ML20039A593

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Responds to NRC Re Violations Noted in IE Insp Rept 50-409/81-19.Corrective Actions:Fuel Element Storage Well Cooling/Demineralizer Pumps Placed in Parallel to Remove Radioactive Corrosion Matl from Elbow to Filters
ML20039A593
Person / Time
Site: La Crosse File:Dairyland Power Cooperative icon.png
Issue date: 11/23/1981
From: Linder F
DAIRYLAND POWER COOPERATIVE
To: Norelius C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20039A592 List:
References
LAC-7935, NUDOCS 8112180481
Download: ML20039A593 (4)


Text

/

e, 0 DA/RYLAND h

k COOPERAT/VE eo sox an reisEAST AV SOUTH LA CROSSE WISCONSIN 54601 1608) 788 4 000 November 23, 1981 In reply, please refer to LAC-7935 t

DOCKET NO. 50-409 Mr. C. E. Morelius, Director Division of Engineering and Technical Inspection U.

S. Nuclear Regulatory Commission Directorate of Regulatory Operations 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 IE INSPECTION REPORT NO. 50-409/81-19

Reference:

(1)

NRC Letter, Norelius to Linder, dated October 23, 1981.

Daar Mr. Norelius:

In response to your letter (Reference 1) which forwarded a notice of an apparent non-compliance with NRC requirements as a result of the subject inspection, we are submitting the following information:

^

ENFORCEMENT ITEM:

Violation:

1 Tachnical Specifications 6.8.1 and C.11 require adherence to l

radiation protection procedurea.

t LACBWR Health and Safety Procedure 02.6, Section 7.11 requires areas uith radiation fields uhich exceed the currounding general area radiation fields by a factor of three in doac rate to be posted

" Caution Radiation Hotspot".

Contrary to this requirement, an area of the fuel element storage cell piping on the mezzanine level of the Containment Building read in exceae of 600 milliroentgeno per hour (mR/hr) which exceeded the radiation field of the currounding general area by a factor of three l

and uas not posted with a " Caution Radiation Hotspot" sign.

l

! 8112180481 811211' gDRADOCK05000g Nov 3 0 198)

Mr. C. E. Norelius, Director November 23, 1981 Division of Engineering and Technical LAC-7935 Inspection DPC RESPONSE:

On September 15, 1981, while conducting a containment building tour, the NRC Resident Inspectors, using a Xetex 305 8 gamma dose equivalent rate meter discovered the gamma radiation dose rate with the Fuel Element Storage Well cooling /demineralizer (FESW) piping near the small water sample sink to be reading about 600 mR/M at contact.

They reviewed the local posted copy of the August 28, 1981 radiation survey sheet which indicated that the general background area near the air conditioning unit, appror.imately six feet from the FESW piping, near the small sample sink, read 23 mR/hr.

The NRC Resident Inspectors then measured the gamma radiation dose rate approximately 18" from the FESW piping, directly over the small sample sink, and obtained a reading of 105 mR/hr, using their instrument.

They re-verified this reading in the presence of the Acting Health and Safety Supervisor.

The Acting Health & Safety Supervisor determined that the 18" gamma dose equivalent rate reading was approximately 100 mR/hr using a Cs-137 calibrated, Eberline RO3A air ionization dose rate meter.

The RO3A reading had not been compensated for temperature nor barometric pressure.

The NRC inspectors then determined that the FESW piping elbow near the small sample sink ~did not have a Hot Spot sticker.

A horizontal section of the same pipe, about 6 feet away from the area in question, did have an appropriate Hot Spot' sticker which indicated that the FESW piping was 230 mR/hr at contact.

The horizontal section of the FESW piping had been shielded with lead sheets approximately 0.5 inch thick.

The elbow section of the FESW piping had not been shielded with lead.

The Acting Health & Safety Supervisor measured the gamma radiation level at the air conditioning unit with his'RO-3A.

The measured radiation level was 28 mR/hr at the air conditioner location which slightly exceeded the local posted survey results taken on August 28, 1981.

The NRC Resident Inspectors then discussed their findings with the Radiation Protection Engineer.

The NRC Inspectors initially felt that a bonafide unmarked and uncontrolled High Radiation Area existed at the small sample sink.

The Radiation Protection Engineer went to the sample sink area and measured the gamma' dose equivalent rate at 18" from the FESW pipe elbow, using a Cesium-137 calibrated, NBS traceable Victoreen Model 660 Electrometer.

The Radiation Protection Engineer determined the gamma dose equivalent rate to be 93 mR/hr at 18" from the FESW piping elbow.

It was a joint conclusion of the NRC Resident Inspectors and the Radiation Protection Engineer, and after a phone craversation with Mr. R.

A.

Paul, Region III Inspector, that a high radiation area did not' exist. -

Mr. C. E. Norelius, Director November 23, 1981 Division of Engineering and Technical LAC-7935 Inspection The Radiation Protection Engineer notified the Mechanical Engineer to either place supplemental lead-vinyl blankets around the FESW piping to reduce the radiation levels or to place a locked barri-cade between the air conditioning unit and the reactor biological shield to positively control access to the sample sink location on the containment building mezzanine.

The Radiation Protection Engineer notified the Operations Supervisor to place both FESW pumps in parallel operation to move FESW internally deposited radioactive corrosion material from the elbow section near the sample sink to the shielded FESW system, thus reducing the radiation level near the sample sink.

During the afternoon of September 15, 1981, the Operations Supervisor placed both FESW pumps in parallel, and this operation successfully moved some radioactive corrosion material from the elbow to the filters.

This was ascertained by a drop in gamma equivalent dose rates at the elbow and an increase in the FESW filter vessel gamma equivalent dose rates.

During the afternoon of September 15, 1981, additional lead blanket shielding was placed around the FESW pipe elbow.

This shielding, complimented by the parallel operation of FESW pumps, reduced the radiation levels to 70 mR/hr at contact with the lead blankets surrounding the FESW pipe elbow.

These corrective measures placed us in compliance with our Health and Safety Procedure HSP-02.6 and therefore in compliance with LACBWR Technical Specifications Section 6.8.1 and 6.11.

On the afternoon of September 17, 1981, a locked control barrier was installed between the reactor biological shield-and the air conditioning unit on the containment building mezzanine to limit personnel access to the sample sink area.

This barrier was installed because the FESW piping has the potential for creating a high radia-tion area in the sample sink area, due to gamma dose rate fluctua-tions caused by the movement of internal radioactive material.

The barrier was labelled with an appropriate " Danger, High Radiation Area" sign.

A new Health and Safety Procedure entitled " Radiological Signs and Markers" will be written and approved by December 15, 1981, which will redefine the use of " Hot Spot" stickers.

The " Hot Spot" procedure will read:

HOT SPOT signo will be used on valves, pipes and other equipment uhich have radiation levels greater than 20 mrem /hr gamma.

When the radiation level is 20 mrem /hr at 18" to 3 feet distance from the HOT SPOT, a sign designating " Remain 3 feet away from this point" vill be used.

When the radiation

. l

Mr. C. E. Norelius, Director November 23, 1981 Division of Engineering and Technical LAC-7935 Inspection level is 20 mrem /hr greater than 3 feet from the HOT SPOT, but not exceeding 100 mrem /hr whole body dose equivalent, a sign designating " Remain 6 feet away from this point" uilt be used.

The most recent survey date vill appear on the Hot Spot sign, but no gamma dose equivalent rates uilt be specified.

The HOT SPOT sign is to be used specifically for ALARA purposes, in conformity with Regulatory Guide 8.8.

Authorization for this reply to be submitted beyond the thirty (30) day reporting period was granted to Mr. Paul Shafer by Mr.

R. A.

Paul of your staff on November 23, 1981.

If you have any questions regarding this letter, please contact us.

Very truly yours, DAIRYLAND POWER COOPERATIVE A

.r p

" 'gd 4~

Frank Linder, General Manager FL:PWS:af cc:

NRC Resident Inspector STATE OF WISCONSIN )

)

COUNTY OF LA CROSSE)

Personally came before me this 24th day of November, 1981, the above named Frank Linder, to me known to be the person who executed the foregoing instrument and acknowledged the same.

d eb "1"w NotaryPuflic, La Crosse County, Wisconsin /

My Commission Expires 2/26/84...

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