IR 05000409/1987006

Insp Rept 50-409/87-06 on 870407-09.Violation Noted:Licensee Failure to Isolate Waste Tanks Which Resulted in Release of Unanalyzed Liquid

ML20213G527
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	05/11/1987
From:	Hueter L, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20213G492	List: IR 05000409/1987006 ML20213G490 ML20213G503
References
50-409-87-06, 50-409-87-6, NUDOCS 8705180332
Download: ML20213G527 (8)

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V. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-409/87006(DRSS)

Docket No. 50-409 License No. DPR-45 Licensee: Dairyland Power Cooperative 2615 East Avenue - South Lacrosse, WI 54601 Facility Name: Lacrosse Boiling Water Reactor Inspection At: Lacrosse Boiling Water Reactor Site, Genoa, Wisconsin Inspection Conducted: April 7-9, 1987 Inspector:

hd L.' J. Hueter 8 //S[

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~'g.hzuswG Approved By: M. C. Schumacher ([////2 Date Inspection Summary Inspection on April 7-9, 1987 (Report No. 50-409/87006(DRSS))

Areas Inspected: Routine, announced inspection of gaseous and liquid radioactive programs including: effluent releases; records and reports of effluents; effluent control instrumentation; procedures for controlling releases; reactor coolant chemistry and activity; gaseous effluent filtration; training and qualification effectiveness; audits; open items; and followup on LERr,.

Results: One violation was identified in Section 5 involving licensee failure to isolate waste tanks which resulted in release of unanalyzed liqui PDR ADOCK 05000409 G PDR .

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DETAILS 1. Persons Contacted L. Goodman, Operations Engineer 2L. Nelson, Health and Safety Supervisor 1,2J. Parkyn, LACBWR Superintendent 2P. Shafer, Radiation Protection Engineer 2R. Wery, Quality Assurance Supervisor I. Villaiva, NRC Senior Resident Inspector The inspector also contacted other licensee personne Denotes those present at the exit meetin Telephone conversation on May 5, 198 . Licensee Action on Previous Inspection Findings (Closed) Open Item (409/85020-02): Licensee to review and revise as necessary the off gas filter testing procedures used to confirm charcoal adsorber filter efficiencies. Because iodine concentration downstream of the filters was sometimes too low to be detected using the existing procedure, xenon had been substituted in the analysis on these occasions. However, use of xenon may be inappropriate for assessing iodine removal. The procedure and practice has been revised by increasing the sample collection time sufficiently to determine the filter efficiency based on I-131 and I-133 rather than on xenon. Also, technicians are trained in use of the procedure aad supervisory retiew of their work and test data has been increase .

(Closed) Open Item (409/85020-01): Licensee to evaluate and establish a limit on permissible background count rate on the liquid radwaete effluent monitor, above which requires decontamination of the liquid chamber. The licensee has established a conservative background count rate limit, developed in combination with the liquid radwaste effluent monitor alarm set poin . Gaseous Effluents The inspector reviewed selected records of radioactive gaseous effluent sampling and analysis for 1986 and the first quarter of 1987 and the semiannual effluent reports for 1986. The pathways sampled and analysis performed appear to comply with the reouirements of Technical Specification Table 5.3. The release path for gaseous effluents is the 350' stack. Stack inputs and the stack monitoring system are as described in Inspection Report 409/85020. The low range noble gas monitoring channel of the Eberline SPING-3 is used to continuously monitor and quantify routine noble gas releases from the plant. The noble gas is proportioned isotopically based on gamma analysis of monthly gas grab samples from the

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stack. These-grab samples are also used to compare gas concentration with that. indicated by the SPING-3 monitor. These comparisons are generally within plus or minus ten-percen Noble-gas effluents are continuing to decline with about 8600 Ci in 1985 and about 3500 Ci in 1986. The-decline -is in large part attributed to the extensive down time in 1986 but is also attributable to good fuel cladding integrity and the continued diminishing effect of tramp' uranium from significant fuel cladding problems about ten years ago. ~The

. improvement is more accurately reflected in the average-noble gas release

- rate during full power operation which declined from about 30 Ci per day

- in 1985 to about 20 Ci per day in 198 ~

. During the 1986 refueling outage, the off gas compressor, after cooler, associated. valves and piping were removed from the off gas system. This equipment, a source of minor.off gas leaks, had not been utilized since the early 1970s when the offgas -system had been augmented to effect an increase in holdup tim The' licensee recently identified their failure to correct iodine isotopes for radioactive decay during sample collection time (normally a week duration) since the time some equipment changes were made several years ago. This failure resulted in under-reporting both iodine activity released and the reported percent of Technical Specification limits. A L cursory review indicates that no Technical Specification limits were approached. This matter was discussed at the exit and during a subsequent

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telephone call with plant management on-May 5, 1987. The licensee agreed to revise past data and semiannual reports with corrected data. This is considered an open item which will be reviewed during a' future

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inspection. (0 pen Item 409/87005-01)

. No violations or deviations were identifie . Liquid Effluents

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The inspector reviewed selected records of radioactive liquid effluent

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sampling and analysis for 1986 and the first quarter of 1987 and the-semiannual effluent reports for 1986. The pathway sampled and analysis

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performed appear to comply with the requirements of Technical Specification 5.3.1.2 except on two occasions as noted later in this section. The system for batch liquid releases is as described in Inspection Report 409/85020. The radioactivity in the licensee's liquid releases had shown a gradual decline over the past several years until 1986 (5.8 Ci in '82, 3.7 Ci in 83', 3.3 Ci in '84, 1.8 Ci in '85, F 5.0 C1 in '86, and 0.12 Ci in first ouarter of '87). About 80 percent of s the liquid effluent activity in 1986 was released during the first half of the year and was primarily associated with draining the reactor for special maintenance on equipment which was non-isolable on three occasion The core was unloaded and the vessel drained for safety. The licensee

!- has insufficient capacity to store all of the water and lacks a treatment system for liquid radioactive waste. The first two drainages were for repairing a leaking decay heat valve. The gasket didn't seat correctly

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following the first repair,-necessitating a repeat of the repair wor The third draining was for replacement of an identified piece of cracked decay heat piping (unrelated to the valve problem associated with the first two drainages). These activities contributed to extensive outage time-in 1986 which in turn increased laundry water waste. The increased

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activity in liquid releases for 1986 resulted in approaching a relatively high percentage of both the quarterly and annual Technical Specification limit for both total body and organ dose (liver) with cesium 137 being the main contributor to dose. The highest organ doses for the first and second calendar quarters of 1986 were 29.8 percent and 24.2 percent respectively of the 5 mrem per calendar quarter limit specified in Technical Specification 4.3.1.3.a, as calculated by ODCM criteria. The highest annual organ dose for 1986 was 31.2 percent of the 10 mrem annual limit specified in Technical Specification 4.3.1. The whole body doses for the first and second calendar quarters of 1986 were 64.2 percent and 52.6 percent respectively of the 1.5 mrem per calendar quarter limit specified in Technical Specification 4.3.1. The annual whole body dose for 1986 was 67.8 percent of the 3.0 mrem annual limit specified in Technical Specification 4.3.1. The calculated dose is based on the consumption of fish exposed to the activity in liquid effluents. The

, actual. dose from fish consumption based on activity found in samples of fish collected near the outfall in 1986 would be rignificantly less than that calculated based solely on effluent releases, No violations or deviations were identifie . Licensee Event Report Followup Through observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determiae that immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with Technical Specification (0 pen) LER 85-12 and (Closed) LER 86-14: Both of these events involve monitored discharge of water from an unsampled waste water tank while simultaneously releasing a properly sampled and analyzed waste water tan These events are described in detail in Resident Inspector Report No. 409/86006 and were caused by operator error and procedural weaknesses although operator error was not identified by the licensee as a root cause for the first event. The first event occurred on April 9, 1986, when the 4500 Gallon Waste Tank (GWT) was being discharged to the rive The operator noticed that although over 3000 gallons had been pumped from the tank, the level was at 53 percent so he secured the releas It was later determined that about 875 gallons had overflowed from the 3000 GWT into the 4500 GWT. There is a nonisolable overflow between the two tanks to prevent possible tank rupture. At the time the discharge of the 4500 GWT began, the 3000 GWT was filling up through a common input from a number of potential sources including Turbine Building sumps (which were pumping frequently at that time due to high Mississippi River water level) and laundry drain. About an hour and fifteen minutes after the release began from the 4500 GWT, a high waste water tank level alarm was received and

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in response, the operator secured the Turbine Building sump pumps that were pumping into the 3000 GWT but did not adequately consider other inputs to the tank, in particular the laundry waste water, as the laundry was in operation during the release. About three and a half hours later, the overflow from the unsampled and unanalyzed 3000 GWT into the 4500 GWT, as the latter was being released, was discovere Subsequent sampling and analysis verified that the release to the unrestricted area was well within . Technical Specification criteria regarding concentration and dose commitment. An LER was prepared and submitted on a timely basis acknowledging the violation of Technical Specifications (Technical Specification 5.3.1.2) that require liquid wastes be-batch sampled and analyzed prior to release. The LER states,

"the Turbine Building sump pumps . . . were pumping into the 3000 GWT, until they were secured at approximately 0600 following receipt of a high weste water tanks level alarm . . ..

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"The washing machine was also discharging into the 3000 GWT." "These water streams caused the 3000 GWT to overflow to the 4500 GWT." However, the LER failed to identify the root cause which was failure of the operator to isolate the tank as required by response procedure for waste water storage tanks high level alarm (Alarm E14-3).

Regarding corrective measures, the LER stated, " Operations personnel were reminded of the need to maintain close control over the waste water tanks'

inventory while river water level is contributing to faster than normal water accumulation." During the inspection it was learned that some additional measures had also been taken including instruction of radiation protection personnel to notify operations personnel before planned operation of the laundry and development of a procedure to transter waste water tank contents to a retention tank if needc However, none of the corrective actions taken properly address the failure to isolate the full tank as required on receipt of a high level alarm. Paying attention to some of the inputs such as Turbine Building sumps and laundry drain water does not isolate the tank to preclude over filling. Also, the alarm response procedure was r.ot modified to reference the new procedural alternative of transferring waste water tank contents to a retention tank if needed. Therefore, the licensee did not make a proper evaluation nor fully take proper corrective measures in response to LER 86-12. The licensee's failure to isolate the 3000 GWT when a high level alarm was received in the control room on April 9, 1986, was a violation of the immediate actions required by Waste Water Storage Tank high level alarm (ALARM E14-3) response procedure contained in LACBWR Operating Manual, Volume I, Integrated Plant Operations. This, in turn, resulted in failure to determine the radioactivity content of the discharge prior to release as required by Technical Specification 5.3.1.2 because of the overflow of unsampled and unanalyzed water into the 4500 GWT which was being released. (Violation 409/87006-02).

The second event, covered by LER 86-14, occurred nine days later on April 18, 1986, when water from an unanalyzed tank was mixed with the discharge of an analyzed tank. However, the root cause of this event was different and the event was properly identified and corrected by the

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licensee. In this case, an operator failed to restore the valve lineup properly following the prior release. Contributing to the event was the rather complicated valving involving a cross-tie between the two tanks and the two pumps to allow either tank to be discharged by either pum A key corrective measure has been the simplification of this system by dedicating one pump to one tank and locking closed several valves that will not be needed in the simplified arrangement. Special procedural controls for any future use of the cross correction include shift supervisor authorization and a special check list. Other corrective measures included training provided to each operating crew on importance of following procedures and proper control of liquid waste release This training was reinforced by a memo on this subject from the plant superintendent to all shift supervisors regarding the need for lineup verification. The licensee's evaluation and corrective measures for LER 86-14 appear appropriate. Therefore, LER 86-14 is considered -

close One violation and no deviations were identifie . Monitor Calibrations and Set-Point Determinations

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The inspector. reviewed the calibration of stack noble gas monitors, the liquid radwaste monitor as well as the turbine condenser monitor and the

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component cooling water monitor. The latter two monitors were replaced

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by new state-of-the-art monitors in February 1986. Timely calibrations were performed for all these monitors in February through April 198 Set points were properly established in accordance with ODCM criteri No violations or deviations were identifie . . . Reactor Coolant Water Quality The inspector reviewed 1986 and first quarter 1987 licensee records to determine compliance with Technical Specification requirements for reactor coolant periodic tests, chemical control and radioactivity control. Records reviewed were cnloride concentration, pH, conductivity, gross alpha, gross beta gamma and dose equivalent I-131. Data reviewed showed that tests were being performed within required frequencies and that parameters were maintained within Technical Specification limit No violations or deviations were identifie . Air Cleaning Systems The only air cleaning system addressed in the Technical Specifications is the containment building ventilation exhaust treatment system to reduce particulate radioactive material in gaseous waste. The criteria address

" operability" but not efficiency testing. The licensee's continuing practice is to install a new HEPA filter each refueling outage or before that if the delta p across the filter approaches six inches of wate No in place testing is performed nor does the system have any provision for such testing. However, the licensee uses filters that have been pretested and certified by the vendor to meet criteria in accordance with ANSI-N509-197 . . . . . . . .

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. The' air ejector off gas' system has-both a particulate filter and a charcoal adsorber-(both' A and B train) located upstream of the recombiner-and off gas. holdup / storage tanks and has identical filtration /adsorbe trains located downstream of.the recombiner and off gas holdup / storage tanks. These filters and charcoal adsorbers are not addressed by, Technical. Specifications but are addressed and are being tested pursuant-

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.to Health Physics Procedure HSP-06-16. The procedure calls'for measuring both the upstream and downstream concentrations of particulate and iodine

.nuclides as appropriate for each train currently in use during reactor operation. The procedure specifies that any off gas system particulate

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filters with efficiencies less than.99 percent and charcoal adsorbing-filters with efficiencies-less than 90 percent should be changed when conditions permit,.which by policy is the next refueling outage, due to-

ALAR /. considerations. . In the interim, the alternate filter train is

. utilized. The latest tests of ~ filters in use was conducted in March 1987 and showed that both upstream and downstream filters met test criteri As described in Inspection Report 409/86003, the licensee-experienced a hydrogen ignition in an off gas sampling rig on March 6, 1986, while using silver zeolite cartridges 'as a substitute for. charcoal cartridges while evaluating methods of determiaing charcoal adsorber filter

. efficiencies when low concentrations of iodine exist. The ignition apparently caused an ignition also in the off gas system to which the , sample rig was connected. .The downstream HEPA filter was damaged (filter media was torn) and replaced. The event, as described in the referenced o report had little effluent significance. Tests showed other filters wer ; not damaged. As a result of this event, the licensee abandoned further use of silver zeolite cartridges in effluent streams having potentia 1'for

elevated hydrogen concentrations.

No violations or deviations were identified.

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Audits The inspector reviewed the reports of two internal audits of the Health

' and Safety Department performed by the Quality Assurance Departmen These. audits were Audit Nos. 70-86-1 and 70-86-3 conducted in August

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through September 1986 and November 1986 through January 1987, respectively.

. Portions of these audits covered activities and procedures of the

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licensee's gaseous and liquid radwaste programs. Specific areas audited included liquid sampling, off gas sampling and analysis, sampling and analysis of stack effluent for particulate and iodine, and calibration

of stack effluent monitors. The licensee appears to be adequately responding in a timely manner to the few audit identified weaknesses and recommendation !

In response to a previous concern of the inspector regarding the limited health and safety experience of the individual conducting the audit, the Radiation Protection Engineer (RPE) assisted in the conduct of the audits 1 described above. The extensive experience of the RPE in this field allays the concern previously expressed.

No violations or deviations were identified.

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10. Organization and Training Staffing in the health and safety group has been stable at both the technician and supervisory level since the last inspection. Personnel interviewed were reasonably knowledgeable of the liquid and gaseous radwaste systems, procedures and their assigned responsibilities. Some increased effort for technician training was noted including training in preparation of the semiannual effluent release repor No violations or deviations were identifie . Open Item Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. An open item disclosed during the inspection is discussed in Section . Exit Interview The inspector summarized the scope and findings of the insp ction with licensee representatives (Section 1) at the conclusion of the inspection on April 9, 1987 and during a subsequent telephone conversation on May 5, 1987. The inspector discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify such documents or processes as proprietary. In response to certain items discussed by the inspector, the licensee: Stated they would revise applicable semiannual effluen;. reports for both activity released and percent of Technical Specification limits for iodine isotopes to account for radioactive decay during sample collection time. (Section 3) Stated that LER 86-12 would be reevaluated both as to root cause of the event and corrective measure taken. (Section.5)

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