ML20199F036
| ML20199F036 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 01/23/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20199F007 | List: |
| References | |
| 50-344-97-05, 50-344-97-5, NUDOCS 9802030039 | |
| Download: ML20199F036 (13) | |
See also: IR 05000344/1997005
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ENCLOSURE 2
U.S. NUCLEAR REGULATORY COMMISSION
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REGION IV
Docket No.:
50-344
License No.:
NPF 1
Report No.:
50 344/97-05
Licensee:
Portland General Electric Company
Facility:
Trojan Nuclear Plant
Location:
121 S, W. Salmon Street, TB-17
Portland, Oregon
Dates:
December 1-3,1997
Inspector:
J. V. Everett, Health Physics inspector
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Approved By:
D. Blair Spitzberg, Ph.D., Chief
Nuclear Materials inspection and Fuel Cycle / Decommissioning
Attachment-
SupplementalInformation
9802030039 900123
ADOCK 05000344
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EXECUTIVE SUMMARY
Trojan Nuclear Plant
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NRC Inspection Report 50-344/97-05
The Trojan facility had been undergoing active decommissioning and dismantlement for several
years. Estimated completion of the decommissioning was 2001. _ Structural components, tanks,
and piping were being removed from containment and the fuel / auxiliary building. Material that
was contaminated had been shipped for burial at Hanford. Material expected to be clean was
initially surveyed at the work area, then sent to a second area for final survey and eventual
release for sale as scrap metal. Workers observed during plant tours by the NRC inspector
were complying with radiological controls and restrictions. Housekeeping and fire loading was
acceptable and overall good safety practices were being implemented by tne workers. The
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water clarity and condition of the spent fuel pool was good. No potential freezing problems due
to cold weather were identified.
Problems continued to occur with surveys of potentially contaminated matenals. Previous
problems associated with the adequacy of surveys for shipping containers destined for burial at
Hanford appeared to have been corrected. However, certain surveys of materials removed from
the radiologically controlled area had been identified as inadequate in 1997. The, resulted in the
release of some materials outside the radiologically controlled area that exceeded free release
limits. The licensee's review of the problem identified that similar inadequacies occurred with
certain materials released during earlier years. The licensee was being aggressive in identifying
the extent of the problem and had shown considerable commitment to co rect the problem.
Corrective actions recently initiated for future surveys should be effective in reducing
unintentional releases of contaminated material from the radiologically controll.*d area.
Sagot Fuel Pool Safetv
Spent fuel pool water level and temperature were conbrmed to be within the required
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limits of the Trojan Technical Specifications. Water clarity was good. Dismantlement
work within the facility had not affected the spent fuel pool or associated systems
(Section 1).
Cold Weather Preoarations
A significant number of tanks and systems which contained water had been removed
from the Trojan facility. The few tanks that were operational did not appear to be
vulnerable to freezing damage considering the typical temperature rangts for the Trojan
area and the location of the tanks. Systems used to maintain the spent fuel pool were
located within the building and were not susceptible to freezing (Section 2).
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~ Decommisalonina Performance and Statum Review
- Disbiantlement activities were proceeding, and a large number of tanks had been -
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removed since the last inspection.-_ A tour of work areas indicated general conditions
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were safe, housekeeping was acceptable, and fire hazards were low (Section 3).
- Control of Raeliaar+!ve haial and Contamina*ian
Accountability for sealed sources was being maintained by the licensee through an
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annual inventory. The sources were being stored in locked cabinets (Section 4).
One violation concerning the discovery by the licensee of contaminated tools and
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scaffolding outside the radiologically controlled area in excess of the release limits
specdied in the Trojan Decommissioning Plan was identified. The NRC has requested
that in response to the violation, the licensee is to take appropriate actions to locate and
resurvey tools and scaffolding that were removed from the radiologically controlled area.
-(Section 4).
Qf93rization. Manacement. and Cost Controls -
- Changes to the licensee's emergency plan implementing procedures submitted .
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August 14,1997, were reviewed with the emergency preparedness engineer and found
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- acceptable (Section 5).
Tbe site emergency exercise was conducted September 30,1997. The exercise
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- involved a fire in containment and a medical emergency involving a potentially ,
contaminated individual. The licensee's evaluation found that all exercise objectives had -
been_successfully met (Section 5);
The year 2000 computer system prublem was being evaluated by a consultant to the
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- licensee. A number of tracking and scheduling systems were being evaluated to .
determine the magnitude of the problem for software used at Trojan (Section 5).
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honort Detans
S1HDFnry of Plant Status
Dismantlement and decommissioning activines were in progress ut ue Trojan facility.
Noticeable dismantlement had occurred since the last inspection, especially in the area of tank
removal. Work had expanded into new rooms and new radiological controls wore observed at
severallocations.
Free release of radioactive material had received considerable attentien by the licensee over th3
past several months. Changes to the program had been made to strengthen controls to prevent
contaminated material from being released from the radiologically controlled area. A significant
effort had been initiated by the licensee to survey all areas of the site to locate contaminated
mateNs improperly released from the radiologically controlled area during past activities.
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>ent Fuel Pool fiafety (60801,86700)
1.1
inspection Scooe
Technical Specifications for the spent fuel pool spacified water level and water
temperature limits. These limits were verified during this inspection. In addition, a tour of
the general area of the spent fuel pool was conductod to evaluate the structural condition
of the spent fuel pool walls and piping and verify that no dismantlement work was
underway that posed a threat to the structuralintegrity of the pool.
1.2
QbiciYahpn and Findinas
Trojan Technical Specification 3.1.1 required the spent fust pool water level to be
maintained at or above 22 feet ov9r the top of the spent fuel assemblies. The records for
the spent fuel pool water level for 1997 were reviewel. Water level was maintained
above 24 feet throughout the year with the lowest level recorded on November 11,1997,
at 24 feet 3 inches.
Trojan Technical Specification 3.1.3 required the spent fuel pool water temperature to be
maintained below 140' F. For 1997, the : vater temperature was typically maintained
between 50' F to 80' F. During December, a maximum temperature was recorded at
102' F. The licensee had allowed the temperature to increase in orde: to increase
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evaporation to make room for the transfer of water hcm the cask loading pit into the
spent fuel pool.
The steam reformer project was still underway and sorting of materialin the spent fuel
pool was observed. Some w1ter clouding around the work area in the fuel transfer canal
was observed; however, the water clarity around the spent fuel was good. A tour was
conducted of the various floors around the spent fuel pool. Work undeNvay to dismantle
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tanks, pipes and systems did not appear to affect the systems associated with the spent
fuel pool. The licensee had implemented a program to ers .re that critical systems were
not deactivated. Prior to any dismantlemnt work in on area, a survy was completed by
engineering. Piping and cables that were not to be removed were marked with red tape.
A tour of several areas where dismantlement had been completed near the spent fuel
pool revealed several pipes that wera taped and had not been affected by the work
completed in the room.
1.3
Conclusion
Spent fuel pool water level and temperature were confirmed to be within the required
limits of the Trojan Technical Specifications. Water clarity was good. Dismantlement
work within the facility had not affected the spent fuel pool or associated systems.
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Cold Weather Preparations (71714)
2.1
Insoection Scooe
A general review of the licensee's prosisions for cold weather protection was conducted.
Primary emphasis was placed on systems related to the spent fuel pool and tanks that
could leak contaminated water.
2.2
Observation and Findinos
A significant portion of the dismantlement effort at Trojan in 1997 was directed toward
removal of tanks. This eliminated much of the potential water inventory in the building.
Tanks inside the building that still had water included the dirty waste tank, clean waste
tank, trested waste tank, spent resin storaga tank and several s, umps. Outside the
building, water was still stored in the primary sater storage tank. This water contained
tntium. The Trojan facility was kept heated in most areas, with automatic switches to
activate heaters in selected areas. Weather conditions at Trojan are relatively mild with
few periods of hard freezing temperatures. Freezing of pipes had not been a problem in
the past.
Three systems with water were connected to the spent fuel pool. These were the cooling
system, the skimmer system, and the make-up water system. The demineralizer system
was connected to the coohng system. All three systems were within the heated
structure. The freezing potential for these systems appeared to be minimal.
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An auxiliary operator had conducted routine plant tours each sh:9. Shifts were 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />
in length. Frocedure OG 13,100 entitled " Auxiliary Operator Rounds," Revision 18, was
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used by the auxiliary operator. Step 4.4.1(r) directed the auxiliary operator to check
room temper:tures during the routine tours to detem1ine if temperatures were
appropriate for the time of year and to check heaters and coolers for proper operatior A
checklist was attached to the procedure to document the completed activities. The
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procedure also established a specific minimum temperature of 40'F for the diesel fire
pump room, otherwise the system was declared inoperable. Procedure POT 24 6," Shift
Operating Routines for Permanently Defueled Conditions," Revision 3, specified that if
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temperatures were below 32'F, special attention should be directed toward equipment
supporting the spent fuel pool, fuel transfer tube which passes ti .mugh the auxiliary
building facade, demineralizer water line in containment and cond . ment heaters.
On June 30,1994, the licensee submitted to the NRC a response to NRC Bulletin 94-01,
- Potential Fuel Pool Draindown Caused by inadequate Maintenance Practices at
Dresden Unit 1." A comparison of the 1994 response with the current procedures found
that procedural commitments were still in place for systems related to the spent fuel pool.
2.3
Conclusion
A significant number of tanks and systems which contained water had been removed
from the Trojan facility. The few tanks that were operational did not appear to be
vulnerable to freezing damage considering the typical temperature ranges for the Trojan
area and the location of the tanks. Systems used to maintain the spent fuel pool were
located within the building and were not susceptible to freezing.
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Decommissioning Performance and Status Review (71801)
3.1
-Inspection Scope
The status of dismantlement activities was observed during a plant tour to evaluate work
conditions, housekeeping, and fire protection.
3.2 -
Observation and Findinos
The dismantlement work at Trojan was proceeding and significant work had been
completed since the last inspection. A larga number of tanks had been removed and
segmented for burial. Several tanks remaineo .. ,,ervice. A tour of tanks used to collect
water from the sumps was performed with the licensee.- This included observing the
control panel which indicated the status of active tanks and touring the area where the
tanks were located to verify that piping was still connected.
A discussion was held with the licensee concerning control of dismantlement activities to
ensure systems were not inadvertently deactivated or disconnected. Prior to work being
conducted in an area, the engineering department identified all systems that were not to
be dismantled and placed pink tape on the system. A tour of several work areas
included observation of the pink tape on selected systems.-
During the tour, the work areas were observed to be relatively free from unnecessary
trash Work areas appeared to be safe with no noticeable industrial hazards observed
during the tour. Fire loading was minimal and no fire hazards were observed.
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Contamination areas were properly identified and posted. Radiation rope or tape was
evident to prevent unintentional entry.
3.3
Conclus10D
Dismantiement activities were proceeding with a large number of tanks removed since
the last inspection. A tour of work areas indicated general conditions were safe,
housekeeping was acceptable, and fire hazards were low.
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Cot >.rol of Radioactive Material and Contamination (83726)
4.1
Inspection Scope
The licensee's program for control of sealed radioactive sources was reviewed to verify
the current inventory was accurate and provisions were in place to annually inventory
sources.
The site survey effort underway to determine if contaminated material had been
improperly released from the radiologically controlled area was reviewed. This effort
invcived a comprehensive survey of areas onsite where material was stored or placed
that could have been released from the radiologically controlled area. The effort was
part of the corrective actions committed to by the licenser in response to the Notice of
Violation issued with Inspection Report 50 344/97 03 dated September 9,1997,
4.2
Qhervation and Findinas
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Technict.l Specification 5.9.2(e) required records to be maintained of the annual physical
inventory of sealed source material. In addition,10 CFR 20.1801 and 20.1802 require
security and controls for sealed sources. The annual physicalinventory sheet dated July
1997 was reviewed during this inspection. Them were 128 radioactive sources listed.
Most sources were stored in either the chemistry laboratory or the radiation protection
cabinet. The storage cabinets were kept locked. A random selection of ten sources was
identified from the inventory list. The radiation protection supervisor 'ocated all sources
selected.
NRC inspection conducted July 21-24,1997, resulted in issuance of a Notice of Violation
to the licensee on September 9,1997, related to the discovery of contaminated material
outside the radiologically controlled area. *lhe mateiial had been inadvertently released
from the radio'ogically controlled area during the final surveying process. The licensee
initiated a comprehensive effort to determine if additional contaminated material had
been released. This included surveying all buildings onsite where material was stored or
placed that had been removed from the radiologically controlled area.
On September 17,1997 a corrective action request (CAR-97-0024)'was initiated by the
licensee describing the discovery of additional radiological material outside the
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radiologically controlled area. A bucket was found on September 15,1997, by a
radiation protection technician outside the normal radiologically controlled area, but
inside a satellite radiologically controlled area, with fixed contamination on its bottom side
reading 1 million disintegrations per minute (dpm)/100 crd. The bucket had come from
the North American tool room. Surveys were conducted of the North American tool room
and shops plus the licensee's rnaintenance tool room and shops. Several additional
items were subsequently found which had fixed contamination levels of up to
25,000 dpm/100 cm' with one item reading 50,000 dpm/100 cnf. These items included
two welding leads, an electrical cord, socket, lifting eye, impact wrench, metal cable
sling, screwdriver, torque wrench, packing puller, and two shackles. All had fixed
contamination except for one item with smearable contamination. The licensee later
identified numerous other items, including scaffolding, that was found to be
contaminated.
Technical Specification 5.7.2.1 requires that procedures for personnel radiation
protection be prepared in a manner consistent with the requirements of 10 CFR 20 and
be approved, maintained, and adhered to for all operations involving personnel radiation
exposure.10 CFR 20.1501(a)(2)(li) requires that each licensee make, or cause to be
made, surveys that evaluate concentrations and quantitles of radioactive material. Limits
for the release of beta / gamma con'aminated material from the radiologically controlled
area at Trojan were established in the NRC-approved Trojan Decommissioning Plan,
Table 4.2.1, as 5,000 dpm/100 cnf average,15,000 dpm/100 cnf maximum, and
1,000 dpm/100 cm'smearable. The 5,000 dpm/100 cnf fixed and 1,000 dpm/100 cnf
smearable limits were also specified in Step 6.1 of Trojan Procedure 20-19, ' Release of
Materials from Radiologically Controlled Areas," Revision 1. Contrary to the above, the
inspector determined that a violation of Trojan Technical Specification 5.7.2.1 had
occurred due to the release of contaminated material from the radiologically controlled
urea exceeding both the average and maximum fixed contamination release limits of the
Trojan Decommissioning Plan and Procedure 2019 (Violation 50-344/9705-01). Despite
having been identified by the licensee, this violation is being cited because of
programmatic significance of the violation.
In the response by the licensee to the violation issued in inspection Report 50-344/97-03
dated September 9,1997, the licensee identified that between 1994 and 1997, tools
removed from the radiologically controlled area were offered for sale to the public.
Scaffolding was also loaned-out for personal use. As discussed during our telephone
exit on January 14,1998, a reasonable efforts is expected of Po-tland General Electric to
identify, locate and resurvey, tools and scaffolding that may have been removed frem the
radiologically controlled area and sold or released to members of the public during the
1994 through 1997 time frame. For all future releases of material from the site that were
not surveyed as part of the recent corrective actions effort, additional controls should be
identified that will preclude releases of contaminated material from the Trojan site in
excess of the limits approved in the Trojan Decommissioning Plan.
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Conclusion
Accountability for sealed sources was being maintained by the licensee through an
annual inventory. The sources were being stored in locked cabinets.
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One violation concerning the discovery by the licensee of contaminated tools and
scaffolding outside the radiologically controlled area in excess of the release limits
specified in the Trojan Decommissioning Plan and site radiological procedures was
identified. The NRC has requested that in response to the violation, the licensee is to
take appropriate actions to locate and resurvey tools and scaffolding that were removed
from the radiologically controlled area.
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Organization, Managernent, and Cost Controls (36801)
5.1
Insoection Snom
The 1997 annual exercise and changes completed during the year to the emergency
plan implementing procedures were reviewed. In addition, the year 2000 computer
problem was discussed with the licensee to determine if any impact on licensee activities
relating to decommissioning was expected.
5.2
Qbservation and FindiDOS
On August 14,1997, the licensee submitted changes to its emergency plan
implementing procedures to the NRC. These changes included the addition and
clarification of terminology related to the emergency action levels and a new attachment
containing guidance and considerations for emergency classifications. These changes
were reviewed during this inspection with the emergency preparedness engineer and
found acceptable.
The annual exercise for Trojan wee conducted on September 30,1997, The scenario
involved a fire in containment which caused significant amounts of smone and the
explosion of several gas bottles exposed to the heat of the fire. A possibly contaminated-
worker was injured during evacuation of containment. The containment purge exhaust
pro-filters became plugged causing smoke to enter the fuel / auxiliary building through the
equipment hatch.
Offsite agencies and organizations that participated in the exercise included the Rainer
Rural Fire Protection District, St. John Medical Center, and Professional Communication
Servicec. Limited participation was provided by Columbia County and the Oregon Office
of Energy. Emergency response actions included offsite notifications, acJvation of the
emergency response organization, communications with offsite response organizations,
dispatching of inplant emergency teams, removal of an injured and contaminated person
from the site and treatment at St. John Medical Center, protective actions for onsite
personnel, and issuance of a news release.
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The strengths identified by the Trojan evaluation team included the response to the
scenano by the emergency team and the drillmanship of the players to deal with the
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scenario events as if actual occurrences. No weaknesses were observed and all
23 exercise objectives were met. A number of observations and areas needing
improvement were identified including clarity and volume of the plant public address
system, coordination of information with the media representative, unavailability of a
radiation survey instrument during initial fire brigade response, and information flow
within the emergency response organization. Completion of the exercise satisfied the
annual exercise requirements in Section 0.1.3 of the Trojan Permanently Defueled
Emergency P:an, Revision 5.
Over the past several years, special concerns have surfaced related to the year 2000
software issue. This issue affects software that uses only the last two digits of the year
to perform calculations. When the year 2000 is reached, errors could be encountered for
any computer operation that subtracts dates.
Portland General Electric had hired a contractor to assist in determining which software
in use at the Trojan facility will encounter problems due to the year 2000 problem.
Examples of systems being evaluated included the work management system,
scheduling software, licensing tracking system, radiation information management
system, CAD system for plant drawings, fire protection tracking system, security access
control system, and iecords management system. There were no computerized systems
in the control room identified as beint susceptible to this problem.
5.3
Conclusion
Changes to the licensee's emergency plan implementing procedures submitted
August 14,1997, were reviewed with the emergency preparedness engineer and found
acceptable.
The site emergency exercise was conducted September 30,1997. The exercise
involved a fire in containment and a medical emergency involving a potentially
contaminated individual. The licensee's evaluation 'ound that all exercise objectives had
been successfully met.
The year 2000 computer system problem was being evalua'ed by a consultart hired by
the licensee. A numter of tracking and scheduling systems were being evaluated to
determine the magrytude of the problem for software used at Trojan.
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Onsite Follow up of Written Reports on Nonroutine Actions (92700)
(Qpened and Closed) Licensee Event Reoort 50-344/9705-02: oH Limit Exceeds NEDES
Limit: On September 6,1997, Trojan notified the NRC Duty Officer that a violation of the
licensee's national pollution and discharge effluent system (NPDES) permit had
occurred. While rinsing a sodium bisulfite barrelin the discharge and dilution structure
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after refilling the sodium bisulfite tank, the licensee received a low pH alarm on the
control room annunciator for the discharge and dilution structure effluent pH monitor.
The minimum pH measured was 5.6 according to the recorder, and 5.3 based on a grab
sample. The lower limit for the licensee's discharge permit was 6.0. The licensee was
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able to return the pH level to above 6.0 within approximately 10 minutes. The discharge
permit limit was not an NRC requirement or licensee technical specification requirement,
however, since the licensee notified the State of Oregon, then notification to the NRC
was required by 10 CFR 50.72(b)(2)(vi).
The licensee issued Corrective Action Request C 97 0021 and evaluated the event.
Approximately 24,000 gallons were released to the Columbia River outfall during the
period the pH level was below the permit limit. The licensee determined that other
methods of rinsing the barrels were available which would preclude recurrence of the
event and planned to develop procedural guidance on rinsing the barrels. The incpector
found the licensee's actions appropriate.
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Exit Meeting
The inspector presented the inspection results to members of the license 9 management
and the Resident inspector for the Oregon Office of Energy at the exit meeting on
December 3,1997. The licensee acknowledged the findings presented. The licensee
did not identify as proprietary any information provided to, or reviewed by, the inspector.
On January 14,1997, a telephone followup exit briefing was conducted to discuss the
final results of the inspection as presented in the inspection report.
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ATTACHMENT
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PARTIAL LIST OF PERSONS CONTACTED
Licensen
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A. Bowman, Radiation Protection Supervisor
J. Cooper. Emergency Preparedness Engineer
M. Gatlin, Nuclear Security Manager
T. Meek, Radiation Protection Manager
D. Nordstrom, Nuclear Oversight Manager
H. Pate, Licensing Manager
S. Schnieder, Plant Operations Manager
State _of013900
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A.' Bless, Resident inspector, Oregon Office of Energy
INSPECTION PROCEDURES USED
36801
Organization, Management, and Cost Controls at Permanently Shutdown Reactors
60801
Spent Fuel Pool Safety at Permanently Shutdown Reactors
71714
Cold Weather Preparations
71801
Decommissioning Performance and Status Review at Permanently Shutdown
Reactors
83726
Control of Radioactive Materials and Contamination, Surveys, and Monitoring
86700
Spent Fuel Pool Activities
92700
Onsite Follow-up of Wri* ten Reports of Nonroutine Events
ITEMS OPENED, CLOSED, AND DISCUSSED
Ooened
50 344/9705-01
Free Release of Contaminated Material
50-344/9705-02
IFl
pH Limit Exceeds NPDES Limit
GQind
50-344/9705-02
IFl
pH Limit Exceeds NPDES Limit
Discussed
None
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LIST OF ACRONYMS
cm
centimeter
CFR
Code of Federal Regulations
dpm
disintegrations per minute
mrem
milli Roentgen equivalent man
mSv
milli Sievert
National Pollution and Discharge Emuent System
Public Document Room
ppm
parts per million
rem,
Roentgen equivalent man
Sv
' Sievert
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