ML20058A754
| ML20058A754 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 10/18/1990 |
| From: | House J, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20058A750 | List: |
| References | |
| 50-461-90-20, NUDOCS 9010290150 | |
| Download: ML20058A754 (8) | |
See also: IR 05000461/1990020
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O. S. NUCLEAR REGULATORY COMMISSION
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REGION 111
Report No. 50-461/90020(DRSS)
Docket No. 50-461
License No. NPF-62
Licensee:
Illinois Power Company
500 South 27th Street
Decatur, Il 62525
Facility Name: Clintor. Nuclear Power Station, Unit 1
Inspection At: Clinton Site, Clinton, Illinois
Inspection Conducted:
September 24-28,1990(0nsite)
October 10, 1990 (Telephone Discussion)
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Inspector:
J. E. House
/d~ P Po
Date
Y,[A'
/o/l(/Fc)
Approved By:
M. C. Schumacher, Chief
Radiological Controls and
Date
Chemistry Section
Inspection Summary
Inspection on September 24-28, 1990 (Report No. 50-461/90020(DRSS))
Areas Inspected:
Routina unannounced inspection of:
(1) the chemistry
program including procedures, organization and training (IP 84750); (2)
reactor systems water quality control' programs (IP 84750);(3) quality
assurance and quality control programs in the laboratory);(IP 84750,79701);
(4) nonradiological confirmatory measurements (IP 79701
(5) Radiological
EnvironmentalMonitoringProgram(REMP),(IP84750);and(6)pastopen
items (IP 92701).
Results:
The laboratory quality assurance program is adequate and the
results of the nonradiological confirmatory measurements were very good.
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The plant is committed to a water quality program. Chemistry parameters
are monitored by trend charts and were generally.within the EPRI BWR Owners-
Group Guidelines. The Chemistry Performance Index (CPI) was at the industry
median for all plants and was improving. The REMP was generally adequate
but a weakness was the licensee's failure to sufficiently address an open
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item involving leak testing air sampling stations. No violations or
deviations were identified.
9010290150 901019
ADOCK 05000461
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DETAILS
1.
Persons Contacted
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fJ. Bednarz, Principal Assistant, IP
3 . A. Brownell, Licensing, IP
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I'2 . Cook, Plant Manager, IP
3 . H. Daniel, Chemistry Supervisor. IP
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C. Elsasser, Director, Schedule & Outage Management,-IP
3 . Ghantous, Chemist Engineer / Specialist. IP
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3 . Greenwood, Power Supply Manager, Soyland
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S. P. Hall, Director, Nuclear Program Assessment Group, IP
K. Harper, Chemist - Nuclear IP
- 53 . Harrison, Licensing, IP
G. Kephart, Supervisor, Radiological Support, IP
5. Klein, Chemist Engineer / Specialist, IP
T. Lones, Chemist - Nuclear, IP
P. Mergen Chemistry Assistant Supervisor, IP
E3 . Millard. Environmental Technician, IP
3 . A. Miller, Manager, Nuclear Station Engineering Department. IP
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M. Niswander, Supervisor, Radiological Environmental, IP
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Otis, Chemistry Assistant Supervisor, IP
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3 . F. Palchak, Manager, Nuclear Planning & Support, IP
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)J. Sipek, Supervisor, Plant Fire Protection, IP
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A. Spangenberg, Manager, Licensing & Safety IP
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3 . Weedon, Radiological Assessor, IP
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R. E. Wyatt, Manager, Quality Assurance, IP
f P. Brochman, . Senior Resident Inspector, NRC
F. Brush, Resident Inspector, NRC
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fPresentattheExitMeetingonSeptember 28, 1990
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Present during telephone discussions on October 10, 1990
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2.
Licensee Action on previous Inspection Findinos (IP 92701)
(Closed) Open Item (50-461/88024-01):
Licensee to spike reactor water
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with anions, split samples with Brookhaven National Laboratory (BNL),
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analyze and send results to Region III.
Both the-licensee and BNL have-
completed the sample split.
The licensee does.not measure fluoride and
BNL did not report the sulfate result. The chloride results for the
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licensee (11.4 ppm) and BNL (141.6 ppm) were a disagreement but this
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discrepancy cannot be resolved as the NRC reference laboratory is no
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longer available. As the licensee performed well in the confirmatory
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measurements program and results in the Interlaboratory Comparison
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Program were good (Sections 5 and 6), this. item is closed.
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(Closed) Open Item (50-461/88024-02):
Licensee to investigate analytical-
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difficulties with the Ion Chromatograph (IC), chloride and sulfate
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analyses; the Atomic Absorption Spectrophotometer (AAS), chromium
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analysis; boron analysis by titration; and silica analysis by spectro-
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photometry.
Instrument performance has improved as evidenced by results
in the current nonradiological confirmatory measurement program (Table 1)
and in the Interlaboratory Comparison Program (Section 5).
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(Closed) Open item'(50-461/88024-03):
Licensee to improve the-
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Intralaboratory Comparison Program (technician testing) and cortrol
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charts. The inspector reviewed these programs and found them to be.
generally adequate (Section 6).
(0 pen) Open Item (50-461/88024-04):
Licensee to check fittings on
environmental air sampling stations and test entire filter train for
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leakage. The licensee's inspection- program does not test the entire air
sampling train for leakage.
Testing occurs from the quick disconnect
fitting to the pump.
The system appeared to be free of leakage as tested,-
however the filter / cartridge holders located upstream from the disconnect
fittings were not tested. Substantial leakage appeared to occur in the'
threaded fittings of this hardware.
The licensee agreed to investigate
and reduce leakage.in these holders and to test the entire filter train
for integrity.
This item will remain open pending implementation of a
testing program that includes the entire filter train and reduction of
leakage in the filter / cartridge holders.
3.
Management Controls, Organization and Training (IP 84750)
Chemistry Department organization is similar to that described in
previous inspections (Region III Inspection Reports 50-461/88024 and
50-461/89029).
All management. positions are now staffed, and these
supervisor / specialists appeared knowledgable and capable of discharging
their responsibilities. The Assistant Supervisor responsible-for
Laboratory Support and the two Chemical engineering W.;ialists reporting
to him monitor plant water system performance, maintain trend charts
of water parameters and are responsible for in-line monitors.
This.
organizational structure is a good management practice. The licensee's-
Chemistry Training Program was INPO. accredited in November 1988.
No violations or deviations were identified
4.
Water Chemistry Control Program (IP 84750)
The inspector reviewed the water chemistry control program as defined in
CPS No. 6001.01, Sampling and Analysis Requirements, Revision 10, June 5,
1990 and CPS No. 6004.01, Trending of Chemical Data, Revision 2, April 7
1988. Chemistry
Guidelines (0GG) parameters are consistant with the EPRI BWR Owners Group
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and management's responsibility in maintaining
chemistry parameters for plant water systems are defined.
Chemistry parameters are trended with a computer data base. A review of
selected records from the past year indicated that water quality was good
and water chemistry parameters were generally maintained within the EPRI
Guidelines.
Chemistry parameters are monitored daily.by chemistry
technicians, twice weekly by chemistry management for trends, and any-
abnormal values or trends are reported to plant management. The Plant-
Manager receives a daily printout of chemistry parameters. The licensee
trends the Chemistry Performance Index (CPI) as an indication of overall
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plant water quality. The CPI for 1989 was'0.41 which was an improvement
over the 1988 value of 0.55.
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In-line monitors include specific conductivity, dissolved oxygen and
sodium for feedwater, which also has a corrosion
collects metals (copper, iron, nickel. and chrome) product monitor that
.for analysis.
Specific
conductivity is measured at the hotwell.
Reactor water measurements
include dissolved oxygen and conductivity.
Other parameters are measured
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by grab semples.
In-line monitor performance is verified weekly by
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comparison with grab samples or for conductivity meters, comparison to-
a laboratory calibrated flow cell. A review of selected data indicated ~
that in-line monitors received adequate testing.
No violations or deviations were identified.
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5.
Nonradiological Confirmatory Measurements (IP 92701)
The inspector 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 regulatory and administrative requirements. . These samples
had been prepared, standardized and periodically reanalyzed (to check
for stability) for the NRC by the Radiological Sciences Division of-
3mokhaven National Laboratory (BNL).
The samples were analyzed by-the
licosee using routine methods'and equipment.
A ; ingle dilution was made for each sample by licensee personnel as
necessary to bring the concentrations within the ranges normally analyzed
by the laboratory, and run in a manner similar to that of routine samples.
The results are presented in Table 1 which also contains the criteria for
agreement. These criteria are based on BNL' analyses of the- standards and
on the relative standard deviations (RSD) derived from the results of the
plants partici
NUREG/CR-5422)pating in the 1986 interlaboratory comparisons (Table 2.1-
The acceptance criteria were that the-licensee's value
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should be within 2 Standard Deviations (SD) of the BNL value for agreement
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and between 2 and 3 SD for qualified agreement. A qualified agreement may
indicate a deficiency in the assay.
The licensee determined 8 analytes at three concentrations each.
Of the
initial 24 analyses, 20 were agreements, 3 were qualified agreements and-
one, low level silica, was a disagreement (Table 1). The licensee reran
those assays that were qualified agreements and those results became
agreements. A new calibration curve was prepared for silica, the. unknown
rerun and the result was also an agreement.
The licencee's results were good, with only.a few assays exhibiting
biases. The inspector reviewed a problem concerning the silica assay
with licensee. representatives. The silica calibration curve is a
multipoint plot of absorbance versus concentration ~from which the .
independent control concentration is read. This concentration value'
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is used by the instrument microprocessor to generate a two point
(including zero)' calibration curve, which is henceforth used by the
instrument.to determine the concentration of unknown samples. This
results in the instrument being calibrated from the control instead
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of the calibration standards.
Licensee representatives agreed to review
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this procedure and to input the calibration curve into the instrument's
microprocessor or read the unknown concentration from the calibration
Curve.
The inspector discussed instrument calibration, preparation of standards
and dilution errors, which can result in biases, with licensee
representatives,
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No violations or deviations were identified.
6.
Implementation of the Chemistry QA/QC Program (IP 84750)
The inspector reviewed the QA/QC program for nonradiological chemistry as
defined by Station Operating Manual CPS No. 6000.01, Quality of Chemistry
Activities, Revision 9. May 4,-1990; and Station Operating Manual CPS No.
1931.01, Chemistry Group Organization and Responsibilities, Revision 4,
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April 25, 1989.
Part of the licensee's QA program includes multiple point
calibration curves and independent controls whose values are manually
plotted on control charts. Percent recovery of the control is plotted with
warning and control limits set at 2 and 3 SD. A review of selected control
charts did not indicate any significant biases.
Chemical technicians
appeared knowledgable about plotting and monitoring control charts. . Many
of the charts were statistically based, however analyses performed on the-
lon Chromatograph (anions) have administrative limits set at 5% for one SD.
Licensee representatives stated that this was done to reduce the size of-
the standard deviation-and improve performance.- Calibration of this
. instrument is performed weekly unless required more frequently by results
of the independent control.
The licensee has a vendor supplied interlaboratory comparison program. A
review of selected data from the past two years indicated that performance
was good with very few biases in the results.
The inspector discussed the
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addition of acceptance criteria with a licensee representative. -This
program appeared to be functioning well and will be reviewed in future
inspections.
The licensee's intralaboratory testing program is part of the inter-
laboratory program in which technicians analyze vendoi prepared
unknowns.
The inspector noted to licensee representatives that there
were no acceptance criteria for this program and that i+. needs more
specific documentation.
Licensee representatives agreea.to review this
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program., add acceptance criteria and to improve the procedure for this
progrr.n. A review of selected records indicated that-technicians were
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bein:, tested in accordance with requirements.
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The inspector reviewed selected data from 1989 and 1990 for the Standby
Liquid Control System (boron) for compliance with Technical Specification
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4.1.5. These results indicated that temperature, concentration and volume
of the boron solution was within prescribed limits.
No violations or deviations were identified.
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7.
Audits and Appraisals (IP'84750)
The inspector reviewed the most recent internal quality assurance audit
of the chemistry program. Q38-90-10, conducted April 10-30. 1990 as
required by Technical Specification 6.5.2.8.
From a review of QA/QC
documents and discussions with licensee representatives, audit team
appeared to address in adequate detail the chemistry QA/QC program.
The report contained no findings and three recommendations which were
oddressed by chemistry management.
No violations or deviations were identified.
8.
Radiological Environmental Monitoring Program (REMP)(IP 84750)
The inspector reviewed the REMP, including the 1989 Annual Environmental
Report and air sampling sations. The Annual Environmental Report
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appeared to comply with the REMP requirements. All of the required
samples were collected and analyzed, except as noted in the report.
The inspector toured the air sampling stations around the plant and
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observed a licensee representative change out air' particulate filters,
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charcoal cartridges and test the sample train for inleakage. The method
used for testing the sample train did not appear to be adequate as the
filter holder was not tested and appeared to be a source of inleakage.
An Open Item from the previous inspection (Section 2d) is being left
open pending resolution of this matter.
9.
Open Items
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Open Items are matters which have been discussd with the licensee, which
will be reviewed further by the inspector, and which-involve some action
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on the part of the NRC or licensee, or both,
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10. Exit Interview
The scope and findings of the inspection were reviewed with licensee
representatives (Section 1) at the conclusion of the inspection on
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September 24-28, 1990.
The inspector discussed Open Items in Section 2,
observations of the chemistry QA/QC programs, plant water. chemistry,
results of the nonradiological confirmatory measurements program and the
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REMP including deficiencies in the air sampler monitoring program.
The
inspector discussed the likely informational content of the inspection
report regarding documents and processes reviewed by the inspectors during
the inspection.
The licensee did not identify any such documents or
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processes as proprietary.
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Attachment: Table 1 Nonradiological Interlaboratory
Comparison Results, September 24-28, 1990
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TABLE 1
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Nonradiological Interlaboratory Test Results
Clinton Nuclear Power Station
September 24-28, 1990
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Analyte
Method
Conc -
Ratio
Acceptance Ranges
Result
1 2sd
1 3sd
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Chloride A
5
0.933
0.933-1.067
0.900-1.100
A-
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B
10
0.926
0.919-1.081
0.887-1.113
A-
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C
15
0.998
0.926-1.074
0.895-1.105
A-
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Rerun
A
5
1.037
0.933-1.067
0.900-1.100
A
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Sulfate
A
4
1.032
0.895-1.105
0.842-1.158
A
B
6
1.045
0.895-1.105
0.868-1.132
A
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C
10
1.045
0.900-1.100
0.867-1.133
A
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G
AA/FL
1000
0.980
0.904-1.096
0 854-1,146
A
H
2000
0.860
0.903-1.097
0.857-1.143
A+
1
3000
0.980
0.903-1.097
0.855-1.145
A
Rerun
H
2000
1.020
0.903-1.097
0.857-1.143
A
G
AA/FL
1000
1.035
0.904-1.095
0.859-1.141
A
H
2000
1.007-
0.904-1.096
0.857-1.143
A
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1
3000
1.025
0.904-1.096
0.857-1.143
A
G
AA/FL
1000
1.025
0.936-1.064
0.006-1.094
A
H
2000
0.943
0.938-1.062
0.908-1.092
A
1
3000
0.911
0.938-1.062
0.907-1.093
A+
1
3000
0.977
0.938-1.062
0.907-1.093
A
Chromium G
AA/FL
1000
0.965
0.905-1.095
0.855-1.145
A
H
2000
0.951
0.903-1.097
0.854-1.146
A
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1
3000
0.985
0.903-1.097
0.853-1.147
A
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Silica
S
Spec
50
1.163
0.906-1.094
0.859-1.141
D
T
100
1.018
0.909-1.091
0.860-1.136
A
U
150
0.925
0.907-1.093
0.857-1.143
'A
Rerun
S
50
0.979
0.906-1.094
0.859-1.141
A
D
Titr
1000
-1.008
0.979-1.021
0.968-1.032
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E
3000
0.997
0.979-1.021.
0.968-1.032
A
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F
5000
0.976
0.979-1.021- 0.968-1.032
A+
F
5000
1.011
0.979-1.021
0.968-1.032
A
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Methods: Titr - Titration
- lon Chromatography
Spec - Spectrophotometry
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AA/FL - Atomic absorption spectrophotometry
(flame)
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Cone: Approxin. ate concentration analyzed.
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Ratio of Licensee mean value to NRf mean value.
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The SD in the fif th and sixth columns represents the cotfficient of.
variation obtained from averag244).ir.g licensee data from the preceding
cycle (Table 2.1 of NUREG/CR-s
The licensee value is considered
to be in agreenent if it falls within the 4 2 SD range; a qualified
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agreenent if it lies outside 4 2 SD but wiIhin + 3 SD; and in
disagreement if it is outside~the 13 SD range.~
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Result:
A = Agreement: Licensee value is within i 2 SDs of the NRC mean
value.
A+ = Qualified agreement: licensee is between i 2 and 1 3 SDs of-
the NRC value.
D = Disagreenent: licensee value is outside 1 3 SDs.
6.
Boronresultsareinpartspermillion(ppm).
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