ML20206D491

Insp Rept 50-302/87-09 on 870309-13.Violations Noted:Failure to Comply W/Dot Regulations for Transporting Radioactive Matl & to Perform Adequate in Vivo (Whole Body Count) Surveys

ML20206D491
Person / Time
Site:	Crystal River
Issue date:	03/23/1987
From:	Collins T, Hosey C, Kuzo G, Weddington R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20206D397	List: IR 05000302/1987009 ML20206D394 ML20206D409 ML20206D491
References
50-302-87-09, 50-302-87-9, NUDOCS 8704130353
Download: ML20206D491 (14)

See also: IR 05000302/1987009

Text

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UNITED STATES -

[M MI o,^ NUCLEAR REGULATORY COMMISSION

[ , REGION ll

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g j ,101 MARIETTA STREET,N.W.

• ATLANTA, GEORGI A 30323

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Report No.:- 50-302/87-QtIS

Licensee: Florida Power Corporation

3201 34th Street, South

St. Petersburg, FL 33733

Docket' No. : 50-302 License No.: DPR-72

Facility Name: Crystal River 3

Inspection Conducted: March 9-13,1987 >

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Inspector:

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t4 bM

.. Weddington Date Signed-

JALvLa

T. R'. Coll'inF

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'Da'te Signed

almLO En 83 L,h Ni9

Date Signed

GtB.(Cuzo

Accompanying Personnel:, C. M. Hosey

Approved by: )  % 3h3 /87

C. M. - Hosey', Secti4n Chief Date Signed

Division of Radiation Safety and Safeguards

SUMMARY

Scope: This routine unannounced inspection involved review of previously

identified inspector followup items and enforcement hatters, external exposure

control, internal exposure control, control of radioactive material, solid

wastes, transportation, and followup of IE Notices.

Results: Three violations were identified: (1) failure to comply with

Department of Transportation regulations for transporting radioactive material,

(2) failure to have adequate procedures in place to ensure personnel were

qualified to wear respiratory protective equipment necessary to perform their

duties, and (3) failure to perform adequate in vivo (whole body count) surveys.

8704130353 870327

PDR ADOCK 05000302

G PDR

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REPORT DETAILS

1.- Persons Contacted

Licensee Employees

• P. F. McKee, Station Manager

• W. K. Baudhauer, Assistant Manager, Nuclear Plant Operations

• W. L. Rossfeld, Manager, Site Nuclear Compliance

• W. J. Lagger, Health Physics Supervisor

• R. E. Fuller, Senior Nuclear Licensing Engineer

• D. T. Wilder, Radiation Protection Manager

• G. R. Clymer, Manager, Nuclear Waste

• V. A. Hernandez, Senior Nuclear QA Specialist

• A. Kazemfar, Supervisor, Nuclear Support Services

• D. Van Ooesterwyk, Supervisor, Health Physics

• S. L. Robertson, Supervisor, Chemistry-Radiation

• J. R. Wright, Nuclear Support Specialist

• S. Lashbrook, Supervisor, Health Physics

• M. S. Mann, Nuclear-Compliance Specialist

• P. D. Breedlove, Supervisor, Records Management

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• G. Fleming, Health Physics

M. M. Siapno, Supervisor, Health Physics

Other licensee employees contacted included engineers, technicians, and

office personnel.

Nuclear Regulatory Commission

T. Stetka, Senior Resident Inspector

• J.-Tedrow, Resident Inspector

• Attended exit interview

2. ExitInterview(30703)

The inspection scope and findings were suninarized on March 13, 1987, with

those persons indicated in Paragraph 1 above. Three apparent violations

concerning failure to comply with Department of Transportation regulations

for transporting radioactive material (Paragraph 9), inadequate

respiratory protection procedures (Paragraph 5), and failure to conduct

j adequate in vivo radiological surveys (Paragraph 6) were discussed. The ,

l licensee acknowledged the inspection findings ~and trok no exceptions. The

licensee did not identify as proprietary any of the material provided to

or reviewed by the inspectors during this inspection.

3. Licensee Action on Previous Enforcement Matters

a. (Closed) Violation (50-302/85-34-02) Inadequate personnel monitoring

(frisking) while leaving the Radiation Controlled Area (RCA). The

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inspector reviewed and verified the implementation of the corrective

actions stated in Florida Power Corporation's letters of November 14,

1985, and January 16, 1986.

b. (Closed) Violation (50-302/86-06-01) Personnel working in a high

radiation area without appropriate survey instruments. The inspector

. reviewed and verified the implementation of the corrective actions

stated in Florida Power Corporation's letter of December 5,1986.

c. (Clased) Violecion (50-302/86-11-02) Radiation Work Permit (RWP)

procedure was -inadequate to address change of work conditions after

RWP was issued. The inspector reviewed and verified the

implementation of the corrective actions stated in Florida Power

Corporation's letter of August 11, 1986.

d.. (Closed) Violation (50-302/86-26-02) Failure to adequately brace i

radioactive materials packages. The inspector reviewed and verified

the implementation of the corrective actions stated in Florida Power

Corporation's letter of December 4,1986,

e. (Closed) Violation (50-302/86-26-04) Failure to implement an alpha

survey program for airborne and contamination control. The inspector

reviewed and verified the implementation of the corrective actions

stated in Florida Power Corporation's letter of December 4,1986.

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f. (Closed) Violation (50-302/86-26-05) Personnel working in a high

radiation area without appropriate survey instruments. The inspector

reviewed and verified the implementation of the corrective actions

stated in Florida Power Corporation's letter of December 4,1986.

g. (Closed) Unresolved Item (50-302/86-35-05) Unauthorized release of

radioactive material outside the RCA. In July 1986, the licensee,

while performing routine surveys of the facility, found a

contaminated tool outside the RCA inside a' contractor's tool trailer.

The event was reviewed and documented in Inspection Report

No. 50-302/86-26 and was determined to be a licensee identified

violation. The licensee's corrective action to preclude future

events of this type included weekly routine surveys of areas outside

the RCA. During October 1986, the licensee found another

contaminated piece of equipment outside the RCA. This equipment was

determined to have been outside the RCA since before the first item

was found. The licensee's corrective action to increase the

frequency of surveys outside t5e RCA was sufficient to locate the

uncontrolled contaminated equipment in October 1986.

The inspector reviewed and discussed with licensee representatives

their long term Radioactive Materials Control Program, which had been

written and sent to management for appval. At the time of the

inspection all of the proposed actions were not complete. However,

Radiological Surveys Procedure, HPP-202 was revised to implement

interim corrective actions. The inspector reviewed and verified that

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HP-202 procedure, Radiological Surveys had been revised and was

adequate to control release of radioactive materials.

The inspector determined that since the material outside the

controlled area had been identified as a result of the licensee's

corrective action for a previous event that ' had been considered

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licensee identified, pursuant to the NRC Enforcement Policy,

10 CFR Part 2, Appendix C, and that the material had likely.not been

released subsequent to the initial finding, then there was no

violation of NRC requirements and the unresolved item would be .

closed.

4. . Maintaining Occupational Exposures ALARA (83728) l

10 CFR 20.1(c) specified that licensees should implement programs to keep l

worker's doses as . low as reasonably achievable (ALARA). The recommended

elements of an ALARA program were contained in Regulatory Guide 8.8,

Information Relevant to Ensuring that Occupational Exposure at Nuclear

Power Stations will be ALARA, and Regulatory Guide 8.10, Operating

Philosophy for Maintaining Occupational Exposures ALARA.

Licensee representatives stated that management commitment to the ALARA

program implementation- came from the highest corporate and plant

management levels. Procedural guidance detailing the licensee's ALARA

program was outlined in Administrative Instruction (AI) 1600, ALARA

Program Manual, June 17, 1986. The Site Nuclear Services ALARA Specialist

was responsible for overseeing the plant ' ALARA program. The ALARA

specialist responsibilities included: (1) interfacing with the Director,

Nuclear Plant O

activities; (2) perations

reviewingtoany

ensure

planned ALARA tasks is maintained

that inmore

may expend dailythan

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1 man-rem; (3) reviewing collective dose to determine success of ALARA

goals, and issuing selected reports and evaluations; (4) evaluating plant

ALARA data and making recommendations as appropriate.

The ALARA specialist conducted pre- and post job ALARA reviews and

reviewed exposure performance against objectives during work in progress.

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Exposure estimates on selected jobs were reviewed daily and the final dose

estimates were then compared with the dose determined by TLD. Management

was routinely apprised of station exposure for each departmental section.

The highest man-rem exposures for 1985 and 1986 were reported for the

health physics and system maintenance departments.

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The inspector discussed the goals and objectives for 1986 and reviewed

man-rem estimates for 1985 and 1986. Based on no expected outages, the

original 1986 goal was 50 man-rem. An additional 300 man-rem was added to

the year's total to account for a reactor coolant pump repair outage. A

subsequent exposure estimate for a letdown cooler replacement was

60 man-rem. Welding difficulties were experienced for this job but the

estimated exposure was not revised. The total assigned exposure was

447 man-rem for 1986, slightly higher than the estimated amount. The 1985

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assigned exposure was 646 man-rem, with 568 man-rem directly attributable

to activities associated with the March-August refueling cycle outage.

No violations or. deviations were identified.

5. Surveys, Monitoring, and Control of Radioactive Material (83726)

10 CFR 20.201(b) requires each licensee to make or cause to be made such

surveys as (1) may be necessary for the licensee to comply with the

regulations and (2) are reasonable under the circumstances to evaluate the

extent of radiation hazards that may be present.

The inspector reviewed plant Procedure RP-202, Radiological Surveys, which

established the licensee's radiological survey and monitoring program and

verified that the procedure was consistent with 10 CFR Part 20, Technical

Specifications and good health physics practices.

The inspector reviewed selected records of radiation and contamination

surveys performed during the period of January to March 1987 and discussed

the survey results with licensee representatives.

During tours of the plant, the inspector observed health physics

technicians performing radiation and contamination surveys.

The inspector discussed with the licensee the method used to release

material from the restricted area and observed technicians performing

release surveys for material.

The inspector observed personrel using the personnel frisker (RM-14/RM-16

with HP-210 pancake probe) to perform contamination surveys of themselves

, while inside the Radiation Controlled Area (RCA). The inspector also

observed personnel performing contamination surveys of themselves using

the PCM-1Bs, Personnel Contamination Monitors, while exiting the RCA.

During the inspection, current radiation survey instrumentation

calibration and performance check program implementation was reviewed.

The inspector observed and discussed with cognizant health physics

technicians selected survey instrumentation calibrations as detailed in

HPP 406, Radiation Protection Instrumentation Calibration Procedures,

December 5,1985, and HPP-414, Calibration and Operation of Eberline

PCM-16 Personnel Contamination Monitor, October 14, 1985. Calibrations,

respan.ee checks, and sensitivity limits as required by procedures for

, selected survey instrumentation in use by plant personnel were reviewed.

The inspector reviewed selected radiation work permits in effect in the

RCA and datermined that adequate controls were specified and ALARA

considerations had been made.

The inspector performed independent radiation surveys of selected areas

outside the RCA and outside the Protected Area (PA) using NRC survey

equipment. Areas surveyed included posted and controlled areas within the

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PA and equipment warehouses outside the PA. The survey results were

consistent with area postings and licensee controls for the areas.

The inspector discussed with the Radiation Protection Manager the total '

contaminated area within the Radiation Controlled Area (RCA). The

inspector was informed that 8,500 ft2 out of 66,100 ft2 was considered

contaminated, which is 12.9% of the RCA. The licensee had not set a goal j

for 1987 to further reduce the total contaminated area inside the RCA,  !

other than maintain the area which is now considered radiologically clean i

due to ALARA considerations and that the remaining areas were not accessed  ;

on a routine basis.

No violations or deviations were identified. l

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6. Internal Exposure Control and Assessment (83725)

a. 10 CFR 20.103(a) . establishes the limits for exposure of ir.dividuals

to concentrations of radioactive materials in air in restricted

areas. This section also requires that suitable measurements of

concentrations of radioactive materials in air be p.3rformed to detect

and evaluate the airborne radioactivity in restricted areas and that

appropriate bioassays be performed to detect and assess individual

intakes of radioactivity.

The inspector reviewed selected results of geberal in-plant air

samples taken during the period January to March 1987 and the results

of air samples taken to support work authorized by specific radiation

work permits.

The inspector reviewed selected results of bioassays (whole body

counts) and the licensee's assessment of individual intakes of

radioactive material performed during the period October 1986 to

March 1987.

No violations or deviations were identified.

b. 10 CFR 20.103(b) requires the licensee to use process or other

engineering controls, to the extent practicable, to limit

concentrations of radioactive material in air to levels below that

specified in Part 20, Appendix B, Table 1, Column 1 or limit

concentrations, when averaged over the number of hours in any week

during which individuals are in the area, to less than 25 percent of

the specified concentrations.

The use of process and engineering controls to limit airborne

radioactivity concentrations in the plant was discussed with licensee

representatives and the use of such controls was observed during

tours of the plant.

No violations or deviations were identified.

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c. 10 CFR 20.103(b) requires that when it is impracticable to apply

process or engineering controls to limit concentrations of

radioactive material in air below 25 percent of the concentrations

specified in Appendix B, Table 1, Column 1, other precautionary

. measures, such as use of respiratory protection, should be used to

maintain the intake of radioactive material by any individual within

seven consecutive days as far below 40 MPC-hours as is reasonably

achievable.

By review of records observations and discussions with licensee

representatives, the inspector evaluated the licensee's respiratory

protection program, including medical qualifications, - fit testing,

MPC-hour controls, quality of breathing air, and the issue, use,

decontamination, repair and storage of respirators.

The inspector reviewed the following plant procedures which

established the licensee's internal exposure control and assessment

program and verified that the procedures were consistent with

. 10 CFR Part 20, Technical Specifications and good health physics

' practices:

HPP-501, Respirator Issue and Return

HPP-502, Respirator Inspection and Quality Checks

HPP-505, Respirator Qualitative and Quantitative Fit Testing

HPP-506, Respirator Leak Test

HPP-510, Breathing Air Service Use

RP-230, MPC Hour Calculation Procedure

RSP-500, Health Physics Respiratory Qualification Program

RSP-501, Respirator Issue Use and Return

No violations or deviations were identified,

d. 10 CFR 20.103(c)(2) requires that the licensee maintain and implement

a respiratory protection program that includes, as a minimum, written

procedures regarding selection, fitting and training of personnel.

Chemistry and Radiation Protection Procedure, HPP-501, dated

l September 23, 1986, Respiratory Issue and Return, Section 3.1.1

specified the licensee's requirements for issuance of respiratory

protection equipment.

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Emergency Plan Implementing procedure, EM-208, dated April 3,1986,

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Duties of the Radiation Emergency Team, Section 2.3 specified the

i licensee's respiratory protection qualification requirements for

emergency team members.

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On November 22, 1986, the plant was in hot standby (Mode 3)

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condition. Plant operators observed an increase in the Nuclear

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Services' Closed Cycle Cooling (SW) system activity with a

corresponding increase in the system's surge tank level. Monitoring

of the makeup and purification system's makeup tank revealed that a

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reactor coolant system to SW system leak had occurred. The leakage

rate was estimated at four gallons per minute (gpm). An unusual

event was declared and a plant cooldown was comenced in accordance

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wis Ta; . is 4ccification (TS) 3.4.6.2.b. Licensee management

representatives decided to send a licensed operator into the Reactor

Building (RB) to investigate the source of leakage. However, the

operator chosen for the task was not respiratory qualified to wear

the Scott Self-Contained Breathing Apparatus (SCBA). The individual

.had not been trained to wear the SCBA. Licensee management was

informed of this problem and nevertheless decided to send the

operator who was not qualified into the RB wearing the Scott SCBA

respiratory equipment because he was considered by management to

be the best qualified person onsite to investigate the source of

leakage. The inspector discussed this event with licensee management

. representatives and was informed that, since the plant was in an

emergency condition (unusual event) they had made a conscious

decision to send the unqualified operator into containment to

investigate the source of leakage. The inspector informed licensee

. management that failure to have adequate respiratory protection

procedures in place to ensure that nuclear operators were qualified

to wear respiratory protective equipment necessary for them to

perform their duties was an apparent violation of 10 CFR 20.103(c)(2)

(50-302/87-09-01),

e. 10 CFR 20.201(b) re

such surveys as (1)necessary

quires each forlicensee to make

the licensee or cause

to comply withtothebe made

regulations in this part and (2) are reasonable under the

circumstances to evaluate the extent of radiation hazards that may be

present.

10 CFR 20.103(c)(2) requires the licensee to maintain and implement a

respiratory protection program that includes surveys and bioassay as

appropriate to evaluate actual exposures.

The licensee conducted entrance, termination, and routine annual

whole body (in vivo) radiological surveys of personnel who could be

exposed to airborne radioactive material. The inspector reviewed and

discussed with cognizant licensee representatives the following

procedures concerning implementation of the whole body counting

program:

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HPP-320, Whole Body Counting System Operation, December 9, 1986

- HPP-321, Whole Body Counting System Linear Energy Calibration

and Quality Control Check, May 13, 1986

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HPP-322, Whole Body Counting System Calibration, May 2, 1985

The inspector reviewed and verified calibration and performance data

for the whole body system during 1987. HPP-320 requires baseline

whole body counting for all personnel which could be exposed to

airborne radioactive material (Section 2.1.1); notification of the

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Health Physics Supervisor (HP3) if the total body burden is in excess-

of 1% MP0B (Section 2.6); ir.put of infonnation co the computer system

as requested by the whole body counting jobstream menu (Section

3.1.2); and positioning of the individual in the whole body chair

such that the detectors are centered on, and as close to the body

part being counted by the detector as possible (Section 3.1.5).

During observations of whole body counting analyses in progress, the

inspector noted that the whole body chair adjustments were not

functional, that is, vertical adjustments to position an individual

in front of the detector were not being conducted. Failure to make a

vertical adjustment resulted in the thyroid detector being 3 or 4

inches below the critical organ. Review of records for whole body

analyses conducted for selected individuals during March 9-13, 1987,

determined that identical (inaccurate) chair position coordinates

were entered into the software program utilized for final data

analysis. Furthermore, records for selected personnel indicated

positive maximum permissible organ burden (MP08) values (flagged at

greater than 1% MP0B), which should have been evaluated prior to

allowing entry into the radiation controlled area, were not

questioned prior to clearing the personnel for access to the plant.

Licensee representatives indicated that they suspected that the

positive values had resulted from high background concentrations of

naturally occurring radionuclides. The inspector noted that the

licensee did not conduct routine background measurements for the

whole body system to verify this assumption. The failure of the

licensee to perform adequate in vivo (whole body) radiation surveys

was identified as an apparent violation of 10 CFR 20.201(b)

(50-302/87-09-02).

7. External Exposure Control (83724)

10 CFR 20.101(a) specified the quarterly radiation exposure limits for

individuals in restricted areas.

10 CFR 20.401(a) requires each licensee to maintain records showing the

radiation exposures of all individuals for whom personnel monitoring is

required by 10 CFR 20.202 and that such records be kept on Form NRC-5 or

equivalent in accordance with the instructions contained on the form.

Form NRC-5, Instructions for Preparation of Form NRC-5, item 5, requires

that, unless the eyes are protected with eye shields having a tissue

equivalent density thickness of at least 700 milligrams per square

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centimeter, dose recorded as whole body dose should include dose delivered

through a tissue equivalent absorber having a density thickness of

300 milligrams per square centimeter or less.

The inspector reviewed radiation exposure records of personnel monitored

by the licensee during the past year and verified that individual

exposures were maintained below quarterly limits.

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The inspector discussed skin dose assessment methodology with licensee

representatives and reviewed a dose assessment that had been performed for

an individual found to have a mixture of contaminants with a total

activity of 0.11 microcuries in a localized trea on. his foot. The

licensee had calculated and assigned a skin dose to the individual of

513 millirem. The inspector independently verified that the dose

assessment was reasonable.

The inspector discussed with licensee representatives the results they

have obtained from a new vendor thermoluminescent dosimeter (TLD) service

that had been in use for approximately a year. The licensee had been

avaluating the accuracy of beta radiation monitoring using the new TLD

System and had been pursuing resolution of the matter with the TLD

vendor. The inspector reviewed the licensee's documentation of the

problem and correspondence between them and the vendor. The inspector

determined that the licensee's actions to obtain resolution of this

problem had been adequate. The inspector obtained a quantity of vendor

TLDs from the licensee so that they can be irradiated by an NRC

contractor.' After irradiation, the TLDs will be returned to the licensee

for normal processing. The results of the TLD study and the licensee's

action to resolve the suspected inaccuracies in their TLDs will be

reviewed during future inspections (50-302/87-09-03).

No violations or deviations were identified.

8. Solid Waste (84722)

10 CFR 20.311(d)(1) requires that any generating licensee who transfers

radioactive waste to a land disposal facility prepare all wastes so that

the waste is classified according to 10 CFR 61.55 and meets the waste

characteristics requirements in 10 CFR 61.56.

The inspector discussed with licensee representatives their program of

waste stream sampling in order to develop waste cla:sification scaling

factors. The licensee obtained quarterly samples of the following waste

streams: RCS liquid, composite RCS filtered crud, spent fuel pool liquid

and miscellaneous waste storage tank liquid. In order to classify dry

active waste (DAW), composite smears were taken in plant areas from which

waste was generated, on noncompactable waste being placed into disposal

packages and on the drum compactor ram. Samples were sent to a contractor

laboratory for analysis on an annual basis. The remaining three quarterly

samples were retained in case additional analyses were required. The

inspector reviewed waste classification determinations filed with selected

shipping records.

The licensee ensured waste stability through use of high integrity

containers and by solidification using an onsite vendor operated process.

The inspector toured the solidification area and observed contractor

technicians performing solidification tests.

No violations or deviations were identified.

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9. Transportation of Radioactive Material (86721)

j 10CFR71.5(a) 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

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with the' applicable requirements of the regulations appropriate to the

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mode of transport of the Department of Transportation in 49 CFR Parts 170

through 189.

49CFR173.475(1) requires that before each shipment of any radioactive

.. mater f als package, the shipper shall ensure by examination or appropriate

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tests, that external radiation and contamination levels are within the

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allowable limits.

49 CFR 173.441(b)(2) requires that the radiation level may not exceed

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200 millirem per hour at any point on the outer surface of exclusive use

closed transport vehicles, including the upper and lower surfaces.

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49 CFR 173.427(c) requires that a packaging which previously contained

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radioactive materials and has been emptied of contents as far as

practical, is excepted from the shipping paper and certification, marking,

. and labeling requirements provided that internal contamination does not

exceed 100 times the limits in 49 CFR 173.443.

i 49 CFR 172.202(a) requires that the shipping description of a hazardous

material .on a shipping paper must include the proper shipping name

prescribed for the material and the identification number.

The inspector reviewed records of licensee radioactive material shipments

! performed during 1986 and 1987.

Shipment Number 87-15, consisting of compacted radioactive waste in

55-gallon drums, was shipped to the radioactive waste disposal facility

near Barnwell, South Carolina on March 5,1987. The shipment was

classified as low specific activity (LSA) and was transported in an ,

l exclusive use, closed transport vehicle. The inspector noted that the '

documentation of the preshipment radiological surveys included with the

, shipping paperwork did not show any surveys of the top outer surface of

the transport vehicle. Licensee representatives stated that surveys of

the tops of exclusive use closed transport vehicles were not routinely

performed. The inspector stated that since a radiation level limit for

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the vehicle tops is specifically stated in 49 CFR 173.441(b)(2), then the  ;

preshipment surveys required by 49 CFR 173.475(1) have to include i

measurements at that location. Failure of the licensee to perform these

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surveys was identified as an apparent violation of 10 CFR 71.5(a)

(50-302/87-09-04).

On January 15, 1987, the licensee received a new high integrity container ,

, (HIC) packaged inside of a 8-120A-2 shipping cask. The rented cask and j

new HIC had been shipped together since they were being obtained from the ,

i same vendor. As part of the receipt ir.spection, the cask lid was removed l

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. 9rd the HIC was partially raised -in order to perform a contamination

. su'rvey. Contamination levels of approximately 20,000 disintegrations per

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mir!ute (dpm) were found on a wide area wipe on the outside of the HIC.

i The licensee decided to send the HIC and cask back to the vendor since new

HICs were stored outside and were controlled as uncontaminated. The

licensee also performed contamination surveys of the sealing area of the

cask, cask lid, bolt holes in the sealing area and one smear approximately

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two feet down on the inside of the cask. The highest contamination found

on the nine smears that were taken was 200,000 dpm/100 cme in the sealing

area on the top of the cask. The cask and HIC were shipped to the vendor

the same day using the empty packaging exception in 49 CFR 173.427(c).

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The inspector discussed the contamination surveys that had been taken on

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the cask with licensee representatives and the health physics technician

who had performed the survey. The inspector determined that contamination

surveys that had been performed by the licensee were not' adequate to

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demonstrate that the shipment met the empty packaging exception criteria

j in 49 CFR 173.427(c). Casks are typically contaminated internally due to  !

spillage from the HIC during loading and handling, resulting in the area

of the cask bottom presenting the highest internal contamination

potential. The survey results from the sealing area of the cask of

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'200,000 dpm/100 cm2 was only 20,000 dpm less than the limit permitted by

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49 CFR 173.427(c) and a more comprehensive survey of the cask internals

may have found contamination levels above the limit. Failure of the

licensee to perform adequate contamination surveys of the cask internals

to demonstrate that the levels met the empty packaging criteria was

identified as another example of an apparent violation of 10 CFR 71.5(a)

(50-302/87-09-04).

On March 17, 1986, the licensee shipped a radiac calibrator containing a

154.6 curie Cesium-137 source to the vendor under Control Number 86-16.

I The inspector reviewed the shipping documentation and determined that the

source had been properly classified and packaged in an approved Type B

container. The shipping papers described the material as Radioactive  ;

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Material, N.O.S., UN 2911. The Hazardous Materials Table in j

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49 CFR 172.101 gives the proper shipping name and identification number of j

a sealed radioactive source as Radioactive Material, Special Form, N.0.S.,

UN 2974. Failure of the licensee to use the correct proper shipping name

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and identification number to describe the calibrator on the shipping

4 papers was identified as another example of an apparent violation of ~

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10 CFR 71.5(a) (50-302/87-09-04). ,

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On August 11, 1986, the licensee received a warning letter from the State l

of South Carolina Department of Health and Environmental Control

concerning the licensee's failure to sign the two certification statements

! on the Barnwell Waste Management Facility's Radioactive Shipment Manifest

form for Shipment Number 0886-078-A on August 7, 1986. Signed shipper

certification statements are required by 49 CFR 172.205(a) and

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49 CFR 172.204(a). The inspector reviewed the documentation of the

shioment and determined that the licensee had included signed

cert.ification statements of the type required by 49 CFR Part 172 on other

forms included with the shipping papers, but the duplicate statements on i

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the disposal site's manifest form had not been signed. The inspector

determined that there had been no violation of NRC requirements since at

least one certification statement of each type required had been signed.

10. InspectorFollowupItems(IFI)(92701)

a. (Closed) IFI (50-302/86-26-01) Development of a procedure to derive

scaling factors for letdown filters. The inspector reviewed letdown

filter sampling techniques that had been added to the licensee's

radioactive waste transportation procedure, WP-101. The inspector

determined that the sampling procedure was adequate.

b. (Closed) IFI (50-302/86-26-03) Long-term corrective action for

contaminated tools offsite. See Paragraph 3 9 for details.

11. IE Information Notices (92717)

The inspector determined that the following NRC Information Notices (IEN)

had been received by the licensee, revirwed for applicability, distributed

to appropriate personnel and that actions, as appropriate, were taken or

scheduled,

a. IEN 85-48: Respirator Users Notice: Defective Self-contained

Breathing Apparatus Air Cylinders

b. IEN 85-60: Defective Negative-pressure, Air-purifying Full Facepiece

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Respirators

c. IEN 85-81: Problems Resulting in Erroneously High Reading with

Panasonic 800 Series Thermoluminescent Dosimeters

d. IEN 85-87: Hazards of Inerting Atmospheres

e. IEN 85-92: Surveys of Wastes Before Disposal from Nuclear Reactor

Facilities

f. IEN 85-97: Jail Term for Former Contractor Employee Who

Intentionally Falsified Welding Inspection Records

g. IEN 86-22: Low-Level Radioactive Waste Scaling Factors,

10 CFR Part 61

h. IEN 86-22: Underresponse of Radiation Survey Instrument to High

Radiation Fields

1. IEN 86-23: Excessive Skin Exposure Due to Contamination with Hot

Particles

J. IEN 86-24: Respirator Users Notice: Increased Inspection Frequency

for Certain Self-contained Breathing Apparatus Air Cylinders

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k. IEN 86-41: Evaluation of Questionable Exposure Readings of Licensee

Personnel Dosimeters

1. IEN 86-42: Improper Maintenance of Radiation Monitoring Systems

m. IEN 86-43: Problems with Silver Zeolite Sampling of Airborne

Radiciodine

n. IEN 86-44: Failure to Follow Procedures When Working in High

Radiation Areas

o. IEN 86-46: Improper Cleaning and Decontamination of Respiratory

Protection Equipment

p. IEN 86-103: Respirator Coupling Nut Assembly Failures

q. IEN 86-107: Entry Into PWR Cavity with Retractable Incore Detector

Thimbles Withdrawn

r. IEN 87-03: Segregation of Hazardous and Low-Level Radioactive Wastes

s. IEN 87-07: Quality' Control of Onsite Dewatering / Solidification

Operations by Outside Contractors

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