ML20133C523
| ML20133C523 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 01/02/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20133C483 | List: |
| References | |
| 50-155-96-11, NUDOCS 9701070209 | |
| Download: ML20133C523 (9) | |
See also: IR 05000155/1996011
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION lli
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Docket No:
50-155
License No:
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Report No:
50-155/96011(DRS)
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Licensee:
Consumers Power Company
Facility:
Big Rock Point Nuclear Plant
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Location:
10269 U.S. 31 North
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Charlevoix, MI 49720
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Dates:
December 2-6,1996
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Inspectors:
N. Shah, Radiation Specialist
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Approved by:
T. Kozak, Chief, Plant Support Branch 2
Division of Reactor Safety
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9701070209 970102
ADOCK 05000155
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Reoort Details
R1
Radiological Protection and Chemistry (RP&C) Controls
R 1.1 Solid Radioactive Waste (Radwaste) ar.d Transoortation Proarams
a.
Insoection Scone (86750,2515/133)
The inspectors reviewed the licensee's solid radioactive waste and transportation
programs as described in the Final Safety Analysis Report (FSAR) and Process
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Control Program (PCP). Annual individual dose totals received by the radwaste
workers from activities conducted through December 1996 were also reviewed.
b.
Observation and Findinas
As described in the PCP, generated radwaste inc!uded dry active waste (DAWl,
spent resins, and filters. The licensee dewatered resin and filters onsite and sent
DAW to an offsite contractor for processing (compaction /supercompaction and
incineration). Waste not immediately sent to burial was stored in the radwaste
storage building (RWSB), which remained as described in NRC Inspection Report
(IR) Nos. 50-155/92011 and 50-155/93026. The inspector reviewed the results of
routine, quarterly inventories of items stored in the RWSB; no problemr.
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identified.
The inspector verified that the vendor system used for resin dewatering was
operated in accordance with an NRC approved topical report and that required
maintenance and functional tests were performed in accordance with vendor
procedures. Additionally, selected system performance criteria were reviewed to
verify that the processed radwaste met 10 CFR Part 61 requirements for waste
stability.
Scaling facto": for 10 CFR Part 61 waste characteriza cn analyses were generated
based on rcutme sampling of DAW, resin and filter waste streams. These samples
were sent to an offsite vendor for analysis and the results of the analysis were
reviewed by the Palisades Nuclear Plant health physics staff Based on that review,
the Palisades staff then generated scaling factors for use in Big Rock Point waste
characterizations. The inspector reviewed the past and current scaling factors used
by the licensee; no problems were identified.
Since burial site access was reinstated in mid 1995, the licensee shipped about
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1500 ft of resin / filters and 6500 ft of DAW for burial. This included the majority
of the waste stored in the RWSB, although there still remained an inventory of
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1340 ft of resin / filters and 1600 ft of DAW. Licensee personnel were trainea in
the revised Department of Transportation (DOT) regulations and, during interviews,
demonstrated knowledge of these requirements. Additionally, the licensee complied
with GL 95-09 (and associated supplements). The licensee classified waste
shipments using a vendor software program, which the inspector verified was
updated to include the revised DOT requirements. The inspector selectively
reviewed shipment records and verified that they were consistent with the
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regulations, that radwaste was properly classified and that the shipment departure
and receipt times were appropriately logged.
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However, the inspector identified several problems with the technical oversight of
the radioactive waste program. Specifically, interviews revealed that neither the
current nor the former radwaste shipping supervisor recognized the purpose or
requirements of the PCP, the licensee's shipping staff was not aware of the review
criteria used by the Palisades health physics staff to generate the scaling factors,
and numerous examples were identified in the above shipping procedures where
either the incorrect or nonexistent regulatory requirements were referenced.
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The inspector noted that these weaknesses were being compensated for by the
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experience level of the staff and, through discussions with the licensee, were
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caused by poor communication of program requirements by RP management to the
implementing staff. The licensee planr.ed to provide training to the staff regarding
program requirements and to revise the affected procedures.
Through December 1996, the average annual individual dose for radwaste workers
ranged from 1.8-1.9 rem compared to the licensee's administrative limit of 2 rem.
This was somewhat higher than past totals and was attributed to the onset of
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shipping activities and the cleanup of the resin tank room (see IR No. 50-
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155/96006). Contributing causes included: reduced use of contract workers for
radwaste activities; informal radwasta shipping plan for 1996; and less than
anticipated oversight by the station ALARA coordinator owing to other emergent
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work. Licensee plans to lower 1997 dose included the development of a formal
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shipping plan for 1997 (including consideration of ALARA actions for high dose
shipments) and increased oversight by the station ALARA coordinator.
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c.
Conclusions
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The licensee's radwaste and processing program was maintained consistent with
regulatory requirements, but the technical oversight of the program was in need of
improvement.
R1.2 Audits and Followuo of Events
a.
Insoection Scooe (IPs 83750. 84750 and 86750)
The inspector reviewed nuclear plant assurance department (NPAD) audit PA-96-10
(dated April 22-May 16,1996) of the effluent and solid radioactive waste and
transportation programs, associated field monitoring reports (FMRs) and radiation
protection (RP) internal self-assessments of the shipping program (dated January 23
and February 16,1996). This review also focused on identified trends based on
findings documented in condition reports (CRs) Nos.96-574, 96-942 and 96-782.
b.
Observations and Findinas
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The NPAD audit and RP self-assessments were technically sound and of good
quality. Through interviews, the inspector verified that the auditors were
knowledgeable of solid radwaste processing and shipping requirements. In
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particular, the inspector noted that the use of previous or current RP personnel to
assist the NPAD group rcsulted in a good technical review. Through a review of
FMRs, CRs and interviews with RP and NPAD representatives, the inspectors
verified that corrective actions for the radwaste audit findings were timely and
thorough. However, the NPAD group had not identified those weaknesses
discussed in sections R1.1 and R2.1. This was discussed with the NPAD group,
who will review the inspector's findings against the NPAD audit criteria.
One notable audit finding concerned the timely updating of radiological survey
status sheets and RP logbook entries by radiation protection technicians (RPTs).
The RPTs were performing required radiological surveys, but were not always
documenting survey results or area posting changes in the RP logbook. However,
the audit did not identify problems where this had resu!ted in workers not being
aware of area radiological conditions. Although this was considered a management
expectation, it was not clearly required by station procedures and was not well
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understood by the RPTs. Because these weaknesses had existed for several years,
the RPTs had become complacent with the misunderstood requirements. A task
group (comprised of RP management and RPT representatives) was formed to
develop corrective actions. These actions included revising applicable plant
procedures and providing remedial training to the RPTs regarding management
expectations for documentation of survey results. The licensee planned to review
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the effectiveness of these actions in a subsequent, routine NPAD audit.
A review of the above CRs identified problems in worker performance and work
planning which were similar to those documented in NRC IR No. 50-155/95010.
Some examples included poor worker self-checking during resin dewatering
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activities resulting in several workers being sprayed with contaminated water,
operator failure to verify a valve lineup resulting in an inadvertent transfer of water
to the No.1 Dirty Waste Receiving Tank from the Chemical Waste Tank, and poor
work planning resulting in the inadvertent siphoning of about 1000 gallons of water
from the Radwaste Concentrator Tank to the Spent Resin Tank room floor. These
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events indicated that worker performance and planning problems continued to exist
at the plant.
c.
farldusions
The licensee audits of the solid radwaste and shipping program were generally
effective. A review of CRs indicated continuing problems with worker performance
and work planning, concerning radwaste processing activities, since 1995.
R2
Status of RP&C Facilities and Equipment
R 2.1
Solid Radwaste Processino Systems
a.
Insoection Scooe (86750)
An inspection of the solid radwaste processing and storage areas and plant
radiological controlled areas was performed.
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b.
Observations and Findinas
Although the inspector observed good radiological controls in the majority of the
areas inspected, several examples of poor radiological surveys and postings in the
radwaste processing and storage areas were observed. Specifically:
Big Rock Point Procedure No. RP-30, " Establishing Area Postings" (Rev. No.
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12), Step 5.3.2 required that high radiation areas be conspicuously posted
with a standard magenta radiation symbol on a yellow background with the
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words " CAUTION, HIGH RADIATION AREA," and Step 5.7.2 required that
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areas having contamination in excess of 1,000 disintegrations per minute per
100 square centimeters of activity (beta / gamma) be conspicuously posted
with a standard magenta radiation symbol on a yellow background with the
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words " CAUTION, CONTAMINATED AREA."
However, the inspector identified that high radiation area and contaminated
area postings in the resin dewatering area of the resin shed had fallen. The
most recent survey of this area (dated October 10,1996) indicated one
location with dose rates of 100 mrem /hr (at 30 cm) and average
contamination levels of 30,000 dpm/100 cm . The licensee indicated that
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the radiological conditions were unchanged since the last survey and did not
identify any personnel who had inadvertently entered the area.
Big Rock Point Administrative Procedure No. 5.11, " Radioactive Material
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Control" (Rev. No.13), Step 5.4.3.1 required that all containers of
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radioactive material be labeled with a visible label bearing the radiation
symbol and the words " CAUTION, RADIOACTIVE MATERIAL." The label
and container shall provide sufficient information to permit individuals
handling, using, or working near the containers to take precautions to
minimize exposure.
However, the inspector identified that 6 of the 16 DAW boxes stored in the
RWSB were incorrectly labeled as having dose rates of less than 5 millirem
per hour (mrem /hr) on contact. Big Rock Point Administrative Procedure No.
5.11, " Radioactive Material Control" (Rev. No.13), Step 5.4.3.1 required
that all containers of radioactive material be labeled with a visible label
bearing the radiation symbol and the words " CAUTION, RADIOACTIVE
MATERIAL." The label and container shall provide sufficient information to
permit individuals handling, using, or working near the containers to take
precautions to minimize exposure.
The inspector measured contact dose rates aetween 20-40 mrem /hr on 4 of the
boxes and between 100-120 mrem /hr on 2 of the boxes. These measurements
were subsequently verified by the licensee. Based on discussions with the licensee,
the incorrect labels may have been in place for several years.
The above problems were considered a violation of Technical Specification (TS)
No. 6.11 which required adherence to RP procedures (VIO 50-155/960:1-
01(DRS)). The licensee indicated that the poor labeling of the DAW boxes resulted
from complacency among the RP staff regarding acceptance of these conditions
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and weaknesses in the radiological survey program. In particular, the DAW boxes
were last surveyed by an RPT (several years ago) who was since terminated for
poor performance. Although no prior, similar problems were identified, the radiation
protection manager indicated that surveys performed by this individual would be
verified as accurate. Subsequent routine monthly radiological surveys of the
RWSB, by other RPTs, failed to identify the discrepancies. Other planned corrective
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actions included revising applicable station procedures to verify labeled information
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with actual readings and providing training on these requirements to the RPTs.
c.
Conclusions
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One violation was identified for failure to follow station procedures regarding
radiological posting and surveys in radwaste processing and storage areas.
R2.2 Documentation of Past Radioloaical Events Per 10 CFR oart 50.75(a)
a.
Insoection Scoce (84750)
The inspector reviewed the licensee's documentation of spills or other similar
events involving the spread of contamination in or around the facility as required by
b.
Observations and Findinos
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The licensee has two areas that were approved under 10 CFR Part 20.302
requirements. These areas include a location on the beach northeast of the plant
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(approved for dredging, but not in use) and one in the general area of the
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condensate tank extending beneath the turbine building floor (stillin use owing to
subsequent leakage). The inspector verified that the licensee maintained
appropriate documentation of these areas and were meeting the record keeping
requirements discussed in NRC Information Notice No. 96-47.
As part of the Decommissioning Plan development, the licensee identified six -
events that required documentation per 10 CFR Part 50.75(g). Briefly, these
events were:
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On November 20,1980, about 10 ft of contaminated resin was spilled on
the pipe tunnel floor. The contaminated material was removed and disposed
as radioactive waste. At the time of disposal, residual contamination in the
area was about 8E-5 uCi/gm.
On September 8,1981, during construction of the RWSB, construction
residue having low levels of contamination was disposed as radwaste. The
affected areas were decontaminated to below environmental lower limit of
detection (LLD) levels.
On May 30,1984, the licensee identified leakage from an underground line
carrying makeup water from the condensate storage tank. Although the
majority of the affected soil (having low levels of tritium and iodine-131
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contamination) was disposed of as radwaste, about 37 uCi of activity was
retained in the area under 10 CFR Part 20.302.
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On February 13,1987, water leaking from the #1 Waste Hold Tank resulted
in low levels of contamination in the ground underneath the tank. The
ground was decontaminated to levels below environmental LLDs and the
affected soil was disposed as radwaste.
On November 27,1993, leakage from an above ground demineralizer fillline
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to the condensate storage tank resulted in low levels of contamination in the
soil below the line. The affected soil was removed and disposed as
radwaste. The remaining soil had activity below the environmental LLDs.
The inspector verified that the licensee had maintained the information documenting
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these events (including disposal records and isotopic sampling and analysis results)
per the requirements of 10 CFR Part 50.75(g).
R.8
Miscellaneous RP&C issues
R8.1
(Closed) Review of Unresolved Item (URI) No. 50-155/96008-04
The inspector reviewed the licensee's corrective actions for the above URI,
concerning the failure to perform an adequate radiological survey which did not
identify contamination prior to the free release of a truck from the RWSB. The
event occurred in October 1996, and was also documented in licensee CR No. 96-
885. The truck was subsequently decontaminated and the bedliner removed.
Based on isotopic analysis of activity found on the truck bed, the licensee
concluded that the contamination came from a bagged, contaminated hose which
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the truck was carrying on October 3,1996. Corrective actions included discussing
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the event and the radiological survey requirements with the radwaste handlers and
RP, chemistry and dosimetry technicians involved in radwaste activities.
Although this event was identified by the licensee, the inspector noted that the
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contamination levels on the truck (20,000 dpm/100 cm ) were readily detectible
had a reasonable survey been performed. The inspector also identified that a
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similar concern, regarding a free release survey for a " boom truck," was
documented in FMR No. FM-B-96-125 (dated 5/23/96), for which corrective actions
were apparently not effective. Therefore, the October event was considered
another example of non-compliance with TS 6.11, for failure to follow the
Station Procedure No. RM-56 " Radiological Clearance For Offsite Removal of
Material" which required that all material having clean status shall have no activity
detected either by direct frisk or shall successfully pass through contamination
monitors (see Section R2.1) (VIO 50-155/96011-01).
X.1
Exit Meeting Summary
The inspector presented the inspection results to members of the licensee
management at the conclusion of the inspection on December 6,1996. The
licensee acknowledged the findings presented and did not identify any of the
documents reviewed as proprietary.
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PARTIAL LIST OF PERSONS CONTACTED
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Licensee
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P. M. Donnelly, Plant Manager
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R. Addy, Assistant Plant Manager
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W. Barnshaw, Lead Resident Assessor, NPAD
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E. A. Bogue, Training Manager
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M. Bourassa, Licensing Supervisor
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L. Darrah, Operations Supervisor
D. D. Hice, Maintenance Manager
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. W. Hoaglund, Radioactive Waste Shipping Supervisor
T. Mosley, Senior Engineer--Chemistry and Health Physics
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K. E. Pallagi, Chemistry and Health Physics Manager
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J. Tilton, Electrical and Instrumentation Engineering Supervisor
D. Turner, Decommissioning Team Leadei
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J. Werner, NPAD Assessor
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- G. C. Withrow, Plant Safety and Licensirig Director
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R. Leemon, Big Rock Point Senior Resident inspector
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C. Brown, Big Rock Point Resident inspector
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INSPECTION PROCEDURES USED
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Radiation Protection Program
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lP 86750
Solid Radioactive Waua and Transportation
Tl 2515/133 Implementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71
ITEMS OPENED, CLOSED AND DISCUSSED
Opened
Violation No. 50-155/96011-01
Failure to Adequately Post and Survey
Radiological Areas
Closed
Unresolved item No. 50-155/96008-04 Failure to Adequately Survey a Truck Prior to
Free Release (Closed as Violation No. 50-
155/96011-01 above).
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PARTIAL LISTING OF DOCUMENTS REVIEWED
Process Control Program for Solid Radioactive Waste (dated 1/22/96)
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NRC Generic Letter 95-09 (and associated Supplements) " Monitoring and Training of
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Shippers and Carriers of Radioactive Materials".
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Station Procedure Nos.:
RM-53 (Rev. No. 30, dated 7/8/96) " Radioactive Material Shipment"
RM-58 (Rev. No. 5, dated 6/29/95) " Packaging of Radioactive Waste for Shipment to
Scientific Ecology Group (SEG)"
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RM-50 (Rev. No.18, dated 10/23/96) "Redioactive Waste"
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RP-30 (Rev. No.12, dated 11/20/95) "Estab!ishing Area Postings"
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RM-56 (Rev. No.14, dated 6/29/95) " Radiological Clearance for Offsite Removal of
Material"
Administrative Procedure No. 5,11 (Rev. No.13, dated 7/31/96) " Radioactive Material
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Control"
Radioactive Shipment Nos: S-1513,S-1525,S-1506, S-1526, S-1482
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Nuclear Performance Assessment Audit (NPAD) No. PA-96-10 (dated April 22-May 16,
1996)
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Condition Report (CR) Nos:
96-942
" Overflow of Chemistry tank to the #1 Dirty Waste Receiving Tank (DWRT)"
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" Siphoning of Approximately 1000 gallons of water from the Radwaste
Concentrator Tank"
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96-564
" Pressurization of High integrity Container Return Hose"
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96-8G5
" Contamination Found in Bed of 2x4 Truck"
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NRC Information Notice No. 96-47 "Recordkeeping, Decommissioning Notifications for
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Disposals of Radioactive Waste by Land Burial Authorized under Former 10 CFR 20.304,
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20.302 and Current 20.2002."
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Big Rock Point Site Decommissianing Plan (Rev. No. 0) Section 3, " Facility Radiological
Status."
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