IR 05000255/1987030

Insp Rept 50-255/87-30 on 871116-1214.Violations Noted.Major Areas Inspected:Radiation Protection Program,Including Organization & Mgt Controls,Internal & External Exposure Controls,Transportation,Alara Program & NRC Info Notices

ML18052B442
Person / Time
Site:	Palisades
Issue date:	01/04/1988
From:	Gill C, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML18052B440	List: IR 05000255/1987030 IR 07100116/2012014 ML18052B439
References
50-255-87-30, IEIN-86-107, IEIN-87-031, IEIN-87-032, IEIN-87-039, IEIN-87-31, IEIN-87-32, IEIN-87-39, NUDOCS 8801120398
Download: ML18052B442 (22)

Text

u~s. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-255/87030(DRSS)

Docket No. 50-255 License No. DPR-20 Licensee:

Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:. Palisades Nuclear Generating Pla.nt Inspection At:

Palisades Site, Covert, Michigan Inspection Conducted:

November 16 through December 14, 1987 Inspector:

C. F. Gill

. C.1-.~

Accompanying Inspector:

M. A. Kunowski Approved By:

L. R. G~

Facilities Rad1~tion Protection Section Inspection*Summary--

1-J/-88 Date Inspection on November 16 thtough December 14, 1987 (Report No. 50-255/87030(DRSS))

Areas Inspected: *Routine, unannounced inspection of the radiatio11 protection program including:

organization and management controls, interna*1 and external exposure controls, control of radioactive mat~rials and contamination, training and quaHfication, audits and.:!ppraisals, radwas'Ce, transportation, and the ALARl progra Also, licensee responses to certain NRC Information Notices,*~ertain LERs, and open items were reviewe Results:

Two violations were identified (failure to follow Process Cont~ol Program and radwaste burial site requirements - Section 14; and failure to follow Department of Transportation Regulations - Section 15).

8801120398 880105 PDR ADOCK 05000255 Q

PDR

• DETAILS Persons Contacted

• 0. Andersen, Senior Quality Assurance (QA) Consultant

1. • C. Axtell, Heaith Physics Superintendent

1. • W. Beckman, Radiological Services Manager

• E. Boque, Radiological Safety Supervisor

• J. Brunet, Senior Emergency Planning Coordinator

• N. Campbell, Senior Health Physicist G. Ellis, Radiological Safety Supervisor

• R. English, Corporate Health Physicist

• R. Fenech, Operations Superintendent

• M. Grogan, Radio.logical Materials Control (RMC) Supervisor K. Haas, Reactor Engineering Superintendent

• J. Had1, QA Consultant

• R. Henry, Radiological Safety Supervisor

• 0. Hoffman, Plant General Manager

1. L. Kenaga, Staff Health Physicist

• C. Kozup, Technical Engineer

• D.- Malone, Nuclear Licensing Analyst

• R. Margol, QA Administrator

• M. Mennucci, Radiological Safety Supervisor

• T. Neal, RMC Administrator

• R. Vincent, Plant Safety Engineering

• E. Swanson, NRC Senior Resident Inspector N. Williamsen, NRC Resident Inspector The inspector*s also c.ontacted other licensee employees including radiation protection technicians and members of the engineering and oper~tions staffs~

--

• Denotes those present at the e~it meeting on November 20, 198 #Denotas thpse prasent at the exit meeting on December 14, 1937. General This inspectiori, which began at 1:00 p.m. on November 16, 1987, was conducted to review the operational radiation protection and radwaste programs, including organizati<<n and management controls, internal and external exposure controls. control of radioactiv* materials and contamination, training and qualification, audits and appraisals, radwaste, transportation, and the ALARA progra Also, licensee responses to certain NRC Information Notices, certain LERs, and open items were reviewe During plant tours, no signiffrant access control, posting, or procedure adherence problems were identified; housekeeping wa~ adequate considering that the plant had just completed an extended outage.

• . *

Licensee Actions on Previous Inspection Findings (IP 92701)

(Closed) Open Item (255/85010-01):

Review technical specification change request concerning the organizational position of the Radiation Protection Manager (RPM).

A technical specification change request concerning the organizational position of the RPM was submitted to NRR in letter dated September 29, 1986, as supplemented by submittals dated March 19 and April 9, 198 In a letter, dated October 21, 1987, NRR issued Amendment No. 108 to Provisional Operating Licensee No. DPR-20 for the Palisades Plant, including Figure 6.2-2 of the Technical Specifications which defines the organizational position of the RP The licensee stated that the license amendment would be implemented on November 20, 198 This matter is considered close (Open) Open Item (255/85011-02):

Demonstrate operability of replacement liquid effluent monitor RE 104 Partially due to the delay incurred by the necessity of seismic evaluation approval, the new monitor has not been installed. This matter will be reviewed.further during a future inspectio (Open) Open Item (255/85019-01):

Implement actions to prevent future flooding of the south radwaste building as a result of cooling tower overflow event The licensee presently plans to move the dry-active waste (DAW) process equipment to a new proposed building *which would be located adjacent to the east radwaste buildin The south radwaste building would then be used for non-radiological storage. Construction is expected to be completed in 1988. This matter will be reviewed further during a future inspectio (Closed) Open Item (255/86012-03):

Review administrative controls to limit filter damage pro~lems associated with fire protection deluge system The licensee initiated Action Item Record (AIR)

.

No. A-PAL-86-091 in response to this Open Ite The completed AIR and*

ass.ociated document.ation were reviewed; the corrective actions, includi;ig procedural revisions, taken in response to inspector concerns appear adequat (Open) Unresolved Item (255/86020-01):

Disposition of contaminated material associated with cooling tower overflows/flooding of the south radwaste buildio By a letter dated November 12, 1987, the licensee requested pursuant to 10 CFR 20.302 in-place retention of contaminated soil adjacent to the south radwaste buildin On November 14, 1987~ the cooling tower overflowed flooding south radwaste building and further contaminated soil adjacent to the building. Since the survey results stated in the November ~2, 1987, submittal to the NRC are invalid, the licensee is evaluating various regulatory options. This matter will b~

reviewed further during a future inspectio (Open) Unresolved Item (255/87005-10):

Review method of whole-body exposure determination and reporting in accordance with Form NRC-5 requirement The licensee has performed an internal study regarding conformance to Form NRC-5 requirements. This matter remains open pending review of the licensee's stud * *

(Open) Open Item (255/87005--11):

Review personnel frisking policy and feasibility of additional frisking unit The licensee is considering purchasing shielded frisking booths which would be installed in the *

engineering safeguards area and near the access to the spent fuel p6o The licensee has purchased three state-of-the-art personnel -contamination monitors; once installed and operational, these monitors should allow the licensee to reduce reliance on whole-body frisking by hand-held frisker This matter will be reviewed further during a future inspectio (Closed) Ooen Item (255/87005-12):

Review actions taken to strengthen controls for lR/hr area egres Corrective actions outlined in the licensee's response dated August 19, 1987, were reviewed; no problems were note (Closed) Open Item (255/87005-13):

Review policy for dedicated multi-job radiation protection coverag Corrective actions outlined in the licensee's response dated August 19, 1987, were reviewed; no problems were note Organization and Management Controis (IP 83522)

The inspectors reviewed the licensee's organization and management controls for the Radiation Protection Program including the organizational structure and staffing, staff stability, effectiveness of procedures and other management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesse.

Currently, all 25 station Radiation P-rotection Technician (RPT) positions are filled. There are 14 Senior Technicians, three Technician !I's, four Technician I 1 s and four Technician Trainees. About 32% of these RPTs have less than two years of applicable experience and do not.meet the selection criteria stated in ANSI 18.1-1971 for technicians in responsible positions; approximately 20% of the RPTs were hired or transferred to the Radiological Safety Department (RSD) within the last year. Although overall RPT staff experience is improving somewhat, the turnover rate remains significan Four contract RPTs are currently augmenting the Radiation Protection Staff while recent hirees and transferees undergo trainin The RSD supervisory, managerial and support staff includes the Radiological Services Manager, the Health Physics Superintendent, five Radiation Safety Supervisors, four Health Physicists, the RMC Supervisor, a Nuclear Operatiqns Analyst (in the RMC section), a Senior Engineering Technician, and two Health Physics Specialists; the average service time is about 11 year Management involvement in radiation pr6tection is evident in that several existing weakness correction programs have been strengthened including lessons learned during a radiation protection program review by RSD staff at Kewaunee Nuclear Power Plant, the five-year exposure reduction plan, the radiological work practice manual, and a broad-scope action plan to improve the overall RSD progra Examples of program improvements recently implemented include increased instrument maintenance, a new job-coverage

training course, RSD meetings with worker groups in other departments to encourage good radiation worker practices, reduction of numerous hot spots, adding radiation worker practices performance appraisal elements for all appropriate plant workers, establishment of a Technician Task Force to review RP practices, broadening experience level of first and second line supervision by attending conferences and special training courses, and establishment of a special dedicated decont~mination cre However, the licensee has been slow to implement numerous other improvement items reportedly because of budgetary restraints; examples include modifications of access control and the cold laboratory, laundry area improvements, improvement of frisking practices, correction of the south radwaste building flooding problem, gray lab improvements, and correction of CROM leak-dff airborne, volume r2duction system and highly contaminated tank problem No violations or deviations were identifie.

Training and Qualifications (IP 83523)

The inspectors reviewed the training and qualifications aspects of the licensee's radiation protection, radwaste, and transportation programs, including:

changes in responsibilities, policies, programs and methods; qualifications of newly-hired or promoted radiation protection personnel; and provisions for appropriate radiation protection, radwaste and transportation training for station personnel. Also reviewed were management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesse In October 1987, the licens*:-~ received INPO accreditaiion of the Radiat~on Safety Technician Training i'l"ogra Training and qualificati.J,1s records of selected radiation prote~*~ion staff members and contract RPTs were reviewed including confor-mar*.;e to ANSI N18.l-197i sel~ction criteria and Regulatory Guides 1.8 and 8.27; no problems were note The lice~see has recently inproved the continuing training program for the RPTs, th*e professional

-~aff, and the first and second line supervisor The planned RPT continuing train~ng prcgram discussed in Inspection Report No. 50-253/87005 has been fully implemente fhe inspectors selectively revi1~~ed training course lesson plans associated with this program; the traiiiing topics appear appropriate and are supplemented by special courses such as plant systems and observation training. Selected members of the-radiological s'afety professional staff and supervision have attend.~d professional society meetings, INPO training activities, and special cff~ite courses in engineering economics, problem solving and decision making~ excellence in supP.rvision, and ALARA progr-ams; the information gleaned by

!~dividuals attending these courses appears to be well-shared within the R~D through the continuing training program, special onsite training ses~ions, or by memoranda.

No violations or deviations were identifie * External Exposure Control (IP 83524)

The inspectors reviewed the licensee's external exposure control and personal dosimetry programs, including:

changes in facilities, equipment, personnel, and procedures; use of dosimetry; planning and preparation for maintenance including ALARA considerations; and required records, reports, and notification Exposure records of plant and contractor personnel for 1987 were selectively reviewe No ~xposures greater than limits in 10 CFR 20.101 or the station's annual administrative action level of 4.5 rem for whole-body dose equivalent were note The licensee tracks and manages personal doses with three computer programs:

(1) the Management Information Dose Tracking System (MIS), described previously in Inspection Reports No. 50-255/86012 and 50-255/87002, tracks self-reading dosimeter (SRO) doses for individuals; (2) the NUCPAS system maintains the primary TLD dose information to satisfy 10 CFR 20 requirements; and (3) the

"daily dose" program is the licensee's tool.for controlling dose based on SRD The.licensee applies a correction factor to SRO values to correct for the over-response of SROs relative to TLD The runn{ng dose total in this program is updated when primary TLOs are processe The primary TLDs issued to RPTs and to auxiliary operators monitor neutron dose as well as beta/gamma dos Primary TLDs routinely issued to other individuals monitor only beta/gamma dose. Requirements for extremity monitoring are described in the licensee's procedure HP 2.29, Revision 2, "Extremity and Special Monitoring."

Extremity dosimetry is required whenever the contact dose rate of the component to be worked is five (5) times greater than the ambient dose rate {measured at 18" from the component surface) and the ambient dose rate is greater than 50 mR/h Individual Harshaw TLD chips or Panasonic element plates (with four TLO elements) are routinely used for extremity dosimetr The* inspectors reviewed the 1986 report covering occupational exposure'

(report required by Technical Specification 6.9.l.b.) and the 1986 summary report of personnel monitoring information recorded by the licensee for individuals for whom personnel monitoring was provided (report required by 10 CFR 20.407).

The person-rem totals in the occupational report are based on SRO readings adjusted by a correction factor to equal the primary TLD dose totals. The summary report indicated no individuals received more than 5 rem total dose in 1986. *No problems were identified by the inspector During plant tours, the inspectors observed the use of temporary lead blankets to reduce exte~nal exposure during maintenance activities, in general access areas, and near frisker stations where the background was hig Except for the shielded frisking station adjacent to the spent fuel pool access (see Section 8), no problems were note The inspectors a 1 so reviewed a QA survei 11 ance report (No. S-QP-87-58), conducted in October 1987 to verify compliance with procedure HP 1.6, Revision 1,

"Control and Use of Shielding and Associated Equipment."

The surveillance resulted in no findings and two observations concerning

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missing signatures and missing postings (on shielding hung in containment).

The observation on the missing signatures has been adequately addressed by the licensee. The licensee's corrective action for the missing postings was not reviewed by the inspectors because the reactor was at powe No violations or deviations were identified by the inspector.

Internal Exposure Control (IP 83525)

The inspectors reviewed the licensee's internal exposure control and assessment programs, including:

changes to procedures affecting internal exposure control and personal exposure assessment; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements; planning and preparation for maintenance including ALARA considerations; and required records, reports, and notification The inspectors reviewed the licensee's whole-body counter (WBC)

operation, calibrations, and procedure Presently, the licensee uses two Helgeson 1100-It-Yourself" WBCs, each equipped with a stationary bed and a movable 8 11 x 4 11 Na! detecto Routine counts of personnel require seven to eight minutes per person and are usually performed by one designated individual, although all RPTs are qualified to operate the unit Shortly after a count is performed, the data obtained during the count is transmitted to the vendo Approximately every two weeks, a wr"i tten evaluation of a 11 counts performed in the previous two weeks is sent to the licensee from the vendor. This evaluation 1s reportedly a refinement of the initial~ immediately available results that are generated by the *computers that are part of the WBC syste The inspectors reviewed the 1986 annual calibration of the WBCs. _The counters are calibrated annualli by the vendor using a masonite phantom and NBS-traceable sources of mock I-131, Co-60, and Cs-13 The calibrations are intended to verify that the accuracy and precision of the units are within the vendor's recommended values. According to the written records of the calibrations, the accuracy and the precision of the licensee's WBCs are within the vendor's recommended value No problems were identified by the inspector The licensee reported to the inspectors that WBC data indicated that in 1986, only one i~d~vidual received greater than 1% maximum permissible body burden (MPBB) and in 1987 to date, four individuals have each received more than 1% of the MPBB; however, none of the intakes exceeded 5.5% MPB A brief discussion of the four intakes in 1987 is given belo The intake in 1986 was previously discussed in Inspection Report No. 50-255/8700 Hot Particle Incident The inspectors reviewed the licensee's investigation of an intake of a

.

"hot particle" (radioactive particle) into the upper respiratory tract.of a maintenance worke On February 17, 1987, the worker set off the exit

portal monitor alarm in the security building. Subsequent contamination surveys of the individual by a RPT with a portable hand-held frisker revealed only low-level activity on the individual 1 s undershirt; however, the individual continued to activate the portal monitor alarm without the undershir Whole body counts of the individual were then performed and indicated the presence of approximately 300 nCi of Co-60 localized in the throat area of the individua On February 18, 1987, a whole-body count apparently indicated that the particle had moved into the individual's lung/upper torso region. This count indicated that the activity of the contamination was approximately 260 nCi, a value confirmed by the follow-up report provided by the WBC vendo On February 19, 1987, two whole-body counts indicated no Co-60 activity in the individua The licensee has assumed that the particle was expelled from the individual sometime between the last count on February 18, 1987, and the first count on February 19, 198 Because the individual had a severe cold during the incident and *because the individual stated that he had expectorated much phlegm during the interval between the two whole-body counts, the licensee believes that the particle was expelled in the phleg Efforts to locate the particle at th~ individual's residence with a portable frisker were unsuccessful, The licensee's investigation into the incident concluded that the particle intake probably took place while the individual was performing maintenance on a charging pum Whole-body counts of the two workers who were with the individual during the maintenance indicated no internal or external contaminatio The three individuals apparently were dressed in the required full set of anti-contamination clothing during the repair wor As allowed by the radiation work permit (RWP), respirators were not worn during the wor Smear and radiation surveys of the work area indicated no unusually high contamination levels; however, radioactive metallic grinding residue was found in a bag that had been used to hold parts during the pump repai The residue was analyzed and found to contain mainly Co-60 with smaller amounts of co~s8, Mn-54~ Cs-134 and Cs-13 During the incident investigation, the individual stated to the licensee that during the pump repair, he rummaged through the bag searching for a par Based on this and a statement by the individual that du~in~ the repair he may have unknowingly wiped his nose on his anti-C's or touched his face with his gloves, the licensee believes that the particle was removed from the bag by the worker when he was searching for the part and was subsequently taken into the worker's nose or mout Based on a conservative assessment of the individuaJ's internal dose from the particle, the licensee has assigned 80 mrem to the individual's permanent whole-body dose recor The inspectors* noted no significant problems regarding the licensee's investigation of the inciden Personnel Contamination in the Treated Waste Room On May 29, 1987, three janitors working in the Treated Waste Room were contaminated by airborne radioactive material apparently as a result of a pressure surge in a faulty or improperly connected drain system.

Whole-body counts performed on the individuals after the event indicated nanocurie quantities of I-131, -133 and -135; and of Cs-134 and -13 *

Subsequent decontamination efforts removed from each of the three workers all of the contamination except for several nanocuries of I-133.,

The largest I-133 burden, approximately 16 nanocuries, corresponds to 5.5% MPB This burden is well-below the licensee's limit of 1080 nanocuries, which corresponds to a 40 MPC-hour acute exposur The licensee's evaluation of the cause of the pressure surge that resulted in the contamination and the steps taken to prevent recurrence will be reviewed during a future inspection (Open Item No. 255/87030-01).

No violations or deviations were identified by the inspector.

Control of Radioactive Materials and Contamination (IP 83526)

The inspectors reviewed the licensee's program for control of radioactive materials and contamination, including adequacy of supply, maintenance, and calibration of contamination survey and monitoring equipment; effectiveness of survey methods, practices, equipment, and procedures; adequacy of review and dissemination of su*rvey data; and effectiveness of methods of control of radioactive and contaminated materjal Al.l surveys, routine and special, are reviewed by the duty HP for completeness and any unusual condition The inspectors selectively reviewed records of routine and special radiation and contamination surveys conducted to date in 198 No problems were identifie Past programmatic problems associated with the licensee's whole-body frisking policy are discussed in Inspection Report No. 50-255/8700 During plant tours conducted during this inspection, it was noted that the licensee has n*ot yet taken adequate corrective action; for example, the engineering safeguards area does not have a frisking station and two of the three friskers located in a temporary shielded area adjacent to the spent fuel pool access were in a radiation_ background which was too high to permit their effective use (plant policy does not allow the use of hand-held friskers in areas which are at or above 300 cpm.)

The licensee is considering purchasing shielded frisking booths for the above delineated area The licensee has purchased three -

state-of-the-art personnel contamination monitors; once installeq and operational these monitors should allow the licensee to reduce reliance on whole-body frisking by hand-held frisker A 1987 station goal is to reduce the percent of auxiliary building floor area contamination from 38% (in December 1986) to. 22%; however, by the end of October the contamination had risen to 47%.

The licensee estimates that the contamination would be about 32% if contamination due to work in progress was subtracted from the total; the baseline goal for non-work in progress contamination is 11%.

The licensee currently has four upgraded janitors assigned to auxiliary building decontamination; this level of effort is significantly below that of the initial Plant Material Condition Improvement Project (see Section 7.f of Inspection Report No. 50-255/87005).

The failure to meet the auxiliary building decontamination goal appears to represent a management weakness and may be a contributing factor regarding recurrent personnel contamination problems (see Section 9).

• *

No violations or deviations were i~entified.

Personnel Contamination Reports (IP 83526)

Procedure No. HP 2.18, "Personnel Decontamination,** requires that personnel contamination reports (PCRs) be completed when portal monitor alarms indicate contamination or personnel frisks yteld greater than 100 cpm above backgroun PCRs are evaluated and findings summarized in reports issued to the Health Physics Superintenden The reports address the number and type of personnel contamination events, the plant location where the contamination is believed to have occurred, and the apparent cause as identified by the HP technician completing the repor There was a total of 397 personnel contamination events (PCEs) in 1986, 106 skin and 291 clothing (215 shoe) contamination The licensee indicated during this inspection that until 1987, it was common for RPTs not to record PCEs involving shoe contamination if shoes could be quickly and easily decontaminated; thus, the number of 1986 shoe contaminations is probably understate The apparent causes and proposed corrective actions for the preponderance of shoe contaminations involving

indfviduals who had entered the RCA but had not entered any posted contaminated areas were addressed by the HP Superintendent in a memorandum dated -January 20, 198 Corrective actions include changing heavily used step-off-pad~ (SOPs) daily, masslin-mop the "non-contaminated" areas of the auxiliary building daily, surveys of masslin after wide-area mopping, and decontamination of areas where the masslin mopping detected significant contaminatio.

'

The 1987 goal for PCEs is 200; as.of October 31, 1987, 262 PCRs (55 skin, 207 clothtng) had occurred of which 181 were shoe contaminations. It is thus apparent that the licensee's corrective actions regarding shoe contaminations has not been particularly effectiv On June 25, 1987,.

the HP Superintendent issued a plant memorandum which noted the continuing PCE problem and apparently excessive shoe contaminations; the memorandum lists recently identified root causes, the need for more thorough decontamination including HVAC ducts and floor drains, and the need for all managers, superintendents, and first-line supervisors to ensure that radiation workers take an active interest in reducing contamination incident Included among the special 1987 efforts to reduce PC Es are monthly QA PCE surveil 1 ance audits, monthly RSD PCE reports, upgr~ding decontamination worker training, RSD meetings with worker groups in other departments to encourage g9od radiation worker

• practices, and adding radiation worker practices to performance appraisal elements for all appropriate plant worker The licensee's trend plot of PCE per 1,000 RCA entries indicate a significant decrease during 1987; however, the inspectors are uncertain regarding the validity of this claim given the large monthly variances in the data and uni~ue nature of the reasons for the PCEs associated with each data point.

No violations or deviations were identified by the inspector *

1 Radiologicar Incident Reports (IP 83522)

Procedure No. HP 1.3, "Investigation of Radiological Incidents,"

identifies occurrences that may be classified as Radiological Incidents, including violations of 10 CFR 20 or Palisades Radiation Protection Procedures; and significant personnel contamination event Radiological incident reports (RIRs) may be initiated by any plant worker; however, most are written by radiation protection personne The Radiological Services Supervisor with cognizance over the activity directly involved is responsible for the initial evaluation of the RI The Health Physics Superintendent provides technical assistance and determines if a deviation report or event report are required in accordance with Administrative Procedure No. 3.03 "Corrective Actions." All RIRs concerning violations of administrative portions of the Technical Specifications require review by the Plant Review Committe Fifty-three RIRs were written for 1986, one was cancelled; as of October 28, 31 RIRs have been written for 198 RIRs were selectively reviewed by the inspectors for significance, corrective actions and timeliness of corrective action Most reports appeared to have adequate and timely corrective actions; disciplinary action was taken where deemed warranted by the license One reason that the number of RIRs is quite low is that in order for a RIR to be generated, a radiological incident must be quite significant and satisfy one of several limited classification criteri. Maintaining Occupational Exposures ALARA (IP 83528)

The inspectors reviewed the-licensee's program for maintaining occupational exposures ALARA, including changes in ALARA policy and procedures; ALARA considerations for maintenance and refueling outage; and est~plishment of goals and objectives, and effectiveness in meeting the Also reviewed were management techniques used to implement the ;

program and experience concerning self-identification and correction of programmatic weaknesse The pr.ofessional ALARA staff consists of an ALARA Coordinator and five technicians; although the technicians periodically are assigned job coverage duties, at least three RPTs are assigned to the ALARA group at any given tim The ALARA Coordinator is a Radiological Safety Supervisor who is responsible for the ALARA/RWP pr.ogra The ALARA staff appears to have the proper qualifications, experience, expertise, and dedication to establish and maintain an effective ALARA progra The licensee prepares job history files on all jobs which require an ALARA review (usually jobs with projected three or greater person-rem exposure).

The licensee has developed more than 200 job history files; repetitive tasks are kept in the same job history file. Job history files nominally contain the pre-job checklist, procedures/work plan, previous job history, radiation work plan, RWPs, surveys, logbook entries, post-job comments, and any additional comment Significant generic lessons-learned are entered into the Radiological Work Practices

• Manual; the licensee presently has about 50 good practice instructions in the manual divided into the categories of maintenance, radiation safety, contamination control,. chemistry, operations, and miscellaneous work

'

practices. The inspectors selectively reviewed portions of the Radiological Work Practices Manual and the job history files; no significant problems were note The 1986 total whole-body dose was 637 person-rem which was higher than planned; due primarily to exposure received in the unplanned continuation of the maintenance outage which began in May 198 The 1987 ALARA goil is 425 person-rem; the exposure through November 16, 1987 is estimated by the licensee to be about 350 person-re No violations or deviations were identifie. Gaseous Radioactive Waste (IP 84724)

The inspectors reviewed the licensee's gaseous radwaste management program, including: changes in equipment and procedures; gaseous radioactive waste effluents for compliance with regulatory requirements; adequacy of required records, reports, and notifications; process and effluent monitors for compliance with maintenance, calibration, and operational requirements; and experience concerning identification and correction of programmatic weaknesse Sampling and release methods and procedures, records and reports appear adequat The inspectors selectively reviewed records of gaseous radioactive releases made during 1986 and to date in 198 These records included the documentation associated with the individual releases and analyses, and the summary information presented in the Semi-Annual Radioactive Effluent Release and Waste Disposal Reports. There were 47 gaseous radioactive waste batch releases during 1986; the total gaseous releases*of noble gas, radioiodine, and tritium were 1.73E+2, 2.43E-3, and 3.13 curies, respectively. There were 11 gaseous radioactive waste batch releases during the first half of 19°87; the total gaseous release of noble gas, radioiodine, and tritium were 6.27E+2, 6.59E-3, and 1.62 curies, respectivel From. May 19, 1986 to April 16, 1987, the plant was in an extended maintenance outage; consequently, gaseous effluent releases for 1986 and the first half of 1987 reflect lower than anti~ipated gaseous release Two recent events may indicate minor programmatic problems regarding operation of the waste gas syste On June 4, 1987, two compensatory flow estimates were not made as required by Technical Specification (TIS) 3.24.2 during a waste gas batch release while flow indicator FI-1121 was inoperabl The licensee issued LER 87-017 regarding the incident, pursuant to 10 CFR 50.73(a)(2)(i); the LER was reviewed by the resident inspectors and closed in Inspection Report No. 50-255187022(DRP).

On July 8, 1987, an inadvertent release of a waste gas decay tank (WGDT)

occurred; although the release was monitored and constituted only 2.9% of the allowable offsite dose rate per 10 CFR 20.106, a violation of TIS 3.24.6.1 occurred. TIS 3.24.6.1 requires that waste gas in a WGDT be held for 15 days prior to release; the waste gas was released from the *

• in-service WGDT due t~ the failure of personnel to follow several plant procedures and policies (see Inspection Report No. 50-255/87018(DRP)).

The licensee issued LER 87-020 regarding the incident, pursuant to 10 CFR S0.73(a)(2)(i); the LER was reviewed by the resident inspector and closed in Inspection Report No. 50-255/87024(DRP).

Because the above events appear to meet the criteria of 10 CFR Part 2, Appendix C, for self-identification and correction of problems, no Notices of Violation were issue No violations or deviations were identified by the inspecto.

Liquid Radioactive Waste (IP 84723)

The inspectors reviewed the licensee's liquid radwaste management program, including~ changes in equipment and procedures; liquid radioactive waste effluents for compliance with regulatory requirements; adequacy of required records, reports, and notifications; process and effluent monitors for compliance with maintenance, calibration, and operational requirements; and experience concerning identification and correction of programmatic weaknesse Sampling and release methods and procedures, records and reports appear adequat The inspectors selectively reviewed records of liquid radioactive releases made during 1986 and to date in 198 The records included the documentation associated with the individual releases and analyses, and the summary information presented in the Semi-Annual

• Radioactive Effluent Release and Waste Disposal Report There were 140 liquid radioactive waste batch releases during 1986; the total tritium released was 63.2 curies. There were 28 liquid radioactive waste batch releases during the first half of 1987; the total tritium released was 17.5 curie On July 31, 1985, a cooling tower overflow flooded the south radwaste.

building (SRB) resulting in contamination of soil adjacent to the SRB :

(see Section 4 of Inspection Report No. 50-255/86020).

By a letter dated November 12, 1987, the licensee requested the NRC, pursuant to 10 CFR 20.302, to approve the in-place retention of contaminated soil adjacent to the SR On November 14, 1987, a subsequent cooling tower overflow again flooded the SRB resulting in further soil contaminatio Since this most recent flood invalidated survey results stated in the November 12; 1987 submittal to the NRC, the licensee is evaluating various regulatory option The licensee presently plans to move the dry-active waste (DAW) process equipment in the SRB to a new proposed building adjacent to the east radwaste buildin The SRB would then be used for non-radiological storag The contamination in the SRB has periodically contaminated adjacent soil due to cooling tower overflow at least since 1981; all attempts by the licensee to prevent these incidents has failed. This failure represents a significant weakness regarding resolution of a technical problem.

No violation or deviations were identified by the inspector *

14. Solid Radwaste (IP 84722)

The inspectors reviewed the licensee's solid radwaste management program, including:

changes to equipment and procedures; processing, control, and storage of solid wastes; adequacy of required records, reports, and notifications; implementation of procedures to properly classify and characterize waste, prepare manifests, and mark packages; and experience concerning identification and correction of programmatic weaknesse *The inspectors selectively reviewed solid radwaste historical data for volume, activity, and classification of wastes generated, stored, and shipped during 1986 and to date in i98 The radioactive waste report dated November 16, 1987, indicated that the licensee had 1,400 ft3 of solid radwaste in temporary storage onsit In 1986 the licensee made 13 shipments to burial sites consisting of 8,445 ft3 of which 7,056 ft3 was DAW; there were six shipments made during the first half of 1987 consisting of 1,203 ft3 of which 980 ft3 was DA Much of the radwaste had been gen~rated during the plant's extended majntenance outage from May 19, 1986 to April 16, 198 The licensee continues to hand frisk each item deposited in clean trash containers. About 40% of the bags contain contaminated material; and 60% of the bags containing contaminated material did not indicate that the bag contained contaminated material by frisking the outside of the ba Only 6% of the material by weight is contaminate About 1,000 bags of material are stored in the east radwaste building awaiting frisking; approximately 600 bags of clean" material was recently processed as DAW rather than incur the cost of the hand frisk procedure The licensee*is considering calibrating an existing bag monitor to reduce the time and expense associated with the current sorting metho T~e i~spectors toured solid radwaste storage facilities and observed

,

processing equipment in the east and south radwaste buildings and in the auxiliary buildin No significant problems were note DAW is sorted and compacted in the south radwaste buildin The DAW is compacted into 98 ft3 volume metal boxe High activity resins and filters are mainly stored in the south radwaste building, although some are stored in the east radwaste building. Section 13 discusses the periodic flooding of the south radwaste building due to cooling towe~ overflow incident As discussed in the licensee's Process Control Prqgram (PCP), Revision 2, March 1, 1987, Palisades utilizes a Waste Chem volume reduction and solidification system (VRS) to process various radioactive liquid waste stream The process uses heat to evaporate water from the waste, thus reducing volum The residue is then encapsulated in an asphalt matri The end-product is designed to be a monolithic, free-standing solid with no free liqui Fifty-gallon drums are used to contain the encapsulated waste for storage, shipment, and burial.

• During this inspection, the inspectors reviewed the circumstances of a recent problem with a drum of solidified evaporator concentrates that had been shipped to the burial site in Barnwell, S Information on the problem was gathered mainly from interviews with licensee representatives; a letter dated October 15, 1987, from the State of South Carolina, Bureau of Radiological Health, to the licensee; and licensee Event Report No. E-PAL-87-054 (D-PAL-87-145).

On September 28, 1987, a Barnwell official noti"fied the licensee that the radwaste in one drum (Drum No. 184)

in a shipment of 21 drums of solidified evaporator concentrates that recently arrived at the Barnwell site (shipment No. 0987-187) was found to contain 750 milliliters of liquid and to have been improperly solidifie Licensee representatives travelled to the site and viewed the contents of the dru Drum No. 184 and another drum, Drum No. 183, were returned to Palisades and subjected to further tests. The tests indicated that the contents of Drum No. 183 were in a condition similar to that of contents of Drum No. 184 in that Drum No. 183 was found to contain about 2 liters of l'iqui In a letter dated October 15, 1987, the State of South Carolina cited Palisades for two infrQctions of the burial site license requirements because of the problems found at the burial site with the contents of Drum No. 18 The infractions were 1) the waste transferred for disposal was not the required free-standing monolith and it exhibited characteristics of a free-flowing, viscous liquid, contrary to the requirements of Condition 33.E of South Carolina Radioactive Material License No. 097, Amendment 43 and 2) the waste contained liquid in excess of regulatory requirements, contrary to the requirements of Conditio.B of South Carolina Radioactive Material License No. 097, Amendment 4 The State also*t~mporarily prohibited Palisades from shipping asphalt-soli~ified waste to Barnwe11 until ~alisades determined and implemented c~rrective actio Li~ense~ repr~sentatives and the licensee's event report indicat~d thai parameter status records for the VRS showed that minimum temperatures *

were not mai~tained during the processing of the drum VRS operators also stated that they were having problems ~ith the system's boiler and with the te~perature controllers and recorder during the processing of those drum The licensee believes that the failure to maintain the proper temp~rature during the processing of the drums resulted in excess liquid residue in the waste and im~roper solidification of the asphal The minimum operating temperatures required to eli~inate liquid and to ensure proper solidification of the asphalt are specified in the licensee's PCP, as well as in Health Physics Procedure HP 6.10, Revision 1, "Processing Waste Through the Asphalt Volume Reduction System," and in System Operating Procedure SOP 18C, "Radioa:;tive Waste System-Solid."

Event Report No. E-PAL-87-054 concluded that the asphalt VRS process temperatures for four of the six drums in the associated process batch were 60° to 100°F lower than required process temperatures profiles for waste feeds specified in SOP 18C ahd 15° to 70°F lower ~han the minimum PCP temperatur *

The failure to operate the VRS at the proper temperatures and to meet Barnwell's burial ground requirements is a violation of TIS 3.24.7, which requires that the solid radwaste system be used at all times in accordance with the PCP to process wet radioactive wastes to meet shipping requirements and burial ground requirements (Violation:

255/87030-02)

One violation was identifie. Transportation Activities (IP 86721)

The i~spectors reviewed the licensee's transportation of radioactive materials program, including: determination whether written implementing procedures are adequate, maintained current, properly approved, and acceptably implemented; determination whether shipments are in compliance with NRC and DOT regulations and the licensee's quality assurance program; determination if there were any transportation incidents involving licensee shipments; adequacy of required records, reports, shipment documentation, and notifications; and experience concerning identification and correction of programmatic weaknesse *

In 1987 to date, the licensee made 45 shipments of radioactive material, mainly low specific activity (LSA) radwaste for burial and limited quantity samples sent out to be analyze Also, for 1987 to date, the licensee received 52 shipments of radioactive materials, including one shipment in which a 400 Ci sealed source of Cs-137 for a new movable calibrator was received. Solid radwaste shipments to burial sites are discussed in Section 1 The inspectors reviewed selected samples of shipping and receipt paper Overall, the licensee's program for transportation of radioactive material appearedto be in compliance with regulatory and procedural requirements; however, several significant problems were found by the inspectors and, are described belo *

Level Gauges In September 1987, the licensee transported 53 level gauges, each containing a seal~d source of Cs-137, from a Consumers Power coal-fired power plant to Palisade Fifty-one gauges each contained a 100 mCi source; the.other two gauges each contained a 2 Ci sourc Licensee employees transported the gauges in a licensee van from the coal-fired

• plant to Palisades on three successive days, September 14, 15, and 1 Inspection of the drums containing the gauges, now stored at the east radwaste building, indicated that the gauges had been transported in properly labelled 55-gallon drums; however, discussions with licensee employees involved with the shipment indicated that shipping papers were not prepared or used for the three shipment This is in violation of 49 CFR 177.817(a), that states that a carrier may not transport a hazardous material, including radioactive material, unless it is accompanied by a shipping paper that is prepared in accordance with 49 CFR 172.200-20 Failure to adhere to 49 CFR 177.817(a) is a violation of 10 CFR 71.5 which prohibits transport of any licensed

1 *

material-outside the confines of a plant or other place of use or delivery of licensed material to a carrier for transport unless the licensee complies with applicable regulations of the Department of Transportation in 49 CFR Parts 170-18 (Violation:

255/87030-03)

Leaking LSA Box In a letter dated April 15, 1987, the State of Washington notified the licensee that violations of U.S. DOT regulations and the conditions of Radioactive Materials License No. WN-I019-2, were identified by State inspectors for a shipment of LSA radwaste that arrived on March 9, 1987, at the burial site in Richland, Washington, for disposa One apparent violation was using a manifest that had not been approved by the State, a violation of Condition 40(a) of Radioactive Material License No. WN-I019-However, the licensee stated to the NRC inspectors that the licensee had previously received verbal approval for the manifest, but the employee who had given th~ approval is no longer employed in the State of Washington agency that regulates the burial site activities. The licensee stated to the NRC inspectors that if written approval for the manifest cannot be obtained, a previously approved manifest would be used for future shipment The licensee's resolution of this matter will be reviewed at a future inspectio (Unresolved Item:

255/87030-04)

The second violation was for inadequate quality control procedures. A small crack was found by a State inspector in one of the boxes of LSA dry-active waste. A small amount of dry, nonradioactive absorbent material had leaked out-through the crack. According to licensee representatives, the crack resulted from a weld failure and the manufacturer, in response to similar failures, has recently changed the welding specifications for newly constructed boxe The shipment of the box with the crack is a violation of 49 CFR 173.475(b), which requires that before each shipment of any radioactive materials package, the shipper ensure by examination or appropriate tests, that the package is in unimpaired physical condition, except for superficial mark Failure to adhere to 49 CFR 173.475(b) is a violation of 10 CFR 71.5 which prohibits transport of any licensed materials outside the confines of a plant or other place of use or delivery of licensed material to a carrier for transport unless the licensee complies with applicable regulations of the Department of Transportation in 49 CFR Parts 170~189. (Violation:

255/87030-03)

One violation with two examples were identifie Audits and Appraisals (IP 83522)

The inspectors reviewed reports of audits and appraisals conducted for or by the licensee including audits required by technical specification Also reviewed were management techniques used to implement the audit program, and experience concerning identification and correction of programmatic weaknesse *

The inspectors selectively reviewed radiation protection related QA surveillance reports to date in 198 The monthly QA personnel contamination surveillances are discussed in Section The QA section has also conducted several housekeeping and radiation worker practice surveillances; these surveillance reports indicate that the licensee has significant problems in these areas to date in 198 This matter was reviewed with radiation protection personnel and during plant tours by the inspectors, it appearsed that the licensee had made some progress in these area However, the response to the QA observations has not yet been fully successful and the progress that is being made (see Sections 4, 8, and 9), is at a slower than desirable rat QA should continued to frequently conduct housekeeping and radiation worker practice surveillance No violations or deviations were identified by the inspector.

Process Control Program (IP 84722)

Revision 2 to the Palisades Process Control Program. (PCP) was issued on March 1, 198 A complete copy of Revision 2 of the PCP was submitted to th~ Commission in the Semi-Annual Radioactive Effluent Release and Waste Disposal Report for the period from July through December 1986 per the requirements of TIS 6.1 Four changes were made to the PCP to answer the comments in the NRC correspondence dated December 30, 1986, "Safety Evaluation of the Revised ODCM and PCP."

Problems identified regarding the implementation of the PCP are discussed in Section 1 An earlier problem associated with the PCP program, which resulted in a Severity Level III violation, is discussed in Section 4 of Inspection Report No. 50-255/84001(DRSS).

No violations or deviations were identifie.

Effluent Reports (IP 84723 and 84724)

The inspectors selectively reviewed radiological effluent analysis results to determine accuracy of data reported in the Semi-Annual Radiological Effluent Release and Waste Disposal Reports for 1986 and the first half of 1987. TIS 6.9.3.1 states that the format and content of this report shall be in accordance with Regulatory Guide 1.21 (Revision 1)

dated June 197 No significant discrepancies from this regulatory guide were identified by the inspectors; however, the last two reports contain numerous corrections to erroneous information submitted to the NRC in the two previous report During an earlier inspection (Inspection Report No. 50-255/86020(DRSS)), the inspector noted errata were submitted to correct inspector identified errors in the 1983 and 1984 semi-annual effluent reports. Thus, it appears that the licensee has had problems regarding the accuracy of information submitted in the semi-annual effluent reports for several year No violations or deviations were identified.

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1 Offsite Dose Calculation Manual (IP 84723 and 84724)

2 Revision 2 to the Palis£des Offsite Dose Calculation Manual (ODCM) w~s issued for use on March 1, 1987. A copy of the changes in the ODCM was submitted to the Commission in the Semi-Annual Radioactive Effluent Release and Waste Disposal Report for the period from July through December 1986 per the requirements of TIS 6.18.2. A new section B. was added to address methodology for calculating effluents from Steam Generator Slowdown Vent and Atmospheric Dump Valve steam releases. This new section was added in response to a comment from the NRC correspondence dated December 30, 1986, "Safety Evaluation of the Revised ODCM and the PCP." Also, tables were updated regarding land use census results, critical receptor locations, and gaseous design objective annual quantitie No violations or deviations were identifie Facilities and Equipment (IP 83527)

The inspectors toured radiation protection facilities, obs~rved radiation equipment in use, and discussed plans for improving access control facilities and equipment with the health physics staf Newly procured or planned equipment and facilities which should enhance the radiation protection program include:

(1) the licensee has purchased three state-of-the-art personnel contamination monitors which should allow the licensee to reduce reliance on less sensitive portal monitors and whole-body frisking by hand-held friskers; (2) the licensee is considering purcha~ing two shielded frisking booths to be located in high ~ackground areas; (3) very higi. radiation area ingress/egress control has been improved by field ~edifications; (4) the quality of secondary TLDs has been improved by switching tu a four-element system (Panasonic-800); (5) a calibrator has been purchased for the calibration of ridiation measuring instrum~ntati~n high ranges; (6) more high and low velum~ air sampler systems have been procured; (7) the technician working area has been improved including th~ fabrication of a technician ready room; and (8) a new instrument mainten~nce and repair program has resulted in a 95% availability of the 248 radiation measuring instrument.

Licensee Event Report (LER) Followup (IP 92700)

The inspectors reviewed selected LERs to determi n.e that reportabil i ty

~equirements were fulfilled and adequate and tim~ly corrective action was ~ccompli~hed, including actions to prevent recurrenc In addition, each event was evaluated for previous similar events, root cause, and potential generic applicabilit The review consisted of in-office revi*..!W, direct observations, discussions with licensee personnel, and revi~w of record The event described in the following LER does not appear to constitute violations of Technical Specifications, regulatory requirements, or demonstrate significant programmatic weaknesses and is considered closed:

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L~R 255/87-033-00:

Detector Failure and Inoperability Greater than Seven Days Results in Technical Specification Special Repor On September 3, 1987, at 1230, h!gh range noble gas stack monitor, RIA-2327, was declared inoperable when detector output valves failed to fall within the acceptance criteria as defined in T/S Surveillance Procedure RR-84C, 11High Range Noble Gas Effluent Monitor RE-2327 Calibration." In accordance with Action Statement*

38 of TIS 3.24.2, the preplanned alternate monitoring instrumentation was installed and declared operable at 150 On September 10, 1987, after unsuccessful attempts to find and correct the problem the detector was sent to the manufacturer for repair or replacement. This LER was submitted by the licensee pursuant to Action Statement 38, which requires a Special Report be submitted if the instrument is not returned to operable status within seven day The following LER documents the licensee's failure to meet Technical Specifications. The violations appear to meet the criteria of 10 CFR Part 2, Appendix C, for self-iden~ification and correction of problem Therefore, a Notice of Violation is not being issued and the LER is considered closed:

LER 255/87-034:

Inadequate Procedure Results in Radioactive Effluent Technical Specification Noncomplianc On October 2, 1987 at approximately 0603, a plant RPT identified that the normal range noble gas stack effluent monitor, RIA-2326, and the normal range particulate stack effluent monitor, RIA-2325, were both inoperable due to a low flow conditio The RPT identified the condition during the performance of TIS Surveillance Procedure DWR-10, Stack Effluent Sampling; Calculation and Record The RPT immediately reset the low flow alarm and reinitiated flo Upon reviewing strip chart recorder results, the condition was deteymined to have existed for approxi~ately 13.3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> Further reviews also indicated no.

alternate sampling was performe This condit*:on is contrary to i Action Statement 37 of TIS 3.24.2, which requires an alternate grab sample be taken at least once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Tha operators did not identify the failure due to an inadequate surveillance procedure to demonstrate operabil.ity of the monitors and the lack of reflash capability within the alarm windo Planned corrective actions include modification of the alarm window to include reflash capabilities and the revision of the surveillance procedure to direct operators to review the ~t~tus of local stack flow indicator lights. The licensee did not tjentify an earlier similar occurrence of this T/S violation and t~e corrective actions planned for this event appear adequate to prev~nt recurrenc No violations or deviations were identified by the inspector NRC Information Notices (IP 92701)

The inspectors reviewed licensee action taken in response to selected NRC Information Notice.. *

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NRC Information Notice No. 86-107:

Entry Into PWR Cavity with Retractable Incore Detector Thimbles Withdraw The licensee stated tha~

the Pa 1 i sades p lc..nt does not have retractab 1 e i ncore detector thi mb 1 e NRC Information Notice No. 87-31:

Blocking, Bracing, and Securing of Radioactive Materials Packages in Transportatio The Plant Safety Engineering (PSE) staff interviewed the RMC Supervisor* and examined Palisades procedures and practices with respect to the shipment of LSA radwast PSE concluded that the current procedures and practices are sufficient to ensure adequate blocking, bracing, and securing of radioactive materials packages shipped from Palisade The inspectors discussed the matter with PSE and RMC personnel; no problems were note NRC Information Notice No. 87-32:

Nuclear-Grade Activated Charcoa vendor reportedly uses the testing notice designates as acceptabl Deficiencies in the Testing of The licensee's charcoal testing protocol which the information NRC Information Notice No. 87-39:

Control of Hot.Particle Contamination at Nuclear Power Plant The licensee reportedly has historically had relatively few fuel defect problems and no identified fuel-related hot particles; although, at least one significant corrosion hot particle incident has occurred (see Section 7). Based on primary coolant system chemistry and specific activity analysis, the licensee currently estimates about ten defective fuel pin During the next refueling outage, tentatively scheduled for October 1988, the licensee intends a full core inspection, possible fuel reconstitution, and a zero-defect fuel reloa Before the refueling outage, the licensee intends to initiate a comprehensive hot particle control progra The inspectors attended a licensee planning miating for this program;

~** problems were noted.

2 Plant Tours (IP 83524 and IP 8~528)

The inspectors toured the east and south radwast~ buildings, the auxiliary building, the shippi,~g and receiving building, and the material storage and trailer area adjacant to the* service buildin Radioactive materials controls, postings, and housekeeping in-these areas appeared adequat Exposure rate measurements made in these areas by the inspectors (with a Xetex Model 3058 survey meter) were in general agreement with posted licensee dat At the main access control poi;1t, during the licensee's daep backshift, the inspectors observed egress activities, including personnel dressed out in protective clothing ent~ring the RCA, the check-out of portable survey and sampling equipment, and personnel frisking upon leaving the RC No problems were noted with the observed ingress/egress activitie The inspectors also observed work being conducted in a contaminated area of the charging pump roo RW? requirements for protective clothing appeared to be fulfille.

Exit Meeting (IP-30703)

The inspectors met with licensee representatives (denoted in Section 1)

at the conclusion of the inspection of November 20, 1987, and by telephone through December 14, 198 The inspectors -summarizad the scope and findings of the inspectio The inspectors also discussed the likely informational content of the inspection report with regard to document~

or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents or processes as proprietar In response to certain matters discussed by the inspectors, the licensee:

a~

Acknowledged the apparent violation (Sections 14 ~nd 15) Acknowledged the inspectors' concern regarding the lice~see's evaluation of the cause of an airborne incident. (Section 7) Acknowledged the inspectors' concern regarding the acceptability to the State of Washington of the licensee's radioactive waste shipment manifest for (Section 15)

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