IR 05000373/2009007

IR 05000373-09-007, 05000374-09-007 on 11/02/09 - 11/20/09 for LaSalle County, Units 1 and 2, Problem Identification and Resolution Inspection

ML093451499
Person / Time
Site:	LaSalle
Issue date:	12/11/2009
From:	Kenneth Riemer NRC/RGN-III/DRP/B2
To:	Pardee C Exelon Generation Co, Exelon Nuclear
References
IR-09-007
Download: ML093451499 (34)

Text

ber 11, 2009

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2 PROBLEM IDENTIFICATION AND RESOLUTION (PI&R) INSPECTION 05000373/2009007; 05000374/2009007

Dear Mr. Pardee:

On November 23, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) inspection at the LaSalle County Station Units 1 and 2. The enclosed report documents the inspection results, which were discussed on November 23, 2009, with members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

The inspection concluded that your staff was effective at identifying problems and incorporating them into the corrective action program. In general, issues were appropriately prioritized, evaluated, and corrected, audits and self-assessments were thorough and probing, and operating experience was appropriately screened and disseminated. Your staff was aware of the importance of having a strong safety-conscious work environment and expressed a willingness to raise safety issues.

No findings or violations were identified during this inspection. 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 (PARS) component of the NRC=s document 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/

Kenneth Riemer, Chief Branch 2 Division of Reactor Projects Docket No. 50-373; 50-374 License No. NPF-11; NPF-18

Enclosure:

Inspection Report 05000373/2009007; 05000374/2009007 w/Attachment: Supplemental Information

REGION III==

Docket Nos: 05000373; 05000374 License Nos: NPF-11; NPF-18 Report No: 05000373/2009007; 05000374/2009007 Licensee: Exelon Generation Company, LLC Facility: LaSalle County Station, Units 1 and 2 Location: Marseilles, IL Dates: November 2-20, 2009 Inspectors: N. Shah, Project Engineer - Team Lead F. Ramirez, Resident Inspector - LaSalle C. Scott, Reactor Engineer D. Swarzc, Reactor Engineer Observers: Jane Yesinowki, Illinois Emergency Management Agency Approved by: Kenneth Riemer, Chief Branch 2 Enclosure

SUMMARY OF FINDINGS

IR 05000373/2009007; 05000374/2009007 (November 2, 2009 - November 20, 2009),

LaSalle County Station Units 1 and 2; Biennial Baseline Inspection of the Identification and Resolution of Problems.

This team inspection was performed by three regional inspectors and the site resident inspector.

No findings or violations were identified.

Identification and Resolution of Problems Overall, the corrective action program (CAP) was being effectively implemented. Issues were identified at a low threshold, evaluated and corrected. Self-assessments and audits by Nuclear Oversight (NOS) were thorough and critical of the assessed areas. Operating experience was recognized as valuable and was effectively communicated. Interviews with licensee staff and a review of the Employee Concerns Program (ECP) indicated that the licensee had a positive safety culture environment that encouraged identification of issues in the CAP.

However, the inspectors identified several areas of concern that may negatively impact the licensees ability to identify and resolve issues. In some cases, these issues had been recognized by the licensee, but effective corrective action had not been taken. Briefly, the issues were:

• The current CAP performance indicators were not always effectively used or sufficient to monitor the program. Although the licensee was aware of these issues, CAP staff appeared willing to live with the shortcomings and had not formally taken corrective action.

• There were some examples of long-standing issues that were either not corrected or not evaluated. In some cases, the licensee had identified the issues, but had not evaluated why previous corrective actions were ineffective.

• There were several examples where the review of operating experience (OE) in cause evaluations were not documented in accordance with licensee procedures. Additionally, there was no formal requirement to evaluate whether the failure to use OE was a precursor during the evaluation of events. Although the licensee had identified these issues in the CAP, the corrective actions were somewhat limited.

• Issues that were reviewed by the ECP, but not captured in a formal case file, were not always well documented. This resulted in some uncertainty regarding whether potentially significant issues were appropriately dispositioned.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Mitigating Systems

None.

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

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 (IP) 71152.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the licensees corrective action program (CAP) implementing procedures and attended CAP program meetings to assess the implementation of the CAP.

The inspectors selectively reviewed risk and safety-significant issues entered in the CAP since the last NRC PI&R inspection in November 2007. The selection of issues ensured an adequate review of issues across the NRC cornerstones. The inspectors included issues identified through NRC generic communications, department self-assessments, licensee audits, operating experience reports, and NRC documented findings as part of this assessment. The inspectors also reviewed a selection of completed root, apparent and common cause evaluations.

The inspectors performed a more extensive review of the licensees control of cabling located in underground vaults, and corrective actions and temporary modifications that had been open for greater than one year. The review of the cabling located inside underground vaults consisted of a five year search of related issues identified in the CAP and discussions with appropriate licensee staff to assess the licensees efforts in addressing identified concerns.

During the reviews, the inspectors evaluated whether the licensee staffs 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, if these issues were entered into the CAP in a timely manner, and if these issues were appropriately resolved. The inspectors also evaluated whether root, apparent, and common cause evaluations were assigned and performed as appropriate. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected issue reports, completed investigations, and NRC-identified issues.

b. Assessment

(1) Effectiveness of Problem Identification Overall, the CAP program was effectively implemented in that issues were identified at a low threshold, evaluated and corrected. Workers were encouraged to identify issues and were familiar with the various avenues available (NRC, ECP, CAP, etc.). 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. This included determining the issues significance, addressing such matters as regulatory compliance and reporting, and assigning any actions deemed necessary or appropriate.

However, the inspectors noted that the licensee performance indicators for monitoring the CAP program were not being effectively utilized. The inspectors identified that there was no requirement to investigate instances where indicators identified poor performance. For example, the inspectors noted that no Action Requests (ARs) had been initiated for several indicators that were either in the yellow or red band (indicating poor performance) during the past year. During interviews, licensee CAP staff commented that some of these indicators, because of how they were defined, may be inaccurately reporting performance. However, the inspectors could not find any CAP entries identifying these indicators so that they could be corrected. The inspectors questioned the efficacy of the indicators when no effort was made to evaluate instances when poor performance was identified or to revise those considered inaccurate. The licensee issued AR 993280993280to evaluate this issue.

The inspectors determined that the station was generally effective at trending low level issues to prevent larger issues from developing. The licensee also used the CAP to document instances where previous corrective actions were ineffective or were inappropriately closed.

Findings No findings of significance were identified.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors concluded that the station was generally effective at prioritizing and evaluating issues commensurate with the safety significance of the identified problem.

The inspectors determined that CAP screening meetings were generally thorough and maintained a high standard for approving actions.

The majority of issues were of low level and were either closed to trend or at a level appropriate for a condition evaluation. Some of these issues were closed to a work request or to another CAP report, but the inspectors noted that both the parent and daughter documents had the necessary verbiage to document the interrelationship.

The inspectors also had no concerns with those assigned an apparent, root or common cause evaluation. There were no items in the operations, engineering, or maintenance backlogs that were risk significant, individually or collectively.

Root, apparent and common cause evaluations were generally thorough; however, the inspectors did identify two examples where the level of review was less than appropriate:

• AR 882701882701was written to perform a common cause evaluation for an adverse trend regarding issues with work orders/packages. The evaluation identified that this issue had been recurring since 2003, but did not address why previous corrective actions were ineffective.

• AR 784631784631was written after the NRC resident inspectors had observed a high radiation barrier (fenced enclosure) that had been built adjacent to the Unit 1 safety-related Standby Gas Treatment System piping. The barrier was in contact with the piping (potentially raising a concern regarding the seismic analysis), but there was no licensee evaluation supporting this condition. Subsequently, the barrier was removed, but there was no documentation for its removal.

The licensee captured the above issues in the CAP as AR Nos. 996319 and 995883.

The inspectors determined that the licensee was generally effective at evaluating equipment functionality requirements after a degraded or non-conforming issue was identified. The inspectors reviewed Maintenance Rule action plans associated with systems currently in (a)(1) and for those returning to a(2) status within the last two years. No issues were identified from this review.

The inspectors also concluded that the licensee had been effectively managing underground cabling.

Findings No findings of significance were identified.

(3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented, commensurate with their safety significance. The inspectors also concluded that sampled corrective actions assignments for selected NRC documented violations were generally effective and timely. However the inspectors did notice some untimely corrective actions as described below.

• AR 840401840401was written after the NRC identified a non-safety hanger attached to a safety related cable tray. In the evaluation, the licensee failed to note that the same issue had been previously identified about four years earlier (AR 352075352075and that corrective actions had not been taken.

• The inspectors noted that the licensee had not taken appropriate action to address potential preconditioning due to inappropriate work scheduling (for example, scheduling a post-maintenance test just prior to a surveillance test)despite having two prior NRC-identified instances of such, associated with the main steam isolation valves and reactor core isolation cooling systems.

• AR 856961856961was written to address oscillations observed on a Unit 1 control rod drive flow control valve. Although a work order was written to address this, it remained open for over two years. The inspectors did not identify any CAP item evaluating why the work order was open for so long.

• AR 736409736409was written to address high dose rates associated with a radioactive waste sample sink. The AR was closed to a work order, but there was no documentation that the work was actually performed.

• The inspectors noted that work orders associated with the removal of temporary modifications, did not contain the necessary cross-referencing as required by procedure (i.e., neither the work order nor the temporary modification paperwork referenced the other).

The licensee wrote ARs 989540, 995336, 995957 and 988746, respectively, to address the above issues.

The inspectors also identified that numerous, recurring issues (since 2006) with the Units 1 and 2 gaseous and particulate radiation monitors used for reactor leak detection had not been resolved. The issues were varied and potentially affected the reliability of the monitors. Although these monitors were nonsafety-related, they were required by Technical Specifications. The licensee had performed past cause evaluations that had recommended corrective actions, but these actions had not been implemented.

Additionally, the licensee had not evaluated whether the issues significantly impacted the ability of the monitors to detect primary system leakage. The licensee subsequently identified that the monitors would perform the Technical Specification function and wrote AR 989527989527to address this issue.

The licensee had 19 open corrective actions that were greater than one year old, with the oldest being 731 days old. The inspectors verified that the open actions were appropriate, that work orders were in place (and scheduled) for final implementation of the action, and that plant operation or risk was not adversely affected.

Findings No findings of significance were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensees implementation of the facilitys OE program.

Specifically, the inspectors reviewed implementing OE program procedures, observed daily station and pre-job briefings to observe the use of OE information, and selectively reviewed completed evaluations of OE issues and events. The intent of the review was to determine whether 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 effectively implemented.

b. Assessment The inspectors concluded that the station appropriately screened OE information for applicability, and used the information for corrective and preventative actions to identify and prevent similar issues. The inspectors observed that OE was discussed as part of the daily station and pre-job briefings and was effectively disseminated across the various plant departments. During interviews with the inspectors, licensee staff generally commented favorably on the use of OE in their daily activities.

Although OE was considered as part of root, apparent and common cause evaluations, the inspectors identified that these reviews were not always documented in accordance with CAP procedures. The licensee had identified several examples during self-assessments conducted in 2008 and 2009 and had taken corrective action.

A subsequent licensee review, conducted prior to the NRC PI&R inspection, had identified no additional issues. However, the inspectors identified several examples where OE potentially applicable to the station was either not reviewed or the review was not documented as required. These examples occurred after the licensee self-assessments were completed, and were not identified in the licensees effectiveness review. The licensee initiated AR 995934995934to evaluate this issue.

The inspectors also noted that the licensees staff was not required to evaluate whether the failure to use OE was a contributing cause of an event. Instead, the staff was only required to identify OE related to an event and use any insights gained in developing the corrective actions. The inspectors noted that several of the licensees root, apparent and common cause evaluations had identified OE that may have prevented the event had it been appropriately evaluated. The licensee initiated AR 995981995981to evaluate this issue.

Findings No findings of significance were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed selected focused area self-assessments, check-in self-assessments, root cause effectiveness reviews, and NOS audits. The inspectors evaluated whether these audits and self-assessments were being effectively managed, adequately covered the subject areas, and whether identified issues were appropriately captured in the CAP. In addition, the inspectors also interviewed licensee personnel regarding the implementation of the audit and self-assessment programs.

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 inspectors concluded that these audits and self-assessments were completed by personnel knowledgeable in the subject area.

The inspectors considered the quality of the NOS audits to be thorough and critical.

The self-assessments were acceptable but, as expected, they were not at the same level of quality as the audits. The inspectors observed that CAP items had been initiated for issues identified through the NOS audits and self-assessments.

Findings No findings of significance were identified.

.4 Assessment of Safety-Conscious Work Environment (SCWE)

a. Inspection Scope

The inspectors interviewed selected members of the licensees staff to determine if there were any impediments of a SCWE. In addition, the inspectors discussed the implementation of the ECP with the ECP coordinators, and reviewed 2007 - 2009 ECP activities to identify any emergent issues or potential trends. In addition, the inspectors reviewed the facilitys ECP implementing procedures, interviewed the licensee ECP coordinators, and reviewed licensee safety culture surveys. The licensees programs to publicize the CAP and ECP programs were also reviewed.

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. All persons interviewed had an adequate knowledge of the CAP and ECP process. These results were similar to the findings of the licensees safety culture surveys. Based on these interviews, the inspectors concluded that there was no evidence of an unacceptable SCWE.

The inspectors determined that the ECP process was being effectively implemented.

The review of the selected ECP issues indicated that site personnel were appropriately using the CAP and ECP to identify concerns. However, during the interviews most station personnel did not know where the ECP office was located, although they could identify the ECP personnel. This did not appear to have a detrimental affect, based on the number of ECP issues currently in the system.

However, the inspectors observed that ECP issues not captured in a formal case file, were not always well documented. This resulted in some uncertainty regarding whether potentially significant issues were appropriately dispositioned. For example, there was one issue regarding a plant individual who exhibited signs of aberrant behavior while on shift. Although this concern was documented by the ECP staff, a formal case record was not opened. The inspectors could find no record of whether this concern was reviewed by the security staff as required by the site Security plan. Subsequently, the inspectors verified that this had occurred; however, the lack of a written record made it somewhat difficult to confirm. The ECP staff acknowledged this issue and was developing corrective actions. However, due to the potential to release confidential information, this observation was not captured in the CAP.

Findings No findings of significance were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

• On November 23, 2009, the inspectors presented the inspection results to Mr. Wozniak and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

J. Bashor, Engineering Director

L. Blunk, Operations Training Manager

A. Byers, Performance Improvement Specialist

K. Ihnen, Nuclear Oversight Manager

B. Rash, Maintenance Director

T. Simpkin, Regulatory Assurance Manager

K. Taber, Operations Director

J. Vergara, Senior Regulatory Specialist

H. Vinyard, Work Management Director

D. Wozniak, Site Vice President

Nuclear Regulatory Commission

K. Riemer, Chief, Branch 2, Division of Reactor Projects

LIST OF ITEMS

Opened and Closed

None.

Attachment