IR 05000225/2003001
| ML20205A583 | |
| Person / Time | |
|---|---|
| Site: | Rensselaer Polytechnic Institute, Trojan File:Portland General Electric icon.png |
| Issue date: | 04/05/1985 |
| From: | Grayson M, North H, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20205A572 | List: |
| References | |
| 50-344-85-09, 50-344-85-9, NUDOCS 8504250553 | |
| Download: ML20205A583 (11) | |
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U.~S. NUCLEAR REGULATORY COMMISSION
' REGION V Report No. - 50-344/85-09 Docket No.
50-344 License.No. NPF-1 Licensee: Portland General Electric Company 122 S.W. Salmon Street Portland, Oregon 97204 Facility Name: Trojan Nuclear Plant Inspection at: Rainier and Portland, Oregon Inspection conducted: February 25-March 1, 1985 Inspectors:
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M. Grayson~, RadiationiSpecialist-Date Signed
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a M %uNN dhs H. J. North, Senior Jtadiatfon Specialist Date Signed-Approved by: _6 h _4_b -
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G. P. (Ytyias, Chief DIte' Signed FacilitTes Radiological Protection Section Summary Inspection of February 25 - March 1, 1985 (Report No. 50-344/85-09)
Areas Inspected: Routine unannounced inspection of licensee action on previous inspection findings; solid, liquid and gaseous waste management; facility tour; and followup on IE Information Notices.
The inspection involved 73 hours8.449074e-4 days <br />0.0203 hours <br />1.207011e-4 weeks <br />2.77765e-5 months <br /> on site by two NRC inspectors.
Results:
No violations or deviations were identified in the six areas examined.
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OETAILS 1.
Persons Contacted
- W. S. Orser, Trojan General Manager A. Cohlmeyer, Engineering Supervisor J. Dunlop, Corporate Quality Assurance (QA) Engineering Branch Manager
- N. Dyer, Supervisory Health Physicist, NSRD
- F. Gaidos, Manager, QA Nuclear Projects L. Larson, Assistant Radiation Protection Supervisor
- T. Meek, Radiation Protection Supervisor
- G. Rich, Chemistry Supervisor Acting Manager Technical Services
- R. Schmitt, Manager, Operations and Maintenance M. Snook, Senior QA Inspector G. Zielinski, Effluent Analyst Non Licensee
- H.Moomey, ODOE Resident
- S. Richards, NRC Senior Resident
- Denotes attendance at the exit interview on March 1, 1985.
In addition the inspectors interviewed other members of the licensee's staff.
2.
Licensee Action on Previous Inspection Findings (0 pen) (50-344/83-20-01) Concerns related to the environmental qualification of the containment high range monitors (NUREG-0737, item II.F.1. Attachment 3) were discussed. The licensee stated that based on a report recently received from Indian Point the required fix may be limited to sealing the cable ends. Resolution of the acceptability of the proposed corrective action is e::pected in a short time.
(Closed) (50-344/83-28-01) The auxiliary-fuel handling building ventilation system deficiencies had been described in RDC-81-087. A contract HV engineer had performed some evaluation and identified the need for additional fans and dampers. Field construction is scheduled to begin in September and to be complete by the end of 1985.
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(0 pen) 50-344/83-33-01 The Kurz flow controlled sampling system had been i
installed and functional tests completed. Operational testing is awaiting PRB approval of the test procedure. The licensee estimates that
testing will require 6 to 12 months to assure that performance under all operating conditions will be evaluated.
(0 pen) (50-344/85-01-01) Licensee action to address technician concerns was discussed at all levels of plant management and with two technicians.
The plant General Manager held an initial meeting with the technicians since the inspection documented in Inspection Report No. 50-344/85-01.
At the time of this inspection it appeared that there had been some
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alleviation of the level of discontent and a positive attitude with respect to future discussions was observed.
(Closed) (50-344/85-01-02) Corporate QA audits GAI-104T-84M, Radiation Protection /Special Nuclear and Source Material; Radioactive Material Packaging and Transport; Radioactive Waste Management, audit period April 23-27, 1984 and GAI-036-84M, Training Activities at Trojan, audit period January 23-27, 1985, were examined. The first audit identified two Loops (1507 and 1508) relating to the documentation of general employee training (GET), radiation protection (RP) training, and training of utility workers. The second audit addressed the use of two RP technicians with less that 2 years experience, a review of GET content, training department personnel qualifications, training in RP and chemistry, verification of qualification of RP and chemistry technicians, and new training programs TP-5-2 and TP-5-5.
These new training programs were too new to evaluate, as such technicans were evaluated against previous criteria.
No violations or deviations were identified.
3.
Solid Waste A.
Audits and Appraisa_1s Reports of audits by the corporate QA department and onsite QA were reviewed. Corporate audits GAI-118T-83, Radiation Protection /Special Nuclear and Source Material; Radioactive Material Packaging and Transport; Radioactive Waste hanagement, conducted April-23-27, 1984, verified seven radwaste shipping packages against druh listings; reviewed documentation of previous 6 months of spent resin shipments; verified dewatering; verified completion of RP form 80 Checklist of Radioactive Material Shipment Requirments; verified Chem Nuclear as a approved supplier of solidification service; incorporation of solidification procedure into plant operating manual; and verified incorporation of 10CFR 20.311 and 10CFR 61.55,56 and 57 into Radiation Protection Manual Procedures (RPMP-1,4 and 5).
On site QA Audit No. 84-07 Solid Radioactive Waste Management, conducted October 1-November 29, 1984, involved 200 man hours. The audit addressed conformance of procedures to regulatory requirements, observation of packaging of materials for three shipments, examination of packaging materials and storage of 17 H steel drums. The audit resulted in the identification of 10 findings. Seven of the findings were documented in five Quality Notices (QN) and two Nonconformance Reports (NCR). Both NCR's and two of the QN's were closed at the time of the inspection. One finding against the Nuclear QA Program, Chapter 2 Appendix B, QA and Administrative Controls for Packaging Radioactive Material for Transport, for failure to incorporate all the program elements required by 10CFR 71 was to be communicated to Nuclear QA Department.
No violations or deviations were identifie m.
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B.
Changes
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No significant changes have occurred.
RPMP,' Determination of Radioactive Material Shipping and Waste Classification,.was being-revised-by the corporate radiological engineering staff. The use of High Integrity Containers (HIC)_for disposal of dewatered resins was being evaluated by the licensee.
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No violations or deviations were -identifi-4.
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Processing and Storage The licensee has used the services of a contra'ctor for onsite
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solidfication of wastes. The contractor prepared Process Control Program (PCP) has been used following review and approval as a plant procedure by_the PRB. Discussion with licensee personnel and examination of records established that quantity and isotopic composition were calculated based on analysis of samples taken of resin from clean up' filters. Good experience was reported concerning the use of contractor supplied solidification systems. Discussion with licensee personnel established that prior to use the system is hydrostatically tested to confirm it's leak tightness. The hydrostatic test requirement is incorporated into the resin transfer procedure. The. inspector examined licensee procedures:
RPMP-2; Radioactive Waste Drumming, RPMP-2-1 Radwaste Drumming-Absorbed Liquids,
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.RPMP-2-2' Determination of Liquid / Absorbent Ratio, j
i RPMP-3 Dewater Procedures for Resin Liners, j
RPMP-4 Determination Radioact.ive Material Shipping and Waste Classification, RPMP-5 Sampling Program to Determine Isotopic Concentration and Scaling Factors for Classification of Low Level Solid Radwaste, RPMP-6-Handling Procedure for'the 30-Gallon DOT 6 M Type B Shipping Drum, Serial Number Trojan-1, l
RPMP-8 Handling Procedure For The OH-142' Type B Shipping Cask.
No violations or deviations were identified.
D.
Disposal of Low Level Fastes The inspector reviewed _ procedure RPMP-1 Radioactive Material Receipt and Shipment;;and the licensees records pertaining to solid waste shipments during the periods of January 1 through May 16 and-July 20 through December-18, 1984. The inspector verified that the
' licensee classifies waste pursuant to'10 CFR 61.55; verifies that i
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waste meets the characteristics of 10 CFR 61.56; and prepares a waste manifest and marks-packages pursuant,to 10 CFR 20.311.- None of the licensee's-shipments have been lost. The licensee's QA program addressed the requirements of 10.CrR 61. Audit reports are
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provided to -the Trojan' General Manager and-the Radiation Protection Supervisor.
No violations or deviations were identified.
4.
Gaseous Waste System A.
' Audits And Appraisals-Audits related to waste management are addressed in Section 3. A.
No violations or deviations were identified.
B.
Changes The licensee stated that no significant changes had been made in the-gaseous waste systems or procedures. The Kurz sampling system, to be used for line loss evaluations had been installed and tested, see
- Section 2 item 50-344/83-33-01. Chemistry Manual Procedures (CMP)
including emergency sampling procedures were reviewed to assure-
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consistency with the revised Technical Specifications.
Procedures examined included:
CMP-37 Planned / Unplanned Releases-Liquid / Gaseous; CMP-40 Post-Accident Sampling and Analysis of Reactor Coolant and Containment Atmosphere;-
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CMP-42 Sampling ~of Containment Atmosphere Using the Post-
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Accident Sampling System; CMP-55 Sampling of PERM-1, 2 and 6 Using the Accident Range -
-Sampling System; and CMP-56 PERM Iodine Cartridge / Particulate Filter Change Out and PERM Iodine Channel Collection / Detector Efficiency Check;
.There have been no changes to shielding, accessibility, or the ability to. collect post accident samples. The licensee plans to add a second chiller to the PERM-6 condenser air ejector sample line.
With a single chiller the' system can operate properly for a full week with off gas flows in the range of 7-7.5 cfm. The second chiller will permit ~ operation at flows of up to 100 cfm.
No violtiion or deviations were identifie _
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C.
Effluents The Annual Report for the Trojan Nuclear Plant, submitted under a-cover letter dated March 1, 1985, was reviewed. The_ report included the data for all of-1984. No obvious mistakes, anomalous measurements, omission or trends were noted.
Selected gaseous waste discharge permits for Waste Gas Decay Tanks (WGDT)L(G-01-84, G-25-84, G-38-84, G-40-84, G-52-84, G-01-85 G-02-85, G-04-85 and G-05-85) and Containment Discharge Permits (G-26-84 and G-27-84) were examined. In addition the Gaseous Radioactive Discharge Report cumulative 1985 records for WGDT, Auxiliary Building Vent Exhaust, Condenser Air Ejector Exhaust and
. Containment Purge Exhaust were examined.
The licensee had increased the WGDT decay time by primary system degassing through use of a reviewed and approved 10 CFR 50.59 design change which allows the pressurizer vapor space to be vented to the CVCS system._In addition cover gas pressure had been raised from 2 to 8 psi, effectively increasing the gas storage capacity. Departmental ALARA goals have been established for effluent releases. For noble
. gases, the goals were 875 Ci in 1983 and 750 Ci in 1984 and 1985.
The 1993 goal was achieved. The 1984 goal was exceeded, 839 C1 (112% of the ALARA goal). The licensee stated that the principal source of gaseous releases was_due to containment pressure equalization. The containment pressure has been increasing at a rate of 0.2-0.3 psi /8 hour shift. Possible soucces of air leakage have been investigated on several occasions and small leaks have been corrected. The licensee is continuing efforts to reduce releases via this pathway. With respect to iodines and particulates the 1984 ALARA goal was 3.00 E-2 C1.
The 1984 release of 4.86 E-3 Ci was 16% of the goal. The estimate annual doses due to liquid and gaseous effluents released during 1984 were less than the design
~ bjectives identified in 10 CFR 50 Appendix 1.
o No.. Violations or deviations were identifed.
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Instrumentation Maintenance and calibration of process and effluent monitors were discussed with I & C department personnel. Instruments are included in the master list of scheduled maintenance. Maintenance procedures address;' process, area, post-accident, containment high range and.
main steam line monitors. Calibration records for 1984 from monitors: PRM-1, Containment Purge Exhaust; PRM-2, Auxiliary Building Exhaust; PRM-4, Waste Gas Discharge and PRM-6, Condensor Air Ejector, were examined.
No violations or deviations were identified.
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Air Cleaning Systems Testing of air cleaning systems was discussed with the cognizant
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engineer. Tests are performed pursuant to Periodic Engineering i
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. Test (PET)-10-1, Air Purification and Cleanup Systems. HEPA filters
have been tested in place, on site, by Nuclear Consulting Services (NUCON), Columbus, OH.
Small charcoal banks are emptied and recharged with new charcoal while samples.are withdrawn for large
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char. coal absorption banks. Filter tests are performed on all systems including'those not identified in the Technical Specifications. _ Test results were examined for: CB-1 A.and B, Control. Room Emergency Ventilation; AB-4 A and B,. Spent Fuel Pool
' Ventilation Exhaust; CS-9, Containment Hydrogen Exhause and AB-3, Fuel:and Auxiliary Building Exhaust, no discrepancies were identified.
5 ~. Liquid and Liquid Wastes A. -
Changes
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i No significant changes have occurred with respect to equipment or procedures associated with control and processing of liquid radioactive wastes. The licensee has made an number of minor
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procedural changes in discharge permits and reports to address the requirements associated with implementation of Radiological Environmental Technical Specifications (RETS).. These changes typicallyjincluded calculation of radioiodine particulate dose
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factor (Ri) and inclusion'Ri in total plant discharges.
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No violations or deviations were identified.-
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B.
Effluents
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Inspection-emphasis was directed towards review of the licensee's Quarterly Liquid Release Reports which is updated weekly and_the-
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.' monthly. Liquid Waste' Composite Logs. These reports were'found to-(
meet or exceed the-RETS 4.11.13.1 surveillance requirement that-l cumulative liquid activity releases excluding tritium and dissolved ~
t gases to unrestricted areas"are determined at least once every 31 g
days. The review of these reports did not identify any instances i
where the licensee had exceeded the radioactive material concentration release limits in 10 CFR 20.106. The licensee has
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established ALARA liquid radioactive release limits of.9Ci during
. 1984 and.6Ci during 1985. During 1984 the licensee released 39% of
' the ALARA goal. The licensee documents liquid releases,in monthly
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chemistry reports which include monthly, quarterly, yearly releases and % of yearly ALARA release limits. This report is distributed ~to
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plant and corporate management.-
No violations or deviations were identified.
C.
Instrumentation
The inspector reviewed licensee records associated with the two main p,
liquid effluent release monitors, PRM #9 the Liquid Waste Discharge
Monitor and PRM #10 the Steam Generator Blowdown monitor. The
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inspector reviewed licensee records to demonstrate compliance with
.the technical specification' requirement 4.3.3.10.2' that each
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radioactive liquid effluent monitoring instrumentation channel shall be demonstrated operable by performance of the channel check, source check, channel calibration and channel functional test operations at frequencies shown in Table 4.3-8.
Based on this review the following observations were made: Channel and source check information is part of the operability check contained on form C-241 the Radioactive Liquid Discharge Permit, approximately 60 discharge permits during 1984 and 1985 were reviewed, no instances were noted where daily operability checks were not performed prior to a radioactive liquid release. Channel functional tests are required by Technical Specifications to be performed once every 92 days.
Records of channel functional tests for 1984 indicated that the licensee is performing channel functional test monthly.
Channel calibration is required by Technical Specifications to be performed once every 92 days. Review of calibration records indicate that the licensee is performing effluent monitor calibrations quarterly.
During a walk through of the facility the radioactive liquid effluent monitors PRM #9, and PRM #10 were observed to be operable with ALARM and trip setpoints identified on control room readouts.
Licensee procedure (CMP-7) Liquid Radwaste Discharge Permit Preparation Procedure was identified as the procedure utilized to establish ALARM setpoints.
The inspector discussed the operability and maintenance history of effluent radiation monitors including PRM #9 and PRM #10 with licensee representatives.
Licensee representatives indicated that maintaining radiation monitor operability had become time intensive.
Concerns discussed included design problems, design changes without corresponding manual changes, and spare parts not being exact replacements.
No violations or deviations were identified.
D.
Primary and Secondary System Chemistry Control Licensee compliance with technical specification requirements for sampling and analysis of primary and secondary systems was evaluated. Technical specification surveillance requirement 4.4.7 requires that "The reactor coolant system chemistry shall be determined to be within the limits of analysis of those parameters at the frequencies specified in Table 4.4-3.
Table 4.4-3 requires that dissolved oxygen, chloride, and flouride be evaluated at least three times per 7 days. Review of licensee records indicate that these parameters are being evaluated four times a week which exceeds the technical specification requirement. Technical Specification 3.4.8 requires that "The specific activity of the primary coolant shall be limited to 5,1.0 uCi/ gram Dose Equivualant I-131 concentration (DEI) and 1100/E uCi gram gross activity.
Surveillance requirement 4.4.8 requires that the specific activity of the primary coolant shall be determined to be within the limits by performance of the sampling and analysis program in Table 4.4-4.
Table 4.4-4 regiures that a gross activity determination be made 3 times per 7 days and the Dose Equivalent Iodine conce'ntration be evaluated once every 14 days. Review of licensee records indicated
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that the licenseeLeeets or: exceeds these requirements. Dose
' Equivalent Iodine'at the time of the inspection was running.
approximately 25% of the-technical specification. limit.- Licensee Technical-Specification 3.7.1.5 requires that "The specific activity.
of the~ secondary ' coolant system shall be i,0.10uci/ gram Dose
. Equivalent I-131. Surveillance' requirement 4.7.1.5 requires that the. specific activity of the secondary coolant system shall be determined.to be within the limit by performance of the sampling and analysis program of Table 14.7-2.
Table 4.7-2 requires that a gross activity determination be made 3 times per.7 days and that Dose.
Equivalent-I-131 concentration be made once every'31 days if DEI is
. larger then 10% of the limit and once every 6 months if is DEI less than 10% of the limit. Licensee records reviewed were found to meet or exceed the technical specification sampling requirements.
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instances were identified.where' primary or secondary system; concentrations exceeded technical specification limits. The
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licensee's chemistry manual provides the technical specification
- sampling frequency requirement in parentheses next to the frequency of sampling currently in use. In all cases reviewed, the licensee
.was,taking and evaluating samples more frequently than required by technical specifications.
No violations or deviations were identified.
'E.
- Audits
.The inspector contacted site QA/QC reprensetative to determine what
. site and corporate QA audits had been performed in the area of liquid radioactive wastes management. One site audit 84-01 on Radwaste Control was conducted in January 1984. No problems were
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. identified as a result of this audit. No corporate QA.?udits of this specific area of the program were. identified as having taken place since 1982. No problems were identified with the audits conducted todate of liquid radioactive effluent controls.
Fo violations or deviations were identified.
6..
Facility Tour Two licensee activities were reviewed during a walk through of the licensee's facility. -These activities included the transfer of radioactive waste to a high integrity container (HIC) prior to
transport offsite for burial and the cleaning of the auxiliary
. building drain sump. During the transfer operation the inspector observed that'the individual fishing the slings from inside the shielded container and sweeping.the sealing surface of the HIC only wore dosimetry on his chest. The inspector observed that the
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location of the individual with respect to the open cask during the sweeping operation was.such that the lens of the eye could have received a higher dose that would be indicated on the individuals chest dosimetry. The inspector also noted that this individual's hands would have received considerably more dose than would have been indicated on his chest dosimetry. Although not clearly a violation of regulatory requirements, the inspectors commented that
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w since the loading.of the HIC was essentially a new operation it.
appeared that it was non-conservative not to provide additional dosimetry to evaluate the whole body dose (to the lens of the eyes)
and to directly measure extremity dose.
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The second operation observed during a. tour of the licensee's facilities was the cleaning, by contract personnel, of the auxiliary building drain sump. The following observations were made:
1.
The Radiological Work Permit (RWP) for the sump cleaning did not require a set of plastics over the cloth coveralls. Yet discussions with contractor personnel indicate they routinely wear them for this type of tank pumping and~ cleaning operation where open tanks / containers of radioactive liquids are present.
It was noted that workers wore plastic suits although not called for by the RWP.
2.
That hand squeezing of these highly radioactive filters to reduce the liquid content was providing exposures to the hands of the contract work personnel that could be avoided. The inspector also discussed whether some of the-four contractor personnel in the immediate vicinity of the pumping operation could have taken. additional measures to keep exposures as low as reasonably achievable (ALARA).
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10 CFR 20.203(b) states that "Each radiation area shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the.words " Caution Radiation Area".
10CFR 20.203 defines a radiation area as "...any area, accessible to personnel, in which there exists radiation, originating in whole or in part within licensed material, at such levels that a major portion of.the body 1could receive in any one hour a dose in excess of 5 millirem....".
During the observance of'
licensee auxiliary building waste sump cleaning operations the inspector asked a licensee. radiation monitoring technician to measure the radiation dose rate at a rope barricade approximatley two to three feet from the sump pumping operation. The licensee measured a dose rate of 15 mr/ hour at the rope, three times the level requiring posting. When this was brought to the licensee's attention the licensee posted the rope barricade as a high radiation area and posted the door to the work area as a radiation area with a 15 mr/ hour general area radiation dose rate. The licensee stopped the pumping operation while the NRC inspectors were onsite to review radiological controls and to evaluate whether controls were I
consistent with the licensee's ALARA program. 10 CFR 20.204(c)
j provides an exception to the posting requirements of 10 CFR
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20.203(b) for rooms or other areas containing radioactive
. materials for periods of less that 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provided that the
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area is under the licensee's control and that an individual is present to take precautions to prevent radiation exposures in
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excess of the limits. Since a radiation protection technician was present during the pumping operations and the licensee posted the area and stopped pumping operations in a period less
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'than'8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after initiation, no further regulatory action is being considered.
No violations or deviations were identified.
7.
Followup on IE Information Notices Receipt, review for applicability-and initiation or completion of appropriate action with respect to IE Information Notices 84-75, 84-82, 84-81, 84-94 and 85-06 was verified.
No violations or deviations were identified.
8.
Exit Interview The results of this inspection were discussed with the licensee representatives denoted in Section 1 at the conclusion of the inspection.
The licensee was_iuformed that no significant matters were identitied in connection with the inspection of the liquid, gaseous and solid waste programs.
The matters addrersed in report Section 2 were specifically identified.
The inspectors commented on what appeared to be a nonconservative approach to several radiation protection matters associated with the HIC cask' loading.and sump cleaning operation discussed in report Section 6.