ML20032C312
| ML20032C312 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 10/09/1981 |
| From: | Taylor J DAIRYLAND POWER COOPERATIVE |
| To: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20032C308 | List: |
| References | |
| LAC-7857, NUDOCS 8111090651 | |
| Download: ML20032C312 (3) | |
Text
.
e D DA/RYLAND h
[k COOPERATNE. PO BOX 817 2615 EAST AV SOUTH. L A CROSSE. WISCONSIN S4601 (608) 788 4 000 October 9, 1981 In reply, please refer to LAC-7857 DOCKET NO. 50-409 Mr.
R. L. Spessard, Director Division of Resident and Project Inspection 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. 50-409/81-14
Reference:
(1)
NRC Letter, Spessard to Linder, dated September 10, 1981.
Dear Mr. Spessard:
In response to your letter (Reference 1) which forwarded a notice of apparent non-compliance with NRC requirements as a result of the subject inspection, we are submitting the following-information:
ENFORCEMENT ITEM Violation "As a result of the inapection conducted on July 1-31, 1981, and in accordance uith the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the follouing violation vac identified:
LACBWR Technical Specification G.11 atates:
"Procelures for personnel radiation protection chatt be prepared conciatent with the requirnmente of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operatione involving radiation exposure."
LACBWR Operating Manual, Volume X, Section G.S.3 etated in part:
(7)
"Each vorker acaigned to the Special Work Permit (SWP) vill complete the required information for each entry into the work area on the entry copy of the SWP."
Contrary to the above, on June 22, 1981, coveral plant management personnet failed to indicate, on the job alte copy of SWP (81-115),
their entry into and exit from the work cite.
It io recognized that 8111090651 811103 DRADOCK05000g 0cT,1 3 1980
Mr.
R. L. Spessard, ulrector LAC-7857 Division of Resident and Project. Inspection October 9, 1981 your staff has revised Operating Manual, Volume X, Section G to delete the requirements to sign in and out of a radiation area at the job site.
This is a Severity Level V (Supplement 1). "
DPC RESPONSE:
1 Plant management personnel had undertaken preparations to perform maintenance work on control rod drive mechanisms in order to sub-stitute for regular maintenance personnel to reduce overall radia-tion exposure to these persons in keeping with the oojectives of the LACBWR ALARA program.
The management personnel were experienced, familiar with the work to be done and although knowledgeable of procedures, overlooked the requirement for entries to be made on the job site copy of the SWP on this particular job.
Although they overlooked entering the required data on the job site copy of the SWP upon entry and exit at the job site, they had read and initialed the " original" copy of the SWP in the Health and Safety Supervisor's office prior to doing the work.
The work performed by management personnel required wearing supplied air hoods and other protection from contaminated primary water.
Following completion of the work at the job site, which was in continuous attendance by a Health Physicc Technician, management.
personnel, after being assisted in the removal of protective clothing, proceeded to the Counting Room where they logged their indicated hi-range dosimeter readings on a form which was later used by the Health and Safety Supervisor to record data on the
" original" copy of the SWP.
In our opinion, there was sufficient knowledge of the doses received by personnel performing maintenance to insure that protection control methods were effective.
Contributing factors to the occurrence of this incident were the random frequencies of involvement of management personnel in 4
hands-on maintenance activities of this nature, the relative obscurity of the posting of the job site copy of the SWP and the attentiveness of the Technician to other job-site tasks.
The oversight was discussed and it was determined through this discussion that procedural changes could be made to ensure uniformity in individual dose logging requirements.
Chief among these changes was the implementation of a revised procedure which adopted a 4-color coded SWP form and the establishment of a pteminent convenient, central location for posting the central access point copy of the i.
SWP and the dosimeter log form.
The procedure revision was,
t
g e
Mr.
R. L.
Spessard, Director LAC-7857 Division of Resident and Project Inspection October 9, 1981 accomplished on June 24, 1981.
The central access posting facility was established a few weeks later in the Change Room which is the common entrance and exit for plant radiation control areas.
If there are any questions concerning this report, please contact s
us.
Very truly yours, DAIRYLAND POWER COOPERATIVE IN #
A James Taylor Assistant General Manager-Power Group JT:RES:af STATE OF WISCONSIN )
)
COUNT" OF LA CROSSE)
Personally came before me this 9th day of October, 1981, the above named James Taylor, to me known to be the person who executed the foregoing instrument and acknowledged the same.
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