IR 05000346/1993008
| ML20035G005 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/19/1993 |
| From: | Steven Orth, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20035G003 | List: |
| References | |
| 50-346-93-08, 50-346-93-8, NUDOCS 9304260019 | |
| Download: ML20035G005 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION j
REGION III
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Report No. 50-346/93008(DRSS)
Docket No. 50-346 License No. NPF-3 Licensee:
Toledo Ed: son Company Edison Plaza 300 Madison Avenue Toledo, Ohio 43652 facility Name:
Davis-Besse Nuclear Power Station Inspection At: Davis-Besse Nuclear Power Station, Oak Harbor, Ohio
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Inspection Conducted: April 5-9, 1993
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Inspector u. K. Orth Date
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YY Approved By:
M. C. Schumacher, Chief Date
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Radiological Controls Section 1 i
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Inspection Summary
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Inspection on April 5-9. 1993 (P.eDort No. 50-346/93008(DRSS))
Areas Inspected:
Routine announced inspection of: (1) the chemistry program (IP 84750) including, organization, training, reactor systems water quality
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control programs, quality assurance / quality control program in-the laboratory,
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and nonradiological confirmatory measurements, (2) the Radiological Environmental Monitoring Program (REMP) (IP 84750), and (3) review of previous
inspection findings (IP 84750).
Results:
The licensee's nonradiological measurements continued to be good.
i Primary and secondary water chemistry parameters were well maintained and
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consistent with industry practices (Section 6). The quality control program for inline and laboratory instruments was very good. Examples of poor control of laboratory standards were identified but were corrected during the l
inspection (Section 7).
The REMP program continued to be properly implemented.
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9304260019 930419 l
PDR ADOCK 05000346
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DETAILS l
1.
Persons Contacted
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- R. Scott, Chemistry Superintendent
- J. Polyak, Radiation Protection Manager
- A. Rabe, Quality Assurance Supervisor D. Hennin, General Supervisor, Chemistry
- R. Edwards, Chemistry Analyst
- J. Lochotzki, Associate Technologist
- G. Bradley, Licensing
- D. Hainman, Licensing Supervising Engineer G. Gillespie, Chemistry Technologist R. Hessersmith, Chemistry Supervisor J. Sankovich, Chemistry Trainer M. Land, Senior Chemistry Tester R. Hoffman, Senior Chemistry Tester
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- S. Stasek, Senior NRC Resident Inspector F
- The above personnel were p esent at the Exit Meeting on April 8, 1993.
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The inspector also contacted other licensee employees in the course of
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the inspection.
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2.
Licensee Action on Previous Inspection Findinos (IP 84750)
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(Closed) Inspection Followup Item (346/91007-01): The-licensee was to
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analyze a liquid sample for H-3, Sr-89, Sr-90, and Fe-55 and report the
results to Region III. The results are listed in Table 1 and the
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comparison criteria in Attachment 1.
The results indicated good comparisons for the Sr-89 and Fe-55 analysis.
However, the H-3 and Sr-j 90 analysis were in disagreement with the NRC reference laboratory's
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results. After relaxing the acceptance criteria to account for the poor counting statistics, the Sr-90 result was in agreement with the NRC reference laboratory result and the H-3 analysis just missed agreement.
These analyses will be reviewed in the next confirmatory measurements inspection.
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3.
Manaaement Control and Oraanization (IP 84750)
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The inspector reviewed the Chemistry Unit organization and discusse'd it with the licensee. The chemistry group has remained virtually unchanged i
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since the last inspection. The chemistry superintendent reported to the operations manager, who reported to the plant manager.
Two chemistry
technologists, a chemistry clerk, a chemistry analyst, and the chemistry i
general supervisor reported to the chemistry superintendent. Twenty
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chemistry testers (cts)-and five supervisors reported to the chemistry general supervisor.
In 1991, the chemistry group lost one chemistry analyst; this position was subsequently eliminated.
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The chemistry group had its full complement of cts, all of who were l
fully qualified by the requirements of the licensee's-training program.
- The chemistry unit continued to be very stable and experienced.
The REMP group consisted of an environmental supervisor and six technologists. During the course of the inspection, one of the technologists resigned from the group, leaving a position which the i
licensee did not expect to be filled.
No violations or deviations were identified.
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Confirmatory Measurements (IP 84750)
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The inspector submitted chemistry samples to the licensee for analyses as part of a program to evaluate the laboratory's capabilities to monitor nonradiological chemistry parameters in various plant systems
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with respect to regulatory and administrative requirements. These samples had been prepared, standardized, and verified for the NRC by the i
Analytical Chemistry Division of Oak Ridge National Laboratory (ORNL).
The samples were analyzed by the licensee using routine methods and
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equipment.
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Three dilutions were made for each sample by licensee personnel, as
necessary to bring the concentrations within the ranges normally
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analyzed by the licensee's laboratory, and were analyzed in a manner similar to that of routine samples. The results are presented in Table 2 which also contains the criteria for agreement.
These criteria are based on analyses of the standards and on the relative standard deviations (RSD) derived from the results of the plants participating in the 1986 interlaboratory comparisons (Table 2.1, NUREG/CR-5422).
The acceptance criteria are such that the ratio of the licensee's result and the standard value should be within 2 Standard Deviations (SD) of the
standard value for agreement and between 2 and 3 SD for a qualified
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agreement. A qualified agreement may indicate a bias in the assay.
The licensee determined nine analytes at three concentrations each and one analyte at two concentrations. Of the 29 analyses, 25 of the i
licensee's values were in agreement and 4 were in disagreement.
Four of
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the licensee's agreements were qualified agreements.
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The licensee's initial analyses of the three sodium samples resulted in one disagreement and two qualified agreements. The sodium analytes were prepared by ORNL using weak nitric acid; however, the licensee calibrates their flame atomic absorption spectrophotometer (AAS) for _
i sodium via neutral standards. Upon acidifying the calibration standards
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and using a multiple point calibration curve, the sodium disagreement-l and qualified agreements became agreements. The inspector discussed the adequacy of the licensee's current AAS calibration practice, which uses
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a single standard and a blank.
The licensee acknowledged the inspector's comments and will evaluate their current method.
This will be reviewed in future inspections.
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i The inspector discussed the disagreements in the low concentration
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chloride and sulfate cnalyses with the licensee. The licensee
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recalibrated the ion chromatograph (IC), yet the analysis still yielded similar results. The licensee suggested that the samples may have been chemically contaminated while transferring the samples from the original sample vials. The licensee reanalyzed a new standard and achieved agreements for both sulfate and chloride at a higher concentration. The i
adequacy of the lower ranges of the licensee's fluoride and sulfate
calibration curves were still to be verified and will be followed in i
future inspections.
i The licensee is to prepare a sample containing an appropriate amount of the anions, diluted with secondary water, to obtain an approximate
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concentration of 20 parts per billion (ppb). This sample will be divided into two aliquots to be analyzed by the licensee and the NRC
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reference laboratory for chloride, sulfate, and fluoride.
The results
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of this analysis will be submitted to the Region III office for comparison.
This will be followed under Inspection Followup Item No.
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346/93008-01.
i The inspector observed the cts performing the analyses and a CT
obtaining primary chemistry samples. Generally, the cts demonstrated
good technique and analytical practices, with the exception that cts did
not always rinse new sample containers prior to transferring solutions.
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Licensee representatives acknowledged that this could be a source of
chemical contamination in the analyses. Also, the inspector discussed
with the licensee some poor examples of reagent / standard labeling in the i
laboratory.
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No violations or deviations were identified.
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Trainino and Oualification of Personnel (IP 84750)
The inspector discussed the licensee's CT training program with the chemistry training supervisor. Continuing training was completed three i
times a year for the cts and was comprised of topics submitted by chemistry management, instruction on +ew instrumentation and methods,
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and review of the post accident sampling system (PASS) analyses.
Chemistry supervisors also attend this training along with other i
industry sponsored training and seminars.
Technicians were required to
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attend classroom training, on the job training, and successfully pass
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examinations to meet this requirement.
If a technician did not obtain a-
score of 70 percent or greater on the examinations, he/she was provided.
remedial training and was retested. Overall, the success rate was good.
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The inspector reviewed the licensee's training records and training reports. They appeared to be well maintained.
No violations or deviations were identified.
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Water Chemistry Control Procram (IP 84750)
The inspector reviewed the licensee's water chemistry control program.
The licensee maintained administrative limits on water quality, as defined in procedure DB-CH-06900, " Operational Chemical Control Limits",
Revision 2, November 18, 1991, which met, and sometimes exceeded, the EPRI PWR Owners Group Guidelines. The inspector reviewed selected trends in water quality over the last operating cycle, November 1991 through March 1993, and found chemistry parameters to be well maintained.
The primary system's water quality remained very good. The reactor coolant system chloride and fluoride concentration were maintained below 3 ppb with an EPRI normal value of 150 ppb for each. The secondary water chemistry was also maintained within the EPRI Owners Group
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Guidelines. The dissolved oxygen averaged less than 1 ppb as compared to an EPRI normal value of 5 ppb. The iron concentration was less than 2 ppb with an EPRI normal value of 10 ppb. Because the licensee uses morpholine for pH control in steam generators, the licensee's cation conductivity is at or above the EPRI 0.2 micro-Siemen/cm (uS/cm) limit.
Chemistry parameters are computerized on the licensee's Chemistry Data Acquisition Management System (CDAMS). All levels of chemistry management review the parameters and historical trends on a daily basis.
The inspector reviewed the boron concentration in the reactor water storage tank, boric acid addition tanks, and the core flooding tanks.
The boron concentrations were maintained within the limits of the Technical Specifications.
No violations or deviations were identified.
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Implementation of the laboratorv OA/0C Proaram (IP 84750)
Chemistry quality control was very good. The inspector reviewed the chemistry quality control program as defined in DB-CH-00010, " Chemistry Quality Control Program", Revision 3, January 4,1993.
The licensee continued to maintain statistically based control charts for the laboratory instruments, to participate in an interlaboratory cross-check program, and to perform technician proficiency testing.
The inspector reviewed selected control charts for the laboratory instrumentation. The licensee determined control limits at 3 SDs and investigated trends based on predefined criteria in DB-CH-00010.
Instrument binders contained both a copy of the previous. control chart and the current control chart for each analysis. Control charts appeared to be well maintained and to show normal distribution; however, the inspector noted that actions taken to correct-biases were not always indicated on the control chart.
The licensee uses inline chemistry instruments to monitor the secondary water chemistry limits. The accuracy of the inline monitors were
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verified by weekly comparisons with laboratory instrumentation.
The inspector reviewed a random group of these comparisons and found them to be properly completed.
If the inline monitor did not meet the comparison criteria, grab samples, analyzed via laboratory instrumentation, were used in place of the inline data.
l The inspector discussed calibration practices with the licensee. The licensee calibrated the laboratory instruments at fixed frequencies, after maintenance, and when the instrument was found to be out of control. Calibration standards were independent of performance standards.
The inspector noted that a 500 parts per million (ppm).
phosphate standard and a 6-Normal (N) sodium hydroxide reagent, stored in the laboratory, had expired on December 4,1992, and January 5,1993, respectively. The licensee immediately removed the chemicals from the laboratory and verified that the chemicals had not been used in any analyses after their expiration dates. The phosphate standard was used in an analysis which was suspended by a licensee memorandum dated November 18, 1992.
In the fourth quarter of 1992, the 6 N sodium hydroxide was used strictly as a training aid for a fluoride determination by specific ion electrode; routine fluoride analyses are determined by IC.
The licensee indicated that an inspection of laboratory reagents / standards would be added to the CT and chemistry supervisor weekly scheduling sheets to ensure laboratory standards are adequately controlled.
l The licensee continued to participate in an interlaboratory comparison program with a vendor laboratory. Overall, the licensee's results in this program were good, but the licensee indicated that the vendor was not providing results in a timely manner and that they were in the process of changing vendor laboratories. The licensee maintained
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normalized trends for each analysis of group performance versus the vendor's value and individual CT performance versus the vendor's value.
The latter of these trends was used to ensure the proficiency of the cts.
The cts results were compared to the vendor's value by applying a j
2 SD criteria derived from the group's results; analyses not falling within these limits were investigated and repeated. The cts' results were generally very good.
No violations or deviations were identified.
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Post Accident Samplina System (PASS) (IP 84750)
The inspector toured the licensee's PASS system and discussed PASS operability and quality control with licensee representatives.
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licensee performed monthly radiological and nonradiological chemistry comparisons between PASS analyses, both liquid and gaseous, and normal sampling points. cts are rotated through these comparisons to ensure l
that they are familiar with the system's operation. The inspector reviewed several of these results, which verified that the PASS samples were representative of the reactor coolant system.
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i Maintenance and operability of the PASS system have been good.
Normally, system malfunctions are entered into the licensee's maintenance work request (MWR) system; if the item would render a sample
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line inoperable, the item receives immediate attention in the form of an Operations Concern. Two outstanding MWRs, replacement of an isolation valve and a flow regulator, were scheduled to be completed during May
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1993.
Discussion with the licensee and the above review of the
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comparisons indicated that these maintenance items did not inhibit i
representative sample collection.
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No violations or deviations were identified.
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Radioloaical Environmental Monitorina Proaram (REMP) (IP 84750)
The inspector examined the REMP, including the 1991 Annual Environmental Operating Report, a draft of the 1992 report, and toured several air
sampling stations. The REMP has been implemented in accordance with the Technical Specifications (TS) requirements, and in several instances, i
sampling exceeded the TS requirements.
Samples which were not obtained were documented in the report as required. The review of the 1991 and
1992 reports did not indicate any radiological release to the i
environment in excess of TS reporting limits.
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i The inspector reviewed REMP program audits AR-91-CMRCW-02 and AR-92-i ENVMG-01, performed in April 1991 and July 1992, respectively..These I
I audits were thorough and examined various aspects of the REMP program, including sample collection, processing, and analysis.
The auditors'
observations indicated that the program had been properly implemented.
The inspector observed the licensee's sample collectors in their routine-air filter replacements.
i.'7 :ollectors appeared competent in the
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replacement procedures. The licensee's air sampling stations were all operable and were within the calibration dates affixed to the samplers.
The collectors properly verified the absence of inleakage into the i
sampling train after installing each replacement air filter head.
l The inspector reviewed the licensee's initial qualification program and
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l annual requalification program for sample collectors.
Initial training
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Sample collectors must successfully complete a qualification card,
. demonstrating acceptable sampling techniques, and obtain a score of 80 percent or greater on a written exam to qualify. Annual requalification l
consisted of performance reviews and a written exam.
The inspactor
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verified that all sample collectors were current in their qualifications.
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No violations or deviations were identified.
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Audits and Appraisals (IP 84750)
i The inspector reviewed chemistry audits SR-91-CMRCW-05 and AR-92-CHRCW-01 conducted in November 1991 and April 1992, respectively.
The audits
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appeared to be technically sound and performed in sufficient depth.
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inspector noted that the audit findings were evaluated by the licensee's
staff and properly resolved in a timely manner. Audit observations did
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not indicate any significant concerns in the chemistry program.
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No violations or deviations were identified.
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Exit Interview The scope and findings of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on
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April 8, 1993. During the exit interview, the inspector discussed the likely informational content of the inspection report with regard to
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documents or processes reviewed during the inspection.
Licensee
representatives did not identify any such documents or processes as
proprietary. The following matters were specifically discussed by the
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inspector:
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the results of the radiological and nonradiological confirmatory l
measurements, specifically the disagreements in the sodium and chloride analyses (Section 4);
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the chemistry quality control program and the licensee's control j
L of laboratory standards and reagents (Section 7); and I
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the implementation of the REMP.
Attachments:
1.
Criteria for Comparing Analytical Measurements 2.
Table 1, Confirmatory Measurements Program Results, 2nd Quarter 1993 3.
Table 2, Radiological Interlaboratory Test Results, April 5-9, 1993 l
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ATTACHMENT 1
CRITERIA FOR COMPARING ANALYlICAL MEASUREMENTS i
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This attachment provides criteria for comparing results of capability-tests j
and verification measurements.
The criteria are based on an empirical relationship which combines prior experience and the a
REGION III==
CONFIRMATORY MEASUREMENTS PROGRAM i
FACILITY: DAVIS BESSE FOR THE 2ND QUARTER OF 1993
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SAMPLE NUCLIDE NRC VAL. NRC ERR.
LIC. VAL.
LIC. ERR.
RATIO RESOL. RESULT
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WASTE H-3 4.91E-02 7.00E-04 3.62E-02 0.74
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TANK FE-55 1.25E-05 4.00E-07 1.00E-05 0.80
A SAMPLE SR-90 1.16E-07 1.20E-08 6.80E-08 0.59
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SR-89 1.42E-06 8.00E-08 1.60E-06 1.13
A TEST RESULTS:
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D-DISAGREEMENT
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o CRITERIA RELAXED o
N=NO COMPARIS0N l
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TABLE 2
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Nonradiological Confirmatory Measurements Results Davis-Besse Nuclear Power Station April 5-9, 1993
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5 Analyte Method Conc Ratio Acceptance Ranges Result 1 2RSD 3RSD l
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pob Chloride A
1.130 0.933-1.067 0.900-1.100 D
B
1.151 0.919-1.081 0.887-1.113 D
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0.963 0.926-1.074 0.895-1.105 A'
l Rerun C'
1.000 0.933-1.067 0.900-1.100 A
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Sulfate A
1.186 0.895-1.105 0.842-1.158
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1.117 0.895-1.105 0.868-1.132 A+
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1.005 0.900-1.100 0.867-1.133 A
Rerun C'
0.993 0.895-1.105 0.842-1 158 A
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Fluoride A
1.072 0.875-1.125 0.833-1.167 A-
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0.971 0.875-1.125 0.833-1.167 A
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C
0.952 0.878-1.122 0.824-1.176 A
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Iron G
AA/FL 200 0.979 0.904-1.096 0 854-1.146 A
H 400 0.963 0.903-1.097 0.855-1.145 A
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800 0.952 0.903-1.097 0.855-1.145 A
Copper G
AA/FL 200 1.074 0.905-1.095 0.859-1.141 A
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400 0.994 0.904-1.096 0.857-1.143 A'
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I 800 0.948 0.904-1.096 0.857-1.143 A
i Sodium J
AA/FL
1.207 0.863-1.137 0.784-1.216 A+
K 100 1.188 0.859-1.141 0.788-1.212 A+
L 200 1.222 0.862-1.138 0.789-1 211 D
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Rerun J
0.997 0.863-1.137 0.784-1.216 A
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K 100 1.053 0.859-1.141 0.788-1.212 A
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150 1.039 0.862-1.138 0.789-1.211 A
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Silica T
Spec
0.991 0.909-1.091 0.860-1.136 A
U 100 1.062 0.907-1.093 0.857-1.143 A
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i Hydrazine P Spec
0.947'
O.922-1.078 0.888-1.118 A-i Q
0.985 0.922-1.078 0.888-1.118 A
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R 100 0.983 0.922-1.078 0.888-1.118 A
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I ppm Lithium JJ AA/FL 0.5 1.025 0.859-1.142 0.788-1.212 A
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0.996 0.859-1.142 0.788-1.212 A
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LL 2.5 0.991 0.859-1.142 0.788-1.212 A
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i Baron D
Titr 100 0.987 0.979-1.021 0.968-1.032 A
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E 300 0.987 0.979-1.021 0.968-1.032 A
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500 0.974 0.979-1.021 0.968-1.032 A+
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Methods:
Titr - Titration
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- lon Chromatography
Spec - Ultraviolet / Visible Spectrophotometry
AA/FL - Atomic Absorption Spectrophotometry (flame)
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Conc: Approximate concentration analyzed.
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Ratio of Licensee mean value to NRC mean value.
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The standard deviation (SD) in the sixth and seventh columns represents the coefficient :
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of variation obtained from averaging licensee data from the preceding cycle (Table 2.1 of NUREG/CR-5244). A result is considered to be in agreement if it falls within the
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2 SD range; a qualified agreement if it lies outside 2 SD, but within-3 SD; and in l
disagreement if it is outside the 3 SD range.
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Result:
I A = Agreement: Licensee value is within 42 SDs of the NRC mean value.
j A+ - Qualified agreement, licensee is between 2 and 13 SDs of
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the NRC value.
D - Disagreement: licensee value is outside 3 SDs.
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