ML20128A518
| ML20128A518 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 05/20/1985 |
| From: | Holtzman R, Januska A, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20128A471 | List: |
| References | |
| 50-483-85-09, 50-483-85-9, NUDOCS 8505240246 | |
| Download: ML20128A518 (11) | |
See also: IR 05000429/2005003
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.U._ S. NUCLEAR REGULATORY. COMISSION
REGION III
Report No. 50-483/85009(DRSS)
Docket No. 50-483
License No. NPF-30
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' Licensee: ' Union Electric Company.
Post Office Box 149.
St. Louis, MO 63166
Facility Name:
Callaway Plant, Unit 1
Inspection At:
Callaway_ Site, Reform, MO-
Inspection Conducted: April 29-May 3, 1985
kb.$inuskaaw]w
A. G.
Mo!84'
Inspectors:
Date
R.&
R. B. Holtzm
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o/d'(
Daty
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Approved By:
M. C. ' Schumacher, Chief
Independent _ Measurements and
Date
Environmental Protection Section
Inspection Summary
Inspection on April 29-May 3, 1985 (Report No.- 50-483/85009[DRSS])
Areas Inspected:
Routine, announced inspection of radiological environmental-
protection including program management, quality control and implementation;
and confirmatory measurements including sampling, laboratory quality control
-and comparison of licensee analyses with those performed in the Region III
Mobile Laboratory.
The inspection involved 72 inspector-hours onsite by.two
NRC-inspectors.
Results:
No items of. noncompliance or deviations were identified.
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8505240246 850520
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" ' DETAILS-
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Per' sons Contacted-
. S.:Miltenberger . Pla"nt Manager
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.*C;:Riggs - Supervisor, Primary Chemistry
- S."Growcock;- Q.A.' Scientist
- D.~Epperson
.Q.A. Scientist
- - R. Wink - Compliance Engineer .
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- . 8. Holderness - Health Physicist-
- C. Graham - Health Physicist-
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. R. Roselius - Supervisor, Health Physics Technical Support
- W; Norton' -Q.A.-Engineer.
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- G. Randolph - Assistant Manager, Technical Services
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L D. Stretch - Chemist, Primary
.R. Kelley - RadChem Technician
- Denotes 1those present at' exit interview.
2.
. Radiological Environmental Monitorina Program (REMP)
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a.
Plan and Implementation
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- The
- REMP is defined:in Table 3.12-1 of the Technical Specifications
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l(T/S).
It_is conducted by personnel under the Cal _laway Plant Manager
and the Manager of Environmental Services and coordinated by a Health
- Physicist under the Manager of Nuclear Engineering, also under the'
Plant Manager.
The Health Physicist coordinates the site and
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corporate sample collection, and analyses are_done by Controls for'
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. Environmental Pollution, Inc.:(CEP), the licensee's environmental
contractor. : A review of the program conducted since October 1984
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.(initial criticality) revealed that it meets or exceeds T/S require-
ments.
At this time there are no drinking water intakes within
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10 miles downstream of the discharge point and no available milk
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satisfying technical. specification requirements.
The licensee,.
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.however, does sample milk from available sources at-3.1 miles-
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northwest and 12.3 miles west southwest.
In addition, the licensee
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.is sampling broad leaf. vegetation as required by the T/S when milk
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sampling is not performed. Milk sampling will be revised as
necessary in accordance with the annual land use census.
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The inspector noted minor disagreements between the' detection limits-
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- quoted in several tables of the Annual Environmental Operating Report-
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'and the values in the T/S Table 4.12-1.
Prior to the close of the
inspection the licensee contacted CEP and verified that correct
detection limits had been used and the disagreements in the report
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were typographical in_ nature.
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? Audits-
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- The. inspector reviewed Audit Report No. 51005-84-07 conducted on ,
-July 9 and 10,.1984, of CEP.._ The audit to ascertain the continued
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technical'and quality acceptability of the' contractor as'an
- analytical;1aboratory for environmental and chemical' analysis consisted
.of twenty-one-audit checklist items with no' findings or observations.
Audit Report No'._ ADSA84080, conducted August 31 through September.14,
- 1984 to verify that the existing and developing environmental
. monitoring procedures meet UE's environmental program and that the
Jprogram and procedures.were being implemented, was also reviewed.
.
-Of the checklist-items that dealt with the radiologica1' portions of
the program, one minor. programmatic deficiency was. identified and
one recommendation was made for programmatic enhancement.
3.
Confirmatory Measurements
-Six samples -(an air particulate filter, a charcoal filter, recirculating
swater, primary coolant, gas stripped from primary coolant and a charcoal
,
spike).were analyzed'for gamma emitting isotopes by the licensee and by
the inspectors'using the Region III mobile laboratory.
Results of the
sample comparisons are listed in Table 1 and the comparison criteria are
given in Attachment 1.
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A unit. vent air particulate sample was counted to verify the ifcensee's
statement that no particulate activity was being discharged. The inspector
.also verified that the count time used_is sufficient to achieve the lower
limits of detection values contained in T/S Table 4.11-2.
A containment air particulate. sample was counted and resulted in only one
available nuclide for comparison, Co-58.-
In' order to compare more energies,
- a short particulate sample collected from gas decay tank #2 was counted
- and yielded agreements for twol additional nuclides, Cs-138 and Rb-88.
A containment charcoal sample yielded only one line, I-131, and the
licensee and the inspectors counted a spiked charcoal adsorber which
resulted in all agreements.
,A reactor water storage tank (RWST) sample split and counted with the
licensee yielded five. agreements.
These comparisons were made even
though the liquid concentrations were all-less.than 10% of applicable -
10 CFR 20 Appendix-B-limits.
The confirmatory measurements program does
.not require that concentrations at these levels be compared, but these
y agreements further demonstrate. accurate calibrations.
' A gasidecayitank sample collected could not-be counted because of the
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- high concentration of activity and therefore the stripped gas from a
reactor coolant sample was used for this comparison.
All eight nuclides
yielded comparisons.
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LAn_ unfiltered reactor coolant sample was split.
Comparison between the
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~ licensee's 20-m1 geometry used for coolant samples and the NRC geometry
' initially yielded 10 disagreements.
It appeared.that the disagreements
.for the.mostipart were' associated with high backgrounds in the energy-
area of concern. To-verify if this was correct or if _the split was the
. reason for'the. disagreements, .the NRC portion of the split was transferred
to another bottle to eliminate plate out, recounted and given to the
licensee to. count in his one-liter Marine 111' geometry.' Concurrently, the
licensee resampled and' counted low and high activity samples in the 20-m1
geometry and also a low activity sample'in a one' liter Marine 111' beaker.
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-The licensee's results between the_ low and high 20 m1 geometry and Marinelli
were consistent for~nuclides between 364 and 1369 kev ~and the comparison
between the licensee and NRC for.the recount of the initial sample gave.
'10 out.of 11 agreements.
The investigation indicated that the initial-
disagreements were due to nonhomogeneity'of the samples. The remaining
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disagreement, Co-58, appears to reflect a difference in plate out effects
forfactivation (crud) products for the two geometries used for this comparison.
The inspector's. review of the licensee's detector.' efficiency curve for his
geometry did not, reveal any anomalous results around the 810 kev Co-58
-energy. peak.
The inspectors have no further questions regarding this
disagreement.
The licensee agreed to count a portion of the RWST sample for gross p,
H-3,'Sr-89 and Sr-90 and report the results to Region III (0 pen Item
50-483/85009-01).-
4.
Primary ~ Chemistry and Radiochemistry Programs'
a.
Management Controls and Organization
The inspectors reviewed the management controls and organization of
the Chemistry Group.
This group is under the Superintendent, Chemistry
_
who supervises the subgroup's Primary Chemistry and Secondary
Chemistry (not reviewed), each'with a supervisor, a chemist, two
foremen, and eight to ten Radiation / Chemistry Technicians (RCTs).
The radiochemistry work'is done in the hot laboratory of the _ Primary
Chemistry subgroup. The samples are counted in the counting room,-
which is under the direction of the Health Physics Group.
The
Counting Room Supervisor reports to the Supervisor of. Health Physics,
Technical Support who, in turn, is responsible to the Superintendent,
~ Health Physics.
The RCTs under Health Physics do the counting and
maintenance of this facility. -The RCTs of both the chemistry and
counting facility are permanently assigned to their respective
groups.
The cooperation between these two groups appears to be
excellent.
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No problems were identified with this organization.
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'QA-Audits for Chemistry and Radiochemistry
LTheLinspectors reviewe'dlthe QA audits' performed by the licensee on
thechemistryandradiochemistry' programs. - Two extensive audits,
both titled ' Quality- Assurance of the Nuclear Operation Chemistry .
Programs ~," No. ADA8403A,. April ~12, 1984, 0QA-0044, and No. ADSA84108,
November 20,_1984, reviewed 29 and'61 items, respective 1y'. . The
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. checklists referred to such items as compliance with the Technical
Specifications, instrument and laboratory maintenance, laboratory .
QC, and RCT qualifications and training.
The auditors found three
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minor problems-in'each of the audits, such as several bottles of
chemicals and reagents.with expired _ labels, an uncalibrated
conductivity bridge, and an'RCT missing one step in an_ analysis.
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The audit concluded that, overall, the-program was operating well.
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- In addition, there were ll." Surveillance Reports" (essentially
-audits' covering a . single item), most of which were on safety-related
problems, such as analysis of boron in various systems, tests on
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~ diesel fuel, and the determination of various-RCS water parameters,
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e.g., the concentrations-of chloride and dissolved oxygen.
..The program' appeared to be very good and no problems were identified
in this area.
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. Training and Qualifications.
The Superintendent, Chemistry and Supervisors, Primary and Secondary
Chemistry appear to be well qualified.
The Superintendent has a
. Bachelor of Science degree, and he has been a chemist at Callaway
since 1979. . He has taken graduate training in nuclear reactor
engineering and related courses, and a vendor PWR chemist course.
While he lacks the one year experience at an operating nuclear power
plant, as required by' ANSI /ANS 3.1-1978, this requirement, in~ accord
with the FSAR,.may be waived because of the experience of the Super-
visor, Primary Chemistry, who has a Master of Arts in Radiochemistry
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and two to three years of experience at the University of Missouri
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research reactor.
This substitution was addressed in a previous
report-(Inspection Report No.- 50-483/82-08). The Supervisor,
Secondary Chemistry has a Bachelor of Chemical Engineering and
experience and training in nuclear power reactor chemistry.
The
others associated with the chemistry group, the chemists and health
physicist-counting room supervisor, the foremen, and RCTs, appear to
be highly qualified in conformance with the T/S. The RCTs in the
Primary group all had Navy ELT experience.
- No. problems were identified in this area.
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L d.- - ! Implementation of the Primary Chemistry and Radiochemistry Programs ~
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,;The: inspectors reviewed the Primary: Chemistry and radiochemistry.:
~ programs, including -the physical' facilities, laboratory operation
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? procedures,. and QC/QA practices in the-~1aboratory.
(The Secondary
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Chemistry program was not reviewed.);
The. hot,l'aboratory is large and roomy, is well organized and properly
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ventilated.
0verall, the laboratory appeared to be run efficiently,
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'the furniture and-instruments are well p1 aced,.the fume hood'and bench
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- spaces are adequate, and the housekeeping was good.
The laboratory
chas a convenient access to the reactor building, but the offices of
the supervisory: staff and chemists were in trailers outside of and
some distance from:the building.
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.The counting room, next to the hot laboratory, was also good, well
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. organized,androomy.
However, the temperature of less than about
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65 F,was uncomfortable for the operating personnel. _ Radiological
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control of.the' units for both the laboratory and the counting room
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consisted of a G-M s'urvey meter (frisker) in the hall at the common
exit to the two rooms.
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'The chemical apparatus was of-generally high' quality, well-maintained,
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and,:where applicable, had calibration stickers.
Each instrument had
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a logbook containing calibration, QC, and maintenance data.
The QC
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. data and charts were not examined in detail', but they appeared to be
properly designed and maintained.
No: chemical. or reagent bottles
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7 appeared to have~ passed their posted expiration dates.
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The inspectors observed operation of some sophisticated instrumenta-
tion used routinely by the RCTs, the determination by atomic absortion
spectrophotometry (AAS) of-lithium concentrations at the 2 ppm level
in Reactor coolant system (RCS) water, and the determination, using
a Dionex Ion Chromatograph, of chloride, sulfate and boron concentra-
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tions in the RCS water. The RCT was quite knowledgeable about-these
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analyses, and he referred often to the relevant procedures:
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-(1) for lithium' analysis:
CTP-ZZ-04010, " Operation of the flame
atomic absorption spectrophotometer", February 21, 1985, Rev. 2,
and CTP-ZZ-02011, " Determination of trace metals (Parameters
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for atomic absorption spectrophotometer operation)", February 22,
~1985, Rev. 4; and-
(2)'-for chloride, sulfate, and-boron:
CTP-ZZ-02050, " Determination
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of anion concentration by ion chromatography method using the
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3390A Integrator", October 4, 1984, Rev. 2.
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The detection level for chloride' appeared to be quite low, about
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5 ppb, compared to about 20 ppb, usually quoted for specific ion
electrodes. 'This improved limit may eventually be significant in
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tracking the effects of corrosion by chloride below the 20 ppb level.
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This analysis may also be applicable to sulfate, which has also been
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implicated in intergranular stress corrosion cracking (IGSCC).
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The radiochemistry instrumentation was of.high quality'and highly
computerized. The laboratory had four Ge detectors operated by a.
~ Nuclear Data N06685 multichannel-ar.alyzer system, a Beckman LS3801
liquid _ scintillation counter.with an automatic sample changer,.a
.Tennelec' Automatic Low Background Alpha / Beta Counting System
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LB5100 Series'II, and several Ludlum alpha and beta counters.
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This' room also had'an SAI Reactor Coolant:and Containment Atmospheric
Sampling and Analysis System.
-One inspector' reviewed the extensive QC/QA program in place in the
counting facility.
The general statistical methods were described-
in'a Health Physics Technical Procedure, HTP-ZZ-06016, " Statistical
Calculations and Methods,'.' August 28, 1984, Rev. 1.
Each instrument.
had control charts with upper and lower investigation limits (UIL and
LIL) at the two-standard deviation (SD) level, and control limits
(UCL and LCL) at the three-SD 1evel.
These limits were calculated
-from-data acquired the previous month.
The limits appeared, in
general, to be too wide, i.e. too few points were at, or over the
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etwo-SD Ifmits (substantially fewer than 1 in 20).
Calculations for
several of the charts examined had faulty-input data,_and a
" theoretical" SD-(statistical counting error) was incorrectly
- calculated,'i.e. it wa's based on' count rates, rather than on total
counts. The latter problem was not serious, because the theoretical
SDs are given, but not'used.
However, if properly calculated these
values could be used to check instrumental operation.
The' licensee
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agreed to correct these problems by the next inspection (0 pen Item
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No. 50-483/85009-02).
The'QC/QA program for-the Ge detectors was handled by a Nuclear Data
program that calculated and plotted several parameters (centroid,.
efficiency and resolution of_ the 122- and 1836-kev gamma peaks) from
check sources counted daily.
The program calculates limits.and flags
- out-of-limit data.
It may also provide plots of the data (control
charts).
The inspectors observed two RCTs collecting samples from a radwaste
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storage tank, a particulate filter, an iodine cartridge, and a gas
sample. They followed a procedure and the more experienced RCT, who
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was training the other, was quite knowledgeable of the procedure
(CTP-ZZ-01114, " Sampling of primary and radwaste bomb sample _ points,"
December 27, 1984, Rev. 3).
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The primary chemistry / radiochemistry program, overall, appeared to be
very good.
The procedures provide good bases for laboratory and plant
operation, the staff and RCTs have very good training and experience,
and they appear to be enthusiastic in their work.
The QC/QA programs
of both management and of the laboratory are excellent, with good
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records on the instrumentation. The program is further enhanced by
having the RCTs assigned full time either to chemistry, or to the
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counting facility.
The inspectors believe that the formal QC program
and their extensive experience lends credence to the accuracy of the
results presented.
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No problems,. other..than.that of poor data entry,- were. identified in '
Lthe implementation of~this program.
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l Exit Interview
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The. inspectors met with-licensee representatives (denoted in Section 1)
at the conclusion of theLinspection. :The scope and findings were-
summarize'd. .The licensee agreed to:
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count a liquid sampleLfor' gross beta, H-3, Sr-89 and Sr-90, and
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report the results to Region III (0 pen ~ Item No. 483/85009-01);
exercise more care in data entries.for the control charts of the
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' laboratory equipment QC program (0 pen Item No. 483/85009-02).
. Attachment's:
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.1. -
Table 1,- Confirmatory Measurements
Program Results, 2nd Quarter 1985
2. .
Attachment 1,-Criteria for Comparing
Analytical Measurements
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TABLE 1
U S NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
'
C NFIRMATORY MEASUREMENTS PROGRAM
FACILITY: CALLAVAY
FOR THE 2 QUARTER OF 1985
NRC-------
LICENSEE-
LICENSEE:NRC----
SAMPLE
ISOTOPE RESULT
ERROR
RESULT
-ERROR
RATIO
T
L: WASTE
1.8E-07
4.5E-08
2.5E-07
4.4E-08
1.4E 00
4.0E 00
A
,
8.3E-08
2.3E-08
8.3E-08
1.0E-08
1.0E 00, 3.6E 00
A
CO-58'
2.4E-06
6.6E-08
2.2E-06
5.4E-08
8.8E-01
3.7E 01
A
9.9E-08
2.7E-08
6.3E-08L 1.1E-08
6.4E-01
3.7E 00
A
NB-95
6.3E-08
2.0E-08
6.3E-08
1.1E-08
1.0E 00- 3.1E 00
A
C FILTER I-131
5.2E-12
2.3E-13
4.5E-12
1.2E-13
8.7E-01
2.2E 01
A
P FILTER CO-58
1.4E-13
2.4E-14
1.2E-13
2.1E-14
8.9E-01
5.9E'00
A
CS-138 -1.1E-02
6.7E-04
1.1E-02' 6.2E-04
1.0E 00
1.6E 01
A
RB-88
8.2E-01
1.3E-02
9.6E-01
8.3E-03
1.2E 00
6.5E 01
A-
OFF GAS
KR-85M
3.6E-03
7.1E-05
4.2E-03
3.9E-05
1.2E 00
5.1E 01
A
KR-87
7.'4E-03
2.1E-04
7.7E-03
1.1E-04
1.0E 00
3.5E 01
'A
KR-88
9.4E-03
2.5E-04
9.5E-03
1.3E-04
1.0E 00
3.7E 01
A
-XE-133
8.9E-02
4.3E-04
9.5E-02
2.2E-04
1.1E 00
2.1E 02
A
XE-133M 2.2E-03
3.9E-04
2.0E-03
1.9E-04
9.3E-01
5.6E 00
A
XE-135
1.BE-02
1.6E-04
2.0E-02
8.1E-05
1.1E 00
1.1E 02
A
XE-135M 7.1E-03
4.1E-04
6.3E-03
2.1E-04
8.8E-01
1.8E 01
A
2.4E-02
1.0E-03
2.4E-02
6.0E-04
1.0E 00
2.3E 01
A
PRIMARY
NA -24
1.1E-02
3.4E-04
1.1E-02- 2.6E-04
1.0E 00
3.2E 01
A
CR-51
5.2E-03
8.3E-04
4.4E-03
2.9E-04
8.4E-01
6.3E 00
A
2.7E-04- 3.8E-05
2.6E-04
2.7E-05
9.7E-01
7.1E 00
A
CO-58
1.2E-02
1.8E-04
9.3E-03
1.1E-04
7.5E-01
6.6E 01
D
2.8E-04
3.6E-05
2.9E-04
3.0E-05
1.0E 00
7.9E 00
A
5.8E-04
5.8E-05
5.0E-04
3.6E-05
8.6E-01
1.0E 01
A
I-133
5.1E-03
1.6E-04
5.1E-03
1.2E-04
1.0E 00
3.2E 01
A
ZR-95
8.1E-04
7.1E-05
6.6E-04
5.6E-04
8.1E-01
1.1E 01
A
NS-95
9.3E-04
5.9E-05
8.3E-04
3.9E-05
8.9E-01
1.6E 01
A
TC-99M
3.3E-04
4.0E-05
4.5E-04
2.9E-05
1.4E 00
8.3E 00
A
2.9E-04
5.5E-05
1.9E-04
3.1E-05
6.6E-01
5.3E 00
A
.T TEST RESULTS:
- A: AGREEMENT
D: DISAGREEMENT
otCRITERIA RELAXED
N:NO COMPARISON
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TABLE 1
U S NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
-CONFIRMATORY MEASUREMENTS PROGRAM
FACILITY: CALLAWAY
FOR THE 2 QUARTER OF 1985
=-NRC-------
LICENSEE----
LICENSEE:NRC----
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SAMPLE
ISOTOPE RESULT
ERROR
RESULT
ERROR
RATIO
T
C SPIKED CO-57
2.3E-03
9.7E-05-
2.1E-03
4.5E-05
8.7E-01
2.4E 01
A
5.7E-03
3.2E-04
5.5E-03
1.8E-04
9.7E-01
1.8E 01
A
HG-203
2.1E-03- 1.2E-04
2.1E-03
6.2E-05
1.0E 00
.1.8E 01
A
Y-88
5.7E-03
3.4E-04
6.9E-03
2.2E-04
1.2E 00
1.7E 01
A
1.1E-01 :3.0E-03
1.2E-01
1.8E-03
1.1E 00
3.6E~01
A
SN-113
4.4E-03
2.0E-04
4.7E-03
1.2E-04
1.1E 00
2.2E 01
A
6.~2E-03
2.4E-04
5.4E-03
1.3E-04
8.7E-01
2.5E 01
A
'CE-139
2.4E-03
9.0E-05
2.4E-03
5.3E-05
1.0E 00
2.7E 01
A
T TEST RESULTS:
AnAGREEMENT
' D: DISAGREEMENT
ocCRITERIA RELAXED
~ N:NO COMPARISON
m-
'
,.f..
-
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 com-
2 parison 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 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.
'+,
.
RESOLUTION
RATIO = LICENSEE VALUE/NRC REFERENCE VALUE
Agreement
.
<3
No Comparison
,
23 and
<4
0.4
2.5
-
_4
and
<8
0.5
2.0
>
-
2p and
<16
0.6
l'.67
-
J.,16 ' and
<51
0.75 - 1.33
251 and
<200
0.80 - 1.25
2200
0.85 - 1.18
i
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.
.