IR 05000409/1986012

Insp Rept 50-409/86-12 on 860902-05.No Violations or Deviations Noted.Major Areas Inspected:Radiation Protection & Radwaste Mgt Programs,Including Organization, Qualifications & Mgt Controls & Training

ML20214S402
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	09/23/1986
From:	Greger L, Miller D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214S392	List: IR 05000409/1986012 ML20214S390
References
50-409-86-12, NUDOCS 8609290484
Download: ML20214S402 (9)

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U.S. NUCLEAR REGULATORY COPWISSION

REGION III

Report No. 50-409/86012(DRSS)

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 BWR Site, Genoa, WI Inspection Conducted: September 2-5, 1986 Inspectors:

b D. E. Mi ler g <- 9-23-86 Da~te-M Approved By: L. k.' reg'er,' Chief 9-23-8G Facilities Radiation Protection Date Section Inspection Sumary:

Inspection on September 2-5, 1986 (Report No. 50-409/86012(DRSS?)

Areas Inspected: Routine, unannounced inspection of the radiat<on protection and radwaste management programs, including: organization, qualifications, and management controls; training; external and internal exposures; control of radioactive materials and contamination; solid radwaste; transportation; and audits. Also reviewed were past open items and licensee responses to selected IE Information Notice Results: No violations or deviations were identifie e60923 PDR ADOCK 05000409 G PDR

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DETAILS 1. Persons Contacted R. Acker, Quality Control (QC) Technician

• L. Nelson, Health and Safety Supervisor

• J. Parkyn, Plant Superintendent

• P. Shafer, Radiation Safety Engineer

• R. Wery, Quality Assurance (QA) Supervisor

• I. Villaiva, NRC Senior Resident Inspector The inspector also contacted other licensee employee * Denotes those present at the exit meetin . General This inspection, which began at 8:00 a.m. on September 2, 1986, was conducted to examine portions of the licensee's radiation protection and radwaste management programs. The inspection included a review of past inspection findings, selected IE Information Notice responses, plant tours, a review of posting and labeling, discussions with plant personnel, and licensee records and report . Licensee Action on Previous Inspection Findings (Closed) Violation (409/86003-02): Beta dose equivalent rates were not determined or known while workers performed tasks in the reactor head cavity area. The licensee has completed implementation of the corrective actions listed in their response letter dated April 22, 198 The corrective actions appear adequat (0 pen) Open Items (409/84008-08 and 409/85005-02): Request for deviation from monitor readout requirements, design basis shielding requirements, and station requirements for use of SA-9 monitor. Several submittals to NRR have been made; the most recent being a supplemental request, dated April 1, 1986, concerning the monitor readout requirements. Since then, the licensee has communicated with NRR by telephone several times. Final resolution of these matters is expected by December 31, 198 (Closed) Open Item (409/83009-09): Provide shielding for portions of the post accident sampling system piping. This item was previously closed in Inspection Report No. 50-409/84014(DRSS) as Open Item No. 409/84008-0 . Organization, Qualifications, and Management Controls The inspector reviewed the licensee's organization and management controls for the radiation protection and radwaste programs including changes in the organizational structure and staffing, effectiveness of

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procedures and other management techniques used to implement these l programs, experience concerning self-identification and correction of l program implementation weaknesses, and effectiveness of audits of these

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programs. Audits are discussed in Section 1 The licensee's organization, staff and staffing, and management controls remain as described in Inspection Report No. 50-409/86003(DRSS).

Ouring the inspection conducted in March 1986, the inspector noted that

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the radiation protection staff appeared strained during the refueling and l maintenance outage in progress. This matter will be reviewed during

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future refueling and maintenance outage inspections to determine if adequate surveillance of radiological work is being provided by the radiological protection staff (409/86003-01).

, The inspector reviewed Radiological Occurrence Reports (RORs) written I

during 1986 through August. The inspector noted that followup reviews are not always thorough enough to identify the root cause for incidents or events; therefore, the corrective actions may or may not be appropriate and effective. Consequently, the ROR system does not appear j to be used as effectively as it should be as a management tool. This matter was discussed at the exit meeting and will be further reviewed during future inspections (409/86012-01).

No violations or deviations were identifie . Training The inspector reviewed the training aspects of the licensee's radiation protection, radwaste, and transportation programs, including changes in responsibilities, policies, goals, programs, and methods. Also. reviewed were management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesse Audits are discussed in Section 1 At LACBWR, the radiation protection staff performs the radiation

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protection, radwaste, and transportation program functions. The training i and retraining programs for these functions have been revised by the licensee. The following new Training Plan Procedures were implemented on June 20, 1986.

• TPP-5 Initial Health Physics Technician On-The-Job Trainin * TPP-6 Health Physics Technician Continuing Training Progra j The on-the-job training procedure includes training requirements based on past experience, testing of program participants, and supervisory verification of acceptable completion of training segments. The continuing education program is a 24-month cycle program designed to provide required radiation protection and radwaste retraining, keep participants abreast of station procedure and equipment changes, provide I

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necessary refresher training, and inform participants of problems encountered at other nuclear power stations. The licensee plans to seek INPO accreditation for these training program No violations or deviations were identifie . External 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 and emergency needs; planning and preparation for maintenance and refueling tasks including ALARA considerations; 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 There have been no significant changes in the licensee's external exposure control and assessment program since previously described in Inspection Report No. 50-409/85015(DRSS).

The inspector selectively reviewed exposure records for the first and second calendar quarters 1986. Several licensee employees exceeded 1250 millirems whole body dose during the second calendar quarter; Forms NRC-4 for these person were selectively reviewed orid found to meet regulatory requirement The licensee's ALARA goal for 1986 was 190 person-rems. The estimated dose received during 1986 as of September 4 was 226 person-rems. The unplanned plant outage to repair a cracked pipe in a non-isolable portion of the decay heat removal system resulted in unforeseen exposures to plant and contractor personne The inspector selectively reviewed Radiation Work Permits and job specific surveys for work being performed during the period of this inspection. No significant problems were note No violations or deviations were identifie . Internal Exposure Control and Assessment The inspector reviewed the licensee's internal exposure control and assessment programs, including: changes in facilities, equipment, personnel, respiratory protection training, and procedures affecting internal exposure control and personnel assessment; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports, and notifications; and 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 *

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The licensee's program for controlling internal exposures includes the use of respirators and equipment, the control of surface contaminants, and the control of airborne radioactivit A selected review of airborne radioactivity 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 expected. The inspector reviewed whole body count results for counts conducted during 1986 to date. No result exceeding the 40 MPC-hour control reasure was note Several follow-up counts were performed on persons who displayed initial elevated counts; all unexpected 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 showering. Some station personnel carry long-term body burdens of Co-60 and elevated counts are expected; the body burdens carried by these persons are small (maximum of about 20 nanocaries) and do not interfere with assessment of current intakes but are readily identifiable by whole body counting. The licensee's respiratory protection program remains as described in Inspection Report No. 50-409/85005(DRSS).

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: adequacy of supply, maintenance, and calibration of contamination survey and monitoring equipment; effectiveness of survey methods, practices, equipment, and procedures; adequacy of review and dissemination of survey data; and effectiveness of methods of control of radioactive and contaminated material During review of contamination survey records and reports, and discussions with licensee personnel, the inspector concluded that personal contamination log sheets are not consistently filled out by persons who find themselves contaminated when performing exit frisking at the controlled area access point. The access point is not manned or directly observed. It appears that some personnel decontaminate themselves, when minor skin contamination is involved, without either notifying a health physics representative or completing the log sheet. Also, for personal contamination log entries that are made, followup evaluations are frequently cursory or followup information is not recorded on the log sheet. The failure to properly record and investigate personal contamination incidents to determine their root causes results in loss of a valuable health physics program management too The inspector discussed with the licensee, during the inspection and the exit meeting, the apparent need to upgrade the personal contamination recording and investigation system. This matter will be further reviewed during future inspections (409/86012-02).

No violations or deviations were identifie "

. Solid Radioactive Waste The inspector reviewed the Licensee's solid radioactive waste management program, including: determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; adequacy of implementing procedures to properly classify and characterize waste, prepare manifests, and mark packages; overall performance of the process control and quality assurance programs; adequacy of required records, reports, and notifications; and experience concerning identification and correction of programmatic weaknesses. Audits are oiscussed in Section 1 The licensee does not solidify wet wastes. Resins are sluiced into high integrity containers where they are dewatered before being shipped for burial. Solid radwa.te consists primarily of compacted Dry Active Wastes (DAW), filters, and solid Packaging of waste is done in the Waste Treatment Building (VfB). Packaged radwaste in 55 gallon drums is stored either in the WTB or in the Interim Radwaste Storage Facilit The inspector toured radwaste handling and storage facilities. Access controls, radiological postings, and labeling were adequate. No problems were note No violations or deviations were identifie . Iransportation of Radioactive Materials The inspector reviewed the licensee's transportation of radioactive materials program, including: determination whether written implementing procedures are adequate, maintained cur.re.nt, properly approved, and acceptably implemented; determination whether shipments are in compliance with NRC and 00T regulations and the licensee's quality assurance program; determination if there were any transportation incidents involving licensee shipments; adequacy of required records, reports, shipment documentation, and notifications; and experience concerning identification and correction of programmatic weaknesses. Audits are discussed in Section 1 There were four shipments of radwaste for burial during 1985. Three shipments were 170-cubic foot high integrity containers containing dewatered resin for a total of about 230 curies of activit One shipment Wds 73 packages of solid and compacted wast There was one radwaste shipment during 1986 to date. This shipment was a dewatered resin shipment. The resin shipments are Class B waste The inspector reviewed the shipping papers for the 1985 and 1986 shipments. The shipping papers were complete and appeared to meet 00T, NRC, and burial site requirement There have been no shipping incidents since June 198 No violations or deviations were identifie ,. .- - - _ _ _ _ - .- -

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11. ~ Quality Assurance Audit The inspector reviewed the annual onsite quality assurance audit of the radiation protection and radwaste programs performed in August and early September 1986. .The audit included selected radiation protection and

radioactive materials handling and disposal subjects. One noncomformance

and six open items resulted from the audit. The nonconformance concerns failure to write a Radiological Occurrence Report (ROR) for an event

meeting procedural requirements for ROR generatio The open items concern a shortcoming in general orientation training subjects,

, shortcomings in a contamination event followup and the personal ,

contamination log, completeness of' ALARA review paperwork, timeliness of  !

corrective actions for an identified radiological. problem, and an

incident where three persons exceeded administrative does limits

specified on a Radiation Work Permit. . Internal responses to the

nonconformances and open items have not been complete The licensee's responses will be reviewed by the inspector during later routine review

> of the licensea's quality assurance progra i

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No violations or deviations were identifie . TMI Action Plan Item II.B.3. This item remained open pending NRR review and acceptance of a LACBWR post-accident sampling system core damage estimate procedure. In a letter i to the licensee, dated August 11, 1986, NRR stated that the licensee's post-accident sampling system meets all the requirements of Item II. !

of NUREG-0737; the safety evaluation was enclosed. This action plan item I

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is considered closed.

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j 1 Stack Post Accident Noble Gas Monitor Response u

l In a June 26, 1986 letter and enclosures from Eberline, the license ~e

recei.ved updated information concerning " PING /SPING Primary Gas l' Calibration and Detector Response to Beta and Photon Sources." The documents present calibration test data for additional gamma and beta calibrations performed.for or by Eberline on PING and SPING noble gas channels. The. inspector discussed with the licensee the possible need to update their post-accident detector response curves for the SPING. The licensee stated that the matter would be reviewed and the curves revised, if necessary, by January 1, 1987. This matter was discussed at the exit meeting (409/86012-03).

1 IE Information Notices

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The inspector reviewed licensee actions in response to the following IE Information Notices. The actions are considered adequat .

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No. 86-20: Low Level Radioactive Waste Scaling Factors, 10 CFR 6 LACBWR has three waste streams; they are DAW, resin,~and filter medi Each of these streams have been analyzed for 10 CFR 61 isotopes by an independent consultan No. 86-22: Underresponse of Radiation Survey Instrument to_High Radiation Fields. The licensee owns an ESP-1; it was returned to the vendor for necessary corrective alteration to correct the underresponse proble No. 86-23: Excessive Skin Exposures Due to Contamination with Hot Particle According to the licensee, LACBWR has experienced minor levels or skin contamination believed to result from release of fixed contamination from laundered protective clothing; no hot particles have been identified. To minimize the potential for such problems, the licensee monitors each piece of protective clothing after laundering and removes protective clothing from use if the fixed contamination level is unacceptable. Also, the licensee requires the wearing of disposable coveralls over normally worn protective clothing for performance of jobs where the potential for high levels of loose contamination is presen No. 86-43: Problems with Silver Zeolite Sampling of Airborne Radioiodine. This notice was written because of an event that happened at LACBW The licensee does not plan further use of silver zeolite for iodine sampling unless the H2 concentration is verified to be less than four percen No. 86-44: Failure to Follow Procedures When Working in High Radiation Area The licensee stated that health physics coverage for such tasks is increased, and pre-job briefings are held. Also, the licensee uses alarmed gates at High Radiation Area (HRA) entrances to alert operations personnel of HRA entrie No. 86-46: Improper Cleaning and Decontamination of Respiratory Protection Equipment. Respiratory protective equipment at LACBWR is cleaned following manufacturer's recommended cleaning practices using approved cleaning solution No problems like those noted in the Notice have been experienced at LACBW . Exit Meeting The inspector met with licensee representatives (denoted in Section 1) at the conclusion of the inspection on September 5, 1986. The inspector summarized the scope and findings of the inspection. The inspector also discussed the likely information content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents / processes as proprietary. In response to certain items discussed by the inspector, the license: Acknowledged the inspector's comment about the apparent need to enhance the Radiological Occurrence Report system, and stated that l

the matter would be reviewed (Section 4).

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b. Acknowledged the inspector's comment about the apparent need to improve the personal contamination reporting and followup system, and stated that the matter would be reviewed (Section 8).

c. Stated that SPING post-accident noble gas detector response curves would be' revise'd, if necessary, by January 1~, 1987 (Section 13).

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