ML20238A597
| ML20238A597 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 07/28/1987 |
| From: | Taylor J DAIRYLAND POWER COOPERATIVE |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| LAC-12310, NUDOCS 8708310139 | |
| Download: ML20238A597 (3) | |
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T D DAIRYLAND
[8/h[M[ COOPERATIVE. e o. cox 817 2615 EAST AVE SO.'. LA CR (608) 788-4000 -
JAMES W. TAYLOR i
General Manager July-28, 1987
)
In reply, please J
refer to LAC-12310 DOCKET No. 50-409 Mr. A. Bert Davis, Regional Administ rator-Directorate of Regulatory Operations U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 SUBJECT DAIRYLAND POWER COOPERATIVE 3
LA CROSSE BOILING WATER REACTOR ~(LACBWR)
PROVISIONAL OPERATING LICENSE 'NO. DPR-45 RESPONSE TO IE INSPECYTON REPORT 50-409/87006 (DRSS)
Reference:
NRC Letter, W. D. Shafer to J. W. Taylor dated May 12, 1937
Dear Mr. Davis:
This letter is in response to the Notice of Violation which was transmitted with your letter of May 12, 1987.
The Notice was issued as a result of the findings stated in Inspection Report No. 50-409/87006 (DRSS).
Technical specification G.8.1.a requires that procedurcs recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, be written, established, implemented and maintained. Regulatory Guide 1.33, llevision 2, Appendix A, Section 7.a requires procedures for the liquid radioactive waste systcm io control radioactivity relcased io the '
environment.
LACBWR's Operating Manual, Volume I, Integrated Plant Operations Response Procedure for Alarm E14-3, (revised February 1974) for high level in waste water storage tanks, requires in step 1 under "lamediate Actions, " that the operator observe local level indicator at '
cach tank, isolate the " full tank"....
1
.D.
Technical Speci11 cation 5.3.1.2 rcquires Ihat radioactivity conteni of.
cach batch of radioactive liquid waste he determined by sampling and analysis before release.
3 Se PCI-33 8708310139 870728 I O s
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9 t) 9 Mr. A. b'ert Davis 1AC-12310 July 28,1987 Page 2
' Contrary to the above, when the high waste water tanks level alarm was received due to high wter level in the 3000 GWT while a release was in pragmss from the 450J GWT on April 9,1986, the full timk was not isolated. Instead, one of the many potential inputs to the 3000 GWT was nlimivated by turning off the Turbine Building sump pumps. As.: result of the failure to isolate the 3000 GWT, the tank continued to fill, a.A overflowd viu the overflow pipe to the' 4500 GWT while a release ws in progress frua ihe latier tank.
Thie in iurn resulted in licensee failure ta detenaine tbn radioactivity coutent af Ihis batch af liquid radwaste prior to releas?. (by sampling and analysis) in that the
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contents of the 3000 GW tank had act been samplcd and analyzed.
Failure to isolate the taiks as required by procedure and the resulting failure to audyze raclioactivity content of the combined tank releases prior to dischstge as required by Technical Specification constitutes a Severity Level IV viointion.
Dpc Response Correct ive Act ion Taken and Heslilts Achieved Operation personnel have oeen re-instructed on the necessity of close level monitoring of the waste tanks during high water periods in the Mississippi River.
Also, prompt recirculation analysis and pumping of full waste water tanks during high water periods has been emphasized to all operatio m and Healf h Physics personnel.
Operations personnel were also re-inst ructed on 1% 'mportance of careful waste water management.
LACIMR's Operating Manual, Volume 1, Integrated Plant Operations, Hesponse Procedure for Alarm E]4--3 (high level in waste wat er st orage t ank) bus been revised to better clarify the immediate action required to be taken by Operations personnel.
Correct ive Action Taken to Avoid Further Noncompliance:
The revision to Alann E]4-3 response bet ter clarifies the immediate actions required to be taken upon receiving this alarm.
This, with the t raining, should avoid furt her noncompliance in this area.
Date When Full Compliance Will Be Achieved:
The response to Alarm E14-3 was approved May 8, 1987 by the Operations Review Committee.
This is the dat e f full compliance.
The NRC lett er also request ed that DPC re-evalute LER 86--12 and address why the LER did not identify the root cause as being the operator failure to follow t he alarm response procedure.
At the time of the report, the high l
PCI-33
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o Mr. A. Bert Davis LAC-12310 July 28, 1987 Page 3 river water level and the failure of Operations personnel to maintain close control over the waste water tanks' inventory were considered more significant contributors to the event than the operator's error in only securing the major source of water to the tank rather than completely isolating the tank.
The LER reflected the plant management's viewpoint at the time by addressing the need for closer control by the operators during the period of high river water level.
Later evaluation determined that the high waste water storage tanks level alarm response procedure was inadequate for t he specific circumst ances that existed.
The procedure was modified to include the following:
If tank is being discharged when this alarm is received, take action to prevent overflow from full tank to the tank being discharged, by either securing the tank discharge or securing incoming water sources to the waste water storage tanks, whichever can be done expeditiously.
The LER is being revised to clearly identify the operator's error in not isolating the tank and to include subsequent corrective actions, which were discussed earlier.
If there are any questions, please contact. us.
Sincerely, DAIRYLAND POWER COOPERATIVE i
d i
James W. Taylor General Manager JWT: LLN: LSG : sks cc:
Mr. Peter Erickson, LACBWR Project Manager flRC Resident Inspector Document Control Desk PCl-33
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