IR 05000261/1993001

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Insp Rept 50-261/93-01 on 930104-08.No Violations or Deviations Noted.Major Areas Inspected:Organization of Chemistry/Effluent Dept & Radwaste Group,Confirmatory Measurements & Plant Water Chemistry
ML14178A322
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 01/25/1993
From: Robert Carrion, Decker T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML14178A321 List:
References
50-261-93-01, 50-261-93-1, NUDOCS 9302120131
Download: ML14178A322 (18)


Text

t REG& l UNITED STATES o

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA STREET, ATLANTA, GEORGIA 30323 JAN' 2 8 1993 Report No:

50-261/93-01 Licensee:

Carolina Power and Light Company P. 0. Box 1551 Raleigh, NC 27602 Docket No.:

50-261 License No.:

DPR-23 Facility Name: H. B. Robinson Nuclear Power Plant Inspection Conducted: January 4 8, 1993 R. P. Carrion, Radiation S cialist Dfte Sfgned Accompanied by: T. R. Volk, Physical Sciences Technician Approved by:

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T. R. Decker, Chief Dte S'igned 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 the organization of the Chemistry/Effluent Department and Radioactive Waste Group, confirmatory measurements, plant water chemistry, the Semiannual Radiological Effluent Release Report, radioactive material processing and transportation, and records for decommissioning plannin Results:

The licensee's organization of its Chemistry/Effluent Department and radioactive material processing and shipping unit satisfied Technical Specification (TS) requirements (Paragraph 2).

The confirmatory measurements comparison showed good agreement between the results of the licensee and the NRC mobile laboratory. The licensee had established a good Counting Room radiochemical analysis program (Paragraph 3).

Plant water chemistry was maintained well within TS limits (Paragraph 4).

9302120131 930128 PDR ADOCK 05000261 PDR

The licensee's Semiannual Radioactive Effluent Release Report was complete and satisfied regulatory requirements (Paragraph 5).

The licensee will, develop a system to identify and maintain events/incidents significant with respect to decommissioning planning (Paragraph 6).

Radioactive material processing and shipping was conducted in a competent, professional manner (Paragraph 7).

REPORT DETAILS Persons Contacted Licensee Employees

  • S. Billings, Technical Aide, Regulatory Compliance
  • R. Chambers, Plant General Manager
  • W. Christensen, Chemistry Supervisor, Environmental and Radiation Control (E&RC)
  • C. Dietz, Vice President, Robinson Nuclear Power Division
  • J. Eaddy, Supervisor, E&RC Technical Support
  • J. Harrison, Manager, Regulatory Compliance
  • J. Padgett, Manager, E&RC R. Slone, Records Management Supervisor Other licensee employees contacted during this inspection included engineers, technicians, and administrative personne Nuclear Regulatory Commission L. Garner, Senior Resident Inspector
  • C. Ogle, Resident Inspector
  • Attended exit interview Acronyms and Initialisms used throughout this report are listed in the last paragrap.

Organization (84750)

Technical Specification (TS) 6.2 describes the licensee's organizatio The inspector reviewed the licensee's organization, staffing levels, and lines,of authority as they related to the Chemistry/Effluents Department and Radioactive Waste Group to verify that the licensee had not made organizational changes since the last inspection which would adversely affect the control of radiation exposures and/or radioactive materia The Environmental and Radiation Control (E&RC) Unit consisted of the same number of positions (sixty) as during the last inspection (92-23),

conducted in August. It was still organized into six functional areas:

Chemistry/Effluents, Radioactive Waste, Technical Support, and three groups for Job Coverag Although some of the technicians had changed due to normal rotation of assignments, the Chemistry/Effluents Unit and the Radioactive Waste Unit had not experienced any changes at all since the previous inspectio II

The inspector concluded that the licensee's E&RC organization satisfied TS requirement No violations or deviations were identifie.

Confirmatory Measurements (84750)

10 CFR 20.201(b) requires the licensee to perform surveys as necessary to evaluate the extent of radiation hazard To evaluate the licensee's analytical capability to make consistently accurate radioactivity measurements, six samples were analyzed for radionuclide concentrations by the licensee and the NRC Region II mobile laboratory, including:

two reactor coolant system (RCS) samples (one which had been collected prior to the inspector's arrival and had decayed for forty-eight hours and another whose collection the inspector observed and had decayed for one and a half hours), a liquid sample from the "0" Waste Condensate Tank, a noble gas sample in the form of RCS stripped gas, a particulate filter loaded with the filtrate of the above-referenced forty-eight hour decay RCS sample, 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 concentration The licensee analyzed all samples in the Chemistry Counting Room, which was equipped with three Germanium-Lithium (GeLi) gamma spectroscopy detectors, one manufactured by Applied Physical Technology, In (APTEC 1299), one manufactured by Nuclear Data, Inc (PGT 1452), and one manufactured by Gamma Products, Inc. (ORTEC 1602A).

The inspector noted that the gamma operating data log was posted on each detector and that it included calibration information for the geometries used by the particular detector to which it was poste The inspector reviewed several calibration curves for the detectors used for the confirmatory measurement exercise, including geometries of:

a one-liter Marinelli beaker on shelf zero, a 47-millimeter filter on shelf zero, and a 125-milliliter bottle on shelf zero for the APTEC 1299; a one-liter Marinelli beaker on shelf zero, a 1260 cc gas beaker on shelf zero, and a 500-milliliter bottle on shelf zero for the PGT 1452; and an iodine cartridge on shelf zero, a 47-millimeter filter on shelf one, and a 125-milliliter bottle on shelf one for the ORTEC 1602A. The calibration curves were developed using mixed gamma sources (which typically contained Cd-109, Co-57, Ce-139, Hg-203, Sn 113, Cs-137, Co-60, and Y-88) plus Am-241. The licensee used nine sources for various geometry calibrations. The inspector reviewed Certificates of Calibration for several of the sources used to generate the referenced calibration curve Each source was prepared using an aliquot measured gravimetrically from a calibrated master radionuclide solution source. The 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 certificat The inspector concluded that the calibration curves and Certificates of Calibration were current and sufficien Daily performance checks for the detectors were done using Am-241, Co-60, and Cs-137 sources. The inspector reviewed the 1992 control charts for the detectors. Some drifting and biases had been experienced by the detectors and the mean (and the associated warning and control limits) had been adjusted to reflect this behavio The inspector reviewed selected portions of Chemistry Procedure CP-003, Revision (Rev.) 13, "Systems Sampling Procedure," effective on August 29, 1992, and Environmental Monitoring Procedure EMP-023, Re, "Liquid Waste Release and Sampling," effective January 1, 1993. The portions reviewed included sampling instructions and were adequate for the intended purpose. The inspector observed licensee technicians obtain a reactor coolant sample and the liquid sample from the "D" Waste Condensate Tank and noted that the procedures were followed closely as they completed their duties. Proper sampling techniques and health physics practices were utilize 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 spectru From the observations made during this inspection, the inspector concluded that the licensee demonstrated that a good Count Room radiochemical analysis program was in plac No violations or deviations were identifie.

Plant Water Chemistry (84750)

At the time of this inspection, the unit was in its fifteenth fuel cycle. The next refueling outage is scheduled for September, 1993. The inspector reviewed the plant chemistry controls and operational controls affecting plant water chemistry for the period of November 21 through December 25, 199 TS 3.1.6 specifies that the concentrations of dissolved oxygen (DO) and chloride in the RCS be maintained below 0.10 parts per million (ppm) and 0.15 ppm, respectively, when the reactor coolant temperature exceeds 250 *F. TS 3.1.4 specifies that the total specific activity of the reactor coolant be limited to less than or equal to 1.0 microcuries/

gram (,uCi/g) dose equivalent iodine (DEI) under all modes of operatio Table 4.1-2 of TS 4.1 specifies the sampling frequencies for these parameters. These parameters are related to corrosion resistance and fuel integrity. The oxygen parameter is established to maintain oxygen

II

levels' sufficiently low to prevent general and localized corrosion. The chloride parameter is established to provide protection from halide stress corrosion. The activity parameter is established to minimize personnel radiation exposure during operation and maintenanc Pursuant to these requirements, the inspector reviewed tabular daily summaries which correlated reactor power output to chloride and DO concentrations of the reactor coolant for the five-week period referenced above. Additional summaries for specific activity for the period were reviewed. The inspector determined that the parameters were maintained well below TS limits. Typical values for DO and chloride were less than 0.001 ppm (the LLD (Lower Limit of Detection) for the

"light tube" method of analysis) and less than 0.020 ppm (the LLD for the mercuric nitrate titration method of analysis), respectively. The inspector noted that chloride analysis using the ion chromatograph typically yielded-concentrations of 0.004 ppm. Typical DE1 values at steady-state conditions were 2.OE-4 yCi/m There had been no evidence of leaking fuel in calendar 1992 since the unit returned to service following the refueling outage. However, on January 1, 1993, a small tight leak apparently developed,in the fue.

Evidence of this development was a rise in the concentrations of 1-131 (from 5.84E-5 microcuries per mill.iliter (pCi/ml) to 7.15E-4 pCi/ml),

DEI (from 4.18E-4 pCi/ml to 1.36E-3 pCi/ml), and Cs-138 (from 2.61E-3 pCi/ml to 1.74E-2 yCi/ml), and the 1-131/1-133 ratio (from 0.080 to 0.463).

These changes occurred between 0214 hours0.00248 days <br />0.0594 hours <br />3.53836e-4 weeks <br />8.1427e-5 months <br /> on December 31, 1992 and 0303 hours0.00351 days <br />0.0842 hours <br />5.009921e-4 weeks <br />1.152915e-4 months <br /> on January 1, 199 Since that time, these parameters had exhibited steady to slightly declining behavior. At the time of this inspection, the licensee was continuing to gather information which would be sent to the corporate Nuclear Fuel Division and Siemens for evaluation and discussion about future actions to be take The inspector concluded that the Plant Water Chemistry was being maintained well-within the TS requirement No violations or deviations were identifie.

Semiannual Radioactive Effluent Release Report (84750)

TS 6.9.d requires the licensee to submit a Semiannual Radiological

.Effluent Release Report within the time periods specified covering the operation of the facility during the previous six months of operatio The TS also states the requirements for the content and format of the report. The inspector reviewed the reports for 1991'and compared the results to those of 1989 and 1990 to verify compliance and to determine trends which might have occurred in liquid and gaseous effluent releases. These data are summarized on the following pag Robinson Radioactive Effluent Release Summary 1990 1991 1992*

Abnormal Releases Liquid

0

Gaseous

0

Activity Released (curies) Liquid 1. Fission and Acti-3.60E-1 2.35E-1 1.83E-1 vation Products 2. Tritium 3.53E+2 1.88E+2 3.10E+2 3. Gross Alpha 0.OOE+0

< LLD

< LLD Gaseous 1. Fission and Acti-7.21E+0 2.26E+0 1.11E+0 vation Gases 2. lodines 1.09E-7

< LLD 8.43E-7 3. Particulates 1.34E-4 1.73E-4 1.20E-4 4. Tritium 4.44E+0 4.48E+0 1.56E+0

  • First half of 1992 onl No abnormal releases were reported in the second half of 1992 by the license A comparison of data from liquid and gaseous effluents 1990, 1991, and first half of 1992 showed no significant trend There were no changes to the Radiological Environmental Monitoring Program (REMP) (as a result of the Land Use Census), the Offsite Dose Calculation Manual (ODCM), or the Radioactive Waste System during the first half of 199 However, minor changes to the Process Control Program (PCP) had been made and included the correction of a typographical error, an editorial change (for consistency throughout the PCP), and the update of two position titles to reflect the current organizatio No outside liquid holdup tank or waste gas decay tank exceeded its regulatory limit of ten curies and 1.90E+4 curies, respectivel Two monitors, FI-1064 and R-16, were reported to be out of service for greater than thirty days during this period. FI-1064, the liquid effluent flowrate measuring device, had originally been declared inoperable in July, 1990 due to erratic readings. The monitor had become obsolete and replacement parts were unavailable. Therefore, an engineering evaluation was initiated to procure a suitable replacemen The replacement was made during refueling outage #14 by plant

III6 modification M-1118 and returned to service on May 30, 199 R-16, which monitors service water from the containment vessel High Volume Heat (HVH) units, was declared to be inoperable on March 25, 1992 due to erratic readings and failure to respond to a source check. The monitor was returned to service on May 30, 199 During the period of equipment inoperabilities, compensatory surveillances were initiated, as required by Table 3.5-6 of the TS The following table summarizes solid radwaste shipments for burial or disposal for the previous two and a half years. These shipments typically include spent resins, filter sludges, dry compressible waste, and contaminated equipmen Robinson Solid Radwaste Shipments 1990 1991 1992*

Number of Waste

90

Disposal Shipments Volume (cubic meters)

6.5 3 Activity (curies)

6.4 4 *First half of 1992 onl Through the end of the year (1992), the licensee had made 112 radioactive material shipments, including nine to Scientific Ecology Group, Incorporated (SEG), six to the disposal facility, fifty-seven special, and forty laundr For solid radwaste, no significant changes were noted for the period reviewe The inspector concluded that the Semiannual Radioactive Effluent Release Report was complete and satisfied regulatory requirement No violations or deviations were identifie.

Decommissioning Planning Records (84750)

10 CFR 50.75(g) requires, in part, that licensees maintain "records of information important to the safe and effective decommissioning of the facility in an identified location until the license is terminated by the Commission."

Furthermore, information considered important by the Commission for decommissioning is identified as "records of spills or other unusual occurrences involving the spread of contamination in and around the facility, equipment, or site" and that the records "must include any known information on identification of involved nuclides, quantities, forms, and concentrations."

Also identified are "as-built drawings and modifications of structures and equipment in restricted areas where radioactive materials are used and/or stored and of

0I

locations of possible inaccessible contamination such as buried pipes which may be subject to contamination."

During. Inspection 92-23, the inspector requested the licensee's decommissioning planning records to verify compliance with the regulations and held discussions with the licensee's Records Management Supervisor to determine program status/effectiveness. The.inspector determined that while the subject information was in the licensee's document control vault, in the form of microfiche and drawings, it was not segregated into one readily identifiable area nor was a listing identifying pertinent information for decommissioning planning available. Timely retrieval and proper classification of documentation (both existing and future) could not be guaranteed. The licensee planned to evaluate and develop a system/program patterned after that in place at one of Carolina Power & Light's (CPL's) other nuclear power plant During the current inspection, the inspector interviewed the Records Management Supervisor to determine the status of the licensee's progra Per a memorandum sent from the supervisor to senior plant management dated December 21, 1992, a Records Task Force (RTF) was being established to review newly-created records to determine storage/retention requirements, establish the appropriate quality classification (Q or non-Q), and identify indexing parameters to facilitate record retrieval. The RTF was to consist of eight representatives, one from each of the following:

Outage and Modifications; Records Management; Document Control; Operations; Technical Support; Maintenance; Regulatory Compliance; and E&R The activities of the RTF would encompass all plant records, not only those required for decommissioning planning. The licensee expected to implement the RTF by the end of January 199 By mid-January, the licensee expected to begin a review of existing records to identify those related to decommissioning plannin The inspector concluded that the licensee was making satisfactory progress in the implementation of a program to identify relevant decommissioning planning records (both existing and future).

No violations or deviations were identifie.

Transportation (86750)

10 CFR 71.5(a) requires 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 49 CFR, Parts 170 through 18 Pursuant to these requirements, the inspector reviewed the licensee's S-activities affiliated with these requirements, to determine whether the licensee effectively processes, packages, stores, and ships radioactive

8 solid materials. The licensee's program for the packaging and transportation of radioactive materials was conducted by the Radwaste Group within the E&RC Department. Radwaste was processed and packaged (including the preparation of shipping documentation) by the Radwaste Grou Radioactive Materials Shipment Documentation Packages Shipment of radioactive materials was the responsibility of the Radioactive Waste Group, which prepared all shipping documents and procured the necessary disposal containers and shipping cask Radioactive materials shipments were classified into four categories:

Casks (for disposal at a burial site); Low Specific Activity (LSA) sent to SEG for incineration and/or compaction prior to final disposal; Special Shipments (including virtually anything from spent fuel to samples containing Limited Quantities); and Laundry. The inspector reviewed two shipping documentation packages for radioactive materials shipments made since the last inspection (August 1992), including Shipment No SEG-92-08 and SEG-92-09, LSA shipments to SEG. The documentation packages were thorough and included shipment information 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, a 24-hour emergency telephone number, emergency response information sheets, et The radiation and contamination survey results were within the limits specified by 49 CFR and the shipping documents were being maintained as require Information Notices (INs) IN 92-62 The inspector discussed IN 92-62, "Emergency Response Information Requirements For Radioactive Material Shipments," with cognizant licensee personnel to be sure that the licensee had received it and that the staff was aware of it and its implications. The IN emphasizes that all emergency response information required by DOT regulations must be accurately provided on shipment papers or other documents and that the licensee must be prepared to respond immediately with the information, as neede Furthermore, the IN indicated that response personnel would expect to be given emergency information within 15 minute The licensee had modified its shipping procedures to ensure that the DOT regulations would be satisfied. Specifically, the licensee's Radwaste/Shipping Group is required to notify Operations when a shipment leaves the site and its destination. In the event of an accident involving the radioactive shipment, Operations will be contacted via the 24-hour emergency telephone number listed on the shipping

papers. Operations will record pertinent -information on a newly-developed information sheet. At the bottom of the sheet, the names and beeper numbers of five Radiation Control Supervisors are provided and Operations has been instructed to contact one of them for specific guidanc Previously, the 24-hour number was answered by Security, but problems had arisen and the decision was made to give the responsibility-to Operation.

IN 92-72 The inspector discussed IN 92-72, "Employee Training and Shipper Registration Requirements for Transporting Radioactive Materials," with cognizant licensee personnel to be sure that the licensee had received it and that the staff was aware of its implications in ensuring regulatory compliance when shipping packages containing radioactive materials. The corporate training department was reviewing the IN to assure that the issues raised were covered in future trainin The inspector concluded that the licensee had good programs in place for the handling and shipping of radioactive material and that they were effectively implemente.

Exit Interview The inspection scope and results were summarized on January 8, 1993, 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 proprietar Dissenting comments were not received from.the license.

Acronyms and Initialisms APTEC - Applied Physical Technology, In CFR - Code of Federal Regulations Ci -

curie CP - Chemistry Procedure CPL - Carolina Power and Light DEI - Dose Equivalent Iodine DO - Dissolved Oxygen DOT - Department of Transportation E&RC - Environmental and Radiation Control EMP - Environmental Monitoring Procedure F -

Fahrenheit g - gram GeLi - Germanium-Lithium HVH - High Volume Heat IN -

Information Notice

>@

1 -

liter, LLD -

Lower Limit of Detection LSA -

Low Specific Activity pCi - micro-Curie (1.OE-6 Ci)

ml - milli-liter NIST - National Institute of Standards and Technology No. -

Number NRC -

Nuclear Regulatory Commission ODCM - Off-site Dose Calculation Manual PCP -

Process Control Program ppm -

parts per million RCS -

Reactor Coolant System REMP - Radiological Environmental Monitoring Program Rev -

Revision RTF - Records Task Force SEG - Scientific Ecology Group, Incorporated TS -

Technical Specification 0II

ATTACHMENT 1 COMPARISON OF NRC AND ROBINSON ANALYTICAL RESULTS JANUARY 4-8, 1993 Type of Sample: Unit 2 Reactor Coolant System (RCS)

Sample Container: NRC 50 ml bottle Robinson 125 ml bottle Radio-Licensee's NRC Reso-Compar nuclide Value (pCi/ml)

Value (Ci/ml)

lution Ratio ison APTEC 1299 Detector Ar-41 3.12E-3 (3.38 +/- 0.12)E-3

0.92 Agree Ce-139 3.44E-5 (6.69 +/- 1.65)E-5

0.51 Agree Co-58 1.74E-4 (1.69 +/- 0.15)E-4

1.03 Agree 1-131 3.05E-4 (2.32 +/- 0.29)E-4

1.31 Agree 1-132 1.45E-3 (1.18 +/- 0.06)E-3

1.23 Agree 1-133 9.27E-4 (6.90 +/- 0.55)E-4

1.34 Agree 1-135 1.17E-3 (1.26 +/- 0.08)E-3

0.92 Agree Kr-85m 1.79E-3 (1.74 +/- 0.07)E-3

1.03 Agree Kr-87 2.20E-3 (2.28 +/- 0.16)E-3

0.96 Agree Na-24 1.31E-3 (1.15 +/- 0.04)E-3

1.14 Agree ORTEC 1602A Detector Ar-41 3.06E-3 (3.38 +/- 0.12)E-3

0.91 Agree Ce-139 1.1OE-4 (6.69 +/- 1.65)E-5

1.64 Agree Co-58 1.91E-4 (1.69 +/- 0.15)E-4

1.13 Agree 1-131 3.07E-4 (2.32 +/- 0.29)E-4

1.32 Agree 1-132 1.40E-3 (1.18 +/- 0.06)E-3

1.19 Agree 1-133 9.75E-4 (6.90 +/- 0.55)E-4

1.41 Agree 1-135 1.11E-3 (1.26 +/- 0.08)E-3

0.88 Agree Kr-85m 1.73E-3 (1.74 +/- 0.07)E-3

0.99 Agree Kr-87 2.30E-3 (2.28 +/- 0.16)E-3

1.01 Agree Na-24 1.30E-3 (1.15 +/- 0.04)E-3

1.13 Agree PGT 1452 Detector Ar-41 2.95E-3 (3.38 +/- 0.12)E-3

0.87 Agree Ce-139 7.1OE-5 (6.69 +/- 1.65)E-5

1.06 Agree Co-58 2.03E-4 (1.69 +/- 0.15)E-4

1.20 Agree 1-131 3.18E-4 (2.32 +/- 0.29)E-4

1.37 Agree 1-132 1.47E-3 (1.18 +/- 0.06)E-3

1.25 Agree 1-133 9.68E-4 (6.90 +/- 0.55)E-4

1.40 Agree 1-135 1.14E-3 (1.26 +/- 0.08)E-3

0.90 Agree Kr-85m 1.79E-3 (1.74 +/- 0.07)E-3

1.03 Agree Kr-87 2.54E-3 (2.28 +/- 0.16)E-3

1.11 Agree Na-24 1.34E-3 (1.15 +/- 0.04)E-3

1.16 Agree

  • Attachment 1

Type of Sample: Unit 2 Reactor Coolant System (RCS) (48-hour decay)

Sample Container: one-liter Marinelli container Radio-Licensee's NRC Reso-Compar nuclide Value (gCi/ml)

Value (ACi/ml)

lution Ratio ison APTEC 1299 Detector Ce-144 2.84E-5 (2.69 +/- 0.31)E-5

1.06 Agree Co-58 3.85E-6 (3.82 +/- 0.48)E-6

1.01 Agree Co-60 5.17E-6 (3.80 +/- 0.61)E-6

1.36 Agree Cs-134 2.60E-5 (2.49 +/- 0.14)E-5

1.04 Agree Cs-136 7.30E-6 (7.04 +7- 0.62)E-6

1.03 Agree Cs-137 2.01E-5 (2.00 +/- 0.11)E-5

1.01 Agree 1-131 4.66E-4 (4.89 +/- 0.36)E.-4

0.95 Agree 1-133 1.14E-3 (1.10 +/- 0.05)E-3

1.03 Agree Mn-54 1.13E-5 (1.08 +7- 0.06)E-5

1.05 Agree Mo-99 3.47E-5 (5.33 +/- 0.56)E-5

0.65 Agree Na-24 1.27E-3 (1.24 +7- 0.05)E-3

1.02 Agree ORTEC 1602A Detector Ce-144 2.15E-5 (2.69 +/- 0.31)E-5

0.80 Agree Co-58 3.87E-6 (3.82 +7- 0.48)E-6

1.01 Agree Co-60 6.11E-6 (3.80 +/- 0.61)E-6

1.60 Agree Cs-134 2.60E-5 (2.49 +/- 0.14)E-5

1.04 Agree Cs-136 7.75E-6 (7.04 +/- 0.62)E-6

1.10 Agree Cs-137 2.05E-5 (2.00 +/- 0.11)E-5

1.03 Agree 1-131 4.74E-4 (4.89 +7- 0.36)E-4

0.97 Agree 1-133 1.15E-3 (1.10 +7- 0.05)E-3

1.05 Agree Mn-54 1.12E-5 (1.08 +/- 0.06)E-5

1.04 Agree Mo-99 3.89E-5 (5.33 +/- 0.56)E-5

0.73 Agree Na-24 1.20E-3 (1.24 +/- 0.05)E-3

0.97 Agree PGT 1452 Detector Ce-144 2.41E-5 (2.69 +/- 0.31)E-5

0.90 Agree Co-58 3.86E-6 (3.82 +/- 0.48)E-6

1.01 Agree Co-60 5.12E-6 (3.80 +/- 0.61)E-6

1.35 Agree Cs-134 2.71E-5 (2.49 +/- 0.14)E-5

1.09 Agree Cs-136 6.65E-6 (7.04 +/- 0.62)E-6

0.94 Agree Cs-137 1.96E-5 (2.00 +/- 0.11)E-5

0.98 Agree 1-131 4.57E-4 (4.89 +7- 0.36)E-4

0.93 Agree 1-133 1.13E-3 (1.10 +7- 0.05)E-3

1.03 Agree Mn-54 1.03E-5 (1.08 +/- 0.06)E-5

0.95 Agree Mo-99 3.66E-5 (5.33 +/- 0.56)E-5

0.69 Agree Na-24 1.24E-3 (1.24 +/- 0.05)E-3

1.00 Agree SII

Attachment 1

Type of Sample:

Waste Condensate Tank "D" Liquid Sample Container:

one-liter Marinelli container Radio-Licensee's NRC Reso-Compar nuclide Value ("Ci/ml)

Value (ACi/ml)

lution Ratio ison APTEC 1299 Detector Ag-110m 1.28E-6 (1.22 +/- 0.12)E-6

1.05 Agree Co-58 4.74E-7 (2.85 +/- 0.93)E-7

1.66 Agree Co-60 2.55E-6 (1.94 +/- 0.23)E-6

1.31 Agree ORTEC 1602A Detector Ag-110m 1.13E-6 (1.22 +/- 0.12)E-6

0.93 Agree Co-58 3.47E-7 (2.85 +/- 0.93)E-7

1.22 Agree Co-60 2.68E-6 (1.94 +/- 0.23)E-6

1.38 Agree PGT 1452 Detector Ag-110m 1.29E-6 (1.22 +/- 0.12)E-6

1.06 Agree Co-58 4.12E-7 (2.85 +/- 0.93)E-7

1.45 Agree Co-60 2.68E-6 (1.94 +/- 0.23)E-6

1.38 Agree Type of Sample:

Charcoal Cartridge (NRC spike)

Radio-Licensee's-NRC Reso-Compar nuclide Value (ACi).

Value (i)

lution Ratio ison APTEC 1299 Detector Cd-109 2.33E-1 (2.93 +/- 0.09)E-1

0.80 Agree Ce-139 7.64E-4 (7.15 +/- 0.62)E-4

1.07 Agree Co-57 3.13E-3 (3.37 +/- 0.13)E-3

0.93 Agree Co-60 3.77E-2 (4.09 +/- 0.14)E-2

0.92 Agree Cs-137 4.53E-2 (4.58 +/- 0.20)E-2

0.99 Agree ORTEC 1602A Detector Cd-109 2.25E-1 (2.93 +/- 0.09)E-1

0.77 Agree Ce-139 7.20E-4 (7.15 +/- 0.62)E-4

1.01 Agree Co-5.95E-3 (3.37 +/- 0.13)E-3

0.88 Agree Co-60 3.72E-2 (4.09 +/- 0.14)E-2

0.91 Agree Cs-137 4.44E-2 (4.58 +/- 0.20)E-2

0.97 Agree PGT 1452 Detector Cd-109 2.23E-1 (2.93 +/- 0.09)E-1

0.76 Agree Ce-139 7.40E-4 (7.15 +/- 0.62)E-4

1.03 Agree Co-57 2.98E-3 (3.37 +/- 0.13)E-3

0.88 Agree Co-60 3.75E-2 (4.09 +/- 0.14)E-2

0.92 Agree Cs-137 4.37E-2 (4.58 +/- 0.20)E-2

0.95 Agree

Attachment 1

Type of Sample:

Stripped Gas Sample Sample Container: One-liter gas Marinelli container Radio-Licensee's NRC Reso-Compar nuclide Value (uCi/cc) Value (gCi/cc) lution Ratio ison APTEC 1299 Detector Ar-41 1.14E-2

_(1.18 +/- 0.04)E-2

0.97 Agree Kr-85m 5.41E-3 (5.18 +/- 0.18)E-3

1.04 Agree Kr-87 7.30E-3 (6.74 +/- 0.37)E-3

1.08 Agree Kr-88 1.17E-2 (9.51 +/- 0.35)E-3

1.23 Agree Xe-133 1.11E-1 (1.29 +/- 0.04)E-1

0.86 Agree Xe-133m 2.91E-3 (2.36 +/- 0.26)E-3

1.23 Agree Xe-135 3.28E-2 (2.65 +/- 0.09)E-2

1.24 Agree ORTEC 1602A Detector Ar-41 1.15E-2 (1.18 +/- 0.04)E-2

0.97 Agree Kr-85m 5.29E-3 (5.18 +/- 0.18)E-3

1.02 Agree Kr-87 7.57E-3 (6.74 +/- 0.37)E-3

1.12 Agree Kr-88 1.14E-2 (9.51 +/- 0.35)E-3

1.20 Agree Xe-133 1.14E-1 (1.29 +/- 0.04)E-1

0.88 Agree Xe-133m 2.73E-3 (2.36 +/- 0.26)E-3

1.16 Agree Xe-135 3.33E-2 (2.65 +/- 0.09)E-2

1.26 Agree PGT 1452 Detector Ar-41 1.14E-2 (1.18 +/- 0.04)E-2

0.97 Agree Kr-85m 5.54E-3 (5.18 +/- 0.18)E-3

1.07 Agree Kr-87 7.20E-3 (6.74 +/- 0.37)E-3

1.07 Agree Kr-88 1.17E-2 (9.51 +/- 0.35)E-3

1.23 Agree Xe-133 1.11E-1 (1.29 +/- 0.04)E-1

0.86 Agree Xe-133m 3.02E-3 (2.36 +/- 0.26)E-3

1.28 Agree Xe-135 3.32E-2 (2.65 +/- 0.09)E-2

1.25 Agree Type of Sample:

Particulate Filter (RCS 48-hour filtrate)

Radio-Licensee's NRC Reso-Compar nuclide Value gCi Value (i)

lution Ratio ison APTEC 1299 Detector Co-58 1.08E-4 (9.62 +/- 0.32)E-5

1.12 Agree Co-60 7.65E-6 (6.50 +/- 0.32)E-6

1.17 Agree Cr-51 1.13E-4 (1.04 +/- 0.13)E-4

1.09 Agree Mn-54 1.14E-6 (8.72 +/- 1.02)E-7

1.31

.Agree Nb-95 1.70E-5 (1.50 +/- 0.06)E-5

1.13 Agree Zr-95 1.95E-5 (1.73 +/- 0.08)E-5

1.13 Agree Zr-97 2.85E-5 (2.20 +/- 0.21)E-5

1.30 Agree

Attachment 1

ORTEC 1602A Detector Co-58 1.08E-4 (9.62 +/- 0.32)E-5

1.12 Agree Co-60 7.55E-6 (6.50 +/- 0.32)E-6

1.16 Agree Cr-51 1.12E-4 (1.04 +/-

0.13)E-4

1.08 Agree Mn-54 9.70E-7 (8.72 +/-

1.02)E-7

1.11 Agree Nb-95 1.74E-5 (1.50 +/- 0.06)E-5

1.16 Agree Zr-95 1.95E-5 (1.73 +/-

0.08)E-5

1.13 Agree Zr-97 2.82E-5 (2.20 +/-

0.21)E-5

1.28 Agree PGT 1452 Detector Co-58 1.09E-4 (9.62 +/-

0.32)E-5

1.13 Agree Co-60 8.15E-6 (6.50 +/-

0.32)E-6

1.25 Agree Cr-51 1.16E-4 (1.04 +/- 0.13)E-4

1.12 Agree Mn-54 1.04E-6 (8.72 +/-

1.02)E-7

1.19 Agree Nb-95 1.75E-5 (1.50 +/-

0.06)E-5

1.17 Agree Zr-95 1.97E-5 (1.73 +/-

0.08)E-5

1.14 Agree Zr-97 2.99E-5 (2.20 +/-

0.21)E-5

1.36 Agree

ATTACHMENT 2 CRITERIA FOR COMPARISONS OF ANALYTICAL MEASUREMENTS 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 progra 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".2 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 sampl 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 agreemen TABLE NRC Confirmatory Measurements Acceptance Criteria Resolution vs.Comparison Ratio Limits Comparison Ratio Limits Resolution for Agreement

< 4 0.4 -.5 -.6 -

1.66 16 -

0.75 -

1.33 51 -

200 0.80 -

1.25

> 200 0.85 -

1.18

'Comparison Rario = Licensee Value NRC Reference Value 2Resolution = NRC Reference Value Associated Uncertainty