IR 05000155/1993008
| ML20045H110 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 07/12/1993 |
| From: | Mccormickbarge, Steven Orth, Nirodh Shah NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20045H100 | List: |
| References | |
| 50-155-93-08, 50-155-93-8, NUDOCS 9307190072 | |
| Download: ML20045H110 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III'
Report No. 50-155/93008(DRSS)
Docket No. 50-155 License No. DPR-6
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Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:
Big Rock Point Nuclear Plant
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Inspection At:
Big Rock Point site, Charlevoix, Michigan Inspection Conducted: June 21-25, 1993 Inspector:
BASM 7N O
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N.' Shah Date
^% K
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,, < - es S. K. Orth
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Date Approved By:
D e [M' det 7 /4 - 1./
J. W. McCormick-Barfer, Acting Chief Date
Radiological Controls, Section 1 Inspection Summary Inspection on June 21-25. 1993 (Recort No. 50-155/93008(DRSS))
Areas Inspected: Routine inspection of the radiation protection (RP) program (inspection procedure (IP) 83750) and gaseous and liquid radwaste program (IP 84750), including management control and organization, internal and external exposure, As low As Reasonably Achievable (ALARA), and calibration of.
gaseous and liquid effluent process monitors. Also reviewed were new 10 CFR Part 20 implementation, refueling outage preparation, and two Licensee Event Reports (LERs) concerning failure to calibrate a stack gaseous sample flow rate meter and failure to post a high radiation area.
Results: Overall, the licensee's radiation protection program appeared good.
Planning and preparation for outage and non-outage work addressed ALARA concerns and made good use of historical data (sections 5 and 6).
Communication between work groups, and maintenance job planning appeared to be improving (section 6b). Transition to the new 10 CFR Part 20 also appeared to be going well (section 3).
However, additional management oversight was warranted for plant housekeeping (section 10) and maintenance of the whole body counter (section 7). One cited and one non-cited violation were identified for failure to calibrate a sample flow rate meter (section 9) and failure to post a high radiation area (section 5), respectively.
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DETAILS
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1.
Persons Contacteo
- E. A. Bogue, Manager Chemistry and Health. Physics
- K. E. Pallagi, Supervisor Radiation Protection
- M. Baurrassa, Licensing Engineer
- T. A. Mosley, Senior Engineer (Chemistry and Health Physics)
- B. Olmstead, Dosimetry Supervisor, RP Technician-
- T. Popa, Site ALARA Coordinator
+M. Moore, Nuclear Performance Assessor D. Turner, Manager Plant Maintenance
- Present at the June 25, 1993 exit meeting
+ Contacted by telephone on June 29, 1993 The inspector also interviewed other licensee personnel.
2.
Licensee Action on Previous Inspection Items (IPs 83750 and 86750)
r (Closed) Inspection Followuo item (IFI) 50-155/92026-02:
Licensee to replace labels on contaminated tools stored in old machine shop and evaluate methods to segregate them from clean tools. The licensee replaced the degraded labels and assigned a worker to review contaminated tool control. Additionally, the radiation protection group will be responsible for controlling and segregating tools and was preparing the old machine shop as a tool storage area. During plant tours (section 10), the inspectors verified that contaminated tools were properly labeled, and observed the preparations of the old machine ' shop.
(0 pen) IFI 50-155/92011-01:
Licensee to perform 10 CFR 50.59 safety evaluation for processing of filters in the radwaste building. The licensee is incorporating filter processing into a revised safety evaluation for the radwaste building. The revision is necessary because the licensee has determined that additional radwaste storage space will be needed. This item will remain open until the evaluation is completed, and reviewed by the inspectors.
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3.
Implementation of the New 10 CFR Part 20 (IP 83750)
The licensee implemented the new 10 CFR Part 20 on January 1, 1993.
Although HRC approval of revised technical specifications are pending, the licensee has adopted new part 20 terminology and requirements into their radiation protection plan and plant procedures. While the overall scope of the change will be reviewed during routine inspections, some significant changes are summarized below:
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The licensee has implemented administrative limits of 2.5 rem / year
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(25 millisieverts (mSv)/ year) and 10 rem (100 mSv) for 5 years for plant workers, which cannot be exceeded without site vice-president approval.
In 1994, the worker annual dose limit will be reduced to 2.0 rem (20 mSv).
For contractors, the administrative limit is 4.0 rem (40 mSv) per year.
An administrative review limit of 1.5 rem / year (15 mSv/ year) was
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also established.
Workers exceeding this limit are required to
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document their activities and exposure to date, for supervisory review. These documents will also be reviewed by the Radiation Protection Manager and the Plant Manager.
For airborne concentrations less than 0.3 Derived Air
Concentrations (DAC) or intakes less than 0.3 DAC-hour, no respiratory protection is required; otherwise, respiratory protection will be used if ALARA.
For intakes expected to exceed 4.0 DAC-hours, additional monitoring is required.
Until the radiation protection technicians (RPTs) gain familiarity with the
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revised respirator policy, all work in areas with airborne concentrations exceeding 0.3 OAC will require DAC-hour tracking.
The inspectors selectively reviewed plant documents to verify that plant procedures incorporated new part 20 requirements, and that specific program changes were based on current industry and NRC guidance.
Additionally, the inspectors reviewed selected jobs (section 5) against the licensee's revised respiratory policy and verified through interviews that workers were becoming attuned to new part 20 terminology.
Overall, the licensee appears to have made a smooth transition to the new 10 CFR Part 20.
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No violations or deviations were identified.
4.
Audits and Appraisals (IPs 83750 and 84750)
The inspectors reviewed the licensee's self-assessment and correction of problems. The inspectors focused on routine audits and appraisals, but also reviewed several radiological incident reports (RIRs) and licensee event reports (LERs). While the LERs are summarized in sections 5 and 9, an RIR concerning a missed air sample is discussed below.
Each individual department performs self quality control (QC)
assessments with the responsible department head acting as QC supervisor.
Formal quality assurance (QA) audits are performed by special assessment teams comprised of specialists from different functional areas at Big Rock Point, Palisades, and the Consumers Power corporate group. The inspectors reviewed selected audits and surveillances and discussed specific findings with the licensee.
Overall, the audits appeared performance based with timely followup.
The radiological engineer was temporarily reassigned to the QA group to assist in review of RP activities.
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RIR l-93 documented an unanalyzed air sample due to personal error by an RPT covering recirculation pump (RCP) seal work. A subsequent analysis of the sample identified acceptable airborne conditions in the work area.
RP management discussed the incident with the RPT and suspended the individual for one day. Additionally, the incident was reviewed in subsequent daily briefings with all RPTs.
The inspectors verified that no radiological intakes had occurred and that RPTs were cognizant of station air sampling requirements.
No violations or deviations were identified.
5.
External Exposure Control (IP 83750)
The inspector reviewed selected aspects of the licensee's external exposure control program including refueling outage preparation and previously completed jobs. Also reviewed was an LER documenting an unposted high radiation area.
For 1993, the licensee set a goal of 200 person-rem (2 person-Sv), and has accrued about 30 person-rem (0.3 person-Sv) to date.
The majority of the accrued dose (about 20 person-rem (0.2 person-Sv)) resulted from equipment failures including inspection / repair of condenser air inleakage, rebuild / replace clean-up pump, repair of turbine steam leaks, replace #2 RCP seal, steam drum valve work, and thermocouple / flux tube repair.
Included in the 1993 goal is an estimated 160 person-rem (1.6 person-Sv) from the refueling outage. Major outage activities include inservice inspection (ISI), rebuild / repair control rod drives (CRDs), repair of M0/V0P-N00123 A&B valves, and refueling activities.
Altogether, these activities account for an estimated 75 person-rem (0.75 person-SV).
The licensee has experienced repeated operability problems with the
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In February 1993, the seal was replaced due to crud buildup on the seal and pump shaft surfaces.
Subsequently, the seal again failed and was scheduled for replacement during the refueling outage.
The licensee hired a contractor to determine why the seals failed and to recommend corrective actions.
The licensee estimates 17 person-rem (0.17 person-Sv) will be spent repairing the seal.
The inspectors reviewed LER 93-001 concerning the failure to post a high radiation area (HRA).
During weekend backshift on January 9, 1993, workers vacuuming the spent fuel pool observed contact readings of 3 rem /hr (30 mSv/hr), and 500 mrem /hr (5 mSv/hr) at 12 inches from the
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top of the vacuum filter housing.
The duty RPT at the radiological control point recorded these readings on the job radiation work permit (RWP), but did not communicate them to another RPT performing a coincident routine survey in the work area.
Later, the second RPT reported the survey results to the shift supervisor and updated relevant RP documentation.
Because both RPTs incorrectly assumed the work area was already posted as an HRA, no additional postings were placed on the
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filter housing. The next regular workday, January 11, 1993, an RP-l
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supervisor noted the elevated readir.gs, immediately had the area resurveyed, and the filter housing posted as an HRA.
i Because this was first use of the vacuum filter unit the job RWP limited access to those workers who were HRA qualified.
This qualification entails special training (see inspection report 50-155/92005(DRSS)) in station HRA procedures and allows workers to perform self dose rate coverage. The licensee verified that no workers had received unexpected
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exposures and counseled both RPTs. This event was also covered in
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subsequent daily RPT briefings and in an expanded training session emphasizing management performance expectations. The inspectors verified these actions and discussed the identified communication and training deficiencies with the licensee. Although failure to post the filter housing is a violation of technical specification 6.12.1 which requires posting of HRAs less than 1000 mrem /hr (10 mSv/hr), it was identified by the licensee and corrective actions should prevent recurrence. Therefore, this violation will not be cited, as the
criteria specified in Section VII.B of 10 CFR Part 2 Appendix C were satisfied.
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One non-cited violation was identified.
6.
Maintainina Occupational Exposures ALARA (IP 83750)
The inspector reviewed the licensee's As Low as Reasonably Achievable (ALARA) actions for the refueling outage and for previous jobs, a.
ALARA Preparation A contract ALARA planner was hired to assist work planning efforts. This individual had over 10 years experience in the
nuclear industry and will also be responsible for computerizing RP job history files.
Decontamination (decon) and housekeeping efforts will be aided by five temporary workers.
These workers were high school graduates over 18 years of age, with no previous nuclear experience. The workers were given special training in
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decon techniques and will be continuously monitored by RPTs.
Fifteen contract RP technicians were also hired to support outage radiological coverage and will report directly to station RP management. Of the eight station technicians, four senior RPTs were temporarily upgraded to supervisors; two of the upgraded RPTs will assist the RP supervisor during the outage, while the others will supervise the temporary decon workers.
Finally, two station RPIs will be assigned as rovers. Overall, RP support for the
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outage appeared good.
b.
ALARA Plannina
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The inspectors noted good communication among work groups during weekly outage planning meetings, with appropriate consideraticn to ALARA.
During the outage, three daily meetings are planned to
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communicate concerns to plant staff. These meetings will be
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supplemented by periodic distribution of three and seven day
schedule overview reports to management. Unplanned work will be discouraged by giving overall outage control to the outage coordinator and instructing shift supervisors and RPTs to disallow unscheduled work unless approved by the outage coordinator or designee.
Maintenance planning was improved thhJgh the assignment of one of the maintenance supervisors to maintenance job planner. This individual will maintain the work history file and assist the health physics planner assigned to maintenance (inspection report 50-155/92026(DRSS)). These two persons are co-located to ensure good communication. A maintenance planning guide was also developed to assist in preparing work packages. The licensee began implementing an advanced maintenance management system (AMMS) to improve the work history files. This system was developed by the licensee's corporate group and was used at other Consumers Power facilities.
Previously, work histories were
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relatively unattainable and had limited use in work planning.
l Finally, mockups were used during planning for CRD and
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miscellaneous valve work.
Plant operations also improved overall planning through weekly
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meetings with maintenance and RP, and through the AMMS. These measures were expected to ensure department awareness hf upcoming
work activities and to reduce aggregate dose from multiple entries
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into radiation areas for surveillances and equipment tagging.
Good ALARA efforts were noted during non-outage work planning I
(section 5).
For example, power reductions during the moisture separator leak repair were credited with saving about 2 person-rem (20 person-mSv).
Plant photos used while planning the condenser
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air inleakage inspection were also included in the work package.
i However, some minor communications and preplanning problems were noted.
For example, an extra entry was needed during thermocouple / flux tube repair due to the wrong component being brought in. Also, poor shift turnover during the RCP seal work resulted in tool accountability problems. The licensee recognized these concerns during postjob reviews and took corrective actions.
c.
ALARA Implementation Source term reduction efforts included replacement of the
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feedwater regulating valve and the performance of a soft shutdown.
The valve replacement was originally scheduled for the 1992 outage, but was delayed due to engineering concerns (inspection
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report 50-155/92011(DRSS)).
Exposure reduction efforts include flushing the CRD poison line to reduce contact dose rates; previous flushings reduced dose rates about 90-95 percent. After the outage, the licensee plans to
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install hydrolazing ports on selected plant piping. Other
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initiatives include constructing a special frame for shielding RCP piping, remote ISI via ultrasonic testing equipment, and using video cameras to record RCP, CRD, and refueling work.
Shielding, installed on the radwaste header, should save 1.5 person-rem (15 person-mSv) annually.
The licensee has been trying to increase the experience level of maintenance workers by assigning them to infrequent jobs. For example, during changeout of the RCP seal (section 5),
inexperienced workers were used under an experienced supervisor.
Although this resulted in higher (10 person-rem (100 person-msv))
than expected (6 person-rem (60 person-mSv)) dose, the licensee
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felt that increasing worker experience will lower long term dose.
Overall the licensee's ALARA program appeared good. Work planning appropriately considered ALARA and used historical results to estimate dose. The use of inexperienced workers under an experienced. supervisor should increase worker expertise and lower long term dose.
Communication between plant departments and maintenance job planning appeared to be improving, and good exposure reduction efforts were noted.
However, additional effort is needed during work turnovers, and source term reduction efforts were somewhat limited.
No violations or deviations were identified 7.
Internal Exposure Control (IP 83750)
The inspector reviewed the licensee's internal exposure program including operation of the whole body counter (WBC), whole body count results, and calibration and operation of continuous air monitors.
Recently, the WBC was modified to allow for onsite data analysis and to reduce the counting time.
Previously, data analysis was done offsite by the vendor.
The inspectors identified several concerns related to these modifications that indicate a weakness in management oversight. After reducing the counting time, the licensee did not verify that the minimum detectable activities (MDA) were sufficient to meet investigation
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levels.
The inspectors later verified these levels by scaling the old MDAs to the new counting time, but these were not in agreement with the licensee's software program results. After discussions with the vendor, a possible software problem regarding MDA calculation was identified.
The vendor is recalculating the MDAs, wil'1 upgrade the software, and provide additional training to licensee staff. These concerns were discussed at the exit meeting (section 11), and will be reviewed in a future inspection (IFI 50-155/93008-01).
The inspectors reviewed the annual calibration verification of the WBC performed by the vendor using a tissue equivalent phantom containing multiple radionuclides.
The performance criteria required an accuracy of 15 percent and a precision of 7.5 percent, which were achieved during the latest verification. When in use, the licensee also did daily
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source checks of the WBC to verify performance.
These tests were
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tabulated by the licensee and had an acceptance criteria of 5 percent.
The inspectors also determined that no intakes above the licensee's administrative limits had occurred and that appropriate followup was taken following suspected intakes.
If a questionable WBC result was identified, the licensee electronically transferred the data to the -
vendor for further analysis.
Continuous air monitors (CAMS) were observed in good condition and were
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calibrated.
Recently, the alarm setpoints for the sphere CAM were reset owing to an increase in background activity from minor steam leakage.
Between December 1992 and March 1993, the leakage was attributed to the reactor depressurization system and was repaired; however, new indications of leakage were recently identified and will be repaired during the outage. Air samples indicated the activity was below 0.03 DAC and consisted of fission and activation products.
Until repairs are completed, daily air samples will be collected and the CAM will remain at the new alarm setpoints.
No violations or deviations were identified, a
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Control of Radioactive Materials and Contamination. Surveys and Monitorina (IP 83750)
The inspectors reviewed the functional tests and calibration procedures
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for the portal monitors and whole body friskers, and verified that they were performed as required.
For the portal monitors, operational checks were performed using a 200 nanocurie (7.4 kiloBecquerels) cesium-137 For the whole pody friskers, a cobalt-60 source is used to source.
simulate 500 dpm/100 cm of contamination. The licensee recently revised the annual portal monitor test / calibration procedure, RIP-18,
" Operational Check of the GAMMA-10 Portal Monitor," to optimize the monitor's operating voltage and sensitivity.
Identification, dose evaluation, and reporting of personnel contamination events (PCEs) appeared to have been done in accordance with procedural requirements. About 9 PCEs were recorded to date, compared to a non-outage goal of 48.
The inspectors verified that necessary dose evaluations were performed correctly and that followup actions were taken when external contamination was suspected.
No violations or deviations were identified.
9.
Calibration of Effluent Process Monitors (IP 84750)
Gaseous and liquid monitors were initially calibrated using gaseous and j
liquid sources, respectively, which were correlated to several solid sources for use in subsequent calibrations. While the liquid monitors were calibrated onsite, the gaseous monitors were calibrated by the manufacturer. The inspectors reviewed selected calibration records and verified that they were performed using sources traceable to the
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National Institute of Standards and Technology. Also reviewed were
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selected functional tests to verify monitor' operability;. no problems were identified. During plant tours (section 10), the inspectors verified that.the monitors were operable and in good condition.
The inspectors reviewed LER 92-015 concerning the failure to calibrate the stack gaseous sample flow rate meter for the stack radioactive gaseous effluent monitor (RGEM). On December 10, 1992, the meter failed due to problems with the system electronics. While reviewing maintenance testing documents, the licensee identified that the meter had not been calibrated since initial installation in 1983.
Immediate corrective actions consisted of verifying that sample flow rate was within the expected range (2.8-3.4 cubic feet per minute) and performing an as found test on the replacement meter using a calibrated air pump.
The first meter was later sent offsite for calibration, prior to reinstallation.
Insufficient management oversight was the root cause of the missed surveillance. Although the flow meter was installed in 1983, it was not required to be calibrated until 1986, following a change in licensee technical specifications (TS). The new TS (TS 13.1.1, table 13-2)
required that the meter be calibrated every 18 months. The licensee determined that no surveillance procedure was generated implementing the calibration requirement, and that subsequent audits had incorrectly assumed that the meter was calibrated during the RGEM calibration.
Corrective actions included developing a surveillance test for the flow meter and having the audit group redo the latest audit of the gaseous radwaste system. The auditors also verified their procedures against current process monitor technical specifications.
Failure to comply with TS requirements is a violation (violation 50-155/93008-02). This event was reviewed by the inspectors and discussed at the exit meeting (section 11).
One violation was identified.
10.
Plant Tours (IPs 83750 and 847501 Accompanied by a station QA auditor, the inspectors toured work areas and took confirmatory radiological measurements. Although radiological postings appeared appropriate, the inspectors noted that housekeeping was declining. Several cases were identified of material crossing contaminated area boundaries and of debris (chipped paint, paper, etc)
in work areas.
The condition of the chemistry laboratory was poor, as evidenced by poor maintenance of work areas and unlabeled containers.
Of particular note was room 441 in the containment sphere, which is used as a storage area between outages.
The inspectors noted that materials appeared haphazardly stored, limiting access to the area. Additionally, the inspectors noted a drum, apparently containing chromates, which may have been leaking into a radwaste floor drain. These items were discussed with the licensee, who took steps to correct the identified deficiencies.
Regarding the drum, the licensee determined that no
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-leakage had occurred. At the exit meeting (section'11), the inspectors-commented that additional management oversight of housekeeping was warranted.
The inspectors observed workers using good radiological work practices, including proper wearing of dosimetry devices.
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11.
Exit Interview The scope and findings of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on June 25, 1993. One cited and one non-cited violation were identified.
No documents were identified as proprietary by the licensee. The
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following matters were specifically discussed by the inspectors:
Failure to post a high radiation area (section 5)
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Failure to calibrate the stack sample flow rate meter (section 9)
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Plant housekeeping (section 10)
Calculation of MDA for the WBC (section 7)
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