ML18046A282
| ML18046A282 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/12/1980 |
| From: | Januska A, Paperiello C, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18046A279 | List: |
| References | |
| 50-255-80-19, NUDOCS 8101090114 | |
| Download: ML18046A282 (12) | |
See also: IR 05000255/1980019
Text
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-255/80-19
Docket No. 50-255
Licensee:
Consumers Power Company
212 West Michigan Avenue
Jackson, MI
49201
Facility Name:
Palisades Nuclear Generating Plant
Inspection At:
Palisades Site, Covert, MI
Inspection Conducted:
October 20-24, 1980
ll.);. ~~~
Inspectors:
A. G . .JQnuska
[A/C3
~
Approved By:
C. J. Paperiello, Acting Chief
Environmental and Special
Projects Section
Inspection Summary
License No. DPR-20
Ins ection on October 20-24
1980 (Re ort No. 50-255/80-19)
Areas Inspected:
Routine, unannounced inspection of 1 Environmental Protection
- including quality control of analytical measurements; program management and
implementation; review of program results; inspection of selected sampling
stations; nonradioactive effluent release rates and limits; and (2) Confirmatory
Measurements - including discussion of previous sample results; collection of
samples, analysis onsite with the Region III Measurements Van and discussion of
results; and program for quality assurance and quality control of analytical
measurements.
The inspection involved 72 inspector-hours on site by two NRC
inspectors.
Results:
Of the eight areas inspected, no apparent items of noncompliance or
deviations were identified in six areas; four apparent items of noncompliance
were identified in two areas; (deficiency - failure to submit the annual non-
radiological environmental report for CY79 on time - Paragraph 4; deficiency -
failure to include all information required in the annual nonradiological environ-
mental report for CY79 - Paragraph 4; deficiency - failure to record and measure
discharge temperature as required - Paragraph 4.a; deficiency - failure to ac-
curately report the total curies for each of the radionuclides released in parti-
culate form - Paragraph lOa) .
DETAILS
1.
Persons Contacted
R. Montross, Plant Superintendent
- H. Palmer, Technical Superintendent
- A. Kowalczuk, Chemistry/Health Physics Superintendent
- R. McCaleb, Quality Assurance Superintendent
- S. Pierce, Radiological Materials Control Supervisor
- D. Andrews, Environmental Supervisor
- P. Stoner, General Health Physicist
J. Pendergast, Chemistry/Health Physics Technician
D. McBride, Chemistry/Health Physics Technician
- Denotes those present at the exit interview.
2.
Im lementation of the Radiolo ical Environmental Monitorin
The inspectors examined the REMP results for CY1979, and for January 1,
1980 through August 31, 1980, to verify compliance with the requirements
of Section 4.11 of Appendix A Technical Specifications.
The examination
included a review of the results in the 1979 Annual Radiological Environ-
mental Monitoring Report and Data Tabulations and Analysis reports prepared
by the licensee's contractor, Eberline Instrument Corporation.
All samples
were taken as required, and any difficulties or anomalous results were noted
where appropriate, and formally reviewed.
In addition to the analyses required by technical specifications, the
licensee determines the total activity of beta emitting isotopes that
exist in plant liquid effluents by collecting a daily composite sample,
and counting the sample with a gas proportional counter.
A monthly
composite of the daily composites is prepared and sent to Eberline for
analysis.
Health Physics procedure HP 3.13 specifies that all gross
beta counting data be recorded on forms HP 3.13-1, HP 3.13-2, and HP
3.13-3.
The inspectors found that during November and December 1979,
all samples had been counted on the same day, and that no samples had
been counted for the period April 1, 1980 through September 30, 1980.
The licensee stated that the counting detector used had been broken and
that a new one was on order.
The inspectors emphasized the need to count
samples as soon as possible after collection to accurately determine the
gross beta concentration, otherwise short-lived radionuclides would decay
away prior to counting.
These problems had been identified during an
audit conducted by the licensee on September 9, 1980.
In response to
this audit, gross beta counting was resumed on a counter located in the
hot lab pending the replacement of the detector on the other counter.
A check of October 1980 counting data to date indicates that corrective
actions taken to correct the gross beta counting problems are adequate.
This problem was discussed at the exit interview .
- 2 -
The inspectors reviewed records of plant environmental Thermoluminescent
Dosimeter (TLD) placement.
This is conducted in accordance with proce-
dure HP 3.11, which states in part that required information be placed
on form HP 3.11-3 or HP 3.11-4, depending on whether these are monthly
or quarterly TLDs, respectively.
Required information for both forms
is the date and time of TLD annealing, packaging, placement, collection,
and readout.
Although TLDs were collected and processed correctly,
numerous errors were found on the result forms.
For example, TLD records
for the month of October 1979 showed that all TLDs had been annealed,
packaged, posted, collected, and read out on the same day (November 1,
1979).
Annealing and packaging had occurred for all TLDs at the same
time (1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br />), even though procedure HP 3.11 states that the TLD
chips shall be allowed to cool before packaging.
Some forms did not
indicate the time, but only the date.
One form showed that the TLDs
had been read out on May 9, 1980, but did not indicate the date or time
of annealing, packaging, posting, or collection.
Numerous forms for
both 1979 and 1980 showed collection and posting dates to be identical.
Procedure HP 3.11 states in part, "Use the form that was partially com-
pleted when these TLDs were placed in the environment one month ago."
This had not been done.
The licensee corrected forms in error for 1980
by "whitening out" the incorrect dates and replacing them with the correct
dates.
The inspectors stated that incorrect entries on records should be
lined out and anotated with the correct entries rather than whitening them
out.
This was discussed at the exit interview.
No apparent items of noncompliance were identified.
3.
Sampling Stations and Equipment
The inspectors toured several environmental sampling stations and
examined air sampling equipment and thermoluminescent dosimeters.
A
test performed by the inspectors indicated no apparent leakage in the
air sampling system.
Records of calibrations of the pumps between
January 1977 and October 1980 were examined and showed that all equipment
had been calibrated on schedule.
One air sampling location was found
inoperable by the inspectors during the tour of the sampling stations.
This sampler, located near a well cover building, had been electrically
disconnected by the plant maintenance department within the past two
weeks so that the building could be removed.
The inspectors observed
that no visible work was being performed to remove the building, and
reminded licensee personnel of the requirement to collect weekly air
samples.
Licensee personnel stated that this sampler would be electri-
cally connected as soon as possible to preclude missing a weekly sample
collection.
This was discussed at the exit interview.
No apparent items of noncompliance were identified.
4.
Nonradiological Environmental Monitoring Program
The inspectors attempted to review the 1979 Annual Nonradiological
Environmental Monitoring Report, but discovered that it had never
- 3 -
been issued.
This is a Violation of Appendix A Technical Specification 6.9.3.1.C which states, in part, that a nonradiological environmental
monitoring report for the previous year shall be issued within 90 days
after January 1 of each preceding year.
The licensee had been under
the impression that the annual NPDES report submitted to the Michigan
State Department of Natural Resources fulfilled this requirement.
The
licensee was reminded that this is not the case, since the NPDES report
does not contain all the information required in the Technical Specifica-
tions.
The licensee prepared the required report and submitted it to
the NRC prior to the completion of this inspection.
On October 23, 1980,
the licensee issued a report titled "1979 Nonradiological Environmental
Monitoring Program." The inspectors reviewed this report and found that
the topics, "heavy metals in the mixing basin water" and "fish in the
discharge" were not discussed in this report as required by Technical
Specification 6.9.3.1.C. Further, this technical specification also
requires that for each medium sampled during the year, a list and map
of the sampling locations and total number of samples shall be included.
The report, where applicable, shall include a comparison with the previous
environmental monitoring results and include an assessment of the observed
impacts of the plant operation on the environment.
None of these items
were addressed in this report, and as such, this constitutes an item of
noncompliance.
The following results of the licensee's nonradiological environmental
monitoring program were examined for compliance with monitoring and
reporting requirements:
a.
Maximum Discharge - 4T
The inspectors discussed monitoring of discharge temperatures, ambient
lake temperatures, and the subsequent computation of~T. Technical
Specification 3.9.9 limits the temperature of the discharge to the lake
during closed cooling system operations to 5°F above the ambient tempera-
ture of the lake at the shoreline.
This limit can be exceeded by no more
than 20% for no more than twelve hours, or up to seven days on the loss
of one dilution pump.
Technical Specification 4.11.4 requires continuous
measurement and hourly records during cooling system operation of the
following:
mixing basin water temperature prior to discharge to the lake,
service water intake temperature, and dilution water intake temperature.
This is to verify compliance with Technical Specification 3.9.9. Health
Physics procedure HP 3.4 is used to determine and record the temperature
and heat rejection to the lake and fulfill the Technical Specification
requirements for monitoring discharge temperature.
Hourly readings must
be placed on form HP 3.4-2 in accordance with this procedure.
The maximum,
minimum, and average intake and discharge temperatures are then recorded
on form HP 3.4-1 and the average daily6.T and heat rejection (Btu/hr) are
computed.
The inspectors reviewed completed forms HP 3.4-1 and HP 3.4-2
for the period November 1, 1979 through September 30, 1980, and found
many forms where individual hourly readings were left blank with no ex-
planation.
No discharge temperatures were recorded for the period
- 4 -
1-
April 28, 1980 through July 31, 1980 although the cooling system operated
during this time period.
This is a violation of procedure HP 3.4 and
Technical Specification 4.11.4, and as such, constitutes an item of non-
compliance.
The inspectors noted that procedure HP 3.4 has no back-up provision
for hourly temperature recording in the event that the temperature
recorder (TR-5370) fails to operate. Auxiliary operators normally
collect a grab sample for lake and discharge temperature during each
shift, but records of these results do not indicate the time of
sample collection.
A review of these records also showed that samples
are often missed, and results are sometimes recorded in Fahrenheit and
sometimes in Centigrade, i.e., intake temperature - 59°, discharge
temperature - 15°.
b.
Chlorine Discharges
The concentration of chlorine in water discharged to the lake is
limited by Technical Specification 3.9.6 to 0.02 ppm at the
point of entry to the lake.
Chlorination is limited by Technical
Specification 3.9.7 to 60 minutes during simultaneous discharge
from the cooling system in a period of one day.
Health Physics
procedure HP 3.3 is used to calculate and record levels of chlorine
in water discharged to Lake Michigan and specifies, in part, that
form HP 3.3-1 be completed a minimum of once per week.
A review
of records for the period January 1, 1980 through September 30,
1980, indicated that form HP 3.3-1 had not been completed as re-
quired even though chlorinations had occurred numerous times during
this period.
A further check by the inspectors determined that the
chlorine concentrations in the discharge water had, in fact, been
measured, but these results had never been recorded on the required
forms.
This failure to follow procedures is another example of the
type of problems discussed in Paragraphs 2 and 4.a above.
The li-
censee stated that he would immediately fill out the required forms
with the data that had been measured.
c.
pH and Conductivity
The pH of all discharges from the plant to Lake Michigan is limited
to the range of 6.5 to 9.5.
The inspectors examined the results of
pH and conductivity for the period November 1, 1979 through August 1,
1980.
No problems were identified with these determinations.
Three apparent items of noncompliance were identified.
5.
Quality Control of Analytical Measurements
The inspectors reviewed the quality control of analytical measurements
taken in the radiological environmental monitoring program.
The li-
censee's contractor participates in the U. S. Environmental Protection
- 5 -
Agency's cross check program and a similar cross check program run by
the Department of Energy.
These results appeared to be within acceptable
ranges of comparison.
The inspectors examined the various procedures for monitoring chlorine,
pH, and conductivity.
The inspectors also examined the daily logbook
of results for these analyses.
The pH meter, amperometric titrator,
and conductance meter were also examined by the inspectors.
No prob-
lems were identified concerning either the instrumentation or proce-
dures examined.
No apparent items of noncompliance or deviations were identified.
6.
Procedures
The inspectors reviewed the thirteen Health Physics Procedures related
to the environmental monitoring program.
With the exception of pro-
cedures HP 3.2 and HP 3.14, all had been reviewed by the Plant Review
Committee within the last three months.
Procedure HP 3.7, Environmental
Liquid Sampling and Analysis, references Technical Specification 3.14;
but Technical Specification 3.14 defines the limiting condition of
operation for the control room air temperature.
This is an obvious error,
and should have been identified at the time this procedure was last re-
viewed in August 1980.
Several chemistry procedures reference other
procedures by number that are either misidentified or no longer in exis-
tence, for example, procedure F 4.23B refers to procedures F 5.10 and
F 4.27 when there is no F 5.10 and F 4.27.
Procedures F 4.23, F 4.23B,
and F 5.9 do not address the problem of counting a mixed alpha-beta sample
for beta using the beta voltage plateau.
In this case, the licensee would
overestimate the amount of beta radionuclides present, as in fact he would
be counting both alpha and beta disintegrations and reporting them as beta.
These problems, discussed at the exit interview, will be corrected by the
licensee.
No apparent items of noncompliance or deviations were identified.
7.
Meteorological Monitoring Program
The meteorological program is being conducted for the licensee by Dames
and Moore.
This program consists of temperature, wind direction, wind
speed, dew point, and atmospheric stability measurements.
The meteoro-
logical system is computerized, and a terminal located in the control
room prints out reduced data every fifteen minutes.
This system also
has remote retrieval capability with a memory of approximately 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
The contractor calibrates the instrumentation every four months.
The
inspectors observed the chart recorder and terminal printout and found
all systems to be in calibration and operating satisfactorily.
No apparent items of noncompliance or deviations were noted.
- 6 -
8.
Licensee Audits
The last audit of the environmental program by the Consumers Power
corporate office wa~
1
conducted in October 1979 and is discussed in a
previous inspection- .
Administrative procedures require that an audit
of this program be conducted each year sometime between July and November.
The 1980 audit had not yet been conducted as of the time of this inspection.
9.
Management Controls
The division of responsibility for implementation of the environmental
monitoring program for the Palisades Nuclear Plant was developed in a
memo dated March 29, 1976, from W. R. Strodl to R. W. Sinderman.
This
memo defines radiological and nonradiological responsibilities for the
plant, the Environmental Activities Department, and the Operating Services
Health Physics Section of the General Office.
This memo also addresses
responsibility assignment for contract laboratory coordination, internal
audit and inspections, review of monitoring results, recording and report-
ing of monitoring results, correction of deficiencies and recording of
results of audits and reviews.
Plant management concurred to this General
Office Memorandum on April 5, 1976.
Based on the above referenced memo, the Operations Services Health
Physics Section is responsible for the coordination of the writing of
the Nonradiological Environmental Monitoring Report.
As discussed in
Paragraph 4 above, this report was not issued as required by March 31,
1980.
When this report was issued on October 23, 1980, it did not con-
tain all required information as specified in the Technical Specifications.
Reports on NPDES noncompliances during 1980 were all issued discussing
exceeding discharge limits for oil and grease, yet two of these reports
were titled "Special Radioactive Environmental Monitoring Report." The
report titled "Semi-annual Radioactivity Effluent Release January - June
1980" begins by stating the enclosed report covers the period January -
June 1979.
These all indicate a lack of management control in the Nuclear
Licensing Department.
Reports apparently are not reviewed to verify their
accuracy, nor are they reviewed to verj{y compliance with the regulatory
requirements for which the report is issued.
Paragraphs 2, 4.a, and 4.b identify several examples where plant per-
sonnel have failed to correctly document records.
Some of these records
are designed to satisfy Technical Specification requirements while others
are not required by Technical Specifications.
These are all failures to
follow internal procedures, and again indicate a lack of supervisory
review to ensure that records are documented correctly.
Some of the pro-
cedures violated specify that acceptance criteria is the satisfactory
!/ IE Report No. 50-255/79-21.
- 7 -
10.
completion of the procedure, yet they do not require anyone to verify
that the procedure has in fact been satisfactorily completed.
All of
these examples indicate a management problem with documentation of
records.
Results of Comparative Analyses
Results of comparative analyses performed on effluent samples split in
December 1979, and split, and analyzed in the Region III Measurements
Van onsite during this inspection are shown in Tables I and II, respec-
tively.
The criteria for comparing measurement results are given in
Attachment 1.
a.
Results of the 1979 Split
For 19 sample comparisons, the licensee's results yielded 18 agree-
ments or possible agreements.
The one disagreement is higher than
the NRC result and can not result in any regulatory limit being
exceeded.
In reviewing the licensee's method of quantifying
particulate activity for semiannual effluent reporting, and the
results provided by the NRC's Reference Laboratory, the inspector
determined that particulate activity is not accurately reported.
Of the total amount of particulate activity for four nuclides
identified on both the particulate filter and charcoal adsorber,
24-30% was present on the charcoal adsorber.
The licensee reports
that fraction of particulate activity on the charcoal adsorber by
assuming a collection efficiency of 90% for the particulate filter.
The licensee may have under reported up to 20% in his semiannual
report for which these results were used.
This constitutes an
a parent item of noncom liance with Technical S ecifications Section
6.9.3.1.A.2.c. 4).
In a telephone conversation on October 30, 1980,
the licensee stated that he would review state of the art filter
media available and obtain a suitable filter for the stack sampling
system.
At the exit interview, the licensee agreed to change the
1979 and 1980 reports to reflect the change in the quantity reported
by total activity, and the nuclide with the largest change.
These
changes will be made within 30 days after receipt of this report.
b.
Results of the 1980 Split
Effluent samples split during this inspection were analyzed by the
licensee and onsite in the Region III Measurements Van.
For 16
sample comparisons, the licensee's results yielded 15 agreements
or possible agreements.
One apparent disagreement, not listed on
Table II, was noted for I-131 on the charcoal adsorber.
A review
of the licensee's and RIII data and calibration curves did not
determine the cause.
The results of an analysis performed on the
adsorber by the NRC reference laboratory will also be reviewed.
If these results are inconclusive, further splits will be made or
a spiked adsorber submitted to the licensee.
The licensee's results
- 8 -
11.
are higher than Region III results and can not result in a regula-
tory limit being exceeded.
Exit Interview
The inspectors met with licensee representatives (denoted
at the conclusion of the inspection on October 24, 1980.
summarized the scope and findings of the inspection.
The
the following remarks in response to certain of the items
the inspectors:
in Paragraph 1)
The inspectors
licensee made
discussed by
a.
Acknowledged statements by the inspectors with respect to the items
of noncompliance.
(Paragraphs 4, 4.a, and 10.a)
b.
Agreed to continue to conduct gross beta counting on effluent com-
posite samples as soon as possible after collection.
(Paragraph 2)
c.
Agreed to correct those forms improperly filled out.
(Paragraph 2)
d.
Agreed to have power restored to the air sampler just east of the
plant as soon as possible to preclude a possible future item of
noncompliance.
(Paragraph 3)
e.
Agreed to complete chlorine monitoring forms to bring them into
agreement with the dates of actual chlorinations.
(Paragraph 4.b)
f.
Agreed to look into revising the procedures that specify how to
monitor beta activity from a mixed alpha beta source and the pro-
cedures with incorrect references.
(Paragraph 6).
g.
Stated in a telephone conversation on October 30, 1980, that filter
media characteristics would be studied and a suitable filter used
for the stack particulate.
h.
Agreed to update the 1979 and 1980 semiannual effluent report data
to reflect the under reporting discussed in Paragraph lOa.
This
will be completed within 30 days of the receipt of this inspection
report.
Attachments:
1.
Attachment 1, Criteria for
Comparing Analytical Measurements
2.
Table I, Confirmatory Measurements
Program Results, 4th Quarter 1979
3.
Table II, Confirmatory Measurements
Program Results, 4th Quarter 1980
- 9 -
,--
ATTACHMENT 1
CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS
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 Reference Laboratory'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 con-
sidered acceptable as the resolution decreases.
The values in the ratio
criteria may be rounded to fewer significant figures to maintain
statistical consistency with the number of significant figures reported
by the NRC Reference Laboratory, unless such rounding will result in a
narrowed category of acceptance.
The acceptance category reported will
be the narrowest into which the ratio fits for the resolution being used.
RESOLUTION
RATIO = LICENSEE VALUE/NRC REFERENCE VALUE
Possible
Possible
Agreement
Agreement "A"
Agreeable "B"
<3
No Comparison
No Comparison
No Comparison
>3 and <4
0.4
2.5
0.3
3.0
No Comparison
>4 and <8
0.5
2.0
0.4
2.5
0.3
3.0
>s and <16
0.6
1. 67
0.5
2.0
0.4
2.5
">16 and <51
0.75 -
1. 33
0.6
1. 67
0.5
2.0
>51 and <200
0.80 -
1. 25
0.75
1. 33
0.6
1. 67
>200
0.85 -
1.18
0.80
1. 25
0.75
1. 33
"A" criteria are applied to the following analyses:
Gamma spectrometry, where principal gamma energy used for identifi-
cation is greater than 250 keV.
Tritium analyses of liquid samples.
"B" criteria are applied to the following analyses:
Gamma spectrometry, where principal gamma energy used for identifi-
cation is less than 250 keV.
Sr,-89 and Sr-90 determinations.
Gross beta, where samples are counted on the same date using the
same reference nuclide *
i
TABLE I
U S NUCLEAR kEGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
CONFIRMATORY MEASUREMENTS PROGRAM
FACILITY: PALISADES
FOR THE 4 QUARTER QF 1979
-~----NRC-------
SAMPLE
I SOTOPE
RESULT
ERROR
---LICENSEF-----
R ESUL T
ERROR
9FF *GAS . XE 133
1.1E:-05
KR 85
p FILTER cs 134
1~2i::-05
8 * 0 E-0 5
cs 137
2 e2 E-04
co 58
41 8E-0 4
MN 54 .
6 * 2 E-0 4
712 E-04
ZN 65
1, 2 E-0 4
118E-05 *
co 60
2.se-03
3, OE-03
6,2E-05
PRIMARY
BETA
H 3
1*1E-01
1,0F-03
- 1.0E-01 *410E-03
co 57
SeOE-05
SB 125
3, 3E-04
4,7E-05
cs 134
cs 137
2.sE-os
6, OE-06
co *58
1, BE-0 2
2 * 1 E-0 5
MN 54
AG 110M
SeOE-05
2 * 0 E-0 5 .6,2E-06
co 60
4113E-05
- 1,BE-03
s P. 124
T TEST RESULTS:
A =AGREEMENT
D=DISAGREEMENT
P=POSSIBLE AGREEMENT
N=NO COMPARISON
L ....
I '
---NRC:LICENSEE----
RATIO
. RES
T
6*6E-01
Se5E+OO
A
110E+OO
1e2E+01
A
1*5E+OO
4113E+OO
A
114E+01
A
- 1e1E+Oo
119E.+01
A
112E+OO
2e1E+01
A
5* 8E.-01
3e3E+OO
A
1e2E+OO
310E+01
A
1e0E+OO
- e0E+01
A
9e1 E-01
1e1E+02
A
2e2E+OO
1eSE+01
p
2e4E.+00
812E+OO
D
1*5E+OO
311E+01
p
110E+OO
'313E+01
A
1e2E+OO
315E+01
A
1 * 2 E.+ 00
313E+01
A
4*0E.:.o1
S18E+OO
p
.112E+OO
3.SE+01
.A.
Li.3E+OO
A
.,
TABLE lI
U S NUCLEAR REGULATORY
COMMISSIO~
OFFICE OF INSPECTION AND ENFORCEMENT
CONFIRMATORY NEASUREMENTS PROGRAM.
F~CILITY: PALISADES
FOR
THE 4 OUARTER OF 1980
NR C-------
-- -L IC ENSF. E- -- --
---NRC:LICENSEE----
SAMPLE
I SOTOPE
RESULT
ERROR
R E~ULT
ERROR*
R~ TIO
T
L "ASTE
XE 133
7.5E-05. 2e5E-06
?.7E-05
1e0E+OO
- 3e0E+01
- A
MN 54
1*7E-04.
1.9E-06
1*9E-0 4
2 .*2 E-06
1e1E+OO
819E+01
A
FE 59
1*9E-06.
4* 8E-0 5
1e2E+OO
2 .. 1E+01
A
co 58
7,9E-04
9, 3 E-0 4
4,4E-.06
1*2E+OO
211E+02
A.
I
131
2e.4E-06
1a0E+OO
7.1E+01
A
cs 134
2 * 6 E-0 4
3e 1E-04
1a2E+OO
1.1E+02
A
cs 136
1~2E-05
1 e4E-06
- 1e3E+OO
1e1E+01
A
cs 137
1e2E+OO
1, 9E +02
A
OFF GAS
XE
131~ . 2 * OE-0 3
1*9E-03
115E+01
A
XE 133
5 e3E-03
1e2E+OO
2e4E+02
p
KR 85
SeOE-04
Se6E:...03
.4e2E-04
1e3E+01
A
cs 137
8,SE-06
2e5E+OO
3,9£+00
A
co 58
1,*sE-05
1 e3 E-05
8aOE.;..06
2e1E+OO
N
- co 60
3e0E-0.4
1.4E-05
1,4E+01
A
FILTER I 133
4 *. BE-03
-1.2E+OO
8e7E+01
A
I 135
.1.0E-04
6.8E-05
1e1E+OO
7e4E+OO
A
'TEST RESULTS:
=~. G REEMEN T
=.DI SAGREE*MENT
=POSSIBLE AGREEMENT
~=NO COMPARISON
.. __ .