ML19259B631
| ML19259B631 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 01/24/1979 |
| From: | Fisher W, Greger L, Hiatt J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19259B629 | List: |
| References | |
| 50-409-78-17, NUDOCS 7903130472 | |
| Download: ML19259B631 (12) | |
See also: IR 05000409/1978017
Text
.
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-409/78-17
Docket No. 50-409
License No. DPR-45
Licensee: Dairyland Power Cooperative
2615 East Avenue - South
La Crosse, WI 54601
Facility Name:
La Crosse Boiling Water Reactor
Inspection At:
La Crosse Boiling Water Reactor Site, Genoa, WI
Inspection Conducted: December 18-21, 1978
Inspectors:h.vJ
R. Greger
l
JN [7 7
v.'Y.
%
h~'J.W.Hiatt
l /c2 Y/7 Y
V Y
s k u.1
Approved By:
W. L. Fisher
( [.2Y 79
Inspection Summary
Inspection on December 18-21, 1978 (Report No. 50-409/78-17\\
Areas Inspected:
Routine, unannounced inspection of radiation
protection program, including: qualifications; audits; training;
radiation protection procedures; instruments and equipment; exn
,uis
control; posting, labeling, and control; surveys; notifications an;
reports; bulletins and circulars; and licensee cetion on previously
identified enforcement items and commitments.
The inspection involved
65 inspector-hours on cite by twc N". inspectors.
Results: Of the 11 areas inspected, no items of noncompliance or
deviations were found in 10 areas; one apparent item of noncompliance
was found in one area (infraction - lack of process or engineering
control or other precautionary procedures to limit exposure of
individuals to airborne concentrations of radioactive material -
Paragraph 10).
79031309 & -
.
.
DETAILS
1.
Persons Contacted
- L. Krajewski, Health and Safety Supervisor
- R.
Prince, Radiation Protection Engineer
- R. Shimshak, Plant Superintendent
H. Towsley, Quality Assurance Supervisor
P. Wiley, Assistant to Operations Engineer
The inspectors also contacted several other licensee employees,
including members of the technical and engineering staffs.
- Denctes those attending the exit interview.
2.
General
This inspection, which began at 11:20 a.m. on December 18, 1978,
was conducted to examine the licensee's radiation protection
program and related activities for compliance with regulatory
requirements. A general tour and inspection of licensee facilities,
including the turbine building, containment building, and control
room, was conducted on December 18, Jn78.
Additional licensee
facilities, including the waste tree' >nt building, arack sampling
area, laboratory and counting area, ,
e?7 rage buildings, were
toured during the inspectior..
3.
Licensee Action on Previous Inspection Findings
(0 pen) Noncompliance (50-409/77-23):
Inadequate evaluation of
whole body counting results for compliance with 10 CFR 20.103.
Although the licensee had completed a procedure for evaluating
whole body counting results, the procedure requires revision
regarding the criteria for correlating insoluble nuclide
counting results to airborne exposures.
(Closed) Noncompliance (50-409/77-23):
Failure to post a high
radiation area in the vicinity of the seal injection reservoir.
The area had been properly posted.
No further high radiation
area posting discrepancies were identified.
(Closed) Unresolved Item (50-409/77-23):
Incomplete documentation
substantiating resolution of an airborne exposure incident.
Review
of corrected isotopic analysis results and airborne exposure
records for the occurrence substantiated the licensee's conclusion
that no airborne exposure in excess of 40 MPC-hours was incurred
as a result of the incident.
-2-
.
.
4.
Organization
The licensee's radiation protection organization consists of the
Radiation Protection Engineer, the Health and Safety Supervisor,
and six Health and Safety Technicians, one of whom is classified
as a trainee. The Health and Safety Supervisor reports directly
to the Plant Superintendent. The Radiation Protection Engineer
position is currently a staff position with no direct responsibility
for conduct of Health and Safety Department Activities.
It is
anticipated that this arrangement will be changed soon, with the
Health and Safety Supervisor reporting through the Radiation
Protection Engineer. The Radiation Protection Engineer posit.ou
was created since the previous radiation protection inspection to
provide additional technical expertise in radiation prgfecgfon and
radwaste activities, an area of recurrent NRC concern.-
-
The current Radiation Protection Engineer appears academically
qualified but has had limited nuclear power plant experience and
does not meet Regulatory Guide 1.8 recommendations for Radiation
Fe c* action Manager qualifications due to this limited experience.
The Radiation Protection Engineer does meet the technical speci-
fication requirements for his position (i.e. ANSI N18.1-1971).
Since the previous radiation protection inspection, offshift
radiation protection coverage by Health and Safety Technicians was
instituted. According to licensee personnel, the Health and Safety
Technicians are capable of successfully accomplishing the radiation
ed in the NRC (NRR) " Criteria for
protection activities descre
Individuals Qualified in Radiation Protection Procedures," although
the specific " criteria" are not included in the documented training
for Health and Safety Technicians.
This matter was discussed at
the exit interview.
No items of noncompliance or deviations were identified.
5.
Licensee Audits
The inspectors reviewed the results of an audit of the Health and
Safety Department conducted by the LACBWR Quality Assurance Staff on
May 24, 1978. The audit coverage was fairly comprehensive.
Corrective
actions were noted to have been instituted for identified discrepancies.
The Safety Review Committee (SRC) has not conducted a comprehensive
audit of the Health and Safety Department since 1976, although an
SRC audit in late 1978 examined selected aspects of the program.
These audit results will be reviewed during a future inspection.
1/ IE Inspection Report No. 50-409/77-03.
2/ IE Inspection Report No. 50-409/77-23.
-3-
.
.
The inspectors reviewed the licensee's internal incident reports
for 1978, including two reports concerning location and removal
of suspected fuel particles at the 701-foot level in containment
and in the reactor cavity drain line.
No items of noncompliance or deviations were identified.
6.
Training
Radiation protection orientation is provided in one of two formats,
either a brief (about one-half hour) version or a longer, more
detailed version (about one-half day).
The brief version is
given to all individuals who will be escorted while at the site
and to persons who frequent the plant and are familar with
basic radiation protection concepts (e.g. NRC inspectors, vendors,
etc.).
Topics covered include LACBWR's access control system,
evacuation alarms, basic biological effects of radiation, and
fundamental ALARA concepts. The longer or complete orientation
is given to persons who will be issued a security badge and will
have unescorted access to the radiologically restricted areas
of the plant. The complete orientation includes more detailed
discussion of the topics covered in the brief version, and, in
addition, respiratory protection training. Both versions are
taught by either the Health and Safety Supervisor nr the
Radiation Protection Engineer, usually in a one
. -one discussion
with the trainee.
No tests are given.
The inspector received the complete orientation from the Radiation
Protection Engineer and noted that the topics required by 10 CFR 19.12
wereadequatgpygresented.
In response to concerns from previous
'
inspections,
the licensee has included discussion af engineering
controls of airborn radioactivity and MPC-hour calculations and has
revised the long version orientation outline to better assure con-
tinuity in the training content.
All site and contract personnel receive retraining annually.
In the
past, this training had basically been a review of Volume X of the
LACBWR Operating Manual (Health Physics Procedures). However, in
1978 the licensee supplemented the retraining with lecturer on
radiobiology, 10 CFR 19, and 10 CFR 20.
The licensee intends to
incorporate other topics, (e.g. instrumentation, dosimetry, etc.)
in the retraining program. Health and Safety Technicians have been
receiving the same retraining as other personnel, but the licensee
int nds to augment their training with additional training in
theoretical health physics.
In 1978, two technicians attended a
short course in health physics and two others attended a course in the
operation of the newly acquired multichannel analyzer.
3/ Ibid.
4/ IE Inspection Report No. 50-409/77-08.
_4-
.
The inspector reviewed initial and refresher training records
(CY 1978) for selected site and contract personnel.
Training
and/or retraining had been received as required.
No items of noncompliance or deviations were identified.
&
7.
Radiation Protection Procedures
The inspectors reviewed revisions made to Volume X (Health
Physics Procedures) of the LACBWR Operation Manual and Health and
Safety Department Procedures and Memoranda.
The revisions did not
appear to diminish the effectiveness of the radiation protection
program.
Toe licensee intends to write a procedure describing the Health
and Safety Technician training and retraining program and to
initiate changes in the respiratory protection and whole body
counting procedures.
(See Paragraphs 6 and 10). These items
will be reviewed further during future inspections.
No items of noncompliance or deviations were identified.
8.
Instruments and Equipment
Inventories and calibrations of radiation and contamination survey
instruments, fixed radiation monitors, and continuous air monitors
were selectively reviewed for CY 1978.
Calibration frequencies
were noted to conform to the licensee's technical specification
and procedural requirements.
The alarm setpoints for the mobile and turbine building mezzanine
continuous air monitors were changed since the previous radiation
protection inspection.
The current setpoints correspond to 9E-9uCi/ml,
which is conservative with respect to FTC's calculated from typical
airborne samples and is low enough to warn of an abnormal increase
in airborne activity.
Survey instruments are normally calibrated onsite except for the
neutron survey meters (PNR-4) which are normally calibrated offsite
annually then checked for continuity of response onsite semiannually
with a neutron source (PuBe). One of the two neutron survey meters
had not been calibrated offsite for about two years; the semiannual
calibration checks did not indicate a significant deviation in response
over that period.
_5_
.
.
The potential erroneous response of iodine monitors due to absorption
of noble gases onto the charcoal was discussed with licensee personnel.
The licensee does not have any iodine monitors and was aware of the
potential problem with iodine samplers.
No items of noncompliance or deviations were identified.
9.
External Exposure Control
Thermoluminescent dosimeters (TLDs), direct reading pocket dosimeters,
and neutron dose calculations are used to monitor personal exposures.
Dosimetry records for CY 1978 .<ere reviewed; no doses greater than
10 CFR 20.101 limits were noted.
The highest annual and quarterly
whole body doses recorded were about 4 rems and 2.5 rems, respectively.
These doses are within the licensee's internal goal of maintaining
annual individual doses below 5 rems.
Selective review of NRC-4's
for personnel who received more than 1.25 rems during a quarter
did not reveal any discrepancies.
Neutron doses are calculated based on stay times and neutron dose
rates measured with a portable survey meter (PNR-4).
At the
end of each calendar quarter, the licensee sends the TLD vendor the
calculated neutron dose per individual for that quarter.
The neutron
dose is added to the individual's cumulative dose total. According
to these reports for the first three quarters of 1978, no individual
received above 300 mrems/ quarter; there were no individuals exceeding
100 mrems in the first quarter, 12 exceeded 100 mrems the second quarter,
and l' exceeded 100 mrems the third quarter.
The highest quarterly
neutron dose recorded was about 200 mrems.
The licensee had installed additional shielding around the TLD badge
storage rack to reduce extraneous exposures to the stored TLD badges.
The licensee also started storing the control badges in the Health and
Safety Supervisor's office.
This latter practice may still result
in nonconservatisms depending upon the radiation levels in the
office. This matter was discussed at the exit interview.
No items of noncompliance or deviations were identified.
10.
Internal Exposure Control
The licensee's program for control of internal exposures consists
of the use of protective clothing and equipment, reduction of surface
and airborne contamination levels, and utilization of airborne
survey information and stay-time calculations. Whole body
counting and urinalyses supplement the routine monitoring
program to provide retrospective information regarding airborne
exposures.
-6-
.
a.
Respiratory Protection
Although procedures for implementation of the respiratory
protection program have been written and approved since
the previous radiation protection inspection, the respira-
tory protection program still has not been fully 5 plemer.ted.
The licensee therefore continues to be unable to take credit
for the use of respiratory e uipment in estimating exposures
s
of individuals to airborne radioactive material.
However,
respiratory equipment is used as a precautionary measure in
certain situations. Exposures to airborne radioactive materials
in these situatfens are controlled on the basis of air samples,
as is the case when individuals do not wear respiratory
protective equipment.
The inspectors reviewed the licensee's respiratory program
procedt zes (Section 10, Volume X of the LACBVR Operation
Manual'. and the MPC-hours records for CY 1978.
No airborne
exposures in excess of 40 MPC-hours were noted based on airborne
surveys and stay-time calculations. Several minor discrepancies
in the respiratory procedures were discussed with licensee
personnel. The major portions of the licensee's respiratory
protection program which have not been implemented to date
include:
(1) Medical determinations that individuals are physically able
to use respiratory protective quipment and perforn required
work.
(2) Performance of facepiece fit-testing.
(3) Determination that supplied air is of approved quality.
(4) Completion of bioassay program.
These items will be reviewed further during a future inspection.
During a previous inspection 5/
two individuals had been iden-
,
tified as possibly exceeding the 40 MPC-hours control measure
based on airborne survey information.
The licensee subsequently
revised the calculated exposures for these individuals based
upon additional analyses of the air samples and concluded that
the 40 MPC-hours control measure was not exceeded.
The inspec-
tor reviewed the licensee's airborne sampling results for this
occurrence and has no further questions regarding this matter.
5/ IE Inspection Report No. 50-409/77-23.
-7-
.
b.
Whole Body Counting
Whole body counting is performed semiannually for those
individuals who routinely work within the restricted (radio-
logical) plant areas and annually for the remainder of the
plant staff. The licensee continues to use a fabricated
chair-type counting arrangement with a NaI detector.
Shielding
additions to both the chair and the detector have resulted in
a lowering of the setection levels for most nuclides.
Typical
detection levels are less than 10 nCi (at three sigma confidence
level) for I-131, Cs-134, Cs-137, and Co-58 and less than 15
nCi (three sigma) for Co-60.
These detection levels represent
a factor of two to three reduction over previous detection
levels.
The inspecto-
.ewed the whole body count ig results for
CY 1978. W
few exceptions, the whole body counting data
did not P
. ate the presence of significant internal depositions
of radio.
lides. In all cases but three, elevated whole
body counts were found to be invalid upon recounting the
involved individuals.
Two of the elevated whole body count
casesresultedfromindividua}sworkinginahighlycontaminated
(approximately lE6 dpm/100 cm ) area in December 1977. Accord-
ing to licensee personnel, the two individuals were instructed
to decontaminate the area before commencing their work.
This
was not done and presumably the two individuals were exposed
to excessive airborne ra?.ioactive material which was resuspended
in the course of their work. Air samples taken the previous
day in the same general area showed about 4 MPC airborne
concentrations; the two individuals were not wearing respiratory
protection equipment. Whole body counts performed on the two
individuals over the subsequent several months, although not
ideal, indicate that the individuals were exposed to greater
than 40 MPC-hours but less than 520 MPC-hours of airborne
radioactive material as a result of this occurrence.
Estimates
of the exposures are approximately 75 MPC-hours and 125 MPC-hours
for the two individuals.
Exposure estimates based on the
stay-times and previous airborne surveys result in about 5
MPC-hours predicted exposure.
The evaluations performed by the
licensee for these individuals were somewhat weak in that:
(1) The individuals were not whole body counted for two days
after the incident was discovered.
(2)
Early whole body counting data are suspect because of
spurious problems encountered with a loose detector
assembly.
-8-
.
.
(3) Other than analysis of whole body count data, no attempt
was made to determine the solubility of the radioactive
material.
The licensee has since adopted a procedure for evaluation
of bioassay results (HSP 13.5).
Review of Procedure HSP 13.5
revealed several discrepancies. Licensee personnel stated
that they were aware of problems with the procedure and were
working on a revision.
The revised procedure will be reviewed
during a future inspection.
10 CFR 20.103(b) requires that process or other e gineering
controls be used, to the extent practicable, to limit airborne
concentrations of radioactive materials to less than " airborne
radioactivity area" levels.
In the above case, the whole body
count data suggest that the two individuals were ex osed to
well in excess of the airborne levels delimiting an " airborne
radioactivity area" as a result of the failure to decontaminate
the work area before commencing the job. This represents
noncompliance with 10 CFR 20.103(b).
One additional case involving a possible excessive air-
borne exposure occurred. An indisidual working on the
core spray bundle in February 1978, showed up with high
whole body counts. The individual was whole body counted
several times over the following six months.
The whole
Lody count data are somewhat conflicting, with the earlier
_ counts indicating significantly greater airborne exposure
than the latter counts. According to licensee personnel,
the individual wore a respirator (full-face, air purifying)
and a representative air sample was taken during the job.
The air sample indicated an exposure of about 5 MPC-hours
while the whole body count data suggest an exposure of
20 to 35 MPC-hours. The air sample is somewhat suspect,
since about 20 feet of suction hose was used upstream of
the filter paper. This matter was discussed at the exit
interview.
An individual identified as having pn ex essive whole body
6
count during a previous inspection- had been recounted and
it was determined that the exposure did not xceed any regu-
latory requirements.
11.
Posting, Labeling, and Control
During inspection of the licensee's facilities, the inspectors
examined radiation caution sign postings, high radiation area
access controls, radiation work permit usage, and survey postings
6/ Ibid.
-9-
.
for conformance to regulatory requirements and the licensee's
procedures. General radiation protection related housekeeping
was very good. One poor posting practice was noted in the contain-
ment basement. The basement entry points are posted and alarmed
(locally and in the control room) to warn of high radiation areas
which exist in several areas of the basement. However, the high
radiation areas were not all posted locally.
In particular,
general radiation levels in the walkway adjacent to the shutdown
cooling heat exchanger were approximately 300 mR/hr but the area
was not posted to indicate the higher radiation levels.
This
item was discussed at the exit interview.
Areas containing radiation fields in excess of 1000 mR/hr were
noted to be controlled as required by 10 CFR 20.203(c)(2).
Radiation (special) work permits (SWP) are required for work
performed under defined radiological conditions.
The inspectors
selectively reviewed the licensee's SWPs and radiation protection
log entries for CY 1978. No discrepancies were noted.
The
radiation log entries were so
improved over those noted
during a previous inspection.77what
The documents required to be posted pursuant to 10 CFR 19.11 were
noted to be posted as required.
No items of noncompliance or deviations were identified.
12.
Surveys
Routine smear and direct radiation surveys are made at established
frequencies and as needed.
The inspectors reviewed survey records
for selected months since the last radiation protection inspection
and noted that the licensee routinely performs neutron surveys
in the containment and turbine buildings. No problens were
identified. Neutron dose rates in the containment basement are
p-
.11y less than 50 mrems/ hour except for the CRD platform,
where dose rates of up to 400 mrems/ hour exist.
General area
nuetron dose rates in the remainder of the containment building
are less than 5 mrems/ hour,except for two locations on the grade
level of up to 50 mrems/ hour and some areas of the mezzanine
level with up to 10 mrems/ hour.
The licensee's records of sealed source leak tests and inventories
were reviewed for the period since the last radiation protection
inspection. Leak tests had been performed within the required six
month frequency. No leaking sources were found.
No items of noncompliance or deviations were identified.
7/ Ibid.
- 10 -
.
13.
Notifications and Reports
Selected records of notifications and reports related to radiation
protection activities as required by 10 CFR 19, 10 CFR 20, and the
technical specifications were reviewed for the period since the
preceding radiation protection inspection.
No items of noncompliance or deviations were identified.
14.
Review of Bulletins and Circulars
The inspectors reviewed the licensee's actions regarding the
following Bulletins and Circulars.
IEB 78-07: Protection Afforded by Air-Line Respirators and
Supplied-Air Hoods
IEB 78-08:
Radiation Levels from Fuel Element Transfer Tubes
IEC 78-03:
Packaging Greater than Type A Quantities of Low
Specific Activity Radioactive Material for Transport
Although the specified actions for IEB 78-07 are not currently
applicable since the licensee does not presently take credit for
use of respiratory protective equipment, the licensee's proposed
respiratory program procedures did not incorporate the information
in the bulletin. This item will be reviewed further during a
future inspection.
IEB 78-08 is not applicable.
IEC 78-08 was discussed with licensee personnel.
No problems
were noted.
No items of noncompliance or deviations ware identified.
15.
Exit Interview
The inspector met with licensee representatives (denoted in
Paragraph 1) at the conclusion of the inspection on December 21,
1978, and further discussed the inspection findings with
Mr. J. Parkyn by telephone on January 10, 1979.
The inspectors
5tmmarized the scope and findings of the inspection.
In response
ts certain items discussed by the inspectors, the licensee:
a.
Stated that Health and Safety Technician training would be
modified to specifically include and document the radiation
protection activities described in the NRC (NRR) " Criteria
for Individuals Qualified in Radiation Protection Procedures."
(Paragraph 4)
- 11 -
.
.
b.
Stated that neutron survey meters would be calibrated offsite
annually if onsite calibration capabilities were inadequate.
(Paragraph 8)
c.
Acknowledged the inspectors' remarks concerning storage of
TLD badge controls and stated that the matter would be
reviewed.
(Paragraph 9)
d.
Stated that the respiratory protection program would be
implemented in the near future and that the outstanding items
identified by the inspectors would be resolved.
(Paragraph 10)
e.
Acknowledged the inspectors' remarks concerning the noncom-
pliance.
(Paragraph 10)
f.
Stated that airborne sampling techniques would be reviewed
for adequacy, especially the use of long suction hoses.
(Paragraph 10)
g.
Stated that the containment basement high radiation area
postings would be reviewed to ensure adequate warning of
local high radiation areas.
(Paragraph 11)
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