ML20132H027
| ML20132H027 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 07/30/1985 |
| From: | Hueter L, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20132H004 | List: |
| References | |
| 50-254-85-21, 50-265-85-24, NUDOCS 8508050228 | |
| Download: ML20132H027 (10) | |
See also: IR 05000254/1985021
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-254/85021(DRSS); 50-265/85024(DRSS)
Docket Nos. 50-254; 50-265
Licensee:
Commonwealth Edison Company
Post Office Box 767
Chicago, Illinois 60690
Facility Name:
Quad Cities Nuclear Power Station, Units 1 and 2
' Inspection At:
Quad Cities Site, Cordova, Illinois
Inspection Conducted:
July 9-12, 1985
Inspector:
Hueter N
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Date
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Approved By:
M. C. S humacher, Chief
Independent Measurements and
Date
Environmental Protection Section
Inspection Summary
Inspection on July 9-12, 1985 (Reports No. 50-254/85021(0RSS); 50-265/85024(DRS'i))
Areas Inspected:
Routine, unannounced inspection of gaseous and liquid
radioactive program including:
effluent releases; records and reports of
effluents; effluent control instrumentation; procedures for controlling
releases; reactor coolant chemistry and activity; gaseous effluent filtration;
and audits.
The inspection involved 35 inspector-hours onsite by one NRC
inspector.
Results: One violation was identified (failure to collect and analyze service
water grab samples at required frequency for both reactor units when the
service water monitors were inoperable - Section 5).
8508050228 850731
ADOCK 05000254
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DETAILS
1.
Persons Contacted
- R. Bax, Production Superintendent
- P. Behrens, Lead Chemist
H. Lihou, Technical Staff Supervisor
E. Mendenhall, Thermal Engineer
- C. Norton, Quality Assurance Engineer
R. Petri, Radwaste Engineer
- J. Sirovy, Rad / Chem Supervisor
R. Soenksen, Scheduler / Work Analyst, Instrument Maintenance
Department
- G. Spedl, Assistant Supervisor, Technical Services
B. Strub, Compliance Coordinator
- T. Tamlyn, Services Superintendent
- A. Madison, NRC Senior Resident Inspector
A. Morrongiello, NRC Resident Inspector
- Denotes those present at the exit meeting.
2.
General
This inspection, which began at 8:00 a.m. on July 9, 1985, was conducted
to examine the licensee's gaseous and liquid radwaste management program
and related activities for safety and compliance with regulatory
requirements.
3.
Gaseous Radioactive Waste
The inspector reviewed the licensee's gaseous radwaste management
program, including:
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 weaknesses.
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The program was reviewed for calendar year 1984 and first quarter of
1985.
The inspector reviewed semiannual effluent reports for 1984 and
selectively reviewed effluent records for the same period.
Gaseous effluents are exhausted from the plant via two pathways, the
reactor building ventilation duct (a ground level release, common to both
units which is sampled and monitored before the two unit effluents combine)
which may include drywell and torus ' venting, and the plant chimney (an
elevated release comprised of sources such as turbine building exhaust,
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standby gas treatment system (SGTS) exhaust, gland steam exhaust and off
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gas, the latter, following processing by the hydrogen recombiner, delay
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line and charcoal beds).
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Under normal plant conditions, gaseous releases are quantified for noble
gas based on weekly grab samples from the reactor building vent duct and
daily grab samples from the plant chimney.
Particulates and iodine
releases are quantified based on weekly particulate filters and charcoal
samples from both pathways.
Under abnormal conditions, sampling may be
more frequent to meet technical specification requirements.
In addition to the grab samples described above for quantifying noble gas
releases, the chart recorders on the noble gas monitors for these pathways
are routinely observed for spikes or peaks that could represent short term
releases over and above that quantified from the grab samples.
Such
releases are quantified by procedure using " area under the peak" and an
efficiency factor obtained during monitor calibration using a sample of
plant generated gas mixture.
Tritium samples are collected monthly from
both the reactor building vent duct and the plant chimney by a freeze
trap using glycol and dry ice.
(Before December 19, 1984, the frequency
of the noble gas, particulate, iodine, and tritium samples was different
than described above in order to meet technical specifications in effect
at that time.)
Particulate filters for the various pathways are accumulated monthly and
a gamma isotopic analysis is performed inhouse following which the
filters are sent to a contractor for analysis of alpha activity and
strontium-89 and strontium-90 activity.
Prior to drywell venting the atmosphere is sampled and analyzed for
particulate and iodine activity to evaluate whether the effluent may be
released from the reactor building vent duct or whether it should be
diverted through SGTS and released via the plant chimney.
The CECO computer program for dose updates and projections is run monthly
to meet technical specification requirements.
By inputting releases of
each nuclide for the month into the computer program, the gamma air dose,
beta air dose, total body dose, skin dose and most restrictive organ dose
is provided for the current month, the current calendar quarter to date,
the three previous calendar quarters and the calendar year to date.
Since July 1, 1984, reactor Unit 1 has been in operational status except
for the first seven weeks of the period and several one to three day
outages since that time.
Since July 1, 1984, Unit 2 has been in
operational status except for a few short outages lasting one to nine
days and one larger outage lasting over 11 weeks, ending on June 5, 1985.
The licensee has had no evidence of fuel cladding problems for the past
several years with either unit.
Radioactive effluent release rates and
offsite dose rates have remained low.
In 1984, 6,000 curies of noble gas
and 4.52E-02 curies of iodine-131 were released in gaseous effluents from
both units combined.
Inserting into the CECO computer code the annual
values of curies of each nuclide released in gaseous effluents in 1984,
the calculated maximum whole body dose and maximum thyroid dose (most
restrictive organ dose) to any individual beyond the site boundary were
4.85E-02 mrem and 6.49E-02 mrem respectively for Unit 1 and 4.77E-02 mrem
and 7.59E-02 mrem respectively for Unit 2.
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In review of gaseous effluent records it was observed that the iodine
activity in gaseous effluents for one month during the third quarter of
1984 was not included in the semiannual effluent report for the last half
of 1984.
The iodine activity had been included in the monthly reports
(prepared for the State of Illinois) which are used to prepare the
quarterly data.
The iodine releases for the month in question were lower
than normal and if included would have added only about 9% to the
quarterly total of iodine releases.
During a previous inspection,
Inspection Report Nos. 50-254/84-13 and 50-264/84-11, errors were
identified in 1983 effluent reports for which the licensee submitted
errata sheets to correct the data.
The inspector observed that although
the errata sheets corrected the previous erroneous data some typographical
errors involving signs of exponential numbers for dilution water volume
were included on one errata sheet involving previously correct data.
These matters were discussed at the exit.
No violations were identified.
4.
Liquids and Liquid Radioactive Wastes
The inspector reviewed the licensee's reactor liquids and liquid radwaste
management programs, including:
determination whether reactor liquids
meet chemical and radiochemical requirements, determination whether
liquid radioactive waste effluents were in accordance with regulatory
requirements, adequacy of required records, reports, and notifications,
and experience concerning identification and correction of programmatic
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weaknesses.
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The program was reviewed for calendar year 1984 and the first quarter of
1985.
The inspector reviewed semiannual effluent reports for 1984 and
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selectively reviewed effluent records for the same period.
No
significant problems were identified during this review.
Liquid effluents are released on a batch basis from a single tank
(following sampling and analysis) to a single release path which is a
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monitored (with alarm and isolation function) radwaste line.
This line
directs effluent to the south diffuser line of two diffuser lines to
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provide adequate dilution with station circulating water to assure that
the effluent reaching the river is below MPC for the mixture of all
nuclides released.
This has been the only release path since May 1984
when use of the stations circulating water system has been operated
directly to the river rather than the spray and recycle mode.
This
change resulted from alteration of a previous commitment made to a public
environmental organization.
It increases the dilution flow when
radioactive liquids are batch released from the discharge tank to the
Most plant liquids, including chemical waste
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liquids, are processed and reclaimed by use of filters and resin beds (no
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radwaste evaporators).
Resins which are basically " spent" are further
used for initial processing of chemical wastes.
As a result, batch
releases consist mainly of laundry water (filtered prior to release) or
an occasional batch of water which has been processed but either does not
meet criteria (such as high organic content) for reuse or is released
during the early stages of an outage due to lack of storage space.
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Analyses of batch liquid releases includes two grab samples of the
recirculated water with verification that gross beta counts of both
samples are within 10 percent of each other.
Following this, either both
samples or the sample having the greater gross beta count is counted
using a GeLi system to identify and determine the concentration of gamma
emitting nuclides.
For pure beta emitters, including strontium-89 and
90, iron-55 and tritium, concentrations are determined by analysis of
monthly composite proportional samples with all beta analyses but tritium
being performed by a contractor.
The concentration of each gamma emitting nuclide and the available
dilution water flow rate are used in calculating the sum of MPC fractions
for the gamma emitters, the allowable radwaste discharge flow rate and
the setpoint of the monitor (when operable) on the discharge line.
Although the beta emitters are not considered in this determination to
demonstrate that diluted release concentrations meet 10 CFR 20 criteria,
a safety factor of 10 built into the equation, which only takes credit
for 10 percent of the actual dilution water, appears to more than
adequately compensate for the pure beta emitters.
A review by the
inspector of data for the last six batches of liquid radwaste releases
for which beta emitter data was available showed that the sum of MPC
fractions increased a maximum of 30 percent when the beta emitte 3 were
accounted for.
An additional variable safety factor involves dilution
flow.
The circulating water returns to the river via either the north or
south diffuser line.
The volume of water in these lines depends on how
many of the six circulating water pumps (157,000 gpm capacity each) and
how many of the five service water pumps (13,800 gpm capacity each) are
operating.
The south diffuser line into which the radwaste effluent
(70 gpm maximum) is diluted is run at full capacity while the north
diffuser line is throttled to adjust for total flow.
In the dilution
equation only half of total flow is considered as going through the south
diffuser pipe.
Therefore an additional safety factor approaching two is
involved when the flow rate in the north diffuser pipe is minimal.
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Selective review of release records identified no problem with determina-
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tion of release rates and setpoint determination and settings when
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monitors were operable.
For details regarding inoperable radwaste effluent
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and service water monitors and required alternate actions, refer to
Section 5.
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To meet surveillance requirements of Technical Specification 4.8.B.2.a,
the activity of each nuclide is entered into a CECO computer program on a
monthly basis which determines the cumulative dose contributions (in
accordance with the ODCM) for the total body and any organ for the month,
for the calendar quarter to date and for the calendar year to date.
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In 1984, about 73 millicuries of gross beta gamma activity (excluding
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tritium) and about 5.4 curies of tritium was released in liquid effluents
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from both units combined.
There were a total of 25 batch releases from
July 1, 1984 through June 30, 1985.
Since mid-September 1984, the
concentration of all batch releases before dilution has been about twice
MPC.
From these effluent releases, the calculated maximum whole body
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dose and maximum liver dose (most restrictive organ dose) to any
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individual beyond the site boundary were 3.28E-03 mrem and 4.8E-03 mrem
respectively for Unit 1 and 3.28E-03 mrem and 4.8E-03 mrem respectively
for Unit 2.
Reactor coolant sampling and analysis records were reviewed for compli-
ance with chemical and radiochemical criteria contained in Technical
Specifications 3/4.C.1-5.
Test results reviewed for the first six months
of 1985 included conductivity, chloride, dose equivalent iodine-131
activity, and monthly isotopic analysis of reactor coolant samples.
No problems were identified during the review in frequency of performing
monthly isotopic analysis of reactor coolant samples for either unit.
Also, dose equivalent iodine-131 activity remained well within the five
microcurie per gram of water limit during the period for both units with
a maximum concentration of 0.01 uCi/ml for Unit 1 and a maximum
concentration of 0.023 uCi/ml for Unit 2 during the review period.
No problems were identified during the review in either frequency of
testing or compliance with concentrations of either chloride or
conductivity for either reactor unit.
Although remaining well within the
limit (10 umho/cm), the conductivity of Unit 1 coolant started showing a
gradual increase beginning in January indicative of a condenser tube
leak.
The conductivity had increased to about 1.2 umho/cm during reactor
operation when on May 8th, the licensee went into a two day outage,
located and repaired the leak.
Following the repair, the conductivity
returned to the range of about 0.1 umho/cm during reactor operating
conditions.
The chloride concentration remained at or below the detection
level of 0.02 ppm during the condenser tube leak.
The licensee has
recently obtained instrumentation for measuring chloride concentration
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which has greater sensitivity by about a factor of 10.
No violations were identified.
5.
Calibrations and Surveillances of Gaseous and Liquid Process and Effluent
Monitors
The inspector reviewed records for one monitor on the liquid system (the
common radwaste discharge monitor) and six monitors on the gaseous system
(two monitors each, for the reactor building Unit 1 vents and Unit 2, and
the chimney).
Technical Specification Table 4.2-4 (effective with
amendment No. 89 on December 19, 1984) requires calibration of the
monitors described above at 18 month intervals and functional tests at
quarterly intervals.
Before December 19, 1984, calibrations were required
at quarterly intervals and functional tests at monthly intervals for the
monitors described above.
The inspector reviewed calibration records and
selected functional tests for the liquid and gaseous effluent monitors
described above for the period July 1, 1984, to June 30, 1985.
The
review showed proper calibrations and functional tests on a timely basis
for operable monitors.
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The radwaste monitor has been declared inoperable since the RETS
technical specifications became effective (December 19, 1984) owing to
its not meeting the change in required sensitivity.
The service water
monitors were not covered by technical specifications before the RETS
technical specification.became effective.
These monitors were also
declared inoperable at that time due to inability to demonstrate that the
sensitivity requirements can be met.
New side stream monitors with
increased sensitivity for both liquid radwaste and service water effluents
were initially intended to be installed and operational on December 19,
1984, when the RETS technical specifications became effective.
The new
monitors were intended to share certain electronics with other monitors
previously provided by the same vendor.
However, delays for engineering
design modifications ensued when it was learned that the new monitors
were not readily compatible electronically with the older monitors.
At
the time of this inspection the new monitors were partially installed but
not operable.
Licensee personnel stated that the current goal for
operability of these monitors was late August 1985.
Technical Specification 3.2.G.2 requires that actions shown in
Table 3.2-5 be taken when one or more radioactive liquid effluent
monitoring instruments is inoperable.
Action B, for the liquid radwaste
effluent monitor in Table 3.2-5, permits effluent releases to continue
with the monitor inoperable provided that prior to initiating a release,
at least two independent samples are analyzed and at least 2 members of
the staff independently verify release calculations and discharge
valving.
These criteria appear to have been met for all liquid radwaste
batch releases.
Action A, for the service water gross activity monitors, in Table 3.2-5,
permits releases to continue with the monitor inoperable provided that at
least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> grab samples are collected and analyzed for beta
or gamma activity.
The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> grab samples from both Unit 1 and Unit 2
service water, required about 8:00 p.m. on June 13, 1985, were not
collected or analyzed.
This omission was not identified by the normal
supervisory review process even though provision had been made for
recording sample collection times on the Miscellaneous Samples Log as a
result of an observation during an inhouse Quality Assurance Surveillance
as described in Section 9.
Failure to collect and analyze the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />
grab samples from the service water of both Unit 1 and Unit 2 at about
8:00 p.m. on June 13, 1985, while the service water monitors for both
units were inoperable is considered to be a violation of Technical Specification 3.2.G.2 which requires the sampling and analysis pursuant
to Table 3.2-5.
(Violation 254/85021-01; 265/85024-01)
One violation was identified.
6.
Procedures for Controlling Releases
The inspector selectively reviewed revisions to the licensee's liquid and
gaseous radwaste procedures.
No significant problems were identified
during the following procedures review.
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QCP 100-59, Revision 3, Liquid Waste Work Sheet
QCP 100-S13, Revision 3, Calculation of Particulate and Halogen Activities
QCP 100-S14, Revision 2, Tritium Gaseous Release Monthly Calculation
QCP 100-S15, Revision 2, Discharge Record Liquid Radioactive Waste
Surveillance Sheet
QCP 100-S16, Revision 2, Percent of Limit, Main Chimney
QCP 100-521, Revision 1, Radwaste Curie Release
QCP 100-S22, Revision 1, Percent Limit Radwaste Curie Release
QCP 100-530, Revision 1, Noble Gas Releases
QCP 100-S31, Revision 1, Main Chimney Monitor Spikes
QCP 100-S32, Revision 1, Reactor Building CAM Spikes
QCP 400-S1, Revision 2, Main Chimney Particulate Isotopic
QCP 400-S2, Revision 2, Reactor Vent Particulate Isotopic
QCP 400-S4, Revision 1, Strontium-89 and Strontium-90
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QCP 400-S5, Revision 1, Percent Limit by Isotopic Calculation Sheet for
Iodines and Particulates
QCP 400-S6, Revision 1, Gaseous Iodine
QCP 400-S7, Revision 1, Monthly Particulate and Iodine Release Rates
QOP 2000-52, Revision 8, Liquid Radioactive Waste Discharge
No violations were identified.
7.
Changes to Equipment and Procedures
In discussions / reviews of changes made to gaseous or liquid radwaste
systems during the past year, two facility changes were identified which
are both in progress and both involve the liquid radwaste system.
One
modification involves the replacement of the liquid effluent monitor with
a side stream monitor having additional shielding and provision for
decontamination or removal of a spool piece in front of the detector.
In
addition, the monitor is being relocated to a lower radiation background
area, all in the interest cf meeting the sensitivity requirements for the
monitor specified in the new RETS technical specifications which became
effective December 19, 1984.
The other modification involves a similar
replacement (and for similar purposes) of the service water effluent
monitors for both reactor units.
The inspector verified that a
10 CFR 50.59 review / evaluation was performed by the licensee for both of
these facility changes.
No violations were identified.
8.
HEPA Filter and Charcoal Adsorber Systems
One ventilation system has HEPA filters and charcoal adsorbers subject ta
technical specification surveillance requirements.
This system consists
of the two trains (common to both reactor units) of the standby gas
treatment system.
Inplace testing of HEPA filters and charcoal adsorbers
were performed inhouse on a timely basis in December 1984.
Records show
the 00P penetration and the halogenated hydrocarbon penetration to be
less than the one percent criteria for HEPA filters and charcoal adsorbers
respectively.
In addition, a laboratory analysis of a representative
carbon sample (also removed in December 1984) from each train for methyl
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iodide removal has been performed by a contractor with records showing the
removal efficiency to be greater than the 95 percent criterion specified
in Technical Specification 3.7.B.2.
The latter test was performed at the
specified test conditions of 130 C and 95 percent relative humidity.
No violations were identified.
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9.
Audits
The inspector reviewed one Quality Assurance audit conducted by an offsite
group and two Quality Assurance surveillances conducted by inhouse QA
personnel during the past year involving, in part, the gaseous and liquid
radwaste processing and effluent programs.
Offsite Audit 04-84-2, a
technical audit of radiation chemistry, conducted September 11-14, 1984,
reviewed collection / analysis of reactor water samples for required
frequency and proper analysis of monthly proportional composite samples
of each batch of liquid effluent.
No problems were identified in these
areas.
Quality Assurance Surveillance No. QA0 4-85-20, or radioactive waste
records and activities, conducted May 13-17, 1985, identified no findings
in the gaseous or liquid radwaste areas.
Quality Assurance Surveillance No. QA0 4-85-40, of chemistry analyses,
conducted April 29, 1985, noted an observation. During a review to
ensure that the service water effluent is sampled once every twelve hours
as required by Technical Specification Table 3.2-5 Action A when the
monitor is inoperable, it was noted that the Miscellaneous Samples Log
(QCP 1400-S34) did not have a provision for recording sample times on the
log.
Although sample times had in most cases been recorded next to the
dates, for a period of several days, the sample times had not been recorded
such that it could be demonstrated by this log alone that the samples had
been taken on a timely basis (a separate service water boildown sample
" checklist" did provide the times of sample collection on the dates in
question).
In response to the observation, a temporary procedure with a
special column to record sample time on the log was promptly implemented
and a permanent procedure change wv. initiated.
No violations were identified.
10.
Exit Meeting
The inspector met with licensee representatives (denoted in Section 1) at
the conclusion of the inspection on July 12, 1985.
The inspector
discussed the likely information content of the inspection report with
regard to documents or processes reviewed by the inspector during the
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inspection.
The licensee did not identify such documents / processes as
proprietary.
The inspector summarized the scope and findings of the
inspection.
In response to certain items discussed by the inspector, the
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licensee:
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a.
Acknowledged the inspectors suggestion for the need of a more
thorough review prior to publication of the data provided in
semiannual effluent reports owing to identification by the inspector
of several errors (relatively minor) in recent reports.
(Section 3)
b.
Acknowledged the inspectors favorable comments regarding the
licensee's shutdown of Unit 1 in early May,1985, for repair of a
condenser tube leak before the conductivity of the primary coolant
approached technical specification levels.
(Section 4)
c.
Acknowledged the violation for failure to collect and analyze service
water grab samples at the required frequency for both reactor units
when the service water monitors were inoperable and failure to
identify the omission even though provision had recently been made
for recording sample collection times on the sample log.
The
licensee commented that the samples for both units had been missed
only once in the past several months and stated that as an additional
check to assure that the samples would be taken and analyzed as
required, these sample requirements would be added to Chemistry
Section's Technical Specification surveillance sheet.
The inspector
noted the long delay in installing and declaring operational the new
liquid radwaste and service water monitors.
(Sections 5 and 9)
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