ML19350D501
| ML19350D501 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 01/06/1981 |
| From: | Linder F DAIRYLAND POWER COOPERATIVE |
| To: | Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19350D500 | List: |
| References | |
| LAC-7307, NUDOCS 8104160045 | |
| Download: ML19350D501 (6) | |
Text
.
O D DA/RYLAND h
[k COOPERAT/VE eo eOx ei7 2615 EAST AV south. t.A CAOSSE WISCO?.S *J 54601 46G8178BM January 6, 1981 In reply, please refer to LAC-7307 DOCKET NO. 50-409 Mr.
R.
F.
Heishman Chief, Reactor Operations and Nuclear Support Branch U.
S.
Nuclear Regulatory Commission Directorate of Regulatory Operations Region III 799 Roosevelt Road Glen Ellyn, IL 60137
SUBJECT:
DAIRYLAND POWER COOPERATIVE LA CROSSE BOILING WATER REACTOR (LACBWR)
PROVISIONAL OPERATING LICENSE NO. DPR-45 IE INSPECTION REPORT NO. 50-409/80-13
REFERENCES:
(1)
NRC Letter, Heishman to Linder, Dated December 12, 1980
Dear Mr. Heishman:
This letter constitutes the written statement required in reply to the October 1980 NRC Inspection Report (Reference 1) which we received December 22, 1980.
Appendix A,
listed two items of noncompliance.
ENFORCEMENT ITEMS Infraction:
1.
10 CPR 73.SS(b)(4) states, in part, "the licensee shall not permit an individual to act as a guard.
or armed response
. untese individual has been trained.
. and i
person qualified to perform such.
duty.
the licensee shalt denonstrate the ability of... escurity personnet The security plan in Section 1.4.1 states, in part, "the criteria provided in Regulatory Guide 5.20(2) have been foltoued.
(2) obere the term should and may are used in the guide, these terme are interpreted to mean shall and uitt."
JNA 9 g,$0b -
810 41600Vd[
1 Mr.
R. F. Heishman Chief, Reactor Operations and LAC-7307 Nuclear Support Branch January 6, 1981 The security plan in Section 1.4.4 etates, in part, "the criteria provided in Regulatory Guide 5.20(2) have been foltoued oith the foltooing exceptione:
(3) testing and requalification, items (b) (c) - frequency once every 6 months to once every 12 monthe."
Regulatory Guide 5.20, Appendix C, states for the "Short Couree" that "guarde must achieve a minimum point total of 1 75 Contrary to the above, during the midnight shift on October 22, 1980, one individual vae permitted to act as a guard, who had demonstrated his inability to meet the minimum firearme acore tieted in Regulatory Guide 5.20.
The individual fired for requalification on the afternoon of October 21, 1980, and achieved a score of tees than 175.
(Note:
the qualification vae given at this time, approximately tuo monthe early in order to finish qualifying during good oeather).
The individual oas permitted to perform duties as a search officer, monitor, and security base guard which required carrying and the use of a firea-m should the need arise.
DPC RESPONSE i
Corrective Action Taken and Results Achieved The corrective action taken for this item was to place the individ ual in a position where performance of his duties did not require use of a firearm until he requalified.
The individual in question did requalify on his next trip to the firing range on October 29, 1980.
The earlier qualification was due to expire February 8, 1981.
Correqtive Action Taken to Avoid Further Noncompliance Henceforth, any previously-qualified guard failing to requalify shall be reassigned to a position that does not require use of a firearm.
Date Full Compliance Achieved October 29, 1980.
l t
t
/
Mr. R. F. Heishman Chief, Reactor Operations and LAC-7307 Nuclear Support Branch January 6, 1981 ENFORCEMENT ITEM Infraction:
2.
Technical Specification 3.8.1 states, in parb, " Written procedures and administrative policies shati be established, implemented, and maintained.
Contrary to the above are the foltouing examples of noncompliance uith this requirement:
a.
LACBWR Administrative Control Procedure ( A CP) Paragraph 4.1.2.3 states, in part, "LACBWR Shif_t_ Supervisor.
is responsible for routinety touring tha entire plant area for evidence of normat and unusual activities as conditione permit."
Contrary to the above, a revieu of the LACBWR records of personnet e ite from the reastor containment on October 8, 9,
1.
16, 21, and 22, 1980, ir.dicate that of ten shifts reviewed, there vere no tours of the :ontainment performed by the Shift Supervisors.
b.
LACBWR Administrative Control Procedure ( A CP) 2.4 states, in part, "The purposo of this procedure is to establish the requirement for LACEVR management to conduct backshift and veekend inepections of the reactor.
This procedure applies to those personnel designated as Shift Technical Advisore "A t t Shif t Technical Advisore shalt make random backshift inspectione of the plant facilities to monitor and assess operatione Contrary to the above, a revieu of the LACBWR records of personnet exite fron the reactor containment on October 8, 9,
i 15, 16, 21, and 22, 1980, indicate that of the eight shifta revieued, there vere no tours of the containment performed by the Shift Technical Advisore.
DPC RESPONSE Corrective Action Taken and Results Achieved a.
The paragraph of LACBWR ACP-2. 3, which addresses the responsibility of the Shift Supervisor to tour the plant is actually Section 4.1.4 rather than 4.1.2.3..__. - _
e Mr. R. F. Heishman Chief, Reactor Operations and LAC-7307 Nuclear Support Branch January 6, 1981 It was not the intent, nor was it specifically stated in ACP-2. 3 that a LACBWR Shif t Supervisor must make a tour of every portion of the entire plant area every shift.
The auxiliary operator, who is under the direct supervision of the Shift Supervisor tours the facility twice per shift and reports any unusual activities to the Shift Supervisor.
The general conclusion recited on Page 4 of Reference (1) that tours of equipment areas are not being conducted at the required frequency is in our opinion not sufficiently supported.
The ACP language addressed:
routinely touring the entire plant
. as conditions permit."
In our opinion this statement did not demand a full and complete tour each shift, but created the general policy for the Shift Supervisor to oe aware of plant conditions through first-hand observation as work activities permitted.
The need to tour the entire plant each shif t as implied by the subject report would have required the Shift Supervisor to tour all out-buildings, the site, and other equipment areas external to the plant each shift.
This would not be practical.
Since frequent contain-ment entry at most operating U.S. nuclear power plants is not accomplished during plant operations, the importance of this enforcement observation to nuclear safety is not fully under-stood by the licensee.
Nevertheless, a review of the LACBWR records of personnel entrances / exits from the Turbine Building and the Containment Buildina on October 8, 15, 16, 21, and 22 showed that on October 8, two Shift Supervisors, one of whom was the Duty Shift Supervisor, were in the Turbine Building.
The Shif t Supervisor, who was not the Duty Shift Supervisor, also was in the Containment Building.
Though he did not have the watch that day, his position as a Shift Supervisor qualified him to perform any duties that procedures require of a LACBWR Shif t Supervisor.
On October 15, five entries were made by a Duty Shift Supervisor into the Turbine Building.
On October 16, a Duty Shif t Supervisor exited the Turbine Building four times.
On October 21, five entries were made by a Duty Shift Supervisor into the Turbine Building.
On October 22, three Duty Shift Supervisors and the Operations Supervisor were in the Turbine Building.
One of the Duty Shift Supervisors was also in the Containment Building.
These records of personnel exits from areas of the plant show that Shift Supervisors are entering the plant routinely.
b.
ACP-2.4 does not require Shif t Technical Advisors to tour the containment every shift.
As quoted above, the procedure requires that " All Shif t Technical Advisors shall make random backshift and weekend inspections of the plant facilities to monitor and assess operation."
9 Mr.
R.
F.
Heishman Chief, Reactor Operations and LAC-7307 Nuclear Support Branch January 6, 1981 The procedure requires that random inspections be made.
In our opinion and consistent with our understanding of the definition of the work random to imply:
" A lack of direction, rule, or method.
Done without aim or purpose; left to chance; fortuitous," a requirement for random inspections does not necessitate that such inspections be conducted every shif t or on any scheduled basis.
A review of LACBWR records of personnel entrances / exits f rom the Turbine Building and Containment Building on October 8, 15, 16, 21, and 22, showed that on October 8, three Shift Technical Advisors ( S TA 's ) were in the Turbine Building, two of whom were in the Containment.
These STA's were not the duty STA, but as Shif t Technical Advisors were definitely qualified to monitor and assess operations, as required above.
On October 15, three STA's exited the Turbine Building, one of whom was in the Containment Building also.
On October 16, one STA was in the Turbine Building and Containment Building.
On October 21, five STA's were in the Turbine Building, one of whom had the duty for the day.
He and one other STA were also in the Containment Building.
On October 22, again five STA's were in the Turbine Building.
Three STA's were also in the Containment Building.
On all six days involved, the duty STA had initialled the Shift Supervisor's Log Book.
The re fo re, all STA's had been in the Control Room on their duty days.
Based on this review of records, it cannot logically be concluded that STA's are not making random inspections of the plant facilities to monitor and assess operations.
Corrective Action Taken to Avoid Further Noncompliance In order to prevent future misunderstanding from occurring, ACP-2.3, Section 4.1.4, has been changed to eliminate the misinter-pretted, possibly ambiguous wording.
It now reads:
"He may make visual inspections of the facility to ensure that the facility is maintained in a safe operating condition."
ACP-2.4 has been revised to clarify that the STA inspections are to be random in nature.
The purpose now reads:
"The purpose of this procedure is to establish the require-ment for LACBWR management to conduct random backshif t and weekend inspections." _ _ _ _ _ _ __
J Mr.
R.
F. Heishman Chief, Reactor Operations and LAC-7307 Nuclear Support Branch January 6, 1981 Hopefully, this change will eliminate future misinterpretations.
Date Full Compliance Achieved The sections of ACP-2.3 and 2.4 quoted were not violated as discussed under " Corrective Action Taken and Results Achieved."
If you have any questions, please contact us.
Very truly yours, i
DAIRYLAND POWER COOPERATIVE
.w (
'.s Frank Linder, General Manager FL: LSG: abs CC:
NRC Office of Inspection and Enforcement Ditision of Reactor Operations Inspection
.s, Washington, D.
C.
20555 3;
Resident Inspectors STATE OF WISCONSIN )
)
COUNTY OF LA CROSSE)
Personally came before me this b 27 day of January, 1981, the above named Frank Linder, to me knren to be the person who executed the foregoing instrument and acknowledged the same.
b Notary Publip, La Crosse County, Wisconsin.j/
My Commission Expires 2/26/84.
l l.