ML20137B195

Task Force Review of Operational History for LaSalle County Station,Units 1 & 2, Final Rept

ML20137B195
Person / Time
Site:	LaSalle
Issue date:	09/24/1985
From:	Ron Kopriva, Schweibinz E, Stasek S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
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ML20137B166	List: ML20137B163 ML20137B195
References
NUDOCS 8511260209
Download: ML20137B195 (19)

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TASK FORCE REVIEW OF OPERATIONAL HISTORY FOR LASALLE COUNTY STATION, UNITS 1 AND 2 FINAL REPORT September 24, 1985 Task Force Members: E. R. Schweibinz S. Stasek R. A. Kopriva S. Rozak A. Dunlop A. L. Madison 8511260209 851122 PDR ADOCK 05000373 P PDR

EXECUTIVE

SUMMARY

Region 111 formed a special task force on July 22, 1985 to review the operating history of LaSalle County Station. The task force subsequently determined that:

(1) Certain plant systems experience problems including equipment failures and/or isolations on a regular basis.

(2) Problems are evident in the implementation of the sodification program.

(3) Control of work activities affecting the plant is inadequate.

(4) Plant operators routinely deal with excessive numbers of work requests, procedure changes; time clock limiting conditions for operation (LCO);

and Technical Specification abnormal conditions.

(5) Plant regulatory performance has historically been poor.

(6) Many of these same problem areas were previously identified by the licensee in an onsite review conducted on July 16, 1982 at the request of the NRC.

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1. INTRODUCTION On July 22, 1985, Region 111 formed a special task force to perform an in-depth review of the operating history of LaSalle County Station (LSCS) with emphasis on identifying potential problem areas from trends that may exist. The task force consisted of two resident inspectors, two regional inspectors and the chief of the lechnical Support Staff (TSS). In addition, a Senior Resident Inspector from another facility perfomed a more in-depth review of selected areas initially identified by the review team. The methodology used to perform the review was two part: (1) to review a variety of hard data concerning operational history, and hardware problems (including assessment of root causes and other contributing factors) for potential trends and (2) to assess NRC perceptions of LaSalle County Station via interviews with regional personnel and to ascertain if pot::ntial problem areas existed that were not identified during the hard data review. The task force subsequently completed its review on September 20, 1985. This report is a compilation of the observations made and conclusions drawn by the tear.

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11. REVIEW METHODOLOGY During the review process, the task force examined both NRC and licensee documents for any potential trends. The time frame for this review extended from 1982 for Unit I and 1984 for Unit 2 to the present and included:

Licensee Event Reports (LERs)

Deviation Reports (DVRs)

Shift Turnover Sheets Work Request Summaries (for Control Room Only)

Selected Licensee Reports NRC Inspection Reports NRC Daily Reports The team also utilized NRC and licensee computer sorts by system, cause code, component, and manufacturer for trend analyses.

In addition, the following individuals were interviewed by team members for their perceptions of LaSalle performance:

L. A. Reyes, Chief, Operations Branch

• W. G. Guldemond, Chief, Operational Programs Section R. D. Lanksbury, Reactor Inspector R. A. Hasse, Reactor Inspector L. J. Dimmock, Reactor Engineer 4 T. E. Lang, Reactor Engineer R. A. Paul, Radiation Specialist i P. L. Eng, Reactor Inspector i

2. Falevits, Reactor Inspector  !

M. J. Jordan, Senior Resident Inspector - LaSalle  :

J. C. Bjorgen, Resident Inspector - LaSalle l

• • R. A. Kopriva, Resident Inspector - LaSalle I

• Former Senior Resident Inspector at LaSalle.

• • Also member of task force. j 1

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Ill. POTENTIAL PROBLEM AREAS IDENTIFIED FROM TREND ANALYSIS There appears to be two general problem areas associated with LaSalle which was evident f rom the trend analysis perfomed. One was in the area of repeated equipment problems with certain plant systems. The other is the apparent overall problem of controlling work activities, both onsite and indirectly offsite.

A. From a review of LERs and DVRs, the following plant systems have been identified as historically experiencing repeated equipment problems.

The associated root causes, if identifiable, were also tallied.

1. There have been a total of 56 LERs/DVRs written concerning the fire protection system. Fourteen of these have involved personnel errors. Seventeen have involved equipment failures of the diesel fire pumps or associated piping / valving, some of which were repetitive. System equipment problems have shown improvement; however, there is no apparent improvement related to personnel errors on this system. There have been four violations issued relating to the fire protection program at LaSalle.

2. Ten failures of the vent stack wide range gas monitors have been documented to date. The causes of the failures include:

electrical noise problems (4); monitor window damage (3); and broken connectors (2). This is an ongoing problem per discussions with the Senior Resident Inspector (SRI). The licensee has been actively involved in trying to resolve this problem. One violation has been issued to date concerning the vent stack monitoring system.

3. Control Room ventilation system ammonia / chloride detectors have experienced a total of 25 failures to date. These detectors cause an engineered safety features (ESF) actuation of the control room ventilation system. Causes of these failures include jamming or breaking of the ammonia detector chem:assette tape (9) and blocked or partially blocked drip orifice in the chloride detector (4).

4. There have been 46 Reactor Water Cleanup (RWCU) system isolations to date (13 on Unit I and 33 on Unit 2) which have occurred since respective initial startup of each unit. Causes of the isolations include trips from high differential flow (33) and trips from high differential temperature (10). All but two of the reported isolations occurred in 1984. Prior to this, LER reporting criteria was under the old rule and RWCU system isolations were

! not reportable. The licensee has recently made changes to the system in relation to the AT isolation signals (including i modifications to Technical Specifications) which have reduced the problems. Other isolations still occur during certain plant evolutions, but the licensee has made procedural revisions to address these. No notices of violation have been issued by Region III in this area.

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5. To date, there have been eight DVRs written concerning problems l with Residual Heat Removal $ervice Water (RHRSW) pumps and motors. ,

These failures were caused by problems with breakers and one with '

the mechanical restriction of flow (i.e., wrench left in strainer). '

Additionally, six of the eight RHRSW pump motors have been rebuilt l (one at a time) due to failures related to the motors. It appears that the licensee has not adequately addressed this problem on a '

root cause basis. As of this time, the NRC has not addressed this

problem with the licensee.

6. There have been five DVRs/LERs written concerning the RHR Shutdown Cooling Isolation valve. Inere has been a problem of operatilig the valve under normal conditions. It is located within the drywell and frequently will not open when required from the control room. Many times, an individual has been required to

crack" the valve off its seat in order for it to operate.

Recently, the station preceduralized an alternate valve lineup.

Preliminary . indications are that this alternate procedure may alleviate the problem; however, the physical problem that resulted in the valve inoperability has not been resolved at this time.

B. There have been 17 DVRs written in response to inadequacies in the control over jumpers and lifted leads. Examples ir,clude: ajumper properly checked out but never installed; a previously unknown jumper found installed in a switchgear compartment; a jumper removed from service for unknown reasons; six leads lifted improperly during rewiring of a local diesel generator panel; and a lead improperly lifted which resulted in silencing of an annunciator horn in the radwaste control room. This last problem was repeated four times within a four month period during 1983-84. The number of DVRs in this  !

area has steadily decreased since 1963. This may indicate licensee performance in this area has improved; however, the review team has nof evaluated this aspect. The NRC has issued 8 violations to date  :

concerning jumper /lif ted leads.

C. A number of problems with the modification / installation programs were identified during the review. Among these were problems with updating drawings, applying changes that are applicable to both units to only one unit, inadequate or incorrect design drawings, and installation of hardware not conforming to design drawings. Examples of the problems found are:

1. On July 17, 1985, the licensee determined that four RHR shutdown cooling pump high suction flow switches on Unit I were piped '

backwards. It was subsequently determined that the drawings used for installation of replacement switches in these locations as l part of a modification package were incorrect. It was further determined that these drawings were found to be incorrect in l May 1982 and were required to be changed at that time. The '

I drawing changes were never completed and directly resulted in the four switches being incorrectly installed. Further, testing performed at the completion of the modification to ensure the correct installation of the switches did not identify the problem.

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2. On July 1,1985, Division I and Division 11 RHR area differential temperature isolation sensors on Unit 2 were found to be in-operable. It was subsequently determined that this situation had existed since original construction. The placement of the sensors was required to be with'n the inlet and outlet ventilation ducts for proper functioning of the isolation logic. However, the original installation located one set of sensors external to the inlet ductwork, thereby defeating the capability to accurately indicate differential temperatures. This inadequacy was identified and corrected for Unit I during initial construction. As part of the Engineering Change Notice (ECN) to correct the Unit 1 installation, Unit 2 was also to be corrected. This was never accomplished.

3. On June 10, 1985, it was determined that for a period of five days, Unit 2 had all three divisions of the Emergency Core Cooling System (ECCS) inoperable. Division I was inoperable .

due to two level switches being found piped backwards (as a result of a recent modification), Division II was out-of- 1 service for maintenance / modifications and Division III was I out-of-service for environmentally qualified (EQ) switch ,

replacement. The unit was in cold shutdown at the time with  !

a single division required to be operable. Also, for three  !

of the five days, the reactor building ventilation was also 1 taken out-of-service for EQ modifications causing secondary i containment to be inoperable. The cause of this problem was inadequate control / coordination of the work groups involved in )

conjunction with the installation error on Division I. l

4. On August 8,1985, a Unit 2 high reactor water level switch for the Reactor Core Isolation Cooling (RCIC) system was found to trip at approximately 28 inches of water level rather than the ,

required 55 inches. This switch was installed during a recent  !

modification. Although the modification package was apparently properly signed-off as complete, a required post-installation calibration of the switch was not accomplished.

5. On May 29,1985, a control relay for the Reactor Building l Closed Cooling Water (RBCCW) containment isolation valve failed. The cause was determined to be wrong relays installed 3 in the control circuitry. A design change had earlier revised i the control power to these relays from 120 volts AC to 125 l volts DC. The relays were to be changed but never were.

6. On March 21, 1985, during surveillance testing, the Unit 2 Reactor Protection System (RPS) sub-channel A failed to trip as required on a Control Rod Drive (CRD) low header pressure signal. In March the licensee identified that the associated terminal block was not wired according to Sargent & Lundy wiring practices. A work request was written at that time to correct the situation and to return the hardware configuration to conformance with the drawings. This resulted in RPS A not 7

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t tripping duiing the later testing because the design drawing was incorrect. The original installation was correct. Further review determined that all four associated pressure transmitters had been wired correctly but that the governing drawings were incorrect.

7. On August 28, 1983, during surveillance testing on Diesel Generator 2A, proper voltage could not be maintained under the conditions invoked and resulted in the tripping of Low Pressure Coolant Injection (LPCI) Pumps B and C. These pumps were started as part of the surveillance test. The cause was determined to be reversal of leads on the series boost input to the voltage regulator.

l The above examples are not all-inclusive of the problems identified in this area but outline the more significant incidents that have occurred.

Eleven violations have been issued in this area to date.

Currently, LaSalle has 543 outstanding modifications. This does not include modification requests in progress. Of these, 270 have been designated as priorities. These priority modifications include 85 l modifications as a result of licensing or other commitments made to the NRC.

. The licensee's ability to complete these modifications in a timely manner is in doubt. .The licensee is currently developing a 5 year ,

, program to deal with this backlog. However, from January 1985 until l

August 1985, only 74 modifications had been completed. This averages I approximately nine modifications per month. At this rate of 1 cospletion, the current priority modifications should be completed in approximately two and a half years. This assumes no new modifications l are reclassified for completion under the priority system. In addition, the licensee stated that to limit the upcoring Unit 1 Refuel outage to

! a 20 week period, only those modifications required by NRC commitment I will be accomplished. This raises a concern that several modifications  !

that may impact on the reliability of safety equipment will not be completed during this outage. It is not clear that a method, other than NRC commitments, exists for prioritization. It appears that modifica-tions to be completed are governed by factors other than by equipment or plant reliability.

D. There have been 21 DVRs/LERs written concerning the failure to take required chemistry samples on time. The reasons for missing the samples include poor communications (6), procedural errors (3), and misinterpre-tation of the requirements (4). The last DVR in this area was in 1984 which may indicate an improving trend. Three violations have been

issued concerning this area.

E. There have been 15 DVRs written concerning improperly locked valves.

No common cause(s) could be determined during the team's review of this area. The last instance occurred on May 16, 1985, and indicates that this type of problem may continue to occur periodically. The NRC has

, issued eight violations to date in the area of improperly locked /mispositioned valves.

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F. In 1984 there were 35 instances as outlined in Radiation Occurrence l Reports (RORs) of unsecured high radiation area doors. As of .

September 20, 1985, there have been 25 such instances in 1985.

Contrary to normal expectations, the majority of instances are attributable to licensee employees versus contractor personnel. The department most frequently responsible was the radiation / chemistry

• department.

> There are some instances that have stemmed from equipment problems and the licensee has a task force assigned to eliminate these mechanical difficulties. The real problem is a personnel problem, not one of procedures and equipment. As such, an April 10, 1985 memo from the plant manager to all plant personnel has stimulated positive results

from a few departments. Security and operations personnel have stopped being contributors to the problem. However, the number of occurrences continues unabated and if the current trend is maintained 1985 will have the same number of RORs for unsecured high radiation area doors as did 1984. To date, the NRC has issued 2 violations in this area.

G. The review team examined a number of documents to aid in an assessment of routine operating practices at LaSalle. The documents reviewed included NRC daily reports, current shif t turnover sheets, and Control i Room work request trend sheets. Discussions with plant persennel were i also conducted. The following observations were made during the review:

1. As a result of Resident Inspector concerns following licensing of Unit 1 in 1982, the licensee has tracked and trended the number of Control Room work requests to date.

In 1982, the number was slightly in excess of 100 for Unit 1.

(Unit 2 had not started up as of that time.) A review of licensee documentation from January through July 1985 shows

that a relatively constant number of 160 Control Room work i requests (80 per unit) exists at any given time (taking into i account larger numbers during outages). The Senior Resident Inspector at Dresden performed a count of outstanding control '

room work requests there for general comparison purposes. At i

the time of the count, there were approximately, 60 outstanding work requests for Dresden's control room (30 per unit).

l The licensee has recently increased the priority status of control room work requests via daily reviews by the Shift Engineer who

, prioritizes the work to be accomplished. The licensee has targeted annunciator problems to be addressed first. A review by operations personnel to address the annunciator concerns has identified additional work requests so that the current number is similar to that in 1982 - approximately 100 per unit. As in 1982, the significance of each work request is not great; however, the number of outstanding work requests significantly impacts the operators' confidence and ability to rely on control room indication and 4

instrumentation. Some improvement has been noted since 1982 in that the number of repeat occurrences (the same instrument failing i in the same manner) has been reduced.

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2. LaSalle appears to routinely operate with several limiting Conditions for Operation (LCO) time clocks running at any given time. For the two week period reviewed, the number of time clocks that were running averaged approximately three to six per unit.

Also, a large number of Technical Specification abnormal conditions routinely exist on a day-to-day basis. These abnormal conditions reflect items that are addressed in Technical Specifications but are not significant enough in themselves to cause entry into an LCO. Technical Specification abnormal conditions averaged 10 to 20 per unit per day during the two week period reviewed.

The licensee utilizes a " Degraded Equipment Log" (DEL) to track abnormal conditions which may result in technical specification considerations. The Shift Control Room Engineer (SCRE) is responsible for maintaining this log and it is required to be reviewed by the Shif t Engineer (SE), SCRE, and the unit operators as part of their shif t change. The DEL was developed as a result of resident inspector concerns following licensing of Unit 1 in 1982.

The DEL fort is a well developed fort and is useful in determining l the amount and significance of degraded equipment throughout the i plant. However, the manner in which it is maintained (legibility, i etc.) reduces its effectiveness. Also, the location of the log in l the control room precludes its use by the Shift Engineer during  ;

his routine approval of work requests, equipment outages, etc.  !

3. From a review of Region III daily reports and information from LERs kept by TSS, the following data was extracted concerning the number of reported scrats at LaSalle.

l i Unit 1 Year Manual Automatic Auto During S/D 1982 4 7 0 1983 3 14 0 1984 0 9 0 1985 3 5 0 TOTAL ID 15 D i Unit 2 Year Manual Automatic Auto During S/D i

1984 4 9 1 1985 - July

• 0 0 0 TOTAL 4 5 1 l l l

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" Unit 2 was in a cold shutdown condition from February to July 1985.

4. There were approximately 1260 outstanding procedure changes as of September 20, 1985. Approximately 50% of these changes affect the operations department. Changes range fron ainor typographical changes to more substantive technical changes.

Procedure changes as a result of an Action Item Record (AIR)

(these may be the result of an NRC or INPO request) and changes as a result of modifications are given priority status. AIRS generally have a flexible det date although some may have a more fixed due date because of an NRC commitment. Changes as a result of modifications are due 30 days following acceptance of the modification for operation. This later is a procedural recommendation only ("should" rather than "shall").

Tracking and trending of procedure changes other than those priority changes mentioned above is nonexistent. Tracking of priority changes was done in a haphazard and ineffective manner. All of those changes due to modifications were past due and no action had been taken. Also, of the 151 AIR

, procedure changes, 64 were past due with no action taken and 84 had no due date assigned.

2 Each procedure change has an associated cover sheet. These cover sheets are maintained by the surveillance procedure group. For the most part, these foms are illegible or incomplete and thus are ineffective in determining the significance of the procedure change. However, these forms did prove useful as routing sheets and in determining the status or location of an individual procedure change.

Priority procedure changes account for less than 20% of the total and do not always account for significant changes. The relative significance of the change is determined by the change initiator. As a result, many insignificant typographical changes are assigned " RUSH" along with significant, important-to-safety changes (approximately 40% of the total).

The licensee intends to initiate a computer tracking system 3

in early 1986 which may eliminate some of the problems in this area.

5. In general, from a review of DVRs and LERs, the review team found that the licensee has classified 212 of the DVRs/LERs as personnel errors. This number may be lower than the actual number because, in several cases, the Senior Resident Inspector at LaSalle has questioned the licensee's cause code determination.

The licensee has, in some cases, categorized a cause of a LER/DVR as something other than personnel error when personnel error was the root cause. There has also been 36 instances of missed surveillances since 1982 at the site. There appears to be a downward trend in this area. However, surveillances are still occasionally missed.

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6. Plant operations are routinely of facted by work being conducted by individual work groups. In the last eight and a-half months, plant operations were affected to a varying extent 24 times.

This indicates a lack of control over work activities on site.

IV. REGULATORY PERFORMANCE LaSalle County Station has historically exhibited poor perfomance in regard to regulatory matters. From the issuance of the low power licenses through July 1985, 172 violations have been issued to the station by the NRC. Many of these fall into specific categories:

Failure to follow procedures -10 Severity IV violations

-15 Severity V violations Inadequate procedures -13 Severity IV violations

-8 Severity V violations Modification problems -9 Severity IV violations

-2 Severity V violations Surveillance problems -5 Severity IV violations

-8 Severity V violations Personnel errors -16 Severity IV violations

-7 Severity V violations Jumpers / lifted leads -5 Severity IV violations

-3 Severity V violations Switches / valves mispositioned -1 Severity 111 violations .

-4 Severity IV violations

-3 Severity V violations LC0 violations -2 Severity Ill violations

-13 Severity IV violations

-1 Severity V violations The area of security was not evaluated by the review team, thus security violations are not included.

Currently, there is one escalated enforcement package pending concerning recent LCO violations. A different breakdown of NRC enforcement at LaSalle is described by the following table:

Unit 1 Violations Year Ill IV V Total Inspection Hours 1982 0 29 21 50 7590 1983 3 29 19 51 3736 1984 1 17 6 24 2180 1985 - July 0 9 5 14 722 l TOTAL Issued i R El TY9 14,Fl6 l

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Unit 2 Violations Year jl1 IV _V Total Inspection Hours 1983 0 10 17 27 4997 1984 1 14 12 27 2636 1985 - July 0 9 5 14 711 TOTAL Issued I T3 R EB 8,NT Total Site Violations Year 111 IV V Total Inspection Hours 1982 0 29 21 50 7,590 (Unit 1) 1983 3 35 32 70 8,733 1984 1 19 15 35 4,816 1985 - July 0 10 7 17 1 433 TOTALS A N3 75 172 2'd72 Several management meetings and enforcement conferences have been held with Commonwealth Edison Company concerning the LaSalle plant.

Civil Penalties Issued

1. Inoperable vacuum breaker closed valve Report Number: 50-373/83-26 Inspection Date: 06/21/83 Licensee Paid Penalty: 12/30/83 Amount of Penalty: $60,000

2. Unsecured vital area hatch Report Number: 50-373/83-45 Inspection Date: 10/18-21/83 Licensee Paid Penalty: 01/18/84 Amount of Penalty: $10,000

3. Standby Gas Treatment inoperable Report Number: 50-373/84-28 50-373/84-36 Inspection Date: 10/30/84 -

12/04/84 Licensee Paid Penalty: 04/19/85 Amount of Penalty: $25,000 Civil Penalties Pending

1. All three (3) divisions of ECCS and Secondary Containment out of service all at the same time Inspection Date: 06/85 Penalty Amount: Not yet determined 13

2. Security badges found in garbage dump Inspection Date: 08/85 Penalty Amount: Not yet determined Enforcement Conferences Topics June 11,1982 Security-related matters.

September 17, 1982 Morrison Company records.

May 13, 1983 Concerns on programmatic deficiencies identified in the surveillance testing program for LaSalle Unit 1.

June 23, 1983 Circumstances that resulted in a mispositioned crywell to suppression chamber vacuum breaker isolation valve during operation. Civil Penalty

($40,000)

September 30, 1983 Circumstances surrounding the inadvertent heat up event occurring on August 24, 1983.

November 10, 1983 Potential enforcement actions with respect to Engineered Safety Features (ESF) reset problems, and an inoperable primary containment isolation valve.

January 24, 1984 Concerns associated with personnel errors which resulted in degradation of the secondary containment November 10-15, 1983.

February 28, 1984 Deficiencies in the submittals regarding ESF reset functions.

June 22,1984 Concerns surrounding RWCU isolation functions for temperature differential flow being inoperable and the system was not isolated.

September 11, 1984 Exceeding an LCO.

December 7, 1984 Concerns surrounding violation of T/5 3.6.5.3 ,

and the continuing problem of control room l operators being inattentive. l May 28, 1985 Circumstances surrounding miswiring of Trip System B for ADS which resulted in an LCO being exceeded and continued personnel errors by maintenance personnel at the site. l 1

June 24,1985 Conference with Management representatives of I Ceco to discuss the recent events involving the loss of all Emergency Core Cooling Systems from June 5-10, 1985 at LaSalle.

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Management Meetings Topics June 11, 1982 NRC concerns over the excessive number of reportable events occurring af ter license issuance.

July 12, 1982 Discussion of licensee audit finding on Morrison QC records.

January 26, 1983 Discussion on proposed CECO guidelines to be used for providing information to NRC Region Ill inspectors.

February 17, 1983 Discussion on future improvements of the regulatory performance of Ceco.

June 1, 1983 Discussion on recent advisory performance trends at the Ceco nuclear facilities.

July 26, 1983 Meeting in Ceco corporate offices to discuss improvement of licensee regulatory performance and enhancement of communications between the NRC and CECO.

September 9, 1983 Continuous discussions on improvement of l licensee regulatory performance and enhancement of communications between CECO and NRC.

September 27, 1983 Discussion on cable separation issues.

October 19, 1983 Continue discussions on improvement of licensee regulatory performance and enhancement of communications between CECO and NRC.

November 21, 1983 Discussion of potential enforcement actions with respect to Engineered Safety Features (ESF) reset and an inoperable containment isolation valve.

September 7, 1984 Discussion of regulatory improvement and enhancing two way communications between Ceco and NRC.

March 7,1985 Discussion of the licensee's regulatory improvement program status.

June 24, 1985 Meeting at LaSalle to discuss the ongoing regulatory improvement program for Commonwealth Edison plants.

In addition,14 meetings have been held between the licensee and the NRC which may be classified as informational / working type meetings.

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V. NRC PERCEPTION OF LASALLE Certain perceptions of the LaSalle plant appear to be common among regional / resident inspectors involved with the site. The review team interviewed Region 111 personnel who have had dealings with the plant.

The following is a brief synopsis of areas in which at least two or more of those interviewed feel problems exist:

1. There exists a question concerning the effectiver.ess of the Quality Control (QC) organization at LaSalle. Specifically, those interviewed stated that weaknesses exist in the QC program in the areas of procurement, modifications, and overall review of work performed at the job sites.

2. The function of the Station Nuclear Engineering Department (SNED) is weak in the area of station modifications. SNED presence onsite appears to be a weak link in the design change process. The modification process seems to be compartmentalized to the extent that the adequacy of the SNED function in this area could not be determined. However, an indepth review by the task force was not performed in this area.

3. Overall control of the station construction group is weak. Station e.

construction is a separv e entity onsite with the function of managing contractor (construction) personnel. There does not appear to be sufficient communication to/from the station on work being performed by contractors.

4. Communications between departments / work groups is weak. Activities of one group are not necessarily communicated to other groups that could be affected by those activities.

5. Weaknesses have historically been evident in the area of surveillances. There has been an ongoing problem with missed surveillances since 1982. However, there appears to have been an improving trend in the implementation of the program since 1984.

6. Certain plant systems were identified by Region III personnel as

" problem" systems. All those identified were subsequently evaluated by the review team and outlined (if applicable) in Paragraph III. A of this report.

7. Control of maintenance activities at job sites in the plant seems weak. First-line supervisors spend excessive amounts of time performing "in-office" functions rather than job-site supervisory functions.

8. LaSalle Technical Specifications may be too complex to be used effectively. The sheer volume of the Technical Specifications may contribute to some of the LCO problems identified. An example of 16 4

this is surveillance requirements for diesel generators specified in one unit's Technical Specifications addressing requirements for the other unit.

It should be noted that all of the aforementioned concerns are based on perceptions as presented to the review team by those interviewed. The review team has not, in most of the subject areas, perfomed a followup to verify the validity of the specific concerns.

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VI. CONCLUSIONS There are a number of conclusions that can be drawn from the data and l interviews conducted during the review process as evaluated by the review team. Specifically, from review of plant data (including LERs, DVRs, etc.), the following was determined:  !

1. Repeated equipment failures of any system should not normally be acceptable. The systems as outlined in this report in Paragraph III. A are experiencing excessive numbers of problems.

2. There is less than adequate control of work activities, both onsite and offsite that have an affect on the plant. Problems in the control of , jumpers / lifted leads, missed samples, control of locked valves, control over high radiation areas, and in general, the large number of personnel errors all seem indicative of this.

3. Problems exist in the implementation of the modification program at all levels. This is evidenced by the package preparation problems, drawing update problems, and hardware installation problems recently experienced by the licensee.

4. The number of outstanding control room work requests is excessive.

5. The number of outstanding modifications is excessive.

6. The number of outstanding procedure changes is excessive.

7. The number of reactor scrams experienced to date is excessive.

8. The overall number of personnel errors is excessive.

9. LaSalle's regulatory performance has been poor, as evidenced by the number'of violations issued to date.

10. A determination of root causes of problems have not been fully addressed in many cases.

From the interviews conducted with Region III personnel, the following probler areas were indicated:

1. The Quality Control organization is less than effective.

2. Communicationsbetweendepartments$orkgroupsmaybelessthan adequate.

It should be noted that many of these same problem areas were previously identified by the licensee in an onsite review conducted July 16, 1982 at the request of the NRC.

In summary, it appears that there are many areas where problems exist that have a detrimental effect on the plant. Many of these have been 18

ongoing and have been the subject of much attention, both by the licensee and the NRC. Despite this attention, acceptable resolution of these issues has not been forthcoming in all cases. This is indicated by the  !

fact that the station is still experiencing may of the same types of 1 problems today as have occurred since 1982. Also, problem areas currently exist that have not been previously identified to the Region but which require further review.

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