IR 05000409/1980007
| ML19295F982 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 11/10/1980 |
| From: | Donahue J, Norelius C, Phillip G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19295F981 | List: |
| References | |
| 50-409-80-07, 50-409-80-7, NUDOCS 8012180026 | |
| Download: ML19295F982 (6) | |
Text
e
..
.
'
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND EhTORCEMENT
REGION III
Report No. 50-409/80-07 Docket No. 50-409 Licensee No DPR-45 Licensee: Dairyland Power Cooperative Lacrosse, Wisconsin Facility Name:
LACBWR Dates of Investigation: August 26-27, 1930 Investigation At:
Genoa, Wisconsin Investigator:
[#
//[///[d
,G.
A. Phillip p'
Daf.e
'
b* Y
// /a[fo Reviewed By:
- -
C. E. Norelius
/'
Date Assistant to the Director
//f/0 ?C
fV R. Donahue, Chief Date Security and Investigation Section Investigation Summary:
Investigation on August 26-27, 1980 (Report No. 50-409/80-07)
Areas Investigated: Because NRC personnel were concerned that information supplied by the licensee in a letter dated January 16, 1980, was possibly intentionally misleading, reviewed procedures and records and interviewed personnel. The investigation involved twelve investigation hours by one investigatcr.
Results: No information was cbtained which indicated that the licensee had intentionally misled the NRC. No items of noncompliance were identified.
- 801218000I0
.
.
REASON FOR INVESTIGATION By letter dated January 16, 1980, the licensee provided information to the NRC concerning the status of the implementation of their Modified Amended Security Plan (KASP). An investigation was initiated to determine whether the contents of that transmittal were intentionally misleading.
SUMMARY OF FACTS To meet the requirements of 10 CFR 73.55, the licensee made commitments to acquire and utilize certain security systems.
Since these systems were not employed in place and functioning on the established date for implementation of the new requirements, February 23, 1979, the licensee was permitted to employ compensatory measures until the MASP, including these systems, was fully implemented. The projected date for full implementation was June 15, 1979.
The licensee did not meet this target date.
By letter dated June 11, 1979, the licensee provided the NRC the status of their implementation of the MASP.
By letter dated January 16, 1980, the licensee again provided an unsolicited letter providing information concerning the status of their implementation of the MASP. The January 16, 1980, letter contains the following statement:
...pending satisfactory check-out of surveillance and detection equipment
"
and completion of guard force training for this equipment, compensatory measures continue to be employe?." It also states:
"... enclosure 1 to this letter provides the current status of implementation of the MASP and revised estimates for completion of unfinished work."
However, the enclosure with this letter states that certain identified systems were " operational."
A NRC security inspection conducted in June 1980 determined some systems were not satisfactory, i.e. the systems could not meet reliability require-ments, acceptance test procedures had not been prepared and such tests had not been conducted. NRC personnel considered characterization of the systems as " operational" to be misleading.
Licensee personnel stated that there was no intent to mislead the NRC and that the word operational, as used in the enclosure, meant that the equip-ment was installed and plugged in, but as indicated in their letter, had not checked out satisfactorily.
No items cf noncompliance were identified during this investigation.
-2-
DETAILS
1.
Persons Contacted Dairyland Power Cooperative R. E. Shimshak, Plant Superintendent W. R. Nowicki, Instrument and Electrical Supervisor G. R. Joseph, Security Director C. Ducheneau, Technical Support Engineer USNRC M. Branch, NRC Resident Inspector 2.
Introduction Although licensees were required to meet the provisions of 10 CFR 73.55 by August 24, 1978, the licensee requested and was granted an extension for full implementation to February 23, 1979. By letter dated February 21, 1979, the licensee submitted the Lacrosse Boiling Water Reactor Modified Amended Security Plan (MASP) and requested specific temporary exemptions from the requirements of 10 CFR 73.55.
On March 21, 1979 the NRC staff discussed the results of their review with the LACBWR Plant Superintendent. Some minor but necessary changes were identified. By letter dated April 3, 1979 the Office of Nuclear Reacter Regulation (NRR) advised the licensee that the MASP, modified by these changes and supplemented by compensatory measures that provide equivalent protection in lieu of those systems that were not imple-mented at that time, would provide the protection required by 10 CFR 73.55 until the projected full implementation date of June 15, 1979.
By letter dated April 19, 1979, the licensee submitted the changes to the MASP and stated the compensatory changes were in effect.
By letter dated June 11, 1979 the licensee provided the status of their implementation of the MASP together with revised estimates for the completion of unfinished work. Target dates for completion of individual items were given which ranged from June 15 to November 1, 1979.
In December 1979 Region III conducted an inspection of the licensee's security program and determined that the compensatory measures were being utilized since the MASP had not been fully implemented. The licensee provided another implementation status report by letter dated January 16, 1980. Since the status report described some systems as
" operational," Region III security personnel concluded the Mt.SP was in effect.
In June 1980, Region III conducted a security inspection at the licensee's facility and determined that some security systems committed to by the licensee in their MASP were not performing their-3-
.
intended functions and that compensatory measures were being utilized to provide adequate protection.
It was further determined that some systems had never functioned satisfactorily, acceptance test proce-dures had not been prepared or the tests conducted.
Prior to this inspection the NRC had been under the impression these systems were performing as required. This impression was based upon the letter, with enclosure, dated January 16, 1980, sent to the Commission by the licensee. The enclosure to this letter characterized the systems as being operational.
A copy of this letter, without the enclosure which contains 2.790 information, is attached to this report as Exhibit A.
3.
Visit to LACBWR During a visit to the LACBWR facility on August 26-27, 1980, the following information was obtained through interviews with personnel and a review of procedures and records. The surveillance and detection equipment required by the licensee's Modified Amended Security Plan (HASP) was purchased by the licensee.
Purchase of the equipment did not inclbde installation and testing of the equipment by the supplier.
During 1979 and continuing in 1980, the licensee experienced problems with the supplier. Equipment was received from the supplier with com-ponents missing and the drawings and diagrams needed for installation of the equipment were sketchy and incomplete. While these problems were being resolved, the licensee utilized compensatory measures to provide equivalent protection to that required by 10 CFR 73.55.
By letter dated June 11, 1979, the licensee provided NRC information on the current status of the implementation of the MASP and estimates regarding the completion of unfinished work. The January 16, 1980 letter was an unsolicited status report concerning the new security systems. The licensee pointed out, that at the time this letter was submitted, the new systems were not being relied upon and the letter stated that "...pending satisfactory check-out of surveillance and detection equipment and completion of security guard force training for this equipment, compensatory measures continue to be employed."
The enclosure to the January 16, 1980 letter states: "The intrusion detection hardware is installed and operational." The licensee indi-cated that the status information set forth in the enclosure with the letter is not misleading if it is reviewed with the statements in the letter itself in mind.
Regarding the status of the closed circuit t.v. system, the licensee stated that the system was in place and functioning satisfactorily as of January 16, 1980, with the exception of an automatic switching feature. This feature, however, was not required by the MASP and switching was still being done manually.
-4-
.
The enclosure to the January 16, 1980 letter stated:
" Microwave and E-Field detection systems are complete and operational." The licensee advised that the microwave and E-field detection system was in place and hooked up to electrical power. Difficulties were experienced with the system in that there were random and spurious alarms making it unreliable.
In December 1979, the supplier visited LACBWR to run tests on the system and at the conclusion of that visit it appeared the systems were functioning properly. During the period of January-March 1980, the licensee's guards were instructed to maintain a log of the systems' performance. The systems, however, registered so many alarms the guard sometimes turned the systems of f.
The computer information concerning the alarms was of little value to the personnel working on the systems so this information was discarded.
Licensee personnel stated the systems could not meet the reliability standards and, for that reason, the January 16, 1980 letter pointed out that the compensatory measures would continue "...pending satisfactory check-out."
The licensee advised that problems were also encountered with the card reader system interface with the computer. As of January 1980, cards for the system had not been issued to LACBWR personnel. Rather the older system was still being used. At one point in early 1980, the card reader system seemed to work properly, but tests of the system were not completed. During this period, some components had to be returned to the supplier for repair and/or replacement. The interface unit between the computer and the back-up computer was on hand, but it had not been hooked up.
The connections supplied by the vendor did not match and were also returned.
A review of the LACBWR security procedures showed that security equipment testing procedures, including those setting forth accept-ance criteria, were all dated July 1980.
Regarding the use of the term " operational," the individual who was the primary author of the January 16, 1980 letter and enclosure, stated the term was not intended to convey the idea that a system was functioning properly but merely that it did work. If the system was functioning so that it could be relied upon, the compensatory measures would have been discontinued. The individual said that in writing the letter, they were not thinking in terms of the technical specifications.
The definition of " operable-operability" set forth in the LACBWR Technical Specifications did not even come to mind.
(Investigator's Note: The LACBWR Technical Specification contains the following definition: "0PERABLE-OPERABILITY" - A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function (s).
Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal and emergency and electrical power sources, required for the system, subsystem, train, component or device to perform its function (s) are also capable of performing their related support function (s)".)
-5-
.
The licensee stated that the January 16, 1980, letter, was prepared in
the interest of keeping the NRC apprised of the status of the security systems and there was no intent to mislead or deceive the NRC.
One of the NRC resident inspectors assigned to LACBWR stated that in January 1980 he was aware the licensee was having difficulty getting the security protective systems to perform as required.
4.
Exit Meeting On August 27, 1980, an exit meeting was held with R. E. Shimshak, Plant Superintendent. At this time the Plant Superintendent reiterated that, regarding the January 16, 1980 letter, there was no intent to mislead the NRC and that it was his position the letter and the enclosure, when taken together, are not misleading. He agreed that in retrospect the use of the term " operational" was unfortunate.
Attachments: Exhibit A, letter dated January 16, 1980 from LACBWR to NRC-6-
.
l DAIRYLAND POWEll Cu:'PEILSTEVE
..
Ba G,m u, O L
,m.-
)
34601 January 16, 29f'.
In reply, please refer to LAC-6738 DOCKET NO. 50-409 Director of Nuclear Reactor Regulation ATTN:
Mr. Dennis L.
Ziemann, Chief Operating Reactors Branch $2 Division of Operating Reactors U. S. Nuclear Regulatory Cruimission Washington, D. C.
20555
.
SUBJECT:
DAIRYLAND POWER COOPERATIVE LA CROSSE BOILING MATER REACTOR (LACBWR)
PROVISIONAL OPERATING LICENSE NO. DPR-45 MODIFIED, AMENDED SECURITY PLAN -
IMPLEMENTATION STATUS References:
(1)
DPC Letter, LAC-6340, Linder to Ziemann, dated June 11, 1979.
vd!)
DPC Letter, LAC-6225, Linder to Ziemann,
,
g.
i dated April 19, 1979.
(3)
NRC Letter, Stello to Taylor,
'
dated April 3, 1979.
..
(4)
DPC Letter, I.AC-6123, Linder to Ziemann, dated February 21, 1979.
Gent-i m'an :
Our letter (Reference 2) sulanitted additional changes to the
-
Modified Amended Security Plan (MASP) and identified temporary,,
compensatory measures to provide equivalent protection 'in lieu of currently non-implemented systems to provide protection required by
-
-
Progress has been made in resolving difficulties with the principal supplier of electronic interface equipnent for security surveillance and detection components, and most of this equipment has now been delivered and installed, however, pending satisfactory checkout of -
_
surveillance and detection equipnent and completion of security.
.
guard force training for this equipment, compensatory measures con--
tinue to be employed.
-
.
,
References (1) and (4) provided status reports of implementation of,
-
the MASP together with estimates for completion of unfinished work.
Enclosure 1 to this letter provides the current statds 'of implemen-tation of the MASP and revised estimates for completion of ' unfinished
work.
-
]:3 l) Oh
-
.
-
1-
' " ~ ~
'
-
.
Cepi.2;q2d2
. Page L of 2 Exhibit "A"
qqf3 e9:qygg..
=5-2 g*
.:
.,s n-= 8..;~*
.-
t
.
..
IAC-6738 tir. Dennis L. Ziemann, Chief L
Operating Reactors Branch 42 January 16, 1980
,
It is requested that the sutmittal (Enclosure 1) be withheld from public disclosure pursuant to Section 2.790 of 10 CFR Part 2.
If there are any questions concerning this submittal, please contact ur.
Very truly yours, DAIRYIAND POWER COOPERATIVE
,
Ach Frank Linder, General Manager FL:FD:af
-
Enclosure J. Keppler, Reg. Dir., NRC-DRO III cc:
-
-
.
...
_
-
.
~
..
_
_-
-
-
. - _ - -
-
--
-
_-
_
.
.
.
)
-
.
-
2-
-
Exhibit "A" Page 2 of 2
.
.