ML20148E376

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Insp Rept 50-424/88-13 on 880222-26.Violations Noted.Major Areas Inspected:Licensee Action on Previous Enforcement Matters,Audits,Onsite Followup of Events,External Exposure Control,Organization & Mgt Controls & Solid Wastes
ML20148E376
Person / Time
Site: Vogtle Southern Nuclear icon.png
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

Text

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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:

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. Weddington \\

Date Signed

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Approved by:

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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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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

10 CFR 20.401(b)

(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.

Portal Monitors

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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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.