IR 05000321/1990003
| ML20012E274 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 03/23/1990 |
| From: | Adamovitz S, Decker T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20012E272 | List: |
| References | |
| 50-321-90-03, 50-321-90-3, 50-366-90-03, 50-366-90-3, NUDOCS 9004030110 | |
| Download: ML20012E274 (11) | |
Text
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,,. w Report Nos!:.50-321/90-03 and 50-366/90-03
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- Licensee
- Georgia Power Company.
L- . . P. 0. Box'1295- ' . . Birmingham, AL' 35201' . Docket-Nos.:' 50-321 and 50-366 Licensee Nos.: DPR-57 and NPF-5' . > , -. . .t ~ ' Facility Namei " Hatch-1 and 2 ' . Inspection Conducted: LFebruary-20-23, 1990 i ' aM M23 O I \\Insheet
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4r 5.. Adamovitz,,. s' ~ ' Date Signed Approved-by: [
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- 7'gT. R. Decker, Chief..
.Date 5fgned _
. Radiological Effluents and Chemistry Section-Emergency Preparedness and Radiological , Protection Branch . . < . Division'of Radiation Safety and Safeguards ,, SUMMARY- , , . ,, Scope:~ ~ g . Thisiroutine,1 unannounced inspection was conducted in the areas of liq'id and- ' u , W. ;
- gaseousstadwaste. management,.. liquid and gaseous effluent monitoring, and
_ environmental monitoring..- ' _
i ' , ' E y (Results: y ' +, , ' 1The1116ensee ' continued the monitoring program for the contaminated "swampjarea D
- and the. tritium levels in groundwater (Paragraphs 7.a and 7.b).>
, , n The:iicensee had successfully initiated a program to reduce liquidjradwaste? 'j
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-system inleakage'and had adopted a goal-of 30,000 gpd per unit (ParagraphL4)., ' h .a
3:x L wo. noncited violatio_ns ~(NCVs) were identified.
One concerned the minimum T
dilution flow alarm / trip setpoint for Units 1 and 2.~ flow monitors during: liquid effluent-releases and:had been:1dentified by audit personnel.(Paragraph 2). 'A-f ':second: NCV! dealt with. the; incorrect liquid-radwaste discharge monitor, setpoint
' Land the: incident'was reported to the NRC in LER 50-321/1989-017(Paragraph 8).
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Persons Contacted Licensee Employees y
- B. Arnold, Chemistry Supervisor:
- K.:Breitenbach,-Engineering Supervisor r
B. Conant, Chemistry Foreman
- 0.-Fraser, Quality Assurance Site Manager R. Jones, Senior Plant. Engineer-M; Link, Health Physics Supervisor
~ *A,' Manning, Senior Quality Assurance Field Representative
- V.. McGowan, Acting Chemistry Superintendent
,
- T. Moore, Assistant General Manager Plant Support
- A. Payne, Senior Plant Engineer i
- D. Self, Representative, Oglethorpe Power Company W. Stovall, Radwaste Supervisor
- S. Tipps, Nuclear Safety and Compliance Manager D.-Woodson, Associate Engineer-
- R. Zavadoski, Manager Health Physics / Chemistry NRC Resident Inspectors
,
- J. Menning R.-Musser
- Attended exit interview-2.
.Audi_ts(84750) The inspector reviewed Quality Assurance (QA) audits.within the scope 6f this inspection and discussed the results with the onsite auditors and Chemistry personnel.
The audits reviewed were: s 89-RWC-2, Audit of Radioactive Waste Control, conducted ' November 28, 1989-January 2, 1990 90-0DCM-1. Audit of Offsite Dose Calculation /HP and Chemistry, conducted February 7-15, 1990.
' A finding concerning the minimum dilution flow alarm / trip setpoint for the ' Units 1 and 2 flow monitors during liquid effluent releases had been identified in the' audit report 90-0DCM-1._ The flow monitors had the capability to automatically terminate a liquid release if the minimum-flow rate was not maintained. The auditor had determined that the flow monitor - .
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c . [ 2-setpoint for minimum dilution flow had been permanently set at 10,000 gallons per minute (gpm).
However, plant procedures for liquid releases allowed minimum flow rates of greater than 10,000 gpm and the > . _. setpoint had not been changed if a greater minimum dilution flow rate was requi red.- The inspector discussed radwaste. releases with_ Operations
' ' personnel and determined _that although the monitor setpoint. had not been changed, ' Operations Radwaste personnel visually monitored.the dilution flow rate to ensure that the greater minimum flow rate _was maintained throughout the liquid release.
In. response to this audit finding,
Chemistry personnel had revised the procedure 64CH-RPT-004-0S " Liquid. Effluents: Reports" to disallow any releases requiring minimum flow rates of greater than 10,000 gpm.
The release permit would be terminated-and
Chemistry would contact Radwaste personnel to reprocess the liquid waste.
The licensee was also'considering replacement of the flow monitors with newer models which would allow setpoints to be easily changed.
Technical Specifications (TS) 3.14.1 (Unit 1) and 3.3.6.9 (Unit 2) require the
alarm / trip setpoints of radioactive liquid effluent monitoring instrumentation channels to be determined in accordance with the Offsite Dose Calculation Manual (0DCM).
The ODCM Revision 5. for Units 1 and 2 specifies that the flow elements FEN-501 (Unit 1) and FEN-502 (Unit 2) be capable of isolating liquid radwaste discharges if the predefined minimum dilution flow is not maintained. The inspector' informed licensee - management that failure to reset the minimum dilution flow alarm / trip setpoint for liquid releases requiring a minimum dilution flow of greater than 10,000 gpm would be considered an apparent violation of TS 3.14.1 ' _(Unit 1) and 3.3.6.9 (Unit 2) and ODCM Revision 5.
Since the licensee had identified this problem and implemented appropriate corrective actions, a , licensee-identified noncited violation (NCV) would be identified.
The criteria, specified in Section V.G 1 of the NRC Enforcement Policy were satisfied and additionally no response would be required (NCV 50-321, 366/90-03-01).
T% onsite. audit group was considered a licensee strength.
Education and work experience of the various auditors were consistent' with the plant , areas being examined. Also audit techniques (i.e. substantial field work) provided thorough and in-depth assessments.
One NCY was identified.
3.
Semiannual Radioactive Effluent Release Reports (84750) The inspector reviewed the Semiannual Radioactive Effluent Release Reports , for 1988 and 1989.
The effluent information presented in Table I was ' obtained from current and previous effluent report.. ] p m a.
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, Table l' . Effluent Release Summary for Hatch Units 1 and 2 l Activity Released (curies) 1986 1987 1988 '1989 1; Gaseous Effluents . ' _ Fission.and Activation 1.98E+4 2.11E+4_ 2.74E+3 1.25E+3 - Products lodines_and Particulates 3.28E-2 3.69E-1 3.90E-2 7.28E-3 Tritium 3.33E+1 7.08E+1 3.05E+1 5.41E+1 2.
Liquid Effluents.
, Fission and Activation 7.90E-1 8.15E-1 9.83E-1 2.48E-1 " Products Tritium-2.85E+1 2.82E+1 4.40E+1 5.44E+1 With the exception of tritium, radioactive liquid and gaseous effluents decreased in 1989.
The licensee attributed the decrease in effluents to good fuel integrity with few leakers.
Additionally, the reports _ did not identify any unplanned liquid or gaseous releases to unrestricted. areas exceeding I curie, excluding dissolved and entrained gases and tritium, for liquid effluents, or 150 curies. of noble gases or 0.02 curies of ' radio-iodines for gaseous releases.
'No violations or deviations were identified.
> 4.
Liquid and Gaseous Releases (84750)
- !
a.
The inspector toured selected portions of the facility's liquid radwaste systems and discussed system operation with cognizant licensee representatives.
Chemistry personnel were responsible for sample collection, subsequent analysis, and generation of the release ' permit.
Actual valve alignments for the liquid releases were- ' performed by the Radwaste group within Operations.
Liquid releases were allowed when-the liquid radwaste monitor was inoperable if two independent samples were ccliected and analyzed.
This requirement was reflected in the procedure 64CH-RPT-004-0S " Liquid Effluents: Reports," temporary change 90-55,- February 15, 1990. -The inspector reviewed 12 liquid release permits completed during 1990. All-packages appeared complete and duplicate samples had been collected-when required.
During January 1989, the licensee had initiated a program to reduce inleakage into the liquid radwaste system.
Inleakage rates during 1988. typically ranged from 40,000 to 80,000 gallons per day (gpd) per unit with spikes as high as 110,000 gpd per unit.
A Radwaste Inleakage Reduction Team was formed and system walkdowns of both units were performed in order to identify the sources of the inleakage.
The investigation concentrated upon areas of known high
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tt ' inleakage, specifically the Units 1 and 2 Turbine Buildings and the Unit 2 Reactor Building.
Major sources of equipment and-floor drain inleakage were identified and repaired, and the licensee adopted an , inleakage goal of 30,000 gpd per unit.
The inspector examined ' l graphed trends of equipment and floor drain-inleakage for both units from February 1988' to January 1990.
Typical inleakage rates during 1989 for Unit I ranged from 15,000 gpd to 40,000 gpd with most-values.
below 30,000 gpd.- Unit 2 inleakage. rates. for 1989 typically ranged from less than 10,000 gpd to 60,000 -gpd with most values below 30,000 gpd.
The licensee was tracking inleakage rates daily as part of a' Daily Radwaste and Auxiliary Report, b'. .The inspector reviewed three 1990 gaseous waste release packages for the Main' Stack, the Recombiner Building Vent and the Units 1-and 2 Reactor Building _ Vent.
The packages appeared _ complete with - appropriate sign-offs.
, No violations or deviations were identified.
5.
Leak Testing of High Efficiency Particulate Air (HEPA) Filters and Charcoal Adsorbers in Ventilation Treatment Systems (84750) Testing of air cleaning systems for leakage was performed by a: licensee contractor, utilizing approved plant procedures with equipment calibrated-by.the contractor. HEPA filter leakage testing was performed with dioctyl phthalate _(DOP), and adsorber charcoal leak testing was performed with a halogenated hydrocarbon aerosol.
Methyl iodide testing of charcoal samples was performed offsite by a contractor laboratory. The licensee's surveillance procedures for the leak tests also included instructions for visual inspections of the filter trains.
The inspector reviewed the test packages and results of in-place-leak tests for the following systems: . Unit 1 Standby Gas Treatment Filter Train A (in place leak test only) February.1990 Unit 1 Standby' Gas Treatment Filter Train B. January 1990 Control Room Habitability Filter Train A. January 1989 Control Room Habitability Filter Train B, March 1989 Unit 2 Standby Gas Treatment Filter Train A, November 1989 Unit 2 Standby Gas Treatment Filter Train B November 1989 , , The_results of all system tests appeared to be adequate.
No violations or deviations were identifie e s , i ... . n.
't i , ,.,(,. . ! 6.. EffluentMonitoringInstrumentation(84750)
$ The inspector accompanied by a licensee representative ' toured selected effluent monitoring stations.and verified the operability of recorders and monitor read-outs in - the control room.
The. inspector also reviewed electronic and - source calibrations for. both units' liquid radwaste monitors conducted November 1989 and the plant service water monitor conducted September 1989.
Monitor calibrations were performed on a plant-refueling outage frequency-using an NIST-traceable liquid calibration source containing Cs-137.
In the past, solid " transfer" sources were' -j cross-calibrated to the liquid calibration source for use as check sources
between calibration' periods.
Recently the licensee decided to discontinue
the monthly!" transfer" source checks and rely on the 18 month efficiency calibrations.
Periodic qualitative source checks were still required ~ by technical specifications but these checks only served to verify that the l instrument was reading onscale and did not serve as a quantitative check of the monitor's efficiency.
The licensee had already discontinued the monthly efficiency checks for -the liquid radwaste monitors and - was -
considering doing the same for the reactor building closed cooling water ! (RBCCW) and plant service water (PSW) monitors.
The inspector ; and
licensee discussed the benefit of interim-efficiency checks between 18-
month calibrations. The licensee was considering reinitiating the interim checks but probably not on a monthly basis.
The inspector also reviewed monthly calibration factors for gaseous effluent monitors conducted during 1990.
The monitors-included the Units 'I and 2 reactor building vents, the recombiner building,;the main stack,.and the Units 1 and 2 offgas pretreatment. The licensee , was in the' process of upgrading the effluent mo'nitoring instrumentation from analog to digital read-outs.
General ' Electric "NUMAC" systems had been installed for the following monitors: liquid radwaste effluent, pretreatment offgas, post treatment offgas, main
steam, and post LOCAs.
Plant service water and RBCCW monitor.
.! read-outs were being upgraded during the current outage.
The main i' stack monitor still utilized an analog readout.
The. inspector reviewed a computer summary of effluent monitor - problems from 1987-1990 to determine if there were an excessive . number of problems or extended periods of inoperability. The listing ' identified 11 incidents of operability problems for the Unit 1 Reactor Building Vent radiation monitor during 1989..The monitor problems included the source check mechanism not functioning .! properly, the monitor not responding properly to the source, or anomalous monitor spiking.
In all cases maintenance work orders were ' written for monitor repair.
No violations or deviations were identified.
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l I 7.
Environmenta1' Monitoring (84750, 80721)' , e a.
Contaminated Swamp , During"1986, a release of radioactive water occurred due to the partial. drainage of the spent fuel pools.
The radioactive water drained into the onsite swamp-east of the plant cooling towers. The r licensee.'. committed to an augmented radiological environniental i monitoring program. for the swamp area and provided a report to the NRC summarizing: the 1988 results of the augmented program.
During- , the current inspection, the inspector toured the swamp area with-a , '* cognizant licensee representative and reviewed 1989 sample results.
F During 1989, the-licensee collected muck and vegetation samples from 6 locations in. the: swamp area ~ including 1 background location.
' = Duplicate.. muck; samples were collected from four' locations.
' Triplicate muck samples. were collected from one location, and a single sample was collected from the remaining location.
A single vegetation sample was collected from each of the six sampling sites.
' Muck sample results generally exhibited the same high variability as
1988 'results among samples collected from the same location. Sample ' ' analyses results were averaged from duplicate or triplicate sample collections for 'a single location and compared to 1988 average results.
In general, Co-60, Cs-134 and Cs-137 were the predominant radioisotopes identified and activity levels didn't change.
.significantly from 1988 to 1989.
Muck samples collected from the area where the water from the spent fuel pool spill entered the swamp showed the highest isotopic-activity.. Average 1989 values for muck samples collected from this location were calculated to be ' ' 4,627 pCi/kg dry, 3,153 pCi/kg dry, and 12,790 pCi/kg dry for 00-60, C Cs-134, and Cs-137, respectively. The average 1989 values for Co-60, Cs-134, and Cs-137 at the remaining five sampling locations were all , less than 1000 pCi/kg dry.
Cesium-137 activity in vegetation samples s s collected in 1989 ranged from 36 pC1/kg wet to 87 pCi/kg wet and generally were less than 1988 values. ' The 87 pCi/kg wet value for ,g.' Cs-137 was from a background vegetation sample.
f The licensee also performed quarterly " walk-over" surveys of the I contaminated areas from the yard drain to the pond or swampy areas, n~ The inspector reviewed 1989 data which showed direct readings from 5 micro R/hr to 28 micro R/hr.
b.
Tritium Contaminated Ground Water The licensee continued to conduct an onsite groundwater monitoring program due to elevated tritium levels in the groundwater. The elevated levels were presumed to have originated from leakage or seepage from Unit 1 plant structures several years previously.
Prior to 1985, the licensee reported quarterly to the NRC the results of the monitoring program.
The quarterly reports were terminated in , 1985, although the licensee committed to continuing the program with program records to be maintained for NRC review.
The inspector ,W i
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, " reviewed the monthly results of the groundwater tritium program from , January (1989 to January 1990.As reported in a previous' inspection l report 50-321,'366/88-19), the groundwater wells having the highest-f concentration of tritium were those immediately adjacent to the Unit
1 Turbine Building.
These wells were identified as T3 and N9B, and p tritium concentrations ranged from 21,100 pCi/1 to 119,000 pCi/1~ for F the well T3 during 1989.
Tritium concentrations.for well N98 ranged from 86,600 pC1/1 to 316,000 pCi/1 during the same time period.
Both wells _ showed a - definite decrease in. tritium activity during the
' '13 months.- ' The 10 CFR Part 20, Appendix B, -Table II, Column 2,- value for offsite ~ , p maximum permissible concentration (MPC) for tritium effluents was ' 3E6 pCi/ liter.
On this basis, the maximum concentration observed in the groundwater was.approximately 10.5 percent of the offsite MPC.
During the inspection, the inspector requested and received two split , groundwater samples from the wells T3 and N9B.
These samples would .j be analyzed by the RII laboratory and the results compared with the i ~ 1.icensee's as part of the RII confirmatory measurements program.
c.
The' inspector also reviewed the licensee's Annual Radiological , - Environmental Surveillance Report for 1988.
The licensee had used ' the'NRC " Criteria.for Comparing Analytical Measurements" to determine agreement with known. values for EPA cross check results.
As "j discussed in the report 50-321, 366/89-32, using the EPA's one sigma l value-to calculate a range of-agreement by the NRC acceptance l criteria allowed a wider range of acceptance values.
Typically, environmental laboratories used the EPA's two sigma uncertainty as a warning limit and three sigma as an "out of control" limit requiring
-_ investigations into the cause of the d_isagreement.
During the - < inspection of the licensee's Power Supply Laboratories conducted November 15-17, 1989, (50-321, 366/89-32; 50-424/89-34, and.. 150-425/89-39) laboratory and' corporate personnel agreed to use the - EPA's three sigma-control limits and to delete the NRC acceptance criteria from future radiological environmental monitoring reports.
i n No violations or deviations were identified.
' 8. - Licensee Event Report (LER) Review (92700) The inspector reviewed the LER 50-321/1989-017 and discussed the corrective actions that had been implemented with licensee personnel. The LER dealt with incorrect liquid radwaste discharge monitor setpoints and identified personnel error as the cause. This condition was identified on November 28, 1989 when Chemistry personnel were determining efficiency ~ factors'for the newly installed liquid radwaste (LRW) discharge radiation monitors.
At that time, Chemistry personnel discovered that the efficiency factors for the old monitors were incorrect and resulted in the setpoint being less conservative than required by TSs 3.14.1 (Unit 1) and 3.3.6.9 (Unit 2). The liquid radwaste monitor was a backup to isotopic a J
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' , analysis of the tank and ~the setpoint served an isolation function to prevent possibly exceeding 10 CFR 20, Appendix B Table II, Column 2.
- The licensee's investigation determined that the incorrect efficiency factors had been used since June 1985. At that time, a correct efficiency
. factor was calculated using a liquid Cs-137 source and logged into the LRW discharge monitor computer, a Hewlett Packard (HP) Model 9845.
The discharge monitor computer performed a setpoint calculation prior to each liquid discharge using the stored monitor efficiency factor.
However, at the same -time, a new Nuclear Data (ND) system was being installed to replace the HP system as the LRW discharge monitor computer.
Functional tests for the ND system software and hardware were performed using a i monitor efficiency factor based upon actual radwaste tank content, a method-utilized prior to using the liquid Cs-137 standard. System experts failed to install the correct efficiency factor based upon the Cs-137 standard.
Once the new monitors were installed and calibrated using the liquid 'Cs-137 source, monthly checks were performed against the correct Cs-137 ' data to' verify the efficiency factors but the incorrect efficiency factors, loaded into the monitor computer, were never checked.
,The licensee's corrective actions' included installing the correct efficiency factors into the ND system software; revising the procedures 62CI-CAL-009-05, " Liquid Radwaste Monitor," 62CH-ADM-001-0S, " Chemistry . Program"' and 64CH-ADM-002-0S, " Chemistry Forms" to require periodic ' comparison of current efficiency factors with those-stored in the LRW discharge monitor computer; and examining 10 percent of the LRW' discharge permits generated since 1985 (594 permits out of 6,000 releases) to verify that no TS/ instantaneous discharge rate limits had been exceeded.
0f the permits examined, the licensee did not identify any releases that exceeded TS instantaneous limits.
The inspector reviewed procedural change forms and verified that the referenced procedures had been altered to include > requirements to check the efficiency factors stored in the computer. The inspector also reviewed selected permits that the licensee had examined and calculated the correct monitor setpoint.
TSs 3.14.1 (Unit 1) and 3.3.6.9 (Unit 2) require the alarm / trip setpoints of the radioactive liquid effluent monitoring instrumentation channels to be set to ensure that the instantaneous limits as specified in 10 CFR 20, Appendix B, Table II, Column 2 are not exceeded.
The inspector informed-licensee management that failure to set the liquid radwaste monitor setpoint to prevent exceeding the 10 CFR 20 instantaneous limits would be considered an apparent violation of TSs 3.14.1 (Unit 1) and 3.3.6.9 (Unit 2).
Since the licensee had identified this problem and implemented appropriate corrective actions, a licensee-identified NCV would be identified.
The criteria specified in Section V.G.1 of the NRC Enforcement Policy were satisfied and additionally, no response would be required (NCV 50-321,366/90-03-02).
One NCV was identifie.y q%!
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a.
The licensee-issued daily chemistry reports which summarized selected , , , . chemistry parameters for various plant systems for both units.
The
I-inspector. reviewed 20 reports covering the past 6 months of plant operation.- Dose equivalent iodine (DEI) levels for both units were . H low with7 levels typically in the E-3 uCi/gm to E-4 uCi/gm range.
' _.
. Copper concentrations in the reactor water were also tracked due to P ' the licensee's condenser tubes being constructed of brass.
Unit 2
brass condenser tubes were-replaced during the latter part of 1989
s > , with titanium and Unit I tubes were to be replaced during.the current
outage, b.
The licensee also issued a daily Radwaste and Auxiliary Report which summarized ~the amounts of liquid radwaste processed; radwaste system inleakage and auxiliary systems' parameters.
During a review of-selected reports, the-inspector noted that the Unit 2 reactor building closed cooling water (RBCCW) showed elevated levels of gross , gamma activities typically 50-75 cpm /ml.. The licensee indicated i that the gross gamma levels were due to residual contamination =left over from incidents of spent fuel pool heat exchanger tube leaks.
' During February 1988, Unit-2 RBCCW gross gamma activities reached , 4,000 cpm /ml due to heat exchanger leaks. - Also.during June 1989, _t RBCCW gross gamma activity reached 240 cpm /ml and five heat exchanger tubes were repaired.
The licensee did not _ identify any - heat exchanger leaks ' during 1988 or 1989 for Unit 1 and gross gamma activity was currently 14 cpm /ml for that unit.
No violations or deviations were identified.
10. Exit Interview The inspection scope and results were summarized on February 23, 1990, , with-those. persons indicated in Paragraph 1.
The inspector described the ' areas inspected and. discussed in detail the inspection results listed below.. Proprietary information is not contained in this report.
' E Dissenting comments were.not received from the licensee.
l Two : NCVs were identified.
One concerned the minimum dilution flow .' alarm / trip setpoint for Units 1 and 2 flow monitor during liquid effluent
releases and had been identified by audit personnel (Paragraph 2).
A s second NCV dealt with the incorrect liquid radwaste discharge monitor setpoint and the incident was reported to the NRC in LER 50-321/1989-017 (Paragraph 8).
The continued-environmental monitoring program for the contaminated swamp area and the onsite tritium in groundwater were reviewed (Paragraphs 7.a and 7.b)
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- leakagei (Paragraph (4)'. ;Inleakage rates during 1988 typically ranged from q
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?The licenseeLhad _ adopted.a goal of 30,000- gpd-per. unit: ands 1989; data j" > - .?i 'x-showed that3thel goal was'usually met forlnon-outage conditionsL
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