IR 05000409/2019001
| ML19294A284 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 10/21/2019 |
| From: | Michael Kunowski Division of Nuclear Materials Safety III |
| To: | Sauger J EnergySolutions |
| Lee P | |
| References | |
| IR 2019001 | |
| Download: ML19294A284 (13) | |
Text
ber 21, 2019
SUBJECT:
NRC INSPECTION REPORT NO. 05000409/2019001(DNMS) - LA CROSSE BOILING WATER REACTOR
Dear Mr. Sauger:
On September 26, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the La Crosse Boiling Water Reactor (LACBWR) in Genoa, Wisconsin. The purpose of the inspection was to determine whether decommissioning activities were conducted safely and in accordance with NRC requirements. The enclosed report presents the results of this inspection, which were discussed with Mr. Scott Zoller of your staff on September 26, 2019.
The inspection consisted of an examination of activities at the facility as they relate to safety and compliance with the Commissions rules and regulations. Areas examined during the inspection included facility management and control, radiological safety, and confirmatory surveys. Within these areas, the inspection consisted of a selective examination of procedures and representative records, field observations of activities in progress, and interviews with personnel.
Based on the results of this inspection, the NRC did not identify any violations.
This letter and its enclosure will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding. We will gladly discuss any questions you have concerning this inspection. If you have any questions, please contact Dr. Peter Lee of my staff at (630) 829-9870.
Sincerely,
/RA/
Michael A. Kunowski, Chief Materials Control, ISFSI, and Decommissioning Branch Division of Nuclear Materials Safety Docket No. 050-00409 License No. DPR-45
Enclosure:
IR 050-00409/2019001 (DNMS)
REGION III==
Docket No.: 050-00409 License No.: DPR-45 Report No. : 050-00409/2019001(DNMS)
Enterprise Identifier: I-2019-001-0092 Licensee: LaCrosseSolutions, LLC Facility: La Crosse Boiling Water Reactor Location: Genoa, Wisconsin Dates: April 9, 2019, through September 26, 2019 Inspectors: Rhex Edwards, Senior Health Physicist Peter J. Lee, Reactor (Decom) Inspector, Ph.D., CHP Approved by: Michael A. Kunowski, Chief Materials Control, ISFSI, and Decommissioning Branch Division of Nuclear Materials Safety Enclosure
EXECUTIVE SUMMARY La Crosse Boiling Water Reactor (LACBWR)
NRC Inspection Report No. 05000409/2019001 (DNMS)
This periodic decommissioning inspection covered aspects of facility management and control, radiological safety, and confirmatory surveys.
Facility Management and Control
- The inspector determined that the licensee implemented organization, management, and cost controls in accordance with regulatory requirements, license conditions, and the Technical Specifications (TSs). (Section 1.1)
- The inspectors determined that the licensees process for evaluating the safety impacts of facility changes and modifications complied with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.59. (Section 1.2)
- The inspectors determined that the licensees corrective actions were adequately implemented in accordance with its Corrective Action Program (CAP). (Section 1.3)
- The inspectors determined that the licensee effluent control equipment was in proper operation to maintain the requirements of the Offsite Dose Calculation Manual (ODCM).
(Section 1.4)
- The inspectors determined that the licensee was adequately controlling decommissioning activities and radiological work areas. (Section 1.5)
Radiological Safety
- The inspectors determined that the licensee continued to be effective in controlling radiation worker personal exposure. (Section 2.1)
- The inspectors determined that the licensee adequately implemented its effluent monitoring program. (Section 2.2)
- The inspectors determined that the licensee had complied with U.S. Nuclear Regulatory Commission (NRC) and U.S. Department of Transportation (DOT) regulations for shipments of radioactive waste. (Section 2.3)
Confirmatory Surveys
- A preliminary review of selected licensee survey data and of the NRCs draft confirmatory survey data indicated to the inspectors that the reactor bowl, former tent area adjacent to the reactor building, Reactor Plant Generator Plant Access (RPGPA)
sump base area and surrounding sloped area, and open land areas, including areas containing stormwater pipes, met the criteria specified in 10 CFR 20.1402. A final conclusion will be made by NRC headquarters staff after review of all submitted licensee survey data and of the final NRC confirmatory survey data. (Section 3.1)
Report Details 1 Summary of Plant Activities During the inspection period, the licensee conducted soil remediation for the preparation of final status surveys (FSSs), and performed FSSs of the reactor bowl, the former tent area adjacent to the reactor building, RPGPA sump base area and surrounding sloped area, and open land areas, including areas with stormwater pipes.
1.0 Facility Management and Control 1.1 Organization, Management, and Cost Controls at Permanently Shutdown Reactors (Inspection Procedure (IP) 36801)
a. Inspection Scope The inspectors reviewed documents and interviewed plant personnel to assess the licensees implementation of a personnel reduction strategy. that and would continue to meet regulatory requirements.
b. Observations and Findings The inspectors determined through direct observation, review of corrective action documents, revised work control procedures, and interviews with licensee personnel that the appropriate regulatory requirements and commitments were followed. The reduction strategy did not adversely challenge public health and safety or decommissioning activities.
No findings were identified.
c. Conclusions The licensee implemented organization, management, and cost controls in accordance with regulatory requirements, license conditions, and the TSs.
1.2 Safety Reviews, Design Changes and Modifications (IP 37801)
a. Inspection Scope The inspectors reviewed the licensees 10 CFR 50.59 safety screening reviews to assess the need for safety evaluations.
b. Observations and Findings The inspectors verified that the safety review process stated in LACBWR Site Restoration Project Regulatory Reviews (LC-RA-PR-001), 10 CFR 50.59 Reviews, dated November 9, 2017, was consistent with the requirements of 10 CFR 50.59. The licensee conducted safety screening reviews per LC-RA-PR-001.
1NOTE: A list of acronyms used in the report is included at the end of the report.
The inspectors reviewed the licensee-approved changes of procedures and design modifications. Specifically, the inspectors reviewed the plan for the direct discharge of liquid radiological waste without dilution flow (revised LC-OP-PR-001) and the revision for FSS data reporting (LC-FS-PR-009). None of the above activities required evaluations.
No findings were identified.
c. Conclusions The inspectors determined that the licensees process for evaluating the safety impacts of facility changes and modifications complied with the requirements of 10 CFR 50.59.
1.3 Self-Assessment, Auditing, and Corrective Actions (IP 40801)
a. Inspection Scope The inspectors reviewed documents and interviewed plant personnel to assess whether licensees administrative procedures prescribed actions for the identification, evaluation, and resolution of problems. Additionally, the inspectors verified whether self-assessments were conducted by technically qualified personnel, were reviewed by management, and issues were identified and corrected in accordance with the licensees CAP. The inspectors reviewed CAP documents to determine if a sufficiently low threshold for problem identification existed; the quality of follow-up evaluations, including extent-of-condition; and if the licensee assigned timely and appropriate prioritization for issue resolution commensurate with the significance of the issue.
b. Observations and Findings The inspectors determined that issues were identified by the licensee at an appropriate threshold within various functional areas of the site and entered into the CAP. Issues were effectively screened, prioritized, and evaluated commensurate with safety significance. The scope and depth of evaluations were adequate in that the evaluations reviewed addressed the significance of issues and assigned an appropriate course of remedial action.
No findings were identified.
c. Conclusions The inspectors determined that the licensees corrective actions were adequately implemented in accordance with its CAP.
1.4 Maintenance and Surveillance (IP 62801)
a. Inspection Scope The inspectors toured the plant to assess the proper operation of the temporary liquid waste system for discharging to the Mississippi River.
b. Observations and Findings Based on a review of records and procedures of the maintenance and surveillance of the temporary liquid waste discharge system, the inspector determined that the effluent releases were properly controlled to maintain the requirements of the ODCM.
No findings were identified.
c. Conclusions The inspectors determined that the licensee effluent control equipment was in proper operation to maintain the requirements of the ODCM.
1.5 Decommissioning Performance and Status Review at Permanently Shut Down Reactors (IP 71801)
a. Inspection Scope The inspectors conducted site tours to assess field conditions and decommissioning activities and to ensure that radioactively contaminated areas were being controlled.
b. Observations and Findings Work areas were observed to be adequately controlled, postings and boundaries were appropriate, and workers were following established procedures.
No findings were identified.
c. Conclusions The inspectors determined that the licensee was adequately controlling decommissioning activities and radiological work areas.
2.0 Radiological Safety 2.1 Occupational Radiation Exposure (IP 83750)
a. Inspection Scope The inspectors reviewed the work instructions, As Low As Is Reasonably Achievable (ALARA) pre-job reviews, and radiation work permits associated with the decontamination of the former tent area adjacent to the reactor building used for the storage of wastes generated from the reactor dismantlement.
b. Observations and Findings The radiological planning of the health physics staff pre-job meeting provided adequate radiation protection coverage and the ALARA reviews were effective in minimizing unnecessary doses. All licensee personnel were knowledgeable about the hazards of the evolutions being performed and the proper radiation protection protocols for any radiological incidents. The personnel exposures were well below 10 CFR Part 20 limits.
No findings were identified.
c. Conclusions The inspectors determined that the licensee continued to be effective in controlling radiation worker personal exposure.
2.2 Radioactive Waste Treatment, and Effluent and Environmental Monitoring (IP 84750)
a. Inspection Scope The inspectors evaluated the licensees activities to effectively control, monitor, and quantify releases of radioactive materials in liquid and particulate forms to the environment.
b. Observations and Findings The licensee set up continuous air sampling stations around the boundary of the radiological controlled area. Based on a review of air sampling results, the inspectors determined that no radionuclides were identified except naturally occurring radionuclides. The inspectors also reviewed records for liquid effluent discharges and determined that the releases were well below 10 CFR Part 20 limits.
No findings were identified.
c. Conclusions The inspectors determined that the licensee adequately implemented its effluent monitoring program.
2.3 Transportation of Radioactive Materials (IP 86750)
a. Inspection Scope The inspectors reviewed radioactive waste shipping documents for selected shipments and conducted interviews of the responsible individual to ensure compliance with NRC and DOT regulations.
b. Observations and Findings The licensee shipped waste generated from soil remediation for the preparation of FSSs to the Clive disposal site in Utah. All the wastes were NRC Class A waste and a DOT Type A quantity of Low Specific Activity (LSA)-II material.
The licensees shipping manifest showed that personnel packaged, labeled, and marked each shipping container according to the DOT and 10 CFR Part 71 transportation requirements. The licensee verified that the results of radiation and removable contamination levels were within applicable limits. The waste manifest included all required information.
No findings were identified.
c. Conclusions The inspectors determined that the licensee had complied with NRC and DOT regulations for shipments of radioactive waste.
3.0 Confirmatory Survey 3.1 Final Status Surveys at Permanently Shutdown Reactors (IP 83801)
a. Inspection Scope The inspectors observed the licensee conducting FSSs and reviewed the sampling results of the reactor bowl, former tent area adjacent to the reactor building, RPGPA sump base area and surrounding sloped area, and the open lands including stormwater pipes. The inspectors observed the licensee conducting angle core boring beneath the reactor bowl and reviewed the sampling results. The NRCs survey contractor, Oak Ridge Associated Universities, was also onsite conducting independent confirmatory surveys of the reactor bowl and various remediated and FSSd survey areas. A State of Wisconsin official accompanied an NRC Region III supervisor during some of the independent surveys. The inspectors verified the calibration of the on-site Ge(Li) and high purity germanium detectors used to analyze the soil samples. All the hard-to-detect radionuclides were analyzed by a certified off-site laboratory. The inspectors also verified the calibrations and the setups of the gamma counting systems used to scan and analyze the activities of the stormwater pipes.
b. Observations and Findings The licensee conducted walk over scans and collected biased and systematic samples in accordance with the FSS plan. All the sampling results of biased and systematic samples were well below the operational Derived Concentration Guideline Levels (DCGLs), which were set at 25% of the DCGLs from the License Termination Plan (LTP).
The core samples taken from soil beneath the reactor bowl and RPGPA sump base area were beneath the water table. Because no samples containing Sr-90the dominant dose-producing isotope for the groundwater pathway----were identified, and only Cs-137 and Co-60---the dominant dose-producing isotopes for external exposure--
--were positively identified, the DCGLs from the LTP for soil surface to 1 meter depth were conservative for the contaminated zone beneath the water table.
Because the RPGPA sump base area and surrounding sloped areas were backfilled prior to the FSS, the licensee conducted biased and systematic core borings during the FSS. With the depth of the backfills being up to about 23 feet, at each core boring location four consecutive one-meter-core-samples were collected to ensure any potential contaminated areas were identified. The licensee also conducted additional core borings around each core boring where elevated samples were identified to delineate the contaminated zone. The inspectors determined that the licensee collected adequate core samples to demonstrate that the average concentrations of each individual contaminated zone were below the operational DCGLs, which were set at 25% of DCGLs from the LTP.
No findings were identified.
c. Conclusions A preliminary review of selected licensee survey data and of the NRCs draft confirmatory survey data indicated to the inspectors that the reactor bowl, former tent area adjacent to the reactor building, Reactor Plant Generator Plant Access (RPGPA)
sump base area and surrounding sloped area, and open land areas, including areas containing stormwater pipes, met the criteria specified in 10 CFR 20.1402. A final conclusion will be made by NRC headquarters staff after review of all submitted licensee survey data and of the final NRC confirmatory survey data.
4.0 Exit Meeting The inspectors presented the inspection results to the licensees Radiation Protection Manager at the conclusion of the inspection on September 26, 2019. The licensee did not identify any of the documents or processes reviewed by the inspectors as proprietary.
ATTACHMENT: SUPPLEMENTAL INFORMATION
SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED J. Nowak, LaCrosseSolutions, Site General Manager J. Spaide, LaCrosseSolutions, D&D Manager S. Zoller, LaCrosseSolutions, Radiation Protection Manager J. Henkelman, Dairyland Power Cooperative, Quality Assurance Specialist INSPECTION PROCEDURES USED IP 36801 Organization, Management, and Cost Controls IP 40801 Self-Assessment, Auditing, and Corrective Actions IP 37801 Safety Reviews, Design Changes and Modifications IP 62801 Maintenance and Surveillance IP 71801 Decommissioning Performance and Status Review IP 83750 Occupational Radiation Exposure IP 84750 Effluent and Environmental Monitoring IP 86750 Transportation of Radioactive Materials IP 83801 Final Status Surveys at Permanently Shutdown Reactors ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None Discussed None PARTIAL LIST OF DOCUMENTS REVIEWED The following is a partial list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather that selected sections of portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
- 50.59 Review No. 2019-001, LC-OP-PR-001, Direct Discharge of Liquid Radiological Waste Without Dilution Flow; Revision 6
- 50.59 Review No. 2019-012, LC-FS-PR-009, Revision of Final Status Survey Data Reporting; Revision 4
- Liquid Effluent Releases: 19-024L, 19-025L, 19-026L
- Waste Shipments, RW 19001-19020
- Final Status Surveys: L1-SUB-TDS B (RPGPA); L1-SUB-TDS A (Sloped Area by RPGPA);
L1-SUB-PAD (Tent Area); L1-SUB-SRX (Sloped Area by Reactor Foundation; Open Land; L1-010-101 through L1-010-107; L2-011-101 through L2-011-104; L3-012-101; L3-012-102; L3-102-109; S3-012-109 B (48 Concrete Pipe); S3-012-102 A (12 Clay Pipe); S3-012-102 B (30 Clay Pipe)
Attachment
INITIALISMS AND ACRONYMS ADAMS Agencywide Documents Access and Management System ALARA As Low As Is Reasonably Achievable CAP Corrective Action Program CFR Code of Federal Regulations DCGL Derived Concentration Guideline Level DOT U.S. Department of Transportation DNMS Division of Nuclear Materials Safety FSS Final Status Survey LACBWR La Crosse Boiling Water Reactor LTP License Termination Plan LSA Low Specific Activity NRC U.S. Nuclear Regulatory Commission ODCM Offsite Dose Calculation Manual ORAU Oak Ridge Associated Universities RPGPA Reactor Plant Generator Plant Access RWP Radiation Work Permit TS Technical Specification 2