IR 05000454/1987003

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Insp Repts 50-454/87-03 & 50-455/87-05 on 870113-15 & 20-22. No Violations or Deviations Noted.Major Areas Inspected: Gaseous & Liquid Radioactive Programs Including Air Cleaning Sys Surveillance & Training & Qualification Effectiveness
ML20211H896
Person / Time
Site: Byron  Constellation icon.png
Issue date: 02/18/1987
From: Hueter L, Schumacher M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20211H854 List:
References
50-454-87-03, 50-454-87-3, 50-455-87-05, 50-455-87-5, NUDOCS 8702260318
Download: ML20211H896 (13)


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U. S. NUCLF.lR REGULATORY COMMISSION

REGION III

Reports No. 50-454/87003(DRSS); 50-455/87005(DRSS)

Docket Nos. 50-454; 50-455 Licenses No. NPF-37; NPF-60 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, Illinois 60690 Facility Name: Byron Station, Units 1 and 2

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Inspection At: Byron Station, Byron, Illinois Inspection Conducted: January 13-15 and 20-22, 1987

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Inspector:

L. J. Hueter M

.2M///7 Date WZ/yhwuclW Approved By:

M. Schumacher, Chief M#N7 Radiological Effluents Da te and Chemistry Section Inspection Summary Inspection on January 13-15 and 20-22, 1987 (Reports No. 50-454/87003(DRSS);

No. 50-455/87005(DRSS))

Areas Inspected: Routine unannounced inspection of gaseous and liquid radioactive programs including effluent releases, records and reports of effluents; procedures for controlling release; effluent control instrumentation, changes to equipment; air cleaning system surveillance; reactor coolant and secondary system water; audits and appraisals; and training and qualification effectiveness.

Status of eight open items was also reviewed.

Results: No violations or deviations were identified.

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DETAILS 1.

Persons contacted P. Andrews, Health Physicist

10. Berg, Nuclear Safety 1,2,3W. Bielasco, Lead Health Physicist W. Burkamper, Quality Assurance Supervisor R. Campbell, Radiation Monitoring, Group Leader

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A. Chernick, Radwaste Operations 1G. Grabins, ASTS, Unit 2 Startup 2,40. Herman, Station Chemist H. Long, Instrument Foreman K. Passmore, Technical Staff, Ventilation, Group Leader IW. Pirnat, Regulatory Assurance 1R. Querio, Station Manager W. Scheffler, Chemist, Group Coordinator J. Schrock, Operating Engineer, Unit 1 S. Wilson, Radwaste Coordinator 1R. Ward, Services Superintendent L. Wehner, Technical Staff, Radwaste Group Leader i

IM. Whitemore, Acting Rad / Chem Supervisor 1F. Willich, Quality Assurance 1E. Zittle, Regulatory Assurance P. Brochman, NRC Resident Inspector IJ. Hinds, Jr., NRC Senior Resident Inspector The inspector also interviewed other plant personnel during the course of

the inspection.

1 Denotes those present at the exit interview.

2 Telephone conversation on February 9, 1987.

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3 Telephone conversation on February 10, 1987.

4 Telephone conversation on February 11, 1987.

2.

Licensee Actions on Previous Inspection Findings

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a.

(Close) Open Items (50-454/85051-02; 455/85037-02):

Commitment to e/aluate cause of occasional readings significantly above background observed on the WGDT effluent line monitor between tank releases.

As noted in previous ins)ection reports, the licensee evaluation added i

a 15 minutes air flusi downstream of the flow control isolation valve

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following each release and changed the sequence of valve closure.

A temporary modification involving a limited nitrogen purge of the WGDT

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l release line, both upstream and downstream of the flow control / isolation j

valve, was also tested and also showed some improvement.

Therefore, as noted during of the last inspection, the licensee planned to go ahead with a permanent modification involving a nitrogen purge with much larger capacity which would be introduced at a location optimizing purge of the entire WGDT effluent line.

Since that inspection, a helium leak test has been performed on the flow control / isolation valve verifying that there is no significant leakage at that valve when in the closed position. Also, maintenance of pressure on all WGDT tanks verifies absence of leakage from the tanks.

During this inspection, the design of the permanent nitrogen purge system was oeing finalized and installation is expected to be accomplished in about six weeks.

Inspector review of recent effluent data, indicated the problem has been significantly reduced.

b.

(Close) Open Items (50-454/86011-01; 50-455/86009-01): Analyze liquid for gross beta, H-3, Sr-89, and Sr-90 and report results to Region III.

Problems associated with gross beta and H-3 were resolved in conjunction with analysis of a split of a licensee release tank sample as described interim Inspection Report No. 50-454/86032; No. 50-455/86028.

Because of the low concentration of Sr-89 and Sr-90 in the split sample, no comparison was attempted for these nuclides.

Instead, the licensee agreed to analyze for Sr-89 and Sr-90 in a spiked sample to be sent i

from the NRC Reference Laboratory, the Radiological Environmental Sciences Laboratory (RESL), Idaho Falls, Idaho.

The sample concentrations provided by RESL and the results of the analysis from the licensee are given in Table 1 along with comparison criterion in Attachment 1.

Agreements were obtained for both Sr-89 and Sr-90 although licensee valves appear to be biased low by about 15' percent.

c.

(Close) Open Items (50-454/86011-02; 50-455/85009-02):

Review E-Bar input value in Appendix A3 of Procedure No. BCP-230-3 and change as appropriate.

The licensee reviewed and recalculated the E-Bar values

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that differed from the NRC values as noted in interim Inspection Reports No. 50-454/86032; No. 50-455/86028.

The remaining differences j

have now been reconciled and the station procedure has been appropriately modified.

d.

(Close) Open Items (50-454/86011-03; 50-455/86009-03):

Evaluate alpha counting capabilities on Canberra and document.

Because of differences between the NRC's and the olants' evaluation of alpha activities on air filter samples and tie very low efficiencies of the licensee's counters for air particulate filters, the licensee, l

as noted in interim Inspection Reports No. 50-454/86032;

No. 50-455/86028, did some preliminary evaluation of the alpha j

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counting efficiency.

At that time the licensee agreed to further evaluate calibrations and to document the conclusions. After discussion of sample preparation techniques with a source manufacturer, the licensee prepared a new " standard" source using modified techniques.

This source resulted in increased counter efficiency and reduced self absorption interference to a range of about zero to ten percent.

The licensee has documented this data with the conclusion that this evaluation adequately resolves the calibration issue for counters used in quantifying alpha activity collected on air filters.

e.

-(Close) Open Items (50-454/86032-02; 50-455/86028-02):

Licensee to write detailed procedure on the Calibration and standardization of in-line monitors.

Byron Chemistry Procedure No. BCP 500-29, Revision'0, " Chemistry Standardization of In-Line pH Monitors," was initiated after approval on October 22, 1986.

f.

(0 pen) Open Item (50-455/86028-03):

Licensee will test conductivity monitoring of water from the condenser trays when sufficient steam is available.

The licensee intends to attain at least 50 percent power to provide adequate steam for proper operation of the ten eductors associated with these 2.0 conductivity cells before testing the cells.

These cells (not required by technical specification) will be used to localize a condenser tube leak that may develop in any of the four water boxes.

If a tube leak can be located in this manner during normal plant operation, it will permit shutting down the affected water box for repair while the unit remains at about 75 percent power.

In the interim, any condenser tube leak should be indicated by a conductivity monitor (with a strip chart) on the discharge of thecondensatepumpsjustupstreamofthecondensatedemineralizers.

This monitor is observed by operations )ersonnel on each shift.

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Secondary Sampling System was accepted ay the station with this remaining testing activity being tracks by the station under

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AIR 6-86-2083.

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g.

(Close) Open Item (50-455/86032-01):

Licensee to evaluate proper

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directionofgasmonitorprobeforPR027,steamjetairejector/

gland steam gas monitor. As noted during the referenced inspection, the licensee observed during an inspection of Unit 2 gas monitors that the monitor probe for PR 027 was directed downstream instead of upstream.

Before reversing the direction of the probe, the licensee decided to evaluate the merits of leaving the probe as found in that the monitor's function is to monitor gas only and if the probe as directed provided an adequate sample, it may be that no useful purpose would be served.

Further, leaving the probe directed down stream might be advantageous in minimizing collection of particulates and water

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droplets that could interfere with sample flow and/or damage the detector.

The licensee evaluation found that the monitor was designed to have the probe directed upstream.

Therefore the probe direction was corrected to the upstream direction and verified as such on October 2, 1986.

h.

(0 pen) Open Item (50-455/86037-01):

Improvements to reduce possible confusion in collection of post accident samples from HRSS.

The licensee determined that the dilution valve in the Unit 2 system could not be reversed to make its operation identical to Unit 1.

Therefore, an arrow will be placed on the mimic board to indicate handle direction when the valve is in the " sample" position.

Region III was notified by telephone on February 13, 1987, that this had been accomplished.

The licensee representative also stated that semiannual hands-on training on this system would be given to the RCT's beginning in the second guarter of 1987.

This will be reviewed in subsequent inspections.

3.

Gaseous Effluents The inspector reviewed selected records of radioactive gaseous effluent sampling and analysis and the semiannual effluent reports for 1986.

The pathways sampled and analyses performed appear to comply with the requirements of Technical Specification Table 4.11-2.

Unit 1 is coasting down in power in preparation for its first refueling outage scheduled to begin in mid-February.

Unit 2 was issued a license on November 6, 1986 and achieved criticality on January 9, 1987 and as of the inspection had not exceeded five percent power.

The licensee has evidence of fuel cladding problems with Unit 1 which they believe consists of six to ten pin hole leaks.

The iodine-131 dose equivalent concentration has been running in the range of two to three E-2 pCi/g (a factor of ten or so above expected levels) with occasional short term increases associateu with power changes.

Even during power changes the iodine-131 dose equivalent concentration has remained well within the technical specification limit of one pCi/g for this parameter.

coolant generally ranges between 0.1 and Grossactivityintheprimary/g)i 1.0 pCi/g (maximum of 1.5 pCi well below the technical specification limit of 100 divided by E-Bar wh ch correlates to about 78 pCi/g.

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This has contributed to a marked increase in noble gas releases in 1986, which totaled 3785 Ci. The quarterly breakdown is as follows:

495 Ci during first quarter; 792 Ci during second quarter; 718 Ci during third quarter; and 1780 Ci during fourth quarter.

The dose rate associated with these releases remained less than one percent of applicable technical specification limits.

Most activity released was attributable to frequent containment venting for pressure relief.

The releases during October and November (650 Ci and 645 Ci respectively) were also augmented by release of Hold Up Tanks (HUTS)

cover gas to allow cleaning of the tanks.

The release was via waste gas decay tanks with minimal holdup time.

Contributing to containment pressure build-up and resulting venting are valve stem leak-off of reactor coolant, leak-off of instrument air or nitrogen used to o)erate some equipment and heat build up of the containment atmosplere.

ThefourReactorContainmentFanCoolers(RCFCs)

are used to reduce the latter.

Various controllers and regulators for air operated valves have a built in bleed off by design.

Both the Power Operated Relief Valve (PORV) on the pressurizer and the Safety Injection (SI) system use high pressure nitrogen and require make up due to small leaks.

During the Unit 1 refueling outage scheduled to begin in mid-February,/

the licensee plans activities to reduce fuel leaks and to make repairs modifications to minimize gaseous leaks into containment which necessitate containment venting.

All fuel is to be sipped and identified leaking fuel will be replaced.

The PORV nitrogen actuation system which uses nitrogen reduced from a pressure of up to 250 pounds will be replaced by a simpler system using instrument air.

Also, maintenance work is planned on the SI system and other systems with identified air / nitrogen leaks and on valves on the primary system.

Noble gas releases are quantified by radiation protection personnel based an analysis of samples collected prior to batch releases from waste gas decay tanks and containment.

No quantifications have been made for continuous (non-batch) releases from the station vent during the past year.

Daily gas samples collected in a Marinelli from the station vent arc analyze for gamma isotopes on a GeLr system and typically detect no activity above the Lower Limit of Detection (LLD).

On a daily basis in the past, hourly release rate trends for noble gases at the station vent were observed on the control room CRT for indication of any significant releases not attributable to batch releases.

None were identified.

The inspector expressed concern that in recent months the CRT observance has diminished to a weekly review of data, most of which at that frequency is

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only available on a daily average basis and as such lacks detail for a good evaluation for possible continuous release.

Further, no attempts had been made to correlate station vent stack monitor average release rates with known batch releases.

The correlation may be somewhat hampered by non use of the background subtraction feature of the station vent noble gas monitor due to a software problem.

As noted during a previous inspection this software problem was being pursued with the instrument vendor who has now issued a Field Change Order (FCO) 202 designed to correct the background subtraction problem.

This modification is expected to be completed by October 1987.

In response to these concerns, during the inspection, the licensee initiated a temporary daily graphing of two minute averages of station vent noble gas release rates which provided very good detail, one small peak, not attributable to batch releases, was identified and quantified at about 0.01 Ci which is insignificant compared to a typical recent containment venting of about 30 Ci.

The need for an improved management system to assure a continuing proper review, evaluation and cuantification of gaseous effluent releases was discussed at the exit and cur'ng subsequent telephone conversations with plant personnel on February 9, 10 and 11, 1987.

The licensee committed to establish an improved management system to accom)lish these goals.

This matter is considered an open item which will ]e reviewed dring a subsequent inspection.

(0 pen Items 454/87003-01; 455/87005-01)

No violations or deviations were identified.

4.

Liquid Effluents The inspector reviewed selected records and procedures associated with controlled liquid releases and the semi annual effluent report for 1986.

The pathways sampled and analysis performed appear to comply with the recuirements of Technical Specification Table 4.11-1.

Equipment mocifications (Section 8) and operating improvements have evaluated the licensee to make substantial reductions (factor of four) in liquid effluent releases in the past year.

Further, of the 4.05 Ci release in 1986, or,11y 2.17 Ci was released in the last 11 months of the year.

The licensee is averaging about 20-30 batches per month of processed waste composed of about 25 percent each of cesium-137 and cobalt-58 and about 15 percent each of cesium-134 and cobalt-60.

On September 1, 1986, a leak was discovered in the cooling water blowdown line to the river.

The line is on CECO property and sample analysis confirmed that the leak was contained on CECO property.

Leaks had developed in the line on two previous occasions at different locations but this was the first time activity was detectable.

The water flow was stopped, dirt excavated, repairs made and the excavation refilled.

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eighty soil samples and one water sample were collected and analyzed, most being sent to a contractor for analysis.

No activity was detectable in the water sample above the Lower Limit of Detection (LLD) value.

Low levels

of cesium-137 (up to about 2 pCi/g) were identified on some of the soil

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samples and even lower concentrations of manganese-45, cobalt-58, cobalt-60 and cesium-134 were identified on a smaller number of samples.

Five control soil samples were taken in areas which would not have been contaminated from the leak to try to identify possible contribution of the activity from the Chernobyl reactor accident.

These samples had positive identification for only cesium-137 and was in the range of 0.1 to 0.3 pCi/g.

The licensee indicated its intention to collect necessary data for submittal of a request (pursuant to provisions of 10 CFR 20.302)

for disposition of the slightly contaminated soil by onsite burial and that the Nuclear Services Group from the corporate office would take the lead

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in this activity.

This matter was discussed at the exit and is considered an open item the status of which will be followed during future inspections.

(0 pen Items 454/87003-02; 455/87005-02)

No violation or deviation were identified.

5.

Reactor Coolant Chemistry The inspector reviewed the licensee's experience for 1986 and the first 13 day of January 1987 with the technical specification required parameters for dissolved oxygen, chloride and fluoride for the primary coolant under various operational modes.

Surveillances have been timely and parameters

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well within applicable specifications throughout the review period.

The gross activity concentration and the iodine-131 dose equivalent concentration

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in reactor coolant have been previously discussed in Section 3 and, as noted, these parameters have also remained well within applicable limits.

The licensee also does a daily gross beta count of a water sample from the secondary side but have not identified any activity to date that would

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indicate primary to secondary leakage.

No violations or deviations were identified.

6.

Instrumentation

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lf The inspector reviewed calibration records for four liquid monito s i

(sodium iodide) and five noble gas monitors (beta scintillation).

The liquid monitors were the liquid radwaste effluent monitor, station blowdown monitor and two essential service water outlet monitors.

The noble gas monitors were two plant vent monitors (low and high range) two gas decay tanks effluent monitors (low and high range), and the containment purge

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monitor.

Calibrations were timely.

It was noted that the calibration procedures do not address background considerations.

In all but one calibration data sheet reviewed, the background count rate had been hand I

written in and according to personnel interviewed was being used in properly determining the calibration.

The need to specifically address background count rates in the calibration procedures to assure it is properly used during calibration was discussed at the exit and the licensee agreed to revise procedures accordingly.

This matter will be reviewed during a future inspection.

(0 pen Items 454/87003-03; 455/87005-03)

The set points for the above monitors were reviewed.

No problems were identified.

Two liquid monitors are being added to the technical specifications.

These are the existing turbine building fire and oil sump monitor and a new monitor on the condensate polisher sump.

No violations or deviations were identified.

7.

Air Cleaning Systems The inspector reviewed records of tests of air cleaning systems and discussed testing procedures and experience with personnel from the ventilation group responsible for-performance of the tests.

The review included both in place tests of HEPA filters and iodine adsorber units as well as laboratory tests of activated carbon samples.

Three systems are covered by Technical Specification (TS) requirements:

(1) Fuel Handling Building Exhaust Filter Plenum (TS 3.9.12); (2) Non accessible Filter

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Exhaust Plenum of the Auxiliary Building Ventilation (TS 3.7.7); and (3)

the Control Room Ventilation System (TS 3.7.6).

For the Fuel Handling Building, both initial and acceptance tests were performed by Plant Construction to the same criteria specified in the technical specifications.

Technical specification surveillance testing has not yet been performed for this system because no fuel has been stored in the storage pool and the applicability of the surveillance technical specification is "when fuel is in the storage, pool."per the The licensee plans to complete this surveillance before the Unit 1 first refueling outage begins, which is scheduled for mid-February 1987.

Surveillance Testing of both the Auxiliary Building Ventilation and the Control Room Ventilation

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systems has been both timely and has met acceptance criteria.

Problems with the monitors associated with the Control Room Ventilation

system have required frequent operation of the makeup unit.

Monitor

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modifications are in progress to correct these problems.

No violations or deviations were identified.

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8.

ChangestoEquipmtg The inspectoe reviewed portions of modification Packages M6-0-85.305 dated March 5, 1986, M6-0-85-357 dated March 14, 1986, M6-0-84-307 dated April 25, 1986, and M6-0-86-200 dated December 22, 1986, involving additions and modifications to the liquid radwaste system to enhance its operating efficiency and minimize activity in liquid effluents.

These modifications included:

addition of a new large regeneration waste drain tank; converting existing one to a dual purpose chemical / regeneration waste drain tank; addition of a piping cross-tie from the dischange of the radwaste monitor pumps to the inlet of the radwaste mixed bed demineralizers; addition of a second release tank and its cross-ties to the existing release tank; and installation of chemical addition system and mixers for the two release tanks.

10 CFR 50.59 reviews / evaluations had been conducted, documented and retained with the above modification packages.

No violations or deviations were identified.

9.

Audits and Appraisals The inspector identified and reviewed portions of several surveillances, audits or appraisals in 1986 that dealt with the gaseous and liquid radwaste program.

QA operating activities Surveillance No. 06-86-38 involved review (by an RS0) of radiation release forms for a gaseous activity release.

No discrepancies were identified by the review.

A part of the Radiochemical and Chemical Control Audit on January 15, 1986, verified proper completion of liquid and gaseous release forms and check off sheets.

No problems were noted.

This specific audit activity was intended to followup on a problem identified during an audit the previous year.

The problem had been corrected and this audit activity was to assure that corrective measures had more than short term effect.

Technical Specification Surveillance Report No. 06-86-735 involved review and verification that Auxiliary Building radioactive gaseous effluents had been determined to be within the limits stated in Technical Specification No. 4.11.2.1.2.

Chemistry Audit No. 08-86-48, of chemistry techniques and practices, included observation of both collection and analysis of a waste gas decay tank sample for conformance with applicable procedures.

No problems were noted.

No violation or deviations were identified.

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Organization and Training The radwaste-program is headed by Al Chernick, Redwaste Operation Engineer.

Reporting to Mr. Cherncik are Bob Aken, Shipping Coordinator, Scott Wilson, Radwaste Coordinator and six radwaste foremen.

Mr. Wilson has a degree in chemical engineering and five and a half year experience in both corporate and plant (three and a half years) chemistry and radiochemistry activities.

He has participated in both company and vendor training programs and participated last year in a corporate radwaste assessment of another CECO plant.

One of the six radwaste foremen has a degree and their experience ranges from five to 15 years with CECO.

The foremen have had systems training.

The radwaste foremen supervise equipment operators who operate the waste panel and equipment attendants who operate valves.

Some of these operators are licensed reactor operators and all have completed the operator training program.

Based on a limited review of radwaste records and discussions with selected radwaste personnel who were knowledgeable of applicable equipment, procedures and responsibilities, it is concluded that radwaste personnel are adequately trained and qualified to conduct an effective radwaste program.

No violations or deviations were identified.

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11.

Open Items

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Open items are matters which have been discussed with the licensee, which will be review (d further by the inspector, and which involve some action i

on the part of the NRC or licensee or both.

Open items disclosed during

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the inspection are discussed in Sections 3, 4, and 6.

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Exit Interview The ins)..aor summarized the scope and findings of the inspection with t

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licensee representatives (Section 1) at the conclusion of the inspection l

on January 22, 1987 and in followup telephone discussions on February 9, l

10 and 11, 1987.

The inspector discussed the likely informational content of the inspection report with regard to documents or processes

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reviewed by the inspector during the inspection.

The licensee did not identify such documents or processes as proprietary.

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TABLE 1 U S NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT CONFIRMATORY MEASUREMENTS PROGRAM FACILITY: BYRON STATN FOR THE 4 QUARTER OF 1986


NRC-------


LICENSEE----

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SAMPLE ISOTOPE RESULT ERROR PESULT ERROR RATIO RES T

L SPIKED SR-89 1.4E-04 4.OE-06 1.2E-04 3.9E-05 8.3E-01 3.5E 01 A

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SR-90 1.3E-05 5.OE-07 1.1E-05 3.OE-07 8.5E-01 2.6E 01 A

T TEST RESULTS:

A= AGREEMENT D= DISAGREEMENT

  • = CRITERIA RELAXED N=NO COMPARISON

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ATTACHMENT 1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS

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This attachment provides criteria for comparing results of capability tests and verification measurements. The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this program.

In these criteria, the judgment limits are variable in relation to the comparison of the NRC's value to its associated one sigma uncertainty.

As that ratio, referred to in this program as " Resolution", increases, the acceptability of a licensee's measurement should be more selective.

Conversely, poorer agreement should be considered acceptable as the resolution decreases.

The values in the ratio criteria may be rounded to fewer significant figures reported by the NRC Reference Laboratory, unless such rounding will result in a narrowed category of acceptance.

RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE Agreement

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0.5 - 2.0 8-

0.6 - 1.66 16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25 200 -

0.85 - 1.18 Some discrepancies may result from the use of different equipment, techniques, and for some specific nuclides.

These may be factored into the acceptance criteria and identified on the data sheet.

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