IR 05000373/2015007
| ML15188A495 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 07/07/2015 |
| From: | Kunowski M A NRC/RGN-III/DRP/B5 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2015007 | |
| Download: ML15188A495 (24) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 July 7, 2015
Mr. Bryan 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-NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000373/2015007; 05000374/2015007
Dear Mr. Hanson:
On May 22, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) biennial inspection at your LaSalle County Station, Units 1 and 2. The NRC inspection team discussed the results of this inspection with Mr. P. Karaba and other members of your sta ff. The inspection team documented the results of this inspection in the enclosed inspection report.
This 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 the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the inspection samples, the inspection team determined that your staff's implementation of the corrective action program (CAP) supported nuclear safety. In reviewing your CAP, the team assessed how well your staff identified problems at a low threshold, your staff's implementation of the station's process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station to resolve these problems. In each of these areas, the team determined that your staff's performance was adequate to support nuclear safety.
The team also evaluated other processes your staff used to identify issues for resolution. These included your use of audits and self-assessments to identify latent problems and your incorporation of lessons-learned from industry operating experience into station programs, processes, and procedures. The team determined that your station's performance in each of these areas supported nuclear safety.
Finally, the team determined that your station's management maintains a safety-conscious work environment adequate to support nuclear safety. Based on the team's observations, your employees are willing to raise concerns related to nuclear safety through at least of several means available.
The NRC inspectors documented one NRC-identified finding of very low safety significance (Green) in this report. This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) in accordance with Section 2.3.2 of the Enforcement Policy. Further, the inspectors documented a licensee-identified violation which was determined to be of very low safety significance (Green) in this report. The NRC is treating this violation as an NCV in accordance with Section 2.3.2 of the Enforcement Policy.
If you contest the violation of significance these NCVs, 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, U.S.
Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector Office at LaSalle County Station.
If you disagree with the cross-cutting aspect assignment to the finding 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 Regional Administrator, Region III, and the NRC Resident Inspector at
LaSalle County Station.
In accordance with Title 10 of the Code of Federal Regulations 2.390, "Public Inspections, Exemptions, Requests for Withholding, 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 Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Michael Kunowski, Branch Chief Branch 5 Division of Reactor Projects Docket Nos. 50-373; 50-374 License Nos. NPF-11 and NPF-18
Enclosure:
IR 05000373/2015007; 05000374/2015007 w/Attachment: Supplemental Information cc w/encl: Distribution via LISTSERV
Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket Nos: 50-373; 50-374 License Nos: NPF-11 and NPF-18 Report No: 05000373/2015007; 05000374/2015007 Licensee: Exelon Generation Company, LLC Facility: LaSalle County Station, Units 1 and 2 Location: Marseilles, IL Dates: May 4-22, 2015 Inspectors: R. Ruiz, Senior Resident Inspector (Team Lead) A. Dahbur, Senior Reactor Inspector B. Jose, Senior Reactor Inspector R. Winter, Reactor Engineer C. Jackel, Reactor Engineer (Observer) R. Zuffa, Illinois Emergency Management Agency Approved by: M. Kunowski, Chief Branch 5 Division of Reactor Projects
2
SUMMARY OF FINDINGS
Inspection Report 05000373/2012007, 05000374/2012007; 05/04/2015-05/22/2015; LaSalle County Station, Units 1 and 2; Biennial Problem Identification and Resolution (PI&R)
Inspection.
This inspection was performed by three NRC regional inspectors, the senior resident inspector, and the Illinois Emergency Management Agency resident inspector. One Green finding was identified by the inspectors. This finding was considered a non-cited violation (NCV) of NRC regulations. The significance of most findings is indicated by their color (Green, White, Yellow,
Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 5, dated February 2015.
Problem Identification and Resolution On the basis of the samples selected for review, the team concluded that implementation of the corrective action program (CAP) at LaSalle County Station was effective. The licensee had a low threshold for identifying problems and entering them into the CAP. Items entered into the CAP were screened and prioritized in a timely manner using established criteria; were properly evaluated commensurate with their safety significance; and corrective actions for conditions adverse to quality were generally implemented in a timely manner, commensurate with their safety significance. Operating experience was entered into the CAP and appropriately evaluated for applicability to station activities and equipment. The use of operating experience was integrated into daily activities. Audits and self-assessments were performed at appropriate frequencies and at an appropriate level to identify issues. The assessments reviewed were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. On the basis of interviews conducted during the inspection, workers at the site expressed freedom to raise safety concerns without fear of retaliation. The inspectors did not identify any impediments to the health of the safety-conscious work environment at LaSalle County Station. There was one finding identified by the team during the inspection. The finding involved a failure to promptly identify and correct misaligned mechanism-operated cell (MOC) switches associ ated with 4-kiloVolt (KV) safety-related breakers. The finding had a cross-cutting aspect in the area of Problem Identification and Resolution.
NRC-Identified
and Self-Revealed Violations
Cornerstone: Mitigating Systems
Green: The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," for the failure to promptly identify and correct the condition adverse to quality of misadjusted MOC switches associated with 4-KV safety-related breakers. Specifically, after the station experienced a system malfunction in 2011 due to misaligned MOC switches, the licensee failed to ensure prompt identification and correction of this degraded condition in the rest of the affected population of safety-related applications, in accordance with the current NRC guidance for timeliness of corrective actions in IMC 0326, Operability Determinations and Functionality Assessments for Conditions Adverse to Quality or Safety, January 31, 2014.
3 The licensee entered action request (AR) 02502652, "
NRC Identified
Issue with MOC Switch Timeliness," into the CAP to correct the issue and restore compliance. The performance deficiency was determined to be more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems Cornerstone, and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee's failure to ensure that the MOC switches associated with the 4-KV safety-related breakers were promptly adjusted and aligned, could potentially result in the undesired malfunction of important equipment, i.e., failure to start, failure to run, inadvertent actuation, during an event. Using Exhibit 2 of IMC 0609, Appendix A, "The SDP for Findings At-Power," dated June 19, 2012, the finding was determined to have very low safety significance because all screening questions were answered "No."
The inspectors determined this finding had an associated cross-cutting aspect in the area of Problem Identification and Resolution (PI&R), Evaluation, because the licensee's organization failed to thoroughly evaluate the MOC switch issue to ensure that the resolution would address the cause and extent of condition commensurate with its safety significance (P.2). (Section 4OA2.1b.(2))
=
Licensee-Identified Violations===
A violation of very low safety significance was identified by the licensee and has been reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensee's CAP. This violation and corrective action tracking number are listed in Section 4OA7 of this report.
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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 as defined in Inspection Procedure 71152. .1 Assessment of the Corrective Action Program Effectiveness
a. Inspection Scope
The inspectors reviewed the licensee's CAP implementing procedures and attended CAP meetings to assess the implementation of the CAP by site personnel. The inspectors reviewed risk and safety significant issues in the licensee's CAP since the last U.S. NRC problem identification and resolution inspection in May 2013. The selection of issues ensured an adequate review of issues across 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 action requests (ARs) generated as a result of facility personnel's performance in daily plant activities. The inspectors also reviewed ARs and a selection of completed causal evaluations from the licensee's various investigation methods, which included root cause, apparent cause, equipment apparent cause, and work group evaluations. The inspectors selected the topic of procedures for a detailed review, i.e., procedure use and adherence, and procedure adequacy. A 5-year review was performed to assess the licensee staff's performance with respect to the aforementioned procedure-related areas. During the reviews, the inspectors determined whether the licensee staff's actions were in compliance with the facility's CAP and 10 CFR Part 50, Appendix B requirements. Specifically, the inspectors determined if licensee personnel were identifying plant issues at the proper threshold, entering the plant issues into the station's CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also determined whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected issue reports associated with conditions adverse to quality. This included a review of completed investigations and previous NRC findings and NCVs. b. Assessment
- (1) Effectiveness of Problem Identification Based on the results of the inspection, the inspectors concluded that problem identification was generally effective. Based on the information reviewed, the inspectors determined that LaSalle County Station personnel had a low threshold for initiating ARs; station personnel appropriately screened issues from both the NRC and industry operating experience at an appropriate level and entered them into the CAP when applicable; and identified problems were generally entered into the CAP in a complete, accurate, and timely manner. 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 correct ive actions were ineffective or were inappropriately closed.
Findings No findings were identified.
- (2) Effectiveness of Prioritization and Evaluation of Issues Based on the results of the inspection, the inspectors concluded that identified problems were generally prioritized and evaluated commensurate with their safety significance, including an appropriate consideration of risk. Higher level evaluations, such as root cause and apparent cause evaluations, were generally technically accurate; of sufficient depth to effectively identify the cause(s); and generally considered extent of condition, generic implications, and previous occurrences in an adequate manner. The inspectors determined that the station ownership committee and management review committee meetings were genera lly thorough and meeting participants were actively engaged and well-prepared. Station ownership committee and management review committee meetings accurately prioritized issues. The inspectors determined that, overall, LaSalle County Station personnel evaluated equipment operability and functionality requirements adequately after a degraded or non-conforming condition was identified, and appropriate actions were assigned to correct the degraded or non-conforming condition.
Observations In June 2012, LaSalle's Nuclear Oversight (NOS) group identified that procedurally controlled temporary configuration changes did not contain the required reference information per procedure CC-AA-112. Specifically, the evaluation number as well as Precautions and Limitations for the temporary configuration changes, such as the allowable plant Modes for installation, were not contained within each procedure as
required. Subsequently, LaSalle's NOS group performed an audit in 2014 to review the station's progress in completing the changes in applicable procedures and discovered that the LaSalle Operating Procedures were not scheduled for review and revision until 16 months after the initial June 2012 identification of the problem. An apparent cause evaluation (ACE) was performed and identified additional procedure families that also needed to be reviewed and revised, such as abnormal operating, surveillance, and general operating procedures. Through interviews, the inspectors noted that there was an apparent lack of prioritization, in that no focus was put on correcting safety-related (activities affecting quality) or risk-significant procedures over those nonsafety-related/nonrisk-significant procedures. For example, numerous nonsafety-related procedures were corrected, while some safety-related procedures were not scheduled for completion until 2018.
The licensee generated AR 2503805 to capture this observation and to create actions to ensure adequate prioritization occurred for the remaining procedures.
Findings Failure to Promptly Identify and Correct Misaligned Mechanism-Operated Cell Switches Associated with 4-KV Safety-Related Breakers
Introduction:
The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," for the failure to promptly identify and correct the condition adverse to quality of misadjusted MOC switches associated with 4-KV safety-related breakers.
Description:
On May 11, 2011, Unit 1 station air compressor trip and trouble alarms annunciated in the control room. This issue was documented in AR 01214832.
Troubleshooting identified that an auxiliary contact of the MOC switch was intermittent due to less-than-optimal adjustment of the switch operating linkage. The linkage travel was originally set in a marginal position, which, coupled with normal wear, resulted in the contact having inadequate pressure to maintain electrical continuity. Maintenance personnel mechanically adjusted the linkage for proper over-travel and contact engagement. The MOC assembly was not part of the 4-KV breaker, but was part of the switchgear cubicle for the breaker; the breaker was not safety-related. These MOC switches were believed by the licensee to be a reliable component, not normally requiring adjustment during breaker preventive maintenance (PM) performed every 10 years per the LES-GM-103 series of procedures. The PM procedures provided guidance on performing the MOC inspection during the PM, but did not include any specific adjustment criteria. Proper operation of the switch was verified by validating the switch changed state and did not have high contact resistance.
In December 2011, the licensee revised the pm series of procedures LES-GM-103 for the 4-KV safety-related and nonsafety-related breakers and added guidance to verify and ensure proper adjustment of the MOC switches. The licensee did not specify any other actions to promptly ensure that the MOC switches had the proper adjustment.
Instead, the licensee relied on the 10-year PM frequency to inspect the MOC switches.
In addition, the licensee issued an industry operating experience describing the event and the corrective actions. On August 13, 2013, during preplanned maintenance activity per LES-GM-103 in the 1C residual heat removal (RHR) switchgear, the main control room received an indication that the 1A diesel generator (DG) cooling water pump had automatically started. The licensee determined that the closure of the MOC switch in the cubicle for the 1c RHR 4-KV safety-related breaker caused the automatic start of an area ventilation fan which in turn started the 1DG01P cooling water pump. The licensee subsequently performed ACE 1546110, which identified that the apparent cause was the misadjustment of the MOC switch linkage arm and switch contacts. The ACE indicated that during the maintenance (cleaning) in the 1C RHR cubicle casual contact with the linkage arm was made and could have momentarily closed the contacts of the MOC switch. The ACE concluded that this condition may apply to maintenance activities in the cubicles for other 4-KV safety-related breakers. The ACE further noted that guidance was added to revision 6 of the PM procedure LES-GM-103D in December of 2011 to address proper adjustment of the MOC switches and this guidance would ensure accurate setting of the MOC switch linkages and prevent similar future events. The ACE reasoned that any existing misadjustments of the MOC switches in the switchgear cubicles would be corrected over the next 10 years as the PM testing was performed. The licensee entered the inspectors' issue into the cap as AR 02502652, "NRC identified issue with MOC switch timeliness," and performed a preliminary review which revealed that since the procedure change to the LES-GM-103 series of procedures in 2011, the licensee has completed PMS on 11 4-KV safety-related breakers and the MOC switch for all except the breaker of 1C RHR were acceptable. The licensee identified that there were 14 remaining 4-KV safety-related breakers that required inspection for extent of condition from the 2013 ACE, including those for the 1B RHR pump and the 2A RHR pump. Based on the review of inspection records for the breakers inspected since the procedure revision showing proper MOC switch alignment, the licensee determined that there were no immediate operability concerns associated with this issue for the remaining safety-related breakers, while a new plan was being formulated to promptly inspect, identify, and correct any MOC switch misalignments among the remaining population.
Analysis:
The inspectors determined that the failure to promptly identify and correct the condition adverse to quality of misaligned MOC switches was not in accordance with the timeliness expectations of IMC 0326 and 10 CFR 50, Appendix B, Criterion XVI, corrective action, and was a performance deficiency. Specifically, following the 2011 MOC switch-related failure, the licensee failed to promptly identify and correct the condition adverse to quality with MOC switch misalignments associated with 4-KV safety-related breakers, deferring to a 10-year PM to identify and correct any misalignments. Further, following the causal evaluation of the 2013 misalignment, the licensee again chose to use the 10-year PM frequency to resolve the issue. The inspectors concluded that the licensee's use of a 10-year PM frequency to identify and correct the potentially misadjusted MOC switches associated with 4-KV safety-related breakers was not timely, giv en the potential safety significance of the issue. NRC IMC 0326, operability determinations and functionality assessments for conditions adverse to quality or safety, issued January 31, 2014. Section 07.02 of NRC IMC 0326, entitled "Timing of Corrective Actions," provides guidance to inspectors in determining whether the licensee made reasonable efforts to promptly complete corrective actions. The IMC states, in part, that "the NRC will consider safety significance, the effects on operability, the significance of the degradation, and what is necessary to implement the corrective action. The NRC may also consider the time needed for design, review, approval, or procurement of the repair or modification; the availability of specialized equipment to perform the repair or modification; and whether the plant must be in hot or cold shutdown to implement the actions. If the licensee does not resolve the degraded or nonconforming condition at the first available opportunity or does not appropriately justify a longer completion schedule, the staff would conclude that corrective action has not been timely and would consider taking enforcement action.
Factors that should be considered are
- (1) the identified cause, including contributing factors and proposed corrective actions,
- (2) existing conditions and compensatory measures, including the acceptability of the schedule for repair and replacement activities,
- (3) the basis for why the repair or replacement activities will not be accomplished prior to restart after a planned outage (e.g., additional time is needed to prepare a design/modification package or to procure necessary components), and
- (4) review and approval of the schedule by appr opriate site management and/or oversight organizations." The inspectors determined that none of the extenuating circumstances outlined in the IMC 0326 guidance above applied to this case, and have therefore concluded that the licensee's reliance on a 10-year PM frequency, following the identification in 2011 that 4-KV safety-related breakers might be affected, was untimely. This conclusion is supported by the 2013 problem involving the MOC switch associated with the 4-KV safety-related breaker for 1C RHR. The performance deficiency was determined to be more than minor, and a finding in accordance with IMC 0612, "Power Reactor Inspection Reports," Appendix B, "Issue Screening," dated September 7, 2012, because it was associated with the equipment performance attribute of the mitigating systems cornerstone, and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee's failure to ensure that the MOC switches associated with the 4-KV safety-related breakers were properly adjusted/aligned, could potentially result in the undesired malfunction of equipment, i.e., failure to start, failure to run, inadvertent actuation, during an event. Using Exhibit 2 of IMC 0609, Appendix A, "The SDP for Findings At-Power," dated June 19, 2012; the finding was determined to have very low safety significance (Green) because all screening questions were answered "No." The inspectors determined this finding had an associated cross-cutting aspect in the area of problem identification and resolution, evaluation, because the licensee's organization failed to thoroughly evaluate the MOC switch issue to ensure that the resolution would address the cause and extent of condition commensurate with its safety significance (p.2).
Enforcement:
Title 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," states, in part, that "Measures shall be established to assure conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected." Contrary to the above, as of May 22, 2015, and following the 2011 issue with a misaligned MOC switch, the licensee failed to promptly identify and correct the condition adverse to quality associated with MOC switch misalignments in 4-KV safety-related breakers. Because this violation was of very low safety significance (Green) and was entered into the licensee's cap (as AR 02502652) to schedule visual checks of the remaining 4-KV safety-related breakers at the licensee's earliest opportunity, this violation is being treated as an NCV, consistent with section 2.3.2 of the NRC Enforcement Policy (NCV 05000373/2015007-01; 05000374/2015007-01, Failure To Promptly Identify And Correct Misaligned Mechanism-Operated Cell Switches Associated With 4-Kv Safety-Related Breakers).
- (3) Effectiveness of Corrective Actions Based on the results of the inspection, overall, the corrective actions reviewed were found to be appropriately focused to correct the identified problem and were generally implemented in a timely manner commensurate with the issues' safety significance. Problems identified through root or apparent cause evaluations were generally resolved in accordance with the CAP procedures and regulatory requirements. Corrective actions intended to prevent recurrence were generally comprehensive, thorough, and timely. The corrective actions associated with selected NRC documented findings and violations, as well as licensee-identified violations, were generally appropriate to correct the problem and were implemented in a timely manner. Additionally, the inspectors reviewed the 2014 95001 inspection report for LaSalle Unit 2 (Inspection Report 05000374/2014009) for incomplete CAP items at the time of the supplemental inspection. Inspectors noted that CAP item #20 from AR 1506809, "Implement Formal Training in the Case Study Methodology," was incomplete at the time of the 95001 inspection. The inspectors verified that the aforementioned CAP item was completed appropriately.
Observations Through the review of root cause report (RCR) 1627300, "Elevated Turbine Bearing 11 Vibrations During Startup from L1R15," and through interviews with representatives of the associated work group, the inspectors concluded that the root cause determination of a misoriented coupling clip appeared to be incorrectly stated as a definitive root cause and the root cause appeared, rather, to be indeterminate.
Specifically, the cause appeared indeterminate due to the large number of variables that could have affected the alignment of the coupling, as documented in the RCR, such as lift pump status, measuring equipment, gas state of the generator, and heat-up of the generator,-coupled with the fact that the subsequent Unit 2 outage found its clips similarly misoriented (i.e., installed backwards) with no ill effects noted. Further, the corrective-action-to-prevent-recurrence for this condition was to modify the design to remove the clips altogether. The inspectors noted that the effectiveness review for this corrective-action-to-prevent-recurrence was simply to verify that the clips were removed. Given the indeterminate nature of the root cause, the inspectors questioned why the effectiveness review did not include some type of measureable performance parameter, such as a measured lack of high vibrations or a lack of subsequent turbine trips on bearing 11. The licensee captured this observation in AR 02503551.
Findings No findings were identified.
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors reviewed the licensee's implementation of the facility's Operating Experience (OE) program. Specifically, the inspectors reviewed implementing OE program procedures, attended CAP meetings to observe the use of OE information, completed evaluations of OE issues and events, and selected monthly assessments of the OE composite performance indicators. The inspectors' 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 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 effectively and timely implemented. b. Assessment In general, OE was appropriately used at the station. The inspectors observed that OE was discussed as part of the daily station and pre-job briefings. Industry OE was disseminated across the various plant departments. 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 root cause evaluations and equipment apparent cause evaluations was appropriate and adequately considered. Generally, OE that was applicable to LaSalle County Station was thoroughly evaluated and actions were implemented in a timely manner to address any issues that resulted from the evaluations.
Findings No findings were identified.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors assessed the licensee staff's ability to identify and enter issues into the CAP program, prioritize and evaluate issues, and implement effective corrective actions, through efforts from departmental assessments and audits. b. Assessment Based on the results of the inspection, the inspectors did not identify any issues of concern regarding LaSalle County Station staff's ability to conduct self-assessments and audits. Assessments were conducted in accordance with plant procedures, were generally thorough and intrusive, adequately covered the subject area, and were effective at identifying issues and enhancement opportunities at an appropriate threshold. Identified issues were entered into the CAP with an appropriate significance characterization and corrective actions were completed and/or scheduled to be completed in a timely manner commensurate with their safety significance.
Findings No findings were identified.
.4 Assessment of Safety-Conscious Work Environment
a. Inspection Scope
The inspectors assessed the licensee's safety-conscious work environment through the reviews of the facility's employee concern program implementing procedures, discussions with coordinators of the employee concern program, interviews with personnel from various departments, and reviews of issue reports. To assess LaSalle County Station's safety culture, the inspectors interviewed a representative group of station employees over the course of the first and third weeks of the inspection. Additionally, the site's most recent safety culture assessment was reviewed and the employee concerns program coordinators were interviewed. b. Assessment Based on the results of the inspection, the inspectors did not identify any issues that suggested conditions were not conducive to the establishment and existence of a safety-conscious work environment at LaSalle County Station. Information obtained during the interviews indicated that an environment was established where LaSalle County Station employees felt free to raise nuclear safety issues without fear of retaliation; were aware of and generally familiar with the CAP and other processes, including the employee concerns program and the NRC, through which concerns could be raised; and safety significant issues could be freely communicated to supervision.
Findings No findings were identified.
4OA6 Management Meeting
.1 Exit Meeting Summary
On May 22, 2015, the inspectors presented the inspection results to Mr. P. Karaba 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.
4OA7 Licensee-Identified Violations
The licensee identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," for the failure to promptly correct the condition-adverse-to-quality of known corroded piping during Unit 2 Refueling Outage L2R13. Specifically, pitting was identified in 2007, 2008, and 2009 on the safety-related 2DG06A piping, and replacement was recommended through the CAP to be performed during L2R13, in the year 2011. Despite this recommendation, work order 1275796 scheduled the piping replacement for refueling outage L2R16, in the year 2017. This piping, however, needed to be replaced in 2015 due to a licensee program inspection that revealed unacceptable levels of degradation. The licensee replaced all effected piping and performed RCE 2471718 "Failure of 2DG05A and 2DG06A Piping" to address the underlying causal factors. In accordance with IMC 0609, Significance Determination Process, this finding was determined to have very low safety significance (Green) because all screening questions were answered "No." ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- P. Karaba, Site Vice-President
- H. Vinyard, Plant Manager
- G. Ford, Regulatory Assurance Manager
- J. Houston, Nuclear Oversight Manager
- R. Bellettini, Corrective Action Program Manager
- L. Blunk, Regulatory Assurance
- S. Shields, Regulatory Assurance
- B. Hilton, Design Engineering Manager
- S. Tanton, Design Engineering Supervisor
Nuclear Regulatory Commission
- M. Kunowski, Chief, Reactor Projects Branch 5
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
- 05000374/2015007-01 NCV Failure to Promptly Identify and Correct Misaligned
Mechanism-Operated Cell (MOC) Switches Associated with 4-KV Safety-Related Breakers (Section 4OA2.1b.(2))
Closed
- 05000374/FIN-2015007-01 NCV Failure to Promptly Identify and Correct Misaligned
- Mechanism-Operated Cell (MOC) Switches Associated with 4-KV Safety-Related Breakers (Section 4OA2.1b.(2))
LIST OF DOCUMENTS REVIEWED
The following is a partial list of documents reviewed during the inspection.
- Inclusion on this list does not imply that the NRC inspector reviewed the documents in their entirety, but rather that selected sections or 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 Revision
- LES-GM-103A Bus 141X I.T.E. Breaker and TSC Switch Operational Test 10
- LOA-AP-201 Unit 2-AC Power System Abnormal 38
- PI-AA-125-1003 Apparent Cause Evaluation Manual 2
- Number Description or Title
- 0694690
- IN 2007-34 Electrical Circuit Breakers
- 1094635 Entered 72-hour Shutdown Time Clock Due to Tripping of the Common Diesel Generator Cooling Water Pump
- 1214832 Unit 1-SAC Trip
- 259080
- LOS-DO-SR2 Required Revision Due to Incorrect Limit
- 295248 2DG011 Limit Adjustment Require Procedure Changes
- 1333644 Clearance Order Tags Were Found Erroneously Removed and Valves Were Discovered Not in the Position Required
- 1350733 Inadequate Operator Response to Alarm Results in Emergent
- Down-power
- 1444878 Seismic Vulnerability Main Control Room
- 1471558 EP New Rule:
Procedure
- Revision Not Completed Timely
- Periodicity Of
- NOS 50.54T
- Audits
- Maintenance Of Equipment Important To EP
- 1480592 2DV009C Relief Valve Lifting During Condensate Fill
- 1493260 LaSalle Station Does Not Have On-Line Water Chemistry Monitoring Capabilities As Recommended For Industry Excellence In The EPRI
- Guideline As Well As Previously Recommended In Multiple LaSalle Chemistry Assessments For Raw Water Chemistry Optimization.
- 1499049 Procedure Deficiency Identified during Simulator Drill
- 1506809 Leakage Past CW Inlet Valve Results in Reactor Trip;
- Corrective Action Item # 20 Implement Formal Training in the Case Study Methodology
(Action Item Not Closed at the Time of 2014 95001 Inspection)
- 1513175 Dual Indication when Performing Week ly Exercising of Extraction Steam Number Description or Title Check Valves
- 1514097 CW System Exceeded Maintenance Rule Performance Criteria
- 1516895 Through Wall Steam Leak on 1RI07B-2 Pipe
- 1518242 Operations Crew 6 4/17/13 LOOP Lessons Learned
- 1518486 Reactor Building Floor Drains Maintenance Rule Criteria Exceeded
- ACE 01520429 RHR Service Water Leak
- 23941 1PL15J Sample Pump Tripped Again
- 01526713
- 1A RPS Motor Generator Trip
- 1528202 Outage Group Lessons Learned From The Dual Unit LOOP
- 1536109 Unit 2 Bus Duct Temperature High Alarm
- 1539979 NOS ID:
- Inadequate Closure Of Action Items
- 1542345 Revise UFSAR Section 9.1.2.2
- 1543929 Abbreviated Maintenance Performed on the Valve to Operate
- 1548172 1PL15J Will Not Restart
- 1548369 Door To Flammable Cabinet Does Not Latch Properly
- MMD-006
- 1549059 Three Compressed Gas Cylinders Were Stored in a Flammable Cabinet With Other Flammables
- 1549484 Potential Adverse Trend in Human Performance-EMD
- 1569471 Operations have Identified an Adverse Trend in Formal Communications
- 1614107 0VS10C Fan Belt Failure
- RCE 01627300
- Elevated Turbine Bearing 11 Vibration During Startup from L1R15
- 1646983 0VA03C Shutdown Due to Adverse Trend
- 1654232 Remove Alligator Clips on HFA Relays
- 1654237 High Radiation Area Discovery Identified
- 1654242 2JB806T has Corrosion and Oil Drops Inside
- 1654244 L2M17 SRV Setscrew Inspections:
- Instrument Out of Tolerance
- Trend Code B4
- 1654251 PM on Breaker Scheduled Online Instead of Offline
- 1654271 Stores Label Expiration Date on Gas Bottles One Year Earlier than Vendors
- 1654341 Security Small Panel on Motorola Radio Console Split
- 1655658
- NRC Finding Associated With RCIC Surveillance Frequency Number Description or Title
- 1655668 NRC Finding For Secondary Containment Door Classification
- 1689555 RCR:
- 2B21-F022BMSIV Failed to Fully Open During
- LES-MS-201
- 1697166 LaSalle Station Access During Inclement Weather
- 2381559 0DG Heat Exchanger Maintenance
- 2394400 B RHR Pump Tripped during
- LOP-RH-07
- 2413956 Ceiling Tile Is Disengaged from Support and Sagging
- 2417222 Procedurally Controlled Temporary Configuration Change Issue
- RCE 02419110
- Precise Control of Infrequent Manipulations
- RCE 02422098 Inadvertent Contact with Plant Equipment
- 24245 INPO Identified A Maintenance
- Performance Issues-Temporary Power Installation Performance Deficiency
- 2425382 Vibration Analysis Identifies Adverse Trend
- 25967 Working Electronic Copy Of The Worker Tag-out Log Wrong Revision
- 27921 NOS ID:
- Actions For Accumulated Dose Alarms Not Effective
- 2437466 Document Quality And Control Issues Related to DEP Documentation Were Identified
- 2446360 0FP01KB Block Heater Is Not Working
- 2448380 NOS ID:
- Adverse Trend Safety-Related, Seismic Installations
- 2448380 NOS ID:
- Adverse Trend Safety-Related, Seismic Installations
- 2449598
- BUS 243 And 2B DG Tripped Unexpectedly
- 2450934 Fire Detection Zone 2-33 To Remain OOS Greater Than 14 Days
- 2452321 2C11-D0223-127 Snoop Bubbles at Air Fitting to 127 Valve
- 2452478 PMT Issues on Unit 2
- HCU 34-31
- 2452479 PMT Issue on Unit 2
- HCU 30-07 116 Valve
- 2452897 Unqualified Worker Doing Fire Watch
- 2454070 Unit 1
- RB 710 Interlock Allowed both Doors to be Opened
- 2459270 2B33-F060A FCV Not Responsive After Pump Start
- 2466170 NRC Finding On MSIV Stem/Disk Separation
- 2468058 1B Heater Drain Pump Trip 10 Seconds After Star
- 2471718 Failure of 2DG05A and 2DG06A Piping
- 2472145 Normal Hotwell Makeup Tuning 1LIC-CD0
- 2480551 IRSF Crane Not Nesting Properly
- 2489827 Maintenance Trend IR January-March 2015
- 2489831 Oil Analysis Identified Particulate in EHC Fluid
- 2491270 Download Data from MCR Recorder
- 2491932 Operations First Quarter Trend Report Number Description or Title
- 2493003
- OP-AA-108-111, Adverse Condition Monitoring and Contingency Planning, U2 Leak Rates Rising
- 2500804 Fan Spinning in Forward Direction with Dampers Closed
- CORRECTIVE ACTION PROGRAM DOCUMENTS WRITTEN DURING INSPECTION
- Number Description or Title
- 2503551 2015 PI&R ID'd EFR for
- RCR 1627300 Not Measureable
- 2503558 Safety Culture Components Applicable
- RCR 2471718
- 2504236 Untimely Actions to Address 2DG06A UT Exam Results
- AUDITS, ASSESSMENTS, AND SELF-ASSESSMENTS
- Number Description or Title
- 1598090
- NOSA-LAS-14-14
- 1598081 Audit 4-Chemistry-2 Weeks:
- May 19-July 25
- 1598082 Audit 5-Engineering Programs-2 Weeks:
- March 17-May 9
- 1451646 Audit 5-Design Eng. Programs-2 Weeks:
- June 17-August 16
- 1451647 Audit 6-HP/RP-2 Weeks:
- June 17-August 16
- 1598082 NOS Audit
- NOSA-LAS-14-05 Engineering Programs
- 1451646 NOS Audit Design Engineering Program
- OPERATING EXPERIENCE ITEM
- Number Description or Title Date or Revision249113 Failure of Linkage in Low Voltage Power System Class 1E
- Circuit Breaker
- 05/11/2011OE 13-003
- OE 13-002
- OE10-005
- 1136071
- 1141618 The non-conforming condition is that there is insufficient fuel volume of fuel oil for both seven days and six days of continuous EDG operation at rated load at the highest frequency allowed by Technical Specifications (i.e., 61.2 Hz).
- This issue impacts all five of the Emergency Diesel Generators.
- OE11-002
- 1245184 The drywell temperature used as input for the containment analysis (135 deg F) may not be conservative relative to the calculated peak Drywell Pressure.
- OE 13-001
- 1459827 Reactor Coolant System Pressure and Temperature Curves 1
- OE 13-005
- 1575421
- 1588860 IST Instrument Calibration Accuracy
- OPERATING EXPERIENCE ITEM
- Number Description or Title Date or Revision1697071 OPEX Evaluation Documentation Not Stand Alone 08/2014
- MISCELLANEOUS
- Number Description or Title Date or Revision
- 2493003 Adverse Condition Monitoring and Contingency Plan for Unit 2 Drywell Unidentified Leakage
- 4/28/2015L2R15 A Packing Program Critique, by A.P. Services 2015 IB 3.6.6.7A Type 2 Auxiliary Switches Installation/Maintenance Instruction 1
- N-LA-OPS CW
- 2013 SOER10-2 Case Study 0
LIST OF ACRONYMS
- USED [[]]
RHR Residual Heat Removal SDP Significance Determination Process
B. Hanson -2-
treating this violation as a non-cited violation (NCV) in accordance with Section 2.3.2 of the Enforcement Policy. Further, the inspectors documented a licensee-identified violation which
was determined to be of very low safety significance (Green) in this report. The NRC is treating
this violation as an NCV in accordance with Section 2.3.2 of the Enforcement Policy.
If you contest the violation of significance these
- NCV , you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the
DC 20555-0001; and the NRC Resident
Inspector Office at LaSalle County Station.
If you disagree with the cross-cutting aspect assignment to the finding 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 Regional Administrator, Region III, and the NRC Resident Inspector at
LaSalle County Station.
In accordance with Title 10 of the Code of Federal Regulations 2.390, "Public Inspections, Exemptions, Requests for Withholding, 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
PARS) component of NRC's Agencywide Documents Access and Management
System (ADAMS).
NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely, /RA/
Michael Kunowski, Branch Chief
Branch 5
Division of Reactor Projects Docket Nos. 50-373; 50-374
License Nos. NPF-11 and NPF-18
Enclosure:
IR 05000373/2015007; 05000374/2015007 w/Attachment: Supplemental Information
cc w/encl: Distribution via LISTSERV
- See next page
Publicly Available Non-Publicly Available
Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy
- OFFICE [[]]
- RIII [[]]
- RIII [[]]
- RECORD [[]]
COPY
Letter to Brian Hanson from Michael Kunowski dated July 7, 2015
- COUNTY [[]]
- AND [[]]
- Kimyata MorganButler
RidsNrrDorlLpl3-2 Resource RidsNrrPMLaSalle
RidsNrrDirsIrib Resource
Cynthia Pederson
- DRPIII [[]]
DRSIII Jim Clay Carmen Olteanu