Technical Specification 5.5.4 states that the effluent monitoring program shall be contained in the
ODCM. Section 2.1.1.2 of the
ODCM specifies the actions to be taken with less than the minimum number of radioactive liquid effluent monitoring instrumentation channels
operable. Table 2-1 of Section 2.1.1.2 requires, in part, at least two independent samples be analyzed prior to a liquid release with radiation monitor RE-18
inoperable. Contrary to this, on June 26, 2015, with RE-18
inoperable, the licensee made a release from Unit 1 Waste Monitor Tank 2 without first collecting two samples from the tank. The licensee identified the error upon review of the release paperwork and documented the event in CR 10089229. This violation was evaluated using the guidance in
IMC 0609, Appendix D,
Public Radiation Safety Significance Determination Process, and was determined to be of very low safety significance (Green) because it did not represent a substantial failure to implement the effluent release program and post-release data indicated that the release did not exceed
10 CFR 50 Appendix I dose values.
