IR 05000409/1986008

Insp Rept 50-409/86-08 on 860804-08 & 14.Violations Noted: Failure to Notify State & Local Govt Agencies within 15 Minutes of Unusual Event & to Maintain Emergency Kit Supplies

ML20214M029
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	08/26/1986
From:	Snell W, Williamsen N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214L992	List: IR 05000409/1986008 ML20214L990 ML20214M008
References
50-409-86-08, 50-409-86-8, NUDOCS 8609100505
Download: ML20214M029 (10)

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. T U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Repcrt No. 50-409/86008(DRSS)

Docket No. 50-409 Licenses No. DPR-45 Licensee: Dairyland Power Cooperative 2615 East Avenue - South Lacrosse, WI 54601 Facility: Lacrosse Boiling Water Reactor Inspection At: LACBWR, Genoa, Wisconsin Inspection Conducted: Augus,t 4-8 and 14, 1986 Inspectors: Norman flfa~ms , s/t4/aG Team Leader Date William G. Snell Approved By: Wi S Chief Emergency Preparedness Section a44/84 Date Inspection Summary Inspection on August 4-8 and 14, 1986 (Report No. 50-409/86008(ORSS));

Areas Inspected: Routine, unannounced inspection of the following areas of the licensee's Emergency Preparedness Program: licensee actions on previously identified emergency preparedness items; licensee emergency response activations; emergency detection and classification; protective action decisionmaking; notifications and communications; changes to the emergency preparedness program; shift staffing and augmentation; knowledge and performance of duties (training); and licensee audit Results: Two apparent violations were identified in two areas: failure to notify State and Local governmental agencies within fifteen minutes after the declaration of an Unusual Event (Section 3c, licensee emergency response activations) and failure to maintain emergency kit supplies (Section 7, changes to the emergency preparedness program).

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DETAILS Persons Contacted

• J. Parkyn, Plant Superintendent

• B. Wery, QA Supervisor

• Polsean, Shift Supervisor

• L. Goodman, Operations Engineer

• R. Christians, Emergency Preparedness Coordinator

• L. Nelson, Health and Safety Supervisor

• L. Kelley, Assistant to Operations / Training Supervisor

• Cota, Training Specialist R. Shimshak, Manager Special Nuclear Projects R. Brimer, Electrical Engineer P. Shafer, Radiation Protection Engineer M. Johnsen, Shift Supervisor G. Dunnum, Shift Supervisor M. Land, Health Physics Technician G. Whynaucht, Shift Supervisor D. Loeffler, HP Technician M. Wilchilnski, Licensed Senior Operator G. Roediger, HP Technician P. Moon, Shift Supervisor J. Gallaher, Shift Supervisor P. Bronk, Shift Technical Advisor

• Attended exit meeting, August 8, 198 . Licensee Actions on Previously-Identified Emergency Preparedness Open Items /83020-02 (Closed) Messages to Offsite Agencies Were Incomplete The Emergency Plan Procedures, for example EPP-2, Appendix H (page 59),

have been amended to emphasize that the initial and followup messages to offsite agencies should include all the items in NUREG-0654, Sections II.E.3 and II.E.4, if availabl This item is closed, /85007-02 (Closed) Discrepancy between Emergency Plan and Emergency Plan Procedures Regarding SPING The Plan and the Procedures have been revised so that the EALs regarding Radiological Effluent Releases read the same in both documents for SPING Annunciator C5-1. This item is close /85007-03 (Closed) Additional Staff Needed in Health and Safety

Related Training A Licensed Senior Operator (LS0) has been permanently assigned to assist the Health and Safety Supervisor as a Training Specialis This item is closed.

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3 /85007-05 (0 pen) Technique and Hardware for PASS Must Be Upgraded The equipment and the procedure for obtaining a post accident sample has been upgraded. This item will remain open until the next emergency preparedness exercise when its use can be demonstrated, /85008-01 (0 pen) Initial Notifications to Offsite Agencies Took Longer Than 15 Minutes In the Exercise of June 25, 1985, the initial notifications to offsite agencies for Alert and Site Area Emergency declarations each took longer than 15 minutes. Additional training has been given and Appendix H to EPP-2 was revised June 1986. This item will be observed during the licensee's next exercis /85008-02 (0 pen) Necessity to Inform Offsite Agencies on Whether a Release is in Progress During an Emergency During the Exercise of June 25, 1985, the initial notification to offsite agencies for the Site Area Emergency did not state whether a release was in progress, as required by the Emergency Pla This has been resolved by revising EPP-2, Appendix H and by specific additional training. This item will remain open until satisfactorily demonstrated during the next exercis . Licensee Emergency Response Activations Activations Listed as Open Items: 409/850XX-01, and 409/850XX-02 (Closed)

Unusual Events declared April 21, 1985 and October 22, 1985, were examined and determined to be properly classified and notifications made in a timely manner. These items are close Other Licensee Activations Other activations of the Emergency Plan since the last inspection were evaluated. A check of the Shift Supervisors' log was made in relation to actual and possible emergency response activation With the exception of the activation described below, the results of the inspection were satisfactory, July 19, 1986 Unusual Event On the morning of July 19, Saturday, the plant was shut down and in Mode-4, which is defined as temperature less than (or equal to)

212 F and zero power. Actual temperature at 0500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> was 117 In Mode-4, there is no Shift Technical Advisor on duty. At 0630 hours0.00729 days <br />0.175 hours <br />0.00104 weeks <br />2.39715e-4 months <br />, lightning struck the main transmission line adjacent to the plant, resulting in loss of offsite powe Diesel-generators automatically started and picked up all vital loads, as designe At 0642 hours0.00743 days <br />0.178 hours <br />0.00106 weeks <br />2.44281e-4 months <br />, offsite power was restored. At 0654 hours0.00757 days <br />0.182 hours <br />0.00108 weeks <br />2.48847e-4 months <br />, an Unusual Event was declared and NRC' headquarters was notifie .

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However, the decision was erroneously made that due to being in Mode-4, it was not necessary to make notifications to the States of Wisconsin and Minnesota and Vernon County (WI) and Houston County (MN).

On Monday morning, the normal complement of staff was present and it was recognized that any declaration of an emergency condition requires the notification of the appropriate states and counties; notifications were then made and completed by approximately 1118 hours0.0129 days <br />0.311 hours <br />0.00185 weeks <br />4.25399e-4 months <br />, July 21, 1986. This was an elapsed time of about fifty-two (52) hours after the declaration of Unusual Even Failure to make prompt notifications on the part of;LACBWR has been noted in the past, such as the Exercise of June 25, 1985, and the loss of offsite power Unusual Event of. July 16, 1984. In the present case, the LACBWR staff made immediate efforts to correct this problem and to avoid recurrence, such as circulating an

" Incident Report Form," making an immediate change in Procedure EPP-2, contacting all of the Shift Supervisors, et Based upon the evaluation of the above information, this violation is '

Severity Level IV. It will be tracked as Open Item No. 409/86008-01, 4. Emergency Detection and Classification (82201)

The inspectors reviewed LACBWR Emergency Action Levels (EAL's) in the LACBWR Emergency Plan, Table E-1, Revision 5, issued August 1984, and the LACBWR Emergency Plan Procedures (EPP's) in EPP-1, Issue 11, dated December 26, 1985. It was noted that the EALs were not numbered for ease of identification. Also, neither the Plan nor the Procedures specifically addressed the requirement of 10 CFR 50.72 (a)(ii)(3)

regarding notification of NRC immediately after notifying State and Local authorities and not later than one hour following the event classification. Interviews revealed that operators were generally familiar only with the one hour requirement. Additionally, in Section 4.4 of EPP-2 (Site Area Emergency), and in Section 4.5 of EPP-2 (General Emergency), there are fourteen and thirteen steps in the checklist, respectively, between the steps requiring State / Local notification and the steps requiring NRC notificatio It was noted the the Plan appropriately specifies a 30 minute goal to achieve accountability as addressed in NUREG-0654, II.J.5. However, the EPP's did not address this issue and our interviews substantiated that this 30 minute time frame was not generally understood. Incident to the interviews it was noted that a radiological check point should be located outside the hallway accessing the Control Room (CR) and the Technical Support Center (TSC) during an emergency. Such a frisking station would guard against possible contamination of the CR and/or TSC by persons entering from outside the building under classifications of Alert and highe i

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Walkthroughs substantiated that, in general, operators were able to use the EAL's to arrive at correct event classifications. However, there were several instances during the walkthroughs where an EAL was selected and therefore the EAL search was terminated, when in fact, a more appropriate EAL existed farther along. Similarly, EAL's which involved release rates or release concentrations for varying time periods (and which only specified the minimum time period) could create some confusion in that an operator might tend to stop too soon rather than looking farther on for a closer fit at a higher emergency classification. Also, operators interviewed were familiar with the three fission product barriers, but appeared to have had very little understanding of the correlation between the loss of one, two, or three barriers and the Alert, Site Area Emergency, and General Emergency classifications, respectivel As a result of the walkthroughs, the following items should be considered for improvement:

• Include in the Plan and Procedures, where appropriate, the wording of 10 CFR 50.72 (a)(ii)(3) regarding notification of the NR * Number the EAL's in the Plan and in EPP-1 for ease of reference and communicatio * In Sections 4.4 and 4.5 of EPP-2, relocate the step regarding NRC notification to earlier in the procedure, in consonance with the intent of 10 CFR 50.72 (a)(ii)(3).

• Revise the EPP's as appropriate to reflect the 30 minute goal to achieve accountabilit * Provide for an HP frisking station outside the hallway entrance to the Control Rooc and the TSC, to be established when the TSC is activate * Document the annual review / concurrence of EAL's by offsite authorities with letters from those authorities, rather than in-house memos to fil * Emphasize in EP training that operators using EAL's should not stop at the first apparent EAL for a classification, but should proceed until the user is assured he has found the most applicable EA * Emphasize in EP training the relationship between loss (or threat)

of one, two, and/or three fissioq product barriers to the classifications of Alert, Site Area Emergency, and General Emergency, respectivel . Protective Action Decisionmaking (82202)

The inspectors reviewed the Emergency Plan and the Emergency Plan Procedures and conducted interviews /walkthroughs with key personnel from five operations shifts and with other plant personnel assigned Emergency Response Organization positions in the Technical Support Center (TSC) and

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the Emergency Operations Facility (EOF). The Shift Supervisor, in his capacity as initial Emergency Control Director (ECD), was responsible on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis for protective action decisionmaking until relieved by the ECD in the TSC or the EOF. The responsibilities of the ECD, including those responsibilities which may not be delegated, were clearly stated in the Emergency Plan and Procedures, and were found to be generally understood by the personnel interviewed. The responsibilities for protective action decisionmaking were adequately supported in the

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Procedures. Dose rates and dose projections were made using a computerized dose assessment program and were backed up by a hand-held calculator metho Several of the operator groups interviewed experienced some initial difficulty in providing a protective action recommendation under the

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situation of a core melt sequence, General Emergency, where no release had yet taken place. However, when they went to the procedure for initial notification for General Emergency, or to the Protective Action Guideline flow chart, they were able to make the proper recommendation Based on the above review, the following is recommended for improvement:

• Upgrade the training program to increase the understanding on the part of ECDs, especially Shift Supervisors who are the initial ECDs, regarding the reason for Protective Action Recommendations under a General Emergency, even prior to a release, and the relationship between the loss (or threat of loss) of one, two, or three fission product barriers and the Alert, Site Area Emergency, and General Emergenc . Notifications and Communications (82203)

The inspectors reviewed the licensee's notification procedures in EPP-2, Issue 27, dated June 26, 1986, and determined that, with the exceptions noted, they were generally adequate to ensure the alerting, notifying, and activation of emergency response personnel as necessary for each emergency classificatio Communications equipment in the emergency response facilities was deemed to be adequat The inspector verified that the following communications tests were being conducted as specified in the Emergency Plan and the Emergency Plan Procedures: monthly tests of the LACBWR PABX, microwave network, radio, ENS red phone, and NAWAS; siren monthly silent test, quarterly growl test, and annual full operational test; and testing of the alert notification radio LACBWR is considering adding an FM station to the present AM station on the alert notification radios in order to improve reception in some of the valleys in Wisconsi . . - - . . - - - - - _ _ - - _ _ _ - - . - - -

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A. review of Section 2.2 of the Emergency Plan against the Evaluation Criteria of NUREG-0654, Part II.E.3 and 4, indicated item by item agreement. However, the form provided in EPP-2 for followup messages to offsite agencies (EPP-2, Page 60), failed to specifically address several of the items listed in NUREG-0654 and in the Emergency Plan. .These were: Location of incident and name of calle Chemical and physical form of released material, et Actual or projected dose rates at site boundar Projected dose rates and integrated dose at about 1, 2, 3 and 5 miles, including sector (s) affecte Estimates of any surface radioactive contamination in the plant, onsite or offsit Emergency response actions underwa It-was'noted that neither the Plan nor the Procedures specified a periodicity for submission of followup messages to offsite authoritie Operator interviews indicated that followups would probably be sent only when a classification was escalated or deescalated, or vital plant conditions change Emergency Plan Procedure No. 2, Page 20, Step 4.5.1, under General Emergency departs from the wording of the corresponding steps for Unusual Event (Step 4.2.2), Alert (Step 4.3.1), and Site Area Emergency (Step 4.4.1). The latter three emergencies merely direct the user to Appendix H; whereas for the General Emergency, guidance is provided within the step which must be remembered when going to Appendix H and the direction to Appendix H is somewhat vague. Additionally, the Appendix H sections for both Site Area Emergency and General Emergency require amplifying information which would be less error prone if the required information were formatted similar to the followup message for It was also noted that the Appendix H form did not provide a space to enter the date of the even Based on the above review the following open item must be addressed:

• Establish a periodicity for submission of followup status reports when no other changes have occurre This will be tracked as Open Item No. 409/86008-0 In addition, the following items should be considered for improvement:

• Revise the notification followup message form (Table 1 of EPP-2)

to include provisions for all of the information specified in the Emergency Pla * Revise the wording of 4.5.1 of EPP-2 to parallel the wording of 4.4.1, 4.3.1, and 4. Revise the General Emergency portion of Appendix H of EPP-2 to include the information/ direction now contained in 4. .

• Provide a format for documenting the information provided under Site Area Emergency and General Emergency in Appendix H to EPP-2 which is event unique (brief description, release information, population / area affected and any protective action recommendations). Changes to the Emergency Preparedness Program (82204)

The Emergency Plan must be reviewed annually per Section 3.3 of Chapter F of the Plan. The latest version of the plan was dated November 1985, and was properly reviewed. The inspector reviewed documentation to ensure that the Emergency Plan Procedures (EPPs) were being adequately reviewed and approved. The Administrative Control Procedure (ACP 07.1) requires the EPPs to be reviewed and updated at least every two years. All of the EPPs have been properly reviewed and update This module also includes inventories and drills. The inspector made a spot check of inventories of emergency kits. Although the licensee had made a check of the various emergency kits every quarter as specified in the Emergency Plant at F-4.1, the inventories were not carried out in an acceptable manner. Specifically, the inventorying of the emergency kits in the Control Room, the TSC, and the " ESP Laboratory" were documented on a single sheet, the informal " Routine Job Tickler," in the Health and Safety Supervisor's office. The problem with these inventories was: (a)

there was only a single column to document completion, so that one set of initials-indicated that all three inventories had been done; (b) there was no place to indicate that an operability check had been successfully done; (c) there was no list of the contents of the emergency kits in the

" Tickler Notebook"; and, (d) there was no list of the required contents of the emergency kits posted at the kits' locatio The inspector also reviewed the inventorying of the emergency kits at i Vernon and Lacrosse Lutheran Hospitals. The following entries were observed on the Routine Job Tickler:

" January 21, 1986, Lutheran Hospital needs three pairs disposable paper coveralls, surgical masks, and surgical glove Vernon Memorial Hospital needs ten caps, three 30 gallon clear plastic bags and one plastic roll."

" April 4, 1986, Vernon Memorial is missing many item A bag of equipment will be prepared and taken to Hospital."

" July 15, 1986, Lutheran Hospital and Vernon need replenishing as stated above."

The items that were missing for these three quarterly inventories had not f been replenished and also, contrary to the Emergency Plan, the Health and Safety Suoervisor had not been informed of the discrepancies that had been j found.

! Based upon the evaluation of the above information, the failure to replenish the emergency kits at Vernon and Lacrosse Lutheran Hospitals is a violation,

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Severity Level IV. It will be tracked as Open Item No. 409/86008-03.

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8. Shift Staffing and Augmentation (82205)

The numbers of personnel required for shift staffing and their functional capabilities are contained in Table A-1 of the Emergency. Plan. The NRC has approved these shift staffing levels. The inspectors verified that an administrative system is in pl, ace to augment offshift personnel as needed. EPP-2 specified the emergency organization positions which must be filled and Appendices B and C contained the list of primary personnel to staff the TSC and EOF, while Appendix D listed supplemental E0F personnel, Appendix E the JPIC personnel, and Appendix G listed additional plant personnel for operations and radiological suppor EPP-3, Page 10, Issue 11, showed the requirements for the semiannual shift augmentation drill. The augmentation drills were done by telephoning the listed personnel and asking for an estimate of how soon they could reach the plant. These drills were performed on December 10, 1984; June 22, 1985; December 5, 1986; and June 14, 1986. All of the results were satisfactor Based on the above review, this portion of the licensee's program is acceptabl . Knowledge and Performance of Duties (Training) (82206)

Walkthroughs were conducted with five teams consisting of Shift Supervisor plus Shift Technical Advisor; additional walkthroughs were done with individuals who had been trained as Emergency Control Director, Cooperative Operations Parameters Director, In-Field Radio 7ogical Assessment Director, Operations and Radiological Parameters Communicators, and others. The inspectors determined that these teams and individuals could perform their respective duties during an emergency situatio The inspectors reviewed the licensee's traini.ng program regarding emergency preparednes Emergency Plan Procedure 14 addresses trainin Training records for all Licensed Senior Operators (LS0s),

Licensed Operators, and other operations personnel are kept by the Assistant to the Operations / Training Supervisor. All LS0s, whether or not they are assigned as Shift Supervisors, are required to stand at least one daytime shif t as SS, every quarte Hence, any LSO could be the initial Emergency Control Directo Emergency Preparedness training records for other personnel are kept by the Emergency Preparedness Coordinato A check of the training records in both the Operations office and the Emergency Preparedness office were inspected for the key positions including Emergency Control Director, Emergency Response Director, Operations Parameters Directors, Radiological Assessment Director The inspector noted that the training " status board" in the office of the Assistant to the Operations / Training Supervisor was set up for calendar year, and cid not have any dates of completion. Therefore, the individual training records were reviewed to determine whether the annual training requirement of the Emergency Plan was being me Regarding the emergency preparedness training / retraining for Licensed

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Senior Operators, four men had exceeded the twelve months, plus or minus 25%, that is stipulated in the Pla However, the Emergency Preparedness Coordinator's records for three of these men showed that they had received emergency preparedness training including ECD and ERD training, within the last twelve month The fourth man; however, had been trained in his normal emergency response position of Onsite Radiological Assessment Director (RAD), but not as ECD or ERD. Since he was an LSO, he should have been trained within the last twglve_ months for that key position, as wel In addition, the classroom training records for a non-licensed man who is listed as a possible ECD (EPP-2, Page 51, Issue 27) could not be foun The following open item must be addressed to achieve an acceptable program:

Emergency Preparedness training records must be complete and current, especially for key personnel such as ECD, ERD, and LS This will be tracked as Open Item No. 409/86008-0 . Licensee Audits (82210)

A review was made of the licensee's most recent audit report (Audit 70-85-2) dated November 15, 1985. The previous audit was conducted during October 1984, which was sufficient to meet the 10 CFR 50.54(t) requirement to conduct a review of the emergency preparedness program at least every 12 months. The audit was performed by Quality Assurance Department personnel who have no direct responsibility for implementation of the emergency preparedness progra The scope and depth of the audit was very good. The audit included examination of the Emergency Plan and Procedures, training, drills, equipment, interferes with state and county governments, and the resolution of previous audit finding Four items of nonconformance and eight open items were identified as a result of the audi Each of these 12 items were reviewed, with corrective actions specified in a letter from the Emergency Preparedness Coordinator to the Quality Assurance Supervisor dated December 20, 198 An examination of the corrective actions determined that they were appropriate and implemented in a timely manne The Plant Superintendent reviewed the audit findings and records are being retained for a minimum of five years as required. The audit of the interface with State and county government was made available to the Based on the above review, this portion of the licensee's program is acceptabl . Exit Maeting The inspectors met with licensee representatives (denoted in Paragraph 1)

at the conclusion of the inspection on August 8, 1986. The inspectors summarized the scope and findings of the inspection, including the possible violations and open items. The inspectors also discussed the content of forthcoming report to determine if the licensee thought any of the information was proprietary. The licensee responded that none of the information should be proprietar