ML20214J673

Insp Rept 50-267/86-17 on 860623-27.No Violations or Deviations Noted.Major Areas Inspected:Water Chemistry & Radiochemistry Programs,Including Organization & Mgt Control,Staffing Qualifications & QA Program

ML20214J673
Person / Time
Site:	Fort Saint Vrain
Issue date:	08/04/1986
From:	Murray B, Nicholas J, Wise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20214J663	List: ML20214J661 ML20214J673
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM 50-267-86-17, NUDOCS 8608150126
Download: ML20214J673 (13)

See also: IR 05000267/1986017

Text

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APPENDIX l

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U.S. NUCLEAR REGULATORY COMMISSION .,

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REGION IV

NRC Inspection-Report: 50-267/86-17 License: DPR-34

Docket: 50-267

Licensee: Public Service Company of Colorado (PSC)

P. O. Box 840

S ?!er, Colorado 80201

Facility Name: Fort St. Vrain Nuclear Generating Station (FSV)

Inspection At: FSV Site, Weld County, Platteville, Colorado

Inspection Conducted: June 23-27, 1986

Inspectors: ,

p/4[r4

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.1, lair Nicholas, S%nior Radiation Specialist Date

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acilities Radiation Protection Section

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Russell Wise, Radiation Specialist, Facilities Date

Radiological Protection Section

Approved: _, F/4//f4

B ne Murray, Ch'ief\ Facilities Radiological Date

rotection Section

Inspection Summary

Inspection Conducted June 23-27, 1986 (Report 50-267/86-17)

Areas Inspected: Routine, unannounced inspection of the licensee's water

chemistry and radiochemistry programs, including organization and management

,

control, staffing, qualifications, training, facilities and equipment, quality

! assurance (QA) program, postaccident samplinh system (PASS), quality

control (QC) of analytical measurements, and radiochemistry confirmatory

measurements.

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8608150126 860G11

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Results: Within the areas inspected, no. violations or deviations'were'

identified. Five previously identified open items were closed.

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DETAILS

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1. Persons Contacted

PSC

• D. W. Evans, Acting FSV Station Manager ,

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F. J. Borst, FSV Support Services-Manager

• D. J. Brown, Instrument and Controls Supervisor

C. H. Fuller, FSV Station Manager J

• A. L. Greenwood, QA Auditing Supervisor - t n

• R. O. Hooper, Technical Training Supervisor

• J. Jackson, QA/QC Supervisor

• M. Lehr, QA Engineering Supervisor

• V. A. hcero, Water Chemistry Supervisor

• V. J. McGaffic, Radiochemistry Supervisor

• P.-F. Poore, QA Technical Support Supervisor

• F. J. Novachek, FSV Technical / Administrative Services Manager

• T. Prenger, QA Services Manager

• L. W. Singleton, Manager, QA

Others .

• R. E. Farrell, NRC Senior Resident Inspector

• Denotes those present during the exit briefing on June 27, 1986.

The NRC inspectors also interviewed other FSV personnel during the

inspection.

2. Licensee Action on Previous Inspection Findings

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(Closed) Open Item (?97/8117-01): Water Chemistry Training Program - This

item involved the licensee's lack of a documented training program for

water chemistry personnel. The licensee had written and implemented a

qualification and training program for FSV water chemistry personnel. The

NRC inspectors reviewed the Training Program Administrative Manual

Procedure TPAM-WC, " Water Chemistry Department Training Program," Issue 5,

May 13, 1986, and found the chemist training checklists satisfactory to

document the chemistry training program. This item is considered closed.

'

(Closed) Open Item (267/8229-03): Confirmatory Measurements - This item

involved the fact that the licensee was unable to analyze an NRC prepared

radioactive face-loaded charcoal cartridge standard sur quantitative

isotopic content with satisfactory agreement to certified values. During

this inspection, the licensee was able to obtain acceptable results on the

charcoal cartridge standard. This item is considered closed.

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-(Closed) Open' Item (267/8421-01): Water Chemistry Organization - This

item involved the lack of the water chemistry section having management

controls and position descriptions which would define responsibilities and

organizational reporting chain specific to FSV. The NRC inspectors  !

reviewed the licensee's revised position information questionnaires for

the positions of chemistry supervisor, senior chemist, chemist, and

chemical engineer and found them specific to job responsibilities at FSV.

The licensee had restructured the FSV organization placing the water

chemistry section under the supervision of the support services manager.

The NRC inspector reviewed the licensee's " Nuclear Policies and

Guidelines," Volume II Organizational Guidelines, issued August 30, 1985,

and various water chemistry procedures which described the organizational

structure and water chemistry responsibilities and found the licensee's

corrective actions satisfactory. This item is considered closed.

(Closed) Open Item (267/8421-02): Water Chemistry Program - This item

involved the lack of a well defined and administered water chemistry

program. The licensee had taken corrective actions including

reorganization of responsibilities, developing administrative procedures.

establishing chemistry system surveillance procedures and chemistry

control procedures, rewriting all chemistry analytical procedures,- and

implementing a QA and instrument calibration program. The NRC inspectors

reviewed the licensee's corrective actions and their results and found a

much improved water chemistry program. This item is considered closed.

(Closed) Open Item (267/8431-01): Environmental Management Controls -

This item involved the lack of the support services manager's

responsibilities and duties associated with the radiological environmental

monitoring program being detailed in Procedure Q-1, " Organization and

Responsibilities," Issue 4, August 27, 1982. The NRC inspectors reviewed

Procedure Q-1, " Organization and Responsibilities," Issue 8, February 13,

1986, and noted that the current procedure states that the support

, services manager is responsible for the radiological environmental

monitoring program. This item is considered closed.

3. Inspector Observations

The following are observations the NRC inspectors' discussed with the

licensee during the inspection and at the exit briefing on June 27, 1986.

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These observations are neither violations nor unresolved items. hese

items were recommended for licensee consideration for program improvement,

but they have no specific regulatory requirement. The licensee stated the

items would be reviewed.

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a. Water Chemistry Personnel Training - The_ licensee had not completely

documented water chemistry staff training as described in the I

training department procedure (see paragraph 6).

b. Water Chemistry and Radiochemistry Programs - The licensee had not

written a procedure for plotting and trending of all chemical and

radiochemical parameters (see paragrapa 7).

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4. Water Chemistry and Radiochenistry Organization and Management Controls

The_NRC inspectors reviewed licensee's organization and staffing of the

water chemistry section (WCS) and radio:-hemistry section (RCS) to

'dete'nine

r compliance with commitments in Sections 12.1 and 12.3 of the

Updated Safety Analysis Report (USAR) and the requirements in Section 7.1

of the Technical Specifications (TS).

The"NRC inspectors verified that the organizational structure of the WCS

and!RCS-were.as. defined in the USAR, TS, and FSV procedures. The NRC

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inspectors reviewed.the FSV management control procedures and position

descriptions for the assignment of responsibilities for the management and

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The

imp NRC

llementation of the

inspectors FSVthat

verified water

thechemistry

administrative and radiochemistry

control programs.

responsibilities specified by the FSV procedures were being implemented.

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The'NRC_ inspectors < reviewed the staffing of the WCS and RCS and noted that

.since the previous 14RC water chemistry /radiochemisty inspection in

August 1984,.the WCS has added two new chemistry technicians and the RCS

, had-lost two radiochemistry technicians to the FSV training department.

. The two radiochemistry technician positions had been filled with qualified

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. personnel. -The licensee's principle staff have remained stable over the

~'past 6 years. 'The staff turnover rate has been less than five percent per

year.

No violations or deviations were identified.

5. Water Chemistry and Radiochemistry Personnel Qualifications

The NRC inspc.ctors reviewed the qualifications of the water chemistry and

radiochemistry personnel to determine compliance with commitments in

Section 12.1.4 of the USAR and the requirements in Section 7.1 of the TS.

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The NRC inspectors reviewed the education and experience backgrounds of

the present water chemistry and radiochemistry staffs and determined that

all personnel met the qualifications specified in the USAR, TS, FSV

procedures, and ANSI N18.1-1971. The NRC inspectors determined that the

licensee had an adequate staff to meet shift staffing requirements.

No violations or deviations were identified.

6. Water Chemistry and Radiochemistry Training Programs

The NRC inspectors reviewed the licensee's water chemistry and

radiochemistry training programs to determine compliance with commitments

in Section 12.2 of the USAR and the requirements in Section 7.1.3 of the

TS.

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The NRC inspectors reviewed the licensee's program for training and

qualification of FSV WCS and RCS personnel as described in the training

department procedures and in the support services manager's administrative

procedures.

The NRC inspectors reviewed the WCS and RCS individual staff training

records and determined that the two recently hired water chemistry

technicians and one recently hired radiochemistry technician were in the

process of completing the required qualification training. The NRC

inspectors noted that not all training checklists have been completed for

all water chemists. It was determined that not all the water chemistry

staff training had been officially documented as described in Training

Program Administrative Manual Procedure (TPAM)-WC. This observation was

discussed with the licensee. The licensee stated they would evaluate the

NRC inspectors' concern and take corrective action as necessary. Progress

made to correct the above observation will be reviewed during future NRC

inspections.

No violations or deviations were identified.

7. Water Chemistry and Radiochemistry Programs

The NRC inspectors reviewed the licensee's water chemistry program and

radiochemistry program to determine compliance with commitments in

Sections 4 and 10 of the USAR and the requirements in Sections 4.2, 4.3,

and 7.4 of the TS.

The NRC inspectors' review of the water chemistry and radiochemistry

programs found that the licensee had revised and approved identified

administrative procedures, surveillance procedures, chemical control

procedures, instrument calibrations and quality control procedures,

sampling procedures, and analytical procedures. A review of selected

,

procedures revised and written since the previous NRC inspection in

l August 1984 indicated that the WCS and RCS had established sufficient

programmatic procedures to meet the requirements of the USAR and TS. The

l NRC inspectors reviewed records of completed chemical and radiochemical

l analyses and determined that the required analyses were being completed as

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scheduled and in accordance with procedure. The review also included

discussions of the recorded trends of the water quality data with water

chemistry personnel. During the review, the NRC inspectors made the

observation that the licensee had not written procedures providing

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direction for plotting and trending chemical and radiochemical data. The

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NRC inspectors reviewed the records of out-of-specification chemical

parameters and the licensee's corrective actions taken when chemical

( parameters had not met established limits. .The NRC inspectors reviewed the -

effectiveness of the water chemistry program to measure and prevent the

introduction of chemical contaminants into secondary water systems and

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found the licensee's procedures adequate. The NRC inspectors held

discussions with WCS and RCS personnel and determined that staff at all

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levels understood the importance and need for water chemistry control.

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The NRC inspectors reviewed the occupational exposure (person-rem) to

plant personnel as it relates to water chemistry control and found no

increased occupational exposure as a result of poor water chemistry.

The NRC inspectors verified that the water chemistry laboratory

instruments and radiochemistry laboratory instruments had been calibrated

according to procedures and an instrument quality control program had been

implemented. FSV participates in the U.S. Environmental Protection Agency

(EPA) crosscheck program and has implemented an internal laboratory

analytical accuracy assessment program using unknown samples of both

non-radiological and radiological chemical components to verify

performance of chemistrv :.nd radiochemistry technicians on analytical

procedures. The NRC in>pectors reviewed the EPA crosscheck results for

1985 and 1986.

No violations or deviations were identified.

8. Facilities and Equipment

The NRC inspectors inspected the facilities and equipment used by the WCS

and RCS staff. The following facilities were inspected: water chemistry

laboratory, radiochemistry laboratory, radiochemistry counting room, and

various chemistry sampling panels. The laboratories were equipped with

the necessary chemicals, reagents, labware, and analytical instrumentation

to perform the required analytical nrocedures. The water chemistry and

radiochemistry facilities and analytical instrumentation appeared to be

adequate to peform rountine chemistry and radiochemistry requirements to

support plant operation.

No violations or deviations were identified.

9. Postaccident Sampling System

The NRC. inspectors reviewed the licensee's PASS to determine compliance

with the requirements of NUREG-0737, Item II.B.3.

The NRC inspectors reviewed the licensee's procedures and equipment to be

used following a reactor incident. The NRC inspectors verified that the

normal sampling points for reactor coolant and containment atmosphere are

to be used and present analytical laboratory instrumentation would be used

to determine required chemical and radiochemical concentrations of the

reactor coolant and containment atmosphere.. The NRC inspectors verified

that the instrumentation and associated procedures satisfied the ,

requirements of NUREG-0737, Item II.B.3, for representativ'e sampling and

analysis of reactor coolant and containment atmosphere following a reactor

incident. The radiochemistry staff have been trained ~and qualified in

operating the PASS equipment and calculating mitigating core damage from

chemical and radiochemical analytical results. The NRC inspectors

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determined that the licensee's procedures and analytical sensitivities of

chemistry and radiochemistry parameters were consistent with PASS

! requirements.

No violations or deviations were identified.

10. Quality Assurance Audit Program

The NRC inspectors reviewed the licensee's QA organization and audit

program regarding water chemistry and radiochemistry activities to

determine compliance with commitments in Section 12.5 in the USAR and

requirements in Section 7.1 in the TS.

The NRC inspectors reviewed the QA department organization, selected QA

l audit procedures, audit schedules for 1985, 1986, and 1987, QA auditor

j qualifications, and audit reports. Audit reports generated from audits

i performed during 1985 and 1986 in the areas of water chemistry and

radiochemistry were reviewed for scope to ensure thoroughness of program

evaluation and timely followup of identified deficiencies. The NRC

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inspectors found the audit plans and checklists were improved and that the

l responses and corrective actions to audit findings were timely and in

l accordance with procedure.

The NRC inspectors reviewed the licensee's progress to close Open

Item 267/8421-03 regarding the use of audit team members with technical .

l expertise in the areas being audited. It was noted that the QA audits, l

especially in water chemistry, were being performed by QA staff who had

, not been formally trained in chemistry / radiochemistry activities and who )

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had no chemistry / radiochemistry experience at a nuclear power facility.

The necessity for future QA audits in water chemistry and radiochemistry to 1

be performed by QA auditors trained or experienced in chemistry and

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radiochemistry at nuclear power facilities was discussed with the licensee

! during the exit briefing. A QA representative state _d_that future audit

teams performing audits of chemistry and radiochemistry activities ~ would

include a member with technical expertise in the area of. the audit. The

NRC inspectors stated that Open Item (267/8421-03) will' remain open

pending the establishment of a QA requirement for audit teams performing

audits of chemistry and radiochemistry to include a technical specialist

with expertise in the area being audited. ,

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No violations or deviations were identified.

l 11. Quality Control of Radiological Analytical Measurements

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l The NRC inspectors reviewed the radiochemistry program for quality control

i of radiological analytical measurements to determine compliance with the

requirements in Section 7.4 of the TS.

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The NRC inspectors reviewed the licensee's records, for the period

August 1984 through June 1986, involving instrument surveillance

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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 Region IV mobile laboratory at FSV during the

inspection:

(1) NRC Particulate Filter Standard (SRS 17818-109)

(2) NRC Face Loaded'Cesco Cartridge Standard (SRS 17816A-109)

(3) Simulated Liquid Radwaste (1 Liter Marinelli Beaker)

(4) Tritium Sample

The confirmatory measurements tests consisted of comparing

measurements made by the licensee and the NRC mobile laboratory. The

NRC's mobile laboratory measurements are referenced to-the National

Bureau of Standards (NBS) by laboratory intercomparisons.

Confirmatory measurements 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 1

contains the criteria used to compare results. *

b. Results.

At the time of the inspection, one detector'was used for comparison

with the NRC results. The licensee performed.the tritium analysis.on

their liquid scintillation counting system. 'The individual sample

analyses and comparison of analytical results 'of the confirmatory'

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measurements are tabulated in Attachment 2.

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L The licensee's gamma isotopic results from'the listed samples in

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Attachment 2 showed 100 percent agreement with the NRC' analysis-

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results. The licensee's tritium result was.in agreement with the NRC

analysis result.

I Confirmatory measurements were performed by the licensee on liquid

samples prepared by the Radiological Environmental Sciences Laboratory

(RESL) in~ Idaho Falls, Idaho.

l The licensee's analytical results were compared to the known sample

activities and the results of the comparisons are presented in

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Attachment 2, samples 5 and 6. The licensee's results were

40 percent agreement for sample 5 analyzed in 1985 and 100 percent

agreement for sample 6 analyzed in 1986.

No violations or deviations were identified.

13. Contractor Activities

The NRC inspectors determined that the licensee was not using contractor

personnel or laboratories to perform chemical or radiochemical analyses.

14. Exit Briefing

The NRC inspectors met with the NRC senior resident inspector and the

licensee representatives identified in paragraph 1 of this report at the

conclusion of the inspection on June 27, 1986. The lead NRC inspector

summarized the scope of the inspection, discussed the inspection findings,

and presented the results of the confirmatory measurements. The licensee

agreed to review the NRC inspectors' observations listed in paragraph 3.

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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 =

" ^

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 .

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16 - 50 0.75 - 1.33

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51 - 200 0.80 - 1.25

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>200 0.85 - 1.18

The above criteria are applied to the following ahalyses:

(1) Gamma Spectrometry.

(2) Tritium analyses of liquid samples.

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(3) Iodine on adsorbers.

(4) 895r and 80Sr determinations.

(5) Gross Beta where samples are counted on the same date using the same

reference nuclide.

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ATTACHMENT 2

CONFIRMATORY MEASUREMENTS RESULTS

1. Particulate Filter Standard (SRS 17818-109)

(Standardized 13:45 MST, June 24, 1986)

No quantitative comparisons were made, due to differences in preparation of

calibration standards. The licensee utilizes a calibration standard with

a smaller total active area.

2. Charcoal Cartridge Standard (SRS 17816A-109)

(Standardized 13:45 MST, June 24, 1986)

PSC Results NRC Results PSC/NRC Comparison

Nuclide (uCi/ sample) (uCi/ sample) Ratio Decision

109

Cd 6.7212.08 E-01 6.5110.02 E-01 1.03 Agreement

57

C0- 6.9111.47 E-03 7.4010.04 E-03 0.93 Agreement

139

Ce 4.5611.15 E-03 5.5310.04 E-03 0.83 Agreement

113

Sn 6.7711.70 E-03 7.9010.08 E-03 0.86 Agreement

137

Cs 3.8310.81 E-02 4.3110.02 E-02 0.89 Agreement

88

Y 9.6212.94 E-03 1.0510.01 E-02 0.92 Agreement

60

Co 3.6510.70 E-02 4.1110.02 E-02 0.89 Agreement

3. Waste Liquid (1 liter Marinelli Beaker)

(Sampled 13:45 MST, June 24, 1986) ,

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PSC Results NRC Results iPSC/_NRC -Comparison-

Nuclide (uCi/ml) (uCi/ml) Ratio .

Decision

131

1 6.0911.44 E-05 6.2710.03 E-05 0.97 Agreement

137

Cs 4.7811.01 E-05 4.8510.04 E-05 ' 0 . 9 91 Agreement

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Co 3.4910.65 E-05 3.57 0.04 E-05 0.98 ' Agre'ement-

Tritium Sample

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4.

(Sampled 12:35 MST, June 20, 1986)

PSC Results NRC Results PSC/NRC. Comparison

Nuclide (uCi/ml) (uCi/ml) Ratio Decision

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H 1.20 E-01 1.18 E-01 1.02 Agreement

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-5. RESL Liquid Sample *

(Standardized 12:00 MST, January 11,1985)

PSC Results NRC Results 1 ' PSC/NRC Comparison

-Nuclide~ (uCi/ml) (uCi/ml) Ratio Decision

3

H 2.05 E-05 3.4810.07 E-05 0.59 Disagreement

89

Sr 1.45 E-04 1.4710.05 E-04 0.99 Agreement

90

Sr 1.62 E-05 1.6110.06 E-05 1.01 Agreement

.137

Cs < LLD 7.2610.15 E-06 -

Disagreement

60

Co < LLD 6.4910.13 E-06 -

Disagreement

6. RESL Liquid Sample

(Standardized 12:00 MST, January 11, 1986)

PSC Results NRC Results 1# PSC/NRC Comparison

Nuclide (uCi/ml) (uCi/ml) Ratio Decision

3

H 7.82 E-05 8.9210.18 E-05 0.88 Agreement

89

5r 1.29 E-04 1.1210.03 E-04 1.15 Agreement

90

Sr 1.28 E-05 1.0610.04 E-05 1.21 Agreement

55

Fe 7.01 E-05 6.6210.13 E-05 1.06 Agreement

137

Cs 1.8110.38 E-05 1.7310.05 E-05 1.05 Agreement

60

Co 1.5910.30 E-05 1.5410.03 E-05 1.03 Agreement

54

Mn 1.1010.20 E-05 1.0710.02 E-05 1.03 Agreement

1/ NRC results were taken from the standard certification supplied to the

Region IV office as prepared by RESL and traceable to the National Bureau

of Standards.