IR 05000409/1988006

Insp Rept 50-409/88-06 on 880517-20.Violations Noted.Major Areas inspected:post-shutdown Radiation Protection & Radwaste Mgt,Including Organization,Mgt Controls,Training External & Internal Exposure Controls & Solid Radwaste

ML20155D398
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	06/02/1988
From:	Greger L, Miller D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20155D390	List: IR 05000409/1988006 ML20155D385 ML20155D392
References
50-409-88-06, 50-409-88-6, NUDOCS 8806150149
Download: ML20155D398 (8)

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jg U.' S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-409/88006(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 Sitt, Genoa, Wisconsin Inspection Conducted: May 17-20, 1988 e. e. sek Inspector: D. E. Miller - 6/a/rf'

Date Accompanying Personnel: W. W. Ogg Approved By: L. Ro ert Greger, Chief 6 -# -M Facilities Radiation Protection Date Section Inspection Summary:

Inspection on May_17-20, 1988 (Report No. 50-409/88006(DRSS))

Areas Inspected: Routine unannounced inspection of the licensee's post-shutdown radiation protection and radwaste management programs, including:

organization, management controls, and training-(IP 83722; 83723); external exposure controls (IP 83724); internal exposure controls (IP 83725); control of radioactive materials and contamination (IP 83726); solid radwaste (IP 84722);

liquid radwaste (IP 84723); gaseous radwaste (IP.84724); and transportation (IP 86721). Also reviewed were past open item Results: The licensee's post-shutdown radiation protection and radwaste management programs are generally adequate. Plant cleanliness has improve One violation concerning failure to whole body count certain individuals at the licensee's internally required frequency was identified (Section 6).

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DETAILS Persons Contacted

• D. Egge, Quality Assurance. Auditor

• L. Nelson, Health and Safety Supervisor

• J. Parkyn, LAC 8WR Superintendent

• P. Shafer, Radiation Protection Engineer

• R. Wery, Quality Assurance Supervisor

• K. Ridgway, NRC Senior Resident Inspector The inspector also contacted other licensee personne * Denotes those present at the exit meetin . General This inspection was conducted to examine portions of the licensee's radiation protection and radwaste management programs. The inspection included a review of past inspection findings, plant tours, a review of posting and labeling, licensee records and reports, radiation protection organization, and discussions with plant personnel. Independent contamination surveys were performed. Posting and labeling are goo Cleanliness has improved. One procedural noncompliance was identifie . Licensee Action on Previous Inspection Findings (IP 92701)

(Closed) Open Item (409/87006-01): Need to make.necessary corrections to past semiannual effluent reports. The 1985 and 1986 reports were corrected to properly quantify iodine-131. releases and revise / correct calculated organ' doses. The revised calculated doses remained well below regulatory limit (Closed) Open Item (409/87014-01): Site specific security briefing when i the licensee's Security Director is absen Lir.ansee internal memorandum L dated November 19. 1987, addresses the licensee's interpretation of the requirements and how the licensee intends to comply with these requirements.

l The inspectors have no further questions at this time; the licensee's

response appears adequat No additional problems were note . -Organization, Management Contic'*., and Training (IP 83722; 83723)

l The inspectors reviewed the licensee's organization and management controls

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for the radiation protectic,t and radwaste management programs including changes in the organizational structure and staffing, effectiveness of procedures and other management techniques used to implement these programs, and experience concerning self-identification and correction of program implementation weaknesse o l

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Since Inspection Report No. 50-409/87014, the licensee has hired an additional health physics / chemistry (HP/C) technician. The current staffing is an engineer, supervisor, and five technician The inspector reviewed the new technician's previous experience, formal training, and site specific training; the technician is qualified in accordance with ANSI N18.1-197 The licensee is still covering all shifts with a HP/C technician to meet technical specification (TS) requirements for fire brigade and emergency response shift staffing. Anticipated TS changes may pennit removal of a HP/C technician from some baci: shifts if station operators are qualified to perform certain radiation protection function Total station staffing remains essentially as discusseo in Inspection Report No. 50-409/8701 Further staff reductions may take place as technical specification requirements are reduce The licensee is continuing self-identification programs such as audits and the Radiological Occurrence Report (ROR) system. Frequency of generation of RORs has decreased; followups and corrective actions are adequate. The inspectors reviewed the results of an annual health physics and chemistry audit conducted during the fourth calendar quarter of 1987. Two open items were identified concerning adequacy of air sample volumes and completeness of safe work permits; these items have since been corrected, or corrective actions are in progres Qualifications of auditors appear adequate. Adequacy of radwaste audits is discussed in Section No violations or deviations were identifie . External Exposure Control and Personal Dosimetry (IP 83724)

The inspector reviewed the licensee's external exposure control and personal dosimetry programs, including: changes in facilities, equipment, personnel, and procedures; and effectiveness of management techniques used to implement these programs, i There have been no significant changes in the licensee's external exposure control, dosimetry, and assessment programs since previously described in Inspection Report No. 50-409/85015(DRSS).

The inspectors selectively reviewed exposure records for the fourth calendar quarter 1987 through the present. The total whole body dose for 1987 was 67 person-rem. The dose for 1988 through May 16 was about nine person-rem. The ALARA goal for 1988 is 75 person-rem. No person received a dose in excess of 10 CFR 20.101 limits, and no annual personal whole body dose exceeded five rem. No problems were noted.

i No violations or deviations were identified.

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, . . . Internal Exposure Controls (IP 83725)

The inspectors reviewed the licensee's internal exposure control and assessment program, including: review of procedures governing. internal exposure control, personnel exposure assessment, and calibration and quality control of the whole body counter; determination whether -

engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements; planning and preparation for maintenance tasks including ALARA considerations; and required records, reports, and notification A licensee representative stated that there is no active work area where wearing of respirators is required. The inspector reviewed licensee document "LACBWR Contamination Control Report" of May 6,1988, which illustrates the results of the licensee's area decontamiriation program and reduced ~ limits / goal The table below is excerpten from the m. cor CONTAMINATION G0AL PERCENT OF AREA AREA (DPM Per FT2) GREATER THAN G0AL CB GRADE FLOOR 1000 2 CB MEZZANINE 1000 5 C6 701 FLOOR 1000 2 TUNNEL 1000 0 TB GRADE FLOOR 500 4 TB MEZZANINE 500 0 TB MAIN FLOOR 500 0 WASTE TREATMENT BLO The inspectors noted that the licensee's routine weekly, daily and shiftly air sampling program for controlled and non-controlled areas appeared comprehensive; sampling schedules are met. A selective review of the calibration of sample counting devices indicted that schedules (mandated by procedure) are met. During the inspection the licensee acknowledged an inspector's comment that recording of survey data (e.g. smear results) appeared to need more attention to detail in that occasionally the radioactivity units were not recorded on the forms.

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The licensee's whole body counter is a home built shielded chair type l using an intrinsic GeLi detector. Calibration of the counter appears I

good and detection efficiency is adequate. Licensee procedures require counting of plant personnel on a semiannual schedul While selectively reviewing whole body count data for 1987, the inspectors noted that several individuals did not receive the semiannual count which was due in the third calendar quarte The licensee had placed a note in the files of the workers not counted stating that they were not whole body counted because of failure of the WBC detector. These notes, however, did not release the licensee from their procedural requirement to perform L semiannual whole body counts. The individuals were counted at their next scheduled whole body count appointment (the first quarter of 1988).

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Failure to count plant personnel who were due for the semiannual count is a violation of Technical Specification 6.8.1 which requires bioassay procedures to be established, implemented and maintained. Implementing health physics bioassay procedures state that whole body counts shall be performed routinely every six months on each plant individual (Violation 409/88006-01).

The inspector noted that the licensee did perform terminating whole body count, as required by the health physics procedure, on about ten plant individuals who terminated during August through October 1987. The licensee used a temporary replacement whole body counting detector to perform the termination count One violation was identifie . Control of Radioactive Materials and Contamination (IP 83726)

The inspector cursorily 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 tours of radiologically controlled areas, the inspectors noted that since the previous inspection, conducted in October 1987, the extent of contaminated areas has been reduced and overall cleanliness improved. Also, to reduce potential for contamination spread, the licensee has covered the fuel storage pool with a reinforced plastic material supported by a fram Discussed in Inspection Report No. 50-409/87014 was the apparent need for the licensee to improve his method of monitoring laundered protective clothing so that hot particles could be identifie Since then, the licensee began using a pancake G-M frisker probe to survey the clothing instead of the previously used less sensitive side window G-M frisker probe. Although use of the pancake probe has improved detection sensitivity, the laundry area (where the clothing is monitored) has

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background radiation levels (one-two millirad per hour) which reduces I the probability of detecting hot particle The inspectors discussed with the licensee during the inspection and at the exit meeting the

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desirability of making further improvements in monitoring of laundered protective clothin According to the licensee, they plan to computerize routine radiological survey schedules / forms to enhance scheduling / performance of such survey No violations or deviations were identified.

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c Solid Radwaste (IP 84722)

The inspectors reviewed the licensee's solid radwaste management program, including: changes to equipment, procedures, processing, control, and storage of solid wastes; adequacy of required records, reports, and notifications; implementation of procedures to properly classify and characterize waste, prepare manifests, and mark packages; and experience concerning identification and correction of programmatic weaknesse The licensee had submitted waste stream samples to an analyses vendor in 1984 to establish nuclide relative abundance and scaling factor The values which resulted are still being use The licensee experienced no significant fuel leakage since about 1980 (significant fuel leakage would have been detected by changes in the isotopic content in coolant and liquid release sample analysis results); therefore, no additional waste stream samples were submitte The inspectors compared the 1987 Environmental Report liquid relative nuclide abundances with the 1984 vendor's analyses; the relative isotopic abundances in the 1987 report agreed closely with the 1984 vendor result The inspectors found no records of licensee audits of the solid radwaste management program. The extent, if any, of licensee commitments to perform such audits was not determined during this inspection; therefore, this matter will be examined further during the next inspection (0 pen Iten, 409/88006-02) .

The licensee's solid radwaste consists of de-watered spent resins, used filters, and dry active waste All wastes generated in the controlled area are considered to be contaminated and are handled as radvaste. The licensee has a small quantity of LSA packaged in 55 gallon drums and stored in the radwaste storage buildin The High Integrity Container (HIC) containing spent resins, described in Inspection Report No. 409/87014(0RSS), was being dewatered and surveyed during this inspection. 'The licensee reported that the maximum contact exposure rate on the HIC was 39 R/hr. The licensee intends to send a representative sample of the HIC contents for vendor analysis; results will probably be received by the licensee after the HIC is shipped for disposal. The licensee stated that burial site records will be revised if the relative isotopic content of the HIC is different than the

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1984 isotopic abundances.

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The inspectors selectively reviewed 1987 solid radwaste data for volume, activity, and classification of wastes generated, stored, and shipped.

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No problems ve.re note The inspectors reviewed the licensee's solid radwaste disposal procedures and found them to be comprehensive; they explicitly reference 10 CFR 61, 10 CFR 20.311,10 CFR 71, and 49 CFR regulations.

( No violations or deviations were identified.

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, Liquid Radioactive Wastes (IP 84723)

The inspector reviewed the licensee's liquid radwaste management program, including: determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; determination whether liquid radioactive waste effluents were in accordance with regulatory requirements; adequacy of required records, reports, and notifications; and determination whether process and effluent monitors are maintained, calibrated, and operated as require The inspector reviewed the licensee's procedures for and methods of calibrating the liquid radwaste effluent monitor and establishing the alarm setpoint. The monitor was last calibrated during September 1987 using three concentrations of primary coolant decayed for more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The calibration, procedures, and alarm set point methods are goo After the April 1987 permanent reactor shutdown, the liquid radwaste release monthly total activity was higher than normal through the end of 1987 because of cleaning of materials that had been deposited in tank bottoms over the years, and limited capacity for cleanup of the liquids before release. Released activity has since decline The effluent release concentrations and quantities were well within ODCM limit No violations or deviations were identifie . Gaseous Effluents (IP 84724)

The inspectors reviewed selected records of gaseous effluent sampling and analysis for the period July 1, 1987 to the present. No radioactive noble gases or iodines have been identified in gaseous effluents since the second calendar quarter of 1987. Some radioisotopes in particulate form remain present in declining concentrations. The concentrations of effluent particulates are well within ODCM limit The licensee calibrated the low range noble gaseous effluent monitors during February 1988. The calibrations were performed using Kr-85; this isotope is appropriate because Kr-85 is essentially the only noble gas radioisotope remaining within the stored used fuel. The licensee plans to perform a similar calibration of the mid-range SPING-4 monitor in the near future. No problems were note No violations or deviations were identifie . Transportation of Radioactive Material (IP 86721)

The inspector reviewed the licensee's transportation of radioactive materials program, including: determination whether written implementing procedures are adequate, maintained current, properly approved, and acceptably implemented; determination whether shipments are in compliance with NRC and DOT regulations; determination if there were any transportation incidents involving licensee shipments; and adequacy of required records, reports, shipment documentation, and notification . -._. - - . - -

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The inspectors reviewed the licensee transportation procedures and found they are comprehensive and explicitly address 10 CFR 61, 10 CFR 71, 10 CFR 20.311, and 49 CFR requirements. Vehicle safety is also detailed in the procedures. The licensee's response to NRC Information Notice 87-31 "Blocking, Bracing, and Securing of Radioactive Materials Packages in Transportation" appears adequate. The shipping casks and containers used by the licensee are certified.

1 Two shipments to licensed waste processors and two shipments to disposal sites were made during 1987. The inspectors reviewed the manifests required by 10 CFR 20.311, prior notification documentation, and vehicle

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radiological surveys for these shipments; no problems were note Approximately 280 cubic feet of radwaste was shipped to waste processors, and 1700 cubic feet to disposal sites. The first shipment in 1988 will be the HIC described in Section 8; the shipment is planned for Jul No violations or deviations were identifie .1 Exit Meeting The inspectors met with licensee representatives (denoted in Section 1)

at the conclusion of the inspection on May 20, 1988, and by telephone with Mr. Parkyn on May 24, 1988. The inspectors sumarized 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 inspector during the inspection. The licensee identified no such documents / processes as proprietary. In response to certain items discussed by the inspector, the licensee: Acknowledged the noncompliance concerning failure to comply with j' the whole body count procedure. (Section 6)

, Acknowledged the inspectors' coment concerning the desirability l of upgrading laundered protective clothing monitoring capabilitie (Section 7)

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