ML19311C536

Integrated Inspection Report 05000373/2019003 and 05000374/2019003

ML19311C536
Person / Time
Site:	LaSalle
Issue date:	11/07/2019
From:	Kenneth Riemer NRC/RGN-III/DRP/B1
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2019003
Download: ML19311C536 (24)

See also: IR 05000373/2019003

Text

November 7, 2019

Mr. Bryan C. Hanson

Senior VP, Exelon Generation Company, LLC

President and CNO, Exelon Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: LASALLE COUNTY STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION

REPORT 05000373/2019003 AND 05000374/2019003

Dear Mr. Hanson:

On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an

inspection at LaSalle County Station, Units 1 and 2. On October 9, 2019, the NRC inspectors

discussed the results of this inspection with Mr. Phil Hansett, Plant Manager, and other

members of your staff. The results of this inspection are documented in the enclosed report.

Two findings of very low safety significance (Green) are documented in this report. Two of

these findings involved violations of NRC requirements. We are treating these violations as

non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or significance or severity of the violations documented in this

inspection report, you should provide a response within 30 days of the date of this inspection

report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional

Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector

at LaSalle.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a

response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,

Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the

NRC Resident Inspector at LaSalle.

B. Hanson -2-

This letter, its enclosure, and your response (if any) will be made available for public inspection

and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document

Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for

Withholding.

Sincerely,

/RA/

Kenneth R. Riemer, Chief

Branch 1

Division of Reactor Projects

Docket Nos. 05000373 and 05000374

License Nos. NPF-11 and NPF-18

Enclosure:

As stated

cc: Distribution via LISTSERV

ML19311C536

x Non-Sensitive x Publicly Available

x SUNSI Review

Sensitive Non-Publicly Available

OFFICE RIII

NAME KRiemer:bw

DATE 11/7/2019

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Numbers: 05000373 and 05000374

License Numbers: NPF-11 and NPF-18

Report Numbers: 05000373/2019003 and 05000374/2019003

Licensee: Exelon Generation Company, LLC

Facility: LaSalle County Station, Units 1 and 2

Location: Marseilles, IL

Inspection Dates: July 01, 2019 to September 30, 2019

Inspectors: M. Garza, Emergency Preparedness Inspector

J. Havertape, Resident Inspector

C. Phillips, Project Engineer

D. Sargis, Resident Inspector

W. Schaup, Senior Resident Inspector

C. St. Peters, Reactor Engineer

R. Zuffa, Illinois Emergency Management Agency

Approved By: Kenneth R. Riemer, Chief

Branch 1

Division of Reactor Projects

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees

performance by conducting an integrated inspection at LaSalle County Station, Units 1 and 2 in

accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs

program for overseeing the safe operation of commercial nuclear power reactors. Refer to

https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Failure to Comply with National Fire Protection Association 13, "Standard for the Installation of

Sprinkler Systems," Requirements During Installation of the Unit 1 Cable Spreading Room

Preaction Fire System

Cornerstone Significance Cross-Cutting Report

Aspect Section

Mitigating Green [P.1] - 71111.05Q

Systems NCV 05000373,05000374/2019003-01 Identification

Open/Closed

The inspectors identified a finding of very low safety significance (Green) and an associated

non-cited violation of the Unit 1 License Condition C.25, and Unit 2 License Condition C.15,

Fire Protection Program, for the failure to install the cable spreading room preaction fire

suppression system in accordance with National Fire Protection Association (NFPA) 13,

Standard for the Installation of Sprinkler Systems, 1976 Edition. Specifically, the licensee

failed to provide a preaction fire suppression system that complied with Section 3-10.2.1 of

NFPA 13. The inspectors determined that the written instructions to drain the preaction fire

protection piping allowed water to remain in the system for prolonged periods. Water

remaining in the system led to a thru-wall leak rending the fire suppression system in the

cable spreading room inoperable for 9 days during repairs.

Failure to Implement the Primary Containment Leakage Rate Testing Program for Traversing

Incore Probes System Containment Isolation Valve 2C51-J004C

Cornerstone Significance Cross-Cutting Report

Aspect Section

Barrier Integrity Green [H.6] - Design 71152

NCV 05000374/2019003-02 Margins

Open/Closed

The inspectors identified a finding of very low safety significance (Green) and an associated

non-cited violation of Technical Specification 5.5.13, Primary Containment Leakage Rate

Testing Program, for the licensee's failure to perform a cause determination and identify

corrective actions that focus on those activities that can eliminate the identified cause of a

failure with appropriate steps to eliminate recurrence for a failed Type C leak rate test.

Specifically, after repeated Type C leak rate failures of the traversing incore probe system 2C

isolation valve 2C51-J004C, the licensee neither performed a cause determination nor

took corrective actions.

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Additional Tracking Items

Type Issue Number Title Report Section Status

LER 05000374/2018-001-00 LER 2018-001-00 For 71153 Closed

LaSalle County Station, Unit

2, Manual Reactor Scram

due to Main Condenser

Vacuum Degradation

LER 05000374/2018-001-01 LER 2018-001-01 for 71153 Closed

LaSalle County Station, Unit

2, Manual Reactor Scram

due to Main Condenser

Vacuum Degradation

LER 05000373/2017-007-00 Low Pressure Core Spray 71153 Closed

System Inoperable Due to

Loss of Cooling

3

PLANT STATUS

Unit 1 began the inspection period at rated thermal power. On September 14, 2019, the unit

was down powered to approximately 77 percent to support various surveillance tests and a rod

pattern adjustment. The unit was returned to rated thermal power on September 15, 2019, and

remained at or near rated thermal power for the reminder of the inspection period.

Unit 2 began the inspection period at rated thermal power. On July 24, 2019, in response to

receiving a half close signal to the 2C main steam isolation valve, the unit was down powered to

85 percent to mitigate the transient to the plant if the valve received the other close signal. On

July 25, 2019, while troubleshooting the 2C main steam isolation valve, the valve closed and the

licensee further down powered the unit to 75 percent to meet requirements in the station's

Technical Specifications. Later the same day, the unit was further down powered to 40 percent

to perform repairs on the 2C main steam isolation valve. The unit was returned to full power on

July 26, 2019. On September 7, 2019, the unit was down powered to approximately 75 percent

to support various surveillance tests and a rod pattern adjustment. The unit was returned to

rated thermal power on September 8, 2019, and remained at or near rated thermal power for

the reminder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in

effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with

their attached revision histories are located on the public website at http://www.nrc.gov/reading-

rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared

complete when the IP requirements most appropriate to the inspection activity were met

consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection

Program - Operations Phase. The inspectors performed plant status activities described in

IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem

Identification and Resolution. The inspectors reviewed selected procedures and records,

observed activities, and interviewed personnel to assess licensee performance and compliance

with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Summer Readiness Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated summer readiness of offsite and alternate alternating

current (AC) power systems.

71111.04Q - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) Unit 1 standby liquid control system on July 17, 2019

(2) Unit 2 Division 3 emergency diesel generator on August 9, 2019

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(3) Unit 1 Division 2 emergency diesel generator during maintenance on the Division 1

emergency diesel generator on September 12, 2019

71111.04S - Equipment Alignment

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the

Unit 1 high pressure core spray system on September 30, 2019.

71111.05Q - Fire Protection

Quarterly Inspection (IP Section 03.01) (5 Samples)

The inspectors evaluated fire protection program implementation in the following selected

areas:

(1) Fire Zone 4D1, auxiliary building, elevation 749', Unit 1 cable spreading room on

July 5, 2019

(2) Fire Zone 2E, reactor building, elevation 761', Unit 1 general area and reactor water

cleanup pump cubicle on July 5, 2019

(3) Fire Zone 4D2, auxiliary building, elevation 749', Unit 2 cable spreading room on

July 9, 2019

(4) Fire Zone 4E3, auxiliary building, elevation 731', Unit 1 Division 2 switchgear room on

July 31, 2019

(5) Fire Zone 4E2, auxiliary building, elevation 731', Unit 1 auxiliary electrical equipment

room on July 31, 2019

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 02.02a.) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Unit 1 cable spreading room and auxiliary electric equipment room

71111.07A - Heat Sink Performance

Annual Review (IP Section 02.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) Unit 1 high pressure core spray diesel generator heat exchanger

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71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(2 Samples)

(1) The inspectors observed and evaluated licensed operator performance in the control

room during unexpected closure of the 2C main steam isolation valve on

July 25, 2019.

(2) The inspectors observed and evaluated licensed operator performance in the control

room during a rod sequence exchange and main steam line isolation testing on

September 7, 2019.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated out of the box examination ESG 126 on

August 6, 2019.

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness Inspection (IP Section 02.01) (4 Samples)

The inspectors evaluated the effectiveness of routine maintenance activities associated with

the following equipment and/or safety significant functions:

(1) Unit 1 high pressure core spray on July 1, 2019

(2) Unit 2 reactor recirculation system following identification of flow control valve bearing

degradation in L2R17

(3) Unit 2 control rod drive system

(4) Unit 1 scoping of safety-related valves into the Generic Letters 89-10 and 96-05

program

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent work

activities:

(1) risk assessment performed for crane near offsite power lines, Units 1 and 2

containment structures and Units 1 and 2 hardened vents on August 12, 2019

(2) planned online Yellow risk on both Units 1 and 2 during maintenance to the unit

common diesel generator on September 9, 2019

(3) planned online Yellow risk during maintenance on the high pressure core spray diesel

generator on September 23, 2019

6

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 02.02) (6 Samples)

The inspectors evaluated the following operability determinations and functionality

assessments:

(1) operability of 1B21-F065A and 1B21-F065B, Unit 1 feedwater primary containment

isolation valves, with a leak on line 1FW011A, Unit 1 reactor water cleanup return line

(2) operability of Unit 2 reactor water cleanup leak detection system due to high

temperature alarm in the 'A' reactor water cleanup heat exchanger room

(3) operability of the Unit 2A flow control valve and recirculation loop with the flow control

valve locked up for hydraulic system maintenance

(4) operability of Divisions 1 and 2 diesel generators with heat gain from the diesel

engine and the diesel generator

(5) environmental qualification of 1G33-F040, Unit 1 reactor water cleanup return primary

containment isolation valve

(6) operability of the Unit 2 cable spreading room preaction fire system with a thru-wall

leak

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

(2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Unit 1 Division 3 emergency core cooling system room cooler replacement under

Engineering Change 622652

(2) Unit 1 reactor water cleanup system feedwater return line leak repair and addition of

drain ports under IT-7000-M-PP-04B

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the following post maintenance tests:

(1) Unit 1 reactor water cleanup system following class 2 piping repair of feedwater return

line, 1FW11A, on July, 29, 2019

(2) Unit 1 reactor core isolation cooling pump after maintenance September 5, 2019

(3) common diesel generator following cooling water maintenance window on

September 12, 2019

(4) Unit 1 high pressure core spray diesel generator heat exchanger on

September 26, 2019

(5) Unit 1 Division 3 diesel generator on September 27, 2019

7

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01) (1 Sample)

(1) Unit 0 common diesel generator operability test attachment 0-Idle on August 14, 2019

Inservice Testing (IP Section 03.01) (2 Samples)

(1) Unit 2A residual heat removal pump biennial comprehensive in-service test on

August 15, 2019

(2) Unit 1 standby gas treatment system operability and in-service test on

September 7, 2019

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated the following submitted Emergency Action Level and

Emergency Plan changes:

• Evaluation 18-45, Exelon Nuclear Standardized Radiological Emergency

Plan, Revision 30

This evaluation does not constitute NRC approval.

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)

(1) Unit 1 (07/01/2018 - 06/30/2019)

(2) Unit 2 (07/01/2018 - 06/30/2019)

MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)

(1) Unit 1 (07/01/2018 - 06/30/2019)

(2) Unit 2 (07/01/2018 - 06/30/2019)

MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)

(1) Unit 1 (07/01/2018 - 06/30/2019)

(2) Unit 2 (07/01/2018 - 06/30/2019)

8

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program

(CAP) related to the following issues:

(1) Action Request 1136071, Potential Non-Conservative Technical Specification for

Diesel Generator Fuel Oil

(2) Action Request 4223654, 2C51-J004C Repair Scope Add

71153 - Follow-up of Events and Notices of Enforcement Discretion

Event Report (IP Section 03.02) (2 Samples)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000373/2017-007-00, Low Pressure Core Spray System Inoperable Due to

Loss of Cooling (ADAMS Accession: ML17230A288)

The inspectors determined that it was not reasonable to foresee or correct the cause

discussed in the LER therefore no performance deficiency was identified. The

inspectors also concluded that no violation of NRC requirements occurred.

(2) LER 05000374/2018-001-00 and LER 05000374/2018-001-01, Manual Reactor Scram Due to Main Condenser Vacuum Degradation (ADAMS Accession:

ML 18303A190)

The circumstances surrounding this LER are documented in report Section 71153.

This LER was closed as a finding (05000374/2019001-02) in NRC Integrated

Inspection Report 2019001.

OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants

Operation of an Independent Spent Fuel Storage Installation at Operating Plants (1 Sample)

(1) The inspectors evaluated the licensees operation of the independent spent fuel

storage installation from July 8 to July 12, 2019. Specifically, the inspectors

evaluated:

• the material, and radiological condition of the ISFSI and loaded storage casks

through reviewing periodic structural evaluation, and performing and reviewing

independent and the licensees radiological surveys on July 11, 2019

• a heavy lift of the loaded transfer cask from the spent fuel pool to the cask

processing area on July 9, 2019

• welding of the root pass of Multi-Purpose Canister (MPC) No.68-598 lid-to-

shell weld on July 10, 2019

• non-destructive evaluations, including helium leak testing, of the lid to shell

and port cover welds for MPC No.68-598 on July 9-11, 2019

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• processing of MPC No.68-598 for storage on July 10-11, 2019, including

removal of bulk water, drying using forced helium dehydration, and backfill

with helium

• the fuel selection for MPC No.68-598, loaded on July 9, 2019

• changes to the 72.212 report and changes screened and evaluated using

10 CFR 72.48

INSPECTION RESULTS

Failure to Comply with National Fire Protection Association 13, Standard for the Installation

of Sprinkler Systems, Requirements During Installation of the Unit 1 Cable Spreading Room

Preaction Fire System

Cornerstone Significance Cross-Cutting Report

Aspect Section

Mitigating Green [P.1] - 71111.05Q

Systems NCV 05000373,05000374/2019003-01 Identification

Open/Closed

The inspectors identified a finding of very low safety significance (Green) and an associated

non-cited violation of the Unit 1 License Condition C.25, and Unit 2 License Condition C.15,

Fire Protection Program, for the failure to install the cable spreading room preaction fire

suppression system in accordance with National Fire Protection Association (NFPA) 13,

Standard for the Installation of Sprinkler Systems, 1976 Edition. Specifically, the licensee

failed to provide a preaction fire suppression system that complied with Section 3-10.2.1 of

NFPA 13. The inspectors determined that the written instructions to drain the preaction fire

protection piping allowed water to remain in the system for prolonged periods. Water

remaining in the system led to a thru-wall leak rending the fire suppression system in the

cable spreading room inoperable for 9 days during repairs.

Description:

On July 1, 2019, the main control room received a fire alarm for the Unit 1 cable spreading

room starting both diesel driven fire pumps. Equipment operators dispatched to the cable

spreading room determined that the fire alarm was invalid but discovered a leak from the

cable spreading room preaction fire suppression system. The cable spreading room

preaction suppression system was isolated to stop the leak. The licensee entered the

appropriate fire impairments for the cable spreading room preaction fire suppression system

being out of service and instituted the required fire watch. The licensee documented this in

the corrective action program as Action Request (AR) 4261004.

The licensee determined that a faulty detector caused the spurious fire alarm. By design, the

alarm charged the preaction fire suppression piping, normally dry, with water resulting in the

discovery of the thru-wall leak in the piping. To address the faulty detector, the licensee

replaced the detector and attempted to drain the fire suppression system using the NFPA

code-required system main drain located near the deluge valve. The licensee determined the

leak was a 3/8-inch hole caused by corrosion through the 4-inch diameter main supply

header that is made of carbon steel. The licensee replaced the affected piping along with an

additional 6 feet of corroded piping identified during extent of condition inspections. During

replacement of the piping, the piping showed evidence that standing water had been in

the lower half of the piping for a significant length of time. The licensee restored the cable

spreading room preaction fire system to service and exited all applicable Technical

10

Requirements Manual actions. Additionally, the licensee determined that the thru-wall leak in

the pipe would not have impacted the ability of the fire protection system to perform its

function.

The inspectors reviewed operating experience associated with spurious actuation and

inadequate draining of preaction fire systems. The inspectors noted that Information Notice 2013-06 discussed a previous issue at LaSalle station pertaining to inadequate

draining of the preaction fire system in the chemistry overlab area. The draining location

used during the flow surveillance was such that portions of the system were not properly

drained. This condition lead to the piping corroding excessively and sediment build up

that clogged the sprinkler piping and spray nozzles.

The inspectors discussed fire protection system restoration and post-maintenance testing

with the shift manager. Following completion of detector and piping repairs, the licensee

intended to perform a 30 psi system leak tightness check using the deluge supervisory air

compressor as the pressure source. The inspectors raised a concern that because the main

supply header dropped in elevation upon entering the cable spreading room and was lower in

elevation than the system drain valve, the system could not have been completely drained

following system reset from the spurious actuation. The inspectors expressed that, as

documented in Information Notice 2013-06, standing water in preaction piping may lead to

significant corrosion. The licensee documented the inspectors' concerns in the corrective

action program as AR 4261784. In response to the discussion with the inspectors, the

licensee used an alternate method to drain the system by removing low point pipe caps on

the 3/4-inch nozzle spray lines to completely drain all portions of the system.

Additionally, the inspectors walked down the Unit 2 cable spreading room fire suppression

systems and noted evidence of thru-wall leak in the Unit 2 cable spreading room fire

suppression system piping. The licensee documented in the corrective action program as

AR 4262877. The licensee performed an operability evaluation and determined that the

thru-wall leak in the pipe would not have impacted the ability of the fire protection system

to perform its function.

The inspectors reviewed licensee's commitments in their fire protection report and

determined that the licensee was committed to NFPA 13, Standard for the Installation of

Sprinkler Systems, 1976 Edition. The inspectors noted that Section 3-10.2 System or Main

Drain Connections and Drain Valves, Part 3-10.2.1 required that Provisions shall be made

to properly drain all parts of the system. Contrary to this requirement, the inspectors noted

that operating procedures used to reset the cable spreading room preaction system following

a spurious actuation, as well as procedures to functionally test the system, directed the

operators to use the main drain valve to remove water from the system. The inspectors

determined that these procedures would not drain all the preaction piping and would lead to

corrosion consistent with that seen on the removed sections of fire protection supply header.

The inspectors discussed their findings with the licensee who documented them in the

corrective action program as AR 4262090.

Corrective Actions: The licensee planned to revise station procedures to ensure adequate

draining of the preaction fire system piping.

Corrective Action Reference: AR 4261784

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Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to provide a preaction

fire suppression system that complied with Section 3 -10.2.1 of NFPA-13 was a performance

deficiency. Specifically, written instructions were such that water remained in the system for

prolonged periods resulting in a thru-wall leak due to excessive corrosion.

Screening: The inspectors determined the performance deficiency was more than minor

because it was associated with the Protection Against External Factors attribute of the

Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure

the availability, reliability, and capability of systems that respond to initiating events to prevent

undesirable consequences. The failure to comply with NFPA 13 provisions for preaction

sprinkler installation led to standing water in a dry pipe fire system and a thru-wall leak.

Therefore, there was an adverse effect on the protection against external factors cornerstone

attribute.

Significance: The inspectors assessed the significance of the finding using Appendix F, Fire

Protection and Post - Fire Safe Shutdown SDP. The inspectors determined that the finding

category was Fixed Fire Protection Systems, and the cable spreading room preaction fire

system does not comply with NFPA 13, Installation of Sprinkler Systems, 1976 Edition.

Specifically, the cable spreading room preaction fire system supply piping does not comply

with Section 3-10.1.3 in that the system could not be drained to comply with the requirements

of Section 3-10.2. The fire protection piping leak did not result in a loss of function; therefore,

it meets the definition of low degradation per IMC 0609 App F, Attachment 2, resulting in the

finding screening as having very low safety significance (Green).

Cross-Cutting Aspect: P.1 - Identification: The organization implements a corrective action

program with a low threshold for identifying issues. Individuals identify issues completely,

accurately, and in a timely manner in accordance with the program. Specifically, operations

personnel routinely drained the preaction fire system with the deluge valve without identifying

that the system could not be completely drained due to the piping configuration.

Enforcement:

Violation: License Conditions 2.C(25) and 2.C(15) for Units 1 and 2, respectively, required

the licensee to implement and maintain in effect all provisions of the approved fire protection

program as described in the Final Safety Analysis Report and as approved through Safety

Evaluation Reports. Appendix H, Fire Hazards Analysis, of the Updated Final Safety

Analysis Report, stated that the appendix had to be relocated to the LaSalle County Station

Fire Protection Report (FPR). Section H.3.4.8, Unit 1 Cable Spreading Room - Fire Zone

4D1 and Section H.3.4.9, Unit 2 Cable Spreading Room - Fire Zone 4D2 of the FPR stated

that a preaction suppression system was provided. The FPR listed NFPA 13, Installation of

Sprinkler Systems, 1976 Edition, as the code of record. National Fire Protection Association

13, Section 3-10.2.1 requires that provisions shall be made to properly drain all parts of the

system.

Contrary to the above, as of July 5, 2019, the licensee did not comply with License Conditions

2.C(25) and 2.C(15) for Units 1 and 2, by failing to provide provisions to drain all parts of the

preaction fire protection system in Fire Zones 4D1 and 4D2, which was required by NFPA 13,

Installation of Sprinkler Systems, 1976 Edition, Section 3-10.2.1. Specifically, written

instructions were such that water remained in the system for prolonged periods resulting in a

thru-wall leak due to excessive corrosion.

12

Enforcement Action: This violation is being treated as an non-cited violation, consistent with

Section 2.3.2 of the Enforcement Policy.

Failure to Implement the Primary Containment Leakage Rate Testing Program for Traversing

Incore Probes System Containment Isolation Valve 2C51-J004C

Cornerstone Significance Cross-Cutting Report

Aspect Section

Barrier Integrity Green [H.6] - Design 71152

NCV 05000374/2019003-02 Margins

Open/Closed

The inspectors identified a finding of very low safety significance (Green) and an associated

non-cited violation of Technical Specification 5.5.13, Primary Containment Leakage Rate

Testing Program, for the licensee's failure to perform a cause determination and identify

corrective actions that focus on those activities that can eliminate the identified cause of a

failure with appropriate steps to eliminate recurrence for a failed Type C leak rate test.

Specifically, after repeated Type C leak rate failures of the traversing incore probe system 2C

isolation valve 2C51-J004C, the licensee neither performed a cause determination nor took

corrective actions.

Description:

On February 23, 2019, the licensee performed a local leak rate test (Type C) of the 2C

traversing incore probe system (TIP) primary containment isolation valve 2C51-J004C in

accordance with station procedure LTS-100-42. The leakage past the valve was determined

to be 24.3 standard cubic feet per hour (SCFH). This value exceeded the administrative

limit of 10 SCFH defined in procedure LTS-100-42. The licensee documented the issue in

AR 4222980. The AR documented previous failures to meet the administrative limit of

10 SCFH. Additionally, the AR documented that the primary containment was operable

since the additional leakage identified did not exceed 0.6 La. The AR also generated a

work request for operations and maintenance to troubleshoot, repair or replace the valve.

The inspectors reviewed the testing history and corrective action documentation for

2C51-J004C and determined the following:

On February 22, 2015, the licensee performed a local leak rate test of the 2C TIP primary

containment isolation valve 2C51-J004C in accordance with station procedure LTS-100-42.

The leakage past the valve was determined to be 15.53 SCFH. This value exceeded the

administrative limit of 10 SCFH defined in procedure LTS-100-42. The licensee documented

the issue in AR 2457086. The AR documented that the primary containment was operable

since the additional leakage identified did not exceed 0.6 La. No further actions were taken.

On February 23, 2017, the licensee performed a local leak rate test of the 2C TIP primary

containment isolation valve 2C51-J004C in accordance with station procedure LTS-100-42.

The leakage past the valve was determined to be 18.97 SCFH. This value exceeded the

administrative limit of 10 SCFH defined in procedure LTS-100-42. The licensee documented

the issue in AR 3977735. The AR documented that the primary containment was operable

since the additional leakage identified did not exceed 0.6 La. No further actions were taken.

The inspectors then reviewed the licensees primary containment leakage rate testing

program as described in Technical Specification 5.5.13, that states in part, this program shall

13

establish the leakage rate testing of the primary containment as required by 10 CFR 50.54(o)

and 10 CFR 50, Appendix J, Option B, as modified by approved exemption. This program

shall be in accordance with the guidelines contained in Nuclear Energy Institute (NEI) 94-01,

Industry Guideline for Implementing Performance-Based Option of 10 CFR 50, Appendix J,

Revision 3-A, dated July 2012. Additionally, the licensee implements the program in

accordance with station procedure ER-AA-380, Primary Containment Leakrate Testing

Program.

During the inspectors review they noted the following, Section 10.2.3 of NEI 94-01, Revision

3-A addresses Type C test interval and more specifically Section 10.2.3.4 addresses

corrective action and states in part, if Type C test results are not acceptable, a cause

determination shall be performed and corrective actions identified that focus on those

activities that can eliminate the identified cause of a failure with appropriate steps to eliminate

recurrence. A failure in this context is exceeding an administrative limit and not the total

failure of the valve. Additionally, station procedure ER-AA-380, Revisions 10 and 11, Steps

4.11.4 and 4.11.4.2 required that, if leakage from any component exceeds its administrative

limit perform a cause determination and take corrective actions to eliminate the identified

cause, with appropriate steps to eliminate recurrence.

The inspectors requested the evaluations and corrective actions for the failed leakrate tests

performed on 2C51-J004C in 2015 and 2017 and the licensee did not have them. The

licensee documented this in AR 4270252.

Corrective Actions: The valve was replaced and successfully passed leak rate testing with

results below the administrative limits during Refueling Outage L2R17 completed in 2019.

Corrective Action References: ARs 2457086, 3977735, 4222980, 4223654 and 4270252

Performance Assessment:

Performance Deficiency: The inspectors determined that failing to perform a cause

determination and identifying corrective actions that focus on those activities that can

eliminate the identified cause of a failure with appropriate steps to eliminate recurrence in

accordance with station procedure ER-AA-380 was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor

because it was associated with the SSC and Barrier Performance attribute of the Barrier

Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable

assurance that physical design barriers protect the public from radionuclide releases caused

by accidents or events. Specifically, despite a degrading trend of valve performance with

respect to leakage rate, the licensee repeatedly took no actions to identify and eliminate the

cause of the test failures.

Significance: The inspectors assessed the significance of the finding using Appendix A, The

Significance Determination Process (SDP) for Findings At-Power. The inspectors screened

the issue against the Barrier integrity questions and determined that the finding was of very

low safety significance (Green) since it did not represent an actual open pathway in the

physical integrity of the reactor containment, containment isolation system and heat removal

components or a reduction of hydrogen igniters in the reactor containment.

Cross-Cutting Aspect: H.6 - Design Margins: The organization operates and maintains

equipment within design margins. Margins are carefully guarded and changed only through a

14

systematic and rigorous process. Special attention is placed on maintaining fission product

barriers, defense-in-depth, and safety related equipment. Specifically, AR documents only

addressed why overall containment leakage was acceptable and did not identify the reduction

in margin to acceptable containment leakage and take actions to carefully guard and maintain

the margin.

Enforcement:

Violation: Technical Specification Section 5.5.13 requires, in part, that the primary

containment leakage rate testing program shall be established, implemented, and maintained

in accordance with the guidelines contained in NEI 94-01, Industry Guideline for

Implementing Performance-Based Option of 10 CFR 50, Appendix J, Revision 3-A, dated

July 2012.

Nuclear Energy Institute 94-01, Revision 3-A, Section 10.2.3 addresses, Type C Test

Interval and Section 12.2.3.4, Corrective Action addresses If Type C test results are not

acceptable, a cause determination shall be performed and corrective actions identified that

focus on those activities that can eliminate the identified cause of a failure with appropriate

steps to eliminate recurrence.

The licensee established Procedure ER-AA-380, Primary Containment Leakrate Testing

Program, Revisions 10 and 11 to address the primary containment leakrate testing program.

Procedure ER-AA-380, Revisions 10 and 11, Steps 4.11.4 and 4.11.4.2 require that if

leakage from any component exceeds it administrative limit perform a cause determination

and take corrective actions to eliminate the identified cause, with appropriate steps to

eliminate recurrence.

Contrary to the above, on February 22, 2015, and on February 23, 2017, the licensee failed

to implement the primary containment leakage rate program in accordance with Technical

Specification 5.5.13, in that steps 4.11.4 and 4.11.4.2 of procedure ER-AA-380, Primary

Containment Leakrate Testing Program, Revisions 10 and 11, which implement the

guidance contained in NEI 94-01, Industry Guidelines for Implementing Performance-Based

Option of 10 CFR 50, Appendix J, Revision 3-A, dated July 2012, were not followed.

Specifically, when the TIP isolation valve 2C51-J004C exceeded its administrative leakage

rate limit, the licensee failed to perform a cause determination and take corrective actions to

eliminate the identified cause with appropriate steps to eliminate recurrence.

Enforcement Action: This violation is being treated as an non-cited violation, consistent with

Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

• On October 9, 2019, the inspectors presented the integrated inspection results to

Mr. P. Hansett, Plant Manager, and other members of the licensee staff.

• On October 3, 2019, the inspectors presented the Exit Meeting for EP Inspection per

IP 71114, Attachment 4 inspection results to Mr. L. Baker, EP Fleet Programs Manager,

and other members of the licensee staff.

15

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

60855.1 Corrective Action Selected Corrective Action Reports generated since

Documents August 2017

Corrective Action AR 04262886 NRC Identified Steps Not Circled/Slashed in Procedure 07/09/2019

Documents

Resulting from

Inspection

Engineering EC 0000620032 Design Analysis Re-Qualifying ISFSI Pad for 90 Casks 11/20/2017

Changes EC 0000622967 Refuel Floor Area Cooling for FHD Skid 05/20/2019

EC 0000623793 Forced Helium Dehydration (FHD) Reactor Building Impacts 04/12/2019

EC 000062987 LaSalle 2019 Dry Cask Storage Fuel Selection Packages - 04/17/2019

ISFSI

Miscellaneous DCS Bi-Annual Walkdown Per OU-AA-630-101 04/10/2019

Selected 72.48 Evaluations Completed Since August 2016

LaSalle County Station Units 1 and 2 72.212 Evaluation 7

Report

2018 Annual Radiological Environmental Operating Report 05/14/2019

Physical Inventory Report Post-Loading Cask Varification 07/09/2019

L-004290 Fuel Selection Packages for LAS-0036 through LAS-0043 03/11/2019

for the 2019 ISFSI Campaign

L-004294 LaSalle CoC 1014 Amendment 8, Revision 1 Cask Model 02/28/2019

with 4 Individual Group Limits

LTS-800-01 Annual Inspection of ISFSI Pad and Casks 07/05/2019

LTS-800-01 Annual Inspection of the ISFSI Pad and Casks 06/14/2017

NDE Reports Report Number Report of Nondestructive Examination of Lid to Shell Weld - 07/09/2019

914603-598-01 Root Layer

Report Number Report of Nondestructive Examination of Lid to Shell Weld - 07/09/2019

914603-598-02 First Layer

Report Number Report of Nondestructive Examination of Lid to Shell Weld - 07/09/2019

914603-598-03 Final Layer

Report Number Report of Nondestructive Examination of Lid to Shell Weld - 07/10/2019

914603-598-04 Post Hydro-static Test

Procedures GQP - 9.2 High Temperature Liquid Penetrant Examination and 10

16

Inspection Type Designation Description or Title Revision or

Procedure Date

Acceptance Standards for Welds., Base Materials and

Cladding

GQP - 9.6 Visual Examination of Welds 18

LFP-800-69 Hi-TRAC Movement within the Reactor Building 22

MA-AA-716-021 Rigging and Lifting Program 30

MA-AA-716-022 Control of Heavy Loads 3

OU-MW-671-200 MPC Processing Forced Helium Dehydration (FHD) for 4

BWRs

PI-CNSTR-OP- Closure Welding of Holtec Multi-Purpose Canisters at Exelon 20

EXE-01 Facilities

Radiation LaSalle Hi-STORM Radiation Survey 06/27/2019

Surveys ISFSI Monthly Pad Survey 05/29/2019

Self-Assessments 2019 LaSalle Spent Fuel Loading Campaign (SFLC) 04/18/2019

Readiness Assessment

NOSA-LAS-18-10 Independent Spent Fuel Storage Installation Audit Report 11/14/2018

Work Orders WO 04706829-01 Annual Reactor Building Crane Inspection 09/17/2018

WO 04722199 01 Dry Cask Storage Hi-STORM Lift Bracket Inspection 07/30/2018

WO 04722200 Dry Cask Storage Lift Yoke Assembly Inspection 07/30/2018

WO 04722201 01 Dry Cask Storage Lift Cleat Inspection 07/30/2018

WO 04722202 01 Dry Cask Storage Hi-TRAC Trunnion Inspection 07/30/2019

WO 04914343-01 Monthly Reactor Building Crane, Beam and Hoist Inspection 05/01/2019

71111.04Q Drawings M-99 Standby Liquid Control System AD

Procedures LOP-SC-01E Unit 1 Standby Liquid Control System Electrical Checklist 10

LOP-SC-01M Unit 1 Standby Liquid Control System Mechanical Checklist 12

71111.05Q Corrective Action AR 4261004 Fire Alarms and Both DFPs Auto Started Due to FP Leak 07/01/2019

Documents AR 4261866 Unexpected Alarm 1PM10J-B303 Division 2 SWGR Fire 07/04/2019

Alarm

AR 4261996 U1 RT Fire Detector Replacement 07/05/2019

AR 4262877 NRC Identified: U2 CSR FP Piping Corrosion 07/09/2019

AR 4263741 Extent of Condition Walkdown of Pre-Action FP Piping 07/12/2019

Corrective Action AR 4261784 NRC Question: Draining of Fire Protection Piping Following 07/03/2019

Documents Deluge Actuation

Resulting from AR 4262090 NRC ID - Dry Pipe FP Lines not Sloped per NFPA 13 07/05/2019

17

Inspection Type Designation Description or Title Revision or

Procedure Date

Inspection AR 4262093 IEMA ID - U1 CSR FP Piping Penetration not Shown on 07/05/2019

Drawing

AR 4262899 NRC Identified: Floor Drains Covered in U1 Cable Spreading 07/09/2019

Room

Miscellaneous LaSalle Fire An Analysis of the Effects of Initiation of Fire Suppression 8

Protection Report Systems on Safe Shutdown Equipment at LaSalle County

Station

LOP-FP-03 Operating Department Procedure, Viking Automatic Deluge 29

Valve Actuation and Reset

LOS-FP-R6 Operating Department Surveillance, Preaction Spray 16

Systems Functional Test

Work Orders WO 1528878 U1 Cable Spreading Room Sprinkler Functional Test, 11/08/2013

Section E.1 of LOS-FP-R6

WO 1947942 Unit 1 Fire Protection Spray and Sprinkler Systems Integrity 08/01/2018

Inspection, Attachment B of LOS-FP-SR3.

WO 4592876 U1 Cable Spreading Room Sprinkler Functional Test, 07/30/2018

Section E.1 of LOS-FP-R6

71111.06 Corrective Action 4261004 Fire Alarms and Both DFPS [diesel fire pumps] Auto Started 07/01/2019

Documents Due To FP [fire protection] Leak

4261891 Floor Drain Leaking Water Onto 1PA02J In U1 AEER 07/04/2019

[auxiliary electric equipment room]

Engineering LaSalle Fire An Analysis of the Effects of Initiation of Fire Suppression 8

Evaluations Protection Report Systems on Safe Shutdown Equipment At LaSalle County

Station

Miscellaneous NFPA 92M Waterproofing and Draining of Floors 1972

71111.07A Procedures ER-AA-340-1002, Heat Exchanger Inspection Report for 1E22-S001 09/23/2019

Attachment 1

71111.12 Corrective Action AR 4193090 (A)(1) Determination for MR Function LAS-2-FUEL-02 11/08/2018

Documents AR 4223642 2G33-F004 MOV Diagnostics Identified Anomalies 02/25/2019

AR 4224174 New Valve Disc Required for 2G33-F004 02/27/2019

AR 4228789 Review of MODs Video ID'd Foreign Material in Jet Pump 03/12/2019

Riser

Drawings VPF-5521-225 Control Ball Valve F

Engineering AR 4169154 Maintenance Rule Functional Failure Evaluation 11/06/2018

18

Inspection Type Designation Description or Title Revision or

Procedure Date

Evaluations LAS-1-PCIS-PC- Unit 1 Maintenance Rule Function Evaluation for Primary 09/13/2019

03 Containment Isolation Valve ASME XI Leak Rate Testing

LAS-1-PCIS-PC- Unit 1 Maintenance Rule Function Evaluation for Primary 09/13/2019

04 Containment Isolation Valve ASME XI Stroke Time Testing

LAS-1-PCIS-PC- Unit 1 Maintenance Rule Function Evaluation for the Reactor 09/13/2019

05 Coolant System Pressure Boundary and Primary

Containment Integrity Function

Procedures ER-AA-302-1006 Motor-Operated Valve Maintenance and Testing Guidelines 19

ER-AA-310-1005 (a)(1) Action Plan Development and Action Plan (Monitoring) 7

Goal Setting Template

Work Orders WO 1223498 Measure Flow Control Shaft Lift of 2B33-F040A 03/05/2011

WO 1450948 Measure Flow Control Shaft Lift of 2B33-F040A 02/28/2013

WO 1629132 Measure Flow Control Shaft Lift of 2B33-F040A 02/22/2015

WO 1814692 Measure Flow Control Shaft Lift of 2B33-F040A 03/04/2017

WO 4627480 Work Request for Gate Valve - Part 21 02/27/2019

WO 4633640 Measure Flow Control Shaft Lift of 2B33-F040A 03/07/2019

71111.13 Corrective Action AR 4277865 License Renewal (LR) Coating Inspection for 0DG01A HX 09/09/2019

Documents

Procedures WC-AA-104-F-01 Disassemble and Inspect the Heat Exchanger 0DG01A 0

WC_AA_104-F- Risk Screening/Mitigation Plan for FHD Scaffolding Removal 07/18/2019

01

Work Orders WO 4624753 LRA Disassemble and Inspect 0DG01A DG Cooling Water 000

HX

71111.15 Corrective Action AR 289539 Provisions for Liquid Tight Jacket Repair 01/11/2005

Documents AR 4191997 3A1 FW Drn Clr Drain Outlet 11/05/2018

AR 4262877 NRC Identified: U2 CSR FP Piping Corrosion 07/09/2019

AR 4266338 Discovery, Work Performed, Lessons Learned 07/22/2019

Drawings Drawing M-139, P&ID Nuclear Boiler and Reactor Recirculating AT

Sheet No. 1

Drawing M-139, P&ID Nuclear Boiler & Reactor Recirculating 2B33-D003A H

Sheet No. 8

Miscellaneous NE-11-32-1 Cable and Connection Inspection Summary Report, Peach 1

Bottom

OU-AA-101-1007 Outage Execution Scope Add Sheet 12

19

Inspection Type Designation Description or Title Revision or

Procedure Date

Tagout 02-B33- Lock Up Both RR HPUs per LOP-RR-07 Limitation D.4 08/14/2019

F421A-001

Operability OpEval 19-002 Diesel Generator Ventilation (VD) 000

Evaluations

Procedures LAP-1600-15 Administrative Procedure, Regulatory Guide 1.97 8

Instruments

71111.18 Corrective Action AR 4251021 Review Code Requirements for Replacement VY Cooling 05/22/2019

Documents Coils

AR 4252624 Code Non-Conformance Identified for VY Coolers 05/29/2019

1(2)VY03A

AR 4257982 1VY02C Air Flowrate Below Required Value 06/19/2019

AR 4267302 Discrepancy in Pipe Sch of Installed Pipe and Design Info 07/24/2019

AR 4267597 Radiography Reject on Line #1FW11A-4 Weld #4 07/28/2019

Drawings Drawing IT-7000- Prequalified Hydrolazing Port Details for Class 2, Class 3, B

M-PP-04B and ANSI B31.1 Piping System

Drawing M-87 P&ID Core Standby Cooling System, Equipment Cooling BR

Water System

LTS-100-10 Feedwater Valve LLRT Quick Reference Diagram 25

Miscellaneous CC-AA-201 Plant Barrier Impairment Permit 12

Tagout 01-E22- Replace 1VY02A Cooler 06/17/2019

00150330-001

Work Orders WO 4633535 Replace both cooler coils and replace the 2-1/2 inlet outlet 12/13/2018

piping. All work will be IAW EC 622556.

WO 4633536 Replace both cooler coils and replace the 2-1/2 inlet outlet 01/31/2018

piping including the 4 90 degree elbows, 4x2-1/2 reducer

and possibly a short piece of the 4 piping after the elbow.

WO 4677534 Replace both cooler coils and replace the 2-1/2 inlet outlet 03/20/2019

piping. Also replace portions of the 4 piping in the

overhead. All work will be IAW EC 622652.

71111.19 Corrective Action AR 4278495 Corrosion of 0DG01A Flange Connections 09/12/2019

Documents AR 4278613 0DG01A Floating End Cover Leak 09/12/2019

Work Orders WO 4662368 In-service Testing Comprehensive Pump Test for 1E12- 09/05/2019

C002B

WO 4899832 LOS-DG-M1 0DG Fast Start 09/12/2019

20

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.22 Miscellaneous STI LA-18-01 Change the Control Room Emergency Makeup Unit 2

Operability Test from a 31-day (1 month) Frequency to an

Annual Frequency

STI LA-18-01 Change the control room emergency makeup unit operability 1

test from a 31-day (1 month) frequency to an annual

frequency.

Work Orders WO 4675852 In-service Testing Comprehensive Pump Test for 1E12- 08/15/2019

C002A

WO 4940210 Unit Common Diesel Generator Idle Start 08/15/2019

71114.04 Miscellaneous Evaluation 18-45 Exelon Nuclear Standardized Radiological Emergency Plan, 02/14/2019

Revision 30

71152 Corrective Action AR 1422001 LaSalle EP Staffing Assessment 10/03/2012

Documents AR 2457086 2C51-J004C Tip Ball Valve LTS-100-42 As Found Failure 02/22/2015

AR 3977735 LLRT - L2R16, 2C51-J004C Tested Above Alarm Limit 02/23/2017

AR 4223654 L2R17 - 2C51-J004C Repair Scope Add 02/25/2019

AR 4270252 Historical 2C51-J004C App J Leakage Evaluations Not 08/07/2019

Found

AR 4276516 WHR Violation 09/03/2019

Miscellaneous NEI 94-01 Industry Guidelines for Implementing Performance-Based 3A

Option of 10 CFR Part 50, Appendix J

Procedures ER-AA-380 Primary Containment Leakrate Testing Program 12

ER-AA-380 Primary Containment Leakrate Testing Program 11

OP-AA-106-101- Event Response Guidelines 31

1001

OP-LA-101-111- On-Shift Staffing Requirements 9

1001

Work Orders WO 1435953 LLRT, 'C' Tip Ball Valve 2C51-J004C 02/22/2015

WO 1809824 2C51-J004C Tip Ball Valve LTS-100-42 As Found Failure- 03/05/2019

Repair

WO 1809884 LLRT, 'C' Tip Ball Valve 2C51-J004C 02/23/2017

WO 4604994 LLRT, 'C' Tip Ball Valve 2C51-J004C 02/23/2019

21