ML18152A419
| ML18152A419 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 12/28/1989 |
| From: | Decker T, Hughey C, Seymour D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A420 | List: |
| References | |
| 50-280-89-32, 50-281-89-32, NUDOCS 9001310099 | |
| Download: ML18152A419 (13) | |
See also: IR 05000280/1989032
Text
Report Nos. :
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
. 101. MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
l,. HI t:J, J 10i.:/i
t.!l~k1 ~
v .. -tt.
50-280/89-32 and 50~281/89-32
Licensee: Virginia Electric and Power Company
Glen Allen, VA
23060 *
Docket Nos.:
50-280 and 50-281
Facility Name:
Surry 1 and 2
License Nos.: DPR-32 and DPR-37
October 16-20, 1989
October 30
D. A. Seymour
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Approved by:
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T. R. Decker, Chief
Scope:
Radiological Effluents and Chemistry Section
Emergency Preparedness and Radiological
Protection Branch
Division of Radiation Safety and Safeguards
SUMMARY
- November 3, 1989
A*i?fj!J' 'l
Date Si_ ed ;,
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Oat~ Signed
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Date -Signed
This routine; unannounced inspection was conducted in the areas of radioactive
effluents, laboratory quality control, and plant chemistry.
Results:
In the areas inspected, one violation was identified:
Modifications to ventilation systems resulting in inadequate surveys of
gaseous effluents.
An Inspector Follow-up Item (IFI) concerning t_he inoperabiiity problem of the
component cooling service water monitor (RM-SW-107) remained open.
During the
inspection and during the exit interview, the licensee committed to restorin~
these monitors to operable status by the end of the next refueling outage iri
both units (Paragraph 2).
Because of ventilation system alignment, there was backflow out of the
laboratory fume hoods (Paragraph 5).
The count room qua 1 i ty con.tro 1 program was adequate to ensure the accuracy of
plant radiochemical analyses (Paragraph 7).
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Liquid and gaseous* radioactive effluents were well within Technical
Specification (TSs). 10 CFR 20, and 10 CFR 50, Appendix I, effluent and
offsite dose limitations for 1988, and the first half of 1989 (Paragraph 8) .
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- W. Benthall, Supervisor - Licensing
- R. Bilyeu, Licensing Engineer
- P. Blount, Supervisor, Radiation Analysis
- R. Boles, System Engineer
- D. Christian, Assistant Station Manager
- D. Erickson, Superintendent, Radiation Protection
- B. Garber, Supervisor, HP Technical Services
- E. Grecheck, Assistant Station Manager
- M. Kansler, Station Manager
- R. McManus, Engineering Supervisor
- M. Paul, System Engineer
E. Swindell, Supervisor, Chemistry
Other licensee employees contacted during t~is inspection included
enaineers, security force members, technicians, and administrative
personnel. *
Other Organization
- G. Smith, Health Physics Supervisor, Westinghouse
NRC Resident Inspectors
- W. Holland
- L. Nicholson
- J. York
- Attended exit interviews
2.
Licensee Action or Previously IdentifiP.d Inspector Follow-up Items (92701)
(Open) IFI 87-02-03:
Resolve the inoperability problem of component
cooling service water monitor RM-SW~l07.
As discussed in Inspection Report No. 89-11, the component cooling service
water monitor, RM-SW-107, had been out of service since 1978, over 11
years. Debris in the service water had caused plugging of the sample line
to the monitor and jamming of associated pumps on a frequent basis. This
caused the 1 i censee to declare the monitor inoperable, requiring the
periodic grab sampling and analysis stated in Table 3.7.5(a) of the
Technical Specifications (JSs) .
"
2
The inspectors discussed with the licensee the most current status of the
monitor replacement program.
To resolve the problem, the licensee plans
to mount a sodium iodide crystal detector in a dry well that was to be
fabricated in the replacement component coolina water heat exchanaers.
-
-
The installation of the new ~etectors will coincide with the replacement
of the heat exchangers.
The semi -annua 1 Radioactive Effluent Re 1 ease Report for the period
January 1 through June 30, 1989, discussed this monitor replacement and
indica_ted that new heat exchangers would be delivered to the site by
January 1990 and that heat exchanger and ra.di ati on monitor replacement
would be completed by the end of the next refueling outage in each unit.
The discussion in this report was considered by the inspectors to be a
commitment and was verified as such with licensee management during an
exit interview conducted October 20, 1989.
This item remains open.
3.
Ventilation Vent No. 2 Gaseous Effluent Sampling (84750)
a.
As part of this inspection, the inspectors reviewed the systems in
place at Surry for monitoring and accounting for radioactive gaseous
effluents, including iodine, noble gases, tritium and radionuclides
in particulate form.
Surry Power Station, as originally designed and
built, had two main gaseous effluent stacks; Ventilation Vent No. 1
and Vent'11at.ion Vent No. 2 (Vent-vent No. 1 and Vent-vent No. 2).
Each of these stacks had been fitted with instrumentation for
monitoring gaseous effluents.
Starting in (approximately) 1978,
major desiqn changes and modifications to the ventilation system wete
undertaken.
The main thrust of these changes resulted in Vent-vent
No. 1 being shutdowr. and Vent-vent No. 1 effluent flows being
diverte-d to Vent-:-vent. No. 2, VJith the exception of condenser air
eJector ~nd vacuum.gas flows for both units which continued to exit
thrc,ugh Vent-vent No. i. These gas flows were monitored at the air
ejector discharges prior to entering Vent-vent No. 1, and on alarm,
divert to containment.
All radionuclide monitoring instrumentation
was removed from Vent-vent No. 1 at this time.
This desian chanae
1 eft Vent-vent No. 2 as one of the primary radioactive gaseous -
effluent release pathways for the plant. This release path included
ventil at.ion exhaust from the fo 11 owing areas:
the auxiliary
building, the fuel building, the decontamination building, safeguards
areas, containment purges, the hot 1 abora tory, the count room, and
the Health Physics (HP) Laboratory.
Currently, Vent-vent No. 2 is outfitted with severa 1 instruments
desianed for radioloaical monitorina.
These include:
a Victoreen
Particulate Monitor -(VG-RM-109), a - Victoreen Noble Gas Monitor
(VG-RM-110), c. Health Prysics Accountability Sampler, a particulate
and iodine cartridq, a back-up Accident Range Gas Monitor
(VG-RM-123), a Kaman High Range Normal Gas Monitor with particulate
and iodine filters (VG-RM-131-1). and a Kaman High Range High Gas
Monitor with particulate and iodine filters (VG-RM-131-2).
These
monitors were not installed all at the same time, but rather, were
added at different times during the course of plant life.
.
3
The licensee did not. provide information
011 exact dates of the
installation 6f these monitors, but the Victoreen Particulate monitor was
original equipment with an installation date in the 1972 timeframe.
The
backup accident range and HP monitors wer~ added sometime later with the
Kaman Accident Monitors added in 1982 as a result of NUREG-0737
requirements.
The inspectors determined, through interviews with licensee personnel, and
review of documentation, that the gaseous effluent samples being drawn off
Vent-vent No. 2 were not always representative.
TS 4.9.E requires
representative samples of gaseous radioactive effluent~ as does
Section 11.3.3.3 of the UFSAR. * One necessary condition to allow the
collection of a representative sample is isokinetic sampling.
During the
inspection, it was determined that isokinetic sampling of the Vent-vent
No. 2 did not exist because of the reasons discussed below.
Vent-vent No. 2 wa~ originally fitted with (and still uses) a stack flow
monitor and a samplin~ nozzle manufactured by Air Monitor Corporation.
Documentation dated June 22, 1989, provided by Air Monitor Corpo~ation to
the litensee specified that when Vent-vent No. 2 air flow was 130,000
cubic feet per minute (CFM), the sample volume being drawn through the
samplino nozzle should have been 7.3+/-20 percent CFM for isokinetic -flow
conditions to have existed.
Normal flow out of the Vent-vent No. 2 s+.ack -
was approximate1y 130,000 CFM.
The inspectors established that at the.
time of inspection that air flow into *this nozzle was approximately 12 CFM
by visual verification and summation of the flows through the monitors
associated with the Vent-veDt No. 2 stack sampling system.
This was the
flow required to adequately supply al i of the previously mentioned
monitors.
Although perfect isokinetic sampling is difficult to achieve,
12 CFM was significantly higher (65 percent) than the recommended 7.3 CFM.
The licensee indicated that this super-isokinicity had existed since the
installation of the Kaman accident ra~ge monitors in 1982._
The inspectors reviewed Surry's 10 CFR 50.59 Safety Analysis for the
installation of the Kaman normal and accident range monitors, Design
Change No. DC-80-64A, entitled Process Vent and Ventilation Vent High
Range Effluent Radiation Monitoring System, dated October 8, 1981.
This
review addressed the addition of extended ranqe effluent radiation
monitors to the previously installed sampling system. This evaluation die
_ not address the loss of isokineticity and thus the loss of representative
sampling of radioactive particles that would result when the sample
velocity through this nozzle was increased to feed additional monitors *
. Sample isokinisity was lost as increased flows required to* supply the
additi ona 1 monitors were added to the system.
This resulted in flows
. since at least 1982, normally well in excess of the required 7.3 CFM
through the Vent-vent_No. 2 sample ~ozzle resulting in a loss of sample*
representativeriess as required by Section 4.9.E of the TSs and specified
by* Section 11.3.3.3 of the UFSAR.
In this respect, this Safety Analysis -
was inadequate, and \\Atas considered a violation of 10 CFR 50.59(a)(l)
requirements (50-280, 281/89-32-01).
b.
4
The inspectors also reviewed NRC Inspection Report Nos. 50-280/84-02
and 50-281/84-02, dated March 13, 1984.
This report raised the issue
of the representativeness of the sampl inq of only the Kaman
monitoring systems under accident conditions; with consideration
aiven to the possible plateout of iodines and particulates in lona
sample lines.
This issue was l~ft as IF! 84-02-05 and was closed in
NRC Inspection Report No. 50-280, 281/86-01, dated February 7, 1989.
Although the licensee addressed this issue in an analysis performed by
Stone and Webster Engineering Corporation dated June 22, 1984, it
must be noted that flow to all of the gaseous effluent monitors
associated with Vent-vent No. 2, except the Kaman Accident ranoe
monitor, is isolated under accident conditions.
This analysis did
not address the fact that under normal operating conditions
(non-accident) the flow through the sampling nozzle was no longer
isokinetic thus not representative due to the increased flow rate
through the nozzle which was necessary in order to supply flow to
the Kaman monitors, the NRC monitors and the Victoreen monitors.
As a result of discussions with the inspectors concerning the issue,
the 1 icensee presented the inspe_ctors with two evaluations concerning
the representativeness of the sampling of the Vent-vent No. 2 stack.
This material was prepared for the licen~ee during the inspection by
their Architect/Engineer (Stone and Webster) and an onsite HP
consultant.
One evaluation stated that the airborne radioactivity
released from a nuclear power plant was in the form of very small
particles and thus anisokinetic samplinq would not cause a
significant deviation from represPntativeness, while the other
restated that most of these particles were small particles, and also
that only a small amount of the large particles preser.t would ever
be coliected on the sample because of impaction or sett1ing in the
sample lines, and that this loss of large particles is accounted for
in the error table presented in ANSI 13.1.
The inspectors received
and reviewed this material, and concluded that: a study on particle
size had not been performed at Surry to confirm the conclusion that
only small particles exist; that evidence was not presented from any
other facilities* studies which supported this view; and that there were
no indications that any "correction factors
11 had ever been applied to air
sample results used to ensure compliance with the off-site dose
limitations of Sections 3.11.B.1, 3.11.B.2 and 311.B.3 of the TSs.
It should also be noted that although the auxiliary ventilation system
consisted of three parallel filter assemblies, each consisting of B
rouqhing. absclute, and charcoal filters, they were not normally used to
filter exhausts from the auxiliary building which would have, therefore,
reduced the average particle site in the effluent stream.
The inspectors also reviewed two Deviation Reports dated March 3,
1989 and April 4, 1989, for Surry Power Station concerning Vent-vent
No. 2
1 s Accountability Sampler.
Both cases involved the VG-109/VG-110
monitor pump being inoperable. The Deviations occurred because alternate
sampling \\"Jas not performed within a one-hour time frame.
The second
deviation did identify the need for an engineering study to determine
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4.
5
if representative samples could be obtained using the
11 primary
accountability sampler
11
when the radiation monitor pump for
VG-109/110 was inoperable.
This request was passed on to a system
engineer, who, as a result of this request, noted in a draft
Engineering Work Request (EWR) the fact that the sampling system,
as was currently set-up was not always isokinetic.
Key personnel in
the HP department, however, who would have been concerned with this
problem from an effluent accountability standpoint, were not aware
of this issue until it was brought to their attention by the inspectors.
In summary, from 1982 to the present, Surry Nuclear Power Station was
co 11 ecti ng gaseous effluent sarnp l es from Vent-vent No. 2 with out
determinina with a reasonable dearee of confidence that these samples
Here isokinetic and/or representative.
This is an example of a
failure to conduct an adequate survey as required by 10 CFR 20.201(b)
arid a failure to obtain a representative sample as required by TS 4.9.E
(50-280, 281/89-32-01).
Ventilation System Leakage (84750)
As previously mentioned in Paragraph 3, Surry Nuclear Power Station
switched from two ventilation stacks to one ventilation stack in the 1978
timeframe.
The modification created an unbalanced ventilation system that
resulted in excessive back pressure in the Service Building Heating,
Ventilation and Air Conditioning (HVAC) system and the Auxiliary Building
HVAC system.
During this inspection, the inspectors observed that the Service Building
HVAC syste~ had degraded, and that there was significant leakage into the
areas discussed below.
This leakace was exacerbated because the system
was unbalanced.
These exhausts were potentiaily contaminated because:
portions of this exhaust was drawn through laboratory fume hoods
and from potentia1ly contaminated areas of the Auxiliary Building.
As a
result of the in~.pectors' findings, the licensee took action tc identify
and quantify this unmonitored leakage.
EWR 89-687, dated October 28, 1989,
discussed the results.
A large part of this leakage (i725 CFM) was
occurring in the Mechanical Equipment Room #2 (MER2), an unmonitored area
of the plar,t that is outside of the Radiation Controlled Area (RCA).
Additionally, the leakage was occurring in the Turbine Building and was
exiting the Turbine Building unmonitored to the environment through the
Turbine Building exhausts.
Additional unmonitored leakage \\'tas found on
the roof of the Service Building in three locations.
Plant management had been aware of this leakage prior to this inspection.
As part of this inspection, the inspectors reviewed a request for
engineering and construction assistance from the Assistant Plant Manager
to the Superintendent of Enaineering, dated July 20, 1989, that referenced
this leakage.
Although this leakage was recognized a~ being potentially
contaminated, it appeared that licensee documentation did not recognize
the leakaqe as being unn~nitored release pathways to the ervironment, nor
were these releases quantified.
6
After quantifying the leakage, the licensee attempted to patch and repair
the leakina portion of the ventilation system.
This caused the back
pressure in the system to increase to 9 inches water gauge from 6.5 inches
(the ventilation system design pressure is 6 inches water gauge).
The
licensee stated that licer.see personnel checked the system every two days
for failed patches and/or leaks.
The inspectors observed, however, that
on October 30, 1989, during the second week of the inspection, several
patches were ineffective and leakage was again occurring.
The licensee also provided Stone and Webster Engineering Corporation with
rough estimates of the amount and activity of the leakage so that an
evaluation could be performed to determine what the maximum permissible
leak rate could be before exceeding the limits given in Table 1, Column 1
of Appendix B to 10 CFR 20.
This evaluation was also to address the
overpressurization of the duct work.
The licensee had also indicated that future plans had been made to restore
Vent-vent No. 1 back to- service in hopes of correcting the back pressure
problems ~nd help minimize leakage from the ductwork.
The licensee has
indicated, verbally, that once this change is complete they will
investigate the feasibility of implementing a Ductwork Integrity
Inspection Program.
The, unmonitored leakage into the Turbine Building and into MER2 are
considered more examples of failure to obtain adequate surveys as required
by 10 CFR 20.201(b) (50-280, 281/89~32-0l).
5.
Ventilation and Hood Flows (84750)
During the first week of th~ inspectiori, the inspectors noted that the
laboratory hoods in the Count Room were
11 blowing back,
11 i.e., that instead
of drawing air into the hood, air flow was reversed or was static. This
situation was also occurring in the Hot Chemistry Laboratory and in
segments of the Auxilic-ry Building a*nd the Service Building. The licensee
indicated that this reverse flow had caused airborne contamination of
these areas in the past, and that the blow-back through the hoods was a
result of. the realignment of the ventilation system as discussed rn
Paragraph 3, which resulted in an unbalanced system and back pressure
buildup.
The static pressure created by the Auxiliary Building exhaust
streams could not be overcome by the hot lab exhaust fans. Subsequent to
these discussions, the licensee issued a plant Deviation Report. dated
October 18, 1989, which described these problems and listed initial and
corrective action~.
These actions included suspending the processing of
radioactive samples in the hoods, and suspending the processing of
personnel and materials through the personnel dress out area upon
identification of airborne contamination *
. .
7
The Operations Superintendent also issued a written directive to all shift
supervisors, dated October 20, 1989~ which directed _the supervisors to
notify the HP Shift Supervisor upon- any changes in the auxiliary
ventilation system line-up that could initiate this backflow.
The
licensee also installed portable airborne radiation monitors in these
areas.
The licensee believed that future plans to restore Vent-vent No. 1 back to
service would correct the ventilation system back-pressures and the
reverse fl ow out of laboratory fume hoods.
An evaluation of the maximum allowable back flow into these areas was
beina performed by Stone and Webster Corporation in conjunction with the
study concernJnq duct leakage and overpressurization discussed in
Patagraph 5 of this report. Ventilation system realignment was made
during the-first week of the inspection in an attempt to fix*the back-flow
problem, however, the inspectors noted during the second week of the
inspection that back flow out of the h~ods was still occurring. The
completion or review of this evaluation will be tracked during subsequent
inspections as IFI 89-32-02.
This reverse flow cut of the laboratory hoods was not indicative of air
being supplied to the least likely areas to be contaminated for
circulation tG and exhaust from locations subject to the greatrst
poteritial contamination as stated in Section 9.13.4 of the UFSAR.
6.
Plant Chemistry (84750)
During a review of various plant chemistry parameters, the following
observation5 were noted.
a.
At the time of the inspection, Unit 1 was operating at 100 percent
power.
Unit 2 was shutdown because of pressurizer code safety rel,ief
valve difficulties.
b.
During steady state operations, Unit 1 reactor coolant Dose
Equivalent Iodine-131 (DEI-131) averaged about 2E-2 micrccuries/gram.
Gross reactor coolant activity ranged between 6E-1 and
7E-l microcuries/gram. Reactor coolant tritium activity averaqed
about 3E-1 microcuries/gram. These values indicated no significant
fuel leakage problems. Unit 2 reactor coolant radiochemical
parameters were not reviewed.
c.
Unit 1 reactor co6lant chlorides had been maintained b~tween 5 and
10 parts per billion (ppb) from January to October 1989.
Fluoride
had been consistently maintained below 5 ppb.
Unit 2 reactor coolant chlorides had been maintained between 5 and
20 ppb and fluorides had been maintained below 5 ppb for the period.
'
8
d.
Because of reactor coolant syst~m leakage into the component cooling
water system (CCW), recent grab samples of the CCW had indicated
radioactivity of about l.6E-3 microcuries/milliliter, and*
approximately 60 parts per million (ppm) boron.
No violations or deviations were identified.
7.
Count Room Quality Control (84750)
The licensee's counting room QA program was reviewed to ensure compliance
with selected and applicable portion of Regulatory Gu.ide 4.15, Quality
Assurance of Radiochemical Monitoring Programs (Normal Operations)
Effluent Streams and the Environment, Revision 1, February 1978 *. The
following observations were made.
a.
Quality control* (QC) checks of the ND.6600 gamma spectroscopy system
detectors, their frequency, and acceptance criteria were described in
procedure HP-3.4.1.6, ND6600 Detector System Energy Calibration and
Quality Control Program. May 12, 1989.
These QC checks included
daily backgrbund and source checks (efficiency) with an acceptance
criteria of plus or mim1f. 2 standard deviations from a predetermined*
.arithmetic mean, and a daily full-width half maximum check
(resolution) with an acceptance range of 1.50 to 3.00.
A review of
these checks for October 1989 indicated these data were within
specified limits, indicating general detector stability.
b.
Daily efficiency ahd background checks of the Beckman LS100C liquid
_ scintillation counter used for tritium analyses were within specified
control limits. for the period January through October 1989.
c.
Daily background and efficiency checks of the PC-4 gas flow
proportional counter (May 1988 through October 1989) and the PC-55
gas flow proportional counter (November 1988 through October 1989),
both used for alpha and beta analyses. were within specified limits
for the period January throug~October 1989.
d.
A 11 comparative results of .a recent confirmatory measurements prograrn
between the NRC and the licensee of selected radionuclides (Tritium,
Iron-55, Strontium-89, and Strontium-90) were wtthin agreement (see
supplement to Inspection Report No. 50~280,281/89-27, October 19,
1989).
e.
The inspectors reviewed the results of a confirmatory measurements
program conducted by the Virginia Power Corporate HP staff during
October 1988 and May 1989.
This program included gamma spectroscopic
and tritium analyses.
The results indicated excellent agreement
for both years.
No violations ~r deviations were identified .
9
. 8.
Semi-Annual Effluent Release Reports (84750)
The inspectors reviewed the semi-annual radioactive effluent report data
for the period January 1 through June 30, 1989.
This review included a
comparison of this data to the liquid and gaseous effluent release data
for 1988 and 1987 data.
The reports appeared to be complete and to
contain the information specified in Regulatory Guide 1.21.
The data is
summarized in the Attachment to the report~
Liquid fission and activation products and gross alpha releases showed no
significant trends between 1987 and the first half of 1989.
Liquid
tritium releases. however, did show a continuing decreasing trend for the
period.
Gaseous tritium and particulate releases showed no significant trends
between 1987 and the first h~lf of 1989.
Gaseous fission and activation
gases and iodines showed n6 significant trends between 1987 and 1988,
however, during the first half of 1989 there was no activity reported for
these categories.
This was attri bu tab 1 e to both uni ts being shutdown
during the entire period.
There was a significant increase in liquid radwaste volume during the
first half of 1989.
This could also be attributed to both units beinq
shut down.
Li~uid and gaseous radioactive effluents were well within TSs, 10 CFR 20,
and 10 CFR 50, Appendix I effluent anct offsite dose limitations for 1988
and the first half of 1989.
No violations or deviations were identified.
9.
Exit Interview
The inspection scope and results were summarized on October 20 and
November 3, 1989, with those persons indicated in Paragraph 1.
The
inspectors described the areas inspected and discussed in detail the
inspection results listed above.
The licensee did not identify as
proprietary any of the material provided to or reviewed by the inspectors
during this inspection.
Dissenting comments were expressed by the
licensee concerning the inspectors' findings on sample representativeness.
Item No.
50-280, 281/89-32~01
50-280, 281/89-32-03
Description and Reference
VIO - Modifications to ventilation
systems
resulting
in
inadequate
surveys
of
gaseous
effluer.ts
(Paragraphs 3, 4, and 5).
IFI - Evaluation of maximum allowable
back fl ow out of the laboratory fume
hoods (Paragraph 5).
\\ *
50-280, 281/89-32-04-
10
IFI - Resolve inoperability problem of
component cooling service water montior
RM-SW-107 (Paragraph 2) *
t
~
)
- s
, ....
ATTACHMENT
SURRY RADIOACTIVE EFFLUENT SUMMARY
1st half
1987
1988
1989
No. of Unplanned Releases
a.
Liquid
0
0
0
b.
Gaseous
0
0-
0
Activity Released (curies)
a.
Liquid
1.
Fission and
5.17E+OO
2.41E+OO
2.2E+OO
Activation Products
2 .
8.15 E+02
4.94E+02
l. lSE-+:02
3.
Gross Alpha
3.91E-05
8.00E-5
6.98E-06
b.
Gaseous
1.
Fission and
3.08E+02
3.66E+02
O.OOE+OO
Activation Gases
2.
l.81E-02
9.58E-03
O.OOE+OO
3.
3.04E+Ol
2.79E+Ol
1. 46E+Ol
4.
Particulate
2.84E-03
l.06E-02
l.62E-03
C.
Volume of Liquid
2. 96E+08
2.58E+08
2.71E+9
Wastes Released
(prior to diluation)
(liters)