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Insp Rept 50-424/87-52 on 870831-0904.Violation Noted.Major Areas Inspected:Training & Qualifications,External & Internal Exposure Control,Facilities & Equipment,Alara Program,Transportation & Followup on IE Info Notices
	ML20235J315
Person / Time
Site:	Vogtle
Issue date:	09/17/1987
From:	Hosey C, Weddington R; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20235J288	List: ML20235J284; ML20235J302; ML20235J315;
References
	50-424-87-52, IEIN-87-003, IEIN-87-007, IEIN-87-031, IEIN-87-3, IEIN-87-31, IEIN-87-7, NUDOCS 8710010398
	Download: ML20235J315 (10)
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@ Moog UNITED STATES

,%'f NUCLEAR REGULATORY COMMISSION

l.[ [ ~ ' n_ REGION il

5.

j- 101 MARIETTA STREET, N.W.

'2 - ATLANTA, GEORGI A 30323

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SEP 2 41987 .

Report No.: 50-424/87-52'

Licensee: Georgia Power Company ,

P. 0. Box 4545

Atlanta, Georgia 30302

Docket No. 50-424 License No.: NPF-68

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Facility Name: Vogtle Electric Generating Plant

Inspection Conducted: August 31 - September 4, 1987

Inspector: /r/ ( #22

l R. E. W#ddington V Date Signed

Accompanying Personnel: R. B. 'Shor_tridge

Approved by: /d4 M' 7W 8[/7[87

fgp C. M.' Hosey, Section Chief. Date Signed

t Division of Radiation Safety and Safeguards

-SUMMARY

Scope: This routine, unannounced inspection was. conducted _in the areas of

training and qualifications, external exposure control, internal exposure

control, facilities and equipment, licensee's program for maintaining exposure-

as low as reasonably achievable (ALARA), transportation,' licensee action on

previous ' enforcement matters, followup on inspector identified items - and-

followup on IE Information Notices.

Results: One violation for failure to adequately control access. to a high

radiation area was identified.

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REPORT DETAILS

1. Persons Contacted j

Licensee Employees ]

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G. Bockhold, General Manager l

T. Greene, Plant' Manager. .

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S. C. Ewald, Manager, Health Physics and Chemistry

I. A. Kochery, Health Physics Superintendent

A. E. Desrosiers, Health Physics Support Superintendent

W. C. Gabbard, Senior Regulatory Specialist ;

C. E. Belflower, Quality Assurance Site Manager

R. M. Odom, Plant Engineering Supervisor

J. E. Swartzwelder, Deputy Manager of Operations ,

E. M. Dannemiller, Technical Assistant to the General Manager i

J. B. Beasley, Manager Outages and Planning !

M. A. Biron, Health Physics Supervisor j

M. H. Kurtzman, Supervisor Health Physics and Chemistry Training i

R. D. Baker, Nuclear Licensing Manager j

C. L. Cross, Senior Regulatory Specialist l

J. L. Wilcox, Quality Assurance

D. F. Hallman, Chemistry Superintendent

H. Handfinger, Unit 2 Project Startup Manager

W. F. Kitchens, Operations Manager !

R. A. Glasby, Bechtel Production Manager i

J. D. Hurd, Bechtel Deputy Manager 1

R. L. LeGrand, Waste Management Superintendent

J. F. Lucot, Health Physics Supervisor i

K. W. Duquette, Health Physics Supervisor

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J. L. McKnight, Health Physics Support Supervisor i

G. Tressler, Health Physics Foreman

M. Seepe, Radwaste Supervisor

Other licensee employees contacted included technicians, security officers

and office personnel.

Nuclear Regulatory Commission

J. Rogge, Senior Resident Inspector

C W. Burger, Resident Inspector

R. J. Schepens, Resident Inspector

Attended exit interview

2. Exit Interview (30703)

The inspection scope and findings were summarized on September 4,1987,

with those persons indicated in Paragraph 1 above. The followirig issues

were discussed in detail: (1) an apparent violation for failure to

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adequately control access to a high radiation area (Paragraph 5.e) and

(2) failure to take full corrective actions for a previous violation

(Paragraph 3.c). Licensee representatives acknowledged the inspection

findings and took no exceptions. The licensee did not identify as

proprietary any of the materials provided to or reviewed by the inspector

during this inspection.

3. Licensee Action on Previous Enforcement Matters (92702)

a. (Closed) Violation (50-424/87-30-01) Failure to post a radiation

area. The inspector reviewed the licensee's response dated June 26,

1987, and verified that the corrective actions as specified had been

completed.

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b. (Closed) Violation (50-424/87-30-02) Failure to maintain a record of

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a radiation survey. The inspector reviewed the licensee's response-

l dated June 26, 1987, and verified that the corrective actions as

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specified had been completed,

c. (0 pen) Violation (50-424/87-35-01) Failure to perform adequate

startup shield verification radiation surveys. The inspector

reviewed the licensee's response dated July 23, 1987, to verify that

the corrective actions specified in the response had been completed.

The licensee's response stated that the 100 percent power survey

portion of Startup Test Procedure 1-600-05 had been changed to

incorporate the recommendations of ANSI /ANS 6.3.1-1980 that were i

referenced in the Notice of Violation. The inspector reviewed the j

changes that had been made to the procedure and observed that one of j

the elements of the Notice of Violation, surveys of horizontal shield

sections, had not been included in the procedure change. Licensee

l representatives stated that such surveys had been performed, but that

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the requirement to do these surveys had been included in the written .

prejob briefing instead of the procedure. The inspector reviewed the !

documentation of the 100 percent power shield verification survey

that had been completed on May 29, 1987. The inspector noted that ,

almost one half of the survey locations that had been included in the

30 and 50 percent surveys were deleted from the 100 percent power

survey. There was not sufficient documentation in the record to

explain the justification for eliminating the survey locations. For s

example, survey location RB172 was deleted after the 30 percent power

level showed a radiation level of less than two millf rem per hour.

The record stated that the survey had demonstrated that the shielding

was adequate. Other survey locations with the same initial readings

were not excluded. The inspector also noted that for some survey

locations, radiation levels. decreased as the power level increased. j

Such discrepancies were not identified or resolved in the record. !

There was also no documentation of the extrapolation of lower power ]

level survey results to full power. The - survey report had been j

reviewed by health physics management and the plant review board j

without apparent comment. Licensee representatives acknowledged that j

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there were apparent discrepancies in the documentation of the . shield .

su rvey.

4. -TrainingandQualifications(83723) ,

Technical Specification 6.3.1 requires that a retraining and replacement'

training program for the plant staff shall be maintained. Personnel will '

meet the minimum education and experience recommendations of l

ANSI N18.1-1971.. ;

.The inspector discussed the health physics technician training program ';

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with licensee representatives. The licensee : was in.. the process of . j

obtaining INP0 accreditation for their program. 'They had submitted their l

safety evaluation report 'and expected- the INP0 site visit in November -

1987.

The inspector' discussed the' health physics portion of the general employee

training (GET) program. with licensee representatives. . The training

consisted of eight and one half hours formal classroom instruction

followed by a protective clothing dressout exercise and an examination.

Other special training, such as respiratory protection'. and advanced ,

radiation worker, were conducted following initial GET.

No violations or deviations were identified.

5. External Exposure Control (83524)

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a. 10 CFR 20.101.a specifies the quarterly' occupational exposure limits

for the whole body, extremities 'and skin of the whole body.

10 CFR 20.401(a) requires that each licensee'shall maintain records

showing the radiation exposures of all individuals for whom personnel >

monitoring is required. Such records shall be kept on Form NRC-5, in- !

accordance with the instructions contained in that form or'on clear

and legible records containing all the information required by '

Form NRC-5.

The inspector reviewed records of licensee employee exposures during y

1987 and verified that the exposures were below the applicable -

regulatory limits and were maintained as required.: .

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No violations or deviations'were identified.

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

such surveys as may be necessary for the licensee to comply with the

regulations in 10 CFR 20 and are reasonable under the circumstances

to evaluate the extent' of radiation-hazards that may be present. -!

The inspector reviewed selected records' of radiation and

! contamination surveys performed by the licensee. During tours of the. ;

l- facility, the inspector performed independent radiation surveys and

found'no inconsistencies with licensee survey results.

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The inspector discussed with licensee. representatives the means used

to evaluate exposures due to noble gases during containment entries.

Licensee Procedure 43006-C, Containment Entry, required that a noble

gas grab sample be taken during the containment entry. Procedure

44015-C detailed a methodology for estimating the skin dose based on !

the noble gas concentration and stay time. The procedure required

recording of doses in excess of 10 millirem. The inspector stated

that the dose to concentration conversion factors in the procedure

appeared to be low and requested that the licensee explain the bases

for their dose. factors. The inspector determined.that the licensee's

dose factors were based on beta exposure only and did not account for

exposure from low energy photons. Licensee' representatives

acknowledged the inspector's comment and. stated that they would j

ensure that such exposures were properly evaluated, however no noble

gas exposures requiring assessment had yet' occurred at the facility.

The inspector discussed with licensee representatives their methods

of assessing neutron exposures. The licensee was in the process of

performing validation studies on a vendor supplied neutron

thermoluminescent dosimeter (TLD). Personnel entering neutron 'l

exposure areas wore the neutron TLD and a calculation was also ]

performed to estimate their exposure based on dose rates and stay j

times. The inspector reviewed selected records of neutron monitoring '

that had been performed in 1987. ;

The inspector reviewed records of and discussed with licensee

representatives a series of containment entries that had been made

during the period of August 29-31, 1987, while the reactor was at !

full power. Personnel entered containment to investigate. an 1

indication of a possibl

Radiation Work Permit RWP)

(y defective RCS

87-0302 waspressure

prepared transmitter,

for the entry.PT405.

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steam leak was found in the vicinity of the pressure transmitter, but j

the personnel could not safely approach close enough .to_ access a !

valve to isolate the leak. Another alternative.was to approach the

leaking line from inside the bioshield and access a isolation valve

further upstream. RWP 87-0303 was prepared for this task. Licensee

health physics personnel determined that the - task could be

, accomplished within allowable exposure limits without requiring the

I reduction of power level. The personnel making the entry were given

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exposure extensions to 2,500 millirem for the quarter. Health

physics personnel with the entry team found maximum exposure rates of

15 rem / hour gamma radiation and 4 rem / hour neutron radiation. The

pressure transmitter was successfully isolated. The highest exposure

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received by any individual on the entry was 73 millirem neutron and

109 millirem gamma. j

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No violations or deviations were identified. !

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Technical Specification 6.11.2 requires that areas accessible to

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l personnel with radiation levels greater than 1,000 millirem / hour at

45 cm (18 in) from the radiation source or from any surface which the

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radiation- penetrates shall be provided with locked doors to prevent

unauthorized entry, 'and the. keys shall be mainteined under the

administrative control of the shif t 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 immediate work areas and the maximum. i

allowable stay time for individuals'in that area.

A previous NRC physical security inspection- (Inspection Report

No. 50-424/87-50) identified a potential problem with .the high

radiation area controls on the Unit 1 containment personnel access.

The personnel access consisted.of two air-lock doors. The licensee

had constructed a cage of metal bars around the outer access door.

The cage door was provided with an~ electronic lock and card reader.

The licensee had reported that they had discovered on August 3,.1987, !

that the spacing of the bars on the top of the cage was such that a i

person.could squeeze through the opening.

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The inspector reviewed the high radiation area controls that had been

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in place for the containment access. During periods of authorized

access to containment, the card reader was deactivated and access was

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limited to authorized personnel working under an approved RWP.

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During the remaining times, the card reader was activated and served L

i as the only access control. Anyone with approved access to the

containment area could gain access to the cage and then would only

have to operate the air lock to gain access to the high radiation

areas in containment. Such entry could be made without the knowledge 1

of health physics and without an approved RWP. When the cage door l

was opened, an alarm sounded in the security central alarm station j

and a security guard would. be sent to_ investigate. . Licensee j

representatives stated that they have had to respond.to such alarms i

in the past and have found individuals inside the cage, although no j

i one recalled anyone actually making an unauthorized entry into- ,

containment. The licensee recognized the problem with ,this .

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arrangement and installed a health physics high radiation area lock e

on the door after the August 3,1987, event. Failure to provide high '

radiation area controls for Unit 1 containment personnel access was

identified as an apparent violation of Technical Specification 6.11.2 )

(50-424/87-52-01).

6. Internal Exposure Control (83725) )

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a. 10 CFR 20.103(c)(2) requires that the licensee may make allowance 'for !

use of respiratory protective equipment in estimating exposures of .)

individuals provided that the licensee maintains and implements a

respiratory protection program that includes, as a minimum: air ]

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sampling sufficient to identify the hazard, permit proper equipment 3

selection and estimate exposures, surveys and bioassays as

I appropriate to evaluate actual exposures; written procedures

regarding selection, fitting and maintenance of respirators, and

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testing of respirators for operability immediately prior to each use,

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and written . procedures regarding supervision and' training of

personnel and issuance records.

The inspector reviewed selected records of air sampling performed

during 1987. The sample results did not indicate < any'significant

airborne radioactivity. The' inspector toured the licensee's

respirator issue facility. The licensee maintained a log .of ;

respirators by serial number. that had been issued to individuals.

The licensee maintained a mask decontamination and repair area

adjacent to the issue area. The inspector reviewed. the documentation

at the issue area. used by the -licensee to verify that individuals -

were qualified to wear respiratory protective devices.

No violations or deviations were identified.. ;

b. 10 CFR 20.103(a)(3)' requires Lthat the licensee shall . use. suitable . j

measurements of concentrations. of. radioactive materials in air for i

detecting and evaluating airborne radioactivity in restricted areas !

and in addition, as appropriate, shall use measurements of ,

l radioactivity in the body, measurements of radioactivity excreted

from the body, or any combination of such measurements as may be

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of radioactivity by exposed individuals.

The inspector discussed .the operation of the whole body counter. with

licensee representatives and reviewed selected records of whole body

counts performed during 1987. On June 8,1987, a whole. body count

was performed on an incoming contractor employee. The initial count

indicated the employee had internally deposited activity of.

approximately 30 nanocuries. A second count was performed with

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approximately the same result. The employee was then given a paper

suit to wear instead of his personal clothing: and then recounted.

This count result was 3.7 nanocuries,. indicating that. the activity

was contamination on the person's clothing and - not internally

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deposited radioactivity. The licensee contacted the individual's

previous employer (another NRC licensed facility in NRC Region.1) and

was informed that the individual had been given two showers.and a-

count in a paper . suit prior to being . released from their facility.

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The employee's personal clothing was returned to him and- he was

allowed to continue his in-processing. The inspector was: told that

the individual's clothing had not been surveyed for contamination ;

although the activity indicated on' the' initial count may have been

detectable with a frisker. There was no frisker in the whole. body-

The inspector ' discussed -with licensee

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counting area.

representatives, the need for performing a survey to release the

individual. Licensee representatives -acknowledged the comment and

stated that they would attempt to locate the individual and survey

his personal clothing.

No violations or deviation's were identified.

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- c. 10 CFR.20.103(b)(1) requires' that the licensee shall, as a

precautionary procedure, use' process; or other, engineering controls _,

to the extent practicable, to limit concentrations of radioactive ,

materials in air to-levels below those which delimit an airborne 'j

radioactivity area. lq

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During. tours of the facility' the inspector obse' ved

engineering controls. The inspector observed ' ventilated hoods,. ,

enclosures and use of. portable ventilation units. 1

No violations or deviations were identified.

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7. FacilitiesandEquipment'(83727)'

The inspector discussed with licensee representatives proposed cha'nges to j

existing facilities in the? radioactive waste and , dosimetry areas.- No j

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changes had been implemented since the previous inspection.-

No violations or deviations were identified.

8. ' Licensee's . Program for Maintaining Exposures. As Low As Reasonably

Achievable-(ALARA) (83728) l

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10 CFR 20.1(c) specified tFat licensee's should' implement programs ' to 1

maintain workers' doses ALARA.- Other recommended elements of an , ALARA -

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program were contained in Regulatory Guides 8.8 and 8.10.

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The inspector discussed the ' licensee's ALARA~ program. with licensee- i

representatives. The licensee _ had not' implemented any' significant

portions of their program due to the low amount of' exposure work- that had

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No violations or deviations were identified.

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9. Transportation (86740)

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10 CFR 71.5(a) requires each licensee who transports licensed material- '!

outside. of the confines cf its - plant or other place 'of use, or who. ;

delivers licensed material to a carrier for transport,- shall comply with i

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the applicable requirements of the regulations appropriate to the mode _ of - 1

transport of the Department of Transportation in 49 CFR Parts 170 through- 1

189.

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.The inspector discussed the licensee's transportation program with'

licensee representatives. A new supervisor had recently:been appointed in- l

the transportation area. -He was in the process of reviewing and revising. j

the section's transportation procedures. The licensee had not yet made a ~

radioactive waste shipment.

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Until the: radwaste facility is completed, the licensee uses a temporary

radwaste-facility to compact boxes of radioactive waste and to dewater and

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solidify other wastes. Waste packing services were performed by a vendor. ]

The inspector reviewed NRC approved topical reports for the vendor.

activities. The inspector toured the facility and noted that spill

control and exposure control considerations had been incorporated into the

design of the facility. <

The inspector toured outside. radwaste storage areas where boxes of

radwaste were temporarily. stored awaiting disposal. The inspector,noted ;

that the labels on most of the boxes were faded and were.not. legible. The

licensee responding by relabeling the containers and protecting the labels

with plastic. The inspector determined that the highest activity in any

box was less than 3 microcuries of principally Co-58, which did not

require labeling by the criteria of 10 CFR 20.203(f).

No violations or deviations were identified.

10. FollowuponInspectorIdentifiedItems(92701)

a. (Closed) Inspector Followup Item (IFI) (50-424/87-18-03) Surveys of

tools for release when the tool. monitor is out of service. The

inspector reviewed licensee Procedsre 43555-C, Operation and Use of

the Tool Monitor, Revision 9, August 14, 1987. The procedure stated

that when the tool monitor is out of service, workers may survey-

personal hand carried items for release using hand held friskers.

All other items were required to be surveyed by health physics

personnel. The inspector determined that this practice was

acceptable.

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b. (Closed) IFI (50-424/87-18-05) Annotation of calibration dates on

stickers. Each portable instrument had a sticker indicating when the

instrument had been calibrated and when it was due. It had been

noticed that the licensee did not consider the calibration period to

begin until the instrument was first issued to a user. The time-

elapsed between when an instrument was calibrated and when it was

issued was not counted against the calibration interval. Licensee

representatives stated that they now considered the calibration

interval to begin as soon as the instrument was calibrated. The

inspector reviewed several instrument calibration procedures and

verified that the correct instructions' had. been placed in the

procedures. The inspector also examined several recently calibrated

instruments and verified that the calibration stickers were properly

annotated. The inspector determined that the licensee had adequately-

responded to this item.

c. (Closed) IFI (50-424/87-18-06) Review of personnel frisking

practices. During tours of the facility the inspector observed

personnel performing personal contamination surveys. These surveys

were being performed in an acceptable manner.

d. (Closed) IFI (50-424/87-18-07) Advanced radiation worker

qualification. This item was opened when it was learned that it was

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being planned to. allow some' workers! to perform their own radiation.

surveys without . assistance- from.. health physics personnel in ' areas !

with dose rates .up. to I rem / hour. The licensee had developed such a

training- program and had qualified several- radwaste personnel. The

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training consisted. of two days of forma 1 instruction- including !

practical survey exercises. The' inspector reviewed' the training 1

program and found it consistent with regulatory requirements. )

e. (Clostd) IFI (50-424/87-18-08) Completion of- radwaste operator ,

qualification journals. . The inspector discussed the radwaste

operator. qualification program with licensee representatives., The- !

operators ha'd completed the1 qualification cards related to their i

major . Job responsibilities and had completed advanced ' radiation l

worker training. -The inspector determined the licensee's actions on l

this. item were acceptable; ]

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11. IE Information Notice (IEN) (92717)

The inspector determined that the following information notices had been .!

received by the. licensee, reviewed for applicability, distributed to

appropriate personnel. and that action, as appropriate, wasL takenL or

scheduled.

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

IEN 87-07: Quality Control of Onsite Dewatering / Solidification j

Operations by Outside Contractors j

IEN 87-31: Blocking, Bracing, and Securing of Radio' active Material

Packages in Transportation- j

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