ML20056F492
| ML20056F492 | |
| Person / Time | |
|---|---|
| Site: | 07000824 |
| Issue date: | 08/09/1993 |
| From: | Pharr W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20056F486 | List: |
| References | |
| 70-0824-93-02, 70-824-93-2, NUDOCS 9308270321 | |
| Download: ML20056F492 (13) | |
Text
-.
[$a med UNITED STATES
\\e NUCLEAR REGULATORY COMMISSION g
REGloN 11 y*
i
(
,E 101 MARIETTA STREET, N.W., sUlTE 2900 E
ATLANTA, GEORGI A 30323-0199
,[
9 ""**
AUS 10123 Report No.: 70-824/93-02 l
Licensee: Babcock and Wilcox Company Lynchburg Technology Center l
Lynchburg, VA 24505 Docket No.: 70-824 License No.: SNM-778 Facility Name: Lynchburg Technology Center Inspection Conducted: July 19 - uly 22, 1993 Inspector:
Mb PN roved by:'
/
App / f K H. Rankin, Chief Date Signed g
Facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch l
Division of Radiation Safety and Safeguards
SUMMARY
Scope:
i This routine, unannounced inspection was conducted in the area of occupational radiation safety and included an examination of: organization and management controls, audits and appraisals, training, external and internal exposure controls, operational and administrative controls, facility tours, and the program for Maintaining Exposures As low As Reasonably Achievable (ALARA).
l Results:
i Overall, the inspector found the licensee's program for providing radiation exposure control to be effectively implemented. No significant changes with the licensee's organization or staffing had taken place since the previous inspection. Monthly audits by the Health Physics (HP) Supervisor, Safety Audit Subcommittee (SAS) audits, and Safety Review Committee (SRC) meetings, were conducted as required by the license and procedural requirements. These self-assessment programs appeared to be beneficial in maintaining the effectiveness of the radiation protection (RP) program. No major changes were noted in the RP training programs, and training material appeared to be appropriate for the level of work performed by employees. No concerns were identified in the external and internal exposure control programs.
Both were appropriately implemented in accordance with license and procedural requirements. Radiation Work Permits (RWPs) and Area Operating Procedures (AOPs) were appropriate for work performed, with both implementing explicit HP 930B270321 930010 PDR ADOCK 07000824 PDR u
C
t i
- control s.
Additionally, ALARA awareness was incorporated into training, RWPs, t
.A0Ps, facility modifications, and reviewed during program audits. One discrepancy was identified in that three vacuum cleaners were not appropriately labeled as radicactive materials, as required by licensee procedure. Based on minimal safety significance and immediate corrective actions, this item was identified as a non-cited violation (NCV)
(Paragraph 8).
i l
L i
l l
l I
I
l REPORT DETAILS I
'1.
Persons Contacted Licensee Employees C. Boyd, Licensing and Compliance Officer
- D. Spangler, Health Physics Supervisor
- P. Rosenthal, Manager, Environment, Safety, and Health
- T. Whittaker, Health Physicist C. Yates, Health Physicist Other licensee employees contacted included engineers, technicians, and office personnel.
i
- Attended July 22, 1993 exit meeting l
2.
Organization and Management Controls (83822)
Figure 2-1 and Section 2.2 of the License Application detail the site i
organization, and position responsibilities and authorities.
During discussions with licensee representatives, the inspector was informed that no major revisions had been made to the organization and i
staffing levels of the Radiation Protection (RP) program since the l
previous inspection of this program area, conducted June 29, through July 2, 1992, and documented in Inspection Report (IR) 70-824/92-04.
i The inspector noted that a group of three Health Physicists, three health physics (HP) operations technicians, and an instrument and calibration technician reported to the HP Supervisor, who reported directly to the Environmental, Safety, & Health (ES&H) Hanager. The inspector did not identify any concerns with the organization and l
assigned responsibilities of the RP group.
l l
Based on discussions with licensee representatives and observation of activities during the inspection, the inspector noted that the HP staffing levels appeared adequate to support ongoing activities.
No violations or deviations were identified.
3.
Audits and Appraisals (83822) l Section 2.3.2.1 of the License Application requires the Safety Review Committee (SRC) to meet at least four times annually to review and approve new Area Operating Procedures (A0Ps) or revisions made to existing A0Ps, to review and approve new projects on major revisions to existing projects,'to review the HP Supervisor's annual report, to provide general consulting services, and to review Safety Audit Subcommittee (SAS) findings.
Section 2.3.3.2 of the License Application requires the SAS to audit facilities, procedures, records, and operations for compliance with written requirements.
l l
I l
l 2
l i
Section 2.8.3.1 of the License Application requires the SAS to perform at least three audits of general safety and compliance annually, i
distributed over a twelve month period. The SAS also is required to I
include audits of HP and industrial safety functions at least once annually.
l Section 2.8.2.1 of the License Application requires the HP Supervisor to conduct monthly audits in accordance with written procedures for the purpose of evaluating the health physics aspects of operations.
l The inspector reviewed SAS audits performed since the previous inspection, conducted June 29, through July 2, 1992, and documented in l
IR 70-824/92-04. The inspector noted that in accordance with license application requirements, the SAS performed three audits during 1992 and had performed one, to date, during 1993. During review of the audits, the inspector noted that records and documentation of activities, as well as, work in progress were reviewed during the auditing process.
The inspector noted that identified issues were tracked until satisfactory corrective actions were implemented.
The inspector also reviewed audits performed by the HP Supervisor. The inspector noted that these audits were performed and documented each month, as required by the license application. The inspector noted that i
the audits appeared to be thorough in their review of areas for licensed l
material use and storage, posting and labeling in those areas, housekeeping, ALARA practices, equipment operability, radioactive material shipments and followup documentation, and facility work orders.
The inspector also noted that issues identified during these audits, were usually promptly corrected. However, if more extensive corrective l
action was required the issue and its status was tracked each following i
month, until its closure. Additionally, the inspector reviewed the 1992 HP Annual Report, as performed by the HP Supervisor. The inspector noted that the report trended the year's exposure and monitoring data, I
and recognized and provided explanation for maximum or outlying data.
In addition, the inspector reviewed meeting minutes from SRC meetings conducted during 1992 and to date in 1993. The inspector noted that the SRC met at least four times during 1992, as required, and had met twice during 1993. The inspector also noted that as required by the license l
application the SRC discussed new and approved A0Ps, as appropriate, revised A0Ps, facility projects, and SAS audit findings. The inspector also noted that the 1992 and 1993, SRC meeting minutes reviewed ongoing efforts to determine causal factors and to implement corrective actions for August 1992 problems associated with receipt and testing of irradiated fuel rods with cladding failure, including failure of the hot cell crane. Although no violations of regulatory requirements were l
identified with the issue or the licensee's actions in response, the inspector did discuss with licensee representatives the excessive delays 1
associated with identification of causal factors and implementation of corrective actions.
Licensee representatives acknowledged the inspector's comments regarding the increasing lack if effectiveness of determining root cause and implementing appropriate corrective actions i
3 when excessive delays prevent prompt followup. At the time of the inspection, the inspector was informed that the licensee had implemented procedural revisions and equipment upgrades to prevent recurrence, and were in the process of developing a procedure to outline a program for prompt followup and resolution of incidents.
The inspector informed licensee representatives that their auditing and self-assessment programs appeared to be beneficial in maintaining the overall effectiveness of the RP program.
i No violations or deviations were identified.
j l
l 4.
Training (83822) l 10 CFR 19.12 requires the licensee to instruct all individuals working l
in or frequenting any portions of the restricted areas in the health protection aspects associated with exposure to radioactive material or radiation, in precautions or procedures to minimize exposure, and in the purpose and function of protection devices employed, applicable provisions of the Commission regulations, individuals responsibilities, and the availability of radiation exposure data.
The inspector reviewed and discussed with licensee representatives their program for providing RP training to plant employees. The inspector was informed that no significant changes had taken place in the training program since the previous inspection, conducted June 29, through July 2, 1992. The ' spector noted that the licensee continued to provide three levels of training, commensurate with the individual's assigned responsibilities.
The inspector also noted that the licensee allowed J
Level 2 and 3 workers, with two previous years of training, a training exemption following successful completion of a bypass examination. The i
inspector was informed that the licensee was preparing to present a worker indoctrination of 10 CFR Part 20 revisions and the major effects those revisions would have on facility operations. The inspector was also informed that during recent RP training sessions the workers were provided a brief overview of the Part 20 revisions, mainly to introduce changes in terminology.
l The inspector reviewed training records for selected licensee employees l
performing work activities involving the use or handling of radioactive materials, and noted that they had been provided the appropriate level of RP training. For those records reviewed all RP training was current, to include successful completion of the examination. The inspector also reviewed training provided to the health physics group and noted that in i
addition to required RP training, the group routinely participated in training of procedural revisions or technical issues.
I
=
i
)
[
4 i
l 5
i The inspector informed licensee representatives that the RP training program continued to successfully provide training to facility workers,
)
and appeared to be appropriate for the level of work performed by the workers.
l i
No violations or deviations were identified.
i 5.
External Exposure Control (83822)
J r
j 10 CFR 20.101(a) requires that no licensee possess, use or transfer licensed material in such a manner as to cause any individual in a j
restricted area to receive in any period of one calendar quarter a total i
occupational dose in excess of 1.25 rem to the whole body, head and j
trunk, active blood forming organs, lens of the eyes, or gonads; 7.5 rem 1
to the skin of the whole body; and 18.75 rem to the hands and forearms, j
feet and ankles.
l 10 CFR 20.101(b)(3) requires the licensee to determine an individual's j
accumulated occupational dose to the whole body on a-Form NRC-4 or l
j equivalent record prior to permitting the individual to exceed the j
limits of 10 CFR 20.101(a).
1 1
10 CFR 20.401(a) requires each. licensee to maintain records in accordance with the instructions contained in Form NRC-5, showing the radiation exposures of all individuals for whom personnel monitoring is required under 10 CFR 20.202(a). The doses entered on the form are to l
)
be for periods of time not exceeding one calendar quarter.
1 i
The inspector.was informed that the licensee had recently implemented a i
change in their dosimetry program, in that following completion of the i
first quarter of 1993 the licensee began using thermoluminescent J
i -
dosimetry (TLDs) for monitoring their workers' occupational exposures.
j Prior to this program change, licensee workers who worked with or j
handled radioactive materials utilized film badges, TLDs, and pocket-i dosimeters, with the film badge dose being the worker's dose of record.
At the time of the onsite inspection, workers working with or handling radioactive materials utilized TLD badges which were read monthly,- while workers which were not allowed to work unsupervised with radioactive materials utilized TLD badges which were read on a quarterly basis. The inspector was further informed that those workers whose TLDs were read l
monthly were also issued pocket dosimeters to allow for daily tracking i
of their radiation exposure. The inspector was further % formed that, mainly due to economic considerations, the licensee was issuing film badges for monitoring exposure to visitors.
i The inspector reviewed and discussed external exposure records during j
the period from January 1, 1992 to May 31, 1993. During review of the HP Supervisor's 1992 annual report, the inspector noted that the licensee issued dosimetry to 320 individuals, with only 133 receiving j
measurable exposure. The inspector noted that the majority of.those individuals received doses of less than 100 millirem (mrem), and.six i
individuals exceeded a dose of 1000 mrem for the year. The inspector i
3
5
~
noted that the maximum whole body, and skin, dose for 1992 was 2270 mrem, and the maximum annual extremity dose was 9300 mrem. The inspector was informed that the individuals to whom these maximum expcsures were assigned were routinely associated with hot cell work and handling of highly radioactive Reactor Vessel Surveillance Program (RVSP) specimens.
lhe inspector also raviewed 1993 exposure data for selected facility personnel, and noted that the maximum quarterly doses were 440 mrem tc both the whole body and the skin of the whole body, and 1220 mrem to the extremity. Again, the inspector noted that these maximum doses were assigned to personnel which were involved in work associated with various activities in the hot cell and with RVSP specimens. The inspector also noted a Form NRC-4 cnd a Form NRC-5, with monthly updates, on file for all selected individuals.
The inspector also reviewed personnel contamination events during the period from January 1, 1992 to June 30, 1993. The inspector noted that during the period the licensee documented 13 skin contaminations and 17 clothing contaminations.
.ne inspector discussed with licensee representatives that although the number of contamination events was maintained relatively low, practically all the documented clothing contaminations were on modesty garments. Following discussions with licensee representatives the inspector was informed that the cause appeared to be poor work practices, and efforts were ongoing to heighten worker awareness. The inspector also noted that in accordance with procedural requirements the licensee appropriately initiated dose assessments and updated exposure records when initially calculated skin doses, based on stay times, contamination levels, and correction factors nxceeded 100 mrem. The inspector reviewed two contamination events =w.ch occurred on May 17, 1993, in which calculated skin doses were 350 mrem and 140 mrem. The inspector noted that since the two incidents involved calculated skin doses which exceeded 100 mrem, the licensee had appropriately initiated skin dose assessments. However, the inspector noted that at the time of the onsitt inspection, the licensee had not yet completed their assessments, and thus had not yet l
assigned the individuals a skin dose due to the contamination events.
Although the licensee discussed the conservatism incorporated into their calculations and the anticipated minimal exposures due to the contaminations, the inspector discussed the importance of prompt assessments so as to assure that skin doses were assigned for the quarter in which the event occurred.
The inspector had no further concerns regarding this issue.
The inspector determined that the licensee was appropriately monitoring and assessing external exposures, and the use of multibadging and exposure extensions were used as appropriate and in accordance with procedural requirements. The inspector concluded that the licensee was adequately maintaining external exposures within 10 CFR Part 20 limits.
No violations or deviations were identified.
r I
i
6 6.
Internal Exposure Control (83822) 10 CFR 20.103(a)(1) states that no licensee shall possess, use, or transfer licensed material in such a manner as to permit any individual in a restricted area to inhale a quantity of radioactive material in any period of one calendar quarter greater than the quantity which would i
result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at uniform i
concentrations of radioactive material in air specified in Appendix B, Table 1, Column 1.
10 CFR 20.103(a)(3) requires for purposes of determining compliance with the requirements of this section, the licensee to use suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas and in addition, as appropriate, to use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for the timely detection and assessment of individual intakes of radioactivity by exposed individuals.
1 Lynchburg Technology Center Technical Procedure, LTC-TP-247, Implementation and Quality Assurance of the LTC Bioassay Program, Revision (Rev.) 2, dated June 29, 1992, establishes which personnel shall participate in the bioassay program, the frequency and type of bioassay, action levels, and documentation requirements.
During discussions with licensee representatives the inspector was i
l informed that since the. previous inspection conducted June 29, to July 2,1992 and documented in IR 70-824/92-04, the licensee had implemented a change in their bioassay program, as approved in their recent License renewal. This approved change revised the minimum action limit for invivo counting from 30 micrograms (ug) of uranium-235 (U-235) to an individual-based minimum detectable limit (MDL).
The inspector reviewed July 1, 1992 to June 30, 1993 exposure records for selected individuals assigned to the Cask Handliag Area (CHA), who were included in the routine Mixed Fission Products (MFP) bioassay program; and the Ceramics Forming Lab, who were included in the routine uranium bicassay program. The inspector verified that the individuals l
were being included in the appropriate bioassay program, were prescribing to the aroropriate counting frequency, and that all bioassay
[
results were less than the licensee's action limits. The inspector also reviewed area air sample data and individual lapel sampler data and determined that the licensee was appropriately performing Maximum Permissible Concentration (MPC) calculations, evaluating workers' exposure to airborne materials, and assigning appropriate internal exposures based on lapel sampler results.
10 CFR 20.103(c)(2) permits the licensee to maintain and to implement a respiratory protection program that includes, at a minimum: air sampling to identify the hazard; surveys and bioassays to evaluate the actual exposures; written procedures to select, fit and maintain respirators; i
f
4
~
7 written procedures.regarding the supervision and training of personnel and issuance of records; and determination by a physician prior to the use of respirators, that the individual is physically able to use respiratory protective equipment.
The inspector also reviewed selected individual records and verified that training, including written examinations, fit-tests, and medical i
qualifications were current as required by the applicable procedures.
The inspector determined that the licensee monitored internal doses adequately and all were within 10 CFR Part 20 limits.
No violations or deviations were identified.
l I
7.
Operational and Administrative Radiological Controls (83822) a.
Sealed Sources LTC-TP-241, Leak Testing of Radioactive Sealed Sources, Rev. 3, dated August 24, 1992, requires that sealed sources containing licensed material with a half-life greater than 30 days, excluding l
exempt material, will be tested for leakage at intervals not I
exceeding six months. Any results greater than 0.005 microcuries (uCi) or more of removable contamination should be reported. The procedure also provides an equation for verification that, based on the count time, efficiency, and background, the counter's lower limit of detection (LLD) is appropriate for detecting the required 0.005 uCi of removable contamination.
J The inspector reviewed and discussed with licensee personnel 1992 and 1993, to date, methodology and records for semiannual sealed
)
source leak tests. The inspector noted that the licensee was appropriately verifying, prior to each test, that the counter's LLD was adequate for detecting the required minimum contamination levels of 0.005 uCi. The inspector verified that sealed sources kept onsite were leak tested as prescribed by procedure. The inspector also noted that for those records reviewed all results were recorded appropriately, with no high test results identified.
No violations or deviations were identified, b.
Area Operating Procedures (A0Ps) and Radiation Work Permits (RWPs) l The inspector reviewed selected A0Ps associated with routine work activities in the CHA and the hot cells and RWPs associated with activities related to a recent hot cell outage, to activities related to the receipt and testing of irradiated fuel rods with cladding failure, and to activities related to fuel can transfers between the CHA storage tubes and the hot cells. The inspector
~
noted that both A0Ps and RWPs appeared appropriate for controlling the work performed. Both established appropriate protective clothing, dosimetry, respiratory protection, and HP survey and job i
I 8
coverage requirements. The inspector also noted that both the A0Ps and RWPs discussed explicit HP controls, such as pre-job briefings, mock-up training sessions, engineering and contamination controls, beta dose protection, and communications, i
to further maintain exposures ALARA. The inspector further noted
{
that ALARA evaluations were appropriately performed for RWPs based i
on the anticipated exposures.
No violations or deviations were identified.
c.
Termination Reports l
10 CFR 19.13(c) states that at the request of a worker formally t
engaged in licensed activities controlled by the licensee, each licensee shall furnish to the worker, within 30 days from the time the request is made or 30 days after the exposure to the individual has been determined by the licensee, whichever is later, a report of the worker's exposure to radiation or radioactive material.
During discussions with licensee representatives and review of l
termination report implementation, the inspector noted that since
~
the licensee did not meet the operating facility criteria specified in 10 CFR 20.408(a), they were not required, in accordance with 10 CFR 20.408(b), to issue termination reports to the Commission nor the individual upon the worker's termination of licensed activities. The inspector noted that the licensee's implementing procedure for issuance of termination reports appropriately incorporated these regulatory requirements.
The inspector noted that for selected individuals reviewed, the licensee did however attempt to issue termination letters to both the individual and the NRC following their termination. The inspector verified that following a worker's request for exposure history the licensee was appropriately issuing such reports to the individual in accordance with regulatory and procedural requirements. The inspector informed licensee representatives i
that their implementing procedure and subsegeint implementation of l
their program for providing workers with their required exposure history was appropriate.
No violations or deviations were identified.
d.
Notice to Employees 10 CFR 19.11(a) and (b) require, in part, that the licensee post current copies of Part 19, Part 20, the license, license conditions, documents incorporated into the license, license amendments and operating procedures, or that a licensee post a notice describing these documents and where they may be examined.
l l
l t
i 9
10 CFR 19.11(d) requires that a licensee post Form NRC-3 " Notice l
4 to Employees". Sufficient copies of the required forms are to be posted to permit licensee workers to observe them on the way to or i
from licensed activity locations.
j During tours of the facility buildings, the inspector verified that Form NRC-3 and notices referencing the appropriate 10 CFR j
Part 19 and Part 20 and licensee documents were posted in accordance with the applicable regulation.
Forms were posted in i
adequate locations to be viewed by personnel on their way to or from licensed activities.
1 No violations or deviations were identified.
8.
Facility Tours (83822) 10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as may be necessary for the licensee to comply with the i
reculations in 10 CFR Part 20 and are reasonable under the circumstances 4
to evaluate the extent of radioactive hazards that may be present.
10 CFR 20.203 specifies the posting, labeling and control requirements i
for radiation areas, high radiation areas, airborne radioactivity areas, i
j and radioactive material.
4 Safety Condition, S-1, of license SNM-778, requires that licensed material be used in accordance with the statements, representations, and conditions of Chapters 1 through 8 of the License Application dated November 26, 1985, and supplements thereto.
i Area Operating Procedure, B-GP-6, Labeling of Radioactive Materials, Rev. 3, dated May 25, 1990, requires that radioactive materials, defined as quantities greater than those listed in 10 CFR Part 20, Appendix C, q
which are to be stored be conspicuously labeled as " Radioactive
~
Material".
During facility tours the inspector independently verified postings, labelings, and radiation and contamination levels in the CHA, the Failure Analysis Lab, the RVSP Lab, Building J, and outside radwaste l
storage areas. The inspector verified that area surveys were performed 4
at the appropriate frequency and that survey results were below those action limits as specified by the applicable procedures. The inspector determined the postings and labelings to be consistent and appropriate for informing workers of the radiological hazards in the area with the exception of three vacuum cleaners, of which one was located in the CHA, one in the Failure Analysis Lab, and another in the Reactor Vessel Surveillance Program (RVSP) Lab. The inspector surveyed each vacuum cleaner and noted that survey results indicated a maximum contact dose rate of 8 mrem per hour (mrem /hr) and maximum removable contamination levels of approximately),2000 disintegrations per minute per 100 square 2
centimeters (dpm/100cm beta / gamma, and 30 dpm/100cm, alpha. The
i i
I i
i
~
10 inspector informed licensee representatives that their failure to properly label 3 vacuum cleaners, which contained radioactive material in excess of procedural established limits was a violation of Safety Condition, S-1.
The licensee promptly corrected the identified deficiency by placing radioactive materials labels on each vacuum cleaner. The inspector informed licensee representatives that based on minimal safety significance and prompt corrective actions, this NRC-identified violation for failure to properly label radioactive material containers would not be cited because the criteria specified in Section VII.B of the NRC Enforcement Policy were met (70-824/93-02-01).
The inspector also observed various survey meters and continuous air monitors in use within the controlled area which were calibrated, operable, and source checked in accordance with licensee procedures.
l The inspector further verified that, in accordance eith procedural and license application requirements, the licensee was performing daily source checks, weekly background checks, and annual calibrations of the Tennelec gas flow proportional counter, and monthly checks to verify air flow direction from areas of lesser potential to higher potential for airborne radioactivity, and monthly verifications of air velocity of at least 100 cubic feet per minute (cfm) for fume hoods.
One NRC-identified non-cited violation (NCV) was identified for the licensee's failure to properly label three vacuum cleaners containing radioactive material in excess of 10 CFR Part 20, Appendix C, limits, as required by procedure.
9.
Program for Maintaining Exposures As Low As Reasonably Achievable (ALARA) (83822) 10 CFR 20.l(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain l
radiation exposures ALARA.
The inspector noted that the licensee had recently developed a facility ALARA policy and it appropriately provided guidance to assure implementation of a strong ALARA program at the facility. The inspector noted that the policy indicated management's commitment to maintaining occupational exposures at the facility ALARA. The inspector further l
noted that the licensee reviewed their highest exposure projects during l
1992 and were incorporating lessons learned into ongoing projects. The inspector noted that A0Ps and RWPs incorporated explicit HP controls so as to maintain exposures ALARA. The inspector also noted that the licensee's auditing programs frequently reviewed RWPs, facility operations, and facility modifications to ensure that ALARA practices were utilized to reduce facility exposures.
No violations or deviations were identified.
l
I l
I 11 10.
Exit Meeting The inspector met with licensee representatives indicated in Paragraph 1 l
at the conclusion of the inspection on July 22, 1993. The inspector summarized the scope and findings of the inspection: including the NCV.
i l
The inspector also. discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the t
inspector during the inspection. The licensee did not identify any such documents or processes as proprietary. Dissenting comments were not received from the licensee.
Item Number Description-70-824/93-02-01 NCV: Failure to properly label radioactive materials as required by procedure (Paragraph 8). NRC-identified NCV of Safety Condition, S-1.
l l
l l
I l
!