ML22223A070

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Energysolutions, LLC, ES-LCR-CR-2017-0073, Survey Unit 010-101-C WTB Subfoundation
ML22223A070
Person / Time
Site: La Crosse  File:Dairyland Power Cooperative icon.png
Issue date: 07/28/2022
From:
EnergySolutions
To:
Office of Nuclear Material Safety and Safeguards
Shared Package
ML22223A088 List:
References
LS-2022-0014
Download: ML22223A070 (10)


Text

Condition Report ES-LCR-CR-2017-0073 Page 1 of 10 Details Division: Lacrosse Name: Survey Unit 010-101-C WTB Subfoundation

==

Description:==

During reviews of the subject Survey Unit FSS results the following was identified.

During FSS of the Waste Treatment Building excavated areas, FSS Techs performed surface scans of the soil which showed detectable contam levels that were within the Operational DCGLs. An NRC Inspector performing follow-up surface scans also saw detectable levels, which as a result prompted the FSS Supervisor to provide direction to Operations personnel to begin removing the soil which resulted in the detection higher levels of contamination.

Start Date: 10/9/2017 4:08:00 PM End Date: 1/31/2018 12:00:00 AM Status: Completed Properties Page 1 of 10

Condition Report ES-LCR-CR-2017-0073 Page 2 of 10 SIG Level: 3 Date/Time Initiated: 10/9/2017 4:08:00 PM Brief

Description:

Survey Unit 010-101-C WTB Subfoundation

==

Description:==

During reviews of the subject Survey Unit FSS results the following was identified.

During FSS of the Waste Treatment Building excavated areas, FSS Techs performed surface scans of the soil which showed detectable contam levels that were within the Operational DCGLs. An NRC Inspector performing follow-up surface scans also saw detectable levels, which as a result prompted the FSS Supervisor to provide direction to Operations personnel to begin removing the soil which resulted in the detection higher levels of contamination.

Immediate Actions:

The FSS was stopped, and the area was resurveyed, contaminated and clean soil/concrete was safely removed in accordance with excavation sloping requirements, and FSS of the remediated area was completed in accordance with FSS release requirements and the NRC Inspectors satisfaction prior to backfill.

Recommended Actions:

The process for performing surveys of areas prior to turning over for FSS should be reviewed for potential improvements. The FSS requirements for this survey unit should be assessed to ensure adequate surveys were taken based on the increased size of the excavation.

Date Discovered: 9/13/2017 Issue Identified By: NRC Related Documents:

Reviewed Date/Time: 10/9/2017 12:00:00 AM Maintenance Rule Applicable? False Reportability Applicable? False Operability Review Required? False 50.75g Issue? True 7230D Issue? False MRC Review Meeting Date:

MRC Approval: False MRC Comments:

Responsibilities Page 2 of 10

Condition Report ES-LCR-CR-2017-0073 Page 3 of 10 Initator: Jason Q. Spaide Shift Manager: Jason Q. Spaide CR Owner:

Events Step Person Start End Date Date Initiation: Jason Q. Spaide 10/9/2017 10/9/2017 OP Review: Jason Q. Spaide 10/9/2017 10/9/2017 Screening: 10/9/2017 10/12/2017 MRC Review:

Pending CA Completion: 10/12/2017 1/31/2018 Verify and Closure: Gregg Tulley 10/12/2017 1/31/2018 Action - ES-LCR-ACT-2017-0164 Action Type: Corrective Due Date: 11/17/2017 Action Assigned To: Joseph D. Date Completed: 10/13/2017 Jacobsen Action:

The process for performing surveys of areas prior to turning over for FSS should be reviewed for potential improvements.

Results:

To review the process for performing surveys of areas prior to turning over for FSS the following Corrective Actions have been issued:

  • ES-LCR-ACT-2017-0177, LACBWR RPM, LACBWR FSS Supervisor and EnergySolutions Director of Radiological Site Closure will perform a review of the Final Status Survey Program and Procedures and revise as necessary.
  • ES-LCR-ACT-2017-0178, FSS Technicians RP Operations Technicians and Operations Personnel will be trained and or rebriefed as required on revisions and changes to the FSS Programs and Procedures.
  • ES-CLR-ACT-2017-0179, FSS Department will procure upgrades to existing data logging/ mapping equipment to provide information on a real time basis.

Page 3 of 10

Condition Report ES-LCR-CR-2017-0073 Page 4 of 10 Action - ES-LCR-ACT-2017-0165 Action Type: Corrective Due Date: 11/17/2017 Action Assigned To: Joseph D. Date Completed: 10/25/2017 Jacobsen Action:

The FSS requirements for Survey Unit 010-101-C WTB Subfoundation should be assessed to ensure adequate surveys were taken based on the increased size of the excavation.

Results:

An assessment was performed on the survey results for the FSS of Survey Unit 010-101-C. Following remediation, 100%

of the surface was scanned per survey plan requirements, including the areas that were expanded as a result of remediation. Although several composited samples were taken to verify that remediation was successful, Attachment 9 of procedure LC-FS-PR-008, Final Radiation Survey Data Assessment required that if significant remediation took place after FSS, the entire FSS should be redesigned and reperformed. Therefore, the 15 soil samples that were originally prescribed would have to be recollected. The site has optioned to obtain these samples via GeoProbe which is adequate. The survey package and results will be updated when data analysis is complete on the additional samples.

Once this is performed the FSS can be considered complete.

The Geoprobe work was completed on site on 10/18/17 to obtain the 15 soil samples at subsurface locations identified by the new systematic soil sample location map based on the larger area of the final WTB excavation. The soil sample results form gamma spectroscopy analysis have been reviewed and accepted with all results well less than the Operational DCGL levels. Two soil samples have been selected for the required HTD analyses by the off site lab-GEL- and were sent to GEL on 10/25/17.

Action - ES-LCR-ACT-2017-0174 Page 4 of 10

Condition Report ES-LCR-CR-2017-0073 Page 5 of 10 Action Type: Corrective Due Date: 10/17/2017 Action Assigned To: Joe A. Nowak Date Completed: 10/13/2017 Action:

Issue a stand down for Turbine Building, Diesel Generator Building and RPGPA Sump below grade structural removal, soil excavation and below grade piping/ utility removal.

Results:

A stand down was issued on 10-12-2017 for the Turbine Building, Diesel Generator Building and RPGPA Sump below grade structural removal, soil excavation and below grade piping/ utility removal activities until it can be demonstrated that D&D activities can be performed without leaving structural components in place prior to beginning FSS activities.

Corrective Actions ES-LCR-ACT-2017-0175 through ES-LCR-ACT-2017-0180 were issued a s a result of the Stand down. The actions will be completed and a readiness review completed prior to the stand down being lifted.

Action - ES-LCR-ACT-2017-0175 Action Type: Corrective Due Date: 11/13/2017 Action Assigned To: Jason Q. Date Completed: 10/18/2017 Spaide Action:

Develop an action plan to identify and implement controls to eliminate the potential for leaving building components or systems in place or below the final below grade surface at the conclusion of demolition and remediation.

Results:

Action Plan was developed with the project team and submitted to the LACBWR General Manager. Action was accepted and presented to Senior Management.

Action - ES-LCR-ACT-2017-0176 Page 5 of 10

Condition Report ES-LCR-CR-2017-0073 Page 6 of 10 Action Type: Corrective Due Date: 11/13/2017 Action Assigned To: Jason Q. Date Completed: 10/24/2017 Spaide Action:

Train project personnel to action plan developed for controls to eliminate the potential for leaving building components or systems in place or below the final below grade surface at the conclusion of demolition and remediation.

Results:

Project personnel were briefed to the Action Plan.

Action - ES-LCR-ACT-2017-0177 Page 6 of 10

Condition Report ES-LCR-CR-2017-0073 Page 7 of 10 Action Type: Corrective Due Date: 1/31/2018 Action Assigned To: Joseph D. Date Completed: 1/30/2018 Jacobsen Action:

LACBWR RPM, LACBWR FSS Supervisor and the EnergySolutions Director of Radiological Site Closure will perform a review of the Final Status Survey Program and Procedures and Revise as deemed necessary.

Results:

LACBWR RPM, LACBWR FSS Supervisor and the EnergySolutions Director of Radiological Site Closure performed a review of rthe FSS Program and procedures.

During their review they noted that the following two procedures required revision:

  • LC-FS-PR-008; Final Radiation Survey Data Assessment
  • LC-FS-PR-010; Isolation and Control for Final Satus Survey Corrective Action ES-LCR-ACT-2017-0181 was created for the revision of the procedures above. Both procedures will be revised and FSS, RP Ops and Operations personnel briefed to the changes as necessary prior to resuming FSS activities.

Update 12/06/17 - All procedures have been updated to reflect the terminology changes within the LTP with the exception of LC-FS-FR-008 which is pending revision upon receipt of the new base case and operational DCGLs. Rather than revise the procedure now, and then again in a few weeks or so, we have extended the CA due date to 01/31/18.

LC-FS-PR-008 is issued for use now with the terminology changes needed and the new base case and operational DCGLs incoroporated.

The FSS Technicians have already been briefed on procedural changes and practice changes tied to the action description.

Action - ES-LCR-ACT-2017-0178 Page 7 of 10

Condition Report ES-LCR-CR-2017-0073 Page 8 of 10 Action Type: Corrective Due Date: 12/31/2017 Action Assigned To: Joseph D. Date Completed: 1/30/2018 Jacobsen Action:

FSS Technicians, RP Operations Technicians and Operations Personnel will be trained and or rebriefed as required on revisions and changes to the FSS Programs and Procedures.

Update 12/06/17 - All procedures have been updated to reflect the terminology changes within the LTP with the exception of LC-FS-FR-008 which is pending revision upon receipt of the new base case and operational DCGLs. Rather than revise the procedure now, and then again in a few weeks or so, we have extended the CA due date to 01/31/18.

Results:

LC-FS-PR-008 is issued for use now with the terminology changes needed and the new base case and operational DCGLs incoroporated.

The FSS Technicians have already been briefed on procedural changes and practice changes tied to the action description.

Action - ES-LCR-ACT-2017-0179 Action Type: Corrective Due Date: 11/13/2017 Action Assigned To: Joseph D. Date Completed: 11/8/2017 Jacobsen Action:

FSS Department will procure upgrades to existing data logging/ mapping equipment to provide information on a real time basis.

Results:

Purchase Order #676783 was issued to Seiler on 11-08-2017 for the purchase of:

- 2 Licenses for Mapping Continental Centerpoint RTX

- 1 License for GPS Pathfinder Office Software Action - ES-LCR-ACT-2017-0180 Page 8 of 10

Condition Report ES-LCR-CR-2017-0073 Page 9 of 10 Action Type: Corrective Due Date: 11/13/2017 Action Assigned To: Joe A. Nowak Date Completed: 10/18/2017 Action:

Perform a readiness review to determine the adequacy of controls developed to identify and implement controls to eliminate the potential for leaving building components or systems in place or below the final below grade surface at the conclusion of demolition and remediation prior to lifting the Turbine Building stand down.

Results:

On 10/18/2017 a readiness review was conducted to verify and authorize Solutions to resume work and lift the Turbine Building stand down.

Action - ES-LCR-ACT-2017-0181 Page 9 of 10

Condition Report ES-LCR-CR-2017-0073 Page 10 of 10 Action Type: Corrective Due Date: 1/31/2018 Action Assigned To: Joseph D. Date Completed: 1/30/2018 Jacobsen Action:

The LACBWR RPM, LACBWR FSS Supervisor and the EnergySolutions Director of Radiological Site Closure performed a review of the Final Status Survey Program and Procedures. Based on theri reviews the following procedures require revision:

  • LC-FS-PR-008; Final Radiation Survey Data Assessment
  • LC-FS-PR-010; Isolation and Control for Final Status Survey Both procedures will be revised and FSS, RP Ops and Operations personnel briefed to the changes as necessary prior to resuming FSS activities.

Update 12/06/17 - All procedures have been updated to reflect the terminology changes within the LTP with the exception of LC-FS-FR-008 which is pending revision upon receipt of the new base case and operational DCGLs. Rather than revise the procedure now, and then again in a few weeks or so, we have extended the CA due date to 01/31/18.

Results:

LC-FS-PR-008 is issued for use now with the terminology changes needed and the new base case and operational DCGLs incoroporated.

Trends Event Codes: #Error Page 10 of 10