IR 05000344/1993002
| ML20044C455 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 02/19/1993 |
| From: | Coblentz L, Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20044C450 | List: |
| References | |
| 50-344-93-02, 50-344-93-2, NUDOCS 9303230059 | |
| Download: ML20044C455 (10) | |
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U. S. NUCLEAR REGULATORY-COMMISSION
REGION V
p Report:
50-344/93-02 License:
HPF-1
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e Licensee:
Portland General Electric Company
.121 SW Salmon Street-Portland, Oregon 97204 Facility:
Trojan Nuclear Plant Inspection location:
Rainier, Oregon Inspection duration:
February 1 - 5, 1 93 Inspected by:
l'/Pkf3-L obikntz,Se r Al 'ation Specialist Date Signed-Approved by:
[Ohl44 h
2 /4!93 ames/h.~ Reese', Chief /
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Date Signed.
ilMies-Radiological Protection Branch
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Summary:
Areas Inspected:
Routine, unannounced inspection of followup' items'and..
were used.
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Inspection. procedures'92700,192701,'92702,1and_83750:-
occupational exposure.
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Results: The licensee's radiation protection.and chemistry organizations were making changes to adapt monitoring strategies ~for' permanent facility-shutdown.
The radiation protection and chemistry staff was maintaining a high;overall degree of professionalism during this adjustment ~ period. -One violation was-identified by the. inspector, regarding the failure ~ to accurately post an, area-in the Radwaste Storage. Building as a "high radiation area."-.In addition,.one,
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'non-cited licensee-identified' violation was noted, regarding changes. to vendor-methods which resulted in failing to meet the required lower limit of detection (LLD) for iodine-131 in environmental milk samples.'
9303230059'930219 P
PDR ADOCK 05000344
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DETAILS 1.
Persons Contacted Licensee
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J. Benjamin, Manager, Quality Controls A. Bowman, Supervisor, Radiation Protection (RP) Technicians
- M. Featherston, Engineer, Nuclear Compliance
- G. Huey, Acting Manager, RP Technical Support L. Larson, Engineer, Radwaste
- R. Machon, General Manager, Trojan Nuclear Plant
- T. Heek, Manager, Personnel Protection
M. Nolan, Supervisor, Radwaste D. Nordstrom, Manager, Nuclear Oversight
- G. Rich, Manager, Chemistry W. Robinson, Vice President, Nuclear
- T. Walt, General Manager, Technical Functions
- J. Westvold, Supervisor, Quality Audits
- W. Williams, Manager, Nuclear Compliance Other J. Franco, Inspector, Oregon Department of Energy (ODOE)
K. Johnston, Senior Resident Inspector, NRC
- J. Melfi, Resident Inspector, HRC
- V. Sarte, Resident Inspector, ODOE
{*) Denotes those individuals who attended the exit meeting on february 5, 1993. The inspector met and held discussions with_ additional members of the licensee's staff during the inspection.
2.
Followup of Licensee Event Reports (LERs) (92700)
Item 50-344/92-17-LO (Closed): This LER involved the failure to obtain and analyze a grab sample of the Auxiliary Building ventilation system as required by Trojan Technical Specifications (TSs). TS 3.3.3.11, Action Statement 28, requires that grab samples be taken at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during periods when the Auxiliary Building process radiation monitor (PRM-2) is inoperable.
The licensee had determined the root cause of this failure to be inadequate Chemistry management controls to ensure proper TS implementation.
As a result, the Chemistry night orders were changed, chemistry technicians were trained on the requirement, the applicable chemistry procedure was revised, a monitoring schedule was developed, and a " Lessons Learned" summary was distributed to plant personnel describing the event.
The inspector verified that chemistry technicians were knowledgeable on this and other TS requirements for grab sampling. No other instances of failure to take required samples were identified during the inspection.
The inspector had no further questions in this matte (
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3.
Followun (92701)
a.
Item 50-344/92-08-01 (Closed):
This item concerned the lack of clearly defined licensee compensatory actions for obtaining primary coolant samples under accident conditions during periods of PASS (post-accident sampling system) inoperability. The licensee had provided additional training to chemistry technicians and operators regarding alternate sampling methods.
In addition, the. licensee had planned to further revise Chemistry _
Procedure CMP-41, " Reactor Coolant Liquid Post-Accident Sampling System Operating Procedure," to give more specific guidance on alternate sampling methods. However, on January 26,'1993, based on plans for permanent shutdown, the licensee had decided to take no further action on this matter, since PASS would no longer be required without fuel in the reactor vessel.
The inspector had no further questions in this matter.
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Item 50-344/92-29-02 (Closed): This unresolved item involved the difficulty in meeting the lower limit of detection (LLD) for iodine-131 in radioactive gaseous effluents during containment pressure relief operations. This difficulty was due, in general, to terminating pressure relief operations prior to obtaining a sample volume sufficient to meet the required LLD.
The Chemistry Department had recommended a TS revision to include the following note from Draft HUREG-0472, Revision 2, " Radiological Effluent Technical Specifications for PWR's":
Occasionally... unavoidably small sample. sizes... may render these LLDs unachievable.
In such cases, the contributing factors will be identified and described in the semiannual Radioactive Effluent Release Report.
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This corrective action had been abandoned, due to the licensee's plans for permanent' shutdown. ' The inspector noted, in addition, that with the reactor vessel defueled, the containment pressure relief mode would no longer be used or applicable.
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The inspector had no further questions in this matter.
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Item 50-344/92-31-01 (Closed): This item involved the failure to meet the the.TS-required LLD for iodine-131 in environmental milk samples. The Albuquerque, New Mexico vendor that performed the
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licensee's environmental analyses had failed to meet the LLDs
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required by the licensee's contract from December 9,1991, until April 27, 1992.
The inspector noted that TS 4.12.1 requires, in part, that analysis
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of environmental samples be performed in accordance with TS Table-3.12-1, which, in turn, permits a maximum LLD of 1 picocurie per
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liter for iodine-131 in milk. As defined
,t-TS, this LLD is an a priori limit; that is, the limit is based '
.- capability of a measurement system for the specific type of sat;iple "before the l
fact," as opposed to being based on the "after-the-fact" conditions
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The inspector noted, further, that on occasions when this problem had been identified in the past (see Inspection Reports 50-344/90-q 37, 50-344/91-02, and 50-344/91-30), it had involved individual i
samples and "after-the-fact" conditions. However, for the samples
i presently in question (December 1991 to April 1992),. the failure to achieve the required LLD had been due to changes made in the vendor's laboratory methods (i.e., changes to the a' priori
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Review of licensee records and vendor correspondence indicated that this problem had been identified by the licensee in April 1992. The vendor had agreed to change back to the previous methods of performing the analysis, in order to achieve the required LLD. The vendor had re-implemented the previous analysis method as of May ll, j
1992.
To prevent recurrence of this problem, the licensee had negotiated a new sample analysis contract with the vendor, in which minimum detectable activities (MDAs) were specified that were equal to or less than the TS-required LLDs.
In addition, the turn-around times for the laboratory had been shortened to facilitate more-timely licensee review of data.
The inspector concluded that the failure to meet the LLD for iodine-131, due to a priori laboratory conditions, constituted a violation of TS 4.12.1.
However,. due to the licensee's self-identification of this matter, and due to the thorough corrective actions taken and proposed, the inspector concluded that the criteria of Section V.G of the NRC Enforcement Policy had been met. As such, this violation will not be cited (50-344/93-02-01).
d.
Item 50-344/92-31-02 (Closedh This item involved the inadvertent draining of resin from the spent resin storage' tank (SRST) to the.
clean waste receiver tank (CWRT). - The licensee had reviewed this -
event, and found that overall worker knowledge of the system had-been adequate; however, errors in:the system drawings had led operators to conduct an improper line-up. These drawings had been appropriately revised.
In addition, the Manager, Personnel Protection stated that Operations had agreed, in the future, to exert a higher _ level of control for similar operations. This would involve using existing procedures or writing special work instructions for draining' the SRST and associated piping, rather than relying simply on a clearance.
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The inspector had no further questions in this matter.
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Item 50-344/92-31-03 (Closed): This item involved the discovery of hydrogen gas in drums of powdex resin containing low-level
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radioactivity. The licensee stated that, as of January 11, 1993,
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the Richland, Washington waste processing vendor had reported that i
i all drums of Trojan powdex waste had been shipped to the burial site.
i In attempting to determine the mechanism causing hydrogen generation and buildup in the sealed drums, the licensee had examined several
drums onsite, and had considered several possibilities:
j (1) Generation of hydrogen due to radiolytic decomposition of water had been rejected as not feasible, due to the extremely low
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levels of radioactivity present.
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(2) Generation of gas due to bacteria had been rejected due to the
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lack of anaerobic activity, and the absence of bacterial l
products (such as methane).
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(3) The licensee had concluded that hydrogen had been generated by chloride corrosion of the drum surface, engendered by the high t
chloride content of the dessicant material (Speedi-bri) used as-
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packaging with the Powdex. Examination of several drums had i
shown corrosion only in those areas in which dessicant had come
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into contact with the drum surface. The licensee believed that i
the corrosion had occurred similarly in all drums containing
Powdex and Speedi-Dri; however, only those drums with an Li extremely tight seal had been pressurized by the hydrogen
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buildup.
The licensee had revised RP Procedure RPMP 2-2, " Drumming Spent-j Radioactive Powdex Resin Waste," to require that a passive vent I
would be installed on all drums used for this purpose, j
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The inspector had no further questions in this matter.
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4.
Followuo of items of Non-Compliance (92702)
a.
Item 50-344/92-26-01 (Closed): This non-cited. violation involved the failure to strictly adhere to the methods defined'in the i
licensee's Offsite Dose Calculation Manual (ODCM) when computing-i offite doses, as required by TS 6.9.1.5.4.
In addition, several
inaccuracies had been identified in the licensee's computer-codes
used for these calculations.
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The RP Technical Support group had completed their revisions to the
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computer codes, correcting the discrepancies identified.
In addition, the licensee was in the process of making. appropriate revisions to the ODCM implementing procedure.
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The inspector had no further questions in this matter.
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Item 50-344/92-29-01 (Closed): This violation involved the failure to maintain traceability to the National Institute of Standards' and
, Technology (NIST) for a radioactive: calibration standard.- The
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traceability for the calibration standard had exceeded the manufacturer's shelf life, and the licensee had not evaluated or-i authorized its continued use.-
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As corrective action, the licensee had revised Chemistry Laboratory 1 Procedure CL-153, " Calibration Check and Efficiency Calibration,":to require appropriate evaluation prior to use of expired radioactive.
standards. A new standard had been obtained, and the expired
radioactive standard had been disposed of.
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The inspector had no further questions in this matter.
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5.
Occupational Radiation Exposure (83750)
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The inspector reviewed this program area'by examination of selected proedures, records, and audits, discussions with cognizant personnel, observation of activities in progress, and conducting independent l
radiation surveys. Observations were made regarding audits and
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surveillances, organizational changes, and external exposure control.
a.
Audits and Surveillances
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The inspector reviewed the reports for the following audits' and surveillances:
AP-693, " Nuclear Oversight Quality Assurance Department Audit
of Radiation Protection /Radwaste," dated January 20,'1993 92-005-SURV, " Radiation Protection Start-Up Activities," dated
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february 5, 1992
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92-012-SURV, " Summary of Trojan Beta Dosimetry History,"' dated
February 26, 1992
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92-016-SURV, " Surveillance of Radwaste Containers," dated March
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31, 1992-t 92-015-SURV, " Control of Confined Area Entry," dated April 1,-
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92-024-SURV, " Personnel Contamination Incidents of May 7th and
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8th," dated May 11, 1992
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92-026-SURV, " Control of Mixed Hazardous' and Radioactive
-Waste," dated May. 21, 1992 l
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92-048-SURV, " Surveillance of Rad Waste Implementation of RPMP
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8-2," dated August 25, 1992 92-055-SURV, " Posting and Labeling in Radiologically Controlled
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Areas," dated August 28, 1992
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92-072-SURV, " Auxiliary Building Airborne Radioactivity Release
- October 21, 1992," dated October 31, 1992
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92-083-SURV, " Forced Outage Containment Surveys," dated l
November 19, 1992
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92-077-SURV, " Quality Assurance Surveillance of the October 27,
1992 Post Accident Sampling System (PASS) Sampling and Analysis," dated November 20, 1992
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92-082-SURV, " Quality Assurance Surveillance of Radiological'
Protection Activities during the Forced Outage," dated December 8, 1992
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In general, the audits and surveillances appeared probing and-technically sound. Observations were made regarding needed i'
improvements for specific procedures, confined space entries,
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criteria for ALARA pre-job briefings, and other areas.
Surveillance 92-026-SURV had resulted in considerable improvements to the licensee's mixed waste identification and storage practices.
No violations or deviations were identified in this area.
b.
Oroanizational Chances The inspector had discussions with the Vice President,; Nuclear, the Plant General Manager, and the Manager, Personnel Protection, regarding the expected changes to the RP-and chemistry organizations'
in view of the planned permanent shutdown.
Several points were noted:
(1) Organizational titles and reporting structures,. for the present, would remain' the same, so as to alleviate confusion
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(2) Procedures were undergoing appropriate revision to reflect differences in focus regarding RP surveys and chemistry t
monitoring.
(3) Prior p1ans to move-the radiological effluent criteria-from the
' t TS to the ODCM were proceeding as before.
Plans to implement the new 10 CFR 20 requirements were' also proceeding as before,
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for an implementation date of January 1,1994.
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No violations or deviations were identified in this area.
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External Exposure Controls The inspector' conducted extensive tours of the licensee's facility, including the Containment Building, Auxiliary Building, Radwaste Building, and Radwaste Storage Building. During facility tours, the inspector conducted independent radiation surveys, using the following instruments:
NRC Xetex survey instrument (Geiger-Mueller (GM) tube detector)
- 008961, due for calibration April 1,1993 PGE PRM-7 survey instrument (ion chamber detector) #462, due
for calibration March 10, 1993 PGE E-530 survey instrument (GM tube detector) #440, due for
calibration March 21, 1993 In addition, the inspector reviewed radiation surveys, associated -
logbooks, and radiation work permits. Several observations were of--
note:
(1) Despite the low morale engendered by the licensee's plans for-permanent shutdown, the RP staff had maintained a high degree of professionalism. RP practices observed, in most cases, were in accordance with NRC regulations and plant procedures.
(2) The personnel contamination log, kept at the radiologically
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controlled area (RCA) exit point, did not have a place for-recording the time or date.
Log entries routinely recorded persons who had been authorized to leave the RCA without successfully clearing the personnel contamination monitors (PCMs). This authorization was usually based on a successful whole-body frisk, coupled with the presence of radon gas, as confirmed by an air sample for the' area in which the person had been. The inspector noted that the absence of a recorded time and date made subsequent verification of the air samples extremely difficult.
(3)
In the Radwaste Annex, the inspector noticed a 5-gallon polyethylene container of waste oil that was not labeled as containing radioactive' material. The inspector brought this-item to the attention of the RP Technician Supervisor (RPTS).
After investigating, the RPTS stated that the waste oil. had, in
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fact, been taken from a contaminated system. The container was-promptly labeled.
(4) On Wednesday, February 3, 1993,.the inspector..made a tour of the Radwaste Storage Building with an ODOE inspector. While conducting a survey of radioactive material containers stored in the building, the inspectors measured radiation levels of approximately 130 millirem per hour (mrem /hr) coming from three 55-gallon drums containing steam generator (SG) inserts. The
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inspectors specifically noted the following points:
(a) The drum labels recorded radiation levels as 35 mrem /hr on contact and 200 mrem /hr at 18 inches.
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(b) The three drums had been placed in a triangular
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arrangement, approximately 18 inches apart, in a manner to allow personnel free access between the drums.
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(c) The highest (whole-body accessible) radiation levels-
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measured were in the center of the triangular arrangement,,
with the survey instrument detector probe held about 30 inches from the floor (slightly above knee level).
Radiation levels dropped off sharply (from 130 mrem /hr to about 80 mrem /hr) when the detector probe was raised or lowered more than about 8 inches.
(d)
10 CFR 20.202(b)(3) defines a "high radiation area" as:
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...any area, accessible to personnel,. in which there exists radiation originating in whole or in part within licensed material at such~ levels that a major portion of the body could receive in any one hour a dose in excess of 100 millirem.
10 CFR 20.203(c) requires that each high radiation area be conspicuously posted with a sign or signs-bearing the ~
radiation caution symbol and the words:
" Caution High Radiation Area."
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(e) The area in question-was posted as a radiation area,. an' d not as a high radiation area.
The inspectors brought this matter to the attention of the
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Manager, Personnel Protection and the RPTS.. The RPTS
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immediately called several RP technicians, who verified the inspectors' survey results and promptly posted the area as a high radiation area.
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The licensee was unable to determine how the drums'had gotten placed-in their present arrangement. The most recent surveys did not show the elevated radiation levels. The licensee noted that the elevated radiation levels were only present at: a-particular horizontal plane, as discussed above;;this appeared
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to be due to the contributing dose from all three' drums, and specifically due to the horizontal placement of a relatively
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high-radiation SG insert at the'same height in each of the j
three drums.
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As further corrective action, the RP Manager and RPTS promptly held training for the entire staff of radiation protection
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r technicians. Other areas of the plant were surveyed, and no i
additional examples of this problem were found.
In addition, i
the RPM stated that a high radiation storage area was being set
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aside in the Radwaste Building, which would be designated for i
l storing any radioactive waste measuring greater than 100 mrem /hr on contact. As necessary, a separate location would be i
set aside in the Auxiliary Building / Fuel Handling Building for l
the same purpose.
l The inspector concluded that the-failure to post the area around the three radwaste drums as a high radiation area
constituted a violation of 10 CFR 20.203(c) (50-344/93-02-02).
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However, based on the promptness and thoroughness of the licensee's corrective action, and based on additional inspector
surveys that indicated this to be an isolated case, no response will be required for this violation.
The licensee's program in this area, with the exception of the i
posting problem described above, appeared to be maintaining an
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adequate level of performance. One violation of NRC requirements i
and no deviations were identified.
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Exit Interview-
i The inspector met with the individuals designated in Section 1 at the conclusion of the inspection on February 5,1993. The scope and findings of the inspection were summarized. The licensee acknowledged the j
inspector's observations.
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