IR 05000269/1989013

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Insp Repts 50-269/89-13,50-270/89-13 & 50-287/89-13 on 890508-11.No Violations or Deviations Noted.Major Areas Inspected:Liquid & Gaseous Effluents,Environ Monitoring, Plant Chemistry & Confirmatory Measurements
ML15224A537
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 05/26/1989
From: Adamovitz S, Dan Collins
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML15224A536 List:
References
50-269-89-13, 50-270-89-13, 50-287-89-13, NUDOCS 8906160003
Download: ML15224A537 (15)


Text

tREG UNITED STATES NUCLEAR REGULATORY COMMISSION REGION 11 101 MARIETTA STREET, ATLANTA, GEORGIA 30323

.**My 26%

Report Nos.:

50-269/89-13, 50-270/89-13, and 50-287/89-13 Licensee:

Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.: 50-269, 50-270, License Nos.: DPR-38, DPR-47, and and 50-287 DPR-55 Facility Name:

Oconee 1, 2, and 3 Inspection Conducted: May 8-11, 1989 Inspector:

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S S. S. Adamovitz ate Signed Approved by: 4 /

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$-,fb --f9 D. M. Collins, Acting Chief Date Signed Radiological Effluents and Chemistry Section Emergency Preparedness and Radiological Protection Branch

Division of Radiation Safety and Safeguards SUMMARY Scope:

This routine, unannounced inspection was conducted in the areas of liquid and gaseous effluents, environmental monitoring, plant chemistry, and confirmatory measurement Results:

No violations or deviations were identifie The licensee maintained an adequate program to control and monitor liquid and gaseous radioactive effluents (Paragraphs 4, 5, and 6).

A Radwaste group had been formed within the Chemistry department which was responsible for liquid tank sampling, release calculations and valve line-up for liquid release The licensee had formed an RIA System Working Group (Paragraph 5) to resolve problems with the facility's radioactive monitoring system. A nuclear station modification had been implemented to replace the station's entire RIA system with a digital radiation monitoring syste Progress was evident on the Unit 3 PALS II Plus system (Paragraph 8).

Gas stratification problems had been resolved and performance test results

continued to improve for the uni One follow-up item was identified F1)R 6PDC concerning installation and performance testing of the PALS II Plus system for Units 1 and The licensee had progressed on the completion of the new secondary laboratory facilities (Paragraph 11)

which would include an inline Dionex ion chromatograp The environmental group had pursued and corrected problems with environmental air sampling (Paragraph 9).

The number of air sampling deviations had been reduced from 20 in 1987 to 2 in 198 Monthly fuel status updates provided information concerning the current condition of the fuel (Paragraph 12).

SII

REPORT DETAILS 1. Persons Contacted Licensee Employees L. Benge, Supervising Scientist, Chemistry R. Bowser, Scientist, Radiation Protection

  • C. Boyd, Design Engineering, Site Office
  • S. Coy, Supervising Scientist, Radiation Protection
  • D. Davidson, Regulatory Compliance
  • Davis, Superintendent of Technical Services W. Elliot, Scientist J. Fletcher, Nuclear Chemistry Specialist L. Hawthorne, Nuclear Production Engineer B. Jones, General Supervisor E. Lampe, Associate Scientist, Radiation Protection G. Lareau, Reactor Engineer E. LeGette, Regulatory Compliance C. Mcllwain, General Supervisor, Station Sciences B. Norris, Productibn Engineer
  • B. Peele, Design Engineering Bn Sevic, Chemistry Manager R. Smith, Health Physics Specialist
  • M. Tuckman, Station Manager C. Yongue, Radiation Protection Manager NRC Resident Inspector
  • L. Wert
  • Attended exit interview 2. Licensee Action on Previous Enforcement Items (97202)

(Closed) 50-269, 270, 287/88-31-02:

Failure to have an approved procedure for the sampling of the condenser offga During a previous inspection conducted September 1988, the licensee failed to verify that the exhaust of the sampling line from the condenser offgas was returned to the gas header. At that time, instructions for the valve lineup of the sampling exhaust return were not contained in the sampling procedur During the current inspection, the inspector reviewed the revised procedure HP/O/B/1000/57, "Procedure for Quantifying Airborne Radioactivity,"

Change 13, dated April 24, 198 The procedure contained steps to ensure correct valve line-up for gaseous sample discharge back to the heade This item is considered close. Audits (84750)

The licensee maintained a program which included formal audits conducted by corporate personnel and informal quality control checks conducted by plant personne The inspector reviewed the audits NP-88-29 (ON),

"Chemistry Activities," conducted September 12 through October 5, 1988, and NP-89-02 (ON), Revision 1, "Health Physics, Environmental Monitoring, and Radwaste Shipment," conducted January 9-27, 1989. The inspector noted that the various program areas were audited against applicable sections of the plant's Technical Specifications (TSs), approved operating procedures, and regulatory requirement The audits identified findings and unresolved items and made recommendation Findings were tracked and resolved in a timely manne The licensee also conducted onsite checks using Section 8.1., "Review and Audit" of the Radiation Protection Manual (RPM).

The inspector reviewed the "Laboratory Quality Control Checklist,"

RPM 8.1, conducted October 31, 198 The checklist was primarily concerned with the status of laboratory instrumentation, supplies and equipmen No violations or deviations were identifie. Semiannual Radioactive Effluent Release Reports (84750)

a. The inspector reviewed the Semiannual Radioactive Effluent Release Reports for 1988 and discussed the reports with licensee representative The effluent information presented in Table A was obtained from current and previous effluent report Table A Effluent Release Summary for Oconee Units 1, 2, and 3 Activity Released (Curies)

1985 1986 1987 1988 1. Gaseous Effluents Fission and Activation 2.35E+4 2.43E+4 1.05E+4 2.59E+4 Products lodines and Particulates 6.14E-3 5.41E-2 1.58E-1 1.88E-1 2. Liquid Effluents Fission and Activation 4.16E0 5.85E0 2.90E0 3.10EO Products Tritium 1.24E+3 1.34E+3 9.49E+2 7.10E+2 Gaseous iodine and particulate releases continued to increase from 1985 to 1988, and the licensee attributed the increase to failed fuel in Units 2 and 3. Additionally, dose equivalent iodine (DEI)

had

increased for Units 2 and 3 due to failed fue Liquid effluents maintained the same levels from 1987 to 1988, or decreased slightly for tritiu b.

Two abnormal liquid releases were identified in the 1988 effluent report The inspector reviewed the plant's documentation and dose calculations concerning these release Investigation report OS-088-08-04 described an abnormal release which occurred November 14-15, 1988. Approximately 150 gallons of steam generator (SG)

cleaning solution containing 1.25 pounds of hydrazine were released to the Keowee River from the #3 Chemical Treatment Pon A vendor supplied system for processing the SG cleaning fluid was being utilized which consisted of an evaporator, a demister, a

condenser/scrubber, and a discharge tan The evaporator had automatically shut down due to high temperature, and the processing system had been restarted without sampling the discharge tank or ensuring that the discharge tank release valve was close The release was terminated and a whole body dose was calculated to be 2.1E-3 mrem based upon Cs-134 and Cs-137 activitie Corrective actions included retraining of plant and vendor personnel concerning actions following a spill, and ensuring that qualified technicians were used to perform the task A second abnormal liquid release occurred December 9, 1988, when approximately 100 gallons of condensate leaked from a faulty gasket in a heat exchanger line. The condensate contained hydrazine and low levels of Co-60, Cs-134, and Cs-137. A dose to the maximally exposed individual was calculated to be 1.8E-4 mrem. As corrective actions, the line was isolated and the faulty gasket replace No violations or deviations were identifie. Effluent Monitoring Instrumentation (84750)

a. The inspector, accompanied by a licensee representative, toured selected effluent monitoring stations and verified the operability of recorders and monitor readouts in the Control Room and Radwaste Buildin The inspector reviewed monitor calibrations for the following monitors:

1-RIA-44 Vent iodine monitor, September 29-October 4, 1988 1-RIA-45 Vent gas monitor, May 12-13, 1988 1-RIA-33 Liquid waste disposal (normal)

monitor, April 13-14, 1988 1-RIA-34 Liquid waste disposal (high) monitor, April 13-14, 1988 1-RIA-37 Waste gas disposal monitor, January 3, 1989

1-RIA-40 Air ejector vent monitor, May 27-31, 1988 2-RIA-45 Vent gas monitor, November 30, 1988 3-RIA-31 Low pressure service water monitor, June 14, 1988 3-RIA-35 Low pressure service water monitor, June 3, 1988 RIA-55 Interim radwaste vent iodine monitor, March 23-24, 1988 The examined records appeared complete and calibrations were performed within the required time perio b. The licensee had established an RIA System Working Group in 1988 to discuss and resolve problems with the facility's radiation monitoring system. The group typically met once or twice a month and attendees consisted of station and general office personne One result of the group's meetings was a coordinated program to replace the station's entire RIA system with a digital radiation monitoring syste The program would be implemented by a series of nuclear station modifications (NSMs) over a 5-year perio Initial modifications to be implemented' during 1989-1990 included installation of a control and data acquisition computer system and replacements of Units 1 and 2 RIAS 43-49, the unit vent and reactor building radiation monitor The licensee had established a schedule for replacement of the remainder of the monitors with an expected completion date of 199 c. The Units 1, 2, and 3 liquid monitors, RIA-35s, had been reported as being consistently inoperable since 1986 in the Semiannual Effluent Release Reports. The functions of RIA-31 and -35 were to monitor low pressure service water (LPSW)

which was used to cool several radioactive systems throughout the plan The RIA-31 sequentially monitored the low pressure injection (LPI)

coolers discharge (2 sample points),

the component cooling (CC)

cooler discharge (1 sample point),

and the reactor building cooling units (RBCUs)

discharge (3 sample points).

While the RIA-31 monitored one of the six discharge points, the RIA-35 collectively monitored the remaining five. The licensee had experienced consistent problems with low flow alarms on the RIA-31 and -3 An investigation determined that the low flow condition was caused by clogged sample lines and that the flow to the RIA-31 was minimal while flow to the RIA-35 was nonexisten During early 1988, the licensee had cleaned and/or replaced several sample lines, RIA coolers, and valves. Some sample lines were not replaced or cleaned at that time since these lines could not be isolated while the unit was on line. The licensee had also determined that the sampler could not correct for differing pressure among the six cooling system Therefore, the system with the highest pressure, the CC cooler, could isolate flow from the other systems if the pressure differential were large enoug The licensee had initiated NSM 2737 to upgrade the associated piping and

install pressure regulator The expected completion date for the NSM was January 199 The radiation detectors would not be replaced with this modification but would be upgraded as part of the station-wide monitor replacemen The Radwaste Facility noble gas vent monitors, 4-RIA-45 and -45, had been declared inoperable since January 198 The licensee had experienced design problems with the isokenetic sampler which had been corrected by an NS Further actions required to make the monitors operable were set point determinations and establishment of a sampling point for the charcoal cartridge and particulate filte The licensee planned to have the monitors in service by the middle of 198 No violations or deviations were identifie. Liquid and Gaseous Radwaste (84750)

a. The inspector discussed liquid and gaseous radwaste system operation and releases with licensee representatives. Effective February 1989, liquid radwaste releases were the responsibility of the Radwaste group located within the Chemistry departmen Formerly, all steps for a liquid felease were coordinated among various department Chemistry personnel were responsible for sampling the tan Health Physics (HP) personnel counted the samples and performed the release rate calculations, and Operations personnel performed the actual valve line-up to release the tan With the formation of the Radwaste group, tank sampling, release calculations, and valve line-up were performed by Radwaste personne Operations personnel were still required to initiate mixing flow through the liquid waste release (LWR)

mixing line or dilution flow from a Keowee Hydro uni The inspector discussed with licensee representatives the advantages of having one group responsible for liquid releases which included minimizing coordination problem The inspector reviewed the procedure CP/O/B/5200/45,

"Liquid Waste Release from RWF,"

dated January 25, 198 The procedure included steps to determine the monitor RIA-33 setpoint, perform tank sampling, calculate a release rate, and perform the valve line-up for the releas The licensee calculated three setpoints, upper, middle, and lower, which defined a range for the monitor readings. Monitor readings outside the range would result in an automatic trip for high range setpoint and an operator initiated trip for the low range setpoin The procedure required independent verification of the valve line-up prior to reinitiating the releas The inspector examined seven liquid waste release permits from October 1988 to March 1989, for releases from the Turbine Building Sump, Waste Monitor Tanks, and Decant Monitor Tan The release packages appeared complete with all procedural requirements fulfille The licensee prepared a monthly composite sample of the liquid waste releases for gross alpha, gross gamma, Fe-55, Sr-89, Sr-90, and H-3 analyses. The Duke Power general office

provided a monthly summary of doses from all plant effluents including liquid, gaseous, and solid radwast b. The inspector reviewed the procedure HP/0/B/1000/60/A,

"Waste Gas Decay Tank Sampling and Release Requirements," dated March 24, 1988, and examined seven gaseous waste releases from July 1988 to January 198 The procedure required a second sample if the Waste Disposal Gas monitors, RIA-37 and -38, were inoperable. All examined packages appeared complete per procedural requirement c. The inspector toured the Radwaste Building with a cognizant licensee representativ Currently, the facility was not being used to process any radioactive waste. Three 30,000-gallon holding tanks in the building were being utilized to dewater spent powdex resin from the plant's secondary system Primary spent bead resin was not being sent to the Radwaste facilit Processed liquid radwaste was held in the facility's monitor tanks and the liquid waste was released from these tanks through the monitor RIA-3 In 1988, the licensee had installed six sluicable demineralizer tanks in the Radwaste Building. During the current tour, the inspector noted that shielding had been added to the vessels but that the tanks had not yet been used for processing liquid radwaste. The licensee expected to have the tinks operational by mid-198 The facility was also equipped with a fluidized incinerator which would be able to process resin, oil, or dry active waste individually. The licensee was still completing tests on this system and planned further operational tests for later this year. The facility's evaporators and solidification process was not scheduled to be use No violations or deviations were identifie. Leak Testing of High Efficiency Particulate Air (HEPA) Filter and Charcoal Absorbers in Ventilation Treatment Systems (84750)

The inspector reviewed selected methyl iodide laboratory tests of charcoal samples for the reactor building purge, and the penetration room ventilation system conducted 1988-198 The inspector noted that results were within TS requirement The inspector also reviewed the results of in-place leak tests for these systems and the control room ventilation system and noted all system tests appeared to be adequat No violations or deviations were identifie. Post Accident Liquid Sampling (PALS) and Gaseous Sampling (PAGS) Systems a. The licensee had installed a new PALS system on Unit 3 during 198 During the previous inspection conducted September 1988, the licensee had not completed functional testing of the new PALS II Plus system and had had problems with gas stratification inside the sampling pane The problem with gas stratification had subsequently been resolved and the licensee had also redesigned the system to

accommodate two pH buffer tanks in order to provide a two point calibration for the inline pH mete A system modification still under consideration and testing was an automatic mechanism for extracting the liquid sample from the Rheodyne loop in order to minimize dos The inspector observed a test of the Unit 3 PALS II Plus system which included operation and collection of samples from the pane The results of the PALS system test and current reactor coolant analyses are presented in the following table along with the acceptance criteri Oconee Unit 3 PALS II Plus/Reactor Coolant Sample Results RCS PALS NUREG 0737 Current Test Acceptance Analysis Sample Data Criteria Gross gamma (uCi/ml)

4.89 3.381 Within a factor of two 15.902 Boron (ppm)

569 582

+/-10% above 500 ppm Hydrogen (cc/kg)

78

+/-15 cc/kg for less than 50 cc/kg pH 7.12 7.10

+/-0.3 pH units 1. Gamma activity for degassed liquid portion only 2. Gamma activity for degassed liquid portion plus stripped gaseous portio The inspector and a licensee representative discussed the applicability of including the gaseous activity from the degassed coolant sample in comparing PALS test data to routine reactor coolant activit Reactor coolant from the normal sampling point would automatically degas noble gases upon collection since the sample was no longer at reactor coolant system pressur The PALS system sampled reactor coolant, depressurized the liquid but collected the noble gases in the system's sample bom Counting the PALS system liquid and gaseous portions and then adding the two activities would yield higher activities for the PALS system's samples as compared to routine coolant sample The inspector reviewed the results of 19 operability tests for the PALS II Plus system conducted during 1988 which substantiated that the licensee had corrected the gas stratification proble The inspector also reviewed the results of the last operability tests for Units 1 and 2 PALS systems conducted March 22, 1989, for Unit 1 and May 10, 1989, for Unit All results met the licensee's acceptance criteria for comparison. The NUREG-0737 criteria were met with the exception of hydrogen for Unit 2. The licensee planned installation

of the new PALS II Plus system prototype for Units 1 and 2 during 198 The inspector informed licensee representatives that installation and testing of the PALS II Plus for Units 1 and 2 would be considered an inspector follow-up item (IFI).

IFI 50-269, 270, 287/89-13-01:

Installation and performance testing of PALS II Plus for Units 1 and b. The inspector reviewed selected 1988 and 1989 performance tests for the Units 1, 2, and 3 PAGS system At the time of the inspection, the licensee has six people qualified to operate the system. Several more personnel had been trained but had not maintained requalification by not retesting during the required time perio The licensee contacted the inspector May 17, 1989, and informed her that fifteen people had been requalified for a total of 21 personnel qualified to operate the PAGS system No violations or deviations were identifie. Environmental Monitoring (84750)

The inspector reviewed the licensee's Environmental Reports for 1987 and 1988, and discussed the reports with licensee representative Fewer sample deviations were identified for 1988 as compared to 198 During 1987, the licensee had reported 20 air sampling deviations primarily due to power interruptions, and attempted numerous corrective actions including installation of lightning suppressors, ceramic fuses, and surge suppressors. In September 1987, duplicate air samplers were placed at the sampling locations and the electrical circuits to the samplers were rewire These steps appeared to have corrected the problem since the licensee reported only two missing air samples for 198 The 1988 report identified increasing trends for selected radionuclides in shoreline sediment, which included Mn-54, Fn-65, Cs-137 =, and Cs-134. The licensee attributed these increasing trends to relocation of the sample collection point nearer the plant's discharge and to drought conditions which lowered the lake level Since shoreline sediment samples were required to be collected at the water's edge, the lower lake levels caused samples to be collected at locations usually submerged where sediment deposition was normally greate No violations or deviations were identifie.

Confirmatory Measurements (84750)

The licensee was provided with a simulated liquid waste sample by the NRC contract laboratory in January 1989, and was requested to complete radiochemical analyses for H-3, Fe-55, Sr-89, and Sr-90 concentration Comparison of licensee and NRC results are listed in Attachment 1 with the acceptance criteria listed in Attachment 2. Results were in agreement for

all isotope Additionally, the licensee was provided a Co-60 spiked liquid to resolve disagreements which occurred in a September 1988 confirmatory measurements inspection. These results are also presented in Attachment A. During the September 1988 inspection, the licensee's Co-60 results for liquid samples were 52% to 71% of the NRC's values, and in disagreemen All other isotopes for the liquid samples showed agreemen For the current Co-60 spike, all licensee results were in agreement and ranged from 75% to 136%

of the known value The inspector also reviewed the results of the licensee's crosscheck program for the latter part of 1988 and 1989, and noted close agreement to known values for liquid sample Additionally, the inspector reviewed the licensee's 1989 calibrations as compared to 1988. Typical efficiency changes for Co-60 peaks in the liquid geometries were less than 10%.

No violations or deviations were identifie.

Secondary Chemistry Laboratory (84750)

The inspector toured the licensee's new secondary laborator The lab contained sample sinks for the collection of secondary system samples, an inline ion chromatograph, other inline instrumentation for measuring secondary system parameters, and a data acquisition system for monitoring and storing dat Inline instrumentation measured conductivity, sodium, oxygen, hydrazine, and chloride with digital readout monitors located in the laboratory are The laboratory also contained a sample preparation area and had been functional since the end of January 198 The ion chromatograph was not yet installed but was expected to be connected inline during the mont No violations or deviations were identifie.

Plant Chemistry and Fuel Integrity (84750)

The inspector reviewed selected records of primary coolant radiochemical parameters for the past eight months which included isotopic cesiums and iodines. Currently, typical DEI values were E-2 uCi/ml for Unit 1 and E-1 uCi/ml for Units 2 and The inspector reviewed the "Duke Fuel Reliability Program Document,"

Revision 2, November 1988, which described the organization responsibilities, methods for data acquisition and evaluation, and action levels based upon DEI activity level The fuel reliability program was also described in Section 4 of the station's "Performance Manual."

This document provided guidance for evaluating radiochemistry data in order to identify the extent of fuel failure and identified action levels for maintaining plant operation with failed fue Unit 1 had experienced some failed fuel during Cycle 11 (December 1987 January 1989).

Iodine-131 (1-131) activity for the three previous fuel cycles averaged E-3 uCi/m During Cycle 11, the unit's 1-131 activity increased from E-4 uCi/ml to 2E-1 uCi/ml after a week at full power, which

indicated new failures had occurre The 1-131 level peaked and slowl decreased to a value of 4E-2 uCi/ml during November 198 This 1-131 level indicated 10 to 13 leakers and the iodine ratio further indicated large defect Based upon the unit's previous experience with little or no failed duel and consistently low 1-131 values, the licensee performed a full core ultrasonic examination during the January 1989 outag The ultrasonic testing identified two defects which were corrected. There was no indication of failed fuel in Unit 1 during the current fuel cycl Unit 2 had experienced problems with failed fuel during Cycle 7, and iodine levels had been in the range of E-1 uCi/ml for the past three fuel cycle The current elevated iodine levels were though to be caused by carry over of leakers from Cycle 7. The licensee had been replacing the Cycle 7 fuel during the subsequent outages to remove the failed fue Unit 2 was currently in fuel Cycle 10 with a refueling outage scheduled for May 198 Unit 3 had also maintained problems with failed fuel which occurred in 1987. A reactor coolant pump failed and portions of the pump were sheared off causing debris to be scattered throughout the cor Iodine levels indicated from 10 to 20 leakers had been generated and the case was assumed to be debris inducted frettin Currently, the iodine levels were stable at E-1 uCi/ml which indicated no new failures had occurre No violations or deiations were identifie.

Licensee Action on Previous Follow-up Items (92701) (Closed)

IFI 50-269, 270, 287/88-26-01:

Track modifications and complete testing of the PALSSI The PALS II Plus system (Paragraph 8.a.)

had been installed and the gas stratification problems with the panel corrected. This item is considered close (Closed)

IFI 50-261, 270, 287/88-31-01:

RESL spike samples for resolving disagreements in Cd-109 in charcoal cartridge and Co-60 in 50 and 1000 ml liquid geometries. The licensee successfully analyzed the supplied liquid spike for Co-60 (Paragraph 10.b.).

The inspector reviewed the licensee charcoal cartridge calibrations for 1988 and 1989, and noted less than 10% difference between the two year The licensee had additionally analyzed several cartridges spiked with Ba-133 which was used as a substitute for 1-13 Analytical results showed close agreement. This item is considered close.

Exit Interview The inspection scope and results were summarized on May 11, 1989, with those persons indicated in Paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results listed below. No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspectio The licensee maintained an adequate program to control and monitor liquid and gaseous radioactive effluents (Paragraphs 4, 5, and 6).

A Radwaste group had been formed within the Chemistry department which was responsible for liquid tank sampling, release calculations and valve line-up for liquid release The licensee had formed an RIA System Working Group (Paragraph 5) to resolve problems with the facility's radioactive monitoring system. A nuclear station modification had been implemented to replace the station's entire RIA system with a digital radiation monitoring syste Progress was evident on the Unit 3 PALS II Plus system (Paragraph 8).

Gas stratification problems had been resolved and performance test results continued to improve for the uni One IFI was identified concerning installation and performance testing of the PALS II Plus system for Units 1 and The licensee had progressed on the completion of new secondary laboratory facilities with an inline Dionex ion chromatograph (Paragraph 11).

Monthly fuel status updates provided information concerning the current condition of the fuel (Paragraph 12).

The confirmatory measurement results for beta emitters were reviewed (Paragraph 10).

All results were in agreemen Two IFIs (Paragraph 13) and one violation (Paragraph 1) were reviewed and close ATTACHMENT 1 NRC-LICENSEE SAMPLE COMPARISON EVALUATION FOR SPIKED SAMPLES PROVIDED JANUARY 1989 CONCENTRATION SAMPLE ISOTOPE LICENSEE NRC RESOLUTION LICENSEE/NRC COMPARISON 1. NRC Spike H-3 1.6E-5 1.88 t.06E-5

0.85 Agreement Sr-89 7.5E-5 8.01 +/- 0.24E-5

0.94 Agreement Sr-90 4.1E-6 4. 34 +/- 0.17E-6

0.94 Agreement Fe-55 1.98E-5 2.03 +/- 0.06E-5

0.98 Agreement NRC Gamma Spike a. 1000 ml geometry Detector 2018 #1 Co-60 1.79E-4 1.31 +/- 0.15E-4

1.37 Agreement Detector 1641 #2 Co-60 1.12E-4 1.31 +/- 0.15E-4

0.85 Agreement Detector 1957 #3 Co-60 1.25E-4 1.31 +/- 0.15E-4

0.95 Agreement Detector 1716 #1 Co-60 1.21E-4 1.31 +/- 0.15E-4

0.92 Agreement Detector 1692 #2 Co-60 1.51E-4 1.31 +/- 0.15E-4

1.15 Agreement Detector 1735 #3 Co-60 9.88E-5 1.31 +/- 0.15E-4

0.75 Agreement b. 50 ml geometry Detector 2018 #1 Co-60 1.33E-4 1.31 +/- 0.15E-4

1.02 Agreement Detector 1641 #2 Co-60 1.14E-4 1.31 +/- 0.15E-4

0.87 Agreement Detector 1957 #3 Co-60 1.29E-4 1.31 +/- 0.15E-4

0.98 Agreement Detector 1716 #1 Co-60 1.22E-4 1.31 +/- 0.15E-4

0.93 Agreement Detector 1692 #2 Co-60 1.14E-4 1.31 +/- O.15E-4

0.87 Agreement Detector 1835 #3 Co-60 1.21E-4 1.31 +/- 0.15E-4

0.92 Agreement

ATTACHMENT 2 CRITERIA FOR COMPARISONS OF 'NALYTICAL MEASUREMENTS This attachment provides the NRC's criteria for the comparison of results of analytical radioactivity measurements. These criteria are based on empirical relationships which combines prior experience in comparing radioactivity analyses, the measurement of the statistically random process of radioactive emission, and levels of egreement in radioactivity measurements acceptable to the NR In these criteria, the "Comparison Ratio Limits".' denoting agreement or disagreement between licensee and NRC results are variabl 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. As the numerical value of "Resolution" increases, the range of acceptable variations or differences between the NRC and licensee analytical becomes smaller or more restrictive. Conversely, as the value of "Resolution" decreases, a wider and less restrictive variation or difference between the NRC and licensee analytical values is considered acceptabl For comparison purposes, a ratio between the licensee's analytical value and the NRC's analytical v.alue is computed for each radionuclide present in a given sample. The computed ratios are then evaluated for agreement or disagreement based on "Resolution."

The corresponding values for "Resolution" and the

"Comparison Ratio Limits" are listed in the Table belo 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 Ratio = Licensee Value NRC Reference Value 2Resolution = NRC Reference Value Associated Uncertainty