IR 05000346/1987021
| ML20237J870 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/31/1987 |
| From: | Greger L, Michael Kunowski, Miller D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20237J836 | List: |
| References | |
| 50-346-87-21, IEC-80-18, IEIN-84-03, IEIN-84-3, IEIN-84-93, IEIN-86-017, IEIN-86-046, IEIN-86-103, IEIN-86-17, IEIN-86-46, IEIN-87-003, IEIN-87-007, IEIN-87-013, IEIN-87-13, IEIN-87-3, IEIN-87-7, NUDOCS 8709040104 | |
| Download: ML20237J870 (13) | |
Text
____.
...
_
.
.
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-346/87021(DRSS)
Docket No. 50-346 License No. NPF-3 Licensee:
Toledo Edison Company Edison Plaza 300 Madison Avenue Toledo, OH 43652 Facility Name:
Davis-Besse Nuclear Power Station Inspection At:
Davis-Besse Nuclear Power Station, Oak Harbor, Ohio Inspection Conducted:
August 3-7, 1987 h& V. 22iffsv Inspector:
Donald E. Miller F-A ' # 7 Date Accompanying Inspector:
ichae A. Kunowski 6-5/-87 Date Approved By:
L.
8-5/-87 Facilities Radiation Date Protection Branch Inspection Summary Inspection on August 3-7, 1987 (Report No. 50-346/87021(DRSS))
Areas Inspected:
Routine, unannounced inspection of the radwaste, transportation, and operational radiation protection programs.
Also reviewed were past inspection findings, Open Items, Licensee Event Reports, selected IE Information Notices, audits, and the recent reorganization of the Chemistry and Health Physics Departments.
Results:
No violations or deviations were identified.
e709040104 870831 PDR ADOCK 05000346 G
p
-
.
.
DETAILS 1.
Persons Contacted L. Bonker, Radiological Health Supervisor
'
- D. Briden, Former Director, Chemistry and Health Physics
.
- R. Coad, Radiological Protection Supervisor D. Erickson, Radiological Control Superintendent
- R. Floed, Assistant Plant Manager, Operations R. Geddes, Lead QA Auditor L. Harder, Health Physics Specialist
- G. Honma, Licensing, Compliance Supervisor
- M. Horne, Radiological Control Program Advisor i
- T. Myers, Nuclear Licensing Director l
T. O'Dou, Associate Technologist
- R. Otto, System Engineer, Rad Monitoring I
- L. Ramsett, QA Director L. Storz, Plant Manager
- P. Strahm, Radwaste/Decon Supervisor
!
- J. Sturdavant, Licensing Principal l
- P. Bryon, Senior Resident Inspector
- W. Shafer, Chief, Emergency Preparedness and Radiological Protection Branch The inspectors contacted other licensee and contractor personnel.
- Denotes those present at the exit meeting.
2.
General
!
l l
This inspection, which began at 8:00 a.m. on August 3, 1987, was
'
i conducted to review the licensee's operational radiation protection, radwaste management, and transportation programs.
Also reviewed were past inspection findings, Open Items, selected Licensee Event Reports, selected IE Circulars and Informt. tion Notices, and recent organization changes.
Several tours of licersee facilities were made to review posting, labeling, and access and contamination controls; no problems were noted.
3.
Licensee Action on Previous Inspection Findings and Open Items (Closed) Open Item (346/83-22-01):
Dosimetry Quality Assurance.
Since previously discussed in Inspection Report No. 50-346/86021, the licensee has replaced 0-500 mR self-reading dosimeters (SRDs) with 0-200 mR SRDs; this change helped reduce reading errors.-
Errors were further reduced by having dosimetry clerks read SRDs worn by temporary workers during autages.
Acceptable deviation limits for comparing SRD/TLD readings have been established; comparison results have greatly improved; non-agreements outside acceptable deviation criteria are investigated.
Longer term planned improvements include development and use of an automated dose tracking system.
I
.
.
(0 pen) Open Item (346/84-08-02):
Energy response of PASS noble gas high range detector.
The licensee initiated a Facility Change Request (FCR)
.
in October 1986 to implement a vendor detector enhancement modification
!
and onsite isotopic calibration.
The FCR includes several additional l
modifications to the monitoring equioment including rerouting sampling
'
lines.
The licensee has contracted Bechtel to perform necessary engineering reviews.
However, according to licensee representatives, lECo and Bechtel have not agreed on contract terms.
The inspector j
discussed with the licensee at the exit meeting the apparent slow
!
progress made in making needed modifications.
j i
(0 pen) Open Item (346/84-30-02):
Stack sample return line.
Rerouting of I
I return line included in the FCR discussed above (0 pen Item 346/84-08-02).
'
(Closed) IE Circular (346/80018-CC):
10 CFR 50.59 Reviews for Radwaste System Changes.
Implementation of 10 CFR 50.59 reviews for radwaste j
system changes is addressed in licensee Nuclear Group Procedure NG-NE-0340, i
Revision ~0, Safety Review and Evaluation.
The procedure includes the j
review requirements specified in IE Circular 80-18.
4.
Organization and Management Controls The inspectors reviewed the licensee's organization and management controls for the radiation protection and radwaste programs including changes in j
the organizational structure and staffing, effectiveness of procedures and i
other management techniques used to implement these programs, experience l
concerning self-identification and correction of program implementation
{
weaknesses, and effectiveness of audits of these programs.
Audits are i
discussed in Section 12.
l During August 1986, the licensee began a phased organizational change l
whereby rad / chem foreman and testers (rad / chem technicians) were assigned to either radiation protection or chemistry duties exclusively.
In order I
to accomplish this split in duties, several testers were promoted to foreman positions in the radiation protection and chemistry sections thereby reducing the number of experienced testers; these foreman positions were in addition to the previously established foreman positions.
Additional job changes further diminished the experienced tester ranks.
As a result, only two experienced testers remained in the Radiation Protection Section.
Three testers were hired into the RP Section in late 1985 and early 1986; two have associate degrees and one has a bachelors degree in radiological health; two have previous experience.
Since August 1986, 12 testers have been hired into the RP Section; all are ex-Navy ELTs or mms.
Tester staffing in the Chemistry Section was not reviewed.
A further organization change was implemented on August 3, 1987.
The Chemistry and Health Physics (C&HP) Department was split ir,to a Chemistry Department and a Radiological Control (RC) Department; the department superintendents report directly to the Plant Manager.
The former Director, C&HP, was reassigned to a corporate position.
The former Radiological Assessment Superintendent was promoted to the RP Department Superintendent position.
The former Radiological Superintendent was reassigned to a Radiological Control Advisor position reporting to the RC Department Superintendent.
-
-
. _.
.
l
.
Total staffing of the RC Department, which includes a Radwaste/Decon Section, is currently 45 persons; the planned staffing level is 60.
Positions planned to be filled include Health Physics Specialists /
i Technologists, Training Coordinator, Administrative Assistant, Clerk, l
Radiological Operations Supervisor, and several testers.
i l
The licensee implemented a new Radiological Awareness Reporting (RAR)
I system effective July 13, 1987.
The RAR system replaces a radiological occurrence report system.
The RAR system, described in Nuclear Group Procedure NG-DS-0221, Radiological Awareness Reporting, provides a formal method of documenting radiological deficiencies, concerns, and suggestions.
Initiating forms are posted at various locations.
Anyone can initiate an RAR.
The procedure delineates management responsibilities, formal followup
procedures and forms, and a method of backfeeding information concerning i
the RAR to the initiator.
The followup and recording systems are highly l
structured.
l l
The inspectors informed the licensee during the exit meeting that the
effect of the organization changes will be the subject of reviews during i
future routine inspections.
l No violations or deviations were identified.
5.
Training The inspectors reviewed the training aspects of the licensee's radiation protection, radwaste, and transportation programs, including:
changes in responsibilities, policies, goals, programs, and methods and provisions j
of appropriate radiation protection, radwaste, and transportation training for station personnel.
Also reviewed was experience concerning self-identification and correction of program implementation weaknesses.
Audits and radwaste training are discussed in Section 12.
The radi aion protection tester training program has been reviewed by INP0 representatives.
Program accreditation is expected soon.
In response to audits performed by or for the licensee, alteration of the GOT/RCT training is in progress; the recommended changes were minor.
No violations or deviations were identified.
'
External Exposure Control and Personal Dosimetry 6.
The inspectors reviewed the licensee's external exposure control and personal dosimetry programs, including:
changes in facilities, equipment, personnel, and procedures; required records, reports and notifications; effectiveness of management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesses.
Audits are discussed
in Section 12.
TLD/SRD quality assurance is discussed in Section 3.
I
_ __-___ -___ _ -
--
-
.
,..
ly
.
.
-
{
The licensee has continued ;o maintained personal doses extremely _
l J
low with a 1986 total of 124 person-rem and a 1987 goal well under 100 person-rem.
1 The inspectors reviewed records and procedures concerned with control, i
maintenance, calibration, and periodic checks _ of self-reading ' pocket
'l j
dosimeters, portable survey instruments, and air samplers.
This
'
equipment is calibrated semiannually, in the licensee's Radiation l
Measuring and Test Equipment. Calibration Laboratory, usually by the Master or the Senior RC Tester.
New equipment and equipment returned -
i after repair by the vendor or a contractor is recalibrates by the-
.
licensee before use.
[
.
_
'
The licensee uses computer generated lists to track calibration due dates.
Equipment-past the due date is tagged out-of-service and returned i
to the calibration laboratory.
Several hand generated lists are used to track the location of meters and samplers.
One high-volume air sampler
]
that'was listed as due for calibration on May 11, 1987,' was not listed i
on the equipment location lists.
Licensee representatives were unable
'to locate the sampler during the inspection.
Two RM-14 " friskers" were j
listed as due for calibration, but had not been returned to the laboratory;
-
because of an ambiguous entry on the equipment location lists, several j
'
telephone calls were needed before licensee representatives were able j
l to locate, retrieve and tag the instruments.
The inspectors reviewed-
,
l calibration, maintenance, periodic source check, and location records
)
for several meters, air samplers, and self-reading dosimeters.
Nomajor
)
problems were identified.
)
The licensee is currently re-cataloging equipment that will-be used by the newly-separated chemistry and health physics departments.
The licensee will soon be tracking equipment locations on a computer.
No violations or deviations were identified.
7.
Internal Exposure Control and Assessment The inspectors reviewed the licensee's internal exposure control and assessment programs, including:
changes in facilities, equipment,.
personnel, respiratory protection training, and procedures.affecting
'
. internal exposure control and personal assessment; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements; required records, reports, and notifications, and effectiveness of management techniques used to.
implement these programs and experience concerning self-identification and correction of program implementation weaknesses.
Audits are
!
'
discussed in Section 12.
In response to station and contracted audits which identified desirable improvements, several programmatic changes are in progress including:
Upgrading of respiratory protective equipment cleaning methods.
!
5-
_-__-_ - __ -
-
,
.
l
.
Testing of respirator particulate air filters before reuse.
- Additional testing of air quality in distribution systems used
as respirable air sources.
Added assurance that persons making repair to respiratory protective
equipment are trained / qualified.
Upgrading of procedures including incorporation of programmatic
changes, and Training appropriate personnel concerning new procedures,
changes and responsibilities.
The licensee plans to complete the above items by October 31, 1987.
The inspectors selectively reviewed whole body counting results for j
1986 and 1987 to date.
No uptakes in excess of the 40 MPC-hour control i
measure were noted.
Based on whole body counting results, there is no
indication that the licensee's internal exposure control and assessment program has been ineffective.
)
l No violations or deviations were identified.
j
8.
Control of Radioactive Materials and Contamination i
The inspectors reviewed the licensee's program for control of radioactive
!
materials and contamination, including:
changes in instrumentation, i
equipment and procedures; effectiveness of survey methods, practices,
,
equipment and procedures; adequacy of review and dissemination of survey I
data; and effectiveness of methods of control of radioactive and contaminated materials.
Audits performed by or for the licensee during 1987 identified weaknesses (observations) in contamination survey frequencies and extent, and supervisory review of survey results.
The licensee is performing a review / revision of appropriate procedures in response to the audit observations.
The inspectors toured the licensee's controlled areas to review access and contamination controls, control of contaminated materials and equipment, and adequacy of posting and labeling of radioactive materials.
No regulatory problems were noted.
Several zoned areas within the controlled area contained contaminated materials temporarily stored for reuse; these zoned areas, though properly posted and delineated, give a cluttered appearance.
The licensee stated that most of the temporarily stored contaminated materials will be stored in the i
new radwaste storage building being constructed.
l l
l
.
- - _ -
.
.
The licensee is constructing a new access control facility to improve efficiency of access to and egress from the controlled area.
New PCM-1B whole body friskers will be positioned in the facility in an area easily viewed by radiation protection personnel who can assure proper use of the friskers.
No violations or deviations were identified.
9.
Solid Radioactive Waste The inspectors reviewed the licensee's solid radwaste management program including adequacy of implementing procedures to properly package, classify, and characterize waste; prepare manifests and survey packages; overall performance of the quality assurance / quality control program; adequacy of required records and notifications; and experience concerning identification and correction of programmatic weaknesses and deficiencies.
Audits are discussed in Section 12.
Pending completion of the interim radwaste storage facility, dry active waste (DAW) and dewatered waste is processed and packaged in the truck j
bay adjacent to the spent fuel pool.
DAW is compacted by health physics l
servicemen in metal bins (volume of 96 ft3 per bin) using a box compactor.
A compactor for compacting DAW in 17H drums (volume of 7.5 ft3) is available, but rarely used.
Spent demineralized / filter media is usually sluiced into vendor-supplied vessels (NUS or Hittman systems) by equipment operators.
Dewatering and preparation of the vessels for shipment is performed by servicemen with coverage by health physics testers.
Isotopic abundance for DAW is determined from an algorithm using generic scaling factors and the dose rate measured at one meter from the bin.
Isotopic abundance for other radwaste is based on gamma spectra performed on samples of the wastes.
Conservative generic values are used for H-3 and C-14.
,
Since January 1986, the licensee made one shipment of four vendor-supplied I
I demineralized vessels and six shipments of DAW.
Several shipments are
)
anticipated during the remainder of 1987 after development of QC radwaste
!
inspection procedures (see Section 12), revision of current radwaste processing and shipping procedures, and sorting (for reuse or disposal)
contaminated equipment stored near the cooling tower in seven semi trailers.
The inspectors observed an operator " walk through" (with a supervisor)
I the setup for transferring wastes to the NUS system.
A health physics i
serviceman explained the dewatering and packaging process to the l
inspectors.
Sorting of contaminated equipment from one of the seven i
trailers by servicemen and a tester was also observed.
No problems were noted.
l The inspectors discussed with licensee representatives, and reviewed records for a December 1986 shipment of four NUS demin vessels.
Except for an arithn,etical error on the shipping manifest, the processing, packaging, and shipment of the radwaste in the four demin vessels appears to have been made in accordance with licensee procedures and the requirements of 10 CFR 20 and 61, 49 CFR 170-178, and the burial site
!
,
..
-
)
in Barnwell, South Carolina.
The error resulted in the declaration of a value of 1181 millicuries for the shipment instead of the 665.3 millicuries shipped.
Apparently, a decimal point error for the total activity contained in one of the four vessels occurred during addition, resulting in the error. -The licensee representative agreed to inform the burial site of the error.
No violations were identified.
10.
Liquid Radioactive Wastes The inspectors reviewed the licensee's liquid radwaste management
',
programs, including:
determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; determination whether liquid radioactive waste affluents were in accordance with regulatory requirements; adequacy of required records, reports, and notifications; and experience concerning identification and correction of programmatic weaknesses.
Audits-are discussed in Section 12.
The inspectors selectively reviewed records of planned liquid releases J
made during 1987.
Procedures for release and methods of quantification appear adequate and appropriate.
However, the inspectors noted that release forms are not always complete in that not all signature or date blanks are filled in and no supervisory review is made to identify /
correct incomplete release forms.
The missing information includad steps performed by radiation protection and operations personnel.
This matter was discussed at the exit meeting (0 pen Item 346/87021-01).
Effluent monitor maintenance / calibration was not reviewed during this inspection.
No violations or deviations were identified.
.
11.
Gaseous Radioactive Waste The inspectors reviewed the licensee's gaseous radwaste management program, including:
determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; determination whether gaseous radioactive waste effluents were in accordance with regulatory requirements; adequacy of required records, reports, and notifications; and experience concerning identification and correction of programmatic weakneces.
Energy response of PASS noble gas high range detector and efflaent sample line open items are discussed in Section 3.
The inspectors cursorily reviewed radioisotopic quantifications records for containment vessel (CV) pressure relief releases.
The inspectors noted that the release procedure was difficult to follow and appeared to contain inconsistencies.
The inspectors noted that the method of quantification led to errors in calculated total activity released.
Because the flow rate during CV pressure release is small, the errors also are small when compared to total gaseous effluent releases from the station.
The inspectors discussed with a licensee representative
~
,
i the specific problems noted with the release procedure and the need I
to i:vestigate procedure chanaes necessary to make more accurate quantification of activity released during CV pressure. relief releases, This matter was also discussed at the. exit meeting (0 pen Item 346/87021-02).
'
No violations or deviations were identified.
12.
Audits i
The inspectors selectively' reviewed onsite and contract audits of
~
the radiation protection and radwaste management programs performed
,
l by or for the licensee from September 1986 to date.
Extent-of audits, l
qualifications of auditors, and adequacy of corrective actions were
!
reviewed.
Radiation Protection Audits One station Quality Assurance audit and two surveillance were conducted.
Included were selected radiation protection and radwaste topics.
One i
finding concerning poor contamination frisking practices for personnel
{
1eaving_the controlled area through the chemistry laboratory was identified.
The licensee's corrective actions for'this finding have since been
implemented and the item closed by the auditors.
An extensive audit was conducted during the period March 11-27, 1987, l
by two station auditors and four contracted technical specialists.
Six findings and 13 observations resulted from the audit.
The findings concerned:
Documentation of contract health' physics technician qualifications.
- Reuse of respiratory protective device filters.
- Documentation of breathing air quality for station service air.
- Recording of tritium bioassay results.
- i High radiation area key logs documentation.
- Incomplete or unreviewed records /results.
- The observations generally concerned extent of procedures, their periodic review and validation, their implementation, and supervisory review of programmatic records and reports.
The subjects included radiological surveys and results, ALARA reviews, G0T/RCT training, radioactive materials postings, certification of calibration standards, respirator cleaning, lost dosimetry, and radiological occurrence followup.
In. response to the audit findings and observations, and previousiy identified weaknesses, the licensee developed a radiation / chemistry improvement plan to implement /
track corrective measures.
Several corrective actions have begun, some i
have been completed, and the remainder are scheduled.
Implementation of-completed corrective actions have yet to be reviewed by Quality Assurance i
representatives.
!
l
,
,
../
,
.
'
Radwaste Audits An audit of the radwaste program performed in 1986 identified two findings.
One finding concerned failure to schedule servicemen for a portion of required health physics and radwaste training.
The other finding concerned the proper method of indicating changes made to entries on radwaste records.
These two findings have been responded to; when servicemen complete the training scheduled for the remainder of 1987, station QA auditors will review implementation.
An audit of the radwaste program performed in 1987 identified several findings.
One important finding was that the QC department has no approved procedures, instructions, and checklists for the inspection of radwaste
',
operations.
QC agreed to develop and implement the required procedures, instructions, and checklists by August 31, 1987.
Extent of audits and qualifications of auditors appears good.
- l No violations or deviations were identified.
13.
Event Report Followup The inspector reviewed the licensee's followup and corrective actions l
for several Reportable Occurrences (R0s) and Licensee Event Reports
!
(LERs).
The R0s and LERs reviewed are discussed below.
R0 No. 79-05:
Loss of Continuous Recording of Station Vent Airborne Activity and Flow.
This item was reviewed because no closecut report
.
'
could be found.
The activity and flow instrumentation has since been replaced to comp?y with NUREG-0737 required post-TMI instrumentation.
This item is considered closed.
R0 No. 79-06:
Station Vent Recorder UJR5023 Inoperable.
This item was reviewed because no closecut report could be found.
This recorder has since been replaced to compl) with NUP.EG-0737 required post-TMI instrumentation.
This item is considered closed.
LER No. 86020:
Post Accident Sampling System (PASS) Operator Access.
As part of the TED Design Review Program committed to the NRC in the licensee's Course of Action Report, a review of a previously performed time-motion study indicated an error had been made and that certain post-accident reactor coolant samples could not be collected within GDC-19 guidelines.
Since then, two design changes involving installation of additional shielding and relocation of certain sample flow monitoring gauges were initiated and completed; appropriate procedure changes were made to reflect the physical changes.
The inspector verified that the changes were completed.
This item is considered closed.
LER No. 86036:
Inadequate Surveillance on Radiation Monitors, On August 12, 1986, the licensee performed an engineering review of Surveillance Test Procedure ST 5031.01, Monthly Functional Test of the Radiation Monitoring System.
The review identified that required monthly
_ --__ - _ _ _ -
.
_.
..
...
.
.
..
.
,
.
.
source checks of two normal range noble gas stack effluent monitors and the containment purge noble gas effluent monitor were being done quarterly instead of monthly as required by the technical specifications.
The licensee determined that a personal error was made during a January 1986 revisic,n of the procedure.
On the day of discovery, the licensee source checked the noble gas monitcrs to verify function and initiated a revision to the test procedure to correct the error.
This item is considered closed.
14.
IE Information Notices The inspectors reviewed the licensee's internal responses to selected IE Information Notices.
The licensee's evaluations, conclusions, and actions appear appropriate and adequate.
The following notices were reviewed.
No. 86-46:
Improper Cleaning and Decontamination of Respiratory Protection Equipment.
The licensee reviewed the respiratory program procedures to ensure that the manufacturers' recommendations for proper cleaning are included.
Licensee staff responsible for cleaning and decontamination were reminded to follow the appropriate procedures.
No. 86-103:
Respirator Coupling Nut Assembly Failures.
The licensee does not use the Ultra-Vue face piece on which the subject coupling nut assemblies are used.
No. 86-017:
Entry into PWR Cavity with Retractable Incore Detector Thimbles Withdrawn.
During movement of any incore detectors, access to the licensee's incore tunnel and incore tank areas is controlled as locked high radiation areas.
These areas are periodically checked to verify the locked barriers.
For non-emergency access, health physics management must accompany persons entering the areas.
For emergencies, the shift supervisor can enter without health physics management:
normal l
high radiaticn access p ocedures must be followed.
Access procedures and the notice have been reviewed with health physics and operations staff.
No. 87-03:
Segregation of Hazardous and Low-Level Radioactive Wastes.
In response to the Notice, the licensee has incorporated into radwaste shipping Procedure DB-HP-01500 a statement emphasizing the need to keep hazardous chemical waste separate from radioactive waste.
Health physics serviceman, responsible for radwaste collection have been reminded of the need to segregate waste.
No. 87-07:
Quality Control of Onsite Dewatering / Solidification Operations by Outside Contractors.
As stated by licensee representatives during this and a previous inspection (Inspection Report No. 50-346/84030),the licensee has not solidified waste since 1981.
Dewatering is performed by licensee personnel using vendor equipment.
Verification of dewatering is performed in accordance with Procedure DB-CH-3007.
_
o Q
No. 87-13:
Potential for High Radiation Fields Following loss of Water from Fuel Pool.
The licensee previously reviewed such potential in
response to IEN 84-93, IEB 84-03, and INP0 Significant Operating j
Experience Report 85-01.
As a result of previous reviews, no irradiated
!
,
components are stored in the spent fuel pool near the water surface as
!
,
i discussed in IEN 87-13.
No previously unidentified concerns were j
l identified during the licensee's review of IEN 87-13.
'
!
15.
Exit Meeting
i
l The inspectors met with Messrs. Storz and Erickson on August 6, 1987, and j
l with licensee representatives (denoted in Section 1) at the conclusion of
'
!
the inspection on August 7, 1987.
The inspectors also discussed the
likely informational content of the inspection report with regard to i
documents and processes reviewed by the licensee during the inspection.
The licensee identified no such documents / processes as proprietary.
l In response to certain items discussed by the inspectors, the licensee:
~
a.
Acknowledged the inspectors' comments about missing information l
on liquid release forms and stated that corrective measures would i
be implemented (Section 10).
b.
Stated that containment vessel pressure relief procedures and i
j quantification calculational methods would be revised to make d
i them more accurate (Section 11).
t l
c.
Acknowledged the inspectors comments that progress in making needed l
i alteration to PASS effluent monitoring / sampling system appears slow l
'
(Section 3).
j i
i l
{
j l
!
!
!
l l
l
.
l i
.
'
,
- *
e J N Ls.
- Y r e.s
'
f s
i
,
!
i
_ _____ - -______-____
_
. _ _
__-
._
._
.
~
.
.. _
.
I USURC-DS 1981 SEP -3 A C; 2 r
l l
0