IR 05000219/1993013
| ML20024J005 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 08/17/1993 |
| From: | Eckert L, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20024J004 | List: |
| References | |
| 50-219-93-13, NUDOCS 9308310140 | |
| Download: ML20024J005 (3) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-219/93-13 Docket No.
50-219 License No.
DPR-16 Licensee:
GPU Nuclear Corporation (GPUNC)
P.O. Box 388 Forked River, New Jersey 08731 Facility Name:
Oyster Creek Nuclear Generating Station (OCNGS)
Inspectica Period:
July 12-16,1993 br D
Inspector-
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L. Eckerl, Radiation Specialist Date Facilides iation Protection Section Approved By:
Ac b }I-k 3 W. Pasciak, Chief Date Facilities Radiation Protection Section s
Areas Inspected: Inspection of the licensee's radiological protection programs during normal operations including: q.tality assurance audits and surveillances, training (in radwaste and transportation requirements) and qualifications of personnel, the radwaste organization, implementation of the ridwaste program, and radioactive material shipping records.
Results: The quality assurance and radwaste training programs were well implemented. The radwaste organization was staffed with a stable work force of well qualified individuals in the radwaste and transportation area. The radwaste program was, in general, well implemented.
Improvement was noted concerning minimEng radwaste generation. A non-cited violation concerning shipment of dewatered filter sludge was identified (see Section 5.4).
9308310140 930820 PDR ADOCK 05000219 O
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i DETAILS 1.0 Personnel Contactest i
1.1 Station Personnel l
- F. Applegate, Quality Assurance (QA)
J. Barton, Director OCNGS W. Barkoczy, Group Radwaste Shipping Supervisor (GRWSS)
W. Collier, GRWSS
- W. Cooper, hianager Radiological Engineering
- P. Czaya, Licensing Engineer
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J. Derby, ALARA**
- M. Douches, QA Audits
- R. Hillman, Manager Radwaste Operations R. Hurley, GRWSS
- S. Levin, Operations and Maintenance Director
- J. Rogers, Senior Licensing Engineer
- P. Scallon, Manager Plant Operations
- A. Wacha, Radwaste Programs Manager Other licensee pers;nnel were contacted during the inspection.
1.2 NRC Personnel
- D. Vito, Senior Resident Inspector l
- Denotes attendance at the exit meeting.
- ALARA = As Law As is Reasonable Achievable 2.0 Audits and Appraisals l
Technical Specification (TS) 6.5.3.1 required that the process control program and implementing procedures for radioactive wastes be audited at least once per 24 months.
Licensee audit S-OC-92-10 was reviewed. The audit was conducted August 1,1991 until November 18,1992. This audit focused on the radwaste organization, training /
qualifications, radwaste services / control requirements, radwaste shipment / record requirements, radwaste packaging / procurement requirements, container control, waste
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classification / Process Control Plan (PCP), radwaste/ Augmented Off Gas (AOG) facility
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operations, equipment control, maintenance / modifications, waste minimization, surveillance
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testing / calibration, Low Level Radwaste Storage Facility (LLRWSF), adequacy of corrective
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actions, and review of Quality Assumnce (QA) monitoring. A deficiency was identified and categorized as an audit finding. This deficiency pertained to improper changes to radwaste system lineup / verification sheets. The auditors noted that an acceptable response was received and that the corrective actions would be evaluated in a future audit / sun'elllance.
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l Another deficiency pertained to a vendor that used a corrective action system other than that which was specified by contract. This deficiency was characterized in the audit as minor.
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This deficiency was closed after receipt of the vendor's corrective action document, which l
was found acceptable by the licensee, and review of vendor actions taken on the behalf of I
other licensees.
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l The inspector reviewed licensee audits of vendor-supplied services, programs, or facilities.
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The following audits were reviewed.
- O-COM-91-07, Chem Nuclear Systems Incorporated (CNSI), January 17,1992 l
This audit was performed by licensee QA staff. This audit identified 3 findings and l
three recommerdations.
- O-COM-91-11, Quadrex, Dezember 20,1991 This audit was performed by licensee QA staff. This audit identified 5 findings.
O-COM-91-12, Scientific Ecology Group (SEG), Incorporated, December 20,1991
This audit was performed by licensee QA staff. This audit identified 2 findings j
(which have potential regulatory compliance implications).
O-COM-93-05, Alaron Corporation, June 15,1992
This audit was performed by Quality Systems Incorporated for TU Electric. Two weaknesses were identified.
Several QA surveillances were also reviewed. Four of the surveillances reviewed dealt with shipment preparation. No significant discrepancies were identified. Another surveillance was conducted to evaluate procedure 351.22, " Radioactive Waste Handling Procedure,"
Revision 14. The evaluation concluded that certain procedural requirements were unnecessarily redundant and that the procedure should be streamlined. The surveillance program was found to be effective in augmenting the biennial audit required by TS.
In summary, the licensee's audit was sufficiently thorough and, where possible, performance based in nature. The licensee's audit and appraisal program was con % red good.
3.0 Organization i
The Manager, Radwaste Operations heads the radwaste organization. Since the last
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inspection in this program area, a new individual has filled this position. This individual was l
SRO certified and had previously served as the Manager, Plant Chemistry and had served in Outage Planning during 14R (the fomteenth refueling outage).
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i The radwaste and transportation program was essentially split into two functional areas,
radwaste operations and radwaste shipping. These functional areas were overseen by the j
Radwaste Engineer and the Radwaste Programs Manager, respectively.
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The Radwaste Engineer was supported by 5 Group Radwaste Shift Supervisors (GRSSs) and 18 Radwaste Operators (RWOs). The Radwaste Programs Manager was supported with three Group Radwaste Shipping Supervisors (GRWSSs), a Radwaste Shipping Clerk, and three CNSI contractor employees. Radwaste shipping responsibilities were split into three areas. Each area was then assigned a cognizant GRWSS. These areas included the following program aspects.
- Dry Active Waste (DAW) packaging, receipt of radioactive materials, laundry, radioactive material control
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Wet waste processing, CNSI oversight LLRWSF eversight, re-usable contaminated equipment storage, source shipments,
pre-planning for special projects, safety evaluations Since the last inspection in this program area, the Radwaste Programs Coordinator position was eliminated and the responsibilities were shifted to 11.2 Radwaste Programs Manager and the Radwaste Shipping Clerk.
i Turnover in the radwaste organization area has been minimal. The licensee has been able to maintain a stable work force of well qualified individuals in the radwaste and transportation
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area.
4.0 Training and Qualifications of Personnel To determine if licensee commitments made in response to I&E Bulletin 79-19, " Packaging of Low-level Radioactive Waste for Transport and Burial," had been met, the inspector conducted interviews with training department and radwaste department personnel, and i
reviewed the licensee's response to I&E Bulletin 79-19, several pertinent lesson plans, and i
selected training records.
4.1 Oualifications of Personnel l
The inspector selected training records for the three GRWSSs, the Radwaste Programs Coordinator, and several RWOs. No discrepancies were noted.
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4.2 Radwaste Transoortation and Shioment Trainine For the past several years, the licensee has provided a broad-based course on the radwaste and transportation requirements annually to the GRWSSs (those individuals responsible for certifying that a shipment of radioactive material meets all of the DOT, NRC and waste burial requirements). In practice, the licensee has either contracted the services of a CNSI instructor to supply the required radwaste and transportation training on-site or has sent selected personnel to CNSI courses off-site. In 1992, an additional course was provided on the RADMAN computer code and was conducted by Waste Management Group (WMG).
Additional training was provided on maintaining regulatory compliance in this training course.
No internal lesson plans had been developed to facilitate GRWSS/Radwaste Programs Manager training. However, licensee training department personnel had reviewed and approved the lesson plans provided by the vendor prior to course instruction. The Radwaste
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Programs Manager directed changes to the vendor-supplied course curriculum on regulatory compliance to provide a more site-specific training curriculum (through the use of station procedures and practices), where possible.
l The inspector noted that efforts were made concerning providing training in the l
transportation and radwaste requirements to auditors and others outside the radwaste l
organization. This was facilitated by the licensee through providing the CNSI course on-site and requesting participation outside the radwaste organization.
In summary, the amount and quality of training provided to those individuals responsible for certifying the adequacy of a shipment of radioactive materials / waste was considered very l
good.
4.3 Radwaste Operations Training l
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The licensee has developed a two-year training cycle for radwaste operations personnel.
I Each cycle was 5 weeks in length. No formalized training matrix had been developed. At the time of the inspection, the licensee was in the process cf modifying the radwaste operator training program. A task-based analysis of responsibilities was underway. This analysis will provide a basis for the core tasks for which training will be required in each two-year l
training cycle. The modified radwaste operator training program will be evaluated in a future inspection.
In order to determine whether radwaste operations personnel had been trained to recognize potential impacts on f' mal waste form, the inspector reviewed pertinent radwaste operations lesson plans. The following lesson plans were reviewed.
821.0003, "A.R.M. System," Revision 1,3/13/90
e 828.0033, " Process Radiation Monitors," Revision 2, 6/25/90 l
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e 828.0070, " Hydrogen Water Chemistry System," Revision 1,2/11/92 836.0001, " Spill Prevention, Control and Countermeasures (SPCC) Plan," Revision e
1,3/13/90 e
838.0117, "Radwaste Minimization," Revision 1, 2/6/91 e
838.0018, " Radiation and Contamination Controls," Revision 0, 6/27/90 e
840.0002, Chemical Waste / Floor Drains," Revision 2, 6/30/92 e
840.0003, "New Radwaste Chlorination," Revision 2, 4/15/92 e
840.0005, " Drain and Sumps," Revision 1, 4/6/90 e
840.018A, " Resin Transfer," Revision 0,1/14/91 e
840.0021, " Advanced Liquid Processing System," Revision 0,11/3/92 The inspector concluded that sufficient training with regard to health physics and radioactive material / waste shipping concerns was conducted. Additional training on chemistry fundamentals was provided to radwaste operations personnel in 1992.
4.4 Trainine Program Summary The radwaste and transportation training program was considered a program strength.
5.0 Implementation of the Radioactive Waste Program i
5.1 Descrintion As described in the Updated Final Safety Analysis Report (UFSAR), the radwaste handling system processed concentrated liquid wastes, chemical filter sludges, high purity filter sledges, Reactor Water Cleanup (RWCU) fihr sludges and resins, fuel pool cleanup filter sludges and resins, dewatered sludges and demineralizer resins from other plant demineralizers. There are three waste streams.
o Concentrated liquid waste (CLW, i.e. evaporator bottoms)
e filter sludge e
spent demineralizer resins (bead and powdered)
At the time of the inspection, the licensee was not using its evaporator to process waste.
Filter sludge was processed using a cement solidification process. Spent resins were transferred via the spent resin transfer system into disposable High Integrity Containers (HICs), which were fitted with dewatering elements. The solidification system for filter sludge and CLW was a vendor-supplied mobile unit which had been approved by an NRC topical report.
As described in the UFSAR, there were four basic liquid collection subsystems and an environmental discharge subsystem comprising the liquid radwaste system. The collection subsystems included the equipment drain subsystem for low conductivity wastes (high purity
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water), the floor drain subsystem for higher conductivity wastes, the chemical drain subsystem, and the laundry subsystem for cleaning agent wastes.
No DAW compacting was currently being done on-site. The licensee utilized the services of Interstate Nuclear Services (INS) for laundry, Quadrex for metals, and SEG for other DAW.
l The following procedures were reviewed.
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e 351.36, " Process Control Plan for Transfer, Solidification and Dewatering of Solid j
Wet Waste," Revision 18, 11/9/92 l
352.0, " Process Control Plan for Processing Resins into a CNSI High Integrity e
Container," Revision 14, 8/29/92 i
No procedural inadequacies were noted.
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i 5.2 Licensee Initiatives Some notable improvements were completed or were planned.
e addition of a lid installation tool (ALARA improvement)
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addition of the EQUA* FLEX vessel to the Advanced Liquid Processing System e
(ALPS) {to reduce the frequency at which filter media needs to be changed, i.e, an
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ALARA improvement}
addition of a platform in the Fill-Aisle (ALARA and industrial safety improvement)
e addition of an in-line sampler (ALARA improvement)
e remote operating valves on the Fill-Aisle batch tank (ALARA improvement)
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5.3 Scaling Factors To determine if 10 CFR 61.55(a)(8), " Determination of Concentrations in Wastes," had been met, the inspector conducted interviews, reviewed procedures, and reviewed relevant licensee
documentation in this area.
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j Licensee procedure 351.47, " Radioactive Waste Sampling Program for Waste Classification,"
i Revision 4,5/4/92 delineated requirements concerning the development of scaling factors.
l The procedure directed a minimum sampling frequency of once per year for each waste stream. The procedure also directed quanerly tests (as a minimum) to verify scaling factors.
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Scaling factors were developed using the RADMAN computer code. This radwaste/
transportation computer code has been reviewed by the NRC and a topical report has been j
issued in validation ofits method. Co-60 was used as the base nuclide for scaling activation I
product nuclides, Cs-137 for fission product nuclides, and Ce-144 for transuranics.
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i Scaling factors have been developed for evaporator bottoms, DAW (using filter sludge data, a conservative approach), irradiated metals (developed by Waste Management Group),
solidified filter sludge, dewatered filter sludge, RWCU resin, condensate demineralizer resin, and ALPS resin.
Scaling factors have been developed for the following filters: ALPS yellow filter (using ALPS resin database), ALPS white one micron filter (ALPS resin database), ALPS bag filter (ALPS resin database), Low Oxidation-state Metal Ions (LOMI) filter (using RWCU resin database), UP-600/2S filter (using fuel pool resia database), condensate tank filter (using condensate demineralizer resin database), RWCU strainer (using RWCU resin database), and ALPS charcoal (using filter sludge database).
The New Radwaste Building has two resin tanks. ALPS, condensate, and fuel pool resins were sent to Spent Resin Tank "A". RWCU resins were sluiced to Spent Resin Tank "B".
Because multiple waste streams were routed to Spent Resin Tank "A", it was difficult to develop a representative scaling factor for shipments of radioactive waste originating from Tank "A". Additionally, there is no direct sampling capability off either Tank "A" or Tank
"B". However, the licensee compensated for this design limitation through use of a module included in the RADMAN computer code that ratios the volumes of the different resin waste streams in a liner. Thus, shipment-specific scaling factors were developed for resins from Spent Resin Tank "A".
Every liner, whether spent resin or filter sludge, was sampled to validate scaling factors.
In summary, the scaling factor program was well implemented. Despite the licensee's difficulties in developing representative scaling factors due to system design, good compensatory measures were taken to develop representative scaling factors. Good efforts were made to develop a large database of scaling factors for different waste types.
l 5.4 Filter Sludge Gas Generation The licensee has had problems concerning the generation of gas from dewatered filter sludge.
The licensee's actions associated with the following shipments of radioactive materials were reviewed.
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Date Activity Decription DOT Type OC-3011-91 7/17/91 31.8 Ci Dewatered faer media ISA OC-301092 7/27/92 57.2 Ci Dewatered reer nedia 13A > *A*
In the first case, the State of South Carolina Department of Health and Environmental Control (DHEC) provided a warning communication to the licensee. After the second problem was identified, the licensee committed to State authorities to process filter sludge through a cement solidification process until an adequate dewatering process was developed to prevent gas generation. In the second case, the State of South Carolina DHEC chose to
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exercise enforcement discretion and chose not to issue a violation, but informed the licensee that dewatered filter sludge was no longer an acceptable waste stream until the licensee was able to provide evidence that gas generation would not occur. At the time of the inspection, the licensee was continuing to solidify filter sludge though a cement solidification process (a waste form acceptable to the State of South Carolina).
Corrective actions included: generation of Deviation Report No.91-686, filter sludge was processed through cement solidification rather than in-liner dewatering, a biochemist was contracted, procedure 351.65 " Injection of Biocide into Batch Tank" was developed, biocides were evaluated, CNSI was contracted to assist in the development of a permanent solution, and CNSI set up a prototype system called Microbiological Total Organic Contml (MITOC).
A full scale MITOC system will be installed on a six-month trial basis, with a delivery date of August 1993. The system was projected to be fully operational in the last quaner of 1993. Progress in this area will be evaluated in a future inspection.
The gas generated was identified as methane by the licensee. Generation of sulfide gas was i
also indicated. It is important to note that, for both shipments, measurements taken at the Barnwell site demonstrated an amount of methane less than 63% of the lower explosive limit (LEL). The presence of sulfides was detected by odor; no measurements of the amount of sulfide gas were taken. 10 CFR 61.56(a)(5) requires that " Waste must not contain, or be capable of generating, quantities of toxic gases, vapors, or fumes harmful to persons j
transponing, handling, or disposing of the waste...." There is no OSHA Permissible Exposure I.evel (P.E.L.) for methane. The National Fire Protection Academy (NFPA) has established a health hazard classification of "1" for methane gas (a classification of "4" being the highest). A hazard classification level of "1" is defined as a material to which an
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materials that cause skin irritation without tissue destruction. An OSHA P.E.L. has been
established for sulfur dioxide (i.e. there is a concern with chemical toxicity). The inspector i
concluded that the safety significance of the gas generated from these two radioactive materials shipments was small due to low chemical toxicity of methane, the amount of gas l
generated was not large, and the shipping casks were breached in an open-air environment.
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i The inspector concluded that the licensee had adequately documented the events and had l
initiated extensive corrective actions. The significance of the events was minimal, as the l
amount of gas generated was small and of low toxicity. Based on the extensiveness of corrective actions, the limited safety significance of the events, the licensee's prior performance in the radwaste and transportation area, and the licensee commitment given to the State of South Carolina DHEC, the violations of 10 CFR 61.56(a)(5) are not being cited.
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5.5 Radwaste Volume Reduction The licensee has created a Radwaste Volume Reduction Committee which was comprised of bargaiiling unit and management personnel. A July 9,1993 edition of Power Points (the station newspaper) contained an article from this committee. In summary, the article stressed the importance of minimizing radioactive waste through better work planning and provided I
some general guidelines in these regards.
Licensee records indicated that the burial volume of radioactive waste from OCNGS was as follows.
Year Burimi Volume Year Burial vehune (thousands M)
(thousands F)
1992 12.7 1987
1991 19.1 1986 21.2 1990 11.9 1985 16 3 1989 15.6 1984 50 3 1988 8.,0 For the period from January 1,1993 to June 30,1993, licensee records indicated the following data pertaining to radioactive waste volume generated and radioactive waste volume buried.
Waste Type Generated (F)
Buried (M)
Fdter Sludge 2.049.6 2,049.6 Resins 1.560.9 1,560.9 Concentrates
0 High Radiation Wet Wastes 360.2 360.2 Other Wet Wastes 289.2 289.2 j
DAW (processed by super cornpaction and incineration)
14,401.2 764.4 Metals (decontaminated / recycled)
1.917.0 220.7 Asbestos 1,801.8 482.4 TOTAL 22,379.9 5,727.4 As noted in the above table,18,120 ft' of DAW and bulk radioactive material and radioactive waste was generated. The amount of DAW and bulk radioactive waste buried
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totaled 1,467.5 ft which represented a 90% volume reduction. The radioactive waste volume burial goal for 1993 was set at 13,900 ft' (as of June 30,1993 the licensee was at 41% of the goal).
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The inspector reviewed a February 26,1988 memorandum from the Radwaste Programs Manager to the Manager, Radwaste Operations. This memorandum detailed a four-phase DAW volume reduction study in which various volume reduction methods / processes were attempted in order to determine the best means of DAW volume reduction. In summary, the licensee concluded that the best means to reduce DAW volume was to process it off-site.
5.6 Implementation of the Radwaste Program Summary This program area was assessed as being well implemented.
6.0 Shipping of IAw-level Wastes for Disposal, and Transportation At the time of the inspection, generators in the State of New Jersey had radwaste burial privileges at Barnwell. The following shipment records were selected and reviewed.
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Identification No.
Date Activity Decription dot Type OC-1006-92 9/30/92 7.5 mci Boiler vesse.1 LSA*. RQ*
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OC-3012-93 6/24/93 10.9 Ci Solidified riher media LSA OC-3011-93 5/5/93 37.3 Ci solidified riher media LSA > *A*
OC-4009-93 7/8/93 28.4 Ci Spent resin and charcoal 13A OC-4008-93 4/1/93 29.5 Ci Spera resin and charcoal ISA > *A*
OC-4003-93 2/5/93 41.9 Ci RWCU demineralizer and condensate domineralizer resins LSA > *A*
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OC-5002-92 5/26/92 1.6 Ci Solidified evaporstor bottoms LSA OC-0108-93 6/18/93 15.7 mci Laundry to INS ISA OC-6002-93 6/23/93 1.8 Ci High radiation trash (DAW to SEG)
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- LSA lew Specific Acuvary RQ Reportabic Quantity These records were found complete. The licensee maintained copies of the consignee's licenses as required. The inspector verified that the licensee was a registered user of the shipping casks used for the shipments noted above. No discrepancies were noted.
At the time of the inspection, the licensee was evaluating the need for the requirement of dual sign offs on radioactive material shipments.
There was no opportunity to observe a shipment of radioactive material during the conduct of this inspection. NRC Inspection Report 50-219/93-06 detailed observations concerning a radioactive materials shipment.
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l 7.0 Exit Meeting The inspector met with licensee representatives at the end of the inspection, on June 11, 1993. The inspector reviewed the purpose and scope of the inspection and discussed the findings. The licensee stated that they would evaluate the findings.
At the exit meeting, the licensee emphasized the extent of corrective actions taken in regards to filter media gas generation problems.
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