ML20148E376
| ML20148E376 | |
| Person / Time | |
|---|---|
| Site: | Vogtle |
| Issue date: | 03/07/1988 |
| From: | Hosey C, Weddington R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20148E368 | List: |
| References | |
| 50-424-88-13, NUDOCS 8803250081 | |
| Download: ML20148E376 (11) | |
See also: IR 05000424/1988013
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETTA ST., N.W.
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ATLANTA, GEORGIA 30323
MAR 151988
Report No.: 50-424/88-13
Licensee: Georgia Power Company
P. O. Box 4545
Atlanta, GA. 30302
Docket No.: 50-424
License No.: HPF-68
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Facility Name: Vogtle
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Inspection Conducted:
February 22-26, 1988
Inspector:
k%
7 /7 /M
. Weddington \\
Date Signed
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Approved by:
W
7 /J /N
C. M. H6sey, Section Chief
Date Signed
Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, unannounced inspection was conducted in the areas of
licensee action on previous enforcement matters, audits, onsite followup of
events, external exposure control, organization and management controls, solid
wastes, transportation, and followup on inspector identified items.
Results: Four violations with examples were identified - (1) three examples of
failure to provide adequate high radiation area controls. (2) failure to adhere
to procedures for installation of temporary shleiding, (3) failure to perform
adequate radiation surveys and (4) two examples of failure to document surveys.
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8803250081 880315
ADOCK 05000424
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- R. Bellamy, Plant Manager
- G. Bockhold, General Manager
- A. Desrosiers, Support Superintendent, Health Physics / Chemistry
- C. Eckert, Manager, Health Physics and Chemistry
- G. Frederick, Quality Assurance site Manager
- T. Greene, Plant Support Manager
- P. Herman, Senior Nuclear Engineer
- D. Hopper, Corporate, Manager, Radiation Safety
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- W. Kitchens, Operations Manager
- I. Kochery. Health Physics Superintendent
- R. LeGrand, Waste Management Superintendent
- K. Pointer, Senior Plant Engineer
- P.
Rice, Vice President, Project Director
- M. Seepe, Radwaste Supervisor
- R. Spinato, Independent Safety Engineering Group Supervisor
- J. Swartzweider, Manager, Nuclear Safety and Compliance
- J. Willcox, Senior Quality Assurance Field Representative
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Other licensee employees contacted included technicians, foremen, security
officers and office personnel.
Nuclear Regulatory Commission
- C. Burger, Resident Inspector
- J. Rogge, Senior Resident Inspector
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- R. Schepens, Resident Inspector
- Attended exit interview
2.
Exit Interview (30703)
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The inspection scope and finding were summarized on February 26, 1988,
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with those persons indicated in Paragraph 1 above.
The following issues
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were discussed in detail:
(1) an apparent violation with three examples
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of failure to provide adequate high radiation area controls
(Paragraphs 5.b and c); (2) an apparent violation for failure to adhere to
procedures for installation of temporary shielding (Paragraph 5.c); (3) an
apparent violation for failure to perform adequate radiation surveys
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(Paragraph 5.d); and (4) an apparent violation with two examples of
failure to document surveys (Paragraph 5.d and e).
Licensee
representatives acknowledged the inspection findings and took no
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exceptions.
The licensee did not identify as proprietary any of the
materials provided to or reviewed by the inspector during this inspection.
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3.
Action on Previous Enforcement Matters (92702)
(Closed) Violation (50-424/87-35-01) Failure to conduct adequate startup
shield verification radiation surveys.
The 5spector reviewed the.
licensee's responses of July 23 and October 26, 1987.
The licensee had
denied the violation and a meeting was held on December 9,1987, at the
Georgia Power Company's Corporate office in Atlanta, Georgia between
Georgia Power and NRC Region 11 management to discuss statements made in
the licensee's October 26, 1987, supplemental response to the violation (a
sunnary of the meeting was issued in a letter dated January 5,1988). The
NRC continues to believe that there were inadequacies in the licensee's
startup surveys and that the violation was correct as written, however,
from the standpoint of exposure to survey personnel and nonreproducibility
of initial radiation levels, it would not be worthwhile for the licensee
to perform e new survey.
Licensee representatives stated that they would
review and incorporate provisions of ANSI /ANS 6.3.1-1980, Program for
Testing Radiation Shields in Light Water Reactors, as appropriate, into
their Unit 2 startup shield verification surveys.
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(Closed) Violation (50-424/87-35-02) Failure to document corrective
actions for deficiencies. The inspe tor reviewed the licensee's responses
of July 23 and November 25, 1987, arJ verified that the corrective actions
stated therein had been taken.
(Closed) Violation (50-424/87-52-01) Failure to provide adequate high
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radiation area controls for Unit 1 containment.
The inspector reviewed
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the licensee's response of October 26, 1987, and verified that the
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corrective actions stated therein had been taken.
(0 pen) Violation (50-424/87-61-01) railure to perform adequate release
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surveys.
The inspector reviewed the licensee's response of December 21,
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1987.
The licensee stated in their response that a high-sensitivity
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monitor had been placed in service on December 8, 1987, to perform release
surveys on bags of trash from the controlled area.
During the inspection,
the inspector observed that the bag monitor was not in operation.
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Licensee representatives stated that the beg monitor had been placed in
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service in December 1987, but it had been taken out of service the
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following month until a chip that would permit a longer count time could
be obtained and placed in the t.ait's nicroprocessor. The inspector stated
this item would remain open until the actual operation of the monitor
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could be reviewed.
4.
Audits (83723, 83724, 83725, 83726, 83728, 84722, 86721, 83722, 83727)
The inspector discussed with licensee representatives the onsite quality
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assurance (QA) audit and surveillance programs in the areas of radiation
protection and radwaste.
The licensee maintained an 18 month master
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schedule for audits and surveillances.
During 1988, two audits and one
surveillance were planned in radiation protection and two audits were
planned in radwaste.
Special audits and surveillances were performed as
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needed as determined by the QA Manager, such as the surveillance that had
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recently been performed on the licensee's ficst offsite radioactive waste
shipment.
The scope of the radiation protection a:dits included programmatic
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performance, internal exposure control, external exposure control,
radioactive material control, surveillances, facilities and equipment.
ALARA, training and conformance to technical specifications. Within these
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nine broad categories, the licensee had defined 30 areas in which
checklists had been prepared.
When an audit was scheduled, the auditor
choose checklists from these areas that are most appropriate based on
current problems and activities in progress.
Licensee representatives
stated that they attempt to perform every checklist at least once every
two years.
The inspector reviewed results of radiation protection audits
that had been performed during the periods November 4-19, 1986,
April 6-22, and September 14-28, 1987, and January 7-21, 1988.
The
inspector also reviewed the results of special surveillance 1-AOS-88-016
which had been performed on February 15, 1988, to review the licensee's
first radwaste sh'pment.
The inspector discussed with licensee representatives the qualifications
of personnel who performed the audits and determined that they had
appropriate training and/or experience in the audit areas.
No violations or deviations were identified.
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5.
Onsite Followup of Events (93702)
a.
Spent Resin Transfer
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On February 22, 1988, the licensee transferred 90 ft3 of spent resin
from the spent resin storage tank (SRST) to the alternate radwaste
building (ARB).
The SRST volume was comprised of 30 f t3 each of two
chemical and volume control system (CVCS) mixed bed loads and one
from the waste monitor tank demineralizers. The CVCS has measured up
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to 15 Rem / hour prior to being transferred to the SRST.
The resins
were sluiced into a liner in the ARB which already contained 100 ft3
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of low activity resins.
Af ter the discharge was complete, the
background radiation levels in the ARB were too high for personnel to
use the portable frisker at the building exit.
A health physics
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survey showed that the radiation levels on top of the resin liner
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were up to 10 Rem /heur at contact and 3 Rem / hour at 18 inches from
the resin sluice line and fill head connuction (the liner had been
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placed inside of a process shield such that dose rates of that
magnitude were only present on the top of the l'ner).
Licensee radwaste management consulted with health physics field
operations personnel and determined that shielding should be placed
on top of the liner to reduce the background dose rates so that
frisking could be performed in the ARB.
Four 55-gallon plastic drums
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were placed on top of the liner and then filled with water from a
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demineralized water line.
Lead blankets were then placed
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spaces between the barrels.
This shielding, however, was not
sufficiently effective to allow resumption of frisking in the ARB and
the frisker remained outside the building.
The licensee also
backflushed the resin discharge lines in an attempt to reduce
radiation levels, but this was also not effective.
b.
High Radiation Area Controls
Technical Specification (TS) 6.11 requires that each high radiation
area in which the intensity of radiation is greater than 100 mrcm/hr
but less than 1,000 mrem /hr at 18 inches from the radiation source or
from any surface which the radiation penetrates shall be barricaded
and conspicuously posted as a high radiation area and entrance
thereto shall be controlled by requiring issuance of a Radiation Work
Permit (RWP).
In addition areas accessible to personnel with
radiation levels greater than 1,000 mrem /hr at 18 inches shall be
provided with locked doors to prevent unauthorized entry, and the
keys shall be maintained under the administrative control of the
shift foreman on duty and/or health physics supervision. Doors shall
remain locked except during periods of access by personnel under an
approved RWP which shall specify the dose rate levels in the
inmediate work areas and the maximum allowable stay time for
individuals in that area.
The inspector reviewed records of two radiation surveys performed
before and after the installation of shielding on the resin liner in
the ARB.
The after shielding surveys indicated that the dose rates
on top of the liner were still in excess of 1 Rem / hour (10 Rem / hour
at contact and 3.5 Rem / hour at 18 inches).
The survey records also
indicated that a flashing light had been installed in the high
radiation area on top of the resin liner.
The inspector toured the
ARB and observed that the two personnel access doors were not locked
and a flashing yellow light was in place on top of the liner.
The
east door of the ARB had a thq affixed to the outside handle dated
November 3,1987, indicating that a key had been broken off inside
the lock.
The inspector discussed the appropriateness of using a flashing light
in lieu of locked doors to control access to the high radiation area
in the ARB. Technical Specification 6.11.2 permits use of a flashing
light as a warning device in lieu of locked doors for high radiation
areas located within large areas, such as PWR containment, where no
enclosure exists for purposes of locking, and where no enclosure can
be reasonably constructed around the individual area.
The NRC
considers that the use of a flashing light was not appropriate in
this case.
No action had been taken to anticipate the need for
locking the doors to the ARB prior to the resin transfer and no
action had been taken to repair the lock in the greater than 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
period that the high radiation area had been present.
Failure to
provide locked doors to control access to the high radiation area in
the ARB was identified as an apparent violation of TS 6.11
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(50-424/88-13-01).
The licensee then took immediate action to lock
both doors to the ARB with hasps and padlocks.
Licensee representatives stated that two surveys had been performed
on the resin transfer piping between the SRST and the ARB.
One
survey was performed after the transfer and the other after the lines
were backflushed.
The inspector performed a walkdown and radiation
survey of the transfer line with licensee radwaste operations and
health physics representatives.
In room RC 74 of the Auxiliary
Building, dose rates in the vicinity of valves 7325 and 157 were
found to
be 3 Rem / hour at contact and 500 mrem / hour at 18 inches.
The ladder providing access to the room was not posted as a high
radiation area.
There was a sign on the base of the ladder stating
that no entry was allowed without health physics coverage.
During
surveys in the radwaste transfer tunnel between the auxiliary
bailding and the ARB, dose rates up to 2.2 Rem / hour and 500 mrem / hour
at 18 inches were found on the overhead resin transfer piping.
The
access to the area was not posted as a high radiation area.
Failure
to post the two high radiation areas on the resin transfer piping was
identified as an additional example of an apparent violation of TS 6.11 (50-424/88-13-01).
c.
Radiation Work Permits and Procedures
Technical Specification 6.10.1 requires that procedures for personnel
radiation protection shall be prepared consistent with the
requirements of 10 CFR part 20 and shall be approved, maintained, and
adhered to for all operations involving personnel radiation exposure.
The inspector reviewed special RWP 88-0176, Liquid Waste Processing -
Spent Rent Storage Tank 0 Level, Resin Sluice to Liner in ARB,
Dry /Dewater Resin in HIC, effective February 16-26, 1988.
The RWP
had been user to perform the resin transfer on February 22, 1988.
The RWP requ ,t stated that radiation levels during the sluice would
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exceed 100 mrem / hour.
However, the high radiation levels in excess
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of 1 Rem / hour which radwaste personnel acknowledged were anticipated
were not specified on the documents.
Radwaste staff indicated that
they told health physics personnel about the anticipated radiation
levels.
The RWP stated that the prejob briefing consisted of reading
the RWP and discussing the need to inform HP of any changes that
occurred during the pumping process. There was nothing on the RWP or
supporting documents concerning surveys of the transfer piping after
the discharge.
Radwaste operations personnel stated that they had
walked down the transfer piping with health physics prior to the
transfer so they would know where to survey, but thera was no
documentation of this.
The inspector determined that tne walkdown
did occur, however the health physics technician who participated in
the walkdown was not the same person who performed the post discharge
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surveys because the survey was not performed until the following
shift.
The inspector discussed the level of detail of RWPs and
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supporting documents with licensee representatives (see Paragraph 6.a
for further discussion).
As discussed previously, when the high radiation levels vere observed
affecting the ability to frisk in the ARB, the licensee installed
shielding on the top of the resin liner.
The inspector reviewed
licensee procedure 41006-C, Temporary Shielding, Revision 2
August 11, 1987, which specified the requirements for installation of
temporary shielding. The inspector determined that the personnel who
had performed the shielding installation were unaware of the
procedure and as a result had not complied with any of its
provisions, which included a documented engineering and ALARA
evaluation and approvals.
Failure to adhere to the provisions of the
shielding procedure was identified as an apparent violation of
TS 6.10.1 (50-424/88-13-02).
The inspector determined that the recovery work in the ARB had been
performed under RWP 88-0105, Operations and Radwaste Operations
Rounds, Surveillances and Valve Line Ups in High Radiation Areas
and/or Airborne Areas, which was the routine operations RWP for the
ARB for high radiation area work.
The inspector reviewed the
supporting documents for the RWP, which included the RWP request and
ALARA review, and determined that the recovery work performed in the
ARB was beyond
e scope of the RWP.
Failure to provide an RWP
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specific to
recovery work in the ARB was identified as an
additional
exa cle of an apparent violation of TS 6.11
(50-424/88-13-01).
d.
Surveys and Records
10 CFR 20.201(b) requires that each licensee shall make or cause to
be made such surveys as may be necessary for the licensee to comply
with the regulations and are reasonable under the circtmstances to
evaluate the extent of radiation hazards that may be present.
10 CFR 20.401(b) requires a licensee to maintain records showing the
results of surveys required by 10 CFR 20.201(b'
The inspector reviewed the results of surveys performed in the ARB
and on the resin transfer piping following the discharge.
The
licensee had a completed survey form for a survey at 1631 hours0.0189 days <br />0.453 hours <br />0.0027 weeks <br />6.205955e-4 months <br /> on
February 23, 1988, on the transfer piping following the backflush.
The survey was performed on the A through D levels of the auxiliary
building mezzanine.
There was also a notation in the health physics
shift logbook that a survey had been performed at 0100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> on
February 23, on the mezzanines.
Licensee representatives confirmed
that no survey had been performed on the resin transfer piping in the
two areas later found by the inspector to contain unposted high
radiation 3reas. Failure of the licensee to perform adequate surveys
to identify these areas was identified as an apparent violation of
10 CFR 20.201(b) (50-424/88-13-03).
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Licensee representatives informed the inspector that no survey form
had been completed for the survey mentioned in the logbook on
February 23.
Failure to maintain a record of this survey was
identified as
an apparent
violation of 10 CFR 20.401(b)
(50-424/88-13-04).
e.
Exposure Control
The inspector reviewed records indicating the exposures received by
personnel in the ARB following the resin transfer.
The records
indicated that the highest exposure was received by a radwaste
operator which was 59 millirem.
The inspector interviewed personnel
who had performed the shielding work cn top of the resin liner.
They
stated that they had worn their assigned dosimetry in its normal
location on the chest and that extremity dosimetry had not. been
provided.
The inspector discussed with licensee representatives the
rationale for not providing extremity dosimetry and not relocating
the whole body dosimetry to above the knee since the radiation source
was underfoot.
Licensee representatives stated that an evaluation
had been performed by the health physics technician prior to the
shielding work and that, based on the dose aradients on top of the
liner and the working positions of the personnel, the determination
had been made that the licensee's procedural criteria for either
relocation of whole body dosimetry and/or use of extremity dosimetry
had not been met. However, there was no documentation of the surveys
that had been performed to support the exposure evaluation.
Failure
to maintain a record of this survey was identified as an additional
example
of an apparent violation of
(50-424/88-13-04).
6.
External Exposure Control (83724)
a.
Radiation Work Permits (RWPs)
The inspector reviewed active general and special RWPs posted in the
vicinity of the health physics field office for repetitive and
nonroutine work.
The inspector also reviewed selected RWP packages
containing the RWP request, ALARA review worksheets and prejob
briefing statements for the active RWPs and those that had been
prepared for the October 1987 cutage. The inspector noted that there
appeared to be a general lack of specific information on the
documents and they generally contained only general statements of
good practices.
Licensee representatives acknowledged that
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improvements could be made in providing more job specific information
and controls on RWPs. This area will be reviewed during a subsequent
inspection (50-424/88-13-05).
No violations or deviations were identified.
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b.
The licensee had recently installed PM-6 portal monitors at the exit
area in the main site gatehouse.
The inspector discussed the
operation of the portal monitors with licensee representatives. The
licensee explained that in order to count the front and back of an
individual, the unit counted for two seconds as a person was entering
the portal and counted for two seconds as he exiting, as well as
counting for two seconds while inside the portal.
The alarm levels
were set to detect contamination on en individual approximately
equivalent to 7,000 dpm/100 cm2
The inspector observed that
personnel leaving at peak periods were following closely behind one
another through the monitor.
There was a small sign on the portal
which stated that one should wait until the person ahead had cleared
before approaching the portal, but the sign was not legible from a
distance.
The inspector discussed with licensee representatives
things that could be done to aid personnel in using the monitor
properly such as a waiting line marked across the floor and/or an
overhead sign.
No violations or deviations were identified.
7.
Organization and management Controls (83722)
By letter dated December 28, 1987, the licensee requested a change to the
plant organization shown in TS Figure 6.2-2.
The cbange establishes the
position c1 Manager, Health Physics and Chemistry and subordinate
positions at the superintendent level of Health Physics, Chemistry and
Technical Support Health Physics / Chemistry.
The inspecto. observed that
the licensee had not proposed qualification requirements .'or the new
organizational positions.
(The NRC had previously determined that the
incumbents in the Health Physics Superintendent and Technical Support
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Health Physics / Chemistry Superintendent positions met the Radiation
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Protection Manager requirements of Regulatory Guide 1.8).
The inspector
reviewed the (;ualifications of the new Manager, Health Physics and
Chemistry and discussed with him the program initiatives he had
implemented or planned.
The Manager had a strong operations and
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management background, but did not have any significant amount of work
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experience creditable under Regulatory Guide 1.8 in Health Physics or
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Chemistry. However, the inspector determined that the individual was well
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qualified to fulfill the licensee's objective in establishing the position
to enhance the management control and effectiveness of the group.
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No violations or deviations were identified.
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8.
Solid Waste (84722)
a.
Waste Classification
10 CFR 20.311(d) requires that any generating licensee who transfers
radioactive waste to a land disposal facility shall prepare all
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wastes so that the waste is classified according to 10 CFR 61.55 and
meets the waste characteristic requirements of 10 CFR 61.56.
The inspector reviewed the licensee's preparations for their first
two radioactive waste shipments to a land disposal facility.
The
inspector also reviewed licensee procedure 10206-C, Revision 0, Waste
Classification Resin Shipments, November 27, 1987. The licensee-used
generic scaling factors for classification purposes until adequate
site specific waste stream data base can be established.
The
licensee also performed sampling and analysis by an offsite
laboratory of wastes being shipped.
These sample results were
compared to the generic scaling factors and the factors were adjusted
as required to be consistent with the actual measurements.
The
inspector reviewed the licensee's classification methodology and
determined that the wastes had been properly classified.
The
inspector also reviewed checklists filed with the licensee's shipping
documents which showed that the contractor operator had followed the
resin liner dewatering procedure and that process parameters had been
verified by the Radwaste Supervisor.
No violations or deviations were identified,
b.
Manifest Tracking
10 CFR 20.311(d)(8) and (h) requires that the licensee maintain a
waste manifest tracking system and investigations be performed if
receipt notification is not received within 20 days of transfer.
The inspector reviewed the licensee's waste manifest tracking system
and verified that there were no overdue shipments and shipment status
was being properly recorded.
No violations or deviations were identified.
9.
Transportation (86721)
10 CFR /1.5 requires that each licensee who transports licensed material
outside of the confines of its plant or other place of use, or who
delivers licensed material to a carrier for transport, shall comply with
the applicable requirements of the regulations appropriate to the mode of
transport of the Department of Transportation in 49 CFR Parts 170 through
189.
The inspector reviewed the shipping paperwork for the licensee's first two
radioactive waste shipments. The first shipment was performed on February
15, 1988, under control number 02-88-184. The low specific activity (LSA)
shipment consisted of dewatered ion exchange resins.
The second shipment,
control number, 02-88-185, consisted of dried filters and dewatered
resins.
The inspector also reviewed licensee procedures 10205-E,
Revision 2, Radwaste Disposal and Notification Requirements, November 27
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1987, and 10210-C, Revision
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Shipment of Radioactive Wastes,
November 27, 1987.
The inspector determined that the waste manifest had been completed
consistent with the shipping paper requirements of 49 CFR 172.201-203 and
that the LSA classification was consistent with 49 CFR 173.403(n).
The
inspector reviewed the radiation survey documents filed with the shipping
documents to verify conformance with the radiation level limitations in
49 CFR 173.441.
The inspector noted that no radiation levels were shcwn
for the cab of the transport vehicle which is required to be less than
2 millirem / hour.
The licensee was able to show the inspector another
survey document which showed that the radiation survey had been performed.
The discrepancy arose because the radwaste personnel had dispatched the
shipment based on their observation of the health physics surveys and
independent measurements performed by themselves prior to receiving the
survey documentation from health physics.
The survey record later
presented to radwaste inadvertently omitted the vehicle cab survey data
and was placed in the file.
The health physics technician later
recognized the omission and corrected his record, but a copy of the
revision was not sent to radwaste.
Licensee representatives stated that
in the future they would ensure that supporting documents showing that
shipping prerequisites had been met would be verified complete and
included in the shipping file prior to releasing the shipment.
No violations or deviations were identified.
10.
Followup on Inspector Identified Items (92701)
(Closed) IFI (50-424/87-35-03) Evaluation of_ IMP-7 whole body frisker unit
alarm set points.
The inspector reviewed a study performed by the
licensee of the detection capabilities of their frisker units, the
technical bases for alarm levels and how those parameters compared to
other industry users of the equipment. The inspector determined that the
frisker units were being operated in an adequate manner to provide a
satisfactory level of personnel contamination detection.
(Closed) IFI (50-424/86-126-01) Relocate remote area radiation monitors
ARE-0009A and AR2-0009B to the new decontamination room.
Licensee
representatives stated that a decision had been made not to relocate the
monitors since the room in which they were presently located was going to
be used for radioactive material storage.
The new decontamination room
had portable area radiation monitors installed.