ML20196J237

Responds to NRC Re Violations Noted in Insp Rept 50-409/88-06.Semiannual Whole Body Counts Required by Procedure But Not by Regulation

ML20196J237
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	06/22/1988
From:	Taylor J DAIRYLAND POWER COOPERATIVE
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
LAC-12570, NUDOCS 8807060346
Download: ML20196J237 (3)

Text

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., ,.. S D DA/RYLAND kb[M[ COOPERATlVE 2615 EAST AVE. SO. . PO. BOX 817 . LA CROSSE, WISCON (608) 788-4000 JAMES W. TAYLOR General Manager - June 22, 1988 In reply, please refer to LAC-12570 DOCKET NO. 50-409 Mr. A. Bert Davis, Regional Administrator Directorate of Regulatory Operations 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 License No. DPR-45 Response to Notice of. Violation Cited in NRC Inspection Report No. 50-409/88006 (DRSS)

REFERENCE:

(1) NRC Letter, W. D. Shafer to J. W. Taylor, dated June 3, 1988.

This letter is in response to the Notice of Violation which was transmitted with your letter of June 3, 1988 (Reference 1). The notice was issued as a result of the findings stated in Inspection Report No.

50-409/88006 (DRSS).

NOTICE OF VIOLATION Technical Specification 6.8.1 states that written procedures shall be established, implemented and maintained covering the activities referenced in Appendix "A" of Regulatory Guide 1.33; Section 7e(8) of the guide includes a bioassay program.

Health and Safety Procedure HSP-13.5, Whole body Councing and LACBWR Operating Manual, Volume X, Health Physics Procedures, state that whole body counts shall be performed routinely every six months on each plant individual.

Contrary to the above, several plant individuals were not whole body counted at the required frequency during 1987.

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Mr. A. Bert Davis

. LAC-12570-Page 2 June 22, 1988 DPC RESPONSE During the August 1987 routine whole body counts, the HpGe detector used to perform the counts malfunctioned. The detector had to be returned to the vender for repair and was not received back onsite until February 1988. A detector was rented for any whole body counts needed to be performed due to personnel leaving the plant. A large personnel reduction was being experienced due to plant shutdown. The rented detector was calibrated to our whole body geometry. This detector had a lower efficiency than the LACBWR whole body counting HpGe. It was adequate to meet the LLD requirements but not as good as our normal detector and was therefore used only to count terminating personnel as needed. The vendor repairing LACBWR's detector was contacted several times but never gave a firm return date.

Semiannual whole body counts are required by procedure but not by regulation. It was because of this that the Health and Safety Supervisor decided not to perform the routine whole body counts of personnel. This decision was based on the following:

1. Semiannual counts are not required by regulation. Annual counting is.

2. The rented detector was of low efficiency.

3. LACBWR was shut down for decommissioning and very little work on contaminated systems or in contaminated areas was being performed.

Therefore, the chance of any internal deposition was negligible.

4. Return date for original detector was unknown.

A letter was placed in the personnel file for individuals not counted.

This was never presented to the Operations Review Committee (ORC). In the future if it becomes apparent that the semiannual routine whole body count cannot be met, a temporary change to the HSP will be submitted to the ORC as allowed by ACP-06.2. The Health and Safety Department will ensure that all plant personnel are whole body counted at least annually.

If there are any c,uestions, please contact us.

Sincerely, DAIRYLAND POWER COOPERATIVE

/

James W. Taylor General Manager JWT:LLN:sks PCl-50

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Mr. A. Bert Davis LAC-12570 Page<3 June 22, 1988 cc: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Peter Erickson, LACBWR Project Manager.

Divisionfof Nuclear Reactor Regulation U. S., Nuclear Regulatory Commission Mr. Ken Ridgway, NRC Resident Inspector Mr. W. D. Shafer, Chief Emergency Preparedness and Radiological Protection Branch U..S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 s.

PCI-50

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