IR 05000302/1981003
| ML20004D301 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/16/1981 |
| From: | Montgomery D, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20004D293 | List: |
| References | |
| 50-302-81-03, 50-302-81-3, NUDOCS 8106090130 | |
| Download: ML20004D301 (11) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION n
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,E REGION 11 Q
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101 MARIETTA ST., N.W., SulTE 3100 j'
ATLANTA, o EORGI A 30303 eO Report No. 50-302/81-3 Licensee:
Florida Power Corporation
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P. O. Box 14042, Mail Stop C-4 St. Petersburg, FL 33733 Facility Name:
Crystal River 3 License No. DPR-72 Inspection at rystal River site, Crystal River, FL Inspector:
N,I o
h N/h/ ff/
D. 71. 'Montgomefy
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Uate'Sisned Accompanying Personn 1:
D. C. McPhail
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Approved by:
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J. Phi [1p'Stohr, pie 4:
Sr'anch Date 51gned
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SUMMARY Dates of Inspection February 9-12, 1981 Areas Inspected:
This routine unannounced inspection involved 48 inspector-hours onsite in the areas of quality control and confirmatory measurements including: review of the laboratory quality control program; review of chemistry and radiochemistry procedures; review of quality control records and logs; and comparison of split samples analyzed by the licensee and the NRC RII Mobile Laboratory.
Results:
Of the four areas inspected, no violations or deviations were identified in three areas; two violations were found in one area (failure to review and approve chemistry procedures as required by Environmental Technical Specifications; failure to conduct interlaboratory crosscheck analyses as required by chemistry procedures).
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DETAILS 1.
Persons Contacted
- D. C. Poole, Plant Manager
- R. E. Fuller, Chemistry and Waste Manager
- D. Wilder, Chemistry-Radiation Supervisor
- R. Pinner, Chemistry-Radiation Supervisor
- G. A. Ruszala, Chemistry-Radiation Protection Manager
- J. L. Bufe, Nuclear Compliance Auditor
- V. A. Hernandez, Nuclear Compliance Auditor Other licensee employees contacted included four technicians.
NRC Resident Inspectors
- T. F. Stetka
- B. Smith
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- Attended exit ir.terview 2.
Etit Interview The inspection scope and findings were summarized on February 12, 1981 with
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those persons indicated in Paragraph 1 above.
The Plant Manager acknow-t
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ledged the violations and agreed to perform the analyses referred to in paragraph 7b and report the results to NRC:RII. The inspector stated that removal of the procedure requirements for interlaboratory comparisons would t
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not be acceptable corrective action unless other alternatives for quality assurance are instituted.
The inspector informed the plant manager by
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telephone on February 19, 1981 that a permanent change in the technical
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specifications to allow for review and approval of chemistry procedures by the Chemistry-Radiation Manager may be acceptable corrective action.
However, the NRC Office of Nuclear Reactor Regulation would have to approve any deviations from the current technical specifications until a permanent change is approved.
3.
Unresolved Items Unresolved items were not identified during this inspection.
4.
Laboratory Quality Control Program The inspector reviewed the licensee's quality control program for chemical and radiochemical measurements in the following areas:
a.
Assignment of responsibility to manage and conduct the QC Program.
The responsibility for conducting the quality control program for chemical and radiochemical analysis is assigned to a Chemistry and
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-2-Waste Supervisor.
Assignment of responsibility is accomplished by a position description.
There are no plant procedures describing the quality assurance responsibilities within the organization above the first-line super *tisory level.
i b.
Provisions for Audits / Inspections i
There are no provisions for audits and/or inspections to review pro-
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gram results beyond first-line supervision, i.e. Chemistry and Waste Supervisor. No systematic review and appraisal of the quality control program is carried out by the Chemistry Waste Supervisor.
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Section 5.3.9 of the Environmental Technical Specifications (Appendix B)
specifys that audits of conformance to procedures and ETS requirements-shall be carried out at least once per twelve months under the cogni-zance of the Nuclear General Review Committee (NGRC).
These audits are not directed to review of quality control data for purpose of
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identifying problems and/or inadequacies of the program.
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c.
Methods for Assuring Dericiencies and Deviations in the Program are Recognized, Indentified, and Corrected.
The Chemist;y and Waste Supervisor is responsible for reviewing all
quality assurance data to identify and correct deficiencies in the i
program. The operational procedures specify quality control checks and analyses that are performed to identify problems in the analytical program. No specific formal procedures are provided for documenting deficiencies with appropriate corrective action.
The inspector noted that licensee's quality control program did not meet recommendations of NRC Regulatory Guide 4.15, " Quality Assurance for Radio-
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logical Monitoring programs (Normal Operations) - Effluent Streams and the Environment" in the following areas: Organizational Structure and Respon-sibilities of Managerial and Operational Personnel, and Audits.
The inspector stated that the licensee's program does not speci fy the structure and the organization and the various responsibilities within the structure as it relates to quality assurance.
In addition, the program does not provide for independent review and audit as recommended in Regulatory Guide 4.15.
Licensee representatives agreed to review the quality control program for chemistry and radiochemistry and consider addressing areas that do not meet Regulatory Guide 4.15.
The licensee has no regulatory requirement to meet Regulatory Guide 4.15. (81-3-01)
5.
Review of Chemistry and Radiochemistry Procedures a.
The inspector reviewed the following procedures:
(1) SP-707,
" Laboratory Radiochemistry Instrumentation Quality Control Surveillance Program", Rev. 5, 11-3-80.
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(2) SP-706, " Analytical Chemistry's Quality Control Surveillance Program", R'ev. 2, 1-17-80.
(3) SP-708, " Laboratory Chemical Instrumentation Quality Control Surveillance Program Rev. 4, 6-12-80.
(4) SP-705, " Analytical Radiochemistry's Quality Control Surveillance Program," Rev. 2, 1-17-80.
(5) CH-145 L, " Analytical Quality Control for Chemical Analysis",
2-10-81.
(6) CH-163, " Preparation for Measurement of Tritium in Liquids,"
7-17-74.
(7) CH-165, " Preparation for Measurement of Gross Alpha Activity in Liquids," 7-17-74.
(8) CH-211L " Quality Control Requirements for Nuclear Counting Instru-mentation," 4-27-77.
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(9) CH-203L, " Preparation and Handling of Radioactive Sources,"
4-27-77.
(10) CH-213,
" Quality Control Requirements for Radiochemistr.y Procedures," 2-10-81.
(11) CH-167, " Preparation of Measurement of Gross Beta Activity in Liquids," 7-17-74.
(12) CH-228L, "Packard Model 2211 Liquid Scintillation System" (13) CH-229L, "NMC Model ASC-70/DS-33 PC Gas Flow Proportional Counter System," 6-13-80.
(14) CH-231, "Ge(L1)/NS-720 Spectrometer System," 5-9-79.
(15) CH-256L, "Np-239 and Gross Alpha Activity Measurement," 1-12-81.
(16) CH-259L, " Determination of Tritium," 4-22-77.
(17) CH-260L, " Determination of Radionuclides U;.ng Gamma Spectros-copy," 4-22-77.
(18) CH-257, Determination of Gross Beta", 11-29-76.
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(19) CH-264L, " Determination of Radiostrontium,"
(20) CH-265, "Cetermination of E-Bar," 1-2-81.
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-4-(21) CH-323, " Sampling Evaporator Condensate Storage Tanks 3A & 38, 12/13/79, Rev. 2.
(22) CH-338, " Sampling the Waste Gas."
The inspector discussed the results of the procedure review with licensee representatives as noted in paragraphs 5b - 5d.
b.
The inspector noted that most of the procedures for radiochemistry and operation of the counting equipment contained many inconsistencies and deficiencies. The inspector stated that the procedures apparently had not been thoroughly reviewed and updated as needed to maintain current procedures.
Deficiencies in the operating procedures included the
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(1) Procedure CH-338 for sampling the waste gas decay tank does not l
specify details of the tritium trap for removing water vapor and does not specify a minimum sampling time or in'.agrated flow to l
ensure that the reauired sensitivity is met. Licensee representa-
tives indicated that the technicians have been instructed te l
sample for a time period that is adequate to ensure that required
analytical sensitivities are met: however, the procedure would be i
revised to specify the minimum sampling time.
(2)
Procedure CH-211L does not specify the source (s) to be used for preformance checks of the gamma ray spectroscopy systems.
This procedure also specifies that performance checks for the liquid scintillation counter are to be carried out using an external standard. The accepted practica for performance checks of radia-tion detection instrumentaion is to utilize internal radio-active sources that produce similar radiation fields as that which is normally measured. The use of an external source does not satisfy this criterion.
(3) Procedure CH-231L for operation of the Ge(Li) counters does not give detailed instructions for efficiency calibrations of gas counting geometries.
This procedure permits counting of samples with analyzer dead times as high as 20 percent, and tests * ave i
been performed to demonstrate the validity of counting at such high count rates.
The referenced radionuclide gamma ray energy
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and intensity compilation does not list the most recent data, and the computer radionuclide library has not been reviewed and updated to reflect the current nuclear decay data.
(4) Procedure CH-213 does not provide acceptance criteria for blind duplicate analyses and interlaboratory crosscheck analyses.
(5) Procedure CH-229L does not specify frequency for plateau voltage check.-.
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-5-(6) Procedure CH-259 does not provide for quench monitoring to ensure purity of the sample for liquid scintillation counting. Although samples are purified by distillation and would normally be pure, quench monitoring with an external standard is good practice to verify that quenching is not significant.
(7) Procedures CH-165 and CH-250L for measurement of gross alpha activity in liquids do not provide for checks of chemical yields for solvent extraction and ion exchange separations.
Althaugh the yields were checked when the procedure was developed, good quality control dictates that recoveries should be
- hecked occasionally to verify that assumed recoveries are still valid.
(8) Procedure CH-257 does not specify the preparation method for filter standards.
The inspector noted that the deficiencies in the procedures were not serious enough to invalidate the procedures or analyses; however, deficiencies should be corrected to eliminate potential problems.
Licensee representatives agreed to review the proce-dures and revise as necessary.
The revised procedures will be reviewed during a subsequent inspection. (81-03-02)
c.
The inspector noted that procedures for operation of the various radiation detection systems and the Instrumentation Quality Assurance Surveillance Program (SP-707) do not specify efficiency calibration f equency.
The inspector stated that calibration requirements and frequencies should be an integral part of the quality control program.
Licensee representatives agreed to revise the applicable procedures and include calibration frequencies for counting room instrumentation.
(81-03-03)
d.
The inspector noted that procedures in the 200 chemistry series had not been approved by the Nuclear Plant Manager and reviewed by NGRC (Nuclear General Review Committee) as required by the Environmental Technical Specifications, Appendix B, Section 5.5.
A licensee representative stated that review of these procedures was limited to the Chemistry Manager and that this policy had been in effect for at least two years. The inspector informed licensee representatives that failure to have chemistry operating procedures for the analysis of liquid and gaseous wastes approved by the Nuclear Plant Manager and reviewed by the NGRC was a violation. (81-03-04)
6.
Review of Records and Logs a.
The inspect? reviewed the following records and logs:
(1) Ge(Li) Calibration Records for Detectors 1, 2 and 3,1980.
(2) Radionuclide Standard Certificates, for Mixed Gamma Ray Sources for 4-L Bottle,1-L Bottle, 35-cc Gas Sphere, 35 mm PF, Cesco Cartridge, 25-cc LS vial,1980.
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i (3) Quality Control Records for Chemistry' December, 1980 to February, i
1981.
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(4) Daily Instrument Checks for Liquid Scintillation, NMC, and Ge(Li)
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(5) GeLi Spectra for liquid waste releases, and gaseous wastes ircluding particulate filter and charcoal cartridge, January
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The inspector discussed the record review with licensee representa-
tives as noted in paragraphs 6b and 6c.
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b.
'The inspector noted that the QC records did not include interlaboratory analyt/ cal results for 1980. A licensee representative stated that
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the interlaboratc y crosscheck analyses for radiochemical analyses had
not been performd ?n 1980 because they had not been able to identify a laboratory that would participate in a program. The inspector noted
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l that many commercial laboratories perform radiostrontium analyses of
j liquiri wastes, and it is likely that they would perform other analyses j
that would satisfy to interlaboratory crosschecks requirements.
The i
inspector noted that Procedure CH-213, " Quality Control Requirements i
i for Radiochemistry Procedures" provides for interlaboratory comparisons
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for gross beta, ganma spe::troscopy, and tritium every six months.
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Environmental Technical Specification 5.5.1 Appendix B requires that
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I explicit written procedures be adhered to for all systems -and
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components involved in carrying out the effluent release program.
The inspector informed licensee representatives that failure to carry
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out interlaboratory analyses as specified in Procedure CH-213 was a I
violation. (81-03-05)
c.
The inspector noted that the computer analysis of gamma ray spectra
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for liquid waste samples did not quantify all noble gases. Specifi-t cally, the computer radionuclide library for routine counting of
liquid waste <amples excludes Xe-133 which is a major constituent in l
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liquid waste releases. Technical Specifications only require monthly l
analysis of nobla gases in liquid wastes; however, quantification of
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noble gases should be made for each release to ensure that noble gas
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j concentrations do not exceed the MPC for noble gases in water l
(Technical Specification 2.4.1 and Table 2.4.1, Appendix A). Licensee i
representative agreed to review the management system for quantifica-
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i tion and reporting of noble gases in liquid effluents and to promptly l
upgrade the computer library to include Xe-133 in the analysis of l
liquid wastes. (81-03-06)
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7.
Confirmatory Measurements
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a.
The results of samples collected during the period of January 22-26,
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1979, were discussed with licensee representatives.
The results are
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given in Table 1 and show agreement for all radionuclides detected in
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j the charcoal cartridge, waste gas sample, and liquid waste samples.
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-7-l The comparison of the particulate filter results show disagreement for
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all radionuclides.
The licensee results were between 26.7 and 29.1 times higher than the NRC valves.
No reason for the disagreement
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could be found. The effect of possible licensee errors for particulate filters would be over-reporting of particulate radioactivity in gaseous effluents, and regulatory limits would not be exceeded. Since results for the particulate filter collected during this inspection
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(paragraph 7b) agreed with the NRC results, this item is considered closed (302/79-7-07).
o.
Liquid and gaseous samples were collected during this inspection and counted by the licensee and NRC RII Mobile Laboratory to verify the licensee's capability to measure radionuclides in effluent and reactor coolant samples. Samples were analyzed by gamma-ray spectroscopy and included:
a reactor coolant sample, charcoal cartridge, particulate
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filter and gas sample from the station vent, and a liquid sample from s
the m'scellaneous waste holdup tank (prior to treatment). An aliquot of the liquid sample from the miscellaneous waste holdup tank was collected for tritium and radiostrontium analyses.
The results will be compared to licensee results in a subsequent inspection.
(81-03-08)
The comparisons of licensee and NRC results are presented in Table 2 with acceptance criteria in Attachment 1.
The results showed agree-ment or possible agreement for all samples except the miscellaneous
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waste holdup tank (MWHT). Licensee values for Cs-137 and Cr-51 were significantly higher than the NRC values and did not meet the accep-tance criteria.
The licensee values were apparently higher because the computer code used to identify and quantify photopeaks failed to properly treat photopeaks that were close together in energy.
The inspector stated that the current program used for gamma spectral analysis did not ap;: ear to be adequate for complex spectra.
A licensee representative agreed to review problems associated with current instrumentation and consider solutions to alleviate the
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problems cited above. (81-03-09)
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Attechment 1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS l
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This attachment provides criteria for comparing results of capability tests and verification measurements.
The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this program.
In these criteria, the judgment limits are variable in relation to the comparison of the NRC Reference Laboratory's value to its associated uncertainty. As that ratio, referred to in this program as " Resolution",
increases, the acceptability of a licensee's measurement should be more selective.
Conversely, poorer agreement must be considered acceptable as the resolution decreases.
LICENSEE VALUE AHO = NRC REFERENCE VALUE Possible Possible Resolution Agreement Agreement A Agreement B
<3 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 0.8C - 1.25 0.75 - 1.33 0.6 - 1.66
>200 0.85 - 1.18 0.80 - 1.25 0.75 - 1.33
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"A" criteria are applied to the following analyses:
i Gamma Spectrometry where principal ganna energy used for identification
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is greater than 250 Kev.
I Tritium analyses of liquid samples.
"B" criteria are applied to the following analyses:
Gamma Spectrometry where principal gamma energy used for identification is less than 250 Kev.
8'Sr and Sr Determinations.
Gross Beta where samples are counted on the same date using the same reference nuclide.
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TABLE 1 RESULTS OF CONFIRMATORY MEASUREMENTS AT CRYSTAL RIVER NUCLEAR PLANT, JANUARY, 1979 CONCENTRATION, MICR0 CURIES /CC RATIO SAMPLE ISOTOPE CRYSTAL RIVER HRG GiB./NRC RESOLUTION COMPAR1 EON Particulate 1-131
?.34 1 0.01 E-2 8.70 1 0.26 E-4 26.8
Di sag reement Filter Cs-134 1.33 1 0.05 E-3 4.57 i O.19 E-5 29.1
Disagreement
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Cs-137 2.13 1 0.07 E '
7.95 i O.30 E-5 26.7 26.5 Di sag reement Cha rcoa l 1-131 2.74 1 0.003 E-1 3.26 1 0.09 E-1 0.84
Ag reement Cartridge Waste Gas Xe-133 4.72 E-3 4.36 1 0.15 E-3 1.08
Agreement Tank Kr-85 4.28 1 0.08 E-2 3.56 i O.14 E-2 1.20
Ag reement Liquid Waste 1-131 9.81 i.03 E-3 8.85 1.26 E-3 1.10
Agreement 1000 ml Cs-134 1.54 i.01 E-3 1.50 i.04 E-3 0.97 37.5 Ag reemen t Di scha rge Cs-137 2.44 i.02 E-3 2.46 i.07 E-3 0.99
Ag reement 1/23 Co-58 1.72 i.08 E-4 1.65 i.09 E-4 1.04 18.3 Ag reement C0-60 1.99 i.32 E-5 1.58 i.08 E-7 1.26 19.7 Ag reement H-3 5.18 1 0.01 E-2 4.51 1 0.03 E-2 1.14 150 Ag reement S r-87 8.93 1 0.04 E-6 1.16 1 0.05 E-5
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Agreement S r-90 8.70 1 2.8 E-8 912 E-8 0.9 4.5 Ag reement
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TABLE 2 RESULTS OF CONFIRMATORY MEASUREMENTS AT CR(STAL RIVER, FEBRUARY, 1981 CONCENTRATION. MIRC0 CURIES /CC RATIO SAMPLE ISOTOPE CRYSTAL RIVER MRg Q P,fEBC RESOLUTION COMPARISON Reactor Coolant 1-131 5.1 1 0.2 E-2 4.82 1 0.07 E-2 1.06
Ag reement 2/10/81 @ 12:40 1-132 5.6 1 0.3 E-2 5.2 1 0.1 E-2 1.08
Agreement 1-133 8.4 1 0.2 E-2 6.31 1 0.06 E-2 1.33 105 Possible Agreement 1-134 8.4 1 0.8 E-2 6.0 1 0.2 E-2 1.4 3u Agreement 1-135 5.9 1 0.6 E-2 6.0 1 0.3 E-2
.98
Ag reemens Cs-138 4.5 1 0.2 E-1 4.22 1 0.03 E-1 1.07 141 Cha rcoa l Ca rt ridge 1-131 4.60 i.04 E-9 4.98 i.04 E-9
.92 125 Ag reement 2/10/81 @ 14:25 l-133 2.44 1 0.04 E-9 2.52 1 0.04 E-9
.97
Agreement Pa rticulate fil ter Cs-134 3.2 1 0.3 E-11 2.8 1 0.1 E-11 1.14
Ag reement RAM-6 2/10/81 @ 14:25 Cs-137 6.1 1 0.4 E-11 4.9 1 0.2 E-11 1.24
Ag reement 1-131 7.4 1 1.6 E-12 8.7 0.8 E-12
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Aqreement 1-133 ND 2.2 1 0.7 E-12 NC NC off Gas Xe-133m 1.44 1 0.14 E-4 1.2 i.18 E-4 1.20
Ag ressent RAM-6 2/10/81 @ 14:25 Xe-133 6.39 i.03 E-3 6.45 1.03 E-3 1.07 215 Agreement Xc-135 2.56 i.05 E-4 2.42 1 0.06 E-4 1.06
Ag reemen t K.-88 9.5 1 2.2 E-6 5.8 1 1.7 E-6 1.64 3.4 Ag reement Miscellaneous Cs-137 3.4 1 0.1 E-4 2.2 1 0.1 E-4 1.54
D i sag reement Waste Holdup Cs-134 1,57 1 0.09 E-4 1.27 1 0.10 E-4 1.24
Agreement Tank Co-60 1.23 1 0.07 E-4 1.24 1 0.02 E-4 1.0
Ag reement C r-51 7.9 1 0.6 E-4 4.7 1 0.1 E-4 1.68
Di sag reement Ag-110m 3.6 1 0.9 E-5 4.5 1 0.1 E-5 0.8
Ag reement Co-58 1.70 1 0.02 E-5 1.4 1 0.1 E-5 1.21
Ag reemen.
Z r-95 1.5 1 0.6 E-5 1.6 i O.2 E-5
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Ag reement Nb-95 3.2 1 0.4 E-4 3.2 t 0.1 E-5 1.0
Ag reement 1-131 1.16 1 0.01 E-3 9.22 i O.10 E-4 1.25
Ag reemen t 1-133 1.98 1 0.06 E-4 1.79 1 0.02 F-4 1.11
Ag reemen t Na-24 1.8 1 0.3 E-5 1.3 i O.6 E->
1.38 2.7 Ag reemen t i