IR 05000373/2019011

NRC Temporary Instruction 2515/193, Implementation of Reliable Hardened Containment Vents Inspection Report 05000373/2019011 and 05000374/2019011

ML19333B843
Person / Time
Site:	LaSalle
Issue date:	11/29/2019
From:	Ann Marie Stone NRC/RGN-III/DRP/TSS
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2019011
Download: ML19333B843 (8)

Text

ber 29, 2019

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2 - NRC TEMPORARY INSTRUCTION 2515/193, IMPLEMENTATION OF RELIABLE HARDENED CONTAINMENT VENTS INSPECTION REPORT 05000373/2019011 AND 05000374/2019011

Dear Mr. Hanson:

On November 20, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at LaSalle County Station, Units 1 and 2 and discussed the results of this inspection with Ms. Deborah McBreen and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Ann Marie J. Stone, Technical Support Team Leader Technical Support Staff Division of Reactor Projects Docket Nos. 05000373 and 05000374 License Nos. NPF-11 and NPF-18

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000373 and 05000374 License Numbers: NPF-11 and NPF-18 Report Numbers: 05000373/2019011 and 05000374/2019011 Enterprise Identifier: I-2019-011-0034 Licensee: Exelon Generation Company, LLC Facility: LaSalle County Station, Units 1 and 2 Location: Marseilles, IL Inspection Dates: November 18, 2019 to November 20, 2019 Inspectors: J. Havertape, Resident Inspector S. Sheldon, Project Engineer Approved By: Ann Marie J. Stone, Technical Support Team Leader Technical Support Staff Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a NRC Temporary Instruction 2515/193, Implementation of Reliable Hardened Containment Vents 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 No findings or violations of more than minor significance were identified.

Additional Tracking Items None.

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 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.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 2515/193 - Inspection of the Implementation of EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions Inspection of the Implementation of EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions (1 Sample)

(1) The inspectors reviewed appropriate elements of the reliable hardened containment wetwell vent as described in the plant specific submittals and the associated safety evaluation (ADAMS Accession No. ML19218A365) to determine whether the licensee was in compliance with NRC Order EA-13-109 Phase 1, Reliable, Severe Accident Capable Wetwell Venting System (ADAMS Accession No. ML13143A321).

The purpose of the inspection was to verify the licensee satisfactorily:

• Installed the Hardened Containment Vent System (HCVS) to meet the performance objectives outlined in Section A.1.1 of Attachment 2 to the Order EA-13-109;

• Installed the HCVS system with the design features specified in Section A.1.2 of Attachment 2 to the Order EA-13-109;

• Designed the HCVS to meet the quality standards described in Section A.2 of 2 to the Order EA-13-109;

• Developed and implemented adequate maintenance and testing of HCVS equipment to ensure their availability and capability;

• Developed and issued procedures to safely operate the HCVS using normal power supplies, during Extended Loss of AC Power (ELAP), and a postulated severe accident scenario, and integrated the procedures into existing plant procedures; and

• Trained their staff to assure personnel can proficiently operate the HCVS.

The inspectors reviewed appropriate elements of the reliable wetwell venting strategy as described in the plant specific submittals and the associated safety evaluation (ADAMS Accession No. ML19218A365) to determine whether the licensee was in compliance with NRC Order EA-13-109 Phase 2, Reliable, Severe Accident Capable Drywell (or alternative strategy) Venting System (ADAMS Accession No.

ML13143A321).

The purpose of the inspection was to verify the licensee satisfactorily developed a strategy making it unlikely to vent from the containment drywell, that includes the following:

• Implemented the Severe Accident Water Addition (SAWA)/Severe Accident Water Management (SAWM) systems as defined and fulfilled functional requirements for installed and portable equipment;

• Installed and/or identified the previously-installed instrumentation necessary to implement SAWM;

• Developed and implemented adequate maintenance and testing of SAWA/SAWM equipment to ensure availability and capability;

• Developed and issued procedures to safely operate the SAWA/SAWM during an ELAP and during postulated severe accident scenario, and integrated their procedures into their existing plant procedures such that entry into and exiting from the procedures are clear when using existing plant procedures; and

• Trained their staff to assure personnel can proficiently operate the HCVS during an ELAP and accident scenario.

The inspectors verified that any noncompliance with requirements, and standards identified during the inspection were entered into the licensee's corrective action program

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

• On November 20, 2019, the inspectors presented the NRC Temporary Instruction 2515/193, Implementation of Reliable Hardened Containment Vents Inspection results to Ms. D. McBreen and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

2515/193 Corrective Action 2703470 Technical Errors in Vendor Design Report for HCVS 08/11/2016

Documents 2716222 Hardened Containment Vent System (HCVS) Connection 09/15/2016

NDE Issue

3955609 HCVS Tower Knife Plate Bolted Connection Gap 12/08/2016

3970177 HCVS Rupture Disc Follow-Up 02/02/2017

3974587 2PC525A Passes Flow When in Normal 02/15/2017

4010161 HCVS Radiation Monitor Not Mounted Per Vendor Drawings 05/12/2017

4030989 Welded Lugs not Installed on HCVS Pipe 07/11/2019

4098335 Work Order to Set SAWA Flow Meter Parameter 01/29/2018

4109342 HCVS Electrical Routing Deviated from Design Drawings 02/28/2018

4145923 HCVS Batteries Require a Longer Equalizing Charge 05/31/2018

4151839 Trend IR: Small Argon Leak on U2 HCVS Bottle Banks 06/29/2018

4179990 NRC Identified - LOA-FSG-002 Contingency Path Issue 10/02/2018

284007 SAWA Flowmeter Orientation Discrepancy Identified 09/18/2019

296569 Incorrect Diagram Submitted with HCVS Final Integrated 11/12/2019

Plan

Corrective Action 4298204 2019 NRC HCVS Walkdown Observation 11/18/2019

Documents 4298700 NRC 2019 HCVS Inspection - Freeze Line 11/20/2019

Resulting from 4298703 NRC 2019 HCVS Inspection LGA-VQ-102/202 11/20/2019

Inspection

Drawings 1E-0-4000FA Key Diagram Hardened Containment Vent System (HCVS) A

25 VDC Distribution Panel 0DC52E

M-138 Sheet 2 P&ID Primary Containment Vent and Purge P

M-138 Sheet 3 P&ID Primary Containment Vent and Purge A

Miscellaneous Final Integrated Plan HCVS Order EA-13-109 12/14/2018

2018 - 2019 Long Range Training Plan 0

Procedures LGA-001 RPV Control 18

LGA-003 Primary Containment Control 18

LGA-004 RPV Blowdown 9

LGA-VQ-102 Unit 1 Emergency Containment Vent 4

LOA-AP-101 Unit 1, AC Power System Abnormal 59

Inspection Type Designation Description or Title Revision or

Procedure Date

LOA-FSG-002 FLEX Electrical Strategy 10

LOA-FSG-003 FLEX Water Supply Strategy 8

LOA-FSG-011 FLEX Beyond Design Basis External Event Guidance 6

LSAMG-001 RPV and Primary Containment Injection 0

LSAMG-002 RPV, Containment, and Radioactivity Release Control 1

Work Orders AR 4067775 HCVS Tee Weight Increase 10/24/2017

WO 1940217 - 71 U2 HCVS PCIV LLRT 02/16/2017

WO 1942017 - 66 U2 HCVS PCIV Testing, Main Control Room and Remote 02/13/2017

thru 69 Operating Station

WO 4571434 - 16 U2 HCVS Radiation Monitor Loop Calibration 02/23/2017

WO 4573336 - 29 U2 HCVS 2PC525A Troubleshooting 02/21/2017

WO 4591065 - 01 LOS-PC-R4, U2 HCVS Testing of ROS and Manual Bypass 02/15/2017

Valves

WO 4591094 - 01 LOS-PC-R6, U2 HCVS Test of 0PM08J Valves and Logic 02/15/2017

WO 4632060 - 19 LOS-PC-R4, U1 HCVS Testing of ROS and Manual Bypass 12/21/2017

Valves

WO 4632060 - 29 LOS-PC-R6, HCVS Test of 0PM08J Valves and Logic 12/21/2017

WO 4632060 - 40 U1 HCVS PCIV Testing, Main Control Room and Remote 12/21/2017

thru 43 Operating Station

WO 4632060 - 44 U1 HCVS PCIV LLRT 02/28/2018

WO 4653865 - 16 U1 HCVS Radiation Monitor and Argon Pressure Transmitter 01/26/2018

and 19 Loop Calibration

WO 4655747 - 01 U2 HCVS PCIV LLRT 03/03/2019

WO 4655748 - 01 LOS-PC-Q2, U2 HCVS Operability, Inservice Inspection, and 03/03/2019

Walkdown

WO 4655751 - 01 LOS-PC-R6, U2 HCVS Test of 0PM08J Valves and Logic 03/05/2019

WO 4655752 - 01 LOS-PC-R4, U2 HCVS Testing of ROS and Manual Bypass 03/05/2019

Valves

WO 4655753 - 01 LOS-PC-R3, U2 HCVS Valve and Logic Test 03/05/2019

WO 4663979 - 01 U2 HCVS Radiation Monitor Calibration and Maintenance 07/20/2018

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