ML20206T743

SALP Rept 50-409/86-01 for Jan 1985 - June 1986

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: ML20206T713 ML20206T743
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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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

operable.

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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

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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

F. Emergency Preparedness

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

Emergency Plan.

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

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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

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- _ _ . -__ _ _ __ - . - . .

.

'

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

Generic Letter 85-19

Emergency Core Cooling System

Static Inverter 1C

Miscellaneous Systems

1C Inverter

Control Rods

Fuel Exposure

Control Rod Drives

Containment Ventilation Dampers

Flooding

Vessel NDT

Byproduct License

(2) Exemption Requests

Primary Property Damage Insurance

FSAR Submittal Schedule

24

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_ _ -- . _ _ _ _ - . _ - - . . - . . -. - -- - - -__ -_ - - .- --

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

Regulatory Guide 1.97

(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

ODCM

Environmental Qualification

Generic Letter 85-07, Integrated Scheduling

Heavy Loads

Generic Item B-24, Venting

ATWS

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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. _ _ _ _ _ _ ___

.

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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

-

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

30

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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.

1

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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

F. Emergency Preparedness

G. Security 4 1

H. Outages

I. Quality Programs and

Administrative Controls

-

Affecting Quality

J. Licensee Activities

K. Training and Qualification

Effectiveness

TOTALS 7 2

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- - - . . _ _ .

.

. .

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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

33

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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

-

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.

34

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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

'

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

35

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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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