IR 05000244/1978003
| ML17244A315 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 03/16/1978 |
| From: | Knapp P, Neely D, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17244A314 | List: |
| References | |
| 50-244-78-03, 50-244-78-3, NUDOCS 7901160107 | |
| Download: ML17244A315 (34) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Report No.
50-244/78-03 Region I Docket No.
50-244 License No.
DPR-18 Priority Category Licensee:
Rochester Gas and Electric Cor oration 89 East Avenue Rochester, New York 14649 Facility Name:
R. 'E.. Ginna Nuclear Power Plant Inspecti'on at:
Ontario, New York Inspection conducted:
January 30 - February 3,'ebruary 13-Inspectors:
rJ
.fw B~;~X:.,~
D.
R. Neely,, Radiation Specialist 17, 1978
.i-b
'a'te signed G.
P.
Y a', Radiation Specialist date signed date signed Approved by:
P. J.
Knapp, Chief, Radi %ion Support Section, FF8MS Branch date signed Ins ection Summar
Ins ection on Januar 30 - Februar 3 and Februar 13-17, 1978 (Re ort No.
0-
/
-03
~td:R f,df p
f f pdftf p t program and the rad waste systems including:
qualification and training of personnel; procedures; exposure control; instruments and equipment; surveys; posting and labeling; notification and reports; radioactive effluents; testing of contaminated air cleaning systems; tests of reactor water quality; solid radioactive waste disposal; tours of'he plant areas; and followup review of previously identified items.
Upon arrival at 7:00 p.m., January 30, 1978, areas where work was being conducted were examined to review radiological protection procedures and practices.
Several additional tours of radiological work areas were made during non-regular hours to observe selected activities.
inspection involved 146 inspector-hours on site by two NRC inspectors.
90> Zso qe-I Region I Form 12 (Rev. April 77)
ection Summary I
Results:
Of the thirteen areas inspected, no items of noncompliance were found in six areas; four-apparent items of noncompliance were found in one area (infraction - failure to control exposure within the limits of 10 CFR 20.101; deficiency - failure to maintain exposure records in an approved form specified by 10 CFR 20.401; infraction - failure to post and barricade high radiation areas as required by Technical Specification 6. 13. l.a; infraction -failure.to lock a high radiation area which the intensity of radiation is greater than 1000 mrem/hr as required by Technical Specification-6.13.l.b, Paragraph 5),
one apparent item of noncompliance was found in one area (infraction - failure to adhere to radiation protection procedure HP-6.2 and to administrative procedure A.l. 1 as required by Techhical Specification 6.11, Paragraph 4),
and one apparent item of noncompliance was found in each of the following ar eas:
(infraction - failure to maintain the training program required by Technical Specification 6.4, Paragraph 3); (infraction-failure to perform surveys necessary to comply with 10 CFR 20.101,
.408, and
.409, Paragraph 7); (infraction - failure to post a radiation area as required by 10 CFR 20.203.b, Paragraph 8);
( deficiency-failure to report the exposure received by an individual to the NRC as required by 10 CFR 20.408, Paragraph 9); (infraction - failure to deliver licensed material to a carrier in accordance with 10 CFR 71.3, Paragraph 13).
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DETAILS 1.
Persons Contacted
- ¹L. S.
Lang, Station Superintendent
- ¹B. A. Snow, Assistant Station Superintendent
¹E. L. DeMeritt, Supervisor, Chemistry and Health Physics
- ¹B. R. guinn, Supervisor, Health Physics
¹J.
F. Sweet, Technical Assistant D. Morrill, Training Coordinator The inspector also talked with and interviewed several other licensee employees including members of the health physics staff, reactor and auxiliary operators, and maintenance personnel.
- denotes those present at the management exit interview held on February 17, 1978.
¹denotes those present at the preliminary exit interview held on
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February 3, 1978.
2.
Action on Previous Ins ection Findin s (Open) Previously Identified Item (77-06-01):
In April 1977, beta surveys were not made in the primary side of the steam generators.
The licensee has revised procedure M-43.2 to include determination of the beta dose rate using thermoluminescent dosimeters and the steam generator manway insert.
The licensee has not established whether this technique produces a ratio that can be applied to the steam generator tube sheet beta dose rate.
(Open) Previously Identified Item (77-06-02):
In April 1977, several high radiation areas located in the containment were not posted or barricaded as required by Technical Specification 6.13.1.a.
During the plant tour on January 30, 1978, the inspector observed that an area (Pressurizer Cubicle) noted in the April 1977 inspection was again not posted or barricaded.
This item is addressed later in this repor (Closed) Previously Identified Item (77-06-03):
In April 1977, the containment equipment hatch was open and no control was being maintained at, that opening for radiological purposes.
The licensee has revised Procedure A-3, "Containment Access," to insure that a
Radiation Work Permit (RWP) or Special Work Permit (SWP) is required for all entries into the containment, and that a step off pad or other precautions are taken to control the spread of contamination when the equipment hatch is open.
(Open) Previously Identified Item (77-02-02):
In March 1977, a
high-radiation area near the reactor coolant filter handling area in the Auxiliary Building was not barricaded as required by Technical Specification 6. 13. l.a.
In the plant tour on January 30, 1978, the inspector observed a high radiation area located in the basement of, the containment near the Pressurizer Spray Tank that was not barricaded.
This item is addressed later in this report.
(Open) Previously Identified Item (77-Hg-01, 76-18-01):
In September 1976, the inspector established that an individual qualified in radiation protection procedures had not been present on back shifts as required by Technical Specification 6.2.2.e.
In December 1976, the licensee issued three procedures (A-1.2, Air Sampling Procedure; A-l.3, Smear Procedure; A-l.4, Radiation Survey Procedure)
to aid the person qualified in radiation protection procedures in performing those tasks that may be routinely required.
The inspectors attempted to verify through observation that the designated individual was qualified but the attempts were unsuccessful.
Arrangements will be made to make this verification at a subsequent inspection.
(Closed) Previously Identified Item (76-22-01):
In December 1976,-
the licensee did not follow all the requirements of Procedure SM75-'7.5 (incomplete survey data and incomplete review of surveys).
It was found that requirements for complete data and review had been discussed with those involved and more attention had been given to documentation of survey requirement.
ualification and Trainin The inspector noted that Technical Specification 6.4, "Training,"
states the following:
"A retraining and replacement training program for the facility staff shall be maintained under the direction of the Training Coordinator and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and Appendix A of 10 CFR Part 55. "
The inspector reviewed Procedure A-50.9, Revision 1, dated April 29, 1976, "Facili'ty Staff Training Program,"
Procedure A-50.9.2, Revision 0, dated March 20, 1976,
"Non-Licensed Staff Retraining Program,"
and Procedure A-l, Revision 9, dated June 20, 1977,
"Radiation Control Manual,"Section II, "Training," and determined that the combination of these procedures meet the requirements of Technical Specification 6.4 above.
The inspector reviewed the implementation and maintenance of the above training program.
The Training Coordinator stated to the inspector that he has no training or retraining program for members of the Health Physics Staff in particular, and for all Non-Licensed Staff in general.
The Training Coordinator stated that he has not complied with the specific requirements of procedures A-50.9 and A-50.9.2.
Since March 1976, of the 10 classroom lecture topics specified in A-50.9.2, only one has been presented.
That lecture was presented to nine individuals on October 22, 1976.
In licensee Audit 76-45:CA in December 1976, potential problems in the training program were identified.
Licensee health physics representatives stated on January 31, 1978, that no formal training program and no formal training records are maintained.
The inspector reviewed a record indicating that eight meetings had been held during 1977, in which technical matters were discussed.
These meetings included some training but did not meet the requirements set out in the training procedures because some specified topics were not covered and tests were not conducted.
On March 17, 1978, the Training Coordinator informed the inspector by telephone that no additional lecture topics required by A-50.9.2 had been presented to the non-licensed since February 17, 1978.
'his finding represents noncompliance with Technical Specification 6.4 (50-244/78-03-01).
4.
Procedures a
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b.
The inspector reviewed those procedures developed.pursuant to Technical Specification 6. 11, "Radiation Protection Program,"
and noted several topics which were not covered in the existing procedures.
These included:
lost film badge investigation and dose evaluation; resolution of discrepancies between simultaneously worn dosimeters; calibration of portable rad-iation instruments including alpha, beta, and neutron monitors; calibration of air samplers; and procedures covering operation of the laundry for contaminated protective clothing.
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"Radiation Protection Program,"
states that radiation control procedures shall be prepared and made available to all station personnel and other persons who may be subject to radiation exposure at the station and the program shall: be adhered to for all operations involving per-sonnel radiation exposure.
C (1)
Procedure HP-6.2, Revision 0, dated October 5, 1976,
"Posting of Contaminated and Airborne Areas," states, in step VI 1., that areas with smearable contamination greater, than 10,000 dpm/100cm2 shall be barricaded and posted as contaminated areas.
In step VI 2. the'procedure states that areas with surface contamination greater than 100,000 dpm/100cm2 shall be barricaded and posted with a
"Caution, Airborne Radioactivity" sign.
During a tour of the Auxiliary Building on February 2,
1978, the inspector observed the Non-Regenerative Heat Exchanger Cubicle and the Radwaste Storage Tank Cubicle were not posted as contaminated areas.
Licensee surveys indicated smearable contamination levels up to 12,000 dpm/100cm2 in'he Non-Regenerative Heat Exchanger Cubicle and 86,000 dpm/100cm2 in the Radwaste Storage Tank Cubicle.
The Waste Evaporator Room and the Waste Holdup Tank Room were not posted as "Caution, Airborne Radioactivity."
areas although surveys indicated smearable gontamination of 112,000 dpm/100cm~
and 132,000 dpm/100cm~,
respectively present in the room The inspector informed a licensee representative of this finding.
During a tour of the Auxiliary building on February 13, 1978, the inspector observed that all cubicles and rooms had either been decontaminated or correctly posted as required by HP-6.2.
(2)
Procedure A-l.l, Revision 3, dated March 28, 1977,
"Locked Radiation Areas," requires, in section 3.4, that when entry to a locked high radiation area is necessary the Shift Foreman will authorize the issuance of the appropriate key and all items on the Key Log will be com-pleted.
During a tour of the Auxiliary building on February 2,
1978, the inspector observed several individuals working in the Waste Evaporator Room, a normally locked high radiation area.
These individuals were working under Special Work Permit (SWP)
143, dated 3:00 p.m.,
February 2, 1978.
The SWP indicates that the work took place between 3:40 p.m.,
and 6:15 p.m.
On the following day the inspector reviewed the
"Locked Radiation Area" Key Log in the control room.
The Key Log did not have entries made to indicate the key to the Waste Evaporator Room had been issued to permit work in the area.
The inspector noted that key log entries are not merely historical records but play a substantial role in the radiation protection program.
Control room operators per'form operations which remotely change radiation con-ditions in key controlled areas and reference to this log is-one of the methods used to assure that no individuals are pr esent in such areas prior to initiating these changes.
This finding iepresents noncompliance with Technical Spec-ification 6.11 (50-244/78-03-02).
5. ~EC a
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In reviewing the licensee's exposure control program, the inspector noted that
CFR 20.101(a),'"Exposure of individuals to radiation in restricted areas,"
requires the licensee to limit the whole body exposure of an individual in a restricted area to one and one quarter rems per calendar quarter, except as provided in paragraph (b) of that section.
Paragraph (b)
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al 1ows a whole body exposure of 3 rems per cal endar quarter provided certain specified conditions are met.
One of these conditions 'is that the licensee determine the individual's accumulated occupational dose to the whole body on Form NRC-4, or on a clear and legible record containing all the information required in that form, in accordance with 10 CFR 20.102,
"Determination of accumulated dose."
The inspector observed from reviewing whole body exposure records and questioning licensee representatives that, although the provisions of 10 CFR 20. 101(b)(3) are sometimes followed, the licensee does not perform the determination of accumulated dose in all instances where individuals are permitted to receive whole body exposures of greater than 1250 mrem in any one calendar quarter.
A review of the records showed numerous instances where this was. being done; specific examples relating
,
to workers who terminated their work assignments at the licensee's facility after the initial Forms NRC-4 were completed and then were again employed at the facility during the second calendar quar ter of 1977, are noted below.
The Form NRC-4 had been completed 'sometime prior to January 1,
1977.
However;. the determination of accumulated dose was not made for the second quarter of 1977, in which the individuals exceeded 1250 mrem.
Individual Most Recent Determination
, of Accumulate Dose in Accord with 10 CFR 20.101(b 3)
" 1976 Whole Body Dose for April throu h
June 1977 mrem 2280 1972 1660 1975 1700 1975 1280 1972 1730 1970 1720 1974 1660 1972 1350 None on file 1560 1976 1750
This finding represents noncompliance with 10 CFR 20.101 in that individuals were exposed in excess of 1.25 rem per quarter (50-244/78-03-03).
The inspector noted in reviewing Procedure A-l, "Radiation Control Manual,"
"Summary of Plant Exposure Limits," the initial indoctrination program and quiz, and from discussions with licensee personnel that it appears that few individuals at this facility recognize 1250 mrem per calendar quarter as an exposure limit.
The inspector noted that
CFR 20.401,
"Records of surveys, radiation monitoring, and disposal," requires in section (a)
that each licensee maintain records showing the radiation exposure of all individuals for whom personnel monitoring is required on Form NRC-5 in accordance with the instructions contained on that Form or on a clear and legible record con-taining all the information required by Form NRC-5.
A licensee representative stated that the "Visitor Film Badge Record,"
Form 48-58, is used to record the radiation exposure of all non-station individuals for whom personnel monitoring is required and that the "Current Occupational Radiation Exposure,"
Form 49-27, is used to recor d the radiation ex-posure of all station individuals for whom personnel monitoring is required.
The inspector observed that the "Visitor Film Badge Record,"
Form 48-58, does not contain the information called for in items 5, 6, 7, 9, 10, 11, and 13 thru 18 of Form NRC-5.
The
"Current Occupational Radiation Exposure,"
Form 49-27, does not contain information called for in item 13 of Form NRC-5 and does not contain a statement of the method of monitoring called for in item 7 of Form NRC-5.
The inspector noted that the licensee's reliance on these forms and their failure to include all information called for in Form NRC-5 was a direct cause of the exposures in excess of regulatory limits discussed in section a above.
This finding represents noncompliance with 10 CFR 20.401 (50-244/78-03-04).
Licensee Technical Specification 6.13.1.a,
"High Radiation Area," requires that each high radiation area in which the intensity of radiation is 1000 mrem/hr or less be barricaded and conspicuously posted as a high radiation are During the tour of the containment building on January 30, 1978, the inspector observed two areas that did not meet the above requirement.
Each of these two high radiation areas have. existed for more than one hour.
One area, the Pressurizer Cubicle, had shield blocks removed to allow access.
An individual could proceed up the cubicle stairway, a few steps across the top, and then down the access ladder into a whole body radiation fiel'd of 175 mrem/hr without passing a barricade or seeing a high radiation sign.
The inspector found a high radiation sign behind pipes at the base of the Pressurizer Cubicle.
A licensee representative theorized that this sign may have fallen from the top of the cubicle stairway located about 20 feet above where the sign was found.
The second area, located in the basement of the containment near the Pressurizer Spray Tank, was properly posted and barricaded from two sides.
However, during the tour the in-spector and a licensee representative walked into an area with a whole body dose rate of 250 mrem/hr without encountering a
barricade or a high radiation sign to warn of this condition.
The licensee representative stated the barricade and sign must have been inadvertently removed during a recent cleanup effort.
These two instances represent an item of noncompliance with Technical Specification 6.13.l.a (50-244/78-03-053.
Licensee Technical Specification 6.13.1.b,
"High Radiation Area-," requires that each high radiation area in which the intensity of radiation is greater than 1000 mrem/hr shall be provided with locked doors to prevent unauthorized entry.
During the tour of'he containment building on January 30,
-1978; the inspector observed one high radiation area that had existed more than one hour did not meet the above requirement.
The inspectors were permitted to tour the containment building under SWP 112 dated January 30, 1978.
The inspector observed a guard posted at the containment personnel air lock.
This guard, a member of the Security Force, stated his function was to,record the movement of personnel to and from the containment.
The guard stated that he did not serve to provide positive control over entry into high radiation area In the basement of the containment the inspector observed a
high radiation sign and rope barricade near the Regenerative Heat Exchanger.
The sign contained additional information indicating that the dose rate in front of the Regenerative Heat Exchanger was 400 mrem/hr.
The inspector noted the area between the containment wall and the Regenerative Heat Exchanger could allow access to an individual.
The inspector and the licensee representative measured the radiation dose rate in this area to be 1500 mrem/hr in an area accessible to the whole body.
Locked door s were not provided to'r event un-authorized entry into this area.
This finding represents noncompliance with Technical Specifi-cation 6. 13. 1. b (50-244/78-03-06 ).
Instruments and E ui ment a.
The inspector reviewed the adequacy and supply of radiation monitoring instruments.
The licensee appears to have sufficient instrumentation necessary to perform the surveys to permit
. compliance with the regulations in 10 CFR 20..
The inspector spot-checked the calibration of ten portable radiation monitoring instruments and found all had been cali-brated within the period specified by the procedure.
The inspector noted that formal calibration procedures were not avai-lable for several instruments including lapel air samplers and'flow indicators used on continuous air monitors.
b.
The inspector selected 10 pocket dosimeters from the control point and reviewed the calibration history according to Procedure HP-7.5,
"Pocket Dosimeter/Accuracy and Leak Test."
The inspector reviewed the testing and calibration of effluent control instrumentation against the requirements of Technical Specification Table 4. 1-1'nd licensee instrumentation and control procedures.
All of the instruments listed below were calibrated and func-tionally checked according to procedure as required above, at the specified frequency during 1976 and 197 Instrument R-10A R-10B Function Containment Iodine Monitor Plant Vent Iodine Monitor R-11 Containment Air Particulate Monitor R-12 R-13 R-15 Containment Gas Monitor Plant Particulate Monitor Plant Gas Monitor Condenser Air Ejector Monitor R-16 R-17 R-18 R-19 R-20 R-21 Containment Fan Cooler Component Cooling Monitor Haste Disposal Monitor S/G Blowdown Monitor Spent Fuel Pit Monitor Retention Tank Monitor No items of noncompliance were identified in this area.
7.
~Serve s
The inspector noted
CFR 20.201(b),
"Surveys," requires each licensee make or cause to be made such evaluations as may be necessary for him to comply with the requirements of, 10 CFR 20.
In reviewing the "Visitor's Film Badge Records" the inspector noted that three individuals had entries of "lost badge" on their exposure records with no corresponding evaluation of dose received.
A review of the "Current Occupational Radiation Exposure" records revealed two instances with the same "lost badge" entries and no evaluation of the dose received.
Each case involved the loss of one of the monthly badges assigned during the quarter.
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The inspector notified the Supervisor, Chemistry and Health Physics of this finding.
The licensee made an evaluation of the dose re-ceived to each individual for the period of the last badge.
The licensee's findings are shown below.
Individual Dose for "Lost Badge" period durin second uarter 1977 140 mrem 70 mrem 400 mrem 65 mrem 150 mr em As a result of the above evaluation, the licensee stated corrected reports will be submitted pursuant to 10 CFR 20..408 and 409 to the Coomission and the individuals where appropriate.
This item represents noncompliance with 10 CFR 20.201(b)
in that evaluations necessary for compliance with 10 CFR 20.101,
CFR 20.408, and 409 were not made (50-244/78-03-07 ).
The inspector reviewed the inventory and leak check of.sealed sources held by the licensee in accordance with Technical Speci-fication 4.13, Technical Specification 6.10. 1(h),
and Procedures HP-8.2 and HP-8.4.
The sealed sources held by the licensee were inventoried and leak checked as required from January 1976 thru January 1978.
8.
Postin and Labelin a.
During tours of the controlled areas the inspectors noted that radioactive material storage appeared satisfactory in relation to control and housekeeping requirements; and radio-active material appeared to be adequately identified and labelled in accordance with 10 CFR 20.203(f).
b.
The inspector noted that
CFR 20.203,
"Caution signs, labels, signals, and controls," requires in (b) that each. radiation area be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words,
"Caution, Radiation Area."
An inspector surveyed the area. surrounding the Upper Radwaste Storage Area on January 31, 1978.
The inspector measured a
radiation field of 6 mrem/hr outside the fence.
A review of licensee surveys indicated this condition had existed for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
This radiation area was not posted with a sign bearing the radiation caution symbol and the words "Caution, Radiation Area."
The inspector noted that an individual could enter the radiation area without seeing any posting which identified the area as required by 10 CFR 20.203(b).
The inspector informed a licensee representative of this finding.
Subsequently, a box of radioactive material wh'ich was inside the Upper Radwaste Storage Area and which had been placed near the fence, was moved to a position fur ther from the fence.
This dec~eased the dose rate at the fence to.3 mrem/hr.
This item represents noncompliance with 10 CFR 20.203(b)
(50-244/78-03-08).
9.
Notification and Re orts The inspector noted that
CFR 20.408,
"Reports of personnel exposui e on termination 'of employment of work," requires that when an individual assigned to work in the licensee's facility terminates his work assignment, the'licensee must furnish a report of the individual's exposure to radiation and radioactive materials to the Director of Inspection and Enforcement within 30 days after the exposure has been determined or 90 days of work, whichever is ear lier.
In reviewing the "Visitor's Exposure Records" the inspector noted that two individuals for whom personnel monitoring had been required, terminated their work assignments in October 1977, and the record did not indicate that the report had been furnished to the Director of Inspection and Enforcemen.
On February 2, 1978, the Office of Management Information and Program Control, Operating Data Branch reported that reports of exposure for these two individuals covering their assignment at the licensee's facility during 1977 had not been received.
This finding represents noncompliance with 10 CFR 20.408 (50-244/
78-03-09).
The licensee submitted the required reports on February 8, 1978.
Radioactive Waste Effluent Releases The inspector reviewed records of the liquid radioactive releases made in 1976 and 1977.
The "Liquid Waste Release Forms" were re-viewed for these releases and were verified to be in accordance with the requirements
'set forth in Technical Specification 3.9.1.
- The inspector reviewed the "Semi-'Annual Report of Radioactive Effluents" made pursuant to Technical Specification 6.9.3.b, for the-period of 1976 and 1977.
One anomaly in the data for the
"Maximum Concentration Released" of radioactive liquid in January 1976 was discovered.
The report lists this maximum concentration as 8.16 x 10-8 uCi/cc while raw data indicates that on January ll, 1976 the maximum concentration was 1.45 x 10-7 uCi/ c.
The inspector informed the licensee representative, who stated, tie matter would be reviewed and a correction submitted if applicable.
Gaseous effluents for 1976 and 1977 were reviewed by the inspector for compliance with the requirements of Technical Specification 3.9.2.
Ho items of noncompliance were identified in this area.
Reactor Coolant Chemistr and Activit Th'e inspector reviewed the licensee's surveillance tests results pertaining to reactor coolant activity and chemistry against the requirements of Technical Specification 3.1.4,
"Maximum Coolant Activity," and Technical Specification 3.1.6,
"Maximum Reactor.
Coolant Oxygen, Fluoride, and Chloride Concentration,"
and Table 4.1-2,
"Minimum Frequencies for Equipment and Sampling."
The surveillance tests were reviewed for the period of 1976 and 1977.
Specifically, tests made in November and December 1976, March and April 1977, and January and February 1978, were reviewed in detail.
12.
No items of noncompliance were identified in this area.
Containment Air Cleanin The inspector reviewed the licensee's surveillance test results of High Efficiency Particulate Air (HEPA) and iodine removal (charcoal)
filters against the equipment test requirements of Technical Specifi-cation 3.3.2, Technical Specification 4. 11, and Technical Specifica-tion 4.5.2.3.
'he inspector noted that the required tests had been performed at the specified frequency and met the acceptable criteria required by the above Technical Specifications.
No items of noncompliance were identified in this area.
Solid Radioactive Waste The inspector reviewed the licensee's program pertaining to the shipment of radioactive waste against the requirements of 10 CFR 71.
The inspector noted
CFR 71.3 states:
"No licensee subject to the regulations in this part shall (a) deliver any licensed material to a carrier for transport or (b) transport licensed material except as authorized in a general license or specific license issued by the Commission or as exempted in this part."
In reviewing "Radioactive Materials Shipment Records" the inspector noted that on April 13, 1977, the licensee delivered to a carrier (Homes Transportation)
approximately 60 cubic feet of spent resins with an aggregate radioactivity of 460 Ci contained in a Chem'-
Nuclear Systems, Inc. transport cask and liner CNS 6-80.
Of the activity present, about 453 Ci were attributed to the following radionuclides:
'Co60, Cs134, Cs"37.
These radionuclides are of Transport Group II The inspector noted that aggregate radioactivity in excess of 200 Ci of Transport Group III radionuclides is defined as a "Large guantity" in 10 CFR 71.4(f).
A general license is issued under
CFR 71.12 to persons holding a
general or specific license to deliver "Large guantities" of licensed material to a carrier for tr'anspor t in a container specified in Department of Transportation regulation
CFR 173.395(c)
or, in a package for which a license, certificate of compliance, or other approval has been issued by the Commission's Director of Nuclear Material Safety and Safeguards.
The inspector noted that the 460 Ci shipment involved the delivery of a Large guantity of Transport Group III radionuclides to a carrier on April 13, 1977, in a 00T 7A, Type A container, a con-tainer which does not meet the requirements of 49 CFR 173.395(c).
The inspector also learned that the container was not certified or approved by the Director of Nuclear Material Safety and Safeguards.
Since this container did not meet the requirements of 10 CFR 71.12, the licensee was not authorized by the general license of this section to deliver this licensed material to a carrier for transport.
The inspector also determined that no exemption applied to the shipment.
This finding represents noncompliance with 10 CFR 71.3 (50-244/78-03-10).
In reviewing the methods used by the licensee to calculate the activity present in solid radioactive waste shipments, it is not clear how soft gamma and pure betta emitting radionuclides are considered in these quantative assessments.
The inspector noted that these radionuclides must be considered in determining compliance with the requirements of 10 CFR 71.
Exit Interview The inspector met with the licensee representatives'(denoted in Paragraph 1) at the conclusion of the inspection on February 17, 1978.
The inspector summarized the scope and findings of the in-spection as presented in this report.