IR 05000373/2013007

IR 05000373-13-007 & 05000374-13-007; Exelon Generating Company, LLC; 05/13-31/2013; LaSalle County Station, Unit 1 and 2, Problem Identification and Resolution Inspection Report

ML13172A188
Person / Time
Site:	LaSalle
Issue date:	06/21/2013
From:	Michael Kunowski NRC/RGN-III/DRP/B5
To:	Pacilio M Exelon Nuclear, Exelon Nuclear Generation Corp
References
IR-13-007
Download: ML13172A188 (22)

Text

June 21, 2013

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2, PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000373/2013007;

05000374/2013007

Dear Mr. Pacilio:

On May 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) inspection at LaSalle County Station, Units 1 and 2.

The enclosed report documents the inspection results, which were discussed on May 31, 2013, with the Plant Manager, Mr. Harold Vinyard, and other members of your staff. The inspection was an examination of activities conducted under your license as they relate to problem identification and resolution and compliance with the Commission's rules and regulations and with the conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel. Based on the inspection sample, the inspection team concluded that the implementation of the corrective action program and overall performance related to identifying, evaluating, and resolving problems at LaSalle County Station was effective. Licensee-identified problems were entered into the corrective action program at a low threshold. Problems were effectively prioritized and evaluated commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner commensurate with their importance to safety and addressed the identified causes of problems. Lessons learned from industry operating experience were generally reviewed and applied when appropriate. Audits and self-assessments were effectively used to identify problems and appropriate actions. Based on the results of this inspection, no findings were identified. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/ Michael Kunowski, Chief Branch 5 Division of Reactor Projects

Docket Nos. 50-373; 50-374 License Nos. NPF-11; NPF-18

Enclosure:

Inspection Report 05000373/2013007; 05000374/2013007 w/Attachment: Supplemental Information

REGION III Docket Nos: 50-373; 50-374 License Nos: NPF-11; NPF-18

Report No: 05000373/2013007; 05000374/2013007 Licensee: Exelon Generating Company, LLC Facility: LaSalle County Station, Units 1 and 2 Location: Marseilles, IL Dates: May 13 - 31, 2013 Inspectors: C. Phillips, Project Engineer - Team Lead J. Corujo-Sandin, Reactor Engineer B. Jose, Reactor Engineer I. Hafeez, Reactor Engineer

Approved by: Michael Kunowski, Chief Branch 5 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000373/2013007; 05000374/2013007; (05/13-31/13); LaSalle County Station, Units 1 and 2; Biennial Baseline Inspection of the Identification and Resolution of Problems. This team inspection was performed by four regional inspectors. There were no findings of significance in this inspection. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in Nuclear Regulatory Guide (NUREG) 1649, "Reactor Oversight Process," Revision 4. Identification and Resolution of Problems Overall, the corrective action program (CAP) was appropriately identifying, evaluating, and correcting issues. Issues were generally being identified at a low threshold, evaluated appropriately, and corrected in the CAP. Overall performance in prioritization and evaluation of issues was acceptable. Issues were appropriately screened by both the Station Ownership Committee (SOC) and the Management Review Committee and the inspectors had no concerns with those items assigned an apparent cause evaluation or root cause evaluation. Corrective actions were generally appropriate for the identified issues. Those corrective actions addressing selected NRC documented violations were also generally effective and timely. The inspectors' review going back five years of the licensee's efforts to address issues with the High Pressure Core Spray (HPCS) system did not identify any negative trends or inability by the licensee to address long-term issues. In general, Operating Experience (OE) was effectively utilized at the station. The inspectors observed that OE was discussed as part of the daily station and pre-job briefings. Industry OE was effectively disseminated across the various plant departments and no issues were identified during the inspectors' review of licensee OE evaluations. The inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying issues and enhancement opportunities at an appropriate threshold level. The inspectors observed that CAP items had been initiated for issues identified through Nuclear Oversight (NOS) audits and self-asse ssments. The inspectors reviewed the self-assessment performed on the CAP and found no issues and generally agreed with the overall results and conclusions drawn. The inspectors determined that plant staff were aware of the importance of having a strong safety-conscious work environment (SCWE) and expressed a willingness to raise safety issues. No one interviewed had experienced retaliation for safety issues raised or knew of anyone who had failed to raise issues because of fear of retaliation. All persons interviewed had an adequate knowledge of the CAP process. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable SCWE.

REPORT DETAILS

4OA2 Problem Identification and Resolution

The activities documented in Sections

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the licensee's CAP implementing procedures and attended selected CAP program meetings to assess the implementation of the CAP by site personnel.

The inspectors reviewed risk and safety-significant issues in the licensee's CAP since the last NRC PI&R inspection in 2011. The items selected ensured an adequate review

of issues across the 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 CAP items generated as a result of licensee staff performance in daily plant activities. The inspectors also reviewed CAP items and a selection of completed investigations from the licensee's various investigation methods, including apparent (ACE), common (CCE) and root cause (RCE) evaluations. The inspectors performed a more extensive review of the safety-related High Pressure Core Spray (HPCS) system. This review consisted of a search of related issues identified in the CAP in the last five years, recommendations by the resident inspector staff, discussions with the system engineer, and other appropriate licensee staff. In addition, the inspectors performed system walkdowns of the HPCS system components.

The intent of the review was to assess the licensee's efforts in addressing previously identified concerns. The inspectors attended meetings of the Station Oversight Committee (SOC) and Management Review Committee (MRC) to observe how issues were being screened and evaluated and to obtain insights into the licensee's oversight of the CAP program.

During the reviews, the inspectors evaluated whether the licensee's actions were in compliance with the facility's CAP and 10 CFR Part 50, Appendix B requirements. Specifically, the inspectors evaluated if licensee personnel were identifying plant issues at the proper threshold, entering the plant issues into the station's CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues.

The inspectors also assessed whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also reviewed the timeliness and effectiveness of corrective actions for selected issue reports (IRs), completed investigations, and NRC findings, including non-cited violations (NCVs). Items selected included, but were not limited to, engineering issues, such as the impact to the low pressure coolant injection (LPCI) system during Mode 3 operation of the shutdown cooling function of residual heat removal (RHR), potentially negative system interactions during a seismic 3 Enclosure event, inadequate 50.59 screenings, and identified deficiencies in design reviews during design bases events. Documents reviewed are listed in the Attachment to this report. b. Assessment

(1) Effectiveness of Problem Identification Issues were generally being identified at a low threshold, evaluated appropriately, and corrected in the CAP. Workers were familiar with the CAP and felt comfortable raising concerns. This was evident by the large number of CAP items generated annually, which were reasonably distributed across the various departments. A shared, computerized database was used for creating individual reports and for subsequent management of the processes of issue evaluation and response. These processes included determining the issue's significance, addressing such matters as regulatory compliance and reporting, and assigning any actions deemed necessary or appropriate.

The inspectors determined that the station was generally effective at trending low level issues to prevent larger issues from developing.

A review of specific trend evaluations did not identify any concerns.

Findings No findings were identified.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors observed that the majority of issues identified were low-level and were either closed to trend or at a level appropriate for a condition evaluation. Issues were being appropriately screened by both the SOC and MRC and the inspectors had no concerns with those items assigned an ACE, CCE, or RCE. There were no items in the operations, engineering, or maintenance backlogs that were risk-significant, individually or collectively. The inspectors determined that the technical adequacy and depth of evaluation for the RCEs and ACEs reviewed were sufficient to ensure that established corrective actions would be effective and that there was appropriate consideration of risk in prioritizing issues.`

Observations Lack of Documentation for Past Operability and Reportability Determinations While reviewing action requests (ARs) generated during previous outages, the inspectors identified deficiencies in the way structures, systems, and components (SSCs), which had failed their required in-service test (IST) requirements, were documented for past operability/reportability. The inspectors found examples where the operability bases were justified as "-not required to be operable in current mode (5)."

Although the statement was correct, by itself it could imply no past operability/reportability review was performed. In particular, the inspectors noted under the AR's 'Operable Basis' or 'Reportable Basis' section there was no included 4 Enclosure explanation discussing the impact the failed component may have had on the system while the affected system was required operable during the previous operating cycle. After discussing the matter with the licensee the inspectors neither identified a violation of any requirement, nor believed the operability of any of the affected systems had been impacted. However, the lack of documented information required the licensee to discuss the issue with the personnel originally involved in order to ascertain what had occurred when the issue was originally identified, and ensure past operability/reportability had been considered. The resident staff had raised similar concerns to the licensee in the recent past. The inspectors discussed this concern with the licensee, which acknowledged that because of the lack of documentation, the identified examples were below the site's documentation expectations. The licensee also informed the inspectors the site had recently instituted corrective actions to pr ovide their Senior Reactor Operators with training focused on the areas of past operability/reportability and expected levels of documentation.

Findings No findings were identified.

(3) Effectiveness of Corrective Actions Corrective actions were appropriate for the identified issues. Those corrective actions addressing selected NRC documented violations were also effective and timely. The inspectors' review of the previous five years of the licensee's efforts to address issues with the HPCS system did not identify any negative trend or inability by the licensee to address long term issues.

Findings No findings were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensee's implementation of the facility's operating experience (OE) program. Specifically, the inspectors reviewed OE program procedures, observed daily meetings for the use of OE information, and reviewed completed evaluations of OE issues and events. The intent was to determine if 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 licensee's 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 implemented effectively and in a timely manner. Documents reviewed are listed in the Attachment to this report.

5 Enclosure b. Assessment In general, OE was effectively utilized at the station. The inspectors observed that OE was discussed as part of the daily station and pre-job briefings. Industry OE was effectively disseminated across the various plant departments and 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 RCEs and ACEs was appropriate and adequately considered. The inspectors noted that station procedures required, in particular, that most formal OE-related items entered into the CAP were required to be screened and evaluated for applicability at the station within 60 days. Further, OE evaluations for items applicable at the station were to be evaluated and closed with corrective actions within 60 days. The inspectors did not identify any instances where these OE review requirements were not met. Generally, OE that was applicable to the station was thoroughly evaluated and actions were taken to address any issues that resulted from the evaluations in a timely manner. Findings No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors assessed the licensee staff's 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. The inspectors reviewed Nuclear Oversight (NOS) audits, departmental self-assessments, and departmental performance assessment reports.

Documents reviewed are listed in the Attachment to this report. b. Assessment The inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying issues and enhancement opportunities at an appropriate threshold level. The audits and self-assessments were completed by personnel knowledgeable in the subject area, and the NOS audits were thorough and critical. The inspectors observed that CAP items had been initiated for issues identified through the NOS audits and self-assessments. The inspectors reviewed the self-assessment performed on the CAP and found no issues and generally agreed with the overall results and conclusions drawn.

Findings No findings were identified.

6 Enclosure

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

The inspectors assessed the licensee's SCWE through the reviews of the facility's Employee Concerns Program (ECP), implementing procedures, discussions with ECP coordinators, interviews with personnel from various departments, and reviews of IRs.

The inspectors also reviewed the results of licensee safety culture surveys.

The inspectors also reviewed selected ECP case files from 2011 to 2013 involving potential cases of harassment and intimidation for raising safety issues. Documents reviewed are listed in the Attachment to this report. b. Assessment The inspectors determined that the plant staff were aware of the importance of having a strong SCWE and expressed a willingness to ra ise safety issues. No one interviewed had experienced retaliation for safety issues raised or knew of anyone who had failed to raise issues due to a fear of retaliation. All persons interviewed had an adequate knowledge of the CAP process. These results were similar with the findings of the licensee's safety culture surveys. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable SCWE. The inspectors determined that the ECP process was being effectively implemented.

Findings No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On May 31, 2013, the inspectors presented the inspection results to Mr. Vinyard and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors returned to the licensee the results of the 2009 safety culture survey, which was the only item considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

G. Ford, Regulatory Assurance Manager

B. Houston, Acting Maintenance Director

P. Karaba, Site Vice-President

K. Lyons, Chemistry Manager

J. Miller, Senior Engineering Manager

K. Rusley, Emergency Preparedness Manager

B. Trafton, Operations Director

H. Vinyard, Plant Manager

Nuclear Regulatory Commission

M. Kunowski, Chief, Branch 5, Division of Reactor Projects

F. Ramirez, Resident Inspector

Attachment

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection.

Inclusion on this list does