ML20140E914

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Insp Rept 50-458/86-05 on 860127-31.Violation Noted:Failure to Maintain Calibr Records of Gas Chromatograph While Performing Tech Spec Required Surveillance
ML20140E914
Person / Time
Site: River Bend Entergy icon.png
Issue date: 03/06/1986
From: Murray B, Nicholas J, Wise R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20140E887 List:
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM 50-458-86-05, 50-458-86-5, NUDOCS 8603280233
Download: ML20140E914 (18)


See also: IR 05000458/1986005

Text

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                                          APPENDIX B
                            U. S. NUCLEAR REGULATORY COMMISSION
                                           REGION IV
   NRC Inspection Report:       50-458/86-05                           License:     NPF-47
   Docket:    50-458
    Licensee:   Gulf States Utilities (GSU)
                P. O. Box 2951
                Beaumont, Texas 77704
    Facility Name:    River Bend Station (RBS)
    Inspection At:    River Bend Station, St. Francisville, Louisiana
    Inspection Conducted:    January 27-31, 1986
    Inspectors:           /IAk.          /Ait2//
                    J. Blair Nicholas, Radiation Specialist,                Dtte
                   & Facilities Radiological Protection Sect on
                      0fdin19Mbvuxb/
                     R'ussell Wise, 'Radiatiori Specialist, Facilit !es
                                                                            5    6/B6
                                                                            0' ate'
                  d. Radiological Protection Section
   Approved:             OfqJMlA{[///                                           M/[[
                    BlaineMurray,~ Chief,facilitiesRadiological             D' ate
                       Protection Section
   Inspection Summary
   Inspection Conducted January 27-31, 1986 (Report 50-458/86-05')
   Areas Inspected:     Routine, announced inspection of the licensee's water chemistry
   and radiochemistry programs including: review of organization and management
   control, staffing and staff qualifications, training program, facilities and
   equipment, NUREG-0737, Item II.B.3, postaccident sampling system (PASS), quality
   assurance (QA) program of chemistry / radiochemistry activities, quality control
   of analytical measurements, radiochemistry and whole body counting system
   confirmatory measurements. The inspection involved 78 inspector-hours onsite by
   two NRC inspectors.
   Results: Within the areas inspected, one violation was identified (see paragraph 6).
   Two previously identified open items were closed.
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                                          DETAILS
   1.   Persons Contacted
        GSU
      *W.   J. Cahill, Senior Vice President , RBS Nuclear Group
      *J. C. Deddens, Vice President, RBS Nuclear Group-
      *T. F. Plunkett, Plant Manager
      *T. D. Burnett, Plant Chemist'
      *S. V. Desai, Chemical Engineer
      ~*J.  W. Evans, Stenographer
      *K. J. Giadrosich, Operations - QA
      *D.   P.. Gipson, Assistant Plant Manager - Operations
      *R.   E. Horn, Nuclear Training Representative
      *R.   J. King, Lkensing Engineer
      *W.   J. Lambert, Systems Engineer
      *G. D. Lipham, Chemistry Foreman
       A. _S. Maryman, Nuclear Chemistry Technician
        R. L. McCann, Nuclear Chemistry Tectnician
      *J. H. McQuirter, Licensing Engineer
      *C. .L. Nash, Chemistry Supervisor

, D. M. Ross, Radiological Health Specialist

        R. J. Shah, QA Engineer
      *J.-  E. Somerindyke, Corporate Security
       J. E. Spivey,-QA Engineer
      *P.   F. Tomlinson, Director, Quality Services
       W. K. Woodcox, Chemistry Foreman
       Others
      *D. D. Chamberlain, NRC Senior Resident Inspector
       W. B. Jones, NRC Resident Inspector-
      * Denotes those present-during the exit briefing on January.3.1, 1986.
       The NRC inspectors also interviewed several'other RBS employees during the
        inspection.
   2.  , Licensee ~ Action on Previous-Inspection Findings

.

        (Closed) Open Item (458/8422-05):       Postaccident Sampling System _- This item
        involved the lack of. PASS operation verification by collecting reactor
       water and contair. ment atmosphere samples, performing required analyses, and
       completing training of nuclear chemistry technicians.on PASS. The NRC                 j
        senior resident inspector witnessed a demonstration of the licensee's                 :
       ability to provide representative reactor water samples using the manual
       grab PASS on November 10, 1985. The NRC inspector during this inspection-            .l
       also witnessed a similar demonstration and verified that the' licensee's
       PASS and associated procedures satisfy the requirements of NUREG-C737,
        Item II.B.3. The licensee had completed technician training on.the PASS               '
                                                                             -.     ,     -
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                                             3

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        for 10 nuclear chemistry technicians. The li'censee's methods, analytical
        sensitivities, and analytical results of chemistry parameters are
        consistent with PASS requirements. This item is considered closed.
        (Closed) Open Item (458/8422-06):      Facilities, Equipment, and Supplies --

!

        This item involved the completion of construction, testing, calibration'of

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        process instrumentation, and the routine.~use of the' chemistry sample panels
        and-associated process instrumentation. The NRC inspectors inspected the           -
        various chemistry sampling areas including the reactor water sample panel,
        turbine. plant sample panel, condensate demineralizer sample panel, makeup
        water sample panel, radwaste sample panel, and fuel building. sample panel.
        The NRC inspectors determined that all the sampling panels had been tested
        and calibrations had been performed on associated process instrumentation
        in accordance with RBS procedures and that all sampling areas were in

j reutine operation. This item is considered closed. 4 3. Inspector Observations

        The following are observations the NRC inspectors discussed with the
        licensee during the inspection and at the exit' interview on January 31,
        1986. These observations are neither violations nor unresolved items.
        These items were recommcnded for licensee consideration for program
        improvement, but they have no' specific regulatory requirement. The
        licensee stated the items would be reviewed.
        o     Confirmatory Measurements - The percent agreement between the licensee
              and NRC were below the expected values for these kinds of measurements
              (see paragraph 12.b).
     4. Chemistry / Radiochemistry Organization and Managemer.t Controls
        The NRC inspectors reviewed the licensee's organization and staffing of the
        chemistry / radiochemistry section (C/RS) to determine compliance with
        commitments in Chapter 13 of the Final Safety Analysis Report (FSAR) and
        the requirements in Section 6.2.of the Technical Specifications (TS) and
        in RBS procedures.
        The NRC inspectors verified that the organizational structure of the C/RS
        was as defined in the FSAR, TS, and RBS procedures. The NRC inspectors
        reviewed the RBS management control procedures and position descriptions
        for the assignment of. responsibilities for the management and implementa-
        tion of the RBS. chemistry / radiochemistry program. The NRC inspectors
        verified that the administrative control responsibilities specified by the
        RBS procedures were being implemented.
                                                                                           '

'

        The NRC inspectors reviewed the staffing of the_C/RS and noted that since
        the previous NRC chemistry / radiochemistry inspection in June 1985, the C/RS
        had lost its lead chemist and~one' chemistry foreman. The chemistry foreman
        position had been filled by one of the plant chemists and the vacated' plant
        chemist position had been filled by one of the senior nuclear chemistry
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       technicians leaving 15 nuclear chemistry technician positions filled and
       one vacancy.   At the time of the inspection, the lead chemist position was
       temporarily filled with a qualified contractor. The chemistry supervisor
      was recruiting to fill the staff vacancies.
       No violations or deviations were identified.
   5.  Chemistry / Radiochemistry' Personnel Qualifications
      The NRC inspectors reviewed the qualifications of the C/RS personnel to
       determine compliance with commitments in Chapter 13 of the FSAR and the
       requirements in Section 6.3 of the TS and in RBS procedures.
      The NRC inspectors reviewed the resumes of each of .he C/RS personnel and
      verified that they met the required qualifications specified in the FSAR,
      TS, RBS procedures, and position descriptions.       The NRC inspectors
      determined that the licensee had an' adequate staff to meet shift staffing

. requirements.

      No violations or deviations were identified.
   6. Chemistry / Radiochemistry Training Program
      The NRC inspectors reviewed the licensee's chemistry / radiochemistry
      training program to determine complianca with commitments in Chapter 13.2
      of the FSAR and the requirements in Section 6.4 of the TS, 10 CFR
      Part 19.12, and in RBS procedures.
      The NRC inspectors reviewed the licensee's program for training and
      qualification of RBS C/RS personnel as described in the nuclear training
      department procedures and in RBS Chemistry Section Procedure.
      The.NRC inspectors reviewed the C/RS individual staff training matrix
      records and determined that nine chemistry technicians had completed all
      matrix training requirements and six chemistry technicians were in the
      process of completing the general RBS systems training and PASS hands-on
      analysis training.
      No violations or deviations were identified.
   7. Chemistry / Radiochemistry Program
      The NRC inspectors reviewed the licensee's chemistry / radiochemistry program
      to determine compliance with commitments in Chapters 5, 9, and 11 of the
      FSAR and the requirements in Section 3/4.4.4 of the TS.and in C/RS procedures.
      The NRC inspectors' review of the chemistry / radiochemistry program found
      that the licensee nad completed and approved all identified administrative
      procedures, surveillance procedures, chemical control procedures, instrument

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                                           5
      calibration and performance check procedures, sampling procedures, and
      analytical procedures. A review of selected procedures, logs, and analyt-
       ical data indicated that the C/RS had established sufficient administrative
      a1d analytical procedures to meet the requirements of the FSAR and TS.
      The NRC inspectors reviewed the calibration and qua'ity control program
       for the secondary chemistry laboratory instruments and primary chemistry
       laboratory instruments. Laboratory instrument calibration and performance
      check data and other documentation of instrument performance were reviewed.
      During the review of instrument calibration data, it was noted that the
      licensee'had not documented any calibrations performeo on the Fisher
      Model 1200 gas chromatograph when performing hydrogen analysis of the
      offgas hydrogen recombiner effluent. The rnalysis. procedure COP-0425,
      " Determination of H2and 0 Gas
                                   2    Concentration - Gas Chromatography Method,"
      Revision 1, July 25, 1985, requires in paragraph 8.3 that calibration
      standard data be recorded on the appropriate chemistry log. The fraquency
      of calibration .'or the gas chromatograph, prior to each use, and appropriate
      chemistry log, 50ul.1.7.4, are specified in CSP-121, "Chcmistry Laboratory
      Instrument Surveillance," Revision 1, December-22, 1985. The NRC inspectors
      determined on January 29, 1986, that the gas chromatograph had been used to
      perform 57 hydrogen analyses of the offgas hydrogen recombiner effluent,
      while the offgas explosive gas monitoring system was inoperable, during the
      period January 14-26, 1986. A review of the TS surveillance report form
      for procedure N P-0100, " Chemical / Radiochemical Technical Specifications
      Surveillances," Revision 1, December 20, 1985, completed during the above
      specified period showed that the offgas hydrogen recombiner effluent had
      been sampled and analyzed every 4 hours for hydrogen concentration .to
      satisfy Technical Specification Table 3.3.7.11-1, Action 123, without the
      required gas chromatograph calibration data being documented.     Technical
      Specification 6.10.2.d requires that records be retained for at least 5
      years of surveillance activities, inspections, and calibrations required
      by the TS. The licensee's failure to maintain calibration records of the
      gas chromatograph while performing a TS required surveillance is considered
      an apparent violation of TS 6.10.2.d. (458/8605-01).
   8. Facilities and-Equipment
      The NRC inspectors inspected the facilities and equipment / supplies used by
      the C/RS staff. The following facilities were inspected:      cold laboratory,
      radiochemistry laboratory, radiochemistry counting room, various chemistry
      sampling panels, and PASS sample preparation area. The licensee had
      completed construction in all the areas inspected. The laboratories were
      equipped with the necessary chemicals, reagents, standards, labware, and
      analytical instrumentation to perform the required analytical procedures.
      The installation of the. various chemistry sampling panels was completed and
      the associated process instrumentation had been tested and' calibrated and
      was routinely operational. The PASS sample preparation area adjacent to
      the radiochemistry laboratory was equipped ano functional.
      No violations or deviations were identified.

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           '9.  Postaccident.Samplina System
                The NRC . inspectors reviewed the licensee's PASS to determine compliance
                with the requirements of NUREG-0737, Item II.B.3, and Section 6.8.4.c
                of the TS.

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               The NRC inspectors inspected the area.in the plant where the PASS hardware
                had been installed. The NRC inspectors verified _that the equipment and
                associated procedures satisfied the requirements of NUREG-0737, Item II.B.3,
               and the TS for representative sampling and analysis of reactor water and
               containment atmosphere follcwing a reactor incident. The licensee had
               completed PASS operator training for 10 C/RS technicians as part of their
                shift qualification.   Five remaining C/RS technicians'will receive PASS
               operator training as soon as current PASS operating procedure revisions are
               approved. The NRC inspectors witnessed the initial monthly chemistry
                surveillance of PASS in accordance with Chemistry Section Procedure,
               CSP-0150, " Chemistry Surveillance of the Post-Accident Sampling System
               (PASS)," Revision 1, January 2, 1986. The licensee demonstrated PASS
               operability by collecting a simulated sample of reactor water using
               demineralized flush water due to the status of the plant at 10 percent
               power and plant operations having many systems isolated to assist in
               diagnosing plant operating problems.. The licensee also collected a sample
               from the containment building. The licensee prepared these samples for.the
               required analyses in accordance with approved procedures. -However, due to
               the nature of these samples, analyses were not performed during this
               inspection. As discussed in NRC Inspection Report 50-458/85-77, the PASS
               had been demonstrated operable on November 10, 1985, by the taking of two
               liquid samples from the jet pump header.

, i The licensee analyzed the first sample for pH, dissolved oxygen, dissolved

hydrogen, boron, conductivity, and radionuclides'within 3 hours from the

i time the decision was made to take the samples as required by NUREG-0737. i

               The NRC inspectors determined that the licensee's procedures, analytical
               sensitivities, and analytical results of chemi_stry parameters were

! consistent with PASS requirements.

               No violations or deviations were identified.

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           10. Quality Assurance Program
               The NRC inspectors revi sed the licensee's QA audit / surveillance program
               regarding chemistry /radicciemistry activities to determine compliance
               with commitments in Chapter 17 of the FSAR and the requirements in
               Section 6.5.3.8 of the-TS and related RBS QA procedures.
               The NRC inspectors reviewed the QA department organization, selected QA
               audit and surveillance procedures, audit schedule for 1986, QA audits

l qualifications, and audit and surveillance reports. The licensee completed

               an audit of the chemistry / radiochemistry program on June 6,1985, which was-
               reviewed in NRC Inspection Report (458/85-47). The NRC inspectors noted

l _ ._- - _ . . . . _ _ _ _

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      that the next chemistry / radiochemistry program audit is scheduled for
      May 1986. . Reports generated from surveillances performed during 1985 in
      the areas of chemistry / radiochemistry TS surveillance requirements were
      reviewed for scope to ensure thoroughness of program evaluation. The NRC
             _
      inspectors found the QA surveillance program adequate and responses and
      corrective actions to surveillance findings timely.
      No violations'or deviations were identified.
 11. Quality Control of Radiological Analytical Measurements
      The NRC inspectors inspected the radiochemistry counting room and reviewed
      the licensee's program for calibration and quality control of radiological
      analytical measurements to determine compliance with the requirements in
      Sections 6.8 and 6.10 of the TS.
      The NRC inspectors reviewed the licensee's records, for the period July
      through December 1985, involving instrument surveillance procedures',
      instrument calibration and quality control procedures, counting instrument
      calibration and performance check data, and other documentation of
      instrument ~ performance.
      No violations or deviations were identified.
 12.  Analytical Measurements
      a.    Confirmatory Measurements
            Confirmatory measurements were performed on the following standards
            and samples in the NRC Region IV mobile laboratory at'RBS during the
            inspection:
            (1) NRC Face Loaded Scott Charcoal Cartridge Standard
                  (SRS-17817-109)
            (2) NRC Particulate Filter Standard (SRS-17818-109)
            (3) Simulated Liquid Radwaste (1 Liter Marinelli Beaker)
            (4) Reactor Coolant System Liquid (1 Liter Poly Bottle)
            (5) Reactor Coolant System Tritium Sample
            The confirmatory measurements test consisted of comparing measurements
            made by the licensee and the N'lC mobile laboratory. The NRC's mobile
            laboratory measurements are referenced to the National Bureau of
            Standards (NBS) by laboratory intercomparisons. Confirmatory measure-
            ments are made only for those nuclides identified by the NRC as being
            present in concentrations greater than 10 percent of the respective
            isotopic values for' liquid and gas concentrations as stated in 10 CFR
            Part 20, Appendix B, Table II. Attachment I contains the criteria used
            to compare results.

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                                            8
       b.   Results
            The licensee maintains four germanium-lithium ~ detectors in the
            radiochemistry counting room. At the time of the inspection, two     of
           .the detectors were out-of-service due to electronic malfunctions.     All
            four detectors.are used for routine isotopic analysis of radioactive
            samples to demonstrate compliance with TS and regulatory requirements.
            The analytical results from the two detectors were compared with the
            NRC results, as well as with each other. The licensee performed the
            tritium analysis on their liquid scintillation counting system.     The
            individual sample analyses and comparison of analytical results of the
            confirmatory measurements are tabulated in Attachment 2.
            The licensee's gamma isotopic results from the listed samples in
            Attachment 2 showed 82 percent agreement with the NRC analysis results
            based on 61 agreement results out of 74.nuclides identified and
            compared. The 82 percent agreement results between the licensee and
            NRC are below the value that would be expected for an effective radio-
            chemistry program. The normally expected agreement would be greater
            than 90 percent. The comparative measurements'results were discussed
            with the licensee during the exit interview on January 31, 1986. The
            licensee stated that their radiochemistry program.would be reviewed in
            an attempt to improve their measurement capabilities. The licensee's
            tritium result on the reactor coolant system sample was in agreement
            with the NRC analysis result.
            Confirmatory measurements were performed by the licensee on a liquid
            unknown samp?e prepared by the Radiological Environmental Sciences
            Laboratory (RESL) in Idaho Falls, Idaho using known nuclide concen-
            trations of 893p, 903p, 3g, 137Cs, and 50Co. The licensee's analytical
            results were compared to the known sample activities and the results
            of the comparisons are presented in Attachment 2, sample 6. The
            licensee's results were in 100 percent agreement with the certified
            activities for 3H, 187Cs, and 60Co in the sample. The analytical
            results for 895r and 90Sr were not available from the licensee's
            contractor laboratory at the time of the inspection.
      No violations or deviations were identified.
 13. Whole Body Counting System
      The NRC inspectors reviewed the licensee's " standup" whole body counting
      system (WBCS) to determine compliance with 10 CFR Part 20.103. The
      licensee maintains a shadow shield bed type WBCS also.
      The NRC inspectors reviewed the licensee's program for operation,. calibration,
      and quality control of the " standup" WBCS and found it adequate. The
      licensee had calibrated the " standup" WBCS using sources of common nuclides
      found in nuclear power facilities which represented vari.ous percentages of
      maximum permissible organ burdens.      The licensee's sources were traceable
      to the NBS and were.used in a masonite phantom supplied by the vendor-of
      the WBCS.
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                  The NRC inspectors supplied the licensee with a whole body counting
                  phantom to perform confirmatory measurements in.' the " standup" WBCS. The
                  phantom and counting arrangements were described in NRC Inspection
                  Report 50-458/85-17. The phantom was-stood. upright on a support in the
                  WBCS during the measurements.        The results of the body positioning ~ test
                  and the. comparison of the analytical results of the confirmatory measurecents-
                  against the standard activities are tabulated in Attachment 3.
                  The licensee analyzed the nuclide~ activities riositioned in the NRC phantom

a to simulate inhalation as " mock f odine"~ in the thyroid and soCo in the

                   lungs. The NRC inspectors checked the licensee's accuracy of body positioning
                   in the " standup" WBCS and found the reproducibility of measurements
                  satisfactory. The results of the body burden activity measurements taken
                  resulted in several observations regarding the " standup" WBCS. These
                  observations include the following:
                                                                               ~
                  a.       The licensee's results for 5 percent through two organ burdens of

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                           6oCo in 'the right lung ranged from 14 percent higher to 25 percent
                           lower than the certified activities of the NRC standards with increasing
                           organ burdens. (See Tests (4)-(8)). These results are more accurate
                           than the results of similar previous tests performed on the licensee's
                           shadow shield style WBCS.    (See NRC Inspection Report 50-458/85-17).
                  b.       The licensee's results~for 5 percent through two organ burdens of
                           133Ba as " mock iodine" in the thyroid were nonconservative and were
                           approximately 40 percent low 3r than the certified activities of the
                           NRC standards. (See Tests (9)-(13)). These results are more
                           consistent and overall more accurate than the results of similar
                           previous tests performed on the licensee's shadow shield style
                           WBCS which showed results ranging from 40 percent lower to 300
                           percent higher than the certified activities over the same organ

! -burden range. (See NRC Inspection Report 50-458/85-17).

                  c.       The licensee was able to analyze most accurately a 5 percent organ
                           burden of 233Ba as " mock iodine" in the thyroid in the presence of a
                           5 percent organ t,urden of 80Co in the lungs. (See Test (17)). The
                           other combinations of activity concentrations tested of " mock iodine"
'
                           in the thyroid and 80Co in lungs gave results indicating the thyro'<i

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                          . activity approximately 50 percent lower than the certified activi

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                           values.    (See Tests (14), (15), (16), and (18)).
                  The licensee was informed of the analytical results of the confirmatory
                  measurements.
  .
                  No violations or deviations were identified.
            14. . Exit Briefina
                  The NRC inspectors met with the NRC senior resident inspector and the
                  licensee representatives identified in paragraph 1 at the conclusion of the-
inspection on January 31, 1986. The lead NRC inspector summarized the

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                  scope of the inspection, discussed the inspection findings,.and presented
                  the results of the confirmatory measurements.
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                                        ATTACHMENT 1.
  Criteria ^for Comparing Analytical Measurements
  The following are the criteria used in comparing the results of capability
  tests and verification measurements. The criteria are based on an empirical
  relationship established through prior experience and this program's-analytical
  requirements.
   In these criteria, the' judgement limits vary in. relation to the comparison of
  the resolution.
                       NRC VALUE
  Resolution =
                   NRC UNCERTAINTY
  Ratio = LICENSEE VALUE
              NRC VALUE
  Comparisons are made by.first determining the resolution ~and then reading across
   the same line to the corresponding ratio. The following table shows the
  acceptance' values.
                           RESOLUTION              AGREEMENT RATIO
                                    <4-                 0.4 - 2.5
                                 4-7                    0.5 - 2.0
                               8 - 15                  0.6 - 1.66
                              16   -50                0.75 - 1.33
                             51 - 200                 0.80 - 1.25
                                  >200                0.85 - 1.18
  The above criteria are applied to the following analyses:
        (1) Gamma Spectrometry.
        (2) Tritium analyses of liquid samples.
        (3)   Iodine on adsorbers.
        (4) 895r and 995r determinations.
        (5) Gross Beta where samples are counted on the same date using the same'
              reference nuclide.
       .                               __                      .         _         _ ,                  .                                . _._
  f
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                                                                 -ATTACHMENT 2
                                                     Confirmatory Measurements:Results

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               1.   NRC Face Lo'ded
                                a                   Scott Charcoal Cartridge Standard (SRS-17817-109)
                    (Standardized 11:00 CST, July 1,1985)
                               RBS                     RBS Results-        NRC-Results.            RBS/NRC.     Comparison
Nuclide Det. -(uCi/ sample) (uCi/ sample) Ratio Decision
!

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                    57Co-      (1)                    =1.8210.08E-02 1.8910.01E-02                  0.96'       Agreement
                               (2)                     2.0110.09E-02                               '1.06        Agreement
                    60Co       #1)                     4.74 0.16E-02 4.8710.02E-02                  0.97        Agreement
;
                               (2)                    ~5.02 0.17E-02                                1.03        Agreement
                    asY        (1)                     1.0810.04E-01 1.1410.01E-01                  0.95        Agreement

j (2) 1.1510.05E-01 1.01 ' Agreement

                    109Cd-     (1)                     1.1710.09E+00 1.1910.003E+0                  0.98        Ngreement'

7 (2) 1.2610.10E+00 1.06 . Agreement ! , 11aSn (1) 6.8210.39E-02 7.3810.04E-02 0.92 Agreement 1 (2) 7.5810.43E-02 1.03 Agreement

                   '137Cs      (1)                     4.4010.24E-02 4.4410.02E-02                  0.99        Agreement
                               (2)                     4.8210.27E-02                                1.09        Agreement
                    139Ce      (1).                    3.1210.21E-02 3.5310.02E-02                  0.88        Agreement                            '

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                               (2)                     3.4710.23E-02                                0.98        Agreement
                    zosHg      (1)                     6.9510.59E-02 7.2110.11E-02                  0.96        Agreement
                               (2)                     7.6110.64E-02
                                                          .
                                                                                                    1.05        Agreement

l 2. .NRC Particulate Filter Standard (SRS-17818-109)

(Standardized 11
00 CST, July 1, -1985)

i

                               RBS                     RBS Results         NRC Results             RBS/NRC      Comparison

j- Nuclide Det. (uCi/ sample) (uCi/ sample) . Ratio Decision !

                    57Co       (1)                     3.8010.08E-02 1.9510.01E-02                  0.92        Agreement
                               (2)                     1.6210.07E-02                                0.83        Agreement
                    80Co       (1)                     4.'6810.16E-02 4.6410.02E-02                 1. 01' '    Agreement
(2) 4.5210.16E-02 0.97 Agreement
                    asY        (1)                     1. 0810. 04E-01 1.0710.01E-01'                1~. 01     Agreement
                              .(2)                     1.0410.04E-01                                0.98        Agreement
109Cd (1) 1.1210.09E+00 1.32 0.003E+0 0.85 Agreement
                               (2)                     1.0310.08E+00                                0.78        Disagreement
                    113Sn      (1)                     7.0210.40E-02 6.8810.04E-02-                  1.02       Agreement.

j .(2) 6.4810.37E-02 0.94 Agreement

1

   .     -   .        .._. .-   , - , , , , . . , .           -       - -              - . , _ , -          --    - , ,.n - . - -. . - -       .-- .
  . .
                                            2
        137Cs     (1)       4.4310.24E-02 4.1110.02E-02    1.08    Agreement
                  (2)       4.19 0.23E-02                  1.02    Agreement
        139Ce     (1)       3.0510.20E-02 3.34 0.01E-02    0.91    Agreement
                  (2)       2.81 0.19E-02                  0.84    Disagreement
        203Hg     (1)       6.6110.56E-02 5.9510.08E-02    1.11    Agreement
                  (2)       6.0210.52E-02                  1.01    Agreement
     3. Simulated Liquid Radwaste (1 Liter Marinelli Beaker)
        (Sampled 14:30 CST, January 28,.1986)
                  RBS       RBS Results      NRC Results  RBS/NRC  Comparison
        Nuclide   Det.      (uCi/ml)          (uCi/ml)    Ratio    Decision
        24Na      (1)       4.74 0.24E-05 4.4810.05E-05    1.06    Agreement
                  (2)       4.63 0.23E-05                  1.03    Agreement
        51Cr      (1).      1.4310.28E-05 1.5310.27E-05    0.94    Agreement
                  (2)-      1.9310.34E-05                  1.27    Agreement
        54Mn      (1)       7.2610.42E-06 7.1810.22E-06    1.01    Agreement
                  (2)       7.03i0.43E-06                  0.98    Agreement

'

        56Mn      (1)       1.4010.06E.04 1.2510.03E-04    1.13    Agreement
                  (2)       1.3510.06E-04                  1.09    Agreement
        ssCo      (1)       2.5410.22E-06 3.7810.19E-06      -
                                                                   No Comparison 1/
                  (2)       2.3810.23E-06                    -
                                                                   No Comparison I/
        64Cu      (1)       2.6910.15E-03 2.7710.06E-03    0.97    Agreement
                  (2)       2.65 0.15E-03                  0.96    Agreement
        97Nb      (1)    Not Identified 2/ 2.01 0.02E-04     -
                                                                   Disagreement
                  (2)    NotIdentified]/                           Disagreement
        99"Tc     (1)    Not Identif ed 2/ 2.1510.04E-05     -
                                                                   Disagreement
                  (2)    NotIdentified2/                     -
                                                                   Disagreement
        99Mo      (1)       1.3710.08E-05 8.20il.01E-06    1.67    Disagreement
                  (2)       1.48i0.09E-05                  1.80    Disagreement
        122Sb     (1)       9.8110.71E-06 7.3310.21E-06    1.34   ,Disaoreement
                  (2)       8.5310.68E-06                  1.16    Agreement
,
        132I      (1)       3.0810.13E-05 2.7610.07E-05    1.12    Agreement
                  (2)       2.8310.18E-05                  1.03    Agreement
        133I      (1)-   Not Identified 3/ 2.9310.20E-06     -
                                                                   Disagreement
                  (2)    1.9310.26E-07                     0.07    Disagreement
        1851      (1)       1.9710.75E-06 2.0910.76E-06    0.94    Agreement
                  (2)       2.6010.77E-06                  1.24    Agreement
                               .    -   -        .           .= .         -    -         -. . -
   .   .
                                                 3
           187W         (1)       2.9010.62E-06 2.0610.87E-06           -
                                                                                 No Comparison 1/
                        (2)       3.39 0.59E-06                         -
                                                                                 No Comparison 1/

j

           ]/     Nuclide concentration' determined by the NRC was less than 10 percent
                  of the isotopic value stated in 10 CFR Part 20, Appendix B, Table-II;
                  therefore, no comparison was made.
                ~
l
          '2/     Nuclide was not identified by the . licensee because it was not included
                  in the isotope library used for the analysis.

4

           3/     Isotopic peak was present 'n the: spectral data;-however, the licensee's
                  peak confidence level for peak identification had been established so
                  as not to allow analysis.of nuclides at sensitivity levels equal to 10
l
                  percent of the isotopic values stated in 10 CFR Part 20, Appendix B,            ,

t Table II, Column 2.

       4.  Reactor Coolant System Liquid (1 Liter Poly Bottle)
           (Sampled 16:30 CST, January 28, 1986)
                        RBS        RBS Results      NRC Results    RBS/NRC       Comparison
           Nuclide      Det.       (uCi/ml)        -(uCi/ml)      - Ratio        Decision
           24Na         (1)       1.8010.10E-04 1.6710.03E-04        1.08        Agreement
                        (2)        1.7610.10E-04                     1.05-       Agreement
           51Cr         (1)        7.4711.68E-05 5.8210.78E-05       1.28        Agreement
     <
                       -(2)       8.84 1.57E-05                      1.52        Agreement
           s4Mn         (1)        2.2710.18E-05 1.8610.06E-05       1.22        Agreement
                        (2)        2.1410.17E-05                    -1.16        Agreement
           56M7         (1)        3.3910.56E-04 3.1310.41E-04       1.08        Agreement
                        (2)        3.6010.60E-04                     1.15        Agreement
           58C0         (1)        9.28tl.13E-06 9.2610.50E-06       1.00        Agreement
                        (2)        1.1510.12E-05                     1.25'       Agreement
           64Cu         (1)        1.0610.08E-02 8.4910.32E-03       1.25        Agreement
                        (2)        1.0610.09E-02                     1. 2r       Agreement
           89Mo         (1)        4.2010.29E-05 3.1210.34E-05       1.35        Agreement
                        (2)        3.7410.26E-05                     1.20        Agreement
           1225b        (1)        5.0510.39E-05 2.0410.07E-05       2.48        Disagreement'
                        (2)        3.6310.31E-05                     1.78-       Disagreement
                                                                                                  4
           187W         (1)        1.7610.44E-05 9.5812.04E-06       1.83        Agreement
                        (2)        1.5910.71E-05                     1.66        Agreement
                                                                                                  i
                                                                                                  e
                                                                            F*
                                                                                       *
 l                                                                               . * <
 . .
                                            4
    5. Reactor Coolant System Tritium Sample
       (Sampled 14:00 CST, January 27, 1986)
                  RBS Result      N.'tC Result    RBS/NRC        Comparison
       Nuclide    (uCi/ml)        (uCi/ml)        Ratio          Decision
       3H         8.5610.31E-05 11.1010.59E-05 0.77              Agreement
    6. RESL Unknown Liquid Sample
       (Standardized 12:00 MST, January 11, 1985)
                  RBS Results     NRC Results     RBS/NRC.       Comparison
       Nuclide- (uCi/ml)          (uCi/ml)        Ratio          Decision
       3H         4.9610.49E-05 4.5610.09E-05      1.08          Agreement
       88Sr           2/                            -
                                                                 No. Comparison
       8 Sr           2/                            -
                                                                 No Comparison
       137Cs      7.62il.03E-06 9.5010.19E-06      0.80          Agreement
       6 Co       6.5010.88E-06 8.4910.17E-06      0.76          Agreement
       1/    NRC results were taken from the st.andard certification supplied to the
             Region IV office as prepared by RESL and traceable to the National
             Bureau of Standards.
       2/    Analytical results were not available from the licensee's contractor
             at the time of the report.

.

        _    -           ..                           -_             _                 . . _ _       .         . .         .
  . .,
                                                          ATTACHMENT 3

I " Standup" Whole Body Counting System Confirmatory' Measurements ! 4

     1. Positioning Verification Test
        NRC Whole Body Phantom With 5 Percent Lung Burden Standard
        Tests (1), (2), and'(3) .
                                ~

i

                       RBS Result'                RBS' Result          RBS Result                     -Standard

j Nuclide Test (1) Test (2) Test (3) Average Deviation ! 60Co 0.636 0.629 '0.627 0.631 0.005 i

     2. Analytical Measurements-
        a.     -Lung Test
                NRC Whole Body Phantom With Various Lung Organ Burden Activities of

,

                Cobalt-60
'
                                                                 RBS Results      NRC Results*         RBS/NRC-
                Test No.              % MP0B                       (uCi)                (uCi)           Ratio
                    4                     5%                       0.568              0.500              1.14
                    5                   10%                        1.204              1.000              1.20
                    6                   50%                        4.780              5.000              0.96

j 7 100% 8.972 10.000; 0.90

                    8                  200%                       15.016            20.000               0.75
        b.      Thyroid Test
                NRC Whole Body Phantom With Various Thyroid Organ Burden Activities of
                Barium-133 as Mock Iodine-131
                                                  RBS Results                NRC Results*              RBS/NRC

-

                Test No.        % MP08                   (uCi)                   (uCi)                  Ratio

'

                    9               5%                    0.022                 0.036                   0.61
                   10              10%                    6.042                 0.070                   0.60
                   11              50%                    0.210                 0.350                   0.60
12 100% 0.354 0.700 0.50

1 13. 200% 0.760 1.400 0.54 1 !

l t

    _ .          .          _._          . . . _ . _ . __ ._.                            - _                __     _ . . _

. .

                                     2
   c. Lung and Thyroid Scan
      NRC Whole Body Phantom With Various Combinations of Lung and Thyroid
      Organ Burden Activities of Cobalt-60 in the Lungs and Barium-133
      as Mock Iodine-131 in the Thyroid
                                       RBS Results  NRC Results*   RBS/NRC
      Test No.   Nuclide   % MP08        (uCi)        -(uCi)        Ratio
        14       133Ba      200%         0.763         1.400          0.'55
                  GoCO       10%         1.116         1.000          1.12
        15       133Ba      100%         0.375         0.700          0.54
                  60C0       10%         1.130         1.000          1.13
        16       133Ba      100%         0.370         0.700          0.53
                  60Co        5%         0.564        -0.500          1.13
        17       133Ba        5%         0.031         0.036          0.86
                  SOCo        5%         0.588         0.500          1.18
        18       133Ba      200%         0.629         1.400          0.45
                  60Co      200%        14.806       20.000           0.74
      *
           NRC values were taken from the standard certificates supplied
           with the standat-ds as prepared by a commercial vendor and
           verified by the NRC's laboratory, RESL, in Idaho Falls, Idaho,
                                                                s
                                                                        .
                                                                            .
                                               #
         ^

f

         ,
                                                          ATTACitMEtiT B                                                     ",
                                                                                                                             *
                                                    OPEN ACTI0fl ITEMS LIST
 Date:        c/n /r;                                                 Type Code:     A= Allegation    M= Miscellaneous
                                                                                     B= Bulletin      0=0 pen Item
 Docket flo:      so ver                                                             C= Circular      R=Part 21 Report
                     (8)                                                             D= Deviation     T= Temporary Instructions
                                                                                     E=50.55(e)       U= Unresolved Item
                                                                                     L=LER            V= Violation
 floto - Max characters allowed for each entry shown in (1)
     1         2            3-           4            5           6                                    7                   8
 Type        I tera      Report  .
                                     Responsible                                                     Update /Closecut     Status
  Item       flo.        Paragraph   Section       Module     Description                            Report               Code
 (1)         (8)           (6)          (4)          (7)         (186)                                 (30)                 (1)
    Y      f?or-oi          &          -r K r       14725~      X. .'/~ <a. k T.a -..J  Ca1:b'<wI. %
                                                                 of A Crs Cho hy,y             L
                                                              .
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I

                                                                                                                                 .
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                                                                                                                                          .                      . . _ _ , _ . . . _ ._ .- _..             . . = . _ ,        . .
                                                                                            ..   . ..
                                                                                                                                                                                                                                  ,
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        ' Pt gs:'              -?-                                  )
         Updatsd:                    mbar 5,1985                f[ffff
                                                  R3 port         Resp.        . .
                                                                                                                                                                Update /Close                                          .
      ' Jyp3                I tts   No.           Pa rac ra ph.   Sect.       Module                                          .ebcriptien                       Ettpo rt                           gbg                  . . .
           0-              8414-004                6.8            T-RP                          GASEOUS RADWASTE SYSTEM                                                                               0                .
                                                                  T-RP                          EFFLUENT RELEASE PROCEDURES                                                                           0
           0                8414-005               7
                            8414-006               8              T-RP                          SOLID RADWASTE SYSTEM                                                                                 0
           0
                                                                  T-RP                          RADIATION MONITORING SYSTEMS                                                                          0
           0               8414-007                9
                                                                                                PROCESS AND EFFLUENT MONITORS
                                                                  T-RP                          AIR CLEANING FILTER SYSTEMS                                                                           0                           1
           0-               841'4-008              10
           0                8422-0'5               8              T-RP   84525                  POSTACCIDENT SAMPLING SYSTEM                                    ( 85-17 )( 85-47 ) ($.or)            .A'C-
           O'               8422-006               9              T-RP.  84525                  FACILITIES, EQUIPMENT, & SUPPLIES                               ( 85-17 )( 85-47 )(g4.os)             D d-
                                                                  T-RP                         ~ NUREG-0737, ITEM lil.A.2                                                                             0
           0                8505-001               13
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