IR 05000409/1985015

Insp Rept 50-409/85-15 on 850916-20.Violation Noted:Failure to Maintain Whole Body Dose Records Per NRC-5 Instructions

ML20133C637
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	10/02/1985
From:	Greger L, Miller D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20133C623	List: IR 05000409/1985015 ML20133C620 ML20133C626
References
50-409-85-15, NUDOCS 8510070472
Download: ML20133C637 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION III

Report No. 50-409/85015(DRSS)

Docket No. 50-409 License No. DPR-45 l

Licensee: Dairyland Power Cooperative 2615 East Avenue - South Lacrosse, Wisconsin 54601 Facility Name: Lacrosse Boiling Water Reactor Inspection At: Lacrosse Boiling Water Site, Genoa, Wisconsin Inspection Conducted: September 16-20, 1985 h 8. A1l&

-Inspector: D. E. Miller /c - a - ##

Date Approved.By: L ief /d/2/Ef Facilities Radiation Protection Section Date Inspection Summary Inspection on September 16-20, 1985 (Report No. 50-409/85015(DRSS)) ,

Areas Inspected: Routine, unannounced inspection of the operational radiation protection program, including: organization and management controls, training, internal and external exposure controls, contamination controls, ALARA, and audits. Also reviewed was previous inspection findings, IE Information Notices, and the planned low level solid radwaste storage facility. The inspection involved 34 inspector-hours onsite by one NRC inspecto Results: One violation was identified (failure to maintain whole body dose records in accordance with requirements - Section 6).

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8510070472 851002 PDR G ADOCK 05000409 PDR

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l DETAILS 1. Persons Contacted

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R. Cota, Training Specialist L. Kelly, Assistant to Operations Supervisor and Training

• L. Nelson, Health and Safety Supervisor J. Parkyn, Plant Superintendent

• P. Shafer, Radiation Safety Engineer

• R. Wery, Quality Assurance Supervisor

• I. Villalva, NRC Senior Resident Inspector The inspector also contacted other licensee employee * Denotes those present at the exit meetin . General This inspection, which began at 12:00 noon on September 16, 1985, was conducted to examine the licensee's operational radiation protection program. The inspection included organization and management controls, exposure and contamination controls, and ALARA. Also reviewed were past inspection findings, selected IE Information Notices, and the planned low level solid radwaste storage facility. Several plant tours were made; posting and labeling, contamination controls, housekeeping, and general cleanliness appeared good. One violation concerning maintenance of personal whole body dose records was identifie . Licensee Action on Previous Inspection Findings (Closed) Open Item (409/84-08-07): Compliance with Clarification Item 4(b) of NUREG-0737 Task Action Item II.F.1.1.B.2. The licensee has expanded the established graphs / charts to convert monitor response to release rates with time post-accident; the revised graphs / charts appear to meet the intent of the Clarification Ite (Closed) Open Item (409/85005-01): Results of dosimeter comparison stud The licensee's study indicated that the TLDs were neutron sensitive and therefore read conservatively high for some personnel. The difference between TLD and film badge indicated responses fell within a reasonable error band. The licensee concluded that no corrections to official dose records were justified. The inspector agrees with the study conclusions and the licensee's decision not to alter the official dose record (0 pen) Open Item (409/84-08-08 and 409/85005-02): Concerning request for deviation from monitor readout requirements, design basis shielding requirements, and station requirements for use of SA-9 monitor. The licensee has corresponded with NRR concerning these NUREG-0737 Task Action Item II.F.1.1 and II.F.1.2 requirements. Because of reassignment of the NRR Project Manager, a delay has been encountered in resolution of these-2-

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matter The licensee stated that all pertinent data would be assembled and a comprehensive request for deviation would be resubmitted; and that the resubmittal would include answers to NRR questions posed since the original submittals were made. The licensee set a target date of October 31, 1985, for resubmitta . Organization, Qualifications, and Management Controls The inspector reviewed the licensee's organization and management controls for the radiation protection program including changes in the organizational structure and staffing, effectiveness of procedures and other management techniques used to implement these programs, experience concerning self-identification and correction of program implementation weaknesses, and effectiveness of audits of these programs. Audits are discussed in Section 1 The licensee's organization and management controls remain as described in Inspection Report No. 409/85005 except for the following change * R. Cota, a former shift supervisor, has been reassigned to a new Training Specialist position reporting to the Health and Safety Superviso * The two Health Physics Technicians (HPTs) that were in training status are now qualified in accordance with ANSI N18.1-1971, and are assigned to shift rotation. The seven technicians are now all shift qualifie In general, the radiation protection staff appears to adequately support the radiation protection and ALARA program The qualifications and performance level of the HPTs and professional staff is generally sufficient. The licensee does not use health physics contractors to supplement the radiation protection staf Because inspector identified problems with vendor dose records (Section 6)

and film badge spiking results (Section 6) were apparent, it seems that licensee oversight and review of such programs should be enhanced to increase the probability for self-identification. This matter was discussed at the exit meetin No violations or deviations were identifie . Training The inspector reviewed the training and qualifications aspects of the licensee's radiation protection, radwaste, and transportation programs, including: changes in responsibilities, policies, goals, programs, and method Also reviewed was management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesses. Audits are discussed in Section 1 L

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The HPT retraining is being performed in accordance with HSP 8.2, "LACBWR Health Physics Technician Retraining Program." The training subjects include waste disposal, emergency plan, radiation protection, radio ~

environmental program, and chemistry program, and is to be successfully completed annually. Training files are maintaine The training program is not formalize The licensee is developing formal training / retraining outlines for all training done at the statio The licensee plans to seek INP0 accreditatio No violations or deviations were identifie . Externa'l Exposure Control and Personal Dosimetry The inspector reviewed the licensee's external exposure control and personal dosimetry programs, including: changes in facilities, equipment, personnel, and procedures; adequacy of the dosimetry program to meet routine needs; required records, reports, and notifications; effectiveness of management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesse Audits are discussed in Section 1 Previous Inspection Reports No. 50-409/81-19, 50-409/84-08, and 50-409/85005 describe a possible problem with differences in TLD and pocket dosimeter results and a comparison study to investigate these problem This matter is discussed in Section There have been no significant changes in the licensee's exposure measurement and control program. The inspector selectively reviewed exposure records for 1984 and 1985 to date. The records indicate that the highest personal dose in 1984 was 4800 millirems and the highest for 1985 through July was 2910 millirems. Total occupational external dose for the station in 1984 was 240 person-rems; total dose to 1985 through September 3, 1985, was 138 person-rem During review of vendor film badge records, which the licensee considered the official record, the inspector noted that the lifetime dose numbers for mechanical maintenance personnel were in error from March 1984 through the most recent film badge results; also, the year to date numbers for those persons in 1984 were in error beginning in March 1984. This is considered a violation of 10 CFR 20.401 requirements (violation 409/85015-01).

There was no indication that the error resulted in violation of 10 CFR 20.101 dose limit After being informed of the errors, the licensee began an extensive review of the vendor's records and computerized dose summaries which are maintained by the licensee. The licensee discovered that the recorded lifetime doses for all permanent personnel were in error. The errors began during a period when station employees were wearing both TLDs and-4-L

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film badges; a study was being performed to investigate identified problems with relative error between TLDs and pocket dosimeters; during this period the licensee was conservatively choosing the larger of TLD badge or film badge (also worn for the study) results for the official dose. The chosen dose was fed to the licensee's computerized records system while the vendor was always adding the film badge results to the permanent record; the licensee apparently was not instructing the vendor to alter the official recor Other errors in lifetime dose in the vendor's report were identified for which no explanation was apparen During the inspector's onsite inspection period, the licensee reviewed the vendor reports and updated the onsite computer records with correct information for all employees; the licensee now considers their computer records system to be the official Form NRC-5 equivalent personal dose records in accordance with 10 CFR 20.401. The licensee stated that they will instruct the vendor to delete the lifetime dose portion of the vendor's reports since they are now redundant and need not be revised to correct the error The inspector discussed with the licensee the need to include social security numbers in the computerized dose record system in order for the system to totally comply with Form NRC-5 requirements. The licensee stated that social security numbers would be added to each individuals computorized dose history by the end of January 1986. Meanwhile, a separate social security record will be maintained for comparison with vendor reports to assure that doses are ascribed to the proper perso Violation 409/85015-01 is considered closed. Addition of social security numbers to computerized dose records is considered an open item (409/85015-02).

During review of film badge dose spiking qual;ty assurance records, the inspector noted that vendor readout results r f licensee spiked badges, performed in 1985, showed errors as high as 30 percent while other results were routinely 15 percent or less. The lictnsee spiking records do not indicate what distances or geometries are uied nor does the written procedure specify these parameters. Becausa of the dose rate variances indicated on the spiking records, and visu 1 observation of the spiking source and associated equipment, it appear:. that the readout / irradiation errors may be the result of inadequate spiking technique. If so, the spiking program has no value as a quality assurance check cf the film badge vendor. The inspector discussed with the licensee the need to investigate the film badge spiking program to determine if spiking technique contributes to the relative readout / irradiated dose errors. The licensee stated that such an investigation would be performed. This matter was also discussed at the exit meeting. (0 pen Item 490/85015-03).

One violation was identifie . Internal Exposure Control and Assessment The inspector reviewed the licensee's internal exposure control and assessment programs, including: changes in facilities, equipment,

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personnel, and procedures affecting internal exposure control and personnel assessment; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements; required records, reports, and notifications; effectiveness of management techniques used to implement these programs, and experience concerning self-identification and correction of program implementation weaknesse The licensee's program for controlling internal exposures includes the use of respirators and equipment, the control of surface contamination, and the control of airborne radioactivit A selected review of airborne radioactivity, surface contamination, and direct radiation survey results was made. No significant problems were note The licensee performs routine whole body counts on radiation workers twice each year and whenever an intake is suspected. The inspector reviewed whole body count results for counts conducted during 1985 to date. No result exceeding the 40 MPC-hour control measure was noted. Several follow-up counts were performed on persons who displayed initial elevated counts; all elevated counts were found to be minor external contamination which was readily removed by showering; no significant activity was detected in these individuals by whole body counting after showerin The licensee's respiratory protection program remains as described in Inspection Report No. 50-409/8500 No violations or deviations were identifie . Control of Radioactive Materials and Contamination The inspector reviewed the licensee's program for control of radioactive materials and contamination, including: changes in instrumentation, equipment, and procedures; effectiveness of survey methods, practices, equipment and procedures; adequacy of review and dissemination of survey data; effectiveness of methods of control of radioactive and contaminateJ materials; and management techniques used to implement the program and experience concerning self-identification and correction of program implementation weaknesse Toward the end of the Spring 1985 refueling outage, the licensee performed a thorough decontamination of the containment building and the turbine floor in a continuing effort to reduce the number of step-off pad access areas. The licensee stated that other contaminated areas / rooms will be decontaminated as time and operational conditions permit. Dering tours in controlled areas, the inspector noted improvement in general plant housekeeping and cleanlines The licensee has installed an Eberline PCM-1A personal contamination ;

monitor at the controlled area access point. According to the licensee, !

the monitor more effectively views the total body than its predecessor l (PCM-1). The licensee plans to determine the monitor's absolute l efficiency when time permit j

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In Section 11 of Inspection Report No. 50-409/85005, the inspectors discussed the need to post a sign, at the containment entry frisker station, concerning the required use of plastic shoe covers when shoe contamination is detected by a worker during frisking. The inspector noted that such a sign has been posted at the frisker station, and plastic shoe covers are provided. Also discussed in Section 11 is the apparent confusion concerning acceptable use of lab coats in posted contaminated areas. The licensee is drafting a procedure change which prohibits the use of lab coats in posted contaminated areas; use will be permitted in uncontaminated portions of the controlled area; the use restrictions will be specified in the revised procedur When questioned, the licensee stated that they routinely bring waste materials out of the controlled area and release them if no activity is detected by frisker survey; these materials are mostly burnable dry wast Most released burnable waste is burned onsite in a burning grate. The inspector suggested that the licensee terminate this practice pending further NRC guidance concerning acceptable survey methods; such guidance is expected in the rear future. The licensee stated that release of such materials would be immediately terminated and that greater emphasis would be placed on permitting only necessary materials to enter the controlled area._ The licensee stated that they have routinely collected samples of ash from the burning pit for gamma analysis; no activity has been detected in the sample No violations or deviations were identifie ,

9. Maintaining Occupational Exposures ALARA The inspector reviewed the licensee's program for maintaining occupational exposures ALARA, including: changes in ALARA policy and procedures; worker awareness and involvement in the ALARA program; establishment of goals and objectives, and effectiveness in meeting them. Also reviewed was management techniques used to implement the program and experience concerning self-identification and correction of program implementation weaknesse The ALARA program remains as described in Inspection Report No. 50-409/85005 except for the following matter The licensee is developing a program to track radiation dose for individual tasks, work groups, and individuals by implementing a dose accountability system. The licensee is inputting, to a computer, radiation dose information from past RWPs, and is categorizing person rem totals by specific job function. No projected date for total programmatic implementation has been establishe Improvements in contamination controls is discussed in Section No violations or deviations were identifie E

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10. Quality Assurance Audit The inspector reviewed the annual onsite quality assurance audit of the radiation protection program performed in September 198 The audit

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included qualifications, training, retraining, procedure adherence, whole body counting records, and the respiratory protection program. One finding concerns failure to provide waste disposal training, in 1984, in accordance with HSP 8.2. The internal response to this finding is due in October 198 The audit also presents and tracks the results of a recent INP0 audi The INP0 audit identified shortcomings in the licensee's radiation exposure control, personal dosimetry, and contamination control program The licensee's formal response, or proposed formal response, was not reviewed. The findings in this inspection report do not reiterate the INP0 findings. However, the licensee's response to the INPO findings will be later reviewe No violations or deviations were note . IE Information Notices The inspector reviewed the licensee's internal responses to the following IE Information Notices. The responses are adequat No. 85-42 Loose Phosphor in Panasonic 800 Series TLD Elements: The licensee does not use Panasonic TLD No. 85-43 Radiographic Events at Power Reactors: The licensee stated that no radiography has been performed at the station for several years. The licensee stated that any future radiographic operations would be scrutinized by radiation protection personnel before and during performanc . Interim Low Level Radwaste Storage Facility The licensee is planning to build an onsite Interim Radwaste Storage Facility (IRSF) for low level radwaste storage in anticipation of the closure of burial sites, on January 1, 1986, as authorized by 1980 Congressional legislatio The licensee's proposed IRSF is for storage of low specific activity dry waste (DAW) packaged in 55 gallon drum The licensee does not plan to include remote operating barrel handling systems in the design. No liquid or reactive contents will be permitte The licensee was performing a 10 CFR 50.59 review during the inspection period. Included in the review was guidance in Generic Letter 81-38, local and state building and fire codes, offsite and onsite dose calculations, possible surface and flood water problems, and anticipated methods of routine surveillance L

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Preliminary plans are to construct the IRSF of noncombustible materials not designed for shielding, equip with fire detection devices, provide curbing to contain or exclude liquids, and provide for radiological postings and access control The licensae stated that there are no plans for additional extended temporary storage of solidified wastes or dewatered resins; original storage may be adequate. Should the need for such storage be later identified, the licensee stated that an additional IRSF will be designed and constructed to contain these material . Exit Meeting The inspector met with licensee representatives (denoted in Section 1) at the conclusion of the inspection on September 20, 1985. The inspectors summarized the scope and findings of the inspection. The inspectors also discussed the likely information content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents / processes as proprietary. In response to certain items discussed by the inspectors, the licensee: Acknowledged the nonresponse violation (Section 6). Stated that social security numbers would be included in NRC-5 equivalent records by January 31, 1986 (Section 6). Acknowledged the inspectors comment about the apparent need to enhance review and oversight of radiation protection programs to identify weaknesses (Section 4). Stated that an investigation of the film badge spiking program would be performed to determine if technique errors contribute to large apparent errors (Section 6).

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