IR 05000348/1992032
| ML20127H003 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/29/1992 |
| From: | Decker T, Mcneill N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20127G966 | List: |
| References | |
| 50-348-92-32, 50-364-92-32, NUDOCS 9301220144 | |
| Download: ML20127H003 (15) | |
Text
D i t>NITED STATES g
g$6 NUCLEAR REGULATORY COMMisslON
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o RE GION 11
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101 MARIETTA STRE ET. N.W.
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DEC 31 %
Report Nos:
50-348/92-32 and 50-364/92-32 Licensee: Alabama Power Company 600 North 18th Street Birmingham, AL 35291-0400 Docket Nos.:
50-348 and 50-364 License Nos.:
NPF-2 and NPF-8 Facility Name:
Farley 1 and 2
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Inspection Conduc ed:
November 0 - December 4, 1992 Inspector:
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htfzVP.IWk N. G. Mc'Neil P ~
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Date Signe'd
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Approved by: V X/m e /(l UAWo a /,y /9.L i
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T. R. Decker, Chief D&te Signed Radiological Effluents and Chemistry Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
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This routine, unannounced inspection was conducted in the areas of the organization of the Chemistry / Environmental Department and the Radwaste Unit (including personnel training and qualification), plant water chemistry, process and effluent monitors, the Semiannual Effluent Release Report, the Radiological Environmental Monitoring Program, the shipping and transportation of radioactive material, Effluent Monitor Incident Reports as filed by the licensee with the Resident Inspector, and the Confirmatory Measurements Non-Radiological Chemistry Sample analysis.
Results:
The licensee's organization of it's Chemistry Department and radioactive material processing and shipping units satisfied Technical Specification (TS)
and Updated Final Safety Analysis Report (UFSAR) requirements (Paragraph 2).
Plant water chemistry was maintained well within limits specified by the TSs (Paragraph 3).
The licensee had reported several Incident Reports, relative to effluent releases, to the Resident Inspector, one of which resulted ja a Non-Cited Violation (NCV) (Paragraph 4).
9301220144 921231 l
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T Southern Nuclear Operating _ Company, Inc._
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Enclosure:-
NRC-Inspection Report cc w/ encl:
B. L. Moore
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Manager, Licensing _
Southern Nuclear Operating
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Company, Inc.
P. O. Box 1295
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Birmingham, AL 35201-1295 R. D. Hill, Jr.
General Manager, Farley Plant Southern Nuclear Operating Company, Inc.
P. O. Box 470 Ashford, AL 36312 W. R. Bayne, Supervisor Safety Audit and Engineering Review Farley Nuclear Plant P. O. Box 470 Ashford, AL 36312 State Health Officer Alabama Department of Public Health 434 Monroe Street Montgomery, AL 36130-1701 James H. Miller, III, Esq.
Balch and Bingham P. O. Box 306 1710 Sixth Avenue North (;
-Birmingham, AL 35201 L
Chairman
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Houston County Commission P. 0. Box 6406 Dothan, AL 36302
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The licensee had in place a good program for the monitoring and evaluation of
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batch released liquid effluents (Paragraph 5).
The licensee had ~ submitted an Annual Radiological Environmental Operating Report which detailed minimal impact on the surrounding environment (Paragraph 6).
The Radwaste Group was staffed by competent personnel who effectively implemented a good Radwaste and Transportation program (Paragraph 7).
The Chemistry Group successfully analyzed a set of Non-Radiological Chemistry samples as part of the Confirmatory Measurements Program, with the exception of one hydrazine sample (Paragraph 8).
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- W. Bayne, Safety Audit and Engineering Review (SAER) Auditor
- 0. Graves, Radwaste Supervisor
- R. Hamm, Engineer, Chemistry and Environmental R. Hill, General Manager - Nuclear Plant J. Kale, Superintendent, Chemistry and Environmental
- R. Livingston, Environmental Supervisor
- M. Mitchell, HP Superintendent N. McGilvray, Nuclear Specialist 1
- C. Nesbitt, Manager Operations J. Osterholtz, Technical Manager
- L. Stinson, Assistant General Manager of Operations G. Terry, Safety Audit and Engineering Review (SAER) Auditor
- M. Willis, Chemistry Foreman
- R. Wood, Chemistry Supervisor Other licensee employees contacted during is inspection included engineers, operators, technicians, and administrative personnel.
Nuclear Regulatory Commission
- G. Maxwell, Senior Resident Inspector
- Attended exit interview Acronyms and Initialisms used throughout this report are listed in the last paragraph.
2.
Organization (84750 and 86750)
a.
Chemistry and Radwasto Units Technical Specification (TS) 6.2 describes the licensee's organization.
The inspector reviewed the licensee's organization, staffing levels, and lines of authority as they related to the Chemistry Department and Radioactive Waste Group to verify that the licensee had not made organizational changes which would adversely affect the ability to control radiation exposures or radioactive material.
The inspector concluded that no major changes had occurred in the respective groups that would adversely affect their ability to perform their assigned task !
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2 b.
Training and Qualificat. ion
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TS 6.4.1 requires the licensee to maintain a training program for the plant staff to assure that the minimum education and experience requirements of Section 5.5 of ANSI N18.1-1971 and Appendix A of 10 CFR 55 and the supplemental requirements specified in Sections A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees are met before a person can be
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considered to be qualified to perform his duties independently.
The program shall include familiarization with the relevant operational experience.
Tha inspector interviewed the licensee's Technical Training Supervisor about the Training / Qualification Program in general and more specifically in the area of Chemistry. There had essentially been no changes to the training program since the last inspection-(Inspection Report No. 92-15) which would adversely affect the licensee's ability to perform the requirements of the program.
The inspector reviewed Qualification Records (QRs) for several persons identified in the organizational chart.
The QR is used to
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document training and guide the performance of the employee during the on-the-job (0TJ) period.
The QRs are received in a sequence which ultimately results in a QR examination. Upon completio'n of the program, the individual may perform tasks independently.
There were also provisions for routine retraining annually. Cross
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training for the Environmental and Chemistry groups was taking place to add flexibility to the organization.
The inspector concluded that the Training Program was well structured to provide a pool of well-trained Environmental and -
Chemistry (E&C) technicians.
No violations or deviations were-identified.
3.
Plant-Water Chemistry (84750)
TS 3.4.8 specifies that the concentrations of dissolved oxygen-(D0),
chloride, and fluoride in the-Reactor Coolant System (RCS) be maintained below 0.10 parts per million (ppm), 0.15 ppm, and 0.15 ppm, respectively. _ TS 3.4.9 specifies that the specific activity of the
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primary coolant be limited to less than or equal to 1.0 microcurie / gram-
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(uCi/g) dose equivalent iodine (DEI).
These parameters are related to corrosion resistance and fuel integrity.
The oxygen parameter is based on maintaining levels sufficiently low to prevent general and -localized corrosion. The chloride = and fluoride parameters are based on providing protection from halide stress corrosion. The activity parameter is based on' minimizing personnel radiation exposure during operation and maintenance.
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Pursuant to these requirements, the inspector reviewed tabular daily-summaries which correlated reactor ' power output to chloride, fluoride, and dissolved oxygen concentrations of the reactor coolant for the
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period of January 1, 1992 through August 31, 1992 and determined that the parameters were maintained well below TS limits.
Typical. values for 00, chloride, and fluoride were less than 10 part: per billion (ppb),
less than 20 ppb, and less than 9 ppb, respectively, for both units.
The inspector concluded that the Plant Water Chemistry was being maintained well within the TS requirements.
No violations or deviations were identified.
4.
Process and Effluent Monitors (84750)
TSs 3/4.3.3.1, 3/4.3.3.10, and 3/4.3.3.ll. define the operation and surveillance requirements for monitors of radioactive (or potentially
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radioactive) streams.
This instrumentation is provided to monitor and control the releases of radioactive materials during normal and abnormal plant conditions as well as in effluents during effluent releases.
The alarm / trip setpoints for the effluent monitors are calculated in accordance with the procedures in the Process Control Program (PCP) to ensure that the alarm / trip will occur prior to exceeding the limits of'
The alarm / trip setpoints for the precess monitors are specified by the TSs.
Three Incident Reports (irs) had been received by the Resident Inspector and were reviewed by the inspector upon arrival at the site. Each IR is discussed separately as follows:
a.
IR No. 2/92/335
"#1 Waste Monitor Tank Released'at 34.4 gallon per minute" In this incident the #1 Waste Monitor Tank in Unit-2 was released at a true release rate of 34.4 gpm which was greater than the release rate of 30 gpm. The 30 gpm rate was. authorized per Liquid Waste Release-Permit 2-92-396. The actual rate of release was discovered by calculation after the tank had been released. The licensee immediately took corrective action to institute a 5 gpm:
buffer on future releases-to allow for variations in the actual.
pumping rate. The rate determined by the Liquid Waste-Release Permit calculation program has.a factor of two'as a margin 'of safety-in the maximum rate possible and the Counting-Room verified that no 10 CFR 20 or 10 CFR 50; limits were exceeded. It was therefore determined that no further action.was required concerning this report, b.
IR No. 1/92/276
"#1 Waste Monitor Tank Totalizer reads low" In this incident the #1 Waste Monitor Tank in Unit 2 was in the process of a release when it was noted that the totalizer was reading lower than expected. At very-low rate settings (in this-case, 5 gpm) these totalizers have experienced the problem of
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reading low or zero, in this instance the totalizer was repaired
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and returned to service. These totalizers have been scheduled for:
replacement in the future.
There was, however,-already existing in procedure FNP-1-SOP-50.1, " Liquid Waste Processing System, Liquid Waste Release From Waste Monitor Tank" provisions for the operator to follow when totalizer settings are very low. The existing procedures allow the operator to account for low settings which may be within the tolerance-of the totalizer to ascertain the actual flow rate and assure that no 10 CFR'20 or 10 CFR 50 limits are exceeded, it was therefore determined that r.o further action was required concerning this report, c.
IR No. 2/92/282
" Effluent Released from Waste Monitor Tank Data
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Not Accurate" In this incident review of the Counting Room data determined that the detectability of the released effluents was not accurate. In particular, Cobalt-60 was identified as not being present in the release due to an er}or in the software analysis-system used in the calculation of energy and efficiency calibrations. The system in use at the present time allows for the " skewing" of the energy alibration spectrum and unless srhcific measures are taken to detect this skewing can result in isotopes being missed in the final analysis of the sample. After this sample had been released the spectrums, which are saved, were reanalyzed with a corrected energy calibration and the Cobalt-60 was quantified. The corrected release showed that no 10 CFR 20 or 10 CFR 50 limits were i
exceeded. The licensee immediately took corrective action _to ensure during the Quality Control energy determination check.that
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no skewing or drift had occurred in the multichannel analyzer by manually checking setpoints to prevent a future recurrence. The licensee has already procured a new system, to be installed in early 1993, which will do self-calibration checks -and should therefore not be subject to this problem in the-future..
While the corrective actions-taken by the licensee should prevent the recurrence of this misidentification appear adequate and the subsequent reanalysis showed that no limits were exceeded, the fact remains that the release was made without proper identification of all nuclides. TS 4.11.1.1.1 requires that the radioactivity content of each batch of radioactive liquid waste be determined by sampling and analysis-in accordance with Table 4.11-1. Table 4.11-1 states that all principal gamma emitters-
-(including Cobalt-60) be identified. On the basis of this misidentification,-and in accordance with the' licensee's efforts in identifying and correcting'the violation as per Section VII.B of the Enforcement Policy, a.Non-cited Violation- (NCV)- was identified. The licensee was informed that-this area will be further reviewed in future inspections to monitor the-application-of the new system when operational.
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5.
Liquid Effluent Processing-and Monitoring (84750)
TS 3.121.1.1 -states the requirements for liquid effluent concentrations.
TSs 4.11.1.1.1, 4.11.1.1.2,_and 4.11.1.1.3 define the surveillance requirements for the associated sampling and analysis program.
TSs 3.11.2.1, 3.11.2.2, and 3.11.2.3 state requirements for dose rates due to radioactive materials-and noble gases released in gaseous effluents from the site, as well as dose rates from radioiodines and radioactive materials in particulate form and radionuclides with half-lives greater than eight days in gaseous effluents released.
TSs 4.11.2.1, 4.11.2.2, and 4.11.2.3 define the surveillance requirements for dose rate calculations.
The inspector reviewed several Release Permits for the year (1992), including liquid batch and gaseous batch and continuous
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releases to verify compliance.
The releases were made from the waste monitor tanks (WMTs), from the waste gas decay tanks (WGDTs), and steam generator blow down (SGBD).
Doses were calculated for each _ release and for the current week, month, quarter, and year for compliance with 10 CFR 20 and 10 CFR 50.
Dose calculations were made for each nuclide and for each: organ considering the average meteorological data-(for gaseous releases). The inspector noted that the permits were complete and no irregularities were identified.
The inspector observed the activities associated with Liquid 'aste W
Release-2-92-483, from Unit 2 #2 Waste Monitor Tank (WMT). The inspector reviewed selected portions'of the following procedures:
FNP-0-CCP-208 " Chemical-Radiochemical Control Procedure,"
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Revision 37, July 16, 1992 FNP-2-STP-714 " Waste Monitor Tank Surveillance,". Revision 12,
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October 15, 1992 FNP-0-CCP-212 " Liquid Waste Release Program", Revision 10,
November 13, 1992-FNP-2-CCP-643 " Sampling Points For Potential Radiological
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Effluents," Revision 12, November 13, 1992 These procedures specified.where and how to take samples as well as the steps required to issue a release permit. After recirculating the tank
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volume-as-required by. procedure, a sample was taken for analysis bysai technician.
The1 inspector observed the technician as he obtained the sample and noted that good technique was used. The technician took the sample directly to the laboratory to be analyzed. The analysis showed that the sample's activity was low enough'to allow the tank to be released to unrestricted areas. Setpoints-for the Process Radiation Monitor (RE-18): were established and release approval was obtained.
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6-The inspector noted that the independent verification part of the procedure, which included items such as aligning the valves and pumps-
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into the proper configuration, was completed prior to commencing the release. The technicians conducted their. activities in a competent, professional manner. Once the release was initiated and' stable, the inspector requested a copy of the records of the release.
The requested copy was received the next day and showed the summaries of activities as-well as the total volume discharged was well within regulatory limits; 10 CFR 50, Appendix 1_and 40 CFR 190.
The inspector concluded-that the licensee's liquid effluent processing program was adequate to~ assure that liquid releases were within regulatory limits.
No violations or deviations were identified.
6.
Annual Radiological Environmental Operating Report (84750)
TS 6.9.1.6 requires that the Annual Radiological Environmental Operating Report be submitted prior to May 1 of the following year of the Annual Radiological Environmental Operating Report.
TS 6.9.1.6.also states format and content requirements for the Annual Radiological Environmental Operating Report.
.The inspector reviewed the Annual Environmental Operating Report.for calendar year 1991 to verify compliance with the TSs. 'The Report had-been submitted in compliance with TS 6.9.1.6 on April 30, 1992, and the.
format and contents were as prescribed by the TS.
There were no changes.
to the environmental monitoring network during 1991. The inspector determined that the Report was in compliance with the TSs.
The Farley Nuclear Plant Environmental Monitoring Program is designed to detect the effects, if any, of plant operation on environmental ~
radiation levels by monitoring airborne, waterborne, ingesti.on, and direct radiation pathways in the area surrounding the plant site.
Indicator sampling stations are located where detection of the:
radiological effects of the plant's operation would be most-likely, where the samples collected should provide a significant indication of-potential dose to man, and where an adequate comparison of predicted radiological levels might be made with measured levels.
Control-l stations are located where radiological levels are not expected to be-.
significantly influenced by plant operation,1.e., at background-locations.
An environmental impact assessment of plant operation is -
made from the radiological readings of the' sampling stations.
The inspector noted that there had been an unusually large-number of j
failures of the air sampling stations over the year. The: inspector noted that these deviations were included in-Table 4 and listed various causes i
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l on the-filter. The inspector visited several air sampling stations.and learned that all stations had been-replaced with much more reliable-systems.
The stations had been replaced by S.A.I.C. Model FN-210B-t
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- 7 Environmental Air Sampling Stations which appear well suited to alleviate the problems encountered in the past and represent a
significant' investment by the licensee in improved environmental monitoring.
The inspector concluded that the licensee had a good program in place to detect the effects of radiological effluents, direct radiation, etc. due to plant operations and that those operations had caused minimum impact
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to the environment and virtually no dose to the general public.
No violations or deviations were identified.
7.
Radwaste Processing and Transportation (86750)
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10 CFR 71.5(a) requires that each licensee who tt ansfers licensed material outside of the confines of its plant or oth"r place of use, or who delivers licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation (DOT) in 49 CFR Parts 170 through 189.
Pursuant to these requirements, the-inspector reviewed the licensee's
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activities affiliated with these requirements, to determine whether the licensee effectively processes, packages, stores, and ships radioactive
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solid materials.
The licensee's program for the packaging and transportation of radioactive materials, including solid radwaste, was conducted by the-Radioactive Waste Group within the Health Physics Department.
Radwaste-was processed and packaged by the Radwaste Group, including compacting contaminated material, loading shipments, and preparing shipping documentation.
a.
Radwaste Shipping Documentation The inspector reviewed shipping packages for Radwaste Shipment Nos. 92-92 and 92-93.
The packages-documented _the shipments and included items such as unique shipment.and shipping container numbers, waste content and volume, total activity, analytical summary and breakdown of isotopes with a half-life greater than-five years. The radiation and contamination survey results were within the limits specified and the shipping documents were being maintained as required. Shipment No. 92-92 consisted of' Steam-Generator Tubes and parts in a wooden crate-to be transferred to Westinghouse Research and Development in Pittsburgh, Pennsylvania.
The second shipment,.No. 92-93, consisted of a shipment of trash and-assorted paper, plastic, metal, and assorted materials 'to Scien_tific Ecology Group (SEG), in Oak Ridge, Tennessee, for sorting and compaction. The-SEG shipment was contained in a-40 foot Sealand container,
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Radwaste Shipments Shipment of radioactive materials was the responsibility of the Radioactive Waste Group, which prepared all shipping documents and procured the necessary disposal containers and shipping casks. The inspector observed the activities associated with the release and transportation of the aforementioned shipments as described in Procedure FNP-0-RCP-815, entitled " Radioactive Waste Handling."
Its purpose was to provide procedural guidance in the preparation of shipments of radioactive material and to ensure compliance of such shipments with all applicable regulations and requirements.
The inspector observed part of the process of loading the box cn the first truck as well as noted that the technicians were
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closely following the procedure, including conducting radiation /
contamination surveys and checking labels and package markings on the shipping boxes prior to loading.The same proficiency was observed in the loading of the Sealand container on the second truck.
Before the trucks left the site, the inspector reviewed the final survey record of the trucks and conducted a review of the shipping manifests as given to the respective drivers.
In general, the inspector thought that the survey was properly done and well documented. The inspector noted that the drivers received thorough briefings by Radwaste personnel prior to leaving the site and that the shipping papers appeared to be adequate and comprehensive.
c.
Emergency Telephone Number Listed in Shipping Papers 49 CFR 172.604(a)(2) requires that a person who offers a hazardous material for transport must provide a 24-hour emergency response
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telephone for use in the event of an emergency involving the material and that the telephone number must be monitored at all times by a person who is either knowledgeable of the hazardous material being shipped and has comprehensive emergency response and incident mitigation information for the material, or has immediate access to a person who possesses such knowledge and information.
Information Notice (IN) 92-62, " Emergency Response Information Requirements For Radioactive Material Shipments," provides guidance which indicates "immediate access" as being 15 minutes.
On the evening of December 3, while the shipment was in transit, the inspector called the emergency telephone number listed in the shipping manifest for shipment No. 92-92. It was answered by Health Physics personnel. The inspector explained that he was trying to ascertain compliance with 49 CFR 172.604, specifically concerning immediate access to someone with incident mitigation information for the shipment in question. The temporary Health Physics foreman was able to immediately answer all questions as posed by the inspector in a complete and appropriate manner.
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The inspector concluded that the Radwaste Group was stable,
. staffed with competent personnel, and executed its responsib_ilities in a professional manner.
No violations-or deviations were identified.
8.
Confirmatory Measurements (84750)
In an effort to' evaluate the licensee's analytical capabilities, Non-
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Radiological Water Chemistry Standards were prepared by the Oak Ridge National Laboratory (ORNL) and represented to the licensee for analysis.
The matrix of samples to be analyzed was determined _ by those analyses
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routinely performed by the licensee at each facility. -The licensee was also provided with an opportunity for the splitting of samples of feedwater between the licensee's laboratory and ORNL. The samples were sent off to ORNL for analysis and comparison. The results of those samples which the licensee analyzed are summarized in Attachment 1. - All results were in agreement with the exception of the low range hydrazine samples.
Upon compilation of the sample analyses which were split with ORNL, the complete results of all participants as well as statistical data will be made available to all of the licensees that submitted splits and analytical results.
The inspector concluded that the licensee's chemistry program for analyzing non-radioactive chemistry was adequate and capable of accurately performing that function.
No violations or deviations were identified.
9.
Exit Interview-The inspection scope and results were summarized on December 4, 1992,-
with those persons-indicated in Paragraph 1. - The inspector described-the areas inspected and discussed the inspection results, including likely informational content of the-inspection report with regard to-documents and/or processes reviewed during the inspection. The licensee did not identify _any such documents or processes as proprietary.
Dissenting._ comments were not_ received from the licensee.
10.
Acronyms and Initialisms ADEM - Alabama Department of Environmental Management-ANSI - American National Standards Institute, Inc.
C&E - Chemistry and~ Environmental CCW - Component Cooling Water CFR - Code of Federal Regulations Ci - curie DEI - Dose Equivalent Iodine DO - Dissolved Oxygen D0T - Department'of. Transportation
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FNP - Farley Nuclear Plant FSAR - Final Safety Analysis Report
- HP - Health Physics IR - Incident Report 1 - liter LLW - Low Level Radwaste mg - milligram mrem - millirem No. - Number
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NPDES - National Pollutant Discharge' Elimination System j
NRC - Nuclear Regulatory Commission
ODCM - Off-site Dose Calculation Manual
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ORNL - Oak Ridge National Laboratory
PCP - Process Control Program ppb - parts per billion ppm - parts per million QR - Qualification Records-RCS - Reactor Coolant System REMP.- Radiological Environmental Monitoring Program.
SDF - Solidification Dewatering Facility TS - Technical Specification
uti - micro-Curie (1.0E-6 Ci)
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ATTACHMENT 1--
ANALYSIS TYPE CONCENTRATION RANGE (mo/L)
RESULTS Ammonia 75.0 - 125 AGREEMENT Ammonia 275 - 325 AGREEMENT Ammonia 400 - 600 AGREEMENT Boron 500 - 1500 AGREEMENT Boron 2500 - 3500 AGREEMENT Soron 4500 - 5500 AGREEMENT
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Chloride Anions 10.0 - 30.0 AGREEMENT Chloride Anions 30.0 - 50.0 AGREEMENT Chloride Anions 60.0'- 100 AGREEMENT-Chromium 15.0 - 25.0 AGREEMENT Chromium 25.0 - 55.0 AGREEMENT Chromium 60.0 - 100 AGREEMENT
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Copper 15.0 - 25.0 AGREEMENT Copper 25.0 - 55.0 AGREEMENT Copper'
60.0 - 100 AGREEMENT Fluoride Anions 10.0 - 30.0 AGREEMENT Fluoride Anions 30.0 - 50.0 AGREEMENT Fluoride Anions 60.0 - 100 AGREEMENT Hydrazine 5.0 - 15.0 DISAGREEMENT Hydrazine 25.0 - 35.0 AGREEMENT Hydrazine 40.0 - 60.0 AGREEMENT Iron 15.0 - 25.0 AGREEMENT Iron 25.0 --55.0 AGREEMENT Iron 60.0 - 100 AGREEMENT Lithium 2.5 - 7.5 AGREEMENT Lithium.
7.5 - 14.5 AGREEMENT Lithium 18.0 - 28.0 AGREEMENT-Nickel 15.0 - 25.0
. AGREEMENT Nickel
'25.0 - 55.0 AGREEMENT Nickel 60.0 - 100 AGREEMENT Silica 20.0 - 40.0 AGREEMENT Silica 40.0 - 60.0 AGREEMENT
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Attachment 1
Sodium 2.5 - 7.5 AGREEMENT Sodium 7.5 - 14.5 AGREEMENT Sodium 12.0 - 18.0 AGREEMENT Sulfate Anions 10.0 - 30.0 AGREEMENT Sulfate Anions 30.0 - 50.0 AGREEMENT Sulfate Anions 60.0 - 100 AGREEMENT Zinc 0.5 - 1.5 AGREEMENT Zinc 4.0 - 6.0 AGREEMENT Zinc 8.0 - 12.0 AGREEMENT
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Note:
Qualified Agreement is s three standard deviations
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Agreement is 5 two standard deviations Disagreement is > than three standard deviations
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