ML20129J228

Insp Rept 50-293/85-13 on 850520-24.Violation Noted: Failure to Adhere to Requirements of Tech Spec 6.8 Re Approval & Adherence to Procedures.Deviation Noted:Failure to Implement Requirements of IE Bulletin 80-10

ML20129J228
Person / Time
Site:	Pilgrim
Issue date:	07/10/1985
From:	Myers L, Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20129J213	List: ML20129J209 ML20129J217 ML20129J223 ML20129J228
References
50-293-85-13, IEB-80-10, NUDOCS 8507220387
Download: ML20129J228 (20)

See also: IR 05000293/1985013

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-293/85-13

Docket No. 50-293

License No. DPR-35 Priority --

Category C

Licensee: Boston Edison Company M/C Nuclear

25 Braintree Hill Office Park

Braintree, Massachusetts

Facility Name: Pilgrim Nuclear Power Station

Inspection At: Plymouth, Massachusetts

Inspection Conducted: May 20-24, 1985

Inspectors: bl. dd

R. L. Nimitz, Senior Radtttion

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date

Specialist

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Approved by: / .

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/ Safety Section

Inspection Summary: Inspection on May 20-24, 1985 (Report No. 50-293/85-13)

Areas Inspected: Routine, announced inspection of the following: licensee

implementation of improvement items identified in the Radiological Improvement

Program; implementation of requirements contained in IE Bulletin 80-10; review

of radiological controls for fuel pool work; and radioactive waste management.

The inspector involved 70 inspector-hours on-site by two region based

inspectors.

Results: One violation was found in one area (failure to adhere to the

requirements of T. S. 6.8 relative to the approval and adherence of

procedures, two examples; paragraph 5). One Deviation was identified in one

area (failure to implement the requirements of IE Bulletin 80-10; paragraph

4). The licensee was found to be closely monitoring implementation of the

Radiological Improvement Program.

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8507220387 850716 l

PDR ADOCK 05000293 i

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DETAILS

1.0 Individuals Contacted

1.1 Boston Edison Comrany (BECo)

• A. L. Oxsen, Vice President-Nuclear Operations

• C. J. Mathis, Nuclear Operations Manager

• W. H. Deacon, Assistant to the Senior Vice President-Nuclear

• R. A. Smith, Chief Chemical Engineer

• R. D. Smith, Chief Technical Engineer

• P. E. Mastrangelo, Chief Operating Engineer

• A. R. Trudeau, Chief Radiological Engineer

• E. T. Graham, Compliance Management Group Leader

• E. J. Ziemianski, Nuclear Operations Support Manager

• D. J. Sukanek, Station Services Group Leader

1.2 Contractors

• G. H. Smith, Hydro-Nuclear Inc.

1.3 NRC

• M. McBride, Resident Inspector, Pilgrim Station

• Denotes attendance at the NRC/ licensee exit meeting on May 24, 1985.

The inspector also contacted other licensee personnel.

2. Purpose of Inspection

The purpose of this routine, announced radiological controls inspection

was to review the following program elements:

• Implementation of licensee commitments presented to NRC in the

Radiological Improvement Program

• Licensee Action on IE Bulletin 80-10, " Contamination of

Nonradioactive System and Resulting Potential for Unmonitored,

Uncontrolled Release to Environment"

Radioactive Waste Management, including:

• radioactive waste storage and handling

• new Rad Waste Compactor Facility

! * Implementation of Radiological Controls During Spent Fuel Pool

l- Work.

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3. Implementation of Licensee Commitments Presented to NRC in the

Radiological Improvement Program.

3.1 General

The inspector reviewed the implementation of licensee commitments

presented to the NRC. The review was with respect to criteria and/or

information contained in the following documents:

Order Modifying Licensee, Notice of Violation, and Notice of

Deviation (NRC Inspection No. 50-293/84-25 and 50-293/84-29), dated

November 29, 1984.

Letter (W. D. Harrington, Senior Vice President-Nuclear, Boston

Edison, to T. E. Murley, Regional Administrator, NRC Region I),

dated February 28,1985 (BECo LTr No 85-042).

Licensee Completed Regulatory Requirement Analysis Forms (various)

relative to Radiological Improvement Plan (RIP) Milestones.

Licensee Radiological Activity Assessment Reports (RAAR) (various).

Radiological Oversight Committee (ROC) Meeting Minutes (various).

The purpose of this review was to determine if,

a

the licensee met the commitments (i.e. milestones) specified in the

Radiological Improvement Program (RIP);

the material or actions taken/ generated by the licensee satisfac-

torily met the commitments made to NRC in the RIP;

the material or actions taken/ generated were properly implemented.

The following aspects of RIP implementation were noted:

a tracking program was in place to identify milestones due;

adequate management controls were in place to monitor implementation

of milestones and initiate proper action when milestones were

identified as potentially not being met;

• adequate review was performed of the material or actions

taken/ generated to determine its adequacy prior to its acceptance

and implementation.

3.2 Findings

The inspector reviewed a total of 65 commitments that were to have been

completed by the licensee by April 30, 1985. The commitments reviewed

are identified in the attachment to this report.

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The review indicated that the licensee satisfactorily completed his

committed action on 63 of the commitments. Several commitments were left

open due to the need for additional NRC review. These are identified in

the attachment to this report.

Within the scope of this review, the following positive attributes of the

RIP were noted:

The licensee's Senior Vice President-Nuclear is closely monitoring

implementation of the Radiological Improvement Program (RIP)

The RIP milestones have been inputted into the licensee's Planning

and Scheduling Computer for monitoring. The monitoring program has

appropriate flags to notify management in a timely manner when a

task may potentially fall behind schedule. The licensee initiates

appropriate action when this is identified.

• The licensee's contractor is also monitoring implementation of RIP

milestones.

• The RIP material or actions taken/ generated have been, where appro-

priate, properly implemented.

• The licensee's RIP Program Manager is: periodically auditing

compliance with the Order Modifying License (referenced above);

auditing RIP implementation; and reviewing the RIP product.

Within the scope of this review, the following additional matter was

identified:

• The licensee Senior Management identified a concern involving timely

resolution by the Radiological Oversight Committee (ROC) of items

brought to its attention. The licensee took action to ensure the

ROC implemented its charter responsibilities in an appropriate

manner.

• Based on NRC findings identified during review of Spent Fuel Pool

work (see Section 5 of this report) the licensee stated that the

Radiological Assessor, who reports his findings to the ROC, would be

requested to place additional emphasis on personnel use of approved

procedures during work and training of personnel in job specific

procedures.

Conclusion

Based on the above review, the licensee is aggressively monitoring

implementation of the RIP deficiencies identified, and is meeting

commitments provided to NRC Region I.

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4.0 IE Bulletin 80-10

The inspector reviewed the licensee's implementation of the requirements

contained in IE Bulletin 80-10, " Contamination of Nonradioactive System

and Resulting Potential for Unmonitored/ Uncontrolled Release to the

Environment." This review followed up Open Item No. 50-293/85-07-03.

Within the scope of the review, the following Deviation was identified:

IE Bulletin 80-10 requires among other matters that: 1) a review of

facility design and operation be performed to identify systems that are

considered as nonradioactive, but could possibly become contaminated

through interfaces with contaminated systems; 2) a routine sampling /

analysis or monitoring program for these systems be established in order

to promptly identify any contaminating events which could lead to

unmonitored, uncontrolled, liquid or gaseous releases to the environment,

including releases to on-site leaching fields and; 3) the specifics of

these reviews be documented and made available to the NRC for review

during future on-site inspection efforts. In particular, special consider-

ation was to be given to the instrument air system and the sanitary waste

system.

The licensee's July 11, 1980 response to this Bulletin indicated that the

above was implemented.

Contrary to the above, as of May 24, 1985, 1) the instrument air system

and sanitary waste system had not been reviewed to determine if these

systems could become radioactive through interfaces with nonradioactive

systems; 2) no routine sampling / analysis or monitoring program (as

appropriate) was established in order to promptly identify any contam-

inating events which could lead to unmonitored/ uncontrolled releases from

these systems; and 3) no specifics relative to the above was documented

and made available to the NRC.

This matter remains open.

Within the scope of this review, the following additional matters were

identified:

• The licensee did not have clearly established action levels to be

used to identify a potentially contaminated, normally uncontaminated,

system in order that appropriate personnel can be notified in a

timely manner to implement the requirements of Section 3 of IE

Bulletin 80-10.

Licensee representatives indicated such guidance would be established by

June 3,1983. (50-293/85-13-01)

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The licensee did not.have clearly established guidance for operations

personnel relative to what action to take if they were notified that

a normally clean system was identified as contaminated.

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Licensee representatives indicated such guidance would be established by

June 3, 1983. (50-293/85-13-02)

Within the scope of the review, the following additional matter was

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identified:

Inspector review indicated that a licensee special instruction dated

June 7, 1984, appeared to supersede a licensee approved procedure

(No. 7.3.41-1) for sampling and analysis of service water. This

matter is unresolved. (50-293/85-13-03)

5.0 Spent Fuel Pool Work

The inspector reviewed the implementation of Radiological Controls for

work in the Spent Fuel Pool. The licensee was cutting control rod blades

and low power range monitors for disposal.

The review was perforced to determine if,

procedures for the operation were properly reviewed and approved in

accordance with station administrative requirements;

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personnel, were appropriate, were properly trained and qualified in

the applicable procedures;

radiological controls personnel, overseeing the work, were properly

trained and qualified in accordance with Technical Specification

requirements;

radiological controls for the task were adequate;

established radiological controls were properly implemented (e.g.,

RWP controls);

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radiation survey equipment used for the task was properly

calibrated.

The evaluation of the licensee's performance in the above areas was based

on:

independent radiation surveys performed by the inspector;

• review of on going work;

• discussions with personnel;

• review of documentation.

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The following documents were selectively reviewed:

Procedure 1.3.4, " Procedures," Revision 27, dated April 24, 1985;

Procedure 1.5.3, " Maintenance Requests," Revision 16 dated

April 1985;

Procedure 3.M.1-19, " Spent Fuel Pool Cleaning," Revision 1, dated

February 6, 1985;

• Procedure TP85-14, " Transfer of Control Rod Blades and Poison

Curtains in the Spent Fuel Pool," Revision 0, dated

December 31, 1985;

Procedure TP85-23, " Waste Characterization," Revision 0, dated

March 6, 1985;

Procedure FP-0P-008-442, " Operating Procedure for Use of Abrasive

Underwater Saw at Pilgrim Station," dated March 24, 1965,

Chem-Nuclear Systems, Inc.;

Procedure FP-0P-007-442, " Procedure for Processing LPRM ' Hot' and

' Cold' Ends at Pilgrim For Disposal," dated March 15, 1985,

Chem-Nuclear Systems, Inc.;

• Procedure 6.4-079, " Operation of the Technical Associates CPMU

Underwater Survey Meter," Revision 3, dated August 26, 1985;

Procedure 6.5-079, " Calibration of the Technical Associates CPMU,

Underwater Model," Revision 2, dated January 27, 1982; and

Certificates of Calibration for CPMU, Serial Nos. 945131 and 3870.

Within the scope of this review, the following violation was identified:

Technical Specification 6.8 requires that written procedures and adminis-

trative policies be established, implemented and maintained, that meet or

exceed the requirements and recommendation of Appendix 'A' of Regulatory

Guide 1.33. Appendix 'A' of Regulatory Guide 1.33, 1972 recommends, in

part, that. procedures for procedure review and approval be prepared. It

also recommends that procedures for the repair or replacement of equipment

be prepared. (50-293/85-13-04)

1. Procedure 1.3.4, Revision 27, " Procedures," specifies, in part, in

section C.3, that the Operation Review Committee (ORC) shall

indicate its approval of a procedure to be included in Category

.Three Group Procedures.

Contrary to the above, as of May 23, 1985, two procedures

(FP-0P-007-442 and FP-0P-008-442), used to provide guidance for

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cutting of control rod blades and LPRMs were not presented to ORC

for approval as Category Three procedures. The procedures were used

since about May 1, 1985 to provide guidance for on going cutting

work.

2. Procedure No. 3.M.1-19, Revision 1, " Spent Fuel Pool Cleaning,"

specifies in section IV that the obtaining of a valid Maintenance

Request (MR) is a prerequisite for procedure use. The procedure

provides general guidance for performing cutting of radioactive

materials in the spent fuel pool. In addition, Vendor Procedure No.

FP-0P-007-442, " Procedure for Processing LPRM Hot and Cold Ends for

Disposal," specifies in-section 4 that the obtaining of a valid

maintenance request is a prerequisite for procedure use.

Contrary to the above, as of May 23, 1985, and for an undetermir.ed period

of time prior to this time, control rod blades and LPRMs were being cut

in the spent fuel pool in preparation for planned disposal but no valid

maintenan ? request was in effect.

The above matters were brought to the. licensee's attention on

May 23, 1985. The licensee performed the following:

halted all work on the Refueling Floor on May 23, 1985;

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presented the vendor procedures to ORC on May 24, 1985;

issued a maintenance request for the work;

ensured all personnel were cognizant of their procedural

responsibilities.

Within the scope of the review, the following additional matters were

identified:

Licensee radiological control technicians, providing oversight of

the cutting work, had not been provided copies of or instructed in

the specific radiological controls requirements in vendor procedures.

One of the procedures required sign-offs by the technicians.

The licensee referenced on the applicable RWP three station approved

procedures for control of selected activities associated with work

in the spent fuel pool. However, the inspectors were unable to

identify any specific supervisory control in place to ensure that

all appropriate technicians had read and understood the referenced

procedures.

These matters were brought to the licensee's attention.

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On May 29, 1985, licensee compliance personnel contacted the inspector

and indicated that all appropriate personnel had reviewed the applicable

procedures.

Licensee representatives indicated the Contractor Onsite Assessor would

be requested in his reviews to ensure personnel were using appropriately

reviewed procedures and were knowledgeable in the procedure requirements.

6.0 Radioactive Waste Transportation

On May 23, 1984, the inspector reviewed selected aspects of a radioactive

waste shipment prepared for transport. The shipment consisted of

miscellaneous material from the spent fuel pool. The shipment contained

an estimated 70 curies.

The following aspects were reviewed:

radiation levels at various locations on the shipment were within

applicable regulatory limits;

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contamination levels on the shipment were within applicable limits;

quantities of radioactive material contained in the shipment were

properly determined;

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selected aspects of the shipping papers were completed in accordance

with procedure requirements;

notifications, were appropriate, were made.

.The review was with respect to criteria contained in the following:

Temporary Procedure TP85-39, " Handling and Loading Procedure for

CNSI 3-55 Cask," Revision 0, dated April 24, 1985;

Temporary Procedure T85-23, " Waste Characterization," Revision 0,

dated December 31, 1985;

Procedure 6.9-160, " Shipment of Radioactive Material, " Revision 20,

dated April 14, 1985; and

• Certificate of Compliance of cask CNSI 3-55, No. 5805, Revision 13.

• - Applicable NRC and DOT Regulatory requirements.

The evaluation of the licensee's performance in this area was based on:

performance of independent radiation surveys by the inspector;

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performance of contamination surveys by the inspector;

• review of documentation;

discussions with cognizant personnel.

Within the scope of this review, no violations were identified. The

licensee implemented the applicable requirements.

Within the scope of this review, the following items for improvement were

identified:

The check-off list for procedure T85-39 did not contain a check-off

for satisfactory performance of a cask leak test. The licensee

issued a procedure change notice to address this matter.

The check-off list for the shipping procedures does not contain a

check-off for satisfactory determination that cask seals have been

replaced within the specified time interval. The licensee should

add such a check-off to the applicable procedure. (50-293/85-13-05)

7.0 _ Trash Compactor Facility

The inspector reviewed operations at the Trash Compactor Facility. The

following matters were reviewed:

• posting and barricading;

control of radioactive material;

airborne radioactivity monitoring;

ventilation system operation;

control of liquid radioactive material;

performance of appropriate safety evaluations for operation of the

facility.

The review was with respect to criteria contained in the following:

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Procedure TP 84-64, Revision 0, " Radiological Controls for the Trash

Compactor Facility (TCF)";

Procedure No. 6.9-179, Revision 1, " Radioactive Waste Press

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(Steel Box - Compactor)";

10 CFR 20, " Standards for Protection Against Radiation";

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- 10 CFR 50.59, " Changes, Tests, Experiments";

NRC Generic Letter 81-38, " Storage of Low-Level Radioactive Wastes

At Power Reactor Sites," dated November 30, 1981;

IE Circular 80-18, "10 CFR 50.59 Safety Evaluation for Changes To

Radioactive Waste Treatment Systems".

The evaluation of the licensee's performance in the area was based on:

inspector tour of the Trash Compactor Facility;

discussions with cognizant personnel;

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review of documentation including review of the following safety

evaluation and calculations:

10 CFR 50.59 Safety Evaluation for New Trash Compactor

Facility, (N0P83ES), dated March 1, 1984;

• Calculation No. ERHS-XIII*B-10-0;

Calculation No. ERHS-XIII*B-9-0.

Within the scope of the review, the following was noted:

The new Trash Compacting Facility is not being utilized as an

interim low level waste storage facility. Rather the licensee is

using it as a holding area for material to be shipped.

No radioactive liquids are to be introduced to the facility

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The licensee established package radiation dose rate and

contamination level criteria for packages to be held at the

facility.

The licensee is using the trash compactor to compact trash in the

facility. Procedures have been established for the purpose

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The licensee is not using the radioactive waste segregation and

sorting capabilities of the facility pending installation of

appropriate airborne radioactivity effluent monitoring equipment.

Within the scope of the review, the following matters are unresolved and

will be reviewed during a subsequent inspection (50-293/85-13-06):

• The licensee's safety evaluation for offsite doses to members of the

public did not clearly indicate that the doses would be below those

specified in 40 CFR 190 (Reference 10 CFR 20.105 (c)).

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The licensee has established a routine radiological survey program

for the facility (Reference TP84-64). However, appropriate action

level criteria were not established to ensure all dose limits of 10

.CFR 20.105 (i.e. 40 CFR 190) were met.

The licensee used one open LSA box as a source term for his safety

evaluation. However, the basis of this source term is uncertain.

8.0 Unresolved Items

Unresolved Items are. items which need additional review to determine if

they are acceptable. One Unresolved Item is discussed in section 4 of

the report. (50-293/85-13-03)

9.0 Exit Meeting

The inspector met with licensee representatives denoted in section 1 of

-the report, on May 24, 1985. The inspector summarized the purpose, scope

and findings of the inspection.

At no time during this inspection did the inspector provide the licensee

. written material.

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Attachment

Status of Boston Edison Company's

Radiological Improvement Program (RIP)

Commitments to be Completed on or

Before April 30, 1985

Commitment Status NRC Comment

1. 1.1.1 Develop and approve Complete Organization complete

An Interim Organization and implemented.

for the Radiological Described in BECo

Control Group Letter No.85-042

(February 28, 1985) dated February 28,

1985. Distributed via

BECo Memorandum No.

CRE 85-165, dated

March 26, 1985

2. 1.1.2 Define functional and Complete NONE

and administrative

responsibilities for each

position in the interim

organization.

(February 28, 1985)

3. 1.1.3 Define interim Complete Established in

organization chain of accordance with

command. organization chart

(February 28,1985) (See Item 1.1.1(#1))

4. 1.1.4 The interim Radiological Complete NONE

Control Organization will

be fully staffed and

implemented by Boston Edison

or Contractor personnel by

March 31, 1985

5. 1.2.1 Develop and Implement an Complete NONE

Organization for the

Radiological Group. Present

the proposed organization to

Corporate Management -

April 30, 1985

6. 1.2.2 Formally define Complete NRC will review

the approved organization these defined

structure for the Radiological elements to determine

Group (April 30,1985) if they are consistent

with/ adequate to

high priority technical implement actual

support requests approved organization

(Milestone 1.2.2,

group functional May 31, 1985)

responsibilities define NRC Follow-up Item

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Commitment Status NRC Comment

• individual responsibilities 50-293/85-13-07

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define Assigned to this

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matter.

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• long term organization

chart define

• long term organization

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responsibilities define

7. 1.3 Develop and implement Complete NONE

an RIP implementation plan

and schedule for organization

improvement.

(completedMarch 31,1985)

8. 2.2.1 Publish training Complete NONE

goals and objectives for

Group Training

(April 30, 1985)

9. 2.2.6 Develop a schedule Complete NONE

for implementing desired

training and ensure the

training department has

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adequate resources to

l meet schedule.

The Nuclear Training

l Department will publish

a training schedule of

training to be offered for

1985. (March 31, 1985)

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Request additional resources

Approve additional resources

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Publish Training Schedule

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! 10. 3.1.1 An evaluation Complete A proposed training

l- will be performed Coordinator Position

l by April 30, 1985 to has been established

l determine the need to (Reference CRE

l permanently assign a Memorandum No.

Radiological Group 85-249)

l Representative to work with

L the Training Group

11. 3.1.1-1 Review and Revise Complete (CRE Memorandum No.

3.1.1-2' General Employee Training 85-148) Revised

Modules by March 31, 1985 program to be

implemented July 31,

1985 (Milestone

3.1.1-3)

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12. 4.1.1 (c)-Proper location for Complete (CRE Memorandum No.

dosimetry placement 84-834)

will be defined

13. 4.1.2 Procedure No. 6.2-111 Complete NRC to review licensee

Will be revised to include corrective action on

frequency for QA checks Step 4 of procedure.

Correction factor not

correct

(50-293/85-13-08)

14. 4.2.1 Documentation Complete NONE

of R. G. 8.13

~ training to be

completed after training

provided.

15. 5.1.1- An addendum to the Completed NONE

special instruction detailing

with the air quality testing ,

process will be written to identify

the operating compressor during

testing (March 31,1985)

16. 5.1.2 Respirator smear checks Complete Requirement

have been improved contained in

Procedure 6.7-110

17. 5.3.1 The onsite compressor Complete NONE

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'has been repaired

(complete)

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l - 18. 6.2.1.a-1 The ANSI standards Complete Licensee review

dealing with whole identified a

.

, body counting number of

will be reviewed recommendations

. (April 30, 1985) for improvement.

l The improvements

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will be implemented

to meet other

milestones contained

l in RIP section 6.0.

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l -19. 6.2.1.c-1 Review whole Complete NONE

l body counter

i' libraries

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20. 6.2.1.d-1,2

, Licensee to perform Complete NONE

literature search and

order document to

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Commitment Status NRC Comment

support whole body

counter operations

( April 30,1985)

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21. 6.2.1.e-1

Licensee to Complete Personnel instructed

revise and in revisions

approve whole body

counting instructions to

include check of critical

parameters (April 30,1985)

22. 6.2.3.1 A policy statement Complete Provided by

will be developed Memorandum to Staff.

on why it is NRC will review to

appropriate to conduct determine need to

thyroid counts include in procedures

(April 30, 1985) (50-283/85-13-09).

23. -6.2.2.d A Radiation Complete NONE

Protection Supervisor

has been assigned oversight

responsibility of the whole

body counter operation

(February 28,1985)

24. 7.1.2.1 Complete re-instruction Complete Meetings held with

of all appropriate personnel appropriate personnel

regarding unnecessary on March 26, 1985

posting and labeling and March 27, 1985

(March 31, 1985)

25. 7.1.6.1 A Specific Health Physics Complete NONE

Supervisor was assigned

implementation and improvement

of the overall survey program

(February 28,1985)

26. 7.1.7.1 Licensee will evaluate if Ongoing Performed by Onsite

present practice for adequacy Assessor. Revisions

and timeliness of radiation to be made to RWP

surveys is acceptable Program if necessary

(February 28,1985) (7.1.7.2) Current

HP Supervisor noti-

fied of need for

adequate surveys.

27. 7.3.1 Nuclear Operation Manager Complete Memorandum No.

to issue a directive to all AD 85-69 issued

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Commitment Status NRC Comment

management regarding improving March 18, 1985

personnel contamination

monitoring (March 31,1985)

~28. 7.3.2.1 Licensee will review current Complete Licensee issued

practices and implement an May 6, 1985. Policy No. 35,

improved policy for NRC Notified " Radiation,"

minimization of contamination of delay Material and

and control of radioactive Contamination,"

material (April 30,1985) May 6, 1985.

Policy to be

implemented via

other milestones

contained in

Section 7.

29. 7.3.3.1 Licensee to complete Complete Completed on

review of Main Control April 22, 1985

Point (April 30, 1985) (CRE 85-251)

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30. 7.3.4.1 . Review Access Complete NONE

Control Points

(April 30, 1985)

31, 7.3.4.2 Institute policies / Complete (See 29)

' notify station personnel Findings of Access

of the restriction of Control Point

access points so as to reviews to be used

have minimal operations to improve current

impact (April 30,1985) access control point

situations

32. -7.3.5.1 Evaluate current problem Complete Review performed.

of circumvention of Review concluded

step-off pads and that poor frisking

frisking to determine practices

'if it is procedural combination of

(April 30, 1985) procedural inad-

equacies or poor

worker performance.

Corrective action

on going.

33. 7.4.1 The location and type of Complete Documented in

air sampling equipment Memorandum No.

will be established SS 85-78. Sampling

(April 30, 1985) for set up for compactor,

the Trash Compactor Sorting table use

Facility suspended pending

installation of

acceptable equipment

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page 6 of 8

Commitment Status NRC Comment

34. 8.1.2.1 Current Radioactive Complete Documented in

8.1.3.1 Waste Storage Areas Memorandum

8.1.4.1 Will be evaluated for: PNOS85-255,

consolidation, enclosure, dated April 30, 1985,

shielding PNOS85-254,

(April 30, 1985) dated April 30, 1985

Note: No commitments due on or before April 30, 1985

contained in section 9, "ALARA"

35. 10.1.1 Correct Water Complete Plan for repairs

related problems (Partial) complete (Memorandum

in HP facilities dated April 17,1985)

10.1.3 -Upgrade house keep Schedule for repairs

and appearance of (Memorandum undated)

HP facilities No apparent action

Develop plan and on 1) housekeeping

schedule to implement 2) appearance.

the necessary repairs (50-293/85-13-10)

(April 30, 1985)

36. 10.2.1.b The thyroid detector Complete NONE

has been repaired on the

APT chair (February 28,1985)

37. 10.2.2.b 1,2

Decontaminate and Complete Background levels

minimize recontamination identified. System

of the Ge(LI) system not contaminated

(March 31, 1985)

38, 10.2.2.d Develop training materials Complete Documented in NTD

in order to properly train #85-0198, dated

personnel to interpret March 27, 1985

Ge(LI) results (March 31,1985)

39. 10.2.5.a.1 ~

An evaluation of the range Complete Documented in

and calibration of R chambers Evaluation

will be completed Memorandum. A .025R

(March 31, 1985) R-chamber to be

ordered

40. 10.2.5.cl Upgrade calibration Complete New jigs in use

10.2.5.c2 jigs. Submit designs

(April 30, 1985)

Irrplement use (August 31,1985)

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page 7 of 8

Commitment Status NRC Comment

41. 10.2.7.1 Tag inoperable Complete NRC will review

Eberline instruments need for monitors

at TIP Area and Rad (50-293/85-13-11)

Waste Segregation Area

Out of Service. Assign

responsibility of units.

42. 10.3.1.1 Issue policy statement Complete NONE

-regarding use of yellow (Memorandum CRE

poly (April 30,1985)85-234)

(April 22, 1985)

43. 10.3.5.1 Coordinate activities Complete NONE

relative to use of

substitutions of supplies.

Initiate discussions

(April 30, 1985)

44. 11.1.-1 Complete a Procedure Plan Complete NONE

for procedures

(April 30, 1985)

11.3.1 Incorporate requirements Complete

for task analysis in

procedure plan

'(April 30, 1985)

11.4.1 Incorporate methodology Complete

for cross referencing of

procedures into procedure

plan (April 30, 1985)

11.5.1 A requirement to field Complete

test procedures or

instructions will be

included in the

. procedure plan

45. 111.6.a.1- A video tape segment Complete Video tape to be

will be incorporated into incorporated into

the General Employee GET. NRC to view

Training Program. (50-293/85-13-12)

(April ~30,1985)

46. 11.6.b.1 A memorandum will be Complete Memorandum No.

issued which provides VPN0 85-17, dated

guidance on the sets of

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February 28, 1985

procedures (February 28,1985)

Note: No commitment to be implemented prior to April 30, 1985

in section 12, " Radiation Materials Controls"

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Commitment Status NRC Comment

47. 13.1.1 Submit Radiological Complete NONE

13.1.2 Improvement Program (RIP)

to NRC (February 28,1985)

Initiate Implementation of

the RIP (March 15,1985)

48. 13.2.1 Establish a detailed RIP Complete NONE

scheduling network

(March 31, 1985)

49. 13.3.3 Implement basic Complete Implemented per

13.3.4 management concepts response to

13.3.5 described in these milestone

13.3.6 recommendations 11.6.a.1 NRC

(11.6.a.1, April 30, 1985) to view tape.

(See No. 45)

50. 13.3.11 Develop or revise a Complete Policy Statement

Nuclear Organization No. 19 revised

Policy to address impacts on April 18,

of changes in staffing, 1985.

organization or policy

.(April 30, 1985)

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