IR 05000409/1981024
| ML20054J277 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 06/22/1982 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20054J270 | List: |
| References | |
| 50-409-81-24, NUDOCS 8206280410 | |
| Download: ML20054J277 (24) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Dairyland Power Cooperative LACROSSE BOILING WATER REACTOR (LACh'n'R)
Docket No. 50-409 Report No. 50-409/81-24 l
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Assessment Period July 1, 1980, to June 30, 1981
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9206290410 920622 PDR ADOCK 05000409
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CONTENTS Page 1.
Letter to Licensee f rom SALP Board Chairman.............. 3 I.
Introduction............................................. 7 II.
Criteria................................................. 8 I I I. S umma ry o f Re s u l t s....................................... 9 IV.
Performance Analyses...................................... 10 V.
Supporting Data and Summaries............................
4 A.
Noncompliance Data.................................. 21
B.
Licensee Report Data................................ 22 C.
Licensee Activities................................. 22 D.
Inspection Activities............................... 23 E.
Investigation and Allegations....................... 23 F.
Escalated Enforcement Action........................ 23 G.
Management Conferences.............................. 23 H.
NRR Evaluation Summary.............................. 23
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March 1, 1982 Docket No. 50-409(DEPOS)
Dairyland Power Cooperative ATTN:
Mr. F. W. Linder General Manager 2615 East Avenue - South Lacrosse, WI 54601 Gentlemen:
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On October 9, 1981, we met with you to discuss the results of a Systematic Assessment of Licensee Performance (SALP) for Lacrosse Boiling Water Reactor. At that time the NRC policy was to issue the SALP reports in con-junction with a national report. Under the direction of the Commission, that policy and SALP process have been changed. There will be no national report.
Under the new SALP procedure, each licensee will have an opportunity to review and comment on the assessments made in the SALP report prior to final issuance by the Regional Administrator.
In certain cases the licensee may be requested to respond to identified weaknesses.
Any responses or comments will be attached to the SALP report and will be addressed, where appropriate, in the cover letter issuing the report.
SALP assessment criteria have also been changed. The criteria are oriented toward an absolute rather than comparative measurement of licensee performance.
The enclosed regional SALP report for Lacrosse Boiling Water Reactor has been structured to reflect the new assessment criteria terminology. There have been no substantial changes to the performance analyses in each functional area presented to you in our meeting of October 9, 1981, except for the ranking terminology of Categor 'ss 1, 2 and 3.
Part II of the report provides the definition of these categot tes.
Four significant findings related to staffing, personnel errors, committee reviews and adherence to procedures were identified in the SALP Board's evaluation of Lacrosse Boiling Water Reactor. These findings and others are summarized in Enclosure 1 to this letter. However, no response to these items is required since they have been adequately addressed in a series of management / enforcement conferences held by the Regional staff. Your response and corrective action will be pursued through our normal inspection and enforcement programs.
Comments concerning our evaluation of your facility should be submitted to this office within twenty days of the date of this letter. Otherwise, it will be assumed that you have no comments.
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Dairyland Power Cooperative
March 1, 1982 In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter, the SALP report and your comments, if any, will be placed in the NRC's Public Document Room when the SALP report is issued.
The comments requested by this letter are not subject to the clearance pro-cedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-5111.
If you have any questions concerning the SALP report for Lacrosse Boiling Water Reactor, we will be happy to discuss them with you.
Sincerely,
J. A. Hind, Director Division of Emergency Preparedness and Operational Support Chairman, Region III SALP Board Enclosure: Significant Findings
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ENCLOSURE 1 Significant Findings Identified in SALP Report for Lacrosse Boiling Water
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General Observations:
The ineffective use of licensee resources and limited staffing are common contributing factors to many of the observed problems in the various func-tional areas. These factors have resulted in the inability of management to cope with and expedite the preparation and approval of licensee staff work in response to the large number of new regulatory issues. They are also conspicuous in personnel errors, failure to follow procedures, defi-ciencies in personnel training, preplanning activities and the quality of committee reviews. On the positive side, there is evidence in the area of radiation controls and security that management can be effective in
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implementing corrective action programs in response to NRC concerns.
Functio:.a1 Area:
Plant Operations The SALP Board identified a need for management attention to minimize personnel errors, to assure that personnel adhere to written procedures, and to assure that procedures provided are properly reviewed and approved
prior to implementation.
Functional Area:
Refueling Operations The SALP Board recommends that the licensee focus attention on the planning, scheduling, and preparation for outage work.
Functional Area: Maintenance Although no major strengths or weaknesses were identified, the SALP Board recommends that the licensee include this area in their efforts to assure adherence to procedures.
Functional Area : Design Changes and Modifications The significant breakdowns in management controls and procedure adherence identified in this area were the results of contributing factors discussed in the General Observations.
Functional Area:
Radiation Control
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The SALP Board notes significant improvement in this area.
i Functional Area:
Emergency Preparedness The licensee failure to meet the new rules for emergency preparedness was the result of the contributing factors discussed in the General Observations.
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Functional Area: Security & Safeguards The SALP Board notes significant' improvement in this area.
Functional Area: Audits, Reviews, and Committee Activities The SALP Board recommends that the licensee focus attention on improving the quality of committee review activities.
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I.
INTRODUCTION The NRC has established a program for the Systematic Assessment of Licensee Performance (SALP).
The SALP is an integrated NRC Staff effort to collect available observations and data on a periodic basis and evaluate licensee performance based upon those observations and data. SALP is supplemental to the normal regulatory processes used to ensure compliance with the NRC rules and regulations. SALP is intended to be sufficiently diagnostic to provide a rational basis (1) for allocating NRC regulatory resources, and (2) for providing meaningful guidance to licensees to promote quality and safety of plant construction and operation.
A NRC SALP Board composed of managers and inspectors who are know-ledgeable of licensee activities met on October 5,1981, to review the collection of observations and data and assess the licensee performance.
This report is the SALP Board's assessment of the licensee safety performance at Lacrosse Boiling Water Reactor (LACBWR) for the one year period July 1, 1980, to June 30, 1981.
The results of the SALP Board assessments in the selected functional areas were presented to the licensee at a meeting held October 9, 1981.
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CRITERIA The licensee performance is assessed in selected functional areas depending whether the facility is in a construction, pre-operational or operating phase. Each functional area normally represents areas significant to nuclear safety and the environment, and are normal programmatic areas. Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observations.
Special areas may be added to highlight significant observation.
One or more of the following evaluation criteria were used to assess each functional area.
1.
Management involvement in assuring quality 2.
Approach to resolution of technical issues from safety standpoint 3.
Responsiveness to NRC initiatives 4.
Enforcement history 5.
Reporting and analysis of reportable events 6.
Staffing (including management)
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Training effectiveness and qualification.
Ilowever, the SALP Board is not limited to these criteria and others may have been used where appropriate.
Based upon the SALP Board assessment each functional area evaluated is classified into one of three performance categories. The definition of these performance categories is:
Category 1.
Reduced NRC attention may be appropriate.
Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction 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 such that satisfactory performance with respect to operational safety or construction is being achieved.
Category 3.
Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used such that minimally satisfactory performance with respect to operational safety or construction is being achieved.
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III. SUMMARY OF RESULTS Functional Area Assessment Category 1 Category 2 Category 3 1.
Plant Operations X
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Refueling Operations X
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Maintenance X
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Surveillance &
Inservice Testing X
5.
Personnel, Training,
& Plant Procedures X
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Fire Protection &
Housekeeping X
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Design Changes &
Modifications X
8.
Radiation Protection, Radioactive Waste Management, &
Transportalon X
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Environmental Protection X
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Security & Safeguards X
12.
QA Audits, Reviews, &
Committee Activities X
13.
Administration, QA Records & Procurement X
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Corrective Actions &
Reporting X
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IV.
PERFORMANCE ANALYSES 1.
Plant Operations a.
Analysis Inspection effort in this area involved parts of eleven inspections to evaluate compliance with technical specifi-cations and plant procedures. Seven items of noncompliance were identified during the assessment period including repetitive examples of personnel errors and failure to follow written procedures which are indicative of a lack of adequate management attention. That same conclusion was reached during the SALP 1 appraisal and was expressed to the licensee in the SALP 1 meeting on December 15, 1980.
An underlying factor contributing to these problems is the strained and somewhat ineffective use of licensee resources.
Limited staffing and the large number of new regulatory issues have resulted in the inability of management to cope with and expedite the preparation and approval of licensee staff work.
The effects of strained resources is also evident in the inability of management to provide timely responses to regulatory matters.
LACBWR continues to have a record of providing untimely responses to the NRC, not only in this area but in other areas also.
The specific items of noncompliances and associated regulatory concerns along with other identified weaknesses are listed below:
(1)
Items of Noncompliance Failure to conduct supervisory tours at intervals
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specified in procedure.
Concerns:
(a) lack of adherence to procedures, (b) inspector finding problems that should hara been found by supervisory personnel.
(Severity Leesl V)
Main steam bypass valve setpoint above technical
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specification value. Concerns:
(a) some operators not aware of technical specification requirement, (b)
no surveillance procedure, (c) initial corrective action not communicated to all operating personnel.
Improter switching resulting in two plant trips and
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challenges to safety systems. Concerns:
(a) lack of adherence to procedures, (b) failure of management to take effective corrective action.
( Two Severity Level V)
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Improper power-to-flow setpoint. Concern:
(a) All
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levels of independent review (QA and ORC) failed to detect discrepancy between technical specification and procedure during initial and periodic reviews, (b) condition existed for 7 years.
Failure to do chemical analysis following power
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changes as required by technical specification.
Concern:
(a) lack of adherence to procedures, (b)
nothing about matter in operational logs.
(2) Other Weaknesses Inadequate review of discrepancy between heat
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balance and nuclear instrumentation readings.
Concerns:
(a) improper calibration, (b) improper factory wiring, (c) improper gain setting, (d)
inadequate evaluation of calorimetric data, (e)
inadequate ORC review.
Issuance of operating memos in lieu of procedures.
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Concern: circumvention of normal procedure review process.
Issuance of procedures that are inconsistent with
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bases. Concern:
inadequate review process.
b.
Conclusion The licensee is rated Category 3 in this area. This is based on the number and nature of the items of noncompliance and the ineffectiveness of corporate and plant management-corrective actions.
c.
Board Comments Licensee and NRC attention needs to be increased in this area to focus on reduction of personnel errors, proper implementation of plant procedures, and increased licensee j
staff resources.
Increased NRC attention was initiated July 28, 1981. An enforcement conference was held on that date and a manage-ment meeting was held September 25, 1981, to discuss items-of noncompliance in thia and other areas.
(See Functional
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l Area IV. 5, "Personne'., Training, and Plant Procedures" for i
additional details.)
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2.
Refueling Operations a.
Analysis Inspection effort in this area indicated that refueling and startup testing were performed in a safe manner but, in some cases, only after intercession by the resident inspectors.
The refueling was started without detailed planning and detailed plans were developed only after being requested by the inspectors. The lack of preplanning was evident in an item of noncompliance which resulted from the licensee's failure to review refueling procedures prior to use.
Addi-tionally, the inspectors noted during a plant tour that the licensee was performing pre-head removal operations without establishing proper reactor vessel water level as required by the refueling procedures; plant management was notified and appropriate action was taken. Although of lesser importance, another example of poor preplanning was the fact that the newly revised fuel element storage well con-figuration was not incorporated into refueling procedures, nor had the necessary training been conducted in the use of the new multi-tiered storage racks.
The licensee was also cited for failure to follow procedures for monitoring the source range indication during fuel movement.
The inspectors did not identify any items of noncompliance during startup testing after the 1980 refueling outage, b.
Conclusion The licensee is rated Category 2 in this area.
c.
Board Comments The licensee should evaluate its preplanning policy and establish a more effective planning program.
3.
Maintenance a.
Analysis A programmatic inspection of maintenance activities was not performed by NRC inspectors; however, station maintenance activities were routinely observed and reviewed by the resident inspectors to ascertain that they were accomplished i
in accordance with approved procedures, regulatory guides, industry codes and standards, and technical specifications.
No significant strengths or weaknesses were identified in this area.
Two items of noncompliance were identified. One was the result of a failure to obtain procedure change prior to implementing a
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wiring modifications. The other was the result of a failure to establish a fire watch prior to drilling through a fire barrier.
Rather than being unique to the maintenance program, the non-compliances are indicative of a general problem of the _1 ability of management to assure adherence to procedures.
b.
Conclusion The licensee is rated Category 2 in this area.
c.
Board Comments Licensee management needs to focus its attention on ensuring adherence to procedures.
4.
Surveillance & Inservice Testing a.
Analysis There were several inspections performed during this appraisal period of surveillance and inservice testing activities. One item of noncompliance was identified related to calibration data sheets; however, no significant problems were identified in this area. The surveillance program lacks the detail required by industry standards and technical specifications which are newer than those applicable to LACBWR; however, the licensee's program appears to be effective and efficient.
b.
Conclusion The licensee is rated Category 2 in this area.
c.
Board Comments None.
5.
Personnel, Training, & Plant Procedures a.
Analysis Inspections in this area were conducted by the resident inspectors who witnessed training and requalification sessions and reviewed plant operating procedures, special orders, and administrative procedures as they were issued.
No items of noncompliance were identified.
The licensee modified its training program to meet the requirements of NUREG-0737 and redirected its limited train-ing staff to meet the new training objective of NUREG-0737.
Fourteen Reactor Operator and Senior Reactor Operator licensing examinations were administered by NRC Operator Licensing Examiners with nine of the candidates passing their examinations. The pass / failure rate indicates the licensee
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is maintaining a training program which is effective in j
maintaining the necessary compliment of licensed operators.
As a result of a resident inspector concern that LACBWR did
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not have a statement of policy for nonlicensed operators a
qualifications prior to being assigned to a watch station, the licensee revised administrative control procedures to include a requirement that a candidate for a nonlicensed operator position complete a training program and possess a a
valid qualification card for the watch station to which the operator is to be assigned.
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Upgrading of Emergency, Security, Contingency and Safeguards
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Plans in addition to the unusual effort related to SEP and
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THI highlighted the NRR-LACBWR management involvement during
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the appraisal period. In all of these areas, the licensee
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has been cooperative and open in assessing the safety aspects,
'n expressing its views and findings, and in meeting the intent of the various NRC safety requirements.
The plant staff is small and has been identified as the primary
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cause for problems identified in several functional areas. The limited staff size was a topic of discussion in a September 25, 1981, management meeting between Region III and the licensee.
The licensee committed to review the plant staffing problem and add additional personnel if possible.
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Conclusion
l The licensee is rated Category 2 in this area.
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Board Comments t
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Region III should continue the routine inspection effort in
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this area with particular attention to the licensee commitment I
to increase and maintain an effective staff.
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Fire Protection & Housekeeping
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Analysis
l A programmatic inspection of fire protection activities was not performed by NRC inspectors; however, the condition of i
housekeeping, fire barriers, fire protection equipment, potential fire hazards, and critical fire protection areas
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were observed during routine plant-tours by the resident j
inspectors. No significant strengths or weaknesses were
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identified in the area.
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Conclusion The licensee is rated Category 2 in this area.
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Board Comments
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None.
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Design Changes & Modifications j
a.
Analysis I
The nature of the four items of noncompliance ~1dentified in
this area indicate a weakness in management controls. This
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weakness is highlighted by the inability of plant management.
to insure procedure adherence by plant personnel. Additionally, because of the limited staff size the licensee has to rely on
outside consultants to complete many of the analyses necessary
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for the accomplishment of facility modifications and this
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reliance has resulted in a delay of many proposed facility
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modifications.
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i Significant breakdowns in the past and present controls of i
design changes is evident by one proposed Severity Level III item of noncompliance and three infractions. Each of the items of noncompliance dealt with unapproved changes to the
facility and two of them resulted in degradation of safety systems used to mitigate the consequences of an accident.
(The proposed Severity Level III item of noncompliance -
unauthorized modification to a containment building pressure
sensing line - was a repetitive example of unapproved changes -
to.the facility and was the topic of an Enforcement Conference with the licensee on July 28, 1981.) The licensee corrective actions in response to the Severity Level III item of noncom-pliance will ensure that the licensee has developed a positive course of. action to avoid further noncompliance.
b.
Conclusion The. licensee is rated Category 3 in this area. This is based on the number and nature of the items of noncompliance and
breakdowns in management controls.
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Board Comments
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l Region III should assure that the licensee corrective actions
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in response to the Severity Level III item of noncompliance
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will ensure that the licensee has developed a positive course of action to avoid further noncompliance.
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Radiation Protection, Radioactive Waste Management, & Transportation a.
Analysis
Four inspections (Health Physics Appraisal, refueling radia-tion protection, followup to the Health Physics Appraisal, and confirmatory measurements) were performed during the
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evaluation period by region-based inspectors.
(The results of the Health Physics Appraisal, including three items of noncompliance, were reflected in SALP 1 and therefore are not included in this SALP report.) The resident inspectors also spent about 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> inspecting this area. Five items of noncompliance were identified in the areas of surveying, adherence to procedures, an unmonitored airborne release, and effluent report submittal. The items of noncompliance and other weaknesses noted indicate that the licensee's performance in certain radiation protection areas needs strengthening. Management action is required in the areas of procedural compliance, personnel training (including HP Technicians), and overall sensitivity of plant personnel to good radiological practices.
Several problems, including contamination control, procedural adherence, and inadequate surveys, recurred during this period. A continuing area of weakness exists in the licensee's ability to accurately quantify Sr-90 (liquids) and I-131 (charcoal absorbers); the licensee has committed to evaluate both matters and implement appropriate corrective measures.
The licensee has made significant improvements in correcting the seven significant programmatic weaknesses identified during the Health Physics Appraisali These improvements included: hiring a professional HP to manage the HP program; promoting a HP technician into the position of Health and Safety Supervisor; implementing a formal training / retraining program; implementing a more formal ALARA program; encouraging HP technicians to be more observant, inquisitive, and aware of anomalous situations; installing a new stack particulate, iodine, and noble gas monitoring system; and implementing a radiation occurrence report system to strengthen procedural adherence.
Although LACBWR did not have any personal overexposures and had a low total exposure (manrems), the power normalized exposure (manrems/MWe) was significantly higher than average; the small plant capacity is the likely cause. The power normalized liquid and gaseous radioactive releases (Ci/MWe)
were significantly higher than average, but were well within technical specification limits. One unplanned release occurred, but neither the release quantity nor concentrations exceeded regulatory limits.
The licensee's radiation protection, radioactive effluents, and radwaste transportation programs have improved over the SALP 1 evaluation period. This improvement was particularly evident in plant management's attitude toward the health physics program.
b.
Conclusion The licensee is rated Category 2 in this area.
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Board Comments An augmented (quarterly) inspection program in this area is being conducted for CY81. This was a result of the below average ranking given the licensee in SALP 1.
The inspection frequency for CY82 should be reduced to one additional in-spection over the normal inspection program.
9.
Environmental Protection a.
Analysis The annual inspection of this area indicated the licensee has implemented an adequate environmental protection program with no apparent strengths or weaknesses. The program is conducted by plant personnel and the data reviewed by the Corporate Environmental Department. The resident inspectors, on a random sample basis, verify the installation and operability of the air, water and radiation sample monitoring stations and observe the licensee sampling techniques for milk, vegetation and fish.
b.
Conclusion The licensee is rated Category 2 in this area.
c.
Board Comments None.
10.
Analysis The licensee performance in this area was characterized by a chronic lateness in meeting the requirements of the emergency preparedness rule. There was a failure to meet required deadlines and a failure to communicate to the NRC when those deadlines could not be met.
TWo Severity Level IV items of noncompliance and a IAL were issued for failure to meet regulatory requirements. The first item of noncompliance resulted when the licensee submitted an emergency preparedness plan three months late. The second item of noncompliance resulted when the licensee implemented the plan one month later than required and only after the IAL was issued to secure a commitment.
The licensee also failed to install an early warning system by July 1, 1981, as required and failed to notify the NRC that the requirement was not going to be met.
A Severity Level IV item of noncompliance was issued subsequent to the SALP 2 period as a result of that problem.
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b.
Conclusion The licensee is rated Category 3 in this area.
c.
Board Comments The licensee should intensify its actions to meet all due dates.
The licensee progress should be monitored to assure compliance and escalated action should be considered if dates are not met.
11.
Security & Safeguards a.
Analysis Inspections performed during the evaluation period identified eleven items of noncompliance. Eight of the items of noncom-pliance were identified during one inspection in July 1980 and were discussed in SALP 1.
As a result of that inspection, a management meeting with 1.4:ensee representatives was held on
July 28, 1980. The appar<nt lack of management attention to the implementation of sectrity plan commitments and require-ments was discussed, and the licensee was asked to provide schedules for preoperational testing and implementation of security systems. An increased inspection frequency was determined to be appropriate. A followup inspection in August 1980 revealed that scheduled testing and implementation dates were being met.
Subsequent inspections in October 1980 and April 1981 revealed that the licensee was effectively imple-menting security requirements and had reanalyzed its entire security program. As a result, a revised security plan was forwarded to the NRC in April 1981.
Only one item of noncompliance remains open and the licensee's progress in resolving the issue has been satisfactory. A re-maining problem area consists of improving the reliability of the perimeter intrusion alarm system. Replacement of some microwave zones with E-Field units and an ongoing analysis of false / nuisance alarms should enable the licensee to overcome this area of concern.
The licensee currently has a strong security management program which is supported by the corporate office. Problems l
encountered are being effectively confronted and resolved.
The licensee's attitude toward security has improved signifi-cantly since July 1980 and the licensee is responsive to NRC requests and suggestions. This represents a significant improvement since SALP 1.
The' resident inspectors have also noted a significant improvement and an increased sensitivity to the regulatory requirements in the security area.
b.
Conclusion The licensee is rated Category 2 in this area.
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Board Comments The increased inspection frequency should be reduced to the normal inspection frequency in view of the improvements and status of the security program.
12.
Audits, Reviews, & Committee Activities a.
Analysis Inspection findings in other functional areas suggest improve-ments are needed to improve the effectiveness of the licensee's review process. An example of shortcomings in this area is that several defective procedures were developed, approved and utilized which resulted in two of the four power range instru-ments being set improperly for several years and both of the reactor power to core flow protective channels being set greater than technical specification limits since 1973.
b.
Conclusion The licensee is rated Category 2 in this area.
c.
Board Comments The licensee should focus attention on improving the quality of committee review activities. A programmatic inspection should be performed as soon as practicable.
13.
Administration, QA Records, & Procurement a.
Analysis Inspections in this area identified four items of noncompliance of Severity Level V and VI.
Although these items of noncom-pliance were not of major concern, they were indicative of a general lack of quality assurance program development. This lack of program development was due, in part, to an in-adequately staffed Quality Assurance department where many functions and responsibilities are spread among too few personnel.
Subsequent to this SALP period a new Quality Assurance t
Program description was approved by NRR. The new program is more extensive than the previous one and will require considerable licensee attention to assure that adequate implementing procedures are developed.
b.
Conclusion The licensee is rated Category 2 in this area.
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Board Comments The licensee should evaluate the staffing of the QA department and augment it where necessary.
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Corrective Actions & Reporting a.
Analysis Inspections in this area did not identify any significant strengths or weaknesses. One item of noncompliance was identified concerning the licenscee's failure to make a one hour Red Phone notification. The licensee increased its awareness of the reporting requirements and has continued to keep the NRC informed of operational problems.
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b.
Conclusion The licensee is rated Category 2 in this area.
c.
Board Comments None.
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V.
SUPPORTING DATA AND SUMMARIES A.
Noncompliance Data Facility Name:
LACBWR Docket No. 50-409 Inspections No. 80-05 through 80-18 81-01 through 81-12 Noncompliances and Deviations Severity Levels Categories Functional Areas I
II III IV V VI Viol.
Infr.
Def.
Dev.
1. Plant Operations
4 2. Refueling Operations
3. Maintenance
1 4. Surveillance &
Inservice Testing
5. Personnel, Training,
& Plant Procedures 6. Fire Protection &
Housekeeping 7. Design Changes &
Modifications
3 8. Radiation Protection, Radioactive Waste Management, &
Transportation
2 9. Environmental Protection 10. Emergency Preparedness
11. Security &
Safeguards 2 1
2 12. Audits, Reviews, &
Committee Activities 13. Administration, QA Records, & Procurement 2 2 14. Corrective Actions &
Reporting
Total
7 16 5
3
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B.
Licensee Report Data 1.
Licensee Event Reports LERs No. 80-05 through No. 81-07 Licensee Approximate Cause Code Assignments:
Number LERs Cause Type SALP 1 SALP 2 Personnel Error
7 Design, Mfg., Constr/ Install.
1 External
1 Defective Procedures
1
.
Component Failure
6 Other
4 Total Number
20 LER Evaluation Evaluation for this SALP period indicates some problem areas.
Older technical specifications and reporting requirements allow the number of LERs to remain low when compared with other BWRs; however, the number and significance of LERs during SALP 2 increased over SALP 1.
Two of the most significant reports indicated a lack of adequate control of plant modifications, two involved electrical switching errors that resulted in dropping offsite power and supplying vital boards with emergency diesel generator power (once during normal plant startup and once in plant Conditon 3), and one involved an excessive plant cooldown rate which is a repeat of a similar event in the previous year. The remaining LERs were either of lesser significance or beyond the licensee's control.
The increase in the number of personnel errors (7 during SALP 2 as compared to 3 during SALP 1) could indicate a trend and will be monitored by inspectors. An evaluation of the LERs does not indicate any abnormal potential for common mode failures.
2.
Part 21 Reports None.
C.
Licensee Activities The facility completed a nine week refueling outage. Prior to the outage the licensee completed the double tiered fuel element storage well modification which was the first of its kind.
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D.
Inspection Activities The Health Physics Appraisal was accomplished. See Section IV.8 for additional details.
E.
Investigations & Allegations As a result of the July 1980 security inspection an investiga-tion was conducted by Region III in August 1980 to determine if the licensee had intentionally attempted to mislead the NRC in reference to the operability of installed security systems. The investigation concluded that there was no intention to mislead the NRC.
F.
Escalated Enforcement Action
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1.
Civil Penalties A proposed civil penalty and associated Notice of Violation related to an unauthorized modification of a containment pressure sensing line which degraded two plant cooling systems was issued to the licensee subsequent to this appraisal period on Cctober 22, 1981. That action was based on inspection findings during this appraisal period.
2.
Orders None.
3.
Immediate Action Letters a.
June 3, 1981, concerning contamination levels on the NAC-ID Spent Fuel Shipping Cask.
b.
June 5, 1981, concerning contamination levels on the NAC-1D Spent Fuel Shipping Cask.
c.
April 15, 1981, concerning failure to implement an Emergency Plan as required by regulatory requirements.
G.
Management Conferences 1.
July 28, 1980, concerning NRC findings in the area of security and potential escalated enforcement action.
2.
December 15, 1980, concerning activities authorized by NRC License DPR-45 (SALP 1), Inspection Report No. 50-409/80-1 H.
NRR Evaluation Summary The review and implementation of the numerous regulatory require-ments resulting from the Three Mile Island accident, the requirements of the SEP program, and Emergency Preparedness placed a heavy burden
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on the licensee in the area of engineering, management, and plant supervision. The licensee's response was professional, but the limited size of the plant staff contributed significantly to untimely responses. The technical competence of the individual plant members is generally good. Technical meetings with the licensee were informctive and productive and indicated good pre-paration. The licensee made an acceptable effort to resolve long standing open issues.
Because of the licensee's organization structure, NRR interacts directly with the Plant Superintendent instead of the corporate office. Plant performance data was provided readily and candidly by the licensee. NRR has worked closely with the licensee to identify problems and stay involved as solutions evolve. However, officient communication arrangement between technical personnel was close to the breakdown threshold at times when the need for documented responses to NRC requests exceeded the limited LACBWR resources.
The licensee's working knowledge of regulations, guides, and generic issues is good, considering that many of the standards and guides and some of the regulations such as Appendix K to 10 CFR 50 do not apply to this plant because of its unique design.
I.
Other 1.
Attitude of Station Personnel Since SALP 1 licensee attitude toward the regulatory process appears to have transposed from negative to passive acceptance.
2.
Communication Licensee efforts initiated since SALP 1 appear to have improved horizontal communications, e.g., craft-to-craft, department-to-department.
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