IR 05000298/1981011
| ML20040G860 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 01/26/1982 |
| From: | Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20040G856 | List: |
| References | |
| 50-298-81-11, NUDOCS 8202160547 | |
| Download: ML20040G860 (16) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket:
50-298/81-11 License:
DPR-46 License:
Nebraska Public Power District P. O. Box 499 Columbus, NE 68601 Facility:
Cooper Nuclear Station Inspected at:
Cooper Nuclear Station, Brownville, Nebraska Inspection Conducted: June 15-19, 1981 Inspector:
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// /,,!rs B. Nicholas, R(diation Specialist Ddte
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Approved by:
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//M/TV BlaineMurray, Chief,FacilityRgdiation
/ Dats Protection Section V
Inspection Summary Inspection conducted during the period of June 15-19, 1981 (Report 50-298/81-11)
Areas Inspected:
Routine, announced inspection of the licensee's radio-chemistry measurements program including sample collection, sample treatment and analysis, chemistry analytical procedures, laboratory instrument calibration and quality controls, licensee audits, and independent measurements by the inspector.
The Regica IV mobile counting laboratory was utilized for onsite comparisons of sample results.
The inspection involved 50 onsite hours by one NRC inspector.
Results:
No violations or deviations were identified.
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DETAILS 1.
Persons Contacted Nebraska Public Power District (NPPD)
J. M. Pilant, Director, Licensing and Quality Assurance
- L. C. Lessor, Station Superintendent J. V.-Sayer, Chemistry and Health Physics Supervisor V. L. Wolstenholm, Quality Assurance Supervisor J. R. Warren, Chemist R. J. Mcdonald, Health Physicist G. Ketner, Lead Chemistry Technician K. Fike, Chemistry Technician D. Snyder, Chemistry Technician M. Wright, Chemistry Technician
Others Contacted
- D. L. DuBois, NRC Resident Inspector, Cooper Nuclear Station
- Denotes those present during the exit interview.
2.
Licensee's Internal Audits The inspector discussed audits of the chemistry and radwaste programs with the Quality Assurance Supervisor and reviewed reports of audits conducted in these areas during the period from January 1979 through June 1981.
The following audits were reviewed for scope and timely follow-up action of problem areas identified during the audit:
a.
QAP-1200, " Quality Assurance Slan for Radioactive Waste Treatment and Disposal".
The frequency of QAP-1200 is annual.
(1) Audit report No. 79-21 was conducted in September 1979.
The following topics were reviewed:
radwaste discharge documentation for the second quarter of 1979; preventative maintenance and calibration control of selected radwaste equipment; health physics surveys of the radwaste building; and solid radwaste shipment records.
The audit report did not identify any significant problem.
(2) Audit report No. 80-13 was conducted in July 1980.
The following topics were reviewed: radwaste handling, storage, and shipping procedures; radwaste discharge documentation for first quarter of 1980; radiation surveys of shipment No. 80-32 and transport vehicle; and solid radwaste shipment records.
Several instruments were found without current calibration stickers.
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This identified problem area was corrected in a timely manner and documented in the QA file.
No other discrepancies were identified in the audit report.
(3) Audit report No. 81-9.was conducted in March 1981.
The following topics were reviewed: radwaste shipping records and radiation survey records for solis radwaste shipments No. 80-10 through No. 80-67 and No. 81-1 through No. 81-7; calibration of radwaste equipment; radwaste logs; radwaste personnel training records; and verification of updated revisions'of the followir.g procedures in the manuals kept in the chemistry laboratory and health physics office:
H. P. Procedure 9.2.1 " Radiation and Contamination Survey Frequency" H. P. Procedure 9.2.1.1 " Radiation, Contamination, and Airborne Limits" H. P. Procedure 9.2.2 " Radiation Surveys - Radwaste" H. P. Procedure 9.5.3 " Radioactive Material Shipment" A.P. 1.4.4.1.7 "Radwaste Logs"
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0.P. 2.2.6.2 " Radioactive Waste System - Gaseous" Chemistry Procedure 8.8.11 " Liquid Radwaste Discharge" b.
YAP-900, " Chemistry".
The frequency of QAP-900 is annual.
(1) Audit report No. 79-14 was conducted in June 1979.
Findings of this audit included: controlled procedure manual No. 8 kept in the chemistry laboratory was not maintained properly; out-of-date procedure was being used on chemical analysis; and several chemicals used in the chemistry laboratory were found to have expired shel f-lives.
A follow-up_ audit conducted on August 14, 1979, showed these discrepancies to be correcte,
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(2) Audit report No. 80-12 was conducted in June 1980.
The following topics were reviewed:
chemistry personnel training program was not properly documented; chemistry logs and analytical reports were in good order; radiochemistry and chemistry instrumentation.
calibration records were in order;_and specific analysis procedures were monitored including:
reactor water, monthly proportional composite, iodine separation, strontium separation, and off gas sample.
It is noted that a formally documented chemistry personnel training program was started in January 1981.
No violations or deviations regarding the licensee's audit program were identified.
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3.
Quality Control of Analytical Measurements a.
Radiological The NRC inspector visited the radiochemistry counting laboratory and reviewed the radiochemistry calibration and quality control program associated with the laboratory counting instrumentation.
The following procedures were_ reviewed along with trend' charts and other documentation of instrument performance:
Procedure CP-8.2.1
" Chemistry Analysis and Instrument Calibration Schedule" Procedure CP-8.2.4
" Split and Spiked Sampling" This procedure covers the annual split samples and confirmatory measurements with the NRC including gross beta, tritium, strontium-89, strontium-90, and gamma isotopic analyses.
Procedure CP-8.5.2.2 " Wide Beta II" Data from January 1979 through May 1981 were reviewed.
It was noted that high voltage determinations from a plateau curve had been p9rformed on February 15, 1980 and June 2,-1981.
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An Am alpha source and a Sr beta source are counted daily prior to use to determine efficiency performance for that day and the
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efficiency is plotted on a trend chart.
Instrument efficiency is determined semiannually for selected radionuclides as determined by the plant chemist.
Procedure CP-8.5.2.3
"LS-100 Liquid Scintillation, Beckman" Data from January 1980 through May 1981 were reviewed.
Beckman quenched tritium standards are used in conjunction with the instrument external standard reference source to determine instrument tritium efficiency prior to daily use.
The tritium efficiency is plotted versus channels ratio between the tritium channel and the external standard.
A new quench curve is determined every two years or more frequently if detector maintenance is performed.
Calibrations were performed on April 6, 1979 and January 26, 1981.
Procedure CP-8.5.2.4 "Well Counter, Harshaw" Data from January 1979 through May 1981 was reviewed.
A pitch-blend sample is used for the performance check source.
Performance checks using the pitch-blend sample and background counts are plotted daily on a control chart using three sigma control lines.
The original calibration was performed using various selected radionuclides.
The instrument efficiency is determined annually for a limited number of radionuclides as determined by the plant chemist.
High voltage
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plateau curves for determining the detector operating high voltage
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are constructed as needed.
Plateau curves were run in May 1980 and June 1981.
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Procedure CP-8.5.2.5 " Gamma Spectrometer, TN-11" Data from Ja g ry I g through fune 1981 was reviewed.
A 2 inch pad
spiked with Ba, Cs, and Co is used for the system performance check source.
The source is counted daily and the three isotopic analyses are plotted on a control chart. The control lines for the plotted activities are 115% of the known activity.
Counting efficiencies are checked annually using selected geometries as determined by the plant chemist.
The efficiency curve for a 1 liter bottle located 5 cm from the detector was checked in June 1981.
It was noted that single radionuclide standards were being used in the system calibration of each counting geometry.
This means several samples of the same geometry must be fabricated in order to obtain detector efficiencies at various gamma ray energies.
This method requires a great amount of standard preparation time and can result in preparation technique errors.
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A single multi-isotope standard which has gamma ray energies from low to high in the energy range of interest has been used routinely in the industry for calibration of GeLi detector systems for some time and requires preparation of only one standard for each counting geometry to perform the instrument calibration. A licensee representative stated that an NBS traceable multi-isotope standard was on order and would be used as a performance check verification standard once received.
It was concluded that the licensee's quality control procedures for radiochemistry counting instruments were adequate.
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b.
N_on-cadiological The chemistry laboratory participates in a cross-check program with an independent connerical laboratory. This program includes semiannual split samples which are analyzed for suspended :;olids, iron, potassium, sodium, and copper.
Results for January 1979, May 1979, November 1979, August 1980, and December 1980 were reviewed. The inspector had no additional questions in this area at this time.
The following calibration and quality control procedures for non-radiological chemistry instrumentation were reviewed along with documentation of instrument performance:
Procedure CP-8,5.1.3 " Conductivity Bridge, Beckman Model RC-19" Performance data is recorded on Form 8.5.3.0 48. Monthly data from January 1981 through May 1981 was reviewed. A standard kcl solution prepared by the chemistry staff is used for the performance check.
No discrepancies were noted.
Procedure CP-8.5.1.8 "pH Meter, Beckman Expandomatic SS-2" Performance data from January 1981 through May 1981 was reviewed.
Monthly data for two pH buffer solutions is recorded on Form 8.5.3.0 4A.
No discrepancies were noted.
Procedure CP-8.5.1.9 "pH Meter, Orion 801A Specific Ion Analyzer" Daily performance data is recorded on Form 8.5.1.0 4C. Data
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from January 1981 through May 1981 was reviewed.
Buffer valves of pH-7 and pH-4 are used and known values versus instrument indicated values are compared.
No discrepancies were noted.
Procedure CP-8.5.1.11 " Spectrometer, Beckman DU-2" Form 8.5.4.0 4B is used to record the monthly performance check data.
Silica standards of 200 ppb'and 400 ppb are used for the performance check with records showing known standard values versus instument indicated values.
The acceptance criteria is 120 ppb.
Data from January 1981 through May 1981 showed no discrepancies.
No violations or deviations regarding the licensee's quality control of analytical measurements program were identified.-
4.
Analytical Measurements a.
Confirmatory Measurements
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Confirmatory measurements were performed on the following samples in the mobile laboratory at Cooper Nuclear Station during the inspection:
(1) Elevated Release Point Charcoal Cartridge
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(2) Elevated Release Point Particulate Filter (3) Liquid Waste (4) Reactor Water L
(5) Off Gas
(6) RESL Charcoal Cartridge Standard The confirmatory measurements test consist of comparing measurements made
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RESL's and the NRC's mobile laboratory measurements are referenced to the National Bureau of Standards by laboratory intercomparisons.
Confirmatory measurements are made only for those nuclides identified by the mobile laboratory or RESL as being present in concentrations greater
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concentrations as stated in'10 CFR Part 20, Appendix B, Table-II, and than 10% of the respective isotopic values for liquid and gas i
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above.the Lower Limit of Detection (LLD) for stack samples.
Stack charcoal cartridge and stack particulate filter comparisons are based on established Lower Limits of Detection (LLD) for total activity per sample.
Attachment No. 1 contains the criteria used to compare results.
Attachment No. 2 lists the LLD's for stack samples.
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Results
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The following tables show the various sample comparisons:
(1) Elevated Release Point Charcoal Cartridge (Collected 10:35 COT, June - 15, 1981)
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NRC Result NPPD Result NPPD/NRC Nuclide (uCi/ sample)
(uCi/ sample)
Ratio Decision
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131 I 1.3910.002E-01 1.2510.004E-01 0.90 Agreement 133I 9.0310.06E-02 8.31 0.06E-02 0.92-Agreement 135
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I 2.6410.62E-03 2.65E-03 1.00 Agreement
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(2) Elevated Release Point Particulate Filter (Collected 10:35 COT June 15, 1981)
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NRC Result NPPD Result NPPD/NRC Nuclide (uCi/ sample)
(uCi/ sample)
Ratio Decision
l Co 1.4810.09E-04 1.8510.35E-04 1.25 Agreement 59Fe 6.4412.75E-05 <2.17E-04
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Disagreement (1)
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60Co 1.4210.03E-03 1.67 0.06E-03 1.18 Agreement 54Mn J.21 0.02E-03 1. 3110. 05E-03 1.08 Agreement 91Sr 5.8410.40E-03 7.21E-03 1.23 Agreement
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91m Y
Not Reported' 4.24r0.21E-03 (2)
131 1-2.02 0.12E-04 1.97 0.34E-04 0.97 Agreement 6.59 0.34E-04 'Not Reported (3)
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Disagreement:
133 I 137 Cs 1.8010.02E-03 2.0910.06E-03 1.16 Agreement 140Ba 1.41 0.01E-02 8.74 1.33E-03 0.62 Disagreement La 1.31 0.01E-02 9.420.41E-03(4) 0.72 Disagreement 140
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(1) Licensee's peak confidence level for peak identification along with other analysis parameters have been established so as not to allow analysis of nuclides at sensitivity levels recomended for principal gamma emitters on effluent particulate filters as presented in Attachment No..2 listing the lower limits of detection for total activity per sample.
(2) Nuclide not identified as activity _had decayed to below the lower level of detectability at time of sample analysis; therefore, no comparison is made.
(3)
Isotopic peak was present in the spectral data; however, the nuclide was not identified by licensee because it was not included in the isotope library used for the analysil3gf this sample type. A licensee representative stated that I would
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be added to the isotope library used in the analysis of elevated release point particulate filters to verify-compliance with 10 CFR Part 20, Appendix B, Table II effluent concentration limits.
(4) Licensee used a half-life of 12.8 days in calculating 1ga result which is the half-life of the parent isotope, Ba.
Uponrecalculationg(0the isotopic data using a half-life of 40.22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> for La, which is used by the NRC mobile laboratory, the analysis result of 1.37E-02 uCi/ sample was in agreement.
(3) Liquid Floor Drain Storage Tank (Collected 10:40 COT, June 16,1981)
NRC Result NPPD Result NPPD/NRC Nuclide (uCi/ml)
(uCi/ml)
Ratio Decision
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tritium 4.55 0.33E-04 4.53 0.03E-04 0.99 Agreement w
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gross 4.0010.20E-04 3.2110.03E-04 0.80 Agreement beta 89Sr 1.0310.40E-05 9.9010.08E-06 0.96 Agreement 90Sr 6.0012.00E-08 1.3410.13E-07 2.23 Agreement
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Na 1.6310.16E-06 <8.55E-07
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Cr 7.6812.22E-06 1.0410.36E-05(2) 1.35 (1)
54Mn 7.7810.07E-05 8.3810.08E-05 1.08 Agreement 58Co 1.4110.04E-05 1.4810.05E-05 1.05 Agreement 60Co 1.5410.01E-04 1.6310.01E-04 1.06 Ag'eement r
I 8.9912.97E-07 8.8514.26E-07(2) 0.98 Agreement 131 134Cs 1.4210.01E-04 1.4210.11E-04 1.00 Agreement 137Cs 1.5710.01E-04 1.7410.01E-04 1.11 Agreement (1) Activity concentration identified by the NRC was less than 10%
of the isotopic value stated in 10 CFR Part 20, Appendix B, Table II; therefore, no formal comparison is made.
(2) Result is taken from analysis performed using a 50% error limit in the peak identification software.
The original analysis using a 25% error limit produced no peak identification and analytical results.
(4) Reactor Coolant Liquid (Collected 10:10 CDT, June 17, 1981)
NRC Result NPPD Result NPPD/NRC Nuclide (uCi/ml)
(uCi/ml)
Ratio Decision 24Na 1.3910.02E-03 1.4110.03E-03 1.01 Agreement 51Cr 8.9810.12E-03 1.0110.03E-02 1.12 Agreement Possible 54Mn 4.4210.11E-04 5.9810.22E-04 1.35 Agreement
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56Mn 1.2410.04E-03 1.1710.07E-03 0.94 Agreement 58Co 2.8810.11E-04 6.5610.22E-04 2.28 Disagreement 60Co 1.0410.02E-03 1.8310.04E-03 1.76 Disagreement 91Sr 2.4910.29E-04 2.26E-04 0.91 Agreement 9I"Y 1.5110.12E-04 Not Reported Disagreement
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92Sr 6.0310.16E-04 3.5613'.56E-03 5.90 Disagreement 95Nb 2.6510.48E-05 7.0111.80E-05 2.65 Disagreement 97Nb 1.5610.13E-04 Not Reported Disagreement
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99"Tc 6.8010.03E-03 6.4610.03E-03 0.95 Agreement 131I Not Reported 1.54fl.54E-05(1)
No Comparison
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132I 5.0710.14E-04 3.1210.20E-04(1) 0.61 Disagreement 133I 2.2810.08E-04 1.9310.01E-04(1) 0.84 Agreement I
1.5110.04E-03 1.1110.05E-03(1) 0.73 Disagreement 134 135I 4.0910.30E-04 3.0510.42E-04(1) 0.75 Agreement-137Cs 4. 7510. 82E-05
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138Cs 1.7110.25E-04 Not Reported Disagreement
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139Ba 8.4110.58E-04 4.7911.04E-04 0.56 Disagreement (1) Analytical results were taken from the iodine separation analysis performed on the reactor water.
(2) Licensee's peak confidence level for peak identification along
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with other analysis parameter have been established so as not to allow analysis of nuclides at sensitivity levels recommer:ded for principal gamma emitters in liquid waste samples as presented in the proposed standard technical specifications for boiling water reactors or at activity levels equal to or less than 10%
of the isotopic values stated in 10 CFR Part 20, Appendix B, a
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Table II, Column 2.
No formal comparison is made.
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(5) Off-gas Sample (Collected 07:46 CDT, June 19,1981)
NRC Result NPPD Result NPPD/NRC Nuclide (uCi/cc)
(uCi/cc)
Ratio Decision
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13N Not Reported 8.7010.06E-03
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Ar 9.8513.59E-06 _4.62E-05
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85mKr 3.50 0.03E-04.3.26 0.14E-04 0.93 Agreement 07Kr 7.95 0.11E-04 4.68 0.20E-04 0.59 Disagreement 88Kr 9.4010.08E-04 4.71 0.28E-04 0.50 Disagreement 133Xe 6.24 0.05E-04 7.46 0.46E-04 1.20 Agreement 133mXe
'3.31 0.85E-05 _2.12E-04
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135Xe 1.47 0.01E-03 9.7110.18E-04 0.66 Disagreement 135mXe 1.8310.18E-03 1.89 0.04E-03 1.03 Agreement 138Xe 9.64 0.99E-03 5.30 0.18E-03 0.5l Disagreement
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(1) Nuclide not identified as activity had decayed to below the lower level of detectability at time of sample analysis; therefore, no comparison is made.
(2) Licensee's peak confidence level for peak identification along with other analysis parameters have been established so as not to allow analysis of nuclides at acitivity levels' equal to or less than 10% of the isotopic values stated in 10 CFR Part 20, Appendix B, Table II, Column 1.
No formal comparison is made.
The several items of disagreement on the off-gas analysis were discussed.
In an attempt to resolve the disagreements, the licensee agreed to recalibrate their off-gas counting geometry using the NRC serum vial standard which is traceable to the National Bureau of Standards and supplied to NRC Region IV by the' Rac'iological and Environmental Sciences Laboratory for-calibration of the mobile laboratory instrumentation. The off-gas sample spectrum was reanalyzed by the licensee using the new efficiency calibration.
The results of this study are given in the following table:
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Off-gas Sa.nple (Collected 07:46 CDT, June 19, 1981 NRC Result NPPD Result NPPD/NRC
Nuclide (uCi/cc)
(uCi/cc)
Ratio Decision 85mKr 3.5010.03E-04 3.2610.14E-04 0.93 Agreement Possible 87Kr 7.9510.11E-04 6.0210.25E-04 0.76 Agreement Kr 9.4010.08E-04 6.7410.41E-04(1) 0.72 Disagreement
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133Xe 6.2410.05E-04 6.7110.41E-04 1.08 Agreement 135Xe 1.4710.01E-03 1.2710.02E-03 0.86 Agreement 135mXe 1.83 0.18E-03 2.4010.05E-03 1.31 Agreement 138Xe 9.6410.90E-03 7.1010.23E-03 0.74 Agreement Based on the results of this study, a licensee's representative stated that the new calibration for the off gas counting geometry would be used in analyzing subsequent off gas samples.
(1) Licensee used a branching ratio of 35% in calculating the
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result.
Upon recalculation of the isotopic data using a branch ratio of 26.3%, which was used by the NRC mobile laboratory, the analysis result of 8.99E-04 uCi/cc was in agreement.
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(6) RESL Charcoal Cartridge Face Loaded Standard No. 80-6 (Standardized 09:00 CST, March 19, 1980)
NRC Result (1) NPPD Result (2)
NPFD/NRC Nuclide (uCi/gm)
(uCi/am)
Ratio Decision Possible 57Co 2.2710.10E-02 3.0910.14E-02 1.36 Agreement 60Co 1.7310.07E-01 2.11 0.01E-01.
1.22 Agreement u-,,n.
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88Y 2.9210.11E-01 3.4210.24E-01 1.17 Agreement 113Sn 5.7510.23E-02 7.12il.35E-02 1.24 Agreement 137Cs 1.2910.05E-01 1.6210.01E-01 1.25 Agreement 241Am 3.1910.13E-02 5.3410.24E-02 1.68 Disagreement
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(1) Results are taken from the standard certificate supplied with the standard as prepared by RESL and traceable to the National Bureau of Standards.
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(2) Licensee's results are based on a detector efficiency curve established using a face loaded standard. The RESL standard cartridge was analyzed without flipping the cartridge at the midpoint of the analysis count.
No violation or deviations were identified.
c.
Previous Confirmatory Measurements Confirmatory measurements were performed on a sample of liquid waste collected December 19, 1978, and the results were reported in Report No.
50-298/79-08 dated May 30, 1979.
A disagreement decision was reported in error for several radionuclides analyzed in this sample.
The results of thefollowingradiongglideg0Co,ghav00Sr, 3H, and gross beta.
shou been reported as agreement rather than disagreement:
Fe, Sr,
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5.
Exit Interview At the conclusion of the inspection on June 19, 1981, the inspection findings were discussed with the Station Superintendent.
The NRC inspector reviewed the scope of the inspection, discussed the inspection findings, and inforrred the licensee of the agreement between NPPD and NRC on measurements performed on various intercomparison sample ATTACHMENT NO. 1
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Criteria for Comparing Analytical Measurements The following are the criteria used in coioparing the results of capability tests and verification measurements.
The criteria are based on an empirical
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relationship established through prior experience and this program's analytical requirements.
In these criteria, the judgement limits vary in relation to the comparison of the resolution.
Resolution = NRC Value NRC Uncertainly Ratio = Licensee Value NRC Value
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Comparisons are made by first determining the resolution and then reading across the same line to the corresponding ratio.
The following table shows the acceptance values.
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RESOLUTION RATIO Possible Possible Agreement..
Agreement A Agreement B
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0.4 - 2.5 0.3 - 3.0 No comparison 4-7 0.5 - 2.0 0.4 - 2.5 0.3 - 3.0 8 - 15 0.6 - 1.66 0.5 - 2.0 0.4 - 2.5 16 - 50 0.75 - 1.33 0.6 - 1.66 0.5 - 2.0 51 - 200 0.80 - 1.25 0.75 - 1.33 0.6 - 1.66 200 0.85 - 1.18'
O.80 - 1.25 0.75 - 1.33
"A" criteria are applied to the following analyses:
Gamma Spectrometry where principal gamma energy used for identification is greater than 250 Kev.
Tritium analyses of liquid samples.
Iodine on adsorbers.
"B" criteria are applied to the following analyses:
Gamma Spectrometry where principal gauma energy used for identification is less than 250 Kev.
90 Sr and Sr Determinations.
Gross Bets where samples are counted on the same date using the same reference nuclide.
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ATTACHMENT NO. 2
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LLDs for Nuclides on Particulate and Charcoal Filters b'uclide LLD (uCi/ sample)
"'Cr 1E-04 Mn 1.5E-05
Co 1.5E-05
l Fe 3E-05 Co 2E-05 Co 3E-05 65 Zn 3E-05 89Sr IE-05
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3gr 2E-07 I
2E-05 134
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Ba 2E-05
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140La 4E-05 141 Ce 2E-uS 144Ce 1E-04
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