ML20137M936
| ML20137M936 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 01/06/1986 |
| From: | Cline W, Stoddart P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20137M906 | List: |
| References | |
| 50-321-85-33, 50-366-85-33, NUDOCS 8601290104 | |
| Download: ML20137M936 (13) | |
See also: IR 05000321/1985033
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETTA STREET, N.W.
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ATLANTA, GEORGI A 30323
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Report Nos.:
50-321/85-33 and 50-366/85-33
Licensee:
Georgia Power Company
P. O. Box 4545
Atlanta, GA 30302
Docket Nos.:
50-321 and 50-366
License Nos.:
Facility Name:
Hatch 1 and 2
Inspection Conducted:
October 28-29, November 18-22, December 10, and
D
ber 16, 1985
Inspector:
,JI/d [
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P. St
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Date
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Approved by:
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- W.'E.'ClineP Seection Chief
'Ofate' 6i gned
Radiological Effluents and Chemistry Section
Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This special, unannounced inspection entailed 41 inspector-hours onsite
in the areas of investigation of an allegation involving the Post Accident
Sampling System (PASS) and plant liquid and gaseous radioactive effluents.
Results:
No violations or deviations were identified.
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8601290104 86012205000321
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REPORT DETAILS
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1.
Persons Contacted
Licensee Employees
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- H. Nix, General Manager
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P. E. Fornel, Site QA Manager
- G. Goode, Plant Engineering Superintendent
- T. Greene, Deputy General Manager
- Z. Wahab, Balance of Plant Engineering Supervisor
- A. Fraser, QA Engineer
- F. Tsakeres, Senior Health Physicist - C,orporate Office
- R. Zavadoski, Manager, Health Physics and Chemistry
- R. Rogers, Health Physics Superintendent
N. Dyar, Security Supervisor
- V. McGowan, Chemistry Supervisor
D. Vaughan, QA Engineer
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S. Ewald, Corporate Health Physicist
R. Ott, Training Supervisor
J. Richardson, PASS Engineer
T. Wells, Acting Balance of Plant Supervisor
C. James, Shift Technical Advisor
C..Stancil, Instrument Shop Supervisor
- M. Bray, Quality Assurance Engineer
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D. Elder, Quality Assurance Engineer
M. Carter, Quality Assurance Engineer
M. Kehoe, Quality Assurance Engineer
- C. Goodman, Acting Regulatory Compliance Supervisor
E. Burkett, Senior Plant Enginear
B. Arnold, Chemistry Lab Supervisor
'
NRC Resident Inspectors
- P. Holmes-Ray, Senior Resident Inspector
- Attended exit interview on October 29, 1985.
- Attended exit interview on November 22, 1985.
- Attended both exit interviews on October 29 and November 22, 1985
2.
Exit Interview
The inspection scope and findings were summarized on October 29, and
November 22, 1985, 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.
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3.
Allegation, Discussion and Findings
On October 18, 1985, Region II received, by mail, an anonymous allegation
concerning operations at the Georgia Power Company's Plant Hatch, located
near Baxley, Georgia.
As of December 16, 1985, no followup letters or
additional allegations had been received and no further contact had been
made by the alleger.
The allegation consisted of a number of statements concerning plant systems
and inferred certain plant system interactions or related effects.
Each of
the several technical aspects of the allegation was investigated in depth
and possible correlations or links were sought between the statements of the
allegation and plant conditions and plant operating records.
The allegation first stated that a " situation" (an apparent shortcoming)
currently existed (approximately October 15, 1985) at Plant Hatch involving
the Post Accident Sampling System (PASS).
It was alleged that the PASS and
three additional, plant systems were involved or in some unspecified way
were related to the " situation" and that the licensee had violated Federal
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Codes and Regulations by failing to file a report.
No specific federal code
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or regulation was cited in the allegation.
On October 28-29, 1985, and again on November 18-22, 1985, a Region II
inspector went to the Plant Hatch site for the purpose of determining the
validity or circumstances of the allegation.
On December 10, 1985, the
inspector went to the Georgia Power Company corporate offices in Atlanta,
Georgia, to review a report of an investigation made by Georgia Power
Company staff of the same allegation, based on a copy of the allegation
received from an unidentified source.
During the November 18-22, 1985 portion of the inspection, the inspector
requested the licensee to supply documentation on the qualifications of
persons known to have installed certain items of safety grade equipment in
the PASS liquid sample lines; this information was received December 16,
1985.
The results of the inspector's findings are described below.
a.
Allegation
"I need to advise you of a situation that presently is existing at the
E. I. Hatch Nuclear plant in Baxley, Ga.
It involves the Post Accident
Sampling System now in use at the plant.
From July 1st thru July 21st,
the plants Radiological waste tanks have been discharged into the
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Altamaha river.
The computer print out showed no variation in the
spectrum of all of those tanks."
Discussion
Processed radioactive liquid wastes containing low level concentr.ations
of radioactive material are routinely discharged from Plant Hatch' to
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the Altamaha River.
Such releases have been routine procedure at Plant
Hatch since plant startLp and are considered as routine practice at
most nuclear power plants.
Radioactive discharges are permitted by the
NRC when they are within the limits in plant Technical Specifications
and conform to the limits of 10 CFR Part 20.
The inspector reviewed plant records for the period of July 1-21, 1985
(the period specified in the allegation), and found no evidence of
increased or unusual liquid discharges and that all releases were in
conformance with Technical Specification requirements.
Gamma radiation spectrum analyses of pre release samples from all
processed liquid radwaste holdup tanks for the period of July 1-21,
1985, were reviewed by the inspector.
The spectra were contained in
119 release procedure packages prepared for the administrative control
of releases and were made prior to release.
Many of the spectra were
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similar in certain respects, as in the recurrence of certain identified
nuclides but in no case were any two spectra identical.
Spectra were
examined for similarity as to (1) identity of radionuclides, (2) energy
value, in MeV, for each peak, (3) height or intensity of each peak, (4)
full width half maximum (FWHM) of each peak, (5) source of input
stream, and (6) age of sample.
Similaritie: in gamma radiation spectra
are to be expected when a reactor is operating normally and has been at
power for an extended period of time.
Differences attributable to
statistical variances, age of sample, and source of material, should be
expected to provide sufficient variation in spectra printouts to assure
that each printout differs in several respects.
Such differences were
observed in the examined spectra and no two spectra were identified as
,
being identical.
!
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The inspector was able to identify a situation which may have been
misunderstood or mistaken by the writer of the allegation.
It was
noted that in the training program which preceded the implementation of
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the Radiological Effluent Technical Specifications (RETS) on July 1,
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1985, the training Lesson Outline required the operator of the RETS
computer program (used to calculate the effects of releases of
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radioactive liquids from the processed radioactive liquid waste tanks)
to " call up" a ore existing radionuclide spectrum from the computer
memory files.
the stored spectrum, which was used to simulate the
analysis of a liquid waste sample containing several typical nuclides,
was employed to shorten the sample counting time to allow more people
to be trained in a given class period.
If a typical routine reactor
coolant sample had been employed, a counting time of one hour or more
could have been required for each sample in order to accumulate
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sufficient data.
Since the identical spectrum would have been printed
out from computer memory each time during training, this may have been
the source of the part of the allegation that the spectra for all
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analyses of liquid radwaste tanks for the period July 1-21, 1985 were
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identical.
As discussed in the preceding paragraph, no basis was found
to substantiate the allegation so far as the record packages for each
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actual release of processed liquid radwaste were concerned.
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The allegation infers that operation of the PASS with the reactor
operating normally would result in release of radioactive material to
the environment or, in this case, to the Altamaha River.
Liquid
drainage resulting from the occasional use of the PASS in training
exercises or periodic checkout is collected in the coolant grade or
high purity waste collection system for cleanup and recycle back to the
reactor water makeup tank or to the reactor coolant system.
Depending
on water inventory, it is occasionally necessary to reduce the reactor
coolant system water inventory by transferring water from the high
purity system to the low purity system, where it is mixed with other
radioactive plant water, treated, and periodically released to the
Altamaha River.
Waste water from the low purity system is filtered,
treated with ion exchange resin beds, or demineralizers for possible
discharge.
When a processed liquid waste holdup tank is filled, it is
mixed thoroughly and then sampled.
The sample is then analyzed for
radioactivity content.
If the analysis shows that the sample meets
administrative criteria for radioactivity content and if a dose
projection based on calculations of the release of the tank contents
shows that Technical Specification guidelines will not be exceeded,
then approval can be made to release the material to the Altamaha
River.
It was noted that the normal sampling point for reactor coolant samples
generates a larger volume of liquid waste than the PASS and is
typically used three times daily, while the PASS is used only
occasionally during required tests and in the training and qualifi-
cation of PASS operators.
Since the same fluid is being sampled in
each case, the normal sampling system would be expected to generate
substantially a larger volume of waste than the PASS.
Records of
analyses of reactor coolant samples for the period July 1-21, 1985
indicated low levels of radioactive materials consistent with a low
incidence of fuel leakage and did not indicate any radioactive release
which could be attributed to operation of the PASS.
Finding
The allegation was not substantiated.
" Radiological" (radioactive)
waste tanks containing processed and analyzed radioactive liquids were
routinely discharged in accordance with NRC regulations and the plant
Technical Specifications.
Nothing was found to be abnormal in the
releases occurring between July 1 and July 21, 1985.
One-hundred and
nineteen (119) waste tank sample analysis gamma spectra were examined,
covering all releases during the specified period, and substantial
variations in the spectra were observed in each instance.
b.
Allegation
"A technician accidentally discovered this was taking place and he
immediately notified his foreman.
An investigation took place and it
was discovered that the PASS System was improperly set up."
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Discussion
The lack of specific detail in the allegation severely limited the
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inspector's investigation.
Names, dates or plant locations which might
have aided in identifying this matter were absent.
The inspector
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discussed the allegation with members of the plant staff and reviewed
plant records and logs but was unable to obtain additional information
as to the existence of either a natification of a foreman by a
technician or the occurrence of an investigation which concluded that
the PASS was improperly set-up.
A NRC contractor performed an operational evaluation of the PASS in
December 1984.
In that evaluation, three items unrelated to the
allegation were identified.
These were: (1) the gas flow rate meter
in the dissolved hydrogen analytical section of the PASS was oversized
and inaccurate for the expected flow and should be replaced with a
smaller capacity flowmeter; (2) the undiluted reactor coolant grab
sample gamma spectroscopy analysis did not meet the required accuracy
guidelines, indicating that a representative sample had not been
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obtained; and (3) an attempt to take an iodine sample using the PASS
grab sample port fittings was unsuccessful.
These items were concerned
with specific components of the PASS system and could not be related to
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the allegation as presented.
To ensure that the PASS was fully operable, the inspector reviewed the
licensee's actions taken to resolve the evaluation items.
Item (1) was
determined to have been the result of an erroneous assumption on the
part of the evaluator in that the flowmeter provided for the dissolved
hydrogen measurement was correctly sized for the value of dissolved ,
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hydrogen specified by the existing criteria.
The nuclear steam supply
system vendor had proposed a smaller value for dissolved hydrogen; the
evaluator was under the impression that the smaller value had been
accepted by NRC.
This was not the case and the larger value remains
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the applicable criterion.
(Closed) Inspector Followup Item (IFI) 321, 366/84-50-01 - Licensee
does not meet accuracy Guidelines for Dissolved Hydrogen Measurements.
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Item based on erroneous assumption.
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Item (2) was concerned with a discrepancy between the analytical
results of a reactor coolant sample taken frca the PASS through a
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manually operated " grab" sample fitting and the results of a routine
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reactor coolant sample taken at the sample station used for reactor
coolant samplS 1 during normal operations.
A licensee representative
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stated that t'a cause of the discrepancy between the samples had been
resolved and that subsequent tests had shown close correlation.
The
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inspector observed as a licensee employee obtained a sample from the
PASS grab sample port, witnessed the preparation of the sample for
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analysis, and reviewed the analysis.
The multiple channel analyzer
printout of the gamma spectrum and the associated computer radionuclide
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identification for the PASS grab sample were compared to the results of
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a normal reactor coolant sample analysis made at approximately the same
time.
Close correlation was seen for the characteristic fission
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product nuclides.
The differences varied from 11.1% for Iodine-133 to
117% for Iodine-134.
Values for the activation product Sodium-24
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varied by 120%.
Since the NUREG-0737 criterion for these measurements
is 1200% (a factor of two), the values obtained were within the
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acceptable range.
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(Closed) IFI 321, 366/84-50-02 - Licensee does not neet all criteria
for backup Liquid Grab Sample.
Re-evaluation showed acceptable
accuracy.
Finding
The allegation was not substantiated.
In the absence of adequate
specific information as to the identity of person or persons involved,
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dates, or plant locations, the inspector was unable to confirm that the
alleged circumstances either occurred or did not occur.
Discussions
with plant staff did not result in additional information.
c.
Allegation
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" ... Rather than bringing in qualified people to install the system
(deletion)
two plant employees who were ... not qualified
,
...
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(were used) to implement the system and it was done completely wrong.
Both employees went to work elsewhere knowing that what they did was
wrong and they didn't want to be around when their mistakes were
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discovered ... "
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Discussion
Since no names were given for the two plant employees alleged to be
involved, and since the inspector was unable to otherwise identify the
two plant employees, the inspector was unable to discuss the allegation
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with the persons concerned.
Plant staff members informed the inspector
that ten or more corporate engineers and 30 or more plant and
contractor employees participated in various aspects of the
installation and checkout of the post accident sampling system (PASS).
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The additional number of architect-engineer, vendor and contractor
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engineers, technicians and craftsmen associated with installation and
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implementation is not known with any certainty.
Seventy-two (72)
Georgia Power Company employees and vendor or contractor employees were
specifically identified from plant records as having participated in
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PASS installation, implementation and operation up to and including
November 1, 1985.
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The principal components of the PASS, specifically all of the PASS
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downstream of the second outboard isolation valves on each RCS sampling
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line, were not required to be designed, constructed or installed to
" safety related" criteria since they are not essential to the safe
operation of the reactor, do not affect the safe shutdown of the
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reactor, and are not required to mitigate the consequences of an
accident.
The licensee requires that persons " qualified" to install or repair
" safety related" equipment must be trained and tested to criteria
established by the licensee to meet the requirements of General Design
Criteria (GDC) 1 of 10 CFR Part 50 and of Appendix 8 to 10 CFR Part 50.
Persons installing or repairing "non-safety grade" equipment must also
be trained and tested to licensee criteria; however, the applicable
criteria are less stringent than those applied to " safety grade"
equipment.
Additionally, craft workers must also meet the minimum
union training and experience requirements to hold union status.
As the allegation was written, the inspector could not ascertain
whether
the alleger was
referring
to
safety-related or
non safety related aspects of the PASS.
If the alleged work was done
on a " safety related" section of the PASS by workers qualified to the
less stringent licensee criteria for non-safety grade work, this could
have led to a violation of GDC 1 and Appendix B,
requirements.
The information provided in the allegation was not
sufficient to support the charge nor was the inspector able to
determine the validity based on records review, examination of
eguipmentanddiscussionwithlicenseerepresentatives.
The writer of the allegation used the terms " install" and " implement"
in apparent reference to the same job or task.
" Install" is usually
taken to mean the physical placement and assembly of a system such as
the PASS, including all activities necessary to get the system ready
for operation.
Such activities included electrical, plumbing,
mechanical and electronic control connections.
" Implement" is usually
taken to mean performing the activities necessary to prepare the
installed system (PASS) for operational use in the plant.
Such
activities included acceptance testing, adjustments, repairs or
modifications of the system necessary to make it operational,
verification of the design functions and capabilities of the system,
preparing operational procedures, the training of operations personnel
in the use of the system and the training of maintenance personnel in
the maintenance of the system.
Discussions with PASS system engineers
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indicated that as many as ten engineers and an estimated 30 to 40 craft
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workers were associated with the installation of the PASS and that as
many as eight engineers and 20 to 25 technicians were associated with
the implementation of the PASS.
Chronologically, the PASS was ordered in September 1980, the first
components were delivered in early 1982, and installation was completed
in June 1983, when hot functional tests initiated the implementation
phase.
Full implementation was completed August 1, 1984, approximately
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one year prior to the period specified in the allegation.
The fourteen months required for full implementation was the result- of: g
series of problems primarily caused by two defective pressure
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reduction valves in the reactor coolant sampling line.
Both of these
valves were nuclear grade, safety related items.
Both failed by
internal leakage, which allowed full reactor coolant pressure to enter
the PASS system instead of performing the design function of reducing
pressure to a maximum of 60 psig.
The resulting overpressure caused
the rupture of several components of the automatic chemical analytical
subsystem.
Substantial delays were entailed in the re-design and
fabrication of the custom-built replacement components.
Minor leaks
also developed in other system valves and components and these were
either repaired or replaced.
The defective nuclear grade valves were
replaced with nuclear grade valves of a different design and
manufacturer.
The replacement values have performed in a satisfactory
manner.
In no instance was any PASS system valve or other component found to
have been improperly installed as the allegation implies.
The writer of the allegation used the term " qualified" without being
specific as to what sense of the term was meant.
There are several
degrees of " qualification" which may be aoplied to the licensee's
evaluation or assessment of an individual with respect to that
individual's training, experience, education and skill or competence in
performing a specific task or craft.
For example, a welder applying
his skills for non nuclear applications would be required to
demonstrate a lesser degree of proficiency or " qualification" in
welding than a welder employed to perform welding on a nuclear grade or
safety-related pipe.
Since the PASS was a new and unique system, there was no " qualified
person" available since no one had previously operated a similar
system; procedures had to be written based on vendor instructions and
test experience; and, no instructor was available to teach system
operation to the implementing personnel.
It was only after the PASS
was installed and available for implementation that training
procedures could be written and formal training provided to qualify
individuals to operate the PASS.
Implementation of the Hatch PASS was
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performed by a number of individuals who had previously demonstrated
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competence in doing similar work.
Each step was performed under a
Quality Assurance Program and was subjected to surveillance.
By
corporate and industry policy and practice the PASS was implemented by
qualified personnel.
In view of the licensee's practices in qualifying
personnel to operate this "first-of-a-kind" system, the alleger's
concern about lack of a " qualified person" cannot be supported.
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As an example of the qualification of personnel to work on ESF systems,
the inspector requested the licensee to provide the qualification
records of the welders who installed replacement PASS liquid sample
line isolation valves in 1984.
On December 16, 1985, the licensee
transmitted copies of the welding qualification records of the six
welders who did the welding which connected the replacement isolation
valves to the PASS liquid sample lines.
The documentation verified
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that the welders had been examined in accordance with the requirements
of Section IX of the ASME (American Society of Mechanical Engineers)
Code.
Finding
The allegation was not substantiated.
More than 70 licensee, vendor
and contractor personnel were involved in the installation and
implementation of the PASS, not two as stated.
No circumstances could
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be identified as having any correlation to the statement that "... it
was done completely wrong."
d.
Allegation
"At present (the allegation was apparently written approximately
October 10, 1985) an outside contractor has been brought in to
straighten out this mess."
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Discussion
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Based on the inspector's discussions with several plant staff engineers
and employees and on review of plant records on the PASS, no "outside
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contractor" had been brought in to work on the system at the
approximate date of the allegation and either prior to or subsequent to
that date.
Licensee representatives stated that during the period of
installation and implementation of the PASS, from early 1982 until
August 1,1984, several representatives of the PASS vendor, two vendor
subcontractors, and the architect engineering firm were at the Hatch
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facility at various times to support the installation of the PASS and
to provide technical assistance during the implementation phase.
It is
possible that some of these persons might be the "outside contractor"
referred to in the allegation; however, the period of time involved,
i.e. ,1982 to 1984, does not coincide with the period specified in the
allegation.
In discussions with licensee representatives and the
various system engineers and from review of the licensee's maintenance
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history files for the PASS, the inspector was not able to identify any
"outside contractor" as having been specifically brought in to resolve
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any problem connected with the PASS other than outlined above.
Finding
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The allegation was not substantiated.
The inspector found no evidence
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of an "outside contractor" having been brought in for any purpose
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having to do with the PASS since the PASS implementation date of
August 1, 1984,
e.
Allegation
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numerous valves
were improperly installed (in the PASS
...
...
system).
Because of this, the off gas readings read incorrectly and no
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one could determine how much radioactive gas was discharged into the
environment."
Discussion
The allegation contains a technical discrepancy in that the "off gas
system" is a separate dedicated system which processes air and
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noncondensible gases extracted from the main condenser and is unrelated
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to the PASS.
The "off gas" system has a limited operating capacity and
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is designed for a nominal input of 30 standard cubic feet per minute of
condenser air inleakage.
Any extraneous air inputs to this system
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would defeat the system's design function of minimizing the release of
short-lived fission product noble gases to the environment.
It is
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extremely unlikely that this was the system to which the alleger meant
to refer.
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It is more likely the alleger meant to refer to one of the building
ventilation exhaust systems.
The PASS system is physically located in
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the area designated as the " hot machine shop" within the Unit 2 reactor
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building.
The PASS area ventilation is vented to the reactor building
ventilation system, which is treated through HEPA filters and charcoal
absorbers prior to release to the en, conment.
Each building vent
release point is continuously monitored by a detector sensitive to
radioactive noble gases which may be present in the exhaust air.
Additionally, continuous samples of airborne particulate material and
airborne iodine are collected for periodic analysis,
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The allegation implies that the "off gas readings read incorrectly" as
a result of improper installation of valves in the PASS.
It should be
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recognized that the improper installation of a valve in the PASS would
likely have no physical effect on the operation of radiation detection
,
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instruments monitoring the releases of radioactive materials in plant
gaseous effluents.
If a valv( were to be installed incorrectly, system
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operation would likely be af fected in such a manner as to be identified
during the system checks and verifications made during system
implementation.
No improper insta'lations were identified.
However, a
defective valve properly installed could and did result in a leak of
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liquid and gas to the PASS area.
In the latter event, however, the level
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of activity in the primary coolant was sufficiently low that the event
was of little consequence from a radiological stand point.
This
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occurred during functional testing beginning in June 1933, and does not
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coincide with the period covered by the allegation.
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During the entire period specified in the allegation, i.e. , " July 1
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through July 21" (presumed to mean July 1-21, 1985), plant logs
indicated that all effluent monitoring instrumentation was functioning
properly.
The inspector noted that the log of gaseous effluent monitor
operation for July 25-26, 1985, showed the Unit 1 post-treatment of f-
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gas noble gas monitor to. be. out-of-service; however, the downstream
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main stack effluent monitor, which serves as a backup, was. operab3etand
show ed 'no increase in effluent activity.
It is possible that'th'ii'may
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have been the monitor referred to in the allegation; however there is
no technical basis for any imputed relation between PASS malfunction
and the outage cf this instrument.
Finding
The allegation was lot substantiated.
The inspector could find no
evidence that an improperly installed valve in the PASS system could in
any manner affect the radiation detection instrumentation of a totally
separate system such as the of f gas system.
Two defective valves had
been part of the original installation but were replaced in 1984, more
than a year prior to the period of time covered by the allegation.
f.
Allegation
"Under the Code of Federal Regulation, the NRC must be notified of any
improper release to the environment . . . no reports (were made) ...
actions violated Federal Codes (and) Regulations."
Discussion
The allegation failed to cite specific instances of either " improper"
or abnormal releases of either liquid or gaseous radioactive effluents.
The inspector reviewed plant records and logs for the specified period
and did not identify any releases exceeding any existing regulations or
Technical Specifications.
In the absence of specific information
concerning such improper releases and in the absence of any information
or records indicating or confirming that such improper releases
actually occurred, the inspector concluded that no regulatory
requirements had been violated.
Finding
The allegation was not substantiated.
Nothing was found in plant
records or in discussions with plant personnel concerning the
allegation to indicate that any regulatory requirements had been
violated or exceeded. The inspector concluded that no reporting
requirement had been violated.
4.
Georgia Power Company Investigation in Response to Allegations
Prior to the inspector's first visit to Plant Hatch (October 28, 1985),
Georgia Power Company had obtained a copy of the allegation from an
unidentified source and had conducted and completed their own investigation
of the allegation.
The inspector reviewed a copy of the Georgia Power
Company investigation report.
The allegation appeared to be a copy of the allegation received at RII and
no differences in appearance, wording, or phrasing were apparent.
The
investigation report of the allegation by Georgia Power Company concluded
that no regulatory requirements were violated.
The licensee's investigation
..
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13
report found that an independent consultant had been hired in early 1985,
for the purpose of adapting a computer program to fit the needs of the Hatch
site relative to the Radiological Effluent Technical Specifications (RETS)
and the calculation of offsite radiation doses resulting from plant
radioactive _ releases.
The subject computer program, however, had no bearing
on or connection with the operation or functioning of the PASS.
The
licensee concluded that it was possible that this individual may have been
the "outside contractor" referred to, if it can be assumed that the alleger
mistook the implementation of the Radiological Effluent Technical
Specifications (RETS) for the implementation of the PASS.
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