IR 05000454/1989013

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Insp Repts 50-454/89-13 & 50-455/89-15 on 890424-28.No Violations Noted.Major Areas Inspected:Chemistry Program, Including Procedures,Organization & Training & Primary & Secondary Sys Water QC Programs
ML20248C216
Person / Time
Site: Byron  Constellation icon.png
Issue date: 05/24/1989
From: Holtzman R, House J, Schumacher M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20248C209 List:
References
50-454-89-13, 50-455-89-15, NUDOCS 8906090303
Download: ML20248C216 (14)


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U.S. NUCLEAR REGULATORY COMMISSION REGION III-Reports No. 50-454/89013(DRSS); 50-455/89015(DRSS)

Docket Nos. 50-454; 50-455 Licenses No. NPF-37; NPF-66 Licensee:

Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name:

Byron Nuclear Power Station, Units 1 and 2 Inspection At:

Byron Site, Byron, Illinois Inspection Conducted:

Aprn 24-28, 1989 (0nsite)

iw (dff/77 Inspectors.

J. E. House Date'

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ppfg Approved By:

M. C. Schumacher, Chief 5//f/ /

Radiological Controls and Date

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Chemistry Section

. Inspection Summary Inspection on April 24-28, 1989 (Report Nos. 50-454/89013(DRSS); 50-455/89015(DRSS))

Areas Inspected:

Routine. unannounced inspection of: (1) the chemistry program, including procedures, organization, and training (IP 84750); (2) primary and secondary systems water quality control programs (IP 84750); (3) quality assurance / quality control program in the laboratory (IP 84750);

(4) nonradiolgical confirmatory measurements (IP 79701); and (5) the radiological environmental monitoring Program (REMP) (IP 84750).

Results: The licensee has an extensive water quality control program that conforms to the EPRI Steam Generator Owners and Primary Systems Guidelines.

Overall water quality was good as were the nonradiological confirmatory measurements.

Laboratory management has been separated from Radiation Protection and the technicians have been permanently assigned to the laboratory.

Laboratory QA/QC programs are improving.

The REMP was operating satisfactorily.

L No violations or deviations were identified.

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DETAILS 1.

Persons Contacted-

  • G. K. Schwartz, Production Superintendent, Byron, CECO
  • S. Wilson, Chemistry Supervisor, Byron
  • S. L. Barrett, Health Physics Services Supervisor, Byron
  • M. Snow, Regulatory Assurance Supervisor, Byron
  • K. L. Lurkins, Chemistry Engineering Assistant, Byron
  • E. M. Zittle, Regulatory Assurance Supervisor, Byron S. Fletcher, Health Physics Instrument Coordinator, Byron D. Olsen, Chemistry Foreman, Byron C. Boughton, Chemistry Foreman, Byron L. Ludicky, Unit 2 Chemist, Byron V. Junlosjiraya, Chemist, Byron R. Tucker, Chemistry Technician (CT), Byron
  • N. V. Gilles, Resident Inspector, NRC The inspectors also interviewed other licensee personnel in various departments in the course of the inspection.
  • Present at the Exit Meeting on April 28, 1989.

2.

Licensee Action on Previous Inspection findings a.

(Closed) Open Item (50-454/37036-02; 50-455/87033-02):

The licensee was to review and correct methods in nonradiological confirmatory measurements that produced disagreements.

The licensee has continued the development of the QA/QC program that now incorporates multiple point calibration curves, independent controls and statistically-based control charts.

Laboratory management appeared to monitor the QA/QC program closely.

The licensee performed well on the present set of nonradiological confirmatory measurement samples and on the corporate interlaboratory comparison program (Sections 6 and 7).

b.

(Closed) Open Item (50-454/88013-10; 50-455/88013-10):

The licensee spiked reactor water with anions and condensate with metals, split j

the samples with Brookhaven National Laboratory, analyzed them and

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sent the results to Region III.

Most of the licensee's results were l

in disagreement with BNL.

The source of the disagreements could not

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be determined.

However, based on licensee performance in the j

previous sample split (all agreements), in the current confirmatory j

measurements analyses and in the licensee's interlaboratory I

comparison program, these disagreements appear to be an anomaly.

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This item is considered closed and another split sample will be

conducted with BNL following this inspection.

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(Closed) Open Item (50-454/88013-11; 50-455/88013-11):

During the c.

inspection, the licensee experienced difficulty in measuring sodium in the presence of lithium using graphite furnace atomic absorption

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An interference was suspected an'd the~1icensee.

. performed'a' study involving several analytical methods. Analysis by flame atomic absorption yielded results that were in agreement'

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The licensee then modified-the graphite furnace method by altering the sample matrix.

Results of _ these analyses were then in agreement with those of BNL..An interference was the most probable cause of the original disagreements.

This problem.

.is'not' serious since the two cations'are not normally determined in each others presence.

d.

(Closed) Open. Item (50-454/87042-01; 50-455/87039-01):

Analyze liquid sample for gross beta,: tritium,.Sr-89,-Sr-90 and Fe-55 and

report results to Region III.

Results_of sample' comparisons are-J given'in Table 1; the comparison criteria are given in Attachment 1.

Agreement resulted for gross beta and. tritium'and the lone disagreement for.Fe-55.

Sr-89 and Sr-90 were not' compared due to poor counting' statistics'

However, the reported values were below

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the licensee's Technical Specification Lower. Limit of Detection.

The Fe-55 analysis will be examined during a subsequent inspection when another. sample will be split and analyzed.

3.

Management Controls, Organization,' and Training (IP 84750)

.The management structure of the Chemistry Department has undergone significant changes since the previous inspection in this area.1 The' Chemistry group'has been separated from the Rad / Chem Department and the Chemistry Supervisor now reports to the Technical Superintendent.

One layer of management (group leader) has been eliminated from the laboratory organization.

The new structure has three Chemistry Foremen and a Lead Chemist reporting'to the Chemistry Supervisor.

Chemists and Engineering Assistants report to a Lead Chemist and Chemistry Technicians (cts). report to the Foremen.

A major change in.the laboratory organization has been the division of Rad-Chem Technicians into two groups, health physics and chemistry.

Thirteen cts are permanently assigned to the chemistry laboratory.

Currently all are qualified as technicians under the ANSI N18.1-1971 standard.

The separation of the technicians should result in improved technician proficiency, laboratory continuity and a reduction in the burden on the laboratory supervisors to continually retrain a large number of technicians and to track their proficiencies.

No violations or deviations were identified.

4.

. Water Chemistry Control Program (IP 84750)

The. inspectors. reviewed the water chemistry control program which is based on a corporate directive, NO Directive NOD-CY.1, "PWR Secondary Water Chemistry Control Program," Revision 1, June 27, 1988, and implemented by BAP 599-39, " Secondary Chemistry Monitoring Program,"

1 Region III Inspection Reports No. (50-454/88013; 50-455/88013)

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Revision 5, September 6, 1988.

These documents commit the licensee to and are consistent with the EPRI. Steam Generator (S/G) Owners Group Guidelines.

Approval to waive the guidelines must come from either the Vice President-PWR Operations or the General Manager-PWR Operations.

The licensee has a procedure specifying the chemistry parameters for the primary system, BAP 599-1 " Reactor Coolant Chemistry System Description (RC/RY), " Revision 4, April 2, 1986.

It is based on the Westinghouse specifications, " Chemistry Criteria and Specifications,"

Westinghouse Corporation, pp. 1-3, 1985, and Technical Specifications.

It does not address the EPRI Primary System Guidelines, but it does appear to be consistent with them.

In-line monitoring systems for S/G blowdown are located in the hot laboratory and analyze all eight S/Gs for specific and. cation conductivity, pH, dissolved oxygen and sodium.

New Orion sodium analyzers were added to this panel since the last inspection.

An in-line Ion Chromatograph analyzed blowdown from one S/G from each unit for chloride, sulfate, sodium and ammonia.

In-line instruments in secondary samp?O panels in other locations monitor main steam, conductivity and feedwater.

Data loggers are utilized to manage these data.

Trend charts for secondary water quality are maintained by the licensee.

A review of selected data from the past year indicated that plant water quality is generally good and chemistry parameters have remained generally within the EPRI guidelines.

Because their concentrations are normally not detectable, feedwater metals are not analyzed.

However, they will be determined when filtration-ion exchange concentrators for dissolved and suspended metals are installed during upcoming outages.

This will be reviewed in subsequent inspections.

Chemistry parameters are monitored by plant and corporate management on a daily basis.

Laboratory personnel monitor water quality and brief the Production Superintendent pricr to the morning meeting. Water chemistry for each unit is discussed by plant management during this meeting and any changes or trends are closely followed.

Corrective actions to reduce increasing contaminant levels are taken whenever an increase is observed, instead of waiting until an action level is reached.

Chemistry trends are reported to corporate management daily.

Licensee management appears to be very supportive of and putting much effort into a study, in conjunction with EPRI, to determine the chemistry mechanisms of 5/G hideout.

Under certain operating conditions some ionic species will be removed from the S/G water and then reappear as power levels are reduced.

It appears that chloride and sodium ions concentrate in crevices, such as at the intersection of the tubes and tube sheet, which makes them locally very corrosive.

On the other hand, sulfate ions appear to deposit on the metal surfaces, are thus more dilute and have much less effect on the metals.

Elucidation of these properties may allow operation of the plants under less corrosive conditions.

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The water quality control program appears to have the support of plant management, to be adequate for controlling water chemsitry and to be well managed.

No violations or deviations were identified.

5.

Implementation of the Chemistry Program (IP 84750)

The inspectors reviewed the chemistry programs, including physical

' facilities and laboratory operations.

Housekeeping was good and bench space was adequate for the analyses performed.

The laboratories were well equipped.

The hot laboratory has two computer-controlled Dionex Ion Chromatography configured for' gradient elution analyses.

The licensee also makes extensive use of an inline IC system for anion and cation analyses on the S/G blowdown.

A highly computerized Varian Spectra AA-40 Atomic Absorption Spectrophotometer is being set up to replace the Perkin-Elmer Model 5000, and a microprocessor-controlled Milton Roy Spectronic Model 1201 UV/Vis Spectrophotmeter with a 5-cm flow-through cell for improved sensitivity in the silica analysis is to replace the older Hitachi unit.

The inspectors observed several cts analyze the confirmatory measurements samples on the ion chromatography and the boron autotitrator.

They appeared to be generally knowledgeable about the work and followed the procedures.

The laboratory is equipped with state-of-the-art instrumentation and it appears to be operating well.

No violations or deviations were identified.

6.

Nonradiological Confirmatory Measurements (IP 79701)

The inspectors submitted chemistry samples to the licensee for analysis as part of a program to evaluate the laboratory's capabilities to monitor nonradiological chemistry parameters in various plant systems with respect to various Technical Specification and other regulatory and administrative requirements.

These samples had been prepared, standardized, and periodically reanalyzed (to check for stability) for the NRC by the f

Radiological Sciences Division of Brookhaven National Laboratory (BNL).

j The samples were analyzed by the licensee using routine methods and

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equipment.

The namples were diluted by licensee personnel as necessary to bring the concentrations within the ranges normally analyzed by the laboratory, and run in triplicate in a manner similar to that of routine samples.

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results are presented in Table 2 and the criteria for agreement in Attachment 2.

These criteria for agreement are based on comparisons of the mean values and estimates of the standard deviations (SD) of the measurements.

Consideration was given to the fact that the uncertainties (SD) of the licensee's results were not necessarily representative of the laboratory's because they were obtained by one analyst over a short i

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period of time.

Consequently, when the licensee's SD was-less than that of BNL, and a disagreement resulted, the BNL value was substituted for that of the licensee in calculating the SD of the ratio Z (S in Attachment _2).

Further, when both the BNL and licensee's SDfappeared to be excessively low for a given analytical method, values of 3% relative SD (RSD) were substituted for the respective SDs.

The licensee will also prepare a' sample of reactor coolant spiked with fluoride, chloride and sulfate to be split with BNL. The licensee'will determine the concentrations of the analytes and the~results will be sent to Region III for comparison with the values determined by BNL.

This will be followed under the Open Item Nos. (50-454/89013-01; 50-455/89015-01).

The licensee determined 10 analytes at three concentrations each.

Of.the initial 30 analyses 27 were in agreement (90%).

The chloride and sulfate results showed decreasing biases with increasing concentrations, which indicated contamination of the dilution water.

The licensee noted that the blank did contain some of these analytes, but they were not quantified.

A rerun.of the low-level chloride had a smaller positive b.ias and was in agreement.

The fluoride showed substantial negative biases,'which appear to be due to high values of the standards, or-

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possibly to problems in the water dip in the IC.

This was not resolved, but the. licensee representatives agreed to look into the matter.

Due to some uncertainties in the values of the boron standards, in this assessment the mean values of the concentrations'obtained by the other plant laboratories in Region III were used as the NRC values in Table 2.

These results appear to have resolved the problem of the consistently negative biases between the licensees and BNL boron analyses.

The licensees appear to have generally reported similar values of the 1000 ppm standard with a relatively small RSD of 11.7%, although the analytical methods differed.

In the present inspection the licensee i

used an inflection endpoint, which the chemist showed to be at pH 8.6,

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.which is consistent with the dead-stop endpoint used by other laboratories under similar conditions.

Overall, the results of the analyses were good.

Laboratory personnel demonstrated a willingness and good ability in determining the causes

.of the disagreements.

No violations or deviations were identified.

7.

Implementation of the QA/QC Program in the Laboratory (IP 84750)

The inspectors reviewed the chemistry laboratory quality assurance program as specified by corporate directive Nuclear Operations Chemistry.

Quality Control Program, Revision 3, January 16, 1989 and detailed in the licensee's procedures BAP 599-47, " Byron Station Chemistry Quality Control Program," Revision 2, January 17, 1989, and BCP 520-4, " Quality Control Reporting Procedure," Revision 2, January 17, 1989.

The BCP procedure describes the setup and operation of the QC program and control charts.

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The licensee uses multiple point calibration curves, independent controls'

- and statistically-based control charts with limits set at 2 SD.

Independent controls are used in preparing control charts.

However, the inspectors noted their concern that the control charts were removed from the instrument lonbook as soon as completed, so that the

- technicians could not easily see the history'of the analysis.

A more significant concern was that, by procedure, the analyses were considered out of control only when two _ consecutive performance check pints were outside the control limits.

This appears to'have resulted in charts with

, numerous non random trends.and much wider control-limits than the analytical methods warrant.

The charts are designed to demonstrate the random statistical operation of the system; thus, trends in the performance check data such as several consecutive points cn one side of the mean line'may, indicate a' lack of control.

Other non-random behavior also may be seen from these charts using the Shewhart criteria.

These criteria do not necessarily need formalization, but the chemists responsible for the QC should be aware of them and able-to estimate the probabilities of various types of events as being purely random occurrences, e.g., the probability of an event _ occurring near the 2-sigma

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control limit is about 1 in 20, of two such consecutive events', 1 in 400.

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These problems _were especially evident.in the IC control charts, an indication that more frequent assessment and calibrations are needed.

Licensee representatives a3 reed to leave at least one older chart (or copy)

in the icgbook and to consider these other criteria for estimating out-of-control analyses.

The licensee's Interlaboratory comparison program is managed by the CECO Technical' Center for all stations.

Data from the third quarter of 1988 showed that 73% of the analyses were within 10% of the reference value.

Fourth quarter data was improved with 100% of the analyses within 10%

of the reference value. The Intralaboratory Comparison Program (CT performance tests) is specified in procedure BAP 599-50, " Byron Station Chemistry Test Program Description," Revision 2, June 20,1988.

From a review of selected data,'it. appears that the program has been functioning normally.

cts failing a given analysis were retested.

The acceptance criteria were not statistically based, but used a percent variation from the mean value.

The inspectors discussed the use of a statistically based criterion with the licensee.

Progress in this area will_be followed in subsequent inspections.

The licensee has just started writing _ a procedure for a calibration and performance check system for inline (process) instrumentation, as specified by the Corporate Directive " Nuclear Operations In-Line Chemistry Instruments Quality Control Program," Revision 1, July 1,1988.

Presently, biweekly, the laboratory compares the process instrumentation readings to laboratory grab samples for conductivity, pH, sodium, calcium, ammonia, hydrazine and-dissolved oxygen.

These are tabulated on a sheet with acceptance criteria and the instruments out of specification are-l adjusted or tagged for repairs. The data collected over the past year will.be used in developing the system.

The laboratory is also developing

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calibration' procedures for the in1_ine-IC in ways that realistically

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resemble sample measurements.themselves.

This program is important

to validate the inline instrumentation.

No violations'or deviations were identified.

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Radiological Environmental Monitoring Program (REMP)(IP 84750)'

The inspectors reviewed the REMP, including the 1987 Annual Environmental

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contains the cumulative-results of the year.

.j The-Annual Environmental Report' appeared to comply with the REMP-requirements.

All of the required samples were collected and analyzed, except as noted in the report, and a perusal of the results showed them to be reasonable. The-1988 monthly reports appeared.to'be acceptable.

.The inspectors toured the air sampling stations around the plant and observed'a licensee representative demonstrate the testing of the air samplers, i.e. check the systems for operability, and leakage of the sampling. train.

While the stations'did not have calibration tags, the maintenance records showed the.flowrates to have been calibrated monthly. :The pumps and filter trains on the five air samplers observed appeared to be operating satisfactorily, both with respect to vacuum and

.flowrate.

The.REMP appeared to be operating satisfactorily.

I-No. violations or deviations were identified.

9.

Emergency Preparedness Drill (IP 84750)

The inspector observed a licensee health physics drill designed to i

demonstrate the licensee's abilities to sample and analyze reactor coolant' and to: sample containment air using the Post Accident. Sampling-System.(PASS).

The sampling team appeared to be knowledgeable about the PASS panels for collecting the RCS sample.

During sampling of the RCS however, a valve malfunction caused the collection container to overfill and a small quantity of reactor coolant was spilled.

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-team monitored the spill area for radioactivity and cleaned it up

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During the containment air sampling part of the drill, the team obtained the sample but appeared to have some difficulty with the equipment panel.

A licensee representative stated that the team had experienced some difficulties with the procedure and equipment operation and that additional training would be provided.

No violations or deviations were observed.

10.

Audits and Appraisals (IP 84750)

The inspectors reviewed the most recent Technical Services Performance Assessment' of the chemistry laboratory conducted from November 28 to a

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December 2, 1988, and the laboratory's subsequent response.

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requiring a written response were made.

The auditors. appeared to address in adequate detail the nonradiological chemistry quality assurance program.

Items identified in the audit appear to have been addressed in a timely manner.

No violations or deviations were identified.

11. Open Items Open items are matters which have been discussed with the licensee, which will' be reviewed further by the inspectors, and which involve some action on the part of the NRC or licensee, or both.

One open-item disclosed during the inspection is discussed in Section 6.

12.

Exit Interview The scope and findings of the inspection were reviewed with licensee-representatives (Section 1) at the conclusion of the inspection on April 28, 1989.

The inspectors discussed the Open Items in Section 2 and observations on the quality control program and the confirmatory measurements.

Licensee representatives noted modifications to be made to the chemistry procedures, as discussed in Sections 5, 6 and 7.

During the exit interview, the inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection.

Licensee representatives did not identify any such documents or processes as proprietary.

Attachments:

1. Table 1, Radiological Interlaboratory Test Results, 4th Quarter, 1987.

2. Table 2, Nonradiological Interlaboratory Test Results, April 24-28, 1989.

3. Attachment 1, Criteria for Comparing Radiological Measurements.

4. Attachment 2, Criteria for Comparing

' Analytical Measurements (Nonradiological).

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TABLE 1 l-U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION CONFIRMATORY MEASUREMENTS PROGRAM FACILITY:

Byron-

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DATE:

4th Quarter, 1987 NRC LICENSEE LICENSEE:NRC-SAMPLE-ISOTOPE-RESULT ERROR RESULT ERROR RATIO RES T

L WASTE BETA 6.1E-06 6.0E-07 4.0E-06 0.0E-01 6.6E-01 1.0E 01 A H-3 1.6E-01 2.0E-03 1.5E-01 0.0E-01 9.7E-01 7.9E 01 A'

SR-89 1.0E-09 6.0E-09

<1.3E-08 0.0E-01 1.3E 01 1.7 N

SR-90 4. 0E-09 3.0E-09

<6.6E-09 0.0E-01 1.7E 00 1.3E 00 N FE-55 1.3E-05 2.0E-07 5.0E-06 5.0E-07 3.9E-01 6.3E 01 D T = Test Results:

A = Agreement D = Disagreement

  • = Criteria relaxed N = no comparison l

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TABLE 2 Nonradiological Interlaboratory Test Results Byron Nuclear Power Station, Units 1 and 2 April 24-28, 1989 a

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Analyte Analytigal NRC Licensee Ratio Comparison Method Y i SD X i SD Z t SD i 2 SD Concentration, ppb Fluoride ICG 5.63 0.50 4.61 1 0.06 0.820 1 0.103 A*

10.58 i 0.20 9.37 0.09 0.886 1 0.038 D+

20.70 i 0.43 18.8 1 0.30 0.908 1 0.038 D+

Chloride ICG 4.63 1 0.03 6.07 0.18 1.312 0.040 D+

9.33 1 0.15 9.81 i 0.23 1.052 1 0.030 A

19.13 1 0.30 18.2 1 0.10 0.952 1 0.040 A+

(rerun)

4.63 1 0.03 4.59 i 0.09 0.991 1 0.020 A

Sulfate ICG 4.88 1 0.35 5.03 0.07 1.032 0.075 A

9.58 1 0.68 9.23 0.23 0.964 1 0.072 A

19.5 1 0.58 18.1 1 0.3 0.928 1 0.039 A*

Fe AA/Fu 18.6 0.5 19.7 0.4 1.059 i 0.036 A

29.25 1 0.75 27.6 i 0.20 0.944 0.034 A*

39.8 0.50 42.6 3.3 1.070 1 0.084 A

Cu AA/Fu 20.0 1 0.3 19.7 1 0.5 0.985 1 0.029 A

30.0 0.75 29.9 i 0.3 0.997 1 0.027 A

40.3 1. 5 39.6 1 0. 2 0.983 1 0.037 A

Li DCP 985 i 20 924 i 13 0.938 1 0.040 A+

1500

1486

0.991 0.029 A

2065 1 50 2061

0.998 0.024 A

NH3 Spec 1040 1 50 990 i 10 0.952 1 0.047 A

2460 1 115 2519

2 1.024 0.048 A

3000

3128

6 1.043 1 0.044 A+

Hydra-Spec 19.9 1 0.3 20.0 1 0.0 1.005 0.016 A

zine 49.9 0.5 50.7 1 0.6 1.016 1 0.016 A

j 100

1 99.7 1 0.6 0.997 0.012 A

l Silica Spec 52.8 1 2.8 47.7 1 0.6 0.903 0.049 A

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0.942 0.046 A

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2 147

1 0.936 0.040 A+

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Analyte Analytigal NRC Licensee Ratio Comparison l

Method

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Y i SD X i SD Z i SD i 2 SD l

.i Concentration, ppm d

l-Boron Titr 1000 1 17 1007 1 10 1.007 i 0.020 A

3960 1 40 2968 i

1.003 i 0.014 A

4902 i 76 4898 1 20'

O.999 0.016 A

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Value + standard deviation (SD); number of BNL analyses is 6 to 9.

The number of licensee analyses is 3.

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Analytical methods:

Titr - titration ICG

- Ion chromatography (Gradient)

Spec - Spectrophotometric AA/Fu - Atomic absorption Spectroscopy (furnace)

DCP

- Direct Current Plasma spectrophotometry c.

A = Agreement 0 = Disagreement d.

NRC (BNL) value replaced by mean values of plants in Region III.

  • Substituted the BNL uncertainty for licensee's uncertainty.

+ Substituted 3% relative SD for BNL and licensee's SDs.

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s ATTACHMENT 1 j

CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS

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This attachment provides criteria for comparing results of capability tests I

and verification measurements. The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this program.

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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 l

licensee's measurement should be more selective.

Conversely, poorer agreement

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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 l

Reference Laboratory, unless such rounding will result in a narrowed category of acceptance.

t RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE Agreement t

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0.5 - 2.0 8-

0. 6 - 1.66

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16 - 50 0.75 - 1.33 i

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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ATTACHMENT 2 Criteria for Comparing Analytical-Measurements

,

This attachment provides criteria for comparing results of the capability tests.

The acceptance limits are based on the uncertainty (standard deviation) of the ratio of the licensee's mean value (X) to the NRC mean value (Y), where (1) Z = X/Y is the ratio, and

(2) S is the uncertainty of the ratio determined from the propagation of the uncertainties of licensee's mean value, S, and of the NRC's mean value, S.2 Thus, x

y S2

s2 z _ x y_, so that T ~ T

_T'

[S*2. S 2D

+ Y-

'

S-=Z*-

z -

(X2 y2)

The results are considered to be in agreement when the bias in the ratio (absolute value of difference between unity and the ratio) is less than or equal to twice the uncertainty in the ratio, i.e.

I 1-Z l 5,2*S7 1.

National Council on Radiation Protection and Measurements, A Handbook of Radioactivity Measurements Procedures, NCRP Report No. 58, Second Edition, 1985, Pages 322-326 (see Page324).

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