IR 05000400/1986079
| ML18004B623 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/25/1986 |
| From: | Kahle J, Stoddard P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18004B622 | List: |
| References | |
| TASK-2.B.3, TASK-2.F.1, TASK-3.D.3.4, TASK-TM 50-400-86-79, NUDOCS 8612030665 | |
| Download: ML18004B623 (19) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
, ATLANTA,GEORGIA 30323 Report Nor I 50-400/86-79'V Licensee:
Carolina Power and Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Harris
Inspection Conducted:
September 29 - October October 27-28, 1986 Inspector.
License No.:
CPPR-158 3, 1986, October 15-17, 1986, and
<</~P'0 art Approved by:J..
ahle, Section Chief Di i ion of Radiation Safety and Safeguards Date Signed A ~.
at Signed SUMMARY Scope:
This routine, announced inspection was in the areas of preoperational inspection of radioactive liquid and gaseous effluent treatment systems, radiological effluent monitoring and post-accident sampling systems.
Results:
No violations or deviations were identified.
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REPORT DETAILS Persons Contacted Applicant Employees AD AJ
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- 5'A AG
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- V L. Tibbetts, Director, Regulatory Compliance I. Loflin, Manager, Harris Plant Engineering Support R. Sipp, Manager, Environmental and Radiation Control G. Wallace, Specialist, Regulatory Compliance N. Hudson, Senior Engineer, Regulatory Compliance Aspray, Startup Engineer, Multi-Anp Corporation Poland, Project Specialist Nathan, E5RC Chemist L. Dority, Startup Supervisor Hinnant, Manager, Startup J.
Woods, Startup Supervisor S.
Bohannon, Director of Special Programs Fregonese, I&C Engineer Woenker, Senior Specialist, Regulatory Compliance NRC Resident Inspector
"*S. P. Burris, Resident Inspector, RII
"Attended exit interview October 3, 1986
~~Attended exit interview October 17, 1986 2.
Exit Interview 3.
The inspection scope and findings were summarized on October 3, 1986 and October 17, 1986, with those persons indicated in paragraph 1 above.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
Applicant Action on Previous Enforcement Matters (92701B)
(92702B)
(Closed) Violation 50-400/86-41-02 ( IV) "Failure To Procure Materials That Conform To Purchase Specification Requirements."
The inspector reviewed changes made in the applicant's guality Assurance program, as applicable to safety-related items received by the applicant from vendors or received by vendors acting under contract to CPRL during the construction phase.
In a letter to RII dated August 6, 1986, referenced as NRC-468, the applicant described details of corrective actions which had been taken to assure that necessary gA controls would be applied to future equipment, procurement, which would include receipt inspection and the identification of documents and test reports.
Purchasing of equipment and
parts was transferred from Ebasco to CP&L and future purchase requisitions were to be generated at Shearon Harris in accordance with AP-XII-Ol.
With respect to the material specifically identified in the citation and to other material which may have been improperly received, inspected, and documented, the Harris Plant Engineering Section (HPES)
performed an extensive investigation and determined that of some fifteen safety-related shipments, five had not been receipt inspected and missing documentation was identified.
Each of these shipments was subsequently receipt inspected and missing documentation was obtained, with the exception of minor documentation problems which were resolved by waiver and by revision to specifications.
The applicant stated that full compliance was achieved on July 18,
. 1986.
Based on the corrective actions taken and on the information described above and with the consent of the inspector who identified the violation, this violation is considered closed.
Containment Hydrogen Post Accident Sampling System (NUREG-0737, Item II.F. 1, Subpart 6)
The inspector, accompanied by an applicant representative, examined the containment hydrogen monitoring system installation and reviewed preoperational inspection and calibration records and procedures.
The sensing element of the system was an Exo Sensor (TM) pressure compensated electrochemical transducer for the detection and measurement of the partial pressure of hydrogen.
The system sampled from multiple points in containment through a
system of valves and manifolds.
The preoperational test procedure demonstrated that a sample could be obtained in approximately three minutes from the most remote sampling point, the reactor dome area.
The readout had a range of 0 to 10% hydrogen in air and was calibrated with standard gas mixtures at 2% and 6%.
As of September 30, 1986, there remained 13 exceptions to completion of the preoperational tests.
These included'he replacement or repair of a flow sensor and procurement of a modified circuit board to provide twelve (12)
computer points for system valves to permit control room readout of valve positions.
None of the 13 items impacted the operability of the hydrogen monitoring system from the local control panel in the auxiliary building.
For purposes of fuel loading and reactor operation to 5% power, the hydrogen monitoring system was considered operable; however, all thirteen exceptions should be cleared prior to exceeding 5% of full power.
(Opened)
Inspector Followup Item 50-400/86-79-01.
Verify that thirteen (13)
exceptions to
. the preoperational test of the containment hydrogen monitor system, including replacement or repair of a
flow sensor and circuit board provision for twelve (12) computer points have been cleared and that the system is fully operational prior to exceeding 5%
of full powe (Closed)
NUREG-0737 Item II.F. 1 Subpart 6,
Containment Hydrogen Monitor (II.F.1 (85-16-18)).
This item is considered closed on the basis of the findings detailed above.
Containment Particulate Air Monitor for Detection of Primary Coolant Leakage in Containment (84524)
The inspector reviewed the actions taken by the applicant in response to Unresolved Item (URI) 50-400/86-54-01, which described inspector concerns relative to the combined sample line for the containment hydrogen monito~
and the containment atmosphere particulate monitor utilized for detection of primary coolant leakage in containment, In a
telephone conference on August 13, 1968, the applicant notified NRC that the sample line would no longer be used for the containment atmosphere particulate sample and that a
new sample line was being installed which would be of minimum length, of adequate diameter for optimum flow conditions, and which would utilize only two isolation valves with a lesser degree of disturbance of flow patterns.
During the current inspection, the inspector examined the new sampling line and found the installation to be essentially as stated in the discussion of August 13, 1986.
The line was approximately 35 feet long from sample intake to the sample collection point, heat tracing was being installed, and the design and installation guidance of ANSI N13. 1-1969 had generally been followed, with the exception that one right angle bend had been incorporated at the sample inlet end.
Applicant representatives stated that a test of particulate transmission efficiency would be performed to verify that representative sampling could be achieved.
(Opened)
Inspector Followup Item 50-400/86-79-02 Review results of flow rate and particulate sampling efficiency tests to be conducted on the containment atmosphere sampling system used for detecting primary coolant leakage in containment.
This test should be conducted prior to exceeding 5% power.
Radioactive Liquid Gaseous Process and Effluent Monitoring and Sampling (84524)
The inspector, accompanied by applicant representatives, reviewed the installation of liquid and gaseous process and effluent monitors and samplers'he inspector observed and noted some problem areas during the course of the inspection.
The high range iodine and particulate sampling stations for the four principal plant effluent release points were noted to.be lined-up in such a manner that the initial sample would be collected downstream of a
sharp 90~ bend in the sample line.
The applicant initiated a work order to re-wire the sample unit solenoid (electrically-actuated)
flow control valves
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such that the initial sample would be collected via another path which would provide straight-through flow.
The affected samplers were identified as No. 3536-1 (turbine building vent),
3546-1 (stack 5),,3547-1 (stack 5A), and 3509-1 (plant vent stack).
While inspecting the various monitor installations, it was noted that the turbine building air monitoring system had experienced severe condensation problems in the sampling of high humidity ambient air.
The applicant was installing heat tracing on the affected lines at the time of the inspection.
This monitor will be inspected at a later date to determine if the combination of heat tracing and the anticipated flow of conditioned air following plant ventilation system activation wi 11 be adequate to correct the condensate problem.
Four process air particulate samplers were observed to incorporate two sharp right angle bends built into the sample delivery lines by the vendor.
Applicant representatives stated that an evaluation of the effect of the bends would be either requested from the vendor or would be otherwise provided by the applicant.
Pr'eoperational tests of the Radiation Monitoring System were incomplete as of the last date of the inspection and a formal completion date had not been established.
The applicant's Work List, as of October 9, 1986, contained
incomplete items and two lineup tests which had not been finished.
Many of the incomplete items were common to more than one monitor and resolution of the incomplete items was expected to be accomplished in two to three weeks.
None of the incomplete items were of a nature which would delay fuel load or startup.
The inspector reviewed the following radiological process and effluent monitoring instrumentation procedures:
RST-012, Primary Calibration of GA Technologies Gaseous Radiation Monitors, Rev.
1, May 23, 1986 RST-011, Primary Calibration of RD-53 Liquid Radiation Monitor, Rev.
2, June 23, 1986 (Opened)
Inspector Followup Item 50-400/86-79-04, Review modifications to four wide-range effluent monitoring particulate/iodine sample skids (II.F.1-152) to provide straight-through sample flow for normal operation.
These modifications should be completed prior to exceeding 5% power.
(Opened)
Inspector Followup Item 50-400/86-79-06, Review Turbine Building effluent air monitoring system after plant startup to determine if moisture condensation problem corrective measures prove adequate.
Post Accident Sampling System (PASS)
(0737 II.B.3)
The inspector, accompanied by applicant representatives, reviewed the installation of the Post Accident Sampling System (PASS).
The PASS was
originally contracted through the Milton Roy Company.
In the period between signing of the contract and delivery of the system, the Milton Roy Company was taken over by the Bull and Roberts Company, under whose name most of the custom-built components were fabricated.
Before system completion and delivery, the part of Bull and Roberts Company responsible for the PASS became part of the Waltron Company.
The inspector walked-down the system with applicant representatives and reviewed the acceptance tests.
It was noted that tests involving highly diluted samples did not fully meet the design criteria and that the applicant had identified an under-size bore of the liquid system dilution metering valve as the probable cause.
The applicant had ordered a replace-ment valve component with a properly-sized bore; the replacement had not been received as the date of the inspection.
An inspector followup item was opened to track the installation of the new valve component and to review re-calibration of the PASS diluted sample subsystem.
The inspector reviewed training material, procedures, and training records and determined that
chemistry technicians were currently qualified in operation of the PASS.
The inspector reviewed the system for obtaining post-accident samples of the containment atmosphere.
The system used the same sampling line as the containment hydrogen monitor and provided for grab samples of containment air for analysis of noble gases, for collection of iodine on charcoal or silver zeolite cartridges, and for collection of particulates on paper filters.
An applicant representative stated that the Westinghouse Owners Group procedure for assessment of 'core damage, which was adopted for use by the applicant and which had been approved by NRR, did not utilize either iodine or particulate sample analyses and that, for that reason, applicant post accident procedures did not require the use of the containment atmosphere post accident iodine or particulate sample sections of the sampling systems.
The applicant representatives stated, however, that an iodine sample analysis would be utilized in calculations of off-site dose consequences in the event of an accident involving loss or rupture of containment.
In the exit interview, the inspector noted that the sampling system, as it currently existed, was subject to substantial and unquantified lines losses of iodine aerosols resulting from the design and installation of the sample line.
An applicant representative stated that an evaluation of iodine line losses would be performed for the sample system.
The following post accident sampling system (PASS) preoperational tests were reviewed:
l.
2115-P-01, Rev.
0, Primary Sampling System Preoperational Test (accepted by Joint Test Group, August 15, 1986)
2.
2115-P-03, Post Accident Sampling System High Pressure Operational Test (Inspector note includes calibrations of system)
(Accepted by Joint Test Group, September 4, 1986).
3.
2115-7-01, Post Accident Sampling System Chiller Functional Test (Accepted by Joint Test Group, February 17, 1986)
4.
2115-T-02, Post Accident Sampling System Functional Test (Accepted by Joint Test Group, August 28, 1986).
All of these tests had been completed, reviewed and accepted in accordance with applicant review procedures and appeared to be satisfactory.
The following post-accident related radiochemistry procedures were reviewed.
1.
CRC-821, Rev. 4, October 7, 1986:
Post-Accident RCS/RHR Sampling 2.
CRC-823, Rev.. 1, June 6,
1986:
Post-Accident Containment Air Sampling 3.
CRC-826, Rev.
0, July 9, 1985:
Post-Accident Sample Chloride Analysis 4.
CRC-827, Rev.
2, September 9,
1986:
Post-Accident Sample Boron Analysis by Fluroborate Specific Ion Electrode 5.
CRC-829, Rev.
1, September 29, 1986:
PASS Sample Storage and Disposal 6.
CRC-830, Rev.
1, June 16, 1986:
Periodic Maintenance and Operability Verification of the PASS 7.
CRC-832 (Revision number and date not recorded)
Calibration of Dissolved Hydrogen Ana')yzer.
All of the above procedures had been reviewed and approved in accordance with applicant's established review process.
The applicant was informed that on the basis of the preoperational tests, operating procedures, and the qualification of an adequate number of trained operators, the PASS was considered operational for startup and power ascension.
The applicant was also informed that NRC would further evaluate the operability of the PASS at such time as the reactor had been operated for at least continuous thirty (30)
days at full power in the period immediately preceding the evaluation.
(Closed)
NUREG-0737, II.B.3, Post-Accident Sampling System (PASS).
Based on the inspection detailed above, the preoperational requirement for inspection of the PASS prior to exceeding 5% full power is considered closed.
(Opened)
Inspector Followup Item 50-400/86-79-03.
Review installation of modified metering valve with larger bore in liquid PASS (II.B.3).
Installation to be completed prior to exceeding 5% power.
(Opened)
Inspector Followup Item 50-400/86-79-05.
Evaluate PASS operation and performance after reactor has operated at least 30 consecutive days at full power.
(Opened)
Inspector Followup Item 50-400/86-79-07.
Review results of iodine aerosol sample loss test/evaluation through post-accident containment
atmosphere sampling system line shared with containment hydrogen sampling system.
Engineered Safety Feature (ESF)
and Non-ESF Filtration and Adsorption Subsystems of Plant Process and Effluent Gaseous Treatment Systems (84524)
As of the starting date of the inspection, none of the high efficiency particulate air (HEPA) filters had been installed in plant gaseous treatment systems and the loading of charcoal had been initiated in only two subsystems.
None of the in-place tests for loaded HEPA and charcoal subsystems had been accomplished.
The inspector examined the HEPA filter frames and charcoal adsorber retention screens in seventeen (17)
ESF and non-ESF systems.
In the ESF system (R2/2A-SA)
serving the control room habitability system, the inspector found a defectively welded charcoal retention screen on the downstream side of the adsorber bed, with three zones each about 4 inches long where the retention screen was not attached to the supporting frame.
The applicant promptly initiated a repair order for the re-welding of the affected retention screen.
The welded areas were subsequently inspected and found satisfactory.
Charcoal retention screens on
other systems inspected appeared to be in satisfactory condition.
In Inspector Followup Item 50-400/85-27-01, the resident inspector noted concern over bulges in the charcoal retention screens.
During the current inspection of the
systems described above, the inspector examined the bulges referred to in IFI 85-27-01 and found these to be typical of similar installations at other facilities.
It was noted in the exit that the occurrence of such bulges was generic to bulk-loaded systems and had not previously resulted in problems, provided that the screen edges were properly welded to the support structure.
(Closed)
Inspector Followup Item 50-400/85-27-01, this item is considered closed on the basis of the inspection and discussion detailed above.
Radioactive Liquid and Gaseous Process and Effluent Sample Preparation and Analysis (84523, 84524, 84525)
The inspector reviewed the following Chemistry and Radiochemistry procedures:
CRC-250, Rev.
2, July 24, 1986 - Plant Vent Sampling; CRC-255, Rev. 2, July 24, 1986 - Waste Gas Decay Tank Sampling; RCP-660, Rev.
1, July 21, 1986 Sample Preparation for Determination of Radioactivity.
Inspector Followup Item 50-400/86-37-01 had identified discrepancies in previous versions of procedures listed above.
The inspector determined that the discrepancies had been corrected and that the concerns of 50-400/86-37-01 had been resolved.
(Closed)
Inspector Followup Item 50-400/86-37-01, Revise procedures numbered CRC-250, CRC-255 and RCP-660 as described in RII Report 86-37.
The inspector reviewed this item, as detailed above, and determined that the procedures had been satisfactorily revised.
This item is considered close Test Criteria for HEPA/Charcoal Gas Waste Treatment Systems (84524)
The inspector reviewed September 30, 1986, revisions to Technical Specifications 4.7.6, 4.7.7, and 4.9. 12, which were changed to reference ANSI standard ANSI N510-1980 instead of ANSI N510-1975.
The inspector also reviewed draft routine surveillance procedure RST-004, covering in-place leak testing of HEPA filter and charcoal adsorber installations, which had been revised to reference ANSI N510-1980.
The applicant's preoperational test procedure had previously referenced ANSI N510-1980 and no revision was required.
(Closed)
Inspector Followup Item 50-400/86-54-02,
"Review of Procedural Discrepancies Referencing Both 1975 and 1980 Versions of ANSI NS10."
Based on the. inspection described above, this item was considered closed.
Radioactive Effluent Release Stacks (84524)
The inspector examined the multi-point gas sampling assemblies and flow velocity measurement assemblies installed in the three principal radioactive gaseous effluent discharge stacks.
In the 'FSAR, the applicant had committed to locate the gaseous effluent sampling nozzles in accordance with the recommendations of ANSI N13. 1-1969,
"Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities".
In discussions with applicant representatives and in a review of stack airflow measurements, the inspector was informed that the applicant had identified significant flow anomalies which, if uncorrected, would adversely impact the efficiency of sample collection for particulates and iodines in the effluent stream and would prevent the applicant from meeting the FSAR commitment to sample the gaseous effluent streams in accordance with the recommendations of ANSI N13. 1-1969.
Initial applicant measurements of the flow velocity profiles across the diameters of the stacks showed irregular flow patterns, with observed velocities varying by more than a factor of ten, as well as isolated observations of reverse flow.
Applicant representatives indicated that the'rregularities could be largely attributed to asymmetric flow inputs resulting from cancellation of the "twin" of Harris, Unit 1, in that the exhaust stacks were originally designed to be shared by two units.
Corrective measures undertaken by the applicant included the addition of a four-inch deep
"honeycomb" profiling grid inside each stack, the addition of a
second four-inch deep
"honeycomb" profiling grid in the plant vent stack about four feet downstream of the first profiling grid, and the installation of baffle strips in stack 5 (Waste Process Building, including Waste Gas Decay Tank discharge)
consisting of a grid of flat stainless steel bars welded across the two principal input plenums to diffuse and break-up the input gas stream.
As of the end-date of this inspection, the applicant had completed and submitted results of a
new stack profile measurement test of Stack 5.
The inspector reviewed the results of thi s test and evaluated the results against ANSI N13. 1-1969 criteria for representative sampling of particulate
aerosols.
Based on the applicant's data on the stack profile measurements in Stack 5, the maximum sampling error for very large (>50 microns)
particles would be approximately
+30% at the worst locations; however, the overall composite error would be somewhat smaller since positive and negative errors at the multiple sampling points would tend to cancel each other.
Since all probable sources of radioactive airborne aerosols at Harris are filtered through at least one prefi lter, one high efficiency particulate air (HEPA) filter, and four inches of charcoal, it is likely that any particulate aerosols penetrating the filter system would be less than five microns in size and that the maximum sampling error due to anisokinetic conditions in the stack would be
<3%.
The number and distribution of sampling points in the stack was found to meet ANSI N13.1-1969 criteria.
While the location of the sampling assembly did not conform to the N13.1 criterion that it should be at least five duct diameters distant downstream from the last input point or transition, we consider that the applicant'
corrective actions in diffusing and profiling stack flow provided adequate compensation.
Based in the above discussion, the sampling system installed in Stack 5 is considered to meet the criteria and intent of ANSI N13. 1-1969 and is acceptable.
Applicant tests on Stack 5A and the Plant Vent Stack will be reviewed at a
later date.
(Opened)
Inspector Followup Item 50-400/86-79-08, Review Applicant Data on Flow Tests of Stack 5A and Plant Vent Stack.
Control Room Habitability Systems (84524 and NUREG-0737, Item III.D.3.4)
The Control Room habitability systems were not ready for inspection as of the end of the inspection.
Applicant personnel were in the final stages of balancing air flows and plugging leaks.
The HEPA filters and charcoal adsorbers in the Control Room emergency filtration system were scheduled to be loaded by November 17, 1986.
Final in-place leak tests of the HEPA filters and charcoal adsorbers had not been scheduled as of the end of the inspection.
Liquid Radioactive Waste Processing Systems (83523)
The inspector reviewed the liquid radwaste processing system during discussions with applicant personnel, reviewed completed preoperational and functional test procedures and results, reviewed system operating procedures, and accompanied by applicant personnel, performed a walkdown inspection of the process systems.
System layout and equipment were in conformance with the FSAR with respect to principal process components and storage tanks.
The inspector observed that the liquid radwaste system had incorporated dikes, raised si lls, and berms to collect leakage, overflow, and spillage.
The inspector reviewed the following Preoperational/Functional Test Procedures:
1-7060-P-01, Waste Holdup and Evaporator System Preoperational Test, September 19, 1986 1-7070-P-01, Gaseous Waste Processing System, September 4,
1986 1-7070-FSI, Gaseous Waste Process System Preoperational Test, July 15, 1986 I
1-8220-P-03, Rev.
1, Control Room Area Emergency HVAC System Test Report (Completed August 28, 1986; Accepted September 11, 1986).
The 'applicant reported that the waste holdup system. evaporator was not able to achieve design flow of 15 gallons per minute without an increase in the condensate trap capacity.
Applicant representatives stated that a
work order had been placed to modify the condensate trap capacity.
The inspector reviewed the following liquid radwaste process system operating procedures:
OP-120-01.02, Secondary Waste Sample Tank, Rev.
1, September 21, 1986 OP-120.09.03, Radioactive Floor Drain Waste Monitor Tank, Rev.
1, September 21, 1986 OP-120. 10.04, Treated Laundry and Hot Shower Tanks, Rev.
1, September 21, 1986 OP-120.06.02, Waste Evaporator Condensate Tanks, Rev.
1, September 21, 1986 CRC-851, Offsite Dose Calculation Manual Software Instructions and Documentation, Rev.
0, May 29, 1986 CRC-854, Reporting Radioactive Liquid Release, Rev.
1, February 6,
1986.
Provisions for sampling of process and effluent systems appeared to be adequate and provisions had been made for sampling under post-accident conditions.
The inspector's review of the acceptance test program for the liquid radwaste system concluded that the program was adequate.
The inspector was unable to schedule an inspection during the periods in which the preoperational tests were being performed; however, test
.results were reviewed and appeared adequate.
The installation, calibration, and testing of liquid radwaste system process and effluent monitor is discussed in another section of the report.
The applicant's documented programs, including the FSAR, preoperational and function test procedures, and system operating procedures were reviewed and were found to be adequat.
Gaseous Waste System (84524)
The Gaseous Waste System was reviewed by the inspector in discussions with applicant personnel, comparison of the as-built system with the FSAR description, review of preoperational/functional test procedures and review of operating procedures.
The inspector also did a walkdown inspection of the system accompanied by a applicant representative.
The gaseous waste system is a
closed-loop system consisting of two compressors, two catalytic recombiners and ten decay tanks (eight normal operation, two for shutdown and startup).
The applicant's FSAR projected that no releases would occur over the anticipated plant life; however, provisions were incorporated in the design for periodic discharge of excess gases through a
HEPA filtered charcoal adsorber for discharge from Stack 5.
The NRR review of plant operation conservatively predicted periodic gas releases from the plant after 90-day holdup for decay of short-lived radioactive gases.
The inspector reviewed the following completed preoperational test procedures:
1-7070-P-01, Gaseous Waste Processing System Preoperational Test, dated September 4,
1986 1-7070-PSI, Gaseous Waste Processing System Preoperational Test Instruction Procedure, dated July 15, 1985.
It was noted that the waste gas compressor did not meet the specifications for flow and pressure when tested at 85 to 90 psig.
The compressor was unable to provide the specified 40 scfm at that pressure but was capable of achieving 45 scfm at a lower pressure.
The applicant decided to accept the processor
"as is" since the maximum pressure was not anticipated to be reached until approximately ten years of full power operation.
The inspector's review of process and effluent sampling and monitoring and of'entilation and gas purge treatment systems is detailed under separate topic headings in this inspection repor P