ML20206T743
| ML20206T743 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 09/30/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20206T719 | List: |
| References | |
| 50-409-86-01, 50-409-86-1, NUDOCS 8610070161 | |
| Download: ML20206T743 (37) | |
See also: IR 05000409/1986001
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SALP 6
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SALP BOARD REPORT
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U. S. NUCLEAR REGULATORY COPNISSION
REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
50-409/86001
Inspection Report
- Dairyland Power Cooperative
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Name of Licensee
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La Crosse Boiling Water Reactor
Name of Facility
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January 1, 1985 - June 30, 1986
Assessment Period
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8610070161 860930
PDR ADOCK 05000409
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I. INTRODUCTION '
The Systematic Assess. tent 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 riormal regulatory processes 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 and operation.
A NRC SALP Board, composed of s'taff meinbers listed below, met on
September 4, 1986, to review the collect' ion of performance observations
and data to assess the licensee's 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.
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SALP Board for LACBWR:
Name Title
J. A. Hind Direct 6r, Division of Radiological
Safety and Safeguards
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C. J. Paperiello s Director, Division of Reactor
Safety
W. G. Guldemond Chief, Reactor Projects Branch 2
W. D. Shafer Chief, Emergency Preparedness and
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Radiological Protection Branch
Chief, 0perations Branch
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C. Hehl
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D. C. Boyd -
Chief, Reactor Projects Section 2D
L. R. Greger Chief, Facilities Radiation Protection
Section ,
M. P. Phillips ,
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Chief, Operational Programs Section
E. R. Schweibinz
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Chief, Technical Support Staff
J. R. Creed Chief, Safeguards Section
T. Burdick Chief, Operator Licensing Section
B. Snell Chief, Emergency Preparedness Section
M. A. Ring Chief, Test Programs Section
R. B. Landsman Project Manager, Reactor Projects
Section 2D
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I. V111alva Senior Resident Inspector
A. G. Januska Reactor Inspector
N. Williamsen Emergency Preparedness Analyst
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II. CRITERIA
Licensee performance is assessed in selected functional areas, depending
upon whether the facility is in a construction, preoperational, or
operating phase. Functional areas normally represent areas significant
to nuclear safety and the environment. Some functional areas may not be
assessed because of little or no licensee activities, or lack of meaningful
observations. Special areas may be added to highlight significant
observations.
One or more of the following evaluation criteria were used to assess each
functional area.
1. Management involvement and control in assuring quality
2. Approach to the resolution of technical issues from a safety
standpoint
3. Responsiveness to NRC initiatives
4. Enforcement history
5. Operational and Construction events (including response to, analyses
of, and corrective actions for)
6. Staffing (including management)
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 definitions of
these performance categories are:
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Category 1: Reduced NRC attention may be appropriate. Licensee
management attention and involvement are aggressive and oriented toward
nuclear safety; licensee resources are ample and effectively used so that
a high level of performance with respect to operational safety and
construction quality is being achieved.
Category 2: NRC attention should be maintained at normal levels. Licensee
management attention and involvement are evident and are concerned with
nuclear safety; licensee resources are adequate and are reasonably
effective so that satisfactory performance with respect to operational
safety and construction quality is being achieved.
Category 3: Both NRC and licensee attention should be increased. Licensee
management attention and 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 quality is being achieved.
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III. SUMMARY OF RESULTS
The overall regulatory performance of the LACBWR Plant has continued at a
satisfactory level during the assessment period. Performance in the area
of Fire Protection declined from a Category 1 to a Category 2. Performance
in the area of Maintenance / Modifications declined from a Category 2 to a
- Category 3 due to the high number of equipment failures which resulted in
reactor scrams. Performance in the area of Outages is rated a Category 3
this period due to the number of problems encountered during the 1986
refueling outage.
Rating Last Period Rating This Period
July 1, 1983 - January 1, 1985 -
Functional Areas December 31, 1984 June 30, 1986
A. Plant Operations 2 2
B. Radiological Controls 2 2
C. Maintenance / Modifications 2 3
D. Surveillance and
Inservice Testing 1 1
E. Fire Protection 1 2
F. Emergency Preparedness 2 2
G. Security 2 2
H. Outages 3
I. Quality Programs and
Administrative Controls
Affecting Quality 2 2
J. Licensing Activities 1 1
K. Training and Qualification
Effectiveness 2
- Not Rated for SALP 5
- Not Rated (new functional area for SALP 6)
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IV. PERFORMANCE ANALYSIS
A. Plant Operations
1. Analysis
Evaluation of this functional area was based on the results of
routine inspections conducted by region-based inspectors and the
resident inspector. In addition, this evaluation includes the
results of a special inspection that was conducted in response
to an unusual occurrence. The following violation was noted
during the evaluation period:
Severity Level IV - Inoperable low pressure coolant
injection system while the plant was pressurized
(409/85009).
The violation resulted from personnel error in that the Alternate
Core Spray (ACS) system was lined up to the river with manual
valves closed and tagged out during a hydrostatic test. This
happened because of insufficient communications during a shift
change. The hydrostatic test procedure required the ACS system
to be lined up for normal operation but this step was skipped in
the procedure. The procedure has been modified requiring all
steps to be initialed. These closures would not have prevented
operation of the low press coolant injection system since the ACS
is supposed to pump river water directly into the vessel if
either of the normal water supplies was unavailable. Therefore,
from a safety standpoint the event was minor.
The special inspection was in response to an event on
October 23, 1985. Because this event was initially diagnosed as
a potential anticipated transient without scram (ATWS) event, the
licensee classified it as an alert and Region III dispatched a
special team to the site and also issued a Confirmatory Action
Letter (CAL). The event was an apparent failure to scram. A
scram alarm was received from the nuclear instrumentation (NI)
system without the expected scram. Normally, a scram should
occur coincident with a scram alarm; however, investigation by
the special team led to the conclusion that an actual scram high
flux level had not been reached and that there had not been a
failure of the reactor protection system. Ultimately, the
failure was found to be in the alarm circuit wherein (i) the
a alarm functioned prematurely, and (ii) that portion of the NI
system that actuates the alarm function was not synchronized with
its counterpart that actuates the scram function. It was further
concluded that, except for the alarm circuit, the reactor
protection system was functioning acceptably and that a scram
would have occurred had the appropriate level been reached.
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The direct involvement and cooperative attitude by LACBWR's
management throughout this event was noteworthy. This involve-
ment contributed to the resolution of the problem within 24
hours, including the licensee's formal response to the CAL.
Further, in response to an NRC request, the licensee devised
a special test to verify the functional operability of the
nuclear instrumentation system. As a result, all the technical
issues associated with the event were resolved in a timely
manner, with highest attention given to plant and personnel
safety.
The LACBWR facility experienced 17 RPS trips during this SALP
period, resulting in a much higher trip rate than the industry
average. Eight scrams were at power levels of 72% or higher.
Ten of the 17 scrams were attributed to plant specific
deficiencies which the licensee plans to remedy. For example,
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six of these scrams were attributed to marginal or obsolete
equipment (i.e., four scrams were attributed to that portion of
the NI system that uses a one-out-of-two scram logic, and two
were caused by malfunctions of the 1A Static Inverter, an old
inverter design that uses an electro-magnetic transfer switch
rather than a solid-state transfer switch). In addition, four
of the scrams were caused by either low gas pressure or low oil
level indication on a single rod drive mechanism, Such scrams
. are the result of the plant's initial design that results in a
one-out-of-58 scram logic. It is significant to note that none
of the scrams from power were due to licensed operator error.
LACBWR's management is concerned about the frequency of the
scrams being experienced and the challenges that scrams impose
on plant safety and the shutdown system. LACBWR's management
has analyzed the past scrams and has instituted a program
directed toward reducing scrams.
Toward this end, the licensee plans to replace the existing NI
system with an improved NI system during the first half of 1987.
The new NI system should reduce the number of scrams due to
instrumentation spikes and to operator errors during plant
startup and shutdown. The licensee had planned to replace the 1A
Static Inverter with a larger unit having a solid state transfer
switch during the 1987 refueling outage. However, the licensee
took advantage of the required outage to repair the decay heat
removal suction pipe and procured and installed the new inverter
on August 29, 1986, subsequent to the expiration of this SALP
period. This modification should improve the inverter's perform-
ance and reduce scrams during transfer switch operation. Finally,
the licensee is considering a modification that would eliminate
partial scrams due to low gas pressure or oil level. In lieu of
such partial scrams, the modification would cause an alarm to
actuate upon low gas pressure or oil level indication on a single
control rod drive mechanism, thereby eliminating the one-out-of-58
scram logic. Such modification will, of course, be contingent
upon NRC approval. Although these modifications may bode well
for future SALP reports, they have not provided a positive impact
for this SALP period.
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In addition to the 17 RPS trips previously mentioned, LACBWR
experienced 24 other events during this SALP period which required
the issuance of Licensee Event Reports (LERs). Eleven of these
events occurred during the 12-month period of 1985, and thirteen
occurred during the six-month period of 1986. Thus, the rate of
reportable events for the most recent time period (the first six
months of 1986) was more than twice that of the previous time
period (all of 1985). Further, since the plant was down for
refueling for about 72 days during the six-month period of 1986
and for only 35 days during the 12-month period of 1985, the
normalized rate for reportable events for comparable operating
time is approximately three times greater for the 1986 time
period than for the 1985 time period. Thus, not only have
reactor scrams been unduly high during this SALP period, but the
rate at which reportable events have occurred during the last six
months of this SALP period has shown a marked increase. The
repetitive nature of some of these reportable events is especially
disconcerting. For example, the release of unsampled waste water
with analyzed waste water occurred four times during this SALP
period.
The operations staffing is adequate, authorities and
responsibilities are generally well defined and usually adhered -
to. Operations personnel are very experienced and knowledgeable
of the plant and its characteristics and conduct themselves in a
professional manner. Conduct in the control room is usually
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business like, professional and virtually without distractions.
The operations staff moral is generally high and the attrition
rate is extremely low. Operations procedures are adequate,
well written, and generally adhered to. Plant management is
involved in day-to-day activities and plant management personnel
are often present in the plant and control room.
2. Conclusion
The licensee has performed well in this area as it relates
to special and unexpected occurrences. Management's
participation in responding to the presumed ATWS type event
and its planning for future reduction of scrams is noteworthy. -
However, the operational problems experienced during this SALP
period (e.g., the total number of reactor trips experienced,
the increase in the rate of occurrence of reportable events
and their repetitive nature), cause the overall rating for-
this functional area to be Category 2.
3. Board Recommendations
The unusually high number of scrams and other reportable events
experienced at LACBWR during this SALP period suggest that
management should be more directly involved in the day-to-day
operation of the facility. Such involvement should be directed
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toward eliminating repetitive errors, providing clear-cut
instructions regarding responsibilities of the various craft and
operating personnel during the various plant operational modes to
assure that the plant is maintained and operated in a safe manner
and in conformance with the applicable regulations.
B. Radiological Controls
1. Analysis
Six inspections were performed during the assessnent period by
region-based specialists. The inspections covered outage and
operational radiation protection, liquid and gaseous radwaste,
low-level radwaste shipments, and confirmatory measurements.
Two violations were identified as follows:
a. Severity Level IV - Failure to monitor beta exposure rates
for workers in the reactor vessel (409/86003).
b. Severity Level IV - Failure to maintain radiation dose
records in accordance with Form NRC-5 requirements
(409/85015).
The two violations, which appear to have resulted from lack of
attention to details, represent improvement in this area over the
six violations during the last assessment period. The licensee's
corrective actions for both violations were appropriate and
timely.
The staffing level in this functional area during normal
operational periods appears adequate. However, the staff
appeared strained during the recent refueling and maintenance
outage. Radiation protection coverage of work in radiologically
significant areas appeared only marginally adequate during that
outage. The radiation protection staff normally is not supple-
mented by contractors during outages. The only supplemental
outage staffing is a part-time (one shift daily, five or six days
a week) laundry operator. Routine labor intensive tasks such as
laundry operation, waste packaging, and some custodial duties
adversely impact on time available to provide radiological
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support for maintenance and operational activities during outages.
The radiological control staff's experience level has improved
since the past assessment period because of improved staff
stability.
Licensee responsiveness to NRC issues was generally acceptable
with some improvement over the previous assessment period as
evidenced by: the replacement of the liquid radwaste effluent
monitor to improve sensitivity; replacement of aging internal
proportional counters to improve quality of analytical measure-
ments; the completion of quality related Regulatory Improvement
Program Items; attention to specifics involved in evaluating and
reporting environmental monitoring results; and revision of low
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level radwaste shipment procedures to provide guidance to
determine radwaste classification in accordance with regulations.
However, these resolutions were not always completed in a timely
manner.
Management involvement in radiation protection and radwaste
matters was evident and generally adequate during the period.
Two liquid monitors were replaced with improved equipment,
backwashable filters were installed in the liquid waste effluent
line, and variability in the background of the environmental
detector which could affect environmental data was investigated.
Previously described problems concerning failure to ensure
adequate corrective actions for procedural violations, poor
coordination between radiatian protection personnel, and poor
utilization of the radiological incident report system were not
evident during this assessment ceriod. Management surveillance
of plant activities has also apprrently improved. However,
quality assurance review of routine radiation protection activi-
ties and records needs improvement as evidenced by inspection
findings concerning maintenance of dose records and film badge
spiking programs. Also, the individual who performed quality
assurance audits of radiation safety activities had limited
experience in the field. Several observations indicate a need
for improved attention to detail and/or supervisory review,
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including contamination levels which were allowed to become
excessive before decontaminating the new liquid radwaste monitor;
procedural cross references were not always properly revised; and
during efficiency testing of a charcoal absorber filter when
iodine concentrations were too low to be detected, xenon was
substituted in the analysis which was inappropriate for assessing
iodine removal.
The licensee's approach to resolution of radiological technical
issues was good during the assessment period. The licensee
developed and implemented a formal respiratory protection
program and continued strengthening the station's contamination
control program, including termination of the permitted use of
laboratory coats for some contaminated area entries, continued
r cleanup / reclamation of contaminated areas, strengthened frisker
,. use requirements, and use of an improved personal contamination
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monitor. Followup of a hydrogen explosion incident in the offgas
system was excellent.
Personal radiation exposures for 1985 (major portion of the
assessment period) were about 30% lower than the preceding year;
this is the third year of declining yearly exposure totals. No
employee received in excess of five rems during 1985. To reduce
exposures (ALARA), the licensee added shielding in several
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areas of containment, limits containment entries during power
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operations, and provides improved ALARA review of specific tasks.
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Liquid radioactive releases have shown a gradual decline over
the past several years (1.8 curies in 1985), but the licensee
continues to release radioactive liquid wastes without treatment
other than filtration. During the assessment period four
instances of failure to sample liquids prior to discharge were
noted by the licensee. Three occasions involved operator and/or
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procedure inadequacies, the fourth was an equipment failure.
Gaseous radioactive releases in 1985 showed about a 20% reduction
from 1984 releases. The reduction is primarily attributable to
improved fuel cladding integrity. Solid waste volumes have been
reduced mainly because of limiting materials permitted in
contaminated areas. There were no transportation incidents.
The licensee has improved his QA/QC program for analytical
measurements on counting data by using control charts and
malfunction sheets to describe problems and corrective actions
for each instrument. Chloride analyses continue to be a problem
although effort was expended in an attempt to solve the problem.
The licensee's results in the confirmatory measurements program
remain essentially unchanged with one disagreement for the
comparisons made with the NRC.
2. Conclusion
The licensee is rated Category 2, which is the same rating
achieved in the previous SALP period; however, performance was
improved over the previous SALP period.
3. Board Recommendations
None.
C. Maintenance / Modifications
i 1. Analysis
Inspections of maintenance / modification activities were conducted
by the resident inspector and region-based inspectors to verify
that these activities were performed in accordance with Technical
, Specification and quality assurance requirements. No violations
l or deviations were noted in these areas.
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Three distinct type of maintenance activities were reviewed:
(1) corrective maintenance activities requiring the interruption
of plant operations, (i.e., maintenance activities resulting in
forced outages wherein the plant was either shutdown or power
reduced); (2) corrective maintenance activities not requiring
the interruption of plant operations, per se, but which impose
a Limiting Condition of Operation (LCO) on continued plant
operation; and (3) preventive maintenance (PM) activities. The
licensee performed 18 corrective maintenance actions which
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required the interruption of plant operations and several
corrective maintenance actions which placed the plant in a LC0
during this SALP period.
On occasions the corrective maintenance actions taken by the
licensee appeared to have been directed toward the symptom rather
than the cause. For example, five malfunctions occurred during
this SALP period (i.e., on 7/10/85, 9/9/85, 11/15/85, 11/18/85
and 12/14/85) that caused the 1A forced circulation pump's
discharge valve to close. The closing of the valve, in turn,
caused a reduction of reactor power until the valve was reopened.
Absent a systematic failure analysis, these malfunctions had,
at various times, been attributed to spikes in a " delta T"
subtractor circuit used to compare the temperature in both forced
circulation loops and to erratic output from a worn out potentio-
meter in the same circuit. Ultimately, during a plant shutdown
on January 8, 1986, while trouble shooting the circuits that
control the pump's discharge valve, a defective solenoid was
found and replaced. Since the valve has not malfunctioned
subsequent to replacing the defective solenoid, it appears that
the root cause for the malfunctions has been determined.
A similar diagnostic deficiency appears to have involved a
malfunction that did not cause a power reduction but placed the
plant in a LCO. On July 1, 1985, while operating at about 98%
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power, the 1A Diesel Driven High Pressure Service Water Pump
failed its monthly surveillance test, (i.e., the diesel started
but stopped almost immediately thereafter). This failure placed
the plant in an LC0 requiring the reactor to be in a hot shutdown
mode within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in a cold shutdown mode within the next
30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> unless the pump was made operable in less than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Subsequent to the diesel's initial failure, additional tests were
conducted and additional diesel stop failures were experienced.
Finally, after approximately eight hours after the initial
failure, the pump passed its surveillance test and about an hour
later the diesel was again started successfully. Based on the
, apparent successful tests, the licensee declared the pump
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Because of the failures experienced subsequent to the initial
diesel failure, coupled with the fact that the actual cause had
not been determined and corrective maintenance, per se, was not
i conducted, the licensee planned for additional troubleshooting
. and initiated a monitoring program requiring that the priming
tank level be monitored daily. In addition, because of the
uncertainties involving the diesel's performance, the licensee
conducted surveillance tests on July 9, 10, 11 and 12, 1985.
Several diesel stop failures occurred while conducting these
tests. Following each failure, maintenance actions were
performed and a successful surveillance test conducted, after
which the unit was again deemed to be operable. During this time
period, the licensee identified several potential causes for the
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failures, but the root cause was not discovered until July 12,
1985. At that time an Allis Chalmers representative discovered a
sluggish valve in the fuel supply line that had been overlooked
during previous troubleshooting. This valve was overlooked
because maintenance history records indicated that it was
installed on the 1B HPSW diesel and not in the 1A diesel and the
fact that this particular valve has the appearance of a line
fitting rather than that of a valve. Upon cleaning this valve
the diesel starting problems were apparently solved (e.g., the
diesel was successfully started on July 13, 14, 15, 17, and 19
with no intervening failures).
Eighty-one modifications (facility changes) were completed during
this SALP evaluation period. Most of the modifications were
directed toward improving plant operations. However, several
modifications were directed toward enhancing plant safety by
responding to recommendations by the licensee's Safety Review and
Operating Review Committees. Examples of facility changes that
should enhance plant safety are highlighted below:
a. The elastomeric components of the upper control rod drive
mechanical seals were upgraded. This change should improve
plant reliability and safety because the seals are more
resistant to fluctuations in operating temperatures. This
change has not been implemented on all control rod drive
mechanisms; however, the new material has been placed in
stock, and will be used on the remaining units when routine
maintenance is performed.
b. A turbocharger was added to the 1A High Pressure Service
Water Diesel Engine. This modification was aimed at improv-
ing the diesel engine's reliability and at increasing its
rating, thereby assuring ample service water flow.
c. Reactor wide range water level transmitter 50-42-305 was
replaced with a new unit having a local rather than a remote
amplifier. The new equipment is qualified to withstand the
postulated harsh environment and is judged to be superior to
the original equipment.
d. The electronics of the component cooling water and turbine
condenser liquid radiation monitors were upgraded to provide
more sensitive and reliable radiation monitoring.
Staffing in the maintenance area is adequate. Personnel are
experienced and knowledgeable. Authorities and responsibilities
are well defined. Maintenance personnel have received training
on plant systems and overall plant operations. This training
contributes to their understanding of the effect of their activi-
ties on the plant operation. Maintenance procedures are generally
adequate and adhered to. Management involvement is good at both
the site and corporate levels, as evidenced by the many plant
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4: upgrade modifications performed. Management is responsive to NRC
initiative and concerns. -They exhibit a positive and cooperative
attitude.
The age of many components at LACBWR and the fact that the
nuclear' steam system suppler (Allis-Chalmers) is no longer a
' viable source for replacement of parts that are wearing out,
suggests that the licensee should upgrade and implement a more
F' extensive and systematic preventive maintenance program. 'This
program should include a systems engineering evaluation for the
explicit purpose of establishing priorities for refurbishment
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or replacement of components reaching their end-of-life. Of the
17 RPS Trips which occurred during this evaluation period, 13
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were caused by mechanical equipment problems (6 at power levels >
72% and 7 at power levels < 1%). This strongly' suggests the need
l for improvement in the preventive and corrective maintenance
4 areas. It is recognized that many actions were initiated during
this evaluation period to reduce the number of such problems, but
the effectiveness of these actions was not current during this
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appraisal period. The major constraint associated with such a PM
program is, of course, the potential negative impact of ALARA
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1 considerations. Accordingly, the PM program should, to the
maximum degree practicable, use mock-ups prior to undertaking
, complex maintenance activities.
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2. Conclusion
The licensee's performance regarding maintenance, especially as
it relates to failure analysis, and the effectiveness of the
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preventive maintenance program appears to have declined from that
l of the previous SALP evaluation and should be given additional
attention by the licensee. On the other hand the licensee's
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modification program is~ considered very effective in not only
improving operations but also in enhancing safety. However, due
to the large number of equipment failures which have resulted in
reactor scrams and other reportable events the overall performance
l- in this area is rated Category 3.
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l 3. Board Recommendations
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More attention by the licensee and by the NRC is required in the
- area's of preventive maintenance and corrective maintenance.
D. Surveillance and Inservice Testing
1. Analysis
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! Routine inspections were conducted in this area by the resident
! inspector and two inspections were conducted by region-based
inspectors to assess the licensee's performance, and compliance
with the relevant procedures and programs, licensee requirements
and applicable regulations. The resident inspector witnessed
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test activities, reviewed procedures and test data, and verified
on a spot-check basis that surveillance tests were performed as
required.' The region-based inspectors performed in-depth inspec-
tions of the licensee's-program for inservice testing of pumps
and valves, and of.startup core performance testing. .None of
these inspections resulted in violations or deviations.
The surveillance activities inspected were performed in a very
professional manner and found to be well managed. No surveillances
were missed during the period. For example, the. manner by which
surveillance activities are conducted clearly indicate that the
authorities and responsibilities in this area are clearly defined,
personnel involved in this area are very knowledgeable and
proficient in performing their assigned tasks, and prior planning
has been well developed. The licensee's training program in this
area stresses the need for adherence to procedures, thereby
assuring that the surveillance actions do not compromise plant
safety or plant operations. Surveillance records were found to
be complete, well maintained and readily available. Likewise,
the licensee's audit reports were found to be complete and
thorough.
The licensee has implemented an inservice testing program and was
conducting testing in accordance with the requirements of the
ASME Code. Modifications or revisions to the inservice testing
program, associated test procedures and test acceptance criteria ,
are reviewed by the Onsite Review Committee, including representa-
tives from Operations, Quality Assurance and plant technical
staff, to insure compliance with Code requirements and that plant
equipment and systems are not unnecessarily challenged.
The licensee responded to technical issues in a timely manner
with appropriate justifications and supportive documentation.
The licensee was in the process of assigning acceptable
instrument accuracy values to plant instruments for which no
3
manufacturer's specified values are given.
l
The licensee responded to NRC identified concerns in an
'
appropriate and timely manner. Inconsistencies identified during
the inspection were addressed and either resolved, or reasons for
delay of resolution and estimated dates of completion were
- *
identified prior to the end of the inspection.
l
! Current staffing is adequate to administer and implement the
,
inservice testing program at LACBWR. However, it was noted that
plant administrative practices and knowledge of past events which
affect implementation of the program appear to reside with one
< individual. The loss of this individual from the LACBVR staff
l
could adversely impact consistency and adherence to Code require-
!
ments associated with surveillance / inservice testing. Members of
,
the licensee's staff were knowledgeable of inservice testing
i requirements and test methods. Interviews with members of each
!'
t
i
! 14
!
!
_. _ _ _ . . . _ _ _ _ _ _ _ _ . . _ _ _ _ . , _ _ _ , _ _ _ _ . , _ , . _ _ _ . . _ , . _ , _ . , _ , _ , _
r
.
operating shift crew and their shift supervisors indicate that
licensee training has produced consistent test methods and test
documentation.
2. Conclusion
The licensee's overall rating in this functional area is Category 1,
the same rating achieved during the last SALP period.
3. Board Recommendations
None.
E. Fire Protection
1. Analysis -
The resident inspector performed routine inspections in this area
during this evaluation period, including evaluation of potential
fire hazards, plant housekeeping and cleanliness and compliance
with LACBWR's fire protection plan. The inspections indicated
excellent housekeeping practices, indicating a marked improvement
from that of a previous inspection. One special inspection was
performed by region based inspectors and their consultants during
this evaluation period to verify the adequacy of the facility's
post fire safe shutdown method (Section III.G., J, 0, and L of
Appendix R), and other fire protection features and modifications.
One violation was identified:
Severity Level V - Failure to hydrostatically test fire
extinguishers (409/85013).
Concerns were raised during the special inspection regarding:
- The sprinkler system, fire detectors and the partial height
fire wall between the fire pumps in the cribhouse did not
provide reasonable assurance (as described in the Supplemen-
tal Safety Evaluation Report, dated March 23,1983) that at
least one fire pump would remain functional, should a
disabling fire occur in the cribhouse. The licensee has
acknowledged this concern and corrective actions are
expected in this area. Some corrective actions in this area
have been taken by the licensee. For example, the licensee
has relocated the starting battery for the 1B high pressure
service water pump, which is also a fire pump, to satisfy
the Appendix R commitment. This relocation resolved the
concern associated with the height of the fire wall between
the fire pumps.
- The inspectors observed that no area wide fire detection
system existed in the control room as specified by Section
5.7.4 of the SER; however, the license condition related to
15
.-
the completion of facility modifications to improve the fire
protection program did not include installation of an area
wide fire detection system in the control room. The licensee
committed to installing an area wide fire detection system
in the control room at the exit meeting of July 11, 1985.
- * Adequate control of combustibles was observed by the
inspectors, although special mention was made regarding the
storage of combustible materials in the electric equipment
room and implied throughout the plant. The inspectors
indicated that combustible materials not essential for
routine operation should be removed. Improvement in this
area is desirable.
Also reviewed during this inspection was the fire brigade
composition and training portion of the licensee's fire protec-
tion program. The fire brigade composition and training
conformed to the guidelines of Appendix A to Branch Technical
Position 9.5-1, although four brigade training program
implementation weaknesses were identified. One additional
concern noted regarded the current licensee's policy on normally
designating the Shift Supervisor as the fire brigade leader.
This practice is discouraged by Appendix A. The licensee was
encouraged to reconsider the use of the Shift Supervisor as the
fire brigade leader.
.
Management involvement and support of their staff during the
inspection was appropriate to the circumstances and the licensee
was willing to listen and discuss inspector raised concerns.
Observations by the resident inspector of site conditions
generally indicated excellent housekeeping practices. Problem
areas identified were promptly corrected and do not appear to
be repetitive. Management and staff appear to take a positive
attitude towards housekeeping and fire prevention.
2. Conclusion
The licensee is rated Category 2 in this area with continued
- strength in the area of housekeeping.
3. Board Recommendations
None.
,
2
1. Analysis
Two inspections were conducted during the SALP period, one
routine inspection and one exercise. The routine inspection was
conducted in April 1985 and resulted in the closing of 14 open
l
i
16
i
_ _ ._- _ __ _ _ _ . _ _ _ , _ _ _ . . _ . _ _ _ _ - _ _ _ ,
.
items and the opening of five more. However, the five new items
were of a minor nature and did not involve any violations. Two
of the open items dealt with inconsistencies between the newly
revised Emergency Preparedness Plan and the Emergency Plan
Procedures. Two more items related to emergency equipment which
was satisfactory but not adequately described in the Plan, in one
case, and in the other case required upgrading based on ALARA
concerns. The fifth open item referred to the hiring of an
additional person, part of whose functions would have been to
assist the Emergency Planning Coordinator.
This latter personnel need has been resolved by replacing the
previous Emergency Planning Coordinator with a more qualified
individual who has an SR0 license. The licensee believes that
the appointment of a more qualified Coordinator eliminates the
need for an assistant.
The licensee's annual exercise was conducted in June 1985 and
resulted in two weaknesses regarding the notifications to State
and local agencies. The initial notification for the Site Area
Emergency was completed within 27 minutes rather than the
required 15 minutes and the notifications did not always specify
whether a release was taking place, as specified by the licensee's
Management control, measured by the number of violations and open
'
items, has improved since the SALP-5 period but still has room
for further improvement. For example, in the May 1984 routine
inspection, nine inspection-related open items were closed, but
seven new items were opened, four of them being violations. Thus,
the April 1985 routine inspection, mentioned above, was an
improvement since 14 Open Items were closed and only five items
(none of them being violations) were opened. However, the open
item concerning inventories that was found in April 1985, was
never corrected during the SALP-6 period and led to a subsequent
violation in 1986.
During the last two to three years there has been a noticeable
improvement in the licensee's responsiveness to NRC concerns.
There are no long-standing regulatory issues attributable to
the licensee. The licensee is generally timely in its responses
but there are still exceptions to this. For example, the June 25,
1985 exercise resulted in a weakness in their notification
-
performance after declaration of an emergency. Less than 30 days
later during a real event (loss of Offsite power) the licensee
failed to notify the State of Minnesota within the required 15
minutes. Timely corrective action on the exercise weakness would
have prevented the notification problem identified during the
actual event.
The enforcement history is improving. In the previous SALP
period there were five violations, whereas there were none
during this SALP period.
17
.
' Staffing at the management level has been unchanged, and the
selection of an experienced SR0 for the Emergency Planning
Coordinator position should be an improvement in staffing.
Training and qualification effectiveness is generally good as
demonstrated by the elimination of any violations during the
SALP period. However, documentation and record keeping of
training must be further improved. The methodology the licensee
used to track completed training resulted in three operators
missing their annual emergency preparedness training by up to
three months.
2. Conclusion
The licensee is rated Category 2 in this area. The licensee
was rated a Category 2 in the last SALP period.
3. Board Recommendations
None.
G. Security
1. Analysis
-
Two security inspections were conducted by region-based physical
security inspectors during the assessment period. Both were
routine inspections. Additionally, the Resident Inspector
routinely conducted observations of security activities. Five
violations were identified relative to the security program as
follows:
a. Severity Level IV - A security screen was inadequately
fastened to a vital area structure (409/85016).
b. Severity Level IV - Search hardware failed to perform as
required (409/85016).
c. Severity Level IV - Some alarm zones failed to perform as
i
required (409/85016),
d. Severity Level IV - Failure to implement adequate
compensatory measures (409/86004).
e. Severity Level V - Failure to maintain a clear isolation
zone (409/85016).
Allegations were received by Region III that dealt with security
at the facility involving compensatory measures not being
l
implemented, alarms not being recognized; events not being
l
l
18
_ _ _ _ _ _ . _
- - . _ __ _ - - - _ _ . - _ _ .- . , - - - - - _
_ _ _ _ _ _ __
-
.
-
reported to the NRC; and vital area doors left open. The alleged
events occurred in 1982 and did not involve current deficiencies.
They could not be fully substantiated. No violations were cited
as a result of any of the allegations.
Weaknesses identified by NRC inspectors were noted that did not
involve violations in the areas of assessment aids, protected
area physical barriers, security system maintenance, and
. discrepancies between the security plan and the contingency
plan. When the violations and weaknesses were identified, the
licensee usually took corrective action in a timely and
effective manner.
Some weaknesses and violations were not self-identified.
Although they were not major in nature, they were recognizable
and could have been corrected, had they been identified. Since
there was an increase in cited violations from the previous SALP,
the licensee should consider a closer and more thorough management
review of the system to identify potential problem areas and
correct them before they become more significant.
Positions within the security organization are identified and
responsibilities are well defined. In November 1985, a new
Security Director was hired to replace the former Security
Director who was promoted to the corporate office. The new
-
security director has established and maintained good
communications with Region III safeguards staff.
Events reported under 10 CFR 73.71 were properly identified and
analyzed. There were six reported events which dealt with
computer problems, such as loss of primary power and protected
area alarm malfunction. Records are generally complete, well
maintained, and available.
Review of the security training program and its effectiveness
was limited. Those portions of the training records reviewed
were adequate. No major problems in performance were noted
which indicated significant weaknesses in training.
There were no technical issues involving physical security from
a safety standpoint which required resolution during this
assessment period.
Management's support for the security program has continued and
was made evident by the purchasing of a walkthrough metal
detector, hand-held explosives detectors, CCTV cameras, hand-held
radios, and upgrading the backup security power supply.
In summary, management's support for the program has increased.
The effectiveness of that support may be increased through a
more aggressive program for self-identification of potential
problems and reviews to determine cost effective protective
!
19
!
t
.
. improvements to the program. This has been shown in the
upgrading of some security equipment. The number of violations
and weaknesses have increased since the previous SALP period;
however, they were of a minor significance.
2. Conclusion
The licensee is rated Category 2 in this area, which is the same
rating achieved in the last assessment period. However, the
overall licensee performance is declining.
3. Board Recommendations
None.
H. Outages
1. Analysis
Evaluation of this functional area was based on the results
of inspections conducted by the resident inspector involving
the scheduled 1986 refueling outage, an inspection by a
region-based inspector regarding the review of selected
procedures and equipment checkouts associated with the 1986
refueling outage, and a special inspection by region-based
inspectors in response to potential damage to the core spray
bundle during the refueling outage. The inspections included
observations of maintenance, refueling, and post-maintenance
conducted during the outage and the review of selected
administrative and procedural requirements. No violations
of deviations were noted for this area.
The licensee completed its 1985 and 1986 refueling outages during
this SALP period. However, because there was no resident
inspector on site during the 1985 refueling outage, it is not
discussed in this report. The 1986 refueling outage was
initially scheduled to be accomplished in approximately 42 days;
however, because of several problems experienced during the
outage, the actual refueling duration was 70 days.
The inspection activities performed by the region-based inspector
included a review of fuel handling equipment checkout and fuel
~
transfer procedures, surveillance test procedures and operating
manuals, observation of fuel handling activities, verification of
performance of fuel transfer accountability records and review of
surveillance test results. The findings associated with this
inspection indicated that (i) licensee performance was properly
managed and effective, (ii) fuel movement activities were conduc-
ted in strict adherence to approved procedures and without error,
and (iii) procedures used during the refueling outage were
technically adequate and properly approved.
As previously indicated, the licensee experienced several problems
during the 1986 refueling outage that increased its duration by
20
---
- _ _ . -__ _ _ __ - . - . .
.
'
about 30 days. Some of the problems were due to personnel error
and others to equipment malfunctions. The more significant of
these events and their impact on the outage are highlighted in
the paragraphs that follow.
On March 7, 1986, one day prior to the scheduled refueling outage,
the reactor scrammed when a 2400 volt reserve feed breaker failed
to close while transferring plant loads from the main source to
the reserve source. Although the actual increase in outage time
accrued to this event is unknown, it adversely impacted the
refueling outage by diverting electrical maintenance personnel
from scheduled PM activities to corrective maintenance activities
on the breaker, thereby placing an additional unplanned work load
on the staff during a hectic period.
On March 12, 1986, while the upper cavity was being flooded,
water leaked from a thermocouple conduit that penetrates the
shield wall into containment. This event was due to personnel
error and poor communications between maintenance and operating
staff personnel. (i.e., A wrong sized thermocouple plug was
installed in the penetration conduit; however, this fact was not
clearly communicated to the operating staff. Thus, the cavity
was being filled while a leak path existed from the cavity to
containment). This event delayed the outage by about one day and
,
also created a contamination control problem inside containment.
On March 15, 1986, while control rod handling was in progress,
the control rod in position 19 was found to be unlatched from its
drive mechanism. The control rod drive mechanism for this rod
had been last installed in September of 1984; therefore, it was
reasonably assumed that the rod had been unlatched since that
date. Upon finding the unlatched rod, a test program was insti-
tuted to verify that all the other rods were latched. Although
this event was not complicated, i.e., the reinstallation of
unlatched rod was straightforward, as was the testing to ensu
that all rods were latched, it added about three days to the
refueling outage.
On April 3, 1986, while lowering the high pressure core spray
(HPCS) bundle into the reactor vessel, the bundle struck the
vessel's internals on at least two occasions. On April 4, while
attempting to bolt down the bundle it did not seat properly and
was sitting about one-half inch higher than it should. The
bundle was, therefore, removed fron the vessel and returned to
the fuel element storage well and inspected. The inspection
revealed that the four outermost tubes of the bundle had been
bent inwards about 20 to 35 degrees. Because of the concern
regarding damage to a safety system, a special inspection was
conducted by region-based inspectors. Based on their review of
this event, the inspectors concluded that the corrective
actions taken were acceptable and that no safety concerns or
violations existed. (NOTE: The actual reason for the seating
l 21
. - -- ._
_
- - . --
.-- - -_
.
.
problem was not determined until August, while the plant was
shutdown to repair a pipe leak. While removing fuel, the
licensee found a bent handle on one of the fuel assemblies.
Subsequent examinations and review of video tapes revealed that
the affected fuel assembly had not been properly seated during
,
the 1986 refueling outage. Thus, the fuel assembly's
protruding handling obstructed the initial seating of the HPCS
bundle). Several factors contributed to this event, including
the constraints associated with working in a high radiation
area, poor visibility, poor crane alignment markings, and
perhaps undue pressure. These factors ultimately led to what
can be euphemistically called personnel error. This incident
adversely impacted the refueling outage by adding about ten
days to the outage.
In addition to the incidents highlighted above, several other
events occurred during the 1986 refueling outage. The cumulative
effect of these events was to increase the outage duration about
five days. Said events include the dropping of an underwater
light shield and clamp into the reactor; the breaking of the
source connecting bolts while the source was being moved from the
storage well to the reactor such that the lower third of the
source (the plug end) landed in the reactor; the damaging
(twisting) of the upper band of a new fuel assembly while it was
being lifted from its storage position; and a small fire that was
quickly controlled in the lagging of the 18 forced circulation
pump's discharge piping.
Although the licensee does not have the same size staff as many
other licensees, it does have knowledgeable and experienced
staff member from each plant discipline who routinely work
together to provide the planning and scheduling function for
the plant. This approach has worked well over the years. In
addition, the licensee has experienced good control over outage
work packages. This is partially due to the fact that most of
the outage work is done by licensee personnel, with very little
work being performed by contractors. However, when contractor
personnel are utilized, adequate communication and supervision
is provided to assure control over their work activities.
Some of the problems experienced during the 1986 refueling
outage could have been prevented by more diligent attention
to detail by both maintenance and operating personnel.
Likewise, improved communications between maintenance and
operating management personnel could have improved the overall
performance during the 1986 refueling outage.
2. Conclusion
The licensee is rated Category 3 in this area.
22
.
~
3. Board Recommendations
Because of the number of reportable events (10) experienced ~during
the 1986 refueling outage and the repetitive nature of some of
the events, it is recommended that LACBWR management be more
directly involved in the-day-to-day activities during refueling
outages. Said involvement should be aimed at assuring that the
refueling activities are performed properly, that appropriate
administrative controls are implemented and that clear lines of
communications are maintained between maintenance staff and
operating staff.
I. Quality Programs and Administrative Controls Affecting Quality
1. Analysis
Evaluation of this functional area was based on the results of
routine inspections conducted at the Lacrosse Boiling Water
Reactor (LACBWR) by the resident inspector and two inspections by
region-based inspectors. The inspections for this area included
routine inspections regarding administrative controls for
maintenance and operations and deviation reports with respect to
the Quality Assurance Plan and the role of the Quality Assurance
Staff. No violations or deviations in this area were noted.
The first region-based inspection for this area was conducted in
the beginning of the SALP period and was aimed at evaluating this
functional area as it relates to (i) the Offsite Review Committee,
(ii) the Offsite Support Staff, and (iii) the Nonroutine Reporting
Program. The licensee was essentially in a transition status
during this early part of the SALP period, e.g., actions had been
initiated or planned in those areas which would result in minor
changes in the licensee's commitment or in its performance to
requirements. These actions and their results were not expected
to have any major safety significance.
The second region-based inspection for this area was aimed at
evaluating LACBWR's maintenance, QA/QC administration, tests and
experiments, receipt, storage and handling, and procurement. The
inspector verified that the licensee had implemented a written
program relative to maintenance activities and QA/QC administra-
tion that was in conformance with Technical Specifications,
regulatory requirements, commitments and industry guides or
>
standards.
The licensee's quality programs and administrative control
affecting quality gave evidence of prior planning, assignment of
priorities, and decision making that was usually at a level to
ensure adequate management review. The responsiveness to NRC
initiatives was timely with acceptable resolution to concerns.
Events were usually identified and reported in an accurate and
timely manner.
23
. l
- The licensee's policies in the areas inspected are adequately
stated and understood, and the procedures are adequately defined
and stated for the control of those activities. Audits have been
complete and thorough. Corporate management was usually involved
in site activities, and management attention and involvement are
evident and show concern for nuclear safety. Quality program
activities appear to be controlled adequately. The implementation
of the QA program is acceptable as reflected in overall plant
performance.
2. Conclusion
The licensee is rated Category 2 in this area.
3. Board Recommendations
None.
J. Licensing Activities
1. Analysis
a. Methodology
The basis of this appraisal was the licensee's performance
in support of licensing actions that were either completed
or active during the current rating period. These actions,
consisting of license amendment requests, exemption requests,
relief requests, responses or generic letters, TMI items,
LER's and other actions, are summarized below:
(1) Amendment Requests
Administrative Controls
Static Inverter 1C
Miscellaneous Systems
1C Inverter
Fuel Exposure
Control Rod Drives
Containment Ventilation Dampers
Flooding
Vessel NDT
Byproduct License
Primary Property Damage Insurance
FSAR Submittal Schedule
24
l
_ _ -- . _ _ _ _ - . _ - - . . - . . -. - -- - - -__ -_ - - .- --
I
.
.
~
(3) Relief Request
None.
(4) TMI Items
I.C.1 Emergency Operating Procedures
I.D.1 Detailed Control Room Design
I.D.2 Safety Parameter Display System
II.B.3 Post Accident Sampling System
II.E.4.2.6 Containment Isolation
II.F.1 Noble Gas Effluent Monitor
II.F.1-2 Design Basis Shielding Envelope
III.A.1.2 Emergency Response Facilities
III.A.2.2 Meteorological Data Upgrade
(5) Other Licensing Actions
SEP, IPSAR, Consequence Study
Diesel Generators
Generic Letter 83-28 (Salem Event)
Control Rod Replacement
Fire Protection
,
Operation Licensing, including BWR Expert Panel
Environmental Qualification
Generic Letter 85-07, Integrated Scheduling
Heavy Loads
Generic Item B-24, Venting
Generic Letter 85-14, Iodine Spikes
Generic Letter 86-04, Engineering Expertise on Shift
Nuclear Instrumentation
Generic Requirements Status List
IE Bulletin 85-03 MDVs
Appendix J Leak Testing
During the SALP period, 61 licensing actions were .
completed which consisted of 45 plant-specific actions,
10 multi plant actions, and six TMI (NUREG-0737) actions.
A very important licensing activity completed during the
review period was the issuance'of a primary property
damage insurance exemption for LACBWR. This achievement
is noteworthy because LACBWR is the first utility to
provide adequate technical justification to support such
an exemption at the Commission level.
In addition, the project manager and other members of the
NRR staff participated in reviews at the plant concerning
the post accident sampling system, systematic evaluation
program topics as well as an Appendix R fire protection
audit.
25
_
.
b. Management Involvement and Control in Assuring Quality
During this rating period, the licensee has demonstrated a
very active role in licensing-related activities. Strong
management involvement has beea especially evident where
issues have potential for substantial safety impact and
extended shutdowns. Licensee management actively partici-
pated in an effort to work closely with the NRC staff and
management to promote a good working relationship. The
majority of submittals were consistently clear and of high
quality. The licensee management frequently participated
in meetings in Bethesda on short notice.
There is one area which indicates a lack of management
attention, and that is the setting of priorities of
licensing actions to be evaluated by the NRC staff.
During the winter 1986 refueling outage management at the
site informed the NRC staff the top priority licensing
action were those related to restart and at the same time
the Lacrosse headquarters management informed the NRC
staff that the property damage insurance exemption was the
highest priority licensing action. This conflict almost
resulted in the licensee having to request an emergency
technical specification change to allow startup. This
conflict and other communication problems between the staff
-
and the licensee were brought to the attention of the
licensee's management. The licensee's management has worked
out the internal problems and worked closely with the NRC
staff in the last three months of the evaluation period to
correct these problems. We recognize a strong improving
trend.
c. Approach to Resolution of Technical Issues from a
Safety Standpoint
The licensee almost always demonstrated a strong
understanding of the technical issues involved in licensing
actions and proposed technically sound, thorough, and timely
resolution. However, there have been issues where the
licensee's approach was good, but the licensee did not
. . thoroughly understand NRR staff guidance. Once the staff
guidance was fully explained, the licensee proposed timely
solutions which were technically sound and exhibited proper
conservatism. For a few issues, full explanation of the
staff guidance required an above average amount of staff
effort. Examples of such issues are post accident sampling
system, ECCS technical specifications and purge and vent.
d. Responsiveness to NRC Initiatives
The licensee has been responsive to NRC initiatives. During
the rating period, it made every effort to meet or exceed
26
I
.
'
commitments. Responsiveness by the licensee facilitated
timely completion of staff review of a large number of
licensing actions and thus substantially reduced the
licensing backlog. The licensee's quality of license
amendment requests, especially the "no significant hazards
consideration" improved significantly after the " counter-
parts" meeting held on January 30, 1986 in Bethesda, where
this topic was discussed in detail. The licensee has
responded promptly and accurately to various surveys
conducted during the reporting period.
In addition, the licensee at the staff's request has
provided submittals for the staff in a very short turn-
around time. This was especially evident in the licensee's
response to the staff's request for the LACBWR status on
the implementation of generic requirements. The licensee
was required to review a vast amount of documentation and
provided the NRC staff with a timely response which was of
high quality,
e. Staffing
The licensee has maintained adequate licensing staff to
assure timely response to the NRC needs.
During this period, the licensee's performance was found to be
above average to excellent overall. Management attention and
involvement was generally as expected. This was evident in both
the safe and efficient operation of the facility. Staffing
levels and quality were adequate. Communication levels between
the operating staff and proper management were established and
generally effective. The licensee has been, in most cases,
effective in dealing with significant problems and NRC initiatives.
The licensee's attention to housekeeping appears to have been
excellent. The licensee's efforts in the functional area of
Licensing Activities has significantly improved during this
evaluation period. This is reflected in the quality of work,
attention to NRR concerns and involvement of senior management.
DPC was an active participant at the counterparts meeting of
January 30, 1986, in Bethesda, Maryland.
2. Conclusion
The overall rating for the functional area of licensing
activities is Category 1.
3. Board Recommendations
None.
27
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_
.
K. Training and Qualification Effectiveness
1. Analysis
A training effectiveness inspection conducted during the
assessment period identified no generic training-related problems.
The training feedback of lessons learned from plant events was
accomplished primarily in supervisor meetings and by required
reading which appeared adequate. However, licensed operators did
express a desire for more input on general plant problems. The
training programs for non-licensed personnel were primarily based
on on-the-job training (0JT) with minimal classroom instruction.
The requalification training for licensed operations consisted of
required lectures conducted on a 24-month cycle and simulated
manipulations. Initial qualification training consisted of
attendance at the requalification lectures and 0JT. The success
rate for initial licensing examinations in the past has been
consistent with national averages over the last several years.
However, during this evaluation period the success rate declined
to less than the national average when only seven of the eleven
candidates passed their examinations.
It was determined by the inspection and operator licensing
staffs that the Lacrosse operator license training program did
not provide the three months of on-shift training for senior
reactor operator candidates for the specific purpose of preparing
them for Shift Supervisor duties. It was also determined that
the applications submitted by two reactor operator candidates
contained inaccurate information and that certain training
credited to them was not relevant to their license training.
It was also determined that training deficiencies existed for
previous senior reactor operator candidates.
These issues were discussed at two meetings held on May 7 and
May 30, 1986, in the Region III office with management represen- -
tatives from Dairyland Power Cooperative and the NRC. During
the May 30 meeting the licensee agreed to implement a documented
on-shift training program for senior reactor operators and to
provide this training to currently licensed senior reactor
operators identified in a letter dated June 5, 1986, from
Mr. James W. Taylor, General Manager, Lacrosse.
Based upon the examination results during the assessment period
and the implementation of the on-shift training program for
senior reactor operators, the Lacrosse license training program
is considered satisfactory.
A separate evaluation of radiological controls training indicated
that the licensee is developing a formal health physics technician
training / retraining program. Training is performed mainly by
station professionals and by required self-study. The training
has contributed to an adequate understanding of work and fair
adherence to procedures with a modest number of personnel errors.
28
1 .
,
.
\
The licensee has made all required submittals to INP0 i
regarding the subject training areas. Licensee management
attention to the training area appeared to be adequate except
for the misunderstanding of SRO candidate training requirements.
\
2. Conclusion .
The licensee is rated Catego'ry 2 in this functional area.
3. Board Recommendations
None.
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V. SUPPORTING DATA AND SUMARIES
A. Licensee Activities
The unit engaged in routine power operation throughout most of
SALP 6 except for two major scheduled outages for plant refueling,
modification, and maintenance. The first one began on March 10,
1985 and was completed on April 17, 1985. The next refueling outage
began on March 7, 1986 and was completed on May 16, 1986.
The remaining outages throughout the period are summarized below:
April 20-21, 1985 Repaired Scram Solenoids on
Control Rod No. 12
April 21-22, 1985 Repaired Seal Inject System
April 27, 1985 Repaired Feedwater Controller
May 17-18, 1985 Replaced Scram Solenoid and
adjusted Pressure Switches
July 25-27, 1985 Repaired Ground in Control
Rod No. 8
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September 14-15, 1985 Repaired Blow Fuse
October 22-23, 1985 Switchyard Breaker tripped
October 23-25, 1985 Nuclear Instrumentation
repair of Channel 6
October 26-27, 1985 Repaired leak on Control Rod
No. 2
January 5-13, 1986 Repair Mechanical Seal on
Control Rod No. 2
January 24-29, 1986 Repaired Seal Leakage on
Control Rod No. 13
May 25-27, 1986 Repaired Forced Circulation
Pump 1A
June 22-25, 1986 Repaired MSIV Relay
June 27-28, 1986 Repaired Reactor Feed Pump 1A
Controller
The plant scrammed 17 times during this assessment period. Eight of
these were from power. This reactor trip frequency is much higher
than the national average. Two of the eight at power scrams were due
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to personnel error. Two were due to feedwater Pump 1B controller
malfunctions. Two were due to the 1B reserve feed breaker failing to
close. The remaining two were due to unrelated equipment failures.
.B. Inspection Activities
The annual Emergency Preparedness Exercise was conducted on June 25,
1985.
Violation data for the LACBWR plant is presented in Table 1, which
includes Inspection Reports No. 85001-85022 and 86001-86007.
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TABLE 1
ENFORCEMENT ACTIVITY
'
FUNCTIONAL NO. OF VIOLATIONS IN EACH SEVERITY LEVEL
AREA
III IV V
A. Plant Operations 1
B. Radiological Controls 2
C. Maintenance / Modifications
D. Surveillance and Inservice Testing
E. Fire Protection 1
G. Security 4 1
H. Outages
I. Quality Programs and
Administrative Controls
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Affecting Quality
J. Licensee Activities
K. Training and Qualification
Effectiveness
TOTALS 7 2
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C. Investigations and Allegations Review
A contractor employee had concerns related to the fact that
compensatory measures were not taken for out-of-service alarms and
vital area doors were left open without a security guard present.
The alleged events occurred in 1982 and could not be substantiated.
D. Escalated Enforcement Actions
There were no escalated enforcement actions during this assessment
period.
E. Licensee Conferences Held During Appraisal Period
1. March 28, 1985 (Glen Ellyn, Illinois)
M2eting to review Systematic Assessment of Licensee
Performance (SALP 5).
2. May 7, 1986 (Glen Ellyn, Illinois)
Meeting to discuss the information on reactor operator
applications submitted to the NRC.
3. May 30, 1986 (Glen Ellyn, Illinois)
Meeting to discuss the information on senior reactor
operator applications submitted to the NRC.
F. Confirmation of Action Letters (CAls)
A CAL was issued on October 23, 1985, concerning issues related to
apparent improper response to the reactor protection system which
resulted in an alert and manual rod insertion during a startup on
October 23, 1985.
G. Review of Licensee Event Reports, Construction Deficiency Reports,
and 10 CFR 21 Reports Submitted by the Licensee
1. Licensee Event Reports (LERs)
LERs issued during the 18 month SALP 6 period are presented
below:
LERs No.
85-01 through 85-20
86-01 through 86-19
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Proximate Cause Code * Number During SALP 6
Personnel Error (A) 2
Design Deficiency (B) 3
External Cause (C) 0
Defective Procedure (D) 1
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Management / Quality Assurance
Deficiency (E) 0
Others (X) 18
No Cause Code Marked ** 14
Total T9
- Proximate cause is the cause assigned by the licensee
according to NUREG-1022, " Licensee Event Report System."
- NUREG-1022 only requires a cause code for component failures.
In the SALP 5 period, the licensee issued 32 LERs in 18 months
for ar, issue rate of 1.8 per month. In the SALP 6 period the
licensee issued 39 LERs in 18 months for an issue rate of 2.2
per month. By comparison to like plants (to which there are
few) the number of LERs is high.
Sixteen of the LERs were related to scrams, four were due to
unsampled water being discharged, three due to the high pressure
service water diesel, two for degraded fire barriers, seven for
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ESF actuations, two due to leakage test failures, one was because
the HPCS bundle was b?nt, one due to an unlatched control rod,
one due to a cracked valve, one due to a wrong alternate core
spray lineup, and one because of an apparent failure to scram.
Three events reported under 10 CFR 50.72 requirements were
considered significant and were discussed at the Operating
Reactor Events Briefing (OREB) in Headquarters. The first
related to a loss of offsite power and a scram that occurred on
October 22, 1985. This event was classified an unusual event.
This event occurred due to maintenance personnel error when the
plant was at 98% power. The scram was normal without complica-
tions and the emergency diesel generator started ano powered all
required loads normally. The event was promptly reported within
16 minutes of its occurrence, and within an hour, offsite power
was restored and the unusual event terminated. The second event
occurred on October 23, 1985 and related to an apparent failure
to scram upon receipt of a high flux signal. The failure to
scram was caused by electrical failure that caused a malfunction
of the reactor protection system (RPS). the control rods were
manually inserted to bring the reactor subcritical. The plant
was placed under alert conditions for a brief period, and all
concerned agencies were notified promptly. The third event
discussed at the OREB occurred on March 6, 1986 and related to
the ignition of the turbine offgas stream during sampling
activities.
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The office for Analysis and Evaluation of Operational Data (AE00)
reviewed the LERs for this period and concluded that, in general
the LERs are of above average quality based on the requirements
contained in 10 CFR 50.73. However, they identified some minor
deficiencies. A copy of the AE0D report has been provided to the
licensee so that the specific deficiencies noted can be corrected
in future reports.
2. Construction Deficiency Reports
No construction deficiency reports were submitted during the
assessment period.
3. 10 CFR 21 Reports
_
No 10 CFR 21 reports were submitted during the assessment
period.
H. ' Licensing Activities
1. NRR/ Licensee Meetings (at NRC)
Discussion of Licensing Issues 06/27/85
Discussion of SEP Topic and FTOL 10/81/85
.
Counterparts Meeting 01/27/86 - 01/30/86
Meeting the EDO 03/27/80
Discussion of Insurance Exemption 04/14/86
Discussion of Insurance Exemption 06/05/80
Preparation for Commission Meeting 06/17/86
2. NRR Site Visits
Appendix R Inspection 07/08/85 - 07/11/85
Plant Orientation 12/11/85 - 12/13/85
3. Commission Meeting
06/17/86 - Commission Briefing on LACBWR Insurance Exemption
4. Reliefs Granted
ISI - ACS & BI Check Valves - 02/28/85
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5. Scheduler Extensions Granted
Equipment Qualifications 03/27/85
FSAR Submittal Date 08/21/85
6. Exemptions Granted
Primary / Property Damage Insurance Exemption 06/26/86
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7. License Amendments Issued ,
Amendment Title Date
38 NUREG-0737 GL 83-02 01/08/85
39 Pressure-Temperature Operating
Limitations 03/22/85
40 Containment Leak Testing 04/23/85
41 SEP Integrated Assessment 05/28/85
42 Byproduct Material Quantity
Limitations 06/05/85
43 Reactor Coolant System Safety
Valves 06/07/85
44 Virgin Water Tank 10/08/85
45 Flooding Conditions 01/06/86
46 Increase Exposure Limit of
Fuel Assemblies 03/25/86
47 Replacement of Control Rods 03/27/86
48 120 VAC IC Bus 04/14/86
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