IR 05000250/1989035
| ML17347B311 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/29/1989 |
| From: | Gloersen W, Kuzo G, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17347B310 | List: |
| References | |
| 50-250-89-35, 50-251-89-35, IEIN-86-063, IEIN-86-63, IEIN-88-079, IEIN-88-100, IEIN-88-101, IEIN-88-79, IEIN-89-013, IEIN-89-027, IEIN-89-047, IEIN-89-13, IEIN-89-27, IEIN-89-47, NUDOCS 8909080142 | |
| Download: ML17347B311 (39) | |
Text
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O UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 AUB 89 t999 Report Nos.: 50-250/89-35 and 50-251/89-35 Licensee:
Florida Power and Light Company 9250 West Flagler Street Niami, FL.
33102 Docket Nos.:
50-250 and 50-251 License Nos.:
DPR-31 and DPR-41-Facility Name:
Turkey Point Units 3 and
Inspection Conducted:
July Inspectors:
I U+
G..
Kuz g~(i.l~~
W; B. Gloer 24-28, 1989'rt (~p~
Date cygne 6'7S 8(t Da e
igned Approved by:
otter, C se Facilities Radiation Protection Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards SUYINARY fsJ'
Signed Scope:
This routine, unannounced inspection of the licensee's radiation protection program involved review of organization and management controls, employee training and qualifications, external and internal exposure monitorina and controls, radioactive material and contamination control, ALARA programs, solid wastes, transportation, and inspector followup of NRC Information Notices (INs)
and previously identified inspector followup and unresolved items.
Results:
Strengths in radiation protection areas were noted for improved staffing,
.
increased onsite Florida Power and Light Company (FPSL Co.) technicians and techriical personnel; radiation protection equipment upgrades; reduction of-stored radioactive wastes; and prompt corrective actions in response to internal audits.
Weaknesses were identified in poor posting of areas containing potentially contaminated materials; lack of root cause analyses in audits; high percentage of controlled area maintained as contaminated; and numerous full-power containment entries by personnel.
In addition, concerns-were noted for the shipping and transportation areas as identified by several non-cited violations (NCVs) reviewed and/or identified durina this inspection.
r rjO7O;~l ) Jr~2 89082 O~sij i.sQ2.)V II
The following non-cited violations were identified:
Failure to use High Integrity Containers (HICs)
as authorized in the Process Control Program.
(Not ci'ted as discussed in Paragraph 7.a.)
Failure to report correct total radioactivity on waste shipping manifests for spent resin shipments.
(Not cited as discussed in Paragraph 7.a.)
Failure to meet the 85 percent minimum fi11 criterion for the containers utilized in three waste shipments.
(Not cited as discussed in Paragraph 7.a.)
Failure ( I) to include on the waste shipment manifest the telephone number of the person generating the waste (NCV due to issue being corrected prior to end of inspection Paragraph 7.b);
and (2) to classify properly, radioactive materials shipped to a waste processer as waste on a shipment manifest (Identified by the State of South Carolina, but not cited due to issue being corrected by licensee prior to NRC onsite inspection, Paragraph 7.b.)
REPORT DETAILS 1.
Persons Contacted Licensee Employees J. Anderson, Regulatory Compliance Supervisor, Quality Assurance (QA)
- J. Arias, Jr. Technical Assistant
- J. Balaguero, Assistant Technical Department'upervisor J.
Brooks, Group Surveillance Supervisor
Ferguson, Health Physics Administrative Supervisor
"D. Hall, Health Physics Supervisor N. Jimenez, Senior Health Physics Engineer=
- E. Lyons, Regulatory Compliance Group Supervisor, Acting
- R. Nende, Operations Supervisor N. Namish, HP Engineer
- L. Pearce, Operations Superintendent
- K. Rowe, Radwaste Supervisor'G.
Smith, Services Nanager
- G. Warriner, Quality Control Supervisor
- N. Wayland, Naintenance Supervisor, Acting Other licensee employees contacted included engineers, technicians, operators, and office personnel.
Nuclear Regulatory Commission
- R. Butcher, Senior Resident Inspector
- T. NcElhi nney, Resident Inspector
- J. Potter, Region II
- G. Schnebli, Resident Inspector 2. 'adiation Control (83822)
a
~
Organization and Staffing The inspector reviewed the health physics (HP) organization staffing upgrades and proposed changes with cognizant licensee representatives.
Technical Specification (TS) 6.3.2. 1 details qualifications required for the HP Supervisor.
The inspector reviewed the recently hired HP Supervisor's qualifications against the applicable TS criteria.
Based on information provided during a meeting between licensee and NRC representatives held at FPSL Company's request in the KRC Region II Office on Nay 5, 1989, and from discussion with cognizant licensee representatives during the onsite audit, the inspector noted that the
HP supervisor's qualifications and experience were adequate'o meet the applicable TS conditions.
The licensee continued to reduce the number of contract-personnel with a
concurrent increase in FPSL Co.
staffing in radiation protection site program areas.
At the time of the onsite inspection, no supervisory positions were vacant.
At full staffing levels, the HP organization is expected to consist of 88 personnel including 57 radiation protection men (RPM)
and senior technicians, 10 junior technicians, 6 technical position supervisors, 12 record technicians, and 3 engineers.
Licensee representatives stated that currently, ll RPM/technician positions are filled with contract personnel and
positions are vacant.
The licensee expects to fill these 14 positions with FPSL Co. employees by October 1, 1989.
The inspector noted that the additional, dedicated FP&L staff, both technician and technical engineers, appears to have improved the routine health physics coverage for job activities.
In addition, the increased technical staff continues to demonstrate a positive impact on the timely, resolution of technical issues and/or program upgrades, for example, the installation and development of procedures for the new whole-body counting system, presently being installed at the site.
Furthermore, the staff would be expected to positively affect health physics issues when additional contractor personnel are employed during outage conditions.
Licensee representatives stated that the previous ratio of licensee HP personnel to contractors during outage conditions was approximately 20: 1 and is expected to be reduced to. 15: 1 during the next scheduled outage.
No violations or deviations were identified.
Audits TS 6.5.2.8 requires audits of facility activities to be performed under the cognizance of the Company Nuclear Review Board (CNRB)
encompassing conformance of facility operation to all provisions contained within the TSs and applicable license conditions at least once per year, and the Process Control Program (PCP)
and implementing procedures at least once every two years.
Cog'nizant licensee representatives provided and discussed the following procedures utilized to implement the quality assurance (QA)
audit program for radiation protection activities.
QI
QAD 3., Scheduling of Quality Assurance Department Audit Activities, Rev.
17, dated March 30, 1989.
QP 18. 1, Performance of Quality Assurance Audits, Rev.
13, dated December 17, 1986.
QP 16. 1, Corrective Action, Rev. 9, dated October 27, 198 The procedures established functional audit areas and their required frequency, guidance for conducting audits, and details required for followup of sig'nificant items.
The inspector reviewed and discussed the following audits of radiological protection activities conducted from January 1987 through July 1989"with cognizant licensee representatives.
gAO-PTN-87-841, Technical Specification 6.17, Process Control Program, dated July 9, 1987.
gAO-PTN-88-937, Radiation Protection Program, dated October 28, 1988.
gAO-PTN-88-950, Radioactive Naterials Sources and Sources Surveillance, dated February 3, 1989.
gAO-PTN-88-953, Technical Specification 6. 12, High Radiation Area, dated December 9,
1988.
gAO-PTN-89-972, Personnel Radiation Protection Program Technical Specification 6. 11, dated April'6, 1989.
All audits were conducted in accordance with the approved procedures.
The inspector noted, that the audit reports included, in addition to TS required items, qualitative review of general housekeeping and radioactive waste storage.
Findings included improper protective clothing use, improper Radiation Work Permit (RWP) application, inadequate High Rad Area locks, improper labeling, poor contamination control/survey practices, and procedural inconsistencies.
For the audits reviewed, no significant trends, for example repeat occurrences, were observed with the findings.
The majority of procedural inconsistencies, equipment inadequacies and other findings, including transportation activities (Paragraph 7),
were corrected or corrective actions initiated prior to completion of the audit and no further actions were required.
These licensee identified violations are not being cited because criteria specified in Section V.G. 1 of the NRC Enforcement Policy were satisfied.
The licensee's corrective action procedure regarding the internal audit program did not require "root cause" analyses of identified issues nor compare findings with previous audit results to determine repeatable occurrences.
The inspector discussed with cognizant licensee representatives mechanisms, for example,
"root cause analysis" and trending of findings, to improve the effectiveness of the evaluation and corrective actions for identified items.
Licensee representatives agreed to evaluate the need for these types of analyses associated with audit findings.
The inspector informed licensee representatives that their evaluation of the need for improved root cause and trend analysis associated with the internal audit program would be tracked as an inspector followup item (IFI)
and would be reviewed during a
subsequent inspection (IFI:
50-250/89-35-01).
No violations or deviations were identified Training and gualifications
CFR 19.12 requires the licensee to instruct all individuals working or frequenting any portions of the restricted areas in the health protection aspects associated with exposure to radioactive material or radiation, in precautions or procedures to minimize exposure, and in the purpose and function of protection devices employed, applicable provisions of Commission Regulations, individual's responsibilities and the availability of radiation exposure data.
CFR 20. 103(c)(2) requires that the licensee maintain and implement a respiratory protection program that includes determination by a
physician prior to use of respirators, that the individual user is physically able to use respiratory equiment.
The inspector reviewed implementation of the respiratory protection program with licensee representatives.
Guidance for qualifying the Respirator Test Booth operators, and conducting fit testing and training of workers is provided in procedure HP-68, 'Operation of the Sodium Chloride Respirator Test Booth, dated June 9,
1989.
In addition, the inspector verified that the licensee has a program for trainina of HP RPN and technicians regarding the Turkey Point Nuclear (TPN) respiratory protection programs.
However, the adequacy of the RPN and HP technician training was not reviewed during this inspection.
J During the current audit, the inspector was informed by cognizant licensee representatives that the respirator test booth was inoperable.
Licensee representatives stated that a replacement booth was procured and would be operational in the near future.
No attempt was made to fix the inoperable test booth and the licensee stated that no respirator fit testing would be conducted until the new booth was operational.
The inspector reviewed current respiratory protection program records to verify training, issuance of medical physicals, respirator fit testing and final approval for selected individuals involved in activities requiring use of respiratory protective equipment for work as specified on selected RMPs associated with Unit 4 Spent Fuel Pit re-rack activities ongoing during the. current inspection.
From review of records and discussion with licensee representatives the inspector verified that all personnel were trained, fit tested, and verified to be medically qualified as required by approved licensee procedure No viol ati ons or devi ati ons were identi fied.
d.
Radiation Work Permit Implementation The inspector observed selected ongoing maintenance activities associated with Unit 4 Spent Fuel Pit Re-rack activities.
The following RWPs were reviewed and discussed with licensee representatives.
RWP 89-1732, Unit 4 Spent Fuel Pit Move Fuel Assemblies for Re-rack, dated May 9, 1989.
RWP 89-1733, Radiation Controlled Area Nonhigh Radiation Areas/Noncontaminated Areas Support Re-rack Operations, dated May 10, 1989.
RWP, 89-1737, Unit 4 Spent Fuel Pool. Move, Decon, and Lift Spent Fuel Racks from Pool for Spent Fuel Pit Re-rack, dated May 9, 1989.
RWP 89-1738, Unit 4 Spent Fuel Pool Move, Decon, and Lift Spent Fuel Racks from Pool for Spent Fuel Pit Re-rack, dated May 9, 1989.
RWP 89-1739, Unit 4 Cask Wash Area and Outside Area Remove Old Racks from Pool, Package Racks and Load Racks into Shipping Containers, dated June 15, 1989.
RWP 89-1740, Unit 4 Spent Fuel Pool Install New Racks in Spent Fuel Pool for Spent Fuel Pit Re-rack, dated May 9, 1989.
t The inspector noted that RWP 89-1739, dated June 15, 1989, did not require a
pre-job briefing."
Cognizant licensee representatives stated and provided appropriate documentation verifying that pre-job briefings were conducted on June 14 and June 26, 1989.
The need to include the pre-job briefi ng requirements on the RWP documentation to ensure workers adherence to the work requirements was discussed.
Licensee representatives revised the RWP to include the pre-job briefing requirement on July 25, 1989.
During tours of the facilities, the inspector verified that all maintenance activities were conducted in accordance with the RWP detailed controls.
The RWP controls appeared to be adequate for the activities in progress.
At the time of the inspection no abnormal occurrences regarding exposures and contamination events associated with the Unit 4 re-rack activities had been documented.
No violations or deviations were identifie.
Internal Exposure
CFR 20.203(a)(3)
requires that the licensee use measurements of concentrations of radioactive materials in air for determining and evaluating airborne radioactivity in restricted areas and in addition, as appropriate, use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for the timely detection and assessment of individual intakes of radioactivity by exposed individuals.
a ~
Program Implementation The inspector reviewed HP Procedure, O-HPA-031, Personnel
.Monitoring of Internal Dose, dated April 6, 1989, which described the licensee's requirements for conducting initial, termination, annual, and special bioassay surveys for all plant personnel.
The licensee had the option of using either whole body counter (WBC)
or urinalysis methodologies prior to the individuals first entry into the Radiologically Controlled Area (RCA)
and for subsequent body burden analyses conducted for licensee personnel.
The action levels are specified in 0-HPA-31 and are summarized below.
Less than one percent Maximum Permissible Organ Burden (NPOB),
no corrective action.
From one to ten percent MPOB, notify the HP Supervisor and review bioassay results for the
CFR Part 20 requirement specifying the
Maximum Permissible Concentration-hour (MPC-hr) exposure limit.
From
to 50 percent NPOB, in addition to the above requirements, perform additional bioassay measurements to make an estimate of the critical organ burden and consider restriction of the individual from the RCA.
Greater than 50 percent NPOB, in addition to the above requirements, restrict the affected individual from the RCA.
Since the last HP inspection (50-250, 251/88-19)
conducted during July 1988, the licensee stated that no personnel who had been monitored, exceeded the one percent NPOB.
During the review of whole body count records, the inspector noted that selected workers had been terminated from employment at the Turkey Point site but had not received a whole body count upon their leaving the facility.
The inspector reviewed selected records of individuals who had terminated thei r employment at the facility without receiving a whole body count from August 1988 through July 1989 and, in addition,
reviewed the HP procedures governing monitoring for internally deposited radionuclides.
Specifically, HP procedure O-HPA-031, Personnel Monitoring of Internal Dose, dated April 6, 1989, Step 5.3, Terminating Bioassay, requiring that a bioassay measurement should be'"
performed for all personnel. terminating employment at Turkey Point.
Additionally, upon notification or determination by Health Physics that an employee has terminated without reporting for a termination bioassay, the procedures required HP personnel to issue a
memo of the occurrence and keep it on file.
For selected persons failing to have a whole-body count, the inspector was able to verify that memos describing the failure to obtain an exit whole body count was placed in the individuals'iles.
From review of records pertaining to improper terminations from August 1988 through July 1989, the inspector observed that at least 72 individuals terminated without obtaining an exit whole body count.
The inspector also observed that the licensee requires an individual to sign Form HP 11.2 - Wholebody Count Procedure Control, which states that the individual signing the form has been informed of the administrative procedure requirement that all persons obtaining an entrance body count for issuance of a thermoluminescent dosimeter (TLD) shall get an exit count to complete accurate exposure records.
If no entry is made into the RCA, a waiver may be signed to complete the individual's exposure history.
The inspector selectively verified that personnel failing to complete a termination whole body count had signed Form HP 11.2.
No violations or deviations were identified..
r Instrumentation The inspector also reviewed-and discussed with licensee representatives, changes to the whole body counting equipment.
The licensee's whole body counting equipment consisted of Nuclear Data
"moving bed" and "chair" geometry systems which were located in a
climate controlled office adjacent to the Dosimetry Records and Issuance Office.
During this inspection, the licensee recently had completed the upgrading of the chair geometry system by installing two intrinsic germanium detectors for evaluating the deposition of radioactivity in the lung and gastrointestinal (GI) tract.
The two detectors were manufactured by Princeton-Gamma Technologies and had nominal efficiencies of approximately 20 percent.
An approximately two inch diameter by two inch thick sodium iodide (NaI) crystal was used in the thyroid detector.
The licensee was in the process of calibrating the system.
Additionally, the licensee purchased a
new work station (YAX 2000) for operating both the upgraded chair and the moving bed geometry systems.
At the time of the inspection, licensee engineers were developing procedures for use with the system upgrades.
No violations or deviations were identifie '
c.
WBC Measurement Quality Control Additionally, the inspector reviewed the QA/quality control (QC)
program pr'ocedures and records.
Specifically, HP Procedure O-HPT-033, Operation of the Health Physics Whole Body Counting Equipment, dated April 27, 1989, described the daily efficiency and background checks, and the once per-shift energy calibration.
Calibration of the whole body counting equipment was specified in O-HPT.-034, dated Nay 16, 1989.
The inspector reviewed the records of the daily efficiency and background checks and the once per-shift energy calibration for the period January 1989 through July 1989.
The licensee trended the daily efficiency checks and energy calibration data.
Control limits for the efficiency checks were established at plus or minus (+) three sigma.of the mean efficiency determined during the annual calibration.
The licensee established control limits, of plus or minus a
three channel shift in the photopeak of two key isotopes.
All of the reviewed data were within established control limits.
The licensee also participated in a
cross-check program with an.approved vendor on a quarterly basis.
The inspector noted that the moving bed geometry system failed the cross-check acceptance criteria on several occasions since the first quarter of 1988.
In discussions with the licensee, the inspector was informed that the moving bed geometry system would be replaced by a Stand-up Fast Scan whole body counter within the next two years.
Although the fast scan WBCs typically provide both rapid screening and quantification of body burdens for internally deposited radioactive materials, they typically provide only crude activity localization capabilities.
No violatio'ns or deviations were identified.
4.
External Exposure
CFR 20. 1(c) requires that persons engaged in activities under licenses issu'ed
'by the NRC should make every reasonable effort to 'maintain radiation exposures as low as reasonably achievable (ALARA).
CFR 20. 101 requires that no licensee shall possess, use or transfer licensed material in such a
manner as to cause any individual in a
restricted area to receive in any period of one calendar quarter a total occupational dose in excess of 1.25 rems to the whole body; head and trunk; active blood forming organs; lens of the eyes; or gonads.
During the audit, the inspector observed preparation for, and in addition, was i nformed of numerous entries into the Unit 4 containment at full power for selected mai ntenance activities.
Licensee representatives indicated that for Unit 4, the most recent entries were for maintenance activities associated with an accumulator level transmitter.
Guidance for containment entries at power to complete this maintenance was detailed in RWP 89-4901, Unit
Containment (Power Entry)
All Elevations Calibrate/Repair Transmitters Indicators and Actuators, dated Nay 6, 198 The inspector reviewed and discussed the frequency of containment power entries associated with the RWP and the accumulated dose.
From June
through July 27, 1989, approximately 138 personnel entered containment signed in on RWP 89-4901, and wer'e assigned an accumulated whole body dose of 1.235 person-rem.
The highest individual dose, as measured by self-reading dosimeter was approximately 100 mrem.
The inspector was notified that for 13 RWPs and seven RWPs associated with Unit 3 and Unit 4 containment entries at power conducted since 1989, the total dose expended was approximately 7.81 and 6.51 person-rem, respectively.
Cognizant plant management indicated that the frequency of power entries was considered excessive and actions were being taken to correct concerns associate with the effectiveness of maintenance evaluations and planning activities.
The inspector noted that the excessive containment entries, although not contributing large individual doses to.personnel, were considered poor practice in regards to the licensee's implementation of their ALARA program.
No violations or deviations were identified.
lt 5.
Tour of Facilities e
CFR 20.203(e)
requires each area in which licensed material is used. or stored and which contains any radioactive material in an amount exceeding ten (10) times the quantity of such material specified in Appendix C of this part to be posted with a sign or signs bearing the radiation caution symbol and the-words:
"Caution, Radioactive Naterial(s)."
CFR 20.203(f)
requires each container of licensed material to bear a
durable, clearly visible label identifying the radioactive contents.
During the inspection, radiological controls and work practices were observed during tours of the RCA.
The following issues were noted and/or discussed with coonizant licensee management.
All Radiologically Controlled Areas.
All survey meters were noted to be operable and calibrated according the standard procedures.
Observation of personnel at selected control points indicated adequate use of survey equipment.
Labeling and Posting of Storage Areas.
On July 25, 1989, during tours of the facility areas, the inspector observed numerous trailers located east of the Auxiliary Building with doors partially opened as a result of broken locks.
Selected trailer doors were posted with signs indicating "Caution Contaminated Naterials."
Closer inspection indicated that the trailers contained construction materials and for those trailers with opened doors, signs were posted inside.
In addition, the inspector noted the "Caut'ion Radiation Area" sign posted on the Waste Sorting Trailer was obscured when the trailer's entrance door was proped open.
These issues regarding poor posting'practices were discussed with coonizant licensee representatives.
The inspector determined that the trailers located east of the Auxiliary
b
Building were used for storage of potentially contaminated construction material and the posting was adequate.
Licensee representatives stated that all broken locks would be replaced in a
timely manner.
,In addition, licensee representatives stated that the sign on the waste sorting trailer would be repositioned to a more appropriate area.
During tours of the Auxiliary Building on July 24, 1989, the inspector noted the door to the North Evaporator Room was unlocked and that when the door was opened to enter the room, a local audible alarm sounded.
The room was posted as a
Further discussion with the HP Shift Supervisor indicated that the alarm had not been removed from when the area was regarded as a locked high radiation area.
From review of current survey records and discussion with cognizant licensee representatives, the inspector determined. that the posting and radiation controls were adequate for the current radiation'evels.
Radioactive Waste Storage Areas.
During tours of the Auxiliary Building's waste processing area, the inspector noted a noticeable, decrease in stored-high level waste since the previous routine HP inspection (Inspection Report 50-250, 251/88-19).
In addition, significant cleanup and decontamination efforts were noticeable for waste processing and decontamination areas.
Licensee representatives stated that significant effort to decontaminate the waste processing area and to ship waste from the site had been conducted and was continuing.
No information regarding the specific area reclaimed nor the amount of actual waste removed from the waste processing area was available.
violations or deviations were identified.
6.
Radioactive Solid Waste and Radioactive Waste Management (84850,8035)
a
~
Waste Classification, Characterization, and Labelling
CFR 20.311(d) (1)
requires that, any generating licensee who transfers radioactive waste to a land disposal facility prepare all waste so that the waste is classified according to
CFR 61.55 and meets all the waste characteristic requirements of 10 CFR 61.56.
The regulation further establishes specific requirements for conducting a
quality control program.
The inspector reviewed the licensee's solid radwaste management program.
Since the last HP inspection (50-250, 251/88-19)
there have been no sionificant changes to equipment, waste processing and controls, or procedures.
The inspector reviewed the results of the most recent waste stream analysis documented in an interoffice correspondence from the Corporate Office to Turkey Point Nuclear Plant, entitled Turkey Point
1989 Scaling Factor Validation and Recommendations, dated July 14, 1989.
This document was prepared by the corporate HP staff utilizing sample analysis results provided by a
vendor laboratory.
The document described the current scaling factors and recommendations for changes.
The licensee indicated that the scaling factors are validated and adjusted, if necessary, annually by the FP&L Co.
Corporate Office.
In addition, the inspector reviewed the licensee's method for classification of radwaste.
At present, the licensee manually classifies and quantifies the total radioactivity in the waste shipments.
Although the licensee has not made an unusually large number.of waste shipments during the last year, this manual method could become a burden as the number of shipments increases.
The licensee was aware of some of the commercially available waste classification programs.
Waste Generation The inspector discussed the solid waste processing activities occuring onsite.
Basically, the only solid waste processing occuri ng onsite is the dewatering of resins and the compaction of dry active waste (DAW).
The licensee has both a
drum compactor and a
box compactor.
Both waste forms are sent to a
vendor for super-compaction.
Additionally, dewatered resins are sent to a
vendor where they are solidified.
Licensee representatives stated that during 1988, approximately 4,960 cubic feet (ft~) of processed waste had been shipped.
Total radioactivity in this volume of waste was approximately 573 curies.
From January 1989 to June 1989, the licensee shipped approximately-4,339 ft'f processed waste containing approximately five curies.
The inspector observed that the last gA audit of the licensee's radioactive waste and Process Control Program (PCP)
was conducted in July 1987.
During this inspection, the licensee was in the process of conducting an audit of the PCP in accordance with TS 6.17.
The auditor reviewed three areas of licensee-identified noncompliances which are discussed in Paragraph 7.
Waste Storage The inspector also discussed the solid waste storage capacity available onsite.
The licensee has an onsite storage facility which is strictly used for DAW.
The licensee has no storage facility for spent resins, however, there was a shielded
"-staging area" with a capacity of approximately 1,500 ft'.
No violations or deviations were identifie.
Transportation
CFR 71.5 requires each licensee who transports licensed material outside the confines of its plant or other place of use, or who delivers licensed material to a carrier for transport, to comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation (DOT)
in
CFR Parts 170-189.
a.
Audits
CFR 71, Subpart H requires the establishment of a gA program for the packaging and transportation of radioactive materials.
CFR 71. 137 requires that the licensee perform a
comprehensive system of planned and periodic audits to verify compliance with all aspects of the gA program and to determine the effectiveness of the program.
CFR 71, Subpart C authorizes the licensee to use specific packages for transporting licensed material and specifies the conditions for using the packages.
During the inspection the licensee's gA group was in the process of conducting the TS required biennial audit of the PCP and, in addition, an audit of radioactive waste transportation activities.
The inspector observed that the gA auditor had identified three violations.
The violations along with the appropriate requirements which were cited are summarized below.
( 1)
The licensee made seven shipments of radioactive bead resins in 1988 using model PL6-80FR High Integrity Containers (HICs).
The PL6-80FR model HIC was not authorized in the PCP.
TS 3.9.3,a requi res that radioactive bead resins be dewatered, as appropriate, in accordance with the PCP to meet shipping and transportation requirements during transit, and disposal site requirements when received at the disposal site.
Operating Procedure 11550.48, Process Control Program for Dewatering Radioactive Waste Liners, authorizes the use of specific HICs for disposal of radioactive bead resins.
Multiple use of a HIC not authorized in the PCP was identified as a violation of TS 3.9.3.a.
The corrective actions which either had been completed or were in the process of completion at the time of the onsite inspection included the following actions.
Purchase specifications for procurement of radioactive waste packaging, transportation and disposal services shall be revised to include a requirement for vendors to notify the licensee of any changes to their equipment or processes which they provide to the licensee.
This requirement will
be included in the purchase order for vendor services currently being written at the time of this inspection.
The PCP will be revised to authorize the use of the different types of HICs for disposal of radioactive bead resin that are consistent with the Certificates Of Compliance (COCs)
issued by the South Carolina Department of Health and Environmental Control.
This apparent violation was discussed with NRC Region II management and reviewed against the requirements specified in 10 CFR Part 2;
Appendix C,Section V.G for non-cited violations (NCVs).
The inspector informed licensee representatives that all requirements for licensee-identified violations (LIVs) were met and at this time the issue would not be cited (NCV: 50-250, 251/89-35-02).
(2)
The licensee incorrectly recorded the radionuclide activities on three shipment manifests in 1987 and seven shipment manifests in 1988 as a result of using an incorrect resin volume.
In 1987, the volume of waste normally contained in the PL6-80CR HIC was calculated from measurments of the internal dimensions, but the calculation was not documented.
The undocumented calculated volume of 44.8 ft'as used in three shipments in 1987 and seven shipments in 1988.
Using the same fill level criterion "that was used in the 1987 calculation and the internal dimensions provided by Operations personnel, the actual bead resin volume should have been 56 ft~;
Therefore, the actual activity in the HICs was greater than the activity reported on the manifests.
The incorrect volume resulted in a non-conservative error of approximately 25 percent.
The waste type classification of the ten waste shipments was not affected.
The failure to report the correct activity on the radioactive waste shipping manifests was identified as a
violation of
CFR 20.311(b)
and
CFR 172.203(d)(iii)
requirements.
The corrective actions which either had been completed or were in the process of completion were as follow.
Specific instructions for determining the volume of waste contained in each type of disposal unit will be included in procedures for use of each container.
A revised manifest will be prepared for each of the shipments using the larger calculated waste volume.
The revised manifests then will be transmitted to the applicable vendor.
The Semiannual Radioactive Effluent Release Reports for the affected years will be revised to include the additional solid waste activit (3)
Revised manifests also will be be transmitted to the Florida Department of Health and Rehabilitative Services (DHRS) to update applicable records.
This apparent violation was discussed with NRC Region II management and reviewed against the requirements specified in
CFR Part 2, Appendix C,Section V.G for NCVs.
The inspector informed licensee, representatives that all requirements.for LIVs were met and at this time the issues would not be cited (NCV:
50-250, 251/89-35-03).
License Condition 39.c of the Barnwell Waste Management Facility-Radioactive Materials License requires that. void spaces within
. the waste, and between the waste and its packaging, be reduced to the extent practicable, but in no cases less that 85 percent of the capacity of the container to be filled.
The licensee may allow a variance from this condition in certain instances, but only after receiving a written justification from the waste generator prior to receiving the waste shipment.
CFR 30.41(c),
requires the licensee before transferring byproduct material to a specific licensee of the Commission or an Agreement State or to a
General Licensee who is required to register with the Commision or with an Agreement State prior to receipt of the byproduct material, to verify that the transferee's'icense authorizes the receipt of the type, form, and quantity of the byproduct material to be transferred.
The licensee failed to meet the 85 percent minimum fill criterion of the HICs used to make three radioactive waste shipments made in 1987.
Shipment to the Barnwell Waste Management Facility of a stable waste container which is less than 85 percent minimum fill criterion without receiving prior authorization in writing, was identified as a violation of 10 CFR 30.41(c).
Corrective actions which either had been completed or were in the process of completion included the following items.
Provide specific guidance in the radwaste shipping procedures to either comply with and verify the 85" percent minimum fill criterion or prepare a written request for a variance prior to transferring Class A Stable, B or C waste to the waste processing vendor.
The licensee will inform the appropriate vendor that three shipments did not comply with License Condition 39.C.
This apparent violation was discussed with NRC Region II management and reviewed against the requirements specified in
CFR Part 2, Appendix C,Section V.G for NCVs.
The inspector informed licensee representatives that all requirements for LIVs
were met and at this time the issues would not be cited (NCV:
50-250, 251/89-35-04).
The inspector noted that licensee management took prompt and aggressive corrective actions once the items of noncompliance were identified by the gA group while the audit was still in progress.
The corrective actions were documented in an internal memo from D.
Hall to K. Harris, dated July 21, 1989.
In addition, licensee management ceased all shipments of radioactive material until the procedures governing the shipment of radioactive materials are revised.
The inspector observed that the licensee's program for transporting radioactive materials was audited biennially in conjunction with the PCP audit.
The inspector discussed the merits of increasing the audit frequency in the program for packaging and transporting radioactive material.
The licensee acknowledged that increasing the audit frequency in this area would be a program enhancement and especially could be needed within the next year because the radwaste and transportation procedures were undergoing major,'evisions.
During a
'eleconference on July 31, 1989, between the inspector and licensee representatives, the licensee committed to consider increasing the audit frequency in the program for the PCP, and the packaging and transportation of radioactive materials.
Review of the annual audits in the PCP and radioactive waste packaging and transportation areas will be reviewed during subsequent inspections and will be tracked by the NRC as an IFI (IFI: 50-250/89-35-05).
b.
Waste Nanifests The inspector reviewed records of selected shipments of radioactive materials performed in 1989, and observed that during the time period of January 1989 to Harch 1989, the licensee failed to include the telephone number of the person generating the waste on at least five shipment manifests.
The inspector did not review the entire shipment manifest file.
This issue was identified as a violation of
CFR 20.311(b)
which requires, in part, that each shipment of radioactive waste to a
licensed land disposal facility must be accompanied by a shipment manifest that contains the name, address, and telephone number of the 'person generating the waste.
The licensee took immediate action to correct the violation by initiation of a procedure change to O-HPA-40, Shipping and Receiving Radioactive Naterial.
The procedure revision request required the addition of shi pping paper (49 CFR 172)
and waste manifest requi rements to clarify information needed on radioactive material and waste shipments.
The procedure revision request was signed and dated before the termination of the onsite inspection.
The inspector informed licensee representatives that their corrective action to this violation met the criteria specified in 10 CFR Part 2, Section
ir S
V.A regarding NCVs and would not be cited at this time (NCV: 50-250, 251/89-35-06).
The inspector also observed that the Florida DHRS inspects each shipment of radioactive waste made by a
Florida generator in accordance with the Rules of the State of Florida, DHRS, Chapter 10D-91, Control of Radiation Hazards.
The State compared the volume of shipments from FPSL Co. facilities to the State of Tennessee records and discovered a discrepancy.
The volume of waste received
.
by the waste processing vendors in Tennessee was higher than that inspected by DHRS.
The licensee reviewed the documentation for shipments made to the waste processing vendor in Tennessee in 1988 and 1989, and determined that two shipments (88-027 and 89-044) were incorrectly manifested as radioactive material rather than radioactive waste.
None of the materials shipped had any commercial value after processing, and therefore should have been considered as waste.
The fai lure to manifest correctly, these radioactive waste shipments, was identified as a second example of a violation of 10 CFR 20.311(b)
requirements (50-250/89-35-06).
The licensee analyzed the problem and identified two root causes.
The first cause was that no criteria had been established, either in procedures or policy, to d'efine which materials shall be tre'ated as waste.
The second cause cited by the licensee was that, the, DHRS.rules did not clearly indicate what materials should be treated as waste.
The following corrective actions which were documented in an interoffice correspondence from D. Hall to J.
Cross dated July 17, 1989, were reviewed by the inspector and dicussed with licensee representatives.
The licensee's corporate office will prepare a Letter of Instruction to provide guidance in determining whether or not material is to be treated as waste.
Shipping procedures are to be revised to incorporate the guidance provided in the Letter of Instruction.
The State of Florida will be consulted in assessing any material outside the scope of the Letter of Instruction.
As noted previously, the inspector observed that the licensee was in the midst of completely revising the procedures governing the packaging and shipment of radioactive materials as well as radwaste processing procedures.
There was a strong urgency for such a revision since, for example, all of the
"HP Forms" that were used in conjunction with making a shipment were not formally a part 'of any approved plant procedure and therefore would not be subjected to the required plant procedure review process.
The inspector observed that the new packaging and shipment procedures could have provisions to perform at least two independent outgoing vehicle surveys in order to better certify that the outgoing vehicle dose rates meet regulatory limits.
The inspector informed licensee representatives that the newly revised packaging and shipping procedures would be reviewed
during a subsequent inspection and would by tracked by the NRC as an IFI (IFI:
50-250/89-35-07).
c.
Radwaste Procedures s.
The inspector also reviewed the applicable procedures which incorporated the quality control checks to ensure the appropriate waste classification, stability characteristics, and manifest reporting were reviewed prior to each shipment.
The inspector noted that this area could be improved by expanding the scope of the gC Radioactive Waste Shipment Inspection Checklist (Form gC-3) to be more comprehensive.
For example, Item No.
1 detailing appropriate documentation could require that. the inspector verify that the various HP Forms and Waste Manifests have been completed correctly.
Item No
concerning dose rate measurements should require the inspector to verify that the package surface dose rates and contamination levels meet regulatory limits, and Item No.
5 could require that the two independent outgoing vehicle surveys meet regulatory limits.
The licensee agreed to consider that the gC checklists needed to be improved.
The inspector informed licensee representatives that this area would be reviewed during a subsequent inspection and would be tracked by the NRC as an IFI (IFI:
50-250/89-35-08).
Inspector Followup Items (92701)
The following IFIs and'RC Information Notices (INs) were reviewed and discussed with cognizant licensee representatives.
a ~
Inspector Followup Items (Closed)
IFI 50-250/88-19-01:
Review changes to details of TPN An'nual Topical guality Assurance Report.
The issue concerned the lack of detail regarding the lines of authori ty betwen the RPN posi tions and the HP Supervi sor position within the HP organization as outlined in the Topical guality Assurance Report, Rev.
12, dated June 24, 1987.
The inspector reviewed the most recent TPN Annual Topical guality Assurance Report organizational chart, dated June 1,
1989.
The chart reflects the current lines of authority among personnel including the.
RPNs, Shift and Operational Area Supervisors, the HP Supervisor, and the Operations Superintendent.
The inspector had no additional comments and the issue is considered closed".
(Closed)
IFI 50-250/88-19-02:
Review use of urinalysis data to evaluate personnel exposure to airborne contamination.
The issue involved the licensee's use of urinalysis data to detect potential uptake and subsequent internal deposition of
radioactive materials for site workers exposed to airborne radioactive contamination.
During a previous NRC audit, the inspector noted that urinalyses were conducted at a higher frequency than are presently performed due to the frequent occurrence of wholebody counting equipment)
malfunctions.
In addition, the inspector noted that no evaluations.of limitations regarding the use of urinalysis methods in lieu of a whole body count to determine intake of radioactive materials had been conducted.
The failure to determine limitations of the analyses to quantify the intake of internally deposited materials was identified as a program weakness.
Cognizant licensee representatives conducted an evaluation of
, detection and assessment capabilities based on the minimum detectable activity (NDA)
associated with the urinalysis methodologies.
Details were outlined in an Inter-Office Correspondence, PTH-HP-88-125, Review of urinalysis detection capabilities, dated August 18, 1988, from a
cognizant HP engineer, to the HP Supervisor.
The inspector verified that the methodology details the determination of the maximum time interval between a potential uptake and bioassay.
sampling that specified NDAs for selected radionuclides would permit the detection of an intake representing the
NPC-hr limit requiring an evaluation in accordance with
CFR 20. 103 requirements.
The inspector discussed with licensee representatives, the incorporation of a
reference to this information in their current internal exposure procedures for future reference.
Licensee representatives agreed to consider including reference to.the documentation in the applicable procedures.
Based on licensee actions, this issue is considered closed.
(Open) IFI'0-250/88-19-03:
Review and evaluate licensee use of finger mounted TLDs for extremity dose monitoring.
During a previous NRC audit, the exclusive use of, and concerns associated with potential nonconservative dose estimates for wrist mounted TLDs used for extremity dose monitoring were reviewed.and discussed.
At the time of the review, licensee representatives stated that an evaluation regarding the accuracy provided for dose estimates using finger-ring and wrist-mounted TLDs would be conducted.
Currently, th'e licensee is using both wrist-mounted and finger-ring TLDs concurrently for work requiring extremity monitoring.
Guidance for the use of extermity moni toring is provided in HPI-13, Extremity Nonitori ng of Personnel, dated January 19, 1989.
The licensee is continuina to collect data regarding the effectiveness of wrist versus finger-mounted TLDs for selected tasks requiring extremity monitoring.
Final guidance regarding this issue has not been completed.
Based on these findings, the issue will remain ope (Closed)
IFI 50-250, 251/88-32-06:
Root cause evaluations in Radiological Incident Reports (RIRs).
During the referenced inspection, a weakness in the licensee's program for performing a root cause evaluation involving hot particle contamination on the outside of an individual's personal clothing was identified.
The licensee reviewed the capability to perform root cause evaluations and completed the following actions:
A Quality Improvement Program (QIP) team was established to evaluate root causes for RIRs.
The team will analyze data and work on long-term corrective actions.
RIR Forms HP-12, HP-12.2, and HP-12.2. 1 were revised to be
- more specific during analysis and to provide better documentation.
A personnel contamination history (HP-12.4)
was implemented to provide more structured root cause evaluation.
Based on the licensee actions this issue is considered closed.
(Closed)
IFI 50-250/89-IN-27:
Limitations on the use of waste forms and high integrity containers for the disposal of low-level radioactive waste.
This issue was a Region II based initiative to verify that the licensee was aware of NRC IN 89-27, dated March 8, 1989.
The inspector verified that the IN was recieved by the licensee and distributed to the appropriate personnel for information and/or action (Paragraph 8.b).
This item is considered closed.
(Closed)
IFI 50-250/89-14-01:
Large percentage of the RCA maintained as contaminated.
This issue was identified during an NRC ALARA team inspection.
The inspector reviewed the responses provided in a letter from the licensee to the NRC dated June 12, 1989, and referenced as Weakness No. 2.
During the current inspection licensee actions regarding this issue were reviewed in detail.
Continuing NRC followup of this issue is being conducted as a result of recently established program initiatives and goals.
This item is considered closed and will be tracked under the new IFI established during the current inspection (Paragraph 9).
(Closed)
IFI 50-250/89-14-02:
Lack of formalization of the ALARA Zone Coordinator concep Thi s itern was identi fi ed duri ng an NRC ALARA team inspect ion.
The inspector reviewed the licensee's response provided in a
letter to the NRC Region II Office, dated June 12, 1989 and referenced as Weakness No 5.
In the response, the licensee committed to utilize the ALARA Zone Coordinator concept for future scheduled outages.
Based on the licensee's actions, this item is considered closed.
(Closed)
IFI 50-250/89-14-03:
Lack of full attendance at the ALARA Coordinating Committee meetings.
During a previous inspection of the licensee's ALARA program, the inspector observed that from June 1987 to November 1988, overall attendance at the ALARA Coordinating Committee meetings was approximately 43 percent.
Personnel from Instrument and Control, and Yiaintenance groups attended only 14 and 28 percent of the meetings, r'espectively.
The inspector reviewed the response provided by the licensee in a letter to the NRC Region II office dated June 12, 1989.
The licensee's response to the identified weakness, documented as Weakness No. 6, indicated that the ALARA Coordinating Committee would be used as a guality Improvement Task Team assignment by the ALARA review board to work on improvement opportunities.
Based on the licensee's actions, this issue is considered closed.
(Closed)
IFI 50-250/89-14-08:
Limitation of sugaestion program for ALARA improvements.
During a previous inspection of the licensee's ALARA program, the inspector determined that the ALARA Suggestion Program only was available to the licensee's employees and not to contract personnel.
Additionally, many ALARA suggestions submitted as employee ideas appeared never to have reached the ALARA Committee.
The inspector reviewed the licensee's response provided in a
letter to the NRC Region II, dated June 13, 1989, and documented as Weakness No. 7.
The HP Department has instructed the Turkey Point Employees Suggestions Program Coordinator to direct suggestions for ALARA improvements to the ALARA review board for consideration.
Although the licensee appeared, to be committed to allow contractor participation, the mechanisms to allow contractor participation in the employees suggestion program were not formalized.
Based on review of licensee actions, this item is considered closed.
(Closed)
Unresolved Item (URI) 50-250/89-13-02:
Evaluation of shielding requirements for the R-15 radiation monito During a previous inspection, the potential failure to meet TS effluent release monitoring requirements resulting from inoperability of the Unit 3, '-15 radiation monitor as a result of the installation of temporary shielding around the detector system, and/or the failure to conduct redundant system or sampling operations was identified as an URI.
The inspector reviewed the licensee's evaluation of this issue.
The licensee's evaluation indicated that the backup channel for
,th'e R -15 effluent monitor was effluent monitor RAD-4-6417.
Review of,maintenance records indicated this monitor to be inoperable
of the approximately 480 days Unit 4 was operating.
For these 60 days the R-15 monitor was in operation.
The licensee evaluated the sensitivity of the Unit 4, R-15 radiation monitor against FSAR, Section 11.2, detection criteria of approximately 1 E-6 microcuries per cc.
Using methodology established in PTN-O-TPNS-88-002, with conservative corrections for sample volume and geometry factors resulting from installation of the temporary shield, the licensee's evaluation determined that the detector's response to the minimum detection criteria would be acceptable to meet FSAR requirements.
Based on the licensee's evaluation, this issue is considered closed.
b.
Information Notices The inspector verified that the following NRC INs were received by
'he licensee, reviewed for applicability, distributed to appropriate personnel and that action, as appropriate, was taken or planned.
High Radiation Hazards from Irradiated Incore Detectors and Cables.
Nisuse of Flashing lights for High Radiation Area Controls.
IN 88-100:
Memorandum of Understanding Between NRC and OSHA Relating to NRC Licensed Facilities (53 FR 43950, October 31, 1988).
IN 88-101:
Shipment of Contaminated Equipment between Nuclear Power Stations.
Alternate Waste Management Procedures in Case of Denial of Access to Low-Level Waste Disposal Sites.
Limitations on the use of Waste Forms and High Integrity Containers for the Disposal of Low-Level Radioactive Wast IN 89-47: Potential Problems with Worn or Distorted Hose Clamps on Self-Contained Breathing Apparatus.
9.
Facility Statistics During the onsite audit, the inspector reviewed and discussed selected statistical parameters regarded as indicators of their radiation protection program effectiveness.
The parameters reviewed included the annual personnel dose, personnel contamination events and the percentage of the site area regarded as contaminated.
a ~
Annual Personnel Dose b.
In 1987, the site cumulative personnel dose was approximately 640 person-rem per reactor as compared to the Pressurized Water Reactor (PWR) national average of 321 person-rem per reactor.
In 1988, the dose goal was established at approximately 671 person-rem per reactor based on the anticipated outages.
The actual cumulative dose received in 1988 was 335 person-rem per reactor as a result of extending outage activities into 1989.
For 1989, a site exposure goal of 790 person-rem as measured by self-reading dosimeters (SRDs)
was established.
As of May 31, 1989, 308 person-rem as'easured by TLD, had been expended.
Currently, the projected dose expended for 1989 is estimated to be 606 person-rem.
Personnel Contamination Events (PCEs)
. The licensee reported 384 total PCEs, 205 skin and 179 personnel clothing contamination events for 1988 compared to 182 skin and 65 clothing contaminations for a total of 247 PCEs for 1987.
Contributing to the increased reports of PCEs for 1988 relative to 1987 was the installation of PCN 18s at RCA exit control points.
As of July, 10, 1989, the licensee reported a total of 110 PCEs, consisting of 65 skin and 45 clothing contaminations.
The PCE value was approximately 23 percent below the licensee's goal of 144 incidents.
For 1989, the licensee has reduced their projected PCEs from 310 to 158 events as a result of delays in the outage schedule.
Licensee representatives discussed their increased awareness and emphasis to determine the root cause and implement activities to reduce the number of PCEs.
The inspector reviewed and discussed the implementation of root cause evaluations concerning PCEs.
Analyses of data indicated that during non-outage conditions, the largest frequency of PCEs were associated with non-contaminated areas.
Licensee representatives indicated that dispersed and uncontrolled radioactive material in the RCA had resulted in high incidence of clean area contamination cases.
Licensee representatives were evaluating actions to reduce PCEs as a result of their finding c.
Area Contamination Control At the end.of 1987, the licensee reported approximately 22,765 square feet (ft') within the RCA, excluding containment areas, as contaminated.
This represented 33 percent of the approximate 69, 193 ft~ of tracked floor space within the RCA.
At the end of 1988, slightly more than 20,433 ft'ere designated as contaminated area with approximately 3,000 ft'eing non-recoverable.
During 1989, increased licensee efforts to evaluate root causes of, and to implement programs to reduce the contaminated floor space resulted in changes for trended parameters including increasing the total tracked area to 97,344 ft',
and increasing area regarded as unrecoverable (area having extended contamination due to operations and high radiation exclusion zones)
to 8,656 ft~.
As of July 10, 1989, for 97,344 ft'ftotal tracked floor space, the licensee was maintaining approximately 20,194 ft',
21 percent, as contaminated.
This area included those process and exclusion areas (approximately 6,946 ft')
where no immediate decontamination effort was planned.
The inspector noted that progress in reducing and maintaining the amount of contaminated space at the site was receiving increased management-attention.
Licensee representatives indicated that as part of a
long-range goal to reduce contamination areas in the RCA, additional areas were added to.the tracked floor space and an action plan for implementing a reduction in site contaminated areas was established.
The action plan was developed to maximize efforts to reduce contaminated 'areas within the RCA and to maintain them as non-contaminated.
Licensee representatives stated that a 4,000 ft'eduction in the amount of contaminated space by December 31, 1989 was established as a short-term goal.
The inspector informed licensee representatives that their efforts regarding implementation of their program for reducing contaminated floor space and the actual progress achieved would be reviewed during a subsequent inspection and would be tracked by the NRC as an IFI (IFI:
50-250/89-35-09).
10.
Exit Interview (30703)
The inspection scope and results were summarized on July 28, 1989, with those persons indicated in Paragraph 1 above.
The inspector summarized the scope and findings of the inspection, including inspector followup items, and NCVs listed below.
Concerns regarding the need to consider an increased frequency of audits regarding radwaste and/or material, shipping and transportation activities were reviewed in detail.
Licensee representatives stated that this issue would be reviewed by approriate-licensee personnel and a response would be telephoned to the NRC Region II office regarding a decision.
In addition, the inspector noted that several of the NRC followup items initially reviewed onsite (Paragraph 8)
required additional review by the NRC Regional Office staff.
The inspector informed licensee representatives that although proprietary information was reviewed during this inspection, such material would not be included in the report.
Licensee representatives acknowledged the ins'pector's comments and did not provide dissenting comment On July 31, 1989, during a teleconference between cognizant licensee representatives and NRC Region II personnel, the licensee committed to increase the audit frequency of shipping and transportation activities from a biennial to an annual frequency.
Item Number Descri tion and Reference 50-250/89-35-01 50-250/89-35-02 50-250/89-35-03 50-250/89-35-04 50-250/89-35-05 50-250/89-35-06
, 50-250/89-35-07 IFI - Review licensee's evaluation of need to include analysis of repeatable occurrences and root cause analysis in audit program implementation (Paragraph 2.b).
LIV - Failure to use High Integrity Container (HIC) as authorized in the Process Control Program (PCP).
(Viol ati on of'S 3.93.a, not cited as discussed in Paragraph 7.a).
LIV - Failure to report correct total radio-acti vity on waste shi pping mani fest for spent res in shi pment ( Violati on of
CFR 20.311(b),
not cited as discussed in Paragraph 7.a):
LIV - Failure to meet 85 percent minimum fill criterion for the containers utilized in three waste shipments (Violation of-
CFR 30.41(c),
not cited as discussed in Paragraph 7.a).
IFI - Review increased frequency of audits regarding radioactive material/waste transportation and shipping activities (Paragraph 7.a).
NCV - Failure to (1) include on the waste shipment manifest the telephone number of the person generating the waste, and (2) classify properly, radioactive materials shipped to a waste processor on a shipment manifest (Violations of
CFR 20.311(b),
not cited as dicussed in Paragraph 7.b).
IFI - Review revised radioactive material/
waste shipping and transportation procedures (Paragraph 7.b).
50-250/89-35-08 50-250/89-35-09 IFI - Review improved gC inspection checklist for review of radioactive waste/
material shipping and transportation activities (Paragraph 7.c).
IFI - Review licensee progress in meeting action plan goal to reduce contaminated RCA floor space by 4,000 ft~
by December 31, 1989 (Paragraph 9).