IR 05000373/2019011

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NRC Temporary Instruction 2515/193, Implementation of Reliable Hardened Containment Vents Inspection Report 05000373/2019011 and 05000374/2019011
ML19333B843
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 11/29/2019
From: Ann Marie Stone
NRC/RGN-III/DRP/TSS
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
References
IR 2019011
Download: ML19333B843 (8)


Text

November 29, 2019

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 2515/193, IMPLEMENTATION OF RELIABLE HARDENED CONTAINMENT VENTS INSPECTION REPORT 05000373/2019011 AND 05000374/2019011

Dear Mr. Hanson:

On November 20, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at LaSalle County Station, Units 1 and 2 and discussed the results of this inspection with Ms. Deborah McBreen 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,

/RA/

Ann Marie J. Stone, Technical Support Team Leader Technical Support Staff Division of Reactor Projects

Docket Nos. 05000373 and 05000374 License Nos. NPF-11 and NPF-18

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000373 and 05000374

License Numbers:

NPF-11 and NPF-18

Report Numbers:

05000373/2019011 and 05000374/2019011

Enterprise Identifier: I-2019-011-0034

Licensee:

Exelon Generation Company, LLC

Facility:

LaSalle County Station, Units 1 and 2

Location:

Marseilles, IL

Inspection Dates:

November 18, 2019 to November 20, 2019

Inspectors:

J. Havertape, Resident Inspector

S. Sheldon, Project Engineer

Approved By:

Ann Marie J. Stone, Technical Support Team Leader

Technical Support Staff

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a NRC Temporary Instruction 2515/193, Implementation of Reliable Hardened Containment Vents Inspection at LaSalle County Station, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

2515/193 - Inspection of the Implementation of EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions

Inspection of the Implementation of EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions (1 Sample)

(1) The inspectors reviewed appropriate elements of the reliable hardened containment wetwell vent as described in the plant specific submittals and the associated safety evaluation (ADAMS Accession No. ML19218A365) to determine whether the licensee was in compliance with NRC Order EA-13-109 Phase 1, Reliable, Severe Accident Capable Wetwell Venting System (ADAMS Accession No. ML13143A321).

The purpose of the inspection was to verify the licensee satisfactorily:

  • Installed the Hardened Containment Vent System (HCVS) to meet the performance objectives outlined in Section A.1.1 of Attachment 2 to the Order EA-13-109;
  • Installed the HCVS system with the design features specified in Section A.1.2 of Attachment 2 to the Order EA-13-109;
  • Designed the HCVS to meet the quality standards described in Section A.2 of 2 to the Order EA-13-109;
  • Developed and implemented adequate maintenance and testing of HCVS equipment to ensure their availability and capability;
  • Developed and issued procedures to safely operate the HCVS using normal power supplies, during Extended Loss of AC Power (ELAP), and a postulated severe accident scenario, and integrated the procedures into existing plant procedures; and
  • Trained their staff to assure personnel can proficiently operate the HCVS.

The inspectors reviewed appropriate elements of the reliable wetwell venting strategy as described in the plant specific submittals and the associated safety evaluation (ADAMS Accession No. ML19218A365) to determine whether the licensee was in compliance with NRC Order EA-13-109 Phase 2, Reliable, Severe Accident Capable Drywell (or alternative strategy) Venting System (ADAMS Accession No.

ML13143A321).

The purpose of the inspection was to verify the licensee satisfactorily developed a strategy making it unlikely to vent from the containment drywell, that includes the following:

  • Implemented the Severe Accident Water Addition (SAWA)/Severe Accident Water Management (SAWM) systems as defined and fulfilled functional requirements for installed and portable equipment;
  • Installed and/or identified the previously-installed instrumentation necessary to implement SAWM;
  • Developed and implemented adequate maintenance and testing of SAWA/SAWM equipment to ensure availability and capability;
  • Developed and issued procedures to safely operate the SAWA/SAWM during an ELAP and during postulated severe accident scenario, and integrated their procedures into their existing plant procedures such that entry into and exiting from the procedures are clear when using existing plant procedures; and
  • Trained their staff to assure personnel can proficiently operate the HCVS during an ELAP and accident scenario.

The inspectors verified that any noncompliance with requirements, and standards identified during the inspection were entered into the licensee's corrective action program

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On November 20, 2019, the inspectors presented the NRC Temporary Instruction 2515/193, Implementation of Reliable Hardened Containment Vents Inspection results to Ms. D. McBreen and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

2515/193

Corrective Action

Documents

2703470

Technical Errors in Vendor Design Report for HCVS

08/11/2016

2716222

Hardened Containment Vent System (HCVS) Connection

NDE Issue

09/15/2016

3955609

HCVS Tower Knife Plate Bolted Connection Gap

2/08/2016

3970177

HCVS Rupture Disc Follow-Up

2/02/2017

3974587

2PC525A Passes Flow When in Normal

2/15/2017

4010161

HCVS Radiation Monitor Not Mounted Per Vendor Drawings

05/12/2017

4030989

Welded Lugs not Installed on HCVS Pipe

07/11/2019

4098335

Work Order to Set SAWA Flow Meter Parameter

01/29/2018

4109342

HCVS Electrical Routing Deviated from Design Drawings

2/28/2018

4145923

HCVS Batteries Require a Longer Equalizing Charge

05/31/2018

4151839

Trend IR: Small Argon Leak on U2 HCVS Bottle Banks

06/29/2018

4179990

NRC Identified - LOA-FSG-002 Contingency Path Issue

10/02/2018

284007

SAWA Flowmeter Orientation Discrepancy Identified

09/18/2019

296569

Incorrect Diagram Submitted with HCVS Final Integrated

Plan

11/12/2019

Corrective Action

Documents

Resulting from

Inspection

298204

2019 NRC HCVS Walkdown Observation

11/18/2019

298700

NRC 2019 HCVS Inspection - Freeze Line

11/20/2019

298703

NRC 2019 HCVS Inspection LGA-VQ-102/202

11/20/2019

Drawings

1E-0-4000FA

Key Diagram Hardened Containment Vent System (HCVS)

25 VDC Distribution Panel 0DC52E

A

M-138 Sheet 2

P&ID Primary Containment Vent and Purge

P

M-138 Sheet 3

P&ID Primary Containment Vent and Purge

A

Miscellaneous

Final Integrated Plan HCVS Order EA-13-109

2/14/2018

2018 - 2019 Long Range Training Plan

Procedures

LGA-001

RPV Control

LGA-003

Primary Containment Control

LGA-004

RPV Blowdown

LGA-VQ-102

Unit 1 Emergency Containment Vent

LOA-AP-101

Unit 1, AC Power System Abnormal

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

LOA-FSG-002

FLEX Electrical Strategy

LOA-FSG-003

FLEX Water Supply Strategy

LOA-FSG-011

FLEX Beyond Design Basis External Event Guidance

LSAMG-001

RPV and Primary Containment Injection

LSAMG-002

RPV, Containment, and Radioactivity Release Control

Work Orders

AR 4067775

HCVS Tee Weight Increase

10/24/2017

WO 1940217 - 71

U2 HCVS PCIV LLRT

2/16/2017

WO 1942017 - 66

thru 69

U2 HCVS PCIV Testing, Main Control Room and Remote

Operating Station

2/13/2017

WO 4571434 - 16

U2 HCVS Radiation Monitor Loop Calibration

2/23/2017

WO 4573336 - 29

U2 HCVS 2PC525A Troubleshooting

2/21/2017

WO 4591065 - 01

LOS-PC-R4, U2 HCVS Testing of ROS and Manual Bypass

Valves

2/15/2017

WO 4591094 - 01

LOS-PC-R6, U2 HCVS Test of 0PM08J Valves and Logic

2/15/2017

WO 4632060 - 19

LOS-PC-R4, U1 HCVS Testing of ROS and Manual Bypass

Valves

2/21/2017

WO 4632060 - 29

LOS-PC-R6, HCVS Test of 0PM08J Valves and Logic

2/21/2017

WO 4632060 - 40

thru 43

U1 HCVS PCIV Testing, Main Control Room and Remote

Operating Station

2/21/2017

WO 4632060 - 44

U1 HCVS PCIV LLRT

2/28/2018

WO 4653865 - 16

and 19

U1 HCVS Radiation Monitor and Argon Pressure Transmitter

Loop Calibration

01/26/2018

WO 4655747 - 01

U2 HCVS PCIV LLRT

03/03/2019

WO 4655748 - 01

LOS-PC-Q2, U2 HCVS Operability, Inservice Inspection, and

Walkdown

03/03/2019

WO 4655751 - 01

LOS-PC-R6, U2 HCVS Test of 0PM08J Valves and Logic

03/05/2019

WO 4655752 - 01

LOS-PC-R4, U2 HCVS Testing of ROS and Manual Bypass

Valves

03/05/2019

WO 4655753 - 01

LOS-PC-R3, U2 HCVS Valve and Logic Test

03/05/2019

WO 4663979 - 01

U2 HCVS Radiation Monitor Calibration and Maintenance

07/20/2018