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{{#Wiki_filter:December 31, 2008  
{{#Wiki_filter:December 31, 2008
  Mr. Charles G. Pardee President and Chief Nuclear Officer (CNO), Exelon Nuclear Chief Nuclear Officer (CNO), AmerGen Energy Company, LLC  
Mr. Charles G. Pardee
4300 Winfield Road Warrenville, IL 60555 SUBJECT: LASALLE COUNTY STATION, UNITS 1 AND 2 TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000373/2008007; 05000374/2008007 Dear Mr. Pardee: On November 21, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at your LaSalle County Station, Units 1 and 2. The enclosed report documents the results of this inspection, which were discussed on November 21, 2008, with Mr. D. Rhoades and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.
President and Chief Nuclear Officer (CNO), Exelon Nuclear
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Based on the results of this inspection, two NRC-identified findings of very low safety significance were identified. The findings involved a violation of NRC requirements. However, because of their very low safety significance, and because the issues were entered into your  
Chief Nuclear Officer (CNO), AmerGen Energy Company, LLC
corrective action program, the NRC is treating the issues as Non-Cited Violations (NCVs) in accordance with Section VI.A.1 of the NRC Enforcement Policy. If you contest the subject or severity of 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,  
4300 Winfield Road
DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the LaSalle County Station.  
Warrenville, IL 60555
C. Pardee     -2-  
SUBJECT:         LASALLE COUNTY STATION, UNITS 1 AND 2
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS),  
                TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000373/2008007;
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Sincerely, /RA by D. E. Hills Acting For/  
                05000374/2008007
Dear Mr. Pardee:
Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-373; 50-374 License Nos. NPF-11; NPF-18  
On November 21, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial
fire protection inspection at your LaSalle County Station, Units 1 and 2. The enclosed report
Enclosure: Inspection Report 05000373/2008007 05000374/2008007   w/Attachment: Supplemental Information  
documents the results of this inspection, which were discussed on November 21, 2008, with
cc w/encl: Site Vice President - LaSalle County Station   Plant Manager - LaSalle County Station  
Mr. D. Rhoades and other members of your staff.
  Regulatory Assurance Manager - LaSalle County Station   Chief Operating Officer and Senior Vice President   Senior Vice President - Midwest Operations   Senior Vice President - Operations Support   Vice President - Licensing and Regulatory Affairs  
The inspection examined activities conducted under your license as they relate to safety and
  Director - Licensing and Regulatory Affairs   Manager Licensing - Braidwood, Byron and LaSalle   Associate General Counsel   Document Control Desk - Licensing   Assistant Attorney General J. Klinger, State Liaison Officer,   Illinois Emergency Management Agency   Chairman, Illinois Commerce Commission  
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
C. Pardee     -2-  
personnel.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any), will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS),  
Based on the results of this inspection, two NRC-identified findings of very low safety
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).  
significance were identified. The findings involved a violation of NRC requirements. However,
Sincerely, /RA by D. E. Hills Acting For/  
because of their very low safety significance, and because the issues were entered into your
Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-373; 50-374 License Nos. NPF-11; NPF-18 Enclosure: Inspection Report 05000373/2008007; 05000374/2008007   w/Attachment: Supplemental Information  
corrective action program, the NRC is treating the issues as Non-Cited Violations (NCVs) in
cc w/encl: Site Vice President - LaSalle County Station   Plant Manager - LaSalle County Station  
accordance with Section VI.A.1 of the NRC Enforcement Policy.
  Regulatory Assurance Manager - LaSalle County Station   Chief Operating Officer and Senior Vice President   Senior Vice President - Midwest Operations   Senior Vice President - Operations Support   Vice President - Licensing and Regulatory Affairs  
If you contest the subject or severity of these NCVs, you should provide a response within
  Director - Licensing and Regulatory Affairs   Manager Licensing - Braidwood, Byron and LaSalle   Associate General Counsel   Document Control Desk - Licensing   Assistant Attorney General J. Klinger, State Liaison Officer,   Illinois Emergency Management Agency   Chairman, Illinois Commerce Commission  
30 days of the date of this inspection report, with the basis for your denial, to the U.S.
  DOCUMENT NAME: G\DRS\Work in Progress\LaSalle 2008-007 DRS RAL.doc  Publicly Available   Non-Publicly Available Sensitive Non-Sensitive
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington,
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
DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory
  OFFICE RIII N RIII       NAME RLangsta
Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the
ff:ls DHills for RDaley   DATE 12/31/08 12/31/08     OFFICIAL RECORD COPY  
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC
  Letter to Mr. Charles Pardee from Mr. Robert Daley dated December 31, 2009. SUBJECT: LASALLE COUNTY STATION, UNITS 1 AND 2 TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000373/2008007; 05000374/2008007 DISTRIBUTION
20555-0001; and the Resident Inspector Office at the LaSalle County Station.
: Tamara Bloomer  
 
RidsNrrDorlLpl3-2 RidsNrrPMLaSalle RidsNrrDirsIrib Resource Mark Satorius Kenneth Obrien  
C. Pardee                                     -2-
Jared Heck Carole Ariano  
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,
Linda Linn Cynthia Pederson DRPIII DRSIII Patricia Buckley  
its enclosure, and your response (if any), will be available electronically for public inspection in
Tammy Tomczak ROPreports@nrc.gov
the NRC Public Document Room or from the Publicly Available Records System (PARS)
Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket Nos: 05000373/2008007; 05000374/2008007 License Nos: NPF-11; NPF-18 Report No: 05000373/2008007; 05000374/2008007 Licensee: Exelon Generation Company, LLC  
component of NRC's Agencywide Documents Access and Management System (ADAMS),
Facility: LaSalle County Station, Units 1 and 2 Location: Marseilles, IL Dates: November 3 through November 21, 2008 Inspectors: R. Langstaff, Senior Reactor Inspector, Lead Z. Falevits, Senior Reactor Inspector  
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public
R. Winter, Reactor Inspector Approved by: R. Daley, Chief Engineering Branch 3 Division of Reactor Safety  
Electronic Reading Room).
Enclosure  
                                              Sincerely,
1SUMMARY OF FINDINGS IR 05000373/2008007, 05000374/2008007; 11/03/2008-11/21/2008; LaSalle County Station, Units 1 & 2. This report covers an announced baseline inspection by regional inspectors. Two Green findings were identified by the inspectors. The findings were considered Non-Cited Violations (NCVs) of NRC regulations. The significance of most findings is indicated by their color (Green,  
                                              /RA by D. E. Hills Acting For/
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 4, dated December 2006. A. NRC-Identified and Self-Revealed Findings
                                              Robert C. Daley, Chief
Cornerstone: Initiating Events  
                                              Engineering Branch 3
* Green. A finding of very low safety significance and associated NCV of Technical Specifications was identified by the inspectors for the failure to implement a fire protection program procedure for combustible controls. Specifically, the inspectors identified three examples where transient combustible materials were staged adjacent to cable risers contrary to the licensee's procedure for combustible controls. The licensee subsequently removed the transient combustible materials and entered the issue into their corrective action program. The finding was determined to be more than minor because, the finding was similar to IMC 0612, Appendix E, Example 4.k, in that the transient combustibles presented credible fire scenarios, which could affect equipment important to safety. The issue was of very low safety significance because, the finding represented a low degradation of the licensee's combustible controls program. Additionally, this finding has a cross-cutting  
                                              Division of Reactor Safety
aspect in the area of Human Performance for the Work Practices component because, multiple examples were identified where transient combustibles were staged contrary to site procedures. [H.4(b)] (Section 1R05.2.b(1)) Cornerstone: Mitigating Systems  
Docket Nos. 50-373; 50-374
* Green. A finding of very low safety significance and associated NCV of the license condition was identified by the inspectors for the failure to install a sprinkler system. Specifically, the licensee had installed a pre-action spray system above the suspended  
License Nos. NPF-11; NPF-18
ceiling in Fire Zone 4F3 instead of a pre-action sprinkler system as specified by the Fire Protection Report. The licensee subsequently entered the issue into its correction action program.  
Enclosure:     Inspection Report 05000373/2008007 05000374/2008007
Enclosure  
                  w/Attachment: Supplemental Information
2The finding was determined to be more than minor because, the installed spray system was less capable than a sprinkler system in that, a fire would be permitted to grow to a larger size and cause more damage as a result of delayed system actuation. The issue was of very low safety significance due to remaining mitigating system capability. (Section 1R05.4.b(1)) B. Licensee-Identified Violations
cc w/encl:     Site Vice President - LaSalle County Station
No violations of significance were identified.  
                Plant Manager - LaSalle County Station
Enclosure  
                Regulatory Assurance Manager - LaSalle County Station
3REPORT DETAILS
                Chief Operating Officer and Senior Vice President
1. REACTOR SAFETY Cornerstone: Initiating Events and Mitigating Systems 1R05 Fire Protection (71111.05T) The purpose of the Fire Protection Triennial Baseline Inspection was to conduct a design-based, plant specific, risk-informed, onsite inspection of the licensee's fire protection program's defense-in-depth elements used to mitigate the consequences of a fire. The fire protection program shall extend the concept of defense-in-depth to fire protection in plant areas important to safety by:  
                Senior Vice President - Midwest Operations
* preventing fires from starting;  
                Senior Vice President - Operations Support
* rapidly detecting, controlling and extinguishing fires that do occur; and
                Vice President - Licensing and Regulatory Affairs
* providing protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by fire suppression activities will not prevent the safe shutdown of the reactor plant. The inspectors' evaluation focused on the design, operational status, and material condition of the reactor plant's fire protection program and post-fire safe shutdown systems. The objectives of the inspection were to assess whether the licensee had  
                Director - Licensing and Regulatory Affairs
implemented a fire protection program that: (1) provided adequate controls for combustibles and ignition sources inside the plant; (2) provided adequate fire detection and suppression capability; (3) maintained passive fire protection features in good material condition; (4) established adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems or features; (5) ensured that  
                Manager Licensing - Braidwood, Byron and LaSalle
procedures, equipment, fire barriers and systems exist so that the post-fire capability to safely shutdown the plant was ensured; (6) included feasible and reliable operator manual actions when appropriate to achieve safe shutdown; and (7) identified fire protection issues at an appropriate threshold and ensured these issues were entered into the licensee's problem identification and resolution program. In addition, the inspectors' review and assessment focused on the licensee's post-fire safe shutdown systems for selected risk-significant fire areas. Inspector emphasis was  
                Associate General Counsel
placed on determining that the post-fire safe shutdown capability and the fire protection features were maintained free of fire damage to ensure that at least one post-fire safe shutdown success path was available. The inspection was performed in accordance with U. S. Nuclear Regulatory Commission (NRC) Inspection Procedure (IP) 71111.05T, "Fire Protection (Triennial)," dated April 21, 2006. The NRC regulatory oversight  
                Document Control Desk - Licensing
process IP used a risk-informed approach for selecting the fire areas and/or fire zones and attributes to be inspected. The inspectors with assistance from a senior reactor analyst used the licensee's Individual Plant Examination for External Events to select several risk-significant areas for detailed inspection and review. Documents reviewed are listed in the Attachment to this report.   The fire areas and/or fire zones selected for review during this inspection are listed below and constituted three inspection samples as defined in IP 71111.05T.  
                Assistant Attorney General
Enclosure  
                J. Klinger, State Liaison Officer,
4 Fire Zone Description
                Illinois Emergency Management Agency
  4D1 Unit 1 Cable Spreading Room 4E1 Unit 1 Auxiliary Electric Room 4F3 Auxiliary Building, Ground Floor (Unit 1 portion) .2 Shutdown from Outside Main Control Room
                Chairman, Illinois Commerce Commission
a. Inspection Scope
 
The inspectors reviewed the functional requirements identified by the licensee as necessary for achieving and maintaining hot shutdown conditions to ensure that at least  
C. Pardee                                                                 -2-
one post-fire safe shutdown success path was available in the event of fire in each of the selected fire areas and for alternative shutdown in the case of a fire in the Unit 1 auxiliary electric room requiring shutdown actions outside the control room. The inspectors reviewed the plant systems required to achieve and maintain post-fire safe shutdown to determine if the licensee had properly identified the components and  
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,
systems necessary to achieve and maintain safe shutdown conditions for each fire area selected for review. Specifically, the review was performed to determine the adequacy of the systems selected for reactivity control, reactor coolant inventory makeup, reactor heat removal, process monitoring, and support system functions. The review also included the fire safe shutdown analysis to ensure that all required components in the  
its enclosure, and your response (if any), will be available electronically for public inspection in
selected systems were included in the licensee's safe shutdown analysis. The inspectors reviewed the licensee's post-fire safe shutdown analysis, normal and abnormal operating procedures, piping and instrumentation drawings, electrical drawings, their updated final safety analysis report, and other supporting documents to verify that hot and cold shutdown could be achieved and maintained from outside the  
the NRC Public Document Room or from the Publicly Available Records System (PARS)
control room for a fire in the Unit 1 auxiliary electric room that relies on shutdown from outside the control room. This review included verification that shutdown from outside the control room could be performed both with and without the availability of offsite power. The inspectors also examined the operators' ability to perform the necessary manual actions for achieving safe shutdown by reviewing post-fire shutdown procedures, the accessibility of safe shutdown equipment, and the available time for performing the  
component of NRC's Agencywide Documents Access and Management System (ADAMS),
actions. The inspectors reviewed the updated final safety analysis report and the licensee's engineering and/or licensing justifications (e.g., NRC guidance documents, license amendments, Technical Specifications, safety evaluation reports, exemptions, and deviations) to determine the licensing basis. b. Findings
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public
No findings of significance were identified.
Electronic Reading Room).
Enclosure  
                                                                          Sincerely,
5.3 Protection of Safe Shutdown Capabilities
                                                                          /RA by D. E. Hills Acting For/
a. Inspection Scope
                                                                          Robert C. Daley, Chief
For each of the selected fire areas, the inspectors reviewed the fire hazards analysis, safe shutdown analysis, and supporting drawings and documentation to verify that safe shutdown capabilities were properly protected. The inspectors reviewed the licensee procedures and programs for the control of ignition sources and transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the fire hazards analysis. The inspectors performed plant walkdowns to verify that protective features were being properly maintained and administrative controls were being implemented. The inspectors also reviewed the licensee's design control procedures to ensure that the process included appropriate reviews and controls to assess plant changes for any potential adverse impact on the fire protection program and/or post-fire safe shutdown analysis and procedures. b. Findings
                                                                          Engineering Branch 3
(1) Unauthorized Transient Combustibles
                                                                          Division of Reactor Safety
Introduction: A finding of very low safety significance and associated Non-Cited Violation (NCV) of Technical Specifications was identified by the inspectors for the  
Docket Nos. 50-373; 50-374
failure to implement a fire protection program procedure for combustible controls. Specifically, the inspectors identified three examples where transient combustible materials were staged adjacent to cable risers contrary to Procedure OP-AA-201-009, "Control of Combustible Material," Revision 7. Description: On October 22, 2008, the inspectors identified a plastic chair staged adjacent to cable risers in the auxiliary building. Specifically, the plastic chair was located between two cable risers and was less than two feet from cable risers containing safety-related cables. The licensee placed the issue into their corrective action program (Action Request (AR) 00834512, "NRC Identified Combustibles During Walkdown with FP Engineer") and subsequently removed the chair. On November 4, 2008, the  
License Nos. NPF-11; NPF-18
inspectors identified an unattended fiberglass cart with rags and tools in the upper tray adjacent to a cable riser containing emergency shutdown system cables (AR 00841326, "NRC ID: Transient Combustible Near Vertical Power Riser"). On November 6, 2008, the inspectors identified a black foam sheet of insulation material, approximately two feet square, left behind and adjacent to a cable riser containing reactor protection system  
Enclosure:               Inspection Report 05000373/2008007; 05000374/2008007
cables (AR 00841490, "NRC Triennial FP Inspection Walkdown"). The licensee initiated corrective action by removing the transient combustible material. Additionally, the licensee performed an extent of condition review and documented their findings in their corrective action program (AR 00841673, "Transient Combustible Material Extent of Condition Walkdown"). Procedure OP-AA-201-009 was the site procedure for combustible controls which, in part, implemented the site fire protection program. Procedure OP-AA-201-009, Section 4.4.2, Paragraph 6, directed licensee personnel to avoid staging exposed
                            w/Attachment: Supplemental Information
Enclosure  
cc w/encl:               Site Vice President - LaSalle County Station
6Class A combustible material immediately adjacent to (i.e., within approximately three feet) cable risers. The inspectors noted that National Fire Protection Association (NFPA) 10, "Standard for Portable Fire Extinguishers," defined Class A fires as fires in ordinary combustible materials, such as wood, cloth, paper, rubber, and many plastics. As such, the inspectors considered the identified materials to be Class A materials located in manner contrary to site implementing procedures for the fire protection program. Analysis: The inspectors determined that staging combustible materials adjacent to cable risers was contrary to site implementing procedures for the fire protection program and was a performance deficiency. Specifically, the inspectors identified three examples where Class A combustible materials were staged near cable risers was contrary to Procedure OP-AA-201-009. The finding was determined to be more than minor because the finding was similar to Inspection Manual Chapter (IMC) 0612, Appendix E, Example 4.k. The Class A transient combustible materials (i.e., the chair, the cart, and the foam insulation) were not in approved temporary storage locations approved by an engineering evaluation. Specifically, the transient combustibles were located within the zone of influence for a 70 kiloWatt fire for the thermoset cables located within the vertical cable risers (IMC 0609, Appendix F, "Fire Protection Significance Determination Process," dated  
                          Plant Manager - LaSalle County Station
February 28, 2005, Table 2.3.2). Consequently, the transient combustibles created credible fire scenarios that could affect equipment important to safety (such as the safety-related cables and/or cables required for safe shutdown, within the vertical cable risers). Therefore, this performance deficiency impacted the Initiating Events Cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge  
                          Regulatory Assurance Manager - LaSalle County Station
critical safety functions during plant operations. The inspectors reviewed IMC 0609, Appendix A, and determined that since the finding affected administrative controls for fire protection, a significance determination evaluation under IMC 0609, Appendix F, was required. The inspectors completed a significance determination of this issue using IMC 0609, Appendix F, Attachment 2, "Degradation  
                          Chief Operating Officer and Senior Vice President
Rating Guidance Specific to Various Fire Protection Program Elements," dated February 28, 2005. The inspectors determined that the staging of Class A combustibles was a low degradation finding against the combustible controls program because the identified materials would not cause a fire from existing sources of heat or electrical energy. Question 1 of IMC 0609, Appendix F, Task 1.3.1, "Qualitative Screening for All  
                          Senior Vice President - Midwest Operations
Finding Categories," showed that the finding was of very low safety significance (Green) due to the low degradation rating. This finding has a cross-cutting aspect in the area of Human Performance for the Work Practices component because the licensee did not define and effectively communicate expectations regarding procedural compliance and personnel failed to follow procedures.
                          Senior Vice President - Operations Support
Specifically, multiple examples were identified where transient combustibles were staged contrary to site procedures. (Example H.4(b)). Enforcement: Technical Specification, Section 5.4.1 required, in part, that written procedures shall be established, implemented, and maintained for fire protection program implementation. The licensee established Procedure OP-AA-201-009 as the implementing procedure for combustible controls for their fire protection program. Section 4.4.2, Paragraph 6, of Procedure OP-AA-201-009 directed licensee personnel to
                          Vice President - Licensing and Regulatory Affairs
Enclosure  
                          Director - Licensing and Regulatory Affairs
7avoid staging exposed Class A combustible material immediately adjacent to (i.e., within approximately three feet) cable risers. Contrary to the above, On October 22, 2008; November 4, 2008; and November 6, 2008, the licensee failed to implement a procedure for fire protection program implementation in that Class A combustible materials were staged adjacent to cable risers contrary to OP-AA-201-009. Specifically, a plastic chair was located less than two feet from cable  
                          Manager Licensing - Braidwood, Byron and LaSalle
risers containing reactor protection system cables (October 22, 2008), an unattended fiberglass cart with rags and tools in the upper tray was adjacent to a cable riser containing emergency shutdown system cables (November 4, 2008), and a black foam sheet of insulation material was left behind and adjacent to a cable riser containing reactor protection system cables (November 6, 2008). Once identified, the licensee removed the  
                          Associate General Counsel
transient combustible materials and entered the issue into their corrective action program (AR 00834512, AR 00841326, and AR 00841490). Because this violation was of very low safety significance and it was entered into the licensee's corrective action program, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy (NCV 05000373/2008007-01(DRS); 05000374/2008007-01(DRS)). .4 Passive Fire Protection
                          Document Control Desk - Licensing
a. Inspection Scope
                          Assistant Attorney General
For the selected fire areas, the inspectors evaluated the adequacy of fire area barriers, penetration seals, fire doors, electrical raceway fire barriers, and fire rated electrical cables. The inspectors observed the material condition and configuration of the installed barriers, seals, doors, and cables. The inspectors reviewed approved construction details and supporting fire tests. In addition, the inspectors reviewed license documentation, such  
                          J. Klinger, State Liaison Officer,
as NRC safety evaluation reports, and deviations from NRC regulations and the National Fire Protection Association codes to verify that fire protection features met license commitments. The inspectors walked down accessible portions of the selected fire areas to observe material condition and the adequacy of design of fire area boundaries (including walls, fire  
                            Illinois Emergency Management Agency
doors, and fire dampers) to ensure they were appropriate for the fire hazards in the area. The inspectors reviewed the installation, repair, and qualification records for a sample of penetration seals to ensure the fill material was of the appropriate fire rating and that the installation met the engineering design. b. Findings
                          Chairman, Illinois Commerce Commission
No findings of significance were identified. .5 Active Fire Protection
DOCUMENT NAME: G\DRS\Work in Progress\LaSalle 2008-007 DRS RAL.doc
a. Inspection Scope
  Publicly Available                         Non-Publicly Available                   Sensitive             Non-Sensitive
For the selected fire areas, the inspectors evaluated the adequacy of fire suppression and detection systems. The inspectors observed the material condition and configuration of
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
Enclosure  
  OFFICE                 RIII                   N RIII
8the installed fire detection and suppression systems. The inspectors reviewed design documents and supporting calculations. In addition, the inspectors reviewed license basis documentation, such as, NRC safety evaluation reports, deviations from NRC regulations, and the National Fire Protection Association codes to verify that fire suppression and detection systems met license commitments. b. Findings
NAME                   RLangstaff:ls                 DHills for RDaley
DATE                   12/31/08                     12/31/08
                                                          OFFICIAL RECORD COPY
 
Letter to Mr. Charles Pardee from Mr. Robert Daley dated December 31, 2009.
SUBJECT:       LASALLE COUNTY STATION, UNITS 1 AND 2
              TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000373/2008007;
              05000374/2008007
DISTRIBUTION:
Tamara Bloomer
RidsNrrDorlLpl3-2
RidsNrrPMLaSalle
RidsNrrDirsIrib Resource
Mark Satorius
Kenneth Obrien
Jared Heck
Carole Ariano
Linda Linn
Cynthia Pederson
DRPIII
DRSIII
Patricia Buckley
Tammy Tomczak
ROPreports@nrc.gov
 
          U.S. NUCLEAR REGULATORY COMMISSION
                          REGION III
Docket Nos:         05000373/2008007; 05000374/2008007
License Nos:       NPF-11; NPF-18
Report No:         05000373/2008007; 05000374/2008007
Licensee:           Exelon Generation Company, LLC
Facility:           LaSalle County Station, Units 1 and 2
Location:           Marseilles, IL
Dates:             November 3 through November 21, 2008
Inspectors:         R. Langstaff, Senior Reactor Inspector, Lead
                    Z. Falevits, Senior Reactor Inspector
                    R. Winter, Reactor Inspector
Approved by:       R. Daley, Chief
                    Engineering Branch 3
                    Division of Reactor Safety
                                                                Enclosure
 
                                    SUMMARY OF FINDINGS
IR 05000373/2008007, 05000374/2008007; 11/03/2008-11/21/2008; LaSalle County Station,
Units 1 & 2.
This report covers an announced baseline inspection by regional inspectors. Two Green
findings were identified by the inspectors. The findings were considered Non-Cited Violations
(NCVs) 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 NRCs program for overseeing the safe
operation of commercial nuclear power reactors is described in NUREG-1649, Reactor
Oversight Process, Revision 4, dated December 2006.
A.     NRC-Identified and Self-Revealed Findings
        Cornerstone: Initiating Events
    *   Green. A finding of very low safety significance and associated NCV of Technical
        Specifications was identified by the inspectors for the failure to implement a fire
        protection program procedure for combustible controls. Specifically, the inspectors
        identified three examples where transient combustible materials were staged adjacent to
        cable risers contrary to the licensees procedure for combustible controls. The licensee
        subsequently removed the transient combustible materials and entered the issue into
        their corrective action program.
        The finding was determined to be more than minor because, the finding was similar to
        IMC 0612, Appendix E, Example 4.k, in that the transient combustibles presented
        credible fire scenarios, which could affect equipment important to safety. The issue was
        of very low safety significance because, the finding represented a low degradation of the
        licensees combustible controls program. Additionally, this finding has a cross-cutting
        aspect in the area of Human Performance for the Work Practices component because,
        multiple examples were identified where transient combustibles were staged contrary to
        site procedures. [H.4(b)] (Section 1R05.2.b(1))
        Cornerstone: Mitigating Systems
    *   Green. A finding of very low safety significance and associated NCV of the license
        condition was identified by the inspectors for the failure to install a sprinkler system.
        Specifically, the licensee had installed a pre-action spray system above the suspended
        ceiling in Fire Zone 4F3 instead of a pre-action sprinkler system as specified by the Fire
        Protection Report. The licensee subsequently entered the issue into its correction action
        program.
                                                  1                                          Enclosure
 
  The finding was determined to be more than minor because, the installed spray system
  was less capable than a sprinkler system in that, a fire would be permitted to grow to a
  larger size and cause more damage as a result of delayed system actuation. The issue
  was of very low safety significance due to remaining mitigating system capability.
  (Section 1R05.4.b(1))
B. Licensee-Identified Violations
  No violations of significance were identified.
                                            2                                      Enclosure
 
                                        REPORT DETAILS
1.   REACTOR SAFETY
    Cornerstone: Initiating Events and Mitigating Systems
1R05 Fire Protection (71111.05T)
    The purpose of the Fire Protection Triennial Baseline Inspection was to conduct a
    design-based, plant specific, risk-informed, onsite inspection of the licensees fire
    protection programs defense-in-depth elements used to mitigate the consequences of a
    fire. The fire protection program shall extend the concept of defense-in-depth to fire
    protection in plant areas important to safety by:
    *     preventing fires from starting;
    *     rapidly detecting, controlling and extinguishing fires that do occur; and
    *     providing protection for structures, systems, and components important to safety
            so that a fire that is not promptly extinguished by fire suppression activities will not
            prevent the safe shutdown of the reactor plant.
    The inspectors evaluation focused on the design, operational status, and material
    condition of the reactor plants fire protection program and post-fire safe shutdown
    systems. The objectives of the inspection were to assess whether the licensee had
    implemented a fire protection program that: (1) provided adequate controls for
    combustibles and ignition sources inside the plant; (2) provided adequate fire detection
    and suppression capability; (3) maintained passive fire protection features in good
    material condition; (4) established adequate compensatory measures for out-of-service,
    degraded or inoperable fire protection equipment, systems or features; (5) ensured that
    procedures, equipment, fire barriers and systems exist so that the post-fire capability to
    safely shutdown the plant was ensured; (6) included feasible and reliable operator
    manual actions when appropriate to achieve safe shutdown; and (7) identified fire
    protection issues at an appropriate threshold and ensured these issues were entered
    into the licensees problem identification and resolution program.
    In addition, the inspectors review and assessment focused on the licensees post-fire
    safe shutdown systems for selected risk-significant fire areas. Inspector emphasis was
    placed on determining that the post-fire safe shutdown capability and the fire protection
    features were maintained free of fire damage to ensure that at least one post-fire safe
    shutdown success path was available. The inspection was performed in accordance
    with U. S. Nuclear Regulatory Commission (NRC) Inspection Procedure (IP) 71111.05T,
    Fire Protection (Triennial), dated April 21, 2006. The NRC regulatory oversight
    process IP used a risk-informed approach for selecting the fire areas and/or fire zones
    and attributes to be inspected. The inspectors with assistance from a senior reactor
    analyst used the licensees Individual Plant Examination for External Events to select
    several risk-significant areas for detailed inspection and review. Documents reviewed
    are listed in the Attachment to this report.
    The fire areas and/or fire zones selected for review during this inspection are listed
    below and constituted three inspection samples as defined in IP 71111.05T.
                                                3                                        Enclosure
 
                Fire Zone     Description
                4D1           Unit 1 Cable Spreading Room
                4E1           Unit 1 Auxiliary Electric Room
                              Auxiliary Building, Ground Floor (Unit 1 portion)
                4F3
.2   Shutdown from Outside Main Control Room
  a. Inspection Scope
    The inspectors reviewed the functional requirements identified by the licensee as
    necessary for achieving and maintaining hot shutdown conditions to ensure that at least
    one post-fire safe shutdown success path was available in the event of fire in each of the
    selected fire areas and for alternative shutdown in the case of a fire in the Unit 1
    auxiliary electric room requiring shutdown actions outside the control room. The
    inspectors reviewed the plant systems required to achieve and maintain post-fire safe
    shutdown to determine if the licensee had properly identified the components and
    systems necessary to achieve and maintain safe shutdown conditions for each fire area
    selected for review. Specifically, the review was performed to determine the adequacy
    of the systems selected for reactivity control, reactor coolant inventory makeup, reactor
    heat removal, process monitoring, and support system functions. The review also
    included the fire safe shutdown analysis to ensure that all required components in the
    selected systems were included in the licensees safe shutdown analysis.
    The inspectors reviewed the licensees post-fire safe shutdown analysis, normal and
    abnormal operating procedures, piping and instrumentation drawings, electrical
    drawings, their updated final safety analysis report, and other supporting documents to
    verify that hot and cold shutdown could be achieved and maintained from outside the
    control room for a fire in the Unit 1 auxiliary electric room that relies on shutdown from
    outside the control room. This review included verification that shutdown from outside
    the control room could be performed both with and without the availability of offsite
    power.
    The inspectors also examined the operators ability to perform the necessary manual
    actions for achieving safe shutdown by reviewing post-fire shutdown procedures, the
    accessibility of safe shutdown equipment, and the available time for performing the
    actions.
    The inspectors reviewed the updated final safety analysis report and the licensees
    engineering and/or licensing justifications (e.g., NRC guidance documents, license
    amendments, Technical Specifications, safety evaluation reports, exemptions, and
    deviations) to determine the licensing basis.
  b. Findings
    No findings of significance were identified.
                                                4                                      Enclosure
 
.3   Protection of Safe Shutdown Capabilities
  a. Inspection Scope
      For each of the selected fire areas, the inspectors reviewed the fire hazards analysis,
      safe shutdown analysis, and supporting drawings and documentation to verify that safe
      shutdown capabilities were properly protected.
      The inspectors reviewed the licensee procedures and programs for the control of ignition
      sources and transient combustibles to assess their effectiveness in preventing fires and
      in controlling combustible loading within limits established in the fire hazards analysis.
      The inspectors performed plant walkdowns to verify that protective features were being
      properly maintained and administrative controls were being implemented.
      The inspectors also reviewed the licensees design control procedures to ensure that the
      process included appropriate reviews and controls to assess plant changes for any
      potential adverse impact on the fire protection program and/or post-fire safe shutdown
      analysis and procedures.
  b. Findings
  (1) Unauthorized Transient Combustibles
      Introduction: A finding of very low safety significance and associated Non-Cited
      Violation (NCV) of Technical Specifications was identified by the inspectors for the
      failure to implement a fire protection program procedure for combustible controls.
      Specifically, the inspectors identified three examples where transient combustible
      materials were staged adjacent to cable risers contrary to Procedure OP-AA-201-009,
      Control of Combustible Material, Revision 7.
      Description: On October 22, 2008, the inspectors identified a plastic chair staged
      adjacent to cable risers in the auxiliary building. Specifically, the plastic chair was
      located between two cable risers and was less than two feet from cable risers containing
      safety-related cables. The licensee placed the issue into their corrective action program
      (Action Request (AR) 00834512, NRC Identified Combustibles During Walkdown with
      FP Engineer) and subsequently removed the chair. On November 4, 2008, the
      inspectors identified an unattended fiberglass cart with rags and tools in the upper tray
      adjacent to a cable riser containing emergency shutdown system cables (AR 00841326,
      NRC ID: Transient Combustible Near Vertical Power Riser). On November 6, 2008,
      the inspectors identified a black foam sheet of insulation material, approximately two feet
      square, left behind and adjacent to a cable riser containing reactor protection system
      cables (AR 00841490, NRC Triennial FP Inspection Walkdown). The licensee initiated
      corrective action by removing the transient combustible material. Additionally, the
      licensee performed an extent of condition review and documented their findings in their
      corrective action program (AR 00841673, Transient Combustible Material Extent of
      Condition Walkdown).
      Procedure OP-AA-201-009 was the site procedure for combustible controls which, in
      part, implemented the site fire protection program. Procedure OP-AA-201-009,
      Section 4.4.2, Paragraph 6, directed licensee personnel to avoid staging exposed
                                                5                                        Enclosure
 
Class A combustible material immediately adjacent to (i.e., within approximately three feet)
cable risers. The inspectors noted that National Fire Protection Association (NFPA) 10,
Standard for Portable Fire Extinguishers, defined Class A fires as fires in ordinary
combustible materials, such as wood, cloth, paper, rubber, and many plastics. As such,
the inspectors considered the identified materials to be Class A materials located in
manner contrary to site implementing procedures for the fire protection program.
Analysis: The inspectors determined that staging combustible materials adjacent to cable
risers was contrary to site implementing procedures for the fire protection program and
was a performance deficiency. Specifically, the inspectors identified three examples
where Class A combustible materials were staged near cable risers was contrary to
Procedure OP-AA-201-009.
The finding was determined to be more than minor because the finding was similar to
Inspection Manual Chapter (IMC) 0612, Appendix E, Example 4.k. The Class A transient
combustible materials (i.e., the chair, the cart, and the foam insulation) were not in
approved temporary storage locations approved by an engineering evaluation.
Specifically, the transient combustibles were located within the zone of influence for
a 70 kiloWatt fire for the thermoset cables located within the vertical cable risers
(IMC 0609, Appendix F, Fire Protection Significance Determination Process, dated
February 28, 2005, Table 2.3.2). Consequently, the transient combustibles created
credible fire scenarios that could affect equipment important to safety (such as the
safety-related cables and/or cables required for safe shutdown, within the vertical cable
risers). Therefore, this performance deficiency impacted the Initiating Events Cornerstone
objective of limiting the likelihood of those events that upset plant stability and challenge
critical safety functions during plant operations.
The inspectors reviewed IMC 0609, Appendix A, and determined that since the finding
affected administrative controls for fire protection, a significance determination evaluation
under IMC 0609, Appendix F, was required. The inspectors completed a significance
determination of this issue using IMC 0609, Appendix F, Attachment 2, Degradation
Rating Guidance Specific to Various Fire Protection Program Elements, dated
February 28, 2005. The inspectors determined that the staging of Class A combustibles
was a low degradation finding against the combustible controls program because the
identified materials would not cause a fire from existing sources of heat or electrical
energy. Question 1 of IMC 0609, Appendix F, Task 1.3.1, Qualitative Screening for All
Finding Categories, showed that the finding was of very low safety significance (Green)
due to the low degradation rating.
This finding has a cross-cutting aspect in the area of Human Performance for the Work
Practices component because the licensee did not define and effectively communicate
expectations regarding procedural compliance and personnel failed to follow procedures.
Specifically, multiple examples were identified where transient combustibles were staged
contrary to site procedures. (Example H.4(b)).
Enforcement: Technical Specification, Section 5.4.1 required, in part, that written
procedures shall be established, implemented, and maintained for fire protection program
implementation. The licensee established Procedure OP-AA-201-009 as the
implementing procedure for combustible controls for their fire protection program.
Section 4.4.2, Paragraph 6, of Procedure OP-AA-201-009 directed licensee personnel to
                                            6                                        Enclosure
 
    avoid staging exposed Class A combustible material immediately adjacent to (i.e., within
    approximately three feet) cable risers.
    Contrary to the above, On October 22, 2008; November 4, 2008; and November 6, 2008,
    the licensee failed to implement a procedure for fire protection program implementation
    in that Class A combustible materials were staged adjacent to cable risers contrary to
    OP-AA-201-009. Specifically, a plastic chair was located less than two feet from cable
    risers containing reactor protection system cables (October 22, 2008), an unattended
    fiberglass cart with rags and tools in the upper tray was adjacent to a cable riser
    containing emergency shutdown system cables (November 4, 2008), and a black foam
    sheet of insulation material was left behind and adjacent to a cable riser containing reactor
    protection system cables (November 6, 2008). Once identified, the licensee removed the
    transient combustible materials and entered the issue into their corrective action program
    (AR 00834512, AR 00841326, and AR 00841490). Because this violation was of very low
    safety significance and it was entered into the licensees corrective action program, this
    violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC
    Enforcement Policy (NCV 05000373/2008007-01(DRS); 05000374/2008007-01(DRS)).
.4   Passive Fire Protection
  a. Inspection Scope
    For the selected fire areas, the inspectors evaluated the adequacy of fire area barriers,
    penetration seals, fire doors, electrical raceway fire barriers, and fire rated electrical
    cables. The inspectors observed the material condition and configuration of the installed
    barriers, seals, doors, and cables. The inspectors reviewed approved construction details
    and supporting fire tests. In addition, the inspectors reviewed license documentation, such
    as NRC safety evaluation reports, and deviations from NRC regulations and the National
    Fire Protection Association codes to verify that fire protection features met license
    commitments.
    The inspectors walked down accessible portions of the selected fire areas to observe
    material condition and the adequacy of design of fire area boundaries (including walls, fire
    doors, and fire dampers) to ensure they were appropriate for the fire hazards in the area.
    The inspectors reviewed the installation, repair, and qualification records for a sample of
    penetration seals to ensure the fill material was of the appropriate fire rating and that the
    installation met the engineering design.
  b. Findings
    No findings of significance were identified.
.5   Active Fire Protection
  a. Inspection Scope
    For the selected fire areas, the inspectors evaluated the adequacy of fire suppression and
    detection systems. The inspectors observed the material condition and configuration of
                                                7                                          Enclosure
 
    the installed fire detection and suppression systems. The inspectors reviewed design
    documents and supporting calculations. In addition, the inspectors reviewed license basis
    documentation, such as, NRC safety evaluation reports, deviations from NRC regulations,
    and the National Fire Protection Association codes to verify that fire suppression and
    detection systems met license commitments.
b.   Findings
  (1) Failure to Provide a Sprinkler System for Fire Zone 4F3
  (1) Failure to Provide a Sprinkler System for Fire Zone 4F3
Introduction: A finding of very low safety significance and associated NCV of license conditions 2.C(25) and 2.C(15) for Units 1 and 2, respectively, was identified by the inspectors for the failure to install a sprinkler system in Fire Zone 4F3. Specifically, the licensee had installed a pre-action spray system above the suspended ceiling in Fire Zone  
    Introduction: A finding of very low safety significance and associated NCV of license
4F3 instead of a pre-action sprinkler system as specified by the Fire Protection Report. Description: Fire Zone 4F3 was centrally located on the ground floor of the auxiliary building. In addition to serving as a chemistry laboratory area, the zone served as a cable spreading area for Division I cables for both units. The cable spreading area was located above the suspended ceiling for the chemistry laboratory facilities. As part of licensing amendment 49, dated May 1980, the license committed to provide an automatic sprinkler system for the cable concentration above the suspended ceiling in this  
    conditions 2.C(25) and 2.C(15) for Units 1 and 2, respectively, was identified by the
area. Additionally, Section H.3.4.18, "Auxiliary Building Ground Floor - Fire Zone 4F3," of the LaSalle County Station Fire Protection Report stated "A pre-action sprinkler system is located above the suspended ceiling to protect the cabling located there.The inspectors noted that sprinkler systems generally have sprinklers located near the ceiling. The code of record for sprinklers used at LaSalle County Station was NFPA 13-1976, "Standard for  
    inspectors for the failure to install a sprinkler system in Fire Zone 4F3. Specifically, the
the Installation of Sprinkler Systems.The suppression system installed above the suspended ceiling for Fire Zone 4F3 was not a sprinkler system and did not meet the requirements of NFPA 13-1976. Specifically, Section 3-15.2.1 of NFPA 13-1976 required that listed sprinklers be used. The licensee's installation used spray nozzles. Section 4-3.2.1 of NFPA 13-1976 specified that deflectors of sprinklers be located 1 to  
    licensee had installed a pre-action spray system above the suspended ceiling in Fire Zone
16 inches below floor decks (i.e., ceilings) for beam and girder construction. During walkdowns of the Unit 1 portion of Fire Zone 4F3, the inspectors did not observe any sprinklers or spray nozzles within 16 inches of the ceiling. The inspectors noted that the suppression system installed was a spray system for the majority of cable trays located above the suspended ceiling. Spray nozzles, connected to a water piping system, were  
    4F3 instead of a pre-action sprinkler system as specified by the Fire Protection Report.
installed between or above cable trays to provide coverage for the majority of cable trays installed above the suspended ceiling. The spray nozzles had 250 degree Fahrenheit thermal elements with deflectors having a 65 degree conical spray pattern. The inspectors consulted with the Fire Protection Branch within the Office of Nuclear Reactor Regulation (NRR) on this issue and NRR concurred that the installed system did not meet the  
    Description: Fire Zone 4F3 was centrally located on the ground floor of the auxiliary
licensing basis for LaSalle County Station. The inspectors noted that sprinkler systems activate through plumes from a fire hitting a ceiling with the resulting ceiling jets activating the nearest sprinkler head. As such, sprinkler systems provide general area fire suppression and activate relatively quickly in the event of a fire. In comparison, spray systems are generally designed with open (i.e., without thermal elements) spray nozzle heads and use a separate detection system for
    building. In addition to serving as a chemistry laboratory area, the zone served as a cable
Enclosure  
    spreading area for Division I cables for both units. The cable spreading area was located
9activation. As such, spray systems are typically used to protect specific components from fire (through activation of a separate detection system). In comparison, the spray system installed in Fire Zone 4F3 was a pre-action system, which used closed heads for the spray nozzles. The detection system for the spray system would cause a valve to open admitting water to the spray piping. However, individual spray nozzle heads would also have to be activated through localized heat for any water suppression to be provided. To activate  
    above the suspended ceiling for the chemistry laboratory facilities.
individual spray nozzles, either the overall hot gas layer temperatures for the area would have to exceed 250 degrees Fahrenheit or a fire would have to be located in a cable tray near a spray nozzle. The inspectors concluded that there typically would be considerable delay in activation of the pre-action spray system installed versus a properly designed sprinkler system for the area. As such, the inspectors determined that a closed-head spray  
    As part of licensing amendment 49, dated May 1980, the license committed to provide an
system would not provide an equivalent level of protection as a sprinkler system. Specifically, the installed spray system was less capable than a sprinkler system because a fire would be permitted to grow to a larger size and cause more damage as a result of delayed actuation. During a partial walkdown of the suppression system, the inspectors identified one section of safety-related cable tray, which did not have spray coverage (cable tray nodes 232C, 232E, and 234E). The inspectors confirmed that the cable tray sections contained cables, which supported safety-related emergency core cooling systems. The licensee presented the argument that localized lack of coverage was acceptable because the purpose was to only control a postulated fire and to prevent its spread to adjacent safety-related areas. The licensee noted that the NRC had based acceptance of the spray systems for the cable spreading rooms, in part on, this argument as documented in Section 9.5.1.2 of  
    automatic sprinkler system for the cable concentration above the suspended ceiling in this
NUREG-0519, Supplement 3, "Safety Evaluation Report related to the operation of LaSalle County Station, Units 1 and 2.The inspectors noted that the cable spreading rooms had overhead sprinkler systems in addition to the spray systems installed for the cable trays. The argument concerning the purpose being only to control postulated fires to prevent spread to adjacent areas only applied to specific deviations from NFPA 15-1973, "Standard  
    area. Additionally, Section H.3.4.18, Auxiliary Building Ground Floor - Fire Zone 4F3, of
for Water Spray Fixed Systems for Fire Protection," for the cable spreading room spray systems and was not applicable to other deficiencies or Fire Zone 4F3. Additionally, Section 9.5.1.2 of NUREG-0519, Supplement 1, and Section H.3.4.18 of the Fire Protection Report indicated that the suppression system for Fire Zone 4F3 was for the cables above the ceiling (as opposed to controlling a postulated fire and preventing its spread to adjacent  
    the LaSalle County Station Fire Protection Report stated A pre-action sprinkler system is
safety-related areas). The licensee entered issues relating to spray coverage into their corrective action system as AR 00840401, "NRC Identified Inspection Findings in Aux Bldg Ceiling," and AR 00855527; "Rotate FP Water Spray Nozzle to Optimize Spray Pattern," dated December 12, 2008. The licensee entered the issue of the installed spray system not meeting the licensing basis  
    located above the suspended ceiling to protect the cabling located there. The inspectors
description of a sprinkler system into their corrective action system as AR 00849044, "NRC Potential Finding; Chemistry Overlab FP System," dated November 21, 2008. Analysis: The inspectors determined that the failure to install a sprinkler system in Fire Zone 4F3 was contrary to Section H.3.4.18 of the LaSalle County Station Fire Protection Report and was a performance deficiency. The finding was determined to be more than minor because the failure to install a sprinkler system was associated with the Mitigating Systems cornerstone attribute of Protection  
    noted that sprinkler systems generally have sprinklers located near the ceiling. The code
Against External Factors (Fire) and affected the cornerstone objective of ensuring capability
    of record for sprinklers used at LaSalle County Station was NFPA 13-1976, Standard for
Enclosure  
    the Installation of Sprinkler Systems. The suppression system installed above the
10of systems to respond to initiating events such as fire. Specifically, the installed spray system was less capable than a sprinkler system because a fire would be permitted to grow to a larger size and cause more damage as a result of delayed system actuation. In accordance with IMC 0609, "Significance Determination Process," Attachment 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," Table 3b the inspectors determined the finding degraded the fire protection defense-in-depth strategies. Therefore,  
    suspended ceiling for Fire Zone 4F3 was not a sprinkler system and did not meet the
screening under IMC 0609, Appendix F, "Fire Protection Significance Determination Process," was required. The inspectors performed a Phase 2 analysis. The inspectors determined that the high transient combustibles and hot work frequencies (1.7x10
    requirements of NFPA 13-1976. Specifically, Section 3-15.2.1 of NFPA 13-1976
-3 per year and 6.9x10
    required that listed sprinklers be used. The licensees installation used spray nozzles.
-4 per year, respectively) from IMC 0609, Appendix F, Attachment 4, "Fire Ignition Source Mapping Information: Fire Frequency, Counting Instructions, Applicable Fire  
    Section 4-3.2.1 of NFPA 13-1976 specified that deflectors of sprinklers be located 1 to
Severity Characteristics, and Applicable Manual Fire Suppression Curves," were applicable due to the presence of the normally occupied chemistry laboratory and heat producing equipment in the area. The inspectors also determined that, though Division I equipment would be unavailable, at a minimum, the following equipment and capabilities would be available: high pressure core spray, depressurization capability, one train of low pressure injection, one train of containment heat removal capability, containment venting capability, survival of injection path following containment failure, and late depressurization with one  
    16 inches below floor decks (i.e., ceilings) for beam and girder construction. During
train of injection. Based on review of the Transients worksheet from the "Risk-Informed Inspection Notebook for LaSalle County Station, Units 1 and 2," Revision 2.1a, the inspectors determined that a conditional core damage probability of 1x10
    walkdowns of the Unit 1 portion of Fire Zone 4F3, the inspectors did not observe any
-4 could be credited due to remaining mitigation capability. For ease of analysis, the inspectors did not credit any suppression capability. Based on the above information and Step 2.9 of IMC 0609,  
    sprinklers or spray nozzles within 16 inches of the ceiling. The inspectors noted that the
Appendix F, the inspectors determined that the finding was of very low safety significance (i.e., Green) due to remaining mitigating system capability. The inspectors did not identify a cross-cutting aspect associated with this finding. Enforcement: 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  
    suppression system installed was a spray system for the majority of cable trays located
protection program as described in the Final Safety Analysis Report (FSAR) 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. Section H.3.4.18, "Auxiliary Building Ground Floor - Fire Zone 4F3," of the LaSalle County Station Fire Protection Report stated that a  
    above the suspended ceiling. Spray nozzles, connected to a water piping system, were
pre-action sprinkler system was provided for the cables above the suspended ceiling. The LaSalle County Station Fire Protection Report listed NFPA 13-1976 as the code of record for sprinkler systems. Section 3-15.2.1 of NFPA 13-1976 required that listed sprinklers be used. Section 4-3.2.1 of NFPA 13-1976 specified that deflectors of sprinklers be located 1 to 16 inches below floor decks for beam and girder construction. Contrary to the above, as of November 21, 2008, the licensee failed to provide a pre-action sprinkler system for Fire Zone 4F3. Specifically, the suppression system installed in Fire Zone 4F3 was a spray system and did not meet the requirements for a sprinkler system as described in NFPA 13-1976. The installed suppression system did not use listed sprinklers and no sprinklers were within 16 inches of below the floor deck. Because this violation was of very low safety significance and it was entered into the licensee's corrective action program as AR 00849044, this violation is being treated as an NCV, consistent with
    installed between or above cable trays to provide coverage for the majority of cable trays
Enclosure  
    installed above the suspended ceiling. The spray nozzles had 250 degree Fahrenheit
11Section VI.A.1 of the NRC Enforcement Policy (NCV 05000373/2008007-02; 05000374/2008007-02). .6 Protection from Damage from Fire Suppression Activities
    thermal elements with deflectors having a 65 degree conical spray pattern. The inspectors
a. Inspection Scope
    consulted with the Fire Protection Branch within the Office of Nuclear Reactor Regulation
For the selected fire areas, the inspectors verified that redundant trains of systems required for hot shutdown would not be subject to damage from fire suppression activities or from the  
    (NRR) on this issue and NRR concurred that the installed system did not meet the
rupture or inadvertent operation of fire suppression systems including the effects of flooding. The inspectors conducted walkdowns of each of the selected fire areas to assess conditions, such as, the adequacy and condition of floor drains, equipment Elevations, and spray protection. b. Findings
    licensing basis for LaSalle County Station.
No findings of significance were identified. .7 Alternative Shutdown Capability
    The inspectors noted that sprinkler systems activate through plumes from a fire hitting a
a. Inspection Scope
    ceiling with the resulting ceiling jets activating the nearest sprinkler head. As such,
The inspectors reviewed the licensee's systems required to achieve alternative safe shutdown to determine if the licensee had properly identified the components and systems necessary to achieve and maintain safe shutdown conditions. The inspectors also focused on the adequacy of the systems to perform reactor pressure control, reactivity control,  
    sprinkler systems provide general area fire suppression and activate relatively quickly in
reactor coolant makeup, decay heat removal, process monitoring, and support system functions. The team conducted selected area walkdowns to determine if operators could reasonably be expected to perform the alternate safe shutdown procedure actions and that equipment labeling was consistent with the alternate safe shutdown procedure. The review also looked  
    the event of a fire. In comparison, spray systems are generally designed with open (i.e.,
at operator training, as well as consistency between the operations shutdown procedures and any associated administrative controls. b. Findings
    without thermal elements) spray nozzle heads and use a separate detection system for
No findings of significance were identified .8 Circuit Analyses
                                                  8                                      Enclosure
a. Inspection Scope
 
The inspectors reviewed the licensee's post-fire safe shutdown analysis to verify that the licensee had identified both required and associated circuits that may impact safe shutdown. On a sample basis, the inspectors verified that the cables of equipment required achieving and maintaining hot shutdown conditions, in the event of fire in the selected fire zones, had  
activation. As such, spray systems are typically used to protect specific components from
been properly identified. In addition, the inspectors verified that these cables had either been adequately protected from the potentially adverse effects of fire damage, mitigated with approved manual operator actions, or analyzed to show that fire-induced faults
fire (through activation of a separate detection system). In comparison, the spray system
Enclosure  
installed in Fire Zone 4F3 was a pre-action system, which used closed heads for the spray
12(e.g., hot shorts, open circuits, and shorts to ground) would not prevent safe shutdown. In order to accomplish this, the inspectors reviewed electrical schematics and cable routing data for power and control cables associated with each of the selected components. In addition, on a sample basis, the adequacy of circuit protective coordination for the safe shutdown systems' electrical power and instrumentation circuit protection were evaluated. Also, on a sample basis, a cable tray that contains both safe shutdown and non-safe  
nozzles. The detection system for the spray system would cause a valve to open admitting
shutdown cables was evaluated for proper circuit protection to ensure that cables are protected by a proper protective device in order to preclude common enclosure concerns. b. Findings
water to the spray piping. However, individual spray nozzle heads would also have to be
No findings of significance were identified. .9 Communications
activated through localized heat for any water suppression to be provided. To activate
a. Inspection Scope
individual spray nozzles, either the overall hot gas layer temperatures for the area would
The inspectors reviewed, on a sample bases, the adequacy of the communication system to support plant personnel in the performance of alternative safe shutdown functions and fire brigade duties. The inspectors verified that plant telephones, page systems, sound powered phones, and radios were available for use and maintained in working order. The inspectors reviewed the electrical power supplies and cable routing for these systems to verify that either the telephones or the radios would remain functional following a fire. b. Findings
have to exceed 250 degrees Fahrenheit or a fire would have to be located in a cable tray
No findings of significance were identified. .10 Emergency Lighting
near a spray nozzle. The inspectors concluded that there typically would be considerable
a. Inspection Scope
delay in activation of the pre-action spray system installed versus a properly designed
The inspectors performed a plant walkdown of selected areas in which a sample of operator actions would be performed in the performance of alternative safe shutdown functions. As part of the walkdowns, the inspectors focused on the existence of sufficient emergency lighting for access and egress to areas and for performing necessary equipment operations. The locations and positioning of the emergency lights were observed during the walkdown and during review of manual actions implemented for the selected fire areas. b. Findings
sprinkler system for the area. As such, the inspectors determined that a closed-head spray
No findings of significance were identified. .11 Cold Shutdown Repairs
system would not provide an equivalent level of protection as a sprinkler system.
a. Inspection Scope
Specifically, the installed spray system was less capable than a sprinkler system because a
The inspectors reviewed the licensee's procedures to determine whether repairs were required to achieve cold shutdown and to verify that dedicated repair procedures, equipment, and material to accomplish those repairs were available onsite. The inspectors
fire would be permitted to grow to a larger size and cause more damage as a result of
Enclosure  
delayed actuation.
13also evaluated whether cold shutdown could be achieved within the required time using the licensee's procedures and repair methods. The inspectors also verified that equipment necessary to perform cold shutdown repairs was available onsite and properly staged. b. Findings
During a partial walkdown of the suppression system, the inspectors identified one section
No findings of significance were identified. .12 Compensatory Measures
of safety-related cable tray, which did not have spray coverage (cable tray nodes 232C,
a. Inspection Scope
232E, and 234E). The inspectors confirmed that the cable tray sections contained cables,
The inspectors conducted a review to verify that compensatory measures were in place for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e.g., detection and suppression systems, and equipment, passive fire barriers, pumps, valves or electrical devices providing safe shutdown functions  
which supported safety-related emergency core cooling systems. The licensee presented
or capabilities). The inspectors also conducted a review on the adequacy of short term compensatory measures to compensate for a degraded function or feature until appropriate corrective actions were taken. b. Findings
the argument that localized lack of coverage was acceptable because the purpose was to
No findings of significance were identified. 4. OTHER ACTIVITIES 4OA6 Management Meetings
only control a postulated fire and to prevent its spread to adjacent safety-related areas. The
  .1 Exit Meeting Summary
licensee noted that the NRC had based acceptance of the spray systems for the
On November 21, 2008, the inspectors presented the inspection results to Mr. D. Rhoades, 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  
cable spreading rooms, in part on, this argument as documented in Section 9.5.1.2 of
 
NUREG-0519, Supplement 3, Safety Evaluation Report related to the operation of LaSalle
Attachment
County Station, Units 1 and 2. The inspectors noted that the cable spreading rooms had
1SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT  
overhead sprinkler systems in addition to the spray systems installed for the cable trays.
Licensee D. Rhoades, Plant Manager E. Ballou, Mechanical Design Engineer J. Bashor, Engineering Director  
The argument concerning the purpose being only to control postulated fires to prevent
R. Dudley, Operations W. Hilton, Design Engineering Manager J. Houston, Regulatory Assurance K. Ihnen, Nuclear Oversight Manager S. Marik, Operations Director  
spread to adjacent areas only applied to specific deviations from NFPA 15-1973, Standard
J. Miller, Mechanical and Structural Supervisor T. Simkin, Regulatory Assurance Manager M. Taylor, Corporate Fire Protection Engineer J. Vergara, Regulatory Assurance E. Zacharias, Plant Electrical Systems Supervisor  
for Water Spray Fixed Systems for Fire Protection, for the cable spreading room spray
systems and was not applicable to other deficiencies or Fire Zone 4F3. Additionally,
Section 9.5.1.2 of NUREG-0519, Supplement 1, and Section H.3.4.18 of the Fire Protection
Report indicated that the suppression system for Fire Zone 4F3 was for the cables above
the ceiling (as opposed to controlling a postulated fire and preventing its spread to adjacent
safety-related areas).
The licensee entered issues relating to spray coverage into their corrective action system as
AR 00840401, NRC Identified Inspection Findings in Aux Bldg Ceiling, and AR 00855527;
Rotate FP Water Spray Nozzle to Optimize Spray Pattern, dated December 12, 2008. The
licensee entered the issue of the installed spray system not meeting the licensing basis
description of a sprinkler system into their corrective action system as AR 00849044, NRC
Potential Finding; Chemistry Overlab FP System, dated November 21, 2008.
Analysis: The inspectors determined that the failure to install a sprinkler system in Fire Zone
4F3 was contrary to Section H.3.4.18 of the LaSalle County Station Fire Protection Report
and was a performance deficiency.
The finding was determined to be more than minor because the failure to install a sprinkler
system was associated with the Mitigating Systems cornerstone attribute of Protection
Against External Factors (Fire) and affected the cornerstone objective of ensuring capability
                                            9                                        Enclosure
 
of systems to respond to initiating events such as fire. Specifically, the installed spray
system was less capable than a sprinkler system because a fire would be permitted to grow
to a larger size and cause more damage as a result of delayed system actuation.
In accordance with IMC 0609, Significance Determination Process, Attachment 0609.04,
Phase 1 - Initial Screening and Characterization of Findings, Table 3b the inspectors
determined the finding degraded the fire protection defense-in-depth strategies. Therefore,
screening under IMC 0609, Appendix F, Fire Protection Significance Determination
Process, was required. The inspectors performed a Phase 2 analysis. The inspectors
determined that the high transient combustibles and hot work frequencies (1.7x10-3 per year
and 6.9x10-4 per year, respectively) from IMC 0609, Appendix F, Attachment 4, Fire Ignition
Source Mapping Information: Fire Frequency, Counting Instructions, Applicable Fire
Severity Characteristics, and Applicable Manual Fire Suppression Curves, were applicable
due to the presence of the normally occupied chemistry laboratory and heat producing
equipment in the area. The inspectors also determined that, though Division I equipment
would be unavailable, at a minimum, the following equipment and capabilities would be
available: high pressure core spray, depressurization capability, one train of low pressure
injection, one train of containment heat removal capability, containment venting capability,
survival of injection path following containment failure, and late depressurization with one
train of injection. Based on review of the Transients worksheet from the Risk-Informed
Inspection Notebook for LaSalle County Station, Units 1 and 2, Revision 2.1a, the
inspectors determined that a conditional core damage probability of 1x10-4 could be credited
due to remaining mitigation capability. For ease of analysis, the inspectors did not credit
any suppression capability. Based on the above information and Step 2.9 of IMC 0609,
Appendix F, the inspectors determined that the finding was of very low safety significance
(i.e., Green) due to remaining mitigating system capability.
The inspectors did not identify a cross-cutting aspect associated with this finding.
Enforcement: 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 (FSAR) 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. Section H.3.4.18, Auxiliary Building Ground
Floor - Fire Zone 4F3, of the LaSalle County Station Fire Protection Report stated that a
pre-action sprinkler system was provided for the cables above the suspended ceiling. The
LaSalle County Station Fire Protection Report listed NFPA 13-1976 as the code of record
for sprinkler systems. Section 3-15.2.1 of NFPA 13-1976 required that listed sprinklers be
used. Section 4-3.2.1 of NFPA 13-1976 specified that deflectors of sprinklers be located
1 to 16 inches below floor decks for beam and girder construction.
Contrary to the above, as of November 21, 2008, the licensee failed to provide a pre-action
sprinkler system for Fire Zone 4F3. Specifically, the suppression system installed in
Fire Zone 4F3 was a spray system and did not meet the requirements for a sprinkler
system as described in NFPA 13-1976. The installed suppression system did not use listed
sprinklers and no sprinklers were within 16 inches of below the floor deck. Because this
violation was of very low safety significance and it was entered into the licensees corrective
action program as AR 00849044, this violation is being treated as an NCV, consistent with
                                            10                                        Enclosure
 
    Section VI.A.1 of the NRC Enforcement Policy (NCV 05000373/2008007-02;
    05000374/2008007-02).
.6   Protection from Damage from Fire Suppression Activities
  a. Inspection Scope
    For the selected fire areas, the inspectors verified that redundant trains of systems required
    for hot shutdown would not be subject to damage from fire suppression activities or from the
    rupture or inadvertent operation of fire suppression systems including the effects of flooding.
    The inspectors conducted walkdowns of each of the selected fire areas to assess
    conditions, such as, the adequacy and condition of floor drains, equipment Elevations, and
    spray protection.
  b. Findings
    No findings of significance were identified.
.7   Alternative Shutdown Capability
  a. Inspection Scope
    The inspectors reviewed the licensees systems required to achieve alternative safe
    shutdown to determine if the licensee had properly identified the components and systems
    necessary to achieve and maintain safe shutdown conditions. The inspectors also focused
    on the adequacy of the systems to perform reactor pressure control, reactivity control,
    reactor coolant makeup, decay heat removal, process monitoring, and support system
    functions.
    The team conducted selected area walkdowns to determine if operators could reasonably
    be expected to perform the alternate safe shutdown procedure actions and that equipment
    labeling was consistent with the alternate safe shutdown procedure. The review also looked
    at operator training, as well as consistency between the operations shutdown procedures
    and any associated administrative controls.
  b. Findings
    No findings of significance were identified
.8   Circuit Analyses
  a. Inspection Scope
    The inspectors reviewed the licensees post-fire safe shutdown analysis to verify that the
    licensee had identified both required and associated circuits that may impact safe shutdown.
    On a sample basis, the inspectors verified that the cables of equipment required achieving
    and maintaining hot shutdown conditions, in the event of fire in the selected fire zones, had
    been properly identified. In addition, the inspectors verified that these cables had either
    been adequately protected from the potentially adverse effects of fire damage, mitigated
    with approved manual operator actions, or analyzed to show that fire-induced faults
                                                11                                      Enclosure
 
    (e.g., hot shorts, open circuits, and shorts to ground) would not prevent safe shutdown. In
    order to accomplish this, the inspectors reviewed electrical schematics and cable routing
    data for power and control cables associated with each of the selected components.
    In addition, on a sample basis, the adequacy of circuit protective coordination for the safe
    shutdown systems electrical power and instrumentation circuit protection were evaluated.
    Also, on a sample basis, a cable tray that contains both safe shutdown and non-safe
    shutdown cables was evaluated for proper circuit protection to ensure that cables are
    protected by a proper protective device in order to preclude common enclosure concerns.
  b. Findings
    No findings of significance were identified.
.9   Communications
  a. Inspection Scope
    The inspectors reviewed, on a sample bases, the adequacy of the communication system to
    support plant personnel in the performance of alternative safe shutdown functions and fire
    brigade duties. The inspectors verified that plant telephones, page systems, sound powered
    phones, and radios were available for use and maintained in working order. The inspectors
    reviewed the electrical power supplies and cable routing for these systems to verify that
    either the telephones or the radios would remain functional following a fire.
  b. Findings
    No findings of significance were identified.
.10 Emergency Lighting
  a. Inspection Scope
    The inspectors performed a plant walkdown of selected areas in which a sample of operator
    actions would be performed in the performance of alternative safe shutdown functions. As
    part of the walkdowns, the inspectors focused on the existence of sufficient emergency
    lighting for access and egress to areas and for performing necessary equipment operations.
    The locations and positioning of the emergency lights were observed during the walkdown
    and during review of manual actions implemented for the selected fire areas.
  b. Findings
    No findings of significance were identified.
.11 Cold Shutdown Repairs
  a. Inspection Scope
    The inspectors reviewed the licensees procedures to determine whether repairs were
    required to achieve cold shutdown and to verify that dedicated repair procedures,
    equipment, and material to accomplish those repairs were available onsite. The inspectors
                                                12                                        Enclosure
 
      also evaluated whether cold shutdown could be achieved within the required time using the
      licensee's procedures and repair methods. The inspectors also verified that equipment
      necessary to perform cold shutdown repairs was available onsite and properly staged.
  b. Findings
      No findings of significance were identified.
.12 Compensatory Measures
  a. Inspection Scope
      The inspectors conducted a review to verify that compensatory measures were in place
      for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown
      equipment, systems, or features (e.g., detection and suppression systems, and equipment,
      passive fire barriers, pumps, valves or electrical devices providing safe shutdown functions
      or capabilities). The inspectors also conducted a review on the adequacy of short term
      compensatory measures to compensate for a degraded function or feature until appropriate
      corrective actions were taken.
  b. Findings
      No findings of significance were identified.
4.   OTHER ACTIVITIES
4OA6 Management Meetings
  .1   Exit Meeting Summary
      On November 21, 2008, the inspectors presented the inspection results to Mr. D. Rhoades,
      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
                                                13                                        Enclosure
 
                                SUPPLEMENTAL INFORMATION
                                  KEY POINTS OF CONTACT
Licensee
D. Rhoades, Plant Manager
E. Ballou, Mechanical Design Engineer
J. Bashor, Engineering Director
R. Dudley, Operations
W. Hilton, Design Engineering Manager
J. Houston, Regulatory Assurance
K. Ihnen, Nuclear Oversight Manager
S. Marik, Operations Director
J. Miller, Mechanical and Structural Supervisor
T. Simkin, Regulatory Assurance Manager
M. Taylor, Corporate Fire Protection Engineer
J. Vergara, Regulatory Assurance
E. Zacharias, Plant Electrical Systems Supervisor
Nuclear Regulatory Commission
R. Daley, Branch Chief, Division of Reactor Safety
G. Roach, Senior Resident Inspection, LaSalle County Station
                    LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened
05000373/2008007-01        NCV    Unauthorized Transient Combustibles
05000374/2008007-01
05000373/2008007-02        NCV    Failure to Provide a Sprinkler System for Fire Zone 4F3
05000374/2008007-02
Closed
05000373/2008007-01        NCV    Unauthorized Transient Combustibles
05000374/2008007-01
05000373/2008007-02        NCV    Failure to Provide a Sprinkler System for Fire Zone 4F3
05000374/2008007-02
                                                1                                    Attachment
 
                                  LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection. Inclusion on this list does
not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that
selected sections of portions of the documents were evaluated as part of the overall inspection
effort. Inclusion of a document on this list does not imply NRC acceptance of the document or
any part of it, unless this is stated in the body of the inspection report.
1R05 Fire Protection Calculations and Analyses (71111.05T)
        L-000776; LaSalle Combustible Load for Fire Zone 4F3; Revision 5
        L-001726; Hydraulic Analysis to Determine the Adequacy of the Service Water Pumps
        to Function as Fire Pumps; Revision 2
        L-001947; Safe Shutdown Control Circuit Breaker-Fuse Coordination; Revision 01
        L--002771; GL 86-10 Operator Action Evaluation for Fuse Pulling in AEER and Valve
        Manipulation in Reactor Building for Post Fire Safe Shutdown; Revision 0
        L-003289; LaSalle Fire Detector Smoke Stratification Justification; Revision 0
        EC 0000331385; Safe Shutdown Control Circuit Breaker-Fuse Coordination Calculation
        Revision; dated December 20, 2001
        GE-NE-A1300384-43-01; LaSalle County Station Power Uprate Project, Task 611:
        Appendix R Fire Protection [Proprietary]; dated September 1999
        Schirmer Engineering Corporation: Automatic Sprinkler System Calculation, LaSalle
        County Station; dated January 26, 1984
Corrective Action Documents
        AR 00369313; Multiple Spurious Actuations of ADS Valves; dated September 1, 2005
        AR 00578440; Replace Smoke Detector with New Style Detector; dated
        January 12, 2007
        AR 00632819; Fireproofing Removed Requiring Compensatory Actions; dated
        May 23, 2007
        AR 00637145; 0B Diesel FP Activities; dated June 5, 2007
        AR 00659506; Two Different Battery Models Installed in B Diesel Fire Pump; dated
        August 10, 2007
        AR 00671437; Overlab FP System - Could not Test All Detectors; dated
        September 14, 2008
        AR 00704946; NOS ID Fire Doors not Inspected Under Proper Surveillance; dated
        November 29, 2007
                                                    2                                  Attachment
 
      AR 00704957; NOS ID Fire Door Sealing Device does not Meet Hour Rating; dated
      November 29, 2007
      AR 00711394; 1FP01C Still Short Cycling; dated December 13, 2007
      AR 00716061; Fire Door 284 Door Latch not Operating Properly; dated
      December 28, 2007
      AR 00747573; Fire Line Pipe Corrosion; dated March 10, 2008
      AR 00750853; Fire Doors/Barrier Reclassification; dated March 17, 2008
      AR 00761675; 0B Diesel Fire Pump Troubleshooting; dated April 10, 2008
      AR 00783879; Local Alarm will not Sound - Building 33; dated June 6 2008
      AR 00836266; Declining Trend in Transient Combustibles; dated October 27, 2008
      AR 00841673; Transient Combustible Material Extent of Condition Walkdown; dated
      November 7, 2008
      CR L2001-02263; Potential Spurious Operations During CR or AEER Fire; dated
      April 5, 2001
Corrective Action Documents Initiated as a Result of Inspection
      AR 00834512; NRC Identified Combustibles During Walkdown with FP Engineer; dated
      October 22, 2008
      AR 00835086; NRC Identified Chair Not Removed Until Following Morning; dated
      October 23, 2008
      AR 00837934; NRC TRI: Passport D030 Discrepancy for DFP Pressure SW; dated
      October 30, 2008
      AR 00839030; NRC Identified Issues - LaSalle Triennial Inspection; dated
      October 30, 2008
      AR 00840401; NRC Identified Inspection Findings in Aux Bldg Ceiling; dated
      November 4, 2008
      AR 00840264; FP Report Document Problem - LaSalle Triennial Inspection; dated
      November 4, 2008
      AR 00840339; NRC Triennial Fire Protection Inspection; dated November 4, 2008
      AR 00840381; NRC Identified SLICE (Cable Analysis) Discrepancies; dated
      November 4, 2008
      AR 00840833; NRC Triennial Inspection-Equip. Number Error on 1E-1-4220AC; dated
      November 5, 2008
                                              3                                  Attachment
 
AR 00841245; NRC Triennial: ELBP 1LL142E North Side Fixed Lamp Aiming; dated
November 6, 2008
AR 00841304; NRC Triennial Inspection - FPR H.4.6.2 Discrepancy; dated
November 6, 2008
AR 00841326; NRC ID: Transient Combustible Near Vertical Power Riser; dated
November 6, 2008
AR 00841364; NRC FP Triennial Inspection - Calc L-001947 Recommendation; dated
November 6, 2008
AR 00841433; NRC Triennial: FP Related Drawing Deficiencies; dated
November 6, 2008
AR 00841355; NRC Triennial: Smoke from AEER Fire Affecting Operator Actions; dated
November 6, 2008
AR 00841458; NRC Triennial: LOA-FX-101 - Fuse Orientation Description; dated
November 6, 2008
AR 00841490; NRC Triennial FP Inspection Walkdown; dated November 6, 2008
AR 00841494; NRC Triennial FP Inspection Walkdown; dated November 6, 2008
AR 00842109; NRC FP Triennial: DFP Start Sequencing Compliance with NFPA; dated
November 7, 2008
AR 00843614; NRC FP Inspection - FZ 4F3 Hydraulic Calc Retrieval Difficult; dated
November 11, 2008
AR 00846249; NRC Triennial Inspection - Discrepancy on Dwg 1E-2-4601BA; dated
November 17, 2008
AR 00846419; NRC Fire Protection Triennial Inspection; dated November 18, 2008
AR 00846433; 2008 NRC FP Triennial - Drawing Discrepancy 1E-4220AQ; dated
November 18, 2008
AR 00846729; NRC Triennial Inspection-Description of Codes Not Available; dated
November 18, 2008
AR 00846731; NRC Identified SRV Issue During FP Triennial Inspection; dated
November 18, 2008
AR 00846760; NRC Fire Protection Triennial; dated November 18, 2008
AR 00846783; NRC Triennial: Smoke Detectors Affect Any Other Functions; dated
November 18, 2008
AR 00847185; FPR Table H.4-59 and Table H.4-60 Incorrectly List Cable 1NB335 As
Supporting Control Room Recorder 1B21-R884A; dated November 19, 2008
                                    4                                    Attachment
 
      AR 00847328; NRC Triennial Inspection-Discrepancy on S/D 1E-2-4220CH; dated
      November 19, 2008
      AR 00847337; NRC Triennial: FP Related Drawing Deficiencies; dated
      November 19, 2008
      AR 00847578; NRC FP Triennial - The Safe Shutdown Cable Routing Drawings
      Incorrectly Show that Cable 1RH360 is Routed in Fire Zone 4E1-1; dated
      November 20, 2008
      AR 00847709; NRC FP Inspection: AEER Roll-Up Door Evaluation Canceled; dated
      November 20, 2008
      AR 00848042; NRC FP Triennial - SLICE Fire Zone Data Reference Only; dated
      November 21, 2008
      AR 00848063; NRC FP Triennial Inspection: FP Spray Nozzle Orifice Size; dated
      November 20, 2008
      AR 00847728; NRC Identified Sprinkler Heat NFPA Code Deviation; dated
      November 20, 2008
      AR 00847809; NRC Triennial: LOA-FX-101(201) AEER Validation Order; dated
      November 20, 2008
      AR 00846788; NRC FP Triennial: DFP Start Sequencing, Timing; dated
      November 18, 2008
      AR 00849044; NRC Potential Finding, Chemistry Overlab FP System; dated
      November 21, 2008
      AR 00855527; Rotate FP Water Spray Nozzle to Optimize Spray Pattern; dated
      December 12, 2008
Drawings
      15; Cable Spreading Rooms Supervised Pre-action Systems; Revision 10
      16A; Auxiliary Building Elevation 7490 Cable Spreading Room Details & Section
      1E-1-3445; Electrical Installation Auxiliary Building Auxiliary Equipment Room Plan EL.
      731-0 Col. 12-15 & J-N; Revision AU
      1E-1-3465; Electrical Installation Control Room Plan EL. 768-0 Col. 12-15 & J-N;
      Revision Z
      1E-1-3663; Cable Pan Routing Aux. Bldg. Plan EL. 7106 Cols 12-15; Revision S
      1E-1-3694M, Sheet 1; Safe Shutdown Cable Routing Aux. Bldg. Plan El. 731-0 Cols.
      12-15; Revision; A
      1E-1-3694M, Sheet 2; Safe Shutdown Cable Routing Schedules for Aux. Bldg. Plan EL.
      731-0 Cols. 12-15; Revision; A
                                                5                                  Attachment
 
1E-1-3694P, Sheet 1; Safe Shutdown Cable Routing Schedules for Aux. Bldg. Plan EL.
749-0 Cols. 12-15; Revision; A
1E-1-3694P, Sheet 2; Safe Shutdown Cable Routing Schedules for Aux. Bldg. Plan EL.
749-0 Cols. 12-15; Revision; A
1E-1-4018ZE; Loop Schematic Diagram - Containment Monitoring System CM, Part 5;
Revision Q
1E-1-4201AA; Schematic Diagram - Auto Depressurization System NB (B21C) Part 1
1E-1-4201AC; Schematic Diagram - Auto Depressurization System NB (B21C)
Part 3; Revision AA
1E-1-4201AD; Schematic Diagram - Auto Depressurization System NB (B21C)
Part 4; Revision AC
1E-1-4201AE; Schematic Diagram - Auto Depressurization System NB (B21C)
Part 5; Revision V
1E-1-4201AF; Schematic Diagram - Auto Depressurization System NB (B21C) Part 6;
Revision AA
1E-1-4201AG; Schematic Diagram - Auto Depressurization System NB (B21C)
Part 7; Revision
1E-1-4201AJ; Schematic Diagram - Auto Depressurization System NB (B21C) Part 9;
Revision G
1E-1-4201AK; Schematic Diagram - Auto Depressurization System NB (B21C)
Part 10; Revision F
1E-1-4203AK; Schematic Diagram - Main Steam/Nuclear Boiler System NB (B21),
Part 10; Revision Y
1E-1-4214AA; Schematic Diagram - Remote Shutdown System RS Part 1;
Revision K
1E-1-4220BD; Schematic Diagram - Residual Heat Removal System RH (E12) Part 28;
Revision N
1E-1-4220BX; Schematic Diagram - Residual Heat Removal System RH (E12) Part 46;
Revision R
1E-1-4220BY; Schematic Diagram - Residual Heat Removal System RH (E12) Part 47;
Revision K
1E-1-4220CH; Schematic Diagram - Residual Heat Removal System RH (E12) Part 56;
Revision M
1E-1-4379AC; Internal Wiring Diagram - 480V MCC Detail; Revision K
                                    6                                Attachment
 
1E-1-4391AB; Internal/External Wiring Diagram - Reactor Building 480V MCC 136Y-1,
Part 2; Revision W
1E-1-4442AA; Internal/External Wiring Diagram - Automatic Depressurization Channel
A Relay Vertical Board 1H13-P628, Part 1; Revision R
1E-1-4622AB; Internal/External Wiring Diagram - 125VDC Distr. Bus 1B and 125VDC
Dist. Panel 112Y; Revision T
1E-1-4622AC; Internal/External Wiring Diagram - Automatic Depressurization
Channel A Relay Vertical Board 1H13-P628, Part 2; Revision AA
1E-1-4622AD; Internal/External Wiring Diagram - Automatic Depressurization
Channel A Relay Vertical Board 1H13-P628; Revision J
1E-1-4622AF; Internal/External Wiring Diagram - Automatic Depressurization
Channel A Relay Vertical Board 1H13-P628, Part 3; Revision G
1E-1-4624AB; Internal/External Wiring Diagram - Automatic Depressurization
Channel B Relay Vertical Board 1H13-P631; Revision AB
1E-1-4658AH; Internal/External Wiring Diagram - Remote Shutdown Panel
1C61-P001, Part 6; Revision Z
1E-1-4696AB; Internal/External Wiring Diagram - ADS/SRV Valves Aux Relay Vertical
Board Div. 1, Panel 1H13-P644; Revision K
1E-1-4696AC; Internal/External Wiring Diagram - ADS/SRV Valves Aux Relay Vertical
Board Div. 1, Panel 1H13-P644; Revision F
1E-1-4697AB; Internal/External Wiring Diagram - ADS/SRV Valves Aux Relay Vertical
Board Div. 2, Panel 1H13-P645; Revision P
1E-1-4697AC; Internal/External Wiring Diagram - ADS/SRV Valves Aux Relay Vertical
Board Div. 2, Panel 1H13-P645; Revision G
81-78483; Cable Trays over Lab ceiling Unit 1 & 2, EL. 7106 Supervised Pre-action
System; Revision 1, Figure 9.5-1, Sheet 15 of 41; Fire Protection System EL 7490;
Revision 17
Figure 9.5-1; Sheet 17 of 41; Fire Protection System EL 7400; Revision 17
Figure 9.5-1; Sheet 22 of 41; Fire Protection System EL 7106; Revision 17
Supervised Pre-action Systems; Revision 10
                                        7                                  Attachment
 
Miscellaneous
      LSCS-FPR; LaSalle Station Fire Protection Report- Appendix H.4, Safe Shutdown
      Analysis; Revision 3
      DBD-LS-E09; LaSalle Units 1 and 2, Electrical Separation, Table 4.4.1-1 Redundant
      and Non-Redundant Divisions; Revision 0
      DBD-LS-E09; LaSalle Units 1 and 2, Electrical Separation, Table 4.4.1-2 Electrical
      Raceway Separation Design Requirements and Design Basis; Revision 0
      SLICE Version 7.6; LaSalle Unit 1 Cable Transaction Report (S102); 1986-1999
      SLICE Version 7.6; LaSalle Unit 1 Fire Shutdown Cables/Fire Zone Report (S115);
      1986-1999
      SLICE Version 7.6; LaSalle Unit 1 Fire Zones/Fire Shutdown Cable Report (S116);
      1986-1999
      SLICE Version 7.6; LaSalle Unit 1 Fire Protection Safe Shutdown Discrepancy List
      Report (S143); 1986-1999
      SLICE Version 7.6; LaSalle Unit 1 Fire Protection Safe Shutdown Discrepancies -
      Unresolved Report (S143); 1986-1999
      AR 707263; LaSalle Station Triennial Fire Protection Inspection Preparatory Self
      Assessment; July/August 2008
      AR 576593; LaSalle Station Fire Protection Program Audit Report Audit NOSA-LAS-07-
      09; dated December 5, 2007
      AR 219447-05; LaSalle Station Focus Area Self-Assessment Report; dated June 2005
      1C-7-0784-002; Actions Necessary to Address Valve Failures or Spurious Operations;
      dated April 2, 1985
      CT.5ENG.4, Appendix R Spurious Operation Analysis, Phase 1 Report (AT-144623-01);
      Revision 0
Procedures
      CC-AA-206; Exelon Nuclear-Fuse Control; Revision 5
      LOA-FP-101; Unit 0 Fire Protection System Abnormal; Revision 2
      LOA-FP-101; Unit 1 Fire Protection Abnormal; Revision 9
      LOA-FX-101; Unit 1 Safe Shutdown with a Loss of Offsite Power and a Fire in the
      Control Room or AEER; Revision 13
                                              8                                    Attachment
 
      LOA-FX-101- Attachment C; Repair of 1E12-F009, RHR Inboard Shutdown Cooling
      Valve; Revision 13
      LOP-RH-17; Alternate Shutdown Cooling; Revision 25
      LOA-SRV-101; Unit 1 Stuck Open Safety Relief Valve; Revision 5
      LOS-FP-M4 U1; FP Deluge Valve Lineup 1112018-01
      OP-AA-201-009; Control of Combustible Material; Revision 7
      OP-MW-201-007; Fire Protection System Impairment Control; Revision 6
Work Orders
      980089736 01; Hydro Test all Fire Hoses per TS 4.7.5.4.D or Replace Fire Hose; dated
      August 29, 2000
      00639790 01; Hydro Test all Fire Hoses per TS 4.7.5.4.D or Replace Fire Hose; dated
      November 14, 2005
      01044223 01; Annual Inspection of FP Strainer for Cleanliness; dated June 25, 2008
      00465471 01; Electrical Fire Penetration Inspection; dated January 28, 2004
      960119253 01; Electrical Fire Penetration Inspection; dated August 20, 1997
      980074104 01; Electrical Fire Penetration Inspection; dated October 30, 1997
      99236634 01; Electrical Fire Penetration Inspection; dated January 31, 2003
      112018 01; LOS-FP-M4 U1 Deluge Valve Lineup; dated June 6, 2008
      849192 01; LOS-FP-R6 U-0 Cable Trays Over Labs Sprinkler Sys; dated July 13, 2007
      952500 01; Overlab Cable Tray Sprinkler Sys Channel Function Test; dated
      November 27, 2007
      859933 01; U-1 Cable Spreading Room Sprinkler Sys Channel Function Test; dated
      January 12, 2007
      992888 01; U-1 Cable Spreading Room Sprinkler Sys Chan. Function Test, LES-FP-06;
      dated January 11, 2008
                                              9                                  Attachment


Nuclear Regulatory Commission
                          LIST OF ACRONYMS USED
R. Daley, Branch Chief, Division of Reactor Safety G. Roach, Senior Resident Inspection, LaSalle County Station
ADAMS Agency Documents Access Management System
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED Opened 05000373/2008007-01 05000374/2008007-01
AR   Action Request
NCV Unauthorized Transient Combustibles 05000373/2008007-02 05000374/2008007-02 NCV Failure to Provide a Sprinkler System for Fire Zone 4F3
FSAR Final Safety Analysis Report
Closed 05000373/2008007-01 05000374/2008007-01
IMC   Inspection Manual Chapter
NCV Unauthorized Transient Combustibles 05000373/2008007-02 05000374/2008007-02 NCV Failure to Provide a Sprinkler System for Fire Zone 4F3
IP   Inspection Procedure
 
IPEEE Individual Plant Examination of External Events
Attachment
IR   Inspection Report
2LIST OF DOCUMENTS REVIEWED The following is a list of documents reviewed during the inspection.  Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort.  Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.  1R05 Fire Protection Calculations and Analyses (71111.05T) L-000776; LaSalle Combustible Load for Fire Zone 4F3; Revision 5 L-001726; Hydraulic Analysis to Determine the Adequacy of the Service Water Pumps to Function as Fire Pumps; Revision 2 L-001947; Safe Shutdown Control Circuit Breaker-Fuse Coordination; Revision 01
LLC   Limited Liability Corporation
L--002771; GL 86-10 Operator Action Evaluation for Fuse Pulling in AEER and Valve Manipulation in Reactor Building for Post Fire Safe Shutdown; Revision 0 L-003289; LaSalle Fire Detector Smoke Stratification Justification; Revision 0 EC 0000331385; Safe Shutdown Control Circuit Breaker-Fuse Coordination Calculation Revision; dated December 20, 2001 GE-NE-A1300384-43-01; LaSalle County Station Power Uprate Project, Task 611:  Appendix R Fire Protection [Proprietary]; dated September 1999 Schirmer Engineering Corporation: Automatic Sprinkler System Calculation, LaSalle County Station; dated January 26, 1984 Corrective Action Documents
NCV   Non-Cited Violation
AR 00369313; Multiple Spurious Actuations of ADS Valves; dated September 1, 2005 AR 00578440; Replace Smoke Detector with New Style Detector; dated January 12, 2007 AR 00632819; Fireproofing Removed Requiring Compensatory Actions; dated May 23, 2007 AR 00637145; "0B" Diesel FP Activities; dated June 5, 2007 AR 00659506; Two Different Battery Models Installed in B Diesel Fire Pump; dated August 10, 2007 AR 00671437; Overlab FP System - Could not Test All Detectors; dated September 14, 2008 AR 00704946; NOS ID Fire Doors not Inspected Under Proper Surveillance; dated November 29, 2007 
NFPA National Fire Protection Association
Attachment
NRC   U.S. Nuclear Regulatory Commission
3AR 00704957; NOS ID Fire Door Sealing Device does not Meet Hour Rating; dated November 29, 2007 AR 00711394; 1FP01C Still Short Cycling; dated December 13, 2007 AR 00716061; Fire Door 284 Door Latch not Operating Properly; dated December 28, 2007 AR 00747573; Fire Line Pipe Corrosion; dated March 10, 2008
PARS Publicly Available Records System
AR 00750853; Fire Doors/Barrier Reclassification; dated March 17, 2008 AR 00761675; 0B Diesel Fire Pump Troubleshooting; dated April 10, 2008 AR 00783879; Local Alarm will not Sound - Building 33; dated June 6 2008 AR 00836266; Declining Trend in Transient Combustibles; dated October 27, 2008 AR 00841673; Transient Combustible Material Extent of Condition Walkdown; dated November 7, 2008 CR L2001-02263; Potential Spurious Operations During CR or AEER Fire; dated April 5, 2001 Corrective Action Documents Initiated as a Result of Inspection
SDP   Significance Determination Process
AR 00834512; NRC Identified Combustibles During Walkdown with FP Engineer; dated October 22, 2008 AR 00835086; NRC Identified Chair Not Removed Until Following Morning; dated October 23, 2008 AR 00837934; NRC TRI:  Passport D030 Discrepancy for DFP Pressure SW; dated October 30, 2008 AR 00839030; NRC Identified Issues - LaSalle Triennial Inspection; dated October 30, 2008 AR 00840401; NRC Identified Inspection Findings in Aux Bldg Ceiling; dated November 4, 2008 AR 00840264; FP Report Document Problem - LaSalle Triennial Inspection; dated November 4, 2008 AR 00840339; NRC Triennial Fire Protection Inspection; dated November 4, 2008
                                      10              Attachment
AR 00840381; NRC Identified SLICE (Cable Analysis) Discrepancies; dated November 4, 2008 AR 00840833; NRC Triennial Inspection-Equip. Number Error on 1E-1-4220AC; dated November 5, 2008 
Attachment
4AR 00841245; NRC Triennial:  ELBP 1LL142E North Side Fixed Lamp Aiming; dated November 6, 2008 AR 00841304; NRC Triennial Inspection - FPR H.4.6.2 Discrepancy; dated November 6, 2008 AR 00841326; NRC ID:  Transient Combustible Near Vertical Power Riser; dated November 6, 2008 AR 00841364; NRC FP Triennial Inspection - Calc L-001947 Recommendation; dated November 6, 2008 AR 00841433; NRC Triennial:  FP Related Drawing Deficiencies; dated November 6, 2008 AR 00841355; NRC Triennial:  Smoke from AEER Fire Affecting Operator Actions; dated November 6, 2008 AR 00841458; NRC Triennial:  LOA-FX-101 - Fuse Orientation Description; dated November 6, 2008 AR 00841490; NRC Triennial FP Inspection Walkdown; dated November 6, 2008 AR 00841494; NRC Triennial FP Inspection Walkdown; dated November 6, 2008
AR 00842109; NRC FP Triennial: DFP Start Sequencing Compliance with NFPA; dated November 7, 2008 AR 00843614; NRC FP Inspection - FZ 4F3 Hydraulic Calc Retrieval Difficult; dated November 11, 2008 AR 00846249; NRC Triennial Inspection - Discrepancy on Dwg 1E-2-4601BA; dated November 17, 2008 AR 00846419; NRC Fire Protection Triennial Inspection; dated November 18, 2008 AR 00846433; 2008 NRC FP Triennial - Drawing Discrepancy 1E-4220AQ; dated November 18, 2008 AR 00846729; NRC Triennial Inspection-Description of Codes Not Available; dated November 18, 2008 AR 00846731; NRC Identified SRV Issue During FP Triennial Inspection; dated November 18, 2008 AR 00846760; NRC Fire Protection Triennial; dated November 18, 2008 AR 00846783; NRC Triennial:  Smoke Detectors Affect Any Other Functions; dated November 18, 2008 AR 00847185; FPR Table H.4-59 and Table H.4-60 Incorrectly List Cable 1NB335 As Supporting Control Room Recorder 1B21-R884A; dated November 19, 2008 
Attachment
5AR 00847328; NRC Triennial Inspection-Discrepancy on S/D 1E-2-4220CH; dated November 19, 2008 AR 00847337; NRC Triennial: FP Related Drawing Deficiencies; dated November 19, 2008 AR 00847578; NRC FP Triennial - The Safe Shutdown Cable Routing Drawings Incorrectly Show that Cable 1RH360 is Routed in Fire Zone 4E1-1; dated
November 20, 2008 AR 00847709; NRC FP Inspection:  AEER Roll-Up Door Evaluation Canceled; dated November 20, 2008 AR 00848042; NRC FP Triennial - SLICE Fire Zone Data "Reference Only"; dated November 21, 2008 AR 00848063; NRC FP Triennial Inspection:  FP Spray Nozzle Orifice Size; dated November 20, 2008 AR 00847728; NRC Identified Sprinkler Heat NFPA Code Deviation; dated November 20, 2008 AR 00847809; NRC Triennial: LOA-FX-101(201) AEER Validation Order; dated November 20, 2008 AR 00846788; NRC FP Triennial: DFP Start Sequencing, Timing; dated November 18, 2008 AR 00849044; NRC Potential Finding, Chemistry Overlab FP System; dated November 21, 2008 AR 00855527; Rotate FP Water Spray Nozzle to Optimize Spray Pattern; dated December 12, 2008 Drawings 15; Cable Spreading Rooms Supervised Pre-action Systems; Revision 10 16A; Auxiliary Building Elevation 749'0" Cable Spreading Room Details & Section 1E-1-3445; Electrical Installation Auxiliary Building Auxiliary Equipment Room Plan EL. 731'-0" Col. 12-15 & J-N; Revision AU 1E-1-3465; Electrical Installation Control Room Plan EL. 768'-0" Col. 12-15 & J-N; Revision Z 1E-1-3663; Cable Pan Routing Aux. Bldg. Plan EL. 710'6" Cols 12-15; Revision S 1E-1-3694M, Sheet 1; Safe Shutdown Cable Routing Aux. Bldg. Plan El. 731'-0" Cols. 12-15; Revision; A 1E-1-3694M, Sheet 2; Safe Shutdown Cable Routing Schedules for Aux. Bldg. Plan EL. 731'-0" Cols. 12-15; Revision; A 
Attachment
61E-1-3694P, Sheet 1; Safe Shutdown Cable Routing Schedules for Aux. Bldg. Plan EL. 749'-0" Cols. 12-15; Revision; A 1E-1-3694P, Sheet 2; Safe Shutdown Cable Routing Schedules for Aux. Bldg. Plan EL. 749'-0" Cols. 12-15; Revision; A 1E-1-4018ZE; Loop Schematic Diagram - Containment Monitoring System CM, Part 5; Revision Q 1E-1-4201AA; Schematic Diagram - Auto Depressurization System "NB" (B21C) Part 1 1E-1-4201AC; Schematic Diagram - Auto Depressurization System "NB" (B21C) Part 3; Revision AA 1E-1-4201AD; Schematic Diagram - Auto Depressurization System "NB" (B21C) Part 4; Revision AC 1E-1-4201AE; Schematic Diagram - Auto Depressurization System "NB" (B21C) Part 5; Revision V 1E-1-4201AF; Schematic Diagram - Auto Depressurization System "NB" (B21C) Part 6; Revision AA 1E-1-4201AG; Schematic Diagram - Auto Depressurization System "NB" (B21C) Part 7; Revision  1E-1-4201AJ; Schematic Diagram - Auto Depressurization System "NB" (B21C) Part 9; Revision G 1E-1-4201AK; Schematic Diagram - Auto Depressurization System "NB" (B21C) Part 10; Revision F 1E-1-4203AK; Schematic Diagram - Main Steam/Nuclear Boiler System NB (B21), Part 10; Revision Y 1E-1-4214AA; Schematic Diagram - Remote Shutdown System "RS" Part 1; Revision K 1E-1-4220BD; Schematic Diagram - Residual Heat Removal System RH (E12) Part 28; Revision N 1E-1-4220BX; Schematic Diagram - Residual Heat Removal System RH (E12) Part 46; Revision R 1E-1-4220BY; Schematic Diagram - Residual Heat Removal System RH (E12) Part 47; Revision K 1E-1-4220CH; Schematic Diagram - Residual Heat Removal System RH (E12) Part 56; Revision M 1E-1-4379AC; Internal Wiring Diagram - 480V MCC Detail; Revision K 
Attachment
71E-1-4391AB; Internal/External Wiring Diagram - Reactor Building 480V MCC 136Y-1, Part 2; Revision W 1E-1-4442AA; Internal/External Wiring Diagram - Automatic Depressurization Channel "A" Relay Vertical Board 1H13-P628, Part 1; Revision R 1E-1-4622AB; Internal/External Wiring Diagram - 125VDC Distr. Bus 1B and 125VDC Dist. Panel 112Y; Revision T 1E-1-4622AC; Internal/External Wiring Diagram - Automatic Depressurization Channel "A" Relay Vertical Board 1H13-P628, Part 2; Revision AA 1E-1-4622AD; Internal/External Wiring Diagram - Automatic Depressurization Channel "A" Relay Vertical Board 1H13-P628; Revision J 1E-1-4622AF; Internal/External Wiring Diagram - Automatic Depressurization Channel "A" Relay Vertical Board 1H13-P628, Part 3; Revision G 1E-1-4624AB; Internal/External Wiring Diagram - Automatic Depressurization Channel "B" Relay Vertical Board 1H13-P631; Revision AB 1E-1-4658AH; Internal/External Wiring Diagram - Remote Shutdown Panel 1C61-P001, Part 6; Revision Z 1E-1-4696AB; Internal/External Wiring Diagram - ADS/SRV Valves Aux Relay Vertical Board Div. 1, Panel 1H13-P644; Revision K 1E-1-4696AC; Internal/External Wiring Diagram - ADS/SRV Valves Aux Relay Vertical Board Div. 1, Panel 1H13-P644; Revision F 1E-1-4697AB; Internal/External Wiring Diagram - ADS/SRV Valves Aux Relay Vertical Board Div. 2, Panel 1H13-P645; Revision P 1E-1-4697AC; Internal/External Wiring Diagram - ADS/SRV Valves Aux Relay Vertical Board Div. 2, Panel 1H13-P645; Revision G 81-78483; Cable Trays over Lab ceiling Unit 1 & 2, EL. 710'6" Supervised Pre-action System; Revision 1, Figure 9.5-1, Sheet 15 of 41; Fire Protection System EL 749'0"; Revision 17 Figure 9.5-1; Sheet 17 of 41; Fire Protection System EL 740'0"; Revision 17 Figure 9.5-1; Sheet 22 of 41; Fire Protection System EL 710'6"; Revision 17 Supervised Pre-action Systems; Revision 10
Attachment
8Miscellaneous
LSCS-FPR; LaSalle Station Fire Protection Report- Appendix H.4, "Safe Shutdown Analysis"; Revision 3  DBD-LS-E09; LaSalle Units 1 and 2, Electrical Separation, Table 4.4.1-1 "Redundant and Non-Redundant Divisions"; Revision 0 DBD-LS-E09; LaSalle Units 1 and 2, Electrical Separation, Table 4.4.1-2 "Electrical Raceway Separation Design Requirements and Design Basis"; Revision 0 SLICE Version 7.6; LaSalle Unit 1 Cable Transaction Report (S102); 1986-1999 SLICE Version 7.6; LaSalle Unit 1 Fire Shutdown Cables/Fire Zone Report (S115);
1986-1999 SLICE Version 7.6; LaSalle Unit 1 Fire Zones/Fire Shutdown Cable Report (S116);
1986-1999 SLICE Version 7.6; LaSalle Unit 1 Fire Protection Safe Shutdown Discrepancy List Report (S143); 1986-1999 SLICE Version 7.6; LaSalle Unit 1 Fire Protection Safe Shutdown Discrepancies - Unresolved Report (S143); 1986-1999 AR 707263; LaSalle Station Triennial Fire Protection Inspection Preparatory Self Assessment; July/August 2008 AR 576593; LaSalle Station Fire Protection Program Audit Report Audit NOSA-LAS-07-09; dated December 5, 2007 AR 219447-05; LaSalle Station Focus Area Self-Assessment Report; dated June 2005 1C-7-0784-002; Actions Necessary to Address Valve Failures or Spurious Operations; dated April 2, 1985 CT.5ENG.4, Appendix R Spurious Operation Analysis, Phase 1 Report (AT-144623-01); Revision 0 Procedures
CC-AA-206; Exelon Nuclear-Fuse Control; Revision 5 LOA-FP-101; Unit 0 Fire Protection System Abnormal; Revision 2
LOA-FP-101; Unit 1 Fire Protection Abnormal; Revision 9 LOA-FX-101; Unit 1 Safe Shutdown with a Loss of Offsite Power and a Fire in the Control Room or AEER; Revision 13 
Attachment
9LOA-FX-101- Attachment C; Repair of 1E12-F009, RHR Inboard Shutdown Cooling Valve; Revision 13 LOP-RH-17; Alternate Shutdown Cooling; Revision 25 LOA-SRV-101; Unit 1 Stuck Open Safety Relief Valve; Revision 5 LOS-FP-M4 U1; FP Deluge Valve Lineup 1112018-01 OP-AA-201-009; Control of Combustible Material; Revision 7
OP-MW-201-007; Fire Protection System Impairment Control; Revision 6 Work Orders
980089736 01; Hydro Test all Fire Hoses per TS 4.7.5.4.D or Replace Fire Hose; dated August 29, 2000 00639790 01; Hydro Test all Fire Hoses per TS 4.7.5.4.D or Replace Fire Hose; dated November 14, 2005 01044223 01; Annual Inspection of FP Strainer for Cleanliness; dated June 25, 2008 00465471 01; Electrical Fire Penetration Inspection; dated January 28, 2004 960119253 01; Electrical Fire Penetration Inspection; dated August 20, 1997 980074104 01; Electrical Fire Penetration Inspection; dated October 30, 1997 99236634 01; Electrical Fire Penetration Inspection; dated January 31, 2003 112018 01; LOS-FP-M4 U1 Deluge Valve Lineup; dated June 6, 2008
849192 01; LOS-FP-R6 U-0 Cable Trays Over Labs Sprinkler Sys; dated July 13, 2007 952500 01; Overlab Cable Tray Sprinkler Sys Channel Function Test; dated November 27, 2007 859933 01; U-1 Cable Spreading Room Sprinkler Sys Channel Function Test; dated January 12, 2007 992888 01; U-1 Cable Spreading Room Sprinkler Sys Chan. Function Test, LES-FP-06; dated January 11, 2008 
Attachment
10LIST OF ACRONYMS USED ADAMS Agency Documents Access Management System AR Action Request FSAR Final Safety Analysis Report IMC Inspection Manual Chapter IP Inspection Procedure  
IPEEE Individual Plant Examination of External Events IR Inspection Report LLC Limited Liability Corporation NCV Non-Cited Violation NFPA National Fire Protection Association  
NRC U.S. Nuclear Regulatory Commission PARS Publicly Available Records System SDP Significance Determination Process
}}
}}

Revision as of 10:07, 14 November 2019

IR 05000373-08-007, 05000374-08-007 on 11/03/08 - 11/21/2008 for LaSalle County Station, Units 1 & 2
ML083660190
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 12/31/2008
From: Robert Daley
Engineering Branch 3
To: Pardee C
AmerGen Energy Co
References
IR-08-007
Download: ML083660190 (28)


See also: IR 05000373/2008007

Text

December 31, 2008

Mr. Charles G. Pardee

President and Chief Nuclear Officer (CNO), Exelon Nuclear

Chief Nuclear Officer (CNO), AmerGen Energy Company, LLC

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: LASALLE COUNTY STATION, UNITS 1 AND 2

TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000373/2008007;

05000374/2008007

Dear Mr. Pardee:

On November 21, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial

fire protection inspection at your LaSalle County Station, Units 1 and 2. The enclosed report

documents the results of this inspection, which were discussed on November 21, 2008, with

Mr. D. Rhoades and other 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.

Based on the results of this inspection, two NRC-identified findings of very low safety

significance were identified. The findings involved a violation of NRC requirements. However,

because of their very low safety significance, and because the issues were entered into your

corrective action program, the NRC is treating the issues as Non-Cited Violations (NCVs) in

accordance with Section VI.A.1 of the NRC Enforcement Policy.

If you contest the subject or severity of 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 a copy to the Regional Administrator, U.S. Nuclear Regulatory

Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the

Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC

20555-0001; and the Resident Inspector Office at the LaSalle County Station.

C. Pardee -2-

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,

its enclosure, and your response (if any), will be available electronically for public inspection in

the NRC Public Document Room or from the Publicly Available Records System (PARS)

component of NRC's Agencywide Documents Access and Management System (ADAMS),

accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public

Electronic Reading Room).

Sincerely,

/RA by D. E. Hills Acting For/

Robert C. Daley, Chief

Engineering Branch 3

Division of Reactor Safety

Docket Nos. 50-373; 50-374

License Nos. NPF-11; NPF-18

Enclosure: Inspection Report 05000373/2008007 05000374/2008007

w/Attachment: Supplemental Information

cc w/encl: Site Vice President - LaSalle County Station

Plant Manager - LaSalle County Station

Regulatory Assurance Manager - LaSalle County Station

Chief Operating Officer and Senior Vice President

Senior Vice President - Midwest Operations

Senior Vice President - Operations Support

Vice President - Licensing and Regulatory Affairs

Director - Licensing and Regulatory Affairs

Manager Licensing - Braidwood, Byron and LaSalle

Associate General Counsel

Document Control Desk - Licensing

Assistant Attorney General

J. Klinger, State Liaison Officer,

Illinois Emergency Management Agency

Chairman, Illinois Commerce Commission

C. Pardee -2-

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,

its enclosure, and your response (if any), will be available electronically for public inspection in

the NRC Public Document Room or from the Publicly Available Records System (PARS)

component of NRC's Agencywide Documents Access and Management System (ADAMS),

accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public

Electronic Reading Room).

Sincerely,

/RA by D. E. Hills Acting For/

Robert C. Daley, Chief

Engineering Branch 3

Division of Reactor Safety

Docket Nos. 50-373; 50-374

License Nos. NPF-11; NPF-18

Enclosure: Inspection Report 05000373/2008007; 05000374/2008007

w/Attachment: Supplemental Information

cc w/encl: Site Vice President - LaSalle County Station

Plant Manager - LaSalle County Station

Regulatory Assurance Manager - LaSalle County Station

Chief Operating Officer and Senior Vice President

Senior Vice President - Midwest Operations

Senior Vice President - Operations Support

Vice President - Licensing and Regulatory Affairs

Director - Licensing and Regulatory Affairs

Manager Licensing - Braidwood, Byron and LaSalle

Associate General Counsel

Document Control Desk - Licensing

Assistant Attorney General

J. Klinger, State Liaison Officer,

Illinois Emergency Management Agency

Chairman, Illinois Commerce Commission

DOCUMENT NAME: G\DRS\Work in Progress\LaSalle 2008-007 DRS RAL.doc

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 N RIII

NAME RLangstaff:ls DHills for RDaley

DATE 12/31/08 12/31/08

OFFICIAL RECORD COPY

Letter to Mr. Charles Pardee from Mr. Robert Daley dated December 31, 2009.

SUBJECT: LASALLE COUNTY STATION, UNITS 1 AND 2

TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000373/2008007;

05000374/2008007

DISTRIBUTION:

Tamara Bloomer

RidsNrrDorlLpl3-2

RidsNrrPMLaSalle

RidsNrrDirsIrib Resource

Mark Satorius

Kenneth Obrien

Jared Heck

Carole Ariano

Linda Linn

Cynthia Pederson

DRPIII

DRSIII

Patricia Buckley

Tammy Tomczak

ROPreports@nrc.gov

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket Nos: 05000373/2008007; 05000374/2008007

License Nos: NPF-11; NPF-18

Report No: 05000373/2008007; 05000374/2008007

Licensee: Exelon Generation Company, LLC

Facility: LaSalle County Station, Units 1 and 2

Location: Marseilles, IL

Dates: November 3 through November 21, 2008

Inspectors: R. Langstaff, Senior Reactor Inspector, Lead

Z. Falevits, Senior Reactor Inspector

R. Winter, Reactor Inspector

Approved by: R. Daley, Chief

Engineering Branch 3

Division of Reactor Safety

Enclosure

SUMMARY OF FINDINGS

IR 05000373/2008007, 05000374/2008007; 11/03/2008-11/21/2008; LaSalle County Station,

Units 1 & 2.

This report covers an announced baseline inspection by regional inspectors. Two Green

findings were identified by the inspectors. The findings were considered Non-Cited Violations

(NCVs) 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 NRCs program for overseeing the safe

operation of commercial nuclear power reactors is described in NUREG-1649, Reactor

Oversight Process, Revision 4, dated December 2006.

A. NRC-Identified and Self-Revealed Findings

Cornerstone: Initiating Events

  • Green. A finding of very low safety significance and associated NCV of Technical

Specifications was identified by the inspectors for the failure to implement a fire

protection program procedure for combustible controls. Specifically, the inspectors

identified three examples where transient combustible materials were staged adjacent to

cable risers contrary to the licensees procedure for combustible controls. The licensee

subsequently removed the transient combustible materials and entered the issue into

their corrective action program.

The finding was determined to be more than minor because, the finding was similar to

IMC 0612, Appendix E, Example 4.k, in that the transient combustibles presented

credible fire scenarios, which could affect equipment important to safety. The issue was

of very low safety significance because, the finding represented a low degradation of the

licensees combustible controls program. Additionally, this finding has a cross-cutting

aspect in the area of Human Performance for the Work Practices component because,

multiple examples were identified where transient combustibles were staged contrary to

site procedures. H.4(b) (Section 1R05.2.b(1))

Cornerstone: Mitigating Systems

  • Green. A finding of very low safety significance and associated NCV of the license

condition was identified by the inspectors for the failure to install a sprinkler system.

Specifically, the licensee had installed a pre-action spray system above the suspended

ceiling in Fire Zone 4F3 instead of a pre-action sprinkler system as specified by the Fire

Protection Report. The licensee subsequently entered the issue into its correction action

program.

1 Enclosure

The finding was determined to be more than minor because, the installed spray system

was less capable than a sprinkler system in that, a fire would be permitted to grow to a

larger size and cause more damage as a result of delayed system actuation. The issue

was of very low safety significance due to remaining mitigating system capability.

(Section 1R05.4.b(1))

B. Licensee-Identified Violations

No violations of significance were identified.

2 Enclosure

REPORT DETAILS

1. REACTOR SAFETY

Cornerstone: Initiating Events and Mitigating Systems

1R05 Fire Protection (71111.05T)

The purpose of the Fire Protection Triennial Baseline Inspection was to conduct a

design-based, plant specific, risk-informed, onsite inspection of the licensees fire

protection programs defense-in-depth elements used to mitigate the consequences of a

fire. The fire protection program shall extend the concept of defense-in-depth to fire

protection in plant areas important to safety by:

  • preventing fires from starting;
  • rapidly detecting, controlling and extinguishing fires that do occur; and
  • providing protection for structures, systems, and components important to safety

so that a fire that is not promptly extinguished by fire suppression activities will not

prevent the safe shutdown of the reactor plant.

The inspectors evaluation focused on the design, operational status, and material

condition of the reactor plants fire protection program and post-fire safe shutdown

systems. The objectives of the inspection were to assess whether the licensee had

implemented a fire protection program that: (1) provided adequate controls for

combustibles and ignition sources inside the plant; (2) provided adequate fire detection

and suppression capability; (3) maintained passive fire protection features in good

material condition; (4) established adequate compensatory measures for out-of-service,

degraded or inoperable fire protection equipment, systems or features; (5) ensured that

procedures, equipment, fire barriers and systems exist so that the post-fire capability to

safely shutdown the plant was ensured; (6) included feasible and reliable operator

manual actions when appropriate to achieve safe shutdown; and (7) identified fire

protection issues at an appropriate threshold and ensured these issues were entered

into the licensees problem identification and resolution program.

In addition, the inspectors review and assessment focused on the licensees post-fire

safe shutdown systems for selected risk-significant fire areas. Inspector emphasis was

placed on determining that the post-fire safe shutdown capability and the fire protection

features were maintained free of fire damage to ensure that at least one post-fire safe

shutdown success path was available. The inspection was performed in accordance

with U. S. Nuclear Regulatory Commission (NRC) Inspection Procedure (IP) 71111.05T,

Fire Protection (Triennial), dated April 21, 2006. The NRC regulatory oversight

process IP used a risk-informed approach for selecting the fire areas and/or fire zones

and attributes to be inspected. The inspectors with assistance from a senior reactor

analyst used the licensees Individual Plant Examination for External Events to select

several risk-significant areas for detailed inspection and review. Documents reviewed

are listed in the Attachment to this report.

The fire areas and/or fire zones selected for review during this inspection are listed

below and constituted three inspection samples as defined in IP 71111.05T.

3 Enclosure

Fire Zone Description

4D1 Unit 1 Cable Spreading Room

4E1 Unit 1 Auxiliary Electric Room

Auxiliary Building, Ground Floor (Unit 1 portion)

4F3

.2 Shutdown from Outside Main Control Room

a. Inspection Scope

The inspectors reviewed the functional requirements identified by the licensee as

necessary for achieving and maintaining hot shutdown conditions to ensure that at least

one post-fire safe shutdown success path was available in the event of fire in each of the

selected fire areas and for alternative shutdown in the case of a fire in the Unit 1

auxiliary electric room requiring shutdown actions outside the control room. The

inspectors reviewed the plant systems required to achieve and maintain post-fire safe

shutdown to determine if the licensee had properly identified the components and

systems necessary to achieve and maintain safe shutdown conditions for each fire area

selected for review. Specifically, the review was performed to determine the adequacy

of the systems selected for reactivity control, reactor coolant inventory makeup, reactor

heat removal, process monitoring, and support system functions. The review also

included the fire safe shutdown analysis to ensure that all required components in the

selected systems were included in the licensees safe shutdown analysis.

The inspectors reviewed the licensees post-fire safe shutdown analysis, normal and

abnormal operating procedures, piping and instrumentation drawings, electrical

drawings, their updated final safety analysis report, and other supporting documents to

verify that hot and cold shutdown could be achieved and maintained from outside the

control room for a fire in the Unit 1 auxiliary electric room that relies on shutdown from

outside the control room. This review included verification that shutdown from outside

the control room could be performed both with and without the availability of offsite

power.

The inspectors also examined the operators ability to perform the necessary manual

actions for achieving safe shutdown by reviewing post-fire shutdown procedures, the

accessibility of safe shutdown equipment, and the available time for performing the

actions.

The inspectors reviewed the updated final safety analysis report and the licensees

engineering and/or licensing justifications (e.g., NRC guidance documents, license

amendments, Technical Specifications, safety evaluation reports, exemptions, and

deviations) to determine the licensing basis.

b. Findings

No findings of significance were identified.

4 Enclosure

.3 Protection of Safe Shutdown Capabilities

a. Inspection Scope

For each of the selected fire areas, the inspectors reviewed the fire hazards analysis,

safe shutdown analysis, and supporting drawings and documentation to verify that safe

shutdown capabilities were properly protected.

The inspectors reviewed the licensee procedures and programs for the control of ignition

sources and transient combustibles to assess their effectiveness in preventing fires and

in controlling combustible loading within limits established in the fire hazards analysis.

The inspectors performed plant walkdowns to verify that protective features were being

properly maintained and administrative controls were being implemented.

The inspectors also reviewed the licensees design control procedures to ensure that the

process included appropriate reviews and controls to assess plant changes for any

potential adverse impact on the fire protection program and/or post-fire safe shutdown

analysis and procedures.

b. Findings

(1) Unauthorized Transient Combustibles

Introduction: A finding of very low safety significance and associated Non-Cited

Violation (NCV) of Technical Specifications was identified by the inspectors for the

failure to implement a fire protection program procedure for combustible controls.

Specifically, the inspectors identified three examples where transient combustible

materials were staged adjacent to cable risers contrary to Procedure OP-AA-201-009,

Control of Combustible Material, Revision 7.

Description: On October 22, 2008, the inspectors identified a plastic chair staged

adjacent to cable risers in the auxiliary building. Specifically, the plastic chair was

located between two cable risers and was less than two feet from cable risers containing

safety-related cables. The licensee placed the issue into their corrective action program

(Action Request (AR) 00834512, NRC Identified Combustibles During Walkdown with

FP Engineer) and subsequently removed the chair. On November 4, 2008, the

inspectors identified an unattended fiberglass cart with rags and tools in the upper tray

adjacent to a cable riser containing emergency shutdown system cables (AR 00841326,

NRC ID: Transient Combustible Near Vertical Power Riser). On November 6, 2008,

the inspectors identified a black foam sheet of insulation material, approximately two feet

square, left behind and adjacent to a cable riser containing reactor protection system

cables (AR 00841490, NRC Triennial FP Inspection Walkdown). The licensee initiated

corrective action by removing the transient combustible material. Additionally, the

licensee performed an extent of condition review and documented their findings in their

corrective action program (AR 00841673, Transient Combustible Material Extent of

Condition Walkdown).

Procedure OP-AA-201-009 was the site procedure for combustible controls which, in

part, implemented the site fire protection program. Procedure OP-AA-201-009,

Section 4.4.2, Paragraph 6, directed licensee personnel to avoid staging exposed

5 Enclosure

Class A combustible material immediately adjacent to (i.e., within approximately three feet)

cable risers. The inspectors noted that National Fire Protection Association (NFPA) 10,

Standard for Portable Fire Extinguishers, defined Class A fires as fires in ordinary

combustible materials, such as wood, cloth, paper, rubber, and many plastics. As such,

the inspectors considered the identified materials to be Class A materials located in

manner contrary to site implementing procedures for the fire protection program.

Analysis: The inspectors determined that staging combustible materials adjacent to cable

risers was contrary to site implementing procedures for the fire protection program and

was a performance deficiency. Specifically, the inspectors identified three examples

where Class A combustible materials were staged near cable risers was contrary to

Procedure OP-AA-201-009.

The finding was determined to be more than minor because the finding was similar to

Inspection Manual Chapter (IMC) 0612, Appendix E, Example 4.k. The Class A transient

combustible materials (i.e., the chair, the cart, and the foam insulation) were not in

approved temporary storage locations approved by an engineering evaluation.

Specifically, the transient combustibles were located within the zone of influence for

a 70 kiloWatt fire for the thermoset cables located within the vertical cable risers

(IMC 0609, Appendix F, Fire Protection Significance Determination Process, dated

February 28, 2005, Table 2.3.2). Consequently, the transient combustibles created

credible fire scenarios that could affect equipment important to safety (such as the

safety-related cables and/or cables required for safe shutdown, within the vertical cable

risers). Therefore, this performance deficiency impacted the Initiating Events Cornerstone

objective of limiting the likelihood of those events that upset plant stability and challenge

critical safety functions during plant operations.

The inspectors reviewed IMC 0609, Appendix A, and determined that since the finding

affected administrative controls for fire protection, a significance determination evaluation

under IMC 0609, Appendix F, was required. The inspectors completed a significance

determination of this issue using IMC 0609, Appendix F, Attachment 2, Degradation

Rating Guidance Specific to Various Fire Protection Program Elements, dated

February 28, 2005. The inspectors determined that the staging of Class A combustibles

was a low degradation finding against the combustible controls program because the

identified materials would not cause a fire from existing sources of heat or electrical

energy. Question 1 of IMC 0609, Appendix F, Task 1.3.1, Qualitative Screening for All

Finding Categories, showed that the finding was of very low safety significance (Green)

due to the low degradation rating.

This finding has a cross-cutting aspect in the area of Human Performance for the Work

Practices component because the licensee did not define and effectively communicate

expectations regarding procedural compliance and personnel failed to follow procedures.

Specifically, multiple examples were identified where transient combustibles were staged

contrary to site procedures. (Example H.4(b)).

Enforcement: Technical Specification, Section 5.4.1 required, in part, that written

procedures shall be established, implemented, and maintained for fire protection program

implementation. The licensee established Procedure OP-AA-201-009 as the

implementing procedure for combustible controls for their fire protection program.

Section 4.4.2, Paragraph 6, of Procedure OP-AA-201-009 directed licensee personnel to

6 Enclosure

avoid staging exposed Class A combustible material immediately adjacent to (i.e., within

approximately three feet) cable risers.

Contrary to the above, On October 22, 2008; November 4, 2008; and November 6, 2008,

the licensee failed to implement a procedure for fire protection program implementation

in that Class A combustible materials were staged adjacent to cable risers contrary to

OP-AA-201-009. Specifically, a plastic chair was located less than two feet from cable

risers containing reactor protection system cables (October 22, 2008), an unattended

fiberglass cart with rags and tools in the upper tray was adjacent to a cable riser

containing emergency shutdown system cables (November 4, 2008), and a black foam

sheet of insulation material was left behind and adjacent to a cable riser containing reactor

protection system cables (November 6, 2008). Once identified, the licensee removed the

transient combustible materials and entered the issue into their corrective action program

(AR 00834512, AR 00841326, and AR 00841490). Because this violation was of very low

safety significance and it was entered into the licensees corrective action program, this

violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC

Enforcement Policy (NCV 05000373/2008007-01(DRS);05000374/2008007-01(DRS)).

.4 Passive Fire Protection

a. Inspection Scope

For the selected fire areas, the inspectors evaluated the adequacy of fire area barriers,

penetration seals, fire doors, electrical raceway fire barriers, and fire rated electrical

cables. The inspectors observed the material condition and configuration of the installed

barriers, seals, doors, and cables. The inspectors reviewed approved construction details

and supporting fire tests. In addition, the inspectors reviewed license documentation, such

as NRC safety evaluation reports, and deviations from NRC regulations and the National

Fire Protection Association codes to verify that fire protection features met license

commitments.

The inspectors walked down accessible portions of the selected fire areas to observe

material condition and the adequacy of design of fire area boundaries (including walls, fire

doors, and fire dampers) to ensure they were appropriate for the fire hazards in the area.

The inspectors reviewed the installation, repair, and qualification records for a sample of

penetration seals to ensure the fill material was of the appropriate fire rating and that the

installation met the engineering design.

b. Findings

No findings of significance were identified.

.5 Active Fire Protection

a. Inspection Scope

For the selected fire areas, the inspectors evaluated the adequacy of fire suppression and

detection systems. The inspectors observed the material condition and configuration of

7 Enclosure

the installed fire detection and suppression systems. The inspectors reviewed design

documents and supporting calculations. In addition, the inspectors reviewed license basis

documentation, such as, NRC safety evaluation reports, deviations from NRC regulations,

and the National Fire Protection Association codes to verify that fire suppression and

detection systems met license commitments.

b. Findings

(1) Failure to Provide a Sprinkler System for Fire Zone 4F3

Introduction: A finding of very low safety significance and associated NCV of license

conditions 2.C(25) and 2.C(15) for Units 1 and 2, respectively, was identified by the

inspectors for the failure to install a sprinkler system in Fire Zone 4F3. Specifically, the

licensee had installed a pre-action spray system above the suspended ceiling in Fire Zone

4F3 instead of a pre-action sprinkler system as specified by the Fire Protection Report.

Description: Fire Zone 4F3 was centrally located on the ground floor of the auxiliary

building. In addition to serving as a chemistry laboratory area, the zone served as a cable

spreading area for Division I cables for both units. The cable spreading area was located

above the suspended ceiling for the chemistry laboratory facilities.

As part of licensing amendment 49, dated May 1980, the license committed to provide an

automatic sprinkler system for the cable concentration above the suspended ceiling in this

area. Additionally, Section H.3.4.18, Auxiliary Building Ground Floor - Fire Zone 4F3, of

the LaSalle County Station Fire Protection Report stated A pre-action sprinkler system is

located above the suspended ceiling to protect the cabling located there. The inspectors

noted that sprinkler systems generally have sprinklers located near the ceiling. The code

of record for sprinklers used at LaSalle County Station was NFPA 13-1976, Standard for

the Installation of Sprinkler Systems. The suppression system installed above the

suspended ceiling for Fire Zone 4F3 was not a sprinkler system and did not meet the

requirements of NFPA 13-1976. Specifically, Section 3-15.2.1 of NFPA 13-1976

required that listed sprinklers be used. The licensees installation used spray nozzles.

Section 4-3.2.1 of NFPA 13-1976 specified that deflectors of sprinklers be located 1 to

16 inches below floor decks (i.e., ceilings) for beam and girder construction. During

walkdowns of the Unit 1 portion of Fire Zone 4F3, the inspectors did not observe any

sprinklers or spray nozzles within 16 inches of the ceiling. The inspectors noted that the

suppression system installed was a spray system for the majority of cable trays located

above the suspended ceiling. Spray nozzles, connected to a water piping system, were

installed between or above cable trays to provide coverage for the majority of cable trays

installed above the suspended ceiling. The spray nozzles had 250 degree Fahrenheit

thermal elements with deflectors having a 65 degree conical spray pattern. The inspectors

consulted with the Fire Protection Branch within the Office of Nuclear Reactor Regulation

(NRR) on this issue and NRR concurred that the installed system did not meet the

licensing basis for LaSalle County Station.

The inspectors noted that sprinkler systems activate through plumes from a fire hitting a

ceiling with the resulting ceiling jets activating the nearest sprinkler head. As such,

sprinkler systems provide general area fire suppression and activate relatively quickly in

the event of a fire. In comparison, spray systems are generally designed with open (i.e.,

without thermal elements) spray nozzle heads and use a separate detection system for

8 Enclosure

activation. As such, spray systems are typically used to protect specific components from

fire (through activation of a separate detection system). In comparison, the spray system

installed in Fire Zone 4F3 was a pre-action system, which used closed heads for the spray

nozzles. The detection system for the spray system would cause a valve to open admitting

water to the spray piping. However, individual spray nozzle heads would also have to be

activated through localized heat for any water suppression to be provided. To activate

individual spray nozzles, either the overall hot gas layer temperatures for the area would

have to exceed 250 degrees Fahrenheit or a fire would have to be located in a cable tray

near a spray nozzle. The inspectors concluded that there typically would be considerable

delay in activation of the pre-action spray system installed versus a properly designed

sprinkler system for the area. As such, the inspectors determined that a closed-head spray

system would not provide an equivalent level of protection as a sprinkler system.

Specifically, the installed spray system was less capable than a sprinkler system because a

fire would be permitted to grow to a larger size and cause more damage as a result of

delayed actuation.

During a partial walkdown of the suppression system, the inspectors identified one section

of safety-related cable tray, which did not have spray coverage (cable tray nodes 232C,

232E, and 234E). The inspectors confirmed that the cable tray sections contained cables,

which supported safety-related emergency core cooling systems. The licensee presented

the argument that localized lack of coverage was acceptable because the purpose was to

only control a postulated fire and to prevent its spread to adjacent safety-related areas. The

licensee noted that the NRC had based acceptance of the spray systems for the

cable spreading rooms, in part on, this argument as documented in Section 9.5.1.2 of

NUREG-0519, Supplement 3, Safety Evaluation Report related to the operation of LaSalle

County Station, Units 1 and 2. The inspectors noted that the cable spreading rooms had

overhead sprinkler systems in addition to the spray systems installed for the cable trays.

The argument concerning the purpose being only to control postulated fires to prevent

spread to adjacent areas only applied to specific deviations from NFPA 15-1973, Standard

for Water Spray Fixed Systems for Fire Protection, for the cable spreading room spray

systems and was not applicable to other deficiencies or Fire Zone 4F3. Additionally,

Section 9.5.1.2 of NUREG-0519, Supplement 1, and Section H.3.4.18 of the Fire Protection

Report indicated that the suppression system for Fire Zone 4F3 was for the cables above

the ceiling (as opposed to controlling a postulated fire and preventing its spread to adjacent

safety-related areas).

The licensee entered issues relating to spray coverage into their corrective action system as

AR 00840401, NRC Identified Inspection Findings in Aux Bldg Ceiling, and AR 00855527;

Rotate FP Water Spray Nozzle to Optimize Spray Pattern, dated December 12, 2008. The

licensee entered the issue of the installed spray system not meeting the licensing basis

description of a sprinkler system into their corrective action system as AR 00849044, NRC

Potential Finding; Chemistry Overlab FP System, dated November 21, 2008.

Analysis: The inspectors determined that the failure to install a sprinkler system in Fire Zone

4F3 was contrary to Section H.3.4.18 of the LaSalle County Station Fire Protection Report

and was a performance deficiency.

The finding was determined to be more than minor because the failure to install a sprinkler

system was associated with the Mitigating Systems cornerstone attribute of Protection

Against External Factors (Fire) and affected the cornerstone objective of ensuring capability

9 Enclosure

of systems to respond to initiating events such as fire. Specifically, the installed spray

system was less capable than a sprinkler system because a fire would be permitted to grow

to a larger size and cause more damage as a result of delayed system actuation.

In accordance with IMC 0609, Significance Determination Process, Attachment 0609.04,

Phase 1 - Initial Screening and Characterization of Findings, Table 3b the inspectors

determined the finding degraded the fire protection defense-in-depth strategies. Therefore,

screening under IMC 0609, Appendix F, Fire Protection Significance Determination

Process, was required. The inspectors performed a Phase 2 analysis. The inspectors

determined that the high transient combustibles and hot work frequencies (1.7x10-3 per year

and 6.9x10-4 per year, respectively) from IMC 0609, Appendix F, Attachment 4, Fire Ignition

Source Mapping Information: Fire Frequency, Counting Instructions, Applicable Fire

Severity Characteristics, and Applicable Manual Fire Suppression Curves, were applicable

due to the presence of the normally occupied chemistry laboratory and heat producing

equipment in the area. The inspectors also determined that, though Division I equipment

would be unavailable, at a minimum, the following equipment and capabilities would be

available: high pressure core spray, depressurization capability, one train of low pressure

injection, one train of containment heat removal capability, containment venting capability,

survival of injection path following containment failure, and late depressurization with one

train of injection. Based on review of the Transients worksheet from the Risk-Informed

Inspection Notebook for LaSalle County Station, Units 1 and 2, Revision 2.1a, the

inspectors determined that a conditional core damage probability of 1x10-4 could be credited

due to remaining mitigation capability. For ease of analysis, the inspectors did not credit

any suppression capability. Based on the above information and Step 2.9 of IMC 0609,

Appendix FProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix F" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., the inspectors determined that the finding was of very low safety significance

(i.e., Green) due to remaining mitigating system capability.

The inspectors did not identify a cross-cutting aspect associated with this finding.

Enforcement: 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 (FSAR) 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. Section H.3.4.18, Auxiliary Building Ground

Floor - Fire Zone 4F3, of the LaSalle County Station Fire Protection Report stated that a

pre-action sprinkler system was provided for the cables above the suspended ceiling. The

LaSalle County Station Fire Protection Report listed NFPA 13-1976 as the code of record

for sprinkler systems. Section 3-15.2.1 of NFPA 13-1976 required that listed sprinklers be

used. Section 4-3.2.1 of NFPA 13-1976 specified that deflectors of sprinklers be located

1 to 16 inches below floor decks for beam and girder construction.

Contrary to the above, as of November 21, 2008, the licensee failed to provide a pre-action

sprinkler system for Fire Zone 4F3. Specifically, the suppression system installed in

Fire Zone 4F3 was a spray system and did not meet the requirements for a sprinkler

system as described in NFPA 13-1976. The installed suppression system did not use listed

sprinklers and no sprinklers were within 16 inches of below the floor deck. Because this

violation was of very low safety significance and it was entered into the licensees corrective

action program as AR 00849044, this violation is being treated as an NCV, consistent with

10 Enclosure

Section VI.A.1 of the NRC Enforcement Policy (NCV 05000373/2008007-02;

05000374/2008007-02).

.6 Protection from Damage from Fire Suppression Activities

a. Inspection Scope

For the selected fire areas, the inspectors verified that redundant trains of systems required

for hot shutdown would not be subject to damage from fire suppression activities or from the

rupture or inadvertent operation of fire suppression systems including the effects of flooding.

The inspectors conducted walkdowns of each of the selected fire areas to assess

conditions, such as, the adequacy and condition of floor drains, equipment Elevations, and

spray protection.

b. Findings

No findings of significance were identified.

.7 Alternative Shutdown Capability

a. Inspection Scope

The inspectors reviewed the licensees systems required to achieve alternative safe

shutdown to determine if the licensee had properly identified the components and systems

necessary to achieve and maintain safe shutdown conditions. The inspectors also focused

on the adequacy of the systems to perform reactor pressure control, reactivity control,

reactor coolant makeup, decay heat removal, process monitoring, and support system

functions.

The team conducted selected area walkdowns to determine if operators could reasonably

be expected to perform the alternate safe shutdown procedure actions and that equipment

labeling was consistent with the alternate safe shutdown procedure. The review also looked

at operator training, as well as consistency between the operations shutdown procedures

and any associated administrative controls.

b. Findings

No findings of significance were identified

.8 Circuit Analyses

a. Inspection Scope

The inspectors reviewed the licensees post-fire safe shutdown analysis to verify that the

licensee had identified both required and associated circuits that may impact safe shutdown.

On a sample basis, the inspectors verified that the cables of equipment required achieving

and maintaining hot shutdown conditions, in the event of fire in the selected fire zones, had

been properly identified. In addition, the inspectors verified that these cables had either

been adequately protected from the potentially adverse effects of fire damage, mitigated

with approved manual operator actions, or analyzed to show that fire-induced faults

11 Enclosure

(e.g., hot shorts, open circuits, and shorts to ground) would not prevent safe shutdown. In

order to accomplish this, the inspectors reviewed electrical schematics and cable routing

data for power and control cables associated with each of the selected components.

In addition, on a sample basis, the adequacy of circuit protective coordination for the safe

shutdown systems electrical power and instrumentation circuit protection were evaluated.

Also, on a sample basis, a cable tray that contains both safe shutdown and non-safe

shutdown cables was evaluated for proper circuit protection to ensure that cables are

protected by a proper protective device in order to preclude common enclosure concerns.

b. Findings

No findings of significance were identified.

.9 Communications

a. Inspection Scope

The inspectors reviewed, on a sample bases, the adequacy of the communication system to

support plant personnel in the performance of alternative safe shutdown functions and fire

brigade duties. The inspectors verified that plant telephones, page systems, sound powered

phones, and radios were available for use and maintained in working order. The inspectors

reviewed the electrical power supplies and cable routing for these systems to verify that

either the telephones or the radios would remain functional following a fire.

b. Findings

No findings of significance were identified.

.10 Emergency Lighting

a. Inspection Scope

The inspectors performed a plant walkdown of selected areas in which a sample of operator

actions would be performed in the performance of alternative safe shutdown functions. As

part of the walkdowns, the inspectors focused on the existence of sufficient emergency

lighting for access and egress to areas and for performing necessary equipment operations.

The locations and positioning of the emergency lights were observed during the walkdown

and during review of manual actions implemented for the selected fire areas.

b. Findings

No findings of significance were identified.

.11 Cold Shutdown Repairs

a. Inspection Scope

The inspectors reviewed the licensees procedures to determine whether repairs were

required to achieve cold shutdown and to verify that dedicated repair procedures,

equipment, and material to accomplish those repairs were available onsite. The inspectors

12 Enclosure

also evaluated whether cold shutdown could be achieved within the required time using the

licensee's procedures and repair methods. The inspectors also verified that equipment

necessary to perform cold shutdown repairs was available onsite and properly staged.

b. Findings

No findings of significance were identified.

.12 Compensatory Measures

a. Inspection Scope

The inspectors conducted a review to verify that compensatory measures were in place

for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown

equipment, systems, or features (e.g., detection and suppression systems, and equipment,

passive fire barriers, pumps, valves or electrical devices providing safe shutdown functions

or capabilities). The inspectors also conducted a review on the adequacy of short term

compensatory measures to compensate for a degraded function or feature until appropriate

corrective actions were taken.

b. Findings

No findings of significance were identified.

4. OTHER ACTIVITIES

4OA6 Management Meetings

.1 Exit Meeting Summary

On November 21, 2008, the inspectors presented the inspection results to Mr. D. Rhoades,

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

13 Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

D. Rhoades, Plant Manager

E. Ballou, Mechanical Design Engineer

J. Bashor, Engineering Director

R. Dudley, Operations

W. Hilton, Design Engineering Manager

J. Houston, Regulatory Assurance

K. Ihnen, Nuclear Oversight Manager

S. Marik, Operations Director

J. Miller, Mechanical and Structural Supervisor

T. Simkin, Regulatory Assurance Manager

M. Taylor, Corporate Fire Protection Engineer

J. Vergara, Regulatory Assurance

E. Zacharias, Plant Electrical Systems Supervisor

Nuclear Regulatory Commission

R. Daley, Branch Chief, Division of Reactor Safety

G. Roach, Senior Resident Inspection, LaSalle County Station

LIST OF ITEMS OPENED, CLOSED AND DISCUSSED

Opened

05000373/2008007-01 NCV Unauthorized Transient Combustibles05000374/2008007-01

05000373/2008007-02 NCV Failure to Provide a Sprinkler System for Fire Zone 4F3

05000374/2008007-02

Closed

05000373/2008007-01 NCV Unauthorized Transient Combustibles05000374/2008007-01

05000373/2008007-02 NCV Failure to Provide a Sprinkler System for Fire Zone 4F3

05000374/2008007-02

1 Attachment

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection. Inclusion on this list does

not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that

selected sections of portions of the documents were evaluated as part of the overall inspection

effort. Inclusion of a document on this list does not imply NRC acceptance of the document or

any part of it, unless this is stated in the body of the inspection report.

1R05 Fire Protection Calculations and Analyses (71111.05T)

L-000776; LaSalle Combustible Load for Fire Zone 4F3; Revision 5

L-001726; Hydraulic Analysis to Determine the Adequacy of the Service Water Pumps

to Function as Fire Pumps; Revision 2

L-001947; Safe Shutdown Control Circuit Breaker-Fuse Coordination; Revision 01

L--002771; GL 86-10 Operator Action Evaluation for Fuse Pulling in AEER and Valve

Manipulation in Reactor Building for Post Fire Safe Shutdown; Revision 0

L-003289; LaSalle Fire Detector Smoke Stratification Justification; Revision 0

EC 0000331385; Safe Shutdown Control Circuit Breaker-Fuse Coordination Calculation

Revision; dated December 20, 2001

GE-NE-A1300384-43-01; LaSalle County Station Power Uprate Project, Task 611:

Appendix R Fire Protection [Proprietary]; dated September 1999

Schirmer Engineering Corporation: Automatic Sprinkler System Calculation, LaSalle

County Station; dated January 26, 1984

Corrective Action Documents

AR 00369313; Multiple Spurious Actuations of ADS Valves; dated September 1, 2005

AR 00578440; Replace Smoke Detector with New Style Detector; dated

January 12, 2007

AR 00632819; Fireproofing Removed Requiring Compensatory Actions; dated

May 23, 2007

AR 00637145; 0B Diesel FP Activities; dated June 5, 2007

AR 00659506; Two Different Battery Models Installed in B Diesel Fire Pump; dated

August 10, 2007

AR 00671437; Overlab FP System - Could not Test All Detectors; dated

September 14, 2008

AR 00704946; NOS ID Fire Doors not Inspected Under Proper Surveillance; dated

November 29, 2007

2 Attachment

AR 00704957; NOS ID Fire Door Sealing Device does not Meet Hour Rating; dated

November 29, 2007

AR 00711394; 1FP01C Still Short Cycling; dated December 13, 2007

AR 00716061; Fire Door 284 Door Latch not Operating Properly; dated

December 28, 2007

AR 00747573; Fire Line Pipe Corrosion; dated March 10, 2008

AR 00750853; Fire Doors/Barrier Reclassification; dated March 17, 2008

AR 00761675; 0B Diesel Fire Pump Troubleshooting; dated April 10, 2008

AR 00783879; Local Alarm will not Sound - Building 33; dated June 6 2008

AR 00836266; Declining Trend in Transient Combustibles; dated October 27, 2008

AR 00841673; Transient Combustible Material Extent of Condition Walkdown; dated

November 7, 2008

CR L2001-02263; Potential Spurious Operations During CR or AEER Fire; dated

April 5, 2001

Corrective Action Documents Initiated as a Result of Inspection

AR 00834512; NRC Identified Combustibles During Walkdown with FP Engineer; dated

October 22, 2008

AR 00835086; NRC Identified Chair Not Removed Until Following Morning; dated

October 23, 2008

AR 00837934; NRC TRI: Passport D030 Discrepancy for DFP Pressure SW; dated

October 30, 2008

AR 00839030; NRC Identified Issues - LaSalle Triennial Inspection; dated

October 30, 2008

AR 00840401; NRC Identified Inspection Findings in Aux Bldg Ceiling; dated

November 4, 2008

AR 00840264; FP Report Document Problem - LaSalle Triennial Inspection; dated

November 4, 2008

AR 00840339; NRC Triennial Fire Protection Inspection; dated November 4, 2008

AR 00840381; NRC Identified SLICE (Cable Analysis) Discrepancies; dated

November 4, 2008

AR 00840833; NRC Triennial Inspection-Equip. Number Error on 1E-1-4220AC; dated

November 5, 2008

3 Attachment

AR 00841245; NRC Triennial: ELBP 1LL142E North Side Fixed Lamp Aiming; dated

November 6, 2008

AR 00841304; NRC Triennial Inspection - FPR H.4.6.2 Discrepancy; dated

November 6, 2008

AR 00841326; NRC ID: Transient Combustible Near Vertical Power Riser; dated

November 6, 2008

AR 00841364; NRC FP Triennial Inspection - Calc L-001947 Recommendation; dated

November 6, 2008

AR 00841433; NRC Triennial: FP Related Drawing Deficiencies; dated

November 6, 2008

AR 00841355; NRC Triennial: Smoke from AEER Fire Affecting Operator Actions; dated

November 6, 2008

AR 00841458; NRC Triennial: LOA-FX-101 - Fuse Orientation Description; dated

November 6, 2008

AR 00841490; NRC Triennial FP Inspection Walkdown; dated November 6, 2008

AR 00841494; NRC Triennial FP Inspection Walkdown; dated November 6, 2008

AR 00842109; NRC FP Triennial: DFP Start Sequencing Compliance with NFPA; dated

November 7, 2008

AR 00843614; NRC FP Inspection - FZ 4F3 Hydraulic Calc Retrieval Difficult; dated

November 11, 2008

AR 00846249; NRC Triennial Inspection - Discrepancy on Dwg 1E-2-4601BA; dated

November 17, 2008

AR 00846419; NRC Fire Protection Triennial Inspection; dated November 18, 2008

AR 00846433; 2008 NRC FP Triennial - Drawing Discrepancy 1E-4220AQ; dated

November 18, 2008

AR 00846729; NRC Triennial Inspection-Description of Codes Not Available; dated

November 18, 2008

AR 00846731; NRC Identified SRV Issue During FP Triennial Inspection; dated

November 18, 2008

AR 00846760; NRC Fire Protection Triennial; dated November 18, 2008

AR 00846783; NRC Triennial: Smoke Detectors Affect Any Other Functions; dated

November 18, 2008

AR 00847185; FPR Table H.4-59 and Table H.4-60 Incorrectly List Cable 1NB335 As

Supporting Control Room Recorder 1B21-R884A; dated November 19, 2008

4 Attachment

AR 00847328; NRC Triennial Inspection-Discrepancy on S/D 1E-2-4220CH; dated

November 19, 2008

AR 00847337; NRC Triennial: FP Related Drawing Deficiencies; dated

November 19, 2008

AR 00847578; NRC FP Triennial - The Safe Shutdown Cable Routing Drawings

Incorrectly Show that Cable 1RH360 is Routed in Fire Zone 4E1-1; dated

November 20, 2008

AR 00847709; NRC FP Inspection: AEER Roll-Up Door Evaluation Canceled; dated

November 20, 2008

AR 00848042; NRC FP Triennial - SLICE Fire Zone Data Reference Only; dated

November 21, 2008

AR 00848063; NRC FP Triennial Inspection: FP Spray Nozzle Orifice Size; dated

November 20, 2008

AR 00847728; NRC Identified Sprinkler Heat NFPA Code Deviation; dated

November 20, 2008

AR 00847809; NRC Triennial: LOA-FX-101(201) AEER Validation Order; dated

November 20, 2008

AR 00846788; NRC FP Triennial: DFP Start Sequencing, Timing; dated

November 18, 2008

AR 00849044; NRC Potential Finding, Chemistry Overlab FP System; dated

November 21, 2008

AR 00855527; Rotate FP Water Spray Nozzle to Optimize Spray Pattern; dated

December 12, 2008

Drawings

15; Cable Spreading Rooms Supervised Pre-action Systems; Revision 10

16A; Auxiliary Building Elevation 7490 Cable Spreading Room Details & Section

1E-1-3445; Electrical Installation Auxiliary Building Auxiliary Equipment Room Plan EL.

731-0 Col. 12-15 & J-N; Revision AU

1E-1-3465; Electrical Installation Control Room Plan EL. 768-0 Col. 12-15 & J-N;

Revision Z

1E-1-3663; Cable Pan Routing Aux. Bldg. Plan EL. 7106 Cols 12-15; Revision S

1E-1-3694M, Sheet 1; Safe Shutdown Cable Routing Aux. Bldg. Plan El. 731-0 Cols.

12-15; Revision; A

1E-1-3694M, Sheet 2; Safe Shutdown Cable Routing Schedules for Aux. Bldg. Plan EL.

731-0 Cols. 12-15; Revision; A

5 Attachment

1E-1-3694P, Sheet 1; Safe Shutdown Cable Routing Schedules for Aux. Bldg. Plan EL.

749-0 Cols. 12-15; Revision; A

1E-1-3694P, Sheet 2; Safe Shutdown Cable Routing Schedules for Aux. Bldg. Plan EL.

749-0 Cols. 12-15; Revision; A

1E-1-4018ZE; Loop Schematic Diagram - Containment Monitoring System CM, Part 5;

Revision Q

1E-1-4201AA; Schematic Diagram - Auto Depressurization System NB (B21C) Part 1

1E-1-4201AC; Schematic Diagram - Auto Depressurization System NB (B21C)

Part 3; Revision AA

1E-1-4201AD; Schematic Diagram - Auto Depressurization System NB (B21C)

Part 4; Revision AC

1E-1-4201AE; Schematic Diagram - Auto Depressurization System NB (B21C)

Part 5; Revision V

1E-1-4201AF; Schematic Diagram - Auto Depressurization System NB (B21C) Part 6;

Revision AA

1E-1-4201AG; Schematic Diagram - Auto Depressurization System NB (B21C)

Part 7; Revision

1E-1-4201AJ; Schematic Diagram - Auto Depressurization System NB (B21C) Part 9;

Revision G

1E-1-4201AK; Schematic Diagram - Auto Depressurization System NB (B21C)

Part 10; Revision F

1E-1-4203AK; Schematic Diagram - Main Steam/Nuclear Boiler System NB (B21),

Part 10; Revision Y

1E-1-4214AA; Schematic Diagram - Remote Shutdown System RS Part 1;

Revision K

1E-1-4220BD; Schematic Diagram - Residual Heat Removal System RH (E12) Part 28;

Revision N

1E-1-4220BX; Schematic Diagram - Residual Heat Removal System RH (E12) Part 46;

Revision R

1E-1-4220BY; Schematic Diagram - Residual Heat Removal System RH (E12) Part 47;

Revision K

1E-1-4220CH; Schematic Diagram - Residual Heat Removal System RH (E12) Part 56;

Revision M

1E-1-4379AC; Internal Wiring Diagram - 480V MCC Detail; Revision K

6 Attachment

1E-1-4391AB; Internal/External Wiring Diagram - Reactor Building 480V MCC 136Y-1,

Part 2; Revision W

1E-1-4442AA; Internal/External Wiring Diagram - Automatic Depressurization Channel

A Relay Vertical Board 1H13-P628, Part 1; Revision R

1E-1-4622AB; Internal/External Wiring Diagram - 125VDC Distr. Bus 1B and 125VDC

Dist. Panel 112Y; Revision T

1E-1-4622AC; Internal/External Wiring Diagram - Automatic Depressurization

Channel A Relay Vertical Board 1H13-P628, Part 2; Revision AA

1E-1-4622AD; Internal/External Wiring Diagram - Automatic Depressurization

Channel A Relay Vertical Board 1H13-P628; Revision J

1E-1-4622AF; Internal/External Wiring Diagram - Automatic Depressurization

Channel A Relay Vertical Board 1H13-P628, Part 3; Revision G

1E-1-4624AB; Internal/External Wiring Diagram - Automatic Depressurization

Channel B Relay Vertical Board 1H13-P631; Revision AB

1E-1-4658AH; Internal/External Wiring Diagram - Remote Shutdown Panel

1C61-P001, Part 6; Revision Z

1E-1-4696AB; Internal/External Wiring Diagram - ADS/SRV Valves Aux Relay Vertical

Board Div. 1, Panel 1H13-P644; Revision K

1E-1-4696AC; Internal/External Wiring Diagram - ADS/SRV Valves Aux Relay Vertical

Board Div. 1, Panel 1H13-P644; Revision F

1E-1-4697AB; Internal/External Wiring Diagram - ADS/SRV Valves Aux Relay Vertical

Board Div. 2, Panel 1H13-P645; Revision P

1E-1-4697AC; Internal/External Wiring Diagram - ADS/SRV Valves Aux Relay Vertical

Board Div. 2, Panel 1H13-P645; Revision G

81-78483; Cable Trays over Lab ceiling Unit 1 & 2, EL. 7106 Supervised Pre-action

System; Revision 1, Figure 9.5-1, Sheet 15 of 41; Fire Protection System EL 7490;

Revision 17

Figure 9.5-1; Sheet 17 of 41; Fire Protection System EL 7400; Revision 17

Figure 9.5-1; Sheet 22 of 41; Fire Protection System EL 7106; Revision 17

Supervised Pre-action Systems; Revision 10

7 Attachment

Miscellaneous

LSCS-FPR; LaSalle Station Fire Protection Report- Appendix H.4, Safe Shutdown

Analysis; Revision 3

DBD-LS-E09; LaSalle Units 1 and 2, Electrical Separation, Table 4.4.1-1 Redundant

and Non-Redundant Divisions; Revision 0

DBD-LS-E09; LaSalle Units 1 and 2, Electrical Separation, Table 4.4.1-2 Electrical

Raceway Separation Design Requirements and Design Basis; Revision 0

SLICE Version 7.6; LaSalle Unit 1 Cable Transaction Report (S102); 1986-1999

SLICE Version 7.6; LaSalle Unit 1 Fire Shutdown Cables/Fire Zone Report (S115);

1986-1999

SLICE Version 7.6; LaSalle Unit 1 Fire Zones/Fire Shutdown Cable Report (S116);

1986-1999

SLICE Version 7.6; LaSalle Unit 1 Fire Protection Safe Shutdown Discrepancy List

Report (S143); 1986-1999

SLICE Version 7.6; LaSalle Unit 1 Fire Protection Safe Shutdown Discrepancies -

Unresolved Report (S143); 1986-1999

AR 707263707263 LaSalle Station Triennial Fire Protection Inspection Preparatory Self

Assessment; July/August 2008

AR 576593576593 LaSalle Station Fire Protection Program Audit Report Audit NOSA-LAS-07-

09; dated December 5, 2007

AR 219447-05; LaSalle Station Focus Area Self-Assessment Report; dated June 2005

1C-7-0784-002; Actions Necessary to Address Valve Failures or Spurious Operations;

dated April 2, 1985

CT.5ENG.4, Appendix R Spurious Operation Analysis, Phase 1 Report (AT-144623-01);

Revision 0

Procedures

CC-AA-206; Exelon Nuclear-Fuse Control; Revision 5

LOA-FP-101; Unit 0 Fire Protection System Abnormal; Revision 2

LOA-FP-101; Unit 1 Fire Protection Abnormal; Revision 9

LOA-FX-101; Unit 1 Safe Shutdown with a Loss of Offsite Power and a Fire in the

Control Room or AEER; Revision 13

8 Attachment

LOA-FX-101- Attachment C; Repair of 1E12-F009, RHR Inboard Shutdown Cooling

Valve; Revision 13

LOP-RH-17; Alternate Shutdown Cooling; Revision 25

LOA-SRV-101; Unit 1 Stuck Open Safety Relief Valve; Revision 5

LOS-FP-M4 U1; FP Deluge Valve Lineup 1112018-01

OP-AA-201-009; Control of Combustible Material; Revision 7

OP-MW-201-007; Fire Protection System Impairment Control; Revision 6

Work Orders

980089736 01; Hydro Test all Fire Hoses per TS 4.7.5.4.D or Replace Fire Hose; dated

August 29, 2000

00639790 01; Hydro Test all Fire Hoses per TS 4.7.5.4.D or Replace Fire Hose; dated

November 14, 2005

01044223 01; Annual Inspection of FP Strainer for Cleanliness; dated June 25, 2008

00465471 01; Electrical Fire Penetration Inspection; dated January 28, 2004

960119253 01; Electrical Fire Penetration Inspection; dated August 20, 1997

980074104 01; Electrical Fire Penetration Inspection; dated October 30, 1997

99236634 01; Electrical Fire Penetration Inspection; dated January 31, 2003

112018 01; LOS-FP-M4 U1 Deluge Valve Lineup; dated June 6, 2008

849192 01; LOS-FP-R6 U-0 Cable Trays Over Labs Sprinkler Sys; dated July 13, 2007

952500 01; Overlab Cable Tray Sprinkler Sys Channel Function Test; dated

November 27, 2007

859933 01; U-1 Cable Spreading Room Sprinkler Sys Channel Function Test; dated

January 12, 2007

992888 01; U-1 Cable Spreading Room Sprinkler Sys Chan. Function Test, LES-FP-06;

dated January 11, 2008

9 Attachment

LIST OF ACRONYMS USED

ADAMS Agency Documents Access Management System

AR Action Request

FSAR Final Safety Analysis Report

IMC Inspection Manual Chapter

IP Inspection Procedure

IPEEE Individual Plant Examination of External Events

IR Inspection Report

LLC Limited Liability Corporation

NCV Non-Cited Violation

NFPA National Fire Protection Association

NRC U.S. Nuclear Regulatory Commission

PARS Publicly Available Records System

SDP Significance Determination Process

10 Attachment