IR 05000373/2003007: Difference between revisions

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=Text=
=Text=
{{#Wiki_filter:ber 4, 2003
{{#Wiki_filter:September 4, 2003


==SUBJECT:==
==SUBJECT:==
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REGION III==
REGION III==
Docket No: 50-373; 50-374 License No: NPF-11; NPF-18 Report No: 50-373/03-07; 50-374/03-07 Licensee: Exelon Nuclear Generation Company Facility: LaSalle County Station, Units 1 and 2 Location: 2601 N. 21st Road Marseilles, IL 61341 Dates: July 21 through August 8, 2003 Inspectors: G. Wright, Project Engineer - Team Lead D. Kimble, Senior Resident Inspector R. Winter, Electrical Engineering Inspector Approved by: Bruce Burgess, Chief Branch 2 Division of Reactor Projects Enclosure
Docket No:
50-373; 50-374 License No:
NPF-11; NPF-18 Report No:
50-373/03-07; 50-374/03-07 Licensee:
Exelon Nuclear Generation Company Facility:
LaSalle County Station, Units 1 and 2 Location:
2601 N. 21st Road Marseilles, IL 61341 Dates:
July 21 through August 8, 2003 Inspectors:
G. Wright, Project Engineer - Team Lead D. Kimble, Senior Resident Inspector R. Winter, Electrical Engineering Inspector Approved by:
Bruce Burgess, Chief Branch 2 Division of Reactor Projects
 
Enclosure


=SUMMARY OF FINDINGS=
=SUMMARY OF FINDINGS=
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Identification and Resolution of Problems In general, the plant identified issues and entered them into the corrective action process at an appropriate level. Nuclear Oversight (NOS) assessment reports identified issues for the plant to resolve, including issues with corrective action follow through. The majority of issues reviewed were properly categorized and evaluated although some evaluations were narrowly focused, particularly for cause evaluations. Most corrective actions reviewed were appropriately implemented and appeared to have been effective. While no findings were identified during the inspection, the team developed a number of observations including:
Identification and Resolution of Problems In general, the plant identified issues and entered them into the corrective action process at an appropriate level. Nuclear Oversight (NOS) assessment reports identified issues for the plant to resolve, including issues with corrective action follow through. The majority of issues reviewed were properly categorized and evaluated although some evaluations were narrowly focused, particularly for cause evaluations. Most corrective actions reviewed were appropriately implemented and appeared to have been effective. While no findings were identified during the inspection, the team developed a number of observations including:
1. A more thorough assessment of issues associated with ineffective corrective action(s) is an aspect of the corrective action process that could be strengthened to reduce repeat issues at the plant.
1.
 
A more thorough assessment of issues associated with ineffective corrective action(s) is an aspect of the corrective action process that could be strengthened to reduce repeat issues at the plant.
 
2.


2. Additional attention to thoroughness and quality of documentation in program descriptions, procedures, condition reports, and cause analyses would enhance the corrective action process by ensuring consistency in program application, completeness of reviews, and preservation of the historical record without reliance on institutional knowledge.
Additional attention to thoroughness and quality of documentation in program descriptions, procedures, condition reports, and cause analyses would enhance the corrective action process by ensuring consistency in program application, completeness of reviews, and preservation of the historical record without reliance on institutional knowledge.


=REPORT DETAILS=
=REPORT DETAILS=
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==OTHER ACTIVITIES (OA)==
==OTHER ACTIVITIES (OA)==
{{a|4OA2}}
{{a|4OA2}}
==4OA2 Problem Identification and Resolution==
==4OA2 Problem Identification and Resolution==
===.1 Effectiveness of Problem Identification===
===.1 Effectiveness of Problem Identification===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed NRC inspection report findings issued over the last 2 years, selected plant corrective action documents, Nuclear Oversight (NOS) assessments, operating experience reports and trend assessments to determine if problems were being identified at the proper threshold and entered into the corrective action process.
The inspectors reviewed NRC inspection report findings issued over the last 2 years, selected plant corrective action documents, Nuclear Oversight (NOS) assessments, operating experience reports and trend assessments to determine if problems were being identified at the proper threshold and entered into the corrective action process.
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The inspectors also conducted focused plant walkdowns of one emergency diesel generator and the diesel generator ventilation system to ensure that equipment problems were entered into the corrective action system. The documents used during the review are listed in Attachment 1.
The inspectors also conducted focused plant walkdowns of one emergency diesel generator and the diesel generator ventilation system to ensure that equipment problems were entered into the corrective action system. The documents used during the review are listed in Attachment 1.


b. Issues In general, the plant identified issues and entered them into the corrective action process at an appropriate level. NOS assessment reports identified issues for the plant to resolve, including timely entry of deficiencies into the corrective action program (CAP). The licensee appropriately used the CAP to document instances where previous corrective actions were ineffective or inappropriate; however, in most instances, the need to identify and address why the initial corrective actions were not effective was not recognized. The teams review also noted the following items:
b.
 
Issues In general, the plant identified issues and entered them into the corrective action process at an appropriate level. NOS assessment reports identified issues for the plant to resolve, including timely entry of deficiencies into the corrective action program (CAP). The licensee appropriately used the CAP to document instances where previous corrective actions were ineffective or inappropriate; however, in most instances, the need to identify and address why the initial corrective actions were not effective was not recognized. The teams review also noted the following items:
* The team identified a minor error within procedure LS-AA-125, Corrective Action Program Procedure, which appeared to have occurred because of a lack of attention to detail. A Condition Report (CR) was issued to correct this condition.
* The team identified a minor error within procedure LS-AA-125, Corrective Action Program Procedure, which appeared to have occurred because of a lack of attention to detail. A Condition Report (CR) was issued to correct this condition.
* The team identified minor differences in cause codes defined in procedure LS-AA-125 and the PASSPORT software used to track corrective action documentation. A CR was issued to correct this condition.
* The team identified minor differences in cause codes defined in procedure LS-AA-125 and the PASSPORT software used to track corrective action documentation. A CR was issued to correct this condition.
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===.2. b.3 for additional information on operating experience.===
===.2. b.3 for additional information on operating experience.===
b.3 Nuclear Oversight The inspectors reviewed a sample of NOS assessment reports from the past 2 years and determined that the NOS staff, in general, was effectively identifying plant performance issues including issues with implementation of the CAP.
b.3 Nuclear Oversight The inspectors reviewed a sample of NOS assessment reports from the past 2 years and determined that the NOS staff, in general, was effectively identifying plant performance issues including issues with implementation of the CAP.


===.2 Prioritization and Evaluation of Issues===
===.2 Prioritization and Evaluation of Issues===
====a. Inspection Scope====
====a. Inspection Scope====
The team reviewed inspection reports and corrective action documents to verify that identified issues were appropriately characterized and entered into the CAP.
The team reviewed inspection reports and corrective action documents to verify that identified issues were appropriately characterized and entered into the CAP.
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Information reviewed by the team dated back to the previous problem identification and resolution inspection conducted in September 2001 (NRC IR 50-373/01-16; 50-374/01-16).
Information reviewed by the team dated back to the previous problem identification and resolution inspection conducted in September 2001 (NRC IR 50-373/01-16; 50-374/01-16).


b. Issues The team verified that the issues reviewed were properly categorized and evaluated.
b.
 
Issues The team verified that the issues reviewed were properly categorized and evaluated.


The team did, however, have several observations regarding the licensees trending program and the quality of its documentation. Details of the teams observations are described in the following subsections.
The team did, however, have several observations regarding the licensees trending program and the quality of its documentation. Details of the teams observations are described in the following subsections.
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===.3 Effectiveness of Corrective Action===
===.3 Effectiveness of Corrective Action===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed past inspection results, selected CRs, root cause reports and common cause evaluations to verify that corrective actions, commensurate with the safety significance of the issues, were specified and implemented in a timely manner.
The inspectors reviewed past inspection results, selected CRs, root cause reports and common cause evaluations to verify that corrective actions, commensurate with the safety significance of the issues, were specified and implemented in a timely manner.
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The inspectors evaluated the effectiveness of corrective actions. The inspectors also reviewed the licensees corrective actions for Non-Cited Violations (NCVs) documented in NRC inspections in the past 2 years. The inspectors conducted a walkdown of one emergency diesel generator and the diesel generator ventilation system to assess the material condition of the system and verify that the licensee appropriately identified degraded conditions within the corrective action program.
The inspectors evaluated the effectiveness of corrective actions. The inspectors also reviewed the licensees corrective actions for Non-Cited Violations (NCVs) documented in NRC inspections in the past 2 years. The inspectors conducted a walkdown of one emergency diesel generator and the diesel generator ventilation system to assess the material condition of the system and verify that the licensee appropriately identified degraded conditions within the corrective action program.


b. Issues In general, the licensees corrective action for the sample reviewed were appropriate and appeared to have been effective. The team noted that the licensee generated CRs when they identified a corrective action which was either inadequate or inappropriate.
b.
 
Issues In general, the licensees corrective action for the sample reviewed were appropriate and appeared to have been effective. The team noted that the licensee generated CRs when they identified a corrective action which was either inadequate or inappropriate.


b.1 Observations on the Effectiveness of Corrective Actions The inspectors had several observations regarding corrective actions that were not fully implemented, not fully effective in correcting the identified issue, or were narrowly focused. These observations are described below.
b.1 Observations on the Effectiveness of Corrective Actions The inspectors had several observations regarding corrective actions that were not fully implemented, not fully effective in correcting the identified issue, or were narrowly focused. These observations are described below.
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===.4 Practice of Closing CRs to Work Requests or other CRs===
===.4 Practice of Closing CRs to Work Requests or other CRs===
====a. Inspection Scope====
====a. Inspection Scope====
The inspection team reviewed condition reports which had been closed to work requests or other condition reports to assess whether the original issue was appropriately addressed in the follow-on document.
The inspection team reviewed condition reports which had been closed to work requests or other condition reports to assess whether the original issue was appropriately addressed in the follow-on document.


b. Issues The team verified that the issues addressed in the initial CR were appropriately addressed in subsequent work requests or CRs.
b.
 
Issues The team verified that the issues addressed in the initial CR were appropriately addressed in subsequent work requests or CRs.


===.5 Assessment of Safety-Conscious Work Environment===
===.5 Assessment of Safety-Conscious Work Environment===
====a. Inspection Scope====
====a. Inspection Scope====
The inspectors conducted interviews with plant staff to assess whether there were impediments to the establishment of a safety conscious work environment. During these interviews, the inspectors used Appendix 1 to Inspection Procedure 71152, Suggested Questions for Use in Discussions with Licensee Individuals Concerning PI&R Issues, as a guide to gather information and develop insights. The inspectors also discussed the implementation of the Employee Concerns Program (ECP) and selected concerns with the plants ECP Coordinators. Additional discussions with the ECP Coordinators centered on integration of the ECP and CAP programs.
The inspectors conducted interviews with plant staff to assess whether there were impediments to the establishment of a safety conscious work environment. During these interviews, the inspectors used Appendix 1 to Inspection Procedure 71152, Suggested Questions for Use in Discussions with Licensee Individuals Concerning PI&R Issues, as a guide to gather information and develop insights. The inspectors also discussed the implementation of the Employee Concerns Program (ECP) and selected concerns with the plants ECP Coordinators. Additional discussions with the ECP Coordinators centered on integration of the ECP and CAP programs.


b. Issues Plant staff interviewed did not express any concerns regarding the safety conscious work environment. The staff was aware of and generally familiar with the corrective action program and other plant processes including the Employee Concerns Program through which concerns could be raised. Further, a review of the types of issues in the ECP indicated that site personnel were appropriately using the corrective action and employee concerns programs to address their concerns. Based on interviews, the ECP Coordinators were appropriately focused on ensuring all site individuals were aware of the program, reviewing individual concerns, and integrating where appropriate the ECP and CAP programs to resolve concerns.
b.
 
Issues Plant staff interviewed did not express any concerns regarding the safety conscious work environment. The staff was aware of and generally familiar with the corrective action program and other plant processes including the Employee Concerns Program through which concerns could be raised. Further, a review of the types of issues in the ECP indicated that site personnel were appropriately using the corrective action and employee concerns programs to address their concerns. Based on interviews, the ECP Coordinators were appropriately focused on ensuring all site individuals were aware of the program, reviewing individual concerns, and integrating where appropriate the ECP and CAP programs to resolve concerns.


{{a|4OA6}}
{{a|4OA6}}
==4OA6 Management Meetings==
==4OA6 Management Meetings==
 
===.1===
===.1 Exit Meeting Summary===
===Exit Meeting Summary===
 
The inspectors presented the inspection results to Ms. Susan Landahl and other members of licensee management in an exit meeting on August 8, 2003. Ms. Landahl acknowledged the findings presented and indicated that no proprietary information was provided to the inspectors.
The inspectors presented the inspection results to Ms. Susan Landahl and other members of licensee management in an exit meeting on August 8, 2003. Ms. Landahl acknowledged the findings presented and indicated that no proprietary information was provided to the inspectors.


PARTIAL LIST OF PERSONS CONTACTED Licensee D. Barrett         LaSalle NO - Employee Concerns J. Barchello       Security J. Beardon         Operations Corrective Action Program Coordinator (CAPCo)
PARTIAL LIST OF PERSONS CONTACTED Licensee D. Barrett LaSalle NO - Employee Concerns J. Barchello Security J. Beardon Operations Corrective Action Program Coordinator (CAPCo)
R. Bellettini     Corrective Action Program Coordinator A. Byers           Radiation Protection CAPCo B. Carter         Nuclear Oversight B. Cockrel         Diesel Generator System Engineer D. Czufin         Engineering Director C. Dieckmann       Training Director L. Kofoid-Durdan   Chemistry CAPCo D. Enright         Operation Services Manager S. Fatora         Chemistry Manager A. Ferko           LaSalle Nuclear Oversight (NO) Manager M. Hayworth       LaSalle NO - Employee Concerns P. Holland         Regulatory Assurance G. Kaegi           Regulatory Assurance Manager S. Landahl         Plant Manager P. Manning         Engineering CAPCo B. McConnaughay   Work Control M. McDowell       Assistant Plant Manager M. Murskyj         Electrical Design Engineering Supervisor M. Phalen         Radiation Protection Superintendent M. Poland         Maintenance CAPCo G. Randle         Maintenance Director S. Shields         Operating Experience Coordinator B. Werder         Engineering J. Wieging         Electrical Design Engineering Supervisor G. Wilhelmsen     Engineering Balance of Plant Systems Manager M. Williams       BOP System Engineer C. Wilson         LaSalle Security Manager ITEMS OPENED, CLOSED, AND DISCUSSED Items Opened: None Items Closed: None LIST OF ACRONYMS AR   Action Request CAP Corrective Action Program CAQ Condition Adverse to Quality CR   Condition Report ECCS Emergency Core Cooling System ECP Employee Concerns Program LER Licensee Event Report MRC Management Review Committee NCV Non-cited Violation NOS Nuclear Oversight NRC Nuclear Regulatory Commission OPEX Operating Experience PI&R Problem Identification and Resolution SCAQ Significant Condition Adverse to Quality LIST OF  
R. Bellettini Corrective Action Program Coordinator A. Byers Radiation Protection CAPCo B. Carter Nuclear Oversight B. Cockrel Diesel Generator System Engineer D. Czufin Engineering Director C. Dieckmann Training Director L. Kofoid-Durdan Chemistry CAPCo D. Enright Operation Services Manager S. Fatora Chemistry Manager A. Ferko LaSalle Nuclear Oversight (NO) Manager M. Hayworth LaSalle NO - Employee Concerns P. Holland Regulatory Assurance G. Kaegi Regulatory Assurance Manager S. Landahl Plant Manager P. Manning Engineering CAPCo B. McConnaughay Work Control M. McDowell Assistant Plant Manager M. Murskyj Electrical Design Engineering Supervisor M. Phalen Radiation Protection Superintendent M. Poland Maintenance CAPCo G. Randle Maintenance Director S. Shields Operating Experience Coordinator B. Werder Engineering J. Wieging Electrical Design Engineering Supervisor G. Wilhelmsen Engineering Balance of Plant Systems Manager M. Williams BOP System Engineer C. Wilson LaSalle Security Manager ITEMS OPENED, CLOSED, AND DISCUSSED Items Opened: None Items Closed: None LIST OF ACRONYMS AR Action Request CAP Corrective Action Program CAQ Condition Adverse to Quality CR Condition Report ECCS Emergency Core Cooling System ECP Employee Concerns Program LER Licensee Event Report MRC Management Review Committee NCV Non-cited Violation NOS Nuclear Oversight NRC Nuclear Regulatory Commission OPEX Operating Experience PI&R Problem Identification and Resolution SCAQ Significant Condition Adverse to Quality LIST OF  


=DOCUMENTS REVIEWED=
=DOCUMENTS REVIEWED=
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4OA2 Identification and Resolution of Problems
4OA2 Identification and Resolution of Problems
Plant Procedures and Audits
Plant Procedures and Audits
EI-AA-101             Employee Concerns Program                                   Rev. 2
EI-AA-101
LS-AA-21               Nuclear Oversight Audit Process Description                 Rev. 0
Employee Concerns Program
LS-AA-115             Operating Experience Procedure                             Rev. 1
Rev. 2
LS-AA-125             Corrective Action Program (CAP) Procedure                   Rev. 5
LS-AA-21
LS-AA-125-1001         Root Cause Analysis Manual                                 Rev. 3
Nuclear Oversight Audit Process Description
LS-AA-125-1002         Common Cause Analysis Manual                               Rev. 2
Rev. 0
LS-AA-125-1003         Apparent Cause Evaluation Manual                           Rev. 2
LS-AA-115
LS-AA-125-1004         Effectiveness Review Manual                                 Rev. 1
Operating Experience Procedure
LS-AA-125-1005         Coding and Trending Manual                                 Rev. 3
Rev. 1
LS-AA-125-1006         CAP Process Expectations Manual                             Rev. 3
LS-AA-125
LS-AA-126             Self-Assessment Program                                     Rev. 2
Corrective Action Program (CAP) Procedure
LS-AA-126-1001         Focused Area Self-Assessments                               Rev. 1
Rev. 5
NO-AA-200-001         Nuclear Oversight Continuous Assessment                     Rev. 2
LS-AA-125-1001
Root Cause Analysis Manual
Rev. 3
LS-AA-125-1002
Common Cause Analysis Manual
Rev. 2
LS-AA-125-1003
Apparent Cause Evaluation Manual
Rev. 2
LS-AA-125-1004
Effectiveness Review Manual
Rev. 1
LS-AA-125-1005
Coding and Trending Manual
Rev. 3
LS-AA-125-1006
CAP Process Expectations Manual
Rev. 3
LS-AA-126
Self-Assessment Program
Rev. 2
LS-AA-126-1001
Focused Area Self-Assessments
Rev. 1
NO-AA-200-001
Nuclear Oversight Continuous Assessment
Procedure
Procedure
NOA-LS-03-2Q           Nuclear Oversight Quarterly Report LaSalle                 07/23/03
Rev. 2
NOA-LS-03-2Q
Nuclear Oversight Quarterly Report LaSalle
County Station April-June 2003
County Station April-June 2003
NOSA-LAS-03-03         NOS Security Audit Report                                 04/04/03
07/23/03
NOA-LS-01-3Q           Nuclear Oversight Continuous Assessment                   10/25/01
NOSA-LAS-03-03
NOS Security Audit Report
04/04/03
NOA-LS-01-3Q
Nuclear Oversight Continuous Assessment
Report
Report
NOA-LS-02-1Q           Nuclear Oversight Continuous Assessment                   04/30/02
10/25/01
NOA-LS-02-1Q
Nuclear Oversight Continuous Assessment
Report
Report
NOA-LS-02-1Q           Nuclear Oversight Continuous Assessment                   01/29/03
04/30/02
NOA-LS-02-1Q
Nuclear Oversight Continuous Assessment
Report
Report
Attachment
01/29/03
 
Condition Reports Reviewed During LaSalle County Station PI&R Inspection:
Condition Reports Reviewed During LaSalle County Station PI&R Inspection:
CR/AR #                                     Title                             Date
CR/AR #
00001119       Perform an effectiveness review in accordance with             11/11/99
Title
Date
00001119
Perform an effectiveness review in accordance with
NSWP-A-16 to the implemented corrective actions resulting
NSWP-A-16 to the implemented corrective actions resulting
from LER 97-043.
from LER 97-043.
00001149       Testing of Removed/Damaged rupture disc assembly               03/07/00
11/11/99
L2001- 05688   Potential for Non-Conservative Steam Carryover Fraction in     10/03/01
00001149
Testing of Removed/Damaged rupture disc assembly
03/07/00
L2001- 05688
Potential for Non-Conservative Steam Carryover Fraction in
Computer Heat Balance Calculation.
Computer Heat Balance Calculation.
L2001-06182   Locked high rad door #208 found open                           11/01/01
10/03/01
L2001-05717   NRC identified: Procedure Adherence with AD-AA-106 CCA         10/02/01
L2001-06182
Locked high rad door #208 found open
11/01/01
L2001-05717
NRC identified: Procedure Adherence with AD-AA-106 CCA
condition report identification
condition report identification
L2001-03138   U-2 Scram generated High Rad Area.                             05/27/01
10/02/01
L2001-03153   Uncoupled Control Rod During Unit 2 Startup                   05/29/01
L2001-03138
L2001-05949   Untimely Station Response                                     10/19/01
U-2 Scram generated High Rad Area.
00002477       Perform an Effectiveness review of the corrective actions     11/30/99
05/27/01
00002503       Perform EFF review of corrective action #4, to perform torque 12/03/99
L2001-03153
Uncoupled Control Rod During Unit 2 Startup
05/29/01
L2001-05949
Untimely Station Response
10/19/01
00002477
Perform an Effectiveness review of the corrective actions
11/30/99
00002503
Perform EFF review of corrective action #4, to perform torque
checks
checks
00030864       Intermediate Hot Spot discovered on the Unit 2 east MPT       06/28/00
2/03/99
00030864
Intermediate Hot Spot discovered on the Unit 2 east MPT
during Thermogoraphy
during Thermogoraphy
00076848       Increase In U-1 Offgas Pretreatment Radiation                 09/25/01
06/28/00
00078266       NRC ident: RCR risk analyses not quantitative.                 10/09/01
00076848
00082155       Testing Required For 2A DG Governor Replacement               11/08/01
Increase In U-1 Offgas Pretreatment Radiation
00085020       Ineffective Perimeter Zone                                     12/04/01
09/25/01
00085280       2A DG exhaust Temps >200 deg delta T during LOS-DG-M2         12/05/01
00078266
00086988       NRC Identified, ineffective corrective actions from scram     12/14/01
NRC ident: RCR risk analyses not quantitative.
00088342       NRC Id - Human Performance Related Error Trend                 12/28/01
10/09/01
00082155
Testing Required For 2A DG Governor Replacement
11/08/01
00085020
Ineffective Perimeter Zone
2/04/01
00085280
2A DG exhaust Temps >200 deg delta T during LOS-DG-M2
2/05/01
00086988
NRC Identified, ineffective corrective actions from scram
2/14/01
00088342
NRC Id - Human Performance Related Error Trend
Identification
Identification
00088688       Potential NCV for unlocked High Rad door                       12/31/01
2/28/01
00089048       2A DG Cylinder Exhaust Temperatures Erratic                   01/02/02
00088688
Attachment
Potential NCV for unlocked High Rad door
00089355 LOS-DG-Q3 Could not be performed for 2B DG A Air         01/07/02
2/31/01
00089048
2A DG Cylinder Exhaust Temperatures Erratic
01/02/02
 
00089355
LOS-DG-Q3 Could not be performed for 2B DG A Air
Compressor
Compressor
00090734 Improper wiring determ in panels 1FW06JA and 1FW06JB       01/14/02
01/07/02
00091429 Unacceptable through bolt location                         01/19/02
00090734
00091988 Fuel moves stopped at step 91 of L1C10 Axis shuffle         01/23/02
Improper wiring determ in panels 1FW06JA and 1FW06JB
00092014 Fuel Handling Error during Shuffle 2                       01/23/02
01/14/02
00092638 2A DG A Air Compressor Interstage Relief lifting           01/28/02
00091429
00092542 1E22-F024, HPCS Pump Discharge Check Failed Acceptance     01/26/02
Unacceptable through bolt location
01/19/02
00091988
Fuel moves stopped at step 91 of L1C10 Axis shuffle
01/23/02
00092014
Fuel Handling Error during Shuffle 2
01/23/02
00092638
2A DG A Air Compressor Interstage Relief lifting
01/28/02
00092542
1E22-F024, HPCS Pump Discharge Check Failed Acceptance
Criteria
Criteria
00092596 Unusual Flow Noise During HPCS Pp Run                       01/27/02
01/26/02
00093177 2A DG 'A' Compressor Relief lifting While Running           01/30/02
00092596
00094268 Unexpected temperatures observed on 1TE-VP115               02/07/02
Unusual Flow Noise During HPCS Pp Run
00094589 2B D/G A Air Compressor Tripping Breaker
01/27/02
00095253 Potential Bus duct Fire seal deficiencies Discovered by NRC 02/14/02
00093177
00097020 Off-pretreat purge valve not opening                       02/27/02
2A DG 'A' Compressor Relief lifting While Running
00099302 Crew Critique for EMD Crew ECM                             03/15/02
01/30/02
00099679 Unit 2 HPCS Pump IST Adverse Trend                         03/18/02
00094268
00100428 Adverse Trend on Past Due PMs in Maintenance               06/03/02
Unexpected temperatures observed on 1TE-VP115
00104619 NOS IDd, RP: Ineffective Corrective Actions for CR 90284   04/20/02
2/07/02
00105133 CRD rebuild rooms continue to challenge RP and station     04/24/02
00094589
00106428 Adverse Trend on Backlog of Past Due PMs in Maintenance     05/02/02
2B D/G A Air Compressor Tripping Breaker
00108670 U-1 B RHR pump seal leak causing contamination             05/18/02
00095253
00108841 Workers continue to leave scrubs in locker rooms           05/20/02
Potential Bus duct Fire seal deficiencies Discovered by NRC
00109626 MSIV A Limit Switch Temperature exceeds 175 Degrees         5/28/02
2/14/02
00110168 Issues Identified During 2B DG Operability Run             05/31/02
00097020
00114125 1A DG Cooling Water Flow Adjustment Reqd During           07/02/02
Off-pretreat purge valve not opening
2/27/02
00099302
Crew Critique for EMD Crew ECM
03/15/02
00099679
Unit 2 HPCS Pump IST Adverse Trend
03/18/02
00100428
Adverse Trend on Past Due PMs in Maintenance
06/03/02
00104619
NOS IDd, RP: Ineffective Corrective Actions for CR 90284
04/20/02
00105133
CRD rebuild rooms continue to challenge RP and station
04/24/02
00106428
Adverse Trend on Backlog of Past Due PMs in Maintenance
05/02/02
00108670
U-1 B RHR pump seal leak causing contamination
05/18/02
00108841
Workers continue to leave scrubs in locker rooms
05/20/02
00109626
MSIV A Limit Switch Temperature exceeds 175 Degrees
5/28/02
00110168
Issues Identified During 2B DG Operability Run
05/31/02
00114125
1A DG Cooling Water Flow Adjustment Reqd During
LOS-DG-Q2
LOS-DG-Q2
00114397 New Quincy Compressors Have Incorrect Hydraulic Unloader   07/03/02
07/02/02
00114397
New Quincy Compressors Have Incorrect Hydraulic Unloader
Asm
Asm
00116251 0DG B Air Start Compressor Discharge Relief Lifting         07/19/02
07/03/02
Attachment
00116251
00116992 Persistent recontamination of 2A RHR room                   07/25/02
0DG B Air Start Compressor Discharge Relief Lifting
00117431 Safety Concern: CO2 Monitor INOP at Lake Screen House       07/30/02
07/19/02
00117569 0DG B Air Start Compressor Discharge Relief Lifting         07/30/02
 
00118101 0DG "A" Compressor Relief Valve Stuck Open                   08/04/02
00116992
00119063 Tech Spec SR 3.8.1.6 not tracked/completed                   10/19/02
Persistent recontamination of 2A RHR room
00120845 Inadequate Closure of a CAPR                                 03/20/02
07/25/02
00121102 Ineffective CAPRs IDd during EFR                           08/29/02
00117431
00121634 Relief Valve 0DG022 B Lifting During Compressor Operation;   09/04/02
Safety Concern: CO2 Monitor INOP at Lake Screen House
00121822 Diesel Gen Air Cmpr "A" Relief Vlv Lifting                   09/06/02
07/30/02
00124828 NRC 2002 SSDI Identified - DG Air Flow Regulator Calibration 09/27/02
00117569
00125571 NOS Idd: (ENG) Potential Adverse trend in Eng. Clock Resets 10/02/02
0DG B Air Start Compressor Discharge Relief Lifting
00127728 2B Voltage Regulator Very Erratic                           10/16/02
07/30/02
00128981 0" Diesel Generator Cooler Outlet Throttle Valve Drifted   10/25/02
00118101
00131093 GE Part 21 TIP System Ball and Shear Valve Radiation Spec   10/08/02
0DG "A" Compressor Relief Valve Stuck Open
00131665 TIP system Ball and Shear Valve Radiation Specification     11/14/02
08/04/02
00134097 Safeguards Drawing found in AEs uncontrolled file           12/04/02
00119063
00134417 Safeguards Drawing found in AEs uncontrolled file           12/06/02
Tech Spec SR 3.8.1.6 not tracked/completed
00140501 NOS Idd: (ENG) Decline in Engineering Performance for 02-   01/22/03
10/19/02
00120845
Inadequate Closure of a CAPR
03/20/02
00121102
Ineffective CAPRs IDd during EFR
08/29/02
00121634
Relief Valve 0DG022 B Lifting During Compressor Operation;
09/04/02
00121822
Diesel Gen Air Cmpr "A" Relief Vlv Lifting
09/06/02
00124828
NRC 2002 SSDI Identified - DG Air Flow Regulator Calibration
09/27/02
00125571
NOS Idd: (ENG) Potential Adverse trend in Eng. Clock Resets
10/02/02
00127728
2B Voltage Regulator Very Erratic
10/16/02
00128981
0" Diesel Generator Cooler Outlet Throttle Valve Drifted
10/25/02
00131093
GE Part 21 TIP System Ball and Shear Valve Radiation Spec
10/08/02
00131665
TIP system Ball and Shear Valve Radiation Specification
11/14/02
00134097
Safeguards Drawing found in AEs uncontrolled file
2/04/02
00134417
Safeguards Drawing found in AEs uncontrolled file
2/06/02
00140501
NOS Idd: (ENG) Decline in Engineering Performance for 02-
4Q
4Q
00142758 Adverse Trend on Backlog of Non-Outage Maintenance PMs       03/04/03
01/22/03
00142779 Incorrect wiring termination for EC 331396 U2 SLMS           02/03/03
00142758
00142811 Adverse Trend on Backlog of Non-Outage PMs                   020/4/03
Adverse Trend on Backlog of Non-Outage Maintenance PMs
00142933 NOS Identified undersized welds                             020/4/03
03/04/03
00143002 B DWFDS sump pump tripped on thermals                       02/05/03
00142779
00143006 2B33-015B fails leak testing                                 020/4/03
Incorrect wiring termination for EC 331396 U2 SLMS
00143076 Repeated trips of the RMCS system with no rod motion         02/05/03
2/03/03
00143130 2E51-F068 valve failed LLRT                                 02/05/03
00142811
00143131 2MS01-2888S missing locking screws                           02/05/03
Adverse Trend on Backlog of Non-Outage PMs
00143169 2E12-F050A fails high pressure water leak rate test         02/05/03
20/4/03
Attachment
00142933
00143175 Incorrect sample tubing routing for EC 331396, SLMS         02/06/03
NOS Identified undersized welds
00143367 Discrepancies on snubbers 2MS01-2877S and 2MS01-2888S       02/06/03
20/4/03
00143658 Incomplete termination of ground on 2FE-RF021 for EC 51151   02/08/03
00143002
00143876 Effectiveness Review Reveals CAPRs not closed as written     02/10/03
B DWFDS sump pump tripped on thermals
00143954 2E51-F008, 63,76,357 LLRT failure in L2R09                   01/26/03
2/05/03
00144084 Safeguards Drawing for Work Package                         02/11/03
00143006
00144297 Water on Undervessel Sump Cover mat Routed to DWEDS         02/12/03
2B33-015B fails leak testing
00144336 NOS IDd inadequate Closure of Root Cause Corrective Action 02/12/03
20/4/03
00144487 Observed leakage RBCCW line to seal cooler                   02/13/03
00143076
00144683 Pipe support M01-NB-16-2402X found out of tolerance         02/14/03
Repeated trips of the RMCS system with no rod motion
00144744 2E51-F063 valve failed LLRT                                 02/15/03
2/05/03
00144744 2E51-F063 valve failed LLRT                                 02/14/03
00143130
00144778 2B TDRFP Woodward hydraulic piping bent                     02/11/03
2E51-F068 valve failed LLRT
00144839 2FW08JA system 1 pressure at 220 instead of 260-280 psig. 02/17/03
2/05/03
00145072 Drains continue to challenge contamination control           02/17/03
00143131
00145074 Strainer leak contaminates 710 for second time in three days 02/18/03
2MS01-2888S missing locking screws
00145338 Inappropriate Style matting utilized under vessel sump area 02/16/03
2/05/03
00146687 Contamination spread in 1A RHR 673" room                     02/27/03
00143169
00147370 ACE (RP) Rejected by MRC                                     030/4/03
2E12-F050A fails high pressure water leak rate test
00151231 Actions in Self Assessment Determined to be ineffective     03/28/03
2/05/03
00153681 Gland Steam Seal Evap low Level Alarm                       04/13/03
 
00153686 SSE low level condition                                     04/12/03
00143175
00155426 0 DG Room exhaust damper is stuck open                       04/23/03
Incorrect sample tubing routing for EC 331396, SLMS
00155441 0 Diesel Generator Partial CO2 Actuation                     04/23/03
2/06/03
00156861 1E12-F068a has dual indication when closed                   05/01/03
00143367
00157037 1E12-F068A did not fully close                               050/2/03
Discrepancies on snubbers 2MS01-2877S and 2MS01-2888S
00159489 Discovery of an unposted neutron area                       05/19/03
2/06/03
00162229 Significant RP resource concern by RPT                       06/06/03
00143658
00165440 Potential Adverse Trend Identified - RP Procedure Adherence 06/29/03
Incomplete termination of ground on 2FE-RF021 for EC 51151
Attachment
2/08/03
00167023       2A RHR pump run contaminates entire room                     07/08/03
00143876
00167691       Inadequate evaluation of Temporary lead shielding Permit     070/8/03
Effectiveness Review Reveals CAPRs not closed as written
00168900       Corrective action closed before actions taken               04/30/03
2/10/03
00143954
2E51-F008, 63,76,357 LLRT failure in L2R09
01/26/03
00144084
Safeguards Drawing for Work Package
2/11/03
00144297
Water on Undervessel Sump Cover mat Routed to DWEDS
2/12/03
00144336
NOS IDd inadequate Closure of Root Cause Corrective Action
2/12/03
00144487
Observed leakage RBCCW line to seal cooler
2/13/03
00144683
Pipe support M01-NB-16-2402X found out of tolerance
2/14/03
00144744
2E51-F063 valve failed LLRT
2/15/03
00144744
2E51-F063 valve failed LLRT
2/14/03
00144778
2B TDRFP Woodward hydraulic piping bent
2/11/03
00144839
2FW08JA system 1 pressure at 220 instead of 260-280 psig.
2/17/03
00145072
Drains continue to challenge contamination control
2/17/03
00145074
Strainer leak contaminates 710 for second time in three days
2/18/03
00145338
Inappropriate Style matting utilized under vessel sump area
2/16/03
00146687
Contamination spread in 1A RHR 673" room
2/27/03
00147370
ACE (RP) Rejected by MRC
030/4/03
00151231
Actions in Self Assessment Determined to be ineffective
03/28/03
00153681
Gland Steam Seal Evap low Level Alarm
04/13/03
00153686
SSE low level condition
04/12/03
00155426
DG Room exhaust damper is stuck open
04/23/03
00155441
Diesel Generator Partial CO2 Actuation
04/23/03
00156861
1E12-F068a has dual indication when closed
05/01/03
00157037
1E12-F068A did not fully close
050/2/03
00159489
Discovery of an unposted neutron area
05/19/03
00162229
Significant RP resource concern by RPT
06/06/03
00165440
Potential Adverse Trend Identified - RP Procedure Adherence
06/29/03
 
00167023
2A RHR pump run contaminates entire room
07/08/03
00167691
Inadequate evaluation of Temporary lead shielding Permit
070/8/03
00168900
Corrective action closed before actions taken
04/30/03
Completed Root Cause Reports
Completed Root Cause Reports
Number         Title                                                   Date/Rev.
Number
00082092       2A D/G Governor Failed to Respond During Monthly Run     11/ 07/ 01
Title
00095677         Unit 1 RR System unable to Obtain Rated Core Flow         02/01/02
Date/Rev.
00110032       2B Diesel Generator (DG) VARs Erratic                     05/30/02
00082092
00130964       Entered Region B during Control Rod Maneuver               11/10/02
2A D/G Governor Failed to Respond During Monthly Run
00139037       Unit 2 Manual Reactor Scram                               01/10/03
11/ 07/ 01
00143880       Numerous Challenges during Installation of EC 338974       02/10/03
00095677
00146141       RR Flow Units Settings Discovered Non-conservative         02/25/03
Unit 1 RR System unable to Obtain Rated Core Flow
00148413       Mispositioned Control Rod                                 03/11/03
2/01/02
00090319       Higher than anticipated drywell dose rates                 01/12/01
00110032
2B Diesel Generator (DG) VARs Erratic
05/30/02
00130964
Entered Region B during Control Rod Maneuver
11/10/02
00139037
Unit 2 Manual Reactor Scram
01/10/03
00143880
Numerous Challenges during Installation of EC 338974
2/10/03
00146141
RR Flow Units Settings Discovered Non-conservative
2/25/03
00148413
Mispositioned Control Rod
03/11/03
00090319
Higher than anticipated drywell dose rates
01/12/01
Operability Evaluations
Operability Evaluations
Number       Title                                                         Date/Rev.
Number
OE02-014     RHR Pump Seal Cooler Flows                                   2/6/2003
Title
Attachment
Date/Rev.
OE02-014
RHR Pump Seal Cooler Flows
2/6/2003
}}
}}

Latest revision as of 07:54, 16 January 2025

IR 05000373-03-007; 05000374-03-007; on 7/21-8/8/2003; Exelon Generation Company; LaSalle County Station; Identification and Resolution of Problems
ML032471674
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 09/04/2003
From: Burgess B
NRC/RGN-III/DRP/RPB2
To: Skolds J
Exelon Generation Co
References
IR-03-007
Download: ML032471674 (19)


Text

September 4, 2003

SUBJECT:

LASALLE COUNTY STATION NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 50-373/03-07; 50-374/03-07

Dear Mr. Skolds:

On August 8, 2003, the U.S. Nuclear Regulatory Commission (NRC) completed a team inspection at the LaSalle County Station. The enclosed report documents the inspection findings which were discussed on August 8, 2003, with members of your staff.

This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, compliance with the Commissions rules and regulations and with the conditions of your operating license. Within these areas, the inspection involved selected examination of procedures and representative records, observations of activities, and interviews with personnel. No findings were identified On the basis of the sample selected for review, the team concluded that in general, problems were being properly identified, evaluated, and corrected. The team made several observations regarding the effectiveness of problem identification and resolution program implementation as detailed in the enclosed report.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosures will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

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

Enclosures:

Inspection Report No. 50-373/03-07; 50-374/03-07

REGION III==

Docket No:

50-373; 50-374 License No:

NPF-11; NPF-18 Report No:

50-373/03-07; 50-374/03-07 Licensee:

Exelon Nuclear Generation Company Facility:

LaSalle County Station, Units 1 and 2 Location:

2601 N. 21st Road Marseilles, IL 61341 Dates:

July 21 through August 8, 2003 Inspectors:

G. Wright, Project Engineer - Team Lead D. Kimble, Senior Resident Inspector R. Winter, Electrical Engineering Inspector Approved by:

Bruce Burgess, Chief Branch 2 Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

IR 05000373-03-007, 05000374-03-007; on 7/21-8/8/2003; Exelon Generation Company;

LaSalle County Station; Identification and Resolution of Problems.

The inspection was conducted by two region-based inspectors and one senior resident inspector. No findings of significance were identified.

Identification and Resolution of Problems In general, the plant identified issues and entered them into the corrective action process at an appropriate level. Nuclear Oversight (NOS) assessment reports identified issues for the plant to resolve, including issues with corrective action follow through. The majority of issues reviewed were properly categorized and evaluated although some evaluations were narrowly focused, particularly for cause evaluations. Most corrective actions reviewed were appropriately implemented and appeared to have been effective. While no findings were identified during the inspection, the team developed a number of observations including:

1.

A more thorough assessment of issues associated with ineffective corrective action(s) is an aspect of the corrective action process that could be strengthened to reduce repeat issues at the plant.

2.

Additional attention to thoroughness and quality of documentation in program descriptions, procedures, condition reports, and cause analyses would enhance the corrective action process by ensuring consistency in program application, completeness of reviews, and preservation of the historical record without reliance on institutional knowledge.

REPORT DETAILS

OTHER ACTIVITIES (OA)

4OA2 Problem Identification and Resolution

.1 Effectiveness of Problem Identification

a. Inspection Scope

The inspectors reviewed NRC inspection report findings issued over the last 2 years, selected plant corrective action documents, Nuclear Oversight (NOS) assessments, operating experience reports and trend assessments to determine if problems were being identified at the proper threshold and entered into the corrective action process.

The inspectors also conducted focused plant walkdowns of one emergency diesel generator and the diesel generator ventilation system to ensure that equipment problems were entered into the corrective action system. The documents used during the review are listed in Attachment 1.

b.

Issues In general, the plant identified issues and entered them into the corrective action process at an appropriate level. NOS assessment reports identified issues for the plant to resolve, including timely entry of deficiencies into the corrective action program (CAP). The licensee appropriately used the CAP to document instances where previous corrective actions were ineffective or inappropriate; however, in most instances, the need to identify and address why the initial corrective actions were not effective was not recognized. The teams review also noted the following items:

  • The team identified a minor error within procedure LS-AA-125, Corrective Action Program Procedure, which appeared to have occurred because of a lack of attention to detail. A Condition Report (CR) was issued to correct this condition.
  • The team identified minor differences in cause codes defined in procedure LS-AA-125 and the PASSPORT software used to track corrective action documentation. A CR was issued to correct this condition.
  • A review of previous inspection findings appeared to indicate that, at times, the licensees perspective on plant conditions did not always consider all potential impacts of the observed condition. For example, the licensee had not associated foreign material in a corner room and the drywell with potential corner room flooding and operability of the drywell leak detection system until brought to their attention by the NRC.

b.1 Identification Threshold The licensee had defined an adequate threshold for the identification of issues to be entered into the corrective action program in accordance with the LaSalle County Station procedure LS-AA-125 Corrective Action Program (CAP) Procedure. La Salle uses an electronic database system. Corrective action documents are called an Action Request (AR) or Condition Report (CR). The generation rate for ARs/CRs was appropriate, with 4356 condition reports written in 2002 and 3149 CRs written in 2003 to date. Both the number and significancy level distribution of CRs appeared to be appropriate for the facility. While the threshold and generation rate appeared appropriate, the licensee found several examples of departments not placing issues in the corrective action program in a timely manner.

b.2 Operating Experience The inspectors reviewed a sampling of industry operating experience (OPEX) reports and concluded that the licensee was appropriately including the issues in the CAP.

Refer to Section

.2. b.3 for additional information on operating experience.

b.3 Nuclear Oversight The inspectors reviewed a sample of NOS assessment reports from the past 2 years and determined that the NOS staff, in general, was effectively identifying plant performance issues including issues with implementation of the CAP.

.2 Prioritization and Evaluation of Issues

a. Inspection Scope

The team reviewed inspection reports and corrective action documents to verify that identified issues were appropriately characterized and entered into the CAP.

Inspection team members attended management meetings to observe the assignment of CR categories for current issues and the review of root, apparent, and common cause analyses, and corrective actions for existing CRs.

The team conducted an independent assessment of the prioritization and evaluation of selected CRs. The assessment included a review of the category assigned, the operability and reportability determinations, the extent of condition evaluations, the cause investigations, and the appropriateness of assigned corrective actions. Other attributes reviewed by the team included the quality of the licensees trending of conditions and the corresponding corrective actions. The team also assessed licensee corrective actions stemming from Non-Cited Violations (NCVs) and Licensee Event Reports (LERs). This review included the controlling procedures, selected records of activities, and observation of various licensee meetings. In addition, the team conducted several interviews with cognizant licensee personnel.

The team likewise reviewed the licensees efforts to capture industry OPEX issues in the CAP. Documents reviewed included the licensees assessment of industry operating event reports, NRC, and vendor generic notices.

Information reviewed by the team dated back to the previous problem identification and resolution inspection conducted in September 2001 (NRC IR 50-373/01-16; 50-374/01-16).

b.

Issues The team verified that the issues reviewed were properly categorized and evaluated.

The team did, however, have several observations regarding the licensees trending program and the quality of its documentation. Details of the teams observations are described in the following subsections.

b.1 Overview of Prioritization and Evaluation Process The corrective action process included a review of newly initiated CRs by the Management Review Committee (MRC) composed of senior plant management. The MRC reviewed the investigation class assigned to each CR by a departmental CAP coordinator. Within the licensees program, an A was assigned to a Significant Condition Adverse to Quality (SCAQ) requiring a root cause evaluation, a B was assigned to a Condition Adverse to Quality (CAQ) requiring an apparent cause evaluation, and C was a CAQ requiring a condition evaluation to determine the proper corrective actions. A significance level D was also available for conditions that were not adverse to quality.

b.2 Trending Program The team performed an in-depth examination of the licensees trending program as a follow-on to an observation made in the previous problem identification and resolution inspection.

As discussed in subsection b.3 below, the team initially had some difficulty identifying the total depth and breadth of the licensees current trending program due to the lack of a single document that identified all of program subcomponents. Following discussions with the licensee, the team concluded that the licensee had in place an extensive trending program.

With respect to the quality of the trending program, the team had two observations:

  • The team noted that the licensees trend analyses rarely, if ever, examined the underlying cause for the apparent trend. The question of, Why did this adverse trend occur in the first place?, was infrequently addressed.
  • In the CAP coding area, the team noted that the licensees use of computer-based, or computer-aided trend analysis relied primarily on individuals to identify trends. While the licensee used the system to generate lists of potentially related issues, it did not use the computer to identify when a trend may exist. The lack of such computer enhanced trending tools in the CAP coding arena placed the burden of trend identification on the judgement of individual CAP coordinators.

The team identified that tools for trending system and component performance were in place.

b.3 Documentation In general, the team found the licensees documentation practices associated with the CAP to be weak. In several instances, the team was only able to successfully understand the licensees actions because key individuals recalled details of what had occurred and, more importantly, why it had occurred. The team noted that this documentation weakness leaves the licensee vulnerable to the loss of key information should certain employees with the institutional knowledge leave LaSalle County Station.

Examples noted by the team are described below.

  • When the team began inspection of the licensees trending program and requested CAP documents that addressed the trending weaknesses identified in the previous problem identification and resolution inspection, the team members were informed that no such documents existed. Through interviews with key licensee personnel, the team learned that the licensee had made a conscious decision to forego the creation of specific corrective actions to address the trending weaknesses because the rollout of a new licensee CAP was imminent.

The new program was believed to be sufficient to address the trending program weaknesses. However, this decision and its basis were not documented.

  • As discussed in b.2 above, the team found no documentation which described the total depth and breadth of the licensees current trending program. For example, the team identified an apparent adverse trend regarding control room log deficiencies. Seemingly, some 80 percent of the identified deficiencies over a 20 month period were either identified by the NRC or the licensees internal NOS group. However, upon further examination, the team found that control room log deficiencies self-identified by Operations personnel over the same 20 month period were about 7 times greater than the number identified by the NRC and NOS. The Operations group did not, however, document these deficiencies in the CAP as CRs, but rather in a scorecard program database used for various Operations group internal observations.
  • In reviewing OPEX items, the team examined the program item which initially looked at the reactor recirculation jet pump hold down beam failure at the Quad Cities Nuclear Station in 2002 (GE RICSIL 086). The licensee evaluated this OPEX item as not applicable to LaSalle Station based upon an understanding that the jet pump hold down beams in use at LaSalle Station were of a different type than those identified in the OPEX item and not susceptible to the discussed failure mechanism. The licensee closed the OPEX item on this basis. The licensee subsequently identified that the assumption was not entirely true, i.e.,

LaSalle Station did have in service some susceptible jet pump hold down beams.

However, the documentation for the original OPEX item was not revised to reflect the new information or the licensees current corrective and compensatory actions.

  • Regarding the root cause analysis for an unexpected radiation level in the drywell, during a recent refueling outage, the licensee did not include all actions it had taken in preparation for the outage. While in this case the team did not believe that the root cause outcome would have been different, failure to include all pertinent information in the assessment limits the evaluation and may deprive the organization of valuable insights and potential corrective actions.

.3 Effectiveness of Corrective Action

a. Inspection Scope

The inspectors reviewed past inspection results, selected CRs, root cause reports and common cause evaluations to verify that corrective actions, commensurate with the safety significance of the issues, were specified and implemented in a timely manner.

The inspectors evaluated the effectiveness of corrective actions. The inspectors also reviewed the licensees corrective actions for Non-Cited Violations (NCVs) documented in NRC inspections in the past 2 years. The inspectors conducted a walkdown of one emergency diesel generator and the diesel generator ventilation system to assess the material condition of the system and verify that the licensee appropriately identified degraded conditions within the corrective action program.

b.

Issues In general, the licensees corrective action for the sample reviewed were appropriate and appeared to have been effective. The team noted that the licensee generated CRs when they identified a corrective action which was either inadequate or inappropriate.

b.1 Observations on the Effectiveness of Corrective Actions The inspectors had several observations regarding corrective actions that were not fully implemented, not fully effective in correcting the identified issue, or were narrowly focused. These observations are described below.

  • A minor issue was identified for inadequate corrective action to preclude repetition concerning diesel generator erratic VAR indication. On May 30, 2002, the 2B diesel generator was started and slowly full loaded, until after about 20 minutes of operation, the VAR meter indicated repetitive spiking. A root cause report 00110032 identified a primary cause and contributing causes.

However, this did not preclude recurrence because on October 16, 2002 the 2B diesel generator during a fast start surveillance again had erratic VAR meter indication. Another root cause report (00127728) was performed and identified the primary cause as a different component within the same governor and identified contributing causes. The self-revealing problem repetition highlighted that the key features in minimizing vulnerability from a number of components was not fully recognized during the first troubleshooting, root cause and analysis.

  • A minor issue was identified for inadequate corrective action to preclude repetition concerning diesel generator air start compressor relief valve problems.

From the period of January through September 2002, a series of ARs were generated because the air start compressor relief valves lifted on several different diesel generators and on one occasion, one relief valve stuck open.

The corrective action was not particularly timely but a solution eventually emerged and actions to prevent recurrence include the change out of the air dryers associated with the diesel generators air start compressors.

  • In evaluating inadequate or ineffective corrective actions, the licensee appropriately addressed the initial issue; however, rarely was an evaluation conducted to review why appropriate corrective actions were not initially proposed or implemented.

.4 Practice of Closing CRs to Work Requests or other CRs

a. Inspection Scope

The inspection team reviewed condition reports which had been closed to work requests or other condition reports to assess whether the original issue was appropriately addressed in the follow-on document.

b.

Issues The team verified that the issues addressed in the initial CR were appropriately addressed in subsequent work requests or CRs.

.5 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

The inspectors conducted interviews with plant staff to assess whether there were impediments to the establishment of a safety conscious work environment. During these interviews, the inspectors used Appendix 1 to Inspection Procedure 71152, Suggested Questions for Use in Discussions with Licensee Individuals Concerning PI&R Issues, as a guide to gather information and develop insights. The inspectors also discussed the implementation of the Employee Concerns Program (ECP) and selected concerns with the plants ECP Coordinators. Additional discussions with the ECP Coordinators centered on integration of the ECP and CAP programs.

b.

Issues Plant staff interviewed did not express any concerns regarding the safety conscious work environment. The staff was aware of and generally familiar with the corrective action program and other plant processes including the Employee Concerns Program through which concerns could be raised. Further, a review of the types of issues in the ECP indicated that site personnel were appropriately using the corrective action and employee concerns programs to address their concerns. Based on interviews, the ECP Coordinators were appropriately focused on ensuring all site individuals were aware of the program, reviewing individual concerns, and integrating where appropriate the ECP and CAP programs to resolve concerns.

4OA6 Management Meetings

.1

Exit Meeting Summary

The inspectors presented the inspection results to Ms. Susan Landahl and other members of licensee management in an exit meeting on August 8, 2003. Ms. Landahl acknowledged the findings presented and indicated that no proprietary information was provided to the inspectors.

PARTIAL LIST OF PERSONS CONTACTED Licensee D. Barrett LaSalle NO - Employee Concerns J. Barchello Security J. Beardon Operations Corrective Action Program Coordinator (CAPCo)

R. Bellettini Corrective Action Program Coordinator A. Byers Radiation Protection CAPCo B. Carter Nuclear Oversight B. Cockrel Diesel Generator System Engineer D. Czufin Engineering Director C. Dieckmann Training Director L. Kofoid-Durdan Chemistry CAPCo D. Enright Operation Services Manager S. Fatora Chemistry Manager A. Ferko LaSalle Nuclear Oversight (NO) Manager M. Hayworth LaSalle NO - Employee Concerns P. Holland Regulatory Assurance G. Kaegi Regulatory Assurance Manager S. Landahl Plant Manager P. Manning Engineering CAPCo B. McConnaughay Work Control M. McDowell Assistant Plant Manager M. Murskyj Electrical Design Engineering Supervisor M. Phalen Radiation Protection Superintendent M. Poland Maintenance CAPCo G. Randle Maintenance Director S. Shields Operating Experience Coordinator B. Werder Engineering J. Wieging Electrical Design Engineering Supervisor G. Wilhelmsen Engineering Balance of Plant Systems Manager M. Williams BOP System Engineer C. Wilson LaSalle Security Manager ITEMS OPENED, CLOSED, AND DISCUSSED Items Opened: None Items Closed: None LIST OF ACRONYMS AR Action Request CAP Corrective Action Program CAQ Condition Adverse to Quality CR Condition Report ECCS Emergency Core Cooling System ECP Employee Concerns Program LER Licensee Event Report MRC Management Review Committee NCV Non-cited Violation NOS Nuclear Oversight NRC Nuclear Regulatory Commission OPEX Operating Experience PI&R Problem Identification and Resolution SCAQ Significant Condition Adverse to Quality LIST OF

DOCUMENTS REVIEWED

The following is a list of licensee documents reviewed during the inspection. Inclusion of a

document on this list does not imply that NRC inspectors reviewed the entire documents, but,

rather that selected sections or portions of the documents were evaluated as part of the overall

inspection effort. In addition, inclusion of a document on this list does not imply NRC

acceptance of the document, unless specifically stated in the body of the inspection report.

4OA2 Identification and Resolution of Problems

Plant Procedures and Audits

EI-AA-101

Employee Concerns Program

Rev. 2

LS-AA-21

Nuclear Oversight Audit Process Description

Rev. 0

LS-AA-115

Operating Experience Procedure

Rev. 1

LS-AA-125

Corrective Action Program (CAP) Procedure

Rev. 5

LS-AA-125-1001

Root Cause Analysis Manual

Rev. 3

LS-AA-125-1002

Common Cause Analysis Manual

Rev. 2

LS-AA-125-1003

Apparent Cause Evaluation Manual

Rev. 2

LS-AA-125-1004

Effectiveness Review Manual

Rev. 1

LS-AA-125-1005

Coding and Trending Manual

Rev. 3

LS-AA-125-1006

CAP Process Expectations Manual

Rev. 3

LS-AA-126

Self-Assessment Program

Rev. 2

LS-AA-126-1001

Focused Area Self-Assessments

Rev. 1

NO-AA-200-001

Nuclear Oversight Continuous Assessment

Procedure

Rev. 2

NOA-LS-03-2Q

Nuclear Oversight Quarterly Report LaSalle

County Station April-June 2003

07/23/03

NOSA-LAS-03-03

NOS Security Audit Report

04/04/03

NOA-LS-01-3Q

Nuclear Oversight Continuous Assessment

Report

10/25/01

NOA-LS-02-1Q

Nuclear Oversight Continuous Assessment

Report

04/30/02

NOA-LS-02-1Q

Nuclear Oversight Continuous Assessment

Report

01/29/03

Condition Reports Reviewed During LaSalle County Station PI&R Inspection:

CR/AR #

Title

Date

00001119

Perform an effectiveness review in accordance with

NSWP-A-16 to the implemented corrective actions resulting

from LER 97-043.

11/11/99

00001149

Testing of Removed/Damaged rupture disc assembly

03/07/00

L2001- 05688

Potential for Non-Conservative Steam Carryover Fraction in

Computer Heat Balance Calculation.

10/03/01

L2001-06182

Locked high rad door #208 found open

11/01/01

L2001-05717

NRC identified: Procedure Adherence with AD-AA-106 CCA

condition report identification

10/02/01

L2001-03138

U-2 Scram generated High Rad Area.

05/27/01

L2001-03153

Uncoupled Control Rod During Unit 2 Startup

05/29/01

L2001-05949

Untimely Station Response

10/19/01

00002477

Perform an Effectiveness review of the corrective actions

11/30/99

00002503

Perform EFF review of corrective action #4, to perform torque

checks

2/03/99

00030864

Intermediate Hot Spot discovered on the Unit 2 east MPT

during Thermogoraphy

06/28/00

00076848

Increase In U-1 Offgas Pretreatment Radiation

09/25/01

00078266

NRC ident: RCR risk analyses not quantitative.

10/09/01

00082155

Testing Required For 2A DG Governor Replacement

11/08/01

00085020

Ineffective Perimeter Zone

2/04/01

00085280

2A DG exhaust Temps >200 deg delta T during LOS-DG-M2

2/05/01

00086988

NRC Identified, ineffective corrective actions from scram

2/14/01

00088342

NRC Id - Human Performance Related Error Trend

Identification

2/28/01

00088688

Potential NCV for unlocked High Rad door

2/31/01

00089048

2A DG Cylinder Exhaust Temperatures Erratic

01/02/02

00089355

LOS-DG-Q3 Could not be performed for 2B DG A Air

Compressor

01/07/02

00090734

Improper wiring determ in panels 1FW06JA and 1FW06JB

01/14/02

00091429

Unacceptable through bolt location

01/19/02

00091988

Fuel moves stopped at step 91 of L1C10 Axis shuffle

01/23/02

00092014

Fuel Handling Error during Shuffle 2

01/23/02

00092638

2A DG A Air Compressor Interstage Relief lifting

01/28/02

00092542

1E22-F024, HPCS Pump Discharge Check Failed Acceptance

Criteria

01/26/02

00092596

Unusual Flow Noise During HPCS Pp Run

01/27/02

00093177

2A DG 'A' Compressor Relief lifting While Running

01/30/02

00094268

Unexpected temperatures observed on 1TE-VP115

2/07/02

00094589

2B D/G A Air Compressor Tripping Breaker

00095253

Potential Bus duct Fire seal deficiencies Discovered by NRC

2/14/02

00097020

Off-pretreat purge valve not opening

2/27/02

00099302

Crew Critique for EMD Crew ECM

03/15/02

00099679

Unit 2 HPCS Pump IST Adverse Trend

03/18/02

00100428

Adverse Trend on Past Due PMs in Maintenance

06/03/02

00104619

NOS IDd, RP: Ineffective Corrective Actions for CR 90284

04/20/02

00105133

CRD rebuild rooms continue to challenge RP and station

04/24/02

00106428

Adverse Trend on Backlog of Past Due PMs in Maintenance

05/02/02

00108670

U-1 B RHR pump seal leak causing contamination

05/18/02

00108841

Workers continue to leave scrubs in locker rooms

05/20/02

00109626

MSIV A Limit Switch Temperature exceeds 175 Degrees

5/28/02

00110168

Issues Identified During 2B DG Operability Run

05/31/02

00114125

1A DG Cooling Water Flow Adjustment Reqd During

LOS-DG-Q2

07/02/02

00114397

New Quincy Compressors Have Incorrect Hydraulic Unloader

Asm

07/03/02

00116251

0DG B Air Start Compressor Discharge Relief Lifting

07/19/02

00116992

Persistent recontamination of 2A RHR room

07/25/02

00117431

Safety Concern: CO2 Monitor INOP at Lake Screen House

07/30/02

00117569

0DG B Air Start Compressor Discharge Relief Lifting

07/30/02

00118101

0DG "A" Compressor Relief Valve Stuck Open

08/04/02

00119063

Tech Spec SR 3.8.1.6 not tracked/completed

10/19/02

00120845

Inadequate Closure of a CAPR

03/20/02

00121102

Ineffective CAPRs IDd during EFR

08/29/02

00121634

Relief Valve 0DG022 B Lifting During Compressor Operation;

09/04/02

00121822

Diesel Gen Air Cmpr "A" Relief Vlv Lifting

09/06/02

00124828

NRC 2002 SSDI Identified - DG Air Flow Regulator Calibration

09/27/02

00125571

NOS Idd: (ENG) Potential Adverse trend in Eng. Clock Resets

10/02/02

00127728

2B Voltage Regulator Very Erratic

10/16/02

00128981

0" Diesel Generator Cooler Outlet Throttle Valve Drifted

10/25/02

00131093

GE Part 21 TIP System Ball and Shear Valve Radiation Spec

10/08/02

00131665

TIP system Ball and Shear Valve Radiation Specification

11/14/02

00134097

Safeguards Drawing found in AEs uncontrolled file

2/04/02

00134417

Safeguards Drawing found in AEs uncontrolled file

2/06/02

00140501

NOS Idd: (ENG) Decline in Engineering Performance for 02-

4Q

01/22/03

00142758

Adverse Trend on Backlog of Non-Outage Maintenance PMs

03/04/03

00142779

Incorrect wiring termination for EC 331396 U2 SLMS

2/03/03

00142811

Adverse Trend on Backlog of Non-Outage PMs

20/4/03

00142933

NOS Identified undersized welds

20/4/03

00143002

B DWFDS sump pump tripped on thermals

2/05/03

00143006

2B33-015B fails leak testing

20/4/03

00143076

Repeated trips of the RMCS system with no rod motion

2/05/03

00143130

2E51-F068 valve failed LLRT

2/05/03

00143131

2MS01-2888S missing locking screws

2/05/03

00143169

2E12-F050A fails high pressure water leak rate test

2/05/03

00143175

Incorrect sample tubing routing for EC 331396, SLMS

2/06/03

00143367

Discrepancies on snubbers 2MS01-2877S and 2MS01-2888S

2/06/03

00143658

Incomplete termination of ground on 2FE-RF021 for EC 51151

2/08/03

00143876

Effectiveness Review Reveals CAPRs not closed as written

2/10/03

00143954

2E51-F008, 63,76,357 LLRT failure in L2R09

01/26/03

00144084

Safeguards Drawing for Work Package

2/11/03

00144297

Water on Undervessel Sump Cover mat Routed to DWEDS

2/12/03

00144336

NOS IDd inadequate Closure of Root Cause Corrective Action

2/12/03

00144487

Observed leakage RBCCW line to seal cooler

2/13/03

00144683

Pipe support M01-NB-16-2402X found out of tolerance

2/14/03

00144744

2E51-F063 valve failed LLRT

2/15/03

00144744

2E51-F063 valve failed LLRT

2/14/03

00144778

2B TDRFP Woodward hydraulic piping bent

2/11/03

00144839

2FW08JA system 1 pressure at 220 instead of 260-280 psig.

2/17/03

00145072

Drains continue to challenge contamination control

2/17/03

00145074

Strainer leak contaminates 710 for second time in three days

2/18/03

00145338

Inappropriate Style matting utilized under vessel sump area

2/16/03

00146687

Contamination spread in 1A RHR 673" room

2/27/03

00147370

ACE (RP) Rejected by MRC

030/4/03

00151231

Actions in Self Assessment Determined to be ineffective

03/28/03

00153681

Gland Steam Seal Evap low Level Alarm

04/13/03

00153686

SSE low level condition

04/12/03

00155426

DG Room exhaust damper is stuck open

04/23/03

00155441

Diesel Generator Partial CO2 Actuation

04/23/03

00156861

1E12-F068a has dual indication when closed

05/01/03

00157037

1E12-F068A did not fully close

050/2/03

00159489

Discovery of an unposted neutron area

05/19/03

00162229

Significant RP resource concern by RPT

06/06/03

00165440

Potential Adverse Trend Identified - RP Procedure Adherence

06/29/03

00167023

2A RHR pump run contaminates entire room

07/08/03

00167691

Inadequate evaluation of Temporary lead shielding Permit

070/8/03

00168900

Corrective action closed before actions taken

04/30/03

Completed Root Cause Reports

Number

Title

Date/Rev.

00082092

2A D/G Governor Failed to Respond During Monthly Run

11/ 07/ 01

00095677

Unit 1 RR System unable to Obtain Rated Core Flow

2/01/02

00110032

2B Diesel Generator (DG) VARs Erratic

05/30/02

00130964

Entered Region B during Control Rod Maneuver

11/10/02

00139037

Unit 2 Manual Reactor Scram

01/10/03

00143880

Numerous Challenges during Installation of EC 338974

2/10/03

00146141

RR Flow Units Settings Discovered Non-conservative

2/25/03

00148413

Mispositioned Control Rod

03/11/03

00090319

Higher than anticipated drywell dose rates

01/12/01

Operability Evaluations

Number

Title

Date/Rev.

OE02-014

RHR Pump Seal Cooler Flows

2/6/2003