ML19345G694
| ML19345G694 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 03/27/1981 |
| From: | Linder F DAIRYLAND POWER COOPERATIVE |
| To: | Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19345G693 | List: |
| References | |
| LAC-7435, NUDOCS 8104220079 | |
| Download: ML19345G694 (4) | |
Text
O I
D DA/RYLAND h
[k COOPERAT/VE
- PO BOX 817 2615 EAST AV SOUTH + LA CROSSE W:SCONSIN 54601 (608) 788 4 000 March 27, 1981 In reply, please refer to LAC-7435 DOCKET NO. 50-409 Mr. R.
F.
Heishman, Chief Reactor Operations and Nuclear Support Branch U.
S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
SUBJECT:
DAIRYLAND POWER COOPERATIVE LA CROSSE BOILING WATER REACTOR (LACBWR)
PROVISIONAL OPERATING LICENSE NO. DPR-45 IE INSPECTION REPORT NO. 50-409/80-01
Reference:
(1)
NRC Letter, Heishman to Linder, dated February 17, 1981.
Dear Mr. Heishman:
In response to your letter (Reference 1) which forwarded a notice of apparent non-compliance with NRC requirements as a result of the sub-ject inspection, we are submitting the following information:
ENFORCEMENT ITEM Violation "10 CFR, Part 20, Section 20.203 states, in part:
".....(c)(2) Each entrance or accese point to a high radiation area shall be:.....(ii) Equipped with a control device which shall cnergize a conspicuous visible or audible alarm signal in such a manner that the individual entering the high radiation area and the licensee or a supervisor of the activity are made avare of the entry; or (iii)
Maintained locked except during periode uhen access to the area is required, uith positive controt over each entry."
LACBWR Technical Specification 3. 9.1 states:
" Written procedures and administrative policies shall be established, implemented and maintained...."
" Procedures for personnel radiation protection shall be prepared con-eistent with the requirements of 10 CFR, Part 20 and shall be approved, maintained and adhered to for all operatione involving personnel radia-tion exposure."
8104 220h g3gg
s Mr.
R. F.
Heishman, Chief LAC-7435 Reactor Operations-and Nuclear Support Branch March 27, 1981 LACBWR Technical Specification 3.13.1 etates:
"In lieu of the " control device" or "atarm signat" required by paragraph 20. 203(c)(2) of 10 CFR 20:
Each High Radiation Area in uhich the intensity of radiation is greater than 100 mrem /hr but less than 2000 mrem /hr shalt be barricaded and conspicuously posted as a High Radiation Area and entrance thereto shall be controtted by iceuance of a apecial Work Permit and any individual or group of individuate permitted to enter auch areas shalt be provided vith a rad; tion monitoring device which continuously indicates the radiation doce rate in the area."
LACBWR Operating Manual, Volume E, Section 2.7(2) states in part:
"..(a) Anyone entering a high radiation area is required to notify the Control Room, prior to entering and exiting a "High Radiation Area" or immediately after exiting the area if communications are impossible from within the area.... ic) Operatione is required to check out any entry alarme where the Control Room is notified prior to entries into "High Radiation Arcae,"...."
LACBWR Operating Manual, Volume X, Section 6.5.3 etates in part:
(7) Reverse Page - Each vorher assigned to the SWP vill complete the required information for each entry into the vork area on the entry copy of the SWP.
Contrary to the above:
1.
The Resident Inspectore noted on January 6, 1981 that tuo LACBWR maintenance personnel assigned to perform uork associated with a Special Work Permit (SWP):
Failed to notify the Control Room Operator prior to enter-a.
ing and exiting a "High Radiation Area" on numerous entries /
exits.
b.
Failed to replace the radiological control barrier when exiting.
c.
Failed to complete the required information on the reverse side of the SWP vhen entering and exiting the work area.
d.
Failed to utilize the radiation monitoring device provided for continuously indicating the dose rate in the area.
Note:
It was also noted the instrument did not have a calibration sticker. ~
Sp
l
\\
s l
Mr. R.
F.
Heishman, Chief LAC-7435 Reactor Operations and Nuclear Support Branch March 27, 1981 2.
The Resident Inspectors noted on January 6, 1981 that the Control Room Operator failed to check out or have checked out entry alarms received in the control room for entries into the full-flow demineralizer area of the turbine building and had not been notified in advance prior to entry into the area."
DPC RESPONSE:
The two LACBWR maintenance personnel assigned to perform work associated with a Special Work Permit (SWP) were interviewed and appropriate documents related to the observation of the Resident Inspectors were examined.
The maintenance personnel declared that they had signed the SWP copy maintained in the Maintenance Shop.
Due to the nature of the work involved in the Full-Flow Demineralizer Room, it was necessary to make frequent entries and exits and remain within the immediate vicinity of the portal to the Full Flow Dermineralizer Room.
Examples of such exits and entries would be the need for adjustments to service air pressure, picking up needed tools or fabricating pipe sections outside the work area, but remaining near by.
The procedural need to record dosimeter readings under such circum-stances would have impeded the practical progress of work.
The maintenance personnel stated that during the work day, they period-ically read their dosimeters and recorded the observed indications.
These observations were made upon initial entry, at the morning coffee break, at the noon lunch break, at the afternoon coffee break and at the end of the work day.
The information was recorded on the 0~7P copy maintained in the Machine Shop.
The maintenance personnel declared that the Control Room operator was notified prior to initial entry to the work area and a member of the Operations Department responded to the work area portal with a key to unlock the barrier.
At the end of the work day, the Control Room operator was similarly notified and response was made to lock the area.
When the work area was exited for relatively shorter periods, such as coffee break and lunch periods, the barrier was not locked.
The alarm at the portal was in operation during the entire period.
All. plant personnel are familiar with the fact that the Full-Flow Demineralizer Room is normally a high radiation area.
The room is not subject to frequent occupancy and the entrance is appropriately posted.
The systems were isolated during the course of the work - all three demineralizer service tanks were blown down and the condensate pumps _...
Mr.
R. F. Heishman, Chief LAC-7435 Reactor Operations and Nuclear Support Branch March 27, 1981 tagged out to prevent the occurrence of a condition which could have increased the dose rate in the work area.
In addition, an operator was assigned from time-to-time to accompany and assist the maintenance personnel.
The dose rates in the area, as a result of four surveys, indicated that the whole body gamma dose rates did not exceed 1 Rem per hour.
A survey meter was available at the entrance to the room, however, the procedural requirement for a continuous monitoring dose rate device was not met because a previous survey by an HP Technician indicated a general whole body dose rate of less than 100 mrem per hour in the work area.
This low reading was attributable to ALARA efforts undertaken by blowing down the tanks.
Corrective actions consisting of improved communications through retraining and instruction to all department personnel concerned with work of this nature and the use of improved indicating dose rate dosimeters together with more frequent and sustained coverage of work in actual or potential high radiation areas by health physics personnel were accomplished following discussions with the Resident Inspectors about their concerns.
The above corrective actions will continue to be implemented.
Authorization for this reply to be submitted beyond the twenty-five day reporting period was granted to Mr. John Parkyn by the Senior Resident Inspector on March 17, 1981.
If there are any questions concerning this response, please contact us.
Very truly yours, DAIRYLAND POWER COOPERATIVE Frank Linder, General Manager FL:RES:af cc:
NRC Resident Inspectors l