IR 05000313/1989021
| ML20244C919 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 06/02/1989 |
| From: | Baer R, Nicholas J, Wilborn L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20244C918 | List: |
| References | |
| TASK-2.B.3, TASK-TM 50-313-89-21, 50-368-89-21, NUDOCS 8906150211 | |
| Download: ML20244C919 (27) | |
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APPENDIX l
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U.S. NUCLEAR REGULATORY COMMISSION REGION IV'
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NRC Inspection Report:
50-313/89-21 Operating Licenses: DPR-51
~50-368/89-21 NPF-6 Dockets:
50-313 50-368
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Licensee: Arkansas. Power & Light Company (AP&L)
P.O. Box'551 Littie' Rock. Arkansas 72203 Facility Name: Arkansas' Nuclear One (AND)
Inspection'At: AND Site,' Russelville, Pope County, Arkansas
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f Inspection Conducted: May 8-12, 1989
Inspectors:. ' '
C414244 '}rgr4u b & 'J.B.Nicfolas,SeniorRadiationSpecialist Date.
Facilities Radiological Protection..Section b 0,6 N'lC44U bk!N ,L 'L. Wilboph, Radiation Specialist-Date ' Facilities Radiological Protection Section.
Accompanied By: R. Wise, Allegations Coordinator Approved: _, 4 [[B .9 - Rf E. Baer, Chief, Facilities Radiological Date Protection Section Inspection Summary Inspection Conducted May 8-12, 1989 (Report 50-313/89-21; 50-368/89-21) Areas Inspected: Routine, unannounced inspection'of the licensee's ! chemistry / radiochemistry ~ program and water chemistry and radiochemistry l confirmatory measurements.
Results: The NRC inspectors determined that the licensee'had developed and implemented a water chemistry program and radiochemistry program based on regulatory and indust +y guidelines. - The water chemistry and radiochemistry - programs were being conducted in accordance with Technical Specification (TS) " 8906150211 990606 PDR ADOCK 050003134-G PNU-& __ _- __-- - - _ - _ = -
._ ____ - __ _ _ _ _ _ _. . ,# t .- , requirements. The licensee was attentive to NRC concern's involving technical issues and had evaluated and resolved seven previously identified inspection findings.
The licensee's water chemistry and radiochemistry staffs had experienced a personnel turnover of approximately 25 percent over the past 18 months. Quality Assurance (QA) surveillance and audits had been performed as required and were technically comprehensive.
The licensee's Postaccident Sampling System (PASS) has experienced numerous operational problems. The Unit 2 PASS had been declared out of service from October 1987 through March 1989 due to the in-line hydrogen analyzer being removed from the system for service. The licensee demonstrated Unit 2 PASS operation under simulated accident conditions during the inspection. The results of the water chemistry confirmatory measurements from the water chemistry laboratory indicated i 96 percent agreement with the NRC results and the radiochemistry laboratory results were in 83 percent agreement. The licensee's radiological confirmatory measurements results were in 99 percent agreement with the NRC results.
Within the areas inspected, no violations or deviations were identified.
Seven previously identified open items were closed in paragraph 2.
Four NRC inspector observations for program improvement are listed in paragraph 3 and respectively discussed in paragraphs 5 and 6.
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DETAILS 1.
Persons Contacted AP&L '.
- S. M. Quennoz, Acting General Manager, Plant Support T. C. Baker, Technical Support B. L. Bata, QA Engineer
- E. E. Bickel, Health Physics (HP) Superintendent
- M. E. Frala, Nuclear Chemistry Supervisor
- R. D. Gillespie, Technical Analysis Superintendent R. E. Green, HP Dosimetry Supervisor H. T. Greene, QA Superintendent
- D. C. Harris, Lead Trainer, Cheiaistry/ Radiochemistry
- L. W. Humphrey, General Manager, Nuclear Quality
- R. L. Jones, Nuclear Chemistry Supervisor
- D. B. Lomax, Licensing Supervisor R. D. McCormick, Nuclear Quality Specialist, Chemistry / Radiochemistry
- W. C. McKelvy, Nuclear Chemistry Supervisor
- D. J. Meatheany, Nuclear Chemistry Supervisor P. L. Michalk, Plant Licensing Engineer
- W. R. Pool, Ut. clear Chemistry Supervisor
- G. D. Provencer, QA Supervisor P. C. Robins, Nuclear Chemistry Supervisor N,R_C
- W. D. Johnson, Senior Resident Inspector, ANO
- Denotes those present during the exit interview on May 12, 1989.
2.
Followup on Previously Identified Inspection Findings (9270.?] (Closed) Open Item (313/8724-01; 368/8724-01): Accredited Training Program for Technical Analysis Section (TAS) Chemists - This item was previously discussed in NRC Inspection Report 50-313/87-24; 50-368/87-24 and involved the lack of a formal, performance based training program for the TAS radiochemist similar to the training program developed for the ANO radiochemist. The NRC inspectors reviewed the licensee's evaluation of the NRC inspector's concern and found that a task analysis had been performed of the TAS program to determine the similar tasks.that are performed by both the TAS staff and the ANO radiochemistry staff.
For the tarks which were similar to both laboratories a list of lesson plans was { developed. When these identified lesson plans are scheduled to be i presented to the AND radiochemistry staff, the TAS staff are informed as
to the schedule and content of the training.
The NRC inspectors reviewed ! selected training course attendance records and verified that TAS personnel were attending AND presented training.
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(Closed) Open Item (313/8724-02; 368/8724-02): Instrument and Controls (I&C) Training on Meteorological Systems - This item was previously discussed in NRC Inspection Report 50-313/87-24; 50-368/87-24 and involved the lack-of formalized required on-the-job training (0JT) for I&C technicians for surveillance and calibration of the meteorological equipment and instrumentation. The NRC inspectors reviewed the licensee's evaluation of the concerns expressod in the open item. The results of the licensee's evaluation of the I&C technician's 0JT qualification program indicated that the meteorological systems equipment was, not complex enough to require a specific 0.lT qualification card.
(Closed) Open Item (313/8724-03; 368/8724-03): Commercial Harvesting of Buffalo Fish in Lake Dardanelle - This item was previously discussed in NL' Inspection Report 50-313/87-24; 50-368/87-24 and involved the licensee not sampling buffalo fish as part of the semiannual f'th sample analyzed i for determining the general population's radiation exposure via that food chain pathway. Buffalo fish are harvested commercially from Lake Dardanelle at the rate of 2,000 pounds per week. The licensee sampled and analyzed Buffalo fish from the ANO discharge canal in the Fall of 1987, Spring of 1988', and Fall of 1988. The NRC inspectors reviewed the analysis results of these fish samples and determined that the radionuclides uptake concentration in Buffalo fish was consistent with those fish species presently being sampled ir, accordance with the current radiological environmental monitoring program described in the TS.
It was concluded that the present fish samples were representative and adequate to monitor the fish radiation exposure pathway.
(Closed) Open Item (313/8724-05; 368/8724-05): Comparison of the Environmental Monitoring Dosimeter to ANSI N545-1975 - This item was previously discussed in NRC Inspection Report 50-313/87-24; 50-368/87-24 and involved the licensee's lack of evaluating the Panasonic Model 802 thermoluminescent dosimeter (TLD) for environmental applications in accordance with the testing criteria recommended in ANSI N545-1975, " Performance Testing and Procedural Specifications for TLD (Environmental Applications)" and Regulatory Guide 4.13.
The licensee conducted a ' comparison and evaluation of the present ANO environmental TLD testing program against the recommended testing criteria presented in ANSI N545-1975 and Regulatory Guide 4.13 and determined that those performance criteria not presently being tested at AND had been performed on the Panasonic Model 802 TLD by others and the test results were available. The licensee's evaluation concluded that the implementation of those TLD tests not currently being performed at ANO would not be expected to substantially upgrade the current environmental TLD testing program.
(Closed) Open-Item (313/8724-06; 368/8724-06): Meteorological System Calibration - This item was previously dismsed in NRC Inspection i Report 50-313/87-24; 50-368/87-24 and involved the lack of a i meteorological tower wind speed sensor calibration point in the 1 to _-__ -_- .. _ - _ . _. - -
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10 miles per hour (mph) range.
The NRC inspectors reviewed Procedure 1304.062, " Meteorological Mor.itoring System Calibration," Revision 2, dated December 8, 1987, and noted that Table 8.6.12 includ2s a wind speed sensor calibration point at 6.4 mph.
(Closed) Open Item (313/8724-07; 368/8724-07): Meteorological System Description in the Unit 2 Updated Safety Analysis Report (USAR) - This item was previously discussed in NRC Insp2ction Report 50-313/87-24; 50-368/87-24 and involved the fact that the meteorological instrumentation-(vancor type and model) referenced in Section 2.3.3.4 of the Unit 2 USAR was not the instrumentation currently installed on the meteorological tower. The licensee's Amendment 5 to the AND, Unit I and Unit 2 USARs, I issued July 22, 1987, contained the current design changes to the meteorological monitoring system. The NRC inspectors reviewed the ANO, Unit 1 USAR, Section 2.3.2.1.2, and the ANO, Unit 2 USAR, Section 2.3.3.4, and verified that the meteorological instrumentation described in the USARs matches the currently installed meteorological instrumentation.
(Closed) Open Item (313/8774-08; 368/8724-08): AND Plant Safety Committee Review of Analytical Services Group Procedures - This item was previously discussed in NRC Inspection Report 50-313/87-24; 50-368/87-24 and involved the apparent lack of AND management oversight concerning analytical procedures used in performance of AND TS environmental. surveillance.
The licensee evaluated the NRC inspector's concern and revised the TAS procedures to require Plant Safety Committee (PSC) review of the TAS Administrative Control Procedure TA-100, and any TAS implementing procedures for which a 10 CFR 50.59 evaluation has been performed. The NRC inspectors reviewed the licensee's evaluation and verified that the TAS Administrative Control Procedure had been reviewed on September 20, 1988, and was approved following incorporation of the PSC's comments.
3.
NRC Inspectors Observations The following are observations the NRC inspectors ciscussed with the licensee dJring the exit interview on May 12, 1989. These observations are not violations, deviations, unresolved items, or open items. These observations were identified for licensee consideration for program improvement, but the observations have no specific regulatory requirements. The licensee stated that these observations would be evaluated.
a.
Sodium Analysis - The licensee was unable to accurately analyze for low-level sodium concentrations in the radiochemistry laboratory (see paragraph 5).
b.
Unit 2 PASS Sample Port - The Unit 2 PASS reactor coolant sample port system leaked under system pressure (see paragraph 6).
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c.
Unit 2 PASS Hydrogen Analyzer - The Unit 2 PASS in-line hydrogen analyzer results was low (see paragraph 6).
d.
PASS In-Line Gamma Detector - The Unit 1 and 2 Pass in-line gamma spectrometer detectors were experiencing prot lems (see paragraph' 6).
4.
Organization anc Management Controls (83722, 84750) The NRC 1.spectors reviewed the licensee's organization and staffing of . the chemistry section (CS) and radiochemistry section (RS) to determine agreement with-commitments in Chapter 12 of the Unit 1 USAR and Chapter 13 of the Unit 2 USAR and compliance with the requirements in Section 6.2 of the Units 1 and 2 TS.
The NRC inspectors verified that the organizational structure of the CS and RS were as described in the USAR and TS. The NRC inspectors reviewed the ANO staff assignments and' management controls for the assignment of responsibilities for management and implementation of the AND chemistry and radiochemistry programs.
The NRC inspectors verified that the administrative control responsibilities specified in the ANO procedures were being implemented. The NRC inspectors discussed with the licensee the proposed organizational changes and the possible consolidation of the chemistry and radiochemistry sections.
The NRC inspectors reviewed the staffing of the CS and RS.
Since the previous NRC chemistry and radiochemistry inspection in November 1987, the CS has experienced a personnel turnover of approximately 25 percent and the RS personnel turnover has been approximately 30 percent.
All of'the recently hired technicians have college science degrees but have had no prior nuclear power facility chemistry or radiochemistry experience.
No violations or deviations were identified.
5.
Light Water Reactor Chemistry Control and Chemical Analysis (19701, 84750) The NRC inspectors reviewed the licensee's waterchemistry control and analysis program including implementation of a water chemistry control program, water sampling, facilities and equipment, implementation of a QA program for chemical measurements, audits and appraisals, and water chemistry confirmatory measurements to determine agreement with the commitments in Chapters 4, 9, 11, and 13~of the Unit 1 USAR and Chapters 5, 9, 11, and 13 of the Unit 2 USAR and compliance with the requirements in Sections 3.10 and 6.8 of the Unit 1, TS and l Sections 3/4.7.1.4 and 6.8 of the Unit 2 TS.
The NRC inspectors' review of the water chemistry programs found that the licensee had revised and approved administrative procedures, surveillance I procedures, chemical control procedures, sampling procedures, instrument calibration and quality control procedures, and analytical procedures. A review of selected procedures revised since the previous NRC water l - _ _ _ _ _ _ _ - _ _ _ _ _ - - - _ _ _ _ - __ --
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chemistry inspection in November 1967 indicated that the CS and RS had implemented sufficient programmatic procedures to meet the commitments of the USARs and the TS requirements. A list of procedures reviewed is provided in Attachment 7.
The NRC inspectors inspected the secondary chemistry laboratory and laboratory instrumentation.
The secondary chemistry laboratory was equipped with the necessary chemicals, reagents, labware, and analytical-instrumentation to r. dorm the required analyses.
The NRC inspectors reviewed selected CS and RS procedures for operation, calibration, and quality control of the laboratory analytical instrumentation used for analysis of the NRC water chemistry standards to determine adequacy and effectiveness of the licensee's water chemistry measurements program.
The NRC inspectors verified that the secondary chemistry laboratory and radiochemistry laboratory analytical instruments had been calibrated in accordance with procedures and an instrument quality control program had been implemented.
It was observed that the licensee had initiated the use of instrument quality control charts to trend quality control data collected from daily or periodic quality control analyses of chemical parameters.
The NRC inspectors verified that the licensee was using two independent standards for calibration and quality control measurements of chemistry analyt Mal instrumentation.
The NRC inspector reviewed water chemistry data for the period January through April 1989 to determine compliance with TS requirements.
It was verified that TS required water chemistry sampling and analyses had been performed.
During the inspection, standard chemical solutions were provided to the licensee for confirmatory measurements analyses.
The standards were analyzed by the licensee in both the secondary chemistry laboratory and the radiochemistry laboratory using routine methods and equipment.
The results of the measurement comparisons are summarized in Attachments 1, 2, 3, and 4 to this report The licensee's analytical results from the secondary chemistry laboratory indicated 96 percent agreement with the Brookhaven National Laboratory (BNL) results, and the analytical results from the radiochemistry laboratory were in 83 percent agreement.
The reason for the lower percentage agreement in the radiochemistry laboratory was due to the sodium contamination from the chalk on the surgeon's gloves used in the radiochemistry laboratory which gave biased high results which were not in agreement with the BNL results.
Because of this chalk contamination in the radiochemistry laboratory, accurate low-level sodium concentration's will be difficult to obtain.
' , No violations or deviations were identified.
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6.
QA and Confirmatory Measureinents for Radiochemistry Anal,vsis (84750) The NRC inspectors reviewed the licensee's radiochemical analysis program including procedures, facilities and equipment, implementation of chemistry control of the reactor coolant system and plant borated watar systems, implementation of an instrument quality control program, PASS, and radioanalytical confirmatory measurements to determine agreement with i commitments in Chapter 4, 9, and 11 of the Unit 1 USAR and Chapters 5, 9, and 11 of the Unit 2 USAR anc compliance with the requirements in
Sections 3.1.4, 3.1.5, and 6.8 of the Unit 1 TS and Sections 3/4.4.7, 3/4.4.8, and 6 8 of the Unit 2 TS.
The NRC inspectors reviewed selected radioanalytical procedures revised and approved since the previous NRC radiochemistry inspection in November 1987 and determined that the licensee had implemented sufficient j radioanalytical procedures to meet USAR and TS requirements.
The NRC inspectors reviewed the licensee's records for the period January 1988 through April 1989 involving radiochemistry counting room instrumentation calibration and quality control.
It was verified that the radiochemistry counting room instrumentation had been calibrated according to procedures and an instrument quality control program had been , l implemented.
I j The NRC inspectors inspected the PASS building and installed PASS ] equipment. The NRC inspectors verified that the PASS equipment and j associated procedures satisfied the requirements of NUREG-0737, Item II.B.3, and TS for representathe sampling and analysis of reactor
l coolant and containment atmosphere following a reactor incident.
The l licensee had completed PASS operator training for radiochemistry j technicians as part of their shif t qualification training and had j implemented a requalification training program for PASS operators which was being conducted semiannually.
The licensee haa implemented a PASS i , l surveillance and preventative maintenance program to meet TS requirements.
I The NRC inspectors reviewed the PASS surveillance test results for the I period July 1988 through April 1989 for Units 1 and 2 and found the j licensee in compliance with their surveillance commitments.
It was noted l that numerous problems with PASS operation had been identified through the licensee's surveillance progrem. The NRC inspector's review revealed that i l the Unit 2 PASS had been declared inoperable from October 1987 through l March 1989 due to the in-line hydrogen analyzer being removed from the i system for service.
The in-line hydrogen analyzer was installed and calibrated in March 1989.
l During the inspection, the NRC inspectors requested an unannounced exercise of the Unit 2 PASS.
The licensee demonstrated PASS operability ) on Unit 2 by collecting an undiluted sample of reactor coolant and i performing a boron analysis. The licensee collected a demineralized water sample in the shielded cask to demonstrate the sampling of an undfluted I' reactor coolant sanple for shipment off site for a chloride analysis at a I
contract laboratory.
The licensee performed a dissolved hydrogen analysis I ' .L_----------- -
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dissolved oxygen analysis, and isotopic analysis of a reactor coolant sample using the PASS in-line analyzers. The analytical results from the PASS sample were compared with results from a reactor coolant grab sample.
The results comparison was satisfactory except. for the dissolved hydrogen { analysis which appeared to be approximately 30 percent of the grab sample analysis result.
The licensee also performed a Unit 2 PASS isotopic , analysis of containment atmosphere. The licensee was abie to perform the requested PASS operations in accordance with NUREG-0737 requirements. The NRC inspectors observed during the PASS exercise the following deficiencies: a.
The reactor coolant sample port system leaked when system pressure was applied and had to be replaced before a sample could be taken for the bornn analysis. Under real accident conditions this would have been a significant contamination problem.
b.
The in-line hydrogen analyzer readout result was approximately 30 percent of the reactor coolant grab sample laboratory result.
The reliability and accuracy of the in-line hydrogen analyzer is questionable.
The in-line gamma spectrometer detectors were experiencing problems c.
and the Unit 1 PASS detector had been removed from the PASS making the Unit 1 PASS temporarily inoperable.
These observations were discussed with the licensee during the exit interview on May 12, 1989.
The licensee agreed to evaluate the NRC inspector's concerns and observations and take corrective actions as necessary to resolve the PASS deficiencies.
During the inspection, radiological confirmatory measurements were performed on standards and split spoles by the licensee and the NRC inspectors in the Region IV mobile laucratory on site. The standards and samples were analyzed by the licensee using routine methods and equipment.
The results of the measurements comparisons are summarized in Attachments 1, 5, and 6.
No violations or deviations were identified.
7.
QA Program (79501, 84750) The NRC inspectors reviewed the licensee's QA surveillance and audit programs regarding water chemistry and radiochemistry activities to determine agreement with commitments in Chapter 17 of the Unit 1 and 2 USAR and compliance with the requirements in Section 6.5.2.8 of the Unit 1
and 2 TS.
j The NHC inspectors reviewed selected QA surveillance 'and audit procedures, audit and surveillance schedules for 1988 and 1989, and the qualifications of the QA auditors. Audit and surveillance reports generated from QA activities during the period January 1988 through April 1989 in the area of water chemistry and radiochemistry were reviewed for scope to ensure
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. thoroughness'of chemistry / radiochemistry program evalua' tion 'and~ timely 4: followup of identified deficiencies. The NRC inspectors determined thatL Ethe surveillance,-audit plans, and checklists were comprehensive. _The.
g' ": NRC' inspectors determined that the QA surveillance and. audits had been-performed in~accordance with ANO.QA; procedures and schedules'and.by a qualified auditor who was' experienced in nuclear powerifacility:. oq chemi stry/radiochemi stry' acti vities. The documents which'were reviewed are listed in-Attachment 7(to this report.- No violations or! deviations'were ident'ified.
8.
Exit'7pterview (30703).
' < The'NRC inspectors met with the NRC senior.rm;ident inspector;andLthe; licensee representatives identified in paragraph 1Rof.this report at' the ' conclusion of the in'spection on May/12,1989. ': The NRC inspectors: , n.
i 'semmarized the' scope.of the inspection *and discussed the inspection / findings,' NRC inspector's observations,_ and the results of: the _ water . chemistry and radiochemistry-confirmatory measurements as presented:in F this. report. The licensee representatives stated at the exit interview ~ that they would evaluate the NRC inspector's concerns:and observations and
- take necessary action to implement program-improvements.
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. ._ - r - . . . ATTACHMENT 1
Analy_ticel Measurements Arkansas Nuclear One NRC Inspection Report 50-313/89-21 and 50-368/89-21 , ! 1.
Water Chemistry Confirmatory Measurements t During the inspection, standard chemical solutions were provided to the licensee.for analysis.
The standard solutions.were prepared by the Brookhaven National Laboratory (BNL), Safety and Environmental Protection Division, for the NRC.
The standards were analyzed by the licensee using routine. methods and equipment.
The analysis of chemical standards is used to verify the licensee's capability to m'onitor chemical parameters in various plant systems with respect to.
Technical Specification (TS) requirements'and other industry standards.
In addition, the analyses of standards are used to evaluate the'1icensee's analytical procedures with respect to accuracy l ~
and precision.- The results of the mes.surements comparisons are listed in Attachment i 2 for the secondary cnemistry laboratory and in Attachment 3 for the-l r' radiochemistry laboratory.
Attachment. 4 contains the criteria. used to j compare results.
All standards were analyzed in triplicate.
i { I The licensee's original analytical results from the secondary chemistry laboratory indicated problems with the analyses for iron and silica.
The original results showed 17 of the 24 results were in I agreement.
(a) The licensee's original iron results were all in disagreement and biased low.
The licensee prepared new calibration standards a and recalibrates the ion chromatograph in' the' secondary chemistry l laboratory and reanalyzed the original BNL standard dilutions.
The retest results were in agre ment except for the low concentration.
(b) The licensee's original silica results were all in disagreement and biased low.
The licensee made dilutions fromethe 86 Series BNL silica standards and ran the silica analysis'on these-
standards.
All results were in agreement.
The' licensee did not recalibrates the spectrometer.
'The.results indicate that the 87 Series BNL silica' standard values may be in error and biased low.
. The licensee's final analytical results from the secondary chemistry laboratory, after the retests'in an attempt to resolve the'eriginal' disagreements, indicated 96 percent agreement with the BNL results-based on 23 agreement results out of 24 results comparea, l ' , l m___ _ _ _ _ -__-_-_ _.
_ , . ATTACHMENT 1
The' licensee's original analytical results from the radiochemistry laboratory indicated problems with the low-level sodium analysis.
The original results showed 15 of the 18 results were in agreement.
The licensea's original sodium results were all in' disagreement and biased high.
The licensee noted that the chalk on the surgeon's gloves used in the radiochemistry laboratory contributed a sodium contamination to the diluted ENL standards.
The licensee attempted to wash the gloves and laboratory area before preparing new BNL standard dilutions..The results of the retests showed lower sodium concentrations, but the sodium analysis results were still in disagreement.
As long as the radiochemistry laboratory continues to use the chalk lined gloves, low-level sodium concentrations will be difficult to accurately obtain.
The licensee's final results from the radiochemistry laboratory indicated 83 percent agreement.
! The unresolved disagreements are not considered to indicate any programmatic problems.
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a ATTACHMENT 1
2.
Radiological Confirmatory Measurements Confirmatory measurements were performed on the following standards and samples in the NRC Region IV mobile laboratory at Antansas Nuclear I One during the. inspection: (1) Air Particulate Filter Standard (2) NRC Charcoal Cartridge Standard (3) AND Charcoal Cartridge Standard (4) Waste Liquid Monitor Tank Sample - 1.0 liter Marinelli beaker (5) Reactor Coolant Gas Sample - 15cc Gas Vial (6) Reactor Coolant Liquid Sample - 20ml Liquid Scintillation Vial (7) Containment Atmosphere Sample - 1.0 liter Gas Marinelli beaker (B) Reactor Coolant Tritium Sample The radiological confirmatory measurement tests consisted of comparing the analysis results of the licensee and the NRC Region IV mobile laboratory.
The NRC's mobile laboratory measurements are referenced to the National Institute of Standards and Technology by laboratory intercomparisons.
Confirmatory measurements are made only for those nuclides identified by the NRC as being present in concentrations greater than 10 percent of the respective-isotopic values for liquid and gas concentrations as stated in 10 CFR Part 20, Appendix B, Table II.
At the time of the inspection, the licensee utilized two germanium-lithium detectors in the radiochemistry counting room for comparison with the NRC results.
The analytical results from these two detectors were compared with the NRC results.
The licensee performed the tritium analysis on their liquid scintillation counting system.
The individual sample analyses and comparison of analytical results of the radiological confirmatory measurements are tabulated in Attachment 5, as caves 1 and 2.
Attachment 6 describes the criteria ! used to compare the analytical results.
' The licensee's gamma isotopic results from the listed standards and j samples in Attachment 5 showed 99 percent agreement with the NRC analysis results.
The licensee's tritium result of the reactor j coolant sample was in agreement with the NRC analysts result.
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.... g .. i .. . t , . \\ - ATTACHMENT O '] ' Water ' Chemi stry Confirmatory Measurements Results (Secondarv' Chem. Lab.)
I Arkansas Nuclear One NRC Inspection Report: 50-313/89-21 and 50-368/89-21 > 1.
' Chloride Analysis ~ (5-40 ppb) Ion Chromatograph l-ANO Results NRC Results ANO/NRC Comparison.
! Samole (oob) .budfL Ratio Decision 87A 10.110.1' '9.310.1 1.09iO.04 Agreement 87B 19.910.2 18.7 0.2 1.0310.02 Agreement 87C 40.710.7' 38.310.6 .1.06 0.03 Agreement
2.
Sulf ate Anal ysis (5-40. ppb) Ion Chromatograph AND Results-NRC Results ANO/NRC Compari son - Samole (nob) (oob) . Ratio Deci si on 87A 10.110.3 9.810.7 1.0310.08 Agreement 87B 19.110.7 19.211.4 0.99 0.08 Agreement l 87C 41.2i2.4 39.011.2 1.06io.07 Agreement l , 3.
Iron Analysis (5-20 ppb) Graphite Furnace Atomic Absorption ANO Results NRC Results AND/NRC Comparison Samole (oob) (pob) Ratio Deci si on
878 5.610.1 6.210.2 0.9010.03 Disagreement 87H 10.6 0.3 13.310.2 0.BOio.03 Disagreement 871 15.910.1 19.5 0.5 0.8210.02 Disagreement . Retest - after instrument recalibration using new calibration
standards-878 7.110.1 6.210.2 0.8810.03 Disagreement , 87H 13.510.5 13.3 0.2 1.0210.04 Agreement ! L 871 19.710.4 19.5io.5.
1.01 0.03 Agreement- ! I j l .\\ ' l 4.
Cooper Anal ysi s (1-10 ppb) Braphite Furnace Atomic Absorption l ANO Results NRC Results AND/NRC Comparison Sample (oob) (oob) Ratio-Deci si on 878 3.3 0.1 3.3 0.1 1.0010.01 Agreement-87H 6.4 0.1 6.710.3 0.96iO.05-Agreement' l '87I 9.7iO.3 10.010.3 0.9710.04 . Agreement L ! -l L
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5.
Sodium Analysi s (5-100 ppb) Flame Atomic Absorption AND Results NRC Results ANO/NRC Comparison Sample (oob) 1pob) Ratio Decision 87J 5.9 0.2 6.110.7 0.9910.12 Agreement 87K 23.910.2 21.2it.2 1.1310.07 Agreement 87L 89.613.5 79.014.5 1.1310.08 Agreement 6.
Ammonia Analysi s (140-700 ppb) Ion Chromatograph ANO Results NRC Results ANO/NRC Comparison Sampl e (oob) (oob) Ratic Decision 87M 337 7 346116 0.97iO.05 Agreement 87N 14612 150 2 0.97 0.02 Agreement 870 50216 492123 1.0210.05 Agreement 7.
Hydrazine Anal ysis (20-100 ppb) Spectroscopy AND Results NRC Results AND/NRC Comparison Sampl e (opb) (oob) Ratio Decision 87P 20.9 1.2 19.910.3 1.0510.06 Agreement 870 50.810.3 49.910.5 1.02 0.01 Agreement 87R 99.910.4 100.0 1.0 0.99 0.01 Agreement 8.
Silica Anal vsi s (5-100 ppb) Spectroscopy ANO Results NRC Results ANO/NRC Comparison Sampl e (pob) (oob) Ratio Decision 87S 10.210.2 13.2iO.7 0.77 0.04 Disagreement 87T 45.210.7 52.012.0 0.8710.04 Disagreement 87U 70.1 0.5 78.511.0 0.8910.01 Disagreement Retest - using the 86 Series BNL standards; no changes in instrument calibration 87S 18.0 0.6 18.111.9 0.99 0.10 Agreement S7T 26.8 1.0 27.3 1.8 0.9810.06 Agreement 87U 78.210.9 80.012.5 0.9810.03 Agreement i ________ ----- -- -- i
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, .. ATTACHMENT 3 Water Chemistry Confirmatory Measurements Results (Radiochem. Lab.)
Arkansas Nuclear One NRC Inspection Report: 50-313/89-21 and 50-368/89-21 1.
Fluoride Analysis (10-50 ppb) Ion Chromatograph AND Results NRC Results ANO/NRC Comparison.
Samole (oob) 1pob) Ratio Deci si on 87A 20.610.1 22.5 2.0 0.92iO.08 Agreement 87B 39.910.1 42.3 0.4 0.94iO.03 Agreement 87C 26.7 0.1 27.610.6 0.9710.02 Agreement 2.
Chloride Analysis (10-50 ppb) Ion Chromatograph ANO Results NRC Results ANO/NRC Comparison Sample 1906) (oob) R,atic Decision 87A 19.610.6 18.5iO.1 1.0610.03 Agreement 87B 37.810.1 37.310.3 1.01 0.01 Agreement 87C 24.910.2 25.5tO.4 0.98iO.02 Agreement 3.
Sulf ate Analysis (10-50 ppb) Ion Chromatograph AND Results NRC Results AND/NRC Comparison Sampl e (oob) (nob) Ratio peci si on 87A 19.410.4 19.511.4 0.99 0.07 Agreement 87B 37.910.4 38.3 2.7 0.99 0.07 Agreement 87C 25.310.5 26.OiO.8 0.97 0.04 Agreement 4.
Baron Analysis (100-2000 ppm) Manitol Titration ANO Results NRC Results ANO/NRC Comparison Sample (com) (com) Ratio Deci si on 87D 99714 1040110 0.9610.03 Agreement i 87E 299 1 30Bi4 0.9710.01 Agreement l 87F 162716 1666130 0.9810.02 Agreernent ) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. - - _ _ _ _ _ _ _ _ - _ _ __ _ _ l
q i , .
,. < ATTACHMENT 3
.] 5.
Sodium ' Analysis (0.1-1.O' ppm) Flame Atomic Absorption 'ANO Results.
NRC Results-ANO/NRC Comparison Sample (oom) (nom) Ratio Decision 87J-0.5510.03 0.30iO.04 1.83 Disagreement 87K O.8010.01 0.5310.03 '1.51 Disagreement j 87L 1.0310.02 0.7910.05.
1.30 Disagreement l l l Retest - after washing the chalk off the surgeon's gloves and-laboratory bench. area in the radiochemistry laboratory; sample bottles were also washed B7J 0.4010.01 0.30iO.04 1.33 Disagreement 87K O.6010.02 0.5310.03 1.13 Disagreement 87L O.8710.01 0.79 0.05 1.10 Disagreement 6.
Lithium Analysis (0.1-1.0 ppm) Flame Atomic Absorption AND Results NRC Results ANO/NRC Comparisons l Samole (com) - (oom) Ratio Deci si on 87J 0.22iO.01 0.2010.01 1.1010.05-Agreement 87K O.6410.01 0.6010.01 1.07iO.04 Agreement 87L O.B2 0.01 0.83 0.02 0.98tO.03' Agreement i I
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4 ATTACHMENT 4 CRITERIA FOR CCM. OARING WATER CHEMISTRY ANALYTICAL MEASUREMENTS This attachment provides criteria f or comparing results of capability tests.
In these criteria the judgement limits are based on the uncertainty of the ratio of the licensee's value to the NRC value.
l The following steps are performed: (1) The ratio of the licensee's value to the NRC value is computed Licensee's Value , ratio ); and , . = NRC VALUE (2) the uncertainty of the ratio is propagated.
If the absolute value of one minus the ratio is less than or equal to twice the ratio uncertainty, the results are in agreement.
(l1-ratioj i2x uncertainty) S$. S$ S#p y Z= then = + , y
x2 y2 1 (From: Bevington, P.
R., Data Reduction and Error Analysis f or the Physi c al Sciences, McGraw-Hill, New York, 1969) i ____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ i
-_ S l i . . j > . i ATTACHMENT 5 BAdiolooical Confirmatory Measurement Results-Arkansas Nucl ear One' .1 I NRC Inspection Report: 50-313/89-21 and 50-368/89-21 I i '1 Air Particulate Filter Standard . (Standardized: 08:00, CDT, May 8, l'989) AND Recults NRC Results ANO/NRC Comparison' ] Nuclide (uCi /samol e) ' (uCi /sampl e) Ratio Deci si on
I ~Cd-109 1.71110.OOSE+0 1.551do.OO4E+0.
1.10 Agreement l 1.56510.OOBE+0 1.01 Agreement Co-57 2.41110.014E-2 2.235tO.010E-2' 1.08 Agreement 2.246tO.02OE-2 1.01 Agreement
I Ce-139 9.'760iO.119E-3 9.375 0.083E-3 1.04 Agreement q 9.133tO.157E-3 0.97 Agreement l Hg-203 5.938ii.021E-4 5.120iO.734E-4 1.16 Agreement , 6.81411.349E-4 1.33 Agreement j Sn-113 1.460io.025E-2 1.136 0.019E-2 1.07 Agreement
1.32710.035E-2 0.98 Agreement
Cs-137 8.91410.053E-2 8.26310.040E-2 1.08 Agreement B.478iO.063E-2 1.03 Agreement Y-88 2.062iO.041E-2 1.950iO.030E-2 1.06 Agreement 2.090iO.052E-2 1.07 Agreement l Co-60 9.212iO.062E-2 8.8811.052E-2 1.04 Agreement ~9.219 0.077E-2 1.04 Agreement 2.
NRC Charcoal Cartridae Standard (Standardized: 08:OO,.CDT, May 8, 1989) AND Results NRC Results ANO/NRC Comparison.
i Nuclide (uCi /sampl e) (uCi /sampl e) Ratio Deci si on l i Cd-109 1.15310.OO4E+0 1.02810.OO3E+0 1.12 Agreement 1.14110.OO7E+0 1.11 Agreement , 'Co-57 2.313 0.012E-2 2.077tO.012E-2 1.11 Agreement , 2.282iO.019E-2 1.10 Agreement i i Ce-139 1.51610.012E-2 1.368 0.013E-2 1.11 Agreement L 1.501iO.018E-2 1.10 Agreement
, ' ~' i - y m , , , Q,l ' s -
- q
'+
- ,.
- , . . + z.
- ATTACHMENT 5
i AND Results' NRC'Results AND/NRC Comparison 'Nuclide (uCi /samol e) - (uCi /samole) Ratio-Decision ' Hg-203' 4.052iO.107E-3; 3.502io.105E-3 1.16; ' Agreement ,, 3.950iO.178E-3; '1.13 ~ - Agreement: e .En-113L L3.10810.02SE-2 12.783iO.026E-2 1.12 Agreement-13.03510.035E-2
- 1.09
/ Agreement- ' Cs-137: 7.039iO.042E-2 e.285 0.040E-2' 1.12 Agreement, 17.OO310.052E-2' 1.11' ' Agreement Y-88 3.92110.040E-2 s3.592 0.039E-2 [1.09 - Agreement 3.87710.051E-2 1.00'
- Agreement
'Co-60 8.053io.053E-2 6.996iO.051E-2 1 ~.15.
Agreement' 7.772io.063E-2 1;11 Agreement 3.
AND C'harcoal Cartridae Standard (Standardized: 11:00, CST,: January 1,' 1989)' AND Results NRC Results AND/NRC Comparison 'Nuclide (uCi /sampl e) ' (uCi /samol e) Ratio.
Deci si on ' Cd-109 2.728iO.OO6E+0 2.493 0.OO6E+0 1.09.
Agreement 2.60910.010E+0 1.05 Agreement Co-57- -6.50310.026E-2 5.778 0.023E-2 1.13 Agreement 6.265 0.040E-2 1.08 Agreement J Ce-139 8.816to.037E-2 8.OOOiO.037E-2 1.10 Agreement 8.507 0.059E-2 1.06 Agreement Hg-203 1.866io.015E-1 1.696iO.014E-1-1.10 Agreement 1.82410.020E-1 1.08-Agreement Sn-113-2.122 0.010E-1 1.910iO.010E-1 1.11 Agreement j 2.008 0.013E-1 1.05-Agreement .
- Cs-137 1.225iO.OO5E-1 1.115iO.OO6E-1 1.10 Agreement i
1.198iO.OO7E-1 1.07 Agreement . J Y-88 2.806 0.014E-1 2.544iO.016E-1 1.10 Agreement j 2.720iO.020E-1 1.07-Agreement ] . l Co-60 1.67410.OO7E-1 1.54110.OOBE-1 1.09 Agreement' ! 1.62110.OO9E-1 1.05 Agreement l l l l ! ! l l - _ - - - - - _ - -. - - _ -- - - - - - - -. -_- - - - - - -_ __-_------J
. a ATTACHMENT 5
4.
Waste Liouid Monitor Tank Sample - 1.0 liter Marinelli beaker (Sampled: 10:10, CDT, May 10, 1989) AND Results NRC Results AND/NRC Comparison Nuclide (uCi /ml ) (uCi/ml) Ratio Decision Mn-54 5.56710.132E-6 5.708 0.157E-6 0.98 Agreement 6.11910.161E-6 1.07 Agreement Co-58 4.08110.121E-6 4.03410.126E-6 1.01 Agreement 4.330 0.140E-6 1.07 Agreement Co-60 1.842 0.086E-6 2.11010.104E-6 0 87 Agreement 1.890iO.101E-6 0.90 Agreement I-131 5.625io.83BE-7 6.942iO.956E-7 0.81 Agreement 5.44611.074E-7 0.79 Agreement
Cs-134 1.827 0.107E-6 1.917 0.111E-6 0.95 Agreement 1.98810.129E-6 1.04 Agreement Cs-137 4.78310.131E-6 4.730iO.129E-6 1.01 Agreement 5.41310.154E-6 1.14 Agreement l 5.
Reactor Coolant Gas Sample - 15cc Gas Vial (Bampled: 09:36, CDT, May 10, 1989) ! l AND Results NRC Results AND/NRC Comparison l Nuclide (uCi/cc) (uCi /ce) Ratio Decision l ! Ar-41 1.22510.031E-1 1.32810.017E-1 0.92 Agreement l 1.23910.031E-1 0.93 Agreement l Kr-85m 2.67010.018E-1 2.703 0.OOBE-1 0.99 Agreement 2.69210.022E-1 0.99 Agreement Kr-87 2.54810.036E-1 2.61310.OO2E-1 0.98 Agreement 2.59610.038E-1 0.99 Agreement Xe-133m 1.289tO. OBOE-1 1.29910.OO3E-1 0.99 Agreement 1.422iO.100E-1 1.09 Agreement Xe-133 5.53310.010E+0 5.222iO.040E+O 1.06 Agreement 5.59010.011E+0 1.07 Agreement Xe-135m 7.772iO.546E-2 9.12110.323E-2 0.85 Agreement 6.97610.547E-2 0.76 Agreement Xe-135 1.59810.OO4E+0 1.643tO.OO2E+0 0.97 Agreement 1.634to.OO4E+O O.99 Agreement l - - - - _ -
,- _ . I i ATTACHMENT 5
i 6.
Reactor Cool ant Li oul d Sampl e - 20ml Li auid Scintill ation Vial (Sampled: 09:17, CDT, May 10, 1989) ANO Results NRC Results AND/NRC Comparinon Nuclide (uCi /ml ) (uCi/ml) Ratio Decision , Na-24 2.81610.030E-2 2.755 0.019E-2 1.02.
Agreement 2.772iO.028E-2 3.01 Agreement Co-58 1.322iO.117E-3 1.24110.071E-3 1.07 Agreement 1.42310.066E-3 1.15 Agreement Nb-95m 4.953i2.193E-4 5.17211.104E-4 0.96 Agreement 5.15912.484E-4 1.00 Agreement Nb-95 4.890iO.746E-4 4.122iO.579E-4 1.19 Agreement 4.600iO.979E-4 1.12 Agreement ]
Ru-106 1.13410.09BE-2 9.394 0.602E-3 1.21 Agreement 1.189iO.089E-2 1.27 Agreement j i I-131 2.34010.122E-3 2.312iO.072E-3 1.01 Agreement l I 2.430iO.127E-3 1.05 Agreement I-132 1.779tO.023E-2 1.739tO.018E-2 1.02 Agreement 1.82710.022E-2 1.05 Agreement I-133 1.220 0.015E-2 1.20410.OO9E-2 1.01 Agreement 1.290iO.015E-2 1.07 Agreement I-134 3.210iO.060E-2 3.OB3tO.059E-2 1.04 Agreement 3.29310.063E-2 1.07 Agreement i I-135 1.95410.060E-2 2.052 0.044E-2 0.95 Agreement l 2.01810.057E-2 0.98 Agreement Cs-134 9.042 0.169E-3 8.28310.123E-3 1.09 Agreement l ' 9.252to.174E-3 1.12 Agreement Cs-137 1.24410.016E-2 1.20510.010E-2 1.03 Agreement 1.25310.016E-2 1.04 Agreement Cs-138 4.433 0.162E-2 4.58310.123E-2 0.97 Agreement 4.33210.153E-2 0.95 Agreement Ba-139 4.38810.636E-3 4.46310.286E-3 0.98 Agreement 4.11010.757E-3 0.92 Agreement _ _ _ _ _ _ _ _ _ _ _ _.
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j l
. . .. . ATTACHMENT 5
l
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Containment Atmosphere Samole - '1. 0 lite'r' Gas Mari nelli beaker l (Sampled: 14:15, CDT, May 10, 1989) -i AND Results NRC Results AND/NRC Comparison y Nuclide (uCi/cc) (uCi/cc) Ratio Decision j . i Xe-133 3.56610.019E-4 4.089 0.010E-4 0.87' Agreement
3.610iO.030E-4 0.88 Agreement Xe-133m 3.74310.680E-6 4.764iO.280E-6 0.79 Agreement 4.91211.318E-6 1.03 Agreement i Xe-135 6.999 0.194E-6 8.820iO.094E-6 0.79 Disagreement 7.034 0.297E-6 0.00 Agreement 8.
Reactor Coolant Tritium Samole (Sampled: 09:17, CDT, May 10,.1989) AND Results NRC Results .AND/NRC Comparison'- Nuclide (uCi /ml ) (uCi /ml ) -Ratio Decision . H-3 1.5310.01E-01 1.37 0.01E-01 1.11 Agreement ! ! i )
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. , ATTACHMENT 6 CRITERIA FOR COMPARING RADIOCHEMISTRY ANALYTICAL MEASUREMENTS The f ollowing are the criteria used in comparing the results of capability tests and verification measurements.
The criteria are based on an empirical 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.
, l ' NRC VALUE . = l Resolution l NRC UNCERTAINTY LICENSEE VALUE Radi o = NRC VALUE l J Comparisons are made by first determining the resolution and then-reading across the same line to the corresponding ratio.
The ] f ollowing table shows the acceptance values.
l RESOLUTION AGREEMENT RAT: 0 l
- i <4 0.40 - 2.50 4-7 0.50 - 2.00 8-
0.60 - 1.66 16 - 50 0.75 - 1.33
51 - 200 0.00 - 1.25 ! >200 0.85 - 1.19 The above criteria are applied to the f ollowing analyses: (1) Gamma 9 spectrometry (2) Tritium in liquid samples (3) Iodine on adsorbers 8' 9
(4) Sr and Sr determinations (5) Gross Deta where samples are counted on the same date using the same reference nuclide.
L ___ ___
tv- ' . . ' , ATTACHMENT 7s DOCUMEi4TS REVIEWED ARKANSAS NUCLEAR ONE NRC-Inspection Report: 50-313/89-21 and 50-368/89-21 Title Revision-Date 1.
Administrative Procedures 1000.042, Steam Generator Water Chemistry
10/04/85-Monitoring - Unit One 1000.043, Steam Generator Water Chemistry
12/06/85 Monitoring - Unit Two q , 1042.001, List of Radiochemistry Forms
02/23/89 and Attachments 1042.002, Quality Control Guidelines and
08/09/88' , Acceptance Criteria j 1042.003, Radiochemistry Routine Surveillance
01/15/88 Schedule and Tech. Spec. Surveillance Reporting 1042.005, Lithium Control
07/15/88 1042.006, Analytical Accuracy Assessment
07/05/88 Program l l 1042.008, Radiochemistry Surveillance
08/26/87~ L Trending Program 1042.010, Radiochemistry Computer Management
05/03/89 and Software / Data File Control Procedure 1052.001, Chemistry Control Inventory and
07/03/84 Storage 1052.002, Chemistry and Environmental
08/08/84 ' Administrative Procedures 1052.003, Chemistry and Environmental Quality
06/27/84 Control Procedures 1052.007, Secondary Chemistry Monitoring
08/08/84 = _ - _ _
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2.
Radiochemistry Procedures 2004.002,' Gross Beta and Gamma Spectroscopy
04/13/87 Sample Preparation 1604.003, Tritium Sample Preparation
.02/14/89 1604.004, Liquid Scintillation Counting For.
02/14/89 Gross Beta and Tritium Measurements
1604.007, Determination of pH of an Aqueous.
04/09/87 Solution I 1604.012, E-Bar Determination
03/24/87 1604.030, Determination of Boron-High Range
02/13/88 1604.035, Preparation of Radioactive Standards
04/05/89-1604.039, Determination and Addition of
03/25/86 Hydrazine 1604.040, Dissolved Silica Analysis
10/21/87 1604.043, Chemical Analysis Using the Ion
09/07/88 Chromatograph 3.
Secondary Chemistry Procedures 1605.015, Determination of Hydrazine - Low
02/22/88 Range (Photometric Method) 1605.025, Determination c' Silica (Photometric
04/18/88 Method) 1505.026, Determination of Sodium (AE Method)
06/16/88 1605.032, Determination of Sulfate by Ion
05/04/88 Chromatography 1605.033, Determination of Chloride by Ion
04/26/88 i Chromatography 1605.037, Determination of Copper (A Method)
03/01/89 . 1505.039, Determination of Iron (AA Method)
02/28/89
1605.063, Determination of Ammonia by Ion
01/25/89 Chromatography _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _
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~ 1606.008, Atomic Absorption Unit Startup,
05/30/84 Shutdown, and Calibration of the IL 551 in the Emission Mode ) 1606.009, Atomic Absorption Unit Startup,
11/22/82 j Shutdown, and Calibration of the Grafite ' Furnace 1606.012 Ion Chromatography Startup, Shutdown,
07/16/86
and Calibration of the Dionex 20101.
1606.014, Atomic Absorption Unit Startup
05/16/84-Calibration and Shutdown of the IL 451 in Emission Mode 4.
~ Quality Assurance (QA) Surveillance and Audits ( QAP-22,. Quality Assurance Procedure - Chemistry
12/10/88 and Radiochemistry QA Audit Report, QAP-22-88, " Chemistry / Radiochemistry," performed September 28, 1988 - February 21, 1989 , QA Surveillance Report 88-086, " Quality Control for Chlorides on the Ion Chromatograph," dated May 11, 1988 QA Surveillance Report 88-102, " Chemistry.
Analysis - Sodium Analyzers," dated May 27, 1988 QA Surveillance Report 88-116, " Offload of Chemical Trucks," dated June 9,1988 QA Surveillance Report 88-119, " Sampling Unit 2 Reactor Coolant," dated June 9, 1988 QA Surveillance Report 88-136, " Unit 2 Tech. Specs.
RCS Chemistry Sample Analysis," dated July 14, 1988 QA Surveillance and Report 88-188, " Evening Shift Chemistry Sampling and Analysis," dated August 31, 1988-QA Surveillance Report 88-218, " Shift Turnover for Chemistry and Radiochemistry," dated September 29, 1988 QA Surveillance Report 88-290, " Calibration of Radiochemistry Instruments (Midshift)," dated December 16, 1988 - - _ _ _ _ _ _ _ _ _ - - - - - _ - _ _ _ _ _ _ _ _ - _ _ }}