ML20210B469

Insp Rept 50-160/87-03 on 870407-10.Violations Noted:Failure to Label Containers of Radioactive Matl,Failure to Perform Radiological Surveys & Failure to Follow Procedures

ML20210B469
Person / Time
Site:	Neely Research Reactor
Issue date:	04/23/1987
From:	Bassett C, Hosey C, Revsin B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20210B452	List: ML20210B447 ML20210B469
References
50-160-87-03, 50-160-87-3, NUDOCS 8705050333
Download: ML20210B469 (14)

See also: IR 05000160/1987003

Text

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• UNITED STATES

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g oq'o NUCLEAR REGULATORY COMMisslON

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g j 101 M ARIETTA STREET, N.W.

2 ATLANTA, GEORGI A 30323

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Report No.: 50-160/87-03

Licensee: Georgia Institute of Technology

225 North Avenue

= Atlanta, GA 30332

Docket No.: 50-160 License No.: R-97

Facility Name: Georgia Institute of Technology Research Reactor (GTRR)

Inspection Conducted: April 7-10, 1987

Inspector: ,9dd M/r M 3M7

B. K. Revsin Date 51gned

C6 amer

C. H. Bassett s

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Da'te Signed

Approved by: N M'

h C. M. Hosey, Section Chief-

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Date. Signed

V Division of Radiation Safety and Safeguards

' SUMMARY

Scope: This routine unannounced radiation protection ins'pection. involved the

areas of transportation of radioactive materials,' internal exposure control,

external exposure control and dosimetry, c'ontrol of ' radioactive materials and

contamination, surveys and monitoring, and followup on previous enforcement

items.

Results: Three violations - (1) failure to labelJcontainers of radioactive

material, (2) failure to perform radiological surveys, and (3) failure to

follow procedures.

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REPORT DETAILS

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1. Persons Contacted

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Licensee Employees

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• R. A. Karam, Director, Nuclear Research Center

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• R.- Boyd, Radiation Safety Officer

P. Sharpe, Health Physics Technician

S. Millspaugh, Health Physics-Technician

-L. D. McDowell, Senior Reactor Operator

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• Attended exit interview

2. . Exit Interview

The inspection scope and findings'were summarized on April .10,1987, with

those persons indicated in Paragraph 1 above. Three violations concerning

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the following areas were discussed in detail: (1)labelingofcontainers= *

of radioactive material [ Paragraph 5.f]; (2) radiological surveys with two

examples [ Paragraphs 5.c and 5.g.2]; and (3) failure to follow procedures

concerning Radiation Work Permits [ Paragraph 5.b.2], wearing of protective

clothing with two examples [ Paragraph 5.e], wearing required dosimetry

[ Paragraph 5.d], review and approval of experiments with two examples

. [ Paragraphs 5.g.1 and 5.g.2], completion of Experimenter's' Checklist.with

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two examples [ Paragraphs 5.g.1 and 5.g.2], personnel response to

i criticality alarm [ Paragraph 5.h], and surveys - of radiation -levels near

j the rabbit port during removal of the rabbit [ Paragraph 5.g.2]. The

i licensee acknowledged the inspection findings and took no exceptions. The

licensee did not identify as proprietary'any of the materials reviewed by

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or provided to the inspector during this inspection.

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3. Licensee Action on Previous Enforcement Matters (92702)

(Closed) Violation (50-160/85-03-02) Upranging the Gas, Monitor 'such that

automatic alarm and isolation of containment would not occur unless the

release rate was a factor of 100 above the limit. The inspector reviewed

i the ~ licensee's response' dated July 22,11986, and verified that the -

corrective action'had been implemented.

'

'

(Closed) Violation (50-160/87-02-01) Securing of- primary coolant sampling

line except during monthly surveillance and conducting five separate

l one-minute counts ior tritium analysis of waste tank samples. .The-

4 inspector reviewed the licensee's response dated April 7,1987, and

verified that the corrective action had been implemented.

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4. . Transportation (86740)

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10 CFR 71.5(a)' requires each licensee who transports licensed material

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outside the confines of its plant 'or other place of use to comply with the

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anglicable requirements of the Department of Transportation in

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41 CFR Parts 170 through 189.

i The inspector reviewed the records of , shipments of radioactive material

from the facility made between September 1986 through February 1987.

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No violations or deviations were identified.

5. Radiation Control (83743)

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a. Posting of Notices

10 CFR 10.11 requires' the licensee to post Form NRC-3, the license

and other pertinent' information. If posting a document was not

practicable, the licensee may post a notice which describes the

document and states where it may be examined. During tours of the

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facility, the inspector verified that entrances to and from areas

where licensed activities were conducted were posted with the

l required documents or a notice describing the document and where it

may be examined.

No violations or deviations were identified.

b. External Exposure Control

I

(1) 10 CFR 20.101 specifies the applicable radiation dose-standards.

The inspector reviewed records of individual radiation exposures

for the calendar year 1986 through' February 1987. All radiation

doses recorded for plant personnel were well within the

quarterly limits specified in 10 CFR 20.101(a).

(2) Technical Specification (TS)6.4.b states that written

procedures shall be provided and utilized for radiation and

radioactive contamination control.

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Health Physics Procedures (HPP), Revision 7, September 1985, l

i Section 8 requires any work involving (1) entry -into a High I

Radiation Area, (2) modification of biological shielding around

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the reactor and/or (3) penetration of any port hole in the )

i biological shield to be authorized by a RWP.

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The inspector reviewed RWPs written for work in the containment

building from August 1986 through March 1987. RWP No. 6355

issued on September 9,1986, for irradiations using the thermal

neutron column required that Health Physics (HP) monitor the job

l from start to finish. In discussion with licensee personnel, 1

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the inspector determined that an' experimenter failed to notify 1

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HP' that the irradiation was being performed. , The experimenter

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had performed his own monitoring when opening the shutter of the

thermal column.- The licensee ~ stated that-in

dose rates of 100 millirem per hour (mr/ hour)ganna general, average

radiation -

and one mr/ hour neutron radiation were generated when the

l-. neutron shutter in the biologicalLshield was' opened, thu's

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creating a High Radiation Area.-

L Failure to - follow instructions' specified on the RWP was -

identified as an apparent -violation of -TS 6.4.b

,

(50-160/87-03-01).

c. 10 CFR 20.201(b) requires each licensee to make or cause to-be

made such surveys as may be necessary for the licensee to comply .

i with the regulations in 10 CFR Part 20 and are reasonable:under-

~t he circumstances .to evaluate the extent of radiation hazards

,

that may be present.

, 10 CFR 20.201(a) defines a survey to mean an evaluation ofl the

radiation hazards incident to the production, use, release,

disposal, or presence of radioactive materials or other. sources

of radiation under- a specific ~ set of- conditions.

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When

appropriate, such evaluation includes a-physical survey of the

location of materials and equipment, and measurements of levels

j of radiation or concentrations of radioactive material present.

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During tours of the facility the inspector observed personnel-

monitoring themselves for contamination preparatory.to exiting

the Reactor Control Zone (RCZ). The inspector noted-that while

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a monitoring device was available for use, personnel exiting

through the vestibule doors at the back entrance of.theifacility

, failed to perform self-monitoring. During discussions with the

! licensee it was also ascertained that personnel on occasion

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exited the facility by1 the vestibule doors ' and left the

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restricted area by the back gate. . Personnel monitoring was not

performed. The licensee stated that the frisker had been placed -

j by the back door in case someone wanted to self monitor but that I

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frisking at the vestibule exit from the .RCZ had never been -  :

i required.  !

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f Failure of licensee personnel to monitor - themselves for

, contamination prior to exiting the ~RCZ was identified as an

apparentviolationof10CFR20.201(b)'(50-160/87-03-02). i

d. HPP, Revision 7, Septrl.wr 1985, Section 6.'d requires all

i personnel entering the - RCZ to. wear appropriate personnel

monitoring devices as designated and supplied by HP. -

Section 7.1.a requires regularly assigned personnel to wear film i

i badges or other monitoring devices capable of detecting beta,

} gamma and neutron radiations at all times when inside the RCZ.

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, At the entrance to ' the RCZ the inspector. observed a posted

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notice which stated;that all personnel entering -the area must *

wear one film badge and one thermoluminescent dosimeterL{TLD).

During a review'of HP techniciar, log books the inspector noted

.that instances of personnel entering the RCZ without dosimetry

. were documented. These 'ocenrred on August 8, November 3 and -

i November 18, 1986. Discussions with ' licensee! representatives

revealed that on two occasions, the same . individual: had failed

' to wear dosimetry.

i Failure of licensee' personnel; to wear required dosimetry :in the

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RCZ was . identified as an! additional example of an apparent

violation of TS 6.4.b (50-160/87-03-01).

The NRC Enforcement Policy,10 CFR 2, Appendix C,1986 states

that a Notice of Violation .will generally not be issued for.

violations identified by the licensee if- (1) it-was identified -

by the licensee; (2) it fits in Severity Level IV or V;'(3) it.

was reported, if required; (4) it was or will be corrected,-

including measures to prevent . recurrence, within a reasonable

! time, and (5) it was not a violation' that could reasonably be 3

t expected to have been prevented by the -licensee's: corrective

i actions for a previous violation,

i The inspector reviewed the corrective action taken by the

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licensee. The licensee stated that'the individual involved on 1

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! each occasion was requested' to leave. the RCZ to obtain the

! appropriate dosimetry. One licensee representative stated that

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the Radiation Safety Officer (RS0) may have been notified. '

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Corrective action to prevent recurrence was not documented by

i the licensee and through ' discussions .with 'the licensee- the

inspector' detennined that no corrective action program was in

place for the facility. The licensee stated that at one time a-

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Report of Violation of Health Physics Procedures Form 'was

i completed in such instances which required the individual's

! supervisor to specify the corrective action taken. These forms

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had not been used in several years -and no other mechanism had

i been adopted to replace this extinct system.

The inspector informed - the licensee that due to' the above

factors, that failure of licensee personnel to wear required

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dosimetry in the RCZ would not be considered licensee

identified.

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e. . HPP, Revision 7, September 1985, Section 7 states that it is

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mandatory for all persons having access to the' Nuclear-Reactor

Control Zones to comply with HPPs and the Georgia-Institute of

Technology (Ga. Tech) Radiation Safety Manual.

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Ga. Tech Radiation Safety Manual, September 1986, Section

IV.F.1.b states that protective clothing appropriate to the

conditions shall be worn at all times when working with loose

radioactive materials.

HPP, Revision 7, September 1985, Section 6.j states that

clothing used to prevent the spread of radioactive material

shall not be worn in clean areas. Section 10 further states

that protective clothing provided for radiological safety shall

not be worn for any other purpose and shall be removed when

passing from a contaminated area to a clean area.

During tours of the facility the inspector observed the

protective clothing stored inside the RCZ which was available

for use by personnel. In addition shoe covers were available at

the boundary of each roped off contaminated area. Discussions

with licensee representatives revealed that personnel sometimes

failed to comply with protective clothing requirements. The

licensee stated that these instances were not always documented

since there was no requirement for documentation, but on

occasion, such instances may be recorded in the HP technician

daily log book. The inspector reviewed the daily log books for

1986 and found that on April 29, 1986, two individuals had been

observed in the hallway (a clean area) of the Nuclear Research

Center Building (NRCB) dressed in protective clothing while on

March 19, 1986, one individual was observed to have entered a

contaminated area without donning shoe covers.

Failure to remove protective clothing prior to entering a clean

area and failure to wear protective clothing appropriate to the

conditions were identified as further examples of apparent

violationsofTS6.4.b(50-160/87-03-01).

The licensee stated that the two individuals found in clean

areas wearing protective clothing, were students and that they

had been reminded of the appropriate areas for wearing

protective clothing. No corrective action was documented or

remembered for the March 19, 1986 event. Review of other HP

records, i.e., personnel files, Monday morning meeting minutes,

etc., did not reveal any further corrective actions. In neither

case were comprehensive corrective action taken to ensure that

all personnel were aware of protective clothing requirements.

Due to deficiencies in licensee's corrective actions, the

inspector informed the licensee that the above finding would not

be considered licensee identified,

f. 10 CFR 20.203(f)(1) and (3) require each container of licensed

material to bear a durable, clearly visible label identifying

the radioactive contents when licensed material is present in

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quantities greater than the applicable quantities specified in ~

' Appendix C of 10 CFR Part 20.

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i 10'CFR 20.203(f)(2) specifies that the above label shall: bear

i. the' radiation caution symbol and the words:: " Caution -(or

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Danger), Radioactive Material," and shall provide sufficient

i information .to permit individuals . handling or using - the

! containers, . or working in the vicinity thereof, . to take'

precautions to avoid or minimize exposures.

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j In. discussions with licensee personnel the inspector ascertained

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that -on June 2, '1986, a sample of material -which had been

irradiated . in the . reactor was removed from the containment

building to the decontamination room where.it was.left unlabeled >

and unattended. It was discovered by HP and was found t read

2 90 mr/ hour at contact with the external surface of the

f container. The length of time the container. remained in the

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- decontamination room was estimated to be approximately one hour.

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The inspector was informed that the quantity of radioactivity

! within the container was approximately 15 microcuries -of Na-24

! and therefore represented a quantity greater than that specified

in 10 CFR 20, Appendix C.

Failure to label each container of. licensed material as required -

j was identified as an apparent violation of 10 CFR 20.203(f)

j (50-160/87-03-03). The apparent violation was not~ considered

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licensee identified due to failure to take corrective action.

g. Irradiation of Experiments

i (1) Procedure 3102, Quality Assurance (QA) for Experiments,

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October 28, 1982,Section II.B states that all experiments

must be initially reviewed and approved by Georgia

Institute of Technology Research. Reactor.(GTRR) management

via the Experiment Approval Fom (EAF).

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, Procedure 3100, Experimenter's Checklist, Revision 1

July 11, 1986, requires ' the experimenter to list 'any

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j changes in the experiment from those specified on the EAF.

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l The -inspector reviewed a letter written on September 26,

i 1986, from P. B. Sharpe . to .the RSO concerning flux

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measurement experiments performed between August 20 and

i September 23, 1986. Documentation for these experiments,.

! Experiment Approval Form, and the accompanying RWPs, were

! reviewed by the inspector. The experiments approved by EAF I

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No. R6832 were measurements of flux rates using bare and Cd ~

j covered indium foils and TLD chips in beam ports H-9,-H-11 ,

and H-13 for 10 minutes at a reactor power level up to one

megawatt. RWP Nos. 6349, 6351', 6352 and 6359, were issued -

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for irradiations on August 20, August 29, September 4 and

September 23, 1986, respectively.

The inpector compared the beam ports used for the

irradiations as specified on the RWPs with those authorized

by EAF No. R6832. EAF No. 6832 authorized use of beam

ports H-9, H-11, and H-13. Beam ports specified on the

RWPs were H-8, H-9, H-12 and H-13. Discussions with

licensee representatives verified that the beam ports used

for the irradiations were those stated on the RWPs.

The use of unauthorized beam ports for the above

experiments had been brought to the attention of -the

Director of the facility via the letter specified above and

an. approval after-the-fact was generated for . the

experiment. Facility personnel were notified by memorandum

from the Director dated October 1,1986, that to ensure

against recurrence, all future RWPs issued for the reactor

would require the Director's approval. All personnel at

the facility initialed the memorandum as having read the

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notification. The inspector reviewed all RWPs issued for

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the reactor since October 1,1986, through March 31,-1987.

Of the 51 RWPs that had been issued..nine had received the

Director's approval. The inspector discussed this matter

with the Director who stated that insufficient oversight

had been exercised.

Failure to comply with the conditions specified on

EAF No. 6832 was identified as an additional example of an

apparent violation of TS 6.4 b (50-160/87-03-01). The

apparent violation was not considered licensee identified

in that corrective ' action was not carried out and

recurrence of similar problems was observed

(Paragraph 5.g.2).

The conduct of experiments was discussed with licensee

representatives who stated that reactor experiments were

controlled by a quality assurance (QA) program which was

designed to ensure reactor and personnel safety. The

primary means of implementing the QA program was through

the Experimenter's Checklist, Procedure 3100, which

required the experimenter and/or operator to certify that

i the proposed experiment meets the requirements specified by

the EAF.

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The inspector reviewed the Checklist that had been

completed for the irradiation performed under EAF

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No. R6832. Item D on the Checklist required that any

changes in the experiment from that specified on the EAF be

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listed. No changes to the irradiations perfonned on

August 20 and 29, and on September 4 and 23,1986, were

listed on the Checklist even though beam ports not

authorized by EAF No. R6832 were to be used.

Failure to specify changes to approved experiments on the

Experimenter's Checklist was identified as an additional

example of an apparent violation of TS 6.4.b

(50-160/87-03-01).

(2) Procedure 3100, Pneumatic Tube Transport System Operation,

Revision 1, October 10, 1974, Paragraph A.1 requires

completion of an EAF.

Procedure 3100, Experimenter's Checklist, Revision 1,

July 11, 1986, specifies the necessary checks that must be

completed in order to certify that an experiment meets the

limitations specified by the EAF.

Procedure 3102, Quality Assurance for Experiments, October

28, 1982, Paragraph II.0.1.d states that a radiation level

near the rabbit port at the time of sample removal from the

rabbit port will be recoroed on .the Schedule Form

(Experimenter's Checklist).

On April 6,1987, an indium foil was inserted in the

reactor via a plastic rabbit. The reactor ..ad been

operational at one megawatt and was shut down immediately

prior to insertion of the rabbit. After completion of the

irradiation, the operator returned the rabbit to the

receiving station located in a laboratory in the NRCB. An

alarm sounded which was heard in the HP office by the RSO

who investigated. The alarm originated from a RM-14

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located approximately six to eight feet from the receiving

station. While no actual measurement of the dose rate had

been performed, the RS0 stated that had the dose rate been

of a significant level, the radiation monitor in the

hallway would have alarmed. The RS0 estimated that the

activity of the activated experiment had' been 20,000 cpm.

The inspector observed the RM-14 near the rabbit receiving

station and noted that the background radiation levels were

sufficiently high to necessitate that the instrument be set

on its highest scale. Consequently an alarm of the

instrument would correspond to activity in excess of

50,000 counts per minute. The licensee stated that no dose

rate measurements had been made and that on the date of the i

irradiation, no dose rate instrument had been available in

the room containing the rabbit receiving station to perform i

such measurements. l

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Failure to adequately evaluate the extent of the radiation

hazard that may have been present was identified as a

second example of an apparent violation of 10 CFR 20.201(b)

(50-160/87-03-02).

The inspector reviewed the documentation covering the

indium foil irradiation. During discussions concerning the

applicable EAF, the licensee stated that indium foils were

routinely irradiated, and after examining EAFs in the

office files concluded that approval may have been

authorized under either EAF No. 5371 or EAF No. 5441.

The inspector reviewed the reactor operator's daily log to

determine which EAF number had been assigned to the

irradiation and noted that no entry concerning the

experiment had been made. The inspector also determined

that the Experimenter's Checklist, completion of which is

required for all irradiations and which requires listing of

the EAF number, was not completed for the indium

irradiation of April 6, 1987.

Failure to receive authorization for the experiment via an

EAF and failure to certify that an experiment meets the

limitations of the applicable EAF were identified as

additional examples of apparent violations of TS 6.4.a

(50-160/87-03-01).

In addition to radiation level measurements required at the

rabbit receiving station, Procedure 3012 required that

radiation levels near the rabbit port at the time of rabbit

removal be documented. The purpose of taking the radiation

level measurements at the rabbit exit port was to notify

the experimenter at the rabbit receiving station of the

radiation levels to expect upon the rabbit's arrival. The

licensee stated that a radiation level had not been taken

on April 6,1987, and that past experience in irradiation

of similar foils made the measurement unnecessary.

Failure to perform radiation level measurements near the

rabbit port at the time of sample removal was identified as

an additional example of an apparent violation of TS 6.4.b

(50-160/87-03-01). I

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HPP, November 1983, Section 15.4.d.1 states that all

personnel not in the containment building will evacuate the

NRCB immediately upon sounding of the criticality alarm.

During reviews of HP technician logbooks, the inspector

noted that on May 1,1985, the criticality alarm sounded

and the NRCB was evacuated. A team entered the NRC8 to

ameliorate / investigate the emergency, and upon re-entry,

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the team discovered that one individual had not evacuated

upon sounding of the alarm. The individual was required to

leave the building.

Failure to evacuate the NRCB upon sounding of the

criticality alarm was identified as an additional example

of TS 6.4.b (50-160/87-03-01). The apparent violation was

not considered licensee identified due to failure to

implement corrective action.

1. The inspector also noted recorded in the HP technician

logbook several instances of events relating to the

security of the facility. On March 2, 1986, both the back

gate (entry to the restricted area), as well as the back

door of the facility (the vestibule doors), were left open

and unattended. Other areas of note documented by the

logbooks include personnel failure to wear security badge,

November 18, 1986, and potentially unauthorized persons in

the RCZ on October 7, 1986. The licensee was informed that

these items would be referred to Region II's Physical

Security Section for followup (IFI 5G-160/87-03-04).

6. Inspector Followup Items (IFI) (92701)

(Closed) IFI (50-160/87-02-03) Review results of waste tank replicate

sample radiological analyses conducted by licensee and NRC Region II

laboratories. Results of replicate liquid waste tank samples collected in

February 1987 and analyzed by the licensee and NRC laboratories were

discussed. Comparison of licer.see and NRC results are listed in Table I

with the acceptance criteria detailed in Attachment 1. Licensee tritium

results were variable among the three analyses, a maximum difference of

approximately 50% among the samples; whereas, NRC data were more precise,

a maximum difference of 2.5%. In general, licensee tritium results were

higher than NRC data. The low licensee precision and biased tritium

results may have resulted from failure to remove interfering nuclides from

the liquid waste prior to liquid scintillation analyses. Licensee gross

activity results also were variable and biased low relative to NRC values,

ratios of licensee to NRC values ranging from 0.04-0.80. The licensee

methodology, use of filter paper to collect gross beta-gamma activity,

would fail to collect activity associated with particles less than 0.45

microns in diameter and/or dissolved in the liquid waste. Licensee

representatives stated that they would be conducting a thorough review of

their radiological analyses procedures to improve precision and accuracy

needed to meet technical specification requirements. Furthermore, the

licensee stated that a quarterly interlaboratory comparison of their

analytical methodology would be initiated. The inspector informed

licensee representatives that their actions in this area would be reviewed

during subsequent inspections.

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(Closed) IFI (50-160/86-02-01) Review of respiratory protection program.

The inspector discussed this issue with licensee representatives who

stated that all respirators onsite were for emergency use only and that in

no instance would protective factor credit be. sought for respirator usage.

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TABLE 1 *

Results of Confirmatory Radionuclide Analyses for

Georg ia Institute of Technology Research Reactor, February 1987

SAMPLE TYPE ISOTOPE CONCENTRATION fuCi/ Unit 1 RESOLUTION RAT 10 COMPARISON .

Qcensee  !!!LQ Licensee /NRC

Liquid Waste Tank H-3 8.80 E-5 1.18 1 0.01 E-4 118 0.74 Di sag reement

(Sample 1) Cross Activity 6.63 E-8 2.8 1 0.1 E-7 **NC 0.24 **NC

Co-60 *NA 4.2 1 0.6 E-7 - *NA **NC

Liculd Waste Tank H-3 1.61 E-4 1.21 1 0.01 E-4 121 1.33 Disagreement -

(Sample 2) Cross Activity 1.99 E-7 2.5 1 0.1 E-7 **NC 0.80 **NC

Co-60 *NA 5.2 1 0.6 E-7 - *NA **NC

Li(uid Weste Tank H-3 1,48 E-4 1.21 i O.01 E-4 121 1.22 Ag reement

(Cischarge Sample) Cross Activity 1.11 E-8 2.5 1 0.1 E-7 **NC 0.04 **NC.

Co-60 *NA 4.2 1 0.6 E-7 -

• NA **NCl ,

• NA = Not Applicable = lsotopic Analyses not Required by Licensee

e*NC = Not Compa red Quantitatively = Gross Activity Measurements

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- ATTACHMENT 1

a

CRITERIA FOR-COMPARING ANALYTICAL MEASUREMENTS

This enclosure 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 judgement limits denoting agreement' or disagreement

between licensee and NRC results are variable. This variability is a function of

the NRC's value relative to its associated uncertainty. As the ratio of the NRC

value to its associated uncertainty, referred to in this program as " Resolution"1

increases, the- range of acceptable differences between the NRC and licensee

values should be more restrictive. Conversely,' poorer agreement between NRC and

licensee values must be considered acceptable as the resolution decrqases.

For comparison purposes, a ratio 2 of the licensee value to the NRC value for each

individual nuclide is computed. This ratio is then evaluated for agreement based

on the calculated resolution. The corresponding resolution and calculated ratios

which denote agreement are listed in Table 1 below. Values outside of the

agreement ratios for a selected nuclide are considered in disagreement.

NRC Reference Value for a Particular Nuclide

2 Resolution = Associated Uncertainty for the Value

Licensee Value

2 Comparison Ratio = NRC Reference Value >

TABLE 1 - Confirmatory Measurements Acceptance Criteria

Resolutions vs. Comparison Ratio

.-

Comparison Ratio

for

Resolution Agreement

<4 0.4 - 2.5

4-7 . 0.5 .2.0

8 - 15 0.6 -31.66

16 - 50 0.75 - 1.33

51 - 200 0.80 - 1.25

~

>200 ,

0.85 - 1.18

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