IR 05000206/1989026

Insp Repts 50-206/89-26,50-361/89-26 & 50-362/89-26 on 890828-0901.No Violations Noted.Major Areas Inspected:Plant Water Chemistry Control & Chemical Analysis,Radiochemical Analysis & QA of Plant Chemistry Activities

ML20248J065
Person / Time
Site:	San Onofre
Issue date:	09/22/1989
From:	Louis Carson, Tenbrook W, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20248J058	List: IR 05000206/1989026 ML20248J056
References
50-206-89-26, 50-361-89-26, 50-362-89-26, NUDOCS 8910130022
Download: ML20248J065 (11)

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h' - S.' NUCLEAR REGULATORY COMMISSION g, -

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REGION V -

y Report Nos. 50-206/89-26, 50-361/89-26 and 50-364/89-26-

' License Nos. DPR-13, NPF-10, NPF-15

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m Licensee: JSouthern California Edison Compan Facility Nainei . San ;0nofre' Nuclear Generating' Station,i tlnits 1,12, and 3

/ r Inspection-at: San Clemente, California

Inspection Conducted

August 28throughSeptember1l1989z

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Inspected by:- [ M

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, ~W..K. TenBrook .

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I< > ; ' f f f y f, Radiation Specialist- Carson II Radiation Specialist

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, Approved by: fI742/89 F. A. Wenslawski, Chief-

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Date Signed'

Facilities Radiological Protection Section

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. Summary: ,

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Areas Inspecte'd: Routine unannounced inspection of. plant water chemistry'

control and' chemical analysis, radiocheinical analysis, and quality assurance .

"of plant chemistry activitie Inspection procedures 92701, 79701, 84750, and-

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.30703 were.use Results: The' licensee's programs for chemistry analysis were superior a demonstrated by licensee staffing, equipment, and procedures (Section'4).

However, NRC confirmatory chemical measurements exhibited only acceptable

= analytical performance (Section 3). The licensee has effectively used and maintained the condensate polishing demineralizers with minimal chemical excursions due to their operation (Section'4). ' Chemistry control weaknesses were heightened-dissolved oxygen. levels in secondary' cycle water and concomitant.heig'tened n levels of feedwater metals (Section 4). The inspectors identified a personnel safety issue concerning the Unit 1 Post-Accident Sampling System (PASS) laboratory, as it is not classified a Confined Area (Section 5, 6).

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DETAILS Persons Contacted"

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Licensee'

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G. Allen, Health Physics Foreman, Unit 1

• R. Baker, Engineer, Nuclear Licensing

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E. Bennett, Supervisor, Quality Assurance

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R. Butler, Health Physics Technician, Unit 1 N. Castro,' Chemistry Technician, Unit 2/3 J. Davison, Chemistry Foreman, Unit 2/3 R. Hinds, Engineer, Quality Control K. Hodges, Chemistry Technician, Unit 1

• T. Kent, Engineer, Station Technical T. Moore, Technical Administrator

• J. Noyes, Supervisor, Technical Administration

• 0. Peacor, Manager, Station Emergency Preparedness

• P. Penseyres, Station Chemistry Supervisor .

• T. Peterson, Engineer, Station Technical

• R. Plappert, Supervisor, Compliance T. Sarette, Chemistry Technician, Unit 2/3 J. Serianni, Health Physics Technician, Unit'2/3

• D. Werntz, Engineer,.Neclear Licensing V. Woodall, Chemistry Foreman, Unit 1 J. Young, Chemistry Supervisor, Unit 1 USNRC

• C. Townsend, Resident Inspector

'* Denotes attendance at the exit meeting on September 1, 1989, Followup'(92701)

Open Item 50-361/88-14-01 (Closed). This item concerned an inproper radioactive decay correction applied to air sampling media. The chemistry department had implemented a decay correction for air sampling media which accounted for radiological equilibrium during the sampling period. This item is closed Water Chemistry Analysis (79701)

The inspectors evaluated the accuracy of the licensee's water chemistry measurements using independent standards analyzed in the licensee's laboratories during the inspection. The standards incorporated analytes measured by the licensee pursuant to the technical specifications and chemistry control procedures. The standards were diluted by the licensee to test concentrations falling within the instrumental calibration range for each analyte. The analyses were performed in triplicate and the arithmetic mean was compared to the certified standard values. The acceptance criteria are described in the Enclosure. Data for the Unit 1 laboratories is given in Table ____- _ __ a

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. Table 1 Unit 1 Chemistry Standard Analyses

'NRC Values Licensee Values Agreemen Analyte (Undiluted, Diluted) (Undiluted, Diluted) . Ratio Range

Fluoride A 22.5 ppm 11.3 ppb 20. ppm 9.8 ppb 0.89 ;0.82-1.18 (Primary)' B'4 .2 3 .8 0.89 C'8 .4 7 .9 0.94 Chloride A 1 .25 1 .6 0.93 0.88-1.12 (Primary) B 3 .7 4 .7 1.11*

C 7 .3 7 .7 1.04 Chloride A 1 .463 2 .59 1.30** 0.88'1.12

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(Secondary) B 37.3, 0.933 4 .00 1.07 C 76.5- 1.91 8 .05 1.07 Sulphate' A 1 .75 1 .6 0.98 0.85-1.15

.(Primary) B 3 .15 4 .0 1.10 C 7 .0 8 .3 1.11*

Sulphate A 1 .488 2 .56 1.13* 0.85-1.15

.(Secondary) B 3 .958 4 .09 1.14*

C 7 .95 8 .10 1.08 Boron D 1040 -

100 .97* 0.97-1.03 (undiluted) E 3100 -

298 .96**

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491 .98 Iron G 1 .372 1 .37 1.00 0.85-1.15 H 3 .796 3 .75 0.94 I 5 .17 6 .12 0.96 Copper G 2 .400 2 .42 1.05 0.85-1.15 H 4 .806 4 .81 1.01 I 6 .20 6 .-20 1.00 Sodium J .2 ppm .1 ppm 0.90 0.79-1.21 K 1 .12 1 .2 1.04 L 1 .16 1 .2 1.01 Lithium J 1 .394 1 .33 0.84* 0.79-1.21 K 3 .600 2 .55 0.92 L 4 .826 3 .78 0.94 Hydrazine -P 1 .95 ppb 2 .2 ppb 1.03 0.88-1.12 Q 4 .0 5 .1 1.05 R 10 .0 10 .4 1.01 Silica S 5 .8 4 .9 0.85* 0.85-1.15 T 10 . 9 .1 0.91 0 15 . 14 .3 0.95

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Exceeded 2 standard deviations of the grand average of program participant ** Exceeded 3 standard deviations of-the grand average of program

, . participant The licensee's analyses generally' met the agreement criteria set out in the enclosure. Reanalysis of the anion matrix was requested as the licensee had identified a measurement control problem. All other results reflect one initial trial. One chloride; reanalysis in the Unit 1 secondary laboratory did not agree. However,'the analyzed concentration was .very . low, near the lower bound of. the; calibration range, therefore the magnitude of the disagreement was'not considered significant!

Several measurement ratios exceeded two standard deviations of the-L program participant mean. Thesemeasurementswerealsoacceptedby(the inspector given the low test concentrations of the analyte Two boron measurements were significantly biased lo The inspector will followup on this discrepancy by split sampling during'a future inspection

'(50-206/89-26-01).

The intercomparisons with the Unit 2/3 laboratories are given in Table' Table 2 Unit 2/3 Chemistry Standard Analyses NRC Values Licensee Values Agreement ,

Analyte (Undiluted,0iluted) (Undiluted,0iluted) Ratio Range  !

Fluoride A 22.5 ppm 11.3 ppb 20.0 ppm 10.0' ppb 0.89 0.82-1.18 (Primary) B 4 .2 3 .8 0.94 C 8 .4 7 .3 0.95 Ch'oride A 1 .25 2 .0 1.08 0.88-1.12 (Primary) B 3 .7 4 .6 1.11*

C 7 .3 8 .4 1.06 Chloride A 1 .463 2 .51 1.10* 0.88-1.12 (Secondary) B 3 .933 3 .92 0.99 i C 7 .91 8 .09 1.09*

Sulphate A 1 .75 2 .7 1.10 0.85-1.15 (Primary) B 3 .15 4 .6 1.18**

C 7 .0 83.2' 4 .07

. Sulphate A 1 .488 1 .48 0.98 0.85-1.15 (Secondary) B 3 .958 3 .99 1.03 ,

C 7 .95 7 .97 1.01 j Boron D 1040 -

100 .97* 0.97-1.03 I (undiluted) E 3100 -

298 .96** I F 5000 -

495 .99

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s Iron' G 18.6L 0.372 2 .48 1.29**' O.85-1.15-H 3 .796 4 .85 1.07

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I.5 .17- 6 .25- 1.07 Copper' G 2 .'400 '2 .44 1.10 0.85-1.15 H 40.~3 0.806 4 .86 1.07 I 6 ;20 6 .28 1.07 .25 1.03 0.79-1.21

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-a Sodium- J .25~

K 1 .12 1 .25 ,1.06 L 1 .1 .6 3.12 0.99 Lithium J 1 .394 ppm 2 .41 ppm' 1.04- 0.79-1.21 K 3 .600 3 .63 1.05 L 4 .826 4 .82 0.99 o

Hydrazine P 1 .95 ppb 1 .2 ppb 0.93 0.88-1.12'

Q=4 .0: 4 .0 0.96

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R 10 .0 9 .6 0.95 Silica S 5 .8 4 .2 0.93 0.85-1.15'

T 10 . 10 . 0.96 0 15 . 15 .1 0.97

• Exceeded 2 standard deviations of the grand average of program parti.cipant . .

• • Exceeded 3 standard deviations of the grand average of program participant All the Uait 2/3 results were from initial trials. The results from the Unit 2/3 analyses were generally in better agreement than those from Unit 1. Some positive bias was observed in low level ion chromatography for chlorides with respect to the NRC standards. However, one each of the sulphate, iron and boron analyses fell outside the three standard-deviation range. The inspector will followup on these disagreements during a future intercomparison (50-361/89-26-01).

.The licensee's performance in the chemical intercorrparisons was acceptable, but not superior. Biases were noted to be generally consistent between the three Units, and biases were conservative with respect to. safety objective . Water Chemistry Control (84750)

ine inspectors. reviewed the licensee's quality assurance oversight of the station chemistry program. Three audits impacting the chemistry department had been performed since the last inspection:

' Audit Report 015-88, Technical Specification (TS) Audit Report 006-88, Radioactive Effluents Audit Report 004-89, Radioactive Liquid and Gaseous Effluents Audit Report 004-89 generated one Corrective Action Request and four l Problem Review Report Salient issues identified included missed f

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- surveillance intervals for 31 day TS dose determinations, record management prob 1 cms and applicability of Unit 2/3 TS 4.11.2.4.2 to air ejector exhaust treatment systems. ~The scope and depth of the audit program was acceptabl The inspectors reviewed the licensee's Quality Assurance Audit Log and!

Schedule. . This database was effective in tracking' audit activities and corrective action , &

The inspectors examined the licensee's program for chemical analysis quality control and quality assurance, internal'to the chemistry

department, pursuant to procedure 50123-III-0.7, Rev. 8, " Chemistry Quality Control Program." ' The chemistry intracomparison program tested-the proficiency of technicians with unknown standards and replicate samples. . The technician staff had demonstrated a high level of success and' competence in'the intracomparison program, with greater that 98%

success in initial analyse '

The interlaboratory comparison program employed unknown standardt supplied.by a contractor to independently assess _the licensee's analytical accuracy. The program was.run with sufficient frequency to continually assess the licensee's capabilities. However, the licensee's results frequently disagreed with the contractor values. The licensee

,had researched these disagreements, and had concluded that the contractor's lack of' strict controls had resulted in many of the

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discrepancies, and was-currently seeking a new contracto .

The inspectors examined the daily quality control practices and documentation for chemistry analysis at each laboratory. The licensee empluyed fully. independent standards for measurement control. Control charts for both precision and accuracy were maintained. The scope and depth of the daily quality control program was superio The inspectors examined records of chemistry and radiochemistry analyses performed pursuant to TS 4.4.6, TS 4.4.7 and pursuant to the following procedures:

50123-III-1.1.1, Rev. 7, and 50123-III-1.1.23, Rev. 16, "... Chemical Control of Primary Plant and Related Systems."

S0123-III-2.1.1, Rev. 5, and 50123-III-2.1.23, Rev. 7, "... Steam Generator and Condensate /Feedwater Chemistry Control and Sampling Frequencies."

l The following conditions were observed in the Unit I reactor coolant

system (RCS), feedwater (FW) and steam generator blowdown (SG) at full power operation during the month of August,1989:

Analyte Conditions Observed Action Level RCS Chloride 2 - 4 ppb 150 ppb RCS 0xygen <5 ppb 100 ppb RCS Hydrogen Repeatedly <20 cc/kg <25, >50 cc/kg i

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, RCS Activity 0.5-1.5 uCi/gm 100 uCi/gm RCS I-131 E <2.3E-2 uCi/gm 1 uCi/gm FW pH 9.2- <8.8-> FW 0xygen 5 - 10 ppb >10 ppb FW Iron 10 ppb >20 ppb FW Copper 5 - 8 ppb >2 ppb SG pH' <9.6,>1 SG Chloride 6 - 7 ppb >100 ppb SG Sulphat '50 ppb >100 ppb The RCS dissolved hydrogen concentration was generally lower.than desired during this period, indicative of recovery from nitrogen blanketing of the RCS during the most recent outag Feedwater oxygen, metals and sulphate were all elevated. Unit 1 does not possess state-of-the-art condensate demineralized systems to reduce ionic and metal impurities to the levels observed at most pressurized water reactors due to sodium phosphate additio The following conditions were observed at Unit'2 during the month of August, 1989:

Analyte Conditions Observed Action Leve RCS Chloride <5 ppb 150 ppb  :

RCS Fluoride 5 ppb 150 ppb RCS 0xygen <5 ppb 100 ppb RCS Hydrogen 35 - 40 cc/kg <25, >50 cc/kg RCS Activity 5.5 uCi/gm 116 uCi/gm RCS I-131 E <0.1 uCi/gm 1 uCi/gm FW pH <8.8-> Condensate Oxygen 5 ppb >10 ppb FW Iron 10-15 ppb >20 ppb FW Copper 0.3-0.6 ppb >2 ppb SG Chloride 1.5 ppb >20 ppb SG Sulphate 0.1-0.3 ppb >20 ppb SG Sodium <1 ppb >20 ppb The following conditions were observed at Unit 3 during August, 1989:

Analyte Conditions Observed Action Level RCS Chloride <5 ppb 150 ppb RCS Fluoride 5 ppb 150 ppb RCS 0xygen <5 ppb 100 ppb RCS Hydrogen 30 - 35 cc/kg <25, >50 cc/kg RCS Activity 1.7 uCi/gm 200 uCi/gm RCS I-131 E <0.04 uCi/gm 1 uCi/gm FW pH 9. 0 <8.8->9.4

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] Condensate Oxygen 4 - 8 ppb >10 ppb FW Iron 15 ppb >20 ppb l

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FW Copper 0.2-0.4 ppb '>2 ppb SG Chlorid ppb _ . >20 ppb SG Sulphate 0.1-0.2 ppb >20 ppb ]"

SG Sodium . <1 ppb >20 ppb-

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The conditions'atLunits Two and Three were generally within plant norm Steam generator anions and cations were low due to effective operation of

. condensate polishing systems and blowdown demineralizers. One iron spike to 39 ppb was noted at Unit Three, along with slightly elevated condensate oxygen. Water quality at all three Units met TS and.

,; procedural requirement The inspectors reviewed monthly reports of plant chemistry performance and_ interviewed personnel to establish the chemical performance of the plant since the last inspection. The following strengths and weaknesses were noted:

Units Two and Three exhibited good control of ionic impurities in condensate, feedwater and. steam generators. The operation of polishing demineralized systems was highly effective ~in reducing these contaminants. In addition, operation and regeneration of-cleanup systems did not result in significant ingress'of contaminants upon alignment of regenerated demineralizer Each Unit exhibited elevated condensate dissolved oxygen, generally between 5 and 10 ppb. Typical concentrations at other PWRs are below 5 ppb. The licensee had addressed this problem by detection and mitigation of air inleakage and studies of condenser air removal efficiency. The latter studies had resulted in the experimental use of nitrogen sparging in the condenser to interrupt zones of stagnant air and improve the overall air removal efficiency of the condense Prior to the nitrogen sparge, Units 2 and 3 condensate oxygen was in excess of 7 ppb. After the initiation of the sparge in March, 1989, oxygen concentrations decreased below 6 pp Oxygen had since trended to less than 5 ppb, with occassional air inleakage causing:

excursions to the previous levels. Unit 1 condensate oxygen had also been elevated until the identification of a significant leakage path at a condensate pump in October, 1988, with the balance of the year spent in outage Feedwater metals also trended high in each Unit, particularly in Unit 1. Corrosion of system components may be exacerbated by the elevated-oxygen levels, and the concomitant use of high concentrations ~of hydrazine as an oxygen scavenger. Also, the licensee has elected to operate the Unit 2 and 3 secondary systems at pH 9.0 to maximize the effectiveness of polishing demineralized systems, where a pH of 9.2-9.3 would be optimal to reduce corrosio Elevated secondary oxygen concentration continues to be a performance weakness, with possible impacts on feedwater metal concentrations. The

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inspector will followup on the licenses's continuing corrective actions 1 for these conditions (50-361/89-26-02). )

i The inspectoritoured the Units 1, 2 and 3 control rooms and turbine j

' chemistry laboratories to examine.the status.of continuous in-line monitoring instrumentation. In-line monitors and chart recorders listed in procedure 50123-III-2.1.23, Attachment 3, "In-Line Monitors for Secondary System Samples," were operating and in calibration. Monthly

~and weekly scheduled maintenance for the in-line' monitors was performed c and documented, The inventory of in-line instrumentation exceeded that-recommended by the Electric Power Research Institute for control and diagnostic chemistry variable 'The inspector observed that several chart recorders for Unit 2/3 in-line chemistry instrumentation had been caution tagged due to the use of improperly scaled chart papers. In some cases log scale paper was '

substituted for linear scale paper. The responsible technical administrator stated that the control room staff supplied all necessary paper for the monitors, and there were occasions when the paper specifically required was not kept on-hand. The inspector and chemistry '

management discussed the lack of simple consumable items such as chart paper where. chart recorders provided the only continuous record for several' chemistry variables. The licensee stated that steps would be taken to ensure the necessary recorder paper was kept on hand (50-361/89-26-03).

The inspectors examined procedure 50123-III-0.4.4, "... Chemistry Memos,"

to determine the path for corrective actions for out-of-specification chemistr The chemistry memo provided an acceptable means to communicate specific chemistry conditions, current status and corrective

, actions to the Shift Superintendent and chemistry department management as a followup to immediate verbal notificatio The licensee's performance in chemistry quality assurance was considered satisfactory. The instrumental quality control program was superior, but the interlaboratory comparison program needs to gain crediblity amongst the chemistry staff as an effective quality assurance functio Control of process chemistry was adequate to meet safety objectives, but secondary dissolved oxygen and metals were elevate . Plant Tours (84750)

The inspectors conducted periodic tours of radiologically controlled areas. The inspectors observed the following items:

During a tour of the Unit 1 yard area, the inspectors observed a contaminated area berm directing minor leakage from the refueling water storage tank filter pump to a drain. Adjoining the berm was a sign indicating that radioactive liquids should not be disposed in

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the drain. The inspectors inquired as to the purpose for this sign

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when contaminated liquids were being routinely directed to the drain. Consultation with the licensee and NRC staff regarding the yard drain sump indicated that the signs were a precaution against uncontrolled dumping of radioactive material to the yard drains, 1-

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I, which do not-have any radwaste' treatment capability. However, mino leakage from plant equipment is directed to the yard drain sump,'as its contents are sampled and its effluent monitored in accordance=

with the-Safety. Analysis. Report, the TS, and the Offsite Dose Cal.culation Manual. The signs had been installed in response to a yard drain sump overflow incident described in Inspection Report 50-206/89-0 The inspectors also noted the Unit 1 PASS equipment skid, located underground, was posted as a Confined Area, where there exists a potential for an Immediately Dangerous to Life and Health (IDLH)

atmosphere. The PASS laboratory adjoined the PASS skid. The laboratory was located approximately .four meters underground, with a'

large steel door. The inspectors' toured the room and noted that the ventilation was not currently operating and liquid nitrogen supply g lines were connected to the PASS control. panel are The inspectors-inquired as to why the Unit 1 PASS lab was not classified a Confined Area. The Manager, Station Emergency Preparedness, committed to evaluate whether the Unit 1 PASS lab should be classified a Confined Area, and if there are as-build conditions that should be changed, such as implementing continuous I ventilation. Given that the PASS laboratory is an important emergency response facility for radiological safety, the inspectors

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. will followup on this item during a future inspection-(50-206/89-26-02). , Exit Meeting (30703)

-On September 1,;1989, the inspectors met with licensee management to

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discuss the scope and findings of the inspection. The inspectors voiced their concern as to the proper posting of the Unit 1 PASS laboratory area, and obtained a commitment from the licensee management to-investigate the PASS lab condition _ _ _Q

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ENCLOSURE

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Acceptance Criteria for Chemical Measurements

/- The following standard deviations were obtained from triplicate analysis by multip1_e licensees of non-radiological chemistry standards prepared by

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' Brookhaven National. Laboratory for the NRC Staf The licensee value should be considered to be (a) in agreement if it falls within the +/- ,

two standard deviation range, (b) in qualified agreement if it is between the +/- two.and.three standard deviation range, and (c) in disagreement

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if it is outside'the +/- three standard deviation rang '

Analyte Percent Standard Deviation Boron -1.1 %

Chloride 4%

Copper 5%

Fluoride 6%

Hydrazine 4%

' Iron 5%

Silica 5%

Sodium 7%

Lithiusi 7%

Sulphate 5%

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