ML20002E477
| ML20002E477 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 01/05/1977 |
| From: | Fisher W, Hueter L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20002E476 | List: |
| References | |
| 50-155-76-22, NUDOCS 8101280129 | |
| Download: ML20002E477 (10) | |
See also: IR 05000155/1976022
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UNITED STATES NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT.
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REGION III
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Report of Radwaste Management Inspection
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'IE Inspection Report No. 050-155/76-22
Licensee:
Consumers Power Company
212 West Michigan Avenue
Jackson, Michigan 49201
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Big Rock Point Nuclear Power Plant
License No. DPR-6
Charlevoix, Michigan.
Category:
C
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' Type of Licensee:
BWR - 240 MWt
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Type of-Inspection:
Routine, Unannounced
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Dates of. Inspection:
December 7-10, 1976
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Principal Inspector:
. J. Hueter
(Date)
Accompanying Inspectors: None
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Other-Accompanying Personnel: None
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. Reviewed By:
W. L. Fisher, Chief
/ - 7- 7 7
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Fuel-Facility Projects and
(Date)
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Radiation Support Section
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SUMMARY-OF'F'INDINGS
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Inspection Summary
Unannounced inspection on December 7-10, 1976, (76-23 :
Radioactive
waste systems inspe'ction included gaseous and liquid effluent releases,
offsite-shipment of radioactive waste and non-waste radioactive materials,
records and reports of effluents and shipments, effluent control instru-
mentation, and procedures. Licensee's response to IE Circular No. 76-03,
,
" Radiation Exposure in Reactor Cavities ," was also reviewed.
Enforcement Items
'The following items of noncompliance were identified during the inspection:
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A.
-Infractions
~
1.
Contrary to 16 CFR 20.203(c)(3), the locked doors and gat'es
used.to control access to high radiation areas in the reactor
facility are not established in such a way that no individual
will be prevented from leaving a high radiation area.
(Paragraph 6. Report Details)
2.
Contrary to 10 CFR 20.201(b), measurement of particulate
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radioactivity in airborne effluents was not adequate to ensure
,
compliance with 10 CFR 20.106 and Technical Specification
!
6.5.4. (a), due to apparent bypass of the stack sample filter as
noted for the week ending January 20, 1976.
(Paragraph 9,
Report Details)
B.
Deficiency
Contrary to Technical Specification 6.9.3.a.(3), the semiannual
report for the first half of 1976, dated August 31, 1976 and revised
September 15, 1976, did not contain any of the required data regard-
ing solid radwaste shipments made during the report period.
(Paragraph 10, Report Details)
,
Licensee Action on Previously Identified Enforcement Items
At the time of the last radwaste management inspection 1/ it was
noted that the licensee had not completed the writing and approval
of a formal procedure for measurement of the off-gas density, which
in turn was part of the planned corrective action regarding an item
I
.
If IE Inspection Rpt No. 050-155/75-14.
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of noncompliance noted during a previous inspection.2/ This procedure
has now been' written, approved, and implemented.
(Paragraph 5,
Report Details)
Other Significant Items
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A.
Systems and Components
1. -
The successful testing and plugging (
'eaking condenser tubes
during the extended outage in the fir e half of 1976 has
.resulted, among other things, in a significant reduction in
'
liquid radwaste effluent during the current run. The repairs,
'
coupled with the favorable experience of fuel element cladding
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integrity during the last two runs, may result in the licensee
maintaining liquid effluent activity (excluding tritium) below
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one curie ~during 1976, a new low for a one-year period.
-(Paragraph 8, Report Details)
2.-
Due to matters considered of higher priority by the licensee,
little progress has'been made since the last radwaste inspection
discussedinpreviousinspectionreports.fthecanalmonitor
regarding the problem of spurious alarms g
(Paragraph 7,
Report " tails)
.
B.
Facility It
"1ans and Procedures)
None.
C.
Managerial. Items
None.
D.
Deviations
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None.
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E.
Status of Previously Reported Unresolved Items
No previously reported unresolved-items within the scope of this
.
inspection.
Management Interview
A
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The -inspector conducted an interview with Mr. Ilartman, Plant Superintendent,
and other-members of the plant staff at the conclusion of the inspection
on December 10 and with Mr. Ilartman by telephone on December 15, 1976.
The
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following items were discussed with licensee personnel:
1
(
2/ RO Inspection Rpt No. 050-155/74-08.
3,/ IE Inspection Rpts No. 050-155/75-09 and No. 050-155/75-14.
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.The three items of noncompliance identified were discussed.
_(Paragraphs
6,~
9 and 10, Report Details)
At the time of the last radwaste' management inspection,4/ an apparent
B.
typographical error had been noted by.the inspector in the licensee
~
reported' percent of limit of liquid radwaste released for 1974'.
The inspector acknowledged that the reported data had been corrected-
by the licensee.
(
. Paragraph 8, Report Details)
During a previous inspection 5/ the inspector had noted some
4.
C.
possible conservative discrepancies-involving reporting of
particulate' activity released in gaseous effluent for December
1974 for' xenon-138 and barium / lanthanum-140. The licensee has
since reviewed the matter, documented the finding, and concludcd
that_the reported data were valid.
The_ inspector noted that he
had reviewed the matter.and has no further questions at this time
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regarding the matter.
(Paragraph 9,. Report Details)
D.
The status of the canal monitor spurious alarms study-was discussed.
(Paragraph 7, Report Details)
'E.
Completion of final corrective action regarding a previous item of
noncompliance, by the writing, approval, anu implementation of a
procedure for measurement of off-gas density, was discussed.
The
inspector stated that he had no further questions regarding the
matter.
(Paragraph 5, Report Details)
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'4/ IE Inspection Rpt No. 050-155/75-14.
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_5/. Ibid.
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REPORT DETAILS
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1.
Persons Contacted
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C. Hartman, Plant Superintendent-
C. Axtell, Plant' Health Physicist
T. - Brun, Chemical and Radiation Protection Supervisor
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2.
_ Procedures
The inspector reviewed a revised and properly approved radiochemistry
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This
procedure (RCP)' prepared since the last radwaste inspection.
procedure is designated RCP-3 (Rev. O, May 14, 1976) "Off-Gas Com-
position Analysis." The inspector has no further questions at this
time regarding the referenced procedure.
c
.
. Containment Air-Cleaning Systems
3.
,
A high efficiency filter is located at the base of the stack for
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removal of particulates from the air ejector off-gas following
holdup. A demister precedes the filter. All other air and vent-
systems leading to the stack are unfiltered.
A gauge measures the
differential pressure across the filter in inches of water. The
differential pressure reading is recorded once per shift in the
Operations' Log Book. The log reading is reviewed by the Plant
4
Health Physicist. The filter has been changed at Icast once or
twice yearly in the past two years. The differential pressure
usual 2y remains at zero throughout the filter use time, but has on
,
occasion in the past read as high as one or two inches of water.
'
No in-place testing of the filter is performed at the time of
filter installation. There are no provisions for introducing the
test media. The inlet side of the filter is buried under ground and
under about a foot-thick layer of concrete.
No specific requirement
'
is contained in the technical specifications or in the final safety
I
analysis report for performing an in-place filter efficiency test.
The licensee has a detailed maintenance procedure for filter instal-
lation to minimize potential for damage to the filter or improper
2
installation, either of which could result in reduced efficiency.
4.
Concentration of Iodine in Reactor Coolant
.
.
.
A review of records from January 1, 1976 through December Si, 1976
4
showed that primary coolant was sampled and analyzed daily as
required for iodine concentration and other quality items during
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l periods of power operation and every second or. third day during
outages. The maximum iodine concentration measured was 2.5E-02
microcuries per milliliter: (pCi/ml), which .is less than one thousandth
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.of the. technical specification limit of 3.5E+01~pCi/ml. The coolant
concentration reached'a low of about 1.0E-07 pCi/ml of iodine
during the extended outage in the first half of-1976.
5.
, Follovup cni Previous Noncompliance Item
L
the time of the lase.' 3dwaste inspection 6/ . the licensee had-not
At
.coupleted all of the planned corrective action (writing andLapproval'
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of a formal procedure for measurement of ~ off-gas density) re9frding
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an item'of noncompliance noted during a previous inspection.-
It
was noted~during this inspection that the. procedure-for measurement
of off-gas density has been written, approved, and; implemented.
"
6.
Licensee Response to IE Circular No. 76-03.
By letter. dated' November-18,.1976, from the Assistant Nuclear
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Licensing Administrator of Consumers Power Company to IE:III, the
licensee responded to IE Circular No. 76-03~ titled " Radiation
Exposures in Reactor Cavities." The inspector reviewed the licensee's
response regarding the Big Rock Point facility and toured the
facility, observing the locations and entrances.to the continonas
a
and, transient high radiation areas.
Review of survey data < mas
that the~ highest accessible radiation level is about 3 R/hr.
Based
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on plant design, operation, and survey data history, the licensee
does not forsee the possibility of radiation levels exceeding
10 R/hr maximum in accessible areas.
!.
The continuous high radiation areas have locked gate or door entrances
with key control by the shift supervisor. The opening of some of
- the gates or doors also sounds an alann in the control room.
A
-log-in and log-out in the control room log is used for each entrance
and-exit from these areas. A radiation survey is required for
,
entry to high radiation areas.
Entrances are posted with-signs
indicating the presence of a high radiation area and a status board
showing results of the most recent radiation survey (including
maximum and general working area 1cvels) and stating the radiation
precautions necessary for entry.
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The entrances to transient high radiation areas are also posted
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with status boards providing the same type of information.
The
sources of radiation in these areas'are such that fields are not
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.likely to change rapidly. -These ~ areas are surveyed daily for
observation of any changes in radiation levels.
Radiation
surveys are required for any work performed in these potential
.
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6/ IE Inspection Rpt No. 050-155/75-14.
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7/ RO Inspection Rpt No. 050-155/74-08.
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During this review it was noted.that the locked gates or doors used
to control access to the high radiation areas were not established
in such a way -that an individual could always unlock the ' door f rom
the inside. Therefore licensee personnel were informed that the
licensee was in apparent noncompliance with 10 CFR 20.203(c)(3), in
that the locked doors and gates used to control access to the high
radiation areas in the reactor facility were not established in
such a way that no individual would be prevented from leaving a
7.
Status of Canal Monitor Spurious Alarms
The problem with spurious alarms of the canal monitor as well as
some-testing and reg 7mmended changes have-been discussed in previous
inspection reports.-
Due to matters considered of higher priority
_
by the licensee, little has been done on this matter in the past
year. The project has been assigned to another' individual, who has
initiated some further testing for a possible alternative t o enclosing
in flexible conduit the signal cable between the auxiliary building
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and the screen house. _The alternative is being sought, as it is
anticipated that considerable difficulty may be encountered in
enclosing the signal cable in flexible conduit due to the length
and bends involved in the underground line.
It was stated that
spurious alarms have been much less frequent in recent months.
'
8.
Liquid Radwaste
Liquid radwaste-is collected and released on a batch basis.
Before
release, each batch is sampled and analyzed.
The analysis includes
a gross beta concentration and specific radionuclide concentrations
of. gamma emitters. A weighted MPC is determined for each batch.
The component radionuclides not identified by gamma spectrometry
but measured by gross beta analysis are conservatively presumed to
'
be all strontium-90 and are released an that basis.
Records and reports of liquid radwaste were reviewed for the last
six months of 1975 and the first six months of 1976; no discrep,ancies
were noted. . Release data, records, and reports for June 1976 were
I
reviewed in more detail. Analytical and release calculations
appear to have been performed accurately and results reported
correctly. 'The total radioactivity released in liquid (excluding
tritium) during 1975 was reported as 1.4 curies, 2.2% of the technical
specification limit. During the first half of 1976 the corresponding
liquid release was reported as about 0.57 curies, about 0.26%~of
the technical specification limit. The licensee anticipates being
i
able to keep releases in liquid effluent below one curie'(excluding
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8/ IE Inspection Rpts No. 050-155/75-09 and No. 050-155/75-14.
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tritium) for the entire ~ year of 1976, a long sought after goal.
The licensee has been aided toward this-goal by the good integrity
of fuel' cladding during the past.two fuel runs and by the testing.
and plugging of faulty condenser tubas during the extended outage
-in'the first half of 1976, thus virtually ending the condenser
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inleakage problem and resultant yste water inventory problem noted
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in a previous. inspection report.
During a previous inspection,10/ the licensee agreed to correct a
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typographical error-(involving a misplaced decimal point) observed
'during the inspection in the reported percent of technical speci-
fication limit for liquid releosr.s.
The correction was subsequently
made on page 45 in the 23rd Semiannual Report of Operations.
9.
Gaseous Radwaste
A sample of off-gas obtained weekly during power operation is
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analyzed by cither GeLi or gamma spectrometry for six noble gas
radionuclides.
Based upon the off-gas flow and the mixture of the
six nuclides, a stack release rate which includes a total of 22
noble gas radionuclides is determined.
The stack release rate is
based on a 30-minute holdup time for off-gas plus a 1% contribution
from the turbine sealing steam system utilizing a two-minute holdup.
The 1% turbine seal contribution has the same distribution of
nuclides as the off-gas corrected for a two-minute decay period.
By
observing the off-gas monitor response at the time the off-gas
(,
sample is taken, a multiplying factor can be obtained which, when
applied to the off-gas monitor response in counts per second, gives-
the resulting release rate at the stack in microcuries per second.
Particulate and halogen releases to the atmosphere are measured by
counting particulate and charcoal filters weekly. The filters
sample stack effluent continuously at a rate of three cubic feet
per minute. Determination of release rates in this manner assumes
that radioactivity is continually being deposited uniformly through-
out the week on the filters. A decay. correction to the time of'
analysis is applied, depending on'the half-life of radionuclide
,
observed. The net unidentified particulate beta activity is conserva-
tively presumed to be all strontium-90 in determining the percent
of release limit. The weekly charcoal and particulate filters are
,
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analyzed and counted at the plant and release _ rates determined.
The inspector conducted a cursory review of gaseous halogen and
particulate records and reports for the last half of 1975 and the
first half of 1976. A more detailed review was made of the January
1976 data and report to evaluate data reduction techniques, radio-
,
nuclide identification, and release rates.
During this rev!ew some
9/ IE Inspection Rpt No. 050-155/75-14.
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problems were noted as described'below:
Particulate filter bypass
- was evident for the weekly samples removed and counted on January 20,
1976,-in that on~y about 4.4E-04 microcuries (,pci) of cesium-137-
was collected on the particulate filter while about 1.2E-03 pCi of
cesium-137 was collected on the backup charcoal filter used for
iodine collection.- Therefore, about 2.7 times as much cesium-137
was-collected on the charcoal filter (a filter not designed for
efficient collection of particulates) as on the particulate filter.
Also, about 1.6 times as much cesium-134 was collected on the
charcoal filter as on the particulate filter.
Therefore, the
licensee is in apparent noncompliance with 10 CFR 20.201(b) in that
measurement of particulate radioactivity in airborne effluent was
'
not adequate to ensure compliance with 10 CFR 20.106 and Technical Specification 6.5.4.(a)
during the first quarter of 1976 due to
evidence of particulate filter bypass.
^
The problem of particulate filter bypass has previously been identi-
Report- poted in a recent Confirmatory Measurements Inspection
fled opy
and the licensee has modified the procedure for particulate
filter installation which the licensee believes has eliminated the
problem. Also, as noted' in the previously referenced Confirmatory -
Measurements Inspection Report, based on the result reported by the
licensee in the confirmatory measurements comparison for the first
'
quarter of 1976, the licensee would have underreported the radio-
'
nuclide concentrations of particulate activity and therefore the
particulate activity released in gaseous effluents during that
.z
quarter.
It should be noted that although the evaluation of particulate
activity in gaseous effluent was inadequate, the licensee would not-
'
have approached any reicase rate limit, based on data reviewed for
weeks when there was no evidence of particulate filter bypass and
based on the magnitude of the differences in confirmatory measurements.
The inspector also observed during the review that the quantities
of cesium-137 and cesium-134 reported in the radioactive-effluent
,
summaries report to the NRC dated August 31, 1976, as being releascd
in gaseous effluent for the month of January 1976, were apparently
in error. The sum of the activity for each of these two radionuclides
as obtained from the weekly packet of data which the licensee
stated was submitted to the corporate office for the report prepara-
tion was significantly higher than that contained in the report.
From the data packets it was observcd that about 400 pCi of ce.ium-
137 were released in January, but the report showed only 92 pCi as
being released.
It appeared that only two of the four pieces of
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. 11/ IE Inspection Rpt No. 050-155/76-20.
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input' data were included in the report data. 'Further, the data
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.fr'om.the weekly: packets indicated that 70 pCi or more of cesium-134'
wbre released in January,1but the record showed'only 45 pCi as
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being: released.
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During a previous inspection
the. inspector noted some possible~
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discrepancies-(conservative.in nature) between xenon-138 and barium /:
lanthanum-140 particulate activity data in licensee records and
7
' data reported for.. December 1974. The licensee had agreed to review-
[
the matter and if errors were-identified to correct previously
reported data. During this_ inspection it was found that.the licensee ~
,
'had reviewed the'matterfand documented the findings which concluded
'that the previously reported values were. valid.
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10. . Solid Radwaste Storage, Transfer, and Records
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.The licensee's colid radwaste generation, handling and storage
~
equipment and facilities, processing, disposal, and procefgyes are
essentially as described in a previous -inspection report.--
No
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discrepancies were noted in a comparison of the licensee's recorded
-data pertaining to offsite shipments of radioactive waste for.the
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last six months of 1975 and corresponding information contained in
i
the semiannual report.
Further,'no problems were noted~during the
review.of the licensee's records of surveys of containers and
vehicles and records of contained activity and volume for the ~1ast
half of 1975 and the first half of 1976.
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. Technical Specification 6.9.3.a. (3)
requires that the semiannual
report contain data on shipments of solid waste shipped from the
.
plant site during the report period. No data on the truck _ load of
drummed solid waste shipped on May- 20, 1976 were contained in the
,
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semiannual report covering the.first half of 1976, dated August 31,
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1976 and as revised September 15, 1976.
Therefore the licensee was
'
informed of apparent noncompliance with Technical Specification 6.9.3.a.(3), in that the semiannual report for the first half of
'
1976, dated August 31, 1976 and revised September-15, 1976 did not:
contain any of the required data regarding solid radwaste shipments
made during the report period.
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12/ IE Inspection Rpt. No. 050-155/75-14.
13/ RO Inspection Rpt No. 050-155/74-08.
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