IR 05000482/1988025
| ML20195B320 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/13/1988 |
| From: | Baer R, Chaney H, Ricketson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20195B309 | List: |
| References | |
| 50-482-88-25, IEIN-86-023, IEIN-86-043, IEIN-86-23, IEIN-86-43, IEIN-87-039, IEIN-87-39, IEIN-88-063, IEIN-88-63, NUDOCS 8811010517 | |
| Download: ML20195B320 (22) | |
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APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-482/88-25 License: NPF-42 Docket:
50-482 Licensee: Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, Kansas 66839 Facility Name: Wolf Creek Generating Station (WCGS)
Inspection At: WCGS, Burlington, Coffey County, Kansas Inspection Conducted:
September 12-16, 1988 y
sw Inspectors:
Ad[JP>?/eO
/d ' '8 - 8 E
. Ch ney,jr5enfur._ Radiation Specialist Date f,~ Facil tie % Radiological Protection Section d'
Lun A%w
/O- /'s i(Y L.Ripketsof,Rhistion5pecialist Date Facil,itieVRadiological Protection Section R(Baer, Chief [, Facilities Radiological (
Approved:
v eo -/.7-SS Date Protection Section Inspection Summary Inspection Conducted September 12-16, 1988 (Report 50-482/88-25)
Areas Inspected: Routine, unannounced inspection of the licensee's radiation protection program and planning activities for the forthcoming refueling outage.
Results: Within the areas inspected, two violations were identified:
f ailure to properly set continuous airborne radioactivity monitor alarms and failure to leak test radioactive sources (see paragraphs 10 and 12, respectively). No deviations were identified.
G811010517 S91013 F'OR ADOCK 05000482 o
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OETAILS 1.
Persons Contacted Licensee
'B D. Withers, President, W91f Creek Nuclear Operating Corporation
- F. T. Rhodes, Vice President, Nuclear Operations
- R. M. L ant, Vice President, Quality
"G. D. Boyer, Plant Manager
- C. E. Parry, Manager Quality Assurance (QA)
"J. O. Zell, Manager, Training
- A. A. Freitag, Manager, Nuclear Power Engineering
+*M. G. Williams, Manager, Plant Support
L. F. Breshears, Supervisor, HP/ Dosimetry
- K. M. Thrall, Senior Corporate HP Engineer H. M. Davis, Supervisor, HP/Calioratton/ Training
- R. L. Taylor, Supervisor, HP/ALARA
- K. O. Peterson, Supervisor, Licensing
- G. J. Pendergrass, Licensing Engineer
"J. O. McMahon, Supervisor, Ter..aical Training D. O. Parks, Supervisor, General Training
"W. R. Norton, Supervisor, Reactor Engineering G. A. McClelland, QA Auditor
- B. O. McKinney, Manager, Technical Support
- C. C. Reekte, Emergency Plan Administrator
- C. O. Medenety, Supervisor, HP/ Radioactive Waste (Radwaste)
- T. M. Damashek, Supervisor, QA Surveillances
"W. M. Lindsay, Manager Quality Systems
+ T. Morrill, Site Health Physicist
+*L. Pavelac, Compliance Engineer
+*0. Maynard, Manager, Licensing Others
+*B. Bartlett, NRC, Senior Resident inspector
+*M. Skow, NRC, Resident Inspector
+*H. Story, Radiation Protection Manager, Delphi Groupe, Inc.
"Denotes personnel in attendance at the exit meeting on September 16, 1988.
+ Denotes personnel involved in the September 23 and/or October 3, 1988, telephone conference with NRC inspector H. Chaney at the NRC Region IV office, see leak testing of sources discussion in peragraph 12 of this report.
The NRC inspectors also contacted other plant personnel, including operators, technicians, and administrative personnel.
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Follow-up on Previous Inspection Findings (Closed) Violation (482/8712-01):
Radiation Protection Manager (RPM)
Qualifications - This item was previously discussed in NRC Inspection Report 50-482/87-12 and involved the failure of the Site Health Physicist (RPM equivalent) to satisfy the qualification requirements of the Technie41 Specifications (TS).
The NRC inspectors examined the licensee's commitments contained in the July 30, 1988, written response.
The licensee had temporarily hired a person that meets the TS qualification requirements for the position of Site Health Physicist and assigned him the title of RPM. The RPM will assist and provide oversight to the bite Health Physicist regarding radiation protection uatters at Wolf Creek Generating Station until the Site Health Physicist meets all of the experience requirements of the TS. The licenset's actions appear to be satisfactory to resolve this problem.
(Closed) Deviation (482/8712-02): Continuous Airborne Monitoring (CAM)
Program - This item was previously discussed in NRC Inspection Reports 50-482/87-12 and 50-482/87-28, and involved the licensee's failure to implement a CAM program that satisfied the licensee's commitments in the Final Safety Analysis Report.
The NRC inspectors examined the licensee's commitments contained in the July 30, 1987, response to the Notice of Deviation.
The licensee's corrective actions and the results of QA audits /surveillances of the CAM program were inspected.
The licensee has in place a sufficient number of new CAMS to resolve the NRC's concerns regarding placement and operational reliability of CAMS in radiologically controlled areas. However, a violation and an open item concerning the CAM program were identified during this inspection.
See paragraph 10.
(Closed) Violation (482/8809-01):
Failure to Lock a Very High Radiation Area - This item was previously discussed in NRC Inspection Report 50-482/83-09 and involved the licensee's failure to properly
';ontrol by locking a very high radiation area as required by the TS. The NRC inspector examined the licensee's commitments contained in the May 13, 1988, response to the Notice of Violation.
The licensee's corrective actions nave resolved this problem and staff training is expected to prevent a future recurrence of the problem, (Closed) Violation (482/8728-01):
Failure to Properly Perform Personnel Contamination Survey - This item was previously discussed in NRC Inspection Report 50-482/87-28 and involved the licensee's failure to consider the shield effect that protective clothing produced during the surveying of personnel for skin contamination. The NRC inspectors examined the licensee's commitrents contained in the January 4, 1988, written response to the Notice of Violation and their implementation. The licensee's corrective actions have adequately resolved this problem.
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-4-(Closed) Violation (482/8736-01):
Improper Disposal of Radioactive Material - This item was previously discussed in NRC Inspection Report 50-482/87-36 and involved the licensee's failure to properly Survey potentially radioactive material and the subsequent transfer / disposal of the material in an unauthorized location offsite.
The NRC inspectors examined the licensee's commitments contained in the January 28, 1988, response to the Notice of Violation and the special ieport submitted to the NRC dated January 7, 1988.
The licensee'*. corrective actions have resolved this problem.
3.
Licensee Event Report (LER)
(Closed) LER (482/87-056): Inadaquate Control Results in Loss of Licensed Material - This LER discussed the loss of a 400 microcurie strontium-90/ yttrium-90 source. The NRC inspectors reviewed the licensee's evaluation of the incident and corrective actions contained in the LER.
The licensee has completed the corrective actions committed to in the LER.
However, the NRC inspectors determined that the licensee's "root cause analysis" lacked sufficient depth to identify a significant breakdown in the licensee's overall control, accountability, and contamination / leakage testing of radioactive sources.
This breakdown was subsequently identified during a licensee performed QA surveillance and NRC inspection of the licensee's source handling and accountability program during the period August 12-23 and September 14-25, 1983, respectively. See paragraph 12 of this report.
Further NRC revfew of the licensee's radioactive source receipt, accountability, control, and contamination / leakage testing will be via Unresolved Item 482/8825-03 and the apparent violation discussed in paragraph 12 of this report.
4.
Unresolved Item Identified During this Inspection An unresolved item is a matter abeut which more information is required to ascertain whether it is an acceptable item, a deviation, or a violation.
The following unresolved item was identified:
Unresolved __ Item
_ tle See Paragraph Ti 482/8825-03 Licensee Self Identified Problems With Radioactive Source Control
5.
Open Items I_dentified During This_ Inspection An open item is a matter that requires further review and evaluation by the NRC inspector. Open Items are used to decceent, track, and ensure adequate follow-up on matters of concern to the NRC inspector. The following open items were identified:
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Oper Item Title See Paragraph 482/8825-04 TS Section 6 and USAR Section 13 Organization Chart Update
402/8825 05 Radiation Survey of Work Areas
482/8825-06 u.ktng of Airborne Radioactivity
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Uptakes During Emergency Response Reentry Activities
482/8825-07 Continuous Air Monitor Procedures and Performance
482/8825-08 Alpha Contamination Surveys
482/8825-09 Emergency Kit Inventory
6.
Inspectors Observations An inspector observation is a matter discussed with the licensee during the exit interview. Observations are neither violations, deviations nor unresolved items. They have no specific regulatory requirement, but are suggestions for the licensee's consideration.
ALARA Work Packages - Review of outage work packages is behind schedule and many packages may not be completed by the October 6, 1988, start of Refueling Outage III.
This satte concern was also raised prior to Refueling Outage II.
Respiratory Protecticn Training - Self contained breathing apparatus training is not provided to all emergency response personnel.
See paragraph 10 of this report.
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Organization and Management Controls - Radiation Protection (83522/83722j fhe licensee's organization and staffing of the station's HP group was examineJ to determine agreement with:
commitments in Sections 12.5 and 13.1 of the Updated Safety Analysis Report (USAR): compliance with the requirements of Section 6 of the TS; and the recommendations of NUREG-0731 and 0761.
The NRC inspectors reviewed the licensee's organization, staffing, assignnent of responsibilities, ractological protection program implementing procedures, Radiation Protection Plan, completed and scheduled QA audits, and management oversight of radiological work activities.
Senior management policies in regard to radiation protection, respiratory protection, and ALARA were also reviewed.
Procedures and docurrents examined are listed in Attachment I to this report.
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The responsibility of mansging the health physics group has been
changed from the Superintendent of Plant Support to the Manager of
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Technical Support (location of the HP group during initial plant start-up).
This change in the organization structure took place in early 1988.
The NRC inspectors determined that the licensee had not updated the USAR or TS organization descriptions or charts to reflect the change in WCGS organizational management responsibilities for the onsite HP group.
This is considered an open item pending further action by I
the licensee.
(482/8830-04)
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The NRC inspectors reviewed the technical support provided the person l
designated Site Health Physicist (RG 1.8 equivalent to RPM) as committed to by the licensee in written responses to Notice of Violation 482/8712-01, i
dated May 21 and May 27, 1988. The licensee's temporary hiring of a i
person meeting RG 1.8 RPM qualifications to oversee Site Health Physicist
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implementation of the site radiolcgical protection program was verified.
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j The licensee's QA audits and surveillance reports for radiological
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protection activities were examined and found to have improved in technical j
quality and depth over previous audits.
However, the NRC inspectors noted at the exit r.eting that the NRC findings during this inspection indicate f
that further improvements in the depth of audits and surveillances are i
needed.
l No violations or deviations were identified.
8.
Training and Qualification - Radiation Protection (83523/83723)
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I The licensee's radiological training program foe workers and the HP
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person'id qualification program were examined '
determine agreement with.
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commitments in Section 13.2 of the USAR: compliance with the requirements j
i of Section 6 of the TS and 10 CFR Part 19.12; and the recommendations of
NRC RGs 8.13, 8.27, and 8.29 and industry standards ANS1 18.1-1971,
NUREG-0041, and NUREG-0761.
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for permanent plant employees, visitors, and contractors.
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respiratory protectien equioment (RPE) training, appears to satisfy the l
requirements of 10 CFR Pars 19.12 and the guidance in RGs 8.13, 8.27, 8.29, and 8.15.
Selected GET and HP training instructor's qualifications
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i and specialized training were examined.
The licensee had received INPO i
accreditation of all their training programs in May 1988.
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personnel screening program, technical knowledge testing, and on-the-job
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training were examined.
Individual experience and qualification for l
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selected oersonnel in the radiation protection group were reviewed.
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licensen's program for integrating industry and NRC lessons learned type material into training programs was examined for effectiveness.
The NIC inspectors examined the licensee's mockup training faciitty for training of personnel on the installation of steam generator (SG) primary side nozzle dams. The coordination of the training was noted to be a combined effort on the part of the maintenance and HP groups.
The facility closely mirrored the expected conditions that would be I
encountered within the reactor containment during the refueling outage.
In order to ensure that exposures are maintained ALARA during the actual nozzle dam installation, each participant had to meet task performance time limitations before being assigned to the job.
The instructors showed a high degree of attention to detail and enthusiasm in setting up the training program.
The NRC inspectors discussed with licensee representativas the need to further evaluate the use of a waist mounted safety belt and lanyard on pcrsonnel entering the SG for nozzle dam installation.
It was pointed out by the NRC inspectors that the waist mounted belt would more than likely cause the outer protective plastic clothing on the workers to be torn during SG ingress and eg ess, which could cause unnecessary personnel contamination incidents and possibly higher exposures due to potential close quarter fouling of service lines to the worker and his tools.
The licensee representatives stated that the use of safety belts in the SG had not been finalized and would be further reviewed by the safety department and plant management.
No violations or deviations were identified.
9.
Externgl Radiation Exposure Control The licensee's external radiation exposure control program was examined for agreement with:
commitments contained in Sections 12.4 and 12.5.2.1 of the USAR; requirements of TS 6.8.1, 6.11, 6.12.1, and 6.12.2, and 10 CFR Parts 19.12, 19.13, 20.101, 20.102, 20.104, 20.105, 20.202, 20.203, 20,205, 20.206, 20.405, 20.407, 20.408, and 20.409; recommendations of NRC Insper. tion and Enforcement Information Notices (IEINs) 86-23, 87-39, ano 88-63, and also the recommendations contained in RGs 8.4, 8,7, 8.8, 8.13, 8.14, and 8.28, and these of industry standards ANSI N13.5-1972 and N13.11-1983.
The NRC inspectors selectively esamined dosimetry issuance and exposure records for visitors, temporary workers, and licensee employees.
Procedures for the selection, testing, processing and creation of required reports for personnel dosimett> appeared adecuate to meet regulatory requirements. The licensee utilizes a compater supported multi-element thermoluminese.ent dusimetry system. This system was last described in NRC Inspection Report 50-482/87-12 and has not changed.
The licensee's dosimetry system is adequate for routine and energency use.
The licensee has in place emergency procedures on control and documentation of personnel radiation exposures that satisfy federal and industry guidance.
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The NRC inspectors performed confirmatory measurements of radiation dose rates in selected plant areas and determined they agreed with recent licensee surveys.
The frequency of certain radiation surveys was discussed with the licensee.
The NRC inspectors noted that there was a lack of definitive guidance for HP personnel on the frequency of surveying radiation dose rate changes in areas of the plant that house temporary liquid radwaste processing equipment.
Currently the licensee performs detailed dose rate surveys of the temporary liquid processing system, located in the Radwaste Building Waste Drum Storage Area (2000-foot elevation, room 7225), only when weekly general area radiation surveys i
indicated the need.
The NRC inspectors informed the licensee that preventative surveys should be performed during and at the conclusion of work operations that may cause a change in the radiological status of an area. The Waste Drum Storage Area was the subject of a Notice of Violation concerning very high radiation area control during NRC Inspection 50-482/88-09.
The NRC inspectors verified on September 15, 1988, that the general area around the Duratek processing system met the requirements for being posted as a radiation area.
The licensee acknowledged the NRC inspectors concern.
This is considered an open item pending further review by the NRC inspectors.
(482/8825-05)
No violations or deviations werrs identified.
10.
Internal Radiation Exposure Control The licc9see's internal radiation exposure control program, including airoorne radioactivity monitoring / sampling and respiratory protection, was examined for agreement with:
commitnents in Section 12.5 of the USAR; requirements of TS 6.11 and 10 CFR Parts 19.12, 19.13, 20.103, 20.201, 20.203, 20.405, 20.407, 20.408, and 20.409; and the recommendations of industry sta.3dards ANSI 13.1-1969, N343-1978, NUREG-0041, and RGs 8.15, 8.20, and 8.26.
The licensee's procedures and selected documented results of 1988 facility airborne radioactivity sampling were examined.
The NRC inspectors examined the licensee's program for control of personnel exposure to airborne radioactivity including routine and emergency situations. The NRC inspectors determined that the licensee did not have in place instructions for the tracking of radioactivity uptakes of emergency response personnel during implementation of the licensee's Radiological Emergency Response Plan (RERP).
Routine tracking of personnel exposure to airborne radioactivity is satisfactorily addressed in licensee procedures. The licensee's RERP implementing procedures provide adequate instructions on respiratory protection equipment (RPE)
used to control exposures to airborne radioactivity, but instructions on the tracking of such exposures or the limits on such internal exposures other than thyroid / Iodine uptakes are nonexistent.
This is considered an open item pending licensee review of their program for tracking radiological exposures (internal) during radiological emergencies.
(482/8825-06)
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The NRC inspectors examined the licensee's personnel bioassay program including procedures, whole body counting equipment operation, calibration, operator training, frequency of counting of employees, significant findings, and records.
The licensee is currently reviewing, fe.r adequacy, their in-vitro measurement / bioassay program for tritium.
Currently the licensee's HP group does not specifically monitor plant areas for or terform bioassays on employees for tritium. The licensee's in-vitro bicassay procedure (HPH 03-006, "Collection of Bioassay Samples")
appears to adequately include the guidance contained in ANSI N343-1978 for sample collection frequency, sample preparation, and results evaluation.
The licensee's RPE inventories, equipment maintenance and repair, selection and use procedures, management policies on RPE use, and personnel training were examined.
Selected RPE was inspected to determine certification status and readiness for issue.
The licensee's facilities for RPE issuance, return, cleaning, and decontamination were examined.
The NRC inspectors noted that only select emergency response personnel receive Self Contained Breathing Apparatus (SCBA) training. All site RPE qualifici personnel are qualified using full face air purifying respirators (same design as face mask used on the SCBAs).
Not all personnel in the HP department are SCBA o salified.
Training department personnel acknowledgr.d the NRC observation and agrsed to evaluate their RPE
training and emergency personnel needs.
The licensee's program for implementation ci a CAM program, equipment placement, and operability was reviewed during the closecut of Notice of Deviation 50-482/8712-02.
The NRC inspectors determined that the licensee had apparently resolved the probles of an excessive number of portable CAMS being inoperable by purchasirg a simpler designed, single function beta particulate CAM to replace tie unreliable CAMS originally used during plant start-up.
The licensee's problems with CAMS were previously discussed in NRC Inspection Reports 50-482/85-42, 50-482/87-12, and 50-482/87-28. The licensee had implemented Procedure HPH 04-077,
"Operation and Calibration of the Eberline AMS-3".
Paragraph 5.2.4 requires that the alarm on the portable AMS-3 CAM be set to alarm at 10 percent above background.
The 10 percent value does not appear to be related to a specific 10 CFR Part 20 limit. The AMS-3 reads out in counts per minute (cpm) on a small logar ;hmic scale (0 to 100,000 cpm range) with labeled decade scale ranges of 0 40,10-100, 100-1,000, 1,000-10,000, and 10,000-100,000.
Each of these decades included 5 small incremental markings.
TS 6.11 requires that procedures for personnel radiation protection shall be prepared consistently with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposures,
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-10-The NRC inspectors determined on both September 13 and September 15, 1988, that the alarms on several monitors (11391,1139L,11397, and 11394) were incorrectly set high, and that the alarm on CAM 11391 would not respond to an alarm test because the alarm setpoint was off scale high.
The failure to properly establish CAM alarm setpoints in accordance with plant procedures is an apparent violation of TS 6.11.
(482/8825-01)
The NRC inspectors discussed with licensee representatives their deviation from accepted industry practices involving the lowest acceptable value when interpreting an analog meter scale.
This is taken as one-half of the smallest scale division.
Procedure HPH 04-077 requires alarms on portable CAMS be set at 10 percent over background. Background radiation levels on most plant CAMS (af ter reaching equilibrium) were observed by the NRC ir spectors to be 800 to 2000 cpm.
Technically, alarm setters would not be
able to set an alarm at 80 cpm over background on a scale increment of
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200 cpm range or establish an alarm at 200 cpm on a scale increment of 1000 cpm range.
The NRC inspectors routinely observed alarm settiags that were two to three times higher than required.
These settings still would have produced an alarm in the event of a significant airborne radioactivity problem, with the exception of CAM 11391 which was set off scale high. Basically, the licensee's alarm setpoint criteria for the portable CAMS is exceedingly conservative and produces many nuisance alarms which desensitizes plant personnel to the importance of the CAMS.
The NRC inspectors also noted the licensee was having problems witn the strip chart records on several CAMS.
The licensee's problems with CAM operating procedures and chart recorders is considered an open item pending licensee action.
(482/8825-07)
No deviations were identified.
11. ALARA program The licensee's ALARA program was reviewed to determine agreement with:
commitments in Section 12 of the USAR; requirements of TS 6.11 and 10 CFR Part 20.1(c); and the recommendations of RGs 8.8, 8.10, and 8.27.
The NRC inspectors examined the license 6's onsite and offsite ALARA program activities.
Offsite corporate committee meetings minutes were examined.
The licensee's AI. ARA program is well documented and supported by plant management and staff.
Staffing of the ALARA section (one supervisor, one technician on temporary loan from the opeistional HP section, and a part time clerk) is marginal considering the extent of ALARA activities.
Attachment 2 lists the licensee's person-rem exposure since start-up (1985) through 1987 and a listing of jobs during Refueling Outage II (September 26 through December 31,1987) that exceeded 5 person-rem.
The licensee did not meet the 1987 refueling outage exposure goals primarily due to the outage being extended and additional work being accomplished.
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-11-The 1988 ALARA goal for exposure expenditures for the plant is 190 person-rem.
Currently, the licensee has used 68 person-rem which leavet 122 person-rem for the remainder of 1988. This value ia less than the 125 person-rem allotted for the 1988 refueling outage.
The licensee was noted to issue monthly exposure goal updates to plant staff and management.
Exposure tracking per job is done on a daily to more frequent basis during outages.
The NRC inspectors discussed with the ALARA coordinator personnel contamination incidents during Refueling Outage II. Approximately 131 incidents occurred and of these, 53 involved skin contaminat:ons.
Eight hot particle occurrences were documented and the highest recorded exposure to the skin was 2 rem.
All design change packages are reviewed by the corporate ALARA group for exposure reduction aspects and HP impact before the ALARA coordinator reviews them.
No violations or deviations were identified.
12.
Control of Radioactive Ma*.erials and Contamination, Surveys, and Monitoring The licensee's RP activities for the control of RAM and contamination, radiological surveys and monitoring were examined to determine agreement
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commitments contained in Section 12.5 of the USAR; requirements contained in 15 3.7.9, and 6.11, and 10 CFR Parts 19.12, 20.4, 20.5, 20.201, 20.203, 20.205, 20.207, 20.301, 20.401, 20.402, and 30.51, and Item 111.0.3.3 of NUREG-0737; and the recommendations of IEINs 86-23, 86-43, 87-39, and 88 63.
The NRC inspectors toured facilities; conducted independent gamma radiation dose rate measurements; reviewed ongoing work operations within the reactor auxiliary and radwaste buildings; examined radiation work permits; axamined radiation, airborne and surface contamination surveys, and examined the licensee's procedures for RP instrumentation.
The NRC inspectors conducted an inventory of special nuclear material in the possession of the licensee. Nuclear Material Transaction Reports and Material Balance Reports (Department of Energy and NRC Forms 741 and 742, respectively) were examined for frequency and accuracy. Appropriate documents correcting erroneous data were sent in a timely manner. All Special Nuclear Material previously accounted for under NRC License SNM-1929 is now covered under the 10 CFR Part 50 license (NPF-42).
The NRC inspectors physically accounted for all materials, except for several excore and incore detectors installed in/on the reactor and used detectors packaged for future disposal.
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The licensee informed the NRC inspectors on September 13, 1988, that a QA departmont audit (TE:
53339 S-1657, dated September 13, 1988) performed during the period August 23-28, 1988, had determined that the source inventory records had been lost, sources of a licensed quantity were not i
being properly controlled (thede strontium-90 sources were not listed on the licensee's master inventory log but were in a source locker), sign out logs for sources were not accurate as to source location, and enmpleted
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source records had not been properly submit wd to record storage files
when sources were disposed of or lost.
Some of these findings constitute an apparent violation of licensee procedural requirements and the requirements of 10 CFR Part 30.51, regarding control and inventory of licensed quantities of radioactive byproduct material / sources. The licensee's audit was being performed to verify corrective actions to LER 87-056 were taken and procedural requirements of HPH 02-001 were being
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properly implemented. The audit indicated that the causes of the lost source referenced in LER 87-056 have not been fully eliminated.
The NRC inspectors discussed these findings with licensee representatives j
responsible for the audited areas on September 15, 1988.
The licensee had
.,ot completed it's rcot cause evaluation or formulated corrective actions.
The licensee discussed several thoughts on why the source control program
j broke down and possible long term corrective actions.
This licensee
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finding can be considered a "licensee identified violation" in accordance with Appendix C to 10 CFR Part 2; however, since the licensee had not had
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tfee to evaluate the problem and implement effective corrective action, this occurrence will be considered an unresolved Jtem pending further
review of the licensee's response to the QA finding and any corrective actions implemented, if required.
(482/8825-03)
i During the NRC inspectors review of the QA audit findings referenced I
above, it was identified by the NR0 inspectors that apparently several 400 microcurie strontium-90/ yttrium-90 ($r-90/y-90) sources had not been j
routinely leak tested as required by th<s TS.
Leak testing of sources is accomplished in accordance with Surveillance Procedure STS HP-001, Revision 1, dated February 27, 1985.
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TS 3.7.9 requires, in part, that "ech paled sowrce containing
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radioactive material either in excess of 100 microcuries of beta and/or i
gamma-emitting material or 5 microcuries of alpha emitting material shall l
be free of greater than or equal to 0.005 microcurie of removable i
contamination.
TS 4.7.9.1 (Surveillance Requirements) states, in part, j
that "Each sealed source shall be tested for leakage...." TS 4.7.9.2 i
requires, in part, that "Each category of sealed sources... shall be tested at the frequency described below, a) Sources in use - At least once per 6 months for all sealed sources containing radioactive materials,
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b) Stored sources not in use - Each sealed source and fission detector
!
shall be tested prior to use or transfer to another licensee unless tested within the previous 6 months."
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-., - -
.- -
,
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_
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.
k
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'
-13-l The NRC inspectors determined on September 15, 1988, that four (400 microcurie each) Sr-90/y-90 sources (Serial Numbers 182, 183, 184, and 185) had not been leak tested in accordance with TS requirements during the period January 13, 1986, through December 10, 1987 The failure to leak test sources at the required frequency is an apparent violation of TS 4.7.9.2.
(482/8825-02)
The NRC inspectors determined from licensee records, reports, and interviews that apparently not all of the subject sources were in a stored condition (TS 4.7.9.2.b) since source number 184 was routinely transported between sites at the plant, for response checking of portable radiation monitoring instruments, prior to being declared lost on December 18, 1987.
Source Serial Number 184 was lost sometime during the period August 198/
through October 1987 and was reported to the NRC via LER 87-056.
The licensee considers the apparatus for response checking survey instruments to satisfy the "shielded container" condition referenced in the Bases Section of the TS. The NRC inspectors informed the licensee, during a telephonic meeting on September 23 and October 3, 1988, that, since the instrument response check apparatus was portable, c' Questionable integrity, and a significant amount of mechanical labor is not necessary to get at the source, the response check apparatuses are not considered a shielded container, such as would be the case with a boronometer, incore detector, or an internal response check source ins i a stationary area monitor.
Furthermore, the licensee stated in LER be 056 that source number 184 was last seen in October 1987; therefore, there is reason to believe that one of the remaining sources (182,183 or 185) was placea into service for response checking instruments, on or about this time,
.
which would necessitate a leak test per TS 4.7.9.2.b.
Licensee Procedure HPH 03-011. "Contamination Survey Methods," requires that approximately 10 percent of the loose surface contamination swipes taken in the spent fuel building be counted for alpha contamination. The NRC inspectors noted that all routine swipes taken in and around the spent fuel pool area (primarily walksays) were counted for alpha contamination and that none of the swipe surveys taken in such places as the spent fuel pool water clean up filter / pump and heat exchanger rooms were counted for alpha contamination.
Currently, there is no indication of alpha contamination in the plant or significant fuel integrity problems; however, it was discussed with licensee representatives that surveying for alpha contamination in an area exposed to liquid spills would be more informative than thase taken in an area normally not exposed to liquid spills and normally kept in a high state of cleanliness.
This is considered an open item pending li'.ensee evaluation of the alpha contamination survey program.
(482/8825-08)
No deviations were identified.
__
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_ _ _ _ - _ - _ _ _ _ _ _ - _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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-14-i
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13.
Radiological Control Equipment / Instruments and Facilities The licensee's facilities for conducting RP activities during routine and emergency situations were examined to determine agreement with:
commitments contained in Section 12.5.2 of the USAR and the WCGS Radiological Emergency Response Plan, Table 4.3-1; nd the reevmmendations
of RGs 1.97, 8.8, and 8.25, NUREG-0041, and NUREd-0654/FEK4-REP-1.
'
The NRC inspectors examined:
training facilities; respirator acrontamination and maintenance facilities; counting laboratori<.s; radioactive source and SNM storage facilities; hot machine shop and decontamination facilities; personnel locker rooms and decontanination facilities; e ergency equipment kits and responso facilities (Technical Support Center, Operations Support Center (OSC), and Control Raom)-
routine and spare equipment inventories of radiological survey
!
,
instruments; and RPE inventories.
Selected emergency equipment
!
J inventories as referenced in the RERP and Emergency Plan Implementing Procedure (EPP) 02-1.5, "Maintenance of Erergency Facilities and
,
Equipment," (Personnel Access Control Station cabinet, ambulance kit, OSC kit, control room cabinet, and two onsite monitoring kits) were
examined.
The licensee was also condu: ting a routine QA surveillance of the emergency kits (EP-kit) during the NRC inspection.
The NRC inspectors determined that a particular type of battery operated contamination
monitor found in the ambulance EP-kit and in one onsite monitoring team i
i EP-kit to be inoperable due to low or completely discharged batteries.
The problem was traced to an easily actuated, slide type, on/off switch on
,
the instruments.
The switch went to the on position during placement into t5eir padded recesses in the EP-kits.
Instruments with rotary type sw1*ches did not exnibit this problem.
A'. a, several kits were found to
'
be la-king a number of silver zeolite cart'.dges and that these cartridges
>
in many kits were not being environmentally maintained (hermetically l
saled to keep out moisture).
In some EP-kits carbon type cartridges
!
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(high noble gas affinity) had been mistakenly substituted for the zwolite
typeiartridges.
None of the aforementioned problems were identified by s
the licensee s QA surveillance or recent audit (QA TE:
50140-K220, dated
!
'
August 24, 1988) of the EP program.
The licensee took immediate actirn to initiate corrective actions to resolve the NRC identified problems.
The
licensee's problems with EP-kit equipmtnt is considered an open item
>
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pending licensee completion of corrective actions and NRC review.
!
(482/8825-09)
!
The licensee's special training facility for radiological workers was i
discussed in paragraph 8 of this report. This facility is located
!
close to the plant's protected area and provides suitable hands on training
!
with duplicate plant components for electrical, HP, and mechanical l
maintenance personnel.
!
No violations or deviations were identified, r
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_ _ _ _ _ _ _ _ _ _ _ _ _.
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-15-14.
Scheduled Outage Advance planning and Preparations (83529)
The NRC inspectors examined the licensee's preparations for a 66-day refueling outage, tentatively scheduled to start on or about October 6, 1988.
Licensee advanced staffing (140 extra HP personnel, 91 HP e
technicians and 49 decontamination personnel), personnel selection criteria, placement testing, site cpecific training and qualification of HP and radwaste workers were reviewed.
The licensee's contractor qualification program ensures contract HP and radwaste technicians are properly qualified to perform specific tasks. The NRC inspector examined licensee organizational staffing for the outage and HP coverage of selected areas and jobs. The licensee has established an ALARA goal of approximately 125 person-rem for the outage.
The licensee's procurement of additional radiation protection instrumentation and expendable supplies was examined.
'
The licensee has scheduled simultaneous full core defueling and steam
,
generator primary side eddy current testing (4 generators), secondary side l
SG sludge lancing including foreign object search and removal, inspection of the reactor vessel outlet nozzles, fuel assembly eddy current testing, and possible reconstitution during this outage.
Nu violations or deviations were identified.
15.
Exit Interview The NRC inspectors met with licensee representatives identified in paragraph 1 at the conclusion of the inspection on September 16, 1988.
The NRC in o...srs summarized the scope and findings of the inspection.
On Septembsr 23 and October 3, 1988, Mr. H. Chaney held a telephone conference with 1;.*entee personnel, identified in paragraph 1, to discuss the iicensee's position on the apparent violation of TS 4.7.9.2 (paragraph 12,482/8825-01).
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ATTACHMENT 1
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TO NRC INSPECTION REPORT 50-482/88-25
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EDGUHFJ1TS_.5_EYlEWE D.
IJILE BEVISipN DATE WCGS_6dm101stretive_Et9teduces_danual_J6DUl
.
ADM 01-006. Manager Technical Support Duties and Responsibilities
07-26-88 ADM 01-009. Site H.P.
Duties and Responsibilities
09-22-87 ADM 01-023, Guidelines for WCGS Staff Working Hours
12-29-87
ADM 01-033. Instructions Describing Reportabilitv.
Revi ew and Documentation of i
Licensee Event Reports (LERs) and Defect / Deficiencies
10-27-87 ADM 01-067. Confined Space Entrv O2 06-16-87
ADM 01-086. 10 CFR Posting Requirements
12-31-86 i
ADM 01-090. Guidelines for Heat Stress Control
11-03-86 ADM 01-092. Industrial Respiratorv Proteceton s
Program
64-27-88
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ADM 01-094. Evaluation of Air Contaminants and Respirator Selection
04-27-88 l
ADM 01-095. Confined Space Monitor Certification
12-15-86 ADM 01-098, Respiratory Protection Program Beard Poliev
07-14-07
!
ADM 01-100. Outage Plannino
06-14-88 ADM 01-114 Operation and Calibration of
,
Safety Instrumentation
06-01-88
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ADM 01-207. Refueling Outage Health Phvsics Program
08-31-87 ADM 03-002. Radiation Worker Guidelines
08-30-88
,
ADM 03-003. Radiography Guidelines
03-01-88
)
ADM 03-006. Notice of Rad Work Practice Violation
08-24-88 ADM 03-007. Duties and Responsibilities of i
Health Phv:1cs Supervisors and
i Technicians
04-26-88 ADM 03-010. Control of Health Physics Documents
03-05-86 ADM 03-011. Radiological Occurrence Reporting Program
08-17-88 ADM 03-012. Contaminated Area Reduction Procram
08-09-88 I
ADM 03-050. WCGS ALARA Program
03-24-88
ADM 03-100. Health Physics Dosimetrv Program
11-10-87 ADM 03-101. Radiation Work Permit Program
08-30-88 ADM 03-104. Control of Locked High Radiation
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l Areas
07-20-87 ADM 03-202. Radiolooical Control and Unconditional Release of Tools and Equipment
08-23-88 ADM 03-203. ADM Procedure for Rad Material
02-23-88 l
ADM 03-204. Hot Particle Contamination Control
08-04-88 l
ADM 03-400. Operation and Calibration of Health
Physics Equipment
02-09-88 l
ADM 03-402. Management of HP-1000 Computer Resources 02 06-02-87 l
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13TLE BEYJSJON D6,1 E
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ADM 03-600. Respiratorv Protection Prooram (Rad)
08-24-86 I
ADM 03-801. Health Physico Tw h'.i c i an Trainino
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Prooram
01-15-86 ADM 03-950 Radioactive Wowte Frocram
05-30-88
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ADM 03-960. Use of Temporarv Lead Shieldino
09-08-87
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ADM 05-600 Special Nuclear Matcrial Safeguards
& Accountability
04-20-88 i
WCG5_E8et9e0cY_ Elf 0_Imple8pnt!DQ_EEocedutes.fEPE1
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EPP 01-8.1 Onsite Radiolootcal Monitorino
03-OF
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EPP 01-9.1. Exposure Control and Personnel s
Protection
06-88 EFP 01-9.2. Personnel Decontamination
12-86 EPP 01-9.3. Radioprotective Drugs
04-88 EFP 01-9.4 Emeroency Team Formation
03-88 f
EFP 01-9.5. Aid to Contaminated / Injured Fersonnel
08-07
[
EPP 01-10.1. Protective Action Pecommendations
08-07
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EPP O2-1.5. Maintenance of Emeroency Facilities and Equipment
04-88
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Health _Pbysics_P ggedytyg_fHPU1
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HFH 01-001. Issuino and Numberino of TLDs
10-07-87
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HFH 01-002. Eaternal Overexposure Evaluation
02-08-85 HPH 01-004 Acceptance Criteria for Panasonic
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03-22-85 i
HFH 01-005. Development of Element Correction i
Factte for Panasonic TLDs
07-11-88
HPH 01-006. TLD Processing
07-11-88 i
HF H 01-008. MPC-Hour Trackino
06-27-88 I
HFH 01-011. Calculation of Non-Penetratino
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and Penetratino Dose from TLDs
04-18-85
I NPH 01-012. Internal Dose Calculations
01-25-8D
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HPH 01-016. Exposure Evaluation of Lost Suspected Damaged or Offscale Dosimetrv
07-11-88 HPH 01-017 Evaluation of Fersonnel Monitorino i
Devices
07-28-86'
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HPH 01-019 Exposure History Files
08-31-88
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HPH 01-020. Neutron Dose Calculations
07-11-88 l
HPH 01-035. Dosimetrv in Non-Uniform Radiation Fields
05-23-88 I
HPH O2-001. Receipt Accountabilitv. Inventerv and Leak Check of Radioactive Materials
01-06-88 HF H O2-006. Receipt of New Fuel
05-28-85 HPH O2-007. Loss of a Radioactive Source
08-01-88 HFH 03-001. In-Plant Radioicdine Monitoring Procram
08-24-88 HPH 03-002. Radiation Survov Methods
05-04-87 HPH 03-003. Airborne Radioactivity Survey Methods
08-14-88 HPH 03-005. Laundry Facility Oporttien
02-24-88
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HPH 03-006. Collection of Bioassav Samples
07-27-87 HPH 03-011. Contamination Survev Methods
08-08-88 HPH 03-012. Schedule of Routine Radiolooical Surveys
08-15-88 NPH 03-013 Health Physics Shift Turnover
01-28-86-L-
...
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_ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _
_
T!TLE REVIS10t4 DATE
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HPH GJ-014. Parsonnel Decontamination
08-16-88 HPS03-015. Postino for Radi ol ool cal Controls O'S 08-05-68
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HPH 03-016. Operation of the Laundrv Drv Cl eanino Facility
08-10-87 HPH 03-017 Initialization and Operation of the Hvdro-Nuclear Services Respirator Cleanino Facilitv O2 08-13-88 HPH 03-020. Health Phvsics Coveraoe of Steam Generator Entrv
07-22-88 HPH 03-025. Radi ol ooi c al Trendino
08-24-88 HPH 03-026. Underwater Dive Operations
08-26-88 HPH 03-027. Skin Dose Calculations
68-26-88 HPH 03-028. Free Release of Tresh UI G7-12-88 HPH 04-001. Countino Blind Samples for WBC Ouality Control
07-22-88 HPH 04-002. Operation of the Whole Bodv Counting Svstem
07-22-88 HPH 04-005. Operation of the Panasonic UD-710A TLD Reader
03-15-88 HPH 04-007. Operation & Calibration of the Eber11ne RO-2 L RD-2A
11 04-87 MPH 04-008. Operation & Calibration of the Eburline RM-14
10-20-87 HPH 04-009. Operation & Calibration of the MS-3 Mini-Scaler
02-12-88 HPH 04-010. Operation & Calibration of the NMC Automatic Counting System (ASC-82)
02-09-88 HPH 04-013. Operation & Calibration of RADECO Model H809-V1 or H809-V2 Air Samplers
03-18-86 HPH 04-017. Operation of Model PRM-110 Portal
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Monitors
09-11-86 HPH 04-021. Operation & Calibration of the XeLex Model 420B Alarmino Dosimeter
11-05-86 HPH 04-022. Preparation b Operation of the Tennelec LB 5100 Alpha / Beta Cm;nter
03-17-88 HFH 04-023. Respirator Fit Booth a Dvn. tech Model 260 Operatine Procedure
12-14-87 HFH 04-024. Operation & Calibra'. ion of the Nuclear Data WDC-BOOO People Mover Svstem
10-26-87 HPH 04-026. Operation of the "RASCAL" PRS-1 with a Neutron Rate Detector
03-03-88 HPH 04-035. Operation of the J.L.
Shepherd Multi-Source Calibration Svstem
09-15-86 HPH 04-040. Operation of the Eberline RO-7
02-ni-88 HPH 04-045. Sel ec t i on L Use of Protective Clothing
08-17-88 HPH 04-055. Quality Control Frooram For Whole Dodv Countino
08-26-08 HPH 04-060 Operation & Calibration of the Ludlum j
Model 19 Micro R/Hr Meter
08-31-88 HPH 04-062. Operation & Calibration of the MSA Lapel Air Sampler
01-14-88 HPH 04-068 Operation & Calibration of the RADECO Model HD-29 and HD-29A Air Samplers
04-29-88-3=
_ _ _ _ _ _ _ _ _ _ _ _ _
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TITLE REilSIQN DATE
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HPH 04-077, Operation & Cal &bration of the Eberline AMS-3
02-01-UD
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HPH 04-078. Operati on t< Cal i br ati on of the NMC BETAMAX Fr i st al l
02-08-88 HPH 04-080 Operation & Maintenance of the RM1 Cavity Decontamination Svstem
09-29-86 NPH 05-001. Calibration of the Whole Body Countino Svstem
08-11-84 HFH 05-011. Calibration 4, Leak Test of Pocket Don 1 meters
09-09-85 HPH 05-012. Calibration & Sensitivitv Ad.i ust ment of Modul FRM-110 Portal Moniters
09-01-88 HPH 05-053. Enerov Calibration af the Whole bodv Countino System
07-11-88 NPH 06-004 Selection of Respiratorv Protection Eaulpment
08-03-88 HPH 06-005. Une of Full Face Respiratorv with Cani ster /Fi l ter
01-09-86 HPH 06-008. Operation & Use of Self Contained B.eathing Apparatus (SCBA)
07-22-88 HPH 06-011, Qualitv Control of Respiratorv Frotection Equipment
08-17-6s NPH 06-018. Operation of the Cascade Air Svstem
11-05-66 NPH 06-019. Issue and Use of GMR-! Iodine Canisters
05-20-87 HPH 06-020. Startup and Operation of the DYNATECH RAF Pure Air Frocess PacLaoe Fill Station
06-08-89 HFH 06-200. SCPA Regulator. Alarm and Face Piece Adiustment and Testino
08-23-88 HPH 07-001. Fre and Post Job ALARA Reviews
03-03-88
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HPH 07-002. ALARA Reviews
07-22-86 HPH 09-512. Incomino Vehicle Surveys
03-19-86 HPH 09-513. Outootno Vehicle Survevs
02-26-88 l
TC4.10$0g_DivisL90_ECogeduces_M?Oyal_JEEl hP-800. Trainino Division Oroani:ation
12-87 KP-802. Superintendent General Trainino Dualifications and Respons1bilities
10-8/
LP-804 Superintendent Technical Trainino Dualifications and Responsibilities
10-87 MP-864 Written Examination Administration
10-07 LP-865. On-the-Job Training
06-87 Qthet_Tcat010g_Dggymeet3_Revteyed Lesson Outline Instruction 029 Doatmotry Technician Training
01-19-88 Professional Supervisorv Trainino Matrtu
09-02-88 GT 12 450 01. General Emplovee Trainino (GET) -
Orientation. Handout
11-11-87 i
GT 12 450 02. GET - Temporarv Emplovees. Handout
08-05-88 GT 12 450 03. GET - NRC. Handout O2 08-24-88 l
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ATTACHMENT 2
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10 NRC INSFCCT10N REPORT a.
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WOLF CREEL bEr.Fn1INa SIAT10N COMPARISOfl WITH AVERAGE NATIONAL FRESSURIZED REACTOR RADIATION EXFOSURE FERFORMANCE AND SELECTED SECOND REFUELING OUTAGE WOR): OPERATION RADIA110N EXPO 5URE EXPENDITURES IGDLE_1 EEBSON:SEU_EZEEUPED YEGB 1984 1985 1906 1987 1988
WCGS GOAL na8 lows *
150.0 150.0 190.0 WCGS EXPENDITURE (TLD)
na 7.2 134.0 124.0 67.6p NATIONAL FWR AVERAGE 552.0 416.0 392.0 371.0
4 WCGS under Construction
- Operating license issued June 4.
1985, p As of August 31, 1988. refueling outage to begin on October 6.
1988
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IGDLE 2 EELEGIED EEBSOU: BED _EEEENQlIWBES E08 EEEUELIUG QUIGGE II 1190Z1
-
00B_QESCBleI100 eg8 spy:EEU Health Fhvsics Containment Access Control 15.562 In Service Inspection (ISI) of Reactor Coolant Piping Fenetration Welds 13.465 ISI of Reactor Pressurizer Skirt Weld 5.585
'
ISI Reactor Coolant RTD Manifold Pipino Wolds 4.095 Inspect / Repair DOS / Transmitter Ravchem Splicing inside Bioshield 5.008 Reactor Vessel Head Activities (venting, disassembiv. removal, inspection, stud work, 0-rino work. cono-seal refurbishment etc..)
25.168 Reactor Cavity Refuelino Activities (cavity drain, fuel transfer tube blank work. cavity seal rino installation and removal)
1.830 Fuel Shuffle 5.080 Duratek Waste Processing (outage ontv)
0.075 Radwaste Operations 1.073 Routine Decontamination 4.159 Installation and Removal of Temporary Shieldino 1.155 STS/LLRT Surveillance Activities (in containment)
1.004 STS/LLRT Surveillance Activities (outside of containment)
0.385
!
TOTAL PERSON-REM EXPENDITURE (TLD)
117.406 PERSON-REM GOAL FOR OUTAGE II (TLD)
115.000
_ _ _ _ _ _ _ _ -
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GT 12 451 U1. GET - Radiation Frotection Trainino (Cateocrv I). Hendeut N
1 1 - T - 8 7
Radiattor. W o r i.e r Iroin a ria GT 12 452 01. GET
-
(Cateoorv II). Handout
08-11-86 HS 81 330 01. Contract Senior Health Physics Technician Trainino - Procedur e Review
69-21-57 HS 81 330 02. Contract Junior Health Fhvcacs Technician Tr ai ni no - F rocedurr-Review
09-23-86 GT 12 453 01. Respiratorv Protection I Lesson F1an
09-06-88 GT 12 453 02. Respiratory Frotection II (SCEAs Losson P1an
11-13-87 Opal i.t. v_ As sur agq p_Dgq umt>nt b l
A u cli t< s.
TE: 50140-6:180, P1 ant Support Indoctrination and Trainino
10-09-07 TE: 50140-l'.710. Radiation Protection
06-16-68 TE: 50140-F220. Emeroencv Plan and Implementino Precedures
08-23-89 Sutveillacco5 1997 S-1528, Calibretion of Health Phvntcs Instruments 05-04-8'
E-1579. Continuous Air Manitors 10-12-8/
5-1582. Health Fhvntcs F1 eld Activities 10-20-87 S-1583. Rcactor Heaa Removal 10-23-87 S-1589 Duratec Activtties 10-23-87 S-1609 Health Phvs1cs Site Attivities 12-31-87 1988 S-1617. Heal t h Fhvcics 0-Rino Outace Activi ties 02-12-88 S-1619 Waste Stream Analvsts L Classification 03-01-88 S-1622. Transfer b Dewaterino of Radwaste Material 03-10-80 S-1635. Control of Contaminated Tool s L Equipment 05-20-88 S-1657. Control of Licensed Material 09-13-83 t.ilEC t'l 1pneog S. Documpo t s For m HPH 01-019~3.
Instrutt1ons for Use of Whol e Bodv TLDs Organt:ation Chart for fJuc l ear Tratnino Division US-20-88 Droanization Chart (G.3) for WCGS Technical Support Grcup
06-01-88 Oraan1:ation Chart (G.3.5) for WCGS Health Phvsacs Sect 1on
06-01-89 Special Report to FJRC (WM 88-0003): Subi: Low Level Radioactive Material Release from WCGS 01-07-88
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T!1LE DATE
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Internal Correspondence (TS 88-0222) - T.S.
Morrill t o 0. L.
Maynard1 Sub1: Consultant Radiation
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Protection Manaaer Responsibilities 05-12-86
'
WCGS Lutter to Martin-Marietta Enerov Systems. Inc.
(TS 87-0265): Sub1: DOE /NRC Form 744 Report Error 08-31-07 Form 741. Nuclear t1atorial Transaction Renort OG-14-E34 Form 741. Nuclear Material Transaction Renort 06-04-Bh Form 741. Nucl ear Material Trannection Report 08-28-67 Form 741. Nuclear Material Transaction Report 11-27-87 Form 742. Material Balance Report (10-1-87 to 3-31-88)
04-20-88 Form 742C. Phvnical Inventory Listino (10-1-87 to 3-31-88)
04-20-88 FHP-15. WCGS Fission Detector Inventorv (ADM 05-600)
04-21-88 Heelth Fhvulcs Instrument Inventorv 09-13-d7 Sel ec t ud 1988 Routine Radiolooical Survevs from For m HF H 03 ')12-1 (Dailv. Woolly, t1onthly and Quar terrl'e sur vevs)
WCGS St-cond Ref ueling Outaoo Font Outaoo rmoort -
Ex posuro Siir.imarv 03-88 ALARA Review of Yearly Exposure Goal s f or 1988 06-88 ALARA Review of Month 1v Exposuro for Auoust 1908 09-88 Surveillance Tont HP-OO1. Source Leat Testu 12/88 Frocedure STS HP-001. Sealed Source Contamination Surveillance Test
v2-27-85
>
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