View source for RA24-023, Response to NRC LaSalle County Station, Units 1 and 2, Integrated Inspection Report 05000373/2024001 and 05000374/2024001

{{Adams
| number = ML24164A061
| issue date = 06/12/2024
| title = Response to NRC LaSalle County Station, Units 1 and 2, Integrated Inspection Report 05000373/2024001 and 05000374/2024001
| author name = Van Fleet J
| author affiliation = Constellation Energy Generation, LLC
| addressee name = 
| addressee affiliation = NRC/NRR, NRC/RGN-III, NRC/Document Control Desk
| docket = 05000373, 05000374
| license number = NPF-011, NPF-018
| contact person = 
| case reference number = RA24-023
| document type = Letter type:RA, Licensee Response to Notice of Violation
| page count = 1
}}

=Text=
{{#Wiki_filter:LaSalle   County                           Station 2601      North 21     "      Road Constellation                                                                                                                                                                           Marseilles. IL  61341 815-415-2000  Telephone

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RA24-023

June                               12,  2024

U.S.                    Nuclear             Regulatory                    Commission ATTN:        Document                                         Control        Desk Washington,                                               DC   20555-0001

LaSalle County                                      Station,  Units         1 and                       2 Renewed                           Facility Operating License       Nos.              NPF-11       and                        NPF-18 NRC     Docket           Nos.           50-373     and                          50-374

==Subject:==
Response                       to    NRC     LaSalle County                                     Station,    Units        1 and                        2  Integrated  Inspection Report 05000373/2024001             and                         05000374/2024001

==Reference:==
Letter from           Robert         Ruiz (U.S.                       Nuclear           Regulatory                     Commission)                             to     David P.
Rhoades                          (Constellation Energy                    Generation,                      LLC),    "LaSalle County                                       Station -
Integrated Inspection                 Report 05000373/2024001              and                       05000374/2024001,"
dated   May                               13,   2024  (ADAMS      Accession                          No.               ML24131A151)

The     U.S.                     Nuclear           Regulatory                     Commission                               (NRC)     documented                                           four       Green       findings and associated                  non-cited                 violations (NCVs)                   in the Integrated Inspection                    Report for the first quarter    of 2024 for LaSalle  County                                   Station    (LSCS).

The    NCV                   and                       associated                 Green       finding of note                is associated                  with the Failure to   Test Motor Operated Valve                   in  Accordance                                                       with the lnservice Test Program                           (NCV                05000374/2024001-02).
The    NCV                   and                        finding was                     for LSCS's failure to    meet the in-service testing requirements  set forth in the American                        Society         of Mechanical                            Engineers   Operations         and                      Maintenance                                               Code             and Addenda                              Code              Case            OMN-1        after performing     maintenance                                                  that could                affect motor-operated valve    performance.

LSCS      is respectfully contesting         the finding and                         violation.        The    attached         enclosure                            to   this letter provides the response                and                          basis      for the contestation                   of the violation and                      finding referenced above.

There are         no                        regulatory           commitments                             contained                                       in this letter.

Should              you                                     have             any                                  questions           concerning                                         this letter, please  contact                              Ms. Laura                                  Ekern, Regulatory                    Assurance                                  Manager,                                  at   (815)   415-2800.

Respectfully, JJJ:::F~<f~
Site Vice              President LaSalle County                                    Station RA24-023 June                              12  , 2024 Page             2  of 2

==Enclosure:==
Response                        to    Non-Cited  Violation            05000374/2024001-02

cc               :                                    NRC     Regional             Administrator, Region              Ill NRC     Director, Office of Enforcement NRC     Senior        Resident Inspector             -            LaSalle County                                     Station Enclosure                      to    RA24-023 Page                1 of 8

ENCLOSURE

LaSalle County                                     Station. Units        1 and                        2 Response                        to   Non-Cited    Violation             05000374/2024001-02

On              May                            13, 2024,   the U.S.                    Nuclear           Regulatory                    Commission                               (NRC)       issued LaSalle County Station  -                     Integrated Inspection                  Report 05000373/2024001             and                        05000374/2024001            (ADAMS Accession                             No.              ML24131A151)          (Reference             1).                In             Reference             1,  the NRC     issued a            non-cited violation (NCV)                05000374/2024001-02             of Title 10 of the Code            of Federal Regulations                 (10  CFR)
Part 50.55a(f)(4)(ii) and                       associated              Green        finding to    LaSalle  County                                   Station  (LSCS)     for the failure to   meet  in-service testing (1ST)  requirements set forth in the American                        Society         of Mechanical                        Engineers        (ASME)   Operation          and                       Maintenance                                           (OM)     Code,             Code             Case            OMN-1 after performing maintenance                                                     that could                   affect motor-operated                            valve  (MOV)                   performance.
Specifically, LSCS   failed to   perform testing on                        primary         containment                                            isolation MOV                2821-F016, Main            Steam               Line Drain       Header         Inboard                                       Isolation        Valve,                 prior to   returning the valve to   service after electrically backseating                             the valve.            The    LSCS    1ST  Program                            Plan       -4 th Ten-Year                           Interval (Reference          2)     lists MOV                 2821-F016        as            an                      ASME    Code            Class  1,    Category                    A,       normally                          open, motor-operated,                         active valve with a          safety  function                       in the closed         position.

LSCS     has          reviewed the details of the NCV                  provided in  Reference             1 and                      disagrees with the NRC assessment                      and                    the conclusions                                          related to  the issue.        LSCS     has           performed   a            detailed review of the applicable      NRC      regulations,     ASME      OM     Code             and                      Code               Case,             and                      NRC     guidance                               related to post-maintenance                                                 testing (PMT)   of an                            1ST component.                                                       The    applicable    documents                                            allow     the licensee to  define the level of testing that is required after replacement,                repair, or     maintenance of an                            1ST component.                                                                    LSCS   asserts that an                       evaluation                   with stroke testing deferred to   a           more suitable plant condition                      can                                   be              used         to   meet   the level of testing required to   return   a           valve to service as           long           as          appropriate   justification is provided to   support      that conclusion.                                        The   following discussion             demonstrates                   that this method                meets the requirements    of Code             Case            OMN-1.

LSCS       Review       of   the NRC      Inspection                                 Report

The    Description section        of the NCV              05000374/2024001-02                 Inspection                  Results in  Reference       1 provides the fundamental                                        premise for issuing the NCV                 as          follows:

Since       both            the valve  and                    its control               system          underwent                             maintenance                                                that could                affect the MO V's           performance,                                       the inspectors   determined the valve   was                required to  be            tested in accordance                                                          with Paragraph                           3. 4  of Code               Case           OMN-1.             The   Code             Case           does           not         provide the allowance                                       to perform   an                     evaluation                           in lieu of the required inservice testing. Although this does          not           conform                                         to  the requirements,      the licensee's evaluation                    and                    work            results provided reasonable                                       assurance                                           the structural integrity of the MO V              was                not             exceeded.
However,                not           performing    any                              testing after maintenance                                               prior to  returning    the valve to service did not           maintain                      the requisite level of assurance                                        for the valve. Considering operating        experiences                    with backseating,                                  the number                                  of assumptions                           embedded                                in   the evaluation,                     and                      the use        of the new                  MOV                BSRT,       the inspectors  noted             there were     several uncertainties    associated                   with the engineering        evaluation                      and                     its use           to  restore operability. Based             on                       the inspectors'     review of the /ST plan          and                  procedures                      for the valve, the inspectors  determined the licensee failed to   ensure                    the testing required after maintenance                                               under                       WO                5443427-01           was              performed        in   accordance                                                             with Code              Case Enclosure                     to    RA24-023 Page             2  of 8

OMN-1.        In            addition,  the licensee did not           request relief from        the code                       via an                   ASME     Code relief request to  the NRG      which    , if approved                    ,   would                  have             allowed         the valve to  be returned      to  service without performing   the required testing.

Furthermore,            the Performance                              Assessment          section         of the NCV                05000374/2024001-02 Inspection                    Results in  Reference            1 provides additional   clarity of the deficiency    that led to   the violation:

Performance                               Deficiency    :   The  licensee's failure to perform   required testing after maintenance                                                  for the primary           containment                                         isolation MOV               2B21-F016         in accordance                                                                 with ASME     OM Code-2004,               2006  Addenda,                            Code                 Case            OMN-1,     Paragraph                             3.4,      was                    a violation of 10 CFR     50.55a(f)(4)(ii) and                       a          performance                                deficiency    . Specifically, the licensee failed to perform    required testing on                         the MOV            prior to  returning the valve   to service after electrically backseating                           the valve,    which      was                  maintenance                                                that could                 affect the valve's performance                                 .

LSCS    understands                             the NRC's      position that Code              Case            OMN-1       requires some                   type     of physical testing prior to    returning the valve   to    service and                     the licensee cannot                                         perform    an                      evaluation                           as           a PMT    in  lieu of testing without    prior NRC     approval                 through             an                    ASME     Code               relief request.          The inspection         report does           not            reference  any                              other NRC       regulation       or     guidance                              to  support        this interpretation of the Code             Case             .

Code                Requirements                               and                         Guidance

A   review of the applicable     ASME       OM     Code              requirements      and                       NRC      guidance                            was                   performed, with the relevant basis       information                   summarized                          below:
* ASME        OM     Code              Case          OMN-1,       Alternative Rules  for Preservice and                        lnservice Testing of Active Electric Motor-Operated        Valve              Assemblies  in Light-Water Reactor                 Power                Plants (Reference               3),    states in   Paragraph                            3.4,     Effect of MOV                 Replacement,                            Repair, or Maintenance:

When                           an                       MO V           or  its control            system           is replaced,      repaired, or  undergoes                         maintenance that could                  affect the valve's performance,                             new                    inservice test values          shall be            determined, or   the previously   established in service test values         shall be            confirmed              before        the MO V             is re tu med           to  service ..    . This testing is intended     to  demonstrate                   that performance parameters               ,   which   could                have             been                     affected by                      the replacement               ,   repair, or maintenance, are         within acceptable                          limits. The  Owner's              program                         shall define the level of testing required after replacement,                   repair, or maintenance                                                      .
* NUREG-1482,                               Revision  3  , Guidelines for lnservice Testing at   Nuclear               Power              Plants (Reference            4),     provides the following guidance                                    in Section        4.4  .2,      Post-Maintenance                                           Testing After Stem       Packing              Adjustments      and                      Backseating                  of Valves            to    Prevent Packing                Leakage                          :

Alternatively, backseating                            a             valve may                               stop packing                leakage             without the need              to   take  the valve  out          of service. Licensees      should        exercise  caution                             when                    performing  such maintenance,                                                        as        improper  backseating                       or  adjustment           of valve  stem packing              could adversely         affect the valve's  functional                capability.         Licensees      will need             to have         justification Enclosure                       to   RA24-023 Page               3  of 8

that backseating                             or packing                  adjustments                 do           not           adverse         [sic] impact           the operational readiness      of the valve.
* The     NRC     Recommendation                                                              for Section          4.4.2    of Reference            4,    states:

If it is necessary                                       to  adjust the stem  packing                  or backseat                                a            valve   to  stop  packing                 leakage and                  if a          required stroke test or  leak rate test is not          practical  in the current         plant   mode,                        the licensee must,              at a          minimum,                            justify by                  analysis                  that ...     (2)     the backseating                              does            not deform          the valve    stem,   and                        (3)    the performance                                 parameters                of the valve   are      not adversely        affected (including        the stroke time of the valve).      When                         intending       to   use backseating                               to  stop   a packing                     leak,    the licensee will be           expected              to   stroke the valve stem  away                                     from          the backseat                          after the initial backseating                               operation                     to  demonstrate                     that the valve  stem     will not          become                                      bound                                                   in the backseat                            by                   this temporary                           leakage mitigation method.                       In             addition,     the licensee must         perform         a  confirmatory                                 test at the first available          opportunity                          when                  plant    conditions                 allow         testing .            ...

Granting       of relief under                      10  CFR       50.SSa(f)   is not          necessary                                because                                        this action                    is in accordance                                                         with the OM  Code              requirements       if the licensee can                            demonstrate                      that the performance                                 parameters                 will not           be            adversely        affected.

To           properly    implement       this guidance,                                 licensees must         perform       a          partial-stroke test, if practical,   to  obtain                        further assurance                                           that the valve    stem    is free to  move.                       At the first opportunity                     when                       the plant  enters an                    operating         mode                             in   which      testing is practical,   the licensee must           test all valves  that have             had        packing                   adjustments              or  been                       backseated without post-maintenance                                                            testing.
* The     Basis for Recommendation                                                           for Section         4.4.2    of Reference          4,     states:

The  licensee  would                   have              to  assess          the effect of backseating                               on                     valve    operation                  and determine  whether post-maintenance                                                          testing is required.

Both   the ASME     OM    Code               Case           and                    the applicable       NRC      NUREG                      guidance                             consistently      state that post-maintenance                                                     testing is required after performing     maintenance                                                that could                   affect a valve's   performance;                                  however,                   both            also          state that the licensee determines the level of testing that is required following   maintenance.                                                               Also, the guidance                               states that if the current           plant conditions                   make                  testing not             practical, an                       analysis                  can                              be             performed   to justify that the valve  will still be             able          to   perform      its required function,                          and                     testing shall be             performed     at  the first available opportunity                    when                      plant   conditions                 allow.

LaSalle        County                                         Station                 Position

It is the position of  LSCS    that the requirements     of Code              Case             OMN-1      and                       the guidance                                    in NUREG-1482                          Section          4.4.2    were     met    by                      performing     an                       analysis                 to   defer post-maintenance testing to   a          more                suitable  plant condition.                              As explicitly stated in OMN-1      Paragraph                               3.4,   it is the licensee program                    that defines the level of testing required after replacement,                  repair, or maintenance.

MOV                 2B21-F016,       which          is located         in the Unit       2  drywell, was                   determined to   be            causing                              an increase                in drywell unidentified leakage           due             to  excessive         packing                  leakage.                     The     LSCS    Unit         1 Enclosure                   to    RA24-023 Page            4   of 8

and                        Unit      2  drywells are       inerted with nitrogen      during        power              operations                  and                       cannot                                         be            entered during       power                operations            to   perform    repairs of equipment.                        Therefore, the only                    option           to    mitigate the excessive        packing               leakage             and                        reduce            drywell unidentified leakage           while at   power               was                  to electrically backseat                            MOV               2821-F016           .          Since        MOV                2821-F016           is located          inside the drywell, there exists the risk that cycling              of the valve  could                     lead to  unacceptable                                                  drywell leakage resulting in the unnecessary                                                   shutdown                            of LSCS      Unit      2 to   repair the packing.                                In             2009,      a            forced shutdown                             of Unit      2 was                   required due            to   elevated drywell leakage          from         a             packing              failure on                     this valve  .           Due             to   past operational                experience              (OE)    with packing               leakage            causing                          a           forced shutdown,                                  a             partial stroke off the backseat                     was                    deemed                not            practical while at  power                 and                          it was deferred to    a            more                suitable plant  condition.

Application of the LSCS  1ST  program,                          in  accordance                                                             with Paragraph                         3.4  of Reference            3, concluded                                   that an                       evaluation                      based                           on                       past diagnostic      testing and                      data              provided justification for returning the valve to   service. This evaluation                       (Reference         5)  justified that the backseating performed      did not            adversely    impact        the operational                  readiness    of the valve.           The   evaluation concluded                                   that the backseating                              did not           deform        the valve stem  and                     the performance                               parameters of the valve  were      not           adversely        affected, including      the stroke time of the valve.          The    evaluation was                   reviewed by                      the NRC     and                     their conclusion                                     is documented                                             in the Description section          of the NCV                05000374/2024001-02              Inspection                 Results in  Reference          1:

The   licensee performed       an                      engineering       evaluation                          in support       of backseating                            the valve under                  engineering    change                                request (ECR)         461530.       The  inspectors  reviewed the evaluation                      and                  noted             there were    two          reasons                         for performing     this evaluation.                        One            aspect of the evaluation                    was                    to  evaluate             the backseating                            evolution,               which      was                  to  be           performed for the first time with a         new                 MOV              backseat                            relay     tool (BSRT),         under                  Work                Order (WO) 5443427-01.            This tool is installed at the MCC   and                   bypasses                                the open                    limit switch to allow        the stem to contact                             the backseat.                                 The   second                       purpose                of the evaluation                        was                     to perform       a  formal    technical     evaluation                     to  assess       the limitation of the backseating,                              the potential effects on                      the MOV              structural capability,       and                      the valve requirements.       The licensee evaluated           the following three criteria: increased            stroke time, thrust and                      torque loads           applied during      backseating                        of the valve compared                                  to   valve/actuator                       structural capability,         and                  post-maintenance                                                   requirements/testing/evaluations     . From                 the review, the inspectors  noted           the structural capabilities of the valve and                    actuator                           were    calculated                  to be            acceptable                            within design limits.

Therefore, the LSCS   PMT   process            determined that a            physical    PMT  was                     not             required, and                            an evaluation                     was                    sufficient to   support        returning the valve to   service while deferring stroking of the valve   (i.e., stroking the valve   stem   away                                        from       the backseat                         after the initial backseating)                              to   a more                suitable plant condition.

This deferral of testing to   a          more                   suitable plant  condition                 due           to     not            being             practical in the current plant  condition                       is allowed        by                     guidance                              provided in the NRC     Recommendation                                                                for Section          4.4.2 of Reference        4:

If it is necessary                                   to   adjust the stem packing                  or backseat                           a             valve to  stop packing                   leakage and                  if a           required stroke test or leak rate test is not        practical in  the current     plant   mode                      , the licensee must,          at a         minimum                                , justify by                    analysis                 that .  .  . (2)    the backseating                       does            not deform          the valve stem,    and                           (3)    the performance                               parameters             of the valve are      not adversely       affected (including        the stroke time of the valve) .              ... In              addition, the licensee Enclosure                       to   RA24-023 Page             5  of 8

must        perform     a           confirmatory                        test at the first available           opportunity                  when                  plant  conditions allow     testing. . .  .

To          properly implement this guidance,                               licensees must         perform  a        partial-stroke test, if practical, to  obtain                      further assurance                                            that the valve   stem is free to  move.                      At the first opportunity                  when                       the plant enters an                      operating     mode                             in  which    testing is practical, the licensee must           test all valves that have            had         packing                 adjustments         or been                      backseated without post-maintenance                                                   testing.

The   deferral of testing does            not           require relief from      the ASME       OM     Code             requirements   if it can                             be demonstrated                  that the performance                            parameters             will not             be            adversely    affected.          As stated in the NRC     Recommendation                                                                   for Section       4.4  .2  of Reference     4   :

Granting     of relief under                     10  CFR      50.55a(f)    is not           necessary                              because                                       this action                   is in accordance                                                           with the OM Code            requirements  if the licensee can                            demonstrate                     that the performance                              parameters              will not           be            adversely   affected.

The   previously   discussed     evaluation                     provided the justification that backseating                           the valve would not            adversely     affect the performance                             parameters             .

Per the evaluation                     (Reference         5),    during        plant shutdown                               (prior to  plant cooldown                                               to  less than 250   degrees F),   the valve    is required to    be              moved                      off the backseat                         to   prevent  internal binding that could                  possibly     damage                                  the valve  or      actuator.                                 The   movement                                  off the backseat                           would coincide             with a           closure            stroke time test and                        meet the intent of a           confirmatory                           test to  verify freedom         of movement                               of the valve stem  .           It also       demonstrates                 that the valve  would                     have            closed in  the required time, supporting   the conclusions                                      of the evaluation                       .

Due             to   LSCS  Unit       2  being               in  Mode                1,    Power                 Operation,       when                       MOV               2821-F016           was                  electrically backseated,                          work             order   (WO)               05443427     was                    scheduled      for the Unit     2  refueling outage,                         L2R20, in  2025  to  test and                      repair MOV              2821-F016.                        Refueling outage                           L2R20     is the first scheduled opportunity                 that Unit        2 will be             in  a          plant  condition                to   allow      testing of MOV               2821-F016           due         to the drywell being          deinerted for refueling and                        maintenance.                                                            Additionally, WO               05443427      was                    placed on                      the forced    shutdown                                  outage                     schedule        to   be           completed           if Unit     2 has          a          forced       outage                      of sufficient scope                and                        duration                prior to  the scheduled      refueling outage                          in 2025.

To            demonstrate                that electrically backseating                                 an                        MOV              does            not            adversely     affect the ability of the MOV               to    close   from       the backseated                         position an                           OE    search          was                     performed through           the Institute of Nuclear            Power              Operations        (INPO)    using           various            terms and                       phrases   such                    as:
* backseat                         and                        "failure to   close"
* backseat                          and                         closure
* backseat                          and                        "failure to   stroke"
* backseat                         and                         bound
         *                              "electrically backseat                          "
         *                                "electrical backseat"

The    review of the INPO    OE   results produced                              one                    applicable       result from      April 18,   2005  at Brunswick,                 OE215560       , (Reference     6)   where         a           MOV             that was                     not              in the 1ST or      MOV                program was                   electrically backseated                             due           to   increased             drywell leakage.                     At a          later time, Operations Enclosure                      to     RA24-023 Page            6  of 8

attempted to    close  the MOV,                     and                       it failed to    close,       resulting in Operations        having           to   use          the handwheel                     to  manually                                    move                       the stem.           The  valve was                   then    able          to   be            operated        electrically with no                        issue.         Investigation of the issue determined binding         was                  unlikely due            to  the backseat geometry.                               The   cause                       of the Brunswick               failure was                    indeterminate.

Other relevant OE  identified was                   Information                            Notice (IN)   87-40,    Backseating               Valves                 Routinely           to Prevent Packing                   Leaks         (Reference           7).              The     IN    identifies multiple instances              of improperly electrically backseating                        MOVs                  by                    temporarily stalling the actuator                       during       backseating,                           thus creating    over      torque       / thrust conditions                 and                       a           failed stroke time from        the backseat.                                        However, this IN   does             not           identify any                                failures to   stroke from       the backseat                       due           to  binding         .            It should             be noted           that IN   87-40   predates the creation           of the NRC      required MOV                  program                       at  commercial nuclear                     power                 plants in  United          States.          Through                    the MOV                Program,                        component                                               weak                     link information,                   actuator                       capability        assessments,                  stroke time computations,                                                and                      performance trending have                been                      implemented    that address    the issues identified in this IN.

Conclusion

As explicitly stated in Code              Case            OMN-1,     it is the licensee program                      that defines the level of testing required after replacement,                  repair, or     maintenance                                                   .           Due          to    MOV               2821-F016            being located          in the drywell, cycling            of the valve could                    have               led to   unacceptable                                               drywell leakage resulting in a            forced    shutdown                             of Unit       2,     similar to  the event   in  2009.              Therefore, stroking of the valve   at  power                was                   considered              not             practical and                        deferred to   a            more                 suitable plant  condition.
The    LSCS      1ST program                     and                        PMT    process         determined an                       evaluation                      was                   sufficient to justify returning the valve to  service while deferring stroking of the valve  to    plant shutdown                              which        is within the guidance                             provided in  Section       4  .4  .2  of  NUREG-1482                       .          The   valve  is scheduled         to   be repaired during      the Unit       2 refueling outage                        in 2025     and                      was                  placed           on                     the forced     shutdown outage                       schedule        to   be             repaired if a           forced    outage                      of sufficient scope                     and                      duration                occurs                             prior to the refueling outage.                                    Per the evaluation,                   the valve   is required to    be            moved                     off the backseat, during       plant  shutdown                               to   prevent internal binding.                      This action               will coincide            with the closure stroke time test that will demonstrate                     the valve  would                      have            closed        in the required time, supporting      the evaluation                     conclusions                                          .

Deferral of testing to    a           more                 suitable plant condition                    because                                   testing is not            practical in the current        plant  condition                 is within the guidance                         of Section       4.4.2   of NUREG-1482                         and                       does             not require relief from       the ASME      OM    Code             requirements  if it can                                 be           demonstrated                 that the performance                                 parameters          are       not             adversely     affected. The    performance                              deficiency   is predicated on                           an                        interpretation that a             level of testing as          described   in the Code             Case           precludes  an                        analysis justifying deferral even           though               the Code            Case            explicitly states the level of testing is determined by                     the licensee's program.                               The    inspection     report does           not         justify this interpretation or      refute NUREG-1482's                           allowance                                 for deferral. Therefore, the finding and                       violation for not             meeting  the requirements    of ASME    OM   Code              Case           OMN-1,      Paragraph                       3.4  is unwarranted                                          .
Enclosure                      to     RA24-023 Page              7  of 8

Table                  1 -                    Acronyms                                                                and                           Abbreviations

Acronym/                                                                                                                                                                                  Description Abbreviation ASME                                                                                                                                                                                        American                         Society        of Mechanical                        Engineers BSRT                                                                                                                                                                                                 backseat                           relay    tool CFR                                                                                                                                                                                                                  Code             of Federal Regulations ECR                                                                                                                                                                                                                        engineering       change                               request IN                                                                                                                                                                                                                                                                Information                            Notice INPO                                                                                                                                                                                                         Institute for Nuclear             Power               Operations 1ST                                                                                                                                                                                                                                     in-service testing LSCS                                                                                                                                                                                                      LaSalle County                                 Station MOV                                                                                                                                                                                                                           motor-operated                        valve NCV                                                                                                                                                                                                                                   non-cited                  violation NRC                                                                                                                                                                                                                Nuclear            Regulatory                    Commission OE                                                                                                                                                                                                                                                operating        experience OM                                                                                                                                                                                                                                   Operations       and                      Maintenance PMT                                                                                                                                                                                                                 post-maintenance                                                    testing WO                                                                                                                                                                                                                                 work              order Enclosure                       to   RA24-023 Page               8  of 8

References
: 1.                     Letter from         Robert              Ruiz   (U.S.                    Nuclear                Regulatory                      Commission)                               to   David      P.      Rhoades (Constellation     Energy                    Generation,                         LLC),      "LaSalle    County                                   Station     -                   Integrated      Inspection Report  05000373/2024001                   and                      05000374/2024001,"                    dated        May                           13,   2023      (ADAMS Accession                            No.             ML24131A151)                .
: 2.                         LaSalle   County                                   Station      Units         1 &   2,     "lnservice Testing Program                            Plan,              Fourth         Ten-Year Interval," Revision      4  , September              23  , 2023     .

3  .                   American                         Society           of Mechanical                           Engineers,          Operations             and                      Maintenance                                           Code              Case OMN-1,       "Alternative Rules  for Preservice and                     lnservice Testing of Active Electric Motor Operated  Valve                Assemblies    in  Light-Water Reactor                  Power                  Plants."

4   .                    United          States Nuclear               Regulatory                       Commission,                                 "Guidelines for lnservice Testing at Nuclear              Power                 Plants,"    NUREG-1482,                                Revision     3  , July           2020      (ADAMS        Accession                               No.
M L20202A4 73).

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