ML20004F661
| ML20004F661 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 05/19/1981 |
| From: | Linder F DAIRYLAND POWER COOPERATIVE |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20004F659 | List: |
| References | |
| LAC-7552, NUDOCS 8106190350 | |
| Download: ML20004F661 (13) | |
Text
3 6
O
.D DA)RYLAND hhf?=1 OOPERA TIVE o o Box en w s e m n r.ours a cnosse escons:n ww
'we> ree<oo May 19, 1981 In reply, please refer to LAC-7552 DOCKET NO. 50-409 Mr. James G. Keppler, Director U. S. Nuclear Regulatory Commission
. Directorate of Regulatory Operations
-Pegion III 799 Rocsevelt Road Glen Ellyn, Illinois 60137
SUBJECT:
DAIRYLAND PCFER COOPERATIVE LA CROSSE BOILING WATER REACTOR (LACRWP)
PROVISIONAL OPERATING LICENSE NO. DPR-45 IF INSPECTION REPOPT NO. 50-409/80 SPFCIAL APPRAISAL OF THE HEALTII PHYSICS PROGRAM Peference:
(1)
NRC Letter, Keppler to Linder, dated March 5, 1981.
rcar Mr. Meppler:
Durina the period September 22 to October 3, 1980, the NRC con-ducted a special appraisal of the Health ahysics Program at the La Crosse Poiling Water Reactor.
Findings of your appraisal indi-cated that some significant weaknesses existed in several areas cf our Health Physics Program as listed in Appendix A of your letter (reference 1).
In addition, your appraisal indicated that certain activities as listed in Appendix B of your letter I
~
(Feference 1) did not appear to have been conducted in full corpliance with NRC recuirements.
In respense to your letter we are submitting the following infor-ration which describes our corrective actions for each significant weakness in the !!ealth Physics Program as described in Appendix A.
In addition, in response to your letter, information describing corrective actions to apparent violations addressed in Appe-dix B is included.
Items which appear to recuire corrective action:
"1.
Cr;:niactional and managerial improvements are needed to ret.~:ve problems regarding health physica tech-ical expertise, out :Plidory p,?rBonnel vorkload, staffina, technician performar.ce, and r:dia tion protection program enforcemen t.
(sec tione 3. a, I.!.
?. 0, and 3.d)"
l 1 * * " "
- 810 6 ro a35C>..
y-e Mr. James C. Keppler, Director LAC-7552 U.
S.' Nuclear Regulatory Commission May 19, 1981 Ti c health physics technician training program requires irtrovement in terms of documented initial and refresher training requirements, and conduct of emergency campling anu cna!.ysis training.
(Sections 4.a and 13)"
"3.
Prcredural coverage and adherence need upgrading to include activities not presently addrecced and to resolve incon-cic:encice betucer procedures and actual practiceo.
(le-tionn 6, 9.a, 8.c,
- 9. b, 11.a, and 11.cI"
- Fe intarnal and axternal e=posure control programa need uTerading to incorporate formalized TLD cF iking, TLD/ pocket dccimetar intercortarisono, and whcie body counter calibrations and to annure che availability of a eufficient supply of respir-atery protective devices for accident response.
(Sectiona 7.a cr.d 7.b)"
"E.
The radiation survey program neede upgrading in terme of scope and frequency of direct radiation surveya, contamination currey coverage, and task oriented curveys.
(Sectione 8.a and e.c)"
"e.
The instrumentation program needs improvement to include calibra-tien acceptance criteria and to resolve problema regarding high range (accident) noble gas monitesing, personal contamination detcetion, and continuous air monitan calibratione.
(Sectione
- 9. b,
9.c,
- 9. d, 9.e and 11.a)"
"7.
A formalized ALARA program necdc to be developed.
(Section 10)"
DPC RESPONSE:
Dalryland Power Cooperative is improving and will continue to improve the technical expertise and the managerent of the LACBWR Health Physics staff.
Iiealth Physics Technicians will be sent to off-site technical radiological training schools such as the University of Michigan Short Course in Radiation Protection and the Nuclear Data Inc. ND-6600 computer training school.
These courses and others should. increase the technical expertise of the staff as a whole.
The current liealth and Safety Supervisor, promoted from the Health Physics Technician group and replacing the former Health & Safety Supervisor who resigned on January 16, 1981, has 10 years experience in Health Physics and Badio-Analytical Chemistry, both as an Engineer-ing Laboratory Technician in the U. S. Navy and at LACBWR.
In addition to his experience, he has 3 years of college credits, spec-ializing in chemistry, and has successfully completed the short course in Radiation Protection offered by the University of Michigan.
2-
j i.
Mr. James G. Keppler, Director LAC-7552 U. S. Fuclear. Regulatory Commission May 19, 1981 The Radiation Protection Engineer has been allowed to devote a larger portion of his time to the Health Physics and Radio-Analytical
?'anagement and Techs.# cal Direction.
This has been accomplished largely because the Revised Radiological Emergency Response Plan and Procedures are being completed by a combined effort of plant staff and Cocperative headquarters personnel.
Specific technical problems identified by the special HP appraisal team such as 1) high range noble gas monitoring, 2) stack monitor charcoal analyses and 2) isokinetic stack sampling system have been improved upon by the installation of an Eberline SPING-4 extended range particulate, iodine and noble gas monitoring system.
Improve-cents will continue in these identified specific areas with the future use of silver zeolite cartridges in place of charcoal for iodine scapling and with the future installation of an Eberline SPING-3 air conj *or for the reactor containment building.
The special HP appraisal team felt that LACBWR's Health and Safety workload appeared excessive.
The supervisory workload is in the process of being reallecated to allow for more time for the Health and Safety Supervisor to perform supervisory functions.
The Radia-tion Protection Engineer will perform a majority of the purely admin-istrative duties as the Radiation Protection Manager.
Technical improvecents and develcpment will be shared by the Health and Safety Supervisor and the Radiation Protection Engineer.
We contemplate establiching an additional management / technical position of Radiation Protection Engineering Assistant.
This person would assist the current Health and Safety management in the areas of training, pro-cedure revisions, instrument testing and calibration, administration and technical support.
The special HP appraisal team felt that LACEWE's current Health rhysics Technician staff, with an average experience level of over 5 years, has good continuity and more than adequately meets the cualification criteria of ANSI N18.1-1971 guidance.
The special HP appraisal team felt that with the current staffing levels, however, that the HP Technicians may be strained screwhat during periods of heavy workload, such as outages or extended absenteeism.
In 1981, we currently have a position for one HP Technician available and hope te fill this position about June 1, 1981.
After this position is filled, we hope to have one additional HP Technician position filled shortly thereafter.
We hope to fill these positions with personnel who meet or exceed ANSI N13.1-1971 qualification require-ments by hiring an ex-U. S. Navy Engineering Laboratory Technician or Radiation Health Officer, or by hiring an experienced utility Radiation / Chemistry Technician. i
Mr. James G.
Keppler, Director LA"-7552 U. S. Muclear Regulatory Commission May 19, 1981 The special HP appraisal team indicated that greater HP Technician
. inquisitiveness and responsibility appeared to be needed.
The HP appraisal team found the morale of the HP Technicians to be good.
IJCBWR's Health and 3afety Management has changed its policy of supervicion to one cf " management by objective".
The HP Technicians are currently included in the decision-making process.
The Health end Safety Supervisor and Radiation Protection Engineer are asking fcr HP Technicians' opinions and for them to take a'more active role in the overall direction of the Health Physics Program.
It is our feeling that this " management by objective" will improve the overall inquisitiveness and responsibility of each HP Technician.
The change in the realth and Safety management personnel has improved morale.
Additiencl HP Technicians, when hired, and the procurement of im-proved health physics and radio-analytical chemistry equipment will further improve HP Technician mcrale.
The special HP appraisal team indicated that LACEWR's radiation rrotection program has been loosely enforced in the past due primarily tc the lack of manpower to adecuately oversee each facet of the pro' ram.
g It is cur opinion that the enfcrcement of the program will be performed by all plant personnel.in the near future.
This will be accomplished ty providing a better training program in Health Physics which emphasizes the positive benefits of following all facets of the radio-Icgical protection program, as opposed to the issuance of radiological occurrcnce reports which emphasize the negative aspects of punitive action, except in the most severe cases which involve actual viola-tions cf 10CFR20.
The special HP appraisal team found LACBWR's HP Technician On-The-Job Training Program to be acceptable, but indicated that there were no documented formal training criteria, practical factor training require
~
ments, ncr testing for progression from OJT to HP Technician.
The appraisal tenh also felt that improvements were needed in the areas of
- 1) plant systems training, 2) emergency sample collection and analysis training and 3) an establishment of a training commitment time frame.
In 1981, we are or will be preparing formal HP Technician On-The-Job training procedures and checklists which establish necessary dccumen-tation in the areas of Radiological Protection, and Radio-Analytical Chemistry.
These procedures will be incorporated in Section 8 of Li.CBWR's Health and Safety Procedure.
In addition, we are plarning to
' ave.re HP Technician while on OJT attend certain plant systems trainirg sessions given by knowledgeable management personnel.
The radiatien Protection Fngineer has conducted formal documented FP Technician training for in-plant airborne activity sanple collection and analyses.
HP Technician training for calculaticns of off-site expcsures (X/Q) during accidents and emergency environmental sampling and anal"ses will be conducted in the near future.
Additional HP
.Mr. James G.
Keppler, Director LAC-7552 U. S. Muclear Regulatory Commission May 19, 1981
~ Technician emergency radiological response training will be com-pleted during 1981 or as additional post-TFT-emergency sampling eculpment is installed.
The special HP appraisal team indicated that formal refresher train-ing for HP Technicians is not defined.
The Radiation Protection Engineer is currently preparing formal HP Technician training manuals which will be used as part of the HP Technician refresher training.
The first manual was completed on April 1, 1981, and ir e?. titled " Health Physics Technician Training Manual, Part 1, Radiation Detection Principles and Instrumentation - Portable Instruments".
Tentatively, there will be eight HP Technician Training Manuals-as follows:
Part 2:
Radiation Detection Principles and Instrumentation -
Laboratory Counting Equipment.
Part 3:
Personnel Dosimetry Part 4:
Air Sampling Instrumentation and Techniques Part 5:
Bioassay Program Part 6:
Analytical Chenistry Part 7:
Radiation Biology Part 9:
Health Physics Technicians Qualification Guide.
These fcrmal training manuals will include technical information and practical applications of the U., S. Navy Engineering Laboratory Technician training nanuals, the Argonne National Laboratory Radia-tion Safety Technician Training Course and training courses in Health Physics developed at the University of Michigan and Purdue University.
These manuals will be ecmpleted as time permits.
In addition to the proposed training manuals, the EP Technicians are heing enrolled in off-site courses such as the ones offered by the Universi ty of Michigan and Nuclear Data C orporation.
The Health and Safety Management at LACBWR is investigating the possibility of aking r.adio-Analytical Chemistry Courses available to the HP Tech-nicians at the University of Wisconsin at La Crosse to further en-hance their technical expertise and practical knowledge.
The special HP appraisal team indicated that Health and Safety pro-cedural coverage and adherence needed upgrading to include activities
, I
.n_
Mr. James G..Keppler, Director LAC-7552 U. S. Nuclear Regulatory Commission May 19, 1981 net addressed and resolve any-inconsistencies between procedures and actual practices.
LACBWR's Health and Safety Procedures and Operating Manual, Volume X, are currently being reviewed and will be revised where applicable during 1981 and 1982.
These revised procedures should improve coherence with actual in-plant practices.
Guidance for procedure revisions will be obtained from ANSI-N18.7-1976 and U. S. NRC Regulatory Guide 1.3.
The special HP appraisal team indicated that our internal and txternal exposure control programs needed upgrading as indicated in Apper. dix A, Item 4.
We are now conducting TLD spikes on a ncnthly basia ning a 10 Curie Cesium-137 calibration source.
A procedure for TLD calibration and performance criteria has been developed.
During 1981, we plan to purchase a X and gamma ray
.cndtor eith integrating dose and dose equivalent rato functions, tich v;11 be traceable to NBS, to perform calibrations of the 10 Curie Cesium-137 source to verify decay corrected source strength ~
This ir.strument should have an accuracy of 1.0% and will be used te replace cur defective condenser R-Meter.
During 1981, we plan to investigate the procurement of known activity Sr-90 and depleted Uraniur t. labs for TLD beta dose equivalent calibrations.
We are currently using our Eberline PNR-4 neutron-Rem Meter with 3" and 9" pclyspheres to better approximate actual neutron energy response calibration factors which are added to TLD results to more accurately assess plant personnel neutron dose equivalents.
I prograr conparing TLD gamma doses with pocxet ionization chamber deses was begun in February, 1981.
A procedure describing TLD and pocket dosimeter intercomparisons is being developed.
Yhole Ecdy Counter calibrations are being delayed until the Whole Eody Ccunter can be added to our ND-6600 computer system, which is expected before August, 1981.
A new phantom and new calibration sources will be used for subsequent Whole Body Counter calibrations.
Fe are investigating the possibility of replacing our 1.5 to 4.5%
efficient 3" x 2" NaI (Tl) crystal in our chair counter with a Streamlined Solid State High Purity Germanium detector with an efficiency of 30% and a P/C of 50/1 to increase the resolution of cur Whcle Ecdy Counts and our counter overall efficiency to 8%.
Individual whole body count results are plotted to observe qualita-tive increasing or decreasing trends in personnel internal depc sition cf radicnuclides.
These plots are available upon request.
respirat,ry protection devices are inventoried en a renthly basis.
Pe are reviewing the need to procure additional N!OSH approved full
, 1 l
Mr. James G. Keppler, Director LAC-7552.
U.
S. Muclear Regulatory Commission
.May 19, 1981 face respirators and SCDA's for emergency use, and a.srall respir-ator fit test' booth as described in NUREG-0041.
In addition, we plan to investigate purchasing NIOSit approved half-mask respirators if acceptable respiratory protection f actors for their use can be established.
Portable air sampling equipment is currently being upgraded with the replacement of Staplex-type high volume air samplers with Radeco variable speed air samplers.
The new air samplers will be used with either charecal or silver zeolite cartridges for Iodine collection instead of charcoal impregnated filter papers to increase collection efficiency.
The new air samplers can be used in a high volume mode at a norinal 10 cfm for a rapid sample collection or at a low volume regulated flow rate for more representative sample collection.
New procedures for the variable speed portable air samplers' use and calibration are being written.
The special HP appraisal team identified weaknesses in our radio-Icgical survey program as indicsted in Appendix A, Item 5.
A Ifealth and Safety Memorandum No. CPC-28 was issued on December 11, 1980, which redefines the plant radiological restricted area as the plant protected area fence.
The Health and Safety Department is notified to determine neccssary training and monitoring requirements for personnel entry into the restricted area commensurate to work 1ccations within the restricted area.
Approp late Destricted Area information signs have been attachec to the plant protected area fence.
The Charge Roon friskers (HP210 GM probes and RM-14 Electronic Scalers) have been noved to an area of 1cwer background, which enables them to be used on the X1 scale ensuring more accurate determination of po-tential personnel contamination.
Checkout instructions and training have been provided.
The portal monitor is no longer located in the
~hange roon.
The HP-210 friskers are now considered to be the primary 4ans fcr personnel contaminaticn checks.
We are considering the use of a tacky-mat at the entry to the Change Roon to minimize the spread af loose surface contamination into the Change Rocr and points beyond.
All sigrificant personnel decontamination will be do.;ucented in the "ealth t r.d Safety Daily Log Book.
Due to the relatively low number of cases cf personnel decontaminaticn in the past, a separate decon-tamination log is not deemed necessary at this time.
l'ealt!: and Safety Memorandum which distinguishes plastic bag storage cf contcrinated and non-contaminated material by color differentiation Mr. James G. Keppler, Director LAC-7552 U. S. Fuclear Regulatory Commission May 19,'1981 will be written.
A new procedure and training for entry into and exit frem sequentially contaminated plant areas will be developed and implemented during 1981.
This procedure should help reduce personnel contamination and reduce the cpread of plant contamin-ction from affected work areas.
Contaminated surfaces that workers are likely to come in contact with are detern.ined with a job specific ccncamination survey.
Noramily, if work is to be performed in areas not frequently accessed, a decontamination effort will preceed the actual work to reduce protective clothing and respirator requirerents.
We are currently reviewing our contamination surveil-lanca p rogram and will supplement contamination surveys in high cccupancy zones to include certain vertical surface areas.
- 7. simplified, logistical method of color-coded Special Work Permits is being initiated at LACDWR.
This system uses a 4-color SWP form and a 2-color access control dose log form.
This new SWP system chculd eliminate confusion over completeness of dosimetry information
'chich it logged on the dose log forms, and should enable the Health cnd Saf ety Department to maintain better centrol of SWP issuance.
The prccedure addressing Hot-Spot postings is currently undergcing revisicn to reflect changes in the requirements fer posting Hot f po ts.
- 1. memorandum to the Operations Department requesting that they notify the Health and Safety Department of any changes in a plant system may cause a significant change in background radiation levels is being considered.
The Health and Safety Department would then per-form necessary surveys to assess any radiation level changes.
Over-all frecuency of direct radiation surveys by Health Physics Technicians will be decreased commensurate with frequency of personnel occupancy in,
specific plant areas.
This will be reviewed in the near future and a procedure outlining radiation survey frequency will be developed if apprcpriate. ' Copies of the most recent radiation surveys wil: be posted near the location in which the survey was performed.
Posting of air sample results is considered to be adequate because the activities are routinely recorded on air sample activity logs in the laboratory and on routine smear surveys.
We are considering adding air sample results to the SWP's, when activity results indicate respiratory protection is required.
The special HP appraisal team identified a need for improvement in instrument calibration criteria as indicated in Appendix A, Item 6.
As indicated previously, we plan to procure an NBS traceable instru-ment to replace our Condenser-R Meter to recalibrate our dose rate 1
a t
Mr. James G. Keppler, Director LAC-7552 U. S. Nuclear Regulatory Commission May 19, 1981 instrument calibration source.
All portable gamma survey instru-ments will be calibrated to this source at least semi-annually.
In addition, cutie-pie type instruments and newly acquired Xetex 205-A2 digital rate meters will be source checked with a Sr-90 check scurce prior to each use.
- 3SI N3
- 2-1978 will be reviewed and its reccmmendations will be inecrpor:ted into our instrument calibration prcgran where applic-elle.
Is indicated previously, we have replaced the portal monitor at the Change P:.om with more sensitive HP-210 GM friskers, and have provided information at the Change Room for proper rersonnel contamination check-cut.
Additional EF-210 GM friskers 11 be provided at the exit frc9 the Waste Treatment Building and the Security section of t he Admiristration Building in the future.
Procedures which define centaminstion. detection. equipment selection, use and calibration ill be revised where applicable.
Calibraticn sources for the new SPING air monitoring equipment have been purchased.
These sources will be used to calibrate the SPINGS cnd all other plant continuous air monitors.
Flow meter calibrations are performed using a flow meter which is traceable to NBS.
Fortable Radeco air sarplers will be flow calibrated by using a vendor supplied flow-calibrater which attaches directly to the sampler air inlet pert.
.uture effluent monitor calibrations will be performed at multiple reints using varying concentrations of radionuclides with similar isotopic compositions to reduce error associated with variance in "aI (TI) detecter energy response.
The exte nded range mobile gas monitors of the SPING-4 stack gas onitel zill be calibrated with a known standard ri::ture of Xe-133 and Kr-EE gases.
20% efficient, with a peak to Comptom ratio of greater than 50/1, Ce (LJ cr High Purity Intrinsic Germanium Detector is being purchased to ii:
- .e iretopic analyses of Environmental Samples.
We expect to 1 ave this new detector by June 1, 1981.
The special HP appraisal team indicated that a formalized ALARA Progran needs to be developed at LACBWR (Appendix A, Item 7).
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?!r. James G. Keppler, Director LAC-7532 U. S. Nuclear Regulatory Commission May 19, 1981 A new ALARA review form for Special Work Permits for jobs that are likely to exceed 1 Man Rem has been developed and has been used twice thus far, for the replacement of the recombiner catalyst and the replacement of the fuel pool system f.!1ters.
This form provides documentation of estimated Man Pem exposure based on previous similar jobs and provides documentation of additional frprovcrents which may reduce exposure in the future on similar jobs.
The special HP appraisal team indicated that improvements in the
':caticn of the Health Physics offices should be considered.
The Hecith and Safety Supervisor's Office was moved from the Admin-tstration Building to the Operations Supervisor's Office in the riant Auxiliary Building.
This office allows the Health and Safety
- -upervicor core direct access to the daily plant routine.
This office also previded adequate space for a HP Technician meeting and training icom.
The duty HP Technician on back-shif ts also uses this office
's his Lase of operations.
'Ji cla ti ens :
'i.
Il CFR.:0,201 (b) requires evaluationc ao nececcary to comply uith the requiremente of 10 CFR 20. :-03(b) for posting radiation arc;J.
Cc r rrary to the above, radiation levels that excoeded 5 mF/hr ucre measured by the appraisers, and. verified by ticensee perconnet, in an unposted area approximately eighteen inches frc-tha outnide wait of the vaste treatment building.
Although tFc radiation cource had been in place for approximately five dayc uhan discovered, the licensee's survey program had nct identified the c ceaeive radiation levete."
~
CPC RESTONSE:-
The HP Technicians have been instructed that whenever any movement of significant radioactive material in the waste treatment building has been dcne, they will survey the outside of the building to verify that
' hole tcdy radiation levels have not exceeded 5 mR/hr.
If the radia-tion levels at eighteen inches from the surface of the building have exceeded 5 mR/hr., but are less than 100 mR/hr., then appropriate "Cautien Radiation Area" signs and ropes will be used to demark the area until the radiation areas can be reduced.
"2.
Tcchnical Specification 3.9.1 and 3.11 recuice adherence to radiation protection procedures.
The foliovina instances o"'
this requiremen t care i.icntif hd during the fai:ure :c meet a; r rc isc 1. "
l
_ ~
Mr. James G. Keppler, Director IAC-7552 U. S. Euclear Regulatory Ccamission May 19, 1981 "a.
Procedure RSP 4.3, Section 6.16.requirca that retaining ring lock nuts on filled raduaste drums be tightened upcn removal of the drums from the compactor.
The lock nut le designed to prevent the retaining (ring) bolt fron loosening.
Contrary to the above, the lock nuts on approximately 25 percent of the raduaste drums being held for shipment vere not adequately tight to prevent retaining bolt move-ment.
"b.
Procedure RSP 2.6, Section 7.11' requires that areas con-tining dose rates uhich exceed the general area dose rate by a factor of three be posted " Caution Radiation ~ Rotspot".
Contrary to the above, the /ppraisal Team and the NRC resident inspectors identified four areas in the containment building and three areas in the turbine building uhich chould have been posted as hotspots but vere not.
"c.
Procedure RSP 2.9, Section 7.10 requires that beta-gamma curvey instrument calibration records include pre-calibration reading for comparison uith the post-calibration readings.
Ccncrary tc the above, pre-calibration readings vere not recorded for approximately SO percent of the 1980 calibra-rioMO.
"d.
Procedure RS.' 2. 9, Section 7.2 requirca multiple point eclibratione en each instrument ccale.
Cen:rcry to the above, at least one instrument (Technical
.' c ac cia te a CP-TP-1 A, No. 802), cae routine;y calibrated at aingle roints on the X1 and X10 scales.
"e.
Procedure RSP 2.8, Section 7.1 requires that portal mcnitors be source checked daily, uith specified acurces, to ensure prcper operation.
The specified source for the Eberline
?"C-42 portal monitor is a nominal 9600 dpm technetium-99 aclid source.
- ontrary to the above, the specified technitium-99 source is not used to perform the portal monitor source checks.
Scurces of significantly greater activity are used, resulting in : less sensitive check on the portal mcnitor response.".
Mr. James G. Keppler, Director LAC-7552 U.
S. Nuclear Regulatory Commission May'19, 1981 DPL RESPONSF:
a.
The lock nuts on the radw ste drums which were found to be loose were tightened as per procedure, Procedure HSP-4.3, Section 6.16, will be changed to require that the retaining ring lock nuts on filled radwaste drums be tightened prior to loading the drum for shipment.
t.
The affected areas in the containment building and turbine building were posted as Hot Spots.
Procedure HSP-2.6, Section 7.11, is currently undergoing revision to reflect changes in the requirements for posting Hot Spots which are not specified in 10CFR20 requirements, but are used as a method to reduce personnel exposure as low as reasonably achieve,ble.
Pre-calibration readings will be recorded-for all 1981 survey c.
instrument calibrations as specified by procedure ESP-2.9, Section 7.10.
d.
The instrument in cuestion was recalibrated as per procedure HSP-2.9, Section 7.2, to mtitiple calibration points on the X1 and X10 scale.
The Technical Associates CP-TP-1A instruments may be phased out of operation in the near future due to old age and procurement of improved survey equipment.
The hand and foot counters and HP-21b'GM friskers which are e.
currently used to checkout personnel are sourced checked daily with the specified 8600 dpm Technicium-99 solid check source.
"3.
TecInical Specification 3. 9. 3(a) requires that a report of radioactive affluente to unrestricted areas be made to the Nic vithin 60 days after January 1 and July 1 of each year.
Cc s:*rary to the above, thu required reporto for the eix-mcnth pcv ode ending December 31, 1977, June 30, 1978, Dacember 31, 1 E 7 :', June 30, 1979, and December 31, 1979, vere submitted ar.rreximately one ueek to cight vecka late.
The report fer the six ncnth period ending June 30, 1980, had not been sub-mitted as cf January 8, 1981."
In Mr. James G. Keppler, Df. rector LAC-7552 U. S. Nuclear Regulatory Commission May'19, 1981
~DPC RESPONSE:
The Dairyland Power Cooperative Environmental Affairs Department, which is responsible for final preparation and distribution of the LACBWR raQicactive effluent report, has been notified of these violations.
They will make a better effort to report these results within the 60 days as specified by Technical Specifications.
Authorization for.this reply to be submitted beyond the twenty-five day reporting period was granted to Mr. Paul Shafer by Mr. Robert Gregor of your staff.
If there are any questions concerning the response, please contact us.
Very truly yours, DAIRYLAND POWER COOPERATIVE
. j
.+L
.-ca...
Frank Linder, General Manager FL:PWS:af c.: :
NPC Resident Inspectors i
FTATE CF FISCeNSIN ).
)
CCtaiTY CF LA CFOSSE) tersonally came before me this.-)B 2I day of May, 1981, the above naTed Frank Linder, to me known to be the person who executed the foregoing instrument and acknowledged the same.
&>v Notary Publkp. La Crosse County, Wisc<)nsin.
My Commission Expires 2/26/84. -.