ML20027D679
| ML20027D679 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 10/21/1982 |
| From: | Linder F DAIRYLAND POWER COOPERATIVE |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20027D674 | List: |
| References | |
| LAC-8667, NUDOCS 8211080235 | |
| Download: ML20027D679 (6) | |
Text
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1
'D
/RYLAND k
COOPERAT/VE. PO BOX 817
- 2615 EAST AV SOUTH
- LA CROSSE. WISCONSIN 54601 (608) 788 4 000 October 21, 1982 In reply, please refer to LAC-8667 DOCKET N0. 50-409 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
SUBJECT:
DAIRYLAND POWER COOPERATIVE LA CROSSE BOILING WATER REACTOR (LACBWR)
PROVISIONAL OPERATING LICENSE NO. DPR-45 RESPONSES TO NOTICES OF VIOLATION IDENTIFIED IN THE APPENDIX OF NRC INSPECTION REPORT 82-14 (DETP)
REFERENCES:
(1) DPC Letter, Reportable Occurrence No. 82-16, Linder to Keppler, LAC-8457, dated July 29, 1982.
(2) DPC Letter, Apparent Violation of 49 CFR 173.393 (J)(3) by DPC Waste Shipment No. 0782-033-A, Shafer to Gregor, LAC-8507, dated August 19, 1982.
(3) NRC Letter, inspection Report 82-14 (DETP), Keppler to Linder, dated September 24, 1982.
Dear Mr. Keppler:
In response to your letter (Reference 3) which identified three Notices of Violation as a result of your inspection conducted on August 2,1982, and in accordance with NRC Enforcement Policy 47FR9987, which were related to waste processing, this letter decribes Dalryland Power Cooperative's planned or taken corrective actions to reduce the potential for reoccurrence of the violations as listed in.the Appendix of your inspection report No. 82-14. We are taking exception to the second violation listed in your letter (reference
- 3) which states that we violated 10 CFR 30.41(b)(5) with our radioactive waste shipment No. 0782-033-A. Our explanation as to why we feel that we are not in violation of 10 CFR 30.41(b)(5) is included in this response.
NRC IDENTIFIED VIOLATION:
1.
10 CFR 71.5 prohibits transport of any licensed mterial outside the confines of a plant or other place of use or delivery of licensed m1terial to a carrier for transport unless the licensee complies with applicable regulations of the Department of Tmneportation in 49 CFR P1 rte 170-189.
40 CFR 173.393(j)(3) Limits the mdiation level at any point two meters (six feet) from the vertical planee projected by the outer lateral surface of the vehicle to 10 mR/hr. WP1.5 00T 2 7 G82 8211080235 821105 PDR ADOCK 05000409 O
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Mr. James G. Keppler October 22, 1982 NRC - Region III LAC-8667 Contmry to the above, a mdiation level of 12 rR/hr me measured by a State of Carolina inspector at too notere from the surface of the tmiler tmnaporti; ; mete shipment No. 0782-033-A from LACBWR to the Barnvell vaste burial facility.
This a Severity Level III violation (Supplement V).
DPC RESPONSE On July 28, 1982, a radioactive material waste shipment No. 0782-033-A, which consisted of one hundred fif ty (150) DOT SPEC.17H 55-gallon drums containing dry active waste (compacted radioactive contaminated trash) was sent from Dairyland Power Cooperative's LACBWR facility to Barnwell Waste Management Facility in Barnwell, S.C. for disposal. Radioactive Material Shipping Records, including van survey records, Chem. Nuclear Systems, Inc. waste management records, and completed driver's instructions accompanied the shipment in accordance with applicable sections of 49 CFR Parts 170-189, and LACBWR Procedure HSP 04.1.
Prior to departure, radiation surveys at contact, at six feet (approx. 2m) from the vertical planes of the surface of the van, and inside the cab were made in accordance with 49 CFR and prggedure. The survey radiation levels determined by a technician, using a IJ'Cs calibrated suSr source checked, _ air ionization dose rate meter (Eberline R0-3), indicated and were documented to be less than all applicable limits of 49 CFR.
At the time of shipment on July 28, 1982, shipment No. 0782-033-A was in compliance with 10 CFR 71.5.
The maximum contact radiation reading on the side of the van had been deter-mined to be 39 mR/hr. The maximum reading at 6 feet from the van, along the vertical plane projected by the outer lateral surface was 9.5 mR/hr. The maximum reading inside the cab " sleeper" area had been determined to be 1.2 mR/hr.
These surveys were randomly verified by a second individual using a 137 s C
calibrated air ionization dose rate instrument.
On July 30, 1982, in the late afternoon, shipment No. 0782-033-A arrived at the Barnwell Waste Management Facility. A receipt radiation suvvey was performed by a member of Chem. Nuclear Systems Inc. staff and a State of South Carolina inspector. One survey taken at two meters from the lateral surface of the van indicated 12.0 mR/hr which would be in excess of the 49 CFR 173.393 (j)(3) limit of 10 mR/hr. Dairyland Power Cooperative was notified by telephone of the apparent violation of 49 CFR 173.393(j)(3). A member of Chem. Nuclear Systems Inc.'s staff made additional radiation measurements at the same location which had indicated 12.0 mR/hr, using independent instruments. Three Eberline PIC-6A's, one Eberline R02A Air ionization dose rate meter and one Eberline E-520 Gi dose rate instrument, all vendor calibrated to 13/Cs, were used to measure the van's dose rates at two meters from the outer lateral surface. Two of the PIC-6A's read 9.0 mR/hr and one read 12.0 mR/hr. The R02A air ionization dose rate meter read 9.0 mR/hr.
The Eberline E-520 GM dose rate meter indicated 15.0 mR/hr. However, WPl.5
Mr. James G. Keppler October 22, 1982 NRC - Region III LAC-8667 according to the Eberline I.C. Equipment Manual, the E-520 GM's energy compensated GM detector has an energy response curve that indicates a relative response ratio of approximately 0.85 at 600 KgY. This would indicate that the E-520 GM dose ryCs.e meter may over-respond to OCo gamma energies, if calibrated to u It is our opinion that, since two calibrated PIC-6A's and one R02A read 9.0 mR/hr, the PIC-6A instrument which indicated 12.0 mR/hr may have been out of calibration, and that our shipment No. 0782-033A was in compliance with 49 CFR 173.393(j)(3). This information has been transmitted to you by our letter (Reference 2).
The State of South Carolina inspector measured 12.0 mR/hr and, on the basis of his instrument indication, on August 4,1982, the State of South Carolina Department of Health and Environmental Control imposed upon Dairyland Power Cooperative a Civil Penalty of $2,000 and revocation of our South Carolina Radioactive Waste Permit No. 0049-48-82-X, in part due to an apparent violation of 49 CFR 173.393(j)(3).
We corresponded with the State of South Carolina Department of Health and Environmental Control en two occasions, on August 16 and September 13, re-questing that they send us additional information regarding shipment recaipt radiation surveys and instrument calibration information. The State of South Carolina has not sent us this information to date.
On September 13, 1982, Dairyland Power Cooperative paid the $2,000 Civil Penalty to the State of South Carolina. On September 16, 1982, the State of South Carolina reinstated our Radioactive Waste Permit No. 0049-48-82-X.
Our corrective actions regarding this apparent violation are as follows:
- 1) Radioactive material shipments from LACBWR will have two separate radiation surveys made with two independent radiation survey instruments in the future, and 2)
If a radiation survey discrepancy exists upon receipt of our radioactive material shipment at the destination point, we may send a technician with the instru;nent(s) used to perform departure surveys to the desti-nation point to verify radiation surveys in order to ascertain whether or not material configuration changes have occurred.
NRC IDENTIFIED VIOLATION:
2.
10 CPR 30.41(b)(S) states, in part, that a licensee my transfer byproduct material under terms of a license issued by an Agreement State, only to a person authorized to receive auch byproduct mterial.
Paragraph 7.2.1.3.1 of the Acceptance Criteria for the Barnoell ta1ste burial site states that drums must not be laid on their eldes in the t
transport van.
l WP1.5
Mr. James G. Keppler Oct her 22,.D82 NRC - Region III LAC-W 7 Contrary to the above, sevent drums in the rear of the traiter used co transport mete shipment No. 0782-033-A from LACBWR vere laid on their eidee.
This is a Severity Level IV violation (Supplement V).
DPC RESPONSE As indicated in our response to NRC Identified Violation 1 of Inspection Report No. 82-14 (DETP), on July 30, 1982, Dairyland Power Cooperative's radioactive waste shipment No. 0782-033-A arrived at the Barnwell Waste Management Facility for disposal of 15017H drums containing compacted trash.
Eight (8) of these D0T SPEC.17H drums containing radioactive waste material were placed on their sides on a second tier of drums to serve as bracing to prevent drum translocation in the van during shipment transit. This practice was not in violation of 49 CFR but was apparently in violation of Paragraph 7.2.1.3.1 of the Barnwell Waste Management's Disposal Site Acceptance Criteria.
It is our opinion, Dairyland Power Cooperative did in fact " transfer by-product material to an authorized person in accordance with the terms of the Agreement State license." The fact that the Barnwell Waste Management Facility accepted and disposed of the 15017H drums containing waste material, in violation of the Site Disposal Criteria, does not mean that Dairyland Power Cooperative violated any applicable license. Furthermore, if it is interpreted that we violated 10 CFR 30.41(b)(5) in that we violated a term of the license, then it could be interpreted to mean that the Barnwell Waste Management Facility was not authorized to receive the radioactive waste material. Yet, on July 30, 1982, Barnwell Waste Management Facility accepted our radioactive waste shipment No. 0782-033-A and disposed of all M0 00T l
SPEC.17H drums containing radioactive waste material.
In conclusion, although the shipment was not in full compliance with the Barnwell Disposal Site Acceptance Criteria, we do not believe we are in violation of 10 CFR 30.41(b)(5).
In the future, we will not use drums laying on their sides as bracing material, but will place adequate wooden braces attached to the van's floor to i
l retain drums in position or use pallets with steel bands to hold drums in l
place during shipment.
l l
NRC IDENTIFIED WOLATION:
i 3.
Technical Specification 2.11.1 states that liquid mates generated within the reactor plant ahatt be collected in retention tanks or in mete mter storage tanks and shalt be processed as required to reduce their mdio-activity concentration prior to their controtted mixing with the condenser discharge to the river. WPl.5 i
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Mr. James G. Keppler October 22, 1982 NRC - Region III LAC-8667 Contrary to the above, approxinntely 25 gallone of unprocessed mdioactive water were discharged to the river from the condensate Domineralizer Tank on July 2, 1982.
This is a Severity Level IV violation (Supplement IV).
DPC RESPONSE During startup of the LACBWR condensate system on July 2,1982, during a refueling outage, approximately 1200 gallons of condensate water were released to the Turbine Building floor over a five minute period. Approximately 1125 gallons were recovered by the waste water tanks, part of the normal radio-active waste water processing system as per Technical Specification 2.11.1.
Approximately 20 gallons of this condensate water entered the ground in the radiologically controlled area outside the West Turbine Building door and the West Turbine Building truck bay door. Additionally, approximately 30 gallons were recovered from the oil separator overflow sump and return to plant radioactive waste water processing systems.
The remaining 25 gallons of condensate water were shown by sampling to have been discharged from the oil separator overflow sump through a preciously concrete plugged drain line to the Mississippi River adjacent to the suction point for the Genoa No. 3 Fossil Power Station Condenser circulating water pumps. As indicated by a later dye test, the majority of this 25 gallons of contaminated condensate water was claimed by the suction of the Genoa No. 3 condenser circulating water, where it mixed with 130,000 gpm of circulating river water prior to being finally discharged to the river.
Based on the Maximum Permissible Concentrations in Water (10 CFR 20 Appendix B, Table II), the discharge to the river near the Genoa No. 3 power plant condenser circulating water suction was determined to be 12.6 MPCw.
If the dilution achieved by the contaminated condensate water passing through the Genoa No. 3 power plant ondenser circulating water prior to being permanently discharged into the river is taken into account, the discharged water would have had a MPCW of 5.1 x t0-4 or 0.05% MPCw. The total activity discharged to the river was approximate 1 r 5 x 10-5 Ci.
We are in violation of Techaical Specification 2.11.1 in that these liquid wastes were not collected in retention tanks or in waste water storage tanks prior to controlled mixing with the condenser water to the river.
It can be demonstrated, however, that the activity was diluted with condenser circulating water discharge to the river.
On July 29, 1982, Reportable Occurrence No. 82-16 (Reference 1) was sent to NRC explaining the details of this violation.
Several actions have been or will be taken since the incident to prevent re-occurrences of this type in the future. WPl.5
e Mr. James G. Keppler October 22, 1982 NRC - Region III LAC-8667 The Resin Inlet Valve, which is a 2-inch, motor-operated valve relay was overhauled, reinstalled and tested. Closure of this valve should prevent sight glass overpressurization and subsequent major condensate water leakage.
A drop gate between the West Turbine Building sump and the oil separator over-flow sump was closed to prevent any future potentially contaminated water from reaching the overflow sump. A plug was placed on the end of the 10-inch line from the oil separator overflow sump to the river to prevent accidental discharge to the river via this pathway. An integrity test of the oil separator overflow sump demonstrated that the sump itself is not leaktight, so it will not be utilized as is. A Facility Change has been initiated to modify the existing grout plugged floor drain system to remedy the problems associated with it. Gaskets on the sight glass which leaked condensate water have been replaced.
The slightly contaminated soil (approx.1.56 x 10-4 )Ci/g) outside the turbine building was removed and placed in DOT SPEC 17H 55-gallon drums to be discarded as low level radioactive solid waste at an authorized disposal site.
We sincerely hope that these responses clearly state our completed or planned corrective actions regarding these Notices of Violation and will make further NRC enforcement action unnecessary.
If you have additional comments or question's, please contact us.
Sincerely, DAIRYLAND POWER COOPERATIVE
&fEW$'5'd tif$
' Frank Linder, General Manager FL:PWS:dh cc - INPO NRC Resident Inspector Document Control Desk U.S. Nuclear Regulatory Commission Washington, D. C. WPl.5
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