IR 05000352/1990008
| ML20012D338 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/12/1990 |
| From: | Bores R, Kottan J, Mcnamara N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20012D334 | List: |
| References | |
| 50-352-90-08, 50-352-90-8, 50-353-90-07, 50-353-90-7, NUDOCS 9003270206 | |
| Download: ML20012D338 (11) | |
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A U. S. NUCLEAR REGULATORY COMMISSION
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REGION I
50-352/90-08-Report No.
50-353/90-07 i
50-352
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Docket No. '50-353 k
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. Licensee:
Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19105
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Facility Name: - Limerick Generating Station, Units 1 & 2
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Inspection At:- Limerick, Pennsylvania i
Inspection Conducted:
February 5-9, 1990
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t Inspectors:g'.
W ME 3-& 9o J. Kot' tan, ~ Laboratory Specialist date
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'NO 3 - 0- 90
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$-y b N. McNdmara,- Laboratory Assistant date
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Approved by:
)T'N 8 ' /2 ~'M R. Bores VChief, Effluents Radiation date Protection Section, FRSSB l
Inspection ~ Summary:
Inspection on February 5-9, 1990 (Combined Inspection
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Report Numbers 50-352/90-08 and 50-353/90-07 Areas Inspected:
Routine, unannounced inspection of-the radiological and non-radiological chemistry programs. Areas reviewed included:
confirmatory measurements-radiological, standards analyses-chemistry, and laboratory QA/QC, l
Results: Of the areas reviewed, no violations were identified, l
9003270206 900313,
PDR ADOCK 0500
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DETAILS I-1.
Individuals Contacted
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Principal Licensee Employees
- G.' Leitch, Vice President, Limerick Generating Station
- M. McCormick, Plant Manager, Limerick Generating Station
- R. Dubiel, Superintendent of Services
- J. McElwain, Superintendent, Nuclear Quality Assurance (NQA)
- J. Keenan, NQA
'*K. Cenci, Radwaste
- J. Mittura, Radwaste
- W. Sokso, Licensing-
- C, Hetrick, Technical Supervisory Chemist
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T. Jackson, Senior Chemist J..Gruber, Chemist J. Docherty, Chemist T. Edwards, Shift Chemist G. McAllister, Shift Chemist A. Lewis, Shift-Chemist
D. Musselman, Plant Supervisory Chemist E. Frick, Chemist A. Feldman, Chemical Engineer - Unit 2 Other Personnel
- L..Scholl, NRC Resident Inspector
- M, Evans, NRC_ Resident Inspector
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- T. Kenny,.NRC Senior Resident Inspector
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- Denotes those personnel who attended the exit meeting on February 9, 1990.
The inspectors also interviewed other licensee personnel including other members of the chemistry and health physics staffs.
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2.
Purpose L
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The purpose of this routine inspection was to review the following areas.
1.
The licensee's ability to measure radioactivity in plant systems and effluent samples, and chemistry parameters in various plant systems.
2.
The licensee's ability to demonstrate the acceptability of analytical results through implementation of a laboratory QA/QC program.
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.3.
Radiological and Chemical Measurements
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3.1 Confirmatory Measurements (Radiological)
l During _ this part of the inspection, liquid, airborne particulate (filter) and iodine (charcoal cartridge), and gas samples were
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analyzed by the licensee and the NRC for the purpose of intercomparison.
The samples were actual split samples with the
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exception of the particulate filter, charcoal cartridge, and offgas samples.
In these cases the samples could not be_ split, and the
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same samples were analyzed by both the licensee and the NRC. Where possible, the samples are actual effluent samples or.inplant samples which duplicated the counting geometries used by_ the-licensee for effluent sample analyses.
The samples were analyzed by the licensee using routine methods and equipment and by the NRC:I Mobile Radiological Measurements Laboratory. Joint analyses of actual effluents samples are used to verify the licensee's capability to
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measure radioactivity i_n effluent and other samples with. respect to the Technical Specifications and other regulatory requirements.
In addition, a liquid effluent sample was sent to the NRC reference laboratory, Department of Energy, Radiological and Environmental Sciences Laboratory (RESL), for analyses requiring wet chemistry.
-The analyses to be performed on the sample are Sr-89, Sr-90, Fe-55, H-3, and gross alpha.
The results of these analyses will be compared with the licensee's results when received at a later date and will be documented in a subsequent inspection report.
The results of an effluent sample split between the licensee and the NRC during a. previous inspection on February 8-12,1988(Inspection Report No. 50-352/88-06) were also compared during this 1_nspection.
The results of the sample measurement intercomparisons indicated that all of. the results were in agreement under the criteria used u
for comparing results.
(See Attachment 1.) The results of the radioactivity measurements comparison are listed in Table I.
During the intercomparison of the charcoal cartridge results the inspector noted that the licensee decayed the measured I-133 result to the mid point of the sample collection period. The sample
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collection period is approximately seven days in duration, resulting in a sample decay time of approximately 315 days.
The inspector discussed this matter with the licensee and stated that if. the I-133 was-uniformly adsorbed on the charcoal cartridge during tb
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collection period, then-decaying the measured result to the mid point l
i of the sample collection period would result in an over estimation
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of the amount of I-133 on the charcoal cartridge by approximately a
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factor of two. The licensee stated that this area would be reviewed,
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and, if appropriate, necessary corrective actions taken. The inspector had no further questions in this area.
No violations were identified.
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3 '. 2 Standards Analyses (Chemical)
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During this part of 'the inspection, standard chemical solutions were submitted to the licensee for analysis.
The standard solutions were prepared by Brookhaven National Laboratory (BNL) for the NRC and were analyzed by the licensee using routine methods and equipment.
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The analysis of standards is used to verify the licensee's i
capability to monitor chemical parameters.in various plant systems with respect to Technical Specifications and other regulatory requirements.
In addition, the analysis'of standards is used to evaluate the licensee's procedures with respect to accuracy and precision.
The results of the standards measurement comparisons indicated that l
all of the measurements were in agreement or qualified agreement under the criteria used for comparing results.
(See Attachment 2.)
The results of the comparisons are listed in Table II. The standards were submitted to the licensee for analysis in triplicate at th'ree concentrations spread over the licensee's normal calibration range. One of the three chloride standards was' analyzed in duplicate only due to time constraints involved in recalibrating the ion chromatograph (IC) as described below.
The licensee routinely calibrates the IC for chloride, nitrite, nitrate, and sulfate. The calibration 'was performed using a solution
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containing all four anion species.
In reviewing the chromatogram of the c:libration standards the in'spector noted that the nitrite and chloride peaks overlap near the baseline. Because of.this overlap the resultant chloride calculated peak area is smaller than that which would be obtained without nitrite present in the sample.
During the analysis of the NRC chloride standards the licensee's
results at all concentrations were biased high by approximately 20
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percent and were in disagreement with the NRC known values. The licensee then recalibrated the IC with only' chloride present in the calibration standard, and the results were in agreement or qualified agreement with the NRC standards. Through discussions with the licensee the inspector determined that the samples that the licensee routinely analyzes on the IC do not contain nitrite and, therefore, the licensee will report chloride concentration values which are biased high by approximately 20 percent. The inspector noted that
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this bias was in a conservative direction and would not result in the licensee ' exceeding any regulatory limit.
The licensee stated that this area would be reviewed and appropriate corrective action taken, The inspector had no further questions in this area.
No violations a
were identified.
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-Laboratory QA/QC The-inspector reviewed the licensee's' chemistry and radiochemistry L
laboratory QA/QC program.. This program is described in the following
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CH-1000, Chemistry QA/QC Program CH-1004, Interlaboratory/Intralaboratory Analyses CH-1004.1, Preparation and Use of Control Charts and
Check Standards CH-1004.2, Graphical Representation of Analytical Data CH-1004.3, Quality Assurance Program for Canberra Gamma Spectrometer System CH-1004.4, Quality Control for Alpha and Beta Counters
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These procedures provide for both an intralaboratory QA/QC program and an interlaboratory QA/QC program.
The intralaboratory program consists of instrument and procedure control charts and the analysis of spiked and duplicate samples. The spiked samples were used as a means of assessing technician performance and the duplicate sample results were plotted on range control charts where applicable.
The interlaboratory program.
consisted of the analysis of chemical and radioactivity standards received from an outside laboratory. The licensee's procedures contain acceptance criteria for comparing these results.
Also the licensee's interlaboratory
. program included the vendor laboratory that performed the radiochemical
, analyses of effluent samples. The inspector reviewed selected data generated by the licensee's laboratory QA/QC program for 1989'and 1990 to L
date and noted that the licensee appeared to be implementing the laboratory QA/QC program as required.
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In reviewing the gamma spectrometry control chart data the inspector noted that the licensee used values of plus or minus ten percent as
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control limits. The inspector discussed with the licensee the fact that the control limits were based on this fixed value of ten percent rather then the use of an experimentally determined estimate of the standard deviation.
The inspector further noted that the other control charts generated by the licensee's laboratory used control and warning limits based on an experimentally estimated standard deviation. The licensee stated consideration would be given to implementing statistical control L
charts for the gamma spectrometry system. The inspector had no further questions in this area.
No violations were identified.
5.
Exit Interview
l The inspector met with the licensee representatives denoted in Section 1
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'of this report at the conclusion of the inspection on February 9, 1990.
The inspector summarized the purpose, scope and findings of the inspection.
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r Table I i
Limerick Units 1 & 2 Verification Test Results
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SAMPLE ISOTOPE NRC VALUE LICENSEE VALUE COMPARISON Results in Microcuries Per Milliliter
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Charcoal I-131 (2.0t0.7)E-13
<2.6E-13 No Comparison r
Cartridge I-133 (513)E-12 (3.4tl.1)E-12 Agreement North Stack-2-6-90 0443 hrs Detector #1
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Offgas Unit 1 Kr-85m (5.210.4)E-4 (5.410.4)E-4 Agreement
'2-6-90 Kr-87_
(4.010.3)E-3 (3.610.3)E-3 Agreement 0855 hrs Kr-88 (2.110.2)E-3 (2.0610.15)E-3 Agreement Detector #5 Xe-135_
(2.9910.07)E-3 (3,010.2)E-3 Agreement-
-1st Count
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Offgas Unit I Xe-133 (2.510.2)E-4 (2.810.2)E-4 Agreement
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2-6-90-Xe-135 (3.3010.10)E-3 (3.2 0.2)E-3 Agreement 0855 hrs Detector #5 2nd count (24 hr decay)
Collection Tank Na-24 (4.74 0.06)E-5 (5.220.4)E-5 Agreement t
2-7-90 Cr-51-(5.7310.04)E-4 (5.9 0.5)E-4 Agreement 1400 hrs Mn-54 (2.7010.06)E-5 (2.510.2)E-5 Agreement Detector #6 Mn-56 (1.7910.08)E-5 (1.510.2)E-5_
Agreement Co-58 (1.6110.05)E-5 (1.610.2)E-5 Agreement l
Co-60-(5.9710.06)E-5 (5.220.2)E-5 Agreement Sr-92 (5.0 0.4)E-6 (4.'/11.1)E-6.
Agreement Tc-99m (1.01410.005)E-4 (1.1910.08)E-4 Agreement Cs-134 (1.0410.05)E-5 (1.2110.11)E-5 Agreement Cs-137 (1.8410.04)E-5 (1.810.2)E-5 Agreement l
I-133 (9.010.3)E-6 (1.05 0.14)E-5 Agreement Unit 1 Reactor Na-24 (2.9210.03)E-3 (2.91t0.14)E-3 Agreement
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Water-Cr-51 (1.90510.014)E-2 (2.01 0.15)E-2 Agreement
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2-6-90 Co-58 (2.4410.14)E-4 (2.2 0.2)E-4 Agreement t
1105 hrs Cu-64 (3.4 0.2)E-2 (3.110.5)E-2 Agreement Detector #4 As-76 (5.310.2)E-4 (5.5 0.5)E-4 Agreement
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Sr-92 (9.3 0.3)E-4 (9.910.7)E-4 Agreement
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Tc-99m (1.47110.003)E-2 (1.3710.09)E-2 Agreement I-132 (1.04t0.02)E-3 (1.18 0.06)E-3 Agreement l
I-133 (4.38 0.11)E-4 (4.410.3)E-4 Agreement
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I-134 (3.2310.13)E-3 (3.7i0.2)E-3 Agreement I-135 (1.11 0.06)E-3 (1.24 0.10)E-3 Agreement i
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Table I (continued)
Verification Test Results SAMPLE ISOTOPE NRC VALUE LICENSEE VALUE COMPARISON Results in Microcuries Per Milliliter Unit 1 Reactor I-132-(1,15 0.02)E-3 (1.11 0.03)E-3 Agreement Water I-133 (4.4210.10)E-4 (4.510.2)E-4 Agreement 2-6-90 I-134 (3.4710.11)E-3-(3.43 0.10)E-3 Agreement 1105 hrs I-135 (1,0510.05)E-3 (1.11 0.04)E-3 Agreement Iodine Separation
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Detector #5 Unit 1 Reactor
'Na-24 (1.12 0.10)E-5 (1.2 0.2)E-5 Agreement Water Filter Cr-51 (1.7510.09)E-4 (2.210.3)E-4 Agreement 2-6-90 Mn-56 (8.4 0.3)E-5 (9.4 0.7)E-5 Agreement 1105 hrs-Co-58 (1,0210.09)E-5 (1.1 0.2)E-5-Agreement Oetector #3 Tc-99m (3.5410.09)E-5 (3.710.3)E-5 Agreement Unit 1 Reactor H-3 (4.38 0.10)E-5 (3.610.2)E-5 Agreement Water Fe-55 (4 5)E-8
<1E-7 No Comparison 2-9-88 Sr-89 (8.8tl.0)E-8
<1E-8 No Comparison
1530 hrs Sr-90 (0 3)E-9
<1E-8 No Comparison
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_ gross alpha (2.5 0.5)E-9
<1.5E-8 No Comparison
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TABLE II-Limerick Units 1 & 2 Chemistry Test Results
Chemical Method of NRC Licensee-Ratio Parameter Analysis *
Known Value Measured Value (LIC/NRC)-
Comparison r
Results in parts per billion (ppb)
' Chloride IC 30 2 29.9 1.0 1.0010.07 Agreement 3112 27.910.5 0.9010.06 Qualified Agreement 9.5 0.5 9.410.7 0.9910.09 Agreement Sulfate IC 1913 18.5 1.2 0.9710.02 Agreement 19 2 18.8 1.0 0.99010.012 Agreement 6.010.4 6.0 0.3 l'.0010.08 Agreement D
' Silica SP
'4914 52 2 1.0610.10 Agreement 11012 104.0 1.0 0.94510.015 Agreement 161 3 15313 0.9410.03 Ag-eement Boron DCP
.1C30 20 1025 7 1.0010.02 Agreement 299 4 295 12-0.9910.04 Agreement 510!10 510140 1.0010.08 Agreement
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Iron DCP 19813 210130 1.0610.15 Agreement
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392110 390140 0.9910.11.
Agreement 580 10 590140 1.0210.07 Agreement
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Copper DCP-199 4 186113 0.9310.07 Agreement 40513 388111 0.9610.03 Agreement 59515 580 20 0.9710.03 Agreement Nickel DCP 203 5 199 13 0.9810.07 Agreement 40316 390120 0.9710.05 Agreement 610 10 590 30 0.97 0.05 Agreement i
i Chromium DCP 200110 199110 1.00 0.07 Agreement
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404 9 390120 0.96 0.05 Agreement L
60017 580 30 0.9710.05 Agreement l-
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Zinc DCP 10213 110130 1.110.3 Agreement 288 9 293 13 1.0210.06 Agreement 47815 49015 1.025 0.015 Agreement
- Note: SP UV-Vis Spectrophotometry
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l IC Ion Chromatography
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DCP = Directly Coupled Plasma Spectrometry
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' ATTACHMENT 1 CRITEPIA FOR COMPARING ANALYTICAL MEASUREMENTS This attachment provides criteria for comparing results of capability tests
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and verification measurements. The criteria are based on an empirical
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program.
In these criteria, the judgement limits are variable in relation to the-comparison of the NRC Reference Laboratory's value to its associated uncertainty. As the ratio, referred to in this program as " Resolution",
increases the acceptability of a licensee's measurement should be more selective.
Conversely, poorer agreement must be considered acceptable as the resolution decreases.
Resolution 2 Ratio for Agreement *-
<3 No Comparison 4-7 0.5 - 2.0 8 - 15 0.6 - 1.66 16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25
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>200 0.85 - 1.18
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2 Resolution = (NRC Reference Value/ Reference Value Uncertainty)
' * Ratio = (License-Value/NRC Reference Value)
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ATTACHMENT 2 i
Criteria for Comparing Analytical Measurements This attachment provides criteria for comparing results of capability tests.-
In these criteria the judgement liraits are based on data from Table 2.1 of NUREG/CR-5244, " Evaluation of Non-Radiological Water Chemistry at Power Reactors".
Licensee values within the plus.or minus two standard deviation-
. range (12Sd)_of the BNL known value are considered to be in agreement.
Licensee values outside the plus or minus two standard deviation' range but within the plus or minus three standard deviation range (13Sd) of the BNL known
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values are considered to be in qua'lified agreement.
Repeated results which are
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.in qualified agreement will receive additional attention.
Licensee values greater than the plus or minus three standard deviations range of the BNL known value are in disagreement.
The standerd deviations were computed using the average percent standard deviation values of each analyte in Table 2.1.
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'The= ranges for the data in Table II are as follows:
Agreement Qualified Agreement-Analyte Range Range i
Chloride 28-32 27-33 28-34 27-35 8.8-10.2 8.5-10.5 Sulfate 17-21 16-22 17-21 16-22 5.4-6.6 5.2-6.8 Silica 44-54 42-56
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100-120
'94-125 146-176 138-184 Boron 1008-1052 997-1063 292-305 289-309 499-521 493-526 i
Iron 179-217 169-227 354-430 336-448 524-636 496-664 Copper 180-218 171-227 366-444 347-463 538-652 510-680 L
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n ATTACHMENT 2(continued
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Agreement Qualified Agreement
- Analyte'
Range Range Nickel 190-216 184-222.
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378-428 366-440-572-648 553-667:
Chromium 181-219 171-229
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365-443 345-463 542-658 512-688 Zinc 92-112 87-117
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259-317 245-331~
u 430-526 406-550 p
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