IR 05000298/1989004

Insp Rept 50-298/89-04 on 890123-27.No Violations or Deviations Noted.Major Areas Inspected:Solid Radwaste & Radioactive Matls Transportation Programs

ML20235T950
Person / Time
Site:	Cooper
Issue date:	02/23/1989
From:	Baer R, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20235T948	List: IR 05000298/1989004 ML20235T945
References
50-298-89-04, 50-298-89-4, IEB-79-19, NUDOCS 8903080537
Download: ML20235T950 (11)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-298/89-04 Operating License: DPR-46 Docket: 50-298 Licensee: . Nebraska Public Power District (NPPD)

P. O. Box 499 Columbus, NE 68602-0499 Facility Name: Cooper Nuclear Station (CNS)

Inspection At: CNS Site, Brownville,- Nebraska Inspection Conducted: January 23-27, 1989

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Inspector: @/MU B. Nicholas, $dnior Radiation Specialist

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Date cilities Radiation Protection Section Approved: , /d /rf Y h I & & V W23h R~. E. Baer, Chief, Facilities Radiological Date Protection Section

o Inspection Summary Inspection Conducted January 23-27, 1989 (Report 50-298/89-04)

Areas Inspected: Routine, unannounced inspection of the licensee's solid radioactive waste and radioactive materials transportation program Results: Within the areas inspected, no violations or deviations were identified. Two previously identified open items and one violation were close i h30 G

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DETAILS 1

' s . . Persons Contacted NPPD ,

• R. Horn,' Division Manager, Nuclear Operations

• L. Beilke; Radiological Support Superviso'r

• L. E. Bray, Regulatory Compliance Specialist G. D. Bray, Auxiliary Equipment Supervisor T.-J. Chard, Health Physicist J.' W. htton, Training Manager- .

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J..H. Kutler, Senior Chemistry and Health' Physics Specialist C. E. McElfresh, Radwaste Operator C. H. Putnam, Jr. , Quality Assurance-(QA) Specialist

• D. R. Robinson', Acting QA Hanage E. M. Rotkvic, Health Physics Training Instructor

• J.' V. Sayer, Radiological Manager-P. R. Windham, Technical Training Supervisor

.NRC .

• R. Bennett, Senior Resident Inspector, C.NS G. A. Pick, Resident Inspector, CNS

• Denotes those present during the exit interview on January 27, 198 . Followup on Previously Identified Inspection Findings (Closed) Open Item (298/8722-01): Health Physics Technician Environmental Training Records - This item was identified in NRC Inspection Report 50-298/8722 and involved the lack of training documentation for health physics technicians to perform environmental monitoring sampling tasks. The NRC inspector reviewed selected health physics technician's training records to verify documentation of environmental sample collection training in accordance with current job performance measure It'was determined that all health physics technicians assigned environmental sampling tasks during 1988 had completed the required training for environmental sample collection and the training was documented in accordance with procedur (Closed) Open Item (298/8723-02): Spent Resin Dewatering System - This item was identified in NRC Inspection Report 50-298/8723 and involved the lack of permanently installed piping between the radwaste spent resin systems and the spent resin dewatering system. The NRC inspector verifie that the temporary rubber hose used to connect the permanent radwaste spent resin transfer piping system to the spent resin dewatering system I had been replaced with permanent pipin {

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.- . e r . 3 (Closed) Violation (298/8827-01): Postaccident Sampling System (PASS),

Requalification Training - This violation was identified in NRC Inspection Report 50-298/88-27 and involved the failure to perform cemiannual PASS operator requalification training and document this training in records !

maintained by the Training Department. The NRC inspector verified that !

the licensee had conducted and documented PASS operator requalification in November 198 It was also determined that the licensee had written a Training Work Request (No. 88-01317) to track the semiannual PASS operator requalification training requirement. PASS operator requalification training is currently scheduled to be performed on or before March 24, 198 . NRC Inspector Observations The following are observations the NRC inspector discussed with the licensee during the exit interview on January 27, 1989. These observations are not violations, deviations, unresolved items, or open items. These observations were identified for licensee consideration for program improvement, but the observations have no specific regulatory requirements. The licensee stated that these observations would be evaluate QA Vendor Audit - The licensee had not completed the reapproval of the contract laboratory used to perform radwaste stream characterization analyses and analytical analyses of radioactive effluent quarterly composites (see paragraph 6), Process Control Program - The licensee had not received approval of their revised radwaste Process Control Program from the NRC (cee paragraph 7).

4. Organization and Management Controls, The NRC inspector reviewed the licensee's organization, staffing, and staff functional assignments relating to solid radioactive waste and transportation programs to determine agreement with commitments in Section XIII of the Updated Safety Analysis Report (USAR) and compliance with the requirements in Inspection and Enforcement (IE)Bulletin 79-19 and in Section 6.1 of the Technical Specifications (TS).

The NRC inspector verified that the organizational structures of the CNS radiological department and operations department responsible for the solid radioactive waste and transportation programs were as defined in the USAR and T The CNS staff assignments, management control procedures, and position descriptions were reviewed for the assignment of responsibilities for the management and implementation of the CNS solid radioactive waste and transportation programs. The licensee's transportation and solid radwaste management controls were described in Administrative Procedure 0.2, " Station Organization and Responsibility,"

Revision 6, April 14, 1988. Paragraph R designates the radiological support supervisor as responsible for ensuring proper receipt and shipment

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of: all radioactive material to and from the. plant. ;The organizational'

structureLand staffing off the radiological and operations departments forg

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managing _and implementing the. solid radwaste and transportation programs-appeared'to be sufficient to meet.the requirements for the routine performance of the. solid radwaste and' transportation activities.-

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'The NRC' inspector reviewed selected management approved procedures to conduct radioactive materia 1 Solidification, dewatering, packaging,

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transporte. tion, and receipt operations. A review'of the~1icensee's' ^

radioactive' materials transportationirecords indicated that the required suoervisor and QA reviews were being made according to established-L procedure The NRC' inspector noted that a QA> inspector performed a QA-surveillance on each radwaste shipment and reviewed the transportation

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records,to ensure the records complied with elements of 10 CFR Part 71,

'Subpart H.-

No violations or deviations were identifie . Training and Qualifications The NRC. inspector reviewed the licensee's training and qualification program for:CNS personnel involved in the transportation of radioactive material and solid radioactive waste activities to determine agreement with commitments'in Sectfon XIII of the USAR'and compliance with;the

. requirements in IE Bulletin 79-19 and in Section 6;1.4 of the T The NRC inspector reviewed the. individual training records of personnel in c operations, maintenance, QA, and health physics who had been assigned to radwaste processing and handling'and. transportation activities. The licensee's training'. records-indicated that those CNS staff who were-assigned to radwaste processing and transportation activities had received training in radwaste packaging and handling and transportation-requirements in mid 1988. The NRC inspector reviewed the lesson plans listed in Attachment 1 to this report and found them adequate to train personnel in the' processing and shipping of radioactive waste and-material The NRC inspector discussed the radioactive waste and transportation training program with the radiological support supervisor, health physics specialist, health physics technicians, radwaste operators, and station

' utility men. "These discussions indicated that the personnel involved in the processing and shipping of radioacti.ve waste materials possessed a working knowledge of the licensee's specific procedural requirements and applicable NRC, Department of Transportation (DOT), and burial site requirement No violations or deviations were identifie .

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i QA Audit Program 1

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, 'The'NRC inspector reviewed the licensee's QA audit and surveillance l

. programs for transportation of radioactive material and solid radwaste 'l packaging ~and handling to determine agreement with. commitments'in , 7j L -Section XIII of the USAR and compliance with the. requirements in-

.Section 6.2 of the T q

• The NRC inspector reviewed the QA s' surveillance and audit plans and ,

. checklists, . selected QA department procedures,: and the qualifications and- 3 training of QA auditors performing th'e surveillance and audits o i radwaste packaging;and handling and transportation activities...The NRC ,

inspector reviewed the licensee's latest audit performed in accordanc ~l with Quality Assurance Procedure (QAP) - 1200, " Quality Assurance Plan" ;

- Radioactive Waste Treatment and. Disposal, Revision 9, June 14,1988, '!

during the time period July 1,1988 through August 31, 1988. =The audit ,j team used a' checklist which appeared to adequately cover all. areas of '

! radwaste processing.and transportation activities as required by CNS ,

procedures!and verify compliance with NRC and 00T regulations. The NRC I inspector also reviewed selected QA surveillance performed on.radwaste' .;

packaging,. handling, and storage, and on all radwaste shipments during the :

period November 1987-through December 1988. The NRC inspector verified l that QA personnel performing audit and surveillance activities had  !

attended training on-radwaste' packing and handling and transportation i regulatory requirement I

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The licensee purchases 55 gallon drums fabricated as DOT Specification 17H 4 containers and strong-tight containers for packaging radwaste that' meet . l the DOT Specification 7A Type;A packages. The NRC inspector reviewed the ;

audits performed by:the licensee on the two vendors and determined that z

j the vendors,wereisupplying~ packages manufactured in accordance with DOT- !

specifications. 'The NRC inspector verified that the two vendors were on the licensee's qualified suppliers lis The NRC inspector determined that the' contract laboratory used by the licensee for analyses of radioactive effluent quarterly composite samples and characterization analyses of radioactive waste streams was due for reapproval in November 1988.> At the time of the inspection, the licensee had not completed the reapproval of_the contract laboratory in accordance

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with.NPPD procedures to meet the requirements of remaining on the licensee's qualified suppliers lis The NRC inspector cautioned the licensee that= the contract laboratory should be requalified prior to acceptance of any further analyses results. This observation was-discussed with the. licensee during the inspection and at.the exit

- interview on January 27, 1989, and the licensee stated that the contract I laboratory would be reapproved as soon as possible and prior to submitting the 1988 radioactive waste stream samples for analysis to meet the requirements of 10 CFR Part 61.5 The NRC inspector verified that the licensee had received NRC Form 311

" Quality Assurance Program Approval," Approval No. 0484, Revision No. ' 2, j i

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expiration date November 30, 1992, which provided NRC approval 1that th licensee's submitted QA program complied with 10 CFR Part 71, Subpart No violations or deviations were identifie . Solid Radioactive Waste Management'

The NRC inspector reviewed the licensee's solid radioactive waste program

, to determine agreement with commitments in Section'IX of.the USAR and compliance with the requirements in Sections 3/4.21.E, 6.5.1.F, 6.6, and 6.8 of the T The NRC inspector inspected the licensee's radioactive waste solidification facility and equipmen Several minor modifications had been installed since the previous inspection in November 1987. These included a drum flushing system and equipment for testing the solidification stability of each batch processe Tne NRC inspector inspected the installation of the spent resin dewatering system. The licenste had replaced the temporary rubber hose used to connect the radwarte spent resin transfer piping system to the spent resin dewatering' system with permanent piping. The NRC inspector also reviewed the draft Radwaste Procedure 2.5.4.4, "NuPac Dewatering System Operating Procedure," which will replace the Special Test Procedure 85-14,

"CNS/ Nuclear. Packaging Onsite Radwaste Procedure," previously used for operating the spent resin dewatering system. The licensee'had performed a 10 CFR Part 50.59 safety review and determined that this equipment would not be an unreviewed safety question and no TS changes would be necessar The NRC inspector inspected the installation and operation of the licensee's new shredder / compactor installed in the multipurpose facilit QA Surveillance Report 88-1200-02 issued a finding involving the lack of a procedure for filling radwaste containers using the shredder / compacto The NRC inspector reviewed the licensee's, response to this finding and the procedure change to Maintenance Procedure 7.9.2, " Filling Radwaste Containers with Waste."

The NRC inspector reviewed the licensee's revised Process Control Program (PCP) submitted for NRC approval on October 28, 1988. At the time of the inspection, the licensee had not received NRC approval of their revised PC During 1988, testing was conducted on samples of the CNS radwaste cement solidification of waste stream materials. This testing

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was performed to satisfy the licensee requirements of U.S. Ecology's burial facilities in Nevada and Washington. These facilities require that

" stable" solidified waste meet the requirements of the NRC Technical Position on Final Waste Form," Revision 0, May 11, 1983. The results of these tests were submitted to the NRC for review and approval in November 1988. The licensee had not received NRC approval of their solidification proces Until the NRC approves the licensee's PCP and '

waste stream test results, the licensee cannot send solidified " stable" waste to U.S. Ecology's burial sites. The licensee has been unable to

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make " stable" waste = shipments since_ June'1988 when their previous burial

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permit expire >

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The NRC. inspector reviewed the semiannual effluent release reports for the periods January 1 through June 30, 1987, July 1 through December 31, 1987- ,

and January 1 through June 30, 1988. These reports.were written in the >

format described in NRC Regulatory Guide'1;21 and contained the-

.information required by TS. During this time period, the: licensee had'

completed 57-radioactive material shipments by exclusive use vehicle to burial sites in Washington, South Carolina, and Nevada. The licensee had also performed 10 spent fuel shipments during the period January 1, 1987, through June 30, 198 No violations or deviations were identifie . Radioactive Waste Classification, Waste Characterization, and Shipping Requirements

.The NRC inspector reviewed the licensee's program for disposal of low-level radioactive waste including management controls, quality control program, shipping manifests, waste classification, waste form and:

. characterization, shipmentilabeling, tracking of waste shipments, and burial facility license conditions to determine compliance with the requirements of 10 CFR Parts 20.311, 61.55, and 61.5 ~

The NRC inspector reviewed the licensee's procedures listed in Attachment 1 to this report and found the licensee's program'for ,

classification and characterization of radioactive waste appeared to meet the requirements of 10 CFR Part 61. The licensee, through a contractor laboratory, performed annual radiochemical analyses on samples of the various radwaste streams forLthe requirements in 10 CFR Part'61.55 and 61.56. The test sample analyses results were used~for determination of-radwaste classification and isotopic composition of the radwaste source The licensee performs isotopic analysis for isotopic characterization on each batch of radwa'ste solidified and employs correlation factors for characterization of isotopes not directly identified as determined by the contractor laboratory analyses test result The NRC inspector reviewed the licensee's radioactive waste shipment manifest form and shipping papers that accompany'each shipment of radioactive waste. The NRC inspector verified that the mtnifest complied with the requirements of 10 CFR Part-20.311. The NRC inspector determined that the licensee's radwaste disposal program was being conducted in such a manner that the requirements of 10 CFR Parts 20.311, 61.55, and 61.56 cppeared to have been satisfie No violations or deviations were identifie ,

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, Transportation Activities The NRC inspector reviewed the licensee's transportation program to determine compliance with the requirements of 10 CFR Parts 20 and 71 and-D0T regulations 49 CFR Parts 170-18 Procurement and Selection of Packages The NRC inspector reviewed the licensee's program for procurement and selection of packages used for transport of radioactive materials to determine compliance with the requirements of 10 CFR Parts 71.12 and 71.54 and 49 CFR Part 173.41 The NRC inspector reviewed the licensee's procurement of 00T and NRC certified packages. The NRC inspector noted that the licensee ships low specific activity (LSA) waste in steel boxes as DOT Specification 7A Type A strong-tight containers or in steel 55 gallon drums manufactured in accordance with D0T Specification 17H. The licensee maintains current documents on the manufacturer's design testing, maintenance, and NRC Certificate of Compliance for all radwaste packages and casks used by the licensee. The licensee was on the user's list for all NRC/ DOT packages being used. A review of the licensee's shipping records and discussions with the licensee's staff indicated the manufacturer's handling and loading procedures were used in preparing casks for shipmen Preparation of Packages for Shipment

The NRC inspector reviewed the licensee's program for preparation of radioactive material packages for shipment to determine compliance with the requirements of 10 CFR Parts 20 and 71 and 49 CFR Parts 171, 172, and 17 The NRC inspector verified that the licensee had established procedures and checklists for preparation of radwaste for shipmen These procedures provided for a visual inspection of the package prior to filling the ' container, instructions for closing and sealing .

the package, marking and labeling requirements, and determining the radiation and contamination limits for packages. Discussions with licensee personnel indicated that individuals involved in transportation of radioactive materials possessed a working knowledge of the related procedures and 00T and NRC regulations pertaining to the preparation of packages for shipmen Delivery of Completed Packages to Carrier The NRC inspector reviewed the licensee's program for delivery of completed packages.to a carrier for shipment to determine compliance with the requirements of 10 CFR Parts 20 and 71 and 49 CFR Parts 170-17 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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-The NRC inspector verified that.the licensee's procedures ~ included ~ .

theLrequired NRC and D0T regulations. .The review of licensee records

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L .and shipping papers indicated that the licensee had prepared .

• appropriate shipping' papers in~ accordance with approved procedures and that the. shipping papers included the"necessary information t comply with regulatory requirements. The license'e used onl *

exclusive use carriers for all radioactive materials shipments'and

, assured the following items were in.accordance with NRC and DO regulations and station procedures: . radiation -levels were~ within required limits, transport vehicle was properly placarded, surface" contamination on packages did not exceed' requirement levels, and blocks and/or braces were.in place to prevent damage lor shifting o n; load during transi ' '

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The NRC inspector observed the licensee' preparing, loading,' labeling, -

placarding, surveying, and completing shipping' documentation for~at *

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cask of dewatered spent resin. The shipment was classified as.LSA '

and shipped on an exclusive use vehicl t

' Records, Reports, and Notifications

'The NRC inspector reviewed the licensee's program of records and reports to determine compliance with the requirements of 10 CFR ,

Part 71 and 49 CFR Part 171.and 17 "

The NRC inspector reviewed selected records of 20 radioactive:

material shipments made by the licensee during the calendar .

year 1988. The licensee's shipments were adequately documented to meet NRC and D0T regulations. The. licensee maintained records of all radioactive material shipments as required. -The. records included all ,

shipping documentation and' required notification dat No violations or' deviations were identifie . Exit Interview The NRC inspector met with the NRC senior' resident inspector and licensee representatives denoted.in paragraph 1 of this report at the conclusion of-the. inspection on January 27, 1989. .The NRC inspector summarized the-scope of the inspection and discussed the inspection findings and tw inspection observations for licensee evaluation as presented in thi report. The NRC inspector also closed three previously identifie inspection findings as discussed in paragraph !

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• ,7 ', ATTACHMENT 1H "

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NRC Insp'ection Report 50-298/89-04'4

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, i . Documents Reviewed

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~ Title? 4 3 3 LRevision: Date- ' <

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1. , Adm'idistrative Pro'cedures , 4 O.2, Station'0rganizationcand Responsibilit ' '

6 04/14/88 L, 0.17, Selection and Training of 5tation  ; Q ~8 04/07/88 Personnel ,  !

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' Radwaste Proce' dure's

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2.5)4.1, Soli _dWetWastePackahing,4 Storage,- ' '

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and-Transfer System .

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2.5.4,2,; Solid Wet Waste Drum Filling 5' 10/29/84~

L 2.5.4.3, Radwaste Drum Mixer Operatio .09/25/86L

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2.5.4.4,RNuPac Dewatering System Operating :0 draf Procedure'

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-Training' Lesson Plans

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L 0TH010-01-01. Radwaste' Packaging and Handling /08/88

'0TH010-02-01, .. Drum Solidification Quality 1 12/07/88 Control OTH010-03-01, Radioactive Waste Management ~ 1 12/07/88-

' Maiiltenance' Procedure .

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n 7 9.2, Filling Radwaste Containers With Waste <' 13 06/16/88

< 0 Health Physics Procedures '

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9.5.1, Receipt of Radioactive Materials 5 12/15/88 9.5.3.1, Radioactive Waste Shipment for. Burial 6 ~08/10/88 9.5.3.2, Radioactive Material Shipment- . 4 08/18/88'-

9.5.3.3,- Condensate Cleanup Waste Resins and 5 10/06/88-Spent Resins' Classifi:ation and Listing-9.5.3.4, RWCU Waste Resj7s Classification and 4 10/06/8 Listing 9.5.3.5, Dry Radioactive Waste Classification 5 '11/09/88 and_ Listing .

-9.5.3.6, Completion of Waste Manifest 3 03/03/88 L Instructions 9.5.3.7,. Cask IF-300 Shipment 4 02/01/88 9.5.3.8, Waste Sludge Classification and Listing 2 10/03/88 9.5.3.9, Solidifying and Packaging Contaminated .2 01/14/88 Liquids for Burial 9.5.3.10, Waste Stream Sampling 1 10/27/88

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. v . Quality Assurance (QA) Audit QA Audit. Report 88-12, QAP-1200 - Radioactive Waste Treatment and !

Disposal, dated September 7, 198 '

QA Vendor Audit Report S87-14, Van Leer Containers, Inc.,

dated February 20, 198 QA Vendor Audit Report S87-15,~ Plymouth Manufacturing, Inc.,

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' dated February 18, 198 . Semiannual Effluent Release Reports January 1 through June 30, 1987

" July 1 through December 31, 1987 January,1 through June 30, 1988

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