IR 05000409/1982013
| ML20028C020 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 01/03/1983 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20028C019 | List: |
| References | |
| 50-409-82-13, NUDOCS 8301050261 | |
| Download: ML20028C020 (26) | |
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SALP 3
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'U.S. NUCLEAR REGULATORY COMMISSION
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RECION III l
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i SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
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Dairyland Power Cooperative l
LA CROSSE BOILING WATER REACTOR (LACBWR)
s Docket No. 50-409
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Report No. 50-409/82-13 i
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i Assessment Period July 1, 1981 through June 30, 1982 i
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8301050261 830103 PDR ADOCK 05000409 G
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CONTENTS Page Letter to Licensee from SALP Board Chairman.................... iii I.
Introduction..............................................
II.
Criteria..
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I I I. S umm a ry o f R e s u l t s........................................
IV.
Performance Analyses
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V.
Supporting Data and Summaries
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October 15, 1982 Docket No. 50-409 Dairyland Power Cooperative ATTN:
Mr. F. W. Linder j
General Manager 2615 East Avenue - South La Crosse, WI 54601
Gentlemen:
This is to confirm the conversation between your Mr. J. Taylor and Mr. R. Walker of the Region III staff scheduling November 5, 1982, at 9:30 a.m. as the date and time to discuss the Systematic Assessment of Licensee Performance (SALP) for the La Crosse Boiling Water Reactor.
Following the SALP meeting, we will discuss the status of your Regulatory Improvement Program. This meeting is to be held at Dairyland Power
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Cooperative Headquarters in La Crosse, Wisconsin.
Mr. James G. Keppler, Regional Administrator, and members of the NRC staff will present the observations and findings of the SALF Board. Since this meeting is intended to be a forum for the mutual understanding of the i
issues and findings, you are encouraged to have appropriate representation at the meeting.
As a minimum, we would ruggest that you and Messrs. J. Taylor,
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l J. Parkyn and managers for the various functional areas where problems have been identified attend this meeting.
Enclosure 1 to this letter summarizes the more significant findings in the
SALP Board's evaluation of the La Crosse Boiling Water Reactor for the period of July 1, 1981 through June 30, 1982.
Enclosure 2 to this letter is the SALP 3 Report which documents the findings of the SALP Board and is for your review prior to the meeting.
Subsequent to the meeting the SALP Report will be issued by the Regional Administrator.
If you desire to make comments concerning our evaluation of your facility, they should be submitted to this office within twenty days after the meeting date; ottarwise, it will be assumed that you have no comments.
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.
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Dairyland Power Cooperative
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If ycu have any questions concerning the SALP Report we will be happy to discuss them with you.
Sincerely,
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J. A. Hind, Chairman Region III SALP Board
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Director, Division of Emergency Preparedness j
and Operational Support Enclosures:
1.
Summary of Significant Findings l
2.
Preliminary LACBWR SALP 3 Report (5 copies)
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cc w/encls:
Resident Inspector, RIII
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ENCLOSURE 1 Summary of Significant Findings General Observation While there has been a noted improvement in the licensee's regulatory per-formance, those improvements have not yet resulted in significant changes in the performance ratings of the individual functional areas from the previous SALP. A notable change was the reduction in the total number of noncompliances (11 vs. 42).
There has also been a noticeable improvement in managemer.t attention to operational problems. Notwithstanding these improvements, limited and streined resources are still common, contributing to licensee management's inability to satisfactorily cope with many problems and issues.
Because of limited staffing, various managers and staff members are required to perform dual functions. This was particularly notable in the areas of Plant Operations, Licensing Activities, Radiation Protection and Emergency Preparedness. These dual responsibilities contribute to a lack of time to devote the required attention to the jobs and at the same time be responsive to NRC issues and concerns.
As a result, many problems are not dealt with in a timely manner.
Plant Operations a
Continued management attention is still warranted in this area. The licensee commitment to the development and implementation of a Regulatory Improvement Program is a positive indication that improved performance is a high priority goal of the licensee.
Radiation Control There was continued improvement in this area; however, the licensee needs to focus attention on excessive work load (dual responsibility) and adherence to procedures.
Maintenance An apparent resolution of design change problems and a solid maintenance
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program contributed to the high rating in this area.
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Emergency Preparedness Performance in this area is marginally acceptable warranting increased corporate and plant attention. Time anc staffing resources devoted are deficient as evidenced by the continued failure to pursue and solve many Emergency Preparedness problems.
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Licensing Activities While overall performance was satisfactory, the licensee needs to focus attention on the limited staff resources to improve responsiveness to licensing issues. The dual licensing and operating responsibilities of managers and staff has affected the licensee's ability to cope with problems in both areas in a timely mannet.
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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.
SALP is supplemental to normal regulatory processes used to insure compliance to the rules and regulations.
SALP is intended primarily from a historical point to be sufficiently diagnostic to provide a ratienal basis for allocating future NRC rescurces 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 the staff members list,ed below, met on September 14, 1982, to review the collection of performance observa-tions and data to assess the licensee performance in accordance with the guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation
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criteria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensee safety performance at La Crosse Boiling Water Reactor (LACB'1R) for the one year period July 1, 1981 through June 30, 1982.
The results of the SALP Board assessments in the selected functional areas were presented to the licensee at a meeting held on October 19, 1982.
SALP Board for La Crosse Boiling Water Reactor:
J. A. Hind, SALP Board Chairman, Director, DEPOS R. L. Spessard, Director, DPRP C. E. Norelius, Director, DETP J. F. Streeter, Chief, Projects Branch 2 C. J. Paperiello, Chief, EPPS Branch L. R. Greger, Chief, Facilities Radiction Protection Section
R. D. Walker, Chief, Section 2C M. C. Schuaacher, Chief, Independent Measurements and Environmental Protection Section T. N. Tambling, Chief, Program Support Section M. W. Branch, Senior Resident Inspector R. F. Dudley, Project Manager, NRR M. J. Jordan, Acting Project Inspector
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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 'unctional 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 initiative.
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Enforcement history 5.
Reporting and analysis of reportable events 6.
Staffing (including management)
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Training effectiveness and qualification.
However, the SALP Board is not limited to these criteria and others may have been used where appropriate.
Based upon the SALP Board assessment each functior.a1 area evaluated is classified into one of three performance categories. The defini-tion of these performance categories is:
Category 1.
Reduced NRC attention may be appropriate. Licensee man-agement 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 A.
Functional Area Assessment Category 1 Category 2 Category 3 1.
Plant Operations X
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Radiological Controls X
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Maintenance X
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Surveillance and X
Inservice Testing 5.
Fire Protection X
and Housekeeping 6.
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Security and Safeguards X
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Refueling Activities X
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Licensing Activities X
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Confirmatory Measurements X
and Environmental Monitoring
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IV.
PERFORMANCE ANALYSES 1.
Plant Operations a.
Analysis During the assessment period, portions of twelve inspections were performed by the Resident Inspector to evaluate compli-ance with Technical Specifications and plant procedures.
In addition, four management meetings were held with the licensee including the SALP 2 assessment to address licensee regulatory performance and methods to improve it.
Within the scope of these management meetings the licensee commenced development of a Regulatory Improvement Program (See Section V.H for a summary of the licensee's first draft of this program). Also, as recommended by the SALP 2 Board, the Resident Inspector focused attention on the areas of personnel errors, proper implementation of plant procedures, effective use of licensee staff resources, and the effectiveness of corporate and plant management to initiate a corrective action program.
The inspection and the regulatory efforts indicated a possible turnaround in the licensee's regulatory performance as evidenced by some positive observations and the licensee's commitment to a Regulatory Improvement Program. However, there are basic weaknesses that still need to be addressed by the licensee in their Regulatory Improvement Program to ensure continued improvement in this area.
The following is a summary of observations and findings in
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this area:
(1)
Improvements Since SALP 2 (a) There has been a reduction in the number of personnel errors from seven in the SALP 2 period to five* in the SALP 3 period.
(b) There has been a noticeable increase in management l
attention to the operational problems that have been
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plaguing LACBWR. Heightened awareness and conserva-tive approaches to problem resolutions were evident I
in the immediate actions taken for Operational Occurrences 81-08 (Main Steam Bypass Valve Controller Not Responding Properly to Pressure Spikes) and 81-10 (Failure of Mechanical Interlock on the Main Airlock).
- 0ne LER, listed in Section V.B., was categorized as component failure by the licensee but was a combination of component failure and personnel error.
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(2) Weaknesses That Need Additional Attention (a) SALP 2 Findings Not Resolved Failure to Follow Written Procedures
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Although the number of noncompliances has been reduced from seven to three, the nature of the noncompliances indicate that the licensee corrective actions have not been completely effective.
l Strained and Ineffective Use of Licensee Resources
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The issues of limited staffing and the large number of current regulatory demands on licensee resources have not been resolved.
There has been a reduction in the amount of new regulatory demand imposed on the licensee resources. This reduction is evidenced by the limited number of NRC Bulletins and Circulars
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issued. As discussed in Section IV.9 of this report the licensee's nuclear organization is
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unique in that licensing submittals and analysis are prepared by the operating staff.
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The tradeoffs between operational and licensing
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priorities has resulted in infrequent tours by
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department managers and untimely responses to NRC issues. The licensee's nuclear organization is not only unique in the area of licensing, but also in the corporate organizational structure.
Perheps the creation of the new corporate posi-tion of Director of Special Nuclear Projects and the licensee's commitment to address any reorganization that may be necessary to implement their Regulatory Improvement Program will resolve the issue of strained and ineffective use of licensee resources.
I (b) Items of Noncompliance Severity Level IV (IR/81-23). Unintentional cooldown of the No. IB Forced Circulation Loop to below Technical Specification limits for loop Reference Nil-Ductility Transition Temperature (RTN T O).
Concerns:
(1) lack of adherence to procedure, (2) failure to properly mark recorder charts, (3) plant management failure to ensure procedure adherence.
Severity Level IV (IR/81-23). The March 16, 1981,
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event of operation on the Main Steam Bypass Valve while at power. This event occurred during the SALP 2 assessment period but is being listed here for
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two purposes.
It is being listed for record purposes because the inapection report that conveyed the non-compliance to the licensee was issued during the SALP 3 assessment period. The second reason is that the licensee took approximately nine months to completely resolve the issue and this untimely resolution is a concern to the NRC.
Severity Level IV (IR/81-23).
The improper issuance of an Operation Memorandum to change the procedures for the operation of the Main Steam Bypass Valve. The reason for listing this item is the same as the above item.
Severity Level IV (IR/82-07). Failure to conduct
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the required followup primary coolant sampling after determining alpha activity exceeded Technical Specifi-cation limits. Concerns:
(1) failure of the Shift Supervisor to recognize the violation, (2) changing the plant status from Mode 4 (Cold Shutdown) to Mode 2 (Startup) with alpha activity greater than that allowed by Technical Specifications, (3) failure i
of health physics personnel to alert the operations personnel of the fact that alpha activity exceeded Technical Specification limits.
Severity Level IV (IR/82-07).
Both High Pressure and Low Pressure Core Spray systems were simultaneously rendered inoperable. Concerns:
(1) failure of Shift Supervisor to recognize violation of Technical Specifi-cation, (2) failure of licensed operators to recognize violation of Technical Specification, (3) failure of the plant's administrative controls, i.e., Maintenance Request System, to detect and prevent violations.
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Conclusion The licensee is rated Category 3 in this area. The untimely resolution of noncompliances and the initial lack of corporate and plant management attention to operating problems and regulatory compliance were the basis for deternining the rating.
On a positive note, the recent personnel changes, the creation of a new corporate nuclear position, and the licensee's commitment to develop and implement a Regulatory Improvement Program are viewed as indicators of the licensee's commitment to reduce errors and ensure the safe operation of LACBWR. Some benefits of these efforts are being seen in the areas of reduced person-nel errors and increased management attention to operational problems.
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Board Recomendations The licensee should continue with the detailed development, approval and implementation of the Regulatory Improvement Program and the NRC should continue with the normc1 inspection program with attention focused on the timely and effective implementation of the licensee's Regulatory improvement Program.
2.
Radiological Controls a.
Analysis (1) Radiation Protection and Waste Management Three inspections of Health Physics Appraisal (HPA)
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followup items, TMI Action Plan items, and refueling radiation protection were conducted during the assessment period by regional specialists. This inspection frequency exceeded the " normal" frequency, as recommended in the previous SALP. The Resident Inspector also conducted routine inspections in this area. The following two items of noncompliance were identified:
(a) Severity Level V - failure to adhere to radiation protection procedures (IR/81-19).
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(b) Severity Level V - failure to follow special work permit instructions (IR/81-14).
These items were promptly and effectively corrected and were not indicative of a programmatic weakness. An addi-tional problem concerning the changing and inplace testing of the HEPA and charcoal filters for the offgas system was also identified; the licensee proposed acceptable corrective actions (IR/81-19),
l Although the licensee continued to improve the Health Physics Program during this SALP period, some weaknesses continue. These include inadequate health physics technician staffing, excessive workload for the Radiation Protection Engineer, and adherence to procedures. The licensee appears to be making progress in these areas.
(See Section IV.6 for further comments concerning health physics staffing.)
The licensee had low total exposure (personrems) but l
power normalized exposure (personrems per MWe) were higher than average for boiling water reactors. The
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liquid and gaseous radioactive releases normalized for power (Ci/MWe) are higher than average, but well within Technical Specification limits. Solid radioactive waste volume and activity were low. No problems were identified with radioactive material shipments. No unplanned releases occurred.
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Conclusion The licensee is rated Category 2 in this area. Although some weaknesses were observed, the licensee continues to improve in this area.
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Board Recommendations The board recommends return to the normal inspection frequency in this area.
3.
Maintenance a.
Analysis Portions of twelve monthly inspections were performed in this area by the Resident Inspector. These inspections were focused toward verification that maintenance was being accomplished in a timely and deliberate manner and that items with the highest importance to safety were receiving the highest priorities.
There were no items of noncompliance identified and the licensee has a good record of not c11owing a large backlog of maintenance items. There was one observed weakness in that after all the emphasis on procedure adherence, the licensee's Administrative Control Procedure ACP 6.2 allows non-supervisory personnel to determine the need for a copy of the maintenance procedure at the job site.
Also, there is very little independent verification of maintenance repair activity; however, there is a QC review of all facility modifications.
LACBWR has been described by many people as one of the
cleanest and best maintained plants in the country. Even during the current long and demanding refueling outage, the licensee continues to maintain a high degree of plant cleanliness.
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Conclusion
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The licensee is rated Category 1 in this area. This rating is based on the licensee's ability to aggressively initiate timely and effective corrective actions in the area of l
Facility Modifications which was rated as Category 3 during the SALP 2 assessment, and the licensee's effective utilization of resources in the area of plant maintenance.
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Board Recommendations Although a Category 1 rating normally calls for a reduction in the inspection program, the Board recommends that when the normal three year inspection program is performed in other areas that this area be included.
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Surveillance and Inservice Testing a.
Analysis Portions of twelve monthly inspections were performed in the area of surveillance testing by the Resident Inspector. The inspections verified that the licensee surveillance testing program was being accomplished in accordance with their written procedures and that proper precautions were being observed and the systems were being removed and restored to service properly.
There was no detailed inspection performed in the area of In-service Testing, however, the Resident Inspector did witness some of the volumetric testing of the reactor vessel flange and verified it was being performed in accordance with written pro-cedure. There is little independent review of the surveillance program by the QC staff; however, the program is audited by QA personnel.
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Conclusion The licensee is rated Category 2 in this area. While no signi-ficanc strengths or weaknesses were identified, the licensee's program was effective in meeting regulatory requirements as indicated by the good compliance record in this area.
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Board Recommendations None.
5.
Fire Protection and Housekeeping c.
Analysis A programmatic inspection of fire protection activities was not performed by NRC inspectors; however, the condition of house-keeping, fire barriers, fire protection equipment, potential fire hazards, and critical fire protection areas were observed during routine plant tours by the Resident Inspector. The attention given to and the overall appearance of the facility reflects a positive attitude by both management and staff towards house--
keeping.
In the area of fire protection, the licensee has been effective in maintainir:g the existing level of fire protection through satisfactory training, fire drills, maintenance of equipment and control of potential fire hazards. However, the licensee was not responsive to NRR in their plans for upgrading fire protection (see Section IV.10.a).
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Conclusion The licensee is rated Category 2 in this area. This rating is based upon the apparent satisfactory performance in main-taining the existing level of fire protection. The licensee's attitude toward housekeeping is recognized as a significant strength.
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Board Recommendations i
The Board recommends that a programmatic fire protection inspection be accomplished.
6.
Analysis Emergency Preparedness activities at the La Crosse Boiling Water Reactor were observed during the licensee's emergency preparedness exercises and during our Emergency Preparedness Implementation Appraisal (EPIA). During the EPIA, NRC identified: three deficiencies which were transmitted to the licensee by Immediate Action Letter; and twenty-nine deficiencies and one item of non-compliance (IR/81-13) regarding lateness of implementation of the emergency plan and procedures which were transmitted to the licensee in the EPIA report. During the emergency preparedness exercise, NRC identified three problem areas regarding communica-tions, training of health physics technicians and hospital emergency room personnel, and staffing of the Emergency Operations Facility (EOF). A Confirmation of Action Letter was transmitted to the licensee regarding these deficiencies identified during the exercise inspection and required the licensee to conduct an additional exercise sufficient in scope to demonstrate that the EOF could be used to perform required communications, accurate and timely offsite dose assessments and maintain the appropriate records with respect to those activities. A subsequent exercise was conducted in which the licensee performed satisfactorily.
La Crosse was the only facility in Region III which performed so poorly during their exercise that another exercise had to be performed in order to demonstrate adequate performance.
The follow-up inspection of the EPIA resulted in the finding that 20 of the 32 significant deficiencies identified during the EPIA had been satisfactorily completed. Significant findings included two noncompliances (IR/82-06)2 and a Confirmation of Action Letter covering minimum shift staffing and augmentation.
One of the noncompliances dealt with shift augmentation and the licensee's ability to meet the time constraints provided in NUREG-0654, Table B-1.
The Itcensee had not demonstrated that shift augmentation could be performed in an effective and timely manner. The other noncompliance dealt with meteorological pro-cedures for obtaining accurate primary and backup information and for calibration, operability checks, and maintenance of meteorological equipment.
- Escalated enforcement action is under consideration.
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m The staf f and management of Dairyland Power Cooperative have not effectively pursued and solved their problems with respect to emergency preparedness. They continue to react to NRC findings rather than aggressively developing their emergency preparedness program in accordance with NRC rules, regulations and guidance. As stated in the previous SALP Report, their performance is characterized by chronic lateness in meeting the requirements of the emergency preparedness rule. They continue to fail to meet the required deadlines and fail to communicate to the NRC when those deadlines cannot be met.
These problems have been caused due to insufficient time and I
attention devoted to emergency preparedness. The person re-sponsible for emergency preparedness is assigned on a part-time basis. The staff believes a full-time Emergency Planning Coordinator is needed to solve these problems.
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Conclusion
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The licensee is again rated Category 3 in this area.
c.
Board Recommendations
An enforcement conference was held on July 23, 1982, and additional escalated enforcement is being considered. The
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licensee must develop a management control system to assure effective and timely compliance with respect to the require-ments for emergency preparedness.
Increased licensee management attention both at corporate and plant levels of
management must be given in the area of emergency prepared-ness.
Similar recommendations were made last year. NRC
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Region III should closely monitor DPC performance to assure l
compliance, and emergency preparedness should be a major topic for discussion during the Regulatory Improvement Program meeting.
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Security and Safeguards a.
Analysis One security inspection was conducted during August 1981. The Resident Inspector also made periodic tours of protected and l
vital areas.
The security inspectors addressed security program audit, vital area physical barriers, lighting, access control (search),
assessment aids, communications, records and reports, and followup on previous items of noncompliance. Although no items of noncompliance were noted, the need to monitor maintenance support for security equipment was addressed.
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One item of noncompliance from a previous inspection pertain-ing to the perimeter alarm system remains open. On August 31,
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1981, the licensee stated that the commitments made concerning
this item had been completed.
The Resident Inspector identified one item of noncompliance pertaining to failure to adequately control access to a vital area (Severity Level IV).
The licensee's attitude toward security has continued to improve and the licensee is responsive to NRC requests and suggestions. The Resident Inspector has also noted an improvement and an increased sensitivity to the regulatory requirements la the security area.
The supervision and staffing level for the security force appear adequate.
The major safeguards tasks facing the licensee are the imple-
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mentation of the Security Force Training and Qualification Plan, i
the implementation of 10 CFR 73.71(c) reporting requirements, j
and implementation of the Safeguards Information Protection Program required by 10 CFR 73.21.
b.
Conclusion The licensee is rated Category 2 in this area. No significant i
strengths or weaknesses were noted during the August 1981 in-spection. Security Plan objections were completed.
c.
Board Recommendations
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None.
8.
Refueling Activities
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a.
Analysis i
Portions of several inspections by the Resident Inspector were conducted in this area. The scope of these inspections was
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directed toward early planning and scheduling as this was a weakness identified during SALP 2.
The licensee has made a number of improvements in the area of refueling since the 1980 refueling outage.
Improvements were in the areas of material accountibility, procedure adherence, radiological protection and preplanning.
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Some new weaknesses were identified in the areas of fuel ac-countability and independent verification. Examples of these weaknesses are (1) knowledge and responsibility of parsons assigned the function of fuel accountability, and (2) very little independent verification of refueling activity by the Quality Control Department. These weaknes'ses were based on the inspectors' observations that visual abnormalities noted during fuel inspection were not always questioned, and a mis-placed fuel assembly went unnoticed until discovered by the Reactor Engineer during his verification of core reload.
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Conclusion The licensee is rated Category 2 in this area.
c.
Board Recommendations None.
9.
Licensing Activities a.
Analysis The licensing activities were evaluated in the following areas:
- Heavy Loads
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- Appendix I i
- Degraded Grid and Adequacy of Station Electirc Distribution Voltages
- Fire Protection
- Responses to NUREG 0737
- Systematic Evaluation Program (1) Management Involvement in Assuring Quality Evidence of prior planning and assignment of priorities exists and there are defined procedures for control of activities. Decisions are made at a level that ensures adequate management reviews and audits are generally thorough and technically sound, but often were not done promptly and resulted in delay of submittals.
(2) Approach to Resolution of Technical Issues from a Safety Standpoint With the exception of fire protection activities, the licensee showed a general understanding of the issues and used conservative and sound approaches. The licensee's performance with respect to fire protection did not show good understanding of the issues or thoroughly sound approaches.
(3) Responsiveness to NRC Initiatives and Staffing The licensee's performance in these areas varied greatly among the different licensing activities. Many accept-able licensing submittals were received on time or early.
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Responses to NUREG-0737 items were usually timely and complete. However, significant inadequacies in other areas such as Fire Protection, 10 CFR 50, Appendix I submittals (eight months late), and Systematic Evaluation Program (SEP) submittals reduced the overall performance rating. Dairyland's nuclear organization is unique in that licensing submittals and analysis are prepared by the operatite, staff and coordinated through the plant
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superintendent. Tradeoffs between operational and licensing priorities were frequently necessary due to the small available staff, and contributed to delays in many licensing actions.
b.
Conclusion The lic ensee is rated Cctegory 2 in this area. Although the licensee overall performance was satisfactory, significant improvements are possible in responsiveness to NRC initiatives and understanding of the issues. The licensee's limited staff appears to be technically.ompetent, but is severely taxed by the combination of plant operation and licensing activities.
c.
Board Recommendations The Board notes that limited staffing continued to be a major problem. Therefore, as part of the ongoing Regulatory Improve-ment Program, the licensee should evaluate staffing needs regarding current and foreseeable regulatory requirements (including the Full Term Operating License and associated hearings) and make staff augmentation or contractual efforts to meet the anticipated demand.
10.
Confirmatory Measurements and Environmental Monitoring a.
Analysis Copfirmatory Measurements
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For the Confirmatory Measurements portion of the inspec-tion (IR/81-17) performed during this assessment period, the licensee achieved thirteen agreements or possible agreements out of sixteen comparisons. Two disagreements in noble gas analyses were caused by not correcting for self absorption in the calibration of the noble gas geometry using a liquid standard. One disagreement was for I-131 on charcoal where the current, past and spike sample results suggest that the licensee's calibration standard was not representative of true I-131 deposition in charcoal. Also a sample counting technique to com-pensate for this anomaly is not used by the licensee. An overall review of the licensee's results suggest skewed efficiency curves in the low energy region. The licensee agreed to recalibrate all gamma spectrometer system geo-metries with fresh source material and implement an interim counting technique for charcoal while investigating permanent procedure.
The licensee has not resolved a continuing problem with the accurate quantification of Sr-90 in liquid. The licensee agreed to apply a correction factor to previous and current analytical results until the problem is resolved and a solution implemented. The licensee was
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sent a liquid sample spiked with Sr-89 &nd Sr-90 on December 2, 1981, and by his letter dated January 27, 1982, implied that this analysis would be performed in l
February.
In the most recent telephone discussion of this matter the licensee representatives indicated the analysis would be performed in September 1982.
Environmental Monitoring
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The licensee's Environmental Monitoring Program appears
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to have been managed and implemented adequately. Data from analyses performed by site personnel indicated no anomalies attributable to the licensee's operation. One item of concern was brought to the attention of the licensee who readily agreed to correct it.
b.
Conclusion The licensee is rated Category 2 in this area.
c.
Board Recommendations In the area of Confirmatory Measurements, the issue of accurate quantification of Sr-90 in liquids needs to be resolved by the
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V.
SUPPORTING DATA AND SUMMARIES A.
Noncompliance Data Facility Name:
LACBWR Docket No. 50-409 Inspections:
No. 81-13 through 81-23
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j No. 82-01 through 82-09 Noncompliances and Deviations Severity Levels Functional Area Assessment I
II III IV V
Dev.
1.
Plant Operations
2.
Radiological Controls
3.
Maintenance 4.
Surveillance and Inservice Testing 5.
Fire Protection and i
Housekeeping
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6.
7.
Security and Safeguards
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8.
Refueling Operations 9.
Licensing Activities 10. Confirmatory Measure-
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ments and Environmental Moni*oring TOTALS *
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- Does not include two items of noncompliance for which categorization has not been finalized and escalated enforcement action is pending (IR/82-06).
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B.
Licensee Report Data Licensee Event Reports (LERs)
LERs 81-08 through 82-15 Proximate Cause*
SALP Period 2 SALP Period 3 a.
Personnel Error
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b.
Design, Manufacturing
1 and Construction /
Installation c.
External Cause
0 d.
Defective Procedure
1 e.
Component Failure
11 x.
Other
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TOTALS
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- Proximate cause is the cause assigned by the licensee according to NUREG-0161, " Instructions for Preparation of Data Entry Sheets for Licensee Event Repor t (LER) File."
LER Evaluation The number of reportable events due to personnel error has been reduced from seven in the SALP 2 assessment period to four in l
the SALP 3 assessment period. This reduction in personnel errors is also noticeable in the reduction of noncompliances during the SALP 3 assessment per'.od.
There was also an increase in the number of reported component failures during the SALP 3 assessment period. Three of the reported component failures documented unacceptable leakage through containment penetrations discovered during type "B" and "C" surveillance leak rate tests.
The licensee should con-sider giving increased attention to those penetrations that have a history of unacceptable leakage.
C.
Licensee Activities 1.
December 23, 1981 through January 26, 1982: Reactor scram due to unknown cause, followed by unintentional cooldown of the No. 1B forced circulation loop, resulted in an extensive checkout of the plant's 2400 VAC electrical system and a detailed calculation of stress imposed on the No. 1B forced circulation loop.
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2.
April 9, 1982 through end of SALP 3 assessment period:
Planned refueling and turbine maintenance outage that was greatly extended due to unscheduled repairs to the main generator rotor.
D.
Inspection Activities During the assessment period the following team inspections were performed:
1.
Emergency Preparedness Appraisal (July 13-24, 1981)
2.
Evaluation of Emergency Preparedness Exercise (October 20-22, 1981)
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Emergency Preparedness Appraisal Followup (May 10-14, 1982)
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E.
Investigation and Allegations Reviews As a result of the May 10-14, 1982 followup of the Emergency Planning Appraisal, an investigation was conducted by Region III in June 1982 to determine if the licensee had intentionally at-tempted to mislead the NRC it reference to the number of qualified health physics personnel available in the event of an emergency.
The investigation identified no items of noncomplianca..
However, there was a concern about the management control system which permitted the incomplete information to be transmitted in the March 8, 1982 emergency plan. Critical facts such as the com-petency of the health physics technicians in on-the-job trainee status to perform emergency health physics surveys and the imminent termination of the fully trained health physics technician should have been in the emergency plan or the transmittal letter.
F.
Escalated Enforcement 1.
Civil Penalties During the SALP 3 assessment period, a Civil Penalty in the amount of $25,000 was assessed by the NRC and paid by the licensee for the April 1981 unauthorized modification of a containment pressure sensing line which degraded two plant Emergency Core Cooling Systems. This matter was addressed in SALP 2 Report and is included here for record purposes.
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2.
Orders
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None.
G.
Admiqistrative Actions 1.
Confirmation of Action Letters and Immediate Action Letters a.
July 28, 1981, concerning Emergency Planning Appraisal finding that needed immediate correction.
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b.
October 28, 1981, concerning Emergency Preparedness Exercise finding that needed immediate correction.
c.
December 28, 1981, concerning the investigation and correc-tive actions that must be performed prior to plant startup following the December 23, 1981, reactor scram and uninter,tional cooldown of the No. 1B forced circulation loop.
d.
May 21, 1982, concerning findings discovered during the followup inspection to the Emergency Planning Appraisal, that needed immediate correction.
2.
Management Conferences a.
July 28, 1981, a combined enfoz ement conference and manage-ment meeting was conducted for the purpose of discussing the potential enforcement actions for the unauthorized modification of the containment pressure switch and to discuss additional operational events which were of concern to the NRC.
b.
September 25, 1981, a nanagement meeting was held as a followup to the management meeting of July 28, 1981.
c.
October 9, 1981, a management meeting was held to discuss the results of the SALP 2.
d.
April 1, 1982, a management meeting was held to discuss the interfaces between Dairyland Power Cooperative and Region III.
H.
Regulatory Improvement Program The Regulatory Improvement Program was first suggested to Dairyland Power Cooperative by Region III management during a meeting held in
La Crosse, Wisconsin, on April 1, 1982. The licensee drafted a pro-gram and presented it to Region III management during a meeting held July 23, 1982, in the Region III Office. The draft program that was presented was a general statement of policy without milestone dates and other implementation details. The licensee stated, during the July 23, 1982 meeting, that after they analyzed the findings from NRC, INPO, and facility audits they would revise their program by October 1, 1982.
The first draft of the licensee's Regulatory Improvement Program addressed the need for improvement in the following general areas:
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Reduction in the number of personnel errors.
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Improvement in written procedures with proper review and approval prior to implementation.
3.
Increased attention to planning, scheduling and preparation for outage work.
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4.
Tighter control on radiation levels and personnel exposure.
5.
Improving the quality of committee review activities.
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The licensee was also requested to address the issue of corporate i
support of the facility in their revised program.
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