ML20032C004

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IE Insp Rept 50-409/81-19 on 810908-11.Noncompliance Noted: Failure to Adhere to Radiation Protection Procedure Requirements
ML20032C004
Person / Time
Site: La Crosse File:Dairyland Power Cooperative icon.png
Issue date: 10/16/1981
From: Greger L, Paul R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20032B992 List:
References
50-409-81-19, NUDOCS 8111060600
Download: ML20032C004 (6)


See also: IR 05000409/1981019

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U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report No. 50-409/81-19

Docket No. 50-409

License No. DPR-45

Licensee: Dairyland Power Cooperative

2615 East Avenue - South

Lacrosse, WI 54601

Facility Name: . Lacrosse Boiling Water Reactor

Inspection At:

Lacrosse Boiling Water Reactor Site, Genoa, WI

Inspection Conducted: September 8-11, 1981

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Inspector:

R. A

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Approved By:

L. R. Greger, dh

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Facilities Radiation

Protection Section

Inspection Summary

Inspeccion on September 8-11, 1981 (Report No. 50-409/81-19)

Areas Inspected: Routine, unannounced inspection of the status of post-TMI

requirements for operating reactors and Jicensee actions taken in response to

llealth Physics Appraisal Findings and items of noncompliance. The inspection

involved 32 inspector-hours onsite by one NRC inspector.

Results: Of the two areas inspected, one apparent item of noncompliance was

found in one area (Severity Level V violation - failure to follow radiation

protection procedures - Section 7).

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8111060600 811023

PDR ADDCK 05000409

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DETAILS

1.

Persons Contacted

  • J. Parkyn, Assistant Plant Supervisor
  • L. Nelson, Health Physics Technician
  • P. Shafer, Radiation Protection Engineer

M. Branch, NRC Resident Inspector

The inspector also contacted other licensee employees including

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members of the technical and engineering staff.

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  • Denotes those preeent at the exit meeting.

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2.

General

This inspection, which began at 11:30 a.m. on September 8, 1981, was

conducted to examine the licensee's actions on post-TMI requirements

and the licensee's actions in response to Health Physics Appraisal

findings.

The inspection also included several plant tours, visual

observation of facilities and equipment, review of posting and labeling,

c.nd independent radiation measurements by the inspector.

General house-

keeping was adequate.

3.

Licensee Action on Previous Inspection Findings

(Closed) Noncompliance Item (409/80-10-10, 409/81-11-05): Failure to

report radioactive effluent data within the prescribed time limit. The

licensee has revised the SWP procedure to strengthen their program.

(0 pen) Noncompliance Item (409/80-10-09): Several instances of

failure to meet Technical Specifications 6.8.1 and 6.11, adherence

to radiation protection procedure requirements. Corrective actions

for two instances are still in the process of being completed.

(Closed) Noncompliance Item (409/81-11-03): Failure of workers in-

volved in cask decontamination to wear adequate protective clothing.

Improvements to enable the licensee to prepare final environmental

data has been initiated.

4.

Monitoring

During a previous inspection, certain technical problems were noted

concerning stack monitor charcoal analyses and isokinetic stack

sampling. Since then, the licensee has made plans to replace tygon

tubing on the high range noble gas iodine and particulate monitoring

system with hardpiping; calibrate the SPING-4 with noble gas and

iodine-131 standards; move the stack monitoring systems to a new

facility to reduce the effect of radiation fields in containment on

the monitoring instrumentation; and correct the SPING-4 computer

memory loss.

(open item, 409/81-11-01)

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5.

Health Physics Training

A review of the licensee's response to the Health Physics Appraisal

during a previous inspection noted the following:

the health physics

technicians (HPT's) had not received technical training at offsite

training schools; the HPT training manual and procedures had not been

completed; most of the advanced HPT training had not been completed;

not all HPT's received training in calculations of offsite exposures

during accidents and emergency environmental sampling and analysis;

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and training had not been give to HPT's in emergency sampling procedure

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(EPP-6). Since then, the licensee:

has sent one HPT to offsite

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training and has scheduled three more in the near future; has given

some on-the-job advanced training; and has given training in offsite

calculations for emergency conditions to all HPT's.

The licensee is

rewriting emergency sampling procedure (EPP-6) and will give training

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to the HPT's in the revised procedures and is developing the HPT

training manual and procedures.

(open items, 409/81-11-02; 409/81-11-06)

No items of noncompliance or deviations were identified.

6.

Internal-External Exposure Control

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The Health Physics Appraisal noted the need for upgrading the licensee's

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internal

d external exposure control programs.

The licensee is conducting monthly TLD spikes; has developed a pro-

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cedure for TLD calibration and performance criteria; has purchased

a gamma monitor with integrating dose and dose equivalent rate

functions; is planning to do TLD beta dose equivalent calibrations;

is in the process of comparing TLD gamma doses with pocket and film

dosimeters; is planning 'o upgrade the whole body counter calibrations

and counting system with the purchase of a phantom and new calibration

sources and a germanium detector; is planning to purchase NIOSH approved

full and half-mask respirators and a small respiratory fit test booth;

and has purchased several high volume air samplers and an air sampler

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calibration unit. The status of these corrective actions will be

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reviewed at a future inspection.

(open item, 409/81-19-01)

The inspector reviewed the licensee's investigation of an employee's

whole body exposure received during the first four days of February

1981. The employee's pocket dosimeter read 295 mR and the TLD dost-

meter results indicated 37 mrem. Although it was noted during the

investigation that the worker was wearing the TLD dosimeter improperly

(backward), the licensee's TLD supplier reported that this should only

cause a 15 percent lower than actual dose reading. Based on their

investigation the licensea concluded the TLD results were more repre-

sentative of the person's whole body exposure for that period than

those of the pocket dosimeter, and assigned 37 mrem as the worker's

whole body exposure for the period.

The inspector does not concur with the licensee's assignment of 37

mrems to the person's record because review of the licensee's dosi-

meter-TLD comparison records from February through July 1981, showa

significant errois between the two types of dosimeters. The average

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error for this period ranges from 15 percent to 48 percent, with the

pocket dosimeter typically reading high. Based on the calibration

results of the self-reader dosimeters, the licensee has ruled out the

significant error between the two types of dosimeters to have been

caused by the self-readers.

The licensee initiated a program of double badging selected employees

in an attempt to resolve the personal monitoring discrepancies. This

matter was discussed at the exit interview,

No items of noncompliance or deviations were identified.

7.

Radiological Survey Pre' ram

During the Health Physics Appraisal, several weaknesses in the radio-

logical survey program were identified.

To correct these weaknesses, the licensee; (1) has relocated the

change room friskers and portal monitors to areas of lower radiation

background; (2) will document on a Radiation Occurrence Report which

will be developed by October 1, 1981, all cases of personal con-

tamination in excess of 30,000 dpm at one centimeter using a 2" erd

window G-H probe, and has implemented a decontamination log; (3) has

developed a system to distinguish contaminated from non-contaminated

material by color differentiation; (4) is writing a procedure in which

training will be given for entry and exit from contaminated plant

areas; (5) will revise procedures for "hotspot" postings and contamina-

tion surveillance and radiation survey frequencies by October 1,1981;

and (6) has developed a new SWP system which adds air sample results

(MPC-hours assigned) when airborne concentrations indicate respiratory

protection is required.

Although the licensee has made some progress to correct the identified

weaknesses in the survey and monitoring program, further problems were

noted during this inspection. As an examnle, surveys by the inspector's

on the mezzanine level in the containment building near the fuel element

storage well piping indicated general radiation fields of 75-115 mR/hr

near a sink.

The posted survey indicated 28 mR/hr. A spot at the elbow of the

piping was in excess of 600 mR/br. This was approximately 20 times

greater than the area survey indicated, and it was not posted with a

" Caution Radiation Hotspot" sign. Failure to post the "hotspot"

represents noncompliance with LACBWR Health and Safety Procedure 02.6,

Section 7.11 (Noncompliance 409/81-19-02).

Another area on the mezzanine level was posted as a contaminated area,

barricaded with a rope, and marked off with white tape on the floor

such that a person could walk into a section of the contaminated area

between the tape and the rope. This discrepancy was corrected during

the inspection. These matters were discussed at the exit interview.

One item of noncompliance was identified.

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8.

Instrumentation

The Health Physics Appraisal identified a need for improvement in

instrument calibration methods and criteria.

In addition to the corrective actions concerning this section noted

in Section 6, the licensee has procured an NBS traceable Victoreen

660 instrument to recalibrate the dose rate instrument calibration

source; will revise instrument calibration procedures to include the

recommendations in ANSI N323-1978; has revised all sections of the

procedures defining contamination detection equipment selection, use,

and calibration; will provide HP-210 friskers at the exit from the

Waste Treatment Building; will calibrate liquid effluent monitors

at multiple points using varying concentrations of radionuclides

with similar isotopic compositions; and will calibrate the SPING-4

stack gas monitor with known concentrations of xenon-133 and

Krypton-85 gases.

(open item, 409/81-19-03.)

No items of noncompliance or deviations were identified.

9.

ALARA

The Health Physics Appraisal Team indicated the need for a formalized

ALARA program.

By January 1982, the licensee has committed to develop formal pro-

cedures incorporating ALARA principles which include such things as

dose accountability (Regulatory Guide 1.16), dose goals, specific job

review, ALARA pre-job and post-job reviews, and pre-outage planning

reviews.

In addition, the licensee has developed an SWP ALARA job

review form to provide dccumentation of estimated man-rem exposure

based on similar jobs and to provide information which may reduce

exposure in future jobs. These matters will be reviewed further at

a future inspection.

(open item, 409/81-19-04.)

10.

Followup on TMI Action Items

The status of the following items is based on evaluation of previous

reviews by the regional specialist inspectors and review during this

inspection of licensee actions to correct the problems noted during

those reviews.

a.

Plant Shielding (2.1.6.b)

The licensee notified the NRC (NRR) in a letter dated June 12,

1980, of their actions to meet the intent of the Category "A"

requirements. The licensee identified no areas requiring

shielding modifications but intends to revise current procedures

covering this area by January 1, 1982.

b.

Post Accident Sampling (2.1.8.a)

This item was inspected by the Region III Health Physics Appraisal

Team during the period September 22 to October 3, 1980. With the

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exception of two items concerning hands on training in sampling

analysis and procedures and simulated sample collection, transport,

and analysis, the licensee has taken actions to correct the weak-

nesses noted in the Health Physics Appraisal. The licensee plans

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to correct the two above identified items.

It appears the licensee has met the intent of Category "A"

requirements and is working to meet the Category "B" requirements.

Instrumentation for Monitoring Accident Conditions (2.1.8.b)

c,

The interim requirements (II.F.1, I and 2) were inspected by the

Health Physics Appraisal Team during the period September 22 to

October 3, 1980. The corrective action the licensee took con-

cerning weaknesses noted in their high range noble gas monitoring

system, stack monitor charcoal analyses, and isokinetic stack

sampling are noted in Inspection Reports No. 50-409/81-11,

Section 4, and No. 50-409/81-19, Section 4.

A containment high

range monitor was installed on April 18, 1981.

It appears the

licensee has met the intent of the Category "A" requirements.

11.

Exit Interview

The inspector met with lic3nsee representatives (denoted in Section 1)

at the conclusion of the inspection on September 11, 1981. The inspector

summarized the scope and findings of the inspection.

In response to

certain items discussed by the inspector, the licensee:

Acknowledged the inspector's renarks concerning the noncompliance

a.

and the significance of a repeat item of noncompliance.

(Section 7)

b.

Acknowledged the inspector's remarks concerning the review of the

Significant Items found during the Health Physics Appraisal.

(Sections 5, 6, 7, 8, and 9).

Stated that the revised radiation occurrence report system will

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be developed by October 1, 1981.

(Section 8)

d.

Stated that the position of the RPEA has been created and should

be filled in the last quarter of 1981.

Agreed to review all personal monitoring results starting January

e.

1981, and assign to each employee's permanent exposure record the

pocket dosimeter results which are in excess of 15 percent of the

TLD results for each month.

(Section 6)

f.

Agreed to revise procedures concerning contamination surveillance,

area surveys, and "hotspot" postings.

(Section 7)

g.

Agreed to have formai procedures incorporating ALARA principles

by January 1982.

(Section 9)

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