IR 05000282/1998019

Insp Repts 50-282/98-19 & 50-306/98-19 on 981013-16.No Violations Noted.Major Areas Inspected:Review of Chemistry Program Re Plant Water Quality & Analytical Capabilities

ML20155D139
Person / Time
Site:	Prairie Island
Issue date:	10/29/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20155D129	List: IR 05000282/1998019 ML20155D127
References
50-282-98-19, 50-306-98-19, NUDOCS 9811030124
Download: ML20155D139 (15)

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l U.S. NUCLEAR REGULATORY COMMISSION l REGION lli l

l Docket Nos: 50-282; 50-306  !

License Nos: DPR-42; DPR-60 i I

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Report Nos: 50-282/98019(DRS); 50-306/98019(DRS)

Licensee: Northern States Power Company Facility: Prairie Island Nuclear Generating Plant

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Location: 1717 Wakonade Dr. East Welch, MN 55089 l

Dates: October 13-16,1993 l

Inspectors: R. Glinski, Radiation Specialist M. Mitchell, Radiation Specialist Approved by: G. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety

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98i1030124 981029 PDR ADOCK 05000282 G PDR

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EXECUTIVE SUMMARY Prairie Island Nuclear Generating Plant

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NRC Inspection Reports 50-282/98019; 50-306/98019 l This inspection consisted of a review of the chemistry program as it relates to plant water l

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quality and analytical capabilities, the Offsite Dose Calculation Manual (ODCM) and the subsequent implementation of the Radiological Environmental Monitoring Program (REMP),

l selected radiation protection controls, and self-assessment activities. The inspection resulted in j the following conclusions:

The REMP program and the land use census were well implemented, and the 1997 data j

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demonstrated that there was no discernable impact on the environment from plant operations. The plant's lower limits of detection (LLD) for drinking water were inconsistent with NRC guidance and industry standards, and plant personnel planned to revise the ODCM to meet the regulatory guidance (Section R1.1).

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Plant water quality for both the primary and secondary systems remained excellent.

j There were notable improvements in secondary system chemistry through effective

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management of the ion exchange equipment and the plastic coating of 50% of the condenser tubesheet (which will be applied to the untreated portions during the next outage). The hideout return studies confirmed improved secondary water quality and indicated minimal steam generator fouling (Section R1.2).

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Chemistry sampling lines were maintained in good operating condition. Throughout the plant, radiological postings and controls were generally well maintained and associated surveys were well performed. The inspectors observed good work practices and no significant radiological impediments to routine work were identified (Section R1.3).

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Plant personnei alertly analyzed soil excavated from a landlocked area to the applicable environmental LLDs and detected very low concentrations of plant radionuclides. The contaminated soil was stored properly and the inspectors discussed with management that the ODCM should be revised to include this newly found effluent pathway. The licensee has included the landlocked area in its 10 CFR 50.75(g) file (Section R2.1).

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Chemistry personnel were knowledgeable of their various responsibilities, demonstrated good laboratory practice, and displayed ownership of chemistry department activitie The analytical performance of the chemistry staff was excellent as evidenced by blind quality control data for a variety of analytes (Section R4.1).

a Overall, the quality assurance activities and materiel condition of the laboratory and

! process instrumentation were excellent, as evidenced by quality control checks and L laboratory intercomparison data. In addition, the control of standards and reagents was l effective (Section R7.1).

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A comprehensive chemistry /REMP self assessment program was conducted by plant personnel. These actions identified areas for improvement and the identified issues were appropriately followed up for proper resolution (Section R7.2).

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in response to hot particle contaminations during the forced outage, the radiation protection staff took appropriate steps to identify the scope and source of the contamination and the radworker dose due to the contaminations. Plant personnel then established specific corrective actions to address the root cause, and their response to this incident demonstrated a thorough and effective management of emergent radiation protection issues (Section R7.3).

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Reoort Details

- IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls R Imolementation of the Radioloaical Environmental Monitorina Proaram (REMP1 Inspection Scope (IP 84750)

The inspectors reviewed the 1997 Annual Radiological Environmental Monitoring Report, the Offsite Dose Calculation Manual (ODCM), and the Technical Specifications (TS). The inspectors also observed air particulate / iodine and surface water sampling, and interviewed various plant staff regarding the operability and materiel condition of the sampling equipment and implementation of the REM Observations and Findinas l

! The inspectors observed that the REMP sample collector's air and water collection techniques ensured sample integrity and he was knowledgeable of appropriate sampling principles. The collector appropriately labeled and packaged the samples, and he also !

properly tested the air sampling train for leakage. The water sampling was conducted appropriately, as the container was rinsed with the sample media prior to sample ,

collection, as required by procedure. During interviews, this individual indicated that I recent problems due to condensation on air sampling components were easily solved by l placing plastic bags over the affected components. The inspectors determined that the REMP sample collector was sufficiently knowledgeable of sampling requirements, equipment, and transport; and no operability or materiel condition issues regarding the

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sampling equipment were identified. The inspectors observed that some of the l vegetation around the P-4 air sample location could potentially impede air flow to the sampler. Plant personnel acknowledged this observation and have made plans to address this issu The inspectors noted that the 1997 REMP was submitted by the TS-required date and that the report contained the information required by the ODCM. The report listed problems with either the collection or analysis for only six of the required samples (one i milk and five air), and since the reasons for these deviations were primarily weather related or were due to the strike of the contract carrier for the samples, specific actions '

to prevent recurrence were unnecessary. Plant staff properly maintained the air sampling equipment and flow calibrations with a secondary standard. The calibrations were performed quarterly to ensure that sample flow was accurately determine The inspectors noted that the required lower limit of detection (LLD) in the ODCM for iodine-131 (1-131) and tritium were listed as 15 and 3000 picoeuries per liter (pCi/l),

respectively, since no drinking water pathway existed. However, during interviews with plant personnel and REMP data review, the inspectors noted that while a municipal

! drinking water sample was collected, groundwater from various wells was also used as

drhking water. The inspectors discussed with radiation protection (RP) management

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that NRC guidance in a Branch Technical Position and in NUREG-0472, " Standard Radiological Effluent Technical Specifications of PWRs", stated that the appropriate LLDs for these radionuclides in samples from a drinking water pathway were 1.0 and 2000 pCi/l, respectively; and that water used as drinking water should be analyzed to the more stringent drinking water pathway LLDs. The applicable water samples are currently analyzed to LLDs of 1.0 and 175 pCi/l such that a change in station practice was not required, however the appropriate LLDs were not required by the ODCM. Plant personnel indicated that the ODCM requirements would be revised to be consistent with industry standards and NRC guidance. This planned ODCM change, along with the potential ODCM change discussed in Section R2.1, will be reviewed as an Inspection Followup Item (IFl 50-282/ 98019-01; 50-306/98019-01)

The REMP program included the collection and analysis of air, water, vegetation, fish, aquatic invertebrates, and bottom and shoreline river sediment. Thermoluminescent dosimeters (TLD) were used to measure direct radiation and were exchanged quarterl The quality assurance data of the vendor radioanalyticallaboratories demonstrated excellent analytical capabilities. The results from the REMP sampling and analyses, including the analyses of supplemental onsite and offsite groundwater wells, indicated that plant operations did not have a discernable radiological impact on the environmen The inspectors compared the 1996 and 1997 Land Use Census data to ensure that the preparation was in accordance with the ODCM and that proper reviews for changes that could affect the assessment of offsite doses were conducted. No changes to the ODCM sampling locations from 1996 were identified as a result of the Land Use Census and the offsite dose modeling did not require any changes from the previous yea Conclusions The REMP program and land use census were well implemented, and the 1997 data demonstrated that there was no discemable impact on the environment from plant operations. The inspectors noted that the required LLD for drinking water was inconsistent with NRC guidance and industry standards, and plant personnel planned to revise the ODCM to meet regulatory guidance.

R1.2 Contrcl of Plant Water Quality Inspection Scooe (IP 84750)

The inspectors reviewed the Updated Safety Analysis Report (USAR), water quality procedures, primary and secondary water quality data for the past year, and hideout return studies from both units. The inspectors also interviewed plant personnel regarding past and future actions to improve plant water qualit Observations and Findiggg Primary and secondary (blowdown, feedwater, and condensate) water quality data for both units showed that chemical contaminants during power operations were controlled well within plant USAR and procedural requirements, which were consistent with the

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Electric Power Research institute (EPRI) Action Level 1 guidelines. The data also showed that reactor coolant chemicals for reactivity control (boron), pH control (lithium),

and corrosion control (hydrogen pressure) were maintained within acceptable limit There were occasional instances when deviations from various water quality levels occurred, and these were due to maintenance activities such as primary system valve tests during downpowers and steam generator (SG) flash tank inspections or a change of a SG blowdown filter. Licensee staff re-established the proper levels in a timely manne i For a few weeks in early 1998, the hydrogen detector indicated that the Unit 1 hydrogen levels in the reactor coolant exceeded the USAR value of 35 cubic centimeters per kilogram of water. The staff determined that the detector was not functioning properly, I as it had been " flooded * during the unit startup. After the detector was dried and I cleaned, the values returned to the acceptable band. During this process, the staff maintained the volume control tank pressure to produce the expected hydrogen leve: Trending of Dose Equivalent lodine (del) and xenon and argon gas levels indicated that there were no fuelintegrity issue The excellent water quality of the secondary system was maintained through a combination of actions. The staff managed the change out of the ion exchange beds by monitoring for flouride breakthrough, as increased flouride would not contribute to system corrosion. Also, the treatment of 50% of the condenser tubesheet with a plastic coating effectively reduced condenser inleakage. Plant personnel have planned to coat ,

the remainder of the condenser tubesheet during the next outag l The inspectors reviewed SG hideout return data for both units and the data indicated significant reductions in contaminant return levels. The total return levels, coupled with the very slight prompt return of the contaminants, demonstrated that the contaminant levels in the SGs were extremely low. In addition, the calculated Molar Ratio Index (MRI) for each of the SGs indicated that the pH in the crevices would be near neutral, which was a notable improvement over previous retum studies. Therefore, based on this combination of data, the chemical fouling of the SGs would be minima The chemistry staff recently initiated a quarterly report which presents primary system radiochemistry data in categories such as corrosion products, control rod wear products, and fission products which should enable plant management to better recognize trends and improve assessment of the primary syste c. Conclusions Plant water quality for both the primary and secondary systems remained excellen There were notable improvements in secondary system chemistry through effective management of the ion exchange equipment and the partial plastic coating of the condenser tubesheet (which will be applied to the untreated portions during the next outage). The hideout return studies confirmed improved secondary water quality and indicated minimal SG fouling.

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I R1.3 Radioloalcal Controls within the Radioloaically Controlled Area (RCA) Insoection Scope (IP 83750)

The inspectors accompanied an RP Technician (RPT) during a routine plant walkdown to determine whether RP controls were effective. The walkdown was conducted throughout the Auxiliary Building and the Radwaste Storage Building. The inspectors also reviewed chemistry sample line materiel condition during the walkdow Observations and Findinas The inspectors noted that all sample lines and fittings were in good condition and without observable degradation or leaks. All radiation protection instrumentation observed in the plant was operable and within calibration. All personnelin the RCA were observed in compliance with good radiation protection practice, using time, i distance and shielding as well as appropriate contamination protection practices. All l

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postings for Radiation Areas, High Radiation Areas, and Locked High Radiation areas were appropriate. Radiation surveys conducted by the inspectors did not identify any ,

incorrectly posted areas, and all Locked High Radiation Areas were found in the locked ,

conditio ! Conclusions Chemistry sampling lines were maintained in good operating condition. Radiological ]

postings and controls were generally well maintained and associated surveys were well l'

performed. The inspectors observed good work practices and no significant radiological impediments to routine work were identifie R2 Status of RP&C Facilities and Equipment R Identification of a New Effluent Pathway Insoection Scooe (IP 84750) '

The inspectors observed the landlocked area used for discharges of condenser water under specific circumstances. The inspectors also reviewed the licensee's 10 CFR 50.75(g) file and interviewed plant personnel regarding this new effluent pathwa Observations and Findinas The inspectors discussed the periodic discharge of water drained from the condenser to an area designated as the landlocked area, which was similar to a drainage ditc )

These discharges occurred during refueling outages when the suspended solids in the l condenser drainage water were high. Under these circumstances, the licensee was prohibited by a State agency from discharging this water into the river, which was the i routine effluent point. Therefore, the licensee then discharged this condenser water to l the landlocked area. This water was analyzed for radionuclide content prior to discharge, but the results were below the applicable effluent LLD ._

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i As part of a modification of the landlocked area, the licensee excavated a significant l amount of soil. Gamma spectrometry of the soil to the appropriate environmental LLDs :

4 detected low levels of plant radionuclides (cobalt-60, cesium-134, and cesium-137 at J 10 4microcuries per gram) in some of the soil. These nuclides were detected to a j

, depth of approximately 45 centimeters at the near side of the landlocked area, and to a length of approximately 60 meters from the discharge point. The depth of the contamination decreased down the length of the landlocked area from the discharge point. The licensee packaged this contaminated soil and stored the containers in the .

l barrel yard of the radwaste building. The soil which contained only cesium-137 at near background levels (from weapons fallout) was planned to be placed back into the landlocked area. The licensee will make record of this soil return in the 10 CFR 50.75(g) required file. The contaminated portion of the landlocked area was within the protected area, but this drainage area extended into the owner controlled area beyond the protected area fenc Based on discussions with plant personnel, the radioanalytical results of the landlocked I l area soil, and past radiochemical analyses of turbine building sump sludge (IR 97017), l the inspectors determined that the extremely low levels of radionuclides in the

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l condenser drain water were being accumulated and concentrated by the landlocked

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area soil. As these discharges occurred on a periodic basis, the inspectors discussed with RP management that this practice should now be considered an effluent pathway l

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, and that a description should be included in the ODCM. Plant personnel indicated that

this would be included in the ODCM. This potential revision of the ODCM, along with the ODCM change stated in section R1.1, will be tracked as an Inspection Followup Item ,

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(IFl 50-282/98019-01; 50-306/98019-01).

In addition, the inspectors reviewed the file that RP staff had prepared in accordance with 10 CFR 50.75(g) and a dose assessment for the condenser water effluents to the landlocked area. The 10 CFR 50.75(g) file contained the appropriate landlocked area

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information and the staff's dose assessment used appropriate methodology, i

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Plant personnel alertly analyzed soil excavated from the landlocked area to the environmental LLDs and detected very low concentrations of plant radionuclides. The contaminated soil was stored properly and the inspectors discussed with site staff that the ODCM should be revised to include this newly found effluent pathway. The licensee j

has included the landlocked area in the 10 CFR 50.75(g) fil R4 Staff Knowledge and Performance in RP&C R Performance of Chemistry Samole Collection and Analysis Inspection Scope (IP 84750)

The inspectors interviewed chemistry staff and observed chemistry sampling and analysis activities. The inspectors also interviewed chemistry supervisory staff and reviewed chemistry technician proficiency data for laboratory analyse .

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. Observations and Findinas The inspectors observed that plant chemistry samples (primary and secondary water)

were collected appropriately. The chemistry technician (CT) was experienced and knowledgeable regarding proper sample collection, analysis, and general laboratory practices. The CT also effectively used the chemistry laboratory database system to log quality control (QC) and analytical results. The inspectors observed that the materiel condition of the sampling panels was excellent and that CT ownership was evident for the chemistry wor Although the chemistry department did not have a formalintracomparison program, the daily QC checks for a variety of analytes on the different laboratory instruments were conducted with standards having chemical concentrations which were unknown to the cts. The concentrations of these " blind" QC daily check standards were changed regularly. For the past year, this trended QC data indicated that the cts analytical performance was excellent. The inspectors noted that the sodium analysis by atomic absorption, with approximately 5% of the QC results outside the acceptance level, had the highest failure rate. In addition, the inspectors noted a positive bias in the boron titration QC results. Chemistry supervision indicated that this bias was caused by the autotitrator's delivery of approximately 1.5% more sample than expected. This method was used for boron analysis of the primary system and the purchase of a new autotitrator has been planne Conclusions Chemistry personnel were knowledgeable of their various responsibilities, demonstrated good laboratory practice, and displayed ownership of chemistry department activitie The analytical performance of the cts was excellent as evidenced by blind QC data for a variety of analyte R7 Quality Assurance in RP&C Activities R7.1 Quality Assurance / Quality Control for Laboratorv instrumentation and Analyses Inspection Scooe (IP 84750)

The inspectors reviewed chemistry quality assurance / quality control (QA/QC) data for 1 both chemistry and radiochemistry laboratory instrumentation, and also interviewed chemistry staff regarding overalllaboratory QA/Q Observations and Findinas The inspectors reviewed the QA/QC data for the following instruments / methods and their associated analyses:

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lon Chromatography - sulfate, chloride, flouride, sodium, boron , lithium

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Wet chemistry / titration - boron

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Ultraviolet / visible spectrometry - silica

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Gamma Spectrometry - gamma emitting isotopes in air and coolant

. Liquid Scintillation Counter - tritium in effluent air

. Atomic Absorption - sodium, feedwater iron

! The QC data for process instrumentation and for chemical and radiochemical laboratory l instrumentation indicated that instrument performance had remained within acceptable i statistical parameters. The staff effectively utilized QC charts to trend instrument

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l performance, and the chemists reviewed the data regularly to check for biases, trends, and outliers; and to initiate corrective action. As an example, in response to anomalous efficiency and resolution data for the germanium detector #1, which was located at access control, the chemistry staff determined that the instrument electronics were overheating. The cabinet was subsequently rearranged and also modified to prevent this phenomenon. There were no recurrences of this proble The counting room staff tracked peak area, peak width, and peak location to gauge the i gamma spectrometry system performance. The liquid scintillation counter QC data

! were also reviewed regularly for any adverse trends. The QC charts demonstrated that laboratory instrumentation performance was excellent. The calibrations and annual verifications of the radiochemicalinstruments utilized commercial radionuclide standards which were traceable to the National Institute for Standards and Testing (NIST). The inspector noted that the mcot recent calibrations were conducted appropriately and comparison to previous calibration data showed that the radiochemistry instruments have remained stabl The laboratory participated in QA interlaboratory comparison programs for both chemical and radiochemical analyses. For 1997, the radiochemistry intercomparison results were excellent, as all reported values were in agreement with the known value The chemistry intercomparison results passed at an 80% level, with some problems encountered for anions in the primary system matrix. The chemistry staff indicated that a recent analytical method change, which passed the intercomparison sample through a cation resin prior to analysis (which reflects the method used for plant chemistry

, samples), should lead to improved performance in the intercomparison program. The l Inspectors noted that this change was appropriate. The materiel condition of the

' laboratory and process instrumentation was very good, and all laboratory reagents were within the prescribed shelf lif Conclusions  !

Overall, the QA/QC and materiel condition of the laboratory and process instrumentation l_ were excellent, as evidenced by QC checks and QA intercomparison data. In addition, i the control of standards and reagents was effective.

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l l R7.2 Chemistry /REMP Proaram Audits and Self Assessments

a. Insoection Scoce (IP 84750)

The inspectors reviewed the chemistry /REMP self-assessments, management

observations of training and field activities, and observation reports prepared by i

Generation Quality Services (GQS) staf b. Observations and Findinas  !

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The inspectors noted that both REMP/ chemistry management and GQS auditors had conducted numerous observations of field work, such as REMP/ effluents sampling, laboratory QA/QC activities, data reports, ODCM setpoints, and training. The audits found that plant requirements and expectations were generally met by the site staf i However, a chemistry self-assessment determined that five procedures should be

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l changed to indicate proper practice, and a procedure for the collection of an air ejector gas grab sample did not exist. The staff effectively followed up and resolved these j issues. The management observations of classroom training indicated that the i mstructor's performance was generally satisfactory, and that the training was effective.

l l In addition, a corporate health physicist conducted an historical assessment of the l REMP program. This individual concluded that the REMP included appropriate l environmental media collection and analysis, but recommended an air campler be added at the nearest residence. The RP management was reviewing this potential l addition to the REMP. This corporate health physicist also accompanied an audit of the REMP contract laboratory in 1995, during which no problems were identified.

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c. Conclusions A comprehensive chemistry /REMP self-assessment program was conducted by plant personnel. These actions identified areas for improvement and the issues were

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I R7.3 Performance of the Error Reduction Task Force (ERTF) in Support of RP issues

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a. Insoection Scooe (IP 83750)

l The inspectors reviewed the licensee's ERTF Report 98-08. The inspectors also interviewed task force members to clarify the corrective action plans related to an incident where hot particle contaminations were identified following the cleaning of the incore instrumentation (ICl) syste Observations and Findinos The licensee identified " hot particle" sources during an ICI system cleaning job in the Unit 1 containment on June 12,1998, which was during a forced outage. The ICI cleaning was performed to remove small particles and grit from the thimbles which would allow for easier detector movement. Thirteen separate personnel contaminations

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occurred during this evolution, involving eleven workers. The highest skin dose to any l

individual was 205 millirem, indicating that the actual radiation exposures were not !

significant. Although the safety significance was low, the RP staff determined that this job warranted further analysis and corrective action, and this issue was subsequently forwarded to the ERTF for revie The ERTF reviewed past ICI system cleanings and found a possible correlation with hot particles and thimble tube work conducted in 1992. The ERTF concluded that the cause for the 1998 contaminations was identified because the work during the forced outage was limited, thus making the correlation more easily recognizabl The inspectors reviewed the chronology of events and summary of factors that influenced human performance surrounding the event. The review of the ERTF report confirmed a good process for root cause identification. This report also identified weaknesses in written communications, work practices, work organization and planning, supervisory methods, training and qualifications, and the ability to manage change. The report also outlined specific corrective actions for each weakness. The inspectors determined that the recommended corrective actions properly addressed the root causes for these contamination Conclusions l

The licensee identified hot particle contaminations during the forced outage, and took appropriate steps to identify the scope and source of the contamination and the radworker dose due to the contaminations. The licensee's assessment of this evolution ;

established specific corrective actions to address the root cause, and their response to this incident shows a thorough and effective management of emergent RP issue V. Management Meetings XI Exit Meeting Summary The inspectors presented the inspection results to members of licensee management on October 16,1998. The licensee acknowledged the findings presented and did not identify any of the information reviewed as proprietar _ _ . _ _ _ _ .

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l PARTIAL LIST OF PERSONS CONTACTED  ;

l Licensee Personnel l M. Agen, REMP Coordinator D. Gauger, Senior Plant Chemist

- A. Johnson, Radiation Protection Supervisor D. Larimer, Radiochemistry Supervisor S. Lappegaard, Radiochemistry Supervisor D. Shuelke, Radiation Protection Manager J. Sorenson, Plant Manager NRC Personnel P. Krohn, Resident inspector S. Thomas, Resident inspector l i

l INSPECTION PROCEDURES USED

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IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 83750 Occupational Radiation Exposure ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-282/98019-01 IFl Planned changes to the ODCM to be consistent with NRC guidance regarding drinking water LLDs and effluent pathways !

50-306/98019-01 1

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LIST OF ACRONYMS USED

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CFR Code of Federal Regulations CT Chemistry Technician DEI Dose Equivalent lodine EPRI Electric Power Research Institute ERTF Error Reduction Task Force GQS Generation Quality Services ICI incore Instrumentation LLD Lower Limit of Detection MRI Molar Ration index NIST National Institute For Standards and Testing ODCM Offsite Dose Calculation Manual pCi/l picoeuries per liter QA/QC Quality Assurance / Quality Control RCA Radiologically Controlled Area REMP Radiological Environmental Monitoring Program RP Radiation Protection RP&C Radiological Protection and Chemistry RPT Radiation Protection Technician SG Stea.n Generator TLD Thermoluminescent Dosimetry TS Technical Specifications USAR Updated Safety Analysis Report

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PARTIAL LIST OF DOCUMENTS REVIEWED Updated Safety Analysis Report, Table 4.1-9, Typical Reactor Coolant Water Chemistry Technical Specifications, Section 6.7.5.C - Environmental Reports Offsite Dose Calculation Manual 1997 Annual Radiological Monitoring Report Radiation Protection implementing Procedure (RPIP) #4731, Revision 5, "REMP Air Samp'ing" RPIP #3006, Revision 3, " Primary Water Chemistry Guidelines" RPIP #3002, Revision 5, " Secondary Water Chemistry Guidelines" Unit 1 Cycle 18 Operation and Hideout Return Evaluation, dated December 31,1997 Unit 2 Forced Outage Hideout Return Evaluation, dated February 27,1998 Tritium Groundwater Sampling Results, dated July 14,1998 Indian Community Well Water Tritium Results for 1998, dated L Y her 3,1998 Dose Rates from Excavated Landlocked Area Soil, dated October 1,1998 Radiochemistry EBAR Analysis Results, dated September 14,1998 1997 Chemistry Self-Assessment Trip Report-Visit to Teledyne Brown isotopes Midwest Lab, September 21-22,1995 GOS Observation Reports 1998089,1998142,1998132,1998150,1998154,1998159, 1998084,1998079,1998056,1998088,1998057

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