IR 05000409/1980018
| ML19351G196 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 01/21/1981 |
| From: | Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19351G192 | List: |
| References | |
| 50-409-80-18, NUDOCS 8102230253 | |
| Download: ML19351G196 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-409/80-18 Docket No. 50-409 License No. DPR-45 Licensee: Dairyland Power Cooperative 2615 East Avenue-South La Crosse, WI 54601 Facility Name: La Crosse Boiling Water Reactor (LACBWR)
Meeting At: Dairyland Power Cooperative Offices-La Crosse, WI NRC Personnel Present: James G. Keppler, Director, RIII R. F. Heishman, Chief,, Reactor Operations & Nuclear Support Branch J. A. Hind, Chief, Safeguards Branch D. C. Boyd, Chief, Reactor Projects Section 4 W. L. Forney, Senior Resident Inspector M.
'. Branch, Resident Inspector O
i Approved By:
eishman, Chi f
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Reactor Operations and
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Nuclear Support Branch Inspection Summary Management Meeting on December 15, 1980 (Report No. 50-409/80-18)
Areas Discussed: Management meeting held at the NRC's request to discuss the regulatory performance of the activities at the LACBWR facility as concluded in the Systematic Assessment of License Performance (SALP) program.
Results: A summation of the licensee performance evaluation was presented.
Areas of concern were discussed with corporate management. The performance at the LACBWR Facility was considered to be adequate.
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i DETAILS 1.
Persons Contacted Dairyland Power Cooperative F. W. Linder, General Manager y
J. W. Taylor, Assistant General Manager R. E. Shimshak, Plant Superintendent
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J. D. Parkyn, Assistant Plant Superintendent
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2.
Areas Discussed l
a.
A summary of the SALP program was presented, including the develop-
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ment, the basis for evaluation, and the purposes of the SALP program, i
b.
The results of the NRC's evaluation of the licensee's performance
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were discussed.
(A copy of the evaluation is enclosed).
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c.
An analysis of LACBWR's noncompliance data for the SA;P period
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(August 1, 1979-July 31, 1980) was presented. Also a comparison of DPC's noncompliance data with that of other RIII operating plants for the years 1975-1979 and for the first nine months of 1980 was presented.
d.
An analysis of the significance of the Licensee Event Reports (LER's)
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submitted by DPC during the SALP period was presented. A comparison of the significance of DPC LER's with those submitted by other RIII operating plants was presented.
The NRC's new enforcement policy, including plans for implementation, e.
was briefly discussed.
3.
Licensee Comments The licensee commented during the presentation of each of the areas in
paragraph 2 and discussed several matters of concern as follows:
a.
Some concern was expressed over the multiplicity of management apprai-sals that keep plant management from performing their normal duties.
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They mentioned Health Physics Appraisal Team, PAB, SALP, and others.
l b.
The licensee took strong exception to the "below average" Health Physics rating and to statements concerning plant management attitude. They emphasized that they have never experienced an over exposure and have completed a number of complex radiation / contamination job efforts, such
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as the spent. fuel rack modification and the handling of contaminated l
resins, without any significant health physics problems.
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c.
The licensee discussed their corporate attitude and philosophy towards
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plant performance. They stated that it has always been their intent to operate their plant safely and in accordance with the Rules and Regula-
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tions and that they intend to be above average in all respects.
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The licensee stated that they had made significant personnel moves and assignment changes in the past several months and that the positive benefits of these changes was just now beginning to show.
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d.
Concern was expressed over the number of and requested response times for the many NRC requests for action, such as TMI Action Plan items, IE Bulletins, NRR Generic Letters, NRR questions related to licensing l
matters, and new regulations. They are having a significant impact on the utilities ability to safely and efficiently operate and manage
t their business while still being responsive to NRC requests. The in-creased work load imposed by the NRC has also created a staffing need that places all parties in the nuclear industry in competition for the limited number of available qualified people.
Enclosure:
LACBWR Performance Appraisal Report
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a LACBWR PERFORMANCE EVALUATION PLAN i
REGION III
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LICENSEE PERFORMANCE EVALUATION (OPERATIONS)
FACILITY: LACBWR
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LICENSEE: Dairyland Power Cooperative
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Unit Identification:
i Docket No.
License No./Date of Issuance
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50-409 DPR-45/ August 28, 1973 Reactor Information:
I NSS Allis-Chalmers i
MWt 165 Appraisal Period:
August 1, 1979 to July 31, 1980 i
i Appraisal Completion Date:
November 4, 1980
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Review Board Members:
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R. F. Heishman, Chief, Reactor Operations & Nuclear Support Branch D. C. Boyd, Chief, Projects Section 4 W. L. Forney, Senior Resident Inspector, LACBWR M. W. Branch, Resident Inspector, LACBWR l
J. A. Hind, Chief, Safeguards Branch J. F. Donahue, Chief, Security & Investigation Section G. Pirtle, Inspector, Security & Investigation Section R. L. Greger, Inspector, Fuel Facility Projects & Radiation Support Section J. Shea, Project Manager, Nuclear Reactor Regulations-Division of Project Managers
- D. H. Danielson,-Chief, Engineering Support Section 2 i
- I. T. Yin, Inspector, Engineering Support Section 2
- Not present for board meeting, however, verbal and/or written information was provided for evaluation.
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A.
Number and Nature of Noncompliance Items
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Noncompliance category:
Violations
Infractions
Deficiencies
Areas of Noncompliance:
(Points)
Operations
FF&MS
Safeguards
Construction
Total 120 Inspection Reports covered by this review:
50-409/79-18 through 50-409/80-08 Evaluation of noncompliance items:
Operations During the SALP period, 8 inspections were performed in this area; 6 infractions and 4 deficiencies were identified.
Although the items of noncompliance were written against a vide variety of requirements an analysis of underlying
causes indicates a common cause of personnel error / failure to follow written procedures to be the primary area of weakness. These items were not significant from the stand-point of adversely affecting the health and safety of the public. In addition, other items of concern not consti-tuting items of noncompliance, were conveyed to plant management by the Resident Inspectors. These items also dealt with failure of plant personnel to follow written procedures. Management has a record of providing untimely responses to IE Bulletins, items of noncompliance, and of reviewing and providing internal resolution to IE Circulars.
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The licensee performance in operational areas is considered to be " average" when compared to other Region III Power Reactor Licensees.
FF&MS During the SALP period, 1 inspection was performed in this area. No items of noncompliance were identified. However, a special Health Physics appraisal conducted September 22, 1980-October 3, 1980, which included the examination of the licensees Health Physics performance during the SALP period
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LACBWR-2-f FF6MS (report not yet issued) identified significant weaknesses in the licensee's radiation protection program. These weaknesses included; incorrect response to the TMI lessons
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learned requirements; slow response to correcting isokinetic stack sampling problems; problems in quantifying gaseous releases; lack of professionalism in H.P. Technicians; and lack of a formal H.P. technican training program. Based on Health Physics Appraisal findings and past inspections, the licensee's Health Physics program ranks "below average" among power reactors.
The licensee's overall performance in the areas of confirma-tory measurements and analytical quality control of measure-ments, environmental protection and emergency planning has been average. There have been no items of noncompliance in these areas. Confirmatory measurements agreement was slight-ly below the regional average at the last inspection but has shown significant improvement since the 1978 results.
The inspection program in these areas will be conducted at the routine frequency.
Safeguards During the SALP period, 2 inspections were performed in this area; 7 infractions and 5 deficiencies were identified.
Within the past year, LACBWR has been plagued by ineffective management control and equipment problems. Since October 1980, however, many of the problems have been resolved.
LACBWR's management's position was that the security plan, in it's entirety, was not binding until all security systems were operational. Acccrdingly, they periodically advised NRR through June 1980, of their progress in implementing portions of the security plan. This interpretation of the plan commitments caused LACBWR management to feel that their progress in plan implementation was satisfactory. The July 7-11, 1980 inspection revealed that their security plan commit-ments were effective and binding as of June 15, 1979 and the
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licensee was found to be in noncompliance with several sections of the security plan.
Prior to December 1979, vendor and equipment suppliers contributed greatly to the difficulties encountered in implementing the licensee security system. Some provided equipment failed to meet specifications and the adequacy l
i of engineering support by a major supplier was less than desired by the licensee. However, by January 1980, suffi-l cient equipment / hardware was installed to initiate accept-l ance testing. Acceptance testing for some sections of the system was not completed in a timely manner and lacked l
adequate management guidance and emphasis.
i A management meeting, held July 28, 1989, emphasized the l
necessity to meet security plan commitments as early as l
possible and resulted in the licensee committing to an implementation schedule. The schedule has been closely monitored by the region and a followup inspection was conducted October 9-10, 1980.
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Since the management meeting, an improvement in management's attitude towards security has been noted. The assistant plant manager was designated to monitor implementation of the secu-rity system and act as the NRC contact for security matters.
The addition of this managerial level within the security organization has resulted in an added impetus for solving security equipment and administrative problems.
Thelicenseehasassumedmajorresponsibilitiesforthe maintenance and service of all security systems. Region 111 plans to continue their increased inspection frequency for LACBWR until all portions of the system are fully opera-tional and the ability of the licensee to effectively main-tain the security systems has been demonstrated. Training requirements pertinent to the licensee's Safeguards Contin-tency Plan and Guard Force Training and Qualification Plan will also be closely monitored.
Performance during the period covered by the SALP is con-sidered "below average" when compared to other R-Cion III power plants.
Construction During this review period one construction inspection, review of fuel racks, was conducted. No items of non-compliance were identified. This plans is rated as " average" in this area when compared to other Region III power reactors.
The licensee's overall regulatory performance is acceptable; Summary however, licensee management needs to focus more attention on plant personnel adherence to written procedures, particularly in the areas of operations and radiological controls, and continue to assure their efforts to complete implementation of the Security Plan.
B.
Number and Nature of Licensee Events Reports Type of Events:
Personnel Error
Design / Man.Const./ Install.
External Cause O
Defective Procedure Component Failure
Other
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Licensee Event Reports Reviewed:
LER No. 79-14 through 80-04 Evaluation of LER's During this SALP period, 3 of the LER's deal with personnel error, one of these resulted in noncompliance, and the other two were ci minimal consequences and resulted in no threat to safe operation.
The number of personnel errors is not considered excessive. Two-thirds of the LER's were due to component and/or equipment failures, and the remainder were design considerations which, af ter evaluation, proved to be of little consequence.
C.
Escalated Enforcement Actions Civil Penalties None Orders Show Cause Order, Installation of a water removal pump to limit / prevent the consequences of plant damage due to liquifaction (February 28, 1980).
Immediate Action Letters
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None D.
Management Conferences Held During Past Twelve Months October, 1979 Retention of operating personnel and recruiting efforts.
July, 1980 Failure to comply with Modified Approved Security Plan.
E.
Justificaton of Evaluations of Functional Areas Categorized as Requiring an Increase in Inspection Frequency / Scope Radiation Protection /Radwaste Operations:
Increased inspection frequency and scope is warranted in this area due to the Health Physics Appraisal findings, and concerns found during inspections performed by the resident inspectors.
Security and Safeguards Increased inspection scope is warranted in this area due to the high numbers of noncompliance and repeat items of noncompliance associated with licensee adherence to the Modified Approved Security Pla _. -
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Emergency Planning Increased inspection scope is warranted in this area because of the recent changes in 10 CFR 50, Appendix E.
This is applicable to the other Region III licensees.
Management Controls Increased inspection scope is warranted in this area because of the apparent inability of management to identify and implement corrective
actions in a timely manner regarding items of noncompliance and inspec-tor concerns. Additionally, management needs to ensure that adequate, well defined procedures are provided and that plant personnel are trained and follow the written procedures.
F.
Other Observations and Conclusions Attitude of Station Personnel The site management has a negative attitude toward the Nuclear Regulatory Commission in general and the Resident Inspector Program in particular.
This attitude has been vocalized in the news media and often times pre-cipitatch down thru the subordinate management structure.
Communication Management effort should be directed toward better horizontal communica-tion, e.g. craf t to craf t, department to department. Better communica-tions within the organization on identified problems, and performance of nonroutine evolutions should result in fewer inspector concerns or items of noncompliances.
Effect of NRC Requirements on Licensee Performance Review and implementation of the numerous new regulatory requirements resulting from lessons learned from the Three Mile Island accident has placed a burden on the licensee,particularly in the area of engineering management. The licensee has responded to these additional requirements in a professional manner; however, due to the size of the plant staff, the amount of time available to the various managers to identify and resolve problems appears to be significantly reduced.
Licensing Project Manager Appraisal The NRR and I&E interfaces with Dairyland Power Cooperative are unique in that they involve the same DPC management personnel, all located at the LACBWR site.
In effect, the LACBWR management is doubly exposed to NRC overview in safety related areas. Over the past year, extensive NRR involvement has included orders,-directives, amendments and requests for information which have resulted in numerous changes to the plant
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-6-technical specifications and important piant modifications to further enhance the health and safety of the population in the vicinity of the LACBWR plant. Some of the NRR involvement with the'DPC management can be typified by the following list of topics:
Fire Protection Upgrade Following Brown's Ferry Three Mile Island Lessons Learned 134 Systematic Evaluation Program Topics Full Term Operating License Hearings Seismic Liquifaction Hearings
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Environmental Qualification Safety Related Equipment Dedicated Safe Shutdown System Plant Size Relative to Risk & Inherent Characteristics Emergency Plans Plant Security Reanalysis of Seismicity and Engineered Safety Features Long Term Generic Items Spent Fuel Pool Storage Expansion Genoa 3 500 ft. Vertical Flue Gas Stack The plant management has been responsive and cooperative in resolving the safety issues listed above and the many other potential safety problems that were identified over the period. To date requested information and changes to the technical specifications on plant equipment modifications to satisfy NRC safety requirements have been made or schedules for such changes have been provided in a timely manner. There is a healthy,unin-hibited exchange of technically oriented safety information.
The licensee's performance in the above areas is considered to be "above average" by the NRR project manager.
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Inspection Frequency and/or Scope FUNCTIONAL AREA Increase No. Change Decrease
1.
Management Control X
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2.
Plant Operations X
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Refueling Operations & Activities X
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Maintenance X
5.
Surveillance & Preoperational Testing-X 6.
Training X
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Radiation Protection X
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Environmental Protection X
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Emergency Planning X
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Fire Protection X
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Security & Safeguards X
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Design Changes & Modifications X
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Reporting
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QA Audits X
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Committee Activities X
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Quality Control X
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Procurement X
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. F. Heishman, Chief j
Reactor Operations and Nuclear Support Branch
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