IR 05000482/1987028: Difference between revisions

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{{Adams
{{Adams
| number = ML20149F411
| number = ML20236W883
| issue date = 02/11/1988
| issue date = 11/24/1987
| title = Ack Receipt of Util 880104 Ltr Informing NRC of Actions Taken to Correct Violations Noted in Insp Rept 50-482/87-28
| title = Insp Rept 50-482/87-28 on 871026-30.Violations Noted.Major Areas Inspected:Licensee Radiation Protection Activities During Second Refueling Outage
| author name = Callan L
| author name = Chaney H, Murray B
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| addressee name = Withers B
| addressee name =  
| addressee affiliation = WOLF CREEK NUCLEAR OPERATING CORP.
| addressee affiliation =  
| docket = 05000482
| docket = 05000482
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = NUDOCS 8802170139
| document report number = 50-482-87-28, NUDOCS 8712080289
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| package number = ML20236W807
| page count = 2
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 5
}}
}}


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FE6 i i 1988 o
MPENDIXB U.S. NUCLEAR REGULATORY COMMISSION
In Reply Refer To:
 
Docket: STN 50-482/87-28 Wolf Creek Nuclear Operating Corporation ATTN: Bart D. Withers President and Chief Executive Officer P.O. Box 411 Burlington, Kansas 66839 Gentlemen:
==REGION IV==
Thank you for your letter of January 4,1988, in response to our letter and Notice of Violation dated December 3, 198 Based on the information in your response along with the additional information provided during the telephone conversations on February 1,1988, between Mr. Gary Pendergrass of your staff and Mr. Blaine Murray in our office, we find that your reply is responsive to the concerns raised in our Notice of Violatio We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine
NRC Inspection Report: 50-482/87-28   License: NPF-42 Docket: 50-482 Licensee: Wolf Creek Nuclear Operating Corporation (WCN00)
P. O. Box 411 Burlington, Kansas 66839 Facility Name: Wolf Creek Generating Station (WCGS)
Inspe'ction At: WCGS Site, Burlington, Coffey County, Kansas Inspection Conducted: October 26-30, 1987 Inspector:  I  ----
      #
H. D. Cla' hey, Radiation Specialist, Facilities li fU/O Date j Radiological Protection Section  i Approved:    in . (D A_n a u /24/9~)
B. Murray, Chief, Facill ~ies Radiological  Dat'e
        '
Protection Section Inspection Summary Inspection Conducted October 26-30, 1987 (Report 50-482/87-28)
Areas Inspected: Routine, unannounced inspection of the licensee's radiation protection activities during the second refueling outag Results: Within the areas inspected, one violation (surveys, see paragraph 4)
and no deviations were identifie '
8712080289 e.71203-PDR ADDCK 05000402 G  PDR
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Sincerely, l    IMginn! Signed By A. B. Beach L. J. Callan, Director Division of Reactor Projects CC:
__  ..
Wolf Creek Nuclear Operating Corporation ATTN: Otto Maynard, Manager of Licensing P.O. Box 411 Burlington, Kansas 66839 Wolf Creek Nuclear Operating Corporation ATTN: Gary Boyer, Plant Manager P.O. Box 411 Burlington, Kansas 66839 (cc continued next page)
    ,
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Wolf Creek Nuclear Operating -2-Corporation Kansas Corporation Ccmmission ATTN: Robert D. Elliott, Chief Engineer Fourth Floor, Docking State Office Building Topeka, Kansas 66512-1571 Kansas Radiation Control Program Director bec to DMB (IE06)
bec distrib. by RIV:
R. D. Martin, RA Myron Karman, ELD, MNBB (1)
Resident Inspector Section Chief, DRP/A)
DRP RPSB RIV File DRS MIS System RSTS Operator Lisa Shea, RM/ALF Inspector Section Chief L. A. Yandell R. L. Bangart R. E. Hall Project Engineer, DRP/A W. L. Forney, RIII Resident Inspector, RIII P. O'Connor, NRR Project Inspector M. E. Emerson l
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DETAILS Persons Contacted Licensee
'
  *G. D. Boyer, Plant Manager
'
  *W. 'J. Rudolph II, Quality Assurance (QA) Manager
      , .
  *A. A. Freitag,' Nuclear Power Engineering Manager
      'l
  * G. Williams, Superintendent of Regulatory
.
  * S. Morrill, Site Health Physicist
        ;
  *J. W. Johnson, Chief of Security
      "" "
  *C. J. Hoch, QA Technician
-
  *E. C. Holman, Health Physics (HP) Supervisor
W$LF CREEld NUCLEAP OPERATING CORPORAT) ;N  ,
  *L. F. Breshears, HP Supervisor
l Bart D. Whhers      I w and      - i January 4, 1988 i VM 87-0352
  *K. M. Thrall, Senior Corporate HP Engineer
    ..
  *H. M. Davis, HP Supervisor
  *R. L. Taylor, HP Supervisor
  *S. R. Sparks, Licensing Engineer
    .
  *K. O. Peterson, Supervisor, Licensing
  *G. J. Pendergrass, Licensing Engineer
  'J. D. Freeman, Radwaste Coordinator C. G. Patrick, Superintendent, Quality Evaluations
  'G. A. McClelland, QA Auditor L. M. Kline, HP Technici a M. M. Nichols, Superintendent, Plant Support  '
T. G. Moreau, Radiation Protection Training Instructor j
Others    -
i
  *J. E. Cummins, NRC Senior Resident Inspector  i
  *B. L. Bartlett, NRC Resident Inspector  j
  *K. H. Oh, Inspector, Advanced Energy Research Institute, Korea j
  *E. W. Creel, Kansas Gas & Electric Nuclear Coordinator  j
  * Denotes personnel in attendance at the exit meeting on [[Exit meeting date::October 30, 1987]]. Followup on Previously Identified Inspection Findings (0 pen) Deviation (482/8712-02): Continuous Airborne Monitoring (CAM) i
         '
         '
    -   ,
Program - This item was identified in NRC Inspection Reports 50-482/87-12 and 50-482/85-42, and involved the failure to implement a CAM program that satisfied commitments in the Final Safety Analysis Report. The NRC inspector determined that the licensee's routine QA surveillance program (QA Surveillance TE: 53359 S-1579) identified that the licensee was still having problems implementing the CAM program as committed to in the licensee's' response to the NRC dated July 30, 1987. This is ccasidered a licensee-identified problem. This item will remain open pending further
  ..    ,
,
U. S. Nuolear Regulatory Corniskion ATIN: Document Control Desk Vashington, D. C. 20555    .
review and followup by the NRC during future inspections.
Reference: Letter dated 12/03/87 from L. J. Callan, NRC, to B. D. Withers, VCNOC Subject: Docket No. 50-482: Response to Violation 482/8728-01
  +
      '
Qentlemen:
Attached is a detailed response to violation 482/8728-01 which was documented in the Referenc Violation 482/8728-01 concerns a failure to properly evaluate certain survey results during the assessment of radiation exposure of two worker If you have any questions concerning this matter, please contact me or M O. L. Maynard of my staf Very truly yours,
  "
ud Bart D. Vithers  ''
President and Chief Ezeeutive Officer BDV/11k Attachment ce: B. L. Bartlett (NRC), w/a R. D. Martin (NRC), w/a P. V. O'Connor (NRC), w/a m g y . u & tt'C D W
,   k PO. Scm 411/ Burtngeon. KS 66430 / Phone: (31813H4431 M M opperssey W WCW h(


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I A Attachment to VM 87-0352
*
!
_ 3. Refueling Outage-(NRC Inspection Procedure 83729)
Page 1 of 2      '
The'NRC inspector reviewed the licensee's radiation protection' program in effect during the refueling outage. The following specific program areas were reviewed:
i
Audits and Appraisals- ,
      '
Planning and Preparation Training and Qualification of Workers External Exposure Control
Violation (482/8728-01): Pailure to Perform Radiological Surveys  ' '
)  Pindings      l
         .
         .
y 10 CPR Part 20.20'(b) requires that licensees shall make or oause to be made
Internal Exposure Control Control of Radioactive Materials and Contamination, Surveys, and Monitoring Indepe'ndent. Surveys by the NRC inspector ALARA Program Staffing An apparent violation concerning dose evaluations is discussed in paragraph 4. No deviations were identifie . Contaminated Workers The NRC inspector reviewed the circumstances surrounding the contamination of two contract workers and the subsequent dose assessment of the two workers. On October 10, 1987, two contract workers were sprayed with radioactive charcoal filter media while working on a liquid waste processing syste The workers were wearing personal clothing when the contamination incident occurred. After the incident, the workers removed their personal clothing, and donned clean protective clothing before transit from the work area to the personnel decontamination station. Radiological surveys of the two workers were not performed until after donning the protective clothing. During a review of the licensee's skin dose calculations, the NRC inspector noted that the licensee had not considered the attenuation provided by the protective clothing when calculating dose values for contamination deposited directly on the ski l  Surveys of the contaminated workers were performed with a RM-14 pancake prob The attenuation provided by the protective clothing for radioactive material deposited on the skin would be a'significant consideration for beta radiation which would contribute the largest portion of the dose. The NRC inspector noted that the licensee's initial L
* *
_ _ _ _ _ _ _ - _ _ _ _
such surveys asa (1) may be necessary for the licensee to ooeply with the i regulations in this part and (2) are reasonable under the circumstances to evaluate the extent of radiation hasards that may be present. As defined in ,
 
10 CFR Part 20.201(a), "survey" meant. an evaluation of the radiation hazards '
_
incident to the production, use, release, disposal, or presence of radioactivo saterials or other sources of radiation under a specific set of condition ,
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      ,
 
Contrary to the above, the NRC inspector determined on October 26, 1987, that the licensee failed to groperly evaluate certain survey results during '
dose calculation could increase by'a factor of 2-5. The NRC inspector also noted that even if the doses were increased by a factor of five, regulatory limits would not be exceede CFR Part 20.201(b) requires that licensees shall make or cause to be made such surveys as: (a) may be necessary for the licensee to comply with the regulations in this part and (b) are reasonable under the circumstances to evaluate the extent of radiation hazards'that may be-presen As defined in 10 CFR Part 20.201(a), " survey" means an evalustion cf the radiation hazards incident to the protection, use, release, disposal, or presence of radioactive materials or other sources-of radiation under a specific set of conditions. 'The failure to properly evaluate radiation exposures'is an apparent violation of 10 CFR Part 20.201(a) (482/8728-01).
      '
the assessment of radiation exposure to the skin of the whole body and
, ,..; extremities of two worker ~
.
  , Reason Por Violation
  ~
'
*
Two health physion technicians from another utility providing additional health physios support during the Wolf Creek Generating Station second refueling outage performed the surveys through the protective clothing that
'
7;. the workers were wearin Procedure HPH 03-014 contains a step requiring a
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survey be performed on the skin if contamination is found on the olothing.


]  The same procedure also states that if contamination is such that it may i .' spread enroute to the decontamination area, the worker may have to don i -
5. Allegation Followup (RIV-87-A0074)
protective clothing to prevent the sprea The two health physio 2 .
An allegation was made to the WCGS resident inspector concerning the radiological safety involved in working in the false ceiling area above
{  technicians did have the workers remove their personal olothing and then don l l Protective clothing to get to the decontaisination area. As there was not a
!
controlled copy of HPH 03-014 at the decontamination area they missed the  :
)  step requiring a survey be performed on the skin and submitted an initial - !
survey sheet for each individual showing the readings through the protective i l clothin l
!  Corrective Steps Which Have Been Taken and Results Achieved:  i f  A cabinet containing decontamination supplies and a controlled copy of HPH
,
03-014 has been located at the decontamination are *
:)
'
'
Conversations with the support health physics technicians and WCNOC health  I
the plant radiochemistry laboratory (1984.0-foot elevation of the Control Building).
. physics technicians were held stressing the importance of following
,
procedures and paying attention to detai l
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        ,


-. . _ _-
Discussion The radiochemistry laboratory was posted as a radiologically controlled area due to the potential for the radiological conditions in the laboratory to change. The subject area (false ceiling) which is accessible via a ceiling mounted access door outside of the laboratory perimeter was not posted or being radiologically controlled at the time of the alleger's presence in the area. The NRC inspector reviewed the ,
physical situation and general area radiation surveys on October 27, 1987, '
and determined the radiochemistry laboratory dose rates are maintained a below the required radiation area posting limits of 10 CFR Part 20.20 '
There is also a permanently mounted alarming area radiation monitor in the I laboratory area. The licensee conducts radiochemistry operations )
utilizing a vented fume hood and the exhaust duct transits the false i ceiling spac ,
Conclusion    l


-
The radiochemistry laboratory and the false ceiling space above it are I properly controlled and posted. Therefore, the area above the i radiochemistry laboratory has been and would currently be a radiologically safe area to occupy, and any fume hood exhaust ventilation system leakage 3 would be inward and not cause any leakage to the false ceiling are Since the dose rates in the laboratory could possibly increase with the age of'the facility, due to radioactivity buildup in the exhaust ducts and ,
s Attachment to VM 87-0352
the processing of higher activity in samples, the HP group posted the J l
$e 2 of 2
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Corrective Steps Vhich Will Be Taken To Avoid Purther Violations:
j


4
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  ~ Procedure HPH 03-014, "Personnel Decontamination" is being revised to include a statement on the Personnel Decontamination Record to remove olothing and survey the skin u..derneath for clothing contamination and Hot Particle contamination incident A review of this incident has been included in the health physics technician training program which will commence on January 4, 1988, and conclude on March 11, 1988. The lesson plan for this training contains a description of the incident and describos why pet,per surveys are required. Health physion technicians working shift will be attending these classe Date When Pull Compliance Vill Be Achieved:
Je .
      . .
  .
The above nortionet health physics technician training and the revision to '
L    5
      .
  .
procedure HPH 03 314 will be oospleted by March 11, 198 The otuer corrective actions taken as a result of this event have been complete B M
  . access. hatch to the false ceiling as a radiologically controlled area when this situation was brought to their attention by the NRC inspector. This item is considered close No violations-or deviations were identifie .' Licensee Event Report (LER)
e f
  (Closed) LER (482/87-036): Inadvertent Release of a Secondary Liquid Waste Monitor Tank Without Prior Sampling - On. July 27, 1987, the licensee discovered that during a July 26, 1987, authorized release of Secondary Liquid Waste Monitor Tank'- B (SLWMT-B) the contents of SLWMT-A was
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siphoned out also and discharged to the environment. No release limits were exceede The NRC inspector reviewed the licensee's evaluation of the incident and corrective actions contained in the LER, and. determined that the licensee had implemented adequate corrective actions to prevent a future recurrence of this incident. This item is considered close . Exit Interview The NRC-inspactor met with the personnel identified in paragraph 1 at the conclusion of the inspection on October 30, 1987. The NRC inspector summarized the scope and. findings of the inspection.


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Revision as of 19:00, 17 February 2021

Insp Rept 50-482/87-28 on 871026-30.Violations Noted.Major Areas Inspected:Licensee Radiation Protection Activities During Second Refueling Outage
ML20236W883
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 11/24/1987
From: Chaney H, Murray B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20236W807 List:
References
50-482-87-28, NUDOCS 8712080289
Download: ML20236W883 (5)


Text

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MPENDIXB U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-482/87-28 License: NPF-42 Docket: 50-482 Licensee: Wolf Creek Nuclear Operating Corporation (WCN00)

P. O. Box 411 Burlington, Kansas 66839 Facility Name: Wolf Creek Generating Station (WCGS)

Inspe'ction At: WCGS Site, Burlington, Coffey County, Kansas Inspection Conducted: October 26-30, 1987 Inspector: I ----

H. D. Cla' hey, Radiation Specialist, Facilities li fU/O Date j Radiological Protection Section i Approved: in . (D A_n a u /24/9~)

B. Murray, Chief, Facill ~ies Radiological Dat'e

'

Protection Section Inspection Summary Inspection Conducted October 26-30, 1987 (Report 50-482/87-28)

Areas Inspected: Routine, unannounced inspection of the licensee's radiation protection activities during the second refueling outag Results: Within the areas inspected, one violation (surveys, see paragraph 4)

and no deviations were identifie '

8712080289 e.71203-PDR ADDCK 05000402 G PDR

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2

,

DETAILS Persons Contacted Licensee

  • G. D. Boyer, Plant Manager
  • W. 'J. Rudolph II, Quality Assurance (QA) Manager
  • A. A. Freitag,' Nuclear Power Engineering Manager
  • G. Williams, Superintendent of Regulatory
  • S. Morrill, Site Health Physicist
  • J. W. Johnson, Chief of Security
  • C. J. Hoch, QA Technician
  • E. C. Holman, Health Physics (HP) Supervisor
  • L. F. Breshears, HP Supervisor
  • K. M. Thrall, Senior Corporate HP Engineer
  • H. M. Davis, HP Supervisor
  • R. L. Taylor, HP Supervisor
  • S. R. Sparks, Licensing Engineer

.

  • K. O. Peterson, Supervisor, Licensing
  • G. J. Pendergrass, Licensing Engineer

'J. D. Freeman, Radwaste Coordinator C. G. Patrick, Superintendent, Quality Evaluations

'G. A. McClelland, QA Auditor L. M. Kline, HP Technici a M. M. Nichols, Superintendent, Plant Support '

T. G. Moreau, Radiation Protection Training Instructor j

Others -

i

  • J. E. Cummins, NRC Senior Resident Inspector i
  • B. L. Bartlett, NRC Resident Inspector j
  • K. H. Oh, Inspector, Advanced Energy Research Institute, Korea j
  • E. W. Creel, Kansas Gas & Electric Nuclear Coordinator j
  • Denotes personnel in attendance at the exit meeting on October 30, 1987. Followup on Previously Identified Inspection Findings (0 pen) Deviation (482/8712-02): Continuous Airborne Monitoring (CAM) i

'

Program - This item was identified in NRC Inspection Reports 50-482/87-12 and 50-482/85-42, and involved the failure to implement a CAM program that satisfied commitments in the Final Safety Analysis Report. The NRC inspector determined that the licensee's routine QA surveillance program (QA Surveillance TE: 53359 S-1579) identified that the licensee was still having problems implementing the CAM program as committed to in the licensee's' response to the NRC dated July 30, 1987. This is ccasidered a licensee-identified problem. This item will remain open pending further

,

review and followup by the NRC during future inspections.

I

_ _ _ - _ - _ _ - _ _ _ _ _ . _

. .

_ 3. Refueling Outage-(NRC Inspection Procedure 83729)

The'NRC inspector reviewed the licensee's radiation protection' program in effect during the refueling outage. The following specific program areas were reviewed:

Audits and Appraisals- ,

Planning and Preparation Training and Qualification of Workers External Exposure Control

.

Internal Exposure Control Control of Radioactive Materials and Contamination, Surveys, and Monitoring Indepe'ndent. Surveys by the NRC inspector ALARA Program Staffing An apparent violation concerning dose evaluations is discussed in paragraph 4. No deviations were identifie . Contaminated Workers The NRC inspector reviewed the circumstances surrounding the contamination of two contract workers and the subsequent dose assessment of the two workers. On October 10, 1987, two contract workers were sprayed with radioactive charcoal filter media while working on a liquid waste processing syste The workers were wearing personal clothing when the contamination incident occurred. After the incident, the workers removed their personal clothing, and donned clean protective clothing before transit from the work area to the personnel decontamination station. Radiological surveys of the two workers were not performed until after donning the protective clothing. During a review of the licensee's skin dose calculations, the NRC inspector noted that the licensee had not considered the attenuation provided by the protective clothing when calculating dose values for contamination deposited directly on the ski l Surveys of the contaminated workers were performed with a RM-14 pancake prob The attenuation provided by the protective clothing for radioactive material deposited on the skin would be a'significant consideration for beta radiation which would contribute the largest portion of the dose. The NRC inspector noted that the licensee's initial L

_ _ _ _ _ _ _ - _ _ _ _

_

l l .- .

l

dose calculation could increase by'a factor of 2-5. The NRC inspector also noted that even if the doses were increased by a factor of five, regulatory limits would not be exceede CFR Part 20.201(b) requires that licensees shall make or cause to be made such surveys as: (a) may be necessary for the licensee to comply with the regulations in this part and (b) are reasonable under the circumstances to evaluate the extent of radiation hazards'that may be-presen As defined in 10 CFR Part 20.201(a), " survey" means an evalustion cf the radiation hazards incident to the protection, use, release, disposal, or presence of radioactive materials or other sources-of radiation under a specific set of conditions. 'The failure to properly evaluate radiation exposures'is an apparent violation of 10 CFR Part 20.201(a) (482/8728-01).

5. Allegation Followup (RIV-87-A0074)

An allegation was made to the WCGS resident inspector concerning the radiological safety involved in working in the false ceiling area above

'

the plant radiochemistry laboratory (1984.0-foot elevation of the Control Building).

Discussion The radiochemistry laboratory was posted as a radiologically controlled area due to the potential for the radiological conditions in the laboratory to change. The subject area (false ceiling) which is accessible via a ceiling mounted access door outside of the laboratory perimeter was not posted or being radiologically controlled at the time of the alleger's presence in the area. The NRC inspector reviewed the ,

physical situation and general area radiation surveys on October 27, 1987, '

and determined the radiochemistry laboratory dose rates are maintained a below the required radiation area posting limits of 10 CFR Part 20.20 '

There is also a permanently mounted alarming area radiation monitor in the I laboratory area. The licensee conducts radiochemistry operations )

utilizing a vented fume hood and the exhaust duct transits the false i ceiling spac ,

Conclusion l

The radiochemistry laboratory and the false ceiling space above it are I properly controlled and posted. Therefore, the area above the i radiochemistry laboratory has been and would currently be a radiologically safe area to occupy, and any fume hood exhaust ventilation system leakage 3 would be inward and not cause any leakage to the false ceiling are Since the dose rates in the laboratory could possibly increase with the age of'the facility, due to radioactivity buildup in the exhaust ducts and ,

the processing of higher activity in samples, the HP group posted the J l

i

_ _

j

, _ _ _ _ .

Je .

.

L 5

.

. access. hatch to the false ceiling as a radiologically controlled area when this situation was brought to their attention by the NRC inspector. This item is considered close No violations-or deviations were identifie .' Licensee Event Report (LER)

(Closed) LER (482/87-036): Inadvertent Release of a Secondary Liquid Waste Monitor Tank Without Prior Sampling - On. July 27, 1987, the licensee discovered that during a July 26, 1987, authorized release of Secondary Liquid Waste Monitor Tank'- B (SLWMT-B) the contents of SLWMT-A was

-

siphoned out also and discharged to the environment. No release limits were exceede The NRC inspector reviewed the licensee's evaluation of the incident and corrective actions contained in the LER, and. determined that the licensee had implemented adequate corrective actions to prevent a future recurrence of this incident. This item is considered close . Exit Interview The NRC-inspactor met with the personnel identified in paragraph 1 at the conclusion of the inspection on October 30, 1987. The NRC inspector summarized the scope and. findings of the inspection.

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