ML20059G613

Responds to Re Violations Noted in Insp Rept 50-409/93-01 on 930903 & 22 & 24.Corrective Actions: Reassigned Mechanics & Instrument Technician to LACBWR Staff

ML20059G613
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	11/01/1993
From:	Berg W DAIRYLAND POWER COOPERATIVE
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LAC-13319, NUDOCS 9311080267
Download: ML20059G613 (3)

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0 DA/RYLAND i

[#/Nh[ _COpFERAT/VE. 3200 EAST AVE.SO.

• PO.BOXB17 LACROSSE. WISCONS (608) 788-4000 oVember }, M i

wiwAM L BERG cenerai uanager i

In reply, please refer to LAC-13319 DOCKET NO. 50-409 Document Control Desk U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:

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SUBJECT:

Dairyland Power Cooperative La Crosse Boiling Water T cactor (LACBWR)

Possession-Only License

o. DPR-45 l

Reply to Notice ofV _ don Identified in i

NRC Inspfctio:s i.eport No. 50-409/93001(DRSS)

REFERENCES:

(1) NRC Letter, Snell to Berg, dated October 6,1993, issuing Notice of Violation and Subject inspection Report (2) 10 CFR 2.201 Dairyland Power Cooperative (DPC) is providing the following information in response to the Notice of Violation identified in the letter of Reference 1. The violation reads as follows:

l During an NRC inspection conducted on September 3 and September 22-24,1993, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, i

Appendix C, the violation is listed below:

Section 6.2 " Organization and Responsibilities" of the La Crosse Boiling Water Reactor (LACBWR) Decommissioning Plan requires the organization of the l

SAFSTOR staff at LACBWR to have three mechanics and two instrument and control (I&C) technicians reporting to the Plant Afanager as indicated in Figure 6-1.

Contrary to the above, as of August 20,1993, only one mechanic and one I&C technician was assigned to the SAFSTOR staff at LACBWR reporting to the Plant Alanager.

This is Severity Level 1V violation (Supplement IV).

j U:l 9311080267 931101

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{DR ADOCK 05000409 PDR-

.,; e NRC Document Control Desk Page 2

~ LAC-13319

. November 1,1993 DPC RESPON_SE Pursuant to the requirements of Reference 2, and in answer to the specific request for -

t information for the reason for violation, DPC provides the following response:

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Reason for Violation A reorganizing and down-sizing efron is currently underway at DPC. Included in this reorganization was a Special Retirement Program (SRP) allowing for an attractive early retirement settlement for eligible employees. Until this program was implemented, the LACBWR staff was in compliance with the minimum staff requirements of the Decommissioning Plan. When it became apparent that the number of personnel taking advantage of the SRP would leave LACBWR with less than the required complement of employees in two of the areas specified in the Decommissioning Plan, discussions were begun concerning how the minimum stafling requirements would be met. There was some confusion and disagreement on how to interpret the requirements of 10 CFR 50 and the Decommissioning Plan. A management decision was finally reached that allowed for supplementing the LACBWR work force with personnel from the fossil fueled plant that shares the site with LACBWR. These personnel were to be made available as needed but

.were not to be permanently assigned to the LACBWR staff. Some of those personnel had had previous experience at LACBWR.

Our intemal review indicated that the stafling changes were not significant enough to require prior NRC approval; therefore, a Safety Analysis was not performed on these changes.

2.

Corrective Steps that aave been taken and Results Achieved On Monday, September 27,1993 (the Monday following the NRC safety inspection), two mechanics from the fossil plant were reassigned to the LACBWR staff. These two mechanics had both been previously assigned to LACBWR for a number ofyears. They had each participated in the training program and had made significant progress toward being a fully qualified mechanic. Also, an instrument technician from the fossil plant was reassigned to LACBWR. This technician had previously been assigned to LACBWR and had achieved full qualification status.

3.

Corrective Steps that will be taken to Avoid Further Violation Any future personnel changes at LACBWR will be discussed at an Operations Review Committee meeting and a Safety Analysis will be performed and documented. Any personnel change (s) that could decrease the effectiveness of operating or maintaining the plant will be submitted to the NRC for approval prior to implementation.

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-NRC Document Control Dcsk Page 3 LAC-13319 November 1,1993

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l The Quality Assurance Department will increase its involvement in routine LACBWR h

activities. They will also increase surveillance on LACBWR to ensure requirements are j

bemg met.

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Date when Full Compliance will be achieved -

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DPC returned to full compliance on Monday, September 27,1993.

j Ifyou have any questions concerning this response, please call John Parkyn, LACBWR i

Plant Manager at (608) 689-2331.

Sincerely, DAIRYLAND POWER COOPERATIVE (J) W (

William L. Berg, Gerral 3.1anager WLB: REC:dh I

i cc:

John Martin, Regional Administrator U. S. Nuclear Regulatory Commission, Region III Glen Ellyn,IL 60137 Larry Pittiglio, Project Manager j

Division of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission l

Washington, DC 20555 l

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