ML20005E374
| ML20005E374 | |
| Person / Time | |
|---|---|
| Site: | 07000036 |
| Issue date: | 12/19/1989 |
| From: | Datta A, France G, Sreniawski D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20005E372 | List: |
| References | |
| 70-0036-89-04, 70-36-89-4, NUDOCS 9001050146 | |
| Download: ML20005E374 (12) | |
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'U.S. NUCLEAR REGULATORY COMMISSION I
REGION III
- Report No. 70-0036/89004(DRSS)-
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Docket No..'70-0036 License No. SNM-33 e
Licensee:' Combustion Engineering, Inc.
H Nuclear Power Systems
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Windsor, CT 06095 c
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-Facility Name:. Hematite
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_ Inspection At: -Hematite, Missouri.
Inspect _ ion Conducted:
November 13 17, 1989 SM S
/1[/Y/i7 Inspectors:
G.
. FJance, III Date i
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.' Approved Byi IDfM/89 e_
0 -J. Sreniawski, Chief
'Datel I
Nuclea Materials Safety Sl!tt on l' Inspection Summary Inspection Conducted November 13-17, 1989, (Report No. 70-36/89004(DRSS))
Areas Inspected:
Routine, unannounced safety inspection to review NRC-licensed activities, including:
management organization and controls (IP 88005); radiation protection program (IP 83822); operations review
-(IP 88020); criticality safety (IP 88015); transportation activities (IP 86740); emergency preparedness (IP 88050); and environmental activities (IP 88045).
Res'ults:
No violations were identified.
Three concerns were discussed with the licensee; review the storage of miscellaneous items in the incinerator
. process bins; the BTP guidelines of 30 pCi/g must be met prior to completing the revitalization process; prevention of contaminated seepage from beneath Building 240.
Seven concerns about fire safety were also identified.
9001050146 891227
.PDR ADOCK'07000036 PNU S
- C.
a DETAILS 1.
Persons Contacted (IP 30703)
L. F. Deul, Manufacturing Engineer _
n-S.EL, Dorlac, Health Physics Data Clerk _
- H. E. Eskridge, Manager, Nuclear Licensing, Safety and Accountability
- R. C.-Fromm, Quality Control Manager
- R. W.,Griscom, Plant Engineering Manager L. N. Grossman, Director, Special Projects Technology G. F. Palmer, Process Engineer E.
C.- Lovell,_ Supervisor, Material Control
- R. C. Miller, Manager, Administration and Froduct. ion Control B. S. Pigg, Quality Control Lahorstory Supervisor C. Proctor, Supervisor, Health Physics
- J. A. Rode, Hematite Plant Manager R. Sanders, Health Physics Technician J. Shaw, Health Physics Technician G. L. Uding, Supervisor, Quality Control _ Engineering
.P. E. Weaver, Scheduler
- Denotes those present at the exit meeting on November 17, 1989.
2.
General This inspection was conducted to examine licensee activities under Special Nuclear Materials License No. SNM-33 which included a review of the emergency preparedness program with emphasis on fire protection and a review ~of the plant revitalization program.
The licensee's performance in the areas of operations, transportation, radiation protection, emergency preparedness, management controls and criticality safety is adequate and satisfies applicable regulatory requirements.
The inspector shared six (6) soil samples with the licensee which were collected from the soil surface located in the phase 2 construction area.
3.
Licensee Action or Previously Identified Items The inspector reviewed the progress the licensee had made in correcting open items and/or observations identified during a previous inspection.
(Closed) Open Item No. 70-36/88001-02:
Develop a procedure for converting whole body count and urinalysis data to MPC-hours.
The licensee adapted a commercially available computer code to convert whole-body counting data and bioassay requests to MPC-hours.
(Closed) Open Item No. 70-36/88001-07:
Maintaining spare detectors / alarms for criticality safety, 2
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4 L-A spare' detector is maintained and stored in the instrument maintenance
- shop.
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(Closed) 0)en Item No. 70-36/89001-02:
Review 10 CFR 71.137..The licensees QA Manual Section 13.
Receipt of packages-should be referenced by procedures for handling and -
storage.
Surveillance checklists should also be provided for receipt of ufo' cylinders.
In addition to procedures, the licenseo has implemented a program to perform a radiological survey on each ufo package received.
This action exceeds the regulatory requirement of surveying only those packages that have a uranium content equivalent to three curies or above..
(Closed) Open Item No. 70-36/89001-03:
Flowmeters, Velometers, and rotameters are calibrated in accordance with the manufacturer's certificate,
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A Velometer used in stack measurements had not been recertified since 1983.' The licensee maintains two Velometers and at the manufacturers suggestion has arranged to have the instruments calibrated and/or recertified during alternate years.
4.
Management Organization and Controls (IP 88005)
The inspector reviewed.the licensee's organization for radiation protection, including changes in the organizational structure and staffing.
Effective this inspection, the licensee's radiation protection program is handled by nine (9) employees.
The radiation protection staff includes the Manager, Nuclear Safety, Licensing and Accountability; a Supervisor, Health Physics, six (6) Health Physics Technicians; and a Health Physics Data Clerk.
The HP clerk provides computer input for the storage and retrieval of sample data and employee exposure data.
The inspector interviewed the most recently hired HP tech and determined that his experience as a radiological technician in nuclear reactor maintenance programs should be adaptable to the radiation protection requirements for manufacturing nuclear fuel.
The inspector also determined that the radiation protection staff's data management requirement is supported by the Production Control Department.
A worker (scheduler) assigned to the Production Control Department is available to perform data management functions and/or radiological surveillance.
The inspector concluded that the licensee has hired the necessary workers to provide radiological health and safety surveillance for Hematite facility programs as well as upgrade the data management capability of the Radiation Protection Department.
No violations or deviations were identified.
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5.-
Radiation Protection (IP 83822)
The inspector reviewed the licensee's internal control programs including required' records,~ reports,.and notifications.
a..
Internal Exposure Control Bioassay records for the January through October 1989 operating period disclosed that the 40 MPC-hour intake limit for soluble
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uranium was not exceeded.
According to the licensee's " operator-exposure. report" workers exceeding 20%~of the quarterly MPC-limit (520 MPC) are whole-body counted.
The minimum frequency for i
E whole-body counting a worker is annually.
According.to the report during the first quarter 1989, five workers (oxide powder / pellet preparation) exceeded 20% of the quarterly MPC limit (520 MPC).
Apparently, the highest reported value of 63% MPC was mitigated to near background level after the worker reshowered.
b.
Airborne Releases-(
The inspector reviewed licensee records of air sample analyses for the January through October 1989 operating period.
Air sampling is q
conducted using fixed room samplers and/or lapel samplers.
No MPC-hour assignment exceeding regulatory requirements was noted.
No violations or deviations were identified.
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-6.
Operations Review (IP 88020)
The-inspector observed the licensee's performance of plant operations to include handling and storage of SNM material in accordance with applicable regulatory requirements.
In the older section of the plant, the licensee was producing fuel pellets from uranium oxide enriched to less than 5 percent U-235 in preparation for shipment to the CE Windsor, Connecticut fuel fabrication facility. The licensee was conducting start up tests of new equipment (pelletizing machine; pneumatic / vacuum transfer system for the movement of uranium oxide to the pelletizer from the storage hopper) in the revitalized sector of the facility. The inspector observed that the test material was composed of depleted uranium oxide which had been recently-approved by license amendment.
Fissile material had not been approved for equipment start up tests at the time of the inspection.
It appeared that the licensee was conducting startup tests in accord with the license amendment.
In addition, the equipment had been reviewed for criticality safety concerns.
Testing of the new equipment will also include
- 1 observation of devices that determine moisture level requirements for processing uranium oxide.
Portions of the scrap recovery plant were not operating end other than miscellaneous materials stored in the incinerator process bins, (see Section 7.b), the overall housekeeping effort at the facility was sati sfactory.
No violation or deviations were identified.
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.7.
Criticality Safety (IP 88015)'
a.
-Audits'
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'A Corporate audit of the nuclear criticality safety program (conducted on: June 21,- 1989)- identified several minor-infractions (unproperly stacked pellet trays ' violated the slab height limit; two pellet trays located on adjacent tables violated the one foot separation requirement; a container of enriched uranium (23 Kgs) exceeded the limit of 22 Kgs for storing 4.3% uranium-235) in the licensee's-criticality safety program. -Appropriate management action was taken to, assure that the infractions were corrected.
b.
Scrap Recovery Operations Several steps are taken by the licensee to control criticality safety in scrap recovery operations.
They include:
Posting of. chemical analysis showing the concentration of uranium in aqueous solutions.
Drying and weighing of UO2 sludge and subsequent posting of j
uranium content.
Incineration of combustible materials and subsequent analysis of the ash for uranium content.
Maintaining SNM materials in fixed array storage.
Performing l appropriate tests on borated glass rings (Rashig Rings) used for retarding' neutron interaction in fissile material processed in unsafe geometric containers.
The inspector noted a housekeeping ~ problem in the three storage bins
-located in the vicinity of the incinerator.
The bins are normally 3
used to store one-item per space when the processing unit (incinerator) is operating.
The incinerator was on standby and a number of incinerator -trays were stacked in each bin.
This area should either be maintained free of items that clutter the bins or the sign should be changed to accommodate storage of materials during the downtime of the incinerator.
A resolution of this problem will be reviewed during a future inspection (0 pen Item No. 70-36/89004-01),
In observing the spacing requirements and controls required for the safe handling of Special Nuclear Materials (SNM), there was no indication that the double contingency principle, as used in ANSI /ANS-8.1-1983, was violated.
This principle allows that
" process designs incorporate sufficient factors of safety to require at least two unlikely independent, and concurrent changes (such as geometry and mass) in process conditions before a criticality accident is possible."
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Revitalization ProgramL During a tour of the revitalized facility,'the inspecttr observed
.that the new pelletizer was undergoing tests that wers limited to pelletizing non-fissile' source material.
At the the of this inspection NMSS had not approved the use of enricaed uranium
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(fissile' material) in the revitalized pellet production line.-
Moderation control appeared to be the primary parameter that must be controlled for nuclear criticality safety in the revitalized pellet
~line.'.The licensee indicated that each of the hoppers used to store-uranium oxide (U0 ) powder is designed with a flanged seal arrangement 2
to prevent the intrusion of moisture.
Start up tests using non-fissile U02 are' designed to monitor-the moisture level of UO2 as well as the. operational proficiency of the new pellet line equipment.
The inspector will monitor the licensee's progress in this area during s.
future inspections.
No violations or deviations were identified.
8; Transportation (IP 86740) l The: inspector reviewed the transportation activities to determine whether the licensee is maintaining an adequate program to assure radiological safety in the receipt, packaging, and delivery of licensed radioactive materials.
1 Shipping records disclosed that the licensee performed adequate program
. requirements that-covered:.
i Monitoring for radiation and contamination of radwaste packages and
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transport vehicles.
Shipping paper documentation in accordance with licensee procedures.
t During this inspection several packages of uraniuin oxide and pellets were prepared for shipment to the licensee's Corporate Fuel Fabrication Plant in Windsor, Connecticut.
The shipping papers included the results of i
the radiological survey performed by the HP Tech, a copy of instruction's to.-the driver and the. shipping route from Hematite, Missouri, to Windsor, Connecticut.
No violations or deviations were identified.
'9.
Environmental Activities (IP 88045)
On August 28, 1989, an unplanned release of uranium occurred at the Hematite Facility.
According to the licensee's investigation and the independent sampling / measurement and calculations performed by the NRC, there was no indication that the spread of contamination extended beyond the' boundaries of the licensee's property.
Details of the unplanned releases may be reviewed in Inspection Report No. 70-0036/89003.
However, the final sample data was not compiled in time for presentation in the aforementioned report.
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On September 1 and 7, 1989, the NRC collected nineteen samples (16 soil, two sludge a.id one pond sediment sample) which were shared with the licensee.
NRC sample shares were submitted to the U.S. Department of Energy, Idaho Operations Office - Radiological and Environmental Sciences Laboratory (RESL) for radiological analyses.
RESL analyzed each semple for (Uranium-234/233; 238 and 235) uranium isotopic content.
The highest concentration of total uranium reported for any one soil sample collected at the Hematite site was 95.8 1 3.04 pCi/ gram.
The average concentration among 15 soil samples was about 20.4 pCi/ gram soil.
A soil sample collected at a nearby residence was reported to have a total uranium concentration of 2.2 1 0.2 pCi/ gram of soil.
The total uranium concentration in each of the two sludge samples and the pond sediment samples was also less than SpCi/ gram of soil.
Sample iesults were compared with data requirements that appear in the NRC's Branch Technical Position (BTP) for application by the Uranium Fuel Licensing Branch (federal Register /Vol. 46, No. 205/ friday, October 23, 1981) which sets criteria for the " Disposal or Onsite Storage of Uranium Wastes from Plant Operations."
In accordance with the BTP the inspectors concluded the following:
The average concentration of uranium (20 pCi/ gram) reported for the fifteen (15) soil samples collected on the licensee's property met the BTP requirement for the disposal of acceptably low conced rations of enriched uranium (30 pCi/ gram).
Contaminated soils meeting the 30 pCi/ gram guideline may be disposed of with no restrictions or burial method.
The highest concentration of uranium repv.-ted among the of f site sample, sludge and pond sediment samples is 2.2 1 0.2 pCi/ gram.
In terms of dose equivalent this is less than the radiation dose 9t delines recommended by the Environmental Protection Agency for protection against transmission elements present in the environment as a result of unplanned contamination.
Furthermore, the 2.2 pCi/ gram is not significantly different than uranium levels that naturally occur in Hematite soils.
10.
Confirmatory Measurements (Revitalization Program)
The licensee is in the process of constructing aoditional manuf acturing and warehouse space and a new utility area.
A major portion of the new manufacturing space (Building 255) will include two (2) new pellet production lines.
This construction (Phase 1) is nearly complete.
One of the pellet production lines has been installed and is undergoing start up tests.
The Phase 2 construction encloses the present utility and connects the Phase 1 construction with Building 240.
On August 10, 1989, at NRC's request ORAU conducted an independent radiological survey of the Phase 2 construction site.
According to the ORAU sample data ten (10) sample locations exceeded the 30 pCi/g guideline for total uranium.
Hence, the area does not comply with the 30 pCi/g BTP requirements.
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1 The licensee has attempted to remediate this area by ext.avating large quantities of contaminated soil. The excavated areas are still accessible and during this inspection the inspector collected six (6) samples in the areas where the licensee indicated that remediation was complete.
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confirmatory measurements indicate that the average concentration of uranium in the soil samples is below the 30 pCi/ gram guideline, the licensee's contractor will be permitted to pour a concrete walkaway.
A walkaway will enable the licensee to move personnel and services between i
Building 240 and the new pellet plant.
Subsequent evaluations must show j
whether remediation is complete, whether additional confirmation by ORAU is needed, whether a concrete seal should be poured in a manner as to e
prevent contamination from spreading from beneath Building 240 to the excavated area beneath the new building and/or whether the average contamination level is acceptably low and meets the 30 pCi/g guideline,
.When these concerns ~are resolved, Region III will recommend to NMSS that the surface area under Phase 2 construction is clear for inclusion in the licensees revitalization program.
11.
Emergency Preparedness (IP 88050)
P a.
Assessment i
The fire protection program of the facility was measured against the requirements of the recently published Branch Technical Position on fire protection, as well as prevalent industry standards, notably the National Fire Protection Association (NFPA) codes.
In performing the assessment, the inspector toured all the buildings and the adjacent outdoor storage, materials handling, and equipment areas which house or support licensed activities.
Documents were examined for the purpose of assessing the licensee's commitment to the fire protection program and actual performance of its procedures.
The assessment methods also included examination of randomly selected portable extinguishers, process equipment, process flow sheets, and past inspection reports of American Nuclear Insurers (ANI).
Facility employees and the Fire Chief of the Hematite Volunteer Fire Department were interviewed.
The details follow:
2 1.
The Buildings The manufacturing activities of the facility are located in five buildings - the Oxide Building, which includes the UFe receiving and vaporizing area; the new and the old pelletizing which also, Building 254 and 255 respectively; the Warehouse, buildings houses two ammonia dissociating units; and Building 240, which houses the incinerator and scrap recovery area, the quality control laboratory, the maintenance shop, change rooms and office areas.
When the new Building 253 is completed, all five buildings would be on a continuous built-up complex and sharing common barrier walls.
The steel structures of the buildings are separate and the floors, walls and roofs are of noncombustible construction.
The buildings are each 8
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served by an independent ventilation system.
By closing the
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doors, each building can be isolated, except that the Oxide Building and the adjoining Building 255 have open communication at the ground floor level, i
There is no automatic fire suppression system and no fire detectors in any of the buildings.
The U02 powder storage areas in the two pelletizer buildings are not isolated from the pelletizer, dewaxer, and sintering furnaces.
The inspector did not discern whether or not a probabilistic risk assessment of the powder storage / pellet processing area weighed the merits of water sprinklers for fire suppression versus moderation control for criticality concerns.
Nevertheless, automatic water sprinklers for fire suppression will not be used.
Under these circumstances, combustibles should be held to the absolute minimum in the area.
Wooden crates and cardboard boxes should L
be removed from open areas as soon as possible upon uncrating the contents.
Some such objects were found on one of the mezzanine floors of Building 255.
It is noted that offices and storage areas in Building 255 are enclosed in concrete enclosures, which provide reasonable resistance to propogation of fire originating within them.
2.
Process Fire Safety Process and equipment layouts, including flammable gas generation and control systems were exanined for fire hazards.
The ultra-violet flame supervision systems of the new Lindberg dewaxing furnaces and sintering furnaces in Building 254 were tested and found to be functioning.
The older furnaces in Building 255, however, do not have flame supervision devices.
The inspector expressed concern about the safety of operation of these furnaces in his discussions with the technical staff of the facility.
Absence of flame supervision means absence uf a safety feature, even if the hydrogen component of the cracked ammonia may continue to burn in its own flame upon loss of the natural gas-fired pilot flame.
A careful review of the issue is recommended.
3.
Fire Protection Systems The facility is protected by hand-held portable extinguishers and one heavier portable extinguisher on wheels.
The extinguishers are of appropriate type and capacity.
Documentation showing periodical hydrostatic testing of the extinguishers were reviewed.
Upon random examination of several extinguishers, however, it was found that the monthly inspection for October 1989, was missed in all of them.
A monthly inspection and sign-off on the hanging tag is required by NFPA 10, Standard for Portable Fire Extinguishers.
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7.- -o The facility has no installed fire water system.
It is dependent on the local Hematite Volunteer Fire Department for suppression of anything but small, incipient fires..The offsite c
fire department must carry the fire suppression water on board their pumper trucks.
Concern was expressed in this matter in discussions with the facility staff.
The facility has plans for constructing a 200,000 gallon surface reservoir and a dry L'
hydrant for the purpose of sprinkling down leaking ammonia from r
outdoor storage tanks in the event of an accident.
The hydrant must be operated by a pumper from the offsite fire department.
This arrangement could provide an augmented supply of water in 1
the event of a fire, but a single hydrant would still be inadequate to cover the entire facility.
ANI has suggested an underground fire main tapping on to the Hematite City water
.L system 3/4 of a mile away, and a requisite number of hydrants and hose cabinets.
Other solutions _are also possible.
A fire water system is desirable for use at this facility.
4.
Pre-fire Planning Emergency response planning documents were examined.
These include procedures to be followed in the event of a fire emergency.
Facility employees are to attempt suppression of small incipient fires only.
The Hematite Volunteer Fire Department is to be called in every instance.
The Festus, Missouri Fire Department, about six miles away, has also agreed to provide assistance.
The licensee's 17-member fire brigade holds at least one fire drill and one training session in a year.
The April, 1988, session consisted only of verbal instruction and viewing of a training film and the March, 1989,
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session of fire extinguisher training.
There were no tests administered to gauge the effectiveness of the instruction.
A much greater emphasis on hands-on fire fighting training with actual fires with different types of extinguishers is recommended.
If at all possible, joint fire drills with participation of the offsite fire department should be held.
The inspector visited the Hematite Volunteer Fire Superintendent and interviewed Mr. Robert Hipes, the Fire Chief.
Mr. Hipes had visited the facility in the past and appeared to be aware of the special restrictions of fighting a fire at the licensee's facility.
The Department possesses two pumper trucks and one water-tender, all maintained in good order.
5.
The South Vault Organic material, such as used HEPA filters and wood, are stored on the floor of this building along with containers of nitric acid.
This constitutes a fire hazard should the acid leak and come in contact with the organic materials.
The licensee should review this matter and consider building a containment dike for the storage of nitric acid.
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f 6.
Housekeeping Housekeeping is generally good.
The wooden crates and cardboard boxes mentioned in Section 11.(a) 1., should be removed from one of the pelletizing buildings.
b.
Microniser Operation The inspector observed an operator manually feeding a microniser in the Oxide Building with presumably scrap oxide powder through an opening in the hood.
At the same time the powder was belching out of another outlet of the equipment on to the floor of the hood.
There seemed to be at least a technical problem with the equipment or its method of operation, if not also a contamination problem.
However, a review of air sampling data for 1989 operations from the nearest area air monitor, disclosed that the uranium airborne concentration is significantly below the regulatory limit mentioned in 10 CFR 20.
This matter was discussed with the facility staff, c.
SUMMARY
The safety of operation of the older dewaxing and sintering furnaces should be reviewed.
(0 pen Item No. 70-0036/89004-02)
Portable fire extinguishers should be inspected monthly.
(0 pen Item No. 70-0036/89004-03)
A fire water system should be provided to upgrade the licensee's fire suppression systems.
(0 pen Item
-No. 70-0036/89004-04)
Training for the fire brigade members should be oriented towards hands-on fire fighting.
The effectiveness of the instruction should be tested.
(0 pen Item No. 70-0036/89004-05)
A dike to contain potential nitric acid leak in the South Vault is recommended.
(0 pen Item No. 70-0036/89004-06)
Housekeeping is generally good.
However, the licensee should promptly remove unneeded combustible objects from the manufacturing areas.
(0penItem No. 70-0036/89004-07)
The microniser equipment and operation should be reviewed for potential loss of containment of SNM material.
(0 pen Item No. 70-0036/89004-08) 11
N 12.
Exit Meeting The scope and findings of the inspection were discussed with the licensee representatives (Section 1) at the close of the onsite inspection on November 17, 1989.
The following items were discussed during the exit meeting.
The inspector indicated that staff additions to the licensee's Radiation Protection Program seemed adequate to cover the revitalization program (Section 4).
The licensee agreed to review / resolve the storage of miscellaneous items in the incineration process bin (Section 6),
The licensee concurred that the BTP guideline of 30 pCi/g must be o
met in order to complete Phase 2 construction (Section 10).
The licensee stated that a concrete seal may be needed to prevent contamination from under Building 240 seeping onto the new construction surface (Section 10).
The licensee acknowledged the concerns / findings discussed by the Fire Safety Specialist (Section 11).
During the course of the inspection and the exit meeting, the licensee did not identify any documents or inspector statements and references to specific process as proprietary.
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