IR 05000261/1991008

Insp Rept 50-261/91-08 on 910311-15.No Violations Noted. Major Areas Inspected:Meteorological Monitoring,Confirmatory Measurements,Training & Qualifications,Primary & Secondary Sys Chemistry & Radioactive Gaseous Effluent Treatment Sys

ML20138F766
Person / Time
Site:	Robinson
Issue date:	04/12/1991
From:	Decker T, Seymour D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20138F760	List: IR 05000261/1991008 ML20138F753
References
50-261-91-08, 50-261-91-8, NUDOCS 9610180059
Download: ML20138F766 (15)

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• * UNITED STATES

[prisp 'o NUCUEAR REGULATORY COMMISSION y' ", REGION il

,j 101 MARIETTA STREET. $ ATLANT A, oEORGI A 3o323

h "\ *****,/ bfA121991 Report No.: 50-261/91-08 Licensee: Carolina Power and Light Company (CP&L)

P. O. Box 1551 Raleigh, NC 27602 Docket No.: 50-261 License No.: DPR-23 Facility Name: H. B. Robinson

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Inspection Conducted: March 11-15, 1991 Inspector: .

de # h/M7/

Date Signed D. A. Seymo [

Approved by: M e///z/W Date Signed T. R. Decker, Chief

Radiological Effluents and Chemistry Section Radiological Protection and Emergency Preparedness Branch y Division of Radiation Safety and Safeguards SUMMARY d'

Scope:

This routine, unannounced inspection was conducted in the areas of meteorological monitoring, confirmatory measurements, training and. qualifications, primary and secondary system chemistry, radioactive gaseous effluent treatment systems, the radiation monitoring system, and solid radwaste management and transportatio Results:

The portions of the meteorological monitoring program that were reviewed met regulatory requirements (paragraph 2).

The licensee was in agreement with accepted NRC values for the sampos they received as part of the Confirmatory Heasurement Program (paragraph 3).

A review of records indicated that the control room filter system .

had been adequately tested in accordance with Technical Specification requirements and that acceptance, criteria had been met (paragraph 5).

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9610180059 DR 910412 -

ADOCK 05000261 PDR

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Liquid and gaseous raffluents were within the concentrations permitted by 10 CFR 20, Appendix B. Radiation doses were well within the limits allowed by 40 CFR 190 and 10 CFR 20.105(c).

There were no upplanned or abnormal releases dttring 1990 (paragraph 6).

The training and qualifications of the person assuming the position of manager of Environmental and Radiation Control met the requirements for this position (paragraph 8).

The licensee had recently completed an upgrade of their Radiation Monitoring System, improving the reliability and operability of this system. The actions of the team that was formed to plan and implement this upgrade was a licensee strength (paragraph 9). l Based on a selective review of portions of the program, it was determined that the Solid Radwaste Management and Transportation Program was adequately implemented (paragraph 10).

Reactor Coolant System chemistry and secondary system chemistry .

I parameters were maintained well below Technical Specification and administrative limits The programs for controlling these pakameters were effectively managed (paragraph 11).

In the areas inspected, violations or deviations were not identifie r' l L

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l l Persons Contacted Licensee Employees .

• • • B. A. Christensen, Foreman, Environmental and Chemistry (E&C)

• • • R. D. Cro)k, Senior Specialist, Requlatory Compliance i ***J. M. Curley, Manager, Environmental and Radiation Control (E&RC)

• C. R. Dietz, Manager, Robinson Nuclear. Power Division l

• • W. D. Dorman, Manager, Nuclear Assessment Department l

• • • J. A. Eaddy, Jr. , Manager, E&RC Support

• • J. M. Griffon, Technician, E&C

• • R. R. Hitch, Specialist E&RC-

• • • J. D. Kloosterman, Manager, Regulatory Compliance

• • • J. A. Padgett, Manager, E&RC

! ***J. J. Sheppard, Plant General Manager -

l- ** D. C. Stadler, Onsite Licensing Engineer

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• A. R. Wallace, Manager, Operations Coordinator l

• • H. J. Young, Manager, Quality Control Other licensee employees contacted during this inspection included

! engineers, mechanics, technicians, and administrative personne NRC Resident Inspectors

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• • • K. Jury, Resident Inspector

• • L. Garner, Senior Resident Inspector

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• Attended entrance interview g,

• • Attended exit interview

• • • Attended entrance and exit interview ,

Acronyms and Initialisms used throughout this' report are listed in the i

1ast paragrap . Meteorological Monitoring Program (84750),

The information obtained from the Meteorological Moaitoring Program is -

integral to the determination of off-site dose projections. The inspector

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l reviewed the Mateorological Monitoring Program at Robinso This review included direct observation, discussions with the licensee, and the review of records. The inspector determined that Robinson had one 300 foot tall meteorological tower. This tower had two' sets of instrumentation located at either the 33 or 206 foot levels. Wind speed, wind direction, wind variance, dew point, and differential temperature wara measured f

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- and barometric pressure instrumentation were also located near ground level or inside the equipment enclosure.' The location of the tower was such that there would be no interference'with the flow of ai The inspector verified by direct observattu,Jand by records review that l the meteorological monitoring instrumentation ~ channels were operable and l

! maintained. The inspector reviewed selected portions of meteorological monitoring instrumentation channel calibration' records and procedures for the time period of October 1990 to February 1991.' These calibrations included the following instruments: wind speed and direction monitoring systems, the ambient temperature and differential temperature monitoring system, barometric pressure, and solar radiation instrumentatio The inspector determined, through conversations with the licensee, that Robinson plant personnel made a weekly visit to the monitoring station to verify component operability. The calibration of the various ,

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meteorological instrumentation sensors were performed by personnel from

. the Meteorology Unit from CP&L's corporate office. : Personnel from this unit perform six, twelve, and eighteen week interin verifications, and semiannual and annual calibrations. The semiannual and annual calibrations included the change out of many of the monitoring systems (i.e. wind and temperature systems, etc.).

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Based on the scope of this review, the inspector determined that the 4 Meteorological Measurement System was capable of fulfilling its required !

l function l No violations or deviations were identified.

, , Confirmatory Measurements (84750)

10 CFR 20.201(b).(2) specifies that each licensee shall make or cause to

,be made such surveys as are reasonabic under the circumstances to evaluate

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the extent of radiation hazards that'may be present..

Pursuant to this requirement, this area was inspected to verify the licensee's ability to conduct precise and accurate measurements. As part of the NRC Confirmatory Measurements Program,' spiked liquid samples were sent to H. B. Robinson for selected r&diochemica1' analyses. The samples were received by Robinson on October 9, 1990. ;The NRC received the analytical results from CP&L in a letter dated December 7, 1990. The comparison of licensee results to known' values are' presented in

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Attachment 1. The acceptance criteria for the comparisons are presented in

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Attachment 2. The results were all in agreement.

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! No violations or deviations were identifie b i

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< Information Notices (92717)

The inspector reviewed Notice 90-50: " Minimization of Methane Gas in j Plant Systems and Radwaste Shipping Containers," Notice 90-56:

L " Inadvertent Shipment of a Radioactive Source in a Container Thought to j be Empty," and Notice 90-82: " Requirements:for Use of Nuclear Regulatory l Commission-(NRC)- Approved Transport Packages for Shipment of Type A j Quantities of Radioactive Material" with licensee personnel. The '

' notices had been received and distributed to the appropriate groups for l information and evaluation, j Control Room Filter System (84750)

Technical Specifications (TS) 3.15 and 4.15 provide the limiting conditions i for operation and list the tests and test frequencies for the Control Room  ;

Filter Syste These filter trains consist of roughing filters, high l efficiency particulate absolute (HEPA) filters, and charcoal absorber Operability of this system helps ensure that.the Control Room will remain s

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habitable during an accident. The tests verify that iodine and particulate I

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removal efficiency are within acceptable limit I Pursuant to these requirements, the inspector discussed system maintenance

- and operability with cognizant licensee personnel, and reviewed test procedures and results for this syste m The inspector determined that Robinson had recently completed a C & trol

Room Habitability Modification Package (Plant Modification Number 994).

This modification upgraded the existing control room filtration unit charcoal bed depth from one to two inche It also increased the design !

air flow to approximately 550 cubic feet per minute. In addition, other l components of the system were upgraded or added, so that active system 6 components (fans, dampers, cooling s'ystems, condensing units) were redundant. The modifications were performed to reduce unfiltered inleakage, and to provide the redundant systems necessary to meet single failure criteri . .

TSs require that after structural modifications of the HEPA filters or the charcoal absorber housing which would adversely affect the air flow distribution specific tests be performed. The inspector reviewed documentation for several of these. tests, and verified that they had been ,

performed as required. These tests included:

- verifying that the system flow was equal to the desig~n'

flow rate i 10 percent (performed January 4,'1991).

- verifying that the charcoal adsorbers removed 2: 99 percent of a halogenated hydrocarbon refrigerant test gas when they were tested in place while the ventilation system was operating at a i flow equal to the design flow * 10 percent (performed January 4., 1991).

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V - verifying that the HEPA filter banks removed 2 99 pere.nt 7f the DOP when they were tested in place in accordance M ANSI N510.1 (1972) while the ventilation system was operating at i

a flow equal to the design flow.i 10 percent (performed

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January 4, 1991).

- verifying that the pressure drop across the combined HEPA filters and charcoal absorbers was < 5 inches water gauge at system design flow rate i 10 percent (performed January l4, 1991).

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- verifying that on containment isolation test signal, the system i automatically switched into a recirculation mode of operation with flow through the HEPA filters and the charcoal.adsorber banks (performedJanuary 15, 1991).

! The inspector also reviewed, and discussed with the licensee, other procedures and test results for these systems. Based on the scope of this review, the operation of these systems was in conformance with .

requirement ,

No violations or deviations were identifie . Semiannual Radioactive Effluent Release Reports (84750)

TS 6.9.d requires the licensee to submit a Semi-Annual Radiological v Effluent Release Report within 60 days after January 1 and July 1 of

each year covering the operation of the facility during the previous six months of operatio These reports summarize the amounts of liquid and ,

i gaseous effluents released from the. site and assess the dose to offsite  !

populations from these effluent , Pursuant to thase requirements, the' inspector reviewed the Semiannual Radioactive Effluent Release Reports for 1990 and discussed these reports with the licensee. This review included'an' examination of the liquid and

, gaseous effluents for 1990 as compared to those of.1989 and 198 This data is summarized belo There were no abnormal or unplanned releasesIfrom Robinson in 1990. Liquid and gaseous effluents showed no significant~ trends between U 88, 1889 and 1990. There was a slight drop in the curies of' fission and activation .

gases and iodines released in 1990, which the lleensee' attributed to good

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fuel and reactor coolant integrity. L There was ~a light increase in tritium l released in liquid effluents during 1990. Which:tne licensee attributed to outage related activities. The annual'dosestdue to these releases L varied insignificant 1y during this time period.L' Robinson liquid, gaseous,

and particulate effluents and the resulting doses were well within TSs, i 10 CFR 20, 40 CFR 190 and 10 CFR 50 effluent limits.

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i l Robinson Radioactive Effluent Release Summary 1988 , 1989 1990 l No. of Abnormal

Releases

! Liquid 0 0 0 Gaseous 0 0 0 l Activity Released (curies) Liquid Fission and

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Activation 9.64E-01 2.81E-01 3.60E-01 .

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' Tritium 5.36E+02 1.63E+02 3.53E+02

- Gross Alpha <LLO <LLO 0.00E+00 Gaseous

'T' Fission and Activation 1.04E+03 2.78E+01 - 7.21E+00 Iodines 1.07E-03 3.17E-06 1.09E-07 . Particulates 2.76E-05 1.38E-04 . 1.34E-04 Tritium 7.66E+00 4.18E+00 4.44E+00

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0ose Estimates (mrem) y 1. Gaseous Effluents Whole Body 2.61E-01 3.49E-02 .

4.16E-02 Skin 7.39E-01 5.73E-02 5.11E-02 ,

. 2. Liquid Effluents Liver 5.12E-02 . 4.68E-0, 1.30E-02 l No violations or deviations were identified.

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l, V Audits and Appraisals (84750)

TS 6.5.3.2.d requires the licensee's Corporate Quality Assurance

{l Department to perform periodic audits.of Facility activities, including:

4, training and qualification of the facility staff; the Radiological Environmental Monitoring Program; the Offsite Dose Calculation Manual;

and the Process Control Program. These audits provide assurance that these prograas are properly and effectively Limplemented.

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Pursuant to these requirements, the inspector reviewed a Quality Assurance Audit conducted on February 5-16, 1990. The-areas covered by the audit included: environmental monitoring, health physics, surveillance testing,

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ALARA concepts, corrective action systems, training and qualifications, chemistry, calibration, and the Post Accident-Sampling Program. The audit t

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team was comprised of six persons, four of whom were from the Shearon Harris Nuclear Power Plant. The inspector determined that the audit was

' conducted as a performance based audit which focused on E&RC activities associated with the daily operation of the plant, and the observations of '

on-going E&RC activities. Areasofmajorweaknesseswerenotider.tified,

- and no nonconformances were issue Based on this review, the inspector determined that the audit contained the technical depth to adequately assess the effectiveness of the E&RC progra .s_- No violations or deviations were identified.

. Training and Qualifications (84750)

TS 6.3.2 specifies that the manager of the E&RC shall meet or exceed the qualifications of Regulatory Guide 1.8, " Selection and Training of Nuclear a, Power Plant Personnel," September 1975. This Regulatory Guide specifies l

a bachelor's degree or equivalent in a science or engineering subject; and

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i in addition, requires five years professional experience.in applied i

radiation protection. These requirements ensure-that persons hired for this position will have obtained minimus knowledge'in the areas of radwaste operations, chemistry, sample analyses, and radiation ,

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instrumentatio j

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Pursuant to these requirements, the inspector' reviewed the background and -

qualifications of the person who was to assume the position of manager of

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' E&RC. This review included an interview with this person and a review of i

his resume. His education and training included a Bachelor's degree in

biology from East Carolina University in North Carolina in 1965, and a

Masters degree in Public Health (major in Radiological Hygiene) from the University of North Carolina in 1966.- His training also included a four month CP&L course titled " Reactor Operator License Training" in 197 *

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' V This gentleman's professional experience spanned the years from June of 1966 to the present, with all but two years at CP&l.. His experience was

in several different areas including

Health Physicist, nuclear weapons

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testing; Health Physicist and Radiatior Protection Officer; Senior

- Engineer and Project Specialist in the Environmental and Technical Services Section and the Nuclear Generation Section;~and E&RC Supervisor

in the Nuclear Generation Section. He~also was employed as Director of l

Health Physics in the Radiological and Chemical' Support Section of the Operations Training and Technical Support. Services Department.

j l The inspector determined that the educational background, and the ,

l professional training and experience of this person met or exceeded the

minimum requirements specified in the TSs for the position of Manager of i the E&R m

! No violations or deviations were identified.

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! Radiation Monitoring System (84750) '

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this area was inspected to determine whether i , Pursuant the licenseeto 10 hadCFR 20.201.(b),icient a system suff to perform the surveys necessary to

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adequately evaluate the extent of radiation hazards.

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As part of this inspection, the inspector reviewed.the status of the

licensee's program to upgrade their Radiation Monitoring System (RMS).

! ^, , In general, due to parts availability and age of the equipment, the i

monitors were difficult to maintain in an operable and reliable conditio The licensee's RMS had a history of requiring numerous work orders in l =

order to stay operational (592 in six years). JIn 1988, various monitors were out of service for a cumulative total of 4,289 hour0.00334 days <br />0.0803 hours <br />4.778439e-4 weeks <br />1.099645e-4 months <br /> As a result of these problems, the licensee formed a RMS Team in 1989 to develop and 4, implement an upgrade plan for the RM The goal of the Team was to complete the ispgrade by the end of the 1990 refueling outage. This deadline required close~ coordination with the vendor supplying the equipment and with the various licensee departments involved with the upgrade. Selected persons on the RMS Team monitored vendor activity to ensure that the equipment would' comply with specifications. This included four trips to the vendor, and included a Factory Acceptance Tes Equipment for this upgrade arrived on site on -

September 11, 1990, shortly after the start :" the refueling outage (September 7, 1990). The RMS Team supported the modification installation; including implementation, field revisions, equipment calibration, and acceptance testing. The modification'was completed and accepted by Operations by December 19, 199 '

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The upgrade modifications involved removal and replacement of the entire plant vent stack monitoring system, including plant vent stack particulate,

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i iodine, noble gas, and flow monitors. The: modification also involved i replacement of analog control room electronics'with digital equipment,

and the replacement of several detectors located through out the plan .

There were several improvements realized as'a; result of this upgrade.

! These improvements included: ~

i j - Simplification of area monitor calibrations j - Improved sensitivity of the new digital ratemeters

- Upgraded most remote check sources. reducing'the need

to use a portable check source .

4 - Digital readouts in the control room-

- Digitally controlled setpoints eliminating drift

. - Equipment manufactured by only two vendors (as opposed l to five previously)

! - Improved RMS drawings and documentatio s

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j . As part of this inspection, the inspector also walked down the RMS;

! observing the changes due to the upgrade, and r.oting operability and j calibration status. The inspector also reviewed selected portions of

calibration procedures and calibration documentation for the RMS. Based on this review, the RMS was adequate to fulfill its intended function.

L.* .- The inspector considered the actions of the RMS Team during the planning and implementation of the RMS upgrade a licensee strength.

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No violations or deviations were identifie . Transportation of Radwaste (86750) - 6

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10 CFR 20.311(b) requires that each shipment ~of radioactive waste to a licensed disposal facility be accompanied by a shipment manifest and

, specifies required entries on the manifestsi s, j

i Pursuant to these requirements,'the inspector' reviewed selected records of several radioactive shipments made 'during 1991,7and verified that tl:e i manifests had been properly completed. The inspector also discussed the i shipment process, the procedures used by the licenseei and the computer

programs the licensee used to generate their shipment documentation. The

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inspector interviewed the technicians responsible for" performing the i shipments, and discussed training and background for these positions with i the technicians and their supervisor. The-technicians were knowledgeable

, of their duties and of shipment. regulations <and-requirement . No violations or deviations were identified.

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V 11. Chemistry (84750)

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! a. Reactor Coolant Chemistry (84750)-

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TS 3.1.4 specifies that the total specific activity in microcuries per gram (pci/g) of the reactor coolant'shall not exceed 1.0 pCi/g dose equivalent Iodine-131 (DEI)1and 100/-bar pC1/g under all modes

! of operation. These parameters are related;to fuel integrit Pursuant to these requirements, the inspector discussed DEI with the licensee. The inspector determined that DEI for March 8 through

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the 14, 1991 ranged from 1.7E-07 pCi/g to 1.8E-04 pC1/g, with the latter value being at 70 percent power. For 1990. DEI for the primary coolant did not exceed 1.0 pCi/g. The inspector also determined from a review of documentation that gross activity did not exceed

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100/E-bar pCi/g during 199 TS ?.1.6.1 specifies that the concentration of oxygen in the reactor ,

coolant shall not exceed 0.1 parts per million when the reactor

- coolant temperature exceeds 250 degrees Fahrenhei This parameter is related to resistance to corrosion and structural integrit Pursuant to this requirement the inspector determined that the oxygen levels in the reactor coolant for the time period of March 8 through 14, 1991 were less than 1 parts per billion (ppb), the LLD

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for the measurement method used for this paramete TS 3.1.6.2 specifies that the concentration of chloride in the l

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reactor coolant shall not exceed 0.15 ppe when the reactor temperature

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exceeds 250 degrees Fahrenhei .

Pursuant to this requirement, t'he inspector determined that the chloride levels in the reactor coolant for.the time period of March 8 through 14, 1991 was less than 20 ppbr the LLD for the measurement method used for this paramete ,

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The inspector also determined that' Robinson planned to return to a Modified Lithium Program for Cycle 14,'from the Elevated Lithium Program. This change was based on industry experience with the Elevated Lithium Program causing higher oxide buildup rates. Lithium ,

is added to control pH, minimize ' corrosion'and corrosion product

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release rate Based on this review, the inspector determined that the licensee had  !

an effective program for managing their, primary system chemistr >

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No violations or deviations were identifie '

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Q Steam Generator (SG) Chemistry (84750) .

The inspector reviewed the results of SG sludge summaries and other chemistry parameters for Robinson, Robinson had reduced the risk of corrosion in their SGs by implementing effective layup practices (the maintenance of alkaline reducing conditions. coupled with nitrogen blanketing), and the reduction of the chemical contaminant inventory during operation (the use of deep bed,> full flow condensate polishing i for start up and normal operation).: Robinson's SG sludge inventory and SG hideout return have been low. The amounts of sludge removed

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from the SGs are detailed below. Robinson had removed copper in the secondary system in an effort to mitigate corrosion concern '

4 Electrical Power Research Institute (EPRI) and vendor guidelines for feedwater oxygen are 5 5 ppb.' For 1990, Robinson averaged 1.2 pp EPRI and vendor guidelines for SG blowdown parameters are:

5 0.8 microSiemens per centimeter (pS/cm) for cation conductivity, and 5 20 ppb sodium, chlorides and sulfates. Robinson's values for 4 these parameters for 1990 for SGA,-SGB'and SGC respectively, were:

. 0.19, 0.17, and 0.16 pS/cm for cation conductivity; 1.6, 2.1, and

~; 2.0 ppb sodium; 2.1, 2.7, and 2.4 ppb chloride; 8.7, 8.1 and 10.1 ppb sulfates. These values were well below the recommended values, providing assurance that corrosive conditions were minimize Based on this review, the inspector determined that the licensee had r an effective program to control SG chemistry and to minimize corrosion ,

Concern No violations or deviations were identifie Steam Generator Sludge St. mary 6 Robinson

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. Pounds Sludge March 1986 April 198 September 1990 Cycle 10 Cycle 11 Cycle 13 SGA 75 45 40 SGB 50 28 96 SGC 88 16 '- 96 12. Exit Interview l The inspection scope and results were summarized on March 15, 1991, with those persons indicated in paragraph 1. The' inspector described the areas inspected and discussed in detail the' inspection'results as listW in the Proprietary information is not contained in this report.

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summar Dissenting comments were not received from the license .

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Q 13. Acronyms and Initialisms CFR Code of Federal Regulations CP&L Carolina Power and Light Company DEI Dose Equivalent lodine-131 E&C Environmental and Chemistry .

E&RC Environmental and Radiation Control .

EPRI Electrical Power Research Institute l HEPA High Efficiency Particulate Absolute  ;

ppb part per billion l ppm parts per million  ;

RMS Radiation Monitoring System SG Steam Generator TS Technical Specification '

pCi/g microcuries per gram pS/cm microSiemens per centimeter

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ATTACHMENT 1

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CONFIRMATORY MEASUREMENT COMPARISONS OF H-3, Fe-55, Sr-89 AND Sr-90 ANALYSES FOR H. B. ROBINSON NUCLEAR PLANT REPORTED ON DECEMBER 7. 1990 NRC Licensee Ratio Resolution _(Licensee /NRC) Comparison Isotope _ (uti/ml) (uCi/ml)

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0.92 Agreement H-3 4.78i0.19 E-5 4.41E-05 4.61E-05 25 0.93 Agreement Fe-55 4.9810.20 E-5 Agreement

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1.11 0.05 E-4 ,1.01E-04 22 0.91 Sr-89

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2.09 E-06 25 0.94 Agreement j Sr-90 2.2310.09 E-6 l

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"' ATTACHMENT 2 CRITERIA FOR COMPARISONS OF ANALYTICAL MEASUREMENTS t

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This attachment provides criteria for the comparison of results of analytical *

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radioactivity measurements. These criteria are based on empirical relationships which combine prior ex>eriencer.in comparing radioactivity

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l' analyses, the measurement of the stat'sticdlly' random process of radioactive emission, and the accuracy needs of this program.

O In these criteria, the " Comparison Ratio Limits"1- denoting agreement This variability or disagreement between licensee and HRC results are variable.

is a function of the ratio of the NRC's analytical value relative to its associated statistical and analytical uncertainty, referred to in this program as " Resolution"2, ,

For comparison purposes, a ratio between the licensee's analytical value and the NRC's analytical value is computed for each radionuclide present in a given sample. The computed ratios are then evaluated for agreement or disagreement l based on " Resolution." The corresponding values 'for " Resolution" Ratio values and the s which " Comparison Ratio Limits" are listed in the Table belo !

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are either above or below the " Comparison Ratio Limits" are considered to be in disagreement, while ratio values within or encompassed by the " Comparison Ratio

!! ' Limits" are considered to be in agreement.

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TABLE i

' ' NRC Confirmatory Measurements Acceptance Criteria Resolution vs. Comparison Ratio Limits Comparison Ratio Limits Resolution for Aareement ,,

<4 0.4 - ' '

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8 - 15 0.6 - 1.66 l

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16 - 50 0.75 - 1.33 l

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51 - 200 0.80 - 1.25

>200 0.85 - 1.18'

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1 Comparison Ratio = Licensee Value l

> NRC Reference Value 2 Resolution = NRC Reference Value Associated Uncertainty

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