ML20151Y953

SALP Board Repts 50-373/85-01 & 50-374/85-01 for May 1984 - Sept 1985

ML20151Y953
Person / Time
Site:	LaSalle
Issue date:	02/11/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20151Y949	List: ML20151Y945 ML20151Y953
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

-

,-

I

t.

SALP 5

,

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

~'

8602130228 860211 3

PDR ADOCK 0500

0

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

2

>

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

'

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.

6

3

-- ..

.. .

_ _ - _ _ _ _ - _ _ _ _ - _ - _ _ _ _ - _ -

~

!

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.

1

!

.

4

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.

5

_

IV. PERFORMANCE ANALYSIS

A. Plant Operations

1. Analysis

'

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).

.

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).

i

I

6

-- - --

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.

7

- -

.. . . . , . _ _ . _ ._

-- -.

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.

8

j

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).

9

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.

10

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

11

i

._ - - - - - _. - -

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

12

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).

13

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

'.

maintenance activities (373/85013-02; 374/85013-02).

14

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

l

l

l

i

,

15

l

. _ - - . _ -

\

. 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.

F. Emergency Preparedness

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

inattentive,

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