IR 05000373/1989001

SALP Repts 50-373/89-01 & 50-374/89-01 for 880316 - 890630

ML20246J339
Person / Time
Site:	LaSalle
Issue date:	06/30/1989
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20246J324	List: IR 05000373/1989001 ML20246J321
References
50-373-89-01, 50-373-89-1, 50-374-89-01, 50-374-89-1, NUDOCS 8909050124
Download: ML20246J339 (33)

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. SALP 8 SALP BOARD REPORT

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U. S. NUCLEAR REGULATORY COMMISSION

. REGION-III SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-373/89001; 50-374/89001 Inspection Report Nos.

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Commonwealth Edison Company Name of Licensee L

l LaSalle County Nuclear Power Station - Units 1 & 2 Name of Facility l

l March 16, 1988, through June 30, 1989 Assessment Period I'

l 8909050124 890828 G PDR- ADOCK 05000373 te O PNU ! ,'-

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.. SUMMARY OF RESULTS Overview Overall, the licensee's performance was'found to be acceptable and improved since the previous SALP assessment period. Of the seven functional areas rated during this assessment period, licensee performance in three areas improved; Plant Operations from a Category 2 rating to a Category 1 rating,' Emergency Preparedness from a Category 2 rating with an' improving trend to a Category I rating, and Security from a Category 2 rating to a Category 2 rating with an improving trend. All of the remaining-functional areas received Category 2 rating The improved rating in Plant Operations was a result of the highly successful scram reduction program, extensive management involvement in the day-to-day. operations of the plant, and the demonstrated excellent performance of the Operations Department. Emergency Preparedness (EP) earned its Category I rating through improved staffing, management involvement and very good performance during the June 1988 EP exercise. Security demonstrated an improving trend by improved enforcement history and performance in handling security event The SALP board had difficulty rating the Radiological Controls area because of the very high station cumulative dose for 1988 and our uncertainty concerning the effectiveness of your ALARA program in limiting station cumulative dose. We based our rating upon our best judgement of your performance in this area, however, we expect to devote additional resources to evaluating the effectiveness of your ALARA program during the current SALP assessment perio The performance ratings during the previous assessment period and this assessment period according to functional areas are given below:

Rating Last Rating This Functional Area period Deriod Trend Plant Operations 2 1 Radiological Controls 2 2

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Maintenance / Surveillance 2/2 2 Emergency Preparedness 2 1 Security 2 2 Improving Engineering / Technical Support 2 2 Safety Assessment / Quality *NR 2 Verification

• NR = a new functional area that was not rated during the previous

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assessmen Other Areas of Interest Non _ _ _ _ _ _ _ _ _ _ _ - - - _ - _ _ _ - _ -

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j III. CRITERIA Licensee performance is assessed in selected functional areas. Functional areas normally represent areas significant to nuclear safety and the environment. Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observations. Special areas may be added to highlight significant observation The following evaluation criteria were used to' assess each functional area:

e - Assurance of quality, including management involvement and control;

, Approach to the resolution of technical issues from a safety standpoint; Responsiveness to NRC initiatives; Enforcement history; Operational events (including response to, analyses of, reporting of, and corrective actions for); Staffing (including management); and Effectiveness of training and qualification program.

3' However, the NRC is not limited to these criteria and others may have been used where appropriat On the basis of the NRC assessment, each functional area evaluated is rated according to three performance cataenries. The definitions of these performance categories are as fallows:

Category 1: Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requireraents. Licensee resources are ample and

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effectively used so that a high level of plant and personnel performance I

is being achieved. Reduced NRC attention may be appropriat Category 2: Licensee management attention to and involvement in the performance of nuclear safety or safeguard; activities are good. The licensee has attained a level of performance above that needed to meet regulatory requirements. Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being achieved. NRC attrntion may be maintained at normal level I

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. Category 3: Licensee management ~ attention to and involvement in the

. performance of nuclear-safety or safeguards activities'are not sufficient. .The 11censee's_ performance doer not significantly exceed-that _ needed' to meet minimal regulatory requirements. . Licensee.' resources appear to be strained or not effectively used. NRC attention should be increased above normal;.-level The MLP report may include an appraisat of-thc performance trend-i functional area for use as a predictive _ indicator if near-term performance is of interest. ' Licensee performance during the last quarter of the assessment period should be examined to determine whether a trend exist Normally, this performance trend should only_be used if both a definite

. trend is discernable and continuation of the trend may result in a change in performance ratin ,.

The trend, if used, is= defined as:

Improving: Licensee performance was determined to be improving near the close of the assessment perio Declining: Licensee performance was dettrmined to be declining near the close of the assessment period, and the licensee had not taken meaningful steps to address this patter A

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p ( IV.' ' PERFORMANCE ANALYSI . . plant Operations Analysis-Evaluation of this' functional area was based on the results of 11 routine,and 2 special inspections conducted by resident inspectors; regional inspectors, and NRR inspectors.

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~ Enforcement history.in this functional area declined slightly .

vt -from the previous-assessment period. A total of three1 Severity Level IV violations were identified in.this- functional area, compared with one Severity Level IV violation . identified in the previous assessment period. Two of the; violations arose fro failures of the control room operators to follow procedure The' third violation arose from a failure to report an engineered safety feature (ESF) actuation. In each of these'thpee cases, management aggressively reviewed each event and took immediate corrective action Scram history during this period showed a significant improvemen The licensee's outstanding implementation of the scram reduction program has been highly successful in correcting the root causes; of the automatic scrams experienced in the past. ~During this period, there was only one automatic scram with control rod motion' compared with nine automatic scrams with control rod motion identified in the previous assessment period,

-demonstrating.a significant improvement in this functional are .

The availability of both units also showed a significant improvement. The gross availability rate for Unit I was 73.7%

and 73.5% for. Unit 2. By contrast, the availability rates 'in the previous assessment period were 55.1% for Unit 1.and 56.9%

for Unit 2. The major impact on the availability rate was a 17-week refueling / modification outage for each unit. 'The forced outage rate for this assessment period was low at 2.07%

for Unit I and 1.11% for Unit 2 and was an improvement over the previous assessment period and is indicative of good performance not only in operations but in other areas such as maintenance and surveillance. The 216 days of continuous operation ended on March 2,1989, when the Unit 2 system auxiliary transformer

< (SAT) faulted, causing the Unit I turbine generator to trip and the reactor to scram. After a.4-day outage to review the event, repair, and replace equipment, the unit was returned to service and experienced 117 days of continuous operation through the end of the assessment period. Unit 2 began the period with a continuous run of 167 days. The unit was then down for 3 days to repair a nitrogen pressure regulator for the automatic depressurization system (ADS) and after return to service operated for 41 days before the licensee manually scrammed the

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. reactor to comply with a Confirmatory Action Letter (CAL) in effect as a result of the March 9, 1988, power oscillation event. At that time, the licensee chose to start a 17-week l refueling and modification outage 1 day early. Unit 2 was subsequently returned to service and experienced 137 days of continuous operation through the end of the assessment perio During this per

oo, there were two significant events. The first event occurred on March 2, 1989, when the Unit 2 SAT faulted, causing a transient on the 345-KV system, which caused the Unit I turbine generator to trip and the reactor to scram. The second event occurred on June 12, 1989, when the Unit 2 SAT again trippe In this case, the trip was caused by a spurious actuation of the SAT fire protection deluge system. No scram occurred on either unit, however, during the recovery phase of the event, the Unit 2 Division III (high pressure core spray (HPCS)) emergency diesel generator's (EDGs) output breaker inadvertently closed paralleling the EDG with the SAT. This resulted in damage to the EDG's generato In all of the above cases, the Operations Department consistently demonstrated excellent performance. Pertaining to the loss of the Unit 2 SAT and the Unit I scram event, the NRCs Augmented Inspection Team (AIT) noted that the licensee conservatively approached the event by declaring an Unusual Event emergency action level, even though the action level declaration was not required. The operators' actions and evaluations mitigated additional plant upsetting conditions and allowed rapid control of both units during a complex event. In particular, it was noted that the alertness of, and prompt action by, the Unit 2 operator prevented Unit 2 from scramming or,a feedwater transient during the March 1989 SAT even Housekeeping conditions within the plant have continued to improve, however, during the last Unit 2 refueling outage there were some instances where minor problems were noted, in particular with control and storage of radiological supplie The licensee's responsiveness in the latter part of the assessment period was evident. Plant tours have consistently revealed that water and oil leaks were few and minor in nature denoting aggressive management attention. The licensee has undertaken a substantial painting program as part of their model space concept in order to improve both the material condition of the plant and its appearance. Accountability for housekeeping of specific areas has been established, with the name of the responsible individual prominently displayed on signs in each area. The assigned individuals are responsible for touring their areas to ensure that housekeeping is maintained at a high level. This has resulted in improved housekeeping and a reduction of cl. utter in the pl. an , . _ _ . . - _ _ _

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, There was'. consistent evidence of management involvement in ensuring the quality of plant operations as demonstrated by

~the' low number of automatic scrams, low forced outage rate, increased plant availability, and aggressive corrective action

'on the three violations issued in this functional area. In

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addition, plant management is extensively involved in the day-to-day operations of the plant as consistently evidenced by daily walkdowns of the control room panels, attendance at the plan-of-the-day me'etings, and attendance at lessons learne meetings. The latter also included periodic attendance by senior corporate managemen In addition, during critical plant evolutions, the licensee places a senior management. individual-on backshift to monitor that evolution. The AIT that responded to the March 2, 1989, SAT event, noted that-the licensee's management, both onsite and offsite, demonstrated conscientious involvement and provided sound evaluations of the Unit 2 SAT and Unit I scram event from a safety standpoint. .The positive managtment attributes noted above have resulted in an enhanced quality of operations and have been directly responsible for the significant reduction of the' scram rate from nine the previous assessment period to one during this perio Management routinely takes a conservative safety approach to

.the identification and resolution of technical issues. These resolutions are sound and the approach is thorough in almost all case For example, conservative actions by the licensee concerning the 2B reactor recirculation pump seal problems included increased monitoring of seal pressures, temperatures, and containment sump levels. A temporary instruction was also-developed to direct operating crew actions for use when self-imposed' administrative limits were exceede The licensee's respon.iveness to NRC initiatives regarding plant operations was usually technically sound and thorough,

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ac::eptaole resolutions were proposed initially and the resolutions were timely. The licensee met frequently with NRC management to keep the region abreast of improvement program implementation and other initiatives they had undertaken. The L licensee also issued monthly performance reports that provided l

statistical data and trends-for parameters covering all major aspects of plant operations. These reports were a valuable

> management tool. The AIT that responded to the March 2, 1989, SAT event noted that the licensee demonstrated positive responsiveness to NRC initiatives associated with this event.

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Staffing for plant operations was ample during this period and consisted of six operating crews that exceeded Technical Specification requirements, for the number of licensed individual Positions were identified, and authorities and responsibility 1es were well defined. Staffing remained stable with a few department changes taking place to enhance management skills and f 8

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. .the knowledge . level of the' 0perations Department as:well as other

departments. Overtime for the' operations staff was scheduled in accordance.with NRC guidance and requirements. During thi assessment; period, the licensee supplemented the control room

. staff with the' addition of a fourth ~ reactor operator. .This was 7 a concern in the previous assessment. period.; The addition of'

the fourth reactor operator has allowed the assigned unit operator to devote.more' attention to overall plant conditions during surveillance testing and has provided an additional measure of control during transient Control room personnel maintain a business-like and professional attitude. The control room is quiet, and work efforts do not.-

interfere with the operation of the units. During the previous asmsment period, it was specifically noted:that the conduct of W tperators during routine activities and shift turnover was t - oq, . This outstanding practice has continued throughout this g &d. The Operations Department maintained a high quality work ethic in the control room throughout;the assessment period. . In addition, it was noted that the operators prepared and issued their own " Code' of Ethics." The reactor operators routinel responded well to alarms and changing conditions within the plant in accordance with procedures and the Technical Specification They were consistently attentive and cognizant ~of the different activities (surveillance ~and maintenance) taking place in the plant that affected plant operation During this assessment period, there were six licensee event reports (LERs) issued that were attributed Lo.this- functional area. Of these six, two resulted from personnel errors. During the previous assessment period there'were also two LERs related to personnel error. The LERs adequately described the major aspects of the events, including all component or system failures that contributed to the event and the significant corrective-actions taken or planned to prevent recurrence. .The LERs were consistent in providing specific details of the events and assessment of the root cause and corrective actions take Safety analyses were thorough and well written, taking into account the actual plant status during the _ event and postulating effects of the events on differing plant modes, as deemed appropriate. Previous similar occurrences were properly referenced in the LERs, as applicabl Operator licensing examinations were administered in April 1988 and June 1989. All 21 candidates passed their examination This 100% success rate represents a significant improvement in the operator licensing program from the previous assessment period, during which three of the four senior reactor operators (SR0s) candidates failed (resulting in a 25% pass rate). No NRC Requalification Examinations were administered during this period. In preparation for the Summer 1989 NRC Requalification

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. Examination, the Operations Department assisted the Training Department in the verification of the materials used to ensure the accuracy and practicality of the testing materials which L resulted in minimum rework by the licensee and NRC to achieve.

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acceptable questions, scenarios, and job performance measure . Performance Rating L The licensee's performance is rated Category 1 in this area.

L The licensee's performance was rated Category 2 in the previous-

!. assessment perio . Recommendations Non Radiological Controls Analysi s s Evaluation of this functional area was based on the results of five routine and two special inspections performed during. this assessment period by regional inspectors and routine observations by resident inspector Enforcement history in this area was basically unchanged with two Severity Level IV violations in radiation protection and chemistry during this assessment period compared with two Severity Level IV and one Severity Level V violations during the previous assessment period. One of the violations arose from an incident involving an inadequate survey, and'the other resulted from failure to follow procedure The chemistry staff appeared to be well qualified, competent, and adequate to handle the existing workload. Staffing quality appeared generally improved with the appointment of a new Radiation Protection Manager (RPM) and the assignment of chemists to specific unit responsibilities and remains adequate to satisfy routine radiation protection and chemistry requirements. The reorganization in the management of the Rad / Chem Department, where both sections of the now divided department have their own supervisors, is expected to have a positive effect by allowing greater technician specialization and also better management oversight for each group. The ALARA group was strengthened by the appointment of two experienced operational radiation protection technicians (RPTs) as ALARA specialist Management involvement to ensure quality was evident but effectiveness was uncertain in light of the high total manrem incurred during the period. More extensive assessments of the

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, station's ALARA and radiation protection programs were ce?bacted by the corporate health physics group following the Unit 1 outage when it became apparent that annual ALARA goals set by the corporate office would be exceeded. Corporate support was also evident in the investigation of a release of radioactive material to an unlicensed facility and in assistance regarding the contamination spill outside the radwaste building. Station i support for the radiological control program was indicated by

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stror.ger support for the Radiation Occurrence Report (ROR)

system, procurement of contractor assistance to improve process and effluent monitor calibration, a stronger effort to reduce contaminated areas, improved radwaste classification, and disposal and continued funding for acquisition of health physics measurement equipment. Near the end of the assessment period, the station initiated a program to foster better cooperation and understanding between radiation protection and other groups at the supervisory level and also mede changes in work planning procedures to achieve better and more timely ALARA group involvemen On the other hand, progress tis slow in reducing the number of radioactive spills and the nuvber of high radiation area (HRA)

control problems and the violation for release of radioactive material to an unlicensed facility pointed out the need for increased management attention to radiological control Weaknesses were also identified regarding the licensee's failure to report required information in the semiannual effluent release reports and lack of timeliness in correcting sampling system de'iciencie The licensee's responsiveness to NRC initiatives nas generally been good. The licensee agreed to implement a program to monitor the quality of their vendor laboratory analyses, particularly in the area of beta analyses. The licensee was responsive to NRC concerns regarding radiological controls in the maintenance machine shop, the respirator distribution and return system, high radiation background levels for the liquid radwaste discharge monitor, and poor radiological control practices that were observed in the drywell. The licensee also reduced the number of radiological cc.. ' led access (RCA)-

controlled exit points and increased surveillance at the remaining control points to improve contamination control Responsiveness was also indicated by improvements in laboratory quality assurance / quality control (QA/QC) and in assignment of unit chemistry responsibilitie The licensee's approach to technical issues appeared generally sound. Internal doses were minimal and personal contamination events decreased as a result of improvements in contamination control. However, the high station dose (2500 person-rem) for 1988 was more than double the projected dose.(1100 person-rem)

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. =and casts some uncertainty on'ALARA effectiveness. Two planned L major refueling outages accounted for about 1500 person-rem f .through the end of 1988 with licensee records showing about half resulting from one time or unusual jobs such as snubber removal, drywell cooling modification, and repair of three reactor

recirculation pumps. Licensee representatives asserted that approximately 800 person-rem were saved primarily through chemical decontamination and flushing. The station goal for 1989 remains high at 1400 person-rem although it anticipates more involvement of corporate health physics and more use of lessons learne The calculated offgas dose rate was elevated early in the assessment period due primarily to a Unit 2 fuel defect problem, but was' improved by replacement of the defective fuel during the late 1988 refueling outage. Although remaining well within

- regulatory limits, liquid radwaste discharges increased markedly

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during the first half of 1988 when chemical intrusion into the liquid waste treatment system led to planned release of large quantities of water in order to maintain required plant water quality. The licensee. continues to make progress-in reducing the volume of solid radwaste-generated. No transportation incidents occurred during the assessment period. The licensee continues to implement its radiological environmental monitoring program'(REMP) satisfactorily, and the quality of radiological confirmatory measurements continues to be good although there was a slight decline with 71. agreements in 76 comparison Nonradiological comparisons were improved with 21 agreements in 25 comparisons'and 6 agreements in 6 split samples with Brookhaven National Laborator . Performance Rating The licensee's performance is rated Category 2 in this are The licensee's performance was rated Category 2 in the previous assessment perio . Recommendations Non C. Maintenance / Surveillance Analysis Evsluation of this functional area was based on the results of 11 routine inspections performed by resident inspectors, six routine inspections by regional inspectors, and a Maintenance Team Inspection (MTI). Maintenance and surveillance were

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l a l, separate' functional areas in the previous assessment period, but

have been combined as one functional area for:this assessmen Areas evaluated included maintenance and surveillance practices, inservice inspection (ISI) activities, and core performance-testing.

r Enforcement history in the maintenance' area showed continued improvement in~ performance. No violations were identified

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during this period. By contrast, two Severity Level IV

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violations were identified during the previous assessment. In the surveillance area, however, enforcement history indicated a slight decline in performance. During this assessment period, four Severity Level IV violations were identified, compared with three in the previous assessment perio Three Technical Specification surveillance were missed during this assessment period. While management attention has been devoted to this issue, it has not been totally effectiv An inadequate surveillance procedure indirectly caused a Unit 2 reactor scram in October 1988. The surveillance procedure allowed both recirculation pumps to coast down to zero spee The reactor was scrammed manually as the licensee complied with the CAL'in effect from the March 1988 power oscillation even Since this event occurred approximately I day prior to a scheduled refueling and maintenance outage, the outage was started early Operational events attributed to this functional area increased during this assessment period from 41 LERs to 50; 13 were in maintenance compared with 11 during the previous period, and b 37 in surveillance compared with 30 during the previous assessment period. Of the 50 LERs, 14 were voluntarily submitted pertaining to Static-0-Ring (SOR) instrument failures in accordance with a previous commitment'to the NR Five LERs were submitted in this regard during the proceeding assessment period. Twelve LERs involved ESF actuations during the present and the previous periods. There were 12 LERs attributed to personnel errors compared with 15 of this type during the previous assessment period. Eight LERs concerned problems with EDGs of which four were associated with the Unit "0" (common)

diesel. Also, there were 6 instances (of 37 in the surveillance area) where inadequate surveillance procedures were considered the probable cause of the LER. The significance of some events, the frequency of occurrence, and the continued high number of personnel errors indicates that corrective action to issues raised in the prior assessment period were not entirely effectiv Management involvement to ensure quality in the maintenance area was evident. This was also noted in balance-of plant (B0P)

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n maintenance, particularly in the case of the resolution of the leaks on.one of the turbine-driven reactor feedwater pump minimum flow bypass lines. However, it was noted that at times contractor personnel deviated from procedures and performed activities without adequate licensee oversight. For example, m

contractors were allowed to bypass procedural steps in the

' case of an environmental qualification inspection of a residual heat removal (RHR) system pump motor and during corrective maintenance of the 2A turbine driven reactor feed pump.. The Unit I refueling and maintenance outage was well ,

l= planned coordinated, and completed on time. The Unit 2, refueling and maintenance outage was completed approximately 10 days late, primarily due to additional reactive work. However, there was evidence of good planning and implementation'during the outage. The ISI activities were adequately planned, and

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appropriate priorities were assigned. All of-these activities were controlled by well stated and well' defined procedure '

-Records were complete and well maintaine Management involvement was further evidenced by the work-completed on assigned sections of the Conduct of Maintenance Program, use of a reliability centered maintenance type study on the feedwater system, a BOP system, and use of personnel who were knowledgeable and dedicated to the conduct of 3 maintenance. In general, maintenance was accomplished,

1. effective, and self-assessed. However, several areas were considered weak, including instances of ineffective direction of maintenance activities that resulted in inadequate controls to monitor performance of fuel oil transfer pump valves for the EDGs and lack of a comprehensive trending program for corrective maintenanc Identification, resolution, and understanding of technical issues from a safety standpoint was not always effectiv For example, maintenance management was not aggressive in the troubleshooting and repair of a deficiency noted on ADS solenoid valves or the change out of solenoid discharge valves for Unit 2

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EDG fuel oil transfer pump Plant staffing in maintenance appeared adequate es evidenced by the size of the maintenance work request backlog. The non-outage corrective maintenance work request backlog had been maintainec' at about 700 from September 1987 through May 1989, which was considered low and nanageable. A review of the corrective maintenance backlog in May 1989 did not identify any work' requests that had impact on equipment operability. The preventive maintenance backlog was also low and manageabl Maintenance training and qualification programs for station maintenance staff were considered effective. The use of mockups contributed to this effectiveness. The ISI personnel

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had adequate expertise to perform their functions. Outside consultants were. utilized at an appropriate level with adequate p, oversight provided. Personnel performing nondestructive

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examinations (NDEs) were well qualified, knowledgeable,'and .

conscientious in their work. Members of.the plant nuclear engineering staff a'ssociated with core performance testing appeared to be adequately trained and had a good understanding of technical issue Management responsiveness to NRC initiatives at times _ lacked depth and thoroughness. The licensee failed to adequately carry out commitments to the NRC on the task associated with monitoring drywell temperatures. Specifically, some required temperatures were not obtained and submitted to engineering for L evaluation, and a special deviation-report, required by the Technical Specifications, was not submitted to the NRC within

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the required time frame. Subsequent actions by the licensee

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corrected these problems. On the positive side, the license reviewed NRC maintenance inspections conducted at other sites-to determine if weaknesses identified elsewhere applied to .

LaSa11 e'. When provided copies of NRC morning reports of events at other facilities, the licensee reviewed the reports and took the necessary action. For instance, in. response to the recirculation pump seal failure at the Clinton Power Station s (CPS), the licensee took immediate action to verify that the failure was not applicable to LaSalle and provided assistance to CPS in resolving the failur . Performance Rating The licensee's performance is rated Category 2 in this are The licensee's performance was rated Category 2 in Maintenance and Category 2 in Surveillance in the previous assessment perio . Recommendations Non Emergency Pret;aredness Analysis Evaluation of this functional area was based on one emergency preparedness (EP) exercise and one routine inspection conducted by region-based inspectors during this assessment perio Enforcement history improved with no violations identified during this assessment period, compared with one violation during the

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previous period. All remaining open items identified during previous assessment periods were resolved, and no new items were identified during the 1988 exercise or routine inspectio Plant and Corporate management support of the emergency preparedness program was very good during the assessment perio This increased management attention to the EP program has had a positive effect. In addition, a comprehensive assessment of the LaSalle EP program was conducted by corporate assessment personnel, corporate EP personnel, and EP coordinators from other Commonwealth Edison Stations. This assessment identified no significant program deficiencies, but did identify areas where the program could be improve Corporate management began developing an extensive EP certification training program during this assessment perio Because the program was still under development, attendance by EP coordinators was optional, although encouraged. The LaSalle EP Coordinator has attended all sessions offered. This certification program is a continuing effort to increase the knowledge and expertise of the licensee's EP personne The licensee's resolution of technical issues from a safety standpoint showed significant improvement as evidenced by the timeliness and thoroughness of corrective actions on all NRC and self-identified concerns. Tracking systems were used effectively to track corrective action taken on items identified during previous NRC inspections and other review The licensee developed a well-coordinated plan for utilizing the LaSalle, Dresden. and Braidwood Stations as relocation centers for nonessential personnel who may be evacuated from any one of these sites in an emergency. As a result of NRC and Federal Emergency Management Agency (FEMA) concerns, the annual medical training program was improved and emphasizes the role of the RPT to better address the contamination control aspects of the medical emergenc Events that resulted in tLe activation of the emergency plan were properly identified ant' classifie Offsite notifications, including to the NRC, were accomplished within the required time frame Overall performance during the June 1988 exercise was very good. The challenging scenario included a prolonged security threat, a loss of the safety parameter display system (SPDS),

and variable weather conditions that affected offsite protective action recommendations. Emergency responders consistently demonstrated good coordination and conservatism in the responses to changing scenario event Staffing of the Emergency Responso Organization (ERO) improved during this assessment period. The licensee maintained a roster with at least three qualified personnel available to fill all

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key positions in the emergency' organization. Non-emergency staffing for the EP program remained unchanged with a dedicated onsite EP Coordinator and an EP Trainer. A review of the training program determined that personnel were receiving training within the time frames required, and that the training was adequate in scope and depth. Training of all director-level positions has been increased from annual to quarterl Training sessions included brief tabletop scenarios to reinforce the program topics. Interviews and walkthroughs conducted during the routine inspection indicated a good awareness of emergency responsibilities at all levels of the ERO staffin This indicates an excel'ient indepth training and drill program and strong management support for the EP progra The licensee support of the state and local emergency programs remains exc. lent. Licensee personnel assisted in redesigning and reorganizing the state emergency operations center (EOC)

facilities and staffing. This was in response to offsite deficiencies identified by FEMA during the last full-scale exercise. Plant personnel also participated in an unannounced EOC activation drill with the new offsite organization in order to assist the offsite support groups in their efforts to satisfy FEMA criteria in EOC activation and organizatio . performance Rating The licensee's performance is rated Category 1 in this are The licensee's performance was rated Category 2 in the previous assessment perio . Recommendations Non E. Security Analysis Evaluation of this functional area was based on the results of three routine inspections and one reactive inspection by regional inspectors and on routine inspection observations of security force activities by the resident inspector The enforcement history in this area has improved. One Severity Level IV violation was identified during this assessme:it period, compared with four Severity Level IV violations and one Severity Level V identified during the previous assessment perio The violation involved a failure to adequately control access to a vital area. The event was discovered by the licensee and was promptly and properly reported. The violation did not represent a programmatic deficienc _ _-_-_-_ _ _ _ .

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Management's role in ensuring the quality of the security program was mixed. The site security management has been-receptive to NRC concerns and displayed a positive and-aggressive attitude toward improvement of security practice Both corporate and plant management were supportive of the security program as evidenced by the allocation of_ material resources. .For example, one type of perimeter detection system is in the process.of a total upgrade. The aging equipment is being replaced with a state-of-the-art system. The other perimeter detection system, however, is aging and future upgrading may be needed. A contractor was hired to conduct a quarterly performance evaluation of the perimeter detection system on a continuing basis. The licensee has repaired identified problems in a timely manner. During this assessment period, all metal and explosive detectors were upgraded with state-of-the-art equipment. Weaknesses were demonstrated when supervisors left their weapons unattended and a guard was found inattentive to dut The licensee's performance in handling security events was a program strength. Managers and employees at various levels responded to events in a thorough and timely manner in all case For example, when the security systera was damaged as a result of unusual weather late in the assessment period, the site security organization responded quickly and ensured that systrm effectiveness was maintaine The licensee's approach to the resolution of technical issues was good, with the exception of a closed circuit television (CCTV) problem which has persisted since 1986. The licensee has persistently attempted to resolve this problem and hired a contractor to assist them. Other technical issues, such as upgrading alarm equipment, have been adequately resolve The licensee's responsiveness to NRC initiatives was mixe The one security event reported to the NRC under 10 CFR 73.71 was properly identified, analyzed, and reported in a timely manner. The event reported was an incident for which the licensee received the above noted violation. The site and corporate responses to specific licensing matters and inspection findings were technically sound and timely and were a program strength. Additionally, the site security staff and corporate Nuclear Security Administrator have maintained very good communications with the assigned Region III Security inspector and Safeguards Staff. Although communications have been good, the responsiveness of the company to issues including upgrading agility testing and reporting and logging practices have been prolonged. These issues are not unique to LaSall Security staf fing levels are ample not only to ensure a level of performance that meets regulatory requirements but also allow

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. . for' timely responses to' changing security needs. Posit;ons

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within the licensee and contractor security organizations were properly identified and responsibilities were well define All licensee's guard training and qualification commitments were me . Performance Rating The' licensee's performance is rated Category 2 with an improving trend in this area. The licensee's performance was rated Category 2 in the previous assessment perio . Recommendations Non F. Engineering / Technical Support Analysi s Evaluation of this functional area was based on the results of seven inspections conducted by region-based inspectors (including the Maintenance Team Inspection), routine inspections by the resident inspectors, and NRR review of licensing submittal 't Enforcement history declined during this period with six Severity Level IV violations and one Severity Level V violation issue This compares with two Severity Level IV violations for the previous assessment period. All seven violations related to-lack of attention to detail by the licensee. Two of the violations identified during the MTI were considered significant end were due to inadequate EDG surveillance procedure Fifteen LERs attributable to this functional area were issued during this assessment perio Eleven of these related to ESF actuations, of which nine were attributable to the control room ventilation system ammonia detectors. The licensee was granted a Technical Specification change that deleted the- requirement for this ESF actuation. Two LERs were attributable to personnel error Management involvement in ensuring quality continued to be mixed. Generally, the engineering content of licensee submittals demonstrated an understanding of the issues, provided acceptable approaches, and met established standards. Management involvement was evident in the root cause analysis and corrective actions

' performed for the power oscillation event (which occurred at-the end of'the previous assessment period), the loss of the Unit 2 reactor recirculation pump discharge valve disk insert,

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ll and the two events involving the loss of the Unit 2 SAT. The

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materials for the 1989 licensed operator replacement examination were significantly improved over previous submittals, including revised lesson plans, well organized material, and timely submittals. There was adequate management involvement in resolving Regulatory Guide 1.97, snubber reduction, and j environmental qualification concerns. Engineering evaluations were technically accurate, and procedures governing the evaluation process were well stated, explicit, and well controlled. Ge.ieric Letter 83-28 implementation was good with established, effective classification and control of safety related structures, systems, and components. The system engineer concept was recently implemented and should help identify and resolve problems; however, these engineers were not routinely reviewing work requests nor were they involved in the identification of post-maintenance testing activities. This would weaken the detection of negative trends, common work failures, and repetitive failure The initial submittal for installing high density racks in the spent f uel pool was inadequate under the postulated seismic events, although subsequent technical approaches were acceptable. Other concerns included the failure to recognize EDG inoperability issues and inadequate review of EDG surveillance procedures, failure to obtain timely technical specification relief for EDG testing, and inadequate engineering support regarding approach to resolution of the 10 CFR Part 21 report concerning Melamine torque switches on limitorque motor-operated valves. Additionally, management has not been aggressive in resolving several temporary changes and modifications that have been outstar. ding for a number of year Examples include: the neutron streaming problem from a Unit 2 penetration and the degraded HPCS system suction piping from the condensate storage tanks for Units 1 and The licensee's approach to the resolution of technical issues from a safety standpoint was mixed. On the positive side, the licensee's snubber reduction program used analytical approaches that were conservative, technienlly sound, and thoroug Engineering evaluations regarding snubbers that failed the functional test criteria were technically sound and complet The licensee demonstrated a conservative approach to.a safety issue by isolating an affected steam line until concerns identified by QA regarding two main steam isolation valve (MSIV)

actuators could be resolved. On the other hand, there were examples were non-conservative approaches were taken. An inoperable reactor building ventilation system isolation damper was declared operable based solely on ability to achieve an acceptable closure time after repeatedly exercising the valv The licensee failed to verify the failure mechanism by performing any work or identifying root cause of the original failure. The damper subsequently failed to close within tr.4

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required stroke time 2 weeks late Root cause determinations

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continue to need improvement as exemplified by the thinning of a feedwater minimum flow line. The problem was initially attributed to the nature of the valve design and a repair was specified; but the repair lasted only 4 months because the actual root cause was a greater leakage rate through the valve than had been originally thought. Another example of root cause analysis failure was the reactor building ventilation system isolation damper failure discussed abov Technical support for plant activities were, in some instances, inadequate. For example technical support of maintenance

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exhibited poor communications en a Limitorque 10 CFR 21 report, which led to untimely corrective action because the reported scope and status had not been provided to the technical staf Additionally, late in the assessment period, surveillance procedures and test methodologies were not adequate to prove that the EDG trip interlocks would prevent a generator trip during an emergency condition. Also, inadequate review of surveillance procedures caused all five EDG's to be tested improperly from ambient conditions for a substantial number of months. The general quality and review of surveillance procedures is a concer The licensee's responsiveness to NRC initiatives was goo When notified of NRC concerns, the licensee promptly instituted corrective actions to ensure that all carbon adsorber banks met Technical Specification surveillance requirements during the last acceptance tests. The licensee immediately addressed the EDG testing frequency concer In preparation for the first NRC requalification exam for licensed operators, the training staff took the initiative to give requalification exams to all licensed operators using the format in NUREG-1021, ES-60 Staffing of the onsite engineering group was adequate although it was noted that the experience level of the technical support group was low at approximately 2-3 years, The onsite presence of the engineering group was increased during this assessment period. This resulted in more timely resolution of engineering problems and enhanced coordinatio During this assessment period, the licensee formally implemented a system engineering concept to provide enhanced accountability and feeling of ownership as well as a more centralized location for changes and overall control that have an impact on plent systems. Corporate engineering has improved the delivery time of refueling outage modification packages to the site. During the last Unit 2 outage, most of the approximately 69 modification packages were onsite 6 months prior to the start of the outage. As a result, outage planning has dramatically improved. This was also due in part to the use of licensed individuals in the outage planning staff.

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. While the licensee continues to rely heavily on outside consultants for technical expertise in the design and analysis .

of plant modifications, some improvements were noted in

. oversight controls. For example, in the snubber reduction program, this~ weakness was recognized and a third party was contracted to provide overview. .This contributed to the success of the projec . Performance Rating The licensee's performance is rated Category 2 in this area' .

The licensee's performance was rated Category 2 in the previous assessment perio . Recommendations Non G. Safety Assessment / Quality Verification Analysis This is a new functional area incorporating many.of the activities reported previously under the functional areas of Quality Programs and Administrative Controls Affecting Quality, and Licensing Activities. Evaluation of this functional area was based on the results of six routine inspections conducted by the resident and regional inspectors, and a Maintenance Team Inspection. In addition, NRC. staff review of licensee submittals and requests for amendments to the operating license were considere Enforcement history in this functional area declined and consisted of one Severity Level III violation, five Severity Level IV violations, and one Severity Level V violation compared with two Severity Level IV violations and one Severity Level V violation in the related functional areas during the previous assessment period. The Severity Level III violation arose from failure to have adequate design control measures and inadequate procedures, which pertained to the Unit 2 reactor core power oscillation event that was discussed in the previous assessmen As a result of the magnitude and generic implication of the event, the licensee and the Boiling Water Reactor Owners Group (BWROG) have been actively pursuing corrective actions to mitigate any future concerns with reactor core power oscillation Management and QA personnel made a concerted effort to reduce overall operational events; with the exception of those events associated with ammonia detector trips and SOR differential pressure switch setpoint drift. Because of the history of l

problems with SORS at LaSalle, the licensee has been required

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. to report failures via the LER system. During the previous assessment period the licensee issued 70 LERs. Of these 70 LERs, 5 were attributable to SORS and 9 were attributable to ammonia detector trips. During this assessment period, th'.

licensee issued 71 LERs. However, of these 71 LERs,14 were attributable to SORS and 9 were attributable to ammonia detector trips. The net number of LERs (minus SOR and ammonia detector)

for this assessment period is 48 and shows improvement over the previous assessment period net total of 56. A long-term plan (over the next several fuel cycles) is now in effect to replace all SOR level switches with a different type of componen Additionally, the licensee has been able to justify allowing the special reporting requirements for SOR failures to be made by means other than an LER submittal. Also, a Technical Arttification amendment was approved that removes all references to the ammonia detection monitoring instrument syste Eliminating the necessity to report the SOR setpoint drifting and ammonia detector trips should significantly reduce the ntmber of reportable events in the future. Some reduction in the number of LERs attributable to personnel errors occurred during this essessment period compared with the previous perio In the area of radiation protection and radwaste, the licensee's station and corporate QA organization and corporate health physics group performed audits and assessments on a routine and srecial basis. The audit and assessment groups appear to have a good complement of technically qualified personnel. Regulatory violations and deficiencies found during audits are few, but all audits and assessments resulted in recommendations for improvemen The licensee's QA and OC departments performed numerous surveillance and audits of maintenance activities and identified several problems, assessed for root cause and possible maintenance program weaknesses. Audits of maintenance for 1988 and 1989 were performance-based, and adequate attention to closing audit findings and followup of corrective actions was eviden The licensee's corrective actions in response to audit / assessment findings were generally good. Responsiveness to NRC initiatives was adequate. However, there was some reluctance to acknowledge the common mode failure potential resulting from a relay problem identified regarding the EDGs. Additionally, the licensee failed to pursue available relief to excessive Technical Specification testing of the EDGs until after the June 12, 1989, loss of the Unit 2 SAT, when the testing was required to be performed. As a result, the licensee requested, and the NRC granted, a temporary waiver of compliance with the Technical Specifications to allow the licensee time to repair the transformer.

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Staffing in this area appeared adequate. The licensee QA audit findings showed depth of effort. A positive initiative by the licensee, was the Safety System Functional Inspection (SSFI)

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conducted by the QA Department on the standby liquid control system. The audit revealed several-minor findings that the QA Department has actively pursued to ensure they are resolve At the end of the assessment period, most of these findings had been corrected or addressed for resolutio The licensee's quality assessment programs and feedback appear-effective in. identifying and correcting substandard performanc QA problems were identified with the Unit 2 MSIV actuator The licensee determined that the Md V actuator supplier did not have an approved QA program and as a result the quality of some actuators were questionable. The licensee elected to operate Unit 2 at a lower power level until the the issue was resolve Recently, the licensee conducted two self-assessments (cperations and maintenance) as well as other review Throughout the assessment period, the licensee frequently

' informed the NRC staff of the status of licensing issues and regulatory initiatives. However, on several occasions, the issue resolution priorities of the NRC staff and licensee were not in agreement. An example of this is the low priority consideration given by t!< licensee to resolving clarification of a EDG Technical Specification footnote regarding testin The licensee's response to bulletins, information notices, and generic letters has been good and, in general, shares the same conservatism and generally agrees with NRC staff position Also, the licensee's program for conducting the 10 CFR 50.59 reviews appears thorough and comprehensiv During the assessment period, the regulatory assurance staff was increased from four to nine members, indicating an active commitment by plant management. This has resulted in more accurate and timely licensing submittals. Regulatory assurance personnel have been cooperative and responsive when dealing with NRC personnel. During this assessment period, frequent discussions between the NRC res4 dent inspectors and the regulatory assurance staff took place. Concerns that the resident inspectors expressed to this staff were generally handled promptly. Communications between the resident inspectors and the regulatory assurrice staff have been open and unencumbere During this assessment period, the offsite nuclear safety organization met with LaSa11e's management every quarter and reviewed the effectiveness of corredive actions associated with nonroutine events. These rev'e s have been effective in evaluating the licensee's corrective action _ _ - _ _ _ - -

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N IThe NRC staff conducted substantial reviews of licensee submittals during'the rating period. These'submittals relate

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~to license amendment applications, responses to generic letters and' bulletins, revisions to license commitments, and-10 CFR 50.59' evaluations. The NRC staff also reviewed.the licensee's analysis of industry operating experience, root cause -

analysis of. plant events, and effectiveness'of the licensee's programs'to identify and correct substandard performance. The licensee's performance in these areas was mixed. The licensee has generally provided well, supported, detailed analyses 1n support of license amendment requests that-stand alone.and-require little or no further discussion.or clarification by the NRC staff. . Examples include.the amendment requests relating to the suppression pool, refuel interval surveillance,'and the Unit 2 reload amendments. On the other hand, other license requests included positions unacceptable.to the NRC. staff or-which required considerable discussion to resolve the issues.

l Examples include EDG testing and removal of the ammonia detector Early in the assessment period, the NRC had some concerns over the control of contractor activities. The licensee, during a reorganization, established the Projects and Construction Services (PACS) organization. Currently,.the. PACS functions are being absorbad into the Engineering and Construction --

Nuclear Operations organization. A key part of the PACS mission

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was to centralize contractor controls by providing direction to ,

contractors; improve the efficiency and effectiveness of contractors; ensure a uniform and consistent approach of managing contractors; and provide accountability for contractor management.

l This action resulted in a reduction of errors and events L initiated by contractor . Performance Rating The licensee's performance is rated Category 2 in this area.

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Because this is a new area, no rating is available for the I previous assessment period.

l Recommendations Non ,.

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V. SUPp0RTING DATA AND SUMMARIES Licensee Activities Unit 1 LaSalle,. Unit 1, began the~ assessment period with its second refueling outage.in progress. The unit was restarted on July 8, 1988, and for approximately 8 months of the assessment-period, Unit.1 operated at varied power levels up to 100%, as it engaged in numerous . load drops and several short outages to perform small repairs, maintenance activities, rod sets, testing, and control rod drive (CRD) exercises. On June 30, 1989, Unit I was' operating routinely, and ended the assessment with 117 days .

of continual operatio Unit i experienced 23 ESF actuations.and I automatic reactor scram during the assessment period. This scram occurred at greater than 15% power and was due to an equipment failur Significant outages and events that occurred during the assessment period are summarized belo Unit 1 Significant Outages and Events During March 12,1988 - July 8,1988, Unit I was shutdown for its second scheduled refueling outage. Outage activities included, reactor vessel hydrostatic testing, rebuilding of the 'IA' reactor recirculation pump,

. overhaul . of Unit l's turbine and control rod drive mechanisms, repairs to the RHR pump discharge valve, main turbine balancing, repairs to a steam leak on No. 4 main turbine control valve, replacment of a leaking safety relief valve, servicing of the recirculation flow control valves, and drywell cleanup and closeout,

_ During July 23 - 29, 1988, Unit I was shutdown to repair steani leaks in the heater bay, replace reactor safety relief vahe, and perform other maintenance activitie During March 2 - 6, 1989, Unit I was shutdown due to a Unit 2 SAT fault. The unit was returned to service after review of the event and the repair / replacement of equipmen . Unit 2 At the beginning of the assessment period, LaSalle, Unit 2, was recovering from a forced outage that was caused by core power oscillations, on March 9, 1988. After its startup on March 17, 1988, Unit 2 operated for approximately 12 months at varied levels up to 100% power as it engaged in numerous

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Jo, y e- load reductions and several outages for rod pattern adjustments, maintenance, repairs, testing, and refueling activities. On June 30, 1989, Unit 2 was operating routinely and ended the assessment period with 137 days of~ continual operatio Unit 2 experienced 7 ESF actuations and.1 manual reactor scram during the assessment period. This scram occurred at greater than 15% power and was the result of procedural error Significant outages and events that occurred during the assessment period are summarized belo Unit 2 Significant Outages and Events During March 9-17, 1988, Unit 2 was shutdown as a result of an automatic scram caused by core power oscillations resulting from both reactor recirculation pumps tripping and the isolation of the feedwater heaters. Outage activities included replacement of the 'B' reactor recirculation pump seals, replacement of MSIV solencids, and re-termination of the 'C' RHR pump motor connection During August 31 - Sc;;tember 3,19i.t Unit 2 was shutdown to repair a failed ADS nitrogen backup pressure regulato Repairs were performed on the instrument nitrogen pressure regulator supply to the ADS valve During October 14, 1988 - February 12, 1989, Unit 2 was shutdown for a scheduled refueling outage, after an operator tripped both reactor recirculation pumps as a result of a procedural error. Outage activities included refueling the reactor, overhauling and replacement of l CRD mechanisms, repairs and maintenance work on '2A' and

'2B' reactor recirculation pump discharge valvas, chemical decontamination of reactor recirculation piping, overhauling of main turbine, and the completion of approximately 69 modification On March 2, 1989, the Unit 2 SAT faulted, causing a transient on the 345-KV system, which caused the Unit 1 turbine generator to trip and the Unit 1 reactor to scram. The Unit 2 SAT was subsequently repaired and returned to servic On July 12, 1989, the Unit 2 SAT again tripped. However, the trip this time was caused by a spurious activation of its fire protection deluge syste Neither unit scrammed, however, during the recovery phase the Unit 2 Division III EDG output breaker inadvertently closed paralleling the l

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e l' .t EDG with the SAT in an uncontrolled manner. This resulted

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in damage to the generator on the EDG. The generator was subsequently replaced and the EDG returned to operabilit Inspection Activities Thirty-eight inspection reports are discussed in this SALP report (March 16, 1988, througn June 30,1989) and are listed in. paragraph I of this Section, Inspection Data. Table 1 lists the violations per functional' area and severity levels. Significant inspection activities are listed in paragraph 2 of this section, Special Inspection Summar . Inspection Data-

' Unit'1 Docket No: 50-373 . .

' Inspection Reports Nos: 88004, 88006 through 88022, 88024 through 88030, 89002 through 89004, 89007 through 89014, and 8901 Unit 2 l Docket'No: 50-374

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Inspection Reports Nosi 88004, 88006 through 88018, 88020, 88021, 88023 through 88030, 89002 through 89004, 89007 through 89014, and 89016.

l Table I Number of Violations in Each Severity Level Unit 1 Unit 2 Both i Functional Areas III IV V III IV V III IV V l

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2 - Maintenance / Surveillance - - - -

2 - -

2 - Emergency Preparedness - - - - - - - - -

L Security - - - - - - -

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l Engineering / Technical Support -

2 - -

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3 1 Safety Assessment /

Quality Verification -

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3 1 Unit 1 Unit 2 Both TOTALS III IV V III IV V III IV V

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. Special Inspection Summary During March 16-24, 1988, an AIT inspection was conducted in response to the dual recirculation pump trip and subsequent core power oscillations which resulted in a reactor scram on March 9,1988 (Inspection Report

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Nos. 373/88008, 374/88008), During June 27 - July 22,1988, a special Probabilistic Rist Assessment (PRA) inspection was conducted of plant operations

'(Inspection Report Nos. 373/88016,374/88015). During November 14 - December 9, 1988, a team inspection was conducted of the licensee's operational radiation protection program (Inspection Report Nos. 373/88028, 374/88028). During March 3-4, 1989, an AIT inspection was conducted to investigate the circumstances surrounding the failure of the Unit 2 SAT and the related reactor scram of Unit 1 of March 9, 1989 (Inspection Reports Nos. 373/89007,374/89007). During May 1-5,.15-19, and 25, 1989, a MTI was conducted of the licensee's maintenance program and practices (Inspection Report Nos. 373/89010,374/89010). Escalated Enforcement Actions On November 18, 1988, an enforcement conference was held with licensee representatives to discuss issues related to the LaSalle neutron flux esci11ations event (March 9,1988) and operators'

action. The licensee failed to detect that the core decay ratio calculated by General Electric was substantially in error. After extensive licensee corrective actions and thorough NRC reviews, the-licensee was issued a Severity Level III violation for failure to recognize this error. However, no Civil Penalty was issued due to the licensee's prompt corrective actions. . (Enforcement Case No. EA 88-271 and Inspection Report Nos. 373/88022,374/88021). Confirmatory Action Letters (CAL)

I A CAL (No. CAL-RIII-88-003) was issued on March 17, 1988, as a request for the licensee to submit a formal report of their findings and conclusions relating to the LaSalle Unit 2 event of March 9, 1988, in which there was a dual recirculation pump trip and subsequent core performance anomalie . A CAL (No. CAL-RIII-89-007) was issued on March 6,1989,

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regarding the prohibiting of the restart of Unit I until the licensee identified the causes (with respect to equipment and the systems which were involved) during the March 2, 1989, event that resulted in a Unit I reactor trip due to a loss of the Unit 2 SA L --_ __--_------- _

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'F E. License Amendments Issued Amendments N Description Date 56, 37 50.73 Tech. Spec. Change.,. 3/16/88 57, 38 Refuel interval surveillkr,ce 5/24/88 58 (Unit 1) Cycle 3' reload 6/23/88 59, 39 Suppression pool'high level 8/31/88

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60, 40 Core pertermance monitoring .9/07/88 41 (Unit 2) Cycle 3 reload 1/06/89 61, 42 Removal of avionia detectors 1/18/89 62, 43 Onsite nuclear safety group 1/31/8 , 44- 'O' EOG out of service 2/07/89 64, 45 Primary. containment isolation 2/07/89 valves 65, 46 Physical security plan 4/10/89 66, 47 Onsite organization charts 4/27/89 F. Review of Licensee Events Reports Submitted by the Licensee Unit 1 LER Nos.:

88002 through 88029 and 89001 through 89020 Unit 2 LER Nos.:

88001 through 88017 and 89001 through 89006 Collectively, 71 LERs (including 18 voluntary LERs No. 373/88-003, 006, 009, 014, 028, and 029; 373/89-003, 005, 007, 008, 010, and 012 and No. 374/88-001, 009, 013, and 015; 374/89-004 and 006) were issued in accordance to NUREG-1022 guidelines during this assessment, and are addressed in this SALP 8 repor Table 2 Cause Areas Unit 1 Unit 2 personnel Errors 8 8 Design Deficiencies 3 0

>< External 0 0 Procedure Inadequacies 4 2 Equipment / Component 11 2 Other/ Unknown 22 11 Totals 48 23 l

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y 3,i Table 3 shows a cause code comparison'of SALP 7 and SALP Table 3 (16 MO) (15.5 M0).

Cause Areas SALP 7- SALP 8

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Personnel Errors 19 (27.2%) 16 (22.5%).

Design Problems 10'(14.3%) 3 ( 4.2%)

External Causes 0 ( 0.0%) -0 (-0.0%)

Procedure Inadequacie (10.0%) 6 ( 8.5%)

Equipment / Component 26 (37.1%) 13 (18.3%)

Other/ Unknown 8 (11.4%) 33 (46.5%)-

ll l TOTALS 70 (100%) 71*(100%)

h- FREQUENCY (LERs/MO) . 4. 6 ~

L * Includes 18 voluntary Reports.

l NOTE: The above LER information was derived from a review of LER's performed by NRC Resident staff

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, and may not completely coincide with the licensee's-cause code assignments.

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