IR 05000397/1982020
| ML20027D089 | |
| Person / Time | |
|---|---|
| Site: | 03013720, Columbia |
| Issue date: | 10/08/1982 |
| From: | Book H, Wenslawski F, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20027D084 | List: |
| References | |
| 30-13720-82-01, 30-13720-82-1, 50-397-82-20, NUDOCS 8210280248 | |
| Download: ML20027D089 (11) | |
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U. S. NUCLFAR FIGULSTORY C01:liISSIO t
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PIGION V Report No. 50-397/82-20, 30-13720/82-01 Docket No. 50-397, 30-13720 treen3e 30, CPPR-93, 46-17964ggbeguards croup Licensee: Washington Public Power Supply System (WPPSS)
P. O. Box 968 Richland, Washington 99352 Facility Na=e: Washington Nuclear Project No. 2 (WNP-2)
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Inspection at: WNP-2 Site and Corporate Office,'Benton County, Washington 9#
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Inspectica conducted _
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Inspectors:
/o/7/82.
G. P. Yuhas, Hadiation Specialist
' Da'te Signed
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Date Signed
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Approved by:
/4/7/ II. -
F. A. Wenslaws~ki, Chiet
'Da6e Signed featorR iationf,rotection Section Approved by:
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/o/P/- F1 11. E. Book, Chief
'Dade Signed Radiological Safety Branch
Date Signed Summary:
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Inspection on August 31 - September 3, 1982 and subsequent telephone discussion with licensee representatives on September 17, 1982 (Report No. 50-397/82-20)
Areas Inspected:
Routine, unannounced initial preoperational inspection of the licensee's environmental monitoring program including:
organization, procedures, instruments and equipment, collection of preoperational radiological data, and audits. At the request of the
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Senior Resident Inspector, compliance with conditions of the licensee's Material License No. 46-17964-01 were reviewed. The inspection involved 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> onsite and at the corporate office by a regionally based inspector.
Results: Of the areas inspected, one item of noncompliance was identified, receipt of radioactive material not authorized by License No. 46-17964-01,10 CFR 30.3, Paragraph 2.
RV Form 219 (2)
8210290248 821012 PDR ADOCK 05000397 O
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I DETAILS 1.
Persons Contacted WPPSS Corporate Office
- P. Shen, Director, Technology
- R. Chitwood, Manager, Environmental Science and Engineering W. Taylor, Manager, Health and Safety Programs
- D. Larson, Manager, Radiological Programs
- D. Feldman, Manager, Operational Quality Assurance
- R. Craig, Supervisor, Radiological Services J. Mudge, Senior Environmental Scientist F. Quinn, Senior Scientist (Meterology)
L. Schledger, Assistant Environmental Engineer WNP-2 Site
- R. Graybeal, Manager, Health Physics / Chemistry t
- D. Walter, Manager, Plant Quality Assurance
- J. Peters, Manager, Administration
- R. Barbee, Supervisor, Plant Engineering L. Berry, Supervisor, Health Physics C. Pettit, Foreman, Instrument and Control J. Reynolds, Technician, Health Physics / Chemistry Indicates those individuals attending the exit interview on September 3,
1982.
2.
Material License No. 46-17964-01.
On arrival at the WNP-2 site on August 31, 1982 the Senior Resident Inspector requested the regional Radiation Specialist to review the adequacy of the licensee's control'of radioactive material possessed pursuant to the Material License No. 46-17964-01.
The inspector toured Warehouse 4 noting the licensee's compliance with the regulation expressed in 10 CFR 20.203, " Caution signs, labels, signals and controls" and 10 CFR 19.11," Posting of notices to workers". The radioactive sources were stored in a fenced area within the warehouse.
The fence was posted as required by 10 CFR
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19.11 and 10 CFR 20.203.
Access to the storage area was locked.
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The access key was controlled by the Warehouse Supervisor. The dose rate measured in the unrestricted area near the fence with a
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portable ion chamber instrument (R03 SN.295, calibration due 11/2/82) was less than 0.5 mr/hr.
Discussions with the warehousemen indicated they had received training pursuant to 10 CFR 19.12, " Instructions to workers".
During these discussions it became clear that the two warehousemen were aware of the need to contact Health Physics for activities involving receipt, use, or transfer of radioactive material as stipulated in their procedure PMI-13.1, " Storage and Handling of
Radioactive Material". The warehousemen commented that a radioactive source had been received that afternoon and they had notified Health Physics as required.
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i Based on a tour of the radioactive material-storage area in Warehouse 4 the followings coments were offered to the Health Physics Supervisor for consideration:
1.
Equipment stacked in close proximity to the storage fence provided easy access-to circumvent the locked gate.
2.
The Form NRC-3, " Notice to Employees" posted, was dated i
January 1980.
On return to the Regional Office, the inspector j
mailed the licensee copies of the. current revision of Form NRC-3, dated June 1982.
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3.
From discussions with the warehousemen it appeared that their level of understanding of radiation and radioactive material
associated with their activities in Warehouse 4 should be improved.
For example: the audible response of the personnel
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frisker was a source of concern since they did not fully
understand the significance of the count. rate.
Rumors concerning unauthorized possession of fuel may have originated with receipt of sealed fission detectors which contain small quantities of Uranium 235 authorized by the license.
i The inspector reviewed the receipt of the radioactive material l
mentioned by the warehousemen to determine compliance with the following requirements:
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t Materials License No. 46-17964-01, Amendment No. 6 issued
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July 15, 1982 I
10 CFR 20.205, " Procedures for picking up, receiving, and
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opening packages."
HPP 11.2.14.1, " Procurement of Radioactive Material" dated
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August 27, 1981
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HPP 11.2.14.2, " Receipt of Radioactive Material" dated August 27, 1981.
The following documentation was reviewed:
Handwritten receipt radiation survey notes.
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Radioactive Material Receipt and Inventory Control Form WP 371
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dated August 31, 1982 at 1445
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Federal Express Airbill No. 441352240
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Amersham Invoice No. 603 348-15 Amersham Radioactive Source Test Report, dated August 26, 1982
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-3-WPPSS Purchase Order No. 52128
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WPPSS Purchase Requisition No. 094106 WPPSS letter to Amersham dated July 15, 1982, G02-82-609
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WPPSS letter to NRC dated May 11, 1982, G02-82-434, " Request
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For Amendment of Washington Public Power Supply System Nuclear Project WNP-2 Materials License No. 46-17964-01 Based on this review the following observations are noted:
Fonn WP371 dated August 31, 1982 at 1445 indicated a 3 Curie
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Americium-241/ Beryllium, Special Form neutron source was surveyed on receipt and found to produce a neutron dose rate of 15.0 mrem /hr and gamma dose rate of 1.2 mrem /hr at 3 ft.
from the package surface.
10 CFR 20.205(c)(2) requires in part that if the radiation level at 3 ft. from the external surface of the package is in excess of 10 millirem per hour the final delivery carrier and the NRC must be immediately notified.
The Health Physics Supervisor stated that the notifications had not been made. A Health Physics Technician pointed out that since this Special Form source was less than 20 Curies the shipment was exempted from survey requirements of 10 CFR 20.205.
At this time (5:15 p.m.)
the Health Physics Supervisor initiated action to resurvey the source.
At 7:25 p.m., in the presence of the inspector and the Health Physics Supervisor, the Health Physics Technician resurveyed the package using an R0-3 (Sn. 008, calib. due 11/2/82), PNR-4 (SN. 005, calib. due 1/13/83) and a tape measure.
The radiation level at 3 ft. from the external surface of the package was found to be 7.5 mrem /hr neutron and 1.0 mrem /hr due to gamma emissions.
The first survey results were determined to be in error due to the technician estimating the 3 ft distance.
An experiment found the first dose rate measurement was orobably made at 2 ft from the external surface of the package.
The unusually long time involved in resurveying the source was primarily due to the access keys not being readily available to the Health Physics Supervisor.
I In the licensee's May 11, 1982 letter they requested amendment of
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their license to include as item Q authorization of Amersham sealed sources (not to exceed 10 Curies each) similar to Amersham catalog number AMN 23 for materials testing and for use in the l
calibration facility. The WPPSS July 15, 1982 letter to satisfy 10 CFR 30.41 provided Amersham a copy of Amendment 5 of the license, a
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copy of the May 11, 1982 letter and stated that the request had l
been approved by NRC, and that, a copy of the approved license would be forwarded when available.
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-4-Amendment No. 06 of License No. 46-17964-01 was issued July 15, 1982 by NRC. This license was not fully responsive to the licensee's May 11, 1982 request. Specifically, item Q authorized possession of Americium 241 sealed neutron sources (Monsanto 2720 Series) not to exceed 10 Curies each for use in the J. L. Shepherd Model 149 B calibrator for dosimeter and instrument calibration.
I The Manager Radiological Programs was not aware the license did not read as requested in the application.
Since the source is not a Mansanto 2720 series and is intended for use in a material testing application the manager took action to ensure the source remains in locked storage until the license is amended.
These actions were discussed in a telephone call between the licensee and NRC Materials Licensing Branch on September 1, and documented in a September 2, 1982 letter (G02-82-728).
Contrary to the July 15, 1982 letter (G02-82-609) the Supply System had not forwarded a copy of Amendment 6 to Amersham as previously stated, according to the flanager of Health Physics / Chemistry.
Failure to scrupulously adhere to HPP 11.2.14.1 resulted in receipt of licensed radioactive material not authorized by a general or specific license.
Receipt and possession of this 3 curie source was controlled in accordance with the condition of 10 CFR 19 and 10 CFR 20 such that a threat to the public health and safety was not created.
However, receipt of Americium-241/ Beryllium source (SN. 5051 NE)
was not authorized by License No. 46-17964-01 and therefore represents noncompliance with 10 CFR 30.3 (50-397/82-20-01).
3.
Environmental Protection A.
Organization Responsibility for the environmental monitoring program rests with the Director of Technology.
The Manager, Environmental Sciences and Engineering is responsible for implementing an appropriate program.
Reporting to the Manager of Environmental Sciences and Engineering are three Senior Environmental Scientists; three Environmental Scientists; a Geologist; an Environmental Engineer; an Engineering Assistant; and an Assistant Environmental Enginee.
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Within the directorate of Support Services, the Manager, Radiological Programs through his Supervisors 'of Radiological Services and Radiological Assessment provide technical support as necessary to the Manager, Environmental Sciences and Engineering.. A Senior Scientist (Meterologist) in the Radio-logical Assessment section accepts responsibility for meterology aspects of the program.
The WNP-2 Manager, Health Physics / Chemistry stated that at this time he has no direct responsibility in this area.
During July 1982, the Environmental Scientist who had been responsible for development and implementation of the radiological environmental monitoring program left the Supply System. 'The responsibilities were delegated to a Senior Environmental Scientist who's forte is in the nonradiological biological monitoring area. At this time the licensee was not soliciting to replace the. Environmental Scientist.
B.
Administrative Controls Three categories of administrative controls have been developed to implement the commitments expressed in the Final Safety Analysis Report (FSAR) and the Environmental Report (ER).
These included:
1.
" Technical Procedures Manual", this document, last revised September 13, 1982, consisted of a series of procedures which present the Supply System's Technical Division policy, scope, and responsibilities for each functional area.
During the inspection the Manager, Environmental Sciences and Engineering stated that he was uncertain as to the operability of this document in view of the August 10, 1982 reorganization.
In a subsequent
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telephone conversation the inspector was advised that the
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" Technical Procedures Manual" although not accurate, are in effect. As each functional area is reviewed that procedure will be deleted and the policy / responsibility
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aspects will become incorporated into a new " Technology Directorate Manual".
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" Environmental Programs Instruction Manual", the objectives of this manual include providing a complete set of instructions for use by all Environmental Sciences and Engineering personnel to perform their assigned responsibilities.
The " Management Statement" clearly requires that these procedures be followed.
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-6-The following radiological Environmental Program Instructions
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i (EPI) were reviewed; Number Title Revision No.
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EPI 12-0.1 Thermolumint: scent Dosimeter
Distribution and Collection i
EPI 12-0.2 Trip Directions to Thennolu-2:
minescent Dosimeter Stations
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EPI 12-0.3 Trip Directions to Environ-
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mental Air Sampler Station
EPI 12-0.'4 Airborne Samples Distribution
i Collection and Shipping EPI 12-0.5 Radiological Environmental Data
Recording and Retention i
EPI 12-0.6 Soil Sampling
EPI 12-0.7 Sediment Sampling
EPI 12-0.8 Fish Sampling _
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EPI 12-0.9 Garden Produce Sampling
EPI 12-0.10 Composite Water Sampler
EPI.12-0.11 Drinking Water Collection
EPI 12-0.12 Drinking and River Water
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EPI 12-0.13 Surveillance at Radiological
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EPI 12-0.15 Milk Collection, Treatment,
and Shipping
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Based on this review the following observations are noted:
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Environmental air samplers Station 21 and 23 have been moved such that the description in EPI 12-0.3 are no longer correct.
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-7-Laboratory analysis have in the past been contracted to
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Eberline-Midwestern Facility.
In August 1982 the licensee began shipping these samples to Eberline's New Mexico facility.
EPI 12-0.4, 12-0.6, 12-0.7, 12-0.8, 12-0.9, 12-0.11, 12-0.12 and 12-0.15 have not yet been revised.
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3.
Health Physics Procedures, this subtier of the Health Physics Policy and Procedures Manual provides direct instruction for those operations performed under the direction of the Supervisor Radiological Services.
Functions associated with the environmental thermoluminescent dosimetry program are addressed in HPP 3.4.1 through 3.4.12.
The inspector did not review these procedures during this inspection.
C.
Equipment and Instrumentation The inspector verified by review of the manufactuer's technical data that the onsite primary meteorological monitoring equipment as described in Section 6.1.3.1 of the Environmental Report met the criteria specified in Table 1 of USNRC Regulatory Guide 1.97, Revision 2.
The preoperational meteorological data was collected between October 1, 1979 and September 30, 1980 however the licensee continues to maintain the primary tower in a fully operable condition.
A backup tower equipped with wind speed, wind direction, temperature, and dewpoint instrumentation is expected to be completed by November 1982.
On September 2,1982 environmental air monitoring station Number 4 and the WNP-2 intake and discharge river water sampling stations were inspected.
The licensee's air sampler, a RADEC0 model HD 28/B Serial No.1109, was operating at 1 CFM with a 4' Hg differential pressure across the filter media.
A calibration sticker on the instrument indicated that it had been calibrated on July 21, 1982 and was due for calibration an January 21, 1982.
The inspector reviewed Standards Laboratory Instruction, SLI 24-6, Calibration of RADEC0 Air Flow Sampler, Revision A, dated August 26, 1982 against the criteria of ANSI 18.7, USNRC Regulatory Guide 8.25 and previous literature published regarding calibration of rotameters.
The following observations were brought to the Instrument and Control Foreman's attention on September 17, 1982.
The procedure is not consistent with the methodology
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presented in USNRC Regulatory Guide 8.25 regarding error limits.
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The procedure does not consider the effect of differential pressure across the sample media on the rotameter accuracy.
(See: Craig, D.K., the Interpretation of Rotameter Air Flow Readings, Health Physics.
Pergamon Press 1971.
Vol. 21 (August) pp. 328-332.)
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Calibration of environmental air samplers will be reviewed in a susequent inspection (50-397/82-20-02).
r The licensee uses C'ollin5-Model 4(, Composite Water Samplers-to collect drinking and river water samoles.
EPI 12-0.10 and: EPI 12-0.12 detail operatthg instructions and sample procedure for 3hese
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units.
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Inspection at the WNP-2 Pump House revealed:
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The riveh ater intake sampler was overflowing the sample
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collection container such that compliance with EPI 12-0.12 is not pospible.
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The adjtittable timers on both intake and discharge were
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set at 00 minutes instead of-30 thinutes as stipulated in s
EPI 12-0.10.
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Accord;ng to licensee representatives the intake sampler
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has 'oeen leaking since installed in July 1982 and timers had been reset in an attempt to compensate for the problem.
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No procedures for calibration or maintenance of the
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Collins Model 47. Composite Water Sampler has been-developed or implemented by the Supp'ly System.
Maintenance, c4libration and operatio'n of the environmental water sample. equipment will be reviewed in a sub;equent inspection \\(50-397/82-20-03).
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D.
Status of Preoperation Radiological Environ'me tal Data.
The inspector reviewed records of data to determine if the preoperation monitoring specified in Section 6.1.6 of the Environmental Report is being performed consistent with a September 1983 fuel loa'd date.
The results of this review are summarized below:
Measurements to be made Licensee results on 2 years pr_ior to fuel load.
file from Direct Radiation September 19)8 bish April *1978
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Vegetation June 1978 Sedi"ent Soil, March 1978 e
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Measurements to be made x Licensee
,1 year prior to fuel. load.
Sampling began.
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Airborne particulate i
ISeptepber 1982*,
Milk
March 1982
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'.r River Water c-J uly ' 1982*
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Gr0und Water -
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_9-The results of these samples should be reviewed in terms
of apparent calibration errors and ' equipment malfunctions.
From review of'this data the inspector noted that the results were reported-as less than the maximum values for the lower limit of detection (LLD) specified in Table 6.1-5 of the Environmental Report.
The licensee representative did not present verification that these LLDs had been determined by their vendor using the methodology presented in Table 6.1-5.
Review of the veracity of preoprerational airborne particulate, riverwater and LLD technique will be performed in subsequent inspections (50-397/82-20-04).
D.
Audits The inspector reviewed the records of two audits.
One audit, performed by the Environmental Scientist in December 1981 of the Eberline Instrument Company's, Midwest-Facility did not identify any deficiencies. The audit was performed consistent with EPI 12-0.13.
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m Corporate Quality Assurance Audit No.82-208, " Environmental Programs" resulted in three Quality Finding Reports (QFR) Two QFRs involving radiological monitoring were. reviewed.
The first QFR, addressed a failure to define specific responsibi-lities in written procedures.
The Manager Environmental Sciences and Engineering's February 22, 1982 response stated that procedures would be updated by September 1,1982. As of September 1,1982 this had not been accomplished.
In an August 16, 1982 memorandum the manager established a January 1, 1983 goal to issue EPI 12.0.
The second QFR involved an apparent failure to document training of section members in appropriate procedures. An August 12, 1983 memorandum initiated action to determine who needed to be trained on which procedures.
Documentation that the training had been completed was not available on September 1, 1982.
The Manager Environmental Sciences and Engineering documented the completion of training by appropriate individuals on September 2, 1982.
No items of noncompliance or deviations from FSAR commitments were identified.
However several findings req; iring licensee action to insure compliance were identified l
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4.
Exit Interview
.The inspector met with the licens'ee representatives (denoted in Paragraph 1) at the conclusion of the inspection on September 3, 1982. The inspector summarized the scope and findings of the inspection.
In addition, as a result of the inspection findings the following comments were made to the licensee representatives.
1.
If at any time the licensee determines, (whether the determina-tion was required or not) that levels of radiation, contamina-tion or concentration of radioactive material exceed the values or conditions which require immediate notification by Commission regulations the NRC expects these notifications to be made within the time frame stipulated.
2.
Observations of activities associated with the radiological environmental monitoring program lead the inspector to conclude.
implementation of the program presented in USNRC Regulatory Guide 4.15, Revision 1 may be necessary to insure quality results.
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