IR 05000373/2013007: Difference between revisions

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| issue date = 06/21/2013
| issue date = 06/21/2013
| title = 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
| title = 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
| author name = Kunowski M A
| author name = Kunowski M
| author affiliation = NRC/RGN-III/DRP/B5
| author affiliation = NRC/RGN-III/DRP/B5
| addressee name = Pacilio M J
| addressee name = Pacilio M
| addressee affiliation = Exelon Nuclear, Exelon Nuclear Generation Corp
| addressee affiliation = Exelon Nuclear, Exelon Nuclear Generation Corp
| docket = 05000373, 05000374
| docket = 05000373, 05000374
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:une 21, 2013
[[Issue date::June 21, 2013]]


Mr. Michael Senior Vice President, Exelon Generation Co., LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
==SUBJECT:==
 
LASALLE COUNTY STATION, UNITS 1 AND 2, PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000373/2013007; 05000374/2013007
SUBJECT: LASALLE COUNTY STATION, UNITS 1 AND 2, PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000373/2013007; 05000374/2013007


==Dear Mr. Pacilio:==
==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.
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).
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 Commissions 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).


Sincerely,/RA/ Michael Kunowski, Chief Branch 5 Division of Reactor Projects
ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).


Docket Nos. 50-373; 50-374 License Nos. NPF-11; NPF-18  
Sincerely,
/RA/
Michael Kunowski, Chief Branch 5 Division of Reactor Projects Docket Nos. 50-373; 50-374 License Nos. NPF-11; NPF-18


===Enclosure:===
===Enclosure:===
Inspection Report 05000373/2013007; 05000374/2013007  
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 NRCs 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 licensees 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.


===w/Attachment:===
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.
Supplemental Information cc w/encl: Distribution via ListServTM Enclosure U. S. NUCLEAR REGULATORY COMMISSION 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
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-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.


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


=SUMMARY OF FINDINGS=
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.
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-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. 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=
=REPORT DETAILS=
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The activities documented in Sections
The activities documented in Sections


===.1 through .4 constituted one biennial sample of Problem Identification and Resolution (PI&R) as defined in Inspection Procedure 71152.===
===.1 through .4 constituted one biennial sample of===
 
Problem Identification and Resolution (PI&R) as defined in Inspection Procedure 71152.


===.1 Assessment of the Corrective Action Program Effectiveness===
===.1 Assessment of the Corrective Action Program Effectiveness===


====a. Inspection Scope====
====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 the licensees 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 licensees 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 licensees 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 licensees 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 licensees oversight of the CAP program.
 
During the reviews, the inspectors evaluated whether the licensees actions were in compliance with the facilitys 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 stations CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues.


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 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 event, inadequate 50.59 screenings, and identified deficiencies in design reviews during design bases events.


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.
Documents reviewed are listed in the Attachment to this report.


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.
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 issues significance, addressing such matters as regulatory compliance and reporting, and assigning any actions deemed necessary or appropriate.


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.


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


A review of specific trend evaluations did not identify any concerns.
Although the statement was correct, by itself it could imply no past operability/reportability review was performed. In particular, the inspectors noted under the ARs Operable Basis or Reportable Basis section there was no included 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.


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)."
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.


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 provide their Senior Reactor Operators with training focused on the areas of past operability/reportability and expected levels of documentation. Findings No findings were identified.
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 sites documentation expectations. The licensee also informed the inspectors the site had recently instituted corrective actions to provide their Senior Reactor Operators with training focused on the areas of past operability/reportability and expected levels of documentation.


(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.
: (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 licensees 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.
Findings No findings were identified.
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====a. Inspection Scope====
====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.
The inspectors reviewed the licensees implementation of the facilitys 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 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 implemented effectively and in a timely manner.
 
Documents reviewed are listed in the Attachment to this report.
 
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.


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.
Findings No findings were identified.


===.3 Assessment of Self-Assessments and Audits===
===.3 Assessment of Self-Assessments and Audits===


====a. Inspection Scope====
====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.
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. 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.


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.
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.


6 Enclosure
Findings No findings were identified.


===.4 Assessment of Safety-Conscious Work Environment===
===.4 Assessment of Safety-Conscious Work Environment===


====a. Inspection Scope====
====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 assessed the licensees SCWE through the reviews of the facilitys 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 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 raise 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.  
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 raise 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 licensees 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.
 
{{a|4OA6}}
{{a|4OA6}}
==4OA6 Management Meetings==
==4OA6 Management Meetings==
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===.1 Exit Meeting Summary===
===.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.
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:
ATTACHMENT:  


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=


==KEY POINTS OF CONTACT==
==KEY POINTS OF CONTACT==
Licensee 
: [[contact::G. Ford]], Regulatory Assurance Manager
: [[contact::B. Houston]], Acting Maintenance Director
: [[contact::P. Karaba]], Site Vice-President 
: [[contact::K. Lyons]], Chemistry Manager
: [[contact::J. Miller]], Senior Engineering Manager
: [[contact::K. Rusley]], Emergency Preparedness Manager
: [[contact::B. Trafton]], Operations Director
: [[contact::H. Vinyard]], Plant Manager Nuclear Regulatory Commission
: [[contact::M. Kunowski]], Chief, Branch 5, Division of Reactor Projects
: [[contact::F. Ramirez]], Resident Inspector


Attachment  
Licensee
: [[contact::G. Ford]], Regulatory Assurance Manager
: [[contact::B. Houston]], Acting Maintenance Director
: [[contact::P. Karaba]], Site Vice-President
: [[contact::K. Lyons]], Chemistry Manager
: [[contact::J. Miller]], Senior Engineering Manager
: [[contact::K. Rusley]], Emergency Preparedness Manager
: [[contact::B. Trafton]], Operations Director
: [[contact::H. Vinyard]], Plant Manager
Nuclear Regulatory Commission
: [[contact::M. Kunowski]], Chief, Branch 5, Division of Reactor Projects
: [[contact::F. Ramirez]], Resident Inspector
Attachment
 
==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
The following is a list of documents reviewed during the inspection.
: Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort.
: Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
: PLANT PROCEDURES Number Description or Title Date or Revision
: LaSalle County Generating Station Foreign Material Exclusion (FME) Improvement Plan Revision 30
: AD-AA-101-1002 Writer's Guide for Procedures and T&RM Revision 15
: EI-AA-101 Employee Concerns Program Revision 10
: EP-AA-122 Drills & Exercises Revision 11
: EP-AA-125 Emergency Preparedness Self Evaluation Process Revision 7
: LAP-100-14 Leak Reduction Program
: Revision 10
: LOA-RH-101 Unit 1 RHR Abnormal Revision 11
: LOP-FC-12, Revision 30 Drainage of the Reactor Well and Dryer/Separator Pit to Waste Collector Tank January 24, 2011
: LOP-RH-07 Shutdown Cooling System Startup, Operation and Transfer Revision 62
: LOP-RH-07 Shutdown Cooling System Startup, Operation and Transfer Revision 62
: LOP-RH-08 Shutdown Cooling System Shutdown Revision 39
: LS-AA-115 Operating Experience Program Revision 17
: LS-AA-120 Issue Identification and Screening Process Revision 14
: LS-AA-125 Corrective Action Program (CAP) Procedure Revision 17
: LS-AA-125-1002 Common Cause Analysis Manual Revision 7
: LS-AA-125-1003 Apparent Cause Evaluation Manual Revision 10
: LS-AA-125-1004 Effectiveness Review Manual Revision 5
: LS-AA-126-1006 Benchmarking Program Revision 2
: LTS-300-7 Leak Reduction and Control Program
: Revision 11
: NF-AA-430 Failed Fuel Action Plan Revision 11
: NSWP-M-02 Fabrication and Installation of Piping and Tubing Revision 4
: OP-AA-108-115 Operability Determinations (CM-1) Revision 11
: OP-AA-108-115-1002 Supplemental Consideration for On-Shift Immediate Operability Determinations (CM-1) Revision 2
: OP-LA-102-104-1002 LaSalle Station Fuel Reliability Advocacy Team (FRAT) Revision 0   
: Attachment CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or Title Date or Revision
: ACE 01248293 Loss of Shutdown Cooling Operability Determination
: ACE 01258014 LaSalle Radiation Protection Standards Decline Revision 9
: ACE 01276400 2VT50Y Fire Damper Not Inspected as Required by LaSalle Technical Requirements Manual
: ACE 1264231-04 Unexpected RB Vent RAD
: HI-HI Alarm Revision 9
: ACE 1350733 Operator Response to Alarm Results in Emergent Down power Revision 10
: ACE 1395501 Inadvertent Inactivation of Vital Door#299 Revision 10
: AR 01181536 NOS ID: Wrong Message Regarding Dose Control
: AR 01182129 NOS ID: Potential FM in DSP Buffer Zone
: AR 01182422 NOS ID: Poor Safety Behavior
: AR 01188879 Dose Outside Acceptance Criteria Week of 3/7/2011
: AR 01190600 Hot and Neutral Wires Swapped in 1C71-P009
: AR 01192068 Potential Declining Trend in RP Fundamental Performance
: AR 01193942 B.5.B Equipment Storage Area Issues
: AR 01199189 ACE Required to Address Common Cause from CCA
: AR 01200990 Multiple Failures on VE/VC Oil Cooler Solenoid Valves
: AR 01201414 Intentionally Abbreviated Maintenance-2B33-D003AS1
: AR 01205873 Lack of Urgency to Fix Long Standing Equipment Issue
: AR 01205934 Knowledge Gap with Shift Regarding Reactivity Management PI
: AR 01212687 Previously Identified Leak Still Is Not Repaired
: AR 01214495 Incomplete Actions Taken Following NSRB
: AR 01221581 PMT for 2C71-N005A Cancelled
: AR 01229347 NOS ID: Multiple Radiation Monitor Equipment Issues
: AR 01243191 Observed Fundamental Weaknesses with Site Standards
: AR 01249019 Adverse Trend in Early Warning System Shaker Failures
: AR 01255426 NOS ID: Security Shift Turnover Issues
: AR 01273159 Perform a CCA on Issues Related to SRVs
: AR 01285272 Internet Restrictions and Watch-Standing Practices
: AR 01299795 Deficiency in 50.59 for
: LOA-AP-101/201 Revision
: AR 01302336 Radiation Material Container Not Labeled in Power Block Attachment
: AR 01305694 Digital Feed Water Control ARAXIS Merge Software Not per Digital Technology Software Quality Assurance
: AR 01321248 NOS ID: Worker RP Standards
: AR 01327352 Fan Control Issue in RCA
: AR 01328005 WHR Time Limit Exceeded Needs a Review for Violation
: AR 01328871 Floor Drain and Ladder Housekeeping Issues
: AR 01328945 Small Gas Cylinder Laying on the Floor on Its Side
: AR 01329473 NOS ID: Poor Rad worker Practices in U-1 HTR Bay
: AR 01329656 Material Handling Below Standard
: AR 01335212 NRC Identified Drywell Temperature Limits Discrepancy
: AR 01341342 Valves Incorrectly Coupled
: AR 01349686 Perform ACE Regarding Rigging and Lifting Issues
: AR 01383295 CCA Requested for WANO Housekeeping Observations
: AR 01390466 NOS ID: D LaSalle RP Rated Yellow
: AR 01403323 NOS ID: D Cyber Security Elevation
: AR 01413150 Procedure Enhancement: Water Tight Door Inspection
: LMS-ZZ-04
: AR 01468691 Door 20 Would Not Energize
: AR 01471998 Switchgear 231X Transformer Cooling Fans Did Not Run
: AR 01473526 NOS ID: RFF Working O/S ZN 1 Area W/O Hardhat / Rubber Gloves
: AR 01473531 NOS ID: Pre-Outage RP Training Delta
: AR 01474523 NOS ID: Issues at D/W Bull Pen Ingress/Egress Point
: AR 01474525 NOS ID: Issues with Posted Guidance for PC Removal at DW Exit
: AR 01474978 NOS ID: Positive Control of Source Not Maintained Outside RCA
: AR 01474986 NOS ID. Adverse Trend in RP Ownership & Oversight of RW Behavior
: AR 01503409 Unit 1 Scram Caused by Loss of Off-Site Power
: AR 01503410 Unit 2 Scram Caused by Loss of Off-Site Power
: AR 01503428 138KV Line 0112 Damaged by Lighting Strike
: AR 01503449 Loss of Relay House System 2 Power
: AR 01504410 Light at Entry to TSC Did Not Initially Work- 1FPEL35
: AR 01504461 TR71 Relay Damaged by Lightning Strike to L0112
: AR 01505026 TRNG: Training Not Held as Scheduled (Force Outage) 
: Attachment
: AR 01505209 PI Server Failed
: AR 01505270 Loss of Power to Plant Process Computer Room Cabinets
: AR 01505528 PPC Room Public Lan Switch Lost Power for 35 Minutes
: AR 01505533 Power Supply Failure on the Sun Storedge Raid Array
: AR 01506138 LOOP and Dual Unit Scram Aggregate Equipment Response
: AR 01506490 NOS ID:
: IRs Were Not Generated for Computer Failures
: AR 01511792 Vibration Trend Identified on 2VT02CB
: AR 01512096 NOS ID: Switch Yard/ Relay House Below Standards and Condition
: AR 01513761 SOER 10-1 Actions Re- Scheduled For Fall, 2013 for Summer
: AR 01514293 SY: Unavailability Criteria Exceeded
: AR 01515601 Relay House South Door Lock Core Needs Repair
: AR 01515979
: LOA-TORN-001/LOA-AP-001 Entry Due to Thunderstorm Activity
: AR 01516900 Received Fire Det. Alarm Due To 12KV Power Oscillation
: AR 1049176
: UT-Inspection Needed on U2 HPCS Suction Line (NMP
: OE 29746)
: AR 1125886 Pre-CDBI Walkdown Items, 1E22-F004 and Area
: AR 1152040 EPU Design Review - HPCS Pump Runout Flow
: AR 1176385 2E51-F084 Failed IST Closure Test
: AR 1176386 2E51-F082 Failed IST Closure Test
: AR 1178053 2E22-F035 Relief Valve Failed As-Found Set Pressure Test
: AR 1180720 2E22-F004 Cannot Perform MOV Motor Boroscope Exam
: AR 1181963 NRC ID: Piping Void
: IR 1179224 Incomplete Description
: AR 1187245 U-2 HPCS PMP Suction Press HI/LO Alarm
: AR 1188381 Perform Common Cause Analysis for CDBI NCVs
: AR 1198573 1E22-N012B-SV Leaking Around Valve Stem
: AR 1198579 1E22-N012B-VV Leaking Around Valve Stem
: AR 1210566 Unit 1HPCS Water Leg Pump Degradation
: AR 1210566 Unit 1HPCS Water Leg Pump Degradation
: AR 1213610 2E22-F370B Relief Valve Needing Rebuild
: AR 1227246 Small Leak on HPCS Discharge Pressure Switch
: AR 1227254 VV System Low Flow
: AR 1227255 VV System Low Flow Attachment
: AR 1250500 NOS ID: Calculation Errors and Unclear Discussion of Methods
: AR 1278610 Foreign
: Material Found in 2D CB Pump Suction Strainer
: AR 1280595 Small Void Upstream of 2E12-F016B Following
: LOS-RX-SR1
: AR 1291131 Latent Organizational Weakness CCA
: AR 1294090 RM - NRC: Potential Violation for Use of Racklife
: AR 1299062 No HPCS Flow Indication. Show on 2E22-R603 During HPCS Pump Run
: AR 1302064 U2 HPCS Discharge Low Pressure Gage Pegged High
: AR 1309004 Replace Degraded VA Compressor
: AR 1312494 Small Void Remained Following MSO Testing of 1E12-F016B
: AR 1314172 Fire Header Through Wall Leak
: AR 1316366 SBLC Tank Temperature Below Rounds Limit
: AR 1327992 Service Water Rad High Alarm
: AR 1328673 HPCS Mon Flow to Close After
: LOS-DG-111
: AR 1330546 Relief Valve Failed As-Found Test - 1E22-F035
: AR 1333733 Small Void Upstream of 1E12-F016B During
: LOP-RH-01
: AR 1335212 NRC Identified - Drywell Temp. Limits Discrepancy
: AR 1335611 Standards Team Observations From Mids 3/2/12
: AR 1338660 Water Inside Disconnect Cabinet
: AR 1343305 Biennial Comprehensive Pump Tests Need Predefines
: AR 1351280 U1 DWEDS PP Failed To Shutdown
: AR 1366357 1C RHR Pump Discharge Pressure High Alarm
: AR 1387822 Request For Engineering Support For RWCU Isolations
: AR 1390515 RHR Discharge Check Valve 1E12-F031A Degrading
: AR 1390774 NRC Triennial Inspection Issue - UHS Fish Mortality
: AR 1393123 SWGR Temperatures Above Rounds Setpoint
: AR 1393998 IEMA: Question Related To OP EVAL 10-005
: AR 1400648 NRC Question - Seismic Interaction/Clearance - Documentation
: AR 1416141 Inadequate 10
: CFR 50.9 Screening
: AR 1418722 Annual Major Dike Inspection Findings 2012
: AR 1421327 Need Cntgcy WO Prepared to Vent 1E22-R554 if Required
: AR 1433447 CCA Needed for CSCS Low Cooling Water Flow
: AR 1434406
: NRC 50.59 Baseline Inspection Report Attachment
: AR 1461043 IEMA Question HPCS Motor Inspection EQ Requirements
: AR 1479568 Small Void Upstream of 2E12-F016B Following
: LOP-RH-01
: AR 1513810 Request Dept Eval on Refuel Floor Protection Detection
: AR 816204 Air Pocket in High Point of HPCS System Piping
: CCA 1161709-03 NRC CDBI Findings
: CCA 1271740 Operations Technical Human Performance Events November 3, 2011
: CCA 1359427 Conduct of Briefs May 17, 2012 CCA1192068 Potential Declining Trend in RP Fundamental Performance Revision 7 CCA1390869 Potential Adverse Trend- LaSalle Chemistry to Include Revision 7 EACE
: 01177034-02 2E12-F041B Fails Water Pressure Isolation Test
: EACE
: 1176385-02 IST Failure of the RCIC Vacuum Breaker Check Valves 2E51-F082/84
: EACE
: 1296372-02 2A D/G Failed to Shutdown Using Engine Stop PB
: IR 1326370 1B RR Pump Seal Cooling Flow LO Did Not Actuate When Required
: RCR 01191445 Foreign Material Leading to Fuel Failures in L1C13 and L2C13 April 28, 2011
: RCR 01221750-03 Technical Specification Post Maintenance Test Not Performed as Required Following Component Replacement June 23, 2011
: RCR 01379483-02 2012 Area for Improvement Reactor Services Performance July 26, 2012
: RCR 1019471-14 Root Cause Report: Recent SBLC Relief Valve Issues
: April 15, 2010
: RCR 1482907 Control Rod Mispositioning Event April 11, 2013 RCR1175095 L2R13 Refuel Floor Contamination Event April 11, 2011 RCR1375666 WANO 2012 Identified AFI on Contamination Controls August 28, 2012 RCR1484057 Increase Dose Rate and Airborne Iodine Levels in Various Plant areas during L2R14 Revision 10   
: Attachment OPERATING EXPERIENCE Number Description or Title Date or Revision OE18942 OE from Columbia Generating Station on Three Condensate Heat Exchangers Tripped Due to Human Error June 27, 2004
: AR 1401163 NRC ID: LPCI Inoperability During Shutdown Cooling in Mode 3
: AR 1401165 NRC ID: E12-F004A/B Generic Letter 95-07 Disposition
: RCR 01465797 Unit 2 Rod 42-19 Failure to Scram due to a Degraded Scram Solenoid Pilot Valve March 1, 2013
: AUDITS, ASSESSMENTS, AND
: SELF-ASSESSMENTS Number Description or Title Date or Revision
: AR1147400 NOS Audit: Engineering Design Control Audit Report August 17, 2011
: AR 1302162 NOS Audit: Engineering Programs and Station Blackout Audit Report April 25, 2012
: AR 01137785-02 Self-Assessment Mechanical Maintenance Productivity
: August 9, 2011
: AR 01321256-07 Self-Assessment Work Execution Preparation July 11, 2012
: AR 1438890 Radiation Monitoring Instrumentation(IP71124.05) Rx Coolant System Activity(IP 71151-BI01) January 10, 2013
: AR 1462462 Radiological Hazard Assessment and Exposure Controls-NRC-IP 71124.01 Occupational ALARA Planning and Controls-NRC
: IP 71124.02 April 17, 2013
: AR 1451773-04 Pre NRC Assessment of
: IP 71130.04 Security Equipment Performance, Testing and Maintenance March 27, 2013
: AR 1425646-02
: NEI 08-07 Objective (08-14) December 13, 2012
: AR 1324825 2012 Employee Concerns Program Assessment December 20, 2012
: CONDITION REPORTS GENERATED DURING INSPECTION Number Description or Title Date or Revision None Attachment MISCELLANEOUS Number Description or Title Date or Revision M-95 P&ID High Pressure Cores Spray (Unit 1) AP M-141 P&ID High Pressure Cores Spray (Unit 2) AS
: EC 353154 ASME Code Case
: OMN-2 Applicability Evaluation Revision 0
: WO 1336544-02 MM Set Point Test Removed Valve and Ship to Vendor August 9, 2011
: TQ-AA-1002-F004 Curriculum Review Committee Minutes: Meeting held on 01/17/12 January 17, 2012
: AT 1266496 Training Effectiveness Evaluation Worksheet (TEEW) 
: Attachment
==LIST OF ACRONYMS==
: [[USED]] [[]]
: [[ACE]] [[Apparent Cause Evaluation]]
: [[ADAMS]] [[Agencywide Document Access Management System]]
: [[AR]] [[Action Request]]
: [[CAP]] [[Corrective Action Program]]
: [[CCE]] [[Common Cause Evaluation]]
: [[CFR]] [[Code of Federal Regulations]]
: [[ECP]] [[Employee Concerns Program]]
: [[FME]] [[Foreign Material Exclusion]]
: [[HPCS]] [[High Pressure Core Spray]]
: [[IMC]] [[Inspection Manual Chapter]]
: [[IR]] [[Issue Report]]
: [[IST]] [[In-Service Test]]
: [[LPCI]] [[Low Pressure Coolant Injection]]
: [[MRC]] [[Management Review Committee]]
: [[NCV]] [[Non-Cited Violation]]
: [[NOS]] [[Nuclear Oversight]]
: [[NRC]] [[]]
: [[U.S.]] [[Nuclear Regulatory Commission]]
: [[NUREG]] [[Nuclear Regulatory Guide]]
: [[OE]] [[Operating Experience]]
: [[PA]] [[Public Address]]
: [[PARS]] [[Publicly Available Records System]]
: [[PI&R]] [[Problem Identification and Resolution]]
: [[RCE]] [[Root Cause Evaluation]]
: [[RHR]] [[Residual Heat Removal]]
: [[SCAQ]] [[Significant Condition Adverse to Quality]]
: [[SCWE]] [[Safety-Conscious Work Environment]]
: [[SDC]] [[Shutdown Cooling]]
SDP Significance Determination Process
S/N Serial Number
: [[SOC]] [[Station Oversight Committee]]
: [[SRA]] [[Senior Reactor Analyst]]
: [[SSC]] [[Structure, System, or Component]]
TS Technical Specification
WS Service Water
M. Pacilio    -2-
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 cc w/encl: Distribution via ListServTM 
}}
}}

Latest revision as of 16:45, 4 November 2019

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  Constellation icon.png
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

une 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 Commissions 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 NRCs 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 licensees 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-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.

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

OTHER ACTIVITIES

4OA2 Problem Identification and Resolution

The activities documented in Sections

.1 through .4 constituted one biennial sample of

Problem Identification and Resolution (PI&R) 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 selected CAP program 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 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 licensees 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 licensees 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 licensees oversight of the CAP program.

During the reviews, the inspectors evaluated whether the licensees actions were in compliance with the facilitys 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 stations 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 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 issues 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 ARs Operable Basis or Reportable Basis section there was no included 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 sites documentation expectations. The licensee also informed the inspectors the site had recently instituted corrective actions to provide 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 licensees 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 licensees implementation of the facilitys 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 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 implemented effectively and in a timely manner.

Documents reviewed are listed in the Attachment to this report.

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 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. 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.

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

The inspectors assessed the licensees SCWE through the reviews of the facilitys 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 raise 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 licensees 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