IR 05000409/1982008
| ML20055A698 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 06/29/1982 |
| From: | Greger L, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20055A695 | List: |
| References | |
| 50-409-82-08, 50-409-82-8, NUDOCS 8207190345 | |
| Download: ML20055A698 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-409/82-08(DETP)
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: Lacrosse Boiling Water Reactor Site, Genoa, WI Inspection Conducted:
94-28, 1982 J
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Inspector:
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Approved By:
L. R. Greger, Chief b 2 9, /f<81 Facilities Radiation
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Protection Section Inspection Summary
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Inspection on May 24-28, 1952 (Report No. 50-409/82-08(DETP))
Areas Inspected: Routine, unannounced inspection of operational radiation protection and refueling activities, including: effluent control instrumen-tation, testing of air cleaning systems, radiation protection procedures, advance planning and preparation, exposure control, training, posting and control, and licensee actions taken in response to previous inspection findings. The inspection involved 39 inspector-hours onsite by one NRC inspector.
Results: No items of noncompliance were identified.
8207190345 820701 PDR ADOCK 05000409 G
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DETAILS 1.
Persons Contacted
- L. Nelson, Radiation Protection Engineering Assistant
- P. Shafer, Radiation Protection Engineer
- R. Shimshak, Plant Superintendent
- B. Zibung, Health and Safety Engineer M. Branch, NRC Senior Resident Inspector The inspector also contacted other licensee employees.
- Denotes those present at exit interview.
2.
General This inspection, which began at 11:30 a.m. on April 24, 1982, was con-ducted to examine the licensee's radiation protection activities during normal operations and associated with the current refueling outage. The inspection included several plant tours, review of licensee records and reports, discussion with licensee personnel, and observation of outage activities.
3.
Licensee Action on Previous Inspection Findings (Closed) Open Item (409/78-06-01 and 02): Concerns regarding cali-bration of offgas and liquid monitors, the bases for the stack particu-late monitor setpoints, and a discrepancy regarding the verification of the offgas trip function.
Health and Safety Procedures 02.4 (Revision 1)
and 02.7 (Revision 2) include the bases for monitor setpoints, verifi-cation of the offgas trip functions, and requirements for multipoint calibrations on the liquid and gaseous monitors.
(Closed) Open Item (409/79-13-02): Licensee to submit a report of gross alpha in excess of technical specification limits. Report submitted to Region III dated June 20, 1979.
(Closed) Open Item (409/79-24-01): Training required for personnel involved in processing, packaging, transfer, and transport of radio-active waste. The current technician training program includes instruction in waste disposal and waste disposal regulations.
(Closed) Open Item (409/80-10-03 and 81-18-01): Need to resolve weak-nesses concerning Health and Safety Procedures HSP's, adherence to procedures, and inconsistencies between procedures and actual practices.
An ongoing program for review, revision, and adherence to HSP's has been implemented by the licensee.
(Closed) Open Item (409/80-19-01): Upgrading of whole body counter calibrations and counting system, and improvements needed in the
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respiratory protection program. The licensee is committed to cali-brate and write calibration procedures for the present whole body counter system. The respiratory protection program has.been strength-ened and the purchasing of a small respiratory fit test booth is being considered.
(Closed) Open Item (409/77-08-01): Failure to discuss the provisions of 10 CFR 20.103 in annual retraining session to plant. workers.
Cur-rent retraining sessions include discussion of 10 CFR 20.103 require-ments, including the use of engineering controls and MPC-hour accounting.
These instructions will be incorporated into an HSP.
(Closed) Open Item (409/81-11-02 and 06): Commitment to rewrite emer-gency sample procedure and develop a training manual and implementing procedures. Emergency Sample Procedure (EPP 6) has been written and a health physics training manual is being developed.
4.
Organization and Staffing The current health physics staff consists of the Radiation Protection Engineer (RPE), the Assistant Radiation Protection Engineer (RPEA), the Health and Safety Supervisor (HSS), and six Health Physics Technicians (HPT). Three of the technicians are trainees. The licensee recently promoted an HPT into the position of RPEA.
Item 1.A.1.3.1 of TMI NUREG-0737, as amended by Generic Letter 82-02, recommended that licensees revise administrative procedures to limit the use of overtime. The licensee revised ACP 02.9 to establish plant policy to control the use of overtime.
ACP 02.9 allows the Plant Super-intendent to deviate from the overtime restriction with good cause.
During the current refueling outage, the plant was working the three qualified HPTs 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> a day, 6 days per week. Every third week one HPT was required to work 7 consecutive days, thereby exceeding the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> per week limit recommended by NRC.
This deviation from the overtime limits of ACP 02.9 was authorized by the Plant Superintendent because of the shortage of fully qualified HPTs. This practice was questioned by the inspector because there appeared to have been sufficient knowledge of the outage staffing requirements to hire additional health physics technicians. This matter was discussed at the exit interview. Accord-ing to the NRC resident inspector,-the HPTs, and other licensee personnel interviewed, the current work schedule has not adversely affected the HPTs job performance.
The RPEA position was developed to assist the RPE in the areas of training, procedure review, and technical support, thereby relieving some of the RPE's workload. However, the RPE continues to spend the majority of his time on emergency planning activities instead of admin-istration of the health physics program. Although this does not appear to have affected the health and safety function of the Health Physics Department to date, it has delayed planned improvements in the Health
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Physics Program in response to the Health Physics Appraisal. This matter was discussed at the exit interview.
5.
Training / Retraining-A selective review of training records for several station and non-station personnel involved in outage work indicated instructions were given commensurate with 10 CFR 19.12.
The general training program for persons frequenting restricted areas was raviewed. The training is conducted by the Health and Safety Department. The training material (described in ACP 21.1) is suffi-ciently comprehensive to ensure compliance with 10 CFR 19.12 require-ments. Currently, the licensee is not testing individuals who receive the general training. However, a testing program is scheduled to be implemented in the near future.
Annual radiological safety retraining is given all plant radiation workers. The course consists of current topics, emergency planning reviews, and other material related to health and safety. The lack of a procedure outlining the retraining content was discussed at the exit interview.
6.
Outage Planning / Preparation /ALARA Health physics personnel were involved in pre-outage reviews, were aware of the major radiation jobs in advance of the outage, and con-ducted ALARA pre-job and post-job reviews for the current outage.
Personal exposures for the outage appeared normal for outage activities.
During a previous inspection, the licensee committed to develop pro-cedures for implementing an ALARA program. Since then, several pro-cedures concerning ALARA have been developed which include specific job review and ALARA pre-job and post-job reviews.
In order for the licensee to fully meet their commitment to a formal ALARA program, they must develop a governing procedure which outlines the content of the ALARA program, and a method for dose accountability. This matter was discussed at the exit interview.
7.
Exposure Control - External
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l The licensee is continuing to compare gamma whole body exposures by double badging selected cmployees using different supplier TLD/ film
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badge dosimeters. During a previous inspection *, significant differ-
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ences were noted between the results of TLD and pencil dosimeters. As a result, the licensee agreed to correct personal monitoring records, starting January 1981, by assigning pencil dosimeter results to em-playees' permanent exposure records whenever pencil dosimeter results were in excess of 15 percent of the TLD results for the month. However, as more TLD/ film badge dose information became available, differences between the different dosimetry methods diminished. Based on this data,
' Inspection Report No. 50-409/81-19
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the licensee decided, with the inspector's concurrence, to delay cor-rection of the personal monitoring records until a more detailed review of the TLD, TLD/ film badge, and pencil dosimeter comparisons could be made. This matter was discussed at the exit interview.
A review of the licensee's whole body exposure records indicate the highest personal exposure in 1981 was 3.3 rems. The highest personal exposure for the first quarter 1982 was 1.6 rems.
The highest personal exposure for 1982 through May was less than 2 rems; this period included the major part of the current refueling outage.
No items of noncompliance were identified.
8.
Exposure Controls - Internal The licensee's program for controlling internal exposures this outage includes: the use of protective clothing, respirators and equipment, and control of surface and airborne radioactivity. A selected review of air samples, smear, and direct survey results was made. No signifi-cant problems were noted.
The whole body counter (WBC) and counting program is essentially the same
as described in the Health Physics Appraisal. The inspector observed whole body counting of two persons and selectively reviewed whole body count results for 1981 and 1982 through the current outage; no results exceeding the 40 MPC-hour control measure were noted.
The WBC has not been calibrated since 1978, nor are there any formal WBC calibration procedures. As was noted in the Health Physics Appraisal, calibration should be performed annually in accordance with recommenda-tions contained in ANSI N343-1978 (American National Standard for Inter-nal Dosimetry for Mixed Fission and Activation Products). These matters were discussed at the exit interview.
9.
Effluent Control Instrumentation Gaseous and liquid effluent monitoring system calibrations and functional tests were reviewed for compliance with technical specification require-ments for the period March 1979 through May 1982. The most recent monitor calibrations were conducted during the last refueling shutdown in Febru-ary 1981; calibrations are scheduled for the current outage. With the exception of the three offgas monitors, the calibrations are conducted with different sample concentrations using a three point correlation between specific concentration and monitor response. The governing pro-cedure for calibration of radiation monitors is HSP 02.7.
No problems were noted.
The offgas monitors are calibrated monthly as required by technical speci-fications. Grab samples are collected from positions downstream of each of the two holdup tanks and the HEPA and charcoal filters. The sam-ples are compared with the offgas monitors. Calibration for the off-
- Inspection Report No. 50-409/80-10
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gas monitors is described in HSP 06.16.
Records indicate the offgas system analysis has been accomplished monthly.
The current trip setpoints for the stack and offgas monitors were checked against the technical specification requirements; no problems were noted.
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10.
Containment Air Cleaning Systems Equipment used to remove radioactive iodine and particulates from air-borne effluents include a prefilter and HEPA filter in the containment building ventilation system and HEPA and charcoal filter banks down-stream of each of the two offgas tanks in the offgas system. The HEPA
and charcoal filters installed in the offgas system have not been
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changed since 1976 according to licensee records. -The licensee does not routinely inplace leak test the offgas system filters nor have they used the information obtained from the monthly offgas grab sam-ples to check filter efficiencies (described in HSP 06.16) since 1977.
The containment ventilation exhaust HEPA filters were changed on June 18, 1981.
Both the pref 11ter and HEPA filters on the containment ventila-tion system are changed when the differential pressure across the filters reaches a preset limit specified in a surveillance procedure; no routine
inplace leak test program is established.
The inspector expressed concern about the licensee's lack of a filter testing and maintenance program. This matter was discussed in the exit interview and subsequent telephone conversations between the inspector and the RPE.
11.
Posting and Controls A review of the licensee's posting and control of radiation areas, high radiation areas, airborne radioactivity areas, and contaminated areas was made. No discrepancies were noted.
12.
Independent Inspection - Obervations i
The inspector observed an individual smoking a cigarette after leaving the change room before washing or frisking himself. Although no spe-cific regulation prohibits this practice, good health physics practices prohibits smoking before adequate personal frisking is accomplished after exiting from a radiologically controlled area.
On several occasions the resident inspector has noted that workers do not stand in the portal monitor for ten seconds, as required by posted instructions.
Because the portal monitor has poor detection capability for low level amounts of radioactivity, it is incumbent on the license
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to ensure that personnel follow the posted instructions for the use of the portal monitor. This matter was discussed at the exit interview.
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13.
Exit Interview I
The inspector met with licensee representatives (denoted in Section 1)
at the conclusion of the inspection on May 28, 1982. The inspector
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summarized the scope and findings of'the inspection.
In response to
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certain items discussed by the inspector, the licensee:
a.
Stated that the refueling work schedule was restricted to fit the health physics technicians availability due to the health physics technician staffing shortage and acknowledged the comments con-corning the workload of the Radiation Protection Engineer.
(Sec-tion 4)
b.
Stated that a procedure will be developed to formalize the content and prescatation of the radiation protection retraining program.
The retraining will include information from Regulatory Guide 8.13, l
" Instructions Concerning Prenatal Radiation Exposure," for female
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persons.
(Section 5)
Stated that formal ALARA procedures would be completed by July 1982.
c.
(Section 6)
d.
Stated that upon completion of a review of personal dosimetry com-parisons, personal exposure records would be modified as necessary.
(Section 7)
Stated that the WBC will be calibrated, procedures for calibrating e.
the WBC will be developed, and persons with elevated organ burdens would be counted--more frequently.
(Section 8)
f.
Stated that the offgas filters would be changed as soon as replace-ments were available, and that procedure HSP 06.16.would be revised to incorporate the filter testing criteria recommended in Regulatory Guide 1.140, " Design, Testing, and Maintenance Criteria for Normal Ventilation Exhaust System Air Filtration and Absorption Units of Light-Water-Cooled Nuclear Power Plants." (Section 10)
g.
Agreed to review ways of correcting misuse of the portal monitor and stated detection efficiency tests of the monitor will be made.
(Section 12)
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