IR 05000259/1992010
| ML18036A688 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/23/1992 |
| From: | Gloerson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18036A687 | List: |
| References | |
| 50-259-92-10, 50-260-92-10, 50-296-92-10, NUDOCS 9205120132 | |
| Download: ML18036A688 (36) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 APR g8 I982" Report Nos.:
50-259/92-10, 50-260/92-10, and 50-296/92-10 Licensee:
Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.:
50-259, 50-260, and 50-296 License Nos.:
DPR-33, DPR-52, and DPR-68 Facility Name:
Browns Ferry 1, 2, and
Inspection C nd ct
March 16-20 and -April 14, 1992 Inspector.
at Signed en y ~sire Date Signed
/
/
Approved by:
l4>r'~Zd'.
R. Decker, Chief Radiological Effluents and Chemistry Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, announced inspection was conducted in the areas of audits, confirmatory measurements with the RII Mobile Laboratory, radiological effluents, offsite dose commitments and the status of previously identified inspection findings.
Results:
The confirmatory measurement results for gamma emitters were reviewed, and, in general, the licensee results were in agreement with the NRC results 91% of the time (Paragraph 8).
The few disagreements which did occur could be attributed to photopeak and background interference and differences between the NRC's and licensee's software for gamma ray spectroscopy.
During the Semiannual Radiological Effluent Report period for July 1 through December 31, 1991 there was no airborne or liquid radiological effluent instrumentation inoperable for periods greater than 30 days.
The area of effluent monitor operability improved in that during the last half of.1990, the Semiannual 9205120132 920428 PDR ADOCK 05000259
0
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Radiological Effluent Report documented a large number of effluent instrumentation inoperable for greater than 30 days due to plant modifications.
The majority of the plant modifications had been completed, and during the first half of 1991, only three HR service water monitors were inoperable for greater than
days
~
The licensee's audits and activities in the areas of radioactive waste treatment, effluent, and environmental monitoring were technically sound, thorough, detailed and well documented.
The licensee effectively controlled, quantified, and monitored releases of radioactive materials in liquid, gaseous, and particulate forms to the environment; and maintained and operated radioactive waste treatment systems to keep offsite doses as low as reasonably achievable (ALUM).
REPORT DETAILS 1.
Persons Contacted Licensee Employees
- S. Armstrong, Chemistry Technical Support Supervisor
- S. Austin, Compliance Engineer
- M. Bajestani, Technical Support Manager R. Baron, Licensing Manager J. Black, Process Control Chemist S.
Bugg, Radwaste Manager
- J. Cory, Radiation Protection Manager
- B. Eiford-Lee, Senior Chemistry Specialist (Corporate)
J.
Johnson, System Engineer (Radiation Monitoring)
R. Johnson, Senior Instrument and Mechanical Foreman
- D. Nix, Chemist
- J. Sabados, Chemistry and Environmental Manager
- P. Salas, Compliance Manager
- J. Scalice, Plant Manager
- K. Schaus, Monitoring Manager, Quality Assurance R. Shireman, Chemist J. Wallace, Compliance Engineer, Licensing K. Wastrack, Meteorologist
- O. Zeringue, Vice President 2.
Nuclear Regulatory Commission
- W. Bearden, Resident Inspector
- E. Christnot, Resident Inspector
- C. Patterson, Senior Resident Inspector
- Attended exit interview on March 20, 1992 Licensee Action on Previous Inspection Findings (92701)
a
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(Closed)
Unresolved Item (URI) 50-259, 50-260, 50-296/91-01-01:
Adequacy of Constant Air Monitor Sampling for Radionuclides in Building Exhausts at Browns Ferry Nuclear Plant Unit 2.
Following the issuance of Inspection Report Nos.:
50-259, 50-260, and 50-'296/91-01, NRC/RII requested technical assistance from NRC/NRR in a letter dated March 14, 1991 to evaluate the adequacy of the continuous air monitor (CAM) sampling system for the reactor, refuel floor, and turbine building ventilation systems.
The evaluation was performed by the Radiation Protection Branch in the Division of Radiation Protection and Emergency Preparedness with the assistance of Battelle Pacific Northwest Laboratories (see Attachment 3).
The concerns identified in the request were whether the configuration of the sampling lines were such that significant line losses would
occur and whether the problem was plant specific or generic to the particular monitoring system.
The NRC has concluded that the air sample transport tubes installed by the licensee and furnished by the CAM vendor would appear to be adequate if one accepts the propositions that particle sizes under present sampler operating conditions will remain no larger than two microns.
However, if the airborne particles include substantial mass on particles larger than three microns, then the.sample transport tubing would significantly hinder sample delivery.
The licensee stated that attempts to collect particle size data have been unsuccessful due'to the low levels of activity in these ventilation areas.
Thus, the licensee's particle size assumption seemed plausible for the present, but circumstances such as poor fuel could cause this assumption to be invalidated.
The NRC also determined that the sample probe locations were not in accordance with the recommendations of ANSI N13.1, but were about as good as available with the existing ductwork.
The licensee did not possess particle concentration mapping data in the sampled cross sections of the ducts to justify the use of a single nozzle probe instead of a multi-port sampling nozzle across the duct cross-section.
In general, the probes were located too near a change in the direction of flow.
Should the contaminant come from one of the feeder ducts of the particular ventilation system, it may not be well mixed with the bulk air flow by the time it reaches the sampling nozzle plane.
Through discussions with the licensee, the inspector determined that the licensee had purchased isokinetic sampling probes so that the Pitot tubes presently in the ductwork could be replaced by air flow velocity probes.
The licensee indicated to NRC/NRR during a teleconference on April 22, 1991 that the isokinetic process sampling probes would be installed during the cycle 6 refueling outage.
However, during the inspection and in a teleconference on April 14, 1992, the licensee indicated that the installation of the isokinetic process sampling probes was not planned for the outage noted above.
The inspector indicated to the licensee that an evaluation should be performed demonstrating that offsite releases would not be underestimated by using the existing duct flow measuring equipment.
In addition, the licensee was not planning to replace the single nozzle on the particle delivery lines with a multiport sampling nozzl Particle penetration data on the piping associated with the CAM piping was not provided by the vendor.
However, since the licensee has modified the piping and utilized a variety of piping fittings and pipe sizes, this information would not be relevant anyway.
The NRC has concluded that the variety of pipe sizes and fittings utilized did not enhance particle penetration to the CAM.
In summary, the adequacy of the CAMs for the three ventilation systems noted above was due more to the assumption of particle size than any other reason.
It was not due to thoughtful designing or implementing practices.
In addition, if the license'e determines or suspects that the particle size of the radioactive material associated with the above men-tioned ventilation systems may have changed, a new assessment to demonstrate that significant sampling line losses will not occur should be performed.
The NRC also determined that this identified problem was plant specific.
This unresolved item is considered closed.
In summary, an evaluation of not using the recently purchased isokinetic sampling equipment for more accurate air flow measurements versus the continued use of the existing equipment using Pitot tubes will be tracked by the NRC as an inspector followup item (IFI: 50-260/92-10-01).
(Closed)
Inspector Followup Item (IFI) 50-260/91-28-01:
Evaluate the PASS for Containment Atmosphere Sampling and Analysis.
During the inspection documented in Inspection Report No.: 50-260/91-28, the licensee was unable to evaluate a containment atmosphere'ample since the containment atmosphere had insufficient activity to make a valid comparison between the normal containment sampling system and the post accident sampling system (PASS).
The inspector reviewed the licensee's response in an internal memo dated January 22, 1992, discussing the comparison of two PASS drywell atmosphere samples with one normal drywell atmosphere sample taken after the Unit 2 plant experienced a
- 4 gpm reactor coolant leak on October 10, 1991.
The results were as follows:
Isotopic Results for, Unit 2 Drywell
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R dionuclide (1) Xe-133 Xe-135 (2) Xe-133 Xe-135 3.26 E-6 2.53 E-6 N.D.
2.35 E-6
%Error 19.
1%'2.
7%'.4%'.47 E-6 2. 17 E-6 1.47 E-6 2.17 E-6
%Error 9.
5%'.3%
9.
5%'.3%'atio 2.22 1.17 N.A.
1.08 In both cases, Xe-135 concentrations compared within a factor of two; however Xe-133 concentrations were not in as close agreement.
In one PASS sample the Xe-133 ratio was 2.22 while Xe-133 was not detected in the other.
The reason for that data spread was attributed to poorer counting statistics in the analysis of the PASS sample geometry.
The PASS sample is normally collected and counted in an off-gas vial.
This geometry was designed to be utilized when significant activity exists.
The small sample volume makes reproducibility difficult at low activity levels.
Based on the material reviewed above, this item is considered closed.
Audits (84750)
Technical Specification (TS) 6.5.2.8 requires that audits of unit activities be performed under the cognizance of the Nuclear Safety Review Board (NSRB) in the following areas:
(1) the radiological environmental monitoring program and the results thereof at least once per 12 months; (2) the OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months; (3) the PROCESS CONTROL PROGRAM and implementing procedures for SOLIDIFICATION of wet radioactive wastes at least once per 24 months; (4) the performance of activities required by the Quality Assurance Program to meet the criteria of Regulatory Guide 4.15, December 1977 or Regulatory Guide 1.21, Rev.
1, 1974, at least once per 12 months; and (5) the Radiological Effluent Manual and implementing procedures at least once per
months.
The inspector reviewed the following audit reports:
Nuclear Quality Audit and Evaluation (NQAKE)
- Audit Report of Radiological Environmental and Effluent Monitoring - Audit Report No. SSA90103, January 18, 1990 Browns Ferry Nuclear Plant-Nuclear Quality Assurance-Radiological Environmental and Effluent Monitoring Audit-BFA91201, December 10, 1991
e The above audits 'assessed the adequacy and effectiveness of the radiological effluent monitoring program, radiological environmental program, the Offsite Dose Calculation Manual (ODCM), and the Radiological Effluent Manual (REM).
The audits covered the areas specified in TS 6.5.2.8.
In general, the audits were thorough, detailed, and well documented.
The audits identified some program weaknesses and licensee management made adequate commitments to correct the few deficiencies identified.
No violations or deviations were identified.
~
Changes to the ODCM, PCP, and Radwaste System Design and Operation (84750)
The inspector and the licensee discussed any changes in the radwaste and radiological environmental monitoring organizations; in the ODCM and PCP; and in the radwaste system design and operations since the last inspection.
Other than reductions in force in the chemistry and environmental organization, there were no other significant organizational changes in, the areas noted above since the last inspection.
There were no major changes to the methodologies of the ODCM or PCP during the period from January
- December 31, 1991.
The inspector did not note any changes to the radwaste system design and operations that would require a 10 CFR 50.59 review since the last inspection.
The inspector noted that the Radiological Effluent Technical Specification (RETS) Manual contained three documents:
the Radiological Effluent Manual (REM); the ODCM; and the PCP.
All three documents were referenced by the Radiological Effluent Technical Specifications which were issued on February 5,
1987 as Technical Specification Amendments Nos.
132, 128, and 103 to Units 1, 2, and 3, respectively.
The REM and ODCM were approved by the NRC when the RETS were issued.
The REM is an NRC controlled document, while the ODCM and the PCP are licensee controlled documents.
II'o violations or deviations were identified.
5.
Process and Effluent Radiation Monitors (84750)
Browns Ferry Nuclear Plant ODCM Revision 10, Sections 1/2.1.1 and 1/2.1.2 describe the controls and surveillance requirements for radioactive liquid effluent and gaseous effluent monitoring instrumentation, respectivel The inspector reviewed the calibration procedures and records for the liquid radwaste monitor, the wide range gaseous effluent monitor, and the Reactor Building Vent exhaust monitor.
The following procedures were included in this review:
O-SI-4.2.D.1,
"Liquid Radwaste Monitor Calibration and Functional Test," Revision 7, October 10, 1991 O-SI-4.2.F-25(A),
"Wide Range Gaseous Effluent Radiation Monitoring System (WRGERMS) Normal Range Noble Gas Calibration,"- Revision 2, November 18, 1991 O-SI-4.2.F-25(B),
"Wide Range Gaseous Effluent'adiation Monitoring System (WRGERMS) Mid and High Range Noble Gas Calibration," Revision 2, November 1,
1991 O-SI-4.2.F-27(A),
"Wide Range Gaseous Effluent Radiation Monitoring System (WRGERMS) Normal Range Flow Loop Calibration," Revision 2, November 8,
1991 O-SI-4.2.F-27(B),
"Wide Range Gaseous Effluent Radiation Monitoring System (WRGERMS) Mid and High Range Flow Calibration and Functional Test," Revision 2,
November 8,
1991 2-SI-4.2.K.2.a,
"Reactor Building Ventilation Exhaust Radiation Monitor Source Calibration and Functional Test, 2-RM-90-250," Revision 4, July 29, 1991 2-SI-4.2.K.2.d,
"Reactor Building Ventilation Exhaust Radiation Monitor Sample Flow Calibration and Functional Test 2-RM-90-250," Revision 3, August 2, 1991 The inspector reviewed the calibration records of the monitoring systems noted above and determined that the monitoring systems had been calibrated in accordance with the applicable procedures and within the frequencies prescribed by the ODCM.
The inspector did not note any chronic operability problems with the radiation monitoring systems noted above.
No violations or deviations were identified.
Dose Commitments (84750)
Browns Ferry Nuclear Plant ODCM, Revision 10, Section 8.0, specifies the method to calculate the annual maximum individual total dose from radioactive effluents and all other nearby uranium fuel cycle sources.
Sections 6.6 and
0'
7.7 specify the quarterly dose calculations for liquid effluent and gaseous effluents, respectively.
The inspector reviewed with a licensee representative the quarterly and yearly dose commitments to a member of the public from radioactive materials in gaseous and liquid effluents released during 1991.
The dose commitments for 1991 were summarized in the July through December 1991 Semiannual Radioactive Effluent Release Report=.
The NRC PC-DOSE computer code was used during this inspection to verify the licensee's calculation for the dose contribution to the maximum exposed individual from the radionuclides in liquid effluents released to unrestricted areas for the third quarter 1991.
There were no significant differences between the NRC results and licensee results for the pathway and calendar quarter noted above.
The inspector did review the licensee's methodologies for calculating the various individual doses and observed no apparent problems.
For the monthly gaseous effluent dose calculations, the licensee uses the worst case, historical meteorological data for operational control purposes.
The quarterly dose calculations due to gaseous effluents were based on actual meteorological conditions, real pathways, and receptor locations which were identified in the last land use survey.
The following table summarizes the cumulative doses from effluents for calendar year 1991:
Cumulative Doses from Effluents
- Calendar Year 1 91 Browns Fer N cl ar Plant Dose Pathwa Dose Annual Limit Percent of Annual Limit Airborne-Gamma Air Dose Airborne-Beta Air Dose Airborne-Max Organ Dose Liquid-Total Body Dose Liquid-Max Organ Dose Total Dose-Thyroid Total Dose-Total Body
'rgan other than Thyroid 1.1E-02 1.88-02 1.6E-01 S.OE-02 1.28-01 1.5E-01 mrad mrad mrem mrem mrem mrem 10 mrad 20 mrad 15 mrem 3 mrem 10 mrem 75 mrem 3.7E-01 mrem 25 mrem 1.5
As can be seen from the data presented above, the annual dose contributions to the maximum exposed individual from the radionuclides in liquid and gaseous effluent released to unrestricted areas were well below the limits specified in the ODCM.
These data support the conclusion that the
licensee's effluent releases were as low as reasonably achievable (ALAE&) and that the radwaste systems were both fully utilized and/or operating within the design criteria.
No violations or deviations-were identified.
Meteorological Monitoring Program (84750)
The inspector verified by direct observation and record review that the licensee's meteorological instrumentation was operable and maintained as delineated in Regulatory Guide 1.23,
"Onsite Meteorological Programs,"
and that the onsite meteorological measurement program was effectively implemented.
The licensee's meteorological monitoring equipment consisted of a 91 meter (m) primary tower with three 'sensing stations located at
m',
46 m, and 91 m.
Each sensing station had instruments for measuring horizontal wind speed, dew point, wind direction, and temperature.
1991 data indicated that the meteorological monitoring instrumentation had a reliability factor ranging from 95-99%.
The inspector verified that the sensing equipment had been calibrated at least once per six months in 1991.
The last calibration was performed in February 1992.
The instrument sensors are normally exchanged and sent to the licensee s Knoxville, TN office for calibration.
In 1991, the licensee upgraded the data recording devices and purchased two Yokogawa HR 2300 hybrid chart recorders.
No violations or deviations were identified.
Confirmatory Measurements (84750)
CFR 20.201(a)
defines a "survey" as an evaluation of the radiation hazards incident to the production, use, release, disposal or presence of radioactive materials or other sources of radiation under a specific set of conditions.
CFR 20.201(b)
requires that each licensee shall make or cause to be made such surveys as:
(1)
may be necessary for the licensee to comply with the regulations and, (2) are reasonable under the circumstances to evaluate the extent of radioactive hazards that may be present.
During this inspection, samples of reactor coolant, waste gas, and liquid waste were collected and the resultant sample matrices were analyzed for radionuclide concentrations using the gamma-ray spectroscopy systems of the licensee's counting laboratories and the NRC RII mobile laboratory.
The purpose of these comparative measurements was to verify the licensee's capability to measure quantities of radionuclides accurately in the various plant process and waste streams.
Analyses were conducted using
the licensee's four gamma spectroscopy systems located in the radiochemistry count room.
Two of these detectors (detector numbers 3 and 4) were designated to count in-plant health physics samples.
Sample types and counting geometries included the following:
(1) reactor coolant-20cc vial; (2) liquid waste monitor tank-one liter Marinelli container; and (3) pre-filter offgas-one liter Marinelli container and a charcoal cartridge.
A spiked particulate filter was provided to the licensee for analysis in addition to the licensee's samples.
A comparison of the licensee and NRC results is listed in Attachment 1, Tables 1 through 5, with NRC acceptance criteria listed in Attachment 2.
In general, the licensee results were in agreement with the NRC results 91% of the time.
The results showed agreement for the charcoal cartridge, particulate filter, and one liter gas Marinelli geometries (see Tables 3 through 5).
Comparisons of reactor coolant sample results (see Table 1)
showed disagreements in all four detectors for two radionuclides (I-134 and Mn-54)
and one additional radionuclide (Y-91m) in detectors 3 and 4.
The disagreements were primarily due to a combination of interference problems due to high sample background and software differences between the NRC and licensee.
Normally, the licensee waits for several hours from the time of reactor coolant collection to analysis to minimize the background effects.
In, the case noted above, only two hours had elapsed between sample collection and analysis.
The licensee was considering an upgrade of the current software which would provide algorithms for spectrum stripping for enhanced interference resolving capabilities to better handle nuclide quantification.
Comparisons of liquid radwaste sample results (see Table 2)
showed disagreements in detectors 3 and 4 for one radionuclide (Cs-134).
The licensee noted that the photopeak widths were wider in detectors 3 and 4 thus contributing to the differences in the Cs-134 quantifications when compared to detectors 1 and 2.
In all four detectors, the licensee results were greater than the NRC results.
The licensee agreed to evaluate and determine the differences.
The inspector observed the collection of the reactor coolant sample.
The inspector noted that approved procedures were being utilized for sample collection and that the technician was knowledgeable of the sample collection process.
In addition, the inspector reviewed several quality control (QC), quality assurance (QA), and calibration procedures for gamma-ray spectroscopy equipment; calibration records; and quality control data.
The following procedures were reviewed:
CI-1100, Quality Assurance for Radiochemical Monitoring Program, Revision 12, June 17, 1991 CI-1101, Quality Assurance/Quality Control, Revision 14, August 21, 1991 CI-1102, Quality Control Samples, Revision 7, August 21, 1991 CI-303.15, Efficiency Calibration (Gamma-Ray Spectroscopy System),
Revision 5, June 11, 1991 CI-303. 16, Preparation of Gamma-Ray Standards (Gamma-Ray Spectroscopy System),
Revision 3, June 27, 1991 In general, the procedures were well written and readily available for counting room analysts; and the inspector had no specific questions or concerns with the procedures noted above.
The inspector also reviewed QA/QC data for the four intrinsic germanium detectors, including daily energy calibrations and full width at half maximum (FWHM) checks; and monthly background checks (10,000 second counting time)
and lower limit of detection (LLD) verifications for seven geometries.
In addition, the inspector reviewed the annual efficiency determinations for the four.detectors which were performed during the period from July 1991 to November 1991.
Where applicable, the QA/QC data were plotted daily and trended by laboratory personnel.
Acceptance criteria were established at +/- 2o'nd 3o'.
The inspector noted that the data were readily available for review, well maintained, and organized.
In general, the laboratory was well organized and personnel were knowledgeable of their specific duties and theoretical principals involving gamma ray spectroscopy.
No violations or deviations were identified.
Exit Meeting The inspector met with licensee representatives indicated in Paragraph 1 at the conclusion of the inspection on March 20, 1992.
The inspector summarized the scope and findings of the inspection, including previously defined inspection findings and the inspector followup item.
During a teleconference on April 14, 1992 with the licensee, the inspector further clarified the IFI.
The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection.
The licensee did not
identify any proprietary documents or processes during this inspection.
Dissenting comments were not received from the licensee.
It m Number 50-260/92-10-01 Cate o
Descri tion and Reference IFI - Evaluate not using of the recently purchased isokinetic sampling equipment for more accurate air flow measurements versus the continued use of the existing equipment using Pitot tubes (Paragraph 2.a.).
ATTAC TABLE
Reactor Coolant Sample:
Detector gl Browns Ferry Nuclear Plant:
March 16
- 20, 1992 ISO-TOPE CONCENTRATION (UCI/UNIT)
LICENSEE NRC ERROR RESO-LUTION RATIO (LICENSEE/NRC)
COMPARISON Co-58 Co-60 Cr-51 I-132 I-133 I-134 I-135 Mn-54 Sr-91 Sr-92 Tc-99M Y-91M Zn-65 2.13e-04 2.20e-04 2.96e-03 2.24e-03 8.07e-04 8.21e-03 2.21e-03 2.33e-04 9.14e-04 2.83e-03 1.58e-02 1.87e-03 4.70e-04 2.59e-04 2.09e-04 2.33e-03 2.36e-'03 7.62e-04 3.72e-02 2.09e-03 9.85e-05 8.35e-04 2.61e-03 1.56e-02 2.48e-03 4.75e-04 2.41e-05 2.40e-05 3.27e-04 1.16e-04 6.41e-05 1.24e-03 1.32e-04 1.93e-05 7.71e-05 1.08e-04 5.16e-04 2.71e-04 5.40e-05
9
20
30
5
24
9
0.82 1.05 1.27 0.95 1.06 0.22 1.06 2.37 1.09 1.08 1.01 0.75 0.99 Agreement Agreement Agreement Agreement Agreement Disagreement Agreement Disagreement Agreement Agreement Agreement Agreement Agreement Reactor Coolant Sample:
Detector g2 Browns Ferry Nuclear Plant:
March 16
- 20, 1992 ISO-TOPE CONCENTRATION (UCI/UNIT)
LICENSEE NRC ERROR RESO-LUTION RATIO (LICENSEE/NRC)
COMPARISON Co-58 Co-60 Cr-51 I-132 I-133 I-134 I-135 Mn-54 Sr-91 Sr-92 Tc-99M Y-91M Zn-65 2.65e-04 2.15e-04 2.98e-03 2.38e-03 8.18e-04 8.68e-03 2.22e-03 2.46e-04 8.41e-04 2.91e-03 1.52e-02 3.37e-03 5.12e-04 2.59e-04 2.09e-04 2.33e-03 2.36e-03 7.62e-04 3.72e-02 2.09e-03 9.85e-05 8.35e-04 2.61e-03 1.56e-02 2.48e-03 4.75e-04 2.41e-05 2.40e-05 3.27e-04 1.16e-04 6.41e-05 1.24e-03 1.32e-04 1.93e-05 7.71e-05 1.08e-04 5.16e-04 2.71e-04 5.40e-05
9
20
.
16
11
30
9 1.02 1.03 1.28 1.01 1.07 0.23 1.06 2.49 1.01 1.11 0.97 1.36 1.08 Agreement Agreement Agreement Agreement Agreement Disagreement Agreement Disagreement Agreement Agreement Agreement Agreement Agreement
TABLE
ontinued
'eactor Coolant Sample: Detector N3 Browns Ferry Nuclear Plant:
March 16
- 20, 1992 ISO-TOPE Co-58 Co-60 Cr-51 I-132 I-133 I-134 I-135 Mn-54 Sr-91 Sr-92 Tc-99M Y-91M Zn-65 CONCENTRAT LICENSEE 2.44e-04 2.08e-04 2.96e-03 2.34e-03 7.88e-04 8.37e-03 2.30e-03 2.-02e-04 8.57e-04 2.90e-03 1.46e-02 4.43e-03 4.53e-04 ION (UCI/UNIT)
NRC ERROR 2.4le-05 2.40e-05 3.27e-04 1.16e-04 6.4le-05 1.24e-03 1.32e-04 1.93e-05 7.71e-05 1.08e-04 5.16e-04 2.71e-04 5.40e-05 2.59e-04 2.09e-04 2.33e-03 2.36e-03 7.62e-04 3.72e-02 2.09e-03 9.85e-05 8.35e-04 2.6le-03 1.56e-02 2.48e-03 4.75e-04 RESO-LUTION
9
20
30
5
24
9
RATIO (LICENSEE/NRC)
0.94 0.99 1.27 0.99 1.03 0.23 1.10 2.05 1.03 1.11 0.93 1.79 0.95 COMPARISON Agreement Agreement Agreement Agreement Agreement Disagreement Agreement Disagreement Agreement Agreement Agreement Disagreement Agreement Reactor Coolant Sample: Detector N4 Browns Ferry Nuclear Plant:
March 16
- 20, 1992 ISO-TOPE Co-58 Co-60 Cr-51 I-132 I-133 I-134 I-135 Mn-54 Sr-91 Sr-92 Tc-99M Y-91M Zn-65 CONCENTRAT LICENSEE 2.53e-04 2.02e-04 3.01e-03 2.27e-03 8.10e-04 8.85e-03 2.41e-03 4.36e-04 8.84e-04 3.12e-03 1.45e-02 5.97e-03 5.10e-04 ION (UCI/UNIT)
NRC ERROR 2.41e-05 2.40e-05 3.27e-04 1.16e-04 6.41e-05 1.24e-03 1.32e-04 1.93e-05 7.71e-05 1.08e-04 5.16e-04 2.71e-04 5.40e-05 2.59e-04 2.09e-04 2.33e-03 2.36e-03 7.62e-04 3.72e-02 2.09e-03 9.85e-05 8.35e-04 2.61e-03 1.56e-02 2.48e-03 4.75e-04 RESO-LUTION
9
20
30
5
24
9
RATIO (LICENSEE/NRC)
0.98 0.97 1.29 0.96 1.06 0.24 1.15 4.43 1.06 1.20 0.93 2.41 1.07 COMPARISON Agreement Agreement Agreement Agreement Agreement Disagreement Agreement Disagreement Agreement Agreement Agreement Disagreement Agreement
TABLE 2 Liquid Radwaste:
Detector ¹1 Browns Ferry Nuclear Plant:
March 16
- 20, 1992 ISO-TOPE Co-58 Co-60 Cr-51 Cs-134 Cs-137 Mn-54 Na-24 Zn-65 CONCENTRATION (UCI/UNIT)
LICENSEE NRC ERROR 1.32e-06 1.59e-06 1.47e-07 4.19e-06 4.77e-06 2.75e-07 9.11e-06 1.00e-05 1.48e-06 6.48e-07 5.09e-07 9.11e-08 7.84e-06 7.61e-06 4.09e-07 1.58e-06 1.49e-06 1.49e-07 2.00e-06 1.65e-06 1.53e-07 5.98e-06 6.73e-06 4.38e-07 RESO-LUTION
17
6
10
15 RATIO (LICENSEE/NRC)
0.83 0.88 0.91 1.27 1.03 1.06 1.21 0.89 COMPARISON Agreement Agreement Agreement Agreement Agreement Agreement Agreement Agreement Liquid Radwaste:
Detector ¹2 Browns Ferry Nuclear Plant:
March 17, 1992 ISO-TOPE CONCENTRATION (UCI/UNIT)
LICENSEE NRC ERROR RESO-LUTION RATIO (LICENSEE/NRC)
COMPARISON Co-58 Co-60 Cr-51 Cs-134 Cs-137 Mn-54 Na-24 Zn-65 1.61e-06 5.27e-06 9.24e-06 6.04e-07 8.67e-06 1.72e-06 1.62e-06 8.22e-06 1.59e-06 4.77e-06 1.00e-05 5.09e-07 7.61e-06 1.49e-06 1.65e-06 6.73e-06 1.47e-07 2.75e-07 1.48e-06 9.11e-08 4.09e-07 1.49e-07 1.53e-07 4.38e-07
17
6
10
15 1.01 1.10 0.92 1.19 1.14 1.16 0.98 1.22 Agreement Agreement Agreement Agreement Agreement Agreement Agreement Agreement
TABLE 2 ontinued Liquid Radwaste:
Detector g3 Browns Ferry Nuclear Plant:
March 16
- 20, 1992 ISO-TOPE CONCENTRATION (UCI/UNIT)
LICENSEE NRC ERROR RESO-LUTION RATIO (LICENSEE/NRC)
COMPARISON Co-58 Co-60 Cr-51 Cs-134 Cs-137.
Mn-54 Na-24 Zn-65 1.56e-06 5.16e-06 9.41e-06 1.08e-06 8.07e-06 1.64e-06 1.63e-06 6.94e-06 1.59e-06 4.77e-06 1.00e-05 5.09e-07 7.61e-06 1.49e-06 1.65e-06 6.73e-06 1.47e-07 2.75e-07 1.48e-06 9.11e-08 4.09e-07 1.49e-07 1.53e-07 4.38e-07
17
6
10
15 0.98 1.08 0.94 2.12 1.06 1.10 0.99 1.03 Agreement Agreement Agreement Disagreement Agreement Agreement Agreement Agreement Liquid Radwaste:
Detector g4 Browns Ferry Nuclear Plant:
March 16 - 20, 1992 ISO-TOPE CONCENTRATION (UCI/UNIT)
LICENSEE NRC ERROR RESO-LUTION RATIO (LICENSEE/NRC)
COMPARISON Co-58 Co-60 Cr-51 Cs-134 Cs-137 Mn-54 Na-24 Zn-65 1.73e-06 4.96e-06 9.09e-06 1.03e-06 8.71e-06 1.66e-06 1.51e-06 7.16e-06 1.59e-06 4.77e-06 1.00e-05 5.09e-07 7.61e-06 1.49e-06 1.65e-06 6.73e-06 1.47e-07 2.75e-07 1.48e-06 9.11e-08 4.09e-07 1.49e-07 1.53e-07 4.38e-07
17 w7
19
11
, 15 1.09 1.04 0.91 2.02 1.14 1.11 0.91 1.06 Agreement Agreement Agreement Disagreement Agreement Agreement Agreement Agreement
TABLE
Charcoal Cartridge: Detector g1 Browns Ferry Nuclear Plant:
March 16
- 20, 1992 ISO-TOPE I-131 I-133 1.33e-11 6.75e-11 1.48e-11 7.39e-11 1.29e-12 5.11e-12 CONCENTRATION (UCI/UNIT)
LICENSEE NRC ERROR RESO-LUTION
14 RATIO (LICENSEE/NRC)
COMPARISON 0.90 Agreement 0.91 Agreement Charcoal Cartridge: Detector g2 Browns Ferry Nuclear Plant:
March 17, 1992 ISO-TOPE CONCENTRATION (UCI/UNIT)
LICENSEE NRC ERROR RESO-LUTION RATIO (LICENSEE/NRC)
COMPARISON I-131 I-133 1.44e-11 6.76e-11 1.48e-11 7.39e-11 1.29e-12 5.11e-12
14 0.97 0.91 Agreement Agreement Charcoal Cartridge: Detector g3 Browns Ferry Nuclear Plant:
March 16
- 20, 1992 ISO-TOPE I-131 I-133 1.35e-11 7.51e-11 1.48e-11 1.29e-12 7.39e-11 5.11e-12 CONCENTRATION (UCI/UNIT)
LICENSEE NRC ERROR RESO-LUTION
14 RATIO (LICENSEE/NRC)
COMPARISON 0. 91 Agreement 1.02 Agreement Charcoal Cartridge: Detector
Browns Ferry Nuclear Plant:
March 16
- 20, 1992 ISO-TOPE CONCENTRATION (UCI/UNIT)
LICENSEE NRC ERROR RESO-LUTION RATIO (LICENSEE/NRC)
COMPARISON I-131 I-133 1.26e-ll 7.21e-11 1.48e-11 7.39e-11 1.29e-12 5.11e-12
14 0.85 0.98 Agreement Agreement
TABLE
Particulate Filter: Detector g1 Browns Ferry Nuclear Plant:
March 16
- 20, 1992 ISO-TOPE CONCENTRATION (UCI/UNIT)
LICENSEE NRC ERROR RESO-LUTION RATIO (LICENSEE/NRC)
COMPARISON CQ-109 Ce-139 Co-57 Co-60 Cs-137.
Sn-113 Sr-85 8.71e-02 1.66e-03 2.79e-03 2.48e-02 2.28e-02 4.60e-03 1.36e-03 1.08e-01 1.53e-03 2.91e-03 2.61e-02 2.46e-02 4.62e-03 1.33e-03 3.61e-03 7.43e-05 1.07e-04 9.38e-04 1.10e-03 3.02e-04 1.25e-04
21
28
15
0.81 1.08 0.96 0.95 0.93 1.00 1.02 Agreement Agreement Agreement Agreement Agreement Agreement Agreement Particulate Filter: Detector g2 Browns Ferry Nuclear Plant:
March 16
- 20, 1992 ISO-TOPE CONCENTRATION (UCI/UNIT)
LICENSEE NRC ERROR RESO-LUTION RATIO (LICENSEE/NRC)
COMPARISON CQ-109 Ce-139 Co-57 Co-60 Cs-137 Sn-113 Sr-85 8.50e-02 1.69e-03 2.83e-03 2.68e-02 2.35e-02 4.46e-03 1.37e-03 1.08e-01 1.53e-03 2.91e-03 2.61e-02 2.46e-02 4'.62e-03 1.33e-03 3.61e-03 7.43e-05 1.07e-04 9.38e-04 1.10e-03 3.02e-04 1.25e-04
21
28
15
0.79 1.10 0.97 1.03 0.96 0.97 1.03 Agreement Agreement Agreement Agreement Agreement Agreement Agreement
l 0'
TABLE
ontinued Particulate Filter: Detector g3 Browns Ferry Nuclear Plant:
March 16
- 20, 1992 ISO-TOPE Cd-109 Ce-139 Co-57 Co-60 Cs-137 Sn-113 Sr-85 CONCENTRATION (UCI/UNIT)
LICENSEE NRC ERROR 8.52e-02 1.08e-01 3.61e-03 1.67e-03 1.53e-03 7.43e-05 2.77e-03 2.91e-03 1.07e-04 2.59e-02 2.61e-02 9.38e-04 2.33e-02 2.46e-02 1.10e-03 4.52e-03 4.62e-03 3.02e-04 1.36e-03 1.33e-03 1.25e-04 RESO-LUTION
21
28
15
RATIO (LICENSEE/NRC)
0.79 1.09 0.95 0.99 0.95 0.98 1.02 COMPARISON Agreement Agreement Agreement Agreement Agreement Agreement Agreement Particulate Filter: Detector g4 Browns Ferry Nuclear Plant:
March 16
- 20, 1992 ISO-TOPE CONCENTRATION (UCI/UNIT)
LICENSEE NRC ERROR RESO-LUTION RATIO (LICENSEE/NRC)
COMPARISON Cd-109 Ce-139 Co-57 Co-60 Cs-137 Sn-113 Sr-85 9.32e-02 1.73e-03 2.90e-03 2.55e-02 2.30e-02 4.61e-03 1.32e-03 1.08e-01 1.53e-03 2.91e-03 2.61e-02 2.46e-02 4.62e-03 1.33e-03 3.61e-03 7.43e-05 1.07e-04 9.38e-04 1.10e-03 3.02e-04 1.25e-04
21
28
15
0.86 1.13 1.00 0.98 0.93 1.00 0.99 Agreement Agreement Agreement Agreement Agreement Agreement Agreement
C
TABL
Gas Marinelli: Detector g1 Browns Ferry Nuclear Plant:
March 16
- 20, 1992 ISO-TOPE CONCENTRATION (UCI/UNIT)
LICENSEE NRC ERROR RESO-LUTION RATIO (LICENSEE/NRC)
COMPARISON Kr-85M Kr-88 Xe-133 Xe-133M Xe-135 4.74e-04 1.24e-03 2.32e-04 1.81e-05 2.82e-03 4.27e-04 9.79e-04 2.71e-04 1.27e-05 2.24e-03 1.42e-05 8.82e-05 8.87e-06 1.76e-06 7.27e-05
11
7
1.11 1.27 0.86 1.43 1.26 Agreement Agreement Agreement Agreement Agreement Gas Marinelli: Detector g2 Browns Ferry Nuclear Plant:
March 11
- 20, 1992 ISO-TOPE CONCENTRATION (UCI/UNIT)
LICENSEE NRC ERROR RESO-LUTION RATIO (LICENSEE/NRC)
COMPARISON Kr-85M Kr-88 Xe-133 Xe-133M Xe-135 4.71e-04 1.14e-03 2.31e-04 1.65e-05 2.89e-03 4.27e-04 9.79e-04 2.71e-04 1.27e-05 2.24e-03 1.42e-05 8.82e-05 8.87e-06 1.76e-06 7.27e-05
11
7
1.10 1.16 0.85 1.30 1.29 Agreement Agreement Agreement Agreement Agreement
Gas Marinelli: Detector g3 Browns Ferry Nuclear Plant:
March 16
- 20, 1992 ISO-TOPE Kr-85M Kr-88 Xe-133 Xe-133M Xe-135 CONCENTRATION (UCI/UNIT)
LICENSEE NRC ERROR 4.64e-04 4.27e-04 1.42e-05 1.13e-03 9.79e-04 8.82e-05 2.35e-04 2.71e-04 8.87e-06 1.63e-05 1.27e-05 1.76e-06 2.88e-03 2.24e-03 7.27e-05 RESO-LUTION
11
7
1.09 1.15 0.87 1.28 1.29 Agreement Agreement Agreement Agreement Agreement RATIO (LICENSEE/NRC)
COMPARISON Gas Marinelli: Detector g4 Browns Ferry Nuclear Plant: March 16
- 20, 1992 ISO-TOPE Kr-85M Kr-88 Xe-133 Xe-133M Xe-135 CONCENTRATION (UCI/UNIT)
LICENSEE NRC ERROR 4.93e-04 4.27e-04 1.42e-05 1.20e-03 9.79e-04 8.82e-05 2.39e-04 2.71e-04 8.87e-06 1.52e-05 1.27e-05 1.76e-06 2.96e-03 2.24e-03 7.27e-05 RESO-LUTION
11
7
RATIO (LICENSEE/NRC)
1.15 1.23 0.88 1.20 1.32 COMPARISON Agreement Agreement Agreement Agreement Agreement
'
ATTACHMENT 2 CRITERIA FOR COMPARING ANALYTICALMEASUREMENTS This enclosure provides criteria for comparing results of capability tests and verification measurements.
The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this program.
In this criteria, the judgement limits denoting agreement or disagreement between licensee and NRC results are variable.
This variability is a function of the NRC's value to its associated uncertainty.
As the ratio of the NRC value to its uncertainty, referred to in this program as the resolution increases, the range of acceptable differences between the NRC and licensee values should be more restrictive.
Conversely, poorer agreement between NRC and licensee values must be considered acceptable as the resolution decreases.
For comparison purposes, a comparison ratio of the licensee value to the NRC value for each individual nuclide is computed.
This ratio is then evaluated for agreement based on the calculated resolution.
The corresponding resolution and calculated ratios which denote agreement are listed in Table 1 below.
Values outside of the agreement ratio for a particular nuclide are considered in disagreement.
TABLE 1 Confirmatory Measurements Acceptance Criteria Resolutions vs.
Comparison Ratio Resolution Com arison Ratio for A reement c 4
-
8
-
16
- 50 51 - 200 200 0.40 0.50 0.60 0.75 0.80 0.85 2.5 2.0 1.66 1.33 1.25 1.18 Resolution
= NRC Reference Value for a Particular Nuclide Associated Uncertainty for the Value Comparison Ratio Licensee Value NRC Refernce Value