title 10 Code of Federal Regulations (CFR) Part 50, Appendix B requirements. Specifically, the inspectors determined if licensee personnel were identifying plant issues at the proper threshold, entering the plant issues into the stations CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also determined whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected issue reports associated with conditions adverse to quality. This included a review of completed investigations and previous NRC findings and non-cited violations (NCV).

b. Assessment

(1) Effectiveness of Problem Identification Based on the results of the inspection, the inspectors concluded that problem identification was generally effective. Based on the information reviewed, the inspectors determined that LaSalle County Station personnel had a low threshold for initiating ARs; station personnel appropriately screened issues from both the NRC and industry operating experience at an appropriate level and entered them into the CAP when applicable; and identified problems were generally entered into the CAP in a complete, accurate, and timely manner.

The inspectors determined that the station was generally effective at trending low level issues to prevent larger issues from developing. The licensee also used the CAP to document instances where previous corrective actions were ineffective or were inappropriately closed.

Observations The inspectors noted through discussions with the licensee group managing the corrective action program, that for some Appendix B procedure compliance/adherence issues, the new CAP process may not require entering these issues into the CAP.

Specifically, issues related to compliance with reference use Appendix B procedures can be categorized as non-CAP and entered and tracked in other processes. No examples of this were identified by the inspectors, however issues of this nature would be considered violations of Appendix B, Criterion V, and therefore conditions adverse to quality.

Findings No findings were identified.

(2) Effectiveness of Prioritization and Evaluation of Issues Based on the results of the inspection, the inspectors concluded that identified problems were generally prioritized and evaluated commensurate with their safety significance, including an appropriate consideration of risk. Higher level evaluations, such as root cause and apparent cause evaluations, were generally technically accurate; of sufficient depth to effectively identify the cause(s); and generally considered extent of condition, generic implications, and previous occurrences in an adequate manner.

The inspectors determined that the station ownership committee and management review committee meetings were generally thorough and meeting participants were actively engaged and well-prepared. Station ownership committee and management review committee meetings accurately prioritized issues.

The inspectors determined that, overall, LaSalle County Station personnel evaluated equipment operability and functionality requirements adequately after a degraded or non-conforming condition was identified, and appropriate actions were assigned to correct the degraded or non-conforming condition.

Observations The inspectors identified several issues whose evaluations were inadequate. These observations were characterized as minor.

In AR 02629002 degradation was identified in the 1A Reactor Recirculation Motor Cooling. The operability basis stated that the degradation would need to be evaluated by engineering to determine if any repairs were needed, however no actions were assigned. Engineering did perform an evaluation to perform a pressure test to identify the leaking tube and repair it, but the evaluation did not consider the extent of condition of the degradation and hence overall condition of the cooler. The licensee initiated AR 02629002 for this observation.

An inspector performed a walkdown of the 1A diesel generator. The inspector noted a pinhole leak in the air start system. Action Request 03959976 was generated in February of 2017 for the air leak and evaluated the leak as acceptable since the air compressors could maintain the required system pressure. The inspector identified the leak was not evaluated to determine if the leak affected the capability of the air start system to perform 5 EDG starts without the air compressors functioning as stating in the FSAR basis. This licensee initiated AR 03959976 and determined the leak did not affect the required capability of the air start system.

Findings No findings were identified.

(3) Effectiveness of Corrective Actions Based on the results of the inspection, the corrective actions reviewed were found to be appropriately focused to correct the identified problem and were generally implemented in a timely manner commensurate with the issues safety significance. Problems identified through root or apparent cause evaluations were generally resolved in accordance with the CAP procedures and regulatory requirements. Corrective actions intended to prevent recurrence were generally comprehensive, thorough, and timely.

The corrective actions associated with selected NRC documented findings and violations, as well as licensee-identified violations, were generally appropriate to correct the problem and were implemented in a timely manner.

Findings No findings were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensees implementation of the facilitys Operating Experience (OE) program. Specifically, the inspectors reviewed implementing OE program procedures, attended CAP meetings to observe the use of OE information, completed evaluations of OE issues and events, and selected monthly assessments of the OE composite performance indicators. The inspectors review was to determine whether the licensee was effectively integrating OE experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensees program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of OE experience, were identified and effectively and timely implemented.

b. Assessment In general, OE was appropriately used at the station. The inspectors observed that OE was discussed as part of the daily station and pre-job briefings. Industry OE was disseminated across the various plant departments. No issues were identified during the inspectors review of licensee OE evaluations. The inspectors also verified that the use of OE in formal CAP products such as root cause evaluations and equipment apparent cause evaluations was appropriate and adequately considered. Generally, OE that was applicable to LaSalle County Station was thoroughly evaluated and actions were implemented in a timely manner to address any issues that resulted from the evaluations.

Findings No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors assessed the licensee staffs ability to identify and enter issues into the CAP program, prioritize and evaluate issues, and implement effective corrective actions, through efforts from departmental assessments and audits.

b. Assessment Based on the results of the inspection, the inspectors did not identify any issues of concern regarding LaSalle County Station staffs ability to conduct self-assessments and audits. Assessments were conducted in accordance with plant procedures, were generally thorough and intrusive, adequately covered the subject area, and were effective at identifying issues and enhancement opportunities at an appropriate threshold. Identified issues were entered into the CAP with an appropriate significance characterization and corrective actions were completed and/or scheduled to be completed in a timely manner commensurate with their safety significance.

Findings No findings were identified.

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

The inspectors assessed the licensees safety-conscious work environment through the reviews of the facilitys employee concern program implementing procedures, discussions with coordinators of the employee concern program, interviews with personnel from various departments, and reviews of issue reports. To assess LaSalle County Stations safety culture, the inspectors interviewed station employees representing a cross section of site departments. Additionally, the sites most recent safety culture assessment was reviewed and the employee concerns program coordinators were interviewed.

b. Assessment Based on the results of the inspection, the inspectors did not identify any issues that suggested conditions were not conducive to the establishment and existence of a safety-conscious work environment at LaSalle County Station. Information obtained during the interviews indicated that an environment was established where LaSalle County Station employees felt free to raise nuclear safety issues without fear of retaliation; were aware of and generally familiar with the CAP and other processes, including the employee concerns program and the NRC, through which concerns could be raised; and safety significant issues could be freely communicated to supervision.

Findings No findings were identified.

4OA6 Management Meeting

.1 Exit Meeting Summary

On August 18, 2017, the inspectors presented the inspection results to Mr. H. Vinyard, and other members of the licensee staff. A re-exit was conducted on September 27, 2017, with Mr. G Ford. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

P. Karaba, Site Vice-President

H. Vinyard, Plant Manager

G. Ford, Regulatory Assurance Manager

R. Bellettini, Corrective Action Program Manager

T. Lanc, Regulatory Assurance

J. Shea, Reactor Engineering Manager

U.S. Nuclear Regulatory Commission

K. Stoedter, Chief, Reactor Projects Branch 1

LIST OF ITEMS

Opened

None

Closed

None