IR 05000341/1987037
| ML20235S603 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 10/02/1987 |
| From: | Greger L, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20235S595 | List: |
| References | |
| 50-341-87-37, NUDOCS 8710090058 | |
| Download: ML20235S603 (11) | |
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U.S. NUCLEAR' REGULATORY COMMISSION
REGION III
' Report No.50-341/87037(DRSS)
Docket-No. 50-341'
License No. NPF-33
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Licensee:
Detroit Edison Company 6400 North Dixie Highway Newport, MI 48166
- Facility Name':
Enrico Fermi Nuclear Power Station, Unit 2 Inspection At:
Fermi Site, Monroe, Michigan
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' Inspection Conducted:
August 31 through September 4, 1987
[ [ h/f/[
" Inspector:
. A. Paul Date
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Approved By:
L. R. Greger, Chief
/o/e/F 7 Facilities Radiation Date.
Protection Section r
Inspection Summary
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Inspection on August 31 through September 4, 1987, (Report No. 50-341/87037(DRSS))
Areas Inspected:
Routine unannounced inspection of radiation protection and radwaste programs, including:
organization and management controls; ALARA activities; audits and appraisals; solid, liquid, and gaseous radwaste; and transportation activities.
Also reviewed'were selected Licensee Event Reports and open items, and radiological controls during spent fuel movement.
Results:
No violations or deviations were identified.
8710090058 871002 ADOCKOSOOg1, PDR G
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t DETAILS
' 1.
Persons Contacted
- R. Anderson, Supervisor, Radiological Engineering
- J. Bobba,' General Supervisor, Health Physics
- R..Eberhardt, Radiological Controls Engineer H. Higgins, Health Physics Supervisor, Operations
- C Weber, General Supervisor, Rad-Waste j
W. Rogers,-NRC Senior Resident Inspector The inspector also contacted several other members of the licensee's staff.
- Denotes personnel attending exit meeting.
2.
General This inspection,' which began at 1:00 p.m. on August 31, 1987,.was conducted to. review theLoperational radiation protection and radwaste programs, including: ' organization and management controls; ALARA activities; audits and appraisals; solid, liquid, and gaseous radwaste; and transportation activities.
Also reviewed were selected Licensee Event Reports, open' items, corrective actions taken as a result of previously identified violations, and radiological controls during spent fuel movement. ~ Area postings, access controls, end housekeeping L
were good.
l-3.
Licensee Action on Previous Inspection Findings (CLOSED) Open Item (341/87018-02):
Review the licensee's investigation and-corrective actions for a past 10 CFR violation.
The licensee initiated a Deviation Event Report (DER) which received appropriate l
management attention and required the Radwaste Department to determine if the method for identifying problems is adequate.
The DER states that the cause of the deviction was inattention to detail.
Actions to prevent recurrence were taken, including strengthening the relevant shipping procedures, performing an audit to ensure the quality of the program, and ins tituting disciplinary action (written record of an oral warning).
(OPEW) Open Item (341/86002-02):
Preoperational test exceptions remaining open for the liquid radioactive waste system.
The exceptions were on the oil coalescer, etched disc filters, filter aid system, and radwaste evaporators.
The licensee is testing these systems and expects to have them test accepted by December 1987.
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4.
Organization, Management Controls, and Staffing The inspector reviewed the licensee's organization and management controls for the chemistry program, including changes in the organizational structure and staffing, effectiveness of procedures and other management techniques used to implement.these programs, and experience concerning self-identification and correction of program implementation weaknessos.
The chemistry department is currently staffed with a general supervisor, chemist, engineer,'two specialists, fifteen technicians, two nuclear equipment technicians and three water technicians; there is an unfilled position for a chemistry engineer.
The general supervisor and chemist meet the ANSI N18.1-1971 requirements.
The chemistry staff appears stable and the experience level is adequate.
No violations or deviations were identified.
5.
Preplanning - ALARA For this outage, health physics personnel were involved in pre-outage reviews and were aware of the major radiation producing jobs in advance.
Outage planners were utilized; no major difficulties were encountered.
In accordance with procedure P0M 61.03, radiological reviews were performed for certain routine activities in accordance with radiological conditions and work to be performed.
These reviews are part of the licensee's exposure reduction program and are particularly important for implementing ALARA during outages.
No violations or deviations were identified.
6.
Liquid and Liquid Radioactive Wastes The inspector reviewed the licensee's reactor liquids and liquid radwaste management programs, including:
determination whether reactor liquids meet chemical and radiochemical requirements, determination whether liquid radioactive waste effluents were in accordance with regulatory requirements, adequacy of required racords, reports, and notifications; and experience concorning identification and correction of programmatic weaknesses.
The program was reviewed for calendar years 1986 and 1987 to date.
The inspector reviewed the semiannual effluent reports for 1986 and 1987, and selectively reviewed effluent records for the same period.
No significant problems were identified during this review.
Following sampling and analysis liquid effluents are released on a batch basis to a single monitored (alarm and isolation function) radwaste line.
This line directs the liquid effluent to the circulating water decant line prior to entering the discharge flume to Lake Erie.
The circulating water decant provides dilution to assure that the effluent reaching the
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lake is below MPC for the nuclides released.
Most plant liquids, l
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including chemical' waste liquids, are processed and reclaimed by use of L
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. filters, radwaste evaporators', and resin beds.
Most batch liquid t
discharges'to date have been made because of high plant water inventory.
AnalysesAf'batchliquid.releasesincludecountingarepresentativesample of the liquid using a Nuclear Data intrinsic germanium system to identify and determine the concentration of gamma emitting nuclides specified in Technical Specification Table 4.11.1-1.
For pure beta emitters including strontium-89 and 90 and. iron-55, their concentrations are assumed to be identical to the concentrations analyzed in the latest monthly composite samples of batch. releases; the composite samples are sent to a contractor for beta analysis.
The concentrations of each nuclide and the actual discharge and dilution. flow rates are fed into a computer program.
The program provides the MPC fraction for each nuclide, the sum of the MPC fractions, the allowable radwaste discharge flow rate, and the setpoint (above background) of the discharge monitor.
The maximum dilution flow used for'the lake blowdown in the calculation is 20,000 gpm.
The maximum release rate from the effluent line is 50 gpm.
Selective review of recent release records identified no problems with setpoint determinations and settings.
To meet Technical Specification.4.11.1.2 surveillance requirements for each liquid batch release, the activity of each nuclide is entered into a computer program which determines the cumulative dose contributions (in accordance with the ODCM) for the total body and any organ for that batch release, for the calendar quarter to date, and for the calendar year to date.
In 1986 and the first 6 months of 1987, less than 5 millicuries of gross beta gamma activity (excluding tritium) was released in liquid effluents.
For.that period, the calculated maximum whole body dose and maximum bone dose (most restrictive organ dose) to any individual beyond the site i
boundary were 1.1E-2 mrem and 1.2E-2 mrem, respectively.
No violations or deviations were identified.
7.
Gaseous Radioactive Waste The inspector reviewed the licensee's gaseous radwaste management program, including:
determination whether gaseous radioactive waste effluents were in accordance with regulatory requirements; adequacy of required records, reports, and notifications; and experience concerning identification and correction of programmatic weaknesses.
The program was reviewed for calendar year 1986 and the first 6 months of 1987.
The inspector reviewed semiannual effluent reports for 1986 and 1987, and selectively reviewed effluent records for the same period.
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Gaseous effluents are exhausted t/a the reactor building and SGTS stacks; containment vents and purges are exnaustbd via the reactor buOding stack.
Currently and under normal plant conditions, gaseous releasd are quantified from monthly stack grab samples for noble gas and weekly particulate filter and charcoal samples.
Stack tritium samples are
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collected monthly to quantify tritium releases using a gas bubbler
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which takes samples from the noble gas port of the stack muitors (SPING-4).
Prior to drywell purges, grab samples for noble gas and tritium'are collected and analyzed from both the vent stack and
! containment to verify that releases will not exceed the Offsite Dose Calculation Manual (0DCM) criteric.
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The Nuclear Data computer program for dose updates Wd pynt:tions is run weekly and before containment purges (more than meetlag the 31 day maximum interval for dose projection determination).
Releases of each nuclide for the period are computed for determining the gamma ait dore, s
t beta air dose, total body dose, skin dose and most restrictive oFgan dose
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for the cu "ent period, the current calendar quarter to date, and the calendar year to date.
For 1986 and 1987 to date, grab gas and weekly iodine charcoal samples collected from the reacts buildirig and SGTS exhausts were less than LLD.
As a result, the total effluent releases and dose to the public were computed as zero curies and mrad, respectively.
Until the reactor facility!generaus noble gas e n ) dents which can be quartified using the reactcr building and/or SGT3 sampling / monitoring system, the licensee is considering using off gas releases to estimate noble gas releases for the semi-annual effluent reports.
No violations or deviati we r e ' i denti fi ed.
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8.
Reactor Coolant Samples Reactor coolant sampling and analysis records were, reviewed fos compliance with chemical and radiochemical criteria contained ~in Technical Specification 3/4.4.1 and 3/4.4.5, respective?y.,,h\\ective test results were reviewed for 19d6 and'1967 to date, inchdtf pH, si conductivity and chloride.
The pH and chloride concentration was contained within the respective specified criteria throughout the review'
period.
The conductivity was out of specification for less than a 72 houe period on two occasions in 1986 and 1987 when.1.0 micro mhos/caYao
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exceeded and reached a maximum of less than 2'idcro mhos/cm.
4Wher a report nor a change in the operational condit/an wac required becausp the f
concentrations were brought back within acceptable criteria within.a period, of less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The licensee attributed the high conductivity.y,
readings in the reactor feedwater to ba the result of resins leaching'!
from the condansate filter demineralizers, and soluble organics fromysint sloughing off into the condenset' f.' ant the low pressure steam hoods.
To correct these problems the licensee M installing new condensate filter demineralizers and hydrolazing the law pressure hoods to remove the paint.
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Dose equivalent iodine-131 and gross beta gamma activity periodic test results for tk wst half of 1987 were selectively reviewed.
No problems were identified in frequency of testing or compliance with concentrations requirements.
No violations or deviations were identified.
9.
Calibrations and Functional Tests of Gaseous and 1.iquid Effluent Monitors The inspector selectively reviewed calibration and channel functional tests records for effluent radiation monitors on the liquid system (including the radwaste discharge and circulating water reservoir decant line) and gaseous system (off gas, reactor, turbine, service, radwaste and onsite storage building (OSSF) monitors).
Technical Specification (T/S) 4.3.7.11 requires calibration of the liquid monitors at 18 month intervals and source checks of the liquid radwaste discharge monitor prior to each release.
T/S 4.3.7.12 requires calibration of the gaseous monitors described above at 18 month intervals, source checks at monthly intervals, and channel functicnal tests at quarterly intervals.
The inspector reviewed selected calibration and source checks for the liquid and gaseous. effluent monitors described above for the period 1986 and 1987 to date.
The review showed proper calibrations on a timely basis.
The selected review of source checks and instrument setpoints identified no problems.
The initial calibration of liquid monitors involved determination of l
efficiency using a single concentration of cesuim-137, cobalt-57, and cobalt-60 liquid sources, and response to several different isotopic sources to determine lineatity of response and for use in subsequent calibration checks.
For subsequent calibrations an electronic linearity test is performed as well as verification that response to
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I decay corrected solid sources has remained within an established error band.
The initial calibration of the normal and accident range gaseous effluent monitors involved using several concentrations cf different noble gases to show counting efficiency for each isotope and to demonstrate linearity
characteristics over the range of the monitor for isotopes with different
beta energies.
At the same time, several solid sources with differing
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beta energies were counted and efficiencies determined.
During subsequent calibrations these solid sources are counted to show thtt the counting efficiency has not significantly changed over a broad range of energies.
Linearity is also verified by counting several sources of a
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single nuclide with a broad range of activities.
No violations or deviations were identified.
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.-10. ' Air Cleaning' Systems d,
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j4 In accordanceLwfui[ technical specifications, the control room emergency cj C'
filtration sybtem T/S 3/4.7.2) and the, standby gas treatment system a4 (T/S 3/4.6.5.3) are. tested.
Records snowed that the last T/S required tests
for the control.rpom emergency filtration and SGTS systems were performed-g'
in'accordance with procedures P0M 43.414.01 and POM 43.404.01, respectively,
and met applicableLT/S criteria.
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No violations or. deviations Vare identified.
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My 11. ~ Solid' Radioactive Waste
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The inspect'or revicwed the licensee's solid radioactive waste management -
- program, - including; determination whether changes to. equipment and procedures were ireaccordance with 10 CFR 50.59; 10 CFR 61.55 and. 61.56 and 10 CFR 20.311; aiequacy of implementing procedures to properly classify y' ; g-and characterize waste, prepare manifests, and mark packages; overall (
performance of the process control and quality assurance programs;.
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adequacy of required records, reports, and notifications; and experience A
concerning identification and correction of programmatic weaknesses.
Tours of the packaging and storage areas'were made.
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So' lid radioactive waste consists primarily of spent resins which are dewatered using a vendor (Chem-Nuclear). process system and DAW placed into 55 gallon steel drums, compacted, and prepared for transportation, The Chem-Nuclear system is connected to the licensee's centrifugal feed i
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\\ tank system in the OSSF; the vendor controls and operates the system.
The licensee's bitumen solidification system is being tested and is not operable.' The licensee operates the. system pursuant to an NRR approved Process Control Program (PCP).
The most recent revision to the PCP (Revision 8) incorporates the dewatering process used by the licensee's current vendor (Chem-Nuclear).
It appears that the waste is prepared in accordance with the PCP requirements.
To meet 10 CFR requirements, the licensee uses interim scating factors based on operating data from other.BWRs to classify wastes produced.
The BWR data base is analyzed using the Impell computer coje.
In the future, a sampling and analysis program will be implemented to generate Fermi-2 specific scaling factors.
Waste streams will be sampled and the samples shipped to an outside. laboratory for radiochemical analysis; the results will be used to determine plant specific scaling f actors.
No violations or deviations were identified.
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12.
Transportation of Radioactive Materials The inspector reviewed the licensee's radioactive materials transportation program, including:
determination whether written implementing procedures are adequate, maintained current, properly approved, and acceptably implemented; determination whether shipments ars 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 weaknesses.
Dry active waste (DAW) is compacted in 55 gallon steel drums. 00T Specification 17-H drums are used which meet the DOT 7-A criteria.
All packaged DAW has been stored in the OSSF since last fall; the first shipment will be made when sufficient DAW has been accumulated.
Liquid wastes consisting primarily of bead and powdered resins are dewatered using a vendor system.
From January 1 through June 30, 1987, approximately 16 curies of radioactive dewatered resins have been shipped for burial.
Selected records of radioactive shipments made in 1987 were reviewed for compliante with 49 CFR 170-189 and 10 CFR 71 requirements; no problems were noted.
No violations or deviations were identified.
13.
Audits and Appraisals
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The inspector reviewed reports of two audits of the radwaste program conducted by the licensee in January and June 1987.
The audits reviewed activities concerning radwaste shipping containers, documentation of radwaste shipments, and chemistry analysis of waste feed tanks.
The audits consisted mainly of procedures and records review.
No significant problems were noted.
However, some discrepancies were observed and the radwaste department took appropriate correctivo actions.
No violations or deviations were identified.
14.
Training and Qualification Effectiveness Liquid, solid, and gaseous radwaste processing, releases, and shipments are handled by operations and rad / chem personnel.
Laboratory work and l
analyses associated with effluent releases, monitor calibrations, and processing of waste for solidwaste shipments are performed by chemists, radiation protection and operations.
A formal training program exists for chemists which includes 0JT, plant specific and health physics theory; practical factor qualification is required.
Radwaste workers who compact DAW in preparation for shipment and are involved in the contractor solidification program also receive training.
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Non-licensed radwaste control room operators who operate the liquid process system are required to be trained and qualified in radwaste processing.
The licensee has recently developed a formal retraining program for radwaste operators.
The training effectiveness in the radwaste and chemistry programs appears adequate.
During a review of the radwaste program, it was noted that radwaste control room operators rotate through radwaste at less than one year intervals.
The inspector informed the licensee that although it appeared the radwaste control room operators were qualified and the policy of rotating nonpermanent operators through radwaste results in developing more operators, rotation prohibits development of an experienced staff that has continuity and a strong understanding of the radwaste system.
This matter was discussed at the exit meeting.
No violations or deviations were identified.
15.
Radiological Controls for Drywell Access During Spent Fuel Movement (TI 2500/23)
To date, the licensee has not performed a fuel movement with irradiated fuel; the first fuel transfers are scheduled to occur in 1988.
The licensee is aware of the need to establish effective programmatic radiological controls to protect drywell workers during spent fuel movements and thus far has obtained a leaded fuel-shute shield to limit dose rate levels in the drywell for defueling spent fuel.
In addition, the licensee intends to control access to the third and fourth levels of the drywell, and establish further radiological controls through specific RWPs, use of alarming devices, and alarms.
Although an operating procedure requires that radiation protection be notified prior to movement of irradiated fuel, existing radiation protection procedures do not specifically address drywell access during spent fuel movement, nor is j
there a formalized training program to provide workers an understanding
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of potential radiological hazards associated with working in the drywell during spent fuel movement.
In addition, there are no procedural limitations or prohibitions on spent fuel movement to ensure fuel is not moved close to the reactor pressure vessel inner wall when the drywell is occupied below the biological shield; this could represent a potential radiological hazard to individuals working around unshielded biological shield piping penetrations.
The matters concerning radiation protection procedures, formalized training, projected radiation levels through penetrations, and drywell radiological controls were discussed with the licensee, who committed to develop a program which meets the objectives of TI 2500/23 before the first refueling outage.
This matter
was discussed at the exit meeting and will be reviewed during a future j
inspection (0 pen Item 341/87037-01).
No violations or deviations were identified.
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16.
IE Information Notice Followup l'
The inspector reviewed the licensee's internal actions to selected IE Information Notices.
The licensee's evaluations, conclusions and corrective actions are presented below:
. Notice No. 87-32:
" Deficiencies in the Testing of Nuclear-Grade Activated Charcoal." This notice alerts licensees to deficiencies found in the testing of nuclear grade activated charcoal used for accident mitigation in nuclear facilities.
Testing of charcoal filters is performed for the licensee by a vendor which reportedly performed satisfactorily during the NRC/ Idaho National Engineering interlaboratory comparison study.
The licensee anticipates retaining the services of their vendor and plans no actions as a result of'this notice.
No violations or deviations were identified.
17.
DevistionEventReport The inspector reviewed Deviation Event Report No.87-285 which concerned the'inoperability of the division 2 SGTS accident range monitor (AXM).
The report discussed the licensee's review and investigation of the circumstances which led to the inoperability of the system.
Based on their review, the licensee intends to initiate an Licensee Event Report (LER).
The inspector will review the LER, and the licensee's corrective actions to prevent recurrence, at a future inspection.
This matter.was discussed at the exit meeting (0 pen Item 341/87037-02).
No violations or deviations were identified.
18.
Allegations An allegation regarding the emission of radon gas from reactor fuel was received by Region III by telephone from a member of the Michigan Department of Health who was forwarding the allegation they received from an employee of the Fermi plant.
The allegation and the inspector's findings are presented below (Allegation No. RIII-87-A-0104 (CLOSED)).
Allegation:
The fuel in the reactor is emitting radon which contaminates employee's hardhats and clothing.
Discussion:
To make reactor fuel, uranium ore is processed to extract J
The uranium is then enriched to fuel grade.
During the processing cycle, all radium-226, which emits radon-222 gas as a daughter product, is removed.
During a typical reactor fuel cycle no appreciable radium-226 is produced as daughter products of the uranium isotopes in the fuel because of the long half-lives of uranium decay products.
For these reasons, reactor fuel does not generate appreciable amounts of radon gases.
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Radium-226 is a naturally occurring radioisotope that is found in rocks and soils and becomes incorporated in various building materials such as
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decay of radium-226, are present to some extent in all buildings and tend to adhere to clothing, particularly polyesters. Because reactor facilities have sensitive personal monitoring devices, the naturally occurring radium daughters may occasionally be detected on personal clothing. The licensee has developed a one-year program to monitor the radon levels in the plant and to seek methods of reduction.
Findings: This allegation was not substantiated.
19.
Exit Meeting The inspector met with licensee representatives (denoted in Paragraph 1)
.throughout and at the conclusion of the inspection. The inspector summarized the scope and findings of the inspection activities. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection.
The licensee did not identify any such documents or processes as proprietary.
In response to the inspector's comments, the licensee:
a.
Acknowledged the inspector's comments concerning the policy of rotating radwaste control operators (Section 14).
b.
Stated that the problem associated with the inoperable AXM did not appear to be a technical specification violation and, based on their review of the problem, an 1.ER will be issued (Section 17).
c.
Stated that a program would be developed to ensure radiological controls were in place for personnel working in the drywell during transfer of spent fuel (Section 15).
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