IR 05000409/1983009
| ML20024F401 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 08/11/1983 |
| From: | Axelson W, Fairobent J, Paperiello C, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20024F396 | List: |
| References | |
| 50-409-83-09, 50-409-83-9, NUDOCS 8309090344 | |
| Download: ML20024F401 (23) | |
Text
{{#Wiki_filter:s . U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-409/83-09 (DRMSP) Docket No. 50-409 License No. DPR-45 Licensee: Dairyland' Power Cooperative 2615 East Avenue - South Lacrosse, WI 54601 Facility Name: Lacrosse Boiling Water Reactor Inspection At: Genoa, WI Inspection Conducted: June 13-17, 20-22, 1983 W.u G. CJ 40s// c)/93 c G. Snell Inspectors: /o[[J ' J. Fair f&d4A Approved By: W. L. Axelson, Chief 0 81 Emergency P aredness Section f ll D ~ ^ e F peri o, Chie . Eme gency P,iaredness and Radiological Safety. Branch Inspection Summary: Inspection on June 13-17, 20-22, 1983 (Report No. 50- 409/83-09(DRMSP)) Areas Inspected: Routine, announced inspection of the Lacrosse Boiling Water Ret: tor to review action taken in respc**C to previously identified-inspection items, and IE Inspection Moduler 62.'21, 82202, 82203, 82205, 82206, 82207 and 02208. The inspectior '* +,i 143 inspector-hours onsite by two NRC ' inspectors and two P'AC nr v eants.
re identified: failure to Results: Two apparent items of noncogr.tano.
.o have capability to promptly notify offaste authoeities within 15 minutes after an emergency declaration and failure to annually review EALs with cognizant state officials.
8309090344 830823 PDR ADOCK 05000409 G PDR _ _._ _ _ . __ _ _
. DETAILS 1.
Persons Contacted
- R. Marose, Emergency Preparedness Coordinator J. D. Parkyn, Plant Superintendent A. N. Foster, Administrative Assistant L. L. Nelson, Radiation Protection Engineering Specialist
- B. R. Zibung, Health and Safety Supervisor R. Christians, Technical Support Engineer
- L. Goodman, Operations Engineer (LS0)
M. Wilchinski, Plant Operator (LS0)
- L. W. Kelley, Assistant to Operation Supervisor and Training (LS0)
- T.
Steele, Director, Environmental Affairs D. Weiss, Air Quality Analyst
- E. Hennen. Environmental Engineer T. Krueger, Plant Operator G. A. Whynaucht, Shift Supervisor (LS0)
A. J. Hanson, Sr. Health Physics Technician
- P. W. Shafer, Radiation Protection Engineer G. S. Boyd, Operations Supervisor (LS0)
R. J. Cota, Shift Supervisor (LS0) H. Frank, Air Quality Specialist
- J. W. Taylor, Assistant General Manager, Power Group
- Denotes those present in the exit interview.
2.
Review of Items Previously Identified a.
(409/82-06-01) (Closed) Notice of Violation Violation: As of the inspection conducted on May 10-14, 1982, the licensee had not provided for the timely augmentation of the response capabili-ties in that a procedure or a system for shift augmentation in an emergency had not been developed or tested.
Corrective Action: The licensee addressed the NRC concerns on shift augmentation in a letter from Linder to Keppler dated June 15, 1982. This letter contained an updated table of LACBWR emergency response personnel and their times for augmen-tation.
In addition, an unannounced test of the shift augmentation program was conducted during the night of June 14, 1982. This test indicated personnel would be able to respond within the times specified in their revised table. Since this initial test, the licensee has installed a fast dialer phone system which will further speed the notification times.
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-- - - . - --. . . _ - . -. . - - - . . P . . , addition, the licensee successfully augmented emergency staff personnel from their residences during the August 4, 1982, exercise.
- The inspectors have determined that the licensee has adequately developed, implemented and tested - a program for augmenting the staff during an emergency.
b.
(409/81-13-02) (Closed) Augmentation of the Onsite Emergency Organization and Minimum Shift Staffing . . Violation: 10 CFR 50.54(q) requires that nuclear power i reactors have and follow plans that meet the l standards in 10 CFR 50.47(b).. 10 CFR 50.47 ' - (b)(2) requires that the onsite and offsite i emergency response plans for nuclear power reactors must meet the following standards: " Adequate staffing to provide initial facility accident response in key functional areas is maintained at all times and timely augmentation of the response capabilities is available."
These standards are addressed by specific criteria in NUREG-0654 entitled " Criteria for - Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980.
During a routine inspection on May 10-14, 1982, NRC inspectors reviewed licensee procedures to determine if a shift augmentation system or ' procedure had been developed and implemented.
Neither Emergency Plan Procedure EPP-2, dated , March 17, 1982, entitled " Organization and Operations During Emergencies" nor any-other licensee emergency plan procedure provided'an acceptable shift augmentation system. An acceptable system would include the following: Prioritization for the order in which key
. ' persons by title and function are to be called.
A system for assuring key persons are . available, such as an administratively controlled duty roster.
Provisions for_ notifying key personnel . such that they can be alerted and report
to their respective job locations within
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. . the prescribed thirty and sixty minute required reporting times. Page units, call down telephone system or tone alert radios would be provided.
A duty officer system to assure a key . person would be available for receiving
e initial communications.
An order of succession for key positions.
' . Provisions for calling in persons by . position / title and the job qualifications or performance capabilities of each of the individuals.
Provisions for testing and demonstrating . the shift augmentation procedure on a periodic basis.
Corrective Action: EPP-2 has been revised to include a prioriti-zation for the order in which key persons by title and function are to be called. The ' inspector examined this prioritization in Sections 4.1 through 4.5 for the emergency action levels and found it to be adequate.
Appendicies A through E to EPP-2 contain the names and phone numbers of individuals to be contacted in an emergency situation with alternates listed if the key person is not available.
Five selected key DPC management personnel have been provided with page units. All other per-sonnel will be notified by telephone. A fast dialer phone is-provided in the control room to notify the primary response personnel and if necessary, their first alternate.
If neither of these individuals is available, other alternates are listed in the Appendicies to EPP-2 which will be phoned normally.
DPC has a duty officer system for key manage-ment personnel. These key personnel carry pagers and there are two or three alternates (without pagers) for each of them. The inspector-determined that this was adequate.
However, it is recommended that a description of the duty roster system be added to the Emergency Plan.
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. EPP-2 provides the procedures for notifying persons by position / title and Appendix 7 of the Emergency Plan contains position qualifi-cations. These were examined and determined to be adequate.
Currently there is no provision for periodically testing and demonstrating the shift augmentation procedure. LACBWR is operating with staffing levels below that indicated in Table B-1 of NUREG-0654, and hope to continue with these levels pending acceptance of their exemption from the NRC in this matter. Because of this, the NRC staff believe that it is necessary for LACBWR to provide evidence on a continuing basis of their ability to augment the staff within 30 and 60 minutes as committed to in Table A-1 of the Emergency Plan. Therefore, it is recommended that LACBWR institute a provision for periodically testing and demon-strating the shift augmentation procedure.
This will be tracked under new open item 409/83-09-01.
b.1. Deficiency: In response to the licensee's statement in their December 17, 1981, letter that they believed their proposed minimum shift staffing levels to be sufficient, the NRC Region III office responded in a letter dated February 5, 1982, as follows: The minimum shift staffing proposed in your response is unacceptable because it does not meec the guidance recommended in NUREG-0654, Table B-1, i.e., you do not provide a !RO-Forcman, a Rad / Chem Tech, nor a Communientor. We understand that you intend to oquest an exemption from the guidance Table B-1.
Until the exemption is iproved, your minimum shift staffing is unscceptable and inadequate compensatory measures are in place.
The licensee has requested an exemption be granted from minimum shift staffing as speci-fled in Table B-1 of NUREG-0654 by letter to Mr. Dennis M. Crutchfield, NRR, from Mr. Frank Linder, DPC, dated June 15, 1982.
Corrective Action: The licensee provided an updated table of their minimum shift staffing level in a letter to the NRC dated April 8, 1983. The
. - staff has reviewed this table and find that the minimum shift staffing levels are accept-able on an interim basis, until NkR has responded to the exemption requested. This will be tracked under new open item 409/83-09-02.
c.
(409/82-06-02) (Closed) Notice of Violation Violation: 10 CFR 50.54(q) requires that nuclear power reactors have and follow plans that meet the standards in 10 CFR 50.47(b) and the require-ments of Appendix E to 10 CFR 50.
10 CFR 50.47(b)(9) requires that the onsite and offsite emergency response plans for nuclear power reactors must meet the following stan-dards: " Adequate methods, systems, and equip-ment for assessing and monitoring actual or potential offsite consequences or a radio-logical emergency condition are in use."
10 CFR 50, Appendix E, Section IV.E.2 requires that adequate provisions shall be made and described for emergency facilities and equipment, including equipment for deter-mining the magnitude of and for continuously assessing the impact of the release of radio-active materials to the environment.
As of the inspection conducted on May 10-14, 1982, the licensee's meteorological systems and equipment for assessing actual or potent-ial offsite consequences were inadequate and adequate provisions were not made and described for meteorological equipment used for continu-ously assessing the impact of the release of radioactive material to the environment in that: Adequate calibration, operability checks, . and maintenance procedures for the onsite meteorological measurements program were not available.
Corrective Action: Written procedures for calibration, opera-bility checks, and maintenance of the onsite meteorological measurements program are avail-able. These procedures are considered adequate. The meteorological measurements system is remotely interrogated daily, and a DPC technician checks the system weekly. Logs are available which describe the findings of each visit. Most maintenance is performed by DPC personnel, with assistance from a
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. conealcant. The consultant currently per-formo quarterly calibrations of the entire meteorological measurements system. Although the documentation of the meteorological measurements program is adequate, the quality of the data displayed in the Control Room is somewhet suspect because of poor quality control of the strip chart records, particularly in keeping'the charts at the appropriate time.
Recommendations for improvement in this area would be to:
(1). Replace the recorder in the Control Room used to display 10m wind speed and direction with a recorder like those used for other meteorological parameters.
l (2) Develop a written procedure and log for i daily check of the Control Room recorders of meteorological information including .a time check appropriately marked on the chart.
! Violation: EPP-5, " Estimate of Offsite Exposure," did not contain provisions for obtaining and utilizing-backup wind speed and wind direction ' data.
Corrective Action: EPP-5, Issue 2, contains procedures to obtain meteorological data if primary measurements ! are not available..These procedures involve direct' substitution of wind direction between between the 105m and 10m levels. Wind speed . .from one level may be used to substitute- ! ' for missing data at the other level by l multiplying the'available wind speed by a correction factor contained in the procedures.
' Wind speed correction factors are based on a ! . power law relationship contained in'the EPA ' CRSTER air quality model.- It is recommended .the licensee develop more appropriate site-specific' correction factors based on onsite measurements.
If the primary stability indicator (vertical i temperature gradient between the 105m and 10m levels) is not available, stability is i inferred through an approach based on 10m
wind speed, cloud cover, and time of day.
. Control Room personnel have access to a window to make observations of cloud cover.
It is recommended that Control Room, TSC, and EOF
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. _ __ _ _ _ _ _ _ _ . _ _ . '- . personnel be trained to distinguish the degree of cloud cover, particularly at night.
A backup power supply has been installed to ?
make the likelihood of failure of the entire primary meteorological measurements system a reasonably remote possibility. However, because of the added uncertainties when using , , backup wind direction data, protective measures i recommendations should be expanded to compensate for these uncertainties. When primary measure-i ments of wind direction are not available, the area of interest should be extended to encompass .. at least two sectors on either side of the identified downwind sector, and even more if offsite information is used. This will be tracked under new open item 409/83-09-04.
(This is alo discussed in Appendix B to the letter of t:iis report) Violation: EPP-8, "Offsite Radiological Survey," did not contain provisions for considering , ground level information.
Corrective Action: EPP-8, Issue 4, was examined and contains provisions for considering ground level infor-mation.
J' Violation: The licensee had not provided a technical basis for utilizing backup data.
Corrective Action: The licensee has provided the report, " Tech-
nical Evaluation of LACBWR Meteorological Program 1983" (June 1983) which examines . and compares onsite and near-site meteorolog-ical data to determine a source of backup-data.
Because of concerns about the represen- , tativeness of other meteorological measure-ments, the licensee has chosen to infer atmospheric stability on the basis of 10m wind speed, cloud cover, and time of day. A comparison of the stability class resulting . ! from this technique to-that produced by vertical temperature gradient has not been performed.
These techniques generally compare favorably over an annual cycle, particularly in areas where neutral (Pasquill type "D") and slightly I stable (Pasquill type "E") conditions predomin-ate.
However, the licensee should perform a real-time comparison of these techniques, and expand the recommendation accordingly. The licensee should continue to explore other .
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. possibilities for backup data. EPP-5 specifies a 15-minute averaging time for primary meteoro-logical measurements. No averaging time is specified for wind speed information used to determine stability class by the backup methodo-logy.
Violation: The licensee did not comply with commitments in his December 17, 1981, letter to revise EPP-5 by February 28, 1982. The procedure, EPP-5, in use on May 14, 1982, had an issue date of July 31, 1981.
Corrective Action: EPP-5 was examined and found to be revised on July 30, 1982.
Other items the licensee should consider for improvement: (1) Continue with efforts to improve the under-standing and description of atmospheric transport and diffusion in the vicinty, with particular attention to integrating an improved source of backup information into emergency planning procedures.
(2) Document to the NRC all changes to meteoro-logical measurements programs used for emergency planning and response purposes, d.
(409/83-13-03) (Closed) Emergency Classification System Deficiency: The LACBWR Operating Manual, Non-routine and Emergency Operating Procedures did not reference the Emergency Plan Procedures (EPP) and activation of the Emergency Plan (EP).
Corrective Action: The LACBWR Operating Manual Emergency Pro-cedures were reviewed and cross referencing checked. Cross referencing was accomplished by referring the operator to EPP-1, Table 4.1 to determine Emergency Action Level and noti-fication. This reference was found in the following procedures: 3.3.1 SCRAM 3.3.2 Complete Loss of Electric Power 3.3.3 Primary System Leak 3.4 Evacuation Procedures Reference to the Emergency Plan Procedures was not found in 3.6, Firefighting Procedure
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. (revision February 1981) although EPP-1, page 30 gives action level classification for fires.
Reference to the Emergency Plan Procedures was not found in 3.3.4, severe weather procedure, although supporting action level classification levels are in EPP-1, issue 6.
The inspectors concluded that'the cross-referencing of major procedures was adequate.
The classification tables (4.1 of EPP-1) were referenced.
Future revisions to the firefighting and severe weather procedures should be donc cross-referencing them to the EPPs.
e.
(409/81-13-13) (Closed) Accident Assessment Deficiency: A definitive emergency plan procciure for sample preparation and analysis of high activity samples was not provided.
, Corrective Action: EPP-6, Issue 1, dated September 3, 1982 was found to be in use.
The inspectors reviewed the procedures and observed them in use for a demonstration of sample preparation and analysis for a simulated sample.
The inspectors concluded that the procedures have been prepared and are in use, f.
(409/81-13-15) (Closed) Accident Assessment Deficiency: Capability and procedures for post-accident sampling and analysis of samples from the liquid effluent system had not been provided.
Corrective Action: The inspectors found that a previous commit-ment had been made by the licensee to revise EPP-6 to include the capability and procedures for post-accident sampling and analysis of liquid effluents. This was targeted for the end of the 1982 refueling outage.
Inspection of EPP-6 shows Section 6.3.1 to read as follows: Under potential accident conditions, no discharge of radioactive liquid will be allowed. Only after the situation has been evaluated and the necessity to dis-
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. , charge liquid effluents deemed necessary
by the ECD shall discharge be allowed.
The inspectors determined that this was acceptable.
' ! g.
(409/81-13-38) (Closed) Post-Accident Sampling Deficiency: Post-accident liquid effluent sampling and analysis system required installation, testing, and development of procedures.
' J Corrective Action: Inspectors found that a previous commitment had been made by the licensee to revise EPP-6 to include the procedures for preparation , and analysis of liquid effluent samples by the
end of the 1982 refueling outage.
Inspection of EPP-6 shows Section 6.3.1 to read as follows: , , , Under potential accident conditions, no
discharge of radioactive liquid will be allowed.
Only after the situation has been evaluated and the necessity to discharge liquid effluents deemed necessary by the ECD shall discharge be
allowed.
The inspectors determined that this was acceptable.
h.
(409/81-13-16) (Closed) Accident Assessment Deficiency: Procedures to obtain samples of stack effluent under accident conditions had not been developed.
' Corrective Action: EPP-6, Issue 1, dated September 3, 1983, was found to have been revised and be in use. The inspectors reviewed procedure 6.0, " Radioactive Effluent Sample Collection and Analysis During Accidents," and the sampling system which now ! has the capability to sample stack effluent under accident conditions.
The inspectors concluded that this item has been adequately completed.
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(409/81-13-21) (Closed) Accident Assessment Deficiency: Procedures for high level sample preparation and analysis did not contain provisions for dilution or fractionation of samples to pre-vent excess MCA dead time.
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. Corrective Action: The inspectors found EPP-6, Issue 1, dated September 3,-1982, had incorporated provisions for dilution and fractionation of samples both during and after sampling for counting. Parts of the procedure were observed in use during a demonstration of parts of the post accident sample system for primary coolant and stack effluent accident sample drawing and analysis.
-Sample dilution and fractionation procedures would have provided sufficiently low exposure rates (4 mR/hr) frcm the samples to reduce MCA dead time to acceptable levels (estimated 10-20% max.). The inspectors concluded that the procedures were developed and are in use. This item has been adequately completed.
J.
(409/81-13-27) (Closed) Radiological Exposure Control Deficiency: Procedures have not been provided for moni-toring of all individuals leaving restricted areas at assembly areas and at reassembly areas.
Correction Action: A procedure had been developed by the licensee which addresses monitoring and decontamination of all personnel at the assembly areas (evacuating points) as necessary during Site Area and General Emergency conditions.
EPP-22, " Health Physics Department Emergency Response Actions," referenced EPP-2, Section 4.5.9 for guidelines, action levels and methods for personnel decontamination. Survey instrumen-tation and documentation of survey data were also addressed in Section 4.5.9.
The inspectors determined that these procedures are cdequate.
k.
(409/81-13-28) (Closed) Radiological Exposure Control Deficiency: An Emergency Plan Procedure (EPP) that orches- .tretes all aspects of the Radiation Protection ~ Program during an emergency was not provided.
Corrective Action: The licensee has developed procedure (EPP-22) " Health Physics Department Emergency Response Actions," which identifies the health physics department activities required to support the emergency effort. This procedure, dated August 31, 1982, offers general guidance to
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the health physics technicians during each emergency classification. In addition, this procedure references additional task specific procedures which offer detailed guidance such as: (1) LACBWR Emergency Plan (2) LACBWR Emergency Plan Procedures, EPP-1 through EPP-21 (3) LACBWR Health and Safety Procedures (4).LACBWR Operating Manual, Volume X, " Health Phyuics Procedures."
Delineation of authorities and responsibilities of health physics department personnel were addressed in EPP-2, Section 3.0, " Organization and Operations During Emergencies."
The inspectors determined these procedures to be adequate.
1.
(409/81-13-29) (Closed) Radiological Emergency Response Training Deficiency: Emergency Plan and. Procedures Training Programs do not include specific training in the contents of EPP-1, EPP-2 and the physical une of the EPPs.
Corrective Action: The 1.icensee has developed and implemented procelure EPP-14 which addresses emergency response instruction for both site workers and offsite support groups. This procedure references EPP-1 and EPP-2 for general guidance in addition to other job specific procedures.
The inspectors reviewed documentation of training / retraining programs for 1982 and 1983 including signatures of personnel who had attended the training sessions both onsite and offsite. No deficiencies were noted. The inspectors found the licensee's training / retraining program as adequate, m.
(409/81-13-30) (0 pen) Technical Support Center Deficiency: Adequate communications and ventilation con-trols were not available in the TSC in accor-dance with NUREG-0696. This is to be accomplished by October 1, 1982.
Corrective Action: The licensee has satisfied the communications requirements for the TSC. The remainder of
. . this item (habitability) has been addressed in a letter to the NRC dated April 8, 1983, (LAC-8997). The inspectors left the item open pending resolution of the issue by NRR pursuant to SECY-82-111b.
n.
(409/81-13-31) (Closed) Technical Support Center Open Item: Data display (SPDS and other Regulatory Guide 1.97 parameters) were not made available to TSC personnel.
Corrective Action: A computerized data display system is available in both the TSC and EOF, The system is used for storage and retrieval of information en plant operating parameters and meteorological data. 'It can provide both current and historical data for 15 minute intervals for up to 14 days. The data is printed out on a CRT screen with a simultaneous printout on hardcopy in either a data listing or graphical format. This area will be examined in more detail during the post implementation Emergency Response Facilty appraisal.
o.
(409/81-13-33) (Closed) Control Room Open Item: The Control Room Ventilation has not been modified to permit Control Room habitability - under accident conditions.
Corrective Action: The licensee responded to NRR by letters of July 22, 1981, and August 11, 1981, regarding requirements of Item III.D.3.4 in NUREG-0737 regarding control room habitability for LACBWR. The licensee committed to install and maintain gaseous detection monitors by January 1, 1983.
, The inspectors physically reviewed the installa-tion of the detectors and their associated alarms and reviewed the facility changes associ-ated with the detectors.
A letter from NRC, Crutchfield to DPC, Linder dated June 10, 1982, approved the DPC response pending a post-implementation review by repre-sentatives of NRC Region III.
Based on review of all correspondence and the installation, the inspectors concluded that this item has been satisfactorily completed.
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(409/81-13-34) (Closed) Post-Accident Sampling Open Item: Primary coolant and containment atmosphere sampling systems required installation, testing, and development of procedures.
Corrective Action: The containment atmosphere sampling system installation was examined by the inspectors and found to be complete. Facility change documentation and test data spot checks confirmed the installation is complete.
l The primary coolant sampling system installa-l tion is now 100% complete. Documentation of capability and operation via test data and facility changes were spot checked to assure systems were verified for flow and operation-ally tested. The test procedure and metho-dology were reviewed and the documentation inspected. Procedures were reviewed by M inspectors and observed in use during a demonstration of the operation for sampling the primary system.
The inspectors. concluded that the facility changes have been made and the procedures and testing are complete. The requirements for this item are adequate, q.
(409/81-13-22) (Closed) Backup Meteorological Data Deficiency: " Procedures for obtaining meteorological data if primary measurements are not available have not been provided. Techniques for obtaining and utilizing backup information should be described in detail for both elevated and ground level-releases.
Identi-fication and utilization of backup data should be consistent in all plant emergency pro-cedures."
Corrective Action: Tlis item was addressed under 409/82-06-02.
The licensee's response was determined to be adequate.
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(409/81-13-23) (Closed) Meteorological Equipment Quality Control Deficiency: " Written procedures for calibration, opera-bility checks, and maintenance of the onsite meteorological measurements program are not adequate."'
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- Corrective Action: This item was addressed under 409/82-06-02.
The licensee's response was determined to be adequate.
s.
(409/81-13-24) (Closed) Utilization of Meteorological Data Deficiency: "The meteorological procedures (EPP-5 and EPP-8) do not consider both elevated and ground level releases and the meteorological procedures do not include provision for obtaining and utilizing backup data. The technical basis for utilizing back-up data should be provided in a document separate from the procedures."
Corrective Action: Both EPP-5, Issue 2, and EPP-8, Issue 4, consider both elevated and ground level releases.
EPP-5 contains procedures for obtaining and utilizing backup meteorological data, and EPP-8 records data from the Control Room which is based on the procedures in EPP-5.
The atmospheric dispersion model for elevated releases described in EPP-5, Issue 2, is not acceptable because of the definition of the effective height of release, h. Table 1 of EPP-5 indicates that a plume w$ich has impacted the ground surface will be assumed to be elevated further downwind if the terrain height decreases downwind. The NRC takes the position that once a plume impacts the ground, the plume should be assumed to remain along the ground unless the licensee can document other plume behavior. This will be tracked under new open item 409/83-09-05.
Other aspects of this item have been addressed under 409/82-06-02 and found to be adequate.
t.
(409/81-13-25) (0 pen) Revision of Procedures to Incorporate Meteorological Information Deficiency: " Provisions for obtaining and utilizing meteorological information beyond that used in'an initial dose assessment have not been identified.
Further, Data Sheets Nos. I and 2 (EPP-5) do not characterize release mode, nor consider 15-minute average meteorological conditions. These provisions should be consistent with EPP-8 as revised. The use of two Figure 3's in EPP-5 on Pages 9 and 15
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s i leads to confusion in which one to use in performing calculations."
Corrective Action: The calculations of atmospheric dispersion conditions' contained in Data Sheets 1 and 2 of EPP-5, Issue 2, do not identify the time and date of the meteorological observations and do not provide for updates. Meteorological data in the form of'15-minute averages is available in the TSC and EOF through a computer link, although the procedures for updating dis-persion calculations are not clear.
In the event of a computer malfunction, meteorological data for the TSC must be obtained from the Control Room and data for the EOF must be obtained via verbal communication with Control Room personnel, u.
(409/81-13-32) (Closed) Meteorological Instrumentation Deficiency: A complete description of the onsite meteoro-logical measurements program to be used in the facility including the location and orientation of all sensors, sensor speci-fications, calibration and maintenance procedures, operability checks, data reduction techniques, and data displays has not been provided.
Corrective Action: A description of the onsite meteorological measurements program is available in the DPC report, " Meteorological Monitoring Plan for the Lacrosse Boiling Water Reactor 1982."
The information in this' report coupled with the written procedures for calibration, ' maintenance, and operability checks provides a complete description of the entire meteoro-logical measurements program.
v.
(409/81-XX-02) (Closed) Unusual Events were declared at the LACBWR site on December 23, 1981, and June 5, 1982. These events were examined for: proper classification, timeliness of notification, notification of proper authorities and proper implementation of the emergency procedures.
In both cases, the events were properly classified. For the December 23, 1981, incident, the records of the procedures sign-off sheet could not be found, so no other verifications could be made other than the NRC was' notified. For the June 5,-1982, incident, the records were available, which indicated the proper procedures were followed_and the necessary personnel notified. However, there were no dates or times on the sign-off sheet (EPP-2, Section 4.2) 17'
. so the timeliness of the notifications could not be examined.
Based on problems encountered in re-examining the use of the pro-cedures for the June 5, 1983, Unusua! Event, the licensee should include on the EPP-2, Sections 4.2 through 4.5 sign-off's, a place to put the time and date. This will be tracked under new item 409/83-09-03.
3.
Emergency Detection and Classification Inspection Procedure 82201 The inspectors verified that the licensee's emergency plan procedure EPP-1 contained EAL's leading to detection and classification of emergencies based upon inplant conditions and inplant and offplant radiological measurement data.
EAL's in Table 4.1 of EPP-1 listed values which could be preset as The alarm points on the indicating media in the control room.
emergency plan procedures also provided for onsite and offsite radiation measurements to be used as protective action parameters.
Notification procedures, specifically Table 4.1 of EPP-1 and the call / notification lists of EPP-2 were specific for criteria for initiation of offsite notifications. However, the inspectors determined that the licensee's emergency plan procedures do not require the licensee to initiate offsite notifications within 15 minutes after an emer-gency has been declared. Further, both the site emergency plan and procedures do not require any notification of State or local offsite authorities for an Unusual Event. The State of Wisconsin and Minnesota and Vernon County, Wisconsin, and Houston County, Minnesota, were not notified by the licensee within 15 minutes after declaration of the two Unusual Events of December 23, 1981, and June 5, 1982. The inspectors noted this item as being an apparent item of noncompliance in the licensee's.. urgency program and that corrective action is necessary in this area in order to achieve compliance with 10 CFR 50, Appendix E, Part IV.D.3.
This will be tracked as open item 409/83-09-06.
Examination of the licensee's training program indicated that EALs are reviewed each year as part of this program with local agencies.
The review includes discussion of the specific EAL's that could necessitate action by each agency and their resultant participation in protective actions. However, the licensee did not review EALs with State agencies as directed in 10 CFR 50, Appendix E, Part IV.B.
This appears to be an item of noncompliance and needs to be incorpor-This will ated into the LACBWR program for the item to be acceptable.
be tracked as new open item 409/83-09-07.
The inspectors determined that the emergency event classifications specified in 10 CFR 50, Appendix E, Part IV.C., were contained in the licensee's emergency plan and that correct classifications would result if these procedures were followed.
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. The inspectors verified that the Shift Supervisor, in the initial capacity as Onsite Emergency Response Director, has the authority and responsibility to immediately and unilaterally classify events and initiate emergency actions. This includes giving initial protective action recommendations to offsite officials.
Examination of Emergency Operating Procedures and walk-throughs with several plant Shift Supervisors indicated that the procedures adequately addressed the classification of EAL's.
The inspectors presented a set of plant parameters which would have indicated primary EALs or core degradation to 5 qualified SRO's in the walk-through exercises. Each individual responded in an adequate manner, using the emergency pro-cedures, to effectively mitigate the scenario emergency situation.
Meteorological parameters were included in the problem scenarios.
4.
Protective Action Decisionmaking (IE Procedure 82202) The inspectors reviewed the licensees procedures sad capabilities for protective action decisionmaking to assess their ability to analyze emergency conditions and promptly initiate recommendations to offsite agencies.
During situational, orally administered, plant-oriented walk-throughs of various events which progressed from abnormal situations to various emergency classification levels, a cross section of licensed plant operators demonstrated their ability to respond to situations and use the plant procedures, emergency plan and emergency procedures.
Procedures were physically used and referenced, both for plant oper-ations and emergency situations in.the emergency plan. Decision making was found to be proper, with reference to the checklists and tables in the emergency plan. These walk-throughs included two shift supervisors, the operations supervisor, the assistant to operations supervisor and training, and operations engineer.
In all cases, the responses would have been adequate to assess plant conditions and make correct protective action recommendations.
Assignment of authority and responsibility were found to be clearly available and interpretable. The relationships and authority lines for plant control and operation versus offsite protective action recommenda-tions were all found to be satisfactory. The operators questioned kept plant control and offsite actions in proper priority and managed them concurrently.
, A high level of sensitivity to the 2 of 3 fission product barriers and the associated level of classification was noted by the inspectors.
Also, the classification tables were used with a good degree of familiarity.
However, examination of EPP-2 showed up inadequacies in the procedures to be followed for protective action decisionmaking. A detailed discussion of this is contained in Appendix B to the letter of this report. This will be tracked under new open item 409/83-09-08.
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_ _ _ _ _ _ _ _ _ _ _ . . . 5.
Notifications and Communications (IE Procedure 82203) The inspectors reviewed the licensee's procedures for notification of offsite agencies and LACBWR personnel during emergency conditions.
Procedures to implement this function were related to the EALs, but several deficiencies were noted.
EPP-2, Sections 4.2 through 4.5 were examined and they specify the onsite and offsite personnel and agencies that are to be notified for Alert classifications and higher, but no offsite agencies were to be contacted for an Unusual Event, as is specified in 10 CFR 50, Appendix E, Part IV.D.3.
In addition, none of the emergency classes indicated that notifications must be made to the local and State agencies within 15 minutes after declaration of the event class. These items must be addressed if an acceptable program is to be achieved. This is further discussed in paragraph 3.D, Emergency Detection and Classification.
Notifications are made by telephone, with a fast dialer system used to speed up the initial notifications. Six pagers are used by key management personnel, including the NRC Resident Inspector.
If the normal onsite phone system is not operational, a microwave system is available as a backup. The telephone list for augmentation of licensee personnel is updated quarterly.
An examination was made of all records pertaining to the monthly and annual communication checks as required by 10 CFR 50, Appendix E, Parts IV.E.9.a through 9.d.
Out of almost two years of monthly phone checks, only two varification records could not be found. All others were correctly filled out. The licensee was of the opinion the tests had been implemented, but the records were incorrectly filed or lost.
Examination of the records of the siren tests indicate that these tests are being adequately implemented.
Currently siren silent tests are conducted monthly, growl tests quarterly and full range tests annually.
EPP-21, Section 5.1.2 states that the full range test is not a substitute for the other tests. However, in discussion with the licensee, the inspector agreed that the procedure could be changed so that a full range test could be substituted for the silent and growl tests.
The communication equipment were examined in each of the emergency response facilities and found to be adequate. The inspector observed a test of the NRC ENS phone which was acceptable.
Portable communications systems used by radiation monitoring teams ! were not examined during this inspection be will be examined during the next exercise.
6.
Shift Staffing and Augmentation (IE Procedure 82205) The inspectors reviewed the physical and administrative aspects of the shift staffing and augmentation procedures.
Currently, LACBWR has an exemption pending with NRR to deviate from the guidance given in Table B-1 of NUREG-0654. On an interim basis, the NRC staff has determined the staffing levels to be adequa* e.
Examination of the
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callup procedures indicates that they are adequate. Two augmenta-tion drills were conducted during 1982 to verify licensee personnel could be augmented in 30 and 60 minutes as specified.
These drills were successful.
More detailed discussions of shift staffing and augmentation, including items that will remain open, are discussed in items 409/82-06-01 and 409/81-13-02.
7.
Knowledge and Performance of Duties (Training) (IE Procedure 82206) The inspectors reviewed the licensee's program for emergency training and retraining and noted that EPP-14 addressed this portion of the emergency plan. An interview was also conducted with the site training coordinator who displayed available lesson plans, examination material, examination results, and attendance records of site personnel and selected offsite support agencies. Emergency training content was focused upon EPP-1 and EPP-2 which listed EAL's and anticipated responses by both onsite and offsite personnel. Documentation indicated that retraining was being conducted on an annual basis as required by the procedures.
Scheduling of retraining classes was cross referenced with attendance verification records in personal training folders of plant operators to ensure that retraining schedules were not being overlooked.
The inspectors, noted that responsibility for administration and documentation of the training program rested with the Health and Safety Supervisor and the Assistant to the Operations Supervisor was func-tioning as the training coordinator.
Walk-throughs aimed toward knowledge and performance of duties were conducted with the Operations Supervisor, the Assistant Operations Supervisor and Training Coordinator, 3 Shift Supervisor, 3 Rad / Chem Technicians, and an Operations Engineer. The inspectors determined that each individual could adequately perform their respective duties during an emergency situation.
Based upon procedural reviews, documentation and walk-throughs, the inspectors determined that this portion of the licensee's emergency program was adequate.
8.
Dose Calculation and Assessment (IE Procedure 82207) The inspectors reviewed the licensee's emergency plan procedure for calculating and assessing dose under anticipated release conditions.
EPP-5 provided guidance in a cookbook format leading to offsite dose calculations via hand calculations and/or computer based techniques.
The procedure offered this methodology for estimating doses at several distances from the plant boundary based upon known release rates and meteorological dispersion data. The release rates were to be determined from data provided by the microprocessor of the SPING-4 stack monitoring
s s system, and the procedure addressed both surface and stack releases of radio-iodine and noble gases. EAL's were defined for protective actions for the general public in the procedure.
The inspectors found that backup dose calculation capabilities were available through a computer based program on a separate computer system l .(ND 66/6600) which plotted a single release plume centerline trajectory.
i A third computer (TI-99), based in the EOF, plotted plume trajectory based upon projected meteorology.
The inspectors also found that the Senior Onsite Health and Safety Representative was responsible for initial offsite dose estimates.
Upon activation of the EOF, the Radiological Assessment Director and Offsite Dose and Trajectory Specialist assumed offsite dose estimate ~ responsibilities as outlined in the procedure EPP-2.
The procedure offered a provision for integrating actual offsite dose measurements into the dose assessment process as that information became available.
EPP-8. offered guidance in survey techniques and data reporting.
Standard forms were available for documenting measurement and meteoro-logical data in the attachments of EPP-8.
A. walk-through of the emergency classification scheme by 5 shift super-visor qualified personnel ~ demonstrated that early dose calculations would result from following the licensee's emergency procedures. A review of the licensee's training documentation indicated that person-nel responsible for dose calculations had received training in this area. The health physics qualification program listed dose calculations as a requirement. A walk-through of computer program R-THYROD on the ND 66/6600 which determined offsite thyroid dose equivalents and noble gas immersion doses was satisfactorily conducted by the Radiation Protection Engineer.
Based upon the above information, the inspectors determined that this portion of the licensee's emergency program was adequate.
9.
Post Accident Measurements and Instrumentation (IE Procedure 82208) The inspectors reviewed radiological instrumentation installations and use.
Calibrations and periodic checks were in order and current.
Conversion factors were posted to correlate core condition to activity monitor readings. Containment high range radiation monitors (2) were -
in place with range capabilities through-10 rad /hr. Fifteen contain-ment building area radiation monitors (ARMS) were in operation. Of ~
these, 13 were capable of gamma detection levels through 10 mrad /hr ~
and two.had capabilities up to 10 mrad /hr. All of the above detectors - could be read out in the control room.
Gaseous effluent monitoring capabilities included constant air monitoring . systems and a nine channel computerized in-line monitoring system which continuously looked at particulates, noble gases and I-131 concentrations in the stack atmospheric post-accident sampling system. _This system . incorporated automatic background subtraction' capabilities for noble
t + gases. Responses were printed out in the control rcom and audible and visual alarms were built into the system.
The inspectors verified the installation and operability and reviewed use of the post-accident sampling system. A demonstration of the system was made in a walk-through for sampling the primary coolant and preparing samples for counting and analysis. The demonstration showed the system and procedures to be workable. As a result of the demonstration, it was recommended that the licensee consider shielding the semple lines leading from the tunnel to the sample cylinder.
(A facility change proposal was initiated for this she11 ding as a result of this and previous observa-tions prior to the completion of the inspection.) Suggestions were dis-cussed to reduce actual sample exposure by the method of removing the sample cylinder without the L-shaped adapters and turning the L-shaped adapters upward to prevent dripping after sample cylinder removal.
The inspectors carried out a detailed review of the meteorological instrumentation system, maintenence procedures and instrument siting.
The licensee has made considerable progress in the development of an acceptable meteorological program and incorporating it into their emergency preparedness program in the last several years. The inspectors determined that only a few areas needed more attention for the program to be acceptable. These and other meteorological concerns have been addressed in more detail in this report in items 409/82-06-02, 409/81-13-22, 409/81-13-23, 409/81-13-24, 409/81-13-25, and 409/81-13-32.
Based on the instrumentation and measurement capabilities listed above, the inspectors determined that this portion of the licensee's program was adequate.
10.
Exit Interview The inspectors met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on June 17, 1983.
The inspector summarized the scope and findings of the inspection.
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