ML20151Y953
| ML20151Y953 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 02/11/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20151Y949 | List: |
| References | |
| 50-373-85-01, 50-373-85-1, 50-374-85-01, 50-374-85-1, NUDOCS 8602130228 | |
| Download: ML20151Y953 (45) | |
See also: IR 05000373/1985001
Text
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SALP 5
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SALP BOARD REPORf.--
U.S. NUCLEAR REGULATORY COMISSION
REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
50-373/85001; 50-374/85001
Inspection Report Nos.
Commonwealth Edison Company-
Name of licensee
LaSalle County Nuclear Power Station
Name of Facility-
May 1, 1984 through September 30, 1985
Assessment Period
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8602130228 860211 3
PDR ADOCK 0500
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I. INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data on
a periodic basis and to evaluate licensee performance based upon this
information. SALP is supplemental to normal regulatory processcs used
to ensure compliance to NRC rules and regulations. SALP is intended to
be sufficiently diagnostic to provide a rational basis for allocating NRC
resources and to provide meaningful guidance to the licensee's management
to promote quality and safety of plant construction aad operation.
A NRC SALP Board, composed of staff members listed below, met on
December 3,1985, to review the collection of performance observations
and data to assess the licensee performance in accordance with the
guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee
Performance." A summary of the guidance and evaluation criteria is
provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety
performance at LaSalle County Nuclear Power Station fcr the period
May 1, 1984 through September 30, 1985.
SALP Board for LaSalle County Nuclear Power Station
Name Title
J. A. Hind Director, Division of Radiation Safety
and Safeguards
C. E. Norelius. Director, Division of Reactor Projects
C. J. Paperiello Director, Division of Reactor Safety
N. J. Chrissotimos Chief, Reactor Projects Branch 2
W. D. Shafer Chief, Emergency Preparedness and Radiological
Protection Branch
J. J. Harrison Chief, Engineering Branch
G. C. Wright Chief, Reactor Projects Section 2C
F. Hawkins' Chief, Quality Assurance Programs Section
W. G. Guldemond Chief, Operational Programs Section
J. R. Creed Chief, Physical Security Section
R. B. Landsman Project Manager, Reactor Projects Section 2C
A. Bournia LaSalle Project Manager, NRR
M. J. Jordan Senior Resident Inspector
J. C. Bjorgen Resident Inspector
R. A. Kopriva Resident Inspector
K. R. Ridgway Reactor Inspector
N. C. Choules Reactor Inspector
T. E. Taylor Reactor Inspector
G. L. Pirtle Safeguards Inspector
M. J. Oestmann Senior radiation Specialist
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II. CRITERIA
The licensee performance is assessed in selected functional areas
depending whether the facility is in a construction, preoperational
or operating phase. Each functional area normally represents areas
significant to nuclear safety and the environment, and are normal
programmatic areas. Some functional areas may not be assessed because
of .little or no licensee activities or lack of meaningful observations.
y Special areas may be added to highlight significant observations.
One or more of the following evaluation criteria were used in assessing )
each functional area. -)
1. Management involvement in assuring quality
2. Approach to resolution of technical issues from a safety I
standpoint
3. Responsiveness to NRC initiatives
4. Enforcement. history
5. Reporting and analysis of reportable events
6. Staffing (including management)
7. ' Training effectiveness and qualification
However, the SALP Board is not limited to these criteria and others may
have been used where appropriate.
Based upon the SALP Board assessment each functional area evaluated is
classified into one of three performance categories. The definition
of these performance categories is:
Category 1: Reduced NRC attention may be appropriate. Licensee-
management attention and involvement are aggressive and oriented toward
nuclear si.fety; licensee resources are ample and effectively used so
that a high level of performance with respect to operational safety or
a construction is being achieved.
Category 2: NRC attention should be maintained at normal levels.
l Licensee management attention and involvement are evident and are
concerned with nuclear safety; licensee resources are adequate and
are reasonably eff ective such that satisfactory performance with
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respect to operational safety or construction is being achieved.
Category 3: Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers
nuclear safety, but weaknesses are evident; licensee resources appear to
be strained or not effectively used so that minimally satisfactory
performance with respect to operational safety or construction is being
achieved.
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Trend: The SALP Board has also categorized the performance trend in
each functional area rated over the course of the SALP assessment period.
The categorization describes the general or prevailing tendency (the
performance gradient) during the SALP period. The performance trends
are defined as follows:
Improved: Licensee performance has generally improved over
the course of the SALP assessment period.
.Same: Licensee performance has remained essentially constant
over the course.of the SALP assessment period.
Declined: Licensee performance has generally declined over.
the course of the SALP assessment period.
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III. SUMMARY OF RESULTS
Overall, the licensee's performance, although acceptable, declined during
this SALP assessment period. This decline appears to be indicative of
weaknesses within the management controls at the site. Although the
licensee has actively pursued the development of a Regulatory Performance
Improvement Program, it has not been implemented in a manner which
resulted in improved performance.
It is evident that strong measures are needed to improve the regulatory
performance at the LaSalle facility.
Rating Last Rating This Trend Within
Functional Area Period Period This-SALP Period
Plant Operations 3 3 Mixed
Radiological Controls 2 2 Declining
Maintenance / Modifications 2 3 Declining
Surveillance and Inservice. 2 3 Declining
Testing
Fire Protection / Housekeeping 2 1 Not discernible
Emergency Preparedness 2 2 Same
Security 2 2 Same
Refueling 1 * *
Quality Programs and
Administrative Controls 2 3 Same
Licensing Activities 2 2 Same
Startup Testing (Unit 2) 2 1 'NA
- No refueling outage during SALP period.
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IV. PERFORMANCE ANALYSIS
A. Plant Operations
1. Analysis
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This functional area was under continuous review by the
resident inspectors during the asssssment period. One special
inspection was conducted, with a continuous 52 hour6.018519e-4 days <br />0.0144 hours <br />8.597884e-5 weeks <br />1.9786e-5 months <br /> control room
inspection effort, and two regional based inspections were also
conducted. As a result of these inspections, ten violations
were identified.
a. Severity Level IV - Failure to close the Drywell
Purge System valves within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Action Statement
of the Technical Specification (373/84023-01; 374/84030-02).
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b. Severity Level IV - Failure to follow administrative
procedures for proper shift and relief turnovers and
proper log entries (373/84023-02; 374/84030-03).
c. Severity Level IV - Failure of the operators to respond
to an off-normal condition concerning safety relief valve
lifting and two annunciators indicating a problem with
ventilation system (373/84023-04A, 04B; 374/84030-05A, 058).
d. Severity Level IV - Failure to follow the Action Statement
of the Technical Specification while having both trains of
the Reactor Water Cleanup System bypassed (374/84023-01).
e. Severity Level III - Four examples of failure to control
operating activities and ensure safe operation of the
facility resulting in the Standby Gas Treatment System
being inoperable (373/84028-01; 374/84036-01).
f. Severity Level IV - Failure to follow procedures resulting-
in room temperature controllers for safety-related equipment
not being set correctly and the improper settings not being
included in the operator rounds (374/85013-04).
g. Severity Level IV - Failure to prevent six inadvertent
Engineered Safety Feature (ESF) actuations (374/85017-04).
h. Severity Level IV - Failure to have an adequa'te procedure
which resulted in the isolati_n of the Residual Heat Removal,
Reactor Building Closed Cooling Water and Primary Containment
Ventilation systems due to an inadequate equipment outage
sheet. (374/85021-02A, 028).
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i. Severity Level IV - Failure to have a procedure for swapping
two control rod drive pumps resulting in a manual scram due
to accumulator alarms in the control room (373/85019-03)
j. Severity Level IV - Failure to follow procedures when
taking a control rod drive nydraulic control unit out of
service (373/85027-02; 374/85028-02)
During the first part of the assessment period, control room
personnel continued to have difficulty in identifying the status
of sensitive equipment, a problem previously noted in SALP 4,
resulting in several management and enforcement conferences
(items a, c and d). The continued inability to properly identify
equipment status resulted in the Level III violation for having
an inoperable Standby Gas Treatment System (Item e) and a civil
penalty of $25,000.
In response to the SALP 4 report utility management took aggressive
action to make the Licensed Operators in the control room aware
of their responsibility for compliance with Technical Specifications.
Programs to assist control room personnel in meeting the Action
Statement requirements of the Technical Specifications were also
implemented. The number of personnel allowed in the control
room was restricted. .The R0s' response to alarms on the units
became more timely and tracking of short term time clock Action
Statements for Technical Specification compliance became aggressive.
All of the above resulted in an improvement in the professionalism
of-control room operations. Management's aggressive approach to
control room problems was then redirected to other site problems
(see maintenance), and as a result, the professionalism of
control room operations started to decline. Examples of this
were six unnecessary ESF actuations in the mi.ddle of 1985
(item g) and late in the assessment period three additional-
unnecessary ESF actuations (items h and i), one of which was a
scram due to operation's personnel not being sufficiently
aggressive. Management's corrective actions after the SBGT
event were not sufficiently reenforced such that late in the
assessment period, the licensee's lack of tracking short term
duration time clock Action Stateme.7ts and the adequacy of log
entries were again brought to the attention of the licensee
by the Resident Inspectors.
Responses to specific violations were technically sound, viable,
and generally thorough. However, as noted abovo, the licensee
had trouble maintaining the level of performance brought about
by the corrective actions. The initial responses were acceptable
in most cases.
Response of the operating staff to actual events was considered
very good. This was best illustrated by the operator's actions
in bringing the one operating unit to a cold shutdown condition
when, due to a ruptured expansion joint, the service water
building flooded. The shift's response and overall communications
were excellent.
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A special Task Force evaluation of site performance was conducted
from July.22 through September 20, 1985. The problems identified
in the operations area by the Task Force were:
- The shift routinely operates with several Limiting Conditions
for Operation time clocks running at any given time, and
with a large number of Technical Specification abnormal
conditions which are not significant enough in
themselves to cause entry into a Limiting Condition for
Operation time clock.
- Prioritization of Control Work requests was needed to reduce
the number of work requests in the control room.
- A large number of outstanding procedure changes existed in
the operations department.
There were 157 reportable events during the assessment period
attributed to the operations area which is an order of
magnitude greater than the 17 such events reported in the
previous SALP period. This is significant even considering
that Unit 2 was not operating in the previous period. Many of
the reports were due to isolations of the Reactor Water Cleanup
System and spurious initiations of the Control o.com Ventilation.
These ESF actuations had been reduced towards the end of the
assessment period. However,.an aggressive approach to this
problem early in the assessment period could have prevented
many of these reportable events. In addition, the licensee
has not determined a final resolution of these two problems.
Eighteen events were the result of personnel error, twenty-seven
events were attributed to design, manufacturing or construction
problems, one event was due to external causes, and six events
were the result of inadequate procedures. The number of events
indicates less than aggressive action in providing solutions to
prcblem areas.
During the period, the licensee experienced 32 unscheduled reactor
scrams (18.on Unit 1 and 14 on Unit 2). Ten of the scrams
occurred while the reactors were in shutdown with all rods fully
inserted. Seven of the scrams resulted directly from personnel
errors. Four scrams were due to defective procedures with the
remainder of the scrams attributed to component failures. The
number of scrams is considered excessive.
During the reporting period, examinations were administered
to 10 reactor operator and 11 senior reactor operator candidates.
There were no reapplications and the overall pass rate was 90%
which is above the national average. Requalification examinations
were not administered by the NRC at LaSalle during this period.
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2. Conclusion
The licensee is rated Category 3 in this area based primarily
on the number and nature of the violations and on the licensee's
inability to sustain a higher level of performance. The licensee
was performing at a Category 3 level early in the assessment period
and midway through the period had raised this level of performance.
They then began declining in performance which continued through
the end of the period.
3. Board Recommendations
The Board recommends a continued high level of NRC and Licensee
management attention in this area.
B. Radiological Controls
1. Analysis
Nine inspections were performed during this assessment per'cd by
regional specialists.. The inspections ~ included radwaste and
transportation management, operational radiation protection,
confirmatory measurements, and environmental monitoring. The
resident inspectors also inspected the licensee's activities in
this area for programmatic implementation and procedural
compliance. The following ten violations were identified:
a. Severity Level IV - Radioactive liquid release made with
monitor alarm / trip setpoint less conservative than
required by technical specifications (373/84031-03;
374/84038-03).
b. Severity Level IV - Failure to adhere to radiation control
procedures concerning location of personal dosimeters on
body, personnel frisking techniques, ~and 50P frisking
requirement (373/85014-01A, O1B, 01C; 374/85014-01A, OlB,
01C).
c. Severity Level IV - Failure to secure radioactive material
in an unrestricted area (onsite dump) from unauthorized
removal (373/85025-02; 374/85026-02).
d. Severity Level IV - Failure to evaluate airborne
radioactivity concentrations during an offgas filter
replacement incident (373/85025-03; 374/85026-03).
e. Severity Level V - Failure to perform technical
specification required weekly gamma isotopic analysis on
each milk sample (373/85003-04; 374/85003-04).
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f. Severity Level V - Failure to include a technical
specification required table of distances and directions
of sampling locations to the plant and maps of all sample
locations (373/85003-05; 374/85003-05).
g. Severity Level IV - Failure of guard forca to be alert to
prevent entrance into a high radiation area (373/84014-01;
374/84018-01).
h. Severity Level IV - Failure to update the computer access
code to the charcoal absorber vault; a high radiation area
(374/84022-01).
i. Severity Level V - Failure to follow procedure to post an
access point to a contaminated area (373/84026-02).
j. Severity Level IV - Failure to control access to a high
radiation area (373/84026-01).
These violations were indicative of licensee inattention
to procedural details, and of weaknesses in correction of
identified high radiation ama control problems. No
overexposures or intakes which 1xceeded regulatory requirements
occurred.
Eleven reportable events were identified during the assessment
period. Nine of these events were the direct result of
personnel error, primarily leaving high radiation areas
unsecured. About two thirds of the way through this assessment
period, the licensee was informed that it was not necessary to
report unsecured high radiation areas as LERs; no further
reports were made. By the close of the assessment period,- the
high radiation area control problem had diminished, but had not
been eliminated.
Licensee staffing has generally improv3d during this assessment
period; however, staff inexperience remains a weakness. This
was evidenced by the staff's inadequate response to the offgas
filter changeout problem discussed later in this report. Recent
actions taken to strengthen staffing include promoting the lead
health physicist to the Radiation Protection Manager (RPM),
transferring an experienced radiation protection supervisor to
assist the RPM, and hiring experienced contract staff and
technicians for the first refueling outage. The number of
professional health physics personnel has been relatively
unstable; two of the four experienced health physicists left
CECO during this assessment period.
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The licensee implements adequate training and retraining of
Rad-Chem Technicians and other plant workers. This training
has been augmented during this assessment period by additional
retraining for workers who violate radiological controls. The
retraining appears to have made a positive contribution to
workers'. performance, increasing awareness of radiological
controls and procedural adherence. Informal supervisory training
of workers in radiological control matters was recently initiated
as part of the licensees RAD / CHEM Improvement program in response
to NRC identified weaknesses in workers' implementation of the
radiological control program. Insufficient time has elapsed to
assess effectiveness of the supervisory training.
Station management involvement during the major part of this
assessment peri.od was weak. Strong corrective actions were
not taken to correct inspector and self-identified radiation
protection problems concerning procedural adherence, contamination
control, and inspector identified weaknesses. Also, a need for
improved management of the environmental program is indicated by
the increased number of violations. During the latter part of
the period, improvements in management attention were made.
Evidence of these improvements were noted by increased attention
to, and followup of, Radiological Occurrence Reports and personnel
contamination events; more disciplinary actions for persons
violating procedures; purchasing and installation of portal
a monitors,- frisker booths and monitoring equipment; increased
management attention to, and correction of, inspector concerns
and identified weaknesses; and providing more physical space to
the Radiation Protection Department to increase operating
efficiency.
The licensee's responsiveness to NRC initiatives was weak during
the first part of the assessment period, with an indication of
significant improvement near the .end of the period. Weaknesses
concerning identified high radiation area and procedural adherence '
violations went partially uncorrected during a major portion of
this assessment period. In response to NRC concerns near the
end of this assessment period, the licensee initiated a Radiation /
Chemistry Improvement Plan designed to address identified
radiation protection program weaknesses. The proposed progrr.m,
which appears responsive to NRC concerns, includes supervisory
improvements in addition to specific improvements in staffing,
high radiation door controls, personal and area contamination
controls, procedural adherence, monitoring eq #,went,
unconditionas releases, and communications bet w r departments.
Several of the Radiological Environmental Monitoring Program
(REMP) problems which had been identified during the previous
SALP period had not been completely resolved. Licensee
responsiveness to these issues improved considerably following a
special inspection in April 1985 with the licensee corporate group
having REMP management responsibility. The corporate environmental
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groups were restructured to place more emphasis on REMP management,
and representatives of this group met with Region III staff at
the regional office to address specific concerns relating to the
LaSalle REMP. The liccnsee has been generally responsive to
both NRC and interna 7ly identified problems in the radwaste area
as evidenced.by relocetion of the liquid radwaste effluent
monitor to an onsite location, ruodification to change the source
of control rod drive cooling water to minimize primary coolant
conductivity anomalies, and a commitment to evaluate the
significance of particulate activitv collected on charcoal
absorbers in gaseous effluent streau.3.
The licensee's approach to resolution of radiological technical
issues has been generally adequate. One exception was the
handling of a radiolejical incident concerning the release of
nobie gas daughter products and the subsequent con' ~mination of
personnel associated v th an offgas filter changeot... NRC
inspections identified problems concerning contami'.ation
controls, procedural adherence, radioactive materials controls,
and availability of friskers, frisker booths, and portal
monitoring systems. The licensee has initiated actions to
correct these problems.
Support for the ALARA Program is adequate; however, increased
management support- for the reclamation phase of the contamination
control program is desirable. Also, strong management actions
are needed to take preventive measures to prevent area
contamination. Self-identified high radiation area violations
continue to exist, and it appears management actions to prevent
recurrence have not been totally effective. Improvement in these
areas is needed to support the program improvements made in the
latter part of this ass'ssment period. Total worker dose during
this assessment period was about 250 person-rems in 1984 (the
first full year of commercial operation of Unit 1; Unit 2 became
operational near the end of the year) and is estimated to be
approximately 650 person-rems for 1985. These cumulative doses
are well below the average for U.S. boiling water reactors, but
not atypical for new plants. The increase in exposure for 1985
is due to an extended Unit 1 Maintenance / Surveillance outage and
the contribution from a full year's operation of Unit 2.
The licensee's radiological effluents are below average for
U.S. boiling water reactors, but not atypical for new plants.
Effluent records were generally complete, well maintained and
available. A below ground pipe break was identified and isolated
during this assessment period. It resulted in soil and ground
water contamination and a minor unplanned release of activity to
the cooling lake and subsequently to the river.
Licensee laboratory performance was generally satisfactory
during the period. Facilities, equipment staffing, and
procedures were satisfactory. Although no evidence of
significantly weak performance was noted, the licensee's
policy of rotating technicians between chemistry.and health
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physics, with resulting long intervals between laboratory
assignments, could require strong management oversight to avoid
performance problems. The licensee does a satisfactory job of
reviewing gamma analysis results and quality control of
instruments and chemicals appeared adequate. The' licensee also
performed well.in. confirmatory measurements comparisons with the
regional laboratory, achieving 20 agreeme'n ts in 20 comparisons.
Difficulty was encountered in obtaining a gas sample for
comparison owing to poor vacuum at the Unit 2 pretreatment
panel. -This was an intermittent problem identified'several
months previously, but it had been regarded as a low priority
item by the licensee, and it was not yet corrected. In
response to inspector comments, the licensee agreed to correct
the problem within two months to facilitate sampling.
The licensee has satisfactorily implemented the solic radwaste
requirements of 10 CFR Part 61 and 10 CFR Part 20.31;. The
licensee has established an adequate QA/QC program to assure
compliance with waste classification and has properly completed
the necessary information on the manifests accompanying
radwaste shipments. The licensee has yet to complete
development of a new computer program designed to prompt the
user in all aspects of shipments; work is in progress.
2. Conclusion
The licen,ee is rated Category 2 in this area. The overall
perfeimance trend for SALP 5 has declined.
3. Board Recommendation
None
C. Maintenance / Modifications
1. Analysis
The resident inspectors routinely inspected the licensee's
activities in this area. Nine special inspections, by region
based personnel, were also performed in the maintenance area.
Thirteen violations were identified as follows:
a. Severity Level IV - Failure to adequately test the Reactor
Water Cleanup System differential flow indicator because
after modification, data sheets were not provided by the
Architect-Engineer resulting in the calibration procedure
being incorrect (373/84003-02; 374/84002-04).
b. Severity Level IV - Failure to issue timely updated
procedures or drawings after the modification for the
Reactor Core Isolation Cooling System and the Feedwater
System (373/84033-02A, 028; 374/84040-02A; 02B).
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c. Severity Level V - Failure to have an adequate procedure
for filling and venting an Automatic Depressurization
System switch after it was replaced resulting in a scram
(373/85009-02).
d. Severity Level IV - Failure to have an adequate procedure
resulting in a Group I isolation and Shutdown Cooling
System isolating (373/85012-03A, 038; 374/85012-03A, 038).
e. Severity Level IV - Failure to have an authorized work
request prior to work being performed which resulted in
an isolation of the Shutdown Cooling System (373/85012-04;
374/85012-04).
f. ' Severity Level IV - Failure to follow procedure resulting
in the Automatic Depressurization System being returned to
service while' inoperable (373/85017-04).
g. Severity Level IV - Failure of the Station Nuclear Engineering
Manager to issue correct drawings for a modification
(373/85017-05).
h. Severity Level III - Nine examples of failure to perform
an Environmental Qualifications modification correctly
resulting in not having the required number of Emergency
Core Cooling Systems operable (373/85023-01; 374/85018-01).
i. Severity Level IV - Failure to incorporate an ECN and
subsequent FCRs into permanent drawings resulting in the
Unit 2 leak detection monitors not being properly located
(374/85025-01).
j. Severity Level IV - Acceptance criteria were not specified
in the maintenance procedure for repair of the valve disc
bushings (373/84026-03A, 038; 374/84033-02).
k. Severity Level V - Failure to perform preventive
maintenance lubrications as required (373/84032-05;
374/84039-05).
1. Severity Level V - Several examples of failure to follow
procedures such as control of lifted leads, CECO temporary
system change procedure LAP-240-6, and drawing control
procedure LAP-810-5 which requires that drawings which are
not to be used for maintenance, operation, design, etc.,
be stamped with a CAUTION stamp (374/85013-05).
m. Severity Level IV - Lack of records to indicate that a
defective safety-related relay was replaced during
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maintenance activities (373/85013-02; 374/85013-02).
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A recurring problem throughout the assessment period was a lack
of adherence to prescribed procedures by personnel performing
maintenance / modification activities (items e, k and 1). Also,
failure to have adequate procedures (items a, c, d, f, g, h
and j) was a recurring problem. In addition, one of the
violations involved failure to update related documents
following maintenance / modifications (item h). This area had
been addressed in the previous SALP as a weakness. Of
particular significance in the area of failure to follow
procedures or have adequate procedures was item h, a Severity
Level III violation, which resulted in issuance of a Civil
Penalty of $125,000.
The lack of early planning and scheduling of the Unit 2 outage
in March 1985 for replacement of instrumentation to meet
environmental qualifications resulted in extensive delay in the
completion of the outage and several of the violations. The
failure of the Station Nuclear Engineering Department to issue
correct drawings in a prompt manner resulted in one of the
violations (item g) and contriluted to several other violations
because the station was requirtd to review, approve, and issue
the work packages while the outage was occurring, thus rushing
this work effort for the modification. The licensee's corrective
action to the violations listed above were often viable, but in
some cases, lacked thoroughness or depth.
A Task Force Evaluation in July and August, 1985, indicated
additional problems as follows:
a. There were 543 outstanding modifications of which 270 had
been designated as priorities. These priority modifications
include 85 modifications as a result of licensing or other
commitments made to the NRC. Other than by NRC commitment
there appeared to be no clear basis for assigning priorites.
o. Thrcughout the assessment period, the number of control
room work requests remained at approximately 80 per unit.
The significance of individual work requests was not of
importance; however, the number of outstanding requests
significantly impacted the operators' confidence and ability
to rely on control room indicators and instrumentation.
c. Procedures were net being issued in a timely manner after
completion of a modification.
During the assessment period there were several maintenance
personnel errors that resulted in unnecessary scrams or ESF
actuations. Examples of these were: while performing work on a
wide range level monitor, a mechanic bumped the instrument
rack causing a scram, and a mechanic grounding an instrument
caused the bypass valves to open and close causing a pressure
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. spike on the instrument rack and a scram. Another personnel
error which did not cause an ESF actuation, but could have caused
a problem resulted in air lines to the air start motors on a
diesel being connected backwards after maintenance such that the
diesel would not start. This error was found by post-maintenance
testing and observed by the inspectors at the time.
Forty-two reportable events occurred in this area during the
assessment period. Sixteen events were the result of personnel
errors, eight were caused by design, manufacturing, or
construction problems, one event was due to a defective
procedure, and one event was due to a management / Quality
Assurance deficiency. The high number of personnel errors was
considered excessive and was also addressed by the Task Force
Evaluation conducted in July and August.
Throughout the inspection period, communications between the
maintenance groups as well as communications with the cperation's
organization was not good. This was brought.to the attention of
management several times and was also determined to be a problem
by the Task Force. Another recurring problem throughout the
assessment period was inadequate testing for operability of
equipment after maintenance or modifications. This was the root
cause of the Level III violation (item h) listed above as well
as the Level III violation in the operations area.
In an attempt to correct these problems the licensee hired a
consultant to assist in improving communications and to increase
personnel awareness of their responsibilities. As a result of
the consultant's findings the need for planning and scheduling
of work was developed such that all groups were aware of what
actions were needed to support maintenance activities. A
planning / scheduling group was organized at the end of the
assessment period. The effectiveness of the group could not
be evaluated because of the relatively short time of its-
existence.
2. Cor.clusion
The litansee is rated Category 3 .in this area. This is a
reduction from the' previous assessment period. The rating is
based on the number of violations identified above and the number
and significance of Licensee Event Reports, all of which indicate
serious problems in the implementation of the maintenance /
modification program. The trend within the period was
declining.
3. Board Recommendations
The licensee should increase its management involvement in this
area. The licensee should assess procedural discipline in the
maintenance area, and strengthen effectiveness.
16
D. Surveillance and Inservice Testing
1. Analysis
During the assessment period, the resident inspectors routinely
inspected this area, concentrating on implementation'of procedures.
Five additional inspections were conducted by regional based
inspectors in the areas of: inservice testing of pumps and
valves; surveillance and calibration programs, including their
implementation to verify compliance with regulatory requirements;
followup on licensee corrective actions taken to reduce excessive
temperatures inside the drywell; and the environmental qualification
program for safety-related equipment inside the drywell.
As a result of these inspections, thirteen violations were
issued as follows:
a. Severity Level V - Failure to take a hydrogen gas sample
within the action statement time of the Technical Specifications
(373/84003-01).
b. Severity Level V - Failure of a mechanic to test the
correct Recirculation Pump trip switch after it was
placed in bypass (373/84014-02).
c. Severity Level IV - Failure to have an adequate procedure
and failure of personnel to follow procedures resulting
in tripping of a Recirculation Pump and two isolations
of the reactor building ventilation system (373/84023-03A,
03B; 374/84030-04A, 048).
d. Severity Level V - Failure to adhere to procedures
resulting in the isolation of the Reactor Water Cleanup
System and the isolation of the control room emergency
ventilation system'(374/84037-01A, 018).
e. Severity Level V - Failure to provide procedures for
the performance of a function and calibration test
required by Technical Specifications of the high pressure
leak detection monitoring switches for the Residual Heat
Removal System (373/84033-06A; 374/84040-05A).
f. Severity Level'V - Failure to follow procedures resulting
in the Shutdown Cooling System isolating and exceeding the
hydrostatic test pressure setting thus lifting three ADS
valves (373/85009-04A, 04B; 374/85009-03A, 038).
g. Severity Level IV tailure to follow procedure on
returning an instrument to service causing a pressure
spike and a reactor scram. Similar as violation
(373/85009-02). See maintenance section (373/85024-02).
17
I
l
l
h. Severity Level IV - Failure to implement pump vibration
testing in accordance with Section XI of the ASME Code or
commitments to NRC (373/85016-03; 374/85016-03).
i. Severity Level IV - A significant number of portable-
tools, gauges, and instruments were found to be improperly
controlled (373/84032-01; 374/84039-01).
j. Severity Level IV - Failure to establish adequate measures
to indicate the operating status of structures, systems
and components in that yellow caution tags we.re left on
containment monitoring system control room recorders
indicating that alarm setpoints were set at setpoints which
were found to be different from the actual field setpoints.
These caution tags were attached to these recorders from
September 1984, to August 1985. (374/85027-02).
k. Severity Level IV - Inadequate or lack of documented
procedures to administer the drywell temperature monitoring
program; to evaluate and review the data collected; and to
take corrective actions when temperatures exceed Technical
Specification limits. Additionally, documented surveillance
procedures to detect potential sources of increased sensible
heat loads inside the drywell were not available (373/85026-03;
374/85027-03).
1. Severity Level IV - Lack of prompt corrective action to
review and evaluate recalculated containment monitoring
alarm setpoints to assure that the qualified life of
safety related components was not degraded (373/85026-04;
374/85027-04).
m. Severity Level IV - Failure to comply with Technical
Specification Section 3.7.7 in that special reports
related to drywell temperatures were not submitted in a
timely manner to the NRC (373/85026-01; 374/85027-01).
A continuing problem in the performance of surveillances was the
lack of procedural adherence resulting in several ESF actuations
(items b, c, d and f). Also, the failure to have an appropriate
procedure for performing work was a continuing problem (items c,
h, j, and k).
These violations also contained examples of untimely engineering
evaluation of data relating to safety-related components, and
failure to fully meet commitments made to the NRC. Specifically,
the licensee did not ensure through a temperature monitoring
surveillance program and actual operating observations that
safety-related cables and components will not be subjected
to temperatures in excess of their environmental qualification
threshold temperatures as required by equipment qualification
limits and the Technical Specification requirements.
18
As_a result of the NRC findings. relating to the excessive
drywell temperatures, on September 3,1985, the licensee
committed that a more comprehensive corrective action program
will be initiated to closely monitor the excessive temperatures
in the Unit 1 and Unit 2 drywells. Subsequent to the SALP period,
a management meeting was held on October 1, 1985 to further
discuss this issue and the licensee did provide sufficient
evaluation and documentation to prove the operability of the
equipment in the drywell.
Procedure deficiencies were also identified in the inservice
testing program, and there was little evidence of program
planning or assignment of priorities. Administrative procedures
did not address all of the Section XI requirements and were not
well defined early enough to establish and assure a desired
quality level for the inservice testing program. Documentation
associated with the program was difficult to retrieve and in
some cases unreadable; consequently, test records were not
conducive to trending and identification of potential generic
problems. As a result, problems which are identified via
inservice testing are generally treated as isolated cases.
The examples above identify the need for increased management
involvement and awareness of the program.
Another problem was the failure to perform surveillances which
were required by Technical Specifications (items a and e). Also
once a problem was identified, the-licensee was slow to react to
prevent it from recurrence. In one case, two consecutive
surveillances of the Recirculation Pumps resulted in a tripped
Recirculation Pump (items b and c) and a power reduction as a
result of a mechanic isolating one switch and then performing
surveillance on an unisolated switch. In another case, a
monthly surveillance was missed due to the lack of a procedure,
even though the lack of the procedure had-been identified
previously.
Personnel error while performing surveillances was a continuing
problem. Examples were: using the wrong volt meter which caused
a ground in the Reactor Protective System resulting in a half
scram; while performing surveillances, a full scram occurred
when the mechanic placed a radio on an instrument rack while
performing surveillance on a switch in another instrument rack.
The rack being worked on induced a half scram and the radio
jarred the other rack causing the other half scram which completed
the logic for a full scram. More than once after completing a
surveillance, a system was valved back into service too rapidly
which caused a perturbation on the instrument rack that then
caused a scram. This last example technically could be described
as a known design problem because both instrument racks are
connected such that a water level perturbation, caused by closing
or opening an instrument isolation valve too rapidly, could cause
both level switches to trip. However, personnel are aware of
the problem and should take precautions when returning the systems
to service.
19
Thirty-four reportab'e events occurred during the assessment
period. Nineteen of these events were attributed to personnel
errors, eight events were caused by inadequate procedures, two
events were related to design, manufacturing, or construction
problems, and one event was attributed to a management / Quality
Assurance deficiency. Many of the personnel errors caused
unnecessary ESF actuations. Many of the event reports could
have been prevented if personnel would have followed procedures
or had adequate procedures been issued for performing work.
The planning and scheduling of surveillance testing in the early
part of the assessment period was weak, such that the support
groups (i.e. Health Physics) who needed to perform surveillance
testing were not notified until the day of the test. Some
improvement in this area was noted in the latter part of the
assessment period.
The NRC recognizes that the LaSalle station has a large number
of surveillance tests which are required, and that the majority
of these are performed in a timely manner. However, the concern
remains that problems are not promptly corrected to prevent
their recurrence.
2. Conclusion
The licensee is rated Category 3 in this area. The performance
trend is declining.
3. Board Recommendations
The Board recommends NRC and licensee attention be focused on
this area.
E. Fire Protection / Housekeeping
1. Analysis
Prior to the licensing of LaSalle Units 1 and 2, each unit's
fire protection program was reviewed by the NRC staff for
conformance with regulatory requirements, including the
applicable portions of 10 CFR 50 Appendix R, and inspections
were performed by Region III to verify that the programs had
been adequately implemented. As a result of these activities,
the NRC concluded that the licensee had adequately impleraented
an acceptable fire protection program for each unit that would
support operation until the first refueling outage provided
that certain changes were made prior to initial criticality and
prior to exceeding 5 percent power. These changes were vetified
to have been accomplished by Region III. Prior to startup from
each unit's first refueling outage, additional changes are
mandated by license conditions.
20
- - __ . - __
This functional area was under continuous review by the
resident inspectors during the assessment period. One
violation was identified as follows:
Severity Level V - Failure to monitor portable
electric heater found in two Diesel Generator
rooms (373/84033-04; 374/84040-03).
Six reportable fire protection events occurred during the
assessment period, half of which were preventable. One event
was caused by personnel error, and two events were due to
defective procedures. All the events occurred in 1984 and no
rem rtable event occurred in 1985.
T'he ..censee's plant is well kept and clean. There are very
l few spots where oil accumulates due to leaking pumps or
l lubricant from valves, etc. The licensee has undertaken a
program to stencil equipment in the plant with names to help in
identification of components. This stenciling program includes
l- the doors leading into equipment rooms to assist personnel in
assuring they are working on the correct components and proper
,
unit.
2. Conclusion
The licensee is rated Category 1 in this area. However, a
broad enough spectrum of inspections was not conducted to
determine a trend.
l 3. Board Recommendations
None.
1
1. Analysis
Three inspections were conducted during the period to evaluate
l the following aspects of the licensee's emergency preparedness
l- program: emergency detection and classification; protective
l action decision-making; emergency notification; emergency
communications systems; shift augmentation provisions; emergency
preparedness training; independent audits of emergency
preparedness; and implementation of changes to the emergency
preparedness program. Two inspections were observations of
i annual exercises, the latest being the first unannounced
l exercise in the Region.
21 !
{
- -
. - _ . . , _ _ , _ . _ - . - . _ . _ _ _ _ _ , . _ _ , . . . , . . _ . , _ _ _ _ . _ . . . . . . _ _ . . _ _ . _ , _ . _ _ , _ . _ - , . . . . -
_ _ _ . _ - - _ - . _ _ .
One violation was identified during these inspections as
follows:
Severity Level V - During the 1985 exercise, the
licensee failed to demonstrate that adequate corrective
actions had been completed on a weakness identif_ied
during the 1984 exercise.
The repeat weakness involved a field monitoring team's
unfamiliarity with the operation of certain features of a
dedicated vehicle for offsite survey tasks and unfamiliarity
regarding what equipment had been stored in this vehicle.
The licensee's corrective action had been to conduct additional
training on the use of this dedicated vehicle during the annual
Radiation Chemistry Technician training program. The corrective
action was not effective since not all personnel who could be
assigned to offsite monitoring teams had received the training,
including those who were assigned to this dedicated vehicle
during the 1985 unannounced exercise. The licensee's proposed
corrective action is now adequate.
Management involvement and control in assuring quality has
generally been adequate. Independent audits of the program
were adequate in scope, depth, and frequency. Audit records
were complete and well maintained. Auditor followup on
corrective actions was thorough and timely. The licensee has
improved its use of a formal system for tracking corrective
actions on action items identified during emergency drills ,
and NRC inspections. Administrative procedures were adhered
to regarding the preparation, review, and distribution of
changes to the emergency plan and its implementing procedures.
The aforementioned violation resulted from incomplete corrective
actions having been taken on an exercise weakness.
Another exercise weakness resulted from the licensee's apparent
misunderstanding of the sensitivity of the issue of timely-
notifications following emergency declarations. During the
previous SALP period, the licensee had corrected procedural
guidance on the required timeliness of initial notifications to
State agencies. liowever, a subsequent procedure revision
reverted to the incorrect guidance. The licensee has again
revised the procedure to provide the proper guidance.
The licensee's resolution of technical issues has generally
been acceptable. A task force of corporate and station
personnel has been established to improve LaSalle's Emergency
Action Levels (EALs), including their standardization with
the EALs of the licensee's other BWR stations. This approach
is sound and comprehensive.
The licensee's responsiveness to NRC concerns needs to be
improved. Of the four written responses required during
the period, three were received after the due dates. One
22
- _ . _ _ _. _ __
extension had also been requested and granted. As evident from
the violation and aforementioned multiple revisions needed to
clarify procedural guidance on offsite notifications, NRC
concerns have not always been resolved by initial corrective
actions. Considerable NRC effort has also been made to obtain
several refinements in the licensee's emergency response
capabilities. The licensee has also identified the following as
needing improvement, but improvements were not yet evident:
logkeeping in the Control Room; operability of the public
address system in the Operational Support Center (OSC); and
reducing noise levels in the OSC.
Records of actual emergency plan activations through January 1985
indicated that all situations were properly classified and that
several were later appropriately reclassified. The NRC and
State of Illinois were initially notified of these emergency
declarations in a timely manner. Notification timeliness
improved significantly after improvements were made to qe
dedicated communications equipment used to contact Statt
agencies.
The licensee has maintained a prioritized roster of qualified
personnel to fill well-defined, key positions in the emergency
organization. However, due to attrition, the staffing of.the
Environs Director position was reduced to one person for several
months before training of additional qualified persons was
completed. Semi-annual drills have successfully demonstrated
the licensee's capability to augment on-shift personnel in a
timely manner.
The licensee's training program contributes to an overall
adequate understanding of emergency responsibilities, as
evident from walkthroughs and exercise performance, with
the notable exceptions being the performance of offsite
monitoring teams assigned to the dedicated survey vehicle
and logkeeping in the Control Room and OSC. The training
department has used procedure change summary memoranda to
better inform affected personnel of significant changes to
implementing procedures.
2. Conclusion
The licensee is rated Category 2 in this area with no
discernible trend.
3. Board Recommendations
1
None. l
l
23
G. Security
1. Analysis
Five inspections were conducted by region based physical
security inspectors during the assessment period. Three were
routine inspections, one was reactive, and the remaining
inspection was of a combined reactive and routine nature.
Additionally, the resident inspectors conducted routine
periodic security inspections of a limited scope during the
assessment period.
Four violations were identified during the inspection efforts
as follows:
a. Severity Level III - The licensee failed to adequately
control security badges / key cards (373/85029-01;
374/85030-01).
b. Severity Level IV - On occasion, required compensatory
measures for an alarm system were not implemented
(373/85022-01; 374/85024-01),
c. Severity Level V - The licensee failed to properly
report an event as required by 10 CFR 73.71(c)
(373/85029-02; 374/85030-02).
d. Severity Level IV - The alarm system for some dual
purpose doors was not tested at the required interval
(373/85022-02; 374/85024-02).
A Confirmatory Action Letter was issued on August 29, 1985, to
confirm licensee commitments regarding the Severity Level III
violation cited above. Also, a civil penalty has been issued
for this violation.
This represents a significant reduction of violations as compared
to the 12 violations noted in the previous SALP period. The four
violations occurred within the last three months of the 17-month
assessment period.
The nature of the violations noted during this assessment period
are attributed to security management, rather than security
force performance or equipment reliability. The violations
pertaining to failuro to test certain dual purpose doors, and
- the failure to implement required compensatory measures were
attributed to a lack of adequate procedural guidance.
Additionally, a concern was noted by NRC pertaining to written
guidance which appeared to potentially conflict with 10 CFR 19.15
and 10 CFR 19.16. This issue was resolved by the licensee's
l
24
corrective actions. Security section management involvement in
assuring section quality performance has declined during the
last three months of this assessment period.
The licensee's responsiveness to NRC concerns has been
generally adequate once security management achieved the
appropriate perspective of the issue. Security management's
initial. perspective of the misaligned equipment events in
February 1985 was one of an operations problem with little
or no need for increased security support. The event
involving inadequate controls for security badges was not
considered significant enough to formally report to the NRC as
required by 10 CFR 73.71(c). Concerns pertaining to written
guidance and proposed contract specifications which potentially
conflicted with 10 CFR 19.15 and 10 CFR 19.16 were initially
opposed by security management. This lack of consistent
recogniticn of the significance of security events is a weakness
of the security management staff. Once the appropriate perception
differences are resolved, the security section staff responds in
an aggressive and effective manner to resolve the issues.
Security management closely monitors inspection findings and
initiates action on all matters, including concerns and observations.
Compensatory measures for computer outages were voluntarily
doubled and measures to compensate for alarm system failures were
considerably strengthened.
Security section objectives have been clearly defined and
address weaknesses noted in past inspection and SALP reports.
Security management implemented a program to significantly
increase management visibility with the contract security
force. Liaison with the contract security force appears
effective.
The only unresolved security issue pertains to the adequacy
of a barrier for certain equipment within the lake screenhouse.
NRC is evaluating the issue.
With the exception of one event, the licensee has generally
reported security events in a timely manner and with adequate
information to allow analysis to be performed. Resolution of
problems have generally been technically sound. Ten security
events have been reported during the assessment period. Eight
of the security events were equipment related (seven security
computer related). The remaining two security events were
caused by personnel error. The total number of events is not
considered excessive.
Maintenance support for security equipment has generally been
excellent. Most maintenance requests were completed within two
or three days after initiation. Unplanned security computer
outages have been a recurrent problem, but the licensee's
corrective actions in August 1985 appear to have corrected the
25
situation. The licensee completed a preventive maintenance
program to renovate all closed circuit television system monitors
during this assessment period. One inspection identified a
concern on the recent false alarm rate for certain sectors of an
alarm system. This concern will be monitored during the next
assessment period.
Staffing levels for the uniformed security force appeared
adequate. Overtime is controlled. The contract security-force
training staff was increased from three to five personnel during
the assessment period. This and strong shift supervision
appears to have eliminated errors due to inattentiveness cited
in the previous SALP report. A new contract security force
site coordinator was assigned in September 1985. The
coordinator has several years of nuclear security experience
at the site and should prove to be an asset to the program.
Training effectiveness and qualification of the security force
has continued to be adequate. Innovative training methods such
as laser weapon training exercises and stress combat training
were initiated during the assessment period. The NRC evaluated
the former program and considered the exercises to be of great
value to the security force.
Day-to-day shift supervision of the security force appeared
strong and is the primary strength of the LaSalle security
program. No violations or unresolved items noted during the
assessment period were attributed to poor performance of the
security force.
The corporate security department has provided' excellent
support to the site security operations. A corporate level
Assistant Nuclear Security Administrator (ANSA) position has
been filled to provide more effective liaison between the site
and corporate security departments. The ANSA closely monitors
inspection results and security licensing issues pertaining
to the site. During the misaligned equipment events in
February 1985, the corporate security department provided
extensive manpower resources and investigative expertise.
The results of the licensee's investigation in this matter were
reviewed by the NRC and determined to be adequate. The scope of
such support needs to continue on a routine basis. Close liaison
exists between the site, corporate security department, ana NRC
Region III. Licensing matters are completed in a timely manner.
Senior management support of security operations was evident.
Examples of such support include: the security computer system
was extensively upgraded during the assessment period; part of
a warehouse facility was renovated and turned over to the
security department for administrative and training purposes
26 1
(this security facility is the largest of its kind for the
licensee's sites); and an alternate alarm monitoring system has
been installed and is being tested. l
In summary, the security section's management effectiveness has
been adequate except for the latter quarter of the assessment
period. This trend warrants senior site and corporate management
support. The security management staff's perception of the
significance of security events and issues also warrants attention.
Major areas such as the contract security force performance,
corporate security support, maintenance support, and senior site
management support has been strong and consistent.
2. Conclusion
The licensee is rated Category 2 in this area. This is the
same rating noted during the previous SALP period. The
performance trend is the same.
3. Board Recommendations
None
H. Refueling
1. Analysis
No licensee activity occurred in this area during the
assessment period and thus is not rated.
2. Conclusion
None
3. Board Recommendations
None.
I. Quality Programs and Administrative Controls
1. Analysis
Tnis functional area covers reviews of the Quality Assurance
and Quality Control programs as well as an assessment of general'
administrative controls to assure that activities are performed
properly and in accordance with regulatory requirements. During
this period, four inspections by region based personnel were
conducted in the QA area. The inspections reviewed the licensee's
activities relative to auditing and surveillance of startup
testing, audits, design changes and modifications, calibration,
surveillance and maintenance, activities and qualifications of
the offsite reviews and investigative function, and procurement
program.
27
The general assessment of administrative controls was made
through routine inspections by resident and region based
inspectors in several functional areas and also by a special
Task Force which reviewed LaSalle operations.
Two violations were identified in the QA area:
a. Severity. Level IV - Failure of the licensee to recognize an
increasing trend of deficiency reports in the calibration
area (373/84-32-03; 374/84-39-03).
b. Severity Level V - Failure of the licensee's QA Department
to perform a technical specification required annual audit
from October 1983 through CY 1984 (373/85003-06; 374/85003-06).
These violations were indicative of licensee inattention to
programmatic and procedural details.
The inspection of the procurement area identified six unresolved
items which related to a programmatic weakness for the potential
procurement, installation, and use of unqualified items.
The licensee's proposed actions relating to these unresolved
items appeared to mitigate some of the weaknesses.
During this assessment period the licensee hired a contractor
to evaluate and to improve its management ano operations. There
is some evidence that this effort was at least partially responsible
for improving operations midway through the assessment period. The
licensee also reorganized in early 1985 and plant staffing appeared
to be sufficient.
However, throughout the assessment period, many examples were
identified where the licensee failed to ensure that permanent
corrective actions were implemented to resolve problems and
prevent their recurrence. This weakness was noted in most
of the functional areas and resulted in the violation being
issued in the Emergency Preparedness area. For example,
administrative controls were not sufficient to prevent the site
from having repetitive problems in the modification program
involving design control, installation practices, and post
maintenance testing. As discussed in the maintenance section,
there were the nine examples of failure to perform an
Environmental Qualifications Modification correctly which
resulted in a Sevecity Level III violation.
Findings of the special Task Force which conducted an evaluation
of LaSalle in mid 1985, also identified concerns with repeated
equipment prot,lems with certain plant systems, and an apparent
overall problem of controlling work activities. In the first
area vent stack monitor failures were due to equipment problems
which have not been solved, and most of the failures of the
control room ventilation system ammonia / chloride detectors also
28
I
. . . . -
have been due to equipment problems, but little progress has
been made in solving them. In the area of lack of control over *
work activities, six items occurred in 1985 that related to
problems with the modification / installation program, as set
forth below. (These items were included in the ni.ne examples of
problems which were compositely identified as a Severity Level
III violation, item h in Section IV.C.1).
1) Four RHR shutdown cooling pump high suction flow' switches
on Unit 1 were piped backwards'because the drawings used
i for installation were incorrect. The drawings had been
identified in 1982.aus needing correction, but the changes
were never made;
2) Division I and Division II RHR area differential temperature
isolation sensors on Unit 2 were found to be inoperable
since original construction. The error which caused this
was discovered during construction of Unit 1 and was
supposed to be corrected for Unit 2. The correction was
not made;
,
3) For a period of five days all three divisions of ECCS on
Unit 2 were inoperable. The cause was inadequate
l control / coordination of work groups.
4)- A Unit 2 high reactor water level switch for RCIC was
found to trip much lower than required. The cause was
failure to perform a post-installation calibration of the
switch even though the modification package was signed off
as complete.
i
5) A control relay for the Reactor Building Closed Coeling
Water Containment isolation valve failed because the wrong
relays were installed in the control circuitry. A design
change had earlier revised the control power to these relays
necessitating a change in the relays. This was not done.
J'
6) During a surveillance test, the Unit 2 RPS sub-channel A
failed to trip as required. The licensee determined that
the associated terminal block was not wired according to
the drawings and wrote a work request to change it. After
j further problems it was determined that the original
i installation was correct, but that the drawings were ,
incorrect.
,
There was poor prior planning of modification activities at the
- site, and this resulted in several of the violations in the area
i of maintenance. Early in the assessment period policies and
responsibilities of individuals were poorly stated and poorly
,
understood. This caused several personnel errors in various
- functional areas. Upon identification of this problem, the
! licensee took corrective action, and late in the assessment period,
1
l
,
29
-. - - __
_ - , - - - - - _ - _ , _ . - - . _ .- .-.... . --. -
management held meetings with the staff to stress the importance
of individuals to understand policy and their responsibilities.
The Task Force also identified that administrative controls were
not effective in preventing an excessive backlog of procedure
changes or an excessive number of outstanding control room work
requests, nor was there a system for effective prioritization
of modifications.
In summary, adequate quality programs have been established and
are staffed by qualified personnel; however, there are numerous
problems in the implementation of these programs and establishing
well defined administrative controls to resolve the problems.
Overall management effectiveness on the implementation and
monitoring of programs is weak.
2. Conclusion
The licensee is rated Category 3 in this area and there is no
discernible trend.
3. Board Recommendations
NRC and licensee attention should be focused in this area.
J. Licensing Activities
1. Analysis
a. Methodology
This performance assessment is based on our evaluation of
the licensee's performance in support of licensing actions
which had a significant level of activity during the
evaluation period. These actions included the licensee
request for license amendments, responses to generic
letters, and various submittals of information for multi plant
and NUREG-0737 actions. Active actions during this period
are classified below. A total of 29 licensing actions were
completed by the NRC:
(1) 31 Plant-specific Actions submitted by licensee
(16 completed by the NRC). Included in this category
and which were used to provide input to this
evaluation are:
- Use of ASilE Code Case N-389
- Raise Capacity of Electrical Heaters in Standby Gas
Treatment System
- Non-applicability of Specification 3.0.4 to
Specification 3.6.3
- Control Rod Position Indication
30
1
__ ____ - _- _ ______- _ ._
.
,
T
- Minimum Critical Power Ratio Versus T.
<
- Response Time for Main Steam Line Low Pressure Trip
- Acceptance Criteria for Firecode CT Gypsum Fire Stops
- Reactor Scram on Low CRD Pump Discharge Pressure
- Repositioning of MSIVs Upon Reset of Isolation Signal
,
- Change Main Steam Tunnel Differential Temperature
i Isolation Setpoints
- RhCU Pump Room High Ambient and High Differential
Temperature Isolation
- Fire Damper Surveillance Program
'
. - Deletion of Channel Check Requirements
' - Change Unit 1 Techr..' cal Specifications to Reflect
Unit 2 Technical Specifications
- Waiver of 18 Month Surveillance Interval
- RCIC Pump Room Differential Temperature Isolation
(2) 19 Multi plant Action submitted by licensee
(11 completed by the NRC). Included in this category
and which were used to provide for this evaluation are:
- GL 83-28 Items 3.1.3 and 3.2.3 - Post-Maintenance
'
Testing
- GL 83-28 Items 3.1.1 and 3.1.2 - Post-Maintenance
Testing Verification (RTS Components)
- GL 83-28 Items 3.2.1 and 3.2.2 - Post-Maintenance
Testing Verification (All Other SR Components) '
- GL 83-28 Item 4.5.1 - RTS Reliability
,
,
- GL 83-28 Item 1.1 - Post-Trip Review -
- GL 83-28 Item 1.2 - Post-Trip Review Data and
I Information Capability
- GL 83-43 Technical Specification Affected by-10 CFR
50.72 and 50.73
'
- GL 83-36 Change Action Statement for Accident Monitoring
Instrumentation
- Implemc ition of NUREG-0313, Revision 1
'
- Control or Heavy Loads
[ - Extension of Equipment Qualification Implementation
Date - 10 CFR 50.49(g)
.(3) 5 TMI (NUREG-0737) Actions submitted by licensee
(2 completed by the NRC). Included in this category
s and which were used for this evaluation are:
,
i
't
i - Safety Parameter Display System I.D.2
.
. - Relief and Safety Valve Testing II.D.1 l
b. Management Involvement and Control in Assuring Quality
, ) i
<
There is evidence of planning and assignment of priorities an
, , decision-making seems to be at a level that ensures adequate
f managen:ent review. Management within CECO was accessible
'
which facilitated the reviews. The typical area where
31
..
- _ _ _ _ _ _ _ _ _ _ _ _ - _ .
management involvement and control was evident was in meeting
the requirements for extension of the date for equipment
. qualification. Effective communication between the licensee
and NRC is good. One area where management attention could be
increased is in the screening of amendment requests to assure
that they provide sufficient discussion of the safety
consequences and/or reason for.the proposed changes.
c. Approach to Resolution of Technical Issues from a Safety
Standpoint
In general, the licensee has a good understanding of the
technical and safety issues and the proposed resolutions have
been conservative and sound. However, in submittals for
Technical Specification changes, sometimes sufficient information
is not provided in the discussion of the safety consequences _and
the reason for the change. As a result, some time and effort is
required in order to arrive at an acceptable resolution.
d. Responsiveness to NRC Initiatives
I
The licensee has provided timely responses which are
usually sound. CECO has been aware of and sensitive to the
needs of the staff to perform its review function. The
licensee is always ready to meet with the staff when such a
meeting would assist in resolving issues. On one of the
occasions where the licensee was proposing using the fine
motion control rod drive in a demonstration test, CECO on
its own initiative, met with the staff to review their
proposed submittal to assure that the submittal would be
completely responsive to the staff's position prior to
transmitting it to the NRC.
e. Staffing
The licensee has competent managers with nuclear experience. i
Most of the managers have worked up through the organization I
and therefore acquired nuclear background. I
f. Recommendations
The licensee's management should maintain a high level of
involvement in the functional area of licensing to assure
improvement in its performance in this area, conduct audit
reviews by screening some of the proposed license
amendments prior to submittal to assure that sufficient
information has been provided for the proposed amendments,
and should strengthen its involvement in Q/A areas to
rectify the problems that have occurred in replacing
qualified equipment.
32
. . -
- _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
--
-
2. Conclusion
The licensee is rated Category 2 in this area and the
performance trend is the sane.
3. Board Recommendations
None.
K. Startup Testing (Unit 2)
1. Analysis
During the assessment period, Unit 2 completed its initial
startup testing program. For Uait 2, the scope of the inspection
program was reduced since the administrative program was the
same as that used for Unit 1 and the test procedures were based
on Unit 1 procedures, (with the addition of lessons learned from
Unit 1). Inspection activities during the assessment period
consisted of indepth reviews of startup test result evaluations,
witnessing of startup test procedures, observations of corrective
actions for problems identified, and independent inspection
effort. Portions of three inspections by resident inspectors
were devoted to this area. Two inspections were conducted by
region inspectors. As a result of these inspections, one
violation was idertified as follows:
Severity Level V - Failure to receive an approved change to
a procedure prior to performing a startup test (374/84034-01).
The above violation is the only one identified during the Unit 2
startup test program and is therefore considered to be an
isolated case. The root cause was a failure of attention to
detail by the test engineers and the involved plant management.
The aggressive management attention to incorporating the lessons
learned from the Unit 1 into the Unit 2 startup assisted greatly
in the rapid progression of the startup program. From time of
receiving the 5 percent power license until completion of the
startup test program was 278 days. This shortened time frame
is indicative of good management attention.
The licensee's assignment of an aggressive management team to
complete the startup program was also effective in that they
planned and scheduled the testing evolution well so that all
personnel involved with the program knew well in advance when
, and what was needed to support a test. This allowed for the
j test to run smoothly and the data to be taken as needed. The
support of the entire station was directed to the accomplishing
'
of this goal. All station groups seem to work well towards
completing the Unit 2 startup.
33
. _ _ . _ _ _ _ . _ - . _ _ _ _ _ , _ _ _ _ _ _
2. Conclusion
The licensee. is rated Category 1 in this area. Since startup
testing is a one-time function there is no trending involved.
3. Board Recommendations
None.
,
!
34
V. SUPPORTING DATA AND SUMMARIES
A. Licensee Activities
Unit 2 completed its initial startup testing progran early in the
assessment period. Throughout most of SALP 5, Units 1 and 2 engaged
in routine power operation. A major scheduled Unit 1 outage for the
18 month Technical Specification surveillance requirements and EQ
replacement began on September 29, 1984 and was completed on
November 24, 1984. A major scheduled Unit 2 outage for maintenance,
18 month Technical Specification surveillance requirements, and EQ
replacement began on February 28, 1985 and was completed on July 20,
1985.
The remaining outages throughout the period are summarized below:
Unit 1
May 31 to June 2, 1984 Repair blown SJAE seals
June 24 to June 25, 1984 Repair reactor water level
control logic
January 5 to January 6, 1985 Repair generator field ground
February 2 to February 3, 1985 Repair high steam tunnel
temperature sensors
February 8 to February 10, 1985 Repair feedpump intakes
March 3 to March 5, 1985 Offsite fault on a transmission
line
March 21 to April 7, 1985 Repair valving error on EQ
modification
April 11 to April 13, 1985 Repair turbine bearing No. 11
May 31 to June 10, 1985 Flooding of lake screen house
June 17 to June 18, 1985 Repair EHC system
June 20, 1985 Replace oil trip solenoid
on turbine
June 29 to June 30, 1985 Adjust CRD flow control
July 12 to July 27, 1985 Repair suppression pool spray
valve
35
_
Unit 2
May 3 to May 6, 1984 Perform minor maintenance work
May 12, 1984 Turbine maintenance
May 21 to May 25, 1984 Repair main transformer
May 27, 1984 Repair No. 3 bypass valve
June 15 to June 16, 1984 Repair HPCS relief valve
June 16 to June 17,' 1984 Repair condensate booster system
July 9 to July 10,.1984 Repair turbine / generator
intercept. valve
July 28 to August 1, 1984 Repair steam leaks on moisture
separator reheater
August 17 to August 29, 1984 Repair main generator exciter
October 27 to October 28, 1984 Repair recirculation flow control
logic
November 12, 1984 Stop valve maintenance work
November 20 to November 22, 1984 Bypass valve maintenance work
December 14 to December 19, 1984 Perform maintenance on turbine
supervisory instrument cabinet
August 1 to August 3, 1985 Investigate high drywell
temperatures
Unit 1 scrammed fourteen times (two occurred while shutdown) and
Unit 2 scrammed eighteen times (eight occurred while shutdown).
Seven of the Unit 1 scrams and six of the Unit 2 scrams were
attributed to equipment malfunctions and required minor maintenance
prior to returning the units to service. Two scrams occurred at
power for Unit I which were attributable to personnel error. Five
scrams occurred at power for Unit 2 which were attributable to
personnel error. While both units were shutdown, two scrams were
attributed to personnel error. Four scrams during SALP 5 were due
to defective procedures.
B. Inspection Activities
On July 22, 1985, Region III formed a special task force to perform
an in-depth review of the operating history of LaSalle County
Station with emphasis on identifying potential problem areas
from trends that'may exist. The task force consisted of two
36
_-
resident inspectors, two regional inspectors and the chief of the
Technical Support Staff. In addition, a Senior Resident
Inspector from another facility performed 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 potential problem areas existed that were not
identified during the hard data review. The task force subsequently
completed its review on September 20, 1985, and 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 modification.
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 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.
Violation data for LaSalle is presented in Table 1, which includes
"
Inspection Reports 84003, and 84013 through 85031 for Unit 1, 84002
and 84017 through 85032 for Unit 2.
,
37
. __..
- - _ - _ , - . -- , - -_ -- . - - _ . _- - _.
TABLE 1
INSPECTION ACTIVITY AND ENFORCEMENT
No. of Violations in Each Severity Level
Functional Unit 1 Unit 2 Site
Areas III IV V III IV V III IV V
A. Plant Operations 1 5 1 8 1 9
B. Radiological Controls 6 3- 6~ 2 7 3
C. Maintenance / 1 8 2 1 7 2 1 9 3
Modificatiens
D. Surveillance and 7 4 7- 3 8 5
Inservice Testing
E. Fire Protection 1 1 1
F. Emergency Preparedness 1 1 1
G. Security 1 2 1 1 2 1 1 2 1
H. Refueling
I. Quality Programs and 1 1 1 1 1 1
Administrative
Controls
J. Licensing Activities
K. .Startup Testing 1 1
(Unit 2)
TOTALS 3 29 13 3 31 12 3 36 16
5
38
_
C. Investigations and Allegations Review
During a safeguards review, followup was made to-two anonymous
allegations received by the Senior Resident Inspector on April 4,
1985. The allegations concerns: (1) an unsigned security badge
that was found during a restine badge review and .the fact that an
incident report was not made, and (2) the fact that the security
supervisor was unbadged for three minutes in the main security-
access facility while the supervisor's security badge was
relaminated. These allegations were substantiated. However, they
were not significant and an evaluation determined that no further
action by Region III was warranted. No violations of requirements
were identified.
D. Escalated Enforcement Actions
1. A Civil Penalty in the amount of $25,000 was issued late in
1984 for a violation involving an inoperable "A" Standby Gas
Treatment train.
2. A Civil. Penalty in the amount of $125,000 was issued in 1985
for a violation involving Unit 2 being without Emergency Core
Cooling System capability for approximately five days.
3. A Civil Penalty in the amount of $37,500 was issued late in
1985 for a violation involving control of security badges.
E. Management Conferences Held During Appraisal Period
1. - Confirmatory Action Letter (CAL)
a. A CAL was issued February 20, 1985, to confirm licensee
commitments regarding~the discovery of a mispositioned
valve on the air' start system of a Unit 1 Diesel Generator
on February. 18, 1985 and the mispositioned breaker on a
Unit 2 safety bus found on February 19, 1985.
b. A CAL was issued June 17, 1985, to confirm licensee
commitments regarding the discovery of improperly installed
instrumentation and the resultant loss of automatic actuation
of Emergency Core Cooling Systems capability.
c. A CAL was issued July 19, 1985, to confirm 1icensee
commitments regarding the discovery of improperly installed
RHR cooling isolation switches on Unit 1.
d. A CAL was issued August 29, 1985, to confirm licensee
commitments regarding the loss of the security badge
system integrity at LaSalle.
39
__. _ _ . _ _ _ . .- _ _ - _ . _ _ _. _ _ _ . .
2. Management-Conferences
a. September 7, 1984 (Glen.Ellyn, Illinois)
MeetingEto discuss licensee performance in regards to
their Regulatory Performance Improvement Program (RPIP).
b. September 17, 1984 (Glen Ellyn, Illinois)
Management meeting to review Systematic Assessment of
Licensee Performance (SALP 4).
c. March 7, 1985 (Glen Ellyn, Illinois)
Meeting to dis ~ cuss licensee performance in regard to
their RPIP.
d. June 24, 1985, (LaSalle County Station)
Meeting to discuss ifcensee performance in regard to
their RPIP.
e. July 16, 1985 (Glen Ellyn, Illinois)
Meeting to discuss additional aspects of the licensee's
RPIP.
3. Enforcement Conferences
a. June 22, 1984 (Glen Ellyn, Illinois)
Enforcement conference to discuss circumstances
surrounding RWCU isolation functions for temperature
differential flow being inoperable and the system was
not isolated.
b. September 11, 1984 (Glen Ellyn, Illinois)
Enforcement conference to discuss exceeding LCO during
vent and purge valve operations at LaSalle site.
,
c. December 7, 1984 (Glen Ellyn, Illinois)
Enforcement conference to discuss circumstances
surrounding violation of Technical Specification 3.6.5.3
and the continuing problem of control room operators being
d. May 28, 1985 (Glen Ellyn, Illinois)
Enforcement conference to discuss circumstances surrounding
miswiring of trip system B for ADS which resulted in an
LCO being exceeded and continuing personnel errors by
maintenance personnel at the site.
40
e. June 24, 1985 (Glen Ellyn, Illinois)
Enforcement conference with management representatives of
-Ceco to discuss the recent events involving the loss of
all Emcrgency Core Cooling Systems from June 5-10, 1985 at
LaSalle.
f. September l'7, 1985 (Glen Ellyn, Illinois)
. -
'
Enforcement conference to discuss the circumstances of the'
uncontrolled security badges found at the site refuge dump.
F. Review of Licensee Event Reports and 10 CFR 21 Reports
1. Licensee Event Reports (LERs)
LERs issued during the 17 month SALP 5 period are presented
below:
Unit 1 Unit 2
LERs No. LERs No.
,
.84-24 through 84-94 84-37 through 84-93
85-01 through 85-62 and 85-65 85-01 through b5-41
Proximate Cause Code * Number During SALP 5
Personnel Error A 62
Design Manufacturing 37
Construction Installation 8
Defective Procedures D 17
Others X 136
TOTAL 252
- Proximate cause is the cause assigned by the licensee
according to NUREG-1022, " Licensee Event Report System."
There were 134 LERs issued for Unit 1 and 118 LERs issued
for Unit 2 during the SALP period. The LERs submitted during
the assessment period provided for the'most part a clear
description of the cause and nature of_the event. However, in
late 1984 and early 1985 after some previous discussions with
the site personnel, the inspectors identified some errors in
LER preparation. Examples of this was as follows:
a. Improper classification of the reporting required and/or
cause code.
i
41
_ , . _ . , . . . _ _ _ _ , _ _ _ _ _ _ . _ _ _ . _ . _ _ _ _ _-___ _ _
b. The narrative descriptivn was not clear or specific enough
to identify what occurred,
c. The corrective action was not specific enough to evaluate
if it was sufficient to prevent recurrence of the report.
d. The section identified at ".other facilities involved" was
filled in with the same facility (unit) as the one in
which the event occurred.
e. Incorrect LER number identified as previous occurrences.
(IE 373/84... should have been 374/84...).
f. Use of undefined acronyms.
g. Identify previous occurrences sometimes were restricted
to only a single unit in lieu of identifying all previous
occurrences at the site. (Both units)
Improper reference to technical specification section.
~
h.
For all errors which were not of a minor nature the licensee
agreed to revise the LER. However, a closer review prior to
issuance of LERs needs to be done in the future. Some of these
errors decreased in the latter part of the assessment period;
however, periodically they have occurred and need continuous
review by the licensee to prevent reoccurrence.
The Event Analysis Branch reviewed LaSalle's LERs and com;,ared
them to reports from four other late model BWRs. They
determined that LaSalle has more serious events than the other
plants. Another point mentioned, was that LaSalle Unit 2 had
procedural problems that were not seen at the other BWRs. This.
reflects, not only on a new plant, but also on a plant with
poor management oversight. One would expect that procedural
inadequacies would have been identified during Unit l's first
few months of operation. To be seeing procedural problems now
suggests that procedures were not getting adequate review or,
that the operating staff was not communicating effectively with
the technical staff and management. Since Unit 1 had less
problems than other similar BWRs, LaSalle's problems as a
station appear to be related primarily to one aspect of
management, namely, difficulty in controlling, reviewing and
checking EQ modifications, and operating procedures.
The Office for Analysis and Evaluation of Operational Data
(AE0D) also performed as assessment of the quality of LERs
submitted by the licensee during this SALP period. AE00 found
these LERs to be of above average quality based on the requirements
contained in 10 CFR 50.73. A copy of the AEOD report has been
provided to the licensee so that minor deficiencies noted can be
corrected on future LERs.
42
._
2. 10 CFR 21 Reports
No 10 CFR 21 reports were submitted during the assessment
period.
G. Licensing Actions
1. NRR/ Licensing Meetings
Feb'ruary 5,1985' Unbraced Length and Slenderness Ratio
March 25, 10"5 Extension of Deadline for Equipment
Qualification
May 16, 1985 Fine Motion Control Rod Drive Demonstration
2. NRR Site Visits
September 17, 1980 Salp Meeting and Licensing Activities Review
3. Commission Briefings
None
4. Schedular Extensions Granted
March 29, 1985 -Extension to Schedular Requirements of
Environmental Qualification of Electrical
Equipment
4
5. Reliefs Granted
None
6. Exemptions Granted
None
7. License Amendments Issued
Unit 1
License Amendment #17 Main Steam Line Temperature Difference
4
Trip Setpoints and Allowable Values
License Amendment #18 Unit 1 Tech Specs to Reflect Changes
Incorporated in Unit 2 Te'ch Specs
License Amendment #19 Modify Limits on Monitors in
Accordance with GL 83-36
License Amendment #20 Eliminate the RWCU Pump Room Ambient
and Differential Tempurature Monitoring
License Amendment #21 Change Method of Calculating the
Kilowatt Capacity for the Electric
Heaters in ??TS
43
. .
. _ _ _ _ _ . . _ _ . _ - - _ . - _ _ , . _ _ _ _ . -- _ , . - _ _
License Amendment #22 Delete the channel Check Req'uirements
for Certain Instruments
License Amendment #23 Incorporate the Revised 10 CFR 50.72
and 50.73 Requirements
Unit 2
License Amendment #2 Main Steam Line Temperature Difference
Trip Setpoints and Allowable Values
License Amendment #3 Incorporate. Reactor Scram on Low CRD
Pump Discharge Pressure as Required by
License Condition 2.C.(7)
License Amendment #4 Vacate Amendment No. 3 and Reinstate
License Condition 2.C.(7)
License Amendment #5 Modify Limits on Monitors in
Accordance with GL 83-36
License Amendment #6 Incorporate Reactor Scram on Low CRD
Pump Discharge Pressure as Required by
License Condition 2.C.(7)
~
License Amendment #7 Eliminate the RWCU Pump Room Ambient
and Differential Temperature Monitoring
i License Amendment #8 Extend the Schedular Requirements of
License' Condition 2.C.(5) for Replacement
of Equipment Qualification
-
License Amendment #9 Change Method of Calculating the
Kilowatt Capacity for the Electric
Heaters in SGTS
License Amendment #10 Delete the Channel Requirements for
Certain Instruments
License Amendment #11 Incorporate the Revised 10 CFR 50.74~
and 50.73 Requirements
License Amendment #12 Change the Main Steam Line Low
Pressure Instrument Response Time
8. Emergency Technical Specification Granted
July 3, 1985 Emergency Ammendment No. 2 for Unit 2 and
Amendment No. 17 for Unit 1
September 4, 1985 Emergency Amendment No. 3 for Unit 2
44
.- _ _, . ._ . _ _ . _ _ . _ _ . _ . _ - _ . - _
- . . , ._. _ _ . _ . - _ _ _ ,__m
E
l-
i
l'
i
!
July.1, 1985 Emergency Amendment No. 12 for Unit 2
i: . 9.. .. Orders Issued
f None
i.
!
10. NRR/ License Management Conference
None
.
,.%,*
45