IR 05000289/1977034

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IE Insp Rept 50-289/77-34 on 771025-28 & 1107.Noncompliance Noted:Failure to Complete Release Records for Releasing Radioactive Gaseous Waste
ML19256D150
Person / Time
Site: Crane 
Issue date: 12/15/1977
From: Clemons P, Knapp P, Plumlee K
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19256D136 List:
References
50-289-77-34, NUDOCS 7910170647
Download: ML19256D150 (12)


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NUCLEAR REGULATORY COMMISSION i

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0FFICE OF INSPECTION AND ENFORCEMENT

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Report No. 50-289/77-34 Docket No. 50-289 License No. DPR-50 Priority Category C

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Licensee:

Metropolitan Edison Company P. O. Box 542 I

Reading, Pennsylvania 19603

Facility Name: Three Mile Island Nuclear Station, Unit 1 Inspection at: Middletown, Pennsylvania

f Inspection conducted: Octobe 5-28, and November 7, 1977

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Inspectors:

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/ NI[7 7 KArl E. Plumlee,' Radiation Specialist date signed (~')

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  • j Percy E. Clemons, Radiation Specialist date' signed

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date si ned

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Approved by:

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3' 77 Pete( J. Knapp, Chief, Radiation Support

'date signed Section, FF&MS Branch Inspection Summary; Insoection on October 25-28, and November 7,1977 (Report No. 50-289/77-34)

Areas Inspected:

Radioactive waste systems operations; analyses, monitoring and limiting of releases; records and reports of radioactive effluents; instrument trip settings, calibrations and tests; procedures; tests of containment air cleaning systems; and licensee events and corrective actions.

Upon arrival, areas where work was being conducted were examined to review radiation safety control procedures and practices.

The initial inspection and area examination was conducted during non-regular hours (October 25, 1977, 6:45 p.m. - 8:45 p.m).

This inspection involved 58 inspector-hours on site by two NRC inspectors.

Results:

Of the seven areas inspected, no items of noncompliance or deviations were identified in six areas.

One item of noncompliance was idt itified in one area (Deficiency -failure to complete the release records for releasing radioactive

'seous waste - Paragraph 6).

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Region I Form 12 (Rev. April 77)

I910170

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DETAILS 1.

Persons Contacted

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  • R. Dubiel, Supervisor of Radiation Protection and Chemistry E. Fuhrer, Operations Engineer

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  • C. Hartmann, Plant Operations Review Connittee, Vice Chairman F. Huwe, Radiation Protection Foreman

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I G. Kunder, Supervisor of Operations, Unit 1

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R. McCann, Radiation Protection Foreman i

T. Mulleavy, Radiation Protection Supervisor

  • J. O'Hanlon, Unit 1 Superintendent

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B. Smith er isor J. Smith,' Station Shift Suke dperation Foreman, RAD Was

  • denotes those present during the exit interview.

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The inspector also interviewed sevaral other licensee and contractor employees during the course of the inspection.

O 2.

Licensee Action on Previous Inspection Findings (Closed) Noncompliance (289/77-01) Omission of record entries

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required by the procedure for TLD badge processing.

Review of records indicated that the corrective actions on this item are acceptable.

(Paragraph 3)

i (Closed) Noncompliances (289/77-12 and 289/77-20) Failures to properly post High Radiation Areas.

Observation during plant tours and a review of survey records indicated that the corrective actions on this item are acceptable.

(Paragraph 4)

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(Closed) Noncompliance (289/77-18) Failure to perform a survey nece'ssary to post and barricade a high radiation area.

Observation during plant tours and confirmatory measurements indicated that timely surveys were being made and the corrective actions on this item are acceptable.

(Paragraph 4)

(Closed) Noncompliance (289/77-18) Unauthorized access into a High Radiation Area. Observation during off-shift and day-shift tourt indicated that the corrective actions on this item are acceptable.

(Paragraph 4)

(Closed) Noncompliance (289/77-18) Improperly issued Radiation Work Permit (RWP).

Review of active and completed RWP records, and'

observations during off-shift and day-shift tours of the facility, in'dicated that the corrective actions on this item'are acceptable.

(Paragraph 4)

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(Closed) Noncompliance (289/77-20) Failure to carry out procedures for solidification, p.ckaging, and shipping radwaste; and lack of procedures for certain operations.

Review of selected active and completed shipping re.:ords and waste operations records, observation of these operations, and a review of procedures and practices indicated that the corrective actions in these areas are acceptable.

(Paragraph 5)

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(Closed) Noncompliance (289/77-20) Failure to label containers of radioactive materials in compliance with requirementa of 10 CFR 20.203(f).

Observation of radwaste operations and containers indicated that the corrective actions on these items was complete.

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3.

Personnel Dosimetry

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l The licansee representative stated that the transition was completed on June 1,1977, from the use of a film badge service to the use of t'hermoluminescent dosimeters (TLD) that are evaluated on site for

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personnel beta-gama radiation dosimetry.

He stated that the s

change made it feasible to read out badges within a short time of

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the exposures and this provided improved control of exposures to i

personnel.

i 77- 01 : A previous inspection identified omissions of logbook information required by the procedure for TLD readout.

Reviews on subsequent inspections and on this inspection showed that the procedure had been revised, recordkeeping had been simplified, and acceptable system operation had been demonstrated.

The licensee

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had followed a consultant's recomendation to have the equipment rechecked by the supplier, before June 1,1977.

The constJtant's report indicated that the observed root mean square difference between badges given the same exposure, in sets of 20, on the annual calibration ranged from 4% to 7% (TLD's) and 4% to 8% (film badges).

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The licensee also provided twelve TLD badges ~to NRC:I eleven of which were then given known exposures to a Cesium-137 radiation source by the National Bureau of Standards.

The licensee was not informed of the exposure levels until the licensee had provided an evaluation of each badge. As listed below, the licensee evaluations had a negligible bias (-0.3% unweighted) for the eleven badges, and the root mean. square difference was 3.5% between the NBS exposures and the licensee evaluations.

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Badge Exposure Adjusted TMI Ser. No.

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TMI Evaluation Error (%)

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736 None (control)

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738 110 107-3 744 110 116

+5 735 230 237

+3

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734 300 31 2

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737 775 772

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739 775 776

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s 743 1250

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741 3075 2930-4 742 6000 5700-5

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i The inspector reviewed the monthly and annual calibration results

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and noted that additional tests would be required if a proposed ANSI Standard (N 324, "Therraoluminescence Personal Dosimetry Performance" HPSSC/N 13/42/WG-1), transmitted fc-coments on July 10, 1974, is implemented.

This would include different numbers of badges for testing, exposures to a greater range of gama energies, and exposures to beta radiation.

There is no requirement to supply the additional information in effect at this time.

The licensee calibrations and tests appeared to be acceptable under-the licensee procedures. The inspector had no further questions on these items.

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4.

Surveys, and High Radiation Area Access Control and Posting 77-12 and 77-18:

Previous inspections identified a failure to survey that led to a failure to post a high radiation area; another high radiation area that had been posted but the sign was removed to clear an entrance, then forgotten, and an example of an individual entering a high radiation area without authorization by the issuance of the required radiation work permit (RWP).

The inspector made confirmatory measurements during tours of the

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facility, and reviewed the survey records and the RWP records and the corrective actions on the above items.

No items of noncompliance were identified.

The corrective actions on these items appeared to be acceptable.

5.

Processing, Packaging and Shipping of Radwaste and Other Radioactive Materials

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Part of the inspection effort was to observe licensee procedures e s i _/

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and practices for shipping radioactive materials, and to review records of shipments, in order to determine compliance with regulatory requirements.

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The inspector observed as the licensee loaded several 50 cu. ft.

containers of solidified evaporator bottoms into the plywood overpacks on a trailer.

The inspector noted that sealant was applied to the joints in the overpack and dry absorbent material was packed in the space surrounding the waste container in each overpack.

77-20: A previous inspection identified failures to follow procedures for waste solidification packaging and shipping, and also a lack of authorized procedures for certain operations encountered in these areas.

During the inspection, the inspector reviewed the revised procedure, No. OP 1104-28, " Packaging and Solidification of Solid and Liquid Radwaste," Revision 5, August 31, 1977, and observed the workers adherence to procedures during the performance of these operations.

The inspector reviewed the active and the recently completed records and checksheets and also the labeling of containe.'s and the placarding of a vehicle for a radwaste shipment made during t.;e irspection.

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The licensee documentation had been reviewed to determine the disposition of containers that had been returned to the site because of observable leakage during transit in mid-June,1977.

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The containers had been drained, patched (if leaking) and shipped.

Licensee records showed that this was with concurrence by the Pennsylvania and the U.S. Department of Transportation in respect to the use of overpacks.

The licensee now makes an electrical conductivity check of each c.ontainer before it is used for waste solidification, which veri-fies the integrity of the corrosion resistant coating in the container.

None of the acceptable containers have leaked.

Efforts to recoat the unacceptable containers generally were ineffective.

The inspector reviewed the shipping records for shipments of radioactive waste, contaminated laundry and contaminated equipment shipped between April 20, 1977 and October 27, 1977.

No further items of noncompliance were identified and the licensee

corrective actions in the above areas appeared to be acceptable.

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Gaseous Effluent Records Technical Specifications 6.8.1 and 6.11, require adherence to procedures and Health Physics Procedure 1522, " Releasing Radio-active Gas Waste," requires in Sections, 5.45 to 5.59 that the quantity of radioactive material released during each Reactor Building Purge be calculated on a form 1622-5, " Total Noble Gas and Tritium Concentrations During Reactor Building Purg. :

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The inspector noted that there had been at least five Reactor Building purges between July 1 and September 30, 1976, and at least ten more between October 1 and December 31, 1976, but he found that no entries had been made on any of the forms 1622-5 attached to the, release records in the files for that period of time.

The licensee representative stated that no completed forms 1622-5 were found that corresponded to that period of time and he could not show that the indicated entries and calculations had been made on the forms.

Failure to complete these entries and calculations represented noncompliance with the above requirements.

(289/77-34-01)

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7.

Disposal Records and Reports

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Environmental Technical Specification 5.6.1, requires that a,

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" report on the radioactive discharges released from the site during

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the previous 6 months of operation shall be subr..itted to the Director

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of the NRC Regional Office within 60 days after January 1 and July 1 of each year. The report shall include a sumary of the quantities of radioactive liquid and gaseous effluent and solid waste released from the plant as outlined in Regulatory Guide 1.21, Measuring, Evaluating, and Reporting Radioactivity in ' Solid Wastes and Releases

of Radioactive Material in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants, with data sumarized on a quarterly basis following the format of Appendix B thereof." This format includes the pe.rcent of the quarterly limit released in each of several categories during each calendar quarter.

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~ Disposal Records and Reports for' Gaseous Effluents The licensee representative stated that any worksheets used in preparing the semiannual radioactive effluent release reports b-were not to be found and that the individuals who prepared these reports were no longer available for interview by the inspector.

The inspector noted that the available gaseous effluent records

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indicated releases that were about 15% less than was reported in the fission and activation gases category for the third and fourth quarters of 1976. This was observed on line Al of Table 1A of the radioactive effluent release report transmitted to NRC: I by a letter dated March 7, 1977.

The inspector totaled all of the information made available to him for the fourth quarter of 1976 and, making allowances for

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the information that appdrently should have been entered on the forms 1622-5, discussed in Paragraph 6, the total for fission and activation gases (line Al of the Table 1A, above)

was betwean 700 and 725 Ci rather than the 844 Ci reported in

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the Radi, active Effluent Report.

Although the licensee repre-sentative stated that a review would be made to find an explana-tion of the difference, no explanation was presented during the inspection.

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The inspector noted that the reported percent of the technical specification limit for fission and activation gases released during each of the four quarters from July 1, 1976 to June 30,

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1977, should have been sequentially 0.5%, 2%, 5% and 8%,

instead of the reported values which were 0.01%, 0.04%, 17.74%

and 16.34% (line A3 of Table 1A).

The increase from quarter

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to quarter, appeared to be the result of the increase in fuel I

exposure while opera. ting, and an outage that comenced during March,1977, during which the reactor vessel, steam generators and other primary system components were opened, releasing

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gaseous radioactive isotopes into the' reactor building and

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containment ventilation exhaust flow.

The inspector also noted that the licensee transmittal letters

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for the Radioactive Effluent Reports due March 2 and August

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30, 1977, were dated March 7 and September 15, 1977.

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Reports of Liquid 'and Solid Radioactive Waste Disposal o

Review of the records and reports of liquid effluents and V

solid waste disposal during the period July 1, 1976 to June 30, 1977, indicated that these records and reports were acceptable except for the timeliness of reports (described above).

No problems were identified involving the observance of regulatory limits on releases of radioactive materials.

8.

Review of Upkeep and Calibrations of Instrumentation

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Part of the inspection effort.was to observe the operation of the

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instrumentation and to review the records of trip settings and

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I calibrations of the ventilation monitors, system monitors and effluent monitors, for the period October 1,1976 to October 15, 1977.

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System Modification A previous inspection (289/77-07, Paragraph 8) reviewed the licensee proposed design change to alleviate contamination (crud trapping) in Miscellaneous Sump Discharge Monitor RM-L8, which was remaining continually tripped and diverting all of the miscellaneous sump discharges to the radwaste system.

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Although the proposed change was completed, which bypassed the Borated Water Storage Tank (BWST) area sump directly to the radwaste system, the Auxiliary Steam System meanwhile became contaminated because of an evaporator _ tube bundle failure (in

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the Reactor Cooling Water Letdown System) and the problem with

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RM-L8 was not totally alleviated.

The evaporator tube bundle was replaced with one removed from TMI-2.

The licensee repre-sentative stated that the Auxiliary Steam System will clean up and the tripped condition of RM-L8 will be alleviated in the due course of time.

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The inspector noted that the tripped condition did not appear to affect the release of radioactive materials.

The inspector has no further. questions on this item at this time.

b.

Waste Gas System Monitoring

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LER 77-1P - Gas monitor misvalving:

The licensee routine

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surveillance check of RM-L8G vent monitor (Auxiliary and Fuel

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l Handling Building ventilation) found it unexplainably valved i

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out of service at 2 a.m. on October 26, 1977, during a planned

. waste gas decay tank discharge.

Environmental Technical Specification 2.3.2 requires RM-L8G and RM-L7G (waste gas discharge monitor) both to be operating during tank discharges.

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The licensee representative immediately returned RM-L8G to i

service and investigated the cause of the misvalving.

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explanation was found.

I The licensee review indicated that the release had not exceeded any required limit, as shown ey RM-L8G being at the expected level after it was placed in operation, and RM-L7G and the flow rates being stable throughout the discharge.

The PORC review of this item was in meeting 77-43, which required the valve to be padlocked in the future.

The inspector has no further questions on this item at this time.

9.

Review of Licensee Ev'aluations of Unplanned Releases The inspector reviewed the records of unplanned releases and potential releases during the period October 1, 1976, to November 7, 1977.

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MU-V-92-Valve packing Leak A potential release was indicated on September 29, 1977, by an air particulate monitor upstream of the ventilation exhaust filters (a high efficeincy particulate filter is part of the filter train)

however, the particulate monitor for the filtered effluent did not indicate any increase.

The licensee identified the cause to be a Make-Up System valve packing leak (MU-V-92) and this was corrected after appropriate preparations were made.

Effluent samples were analyzed, indicating that the airborne exposure on this job was limited to 2 x 10-8 uCi/ml (particluate activity, mostly rubidium-88).

The concentration released to unrestricted areas was not up to the detection level.

LER 77-25/3L Seal Water Line Break

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A release on October 28, 1977, resulted from a break in the 1/2 inch piping of the seal water li.ne to a vacuum pump for a waste

evaporator. The licensee evaluation indicated an operator was

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opening a manually operated valve in the line during a startup of the evaporator Md he observed the occurrence of the break.

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immediately left the area and isolated the system and no uptake was

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indicated by subsequent checks of this individual and of three others in the Auxiliary Building at the time, all of whom were

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evacuated imedately. The licensee evaluation is that 27.9 Ci of

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airborne radioactive material (mostly Xe-133) was released, possibly i

in the leaking water or the cover gas of the seal water tank.

No iodine isotopes were identified in the samples of the filtered

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effluent. The event was reported to the NRC (LER 77-25/3L).

No items of noncompliance were identified and the quant!ity released to unrestricted areas appeared to be about 0.1% of the quantity that could be released during a calendar quarter without exceeding any regulatory limit. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> average concentration in the room where the leak occurred was calculated to be 7.59 x 10-4 uCi/ml based on the licensee's integration of the (Auxiliary and Fuel Handling Building) recorder chart for the ventilation exhaust

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monitor upstream of the building filters, with allowances for dilution prior to that point.

Grab samples taken in the room indicated that the exposure was somewhat lower than this.

The activity was > 90% xenon-133 and > 99% noble gases.

The licensee calculated the operator's exposure to iodine to be about a minute at 2 x 1C-10 uCi/ml iodine-131 equivalent airborne concentration.

(This concentration is below that shown in 10 CFR 20, Appendix B for restricted areas).

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The licensee required the four involved individuals to frisk and to take nasal smears, and no uptake or contamination was indicated.

The licensee read out their self-reader dosimeters and no whole body exposures beyond.r.ormal daily exposures were identified.

The release to unrestricted areas appeared to be diluted as described above.

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The inspector found that these licensee evaluations appeared to be ecceptable.

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10.

Procedures ~for Processing Radioactive Wastes and Releasing and Shipping Wastes I

The licensee procedures are being revised to acconinodate anticipated I

startup and operation of Unit 2.

This aspett of the procedures will be reviewed during inspections of Unit 2.

Review of Procedure 1104-28 was described in Paragraph 5.

l The inspector noted in connection with the records described in g

Paragraph 7, that the licensee is developing the capability to

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maintain part of the release records by use of computer printout,

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however, this does not appear to be reflected in procedures.

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is not required as long as the records required by the procedure l

are kept. No items of noncompliance were identified in the upkeep l

of procedures.

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Testing and Controlling Containment Air Cleaning Systems The inspector reviewed records of surveillance tests, including filter removal efficiency tests, of the containment air cleaning systems and the control room ventilation systems for the period January 1,1977, to October 1,1977.

No problems were identified in this area of the inspection.

12.

Reactor Water Purity and Radioactivity

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Part of the. inspection effort was to review recoros of reactor cooling water tests, chemical control and radioactivity control over the period October 1,1976 to October 1,1977.

The inspector also toured.the facility and observed the equipment involved in these operations.

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No items of noncompliance were identified.

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13. Solid Waste and Other Radioactive Materials The inspector reviewed the licensee management and records of solid radioactive waste, and vaste packaging and shipping as well as provisions for safe shipment of equipment used during the summer, 1977, refueling outase that was to be transferred to other sites.

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No items of noncompliance were identified.

14. Training, Staffing and Organization for Radirtion Protection The inspector reviewed the recent additions to the Health Physics Staff. Since the most recent inspection of this item (on Inspection No. 289/77-07), a Health Physics Engineer a.nd two technician trainees

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were added to the organization.

A contractor was providing formal training)onsite for the trainees during this inspection, and additional

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(offsite training is scheduled.

i The inspector has no further questions on this item at this time.

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Exit Interview I

The inspector met with the licensee representative (denoted in Paragraph 1) at the conclusion of the inspection.

The scope and findings of the inspection were reviewed.

The licensee representative stated that corrections would be provided for the radioactive effluent reports (Paragraph 7).

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