IR 05000373/1986006
| ML20212L946 | |
| Person / Time | |
|---|---|
| Site: | LaSalle |
| Issue date: | 03/04/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20212L943 | List: |
| References | |
| 50-373-86-06, 50-373-86-6, 50-374-86-07, 50-374-86-7, NUDOCS 8703110007 | |
| Download: ML20212L946 (40) | |
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SALP 6 SALP BOARD REPORT NUCLEAR REGULATORY COMMISSION
REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-373/86006; 50-374/86007 Inspection Report Nos.
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Comonwealth Edison Company Name of Licensee LaSalle County Nuclear Power Station Units 1 & 2 Name of Facility October 1, 1985 through November 15, 1986 Assessment Period 3110007 870304
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ADoCK 05000373 PDR d
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c LASALLE STATION SUMMARY OF RESULTS Overall, the licensee's performance was found to be acceptable. Of 11 functional areas rated during this assessment period, licensee performance in four areas improved from Category 3 to Category 2.
Four functional areas sustained Category 2 ratings, but the area of Security was noted to have a declining trend during this assessment period. A decline in the area of Fire Protection / Housekeeping was observed with the rating decreasing from a Category 1 during the last assessment period to a Category 2 during this assessment period. Two of the functional areas, Outages and Training and Qualification Effectiveness, were not rated during the previous assessment period.
Rating Last Rating This Functional Area Period Period Trend A.
Plant Operations
2 B.
Radiological Controls
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Maintenance 3**
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Surveillance
2 E.
Fire Protection /
2 Housekeeping F.
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Security
2 Declining H.
Outages
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I, Quality Programs and
2 Administrative Controls Affecting Quality J.
Training and Qualification
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Effectiveness K.
Licensing Activities
2 New Functional Area - not rated during the previous assessment.
- During the previous assessment this functional area included
" Modifications" which has been moved to the " Outage" functional area.
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IV.
PERFORMANCE ANALYSIS A.
Plant Operations 1.
Analysis This-functional area was under continuous review by the resident inspectors during this assessment period. Two special inspections were conducted. Of note was the special inspection in the area of facility operations conducted at the site by five Senior Resident Inspectors from different sites throughout the country.
As a result of these inspections, one Severity Level III, and eight Severity Level IV violations were issued. All but three of the violations were issued prior to June 1986, including the Severity Level III violation. Also, the three violations that occurred after June 1986, were the result of a single incident.
In general, the enforcement history is about the same as in the previous assessment period where ten violations (one Severity Level III and nine Severity Level IVs) were identified. However, there was a noteable improvement in this area at the end of the assessment period.
A number of the violations issued during this assessment involved failure of personnel to adhere to procedures, which has been an ongoing problem at LaSalle.
Failure to adhere to procedures was a dominant factor in other activities for which violations were not issued because the violations met the enforcement policy for not doing so. Other violations involved failure of operators to recognize off normal conditions in the control room. These types of deficiencies were also identified during the previous assessment period. Management's corrective actions to reduce and eliminate these types of errors were aggressively initiated and written responses to specific violations were technically sound, viable, and generally thorough. However, these actions were not fully effective in preventing recurrences.
The Severity Level III violation and subsequent civil penalty were issued when the licensee inadvertently left an Emergency Core Cooling System (ECCS) out of service for longer than the time allotted by Technical Specifications. The system had been rendered inoperable when a valve was mispositioned due to incorrect interpretation of the Technical Specifications.
The licensee's corrective action was not totally effective in that within four months the licensee again mispositioned a similar valve.
In the second event, the system was returned
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to an operable status before the Limiting Condition for Operation (LCO) time limit had expired.
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The licensee has enforced good work practices and conduct.
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. ithin the control room. The licensed co.. trol room personnel
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continually assess the activities in the control. room and
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implement-the appropriate actions necessary to maintain a good working atmosphere. This includes maintaining noise level to a minimum, minimizing the number of surveillances and/or work activities that are taking place concurrently,
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maintaining control over the number of people around the-
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control panels, limiting non-pertinent conversations, and monitoring the behavior of the personnel in the control room.
The control room atmosphere is generally quiet and orderly.
Despite enforcing good work practices in the control room and meeting the minimum requirements for control room staffing, L
the licensee continues to have' problems with failure of the l
operators to recognize off normal conditions.
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The licensee had experienced a series of ongoing problems
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which led to poor operating perfonnance during the previous
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assessment period. Some performance' improvements were noted
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shortly after implementation of a corrective action program developed in response to the letter issued by the NRC pursuant
to 10 CFR 50.54(f) (described in Section IV.I). However,
progress in attaining performance goals was hampered during
the summer of 1986 due to extensions to the Unit I refueling i -
outage and an outage on Unit 2 to address differential pressure
switch problems. Shortly before Unit 2 was restarted, the i
licensee presented an aggressive program to Region III for an i
error free startup of each unit which involved increased
supervisory and management presence on shift, extensive
pre-startup testing to verify equipment operability, weekly i.
management reviews of plant performance, and phased power ascension. This program was successful in returning both units to operation with'a minimum of problems.
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Following the return of both units to operation, the NRC
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performed a special assessment of-LaSalle operations to
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determine the effectiveness of the licensee's corrective action
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program beyond initial startup.
It was the conclusion of the assessment team that the licensee now has in place the
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mechanisms to support quality operations, that these mechanisms
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have the full support of site and corporate management, and j
that the licensee has a staff of highly motivated operations j
personnel eager to perform well.
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improvement existed. The team felt that the Support Services i.
organization should become more actively involved in operations
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l support and that the Shift Supervision is not being utilized
effectively due to an overload of administrative duties.
The team also noted obstacles which interfere with the l
performance of routine activities including inaccessible
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equipment, excessive numbers of-temporary system configurations-r
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and modifications. and reference material which was difficult
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to use. The licensee has taken-action to reduce some of the
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overload of= administrative duties for the Shift Superivision.
The-other' areas of concern are under review by the licensee.
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technical issues was' satisfactory from a safety standpoint.
. once the issues were identified. The licensee's response to the
- June.1, 1986 event, where the reactor protection system failed to trip in response to low reactor vessel level, was an
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example of safe operation. Once the licensee identified that
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a scram should have occurred on low level.-the unit was brought
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i to a cold shutdown condition and an extensive investigation was conducted. Both units remained shut down until the problem was well defined and solutions were implemented.
Two Confirmatory Action Letters were issued in this area to t
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. document corrective actions agreed upon by the licensee and Region III:
June 2, 1986, concerning improper response of the reactor protection system due to a-decrease in reactor vessel
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June 19, 1986, concerning a licensed operator who
improperly verified an out of service condition.
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The licensee was responsive.to NRC initiatives in that when a
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- Confirmatory Action Letter was warranted, the licensee worked I
with the NRC in identifying what action would be taken to resolve the problem. This was also reflected in the licensee's approach to resolving the concerns of the 10-CFR 50.54(f)
L letter discussed in Section IV.I.
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There were 18 reportable events during the assessment period attributed to the operations area, which is an order of
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magnitude reduction from the 157 events reported in the
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previous SALP period. Eight events were the result of L
personnel error. This was a reduction from the 18 events attributed to personnel errors during the previous assessment perioo. Many of the events in the early part of this assessment period were due to spurious isolations of the
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control room ventilation system due to the tripping of the
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chlorine monitors. The licensee was finally able to reduce j
the occurrence of these Engineered Safety Feature (ESF)
l actuations by obtaining a change to the Technical Specifica-
tion which eliminated the requirement for a chlorine monitoring system. This problem and problems with isolations of the
l Reactor Water Cleanup System (RWCU) were identified in the previous assessment period. Through aggressive attention to i
these problems by management and personnel, the problems have t
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been reduced.- These efforts were very effective in the latter part of.the assessment period.
During this assessment period, the licensee experienced a relatively high number of unscheduled reactor scrams, having a total of ten scrams on both units (four on Unit 1 and six on Unit 2). Five of these scrams occurred while the reactors were in cold shutdown and two scrams occurred at less than 15% power.
Five.of the ten scrams were due to personnel error, three of which occurred during shutdown conditions.
However, only one scram occurred after May 1986, indicating an improve-ment at the end of the assessment period.
The overall quality of the operations staff was considered very high. The dedication to responding to events and properly correcting the.1 was very good, an example of which was the response to the low reactor water level transient and associated corrective actions. Also the actions taken during transients to prevent ESF actuations or scrams and during scram recoveries were always good.
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Conclusion The licensee is rated Category 2 in this area. The license received a rating of Category 3 in the last SALP. The impro..i rating is based on the noticeable reduction in the number of reportable events and personnel errors since the previous assessment and the increased support and involvement of licensee management to attain improved performance. The Category 2 rating is based heavily on the licensee's performance at the end of the assessment period, where the most noteable improvements have been achieved.
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Board Recommendations Aggressive management involvement in this area must continue to ensure continued improvement in performance.
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B.
Radiological Controls 1.
Analysis Eight inspections including one special inspection of a licensee event report were performed during this assessment period by regional specialists. The resident inspectors also performed inspections in this area.
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There were four Severity Level IV violations identified. One of the violations resulted from continuation of the high radiation area problems identified by the licensee during the previous assessment period. The licensee's corrective actions for the violations were appropriate and timely; the licensee's actions to prevent recurrence have been effective. The four violations represent improved regulatory performance over the previous assessment period when ten violations (seven Severity Level IV and three Severity Level V) were identified.
Licensee staffing in the radiation protection program has generally improved during this assessment period with the establishment of a dedicated individual responsible for personnel and area decontamination, the addition of an experienced health physicist to the staff, and improved staff stability. However, chemistry staff inexperience remains a weakness; only 2 of the 5 chemists have been in the plant for more than 11 years. This has resulted in a somewhat slow pace in developing programs for the laboratory QA/QC and in bringing new state of the art laboratory instruments into use for routine analysis. Technicians demonstrated generally satisfactory capability in laboratory assignments, but the licensee's practice of rotation between chemistry and health physics assignments is a weakness that limits proficiency and requires close supervision to avoid performance problems.
Management involvement has improved and was generally adequate during this assessment period; however, further improvement is needed in self-identification and correction of program weaknesses. Corrective actions have been taken for self-identified radiation protection problems concerning personnel and area contamination control, solid waste management, and environmental progiams.
The licensee has continued to followup radiation occurrence reports and personnel contam-ination events, installed more detection and monitoring equipment, and been more responsive to a large number of inspector identified concerns in this area. The licensee has also made progress in developing nonradiological chemistry QA/QC programs.
The licensee has been generally responsive to NRC concerns.
Steps to resolve weaknesses concerning identified high radiation area problems have been initiated during this assessment period in response to concerns expressed by NRC personnel. Weaknesses concerning the need for strong staff surveillance to identify and resolve radiological problems and discrepancies found in the plant continued during this assessment aeriod.
This was evidenced by the problems identified )y the inspector during plant tours concerning procedural adherence, following of posted instructions, potentially contaminated protective clothing found in uncontrolled areas, and unreturned respirators. Areas
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indicative of licensee responsiveness during this assessment period include continuing implementation of the RAD / CHEM improvement plan, simplification and clarification of the RWP system, continued efforts in increasing radiation detection systems for personal contamination, analyzing monthly composite samples for tritium taken from the cooling lake blowdown, and agreeing to issue an errata to correct 1985 gaseous and liquid effluent data erroneously reported in the semiannual effluent reports. Recurring problems with laboratory temperature control were corrected following an NRC inspection near the middle of the assessment period.
The licensee's approach to resolution of radiological technical issues has been generally adequate. An exception was an event on the refuel floor which caused some personnel and extensive area contamination because the licensee had not been aware of changed radiological conditions.
Investigation of the contamination incident identified several problems concerning measures that should have been taken involving the use of monitoring equipment on the refueling floor for better understanding of radiological conditions. Another exception was a lack of awareness of radiological conditions in the Control Rod Drive (CRD) repair room which contributed to worker intake of radioactivity. A review of the circumstances which led to the worker intake identified problems in the routine and RWP pre-job survey programs. The licensee's approach in integrating the area and personnel contamination control program and the radiological control program with the ALARA program and the RWP system is good.
Support for the ALARA program continues as noted by the ALARA initiatives taken during the Unit I refueling outage, stronger management support for the contamination control program, and continued use of a dose accountability system.
Personnel contamination events were considerably reduced during the latter part of this assessment period. Total worker dose was 640 person-rem in 1985 and approximately 700 person-rem for the first six months of 1986.
The 1985 dose included several months of the Unit I refueling outage; the 1986 dose included the remainder of the refueling outage and maintenance work activities on Unit 2.
These cumulative doses are slightly below the 1985 average for U.S.
boiling water reactors (BWRs) (800 person-rem per reactor).
The licensee's radiological effluents are also below average for U.S. BWRs.
No unplanned liquid or gaseous releases were reported.
The licensee has achieved a zero liquid batch release program since mid-December 1985. One problem was identified with the licensee's transportation of radioactive material.
The problem was not indicative of a progrannatic weakness and sufficient actions were taken to prevent recurrence.
The licensee has implemented a water chemistry control program which satisfactorily addresses the major elements of the BWR Owners Guidelines designed to minimize localized corrosion in
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I the reactor coolant system and turbines. Surveillance data show the station has been taking timely corrective action for
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off normal conditions and that water quality is improving. The licensee is also making a number of modifications to further improve chemistry controls.
The licensee has established QA/QC programs for chemistry measurement control that include instrument performance
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testing, interlaboratory comparisons, and Radiation / Chemistry Technician (RCT) proficiency testing. Proficiency testing is just getting underway and improvements in data assessment are warranted to better evaluate RCT performance.
Improvement is also needed in the use of the new fon chromatograph as indicated by problems observed in an inspection conducted just after the end of the assessment period.
A QA/QC program is well established in the counting room and control charts of performance checks are used to determine the reliability of each counter. An interlaboratory comparison program similar to the one in chemistry is being developed.
The licensee's confirmatory measurements performance declined since the previous assessment period with 6 disagreements in 47 comparisons.
Five were for gaseous nuclides in an off gas pretreat sample analyzed on the laboratory gamma spectrometer.
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Agreements were obtained when the sample was analyzed on the Post Accident Radionuclide Analysis Portable System. The license took prompt action to recalibrate the gamma spectro-meters.
Conduct of the Radiological Environmental Monitoring Program
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(REMP) during this period was satisfactory, except for a persistent leakage problem in one of the environmental air sampler stations. This problem, discussed in the previous assessment period, is now receiving licensee attention to resolve it. The licensee has exerted extensive efforts to improve the REMP during this period by correcting errors in previous annual operating reports and having tighter management i
oversight by the corporate office in the conduct of the REMP.
A special inspection was made of Licensee Event Report (374/85040) in which the licensee reported difficulties in adjusting an excess concentration of sodium pentaborate in the Standby Liquid Control Tank in a timely manner.
The problems appeared to have been due to various aspects of poor quality control of the analysis and the tank volume measurement method. The licensee has since modified procedures to reduce
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such problems.
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Conclusion The licensee is rated Category 2 in this functional area.
The licensee was rated Category 2 in the last SALP.
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Board Recommendation None C.
Maintenance 1.
Analysis
This functional ' area has changed since the last assessment period when both maintenance and nadifications were addressed in this area. Modifications are now addressed under the Outage functional area.
This functional area was continuously monitored and reviewed by the resident inspectors during this assessment period. The inspectors observed station maintenance activities of safety related systems and components. Also included were general tours of Units 1 and 2 reactor buildings and turbine buildings
to observe general and specific maintenance activities including balance of plant and preventive maintenance activities.
Several special inspections were performed by regional based inspectors.
i As a result of these inspections, five violations were-identified; three were Severity Level IV and two were Severity Level V.
The violations pertained mainly to lack of administrative control in the areas of inadequate procedures i
and failure to follow procedures. This item has been addressed in previous SALPs as a weakness and continues as a recurring problem.
During the previous assessment period, problems were identified
with excessive drywell temperatures. During this assessment
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period, the licensee had taken more comprehensive corrective measures to reduce the drywell temperatures to acceptable levels and the licensee is continuing an improved drywell temperature monitoring program. One violation was issued concerning failure to follow procedures with respect to drywell temperature monitoring. The licensee took appropriate corrective actions and was responsive to NRC concerns.
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An in-depth NRC assessment of maintenance activities that
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was prompted by the relatively large number of maintenance related Licensee Event Reports (LERs) in the previous assessment period was conducted.
From this assessment, the NRC concluded that corrective measures were required to reduce the work request backlog, improve the Preventive Maintenance (PM) program, and fully develop the maintenance history program.
Also, the NRC concluded that the relative inexperience of maintenance personnel, lack of effective engineering and
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maintenance management support, and inadequate maintenance
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programs have contributed significantly to the observed maintenance problems at the LaSalle Station.
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During a meeting at Region III in May 1986, licensee personnel-
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These included. actions to' improve support of. maintenance-activities; development of.a system to give an accurate-account and status of work requests; expansion of the PM
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program; implementation of a task specific training program; conduct of various information, planning and briefing meetings;
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increased supervision in the field; conversion of routinely _
used work instructions (Figure 9s) into approved. procedures; implementation of the maintenance-history program; and continued revision of surveillance procedures.;
A followup inspection was conducted in July 1986, which verified that the~ proposed corrective actions were being implemented.
Improvements were noted, especially in the-communications between operations and maintenance department personnel and in the engineering _ support area.
- There were a total.of 29 LERs identified in this functional area.. There were several LERs referencing unqualified electrical terminations or splices. The licensee's Environmental Qualification (EQ) program failed to identify this problem. Subsequent testing and/or repairs corrected-
'the unqualified terminations and splices identified. Another LER dealt with a reactor scram due to inadequate control of the feedwater regulating valve instrumentation. This subject was addressed in the licensee's response to the 50.54(f) letter discussed in Section IV.I of this report.
In regard to the licensee's performance in the Environmental Qualification (EQ) area, the inspector found the licensee's approach to the resolution of technical issues to be technically sound and thorough, with a clear understanding of issues, and with conservatism routir ely exhibited in the resolutions. Records were complete, well maintained, and
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available. Events were promptly and accurately reported with i
timely resolution of issues. Staffing and training was l
adequate. The only problem identified wa: that the licensee's
review program was not adequate in ident,Jying everything
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needed for environment qualification (i.e., the electrical
terminal connections mentioned previously).
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In the previous assessment the Category 3 rating was based
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mainly on the large number of violations (13 violations) and the significance of the Licensee Event Reports (LERs) issued.
Many of these violations and LERs were the result of the l
modification program which was included in this functional
area for SALP 5 and is included in the Outage functional area j
for this assessment. However, many of the problems outside of the modifications, excluding the issues identified above, did r
not repeat themselves during this assessment period such as poor
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communications and personnel error which resulted in scrams
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or unnecessary Engineered Safety Features (ESF) actuations-during the previous. assessment period. Management involvement
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In general, the licensee's overall performance of maintenance
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activities was well executed, technically sound, with problems
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._ Conclusion
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The licensee is rated a Category-2 in this area. The licensee
was rated Category 3 in the last SALP where modifications were included in this-functional area. The improved rating is due to the change in the scope of this functional area and management's involvement to prevent the majority of the problems identified in the previous assessment from recurring.
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Board Recommendations
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Surveillance 1.
Analysis-
This functional area was under continuous review by the resident Linspectors during the assessment period concentrating on implementation of procedures. Two special inspections were conducted by regional based inspectors.
Enforcement history improved durin Seven violations were identified '(g this assessment period.
six Severity Level IV and one Severity Level V) compared to thirteen violations identified during the previous assessment period (eight Severity Level IV and five Severity Level V). Failure to follow required procedures contributed to the majority of the violations identified during this assessment period. While the individual violations were of minor safety significance and the licensee's proposed corrective actions were adequate, the licensee's efforts to implement these actions have not been totally effective.
Most noteworthy of the remaining violations were those involving the licensee's continued failure to properly implement the requirements of Section XI of the ASME Code for inservice testing. During the last assessment period, untimely engineering evaluations of test data and deficiencies in the administrative procedures governing inservice testing practices were identified as a significant concern. Although the licensee has revised their administrative controls, there is
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i still evidence that inservice test data evaluations are not being properly conducted. As examples: on one occasion the licensee unknowingly entered an LCO due to inadequate review of available. test data; on an other occasion:the licensee placed-the plant into'a condition where one division of ECCS was required when sufficient test data to support an operability
' determination did not exist. The root cause of the violations was the' licensee's inadequate implementation of corrective actions taken in response to concerns identified during the previous assessment period.
While ~ involving only one violation,- improper verification of equipment status occurred at least four times. Although the individual occurrences were of minor safety significance, the recurrence of this problem throughout the assessment period indicates management involvement in assuring quality,has been-less than totally effective.
Additional problems in the area'of surveillance were noted in the fire protection program and are discussed under the functional area of Fire Protection / Housekeeping.
In contrast to the. specific problems identified above, management's involvement in assuring quality when considering the overall surveillance program has been particularly evident.
Since the previous assessment period, there has been.a noticeable reduction in the number of Engineered Safety Features actuations (3 versus 19), LERs related to personnel errors (8 versus 43), and missed surveillances (5 versus 23).
As indicated above, licensee performance has improved significantly when considering the thousands of surveillances conducted.
The licensee's handling of the Static-0-Ring (SOR) differential pressure switch problem is worthy of special note:
In June 1986, licensee management became involved in a problem with surveillance of reactor water level switches in the plant (SOR differential pressure switches). The licensee's approach to resolving this problem was considered to be safe and aggressive. Management'became deeply involved p
at the site and at their corporate office to assure a compre-F hensive answer to the problem was developed. The licensee was i
very responsive to NRC initiatives as evidenced in telephone
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conversations, in meetings with the NRC both in Washington i
D.C. and at the site, and in promptly providing information U
requested. They were very open and agreeable to performing j
special testing of systems to assure the problem was identified i.
and adequately addressed. The licensee's response and corrective
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action were thorough and conservative. The licensees j.
interface with the NRC was professional.
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C,onclusion The licensee is rated Category 2 in this functional area, an improvement from the Category 3 rating in the last SALP. The
improved rating is based on the significant reduction in the number of missed surveillances, personnel errors, and ESF actuations.
It is noted, however, that in the area of inservice testing, the licensee had been unable to correct problems identified during the pervious SALP period.
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Board Recommendations The Board notes that there is a i.eed for greater management attention to the inservice testing program regarding test data evaluation and documentation.
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Fire Protection / Housekeeping 1.
Analysis This functional area was under continuous review by the resident inspectors during the assessment period and one regional inspection was also conducted.
Enforcement history remained about the same during this assessment period. One violation was identified (Severity Level IV) compared to one violation (Severity Level V)
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identified during the previous assessment period. The Severity Level IV violation was identified for failure to install fire detection and alarm systems in accordance with governing code requirements. The licensee's written response to the violation is still under review to determine acceptability.
Licensee management's controls over surveillance testing for fire protection were not as extensive as they should have been. This resulted in a missed surveillance test of some hose stations due to an individual going on vacation. Also a fire door surveillance was being controlled by a Security Post Order which did not receive the same level of review as other surveillance procedures (i.e., the fire marshal or technical staff supervisor) to assure the actions to be taken were adequate.
Only two Licensee Event Reports were issued in this functional
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area. One was for the missed surveillance on hose stations and one for a reactor scram caused by a stationman, while cleaning the plant.
This was a reduction from the previous assessment period when six LERs were issued.
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o During the extended Unit 1 outage which began in October 1985, and ended in September 1986, the overall housekeeping of the plant deteriorated.
During the Operational Team Inspection conducted between September 29 and October 3, 1986, team members spent significant time in the plant assessing not only operational activities, but housekeeping and material conditions as well. The team concluded that, while the plant appeared acceptable in general, closer examination revealed numerous housekeeping and minor material deficiencies.
Furthermore, the team concluded that the licensee's threshold for acceptability of minor deficiencies and housekeeping items was too high and that a sense of account-ability and pride in ownership were lacking. This finding was based on direct observation of plant personnel who did not generally identify or pursue such items aggressively and the apparent long-standing nature of some of the items.
Immediately after the completion of the outage, the licensee management commenced an aggressive program of cleaning, stripping floors, painting, relabeling, and stenciling to return the plant to a clean condition. The station management in a daily meeting receives a report as to where the painting was being accomplished. During the assessment period and even during the outage, the licensee was able to continue a steady cleanup program to recapture contaminated areas such that from January 1986 to the end of this assessment period, the licensee reduced the amount of contaminated area in the
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plant from 315,000 sq. ft. to 230,000 sq. ft. Total accessible '
area contamination was reduced from 140,000 sq. ft. to 25,000 sq. ft. over the same period.
While this is a considerable improvement, the amount of contaminated area in the plant remains high. This aggressive management approach to house-keeping was also considered a good response to NRC initiatives in the area of plant housekeeping.
The attention of management to make the plant not only clean, but also a safe environment, was demonstrated by the painting of yellow barriers where people may trip or injure themselves.
During the assessment period, the licensee replaced the fire marshal with an individual with a broader background in fire protection programs.
The new staff for fire protection appeared to be competent and willing to address fire protection problems.
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Conclusion The licensee is rated Category 2 in this functional area.
The licensee was rated Category 1 in the last SALP.
The decline in the rating is due to the degradation of management control over surveillance testing and the lack of aggressiveness in
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resolving long standing minor deficiencies and housekeeping items.
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Board Recommendations None F.
Analysis Two inspections were conducted during the assessment period.
The staff also monitored the licensee's responses to offsite emergency planning concerns expressed by some local government officials.
Enforcement history remained about the same as during the previous assessment period. One violation was identified (Severity Level V described below) compared to one violation (also a Severity Level V) identified during the previous assessment period.
Management involvement and control in assuring quality has generally been adequate.
Independent audits of the program were adequate in scope, depth, and frequency. Auditor followup on corrective actions was adequate. Credit was taken for three surveillances of the emergency preparedness program during 1985; however, two of the three were primarily surveillances of the station's health physics and fire protection programs which also had some emergency preparedness implications. The Station's emergency planning coordinator had improved the record keeping of emergency preparedness drills and documentation of associated corrective actions.
All periodic emergency communications tests and emergency supply inventories had been conducted and adequately documented. However, a Severity Level V violation was issued as a result of a repeated inability to issue quarterly updates of an emergency responders call-out procedure in a timely manner.
Cor) orate emergency planning staff has typically interfaced wit 1 the station on the annual exercise, certain drills, offsite support agency training sessions, and on revisions to the emergency plan. During mid-1986, corporate and station management exhibited proper concern and responsiveness in addressing issues raised by several local government officials regarding the adequacy of offsite emergency planning.
The licensee met as needed with NRC, FEMA, and local government officials to better define the issues. The licensee interacted with a)propriate officials to improve working relationships and to sec( mutually acceptable solutions to identified problems.
.-
.
During the 1986 exercise, 4 ftems requiring corrective action and 18 improvement items were identified. The items related to the performances of both station and corporate staffs.
The licensee's proposed corrective measures were acceptable.
Fourteen emergency plan activations, which took place before or early in this assessment period, were examined during the routine inspection and determined to have been correctly classified. Subsequent notifications were completed in a timely manner. Of the three activations which occurred later in the assessment period, the only one examined in detail was the June 1, 1986, potential ATWS.
The licensee took some very conservative actions in responding to this event and met all regulatory requirements involving notifications once the event had finally been classified as an Alert. However, it would have been more prudent for the licensee to have made an earlier, courtesy call to the NRC Operations Center to inform the Duty Officer that a transient had taken place, which was being thoroughly evaluated by the station senior technical staff.
The licensee has maintained a prioritized roster of qualified personnel to fill well-defined, key positions in the onsite emergency organization. The licensee conducted several successful off-hours augmentation drills. However, it was noted that several dedicated callers had not utilized the current callout procedure revisions during the drills. The licensee has demonstrated some improvements in promptly adding newly trained personnel to replace persons whose roles in the onsite emergency organization had clanged.
Based on walkthroughs and reviews of lesson plans and examinations, the licensee has improved upon the training given to key members of the onsite emergency organization.
Specialized training consisting of required readings and classroom lectures was conducted. Training records were complete and well maintained. However, based on the large number of items identified during the 1986 exercise for which additional training was deemed the appropriate corrective action, additional emphasis on drills is necessary to supplement classroom training and required readings.
2.
Conclusion The licensee is rated Category 2 in this area.
The licensee was rated Category 2 in the last SALP.
3.
Board Recommendations None
_.. _ _.
_
.
G.
Security 1.
Analysis Six routine and reactive inspections were conducted by region based physical security inspectors during the assessment period. Additionally, the resident inspectors conducted routine periodic security inspections of a limited scope.
Five Severity Level IV violations were identified during the inspection efforts. All of the violations occurred within the last quarter of the assessment period.
Four violations were noted in the previous 17 month SALP period.
Difficulty in implementation of compensatory measures and failure to properly i
report a security event were noted in the previous SALP assessment. These two areas continue to warrant increased security management c,ttention. Three of the five violations noted during this period pertained to compensatory measures or security event reporting. One violation pertained to an alarm assessment and the remaining violation pertained to protection of safeguards information.
Two inspections pertained to allegations received by NRC Region !!!. One allegation addressed perceived weaknesses in the licensee's personnel security screening program and it's fitness for duty program. The NRC inspection concluded that the personnel security screening and fitness for duty programs for contractor personnel were adequate. The licensee's investigation results regarding the fitness for duty program were also determined to be adequate. The other allegation pertained to reduced security force effectiveness i
because of excessive work hours. The NRC inspection concluded
'
that some security force members have worked excessive hours at times, but overall effectiveness had not decreased in reference to security plan compliance.
Security management has developed an effective evaluation policy for personnel working in excess of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Eleven security events have been reported during this assessment period. This compares to 10 security event reports submittedduringthepreviousSALPperiod(17 months). Seven of the 11 security events were equipment related, 3 of the security events were caused by personnel error and 1 event report pertained to a bomb threat. With the exception of 1 event, the licensee has generally reported security events in a timely manner. The security event reports lack detailed information and can be improved, but this is compensated for by close liaison and frequent information updates to Region
!!! by the security management staff.
The total number of security event reports is not considered excessive, but can be improved.
. _ _ _ _ _ _ _ _ _ _,
a o
The previous SALP report was critical of security management's lack of consistent recognition of the significance of security events and responsiveness to certain NRC concerns. This issue has been resolved. Security management has been very responsive to NRC concerns, has conducted detailed inquiries pertaining to violations, and consistently provides aggressive and timely actions to resolve noted problem areas.
There are no unresolved security issues.
The contract security force's effectiveness has significantly declined. This represents an adverse trend during the assessment period. All but one of the violations noted during this assessment period were attributed, in part, to the security force's performance. Although the two incidents pertaining to breached security barriers were not directly caused by the security force, their actions upon detecting the defective barriers were inadequate and resulted in violations.
Additionally, some Safeguards Information possessed by the contract security force was not adequately secured while unattended. A management meeting pertaining to this adverse trend was held in August 1986. Continued aggressive management attention is warranted to correct this adverse trend.
Staffing levels for the contract security force have remained constant during this assessment period. The inspectors noted the need for security management to monitor occasions of double shift work conditions to assure continued effectiveness of personnel involved. This issue has subsequently been resolved.
Training effectiveness and qualification of the security force is acceptable. Procedural guidance is generally adequate and day-to-day supervision of security force performance is adequate, except for the July 1986 period, when three violations involving the security force were cited.
Maintenance support for security equipment has generally been excellent; however, several similar incidents relating to the security radio system have occurred during this assessment period. This issue remained open at the end of the assessment period and requires final resolution by the licensee.
An alternate alarm monitoring system still requires acceptance testing and formal implementation. The assessment system upgrade and preventive maintenance program should continue to receive senior plant management support. New search equipment has been installed during this assessment period and the existing special search equipment represents modern design and is well maintained. Working facilities for the security force are adequate and housekeeping is generally acceptable.
The corporate security department continues to provide excellent support to site security operations. Corporate and
,
- _- __ _ _- -. _,
.
,
.M site security managers closely monitor inspection findings,
-
coordinate investigative actions, and address licensing issues
>
in a timely and effective manner. Close liaison exists between the site, corporate security department, and NRC Region III.
2.
Conclusion
,
,
The licensee is rated Category 2 in this area, but the
,
performance trend is declining, primarily because of the
,
contract security force performance in the latter part of the assessment period which contributed to three violations cited during this assessment period. The licensee was rated Category 2 in the last SALP.
3.
Board Recommendations Increased licensee management attention and NRC inspection effort should continue in the security area until the contract security force performance is determined to be stable.
H.
Outages 1.
Analysis This functional area was under continuous review by the resident inspectors. Unit 1 started its first refueling outage on October 18, 1985, and ended on September 17, 1986.
There were two special inspections conducted in the area
,
of modification preparation and post modification testing.
The outage included the performance of approximately 140 modifications and approximately 2675 work requests.
- '
In the area of modifications, improvements were found in the testing methodology and thoroughness of the test result reviews. The licensee had developed a review process similar to the review process used during preoperational testing.
As a result of problems in the modification area discussed in SALP 5, the licensee hired an outside contractor to review and evaluate completed post modification testing and the licensee's testing program.
The major recomendations of the review team were already being implemented, as these items had been previously identified as weaknesses in the program.
There were two Severity Level IV violations issued during the refueling activity. One for failure to follow Technical Specifications requiring a Source Range Monitor (SRM) to be inserted into the core during fuel movements, and a second for failure to follow procedures resulting in a wrong fuel bundle being loaded into the core.
Both of these violations could have been prevented if personnel had adhered to written procedures.
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. - - - - - - - - - -
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Although the licensee had a planning group working on outages
,
,
'
in late 1985. the establishment of a senior management position c
r
-
for outage plaaning did not occur until the first part of 1986, hx I
f, two months 'after the first refueling outage started. Also, the licenseo did not sufficiently increase the staffing in the
'
' technical and work force in preparation for this outage such
5that each delay had an increased effect.
-
,
'
/ The licensee had not planned or anticipated the manpower r.eeded for the increased maintenance and inspections of the
'
linaltorque operators and the removal of interferences for perfarming Induction Heating Stress Improvement (IHSI)
activities. Also, due to the drawing documentation problem
",
identified in the modification program and addressed in the
'
,
,
'
pre.vious SALP, the licensee, late in 1985, called back several
'
,
of the major modifications to incorporate Field Change Requests (FCR's) into drawings before the modification began, to prevent
,'
"
a similar problem from recurring. Sufficient resources were not allotted for this work in the outage planning to provide an increase in technical support or field workers to help prevent the delays in the outage. Also, three of the major
..
-
modifications (containment ventilation replacement, scram discharge vent and drains modification, and drywell cooler modification) did not have sufficient engineering design support either at the site or at the corporate office to prevent delays in their completion.
,
'
The Unit I refueling outage extended beyond the scheduled
-
'
return to service date due to a number of unanticipated problems including:
problems associated with proper wiring and
-
lubrication of limitorque operators; identification of problems
'
with Static-0-Ring differential pressure switches and RayChem
.
'
splicos; and an unanticipated high number of snubber failures.
,
These problems demanded a large quantity of resources that r
resulted 'In significant delays.
The licensee has taken the lessons learned from the first Unit I refueling outage and has factored them into the upcoming first Unit 2 refueling outage to prevent recurrence of similar problems.
The licensee, prior to startup of Unit 1, did extensive testing of safety and balance of plant equipment to minimize the identification of failures during the startup. Alsc, for the startup on Unit 2 in August 1986, and the starcup on Unit 1 in September 1986, the licensee increased shift manning and the corporate overview such that both restarts were performed extremely well.
r
'
o 2.-
Conclusion The licensee-is rated Category 2 in this area. This area was not assessed during the last SALP because a refueling outage had not occurred.
3.
Board Recommendations None I.
Quality Programs and Administrative Controls Affecting Quality I '.
Analysis i
The assessment of administrative controls affecting quality was reviewed during routine inspections by resident inspectors.
Enforcement history improved in this area during the assessment period.
No violations were identified. Two violations (one Severity Level IV and one Severity Level V) were identified during the previous assessment period.
Licensee management took effective action on many of the weaknesses in administrative controls identified in the previous SALP. This was most noticeable in the modification package preparation and post modification testing, where earlier prcblems had resulted in a Severity Level III violation identified in the Maintenance / Modifications functional area during the previous assessment period. The licensee also increased its engineering support for modification preparation which was a benefit to site performance in the modification program. Unlike previous startups, no major problems associated with modifications were identified during and subsequent to the Unit i refueling outage startup.
Early in the assessment period, the administrative controls for review of modifications failed when, in one modification package, all parties verified that the post maintenance surveillance test was performed satisfactorily.
In fact, l
only a functional test was performed, which caused a switch to be left with an improper trip setpoint.
In another case, the licensee's review of a completed modification package did not identify that three Environmentally Qualified (EQ) switches, required by the modification, had not been installed. However, the station did get verbal Station Nuclear Engineering Division
(SNED) approval not to install the three switches, but did not l
receive followup written documentation. After Unit 2 was
!
returned to power, the lack of documentation was discovered,
!
and subsequent reanalysis by SNED determined that the installed switches were satisfactory. This should have been resolved during the review prior to returning the unit to power. The licensee, in the latter case, implemented a program which prevented similar problems during the Unit 1 outage.
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IAnother area where administrative controls were not effective was independent verification of valve positions. On four occasions the-licensee found valves which had been independently' verified to be correct, but were in fact, in.
the. wrong position. The specific examples.did not have
-
u.
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significant safety inpact, but represented a weakness in the licensees implementation of the independent verification program.
Because of a series of ongoing problems, which the_LaSalle station.had experienced during the previous SALP period, the-NRC-. issued al letter to the licensee pursuant to 10 CFR 50.54(f)~
on November-22, 1985, identifying the areas of concern and requiring a response describing the company's planned corrective actions.
-The. licensee's response described a corrective action plan to
,
strengthen management control of LaSalle operations.
Included in this' program were increased corporate management oversight, more extensive event review to determine root causes of problems, and monthly management meetings with Region III to discuss progress in attaining improved levels of performance.
The administrative controls established as a result of the 50.54(f) letter resulted in' improvements in the overall-i.
operation'of the facility, as evidenced by a reduction in
!
the total number of outstanding control room work requests,
procedure changes, and modifications which were identified-as weaknesses _during the previous assessment period.
Additionally, to support Units 1 and 2 return to service
!
'
activities, the licensee developed and implemented a-restart-program' including increased management and bargaining unit
,
L personnel present on shift, increased' plant performance reviews, and increased pre-startup support equipment testing.
i While the restarts were not error free, both units were restarted with few errors and without any unanticipated scrams. Based on the success at LaSalle, similar restart programs are being implemented at other Commonwealth Edison facilities.
i Other management programs such as Action Item Record, Licensee Event Reports, and Deviations, appeared to be effective, well
-
defined, and followed without problems.
2.
Conclusion
'
The licensee is rated Category 2 in this area. The licensee was rated Category 3 in the last SALP. The improved rating is based on the effective actions management has taken pertaining to administrative controls and increased engineering support and the general improvements described L
in the licensee's response to the 50.54(f) letter.
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=
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3.
Board Recommendations None J.
Training and Qualification Effectiveness 1.
Analysis Evaluation of this functional area is based on parts of inspections by resident and regional. inspectors.
In addition, an in-depth inspection of the licensee's training programs for both licensed and non-licensed personnel was performed by Region III specialists. The in-depth inspection consisted of evaluating whether lessons learned from recent events and past occurrences were appropriately factored'into training programs.
No violations were identified.
Management personnel were cognizant of the status and content of the training programs. Administrative procedures addressing plant modifications were routed to the training supervisor to ensure that the training department was kept informed of changing plant conditions.
Procedures and department practices were appropriately documented and pertinent records revealed that these procedures were followed.
The licensee's training staff failed to perform a followup debriefing session on the problems identified during the
.
observation of a trainee's performance. Examples where operations discussed licensed operator training needs were observed, however, no documentation of requests for additional training or topic emphasis from operations was found.
Although several methods to quickly disseminate information regarding recent events were apparent, and those trainees who had not received such training were identified, there was no evidence that the licensee had a method to ensure that trainees have been trained prior to performing tasks on new or modified equipment.
The training staff is generally adequate but was observed to be somewhat overloaded with work activities. This may be due, in part, to preparation of the self evaluation reports for submittal to the Institute of Nuclear Power Operations (INP0) for accreditation review.
The licensee's training program being) developed for experienced Radiation / Chemistry Technicians (RCTs will include an annual two week program emphasizing chemistry practices on new instruments.
This will be implemented in early 1987. Current training for new RCTs appears adequate and includes a formal 14-week course at the Braidwood Production Training Center and a six month on-the-job training program.
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The' licensee received INP0 accreditation for Senior Reactor Operator, Reactor Operator, and non-licensed operators in the latter_part of 1985.
The licensee also was reviewed by.INP0 for-the remainder of.
their._ training accreditation program in the latter part of the assessment period and received only four findings, which were the least number for a full. accreditation program so far. -The licensee expects to receive INP0 accreditation of -
their; remaining program shortly.
Inadequate training of personnel could rarely be traced as a root cause of events or problems identified in the other SALP functional areas during this assessment.
2.
Conclusion The licensee is rated Category 2 in this functional area.
-The licensee was not rated during the last SALP.
3.
Board Recommendation None
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I K.
Licensing Activities 1.
Analysis This assessment is based on our evaluation of the licensee's
= performance in support of licensing actions which had a
.
significant level of activity during the assessment period.
i These actions included the licensee request for license amendments, responses to generic letters, and various
.
submittals of Information for multi-plant and NUREG-0737
!
actions. A total of 63 licensing actions were completed.
There were evidence'of planning and assignment of priorities and decision making which seemed to be at a level that ensures
'
adequate management review. Management within CECO was
.
accessible which facilitated the reviews. As presented above,
[
there have been a significant number of licensing actions processed. :For the most part, the management of this activity
!.
by the licensee assured completion in a timely manner. This was also demonstrated in that there was only one emergency amendment as compared to three during the last assessment i-period. The first refueling outage for Unit I was for a long duration due to problems of snubbers and switches and the replacement of qualified equipment.
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Effective communication between the licensee and NRC is good.
One area where management attention could be increased is in the screening of amendment requests to assure that they provide sufficient discussion of the safety consequences and/or reason for the proposed changes.
In addition, there needs to be some assurance that the packages submitted includes the right information.
In general, the licensee had a good understanding of the technical and safety issues and the proposed resolutions have been conservative and sound. However, in submittals for Technical Specifications changes, sometimes sufficient information was not provided in the discussion of the safety consequences and the reasons for the change. As a result, some time and effort was required in order to arrive at an acceptable resolution.
Overall, however, the licensee performed well in this attribute and some improvement was indicated.
The licensee has maintained adequate licensing staff to assure, in the majority of time, timely responses to NRC needs, which were usually sound. CECO was aware of and sensitive to the needs of the staff to perform it's review function. The
. licensee was always ready to meet with the staff when such a meeting would assist in resolving issues. However, in the licensee's reload package and some of the licensee condition amendments, the inputs were transmitted somewhat late, which demonstrated inadequate planning. The new position of Assistant Superintendent for Work Planning in the organization may improve this area.
Most events at the facility were reported promptly and accurately.
2.
Conclusion t
The licensee is rated Category 2 in this area. The licensee
'
was rated Category 2 in the last SALP.
3.
Board Recommendations None
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V.
SUPPORTING DATA AND SUMMARIES A.
Licensee Activities 1.
Unit 1 During this assessment period, LaSalle Unit 1 entered it's first refueling outage on October 18, 1985, and remained in the refueling mode throughout most of the assessment period. Major activities completed during the refueling outage included the
.eempletion of the installation of environmentally qualified electrical equipment, testing of mechanical snubbers, inservice inspection, and Induction Heat Stress Improvement tIHSI) of primary system piping welds. Unit 1 initiated a startup after the prolonged refueling outage on September 17, 1986. The unit did not experience any forced outages.
,
The average unit availability during the assessment period was approximately 9.6%.
Four scrams were reported during this assessment period. All 4 occurred while the reactor was in cold shutdown. Three of these scrams were due to procedural inadequacies or personnel errors and I was due to mechanical /
equipment problems. Unit 1 experienced 23 Engineered Safety Features (ESF) actuations.
2.
Unit 2 During this assessment period, LaSalle Unit 2 availability was approximately 51.6%. The unit experienced 5 forced outages as summarized below:
a.
October 21, 1985 - December 22, 1985; Reactor scram caused by inadvertant steam-line isolation during an instrument surveillance. The unit remained shutdown for outage modification and environmental qualification work.
b.
March 2-5, 1986; Reactor was shutdown to repair a reactor water clean-up isolation valve.
c.
May 9-11, 1986; The reactor scrammed on low reactor water level following loss of Turbine Driven Reactor Feed Pump control power. The unit remained shutdown to investigate the cause of the scram, d.
May 11-24, 1986; The reactor scrammed following main steam line isolation on high steam line flow.
The unit remained i
shutdown to investigate the cause of the scram.
e.
June 1, 1986 - August 8, 1986; The reactor was shutdown to L
resolve problems with static-o-ring reactor differential pressure switches.
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Six scrams were reported for Unit 2.
Two of the scrams were related to procedure inadequacies or personnel errors, I was related to equipment problems, I was attributable to a transmission line problem, and 2 were related to other or unknown causes. Unit 2 experienced 10 Engineered Safety Features actuations.
B.
Inspection Activities There were 49 inspections conducted during this assessment period, October 1, 1985 through November 15, 1986. Major or significant inspection activities are listed in Paragraph 2 of this Section, Special Inspection Summary.
1.
Inspection Data Facility Name: LaSalle Unit:
Inspection Reports Nos.: 85001, 85028, 85032 through 85040, 86001 through 86008, and 86010 through 86038.
Facility Name: LaSalle Unit: 2 Inspection Reports Nos.: 85001, 85029, 85033 through 85037, 85039 through 85041, 86001 through 86009, 86011 through 86014, 86016 through 86020, and 86022 through 86038.
Table 1 Number of Violations in Each Severity Level Common to Unit 1 Unit 2 Both Functional Areas I II III IV V I II III IV V I II III IV V A.
Plant Operations
6
B.
Radiological Controls
C.
Maintenance
1 1 2 D.
Surveillance
4 E.
Fire Protection /
Housekeeping F.
G.
Security
H.
Outages
I.
Quality Programs and Adminis. Controls Affecting Quality J.
Training & Qualification Effectiveness K.
Licensing Activities TOTAL I II III IV V I II III IV V I II III IV V
1
17 3
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2.-
Special Inspection Summary January 29, 1986 - Special Radiological Environmental Monitoring _ Program (REMP) inspection was conducted (50-373/86005;50-374/86006).
March 27, 1986 - Special inspection of the licensee's Inservice Inspection (ISI) of snubbers (50-373/86010).
June 2, 1986 - Augmented Investigation Team (AIT) to evaluate the June 1, 1986, loss of feedwater and failure to scram event.
C.
Investigations and Allegation Review Four allegations relating to LaSalle consisting of eight concerns were received in Region III during this assessment period. Two of the four allegations remained open at the end of the assessment period and will be reviewed by Region III in the'near future.
D.
Escalated Enforcement Actions One Civil Penalty in the amount of $50,000 was issued during this assessment period for a violations involving an inoperable Emergency Core Cooling System. The Notice of Violation was
' issued March 19, 1986.
,
E.
Licensee / Conferences Held During the Assessment Period 1.
October 29, 1985 - Enforcement conference to discuss the dry-well high temperature issues at Lasalle.
l 2.
December-4, 1985 - Enforcement conference to discuss the event where two divisions of Emergency Core Cooling Systems (ECCS) were out-of-service at the same time while at 100%
j-power.
!
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3.
January 15, 1986 Management meeting to discuss the
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!
licensee's initial response to the 50.54(f) letter, dated November 22, 1985, concerning poor plant performance, management, maintenance programs, etc. The meeting resulted in a number of clarifications to Comonwealth Edison Company's
,
i initial response and a resubmittal of the response to the 50.54(f).
Subsequent meetings as indicated below were held to discuss the licensee's progress in implementing the commitments made in response to the 50.54(f) letter.
l 4.
February 18, 1986 - Management meeting to discuss the SALP 5 i
results and 50.54(f) letter as described above.
i
5.
March 19, 1986 - Management meeting to discuss deficiencies
identified during snubber functional testing.
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-6.
March 21, 1986 Management meeting to discuss the status of
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corrective actions taken in response to the 50.54(f) letter-as described above.
7.
April 30, 1986 Management meeting to discuss the status of
-
corrective actions taken in response to the 50.54(f). letter as described above.
8.
May 12, 1986 - Enforcement conference to discuss an event in which a Nuclear Station Operator (NS0) entered the initials of an Equipment Attendant (EA) on a checklist thereby certifying that a second verification of the position of a motor operated valve breaker had been performed.
9.
May 28, 1986
' Management meeting to discuss the Maintenance Assessment Program.
10. June 13, 1986 Management meeting to discuss the status of
-
corrective actions which were taken in response to the 50.54(f)
letter as described above.
11. June 20, 1986 Management meeting to discuss the licensee's
-
planned management changes at LaSalle Nuclear Power Station.
12. June 23,1986 Management meeting to discuss problems with
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static-o-ring switches.
13. July 9,1986 Management meeting to discuss the status of
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actions with regard to the June 1, 1986, feedwater transient as set forth in the Confirmatory Action Letter dated June 2,1986.
14. July 12, 1986 A management meeting was held to discuss
-
offsite emergency planning issues related to the LaSalle Station.
15. July 18, 1986 Management meeting in Headquarters to discuss
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Static-0-Ring switches and actions taken concerning these switches at LaSalle. These switches were the suspected cause of the failure to scram on June 1, 1986.
16. July 22, 1986 Management meeting with the Mayor of Seneca
-
to discuss his concerns relative to emergency planning and other issues associated with the LaSalle Nuclear Power Station.
17. August 5, 1986 - Management meeting to discuss the status of corrective actions which are being taken in response to the 50.54(f) letter and to discuss corrective actions taken with regard to personnel errors.
18. August 13, 1986 - Management meeting to discuss security violations noted during an inspection conducted between July 28 and August 1,1986, and to discuss the security force j
poor performance trend.
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, 3.; e
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Confirmatory Action Letters.(CALs)-
- F.
a.
June.2,'1986~, CAL-RIII-86-003, relates to improper response of the Reactor Protection System (RPS) on June 1, 1986. An Augmented Investigation Team (AIT) was implemented to evaluate the root cause and significance of the event.
b.
June 19,.1986, CAL-RIII-86-004, referenced Enforcement Conference held May 12, 1986, related to concerns over the
"
event in which the Nuclear. Station Operator.(NS0) entered the
~
initials of an' Equipment Attendant (EA) on a. checklist and certified that a second verification of the position of a
.
motor operated valve breaker had been performed. As a result
"
of the NS0's action, the second verification was not performed.
- G.
A Review of Licensee Event Reports, and 10 CFR 21' Reports Submitted by the Licensee 1.
Licensee Event Reports (LERs)
,
LERs. issued during the-13 1/2 month SALP 6 period are presented-below:
LaSalle Unit 1 i
Docket No.:
50-373
'
LER Nos.~: 85063 through 85064
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85066 through 85069 86001 through 86039
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LaSalle Unit 2 Docket No.:
50-374 LER No.s: 85042 through 85048 86001 through 86017
,
j.
(17 mo)
'(13 1/2 mo)
l Proximate Cause Code SALP 5 SALP 6 i
Personnel Error (A)
26
[
Design Deficiency)(B)
7 External Cause (C
0
Procedure Inadequacy (D)
8 Management Quality Assurance Deficiency (E)
0 1-
Others (X)
136
Total ET
NOTE: The above information was derived from reviews of Licensee Event Reports performed by NRC Staff and may not completely coincide with the unit or cause assignments which the licensee would make.
In i
addition, this table is based on assigning one cause code for each LER and does not necessarily correspond i
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. -
,.a
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to the identification of LERs addressed in the Performance Analysis Section (Section IV) where multiple cause codes may be assigned to each LER.
There were 252 LERs issued during SALP 5 for an average of 15 per month. During SALP 6 there were 70 LERs issued for an
- average of 5.2 per month. During SALP 5 sixty-two LERs, 3.6 per month, were designated as caused by personnel error.
During SALP 6 twenty-six LERs, 1.9 per month, were designated as caused by personnel error. The reduction in overall LERs and the reduction in personnel errors is indicative of an improving trend. However, the types and repetitive nature of the LERs are of concern. This is further discussed in Section IV of this. report.
2.
Analysis and Evaluation of Operational Data (AE0D)
The Office of Analysis and Evalu$ tion of Operational Data (AE0D) reviewed the LERs for this period and concluded that overall, as compared to reports from other facilities, the reports for this assessment period were above average and of very high quality. This is a significant improvement over SALP 5 in which the. reports were considered average; however, some minor weaknesses were identified. A copy of the AEOD report has been provided to the licensee so that the specific deficiencies noted can be addressed in future reports.
3.
10 CFR 21 Reports No 10 CFR 21 Reports were submitted during the assessment period.
H.
Licensing Activities 1.
NRR Site Visits /Mtgs/ Licensee Management Conferences January 21, 1986
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Discussion of Licensing Issues
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March 25-26,1986
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Plant Orientation June 4-6, 1986
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Detail Control Room Design
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j Meeting June 12, 1986 Static-0-Ping (SOR) Switches
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2.
Commission Meetings
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None.
3.
Schedule Extensions Granted October 1, 1985 Surveillance Extension
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..-. -
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,.-6 4.
-Reliefs Granted November 13, 1985 Relief of Surveillance
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Requirements 5.
Exemptions Granted None 6.
License Amendments Issued Unit 1 Amendment No. 24 Extension on (one-time-only basis) a limited number of the surveillance requirements in the Technical Specifications.
Amendment No. 25 Extension on (one-time-only waiver)
the 18-month Diesel Generator interval surveillance requirement.
Amendment No. 26 To incorporate numerous Technical Specification changes.
Amendment No. 27 To incorporate the instruments for the suppression pool water level and water temperature monitoring instrumentation at the remote shutdown panel.
Amendment No. 28 To revise the setpoints and setpoint tolerances for the 18 safety-relief valves.
Amendment No. 29 To incorporate the modification
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of the automatic depressurization system logic.
l Amendment No. 30 To revise the Technical
,
Specifications with respect to the l
Average Power Range monitor gain adjustment to allow time to correct calibrations.
Amendment No. 31 To remove the air-operated testable-bypass-check valves installed in each of the emergency core cooling
,
i systems and the reactor core isolation cooling system.
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.6-
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Amendment No. 32 To allow up to four fuel bundles to be loaded around each Source Range Monitor with no minimum channel count
< rate requirements.'
Amendment No. 33 To incorporate the reactor scram on the low control rod drive pump discharge pressure modification.
Amendment No. 34 To add an excess flow check valve to the instrument line for the containment flood-up measurement system.
Amendment No. 35 To allow an alternate method for controlling access to high radiation areas.
Amendment No. 36 To change the Main Steam Line Low Pressure instrument response time from 1 to 2 seconds.
Amendment No. 37 To replace the eight 26-inch and two 8-inch vent and purge isolation valves with valves that meet all requirement for containment vent and
'
purge isolation valves.
Amendment No. 38 To eliminate the chlorine detector monitoring instrument system.
Amendment No. 39 To change the alarm calibration setpoint to greater than or equal to 940 psig instead of 940 psig +30,.-0 psig.
Amendment No. 40 To support operation at. full rated power during Cycle 2 operation.
Amendment No. 41 To incorporate a low and/or degraded grid voltage modification.
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Amendment No. 42 To add backup overload protection devices.
Amendment No. 43 To eliminate the requirements of NPDES violations and to terminate the iog and ice monitoring program.
Amendment No. 44 To add fire detector instrumentation in Zones 2C, 4C2, 3C, 4C3, and 6E to satisfy License Condition 2.C.(25)(c).
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. -
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_ _ _ _ _
- ?. 6 Amendment No. 45
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To add Rod Block Monitor Setpoints'for L
both dual.and single' loop operation.
Amendment No. 46 To change Reporting Requirements for iodine spiking.
Unit 2 Amendment.No. 13 Extension (one-time-only waiver)
of the 18 month Diesel Generator interval surveillance requirement.
Amendment No. 14 To inccrporate numerous Technical Specification changes.
Amendment No. 15 To revise the setpoints and setpoint tolerance for the 18 safety-relief valves.
Amendment No. 16 To provide relief by extending the present three-day or seven-day period to thirty days during which only three generators would be required.
Amendment No. 17 To revise the Technical Specifications with respect to the Average Power Range Monitor gain adjustment to allow time to correct calibration.
Amendment No. 18 To allow up to four fuel bundles to be loaded around each Source Range Monitor with no minimum channel count rate requirements.
Amendment No. 19 To allow alternate method for controlling access to high radiation areas.
Amendment No. 20 To eliminate the chlorine detector monitoring instrument system.
Amendment No. 21 To change the alarm calibration setpoint to greater than or equal to 940 psig instead of 940 psig +30, -0 psig.
,,. O
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Amendment No. 22 To incorporate a low and/or degraded grid voltage modification.
Amendment No. 23 To add backup overload protection devices.
Amendment No. 24 To eliminate the requirements of NPDES violations and to terminate the fog and ice monitoring program.
Amendment No. 25 To replace eight 26-inch and two 8-inch vent and purge isolation
valves.
Amendment No. 26 To incorporate the instruments for the suppression pool water level and water monitoring instrumentation at the remote shutdown panel.
-
Amendment No. 27-To incorporate the modification of the automatic depressurization system logic.
Amendment No. 28 To change Reporting Requirements for iodine spiking.
8.
Emergency Technical Specifications Granted September 26, 1986 Emergency Amendment No. 25 for
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Unit 1 and Amendment No. 13 for Unit 2.
9.
Orders Issued None i
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