IR 05000346/1997012

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Insp Rept 50-346/97-12 on 971006-10.Violations Noted. Major Areas Inspected:Review of Radiation Protection & Chemistry Programs
ML20198Q090
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 11/04/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20198Q054 List:
References
50-346-97-12, NUDOCS 9711120107
Download: ML20198Q090 (17)


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U.S. NUCLEAR REGULATORY COMMISSION REGIONlli Docket No: 50-346-License No: NPF-3 Report No: 50-346/97012(DRS) y Licensee: Centerior Service Company Facility: Davis-Besse Nuclear Power Station Location: 5501 North State - Route 2 Oak Harbor, OH 43449 Dates: October 6-10,1997 Inspector: Kara N. Selburg, Radiation Specialist Approved by: Gary L, Shear, Chief, Plant Support Branch 2 Division of Reactor Safety

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9711120107 971104 PDR ADOCK 05000346 G PDR

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EXECUTIVE SUMMARY Davis Besse NJclear Power Plant, Unit 1 NRC Inspection Report 50-346/97012 This routine inspection included a review of the radiation protection and chemistry program Specifically, the inspector reviewed the licensee's chemistry program, the radiological environmental monitoring program, post acddent sampling capabilities, radioactive waste processing, transportation of radioactive material, radiation worker practices, and radiological control .

The licensee failed to maintain a radioactive material shipment, which was sent to the Perry Nuclear Power Plant on August 28,1997, within the regulatory lin 4ts for external radiation levels for a Limited Quantity shipment. While the dose rates associated with the shipment were such that the potential for personnel to receive significant dose was

unlikely, the failure to perform an adequate survey to ensure that regulatory limits were met was of concern. (Section R1.1)

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The water chemistry of primary and secondary systems was well maintained and monitored. Levels of corrosive impurities were maintained below industry guideline (Section R1.2)

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There was ra discernable impact on the environment from plant operations. Specific aspects of the radiological environmental monitoring program, including material condition of air sampling equipment, and sample collection were appropriately implemented. (Section R1.3)

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The post accident sampling system (PASS) was effectively maintained as required by technical specifications. Material condition and maintenance history was tracked, individuals were trained, and the PASS samples showed good agreement with reactor coolant system samples. One inspection follow-up item was opened to evaluate the long term corrective actions for a PASS configuration which resulted in an alarm of the cafety features actuation system radiation monitors. (Section R2.1)

. During immediate action maintenance conducted on September 4,1997, a narrow focus on completing the evolution resulted in workers failing to contact radiation protection prior to the start of the evo!ution, as required by the radiation work permit. Several workers in the area were unaware of the actual radiological conditions. (Section R4.1)

. The chemistry laboratory quality control program was effective, and ensured that the licensee could obtain accurate chemical and radiochemical analyses. (Section R7.1)

. The corrective actions implemented to address a violation regarding the failure to appropriately post a radiation area were effective in preventing recurrence. (Section R8.3)

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Reoort Details IV. Plant Support l R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Transoortation of Radioactive Materialin Excess of DOT Radiation Limits

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The inspector reviewed the circumstances surrounding an August 28,1997, transportation incident in which a shipment of radioactive material was inappropriately characterized. The inspector interviewed personnelinvolved with the event and event investigation, reviewed applicable radiological survey records, and reviewed the calibration results of the survey instrumentation. The inspector also reviewed the applicable procedures and procedure changes, Observations and Findinos On August 28,1997, the Perry Nuclear Power Plant Radioactive Material Coordinator

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notified the Davis Besse Radiation Protection Radioactive Material Shipping coordinator that one of the four boxes (PB-07) of lead received as part of Davis Besse Shipment RM 9729 (a Limited Quantity shipment) had a beta-gamma measurement of 2.5 millirem per hour (mrem /hr) on the right side,1.2 mrem /hr on the front, and 0.7 mrem /hr on the bottom of the box. This exceeded the 0.5 mrem /hr maximum radiation limit on the external package required for excepted packages of limited quantitles in 49 CFR 173.421. The surveys performed by the licensee prior to shipment indicated a maximum reading of 0.25 mrem /hr on box PB-07 at the bottom of the bo The radiation protection technician (RPT) who performed the initial radiological survey had been informed that (based on prior surveys of the lead) the shipment was anticipated to be sent as a Limited Quantity. The RPT performed the survey using an Extender 2000W, and noted dose rates in excess of 0.5 mrem /hr on box PB-07. Since this was not the anticipated dose rate for a Limited Quantity shipment, the technician performed a second survey using a Bicron Micro Remeter, and noted maximum dose rates on box PB-07 of 0.25 mrem /hr. The RPT recorded this data without performing any subsequent surveys, and without informing supervision of the higher than anticipated dose rates attained with the Extender 2000 After Perry discovered the higher than expected dose rates, the licensee performed calibration and source checks of the instrumentation used to perform the initial radiological surveys and determined that the checks were sati:; factory for each instrument indicating proper instrument performance. Additionally, both licensees determined that the lead in the packages was sufficiently braced, and the trip between the two licensees was relatively short, such that shifting of the contents was unlikel Through discussions with the RPT, and through the elimination of other probable causes, the licensee determined that the RPT had performed the survey using the

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Bicron Micro Remeter which was set on the incorrect scale (the x10 scale instead of the x1 scale), and thus causing the incorrect dose rates to be recorded.

l The root cause of this event was an inadequate survey caused by personnel error in l using a radiological survey ir,strument on the incorrect scaling factor. The safety significance of this event was very low. The additional dose rate on the box was 2 mrem /hr, which is radiologically insignificant. * .v notable increase in radiological exposure occurred as a result of this shipment. While this issue was not radiologically significant, this issue was of regulatory sigalficance because the classification allowed the shipment to be excepted from additional Department of Transportation (DOT)

requirement The licensee's corrective actions were timely, thorough, and should be sufficient to prevent recurrence. The licensee performed the following corrective actions:

The licensee coordinated efforts with the Perry Nuclear Power Plant to ensure proper handling of the box. The licensee also received and reviewed radiological surveys documenting the as-found condition of the box at Perry;

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The licensee initiated a Category 2 Potential Condition Adverse to Quality Report (PCAQR) investigation;

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'Ihe licensee isolated and tested the two instruments used for the radiologicel survey (the Extender 2000W LI 2.7.249, and the Bicron Micro Remeter LI 2.7.316). Instrument response checks and calibration checks were satisfactory;

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The licensee interviewed personnel and investigated the perfonnance of

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radiological surveys associated with the radioactive material shipment;

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The licensee issued a Standing Order (97-0005) to all Radiation Protection Supervisors, Radiation Protection Technicians and Health Physics Sarvicemen involved with radioactive material shipments which required that all radioactive waste and radioactive material shipments be made with the performance of two individual radiological surveys;

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The licensee revised procedure DB-HP-01500 Revision 01, " Shipping Radioactive Material," to specify the survey instrument type (Extender 2000W),

and require independent external radiation surveys; and

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The individual who had performed the radiological survey was counseled on appropriate survey technique No significant problems with radiological surveys performed by radiation protection personnel, and no inaccurate surveys associated with radioactive material shipments or radioactive waste shipments had occurred within the last three years. Additionally, the overall sustained performance of the licensee in the areas of radiation protection and transportation hed been good. However, licensees who ship radioactive material are

a required to comply with 10 CFR 71.5 which requires licensees to comply with the l requirements of 49 CFR parts 170 through 189. 49 CFR 173.421 requires that a j package excepted from the specification packaging, marking and labeling requirements, and the shipping paper and certification requirements must have external package readings of up to 0.025 mSv/hr. The package sent bv the licensee had radiation levels which exceeded the 0.005 mSv/hr maximum radiation limit on the external package required for excepted packages, which resulted in a violation of 49 CFR 173.421 (VIO 50-346/97012-01). Conclusions The failure to maintain a radioactive material shipmer.:within the regulatory limits for external radiation is significant since these lim.ts are established to ensure the health and safety of the public and of the workers associated with package preparation, transfer, and receipt. On August 28,1997, the licensee failed to ensure that these limits were met due to the performance of an inadequate radiological survey. The failure to perform an adequate survey la significant, however, the potential for personnel to receive a significant exposure from the shipment was minimal due to the low external dose rates. While this issue is not radiologically significant, this issue ic of regulatory significance because the classification allowed the shipment to be excepted from additional DOT requirement R1.2 Plant Water Chemistrv Control Insoection Scoce (IP 84750)

The inspector reviewed the licensee's management of primary and secondary water chemistry. Included was a review of the licensee's trending and analyses of chemistry parameters for the period of July 1996 through September 1997, and a review of selected procedures. The inspector compared the licensee's program to the Electric Power Research Insmutes (EPRI) Pressurized Water Reactor (PWR) water chemistry guidelines, Observations and Findinas-The licensee maintained excellent control of the secondary system consistent with the EPRI PWR Secondary Water Chemistry Guidel5es. On August 29,1995, the licensee switched to an elevated morpholine addition to minimize steam generator fouling and 6xtend the time when steam generator deposits must be physically removed to maintain 100% power operation. The inspector reviewed the licensee's trends of parameters and noted that the chhnge to the elevated morpholine appeared to lower the rate of incune of the steam generator fouling.

The licensee maintained excellent control of primary water chemistry, and maintained this program consistent with the EPRI PWR Primary Water Chemistry Guideline ,

Chloride concentrations approached the licensee's lower limit of detection of 1 part per billion (ppb), and fluoride concentrations were approximately 2 ppb. These rates were

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well beneath industry guidelines and indicated that the purification systems were effective and that there were minimal circulating water intrusions. Sulfate concentrations remained at or near the lower limit of detection of 3 ppb indicating no resin intrusio The inspector noted that fuel integrity was consistently monitored, and chemistry data Indicated that the integrity was very good. The concentration of xenon 133 (Xe 133)

remained constant with the exception of a reactor trip in the second quarter of 1997, and

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no increases were observed with reactor coolant radiolodines. Finally, primary to secondary leakage remained at less than 0.1 gallons per day based on a condenser of gas analysis and comparison of reactor coolant system and condensate tritium

" 3ncontration Conclus!ord The v'ater chemistry of primary and secondary systems was well maintained and monitored. Levels of corrosive impurities were maintained below industry guideline R1.3 .tadiological Environmental Monitoring Program kl1DECtion Scoon (IP 84750)

Tha inspector reviewed the implementation of the Radiolo0lcal Environmental

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Monitoring Program (REMP) based on requirements of the Off site Dose Calculation Manual (ODCl.1). The inspector also observed air and water sample collection and examined air sampling equipment. The 1996 Annual Radiological Environmental

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Operating Report (AOR) was reviewed to ensure that the report was submitted as required and to evaluate the effect of plant operations on the environmen Observations and Findings The materist condition of the air sampling t.quipment was very good, and sampling was performed in accordance with procedures. The sampling was conducted by a radiation protection tester and the inspector noted that the individual was knowledgeable of the sample locations, and sample acquisition processes. The AOR for 1996 presented the data in an organized manner and appropriate documentation for missed samples was included. The AOR data demonstrated that there was no discemable radiological impact on the environment due to plant operation The licensee had some problems in 1997 with ' 31 thermolumimscent detectors (TLDs)

used for environmental monitoring. The i" tor noted that tne licenses appropriately documented this in a PCAOR. The R uommunicated with local law enforcement officials to address the possibility u wr: m as the culprit for the missing TLDs. The lost samples were to be documented in ' 1997 AO he licensee continued to implerv ' a GMP enhancement program which provided more comprehensive analyses tt ,. c. onmentalimpacts from the operation of the 5 j

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facility. The inspector noted that the licensee was conservative in implementing the enhanced program to further ensure accurate monitoring of the facility's effect ni surrounding areas, Coaci.uslQmi There had been no discernable impact on the environment from plant operation Specific aspects of the REMP program, including material condition of air sampling equipment, and sample collection were appropriately implemente R2 Status of RP&C Facilities and Equipment R Post Accident Samolina System Insp3ction Scooe flP 84750)

The inspector reviewed the licensee's post accident sampling system (PASS) program, and compared it to technical specification requirements. The inspector also reviewed the licensee's PASS sample results. The inspector inspected the system, reviewed the material condition history, and discussed the resolution of the material condition problems with the appropriate personnel. In addition, the inspector reviewed the circumstances surrounding a September 16,1997, actuation of the safety feature actuation system (SFAS) radiation monitors during a PASS sample valve configuratio Observations and Findings The inspector noted that the post accident sampling system was being maintained as required by technical specifications. Testers were routinely trainoa on the use of the system, and the maintenance of the system was being effectively tracked. Samples obtained from the PASS showed good agreement with the reactor coolant samples, Indicating that the PASS could adequately obtain a representative sample during accident condition Overall, the material condition of the PASS was slightly improved from the last PASS Inspection (IR 50 346/96013), with fewer maintonance 1sgs observed on the system, and no problems recorded with sample acquisitions. However, two check valves (the demineralizer water flush check valve (SS 238), and the out!et isolation valve to the reactor coolant drain tank (SV 4637)) were leaking by and causing a slow increase in the reactor coolant drain tank level. These valves were tentatively scheduled to be repaired by October 27,1997, however, the licensee was having difficulties loca'ing the appropriate part The licensee continued to perform monthly surveillances on the PASS system. On September 16,1997, during the line up for a PASS sample flow test, operations opened two valves to line up the reactor coolant system's (RCS) cold leg for the flow test. After approximately 30 seconds in this configuration, operations received alarms on the safety features actuation system radiation monitors indicating that these monitors were reading

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radiation levels in excess of the alarm trip points. Operations staff secured the line up, compared the SFAS radiation monitor readings to the expected values, and noted that the values had returned to normal. The annunciators were reset within 10 minutes after the satisfactory channel comparisons were verified. An apparent build up of CRUD had passed through the RCS cold leg, increasing general area radiation levels, thus actuating the SFAS radiation monitors in the general area of the lin Periodic checking of the SFAS radiation monitor trends from the radiation monitoring computer databass unit found that on some occasions those monitors had recorded increases 11 radiation levels when chemistry samples were obtained or flow checks were performed. However, the radlation level increases were minor (when compared to the trip set pcInts), and no alarms or trips had been received during the chemistry check Therefor 9, plant engineering personnel, who were aware of these increases, did not consider that a trip was probable, and did not officially contact chemistry or document the trend The lir,ensee was considering several corrective actions to prevent recurrence of this type of event, including potentially shielding the line, obtaining a sample from another location, moving the location of the radiation monitor, or receiving an exemption from the NRC from having to maintain the SFAS radiation monitors. Currently, the licensee was not obtalning samples through the cold leg, but instead determining a flow path out of containment, then, after isolating the line, testing the valves. The inspector noted that the short term corrective actions were consistent with the PASS system requirement However, this item will be tracked as an open item pending the final resolution of this raroblem (IFl 50-346/97012-02). Conclusions The inspector noted that the licensee was effectively maintaining PASS as required by technical specifications. Material condition and maintenance history was tracked, individuals were trained, and the PASS samples showed good agreement with reactor coolant system samples, One inspection follow up item was opaned to evaluate the long term corrective actions for a PASS configuraibn which rosulted in an alarm of the SFAS radiation monitor R4 Staff Knowledge and Performance in RP&C R Poor UnderstandiDS Of RadioloalerJ Conditions Durina immediate Action Maintenanco IDSoection Scooe (IP 83750)

The inspector reviewed radiological contruts utilized during immediate action maintenance performed in the tscay heat cooler room on September 4,1997. The circumstances regarding the maintenance activities were described in Licensee Event Report 97 012. The inspector reviewed radiological survey maps, radiation worker exposures, radiation work permits, and the licensee's investigation results. The

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Inspector interviewed numerous radiation protection and maintenance personnel involved with the event, Observations and Findingg During the conduct of immediate action maintenance (IAM) on the decay heat coolers performed on September 4,1997, several maintenance workers entered the radiologically restricted area without complying with theli radiation work permit (RWP 1997-0601, revision 1). Specifically, th9 individuals did not contact radiation protection prior to starting the work evolutio From interviews w!th various maintenance and radiation protection personnel, the inspector noted that the maintenance workers had felt pressured to complete this activity as quickly as possible in order to prevent the station from entering Technical

- Specification 3.03 actions. Further discussions with certain maintenance workers indicated that they considered entering this action statement as important to safety as entering an emergency classification. This focus, in conjunction with no IAM procedural remindert to involve radiation protection (RP), resulted in the workers entering the radiologically restricted area (RRA) without contacting RP. After the workers began the evolution, other maintenance personne entered the RRA and appropriately contacted RP When RP arrived at the work site several workers were interviewed who were unaware of the current radiological conditions in the room. Radiological surveys of the area and a review of individuals' exposures indicated that there was a minimal radiological impact from this evolution. RP personnel documented this event in a PCAQR which was subsequently assigned to maintenanc The corrective acticas taken and planned to address this issue included training personnel on technical specification 3.03, discussing the importance of understanding radiological conditions prior to performing work, and proposed procedural modifications to the LAM process which would require radiation protection to be contacted prior to the evolution star Radiation Work Pemiit 1997-0601, revision 0, required that workers notify RP prior to the start of each work evolution. Procedure NG DB 00208 (a procedure for personnel radiation protection) required personnel to obey instructions in radiation work permits, and Technical Specification 6.11 requires that procedures for personnel radiation protection be adhered to for all operations involving radiation exposure. The failure io notify radiation protection prior to beginning the work evolution consitutued a violation of Technical Specification 6.11. This non-repetitive, licensee identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (NCV 50-346/97012-03). Conclusions During immediate action maintenance conducted on September 4,1997, a narrow focus-on completing the evolu - 1sulted in workers falling to contact radiation protection prior to the start of the evolution. The failure to contact radiation protection constitued

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a violation of Technical Specifications. This violation is being classified as a Non Cited Violation due to the station's prompt identification and comprehensive corrective actions in response to these event R7 Quality Assurance In RP&C Activities R7.1 Chemistry Laboratorv Quality Control Program laspection Scoce (IP 84750)

The inspector reviewed the quality control and quality assurance programs for the chemistry laMatory. This included a review of the instrumentation program, the radioactive source control program, standards control program, and the interlaboratory cross check program. The inspector reviewed numerous records and trending analyses, and interviewed cognizant chemistry and radiation protection personnel, Observations and Findings Laboratory quality control appeared effective. The inspector reviewed selected control charts for counting room instruments, and noted that trends were documented and resolved as required by procedure. The inspector reviewed maintenance history files for chemistry instruments, and noted that problems identified with the instruments were repaired in a timely matter either by chemistry or vendor personnel. The inspectors noted that the enemistry testers were familiar with instrumentation, and the basis of operation for each instrumen The inspector noted that radiological sources were controlled in a locked container in the chemistry laboratory, and that the chemistry department maintained information regarding source accountability and traceability. Standards in the laboratory were appropriately labeled and controlle The inspector reviewed the results of the interlaboratory cross check program from July 1996 through the second quarter of 1997. The licensee received radiochemistry cross check samples from a vendor (Analytics) and performed an analysis on each sourc These results were returned to Analytics who subsequently performed a comparison of the licensee's values with the actual values. The comparison results from the third quarter of 1996 through the second quarter of 1997 were in agreement. For the second quarter of 1997, the licensee noted that the tritium results were approximately ten times higher than the results from previous years. The chemistry department attempted to find the tritium source for re analys:s, but was unsuccessful. The Analytics comparison of licensee results to the actual source results confirmed that the tntium reading was not in agreement. The licensee performed daily instrument source checks for tritium, which the inspector noted effectively ensured that the laboratory could analyze tritiu ,

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. Conclusions The inspector noted that the licensee's chemistry laboratory quality control program was effective, and ensured that the licenseo could obtain accurate chemical and radiochemical analyse R7.2 Quality Assurance (IP 84750)

The inspector noted that self cssessment reports in the chemistry and in the radiation protection areas were thorough and self. critical. Additionally, the inspector notad that the chemistry department's response to quality assurance audits was comprehensiv One finding from previous chemistry cudits discussed problems with procedural adherence. The inspector observed numerous chemistry testers exhibit stringent

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procedural compliance during the performance of routine activities, Indicating that the corrective actions to this audit finding were effectiv R8 Miscellaneous RP&C lasues R (Closedi IFl 50-346/96013At Classification of radioactive waste. The licensee's procedure for waste classification was vague as it stated, without other guidance, that

software was utilized to classify radioactive material shipments and that all radioactive material shipped off site must be waste classified. A revision to the transportation procedure to include guidance on the waste classification process prior to shipment was developed The inspector reviewed the licensee's procedure (DD HP-01500, revision 01) for " Shipping Radioactive Material," and noted that additional guidance had been included. This included a description of the computer software's capabilities, and directed the procedure user to refer to the *RADMAN Software Operating Manuar for software operation. Additionally, the procedure provided a classification flowchart to

, pictorially describe the software operation. This item is close R8.2 [ Closed) URI 50-346/96013-02; Revision of dewatering procedures. The inspector reviewed the licensee's resin dewatering processes. The licensee primarily used two high integrity containers (HICs) supplied by separate vendors for shipping dewatered resin. The licensee had used vendor procedures for the dewatering process. Although separate dewatering instructions existed for each HIC, it appeared that several steps in one procedure needed to be followed for the other HIC type, The radioactive waste supervisor stated that some steps were uncient in the vendor procedures, including the dewatering verification step to ensure that the HIC contained less than one percent free-standing liquid by waste volume. The licensee developed a new procedure (DB H , revision 01,"Dewaterir.g of Filter Media") to further clarify the dewatering process. This procedure addressed dewatering pump setup and HIC preparation for primary resins, dewatering primary resin for shipment, final dowatering and verification of primary resins, dewatering of Duratelt media and/or filtem in a HIC, and the final dewatering and verification of Duratek media and/or filters in a HIC. The procedure was a combination of the vendor dewatering procedures and was developed by the licensee with vendor assistance. The inspector verified that the licensee had successfully dowatered a HIC using the new procedures. Additionally, the licensee had not been

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i notified of any problems due to an excess amount of liquid in the HIC and all quality assurance checks had been reported to be satisfactory by the disposal site. The lnspector noted that while the initial procedures had been unclear, no violations of regulatory requirements were observed, and this item will be close R8.3 (CjmiLBO 50 346/9M13-D3: Failure to post a radiation area. The inspector had identified one radiation area posting violation. The licenseo controlled the truck bay adjacent to the cask wash down pit as a radiation area. The inspector performed confirmatoy radiation surveys and determined that this area had dose rates of approximately 10 millirem per hour. The inspector identified that one entry into the truck bay was not posted as a radiation area. This was in violation of 10 CFR 20.1902(a)

which requires that the licensee post each radiation area with a conspicuous sign or signs bearing the radiation symbol and the words " CAUTION, RADIATION AREA." The apparent cause for the violation at the truck bay access was the failure to verify proper radiological postings following the decontamination and removal of contamination /

radiation area postings in the adjacent cask wash pit area. The licensee Inspected all other radiological postings to verify accura ~y, and additional PCAORs were generated to address similar findings. The licensee revised the applicable procedure (DB HP-01100, revision 3, * Posting, Labeling, Marking") to clarify posting requirements, and conducted training for radiation protection personnel to increase their awareness of attention to detailincidents. The licensee established a periodic routine activity to specifically certify radiological postings. The inspector reviewed the licensee's corrective actions and

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detormined that they were adequate to prevent recurrence. Additionally, the inspector independently verified numerous radiological postings and noted no discrepancie Therefore, this item is close V. Management MettlDas X1 Exit Meeting Summary On October 10,1997, the inspector presented the inspection results to licensee managemen The licensee acknowledged the findings presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie .

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PARTIAL LIST OF PERSONS CONTACTED

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L. A. Bonker, Jr., Supervisor, ALARA Services 4 L. H. Bowyer, Supervisor, Radwaste Operations V. N. Capozzlello, Supervisor, Chemistry

R. B. Coad, Jr., Superintendent, Radiation Protection R. D. Edwards, Chemistry Technologist
J. V. Feckley, Supervisor, Radiation Operations

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K. A. Filar, Senior Chemical Engineer B. L. Geddes, Senior Health Physicist G.W. Gillesple, Superintendent, Chemistry

R. A. Greenwood, Supervisor, Health Physics K. L. Harsenje, Supervisor, Maintenance

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L. D. Klett, Chemistry Technologlst

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J. H. Lash, General Manager, Plant Operations J. A. Lochotzki, Technologist Nuclear i R. D. Messersmith, Supervisor, Chemistry D. E. Messig, Senior Maintenance Advisor

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J. M. Priest, Health Physicist T. M. Purdue, Master Rad Control Tester J. H. Sankovich, Jr., Supervisor, Chemistry

J. L. Scott, Health Physicist

, R. J. Scott, Manager, Radiation Protection

J. A. Wilson, Senior Chemistry Tester L. T. Zamora, Senior Chemistry Tester NRC

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Stanley Stasek Senior Res! dent Inspector

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lNSPECTION PROCEDURES USED IP 83750: Occupational Radiation Exposure IP 84750: Radioactive Waste Treatment and Effluent and Environmental Monitoring

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IP 86750: Solid Radioactive Waste Management and Transportation of Radioactive Material IP 92904: Follow up Plant Support

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i riEMS OPENED, CLOSED, AND DISCUSSED DDitDitd 50 346/97012-01 VIO Radioactive material package exceeding regulatory radiation limit /97012-02 IFl PASS sample actuating SFA /97012 03 NCV Failure to comply with radiation work permi ClQAed 50 346/96013 01 IFl Classification of radioactive wast /96013 02 URI Dewatering processe /96013 03 VIO Failure to post a radiation are i

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e LIST OF ACRONYMS USED ,

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AOR Annual Radiological Environmental Operating Report AVT All volatile Treatment CFR Code of Federal Regulations DOT Department of Transportation DRS Division of Reactor Safety  ;

EPRI Electric Power Research Institute ETA ethanolamine HIC high integrity container i lodine IFl inspection Follow-up Item IP Inspection Procedure IR Inspection Report MPA 3-methoxypropylamine mrem /hr millirem per hour mSv/hr millisleverts per hour NRC Nuclear Regulatory Commission ODCM Off site Dose Calculation Manual PASS Post Accident Sampling System PCAOR Potential Condition Adverse to Quality Report PDR Public Document Room PWR Pressurized Water Reactor REMP Radiological Environmental Monitoring Program RP Radiation Protection RP&C Radiological Protection and Chemistry RPT Radiation Protection Technician RRA Radiologically Restricted Area RWP Radiation Work Permit SFAS Safety Features Actuation System ,

TLD Thermoluminescent Dosimeter TS Technical Specification URI Unresolved item VIC Violation Xe -Xenon

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DOCUMENTS REVIEWED Annual Radiological Environmental Operating Report (1996).

Certificate of Conformance (Analytics).

Chemistry Manual:

DB CH 00001, rev 02," Chemistry Program Administration."

DB CH 00007, rev 02," Post Accident Radiological Sampling and Analysis."

DB-CH-00009, rev 05, " Chemistry Measurement and Test Equipment (CM&TE) Control Program."

DB CH-00010, rev 03, " Chemistry Quality Control Program."

DB CH-00012, rev 03," Chemistry Radioactive Source Accountability and Control."

DB CH-00013, rev 03, " Radiochemistry Quality Control Program."

DB CH-06000, rev 05,' Post Accident Sampling System Operation and Analysis."

Chemistry Trend Charts: July 1996 through September 199 Chemistry Unit Self Assessment Report Second Quarter 199 Health Physics Manual:

DB HP-00013, rev 01," Review and Evaluation of REMP Sample Analysis Results."

DB HP-00014, rev 01, " Annual Radiological Environmental Operating Report Preparation."

DB HP-00015, rev 01, * Radiological Environmental Monitoring Program."

DB-HP-01100, rev 03, * Posting, Labeling, Marking."

DB HP-01500, rev 01," Shipping Radioactive Material."

DB-HP-01502, rev 01, " Dewatering of Filter Media."

DB-HP 03005, rev 03, " Radiological Monitoring, Weekly, Semimonthly, Monthly Sampling."

Individual RWP Access Records for 9/4/97 frcm 0630 to 0930 for RWP Numbers 1997-0061, 1997-1037,1997-000 (

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Licensee Event Repoi197-012,

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Nuclear Group Procedure, NG DB-00208, rev 02, " Radiation Protection Program."

Off site Dose Calculation Manual, rev 1 Potential Condition Adverse to Quality Reports PCAQR: 961568 971225, 971178, Quality Assessment Audits AR 96 OPSCH-01, AR 96 RPRWP-01, AR-97-RPRWP-0 ,

Quality Assessment Response AR 96 OPSCH 01-0 Radiation Work Permit 1997-0601, rev Radiochemistry Cross check Summaries and Results: second quarter 1996, third quarter 1996, fourth quarter 1996, first quarter 1997, second quarter 199 Radiological Survey Form, Survey Number 97 01600,97 01627, i

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