IR 05000302/1987009

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Insp Rept 50-302/87-09 on 870309-13.Violations Noted:Failure to Comply W/Dot Regulations for Transporting Radioactive Matl & to Perform Adequate in Vivo (Whole Body Count) Surveys
ML20206D491
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 03/23/1987
From: Collins T, Hosey C, Kuzo G, Weddington R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20206D397 List:
References
50-302-87-09, 50-302-87-9, NUDOCS 8704130353
Preceding documents:
Download: ML20206D491 (14)


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Report No.:- 50-302/87-QtIS Licensee: Florida Power Corporation 3201 34th Street, South St. Petersburg, FL 33733 Docket' No. : 50-302 License No.: DPR-72 Facility Name: Crystal River 3 Inspection Conducted: March 9-13,1987

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'Da'te Signed almLO En 83 L,h Ni9 GtB.(Cuzo Date Signed Accompanying Personnel:,

C. M. Hosey Approved by:

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3h3 /87 C. M. - Hosey', Secti4n Chief Date Signed Division of Radiation Safety and Safeguards SUMMARY Scope:

This routine unannounced inspection involved review of previously identified inspector followup items and enforcement hatters, external exposure control, internal exposure control, control of radioactive material, solid wastes, transportation, and followup of IE Notices.

Results:

Three violations were identified:

(1) failure to comply with Department of Transportation regulations for transporting radioactive material, (2) failure to have adequate procedures in place to ensure personnel were qualified to wear respiratory protective equipment necessary to perform their duties, and (3) failure to perform adequate in vivo (whole body count) surveys.

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REPORT DETAILS 1.-

Persons Contacted Licensee Employees

  • P. F. McKee, Station Manager
  • W. K. Baudhauer, Assistant Manager, Nuclear Plant Operations
  • W. L. Rossfeld, Manager, Site Nuclear Compliance
  • W. J. Lagger, Health Physics Supervisor
  • R. E. Fuller, Senior Nuclear Licensing Engineer
  • D. T. Wilder, Radiation Protection Manager
  • G. R. Clymer, Manager, Nuclear Waste
  • V. A. Hernandez, Senior Nuclear QA Specialist
  • A. Kazemfar, Supervisor, Nuclear Support Services
  • D. Van Ooesterwyk, Supervisor, Health Physics
  • S. L. Robertson, Supervisor, Chemistry-Radiation
  • J. R. Wright, Nuclear Support Specialist
  • S. Lashbrook, Supervisor, Health Physics
  • M. S. Mann, Nuclear-Compliance Specialist
  • P. D. Breedlove, Supervisor, Records Management
  • G. Fleming, Health Physics

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M. M. Siapno, Supervisor, Health Physics Other licensee employees contacted included engineers, technicians, and office personnel.

Nuclear Regulatory Commission T. Stetka, Senior Resident Inspector

  • J.-Tedrow, Resident Inspector
  • Attended exit interview 2.

ExitInterview(30703)

The inspection scope and findings were suninarized on March 13, 1987, with those persons indicated in Paragraph 1 above.

Three apparent violations concerning failure to comply with Department of Transportation regulations for transporting radioactive material (Paragraph 9),

inadequate respiratory protection procedures (Paragraph 5), and failure to conduct j

adequate in vivo radiological surveys (Paragraph 6) were discussed.

The

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l licensee acknowledged the inspection findings ~and trok no exceptions. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspection.

3.

Licensee Action on Previous Enforcement Matters a.

(Closed) Violation (50-302/85-34-02) Inadequate personnel monitoring (frisking) while leaving the Radiation Controlled Area (RCA).

The

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inspector reviewed and verified the implementation of the corrective actions stated in Florida Power Corporation's letters of November 14, 1985, and January 16, 1986.

b.

(Closed) Violation (50-302/86-06-01) Personnel working in a high radiation area without appropriate survey instruments. The inspector

. reviewed and verified the implementation of the corrective actions stated in Florida Power Corporation's letter of December 5,1986.

c.

(Clased) Violecion (50-302/86-11-02) Radiation Work Permit (RWP)

procedure was -inadequate to address change of work conditions after RWP was issued.

The inspector reviewed and verified the implementation of the corrective actions stated in Florida Power Corporation's letter of August 11, 1986.

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(Closed) Violation (50-302/86-26-02) Failure to adequately brace radioactive materials packages.

The inspector reviewed and verified the implementation of the corrective actions stated in Florida Power Corporation's letter of December 4,1986, e.

(Closed) Violation (50-302/86-26-04) Failure to implement an alpha survey program for airborne and contamination control. The inspector reviewed and verified the implementation of the corrective actions stated in Florida Power Corporation's letter of December 4,1986.

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(Closed) Violation (50-302/86-26-05) Personnel working in a high radiation area without appropriate survey instruments. The inspector reviewed and verified the implementation of the corrective actions stated in Florida Power Corporation's letter of December 4,1986.

g.

(Closed) Unresolved Item (50-302/86-35-05) Unauthorized release of radioactive material outside the RCA.

In July 1986, the licensee, while performing routine surveys of the facility, found a contaminated tool outside the RCA inside a' contractor's tool trailer.

The event was reviewed and documented in Inspection Report No. 50-302/86-26 and was determined to be a licensee identified violation.

The licensee's corrective action to preclude future events of this type included weekly routine surveys of areas outside the RCA.

During October 1986, the licensee found another contaminated piece of equipment outside the RCA. This equipment was determined to have been outside the RCA since before the first item was found.

The licensee's corrective action to increase the frequency of surveys outside t5e RCA was sufficient to locate the uncontrolled contaminated equipment in October 1986.

The inspector reviewed and discussed with licensee representatives their long term Radioactive Materials Control Program, which had been written and sent to management for appval.

At the time of the inspection all of the proposed actions were not complete.

However, Radiological Surveys Procedure, HPP-202 was revised to implement interim corrective actions. The inspector reviewed and verified that

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3-HP-202 procedure, Radiological Surveys had been revised and was adequate to control release of radioactive materials.

The inspector determined that since the material outside the controlled area had been identified as a result of the licensee's corrective action for a previous event that ' had been considered

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licensee identified, pursuant to the NRC Enforcement Policy, 10 CFR Part 2, Appendix C, and that the material had likely.not been released subsequent to the initial finding, then there was no violation of NRC requirements and the unresolved item would be.

closed.

4.

. Maintaining Occupational Exposures ALARA (83728)

10 CFR 20.1(c) specified that licensees should implement programs to keep worker's doses as. low as reasonably achievable (ALARA).

The recommended elements of an ALARA program were contained in Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Exposure at Nuclear Power Stations will be ALARA, and Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Exposures ALARA.

Licensee representatives stated that management commitment to the ALARA program implementation-came from the highest corporate and plant management levels.

Procedural guidance detailing the licensee's ALARA program was outlined in Administrative Instruction (AI) 1600, ALARA Program Manual, June 17, 1986. The Site Nuclear Services ALARA Specialist was responsible for overseeing the plant ' ALARA program.

The ALARA specialist responsibilities included:

(1) interfacing with the Director, activities; (2) perations to ensure ALARA is maintained in daily plant -

Nuclear Plant O reviewing any planned tasks that may expend more than 1 man-rem; (3) reviewing collective dose to determine success of ALARA goals, and issuing selected reports and evaluations; (4) evaluating plant ALARA data and making recommendations as appropriate.

The ALARA specialist conducted pre-and post job ALARA reviews and

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reviewed exposure performance against objectives during work in progress.

Exposure estimates on selected jobs were reviewed daily and the final dose estimates were then compared with the dose determined by TLD. Management was routinely apprised of station exposure for each departmental section.

The highest man-rem exposures for 1985 and 1986 were reported for the health physics and system maintenance departments.

The inspector discussed the goals and objectives for 1986 and reviewed

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man-rem estimates for 1985 and 1986.

Based on no expected outages, the original 1986 goal was 50 man-rem. An additional 300 man-rem was added to the year's total to account for a reactor coolant pump repair outage. A subsequent exposure estimate for a letdown cooler replacement was 60 man-rem.

Welding difficulties were experienced for this job but the estimated exposure was not revised.

The total assigned exposure was 447 man-rem for 1986, slightly higher than the estimated amount. The 1985

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assigned exposure was 646 man-rem, with 568 man-rem directly attributable to activities associated with the March-August refueling cycle outage.

No violations or. deviations were identified.

5.

Surveys, Monitoring, and Control of Radioactive Material (83726)

10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.

The inspector reviewed plant Procedure RP-202, Radiological Surveys, which established the licensee's radiological survey and monitoring program and verified that the procedure was consistent with 10 CFR Part 20, Technical Specifications and good health physics practices.

The inspector reviewed selected records of radiation and contamination surveys performed during the period of January to March 1987 and discussed the survey results with licensee representatives.

During tours of the plant, the inspector observed health physics technicians performing radiation and contamination surveys.

The inspector discussed with the licensee the method used to release material from the restricted area and observed technicians performing release surveys for material.

The inspector observed personrel using the personnel frisker (RM-14/RM-16 with HP-210 pancake probe) to perform contamination surveys of themselves while inside the Radiation Controlled Area (RCA).

The inspector also

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observed personnel performing contamination surveys of themselves using the PCM-1Bs, Personnel Contamination Monitors, while exiting the RCA.

During the inspection, current radiation survey instrumentation calibration and performance check program implementation was reviewed.

The inspector observed and discussed with cognizant health physics technicians selected survey instrumentation calibrations as detailed in HPP 406, Radiation Protection Instrumentation Calibration Procedures, December 5,1985, and HPP-414, Calibration and Operation of Eberline PCM-16 Personnel Contamination Monitor, October 14, 1985.

Calibrations, respan.ee checks, and sensitivity limits as required by procedures for selected survey instrumentation in use by plant personnel were reviewed.

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The inspector reviewed selected radiation work permits in effect in the RCA and datermined that adequate controls were specified and ALARA considerations had been made.

The inspector performed independent radiation surveys of selected areas outside the RCA and outside the Protected Area (PA) using NRC survey equipment. Areas surveyed included posted and controlled areas within the

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PA and equipment warehouses outside the PA.

The survey results were consistent with area postings and licensee controls for the areas.

The inspector discussed with the Radiation Protection Manager the total contaminated area within the Radiation Controlled Area (RCA).

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inspector was informed that 8,500 ft2 out of 66,100 ft2 was considered contaminated, which is 12.9% of the RCA. The licensee had not set a goal j

for 1987 to further reduce the total contaminated area inside the RCA, other than maintain the area which is now considered radiologically clean i

due to ALARA considerations and that the remaining areas were not accessed on a routine basis.

No violations or deviations were identified.

i 6.

Internal Exposure Control and Assessment (83725)

a.

10 CFR 20.103(a). establishes the limits for exposure of ir.dividuals to concentrations of radioactive materials in air in restricted areas.

This section also requires that suitable measurements of concentrations of radioactive materials in air be p.3rformed to detect and evaluate the airborne radioactivity in restricted areas and that appropriate bioassays be performed to detect and assess individual intakes of radioactivity.

The inspector reviewed selected results of geberal in-plant air samples taken during the period January to March 1987 and the results of air samples taken to support work authorized by specific radiation work permits.

The inspector reviewed selected results of bioassays (whole body counts) and the licensee's assessment of individual intakes of radioactive material performed during the period October 1986 to March 1987.

No violations or deviations were identified.

b.

10 CFR 20.103(b) requires the licensee to use process or other engineering controls, to the extent practicable, to limit concentrations of radioactive material in air to levels below that specified in Part 20, Appendix B, Table 1, Column 1 or limit concentrations, when averaged over the number of hours in any week during which individuals are in the area, to less than 25 percent of the specified concentrations.

The use of process and engineering controls to limit airborne radioactivity concentrations in the plant was discussed with licensee representatives and the use of such controls was observed during tours of the plant.

No violations or deviations were identifie.

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c.

10 CFR 20.103(b) requires that when it is impracticable to apply process or engineering controls to limit concentrations of radioactive material in air below 25 percent of the concentrations specified in Appendix B, Table 1, Column 1, other precautionary

. measures, such as use of respiratory protection, should be used to maintain the intake of radioactive material by any individual within seven consecutive days as far below 40 MPC-hours as is reasonably achievable.

By review of records observations and discussions with licensee representatives, the inspector evaluated the licensee's respiratory protection program, including medical qualifications, - fit testing, MPC-hour controls, quality of breathing air, and the issue, use, decontamination, repair and storage of respirators.

The inspector reviewed the following plant procedures which established the licensee's internal exposure control and assessment program and verified that the procedures were consistent with

. 10 CFR Part 20, Technical Specifications and good health physics

' practices:

HPP-501, Respirator Issue and Return HPP-502, Respirator Inspection and Quality Checks HPP-505, Respirator Qualitative and Quantitative Fit Testing HPP-506, Respirator Leak Test HPP-510, Breathing Air Service Use RP-230, MPC Hour Calculation Procedure RSP-500, Health Physics Respiratory Qualification Program RSP-501, Respirator Issue Use and Return No violations or deviations were identified, d.

10 CFR 20.103(c)(2) requires that the licensee maintain and implement a respiratory protection program that includes, as a minimum, written

procedures regarding selection, fitting and training of personnel.

Chemistry and Radiation Protection Procedure, HPP-501, dated l

September 23, 1986, Respiratory Issue and Return, Section 3.1.1 specified the licensee's requirements for issuance of respiratory protection equipment.

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Emergency Plan Implementing procedure, EM-208, dated April 3,1986,

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Duties of the Radiation Emergency Team, Section 2.3 specified the licensee's respiratory protection qualification requirements for i

emergency team members.

On November 22, 1986, the plant was in hot standby (Mode 3)

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condition.

Plant operators observed an increase in the Nuclear

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Services' Closed Cycle Cooling (SW) system activity with a

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corresponding increase in the system's surge tank level. Monitoring of the makeup and purification system's makeup tank revealed that a

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reactor coolant system to SW system leak had occurred.

The leakage rate was estimated at four gallons per minute (gpm).

An unusual event was declared and a plant cooldown was comenced in accordance wis Ta;. is 4ccification (TS) 3.4.6.2.b.

Licensee management

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representatives decided to send a licensed operator into the Reactor Building (RB) to investigate the source of leakage.

However, the operator chosen for the task was not respiratory qualified to wear the Scott Self-Contained Breathing Apparatus (SCBA). The individual

.had not been trained to wear the SCBA.

Licensee management was informed of this problem and nevertheless decided to send the operator who was not qualified into the RB wearing the Scott SCBA respiratory equipment because he was considered by management to be the best qualified person onsite to investigate the source of leakage. The inspector discussed this event with licensee management

. representatives and was informed that, since the plant was in an emergency condition (unusual event) they had made a conscious decision to send the unqualified operator into containment to investigate the source of leakage.

The inspector informed licensee

. management that failure to have adequate respiratory protection procedures in place to ensure that nuclear operators were qualified to wear respiratory protective equipment necessary for them to perform their duties was an apparent violation of 10 CFR 20.103(c)(2)

(50-302/87-09-01),

10 CFR 20.201(b) re such surveys as (1) quires each licensee to make or cause to be made e.

necessary for the licensee to comply with the regulations in this part and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.

10 CFR 20.103(c)(2) requires the licensee to maintain and implement a respiratory protection program that includes surveys and bioassay as appropriate to evaluate actual exposures.

The licensee conducted entrance, termination, and routine annual whole body (in vivo) radiological surveys of personnel who could be exposed to airborne radioactive material. The inspector reviewed and discussed with cognizant licensee representatives the following procedures concerning implementation of the whole body counting program:

HPP-320, Whole Body Counting System Operation, December 9, 1986

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HPP-321, Whole Body Counting System Linear Energy Calibration

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and Quality Control Check, May 13, 1986

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HPP-322, Whole Body Counting System Calibration, May 2, 1985 The inspector reviewed and verified calibration and performance data for the whole body system during 1987.

HPP-320 requires baseline whole body counting for all personnel which could be exposed to airborne radioactive material (Section 2.1.1); notification of the

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Health Physics Supervisor (HP3) if the total body burden is in excess-of 1% MP0B (Section 2.6); ir.put of infonnation co the computer system as requested by the whole body counting jobstream menu (Section 3.1.2); and positioning of the individual in the whole body chair such that the detectors are centered on, and as close to the body part being counted by the detector as possible (Section 3.1.5).

During observations of whole body counting analyses in progress, the inspector noted that the whole body chair adjustments were not functional, that is, vertical adjustments to position an individual in front of the detector were not being conducted.

Failure to make a vertical adjustment resulted in the thyroid detector being 3 or 4 inches below the critical organ.

Review of records for whole body analyses conducted for selected individuals during March 9-13, 1987, determined that identical (inaccurate) chair position coordinates were entered into the software program utilized for final data analysis.

Furthermore, records for selected personnel indicated positive maximum permissible organ burden (MP08) values (flagged at greater than 1% MP0B), which should have been evaluated prior to allowing entry into the radiation controlled area, were not questioned prior to clearing the personnel for access to the plant.

Licensee representatives indicated that they suspected that the positive values had resulted from high background concentrations of naturally occurring radionuclides.

The inspector noted that the licensee did not conduct routine background measurements for the whole body system to verify this assumption.

The failure of the licensee to perform adequate in vivo (whole body) radiation surveys was identified as an apparent violation of 10 CFR 20.201(b)

(50-302/87-09-02).

7.

External Exposure Control (83724)

10 CFR 20.101(a) specified the quarterly radiation exposure limits for individuals in restricted areas.

10 CFR 20.401(a) requires each licensee to maintain records showing the radiation exposures of all individuals for whom personnel monitoring is required by 10 CFR 20.202 and that such records be kept on Form NRC-5 or equivalent in accordance with the instructions contained on the form.

Form NRC-5, Instructions for Preparation of Form NRC-5, item 5, requires that, unless the eyes are protected with eye shields having a tissue equivalent density thickness of at least 700 milligrams per square centimeter, dose recorded as whole body dose should include dose delivered

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through a tissue equivalent absorber having a density thickness of 300 milligrams per square centimeter or less.

The inspector reviewed radiation exposure records of personnel monitored by the licensee during the past year and verified that individual exposures were maintained below quarterly limits.

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The inspector discussed skin dose assessment methodology with licensee representatives and reviewed a dose assessment that had been performed for an individual found to have a mixture of contaminants with a total activity of 0.11 microcuries in a localized trea on. his foot.

The licensee had calculated and assigned a skin dose to the individual of 513 millirem.

The inspector independently verified that the dose assessment was reasonable.

The inspector discussed with licensee representatives the results they have obtained from a new vendor thermoluminescent dosimeter (TLD) service that had been in use for approximately a year.

The licensee had been avaluating the accuracy of beta radiation monitoring using the new TLD System and had been pursuing resolution of the matter with the TLD vendor.

The inspector reviewed the licensee's documentation of the problem and correspondence between them and the vendor.

The inspector determined that the licensee's actions to obtain resolution of this problem had been adequate.

The inspector obtained a quantity of vendor TLDs from the licensee so that they can be irradiated by an NRC contractor.' After irradiation, the TLDs will be returned to the licensee for normal processing.

The results of the TLD study and the licensee's action to resolve the suspected inaccuracies in their TLDs will be reviewed during future inspections (50-302/87-09-03).

No violations or deviations were identified.

8.

Solid Waste (84722)

10 CFR 20.311(d)(1) requires that any generating licensee who transfers radioactive waste to a land disposal facility prepare all wastes so that the waste is classified according to 10 CFR 61.55 and meets the waste characteristics requirements in 10 CFR 61.56.

The inspector discussed with licensee representatives their program of waste stream sampling in order to develop waste cla:sification scaling factors.

The licensee obtained quarterly samples of the following waste streams:

RCS liquid, composite RCS filtered crud, spent fuel pool liquid and miscellaneous waste storage tank liquid.

In order to classify dry active waste (DAW), composite smears were taken in plant areas from which waste was generated, on noncompactable waste being placed into disposal packages and on the drum compactor ram. Samples were sent to a contractor laboratory for analysis on an annual basis. The remaining three quarterly samples were retained in case additional analyses were required.

The inspector reviewed waste classification determinations filed with selected shipping records.

The licensee ensured waste stability through use of high integrity containers and by solidification using an onsite vendor operated process.

The inspector toured the solidification area and observed contractor technicians performing solidification tests.

No violations or deviations were identified.

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9.

Transportation of Radioactive Material (86721)

j 10CFR71.5(a) requires that each licensee who transports licensed material outside of the confines of its plant or other place of use, or who delivers licensed material to a carrier for transport, shall comply with the' applicable requirements of the regulations appropriate to the

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mode of transport of the Department of Transportation in 49 CFR Parts 170

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through 189.

49CFR173.475(1) requires that before each shipment of any radioactive mater f als package, the shipper shall ensure by examination or appropriate

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tests, that external radiation and contamination levels are within the

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allowable limits.

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49 CFR 173.441(b)(2) requires that the radiation level may not exceed 200 millirem per hour at any point on the outer surface of exclusive use

closed transport vehicles, including the upper and lower surfaces.

49 CFR 173.427(c) requires that a packaging which previously contained radioactive materials and has been emptied of contents as far as

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practical, is excepted from the shipping paper and certification, marking,

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and labeling requirements provided that internal contamination does not exceed 100 times the limits in 49 CFR 173.443.

i 49 CFR 172.202(a) requires that the shipping description of a hazardous material.on a shipping paper must include the proper shipping name prescribed for the material and the identification number.

The inspector reviewed records of licensee radioactive material shipments

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performed during 1986 and 1987.

Shipment Number 87-15, consisting of compacted radioactive waste in 55-gallon drums, was shipped to the radioactive waste disposal facility near Barnwell, South Carolina on March 5,1987.

The shipment was classified as low specific activity (LSA) and was transported in an

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l exclusive use, closed transport vehicle.

The inspector noted that the

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documentation of the preshipment radiological surveys included with the shipping paperwork did not show any surveys of the top outer surface of

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the transport vehicle.

Licensee representatives stated that surveys of

the tops of exclusive use closed transport vehicles were not routinely performed.

The inspector stated that since a radiation level limit for the vehicle tops is specifically stated in 49 CFR 173.441(b)(2), then the

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preshipment surveys required by 49 CFR 173.475(1) have to include i

measurements at that location.

Failure of the licensee to perform these

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surveys was identified as an apparent violation of 10 CFR 71.5(a)

(50-302/87-09-04).

On January 15, 1987, the licensee received a new high integrity container

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(HIC) packaged inside of a 8-120A-2 shipping cask.

The rented cask and j

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new HIC had been shipped together since they were being obtained from the

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i same vendor.

As part of the receipt ir.spection, the cask lid was removed

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9rd the HIC was partially raised -in order to perform a contamination

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. su'rvey.

Contamination levels of approximately 20,000 disintegrations per mir!ute (dpm) were found on a wide area wipe on the outside of the HIC.

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i The licensee decided to send the HIC and cask back to the vendor since new HICs were stored outside and were controlled as uncontaminated.

The licensee also performed contamination surveys of the sealing area of the cask, cask lid, bolt holes in the sealing area and one smear approximately two feet down on the inside of the cask. The highest contamination found

on the nine smears that were taken was 200,000 dpm/100 cme in the sealing area on the top of the cask. The cask and HIC were shipped to the vendor the same day using the empty packaging exception in 49 CFR 173.427(c).

I The inspector discussed the contamination surveys that had been taken on the cask with licensee representatives and the health physics technician

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who had performed the survey. The inspector determined that contamination surveys that had been performed by the licensee were not' adequate to

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demonstrate that the shipment met the empty packaging exception criteria j

in 49 CFR 173.427(c).

Casks are typically contaminated internally due to spillage from the HIC during loading and handling, resulting in the area

of the cask bottom presenting the highest internal contamination

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potential.

The survey results from the sealing area of the cask of

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'200,000 dpm/100 cm2 was only 20,000 dpm less than the limit permitted by 49 CFR 173.427(c) and a more comprehensive survey of the cask internals

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may have found contamination levels above the limit.

Failure of the licensee to perform adequate contamination surveys of the cask internals to demonstrate that the levels met the empty packaging criteria was identified as another example of an apparent violation of 10 CFR 71.5(a)

(50-302/87-09-04).

On March 17, 1986, the licensee shipped a radiac calibrator containing a

154.6 curie Cesium-137 source to the vendor under Control Number 86-16.

I The inspector reviewed the shipping documentation and determined that the

source had been properly classified and packaged in an approved Type B container.

The shipping papers described the material as Radioactive

Material, N.O.S.,

UN 2911.

The Hazardous Materials Table in j

49 CFR 172.101 gives the proper shipping name and identification number of j

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a sealed radioactive source as Radioactive Material, Special Form, N.0.S.,

UN 2974.

Failure of the licensee to use the correct proper shipping name and identification number to describe the calibrator on the shipping i

papers was identified as another example of an apparent violation of

10 CFR 71.5(a) (50-302/87-09-04).

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On August 11, 1986, the licensee received a warning letter from the State of South Carolina Department of Health and Environmental Control concerning the licensee's failure to sign the two certification statements

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on the Barnwell Waste Management Facility's Radioactive Shipment Manifest

form for Shipment Number 0886-078-A on August 7, 1986.

Signed shipper certification statements are required by 49 CFR 172.205(a) and 49 CFR 172.204(a).

The inspector reviewed the documentation of the

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shioment and determined that the licensee had included signed cert.ification statements of the type required by 49 CFR Part 172 on other forms included with the shipping papers, but the duplicate statements on i

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I the disposal site's manifest form had not been signed.

The inspector determined that there had been no violation of NRC requirements since at least one certification statement of each type required had been signed.

10.

InspectorFollowupItems(IFI)(92701)

a.

(Closed) IFI (50-302/86-26-01) Development of a procedure to derive scaling factors for letdown filters.

The inspector reviewed letdown filter sampling techniques that had been added to the licensee's radioactive waste transportation procedure, WP-101.

The inspector determined that the sampling procedure was adequate.

b.

(Closed) IFI (50-302/86-26-03) Long-term corrective action for contaminated tools offsite. See Paragraph 3 9 for details.

11.

IE Information Notices (92717)

The inspector determined that the following NRC Information Notices (IEN)

had been received by the licensee, revirwed for applicability, distributed to appropriate personnel and that actions, as appropriate, were taken or scheduled, a.

IEN 85-48:

Respirator Users Notice:

Defective Self-contained Breathing Apparatus Air Cylinders b.

IEN 85-60: Defective Negative-pressure, Air-purifying Full Facepiece

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Respirators c.

IEN 85-81:

Problems Resulting in Erroneously High Reading with Panasonic 800 Series Thermoluminescent Dosimeters d.

IEN 85-87: Hazards of Inerting Atmospheres e.

IEN 85-92:

Surveys of Wastes Before Disposal from Nuclear Reactor Facilities f.

IEN 85-97:

Jail Term for Former Contractor Employee Who Intentionally Falsified Welding Inspection Records g.

IEN 86-22:

Low-Level Radioactive Waste Scaling Factors, 10 CFR Part 61 h.

IEN 86-22:

Underresponse of Radiation Survey Instrument to High Radiation Fields 1.

IEN 86-23:

Excessive Skin Exposure Due to Contamination with Hot Particles J.

IEN 86-24:

Respirator Users Notice:

Increased Inspection Frequency for Certain Self-contained Breathing Apparatus Air Cylinders

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k.

IEN 86-41:

Evaluation of Questionable Exposure Readings of Licensee Personnel Dosimeters 1.

IEN 86-42:

Improper Maintenance of Radiation Monitoring Systems m.

IEN 86-43:

Problems with Silver Zeolite Sampling of Airborne Radiciodine n.

IEN 86-44:

Failure to Follow Procedures When Working in High Radiation Areas o.

IEN 86-46:

Improper Cleaning and Decontamination of Respiratory Protection Equipment p.

IEN 86-103:

Respirator Coupling Nut Assembly Failures q.

IEN 86-107:

Entry Into PWR Cavity with Retractable Incore Detector Thimbles Withdrawn r.

IEN 87-03: Segregation of Hazardous and Low-Level Radioactive Wastes s.

IEN 87-07:

Quality' Control of Onsite Dewatering / Solidification Operations by Outside Contractors

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