IR 05000250/1992014

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Insp Repts 50-250/92-14 & 50-251/92-14 on 920601-05.No Violations or Deviations Noted.Major Areas Inspected: Organization of Chemistry Dept & Radwaste Group,Confirmatory Measurements,Plant Water Chemistry & Info Notice 92-34
ML17349A300
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 06/25/1992
From: Robert Carrion, Decker T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17349A299 List:
References
50-250-92-14, 50-251-92-14, IEIN-92-034, IEIN-92-34, NUDOCS 9207140161
Download: ML17349A300 (28)


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UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323

~W ~TIII Report Nos:'0-250/92-14 and 50-251/92-14 Licensee:

,Florida Power and 'Light Company'250 West Flagler Street Miami, FL 33102 Docket Nos.:

50-250 and 50-251 License Nos.:

DPR-31 and DPR-41 Facility Name:

Turkey Point 3 and

Inspection Conducted:

June 1-5, 1992 Xnepector:

<P~~~ ~~~" ~i R.

P.

Car "ion d zs

~ip Date, Signed Accompanied by:

T.

R. Volk and M. T. Janus Approved by:

Z~<CN'

T. R. Decker, Chief Radiological Effluents and Chemistry Section Radiological Protection and

= Emergency Preparedness Branch Division of Radiation Safety and Safeguards Date Signed SUMMARY Scope:

This routine, unannounced inspection was conducted in the areas of organization of the Chemistry Department and Radwaste Group, confirmatory measurements, plant water chemistry, Information Notice 92-34, the Annual Radiological Environmental Operating Report, high particulate loading of ventilation systems, contingencies for. long-term storage of Low Level Radwaste (LLW),

on-site contaminated soil, and radwaste shipping documentation.

Results:

The Chemistry Department and Radwaste Unit were stable and staffed by competent personnel.

(Paragraph 2).

9207140161 920626 PDR ADOCK 05000250 8 'DR

The confirmatory measurements comparison showed good agreement between the results of the licensee and the NRC mobile laboratory.

The licensee had established a good Count Room radiochemical analysis program.

(Paragraph 3).

Plant water chemistry was maintained well within Technical Specification (TS) limits.

(Paragraph 4).

Information Notice 92-34,

"New Exposure Limits For Airborne Uranium and Thorium," was discussed with the licensee.

(Paragraph 5).

The licensee had a good program in place to detect the effects of radiological effluents, direct radiation, etc.

due to plant operations and that those operations had caused minimum impact to the environment and virtually no dose to the general public.

(Paragraph 6).

The licensee had no history of high particulate loadings of its ventilation systems nor special training in place to recognize, evaluate; and/or respond to off-normal airborne releases of particulates.

(Paragraph 7).

The licensee continued to prepare contingencies for long-term storage of low level r'adioactive waste even though the operating license of the current disposal facility had been extended.

(Paragraph 8).

Contaminated soil on the Turkey Point site was well-controlled and posed no risk to either plant personnel or the general public.

'(Paragraph 9).

Radwaste shipping documentation was complete and well-maintained.

(Paragraph 10).

REPORT DETAILS

. Persons Contacted Licensee Employees

  • T. V.

W. M.

  • V. A.
  • J. E.

J.

D.

  • G. M.
  • L. W.

R.

K.

  • R. N.
  • E J,,

Abbatiello, Site Quality Manager Eades, Quality Assurance (QA) Engineer Kaminskas, Operations Superintendent Knorr, Regulation and Compliance Specialist Lindsay, Health Physics (HP) Supervisor Murphy, Operations Supervisor (Acting)

Pearce, Plant General Manager Rowe, Health Physics Engineer Steinke, Chemistry Supervisor Weinkam, Licensing Manager Other licensee employees contacted during this inspection included technicians and administrative personnel.

Nuclear Regulatory Commission

  • G. A. Schnebli, Resident Inspector L. Trocine, Resident Inspector
  • Attende'd exit interview Acronyms and Initialisms used throughout this report are listed in the last paragraph.

Organization (84750)

Technical Specification (TS) 6.2.2 describes the licensee s

onsite facility organization.

The inspector reviewed the licensee s organization, staffing levels, and lines of authority as they related to the Chemistry Department and Radwaste Group to verify that the licensee had not made organizational changes which would adversely affect the ability to control radiation exposures or radioactive material.

The inspector determined that no changes had occurred since the last inspection (92-09) in this area.

The inspector concluded that the organization and staffing levels were satisfactory and met TS requirements.

No violations or deviations were identified.

Confirmatory Measurements (84750)

CFR 20.201(b)

requires the licensee to perform surveys as necessary to evaluate the extent of radiation hazards.

To evaluate the licensee's analytical capability to make

consistently accurate radioactivity measurements, the following samples were analyzed for radionuclide concentrations by the licensee and the NRC Region II mobile laboratory:

reactor coolant system (RCS)

and noble gases (which were collected by the licensee),

an NRC-spiked gas Marinelli flask, an NRC-spiked liquid Marinelli flask, an NRC-spiked particulate filter, and an NRC-spiked charcoal cartridge.

The purpose of these comparative measurements was to verify the licensee's capability to accurately detect and identify gamma-emitting radionuclides and to quantify their concentrations.

The licensee analyzed all of the samples in the Chemistry Count Room, which was equipped with three High Purity Germanium (HPGe)

gamma spectroscopy detectors.

The inspector reviewed calibration curves for two of the detectors (Detectors

¹2 and ¹3) used for the confirmatory measurement exercise.

The calibration curves were developed using Cs-137, Co-57, and Co-60 sources.

The inspector reviewed Certificates of Calibration for the five sources used to generate the referenced calibration curves.

Each source was prepared using an aliquot measured gravimetrically from a master radionuclide solution source which was calibrated using a germanium gamma spectrometer system.

This calibration had been confirmed by the National Institute of Standards and Technology (NIST) in a Measurements Assurance Program as described in NRC Regulatory Guide 4.15, Rev.

1, dated February 1979.

Confirmation was obtained for each gamma ray listed to within the limits stated on the certificate.

Specific geometries included a 500-ml bottle (for the RCS sample),

a 1-liter Marinelli container.(for gas and liquid samples),

a 33-ml glass bulb (for gas samples),

a charcoal cartridge (for iodine and/or other gamma-ray emitters),

and a filter (for airborne particulates).

The inspector concluded that the calibration curves and Certificates of Calibration were current and sufficient.

Daily calibration checks for Detectors

¹2 and ¹3 were reviewed from mid-January to the date of this inspection.

. Detector ¹2 showed no bias.

Detector ¹3 was biased high for the Cs-137 souice, with eight data points outside the upper two-sigma band.

For the Co-57 and Co-60 sources, the detector was biased low but no data points exceeded the two-sigma bands.

The inspector reviewed selected portions of Nuclear Chemistry Procedures NC-50A,

"Sampling of the Plant Vent, Unit 3 Spent Fuel Pit Vent, and Air Ejector Vents for Noble Gas and Tritium," approved on August 22, 1991, O-NCZP-046.4,

"Obtaining a Reactor Coolant Demineralizer Sample,"

approved February 11, 1992, and O-NCZP-061.1,

"Gas Decay Tank Sampling," approved October 24, 1991.

The portions reviewed included sampling instructions and were adequate for the intended purpose.

The inspector observed licensee technicians obtain the reactor coolant sample, the Waste Gas Decay Tank sample, and the Plant Vent Sample and noted that the procedures were followed closely as they completed their duties.

Proper sampling techniques and health physics practices were utilized.

The source of the 'noble gas sample was the Waste Gas Decay Tank "C".

Because the Containment Atmosphere sample contained only one radioisotope and the Plant Vent sample showed no measurable activity, the licensee was given an NRC-spiked gas Marinelli flask to count.

The licensee was also given an NRC-spiked liquid Marinelli container, particulate filter, and charcoal cartridge for analysis.

Attachment 1 provides a comparison of the licensee's results to the NRC's results for each sample.

Attachment 2 provides the criteria for assessing the agreement between the analytical results.

As indicated in Attachment 1, all licensee results compared favorably with the NRC results, indicating that the licensee's analysis system was capable of identifying isotopes over a wide energy spectrum.

From the observations made during this inspection, the inspector concluded that the licensee demonstrated that a good Count Room radiochemical analysis program was in place.

No violations or deviations were identified.

Plant Water Chemistry (84750)

At the beginning of the inspection, Turkey Point Units 3 and 4 were operating at 87 percent and 100 percent power,

- respectively.

Unit 3 was in its twelfth fuel cycle and Unit 4 was in its thirteenth fuel cycle.

Refueling outages were tentatively scheduled to begin August 24, 1992 (Unit 3)

and March 1, 1993 (Unit 4).

The inspector reviewed the plant chemistry controls and operational controls affecting plant water chemistry since the last inspection (92-05) in this area.

TS 3.4.7 specifies that the concentrations of dissolved oxygen (DO), chloride, and fluoride in the Reactor Coolant System (RCS)

be maintained below 0.10 parts per million (ppm),

0.15 ppm, and 0.15 ppm, respectively.

TS 3.4.8 specifies that the specific activity of the primary coolant be limited to less than or equal to 1.0 microcuries/gram (pCi/g) dose equivalent iodine (DEX).

These parameters are related to corrosion resistance and, fuel integrity.

The oxygen parameter is based on maintaining levels sufficiently low to prevent general and localized corrosion.

The chloride and fluoride parameters are based on providing protection from halide stress corrosion.

The activity parameter is based on-minimizing personnel radiation exposure during operation and maintenance.

Pursuant to these requirements, the inspector reviewed tabular daily summaries which correlated reactor power output to chloride, fluoride, and dissolved oxygen concentrations, and DEI of the reactor coolant for the period of April 1, 1992 through May 31; 1992 and determined that all of, the parameters were maintained well below TS limits.

Typical values for DO, chloride, and fluoride were less than one part per billion (ppb), less than three ppb, and less than four. ppb,'espectively, for both units.

Typical DEI values were 1.5E-2 pCi/g for Unit 3 and 9.0E-3 pCi/g for Unit 4, with a maximum of 1.38E-1.

The licensee suspected a pin-hole leak in the Unit 3 fuel earlier in the year.

However, further review of the situation determined that there was none.

No leakers were suspected in Unit 4.

No violations or deviations were identified.

Discussion of Information Notice (IN) 92-34 The inspector discussed-IN 92-34,

"New Exposure Limits For Airborne Uranium and Thorium," with the Chemistry Supervisor to be sure that he and his staff were cognizant of it and its implications.

The IN emphasizes the two changes due to the NRC's adoption of the dose-assessment methodology recommended by the International Commission on Radiation Protection (ICRP)

26 and 30 in the new 10 CFR 20.

These are significant changes in occupational exposure limits and equivalence of internal and external dose and could have great impact on licensees that experience airborne concentrations of uranium and thorium compounds.

Annual Radiological Environmental Operating Report (84750)

TS 6.9.1.3 requires that the Annual Report be submitted prior to May 1 of the following year.

TS 6.9.1.3 also states format and content requirements for the Report.

a

~

1991 Annual Radiological Environmental Operating Report The inspector reviewed the Annual Environmental Operating Report for calendar year 1991 to verify

compliance with the TSs.

The Report had been submitted in compliance with TS 6.9.1.3 on April 28, 1992, and the format and contents were as prescribed by the TS.

There were no changes to the environmental monitoring network during 1991.

The inspector determined that the Report was in compl'iance with the TSs.

The Turkey Point Nuclear Plant Environmental Monitoring Program is designed to detect the effects, if any, of plant operation on environmental radiation levels by monitoring airborne, waterborne, ingestion, and direct radiation pathways in the area surrounding the plant site.

It also supplements the Radiological Effluent Monitoring Program by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and the modeling of the environmental exposure pathways.

Indicator sampling stations are located where detection of the radiological effects of th'e plant's operation would be most likely, where the samples collected should provide a significant indication of potential dose to man, and where an adequate comparison of predicted radiological levels might be made with measured levels.

Control stations are located where radiological levels are not expected to be significantly influenced by plant operation, i.e., at background locations.

An environmental impact assessment of plant operation is made from the radiological measurements of the sampling stations.

Those measurements verified that the dose to members of the public were well within the limits established by 10 CFR 50, Appendix I.

Analytical Comparison of 1990 Report Radiological environmental monitoring for the Turkey Point Plant is conducted by the State of Florida, Department of Health and Rehabilitative Services (DHRS).

Samples are collected and analyzed by DHRS personnel at the DHRS Environmental Radiation Control Laboratory in Orlando, Florida.

I The NRC contracts with RESL to analyze samples split between the State of Florida and the NRC.

The NRC compares the Radiological and Environmental Sciences Laboratory (RESL) results to those of the State of Florida for analysis confirmation.

The inspector compared a random selection of analytical results for gross beta in air particulates at Sample Station T-58 as well as the isotopic analysis for

broadleaf vegetation, specifically the Brazilian Pepper at Sample Station T-40, as reported in the 1990 Annual Report.

After adjusting for the different units used by the different laboratories to report the results, the inspector determined that the, reported results compared favorably with those of RESL.

Typical values for gyoss beta in the air particulates were 0.010 pCi/m and for the broadleaf vegetation 50 pCi/kg (for Cs-137)

and 4600 pCi/kg (for K-40)..

The inspector discussed his findings with the Chemistry Supervisor and concluded that the State of Florida was capable of analyzing environmental samples as required for the Annual Radiological Environmental Operating Report.

The inspector concluded that the licensee had a good program in place to detect the effects of radiological effluents, direct radiation, etc.

due to plant operations and that those operations had caused minimum impact to the environment and virtually no dose to the general public.

No violations or deviations were identified.

The inspector requested information concerning high particulate loading 'in the plant's ventilation systems.

From discussions with cognizant licensee personnel, the inspector determined that two ventilation systems utilized outs'ide air, the Control Room Emergency Ventilation System and the Technical Support Center Emergency Ventilation System.

The inspector reviewed selected portions of procedures O-OSP-301.1,

"Technical Support Center Emergency Ventilation System Filter Performance Test," approved May 24, 1988, and O-OSP-025.2,

"Control Room Emergency Ventilation System Filter Performance Test," approved

.

February 11, 1989 as well as the data of the most recently completed (January, 1991) performance tests for the HEPA filters of the referenced systems.

The pressure differential between the upstream and downstream sides of the filter was less than two inches of water.

(The maximum allowable before action was required to be taken was six inches of water.)

The HEPA filter was not heavily loaded.

The licensee had evaluate, and/or particulates due high particulate no special training in place to recognize, respond to off-normal airborne releases of to the fact that there was no history of loadings at the plant.

No violations or deviations were identifie.

Low Level Radwaste (LLW) Storage (84760)

The inspector requested an update on the contingencies being pursued by the Turkey Point management with respect to LLW long-term on-site storage.

a

~

Disposal Site Status The governor of South Carolina, the South Carolina Budget and Control Board, and the South Carolina Department of Health and Environmental Control recommended keeping the Barnwell disposal facility open to regional and non-regional radwaste generators.'owever, legislative action by the South Carolina General Assembly was required to extend the license and determine under what conditions and cost.

In late May, the General Assembly voted to extend the operating license for the disposal facility until December 31, 1995.

During that period, the next host of the Southeast Compact will prepare a replacement facility.

b.

Status of Turkey Point Contingencies The inspector discussed the status of the plant's long-term LLW storage contingencies and plans, especially how they may have been affected by the extension of the operation permit of the disposal site, with the HP Supervisor and other cognizant licensee personnel.

The licensee planned to continue its efforts to utilize the Dry Storage Warehouse (in which contaminated tools, welding machines, scaffolding, etc.

were stored for possible future use) for the storage of DAW.

The licensee had continued its effort to reduce the volume of material stored there and had surpassed its target to date substantially.

Less than 9600 cubic feet (ft )

of material/equipment remained to be removed/permanent-ly stored (of an originally-estimated 39000 ft ).

The goal was to have about 3500 ft of material/equipment remaining in the Dry Storage Warehouse by the end of the year.

Although great strides in the reduction effort had been made to date, expectations were that the last several thousand cubic feet would be substantially more difficult to complete and would be manpower intensive, requiring more hand sorting.

A safety evaluation about the use of the Dry Storage Warehouse for DAW storage continue The budget for construction of a new Resin Storage Facility had been temporarily frozen.

However, engineering for the facility and planning for its optional use would continue to a point where such plans and designs could be easily resurrected in the future should circumstances warrant such action.

The licensee maintained a high degree of flexibilitywith this approach.

The inspector concluded that the contingencies were appropriate and that the licensee's management was proceeding in a prudent manner.

No violations or deviations were identified.

Gn-Site Contaminated Soil Although a large quantity of contaminated soil was deposited on site, it did not pose a hazard to either site personnel or the general public.

Most of it was attributable to an incident which occurred on August 16, 1988 in which water from the Unit 4 Spent Fuel Pool overflowed to the west side of the, retaining wall located just east of the Auxiliary Building.

Soil in this area had been excavated for disposal and the only soil remaining on site was of low activity.

Isotopic analysis of six samples of the material showed the following typical isotopes and their respective activities (in microcuries per gram (pCi/g) to be):

H-3, 1.2E-S; Co-58, 2.4E-6.

Co-60, 2.1E-3

~ Sr-90, 3.3E-7-and Cs-137, 1.5E-5.

The licensee had been disposing of this material little by little to fillout shipments of LSA material for disposal that were not otherwise full.

The inspector concluded that the issue of contaminated soil on the Turkey Point site was well-controlled and posed no risk to either plant personnel or the general public.

No violations or deviations. were identified.

Radwaste Shipping Documentation (86750)

CFR 71.5 (a) requires that each licensee who transfers licensed material outside of the confines of its plant or other place of use, or who delivers licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation (DOT) in

CFR, Parts 170 through 189.

Pursuant to these requirements, the inspector reviewed the licensee s radwaste shipping documentation, specifically three shipping packages for shipments made since March, 1992

(Nos; 92-18, 92-19, and 92-31) for completeness and compliance with the regulations.

The shipments reviewed included one of limited quantities (shipped non-exclusive use)

and two of Low Specific Activity (LSA) solid metal oxides (shipped exclusive use).

The packages documented the shipments and included items such as unique shipment and shipping container numbers, waste content and volume, total activity, analytical summary and breakdown of isotopes with a half-life greater than five years.

The radiation and contamination survey results were within the limits specified.

The inspector concluded that the licensee's radwaste shipping documentation was complete and well-maintained.

No violations or deviations were identified.

Exit Interview The inspection scope and results were summarized one June 5,

1992, with those persons indicated in Paragraph 1.

The inspector described the areas inspected and discussed the inspection results, including likely informational content of the inspection report with regard to documents and/or processes reviewed during the inspection.

The licensee did not identify any such documents or processes as proprietary.

Dissenting comments were not received from the licensee.

Acronyms and Initialisms CFR - Code of Federal Regulations Ci - curie DAW - Dry Active Waste DEI - Dose Equivalent Iodine DHRS - Department of Health and Rehabilitative Control DO - Dissolved Oxygen

,DOT - Department of Transportation ft - foot (feet)

g - gram HEPA - High Efficiency Particulate Air HP

- Health Physics HPGe

- High Purity. Germanium ICRP

- International Commission on Radiological Protection IN - Information Notice IR - Inspection Report kg - kilogram l - liter LLW - Low Level Radwaste LSA - Low Specific Activity pCi - micro-Curie (1.0E-6 Ci)

m - meter

mCi - milli-Curie (1.0E-3 Ci)'l

- milli-liter NIST - National Institute of Standards and Technology NRC

- Nuclear Regulatory Commission pCi

- pico-Curie (1.0E-12 Ci)

ppb

- parts per billion ppm

- parts per million RCS

- Reactor Coolant System RESL

- Radiological and Environmental Sciences Laboratory Rev - Revision TS

- Technical Specification

ATTACHMENT 1, COMPARISON OF NRC AND TURKEY POINT ANALYTICALRESULTS JUNE 1-5, 1992 Type of Sample: Unit 4 Reactor Coolant System (RCS)

Sample Container:

NRC 500 ml bottle Turkey Point 500 ml bottle (wide-mouth bottle)

Radio-Licensee's nuclide Value Detector ¹1 NRC V~l~u Reso-lution Ratio Compar-ison I-131 I-132 I-133 I-134 I-.135 Cs-138 1.24E-3 1.52E-2 9.91E-3 2.53E-2 1.79E-2 3.01E-2 (1. 15 (1.46 (1. 01 (2.43 (1. 67 (3. 52

+/- 0.13)E-3

+/- 0.07)E-2

+/- 0.05)E-2

+/- 0.10)E-2

+/- 0.07)E-2

+/- 0.30)E-2

21

24

12 1.08 1.04 0.98 1.04 1.07 0.86 Agree Agree Agree Agree Agree Agree Detector ¹2 I-131 I-132 I-133 I-134 I-135 Cs-138 1.11E-3 1.46E-2 9.91E-3 2.34E-2 1.70E-2 2.52E-2 (1. 15 (1. 46 (1.01 (2.43 (1. 67 (3. 52

+/- 0.13)E-3

+/- 0.07)E-2

+/- 0.05)E-2

+/- 0.10)E-2

+/- 0.07)E-2

+/- 0.30)E-2

21

24

12 0.97 1.00 0.98 0.96 1.02 0.72 Agree Agree Agree Agree Agree Agree Detector ¹3 I-131 I-132 I-133 I-134 I-135 CB-138 1.22E-3 1.49E-2 9.68E-3 2.42E-2

'1.68E-2 2.25E-2 (1.15 (1.46 (1.01 (2.43 (1. 67 (3. 52

+/- 0.13)E-3

+/- 0.07)E-2

+/- 0.05)E-2

+/- 0.10)E-2

+/- 0.07)E-2

+/- 0.30)E-2

21

24

12 1.06 1.02 0.96 1.00

'1.00 0.64 Agree Agree Agree Agree Agree Agree

Attachment

Type of Sample:

Radioact ive Liquid (NRC 1000 ml marinelli Spike)

Radio-Licensee's Detector ¹1 NRC Value Reso-Compar-1UtitUI1

~Rt~x

~111 Co-57 Co-60 Y-88 Cd-109 Sn-113 Ce-139 1.18E-2 9.21E-2 8.18E-3 6.90E-1 6.53E-3 4.77E-3 (1.22 (9. 63 (7. 36 (8.99 (6.39 (4.39

+/-

+/-

+/-

+/-

+/-

+/-

0.04)E-2 0.32)E-2 0.66)E-3 0.27) E-1 0.49)E-3 0.22)E-3

30

33

20 0.97 0.96 1.11 0.77 1.02 1.09 Agree Agree Agree Agree Agree Agree Detector ¹2 Co-57 Co-60 Y-88 Cd-109 Sn-113 Ce-139 1.19E-2 9.58E-2 8.02E-3 6.83E-1 6.00E-3 4.55E-3 (1. 22 (9. 63 (7.36 (8.99 (6.39 (4. 39

+/-

+/-

+/-

+/-

+/-

+/-

0.04)E-2 0.32)E-2 0.66)E-3 0.27)E-1 0.49)E-3 0.22)E-3

30

33

20 0.98 0.99 1.09 0.76 0.94 1.04 Agree Agree Agree Agree Agree Agree Detector ¹3 Co-57 Co-60 Y-88 Cd-109 Sn-113 Ce-139 1.16E-2 8.87E-2 8.04E-3 7.14E-1 6.68E-3

'.90E-3 (1. 22 (9. 63 (7.

36'8.99 (6.39 (4.39

+/-

+/-

+/-

+/-

+/-

+/-

0.04)E-2 0.32)E-2 0. 66) E-3 0.27) E-1 0.49)E-3 0.22)E-3

30

33.

20 0.95 0.92 1.09 0.79 1.05 1.12 Agree Agree Agree Agree Agree Agree

~

Attachment

3 Type of Sample:

1.0 liter Gas Marinelli Flask NRC Spike Radio-Licensee's

"I Detector ¹1 NRC Value Reso-lution

~Rati Compar-

~in Co-57 Co-60 Y-88 Cd-109 Sn-113 Cs-'137 Ce-139 2.52E-2 2.00E-1 1.,73E-2 1.47E-O 1.32E-2 2.13E-1 1.05E-2

, (2.52 (1. 89 (1. 59 (1. 77 (1. 22 (2. 03 (8.98

+/- 0.08)E-2

+/- 0.06)E-1

+/- 0.07) E-2

+/-

0'. 05) E-0

+/- 0.07)E-2

+/- 0.08)E-1

+/- 0.44)E-3

1.00

1.06

.

1.09

0.83

1.08

'.05

1.17 Agree Agree Agree Agree Agree Agree Agree.

Detector ¹2 Co-57 Co-60 Y-88 Cd-109 Sn-113 Cs-137 Ce-139 2.52E-2 1.98E-1 1.58E-2 1.49E-O 1.29E-2 2.12E-1 1.05E-2 (2.52 +/-

(1.89 +/-

(1.59 +/-

(1.77 +/-

(1.22 +/-

(2.03 +/-

(8.98 +/-

0.08)E-2 0.06) E-1 0.07) E-2 0.05)E-O 0. 07) E-2 0.08) E-1 0.44) E-3

32

35

25

1. 00 1.05 0.99 0.84 1.06 1.04 1. 17 Agree Agree Agree Agree Agree Agree Agree Detector ¹3 Co-57 Co-60 Y-88 Cd-109 Sn-113 Cs-137 Ce-139 2.55E-2 2.00E-1 1.69E-2.

1.49E-O 1.32E-2 2.14E-1 1.07E-2 (2.52 +/-

(1.89 +/-

(1.59 +/-

(1.77 +/-

(1.22 +/-

(2.03 +/-

(8.98 +/-

0. 08) E-2 0.06) E-1 0.07)E-2 0. 05) E-0 0. 07) E-2 0.08) E-1 0.44)E-3

32

35

25 20-1.01 1.05 1.06 0.84 1.07 1.05 1.19 Agree Agree Agree Agree Agree Agree Agree

Attachment

Type of Sample:

Waste Gas Decay Tank "C" Sample Container:

NRC 25 ml container Turkey Point 33 ml glass bulb Radio-Licensee's NRC V~t~lu Reso-lution

~R~i~p Compar-

~in Detector ¹1 Xe-133 2.13E-3 (1.91 +/- 0.06)E-3

Detector ¹2 1.12 Agree Xe-133 2.14E-3 (1.91 Detector ¹3 Xe-133 2.03E-3 (1.91

+/- 0.06)E-3

+/- 0.06)E-3

1.12 Agree 1.06 Agree Type of Sample:

Particulate Filter (NRC Spike)

Radio-Licensee's nuclide Value Detector ¹1 NRC Value Reso-lution

~Rati Compar-ison Co-57 Co-'60 Sr-85 Y-88 Cd-109 Cs-137 2.49E-3 2.56E-2 6.57E-4 5.15E-3 8.32E-2 2.29E-2 (2. 48 (2.45 (6.30 (5. 19 (9. 75 (2. 35

+/- 0.10)E-3

+/- 0.09)E-2

+/- 0.91) E-4

+/- 0.25)E-3

+/- 0.33)E-2

+/- 0. 11) E-2

27

21

21 1.00 1.04 1.04 0.99 0.85 0.97 Agree Agree Agree Agree Agree Agree Detector ¹2 Co-57 Co-60 Sr-85 Y-88 Cd-109 Cs-137 2.45E-3 2.64E-2 7.09E-4 5.38E-3 8.09E-2 2.26E-2 (2.48 (2.45 (6.30 (5. 19 (9. 75 (2. 35

+/- 0.10)E-3

+/- 0.09)E-2

+/- 0.91) E-4

+/- 0.25)E-3

+/- 0.33)E-2

+/- 0.11)E-2

27

21

21 0.99 1.08 1.13 1.04

'.83 0.96 Agree Agree Agree Agree Agree Agree Detector ¹3 Co-57 Co-60 Sr-85 Y-88 Cd-109 CB-137 2.61E-3 2.68E-2 7.07E-4 5.69E-3 8.57E-2 2.43E-2 (2. 48 (2. 45 (6.30 (5. 19 (9. 75 (2. 35

+/- 0.10)E-3

+/- 0.09)E-2

+/- 0.91)E-4

+/- 0.25)E-3

+/- 0.33)E-2

+/- 0.11)E-2

27

21

21 1.05 1.09 1.12 1.10 0.88 1.03 Agree Agree Agree Agree Agree Agree

Attachment

Type of Sample:

Charcoal Cartridge (NRC spike)

Radio-.

Licensee's Detector ¹1 NRC

~Vl~

Reso-lution

~Rati Compar-

~in Co-57 Co-60 Y-88 Sn-113 Cs-137 Ce-139 5.08E-3 4.04E-2 3.42E-3 2.52E-3 4.22E-2 2.00E-3 (5. 75 (4. 35 (3. 73 (2. 85 (4. 75 (2. 17

+/- 0.20)E-3

+/- 0.15)E-2

+/- 0.37)E-3

+/- 0.31) E-3

+/- 0.21)E-2

+/- 0.10)E-3

29

9

'23

0.88 0.93 0.92 0.88 0.89 0.92 Agree Agree Agree Agree Agree Agree Detector ¹2 Co-57 Co-60 Y-88 Sn-113 Cs-137 Ce-139 Detector ¹3

.26E-3

.20E-2

.50E-3

.66E-3

.43E-2

.11E-3 (5. 75 (4. 35 (3. 73 (2. 85 (4. 75 (2. 17

+/- 0.20)E-3

+/- 0.15)E-2

+/- 0.37)E-3

+/- 0.31)E-3

+/- 0.21)E-2

+/- 0.10)E-3

29

9

22 0.91 0.97 0.94 0.93 0.93 0.97 Agree Agree Agree Agree Agree Agree Co-57 Co-60 Y-88 Sn-113 Cs-137 Ce-139

.52E-3

.27E-2

.68E-3

.96E-3

.63E-2

.24E-3 (5. 75 (4. 35 (3. 73 (2. 85 (4. 75 (2. 17

+/- 0.20) E-3

+/- 0.15)E-2

+/- 0.37)E-3

+/- 0.31) E-3

+/- 0.21) E-2

+/- 0.10)E-3

29

9

22 0.96 0.98 0.99 1.04 0.97 1.03 Agree Agree Agree Agree Agree Agree

e CRITERIA FOR COMPARISONS OF ANALYTICALMEASUREMENTS This attachment provides criteria for the comparison of results of analytical radioactivity measurements.

These criteria are based on empirical relationships which combine prior experience in comparing radioactivity emission, and the accuracy needs of this program.

In these criteria, the

"Comparison Ratio Limits" denoting agreement or disagreement between licensee and NRC results are variable.

This variability is a function of the ratio of the NRC's analytical value relative to its associated statistical and analytical uncertainty, referred to in this program as

"Resolution".

For comparison purposes, a ratio between the licensee's analytical value and the NRC's analytical value is computed for each radionuclide present in a given sample.

The computed ratios are then evaluated for agreement of disagreement bases on

"Resolution."

The corresponding values for "Resolution" and the

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

"Comparison Ratio Limits" are listed in the Table below.

Ratio values which are either above or below the "Comparison Ratio Limits" are considered to be in disagreement, while ratio values within or encompassed by the

"Comparison Ratio Limits" are considered to be in agreement.

TABLE NRC Confirmatory Measurements Acceptance Criteria Resolution vs.Comparison Ratio Limits Re ol ti n Comparison Ratio Limits for A r ement c

4

-

8

-

16

-

51

- 200 200 0.4

- 2.5 0.5

- 2.0 0.6

- 1.66 0.75

- 1.33 0.80

- 1.25 0.85

- 1.18 Comparison Rario

= Li en ee Value NRC Reference Value Resolution

= NRC Reference Valu'e Associated Uncertainty

~

J