IR 05000333/1987018

Health Physics Appraisal Rept 50-333/87-18 on 870615-19.No Violations Noted.Major Areas Inspected:Licensee Radiation Protection Program,Including Radiation Protection Organization & Staffing,Exposure Control & ALARA Program

ML20237F949
Person / Time
Site:	FitzPatrick
Issue date:	08/06/1987
From:	Cioffi J, Dragoun T, Kottan J, Lequia D, Loesch R, Shanbaky M, Struckmeyer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20237F915	List: IR 05000333/1987018 ML20237F912
References
50-333-87-18, NUDOCS 8708210622
Download: ML20237F949 (32)

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U.S. NUCLEAR REGULATORY COM',.ISSION

REGION I

Report N /87-18 Docket N License N DRP-S9 Priority -

Category C Licensee: Power Authority of the State of New York 10 Columbus Circle New York, New York 10019 Facility Name: James A. FitzPatrick Nuclear Power Plant Inspection At: Scriba, New York Inspection Conducted: June 15-19, 1987 Inspectors: ~/ Jh me or k'472 T. Dras Senior Ra'diation Specialist dafd ~~ '

+ 6R- eh/r, '

i J ./ ioffi, Rad 'attion Specialist da te'

d ~. d ! _O " 07 J. Kottan, Laboratory Specialist datd /

b -uT 'd] < 8lYl81 t. D. LeQuia, Radiation Specialist date

) .u12~ tlN - */- 8/4//7 R. Loesch, Radiation Specialist date

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l N' i g . Struckmey6r, Radiation Specialist b/f &}

dge /

Approved by: .// m u c 2 M.Shan%ky, hief,Fhcj/itiesRadiation dat'e' ~ i ProtectM ection (Inspection Team Leader)

8708210622 8708f9 i DR ADOCK0500g3 j

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Inspection Summary: Inspection on June 15-19, 1987 (Report Number 50-333/87-18).

Areas Inspected: Special, announced Health Physics Appraisal to evaluate the i licensee's Radiation Protection Program. Areas reviewed were: radiatio protection organization and staffing; personnel selection, qualification, and training; exposure control; radioactive waste management system; ALARA program; facilities and equipment; chemistry program; and whole body counting progra Results: No violations were identified. Program weakness and strengths were identified and discussed in this Inspection Report.

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Persons Contacted The following personnel attended the exit interview on June 19, 1987:

Licensee Personnel R. Burns, Vice President, Nuclear Operaticas R. Converse, Resident Manager W. Fernandez, Superintendent of Power D. Lindsey, Operations Superintendent E. Mulcabey, Radiological & Environmental Services Superintendent V. Walz, Technical Services Superintendent H. Keith, Instrumentation and Controls Superintendent G. Vargo, Radiological Engineer J. Solini, Health Physics General Supervisor T. Bergene, ALARA Supervisor J. McCarty, Radiation' Protection Supervisor l K. Szeluga, Radiation Protection Supervisor '

R. Patch, Quality Assurance Superintendent J. Allingham, Director, Operational Appraisal NRC Personnel A. Luptak, Senior Resident Inspector

, H. Abelson, NRR Project Manager During the course of this appraisal, additional personnel were contacted or interviewe .0 Radiation Protection Organization and Staffing 1.1 Organization The organization of the Radiological & Environmental Services (RES)

Department, as specified in RES Department Standing Order No. 3, Rev. 6, is shown in Figure This Standing Order, in conjunction with Chapter 3 of the Radiation Protection Manual, " Organization and Responsibilities," provides a well defined management structure with clear assignment of respon- q sibilities and authoritie Included in these authorities is the i ability to issue Stop Work Orders. This authority extends from the RES Superintendent (designated as the Radiation Protection Manager as defined in Regulatory Guide 1.8) and downward through the organi- ,

zation to the RES technician The RES Superintendent reports directly to the Superintendent of Power, who has the responsibility to implement, direct and support plant and corporate radiation protection policy throughout the oper-ational organization. He is also responsible for establishment of radiation protection goals and objectives for the plant and ensures overall commitment to these goal j

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RES Department Organization i Superintendent of Power Radiological and Environmental Services Superintendent Emergency Planning Coordinator Ass't. Radiological and Environmental Ass' Service Superintendent l Chemistry Health Physics Radiological J General General Supervisor Engineer Supervisor Radiation Radiation Protection Protection Supervisor Supervisor

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l Chemistry /

Environmental Dosimetry ALARA Radiochemistry Supervisor Supervisor Supervisor Supervisor

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Figure 1  ;

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As e further organizational enhancement to safety, the RES Super-intendent and through him the Health Physics General Supervisor have Cirect access to the Resident Manager (a member of the Corporate Staff located on-site) to prevent unsafe practices or to resolve radiological concerns. In addition, the RES Superintendent is permitted to go outside the James A. FitzPatrick (JAF) Plant organization to higher levels of New York Power Authority (NYPA)

Headquarters (Senior Vice President - Nuclear Generation) Management with his recommendations of corrective actio Frequent involvement in technical support for the Radiation Protection Program is provided by an offsite (i.e., Corporate)

Radiological Health and Chemistry Group, whose manager, a Certified -

Health Physicist, reports to the Vice President - Nuclear Suppor This group provides technical expertise in chemistry and radiological health problem Personnel from this group spend approximately 20%

of their time at the plant coordinating special project During the last outage, one Radiological Engineer from this group was detailed to the station as an Assistant Radiation Protection Superviso l Additional corporate oversight of RES Department activities is 4 provided by the Department of Appraisal and Compliance Services. The I Operational Appraisal section of this department conducts ongoing, programmatic reviews of radiological, chemical and environmental

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program elements. These evaluations, which go beyond merely

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compliance-incorporating industry good practice, are broken up into l twenty modules that provide a systematic review of the entire program approximately every two years. The Director of this section is also a Certified Health Physicis Communication mechanisms between the RES Department and other departments, as well as within the RES Department, appeared i effective. Numerous planning meetings are routinely held to ensure i

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the smooth and orderly flow of information throughout all levels of the plant staf Furthermore, the recent promotion of the Environmental Supervisor to Health Physics General Supervisor provided improved communication pathways from the RES Superintendent to the RES technician During the previous Health Physics Appraisal at JAF (see Inspection Report No. 80-20), weaknesses relative to the documented responsibil-ities of the Assistant RES Superintendent (ARESS) and the Radiation Protection and Radiochemistry Supervisor (RPRS) were observe Specifically, the previous appraisal found the position descriptions so generalized that it was not possible to establish from Standing Order No. 3 what . specific duties had been assigned to the Inspec-tor review of the revised Standing Order, Rev. 6, and Chapter 3 of the Radiation Protection Manual, Rev. O, determined that the position description for Assistant RES Superintendent clearly defined his radiological control responsibilities, but did not address his responsibilities relative to his oversight and involvement with the

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chemistry progra This was recognized by the licensee, who stated i that these responsibilities will be incorporated into a Chemistry Manual which is currently being developed. Relative to the RPRS position description, this job title has been deleted, with reassignment of chemistry responsibilities to the Chemistry General Supervisor and Chemistry / Radiochemistry Superviso Standing Order No. 3 provides appropriate responsibility assignments for these job title I Interviews with RES Department managers, supervisors and technicians indicated that they had an adequate understanding of their individual and group responsibilitie In addition, the support provided from upper management appears effective, especially with the constant corporate presence provided on-site by the Resident Manager. This was considered a strong point by the inspecto One weakness relative to organization charts was identified by the inspector. Specifically, corporate " Tables of Organization" do not accurately reflect the RES organization and associated reporting ,

relationship as depicted on the site organizational r. hart. When this >

was identified to the RES Superintendent, he indicated that he would submit a memo to corporate requesting revision of these tables to make them consistent with site organizational chart Summary i

In general, the RES organizational structure and reporting chain (

appear effective to operate the station during routine, outage and 1 emergency conditions. This structure includes a high degree of l corporate oversight by both the Resident Manager and through frequent I on-site assignments by corporate-based personne In addition, !

position descriptions and responsibilities for most RES personnel were clearly define "

1.2 Staffing

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Since the Health Physics Appraisal in 1980 (Inspection Report N I l 80-20), the licensee has added a number of RES technicians'to their i staf The following table provides a comparison of staffing levels )

present during these two appraisals: j l

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l PASNY Employees 1980 1987 Classification Number Number Senior *(I) 4 7 C*(I) 3 19 B(I) 4 7 A(I) 1 0 Contractor Technicians Classification Senior *(2) 8 6 Jr 5 2

• Personnel who qualify as " technician" under ANSI N18.1-197 Note (1): The licensee is currently in the process of phasing out technician A, B, C and Senior classifications in favor of Apprentice, Journeyman and Chief Journeyman techni-clan titles, while completely eliminating technician A position Note (2): Not equivalent to PASNY Senior technician, who functions as a Lead or Chief technician, providing first-line supervision.

l While the number of technicians has increased substantially, so has the scope of responsibilities assigned to the RES Department. This j has resulted in a shortage of day-shift technicians, with only two technicians being available for routine coverage, augmented by one relief-crew technician (backshift coverage continues to be provided by one (1) chemistry and one (1) radiation protection technician).

Furthermore, the recent addition of five technicians to the RES staff did not alleviate this condition as they were assigned on a priority basis to the chemistry group to upgrade that area. Consequently, the licensee has had to rely on extensive use of contractor technicians, j

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with an average of seven (7) required during 1986, and eight (8)

technicians and a clerk thus far in 1987, to assure that assigned work is at least minimally covered. To the licensee's credit, they have recognized the need for additional staffing. Inspector discussions with the RES Superintendent revealed that five (5)

additional technicians, dedicated to radiation protection, will be proposed in next year's budget. This should help to relieve tech-nician shortage i As a direct result of RES Department staffing shortages, on-the-job training for the new Apprenticeship Program has been delaye Technicians are not making the expected rate of progress in this program due to a lack of personnel to train the In addition, cross-training between sections of the RES Department cannot be effectively accomplished due to insufficient personnel to perform surveillance while cross-training is being conducte This lack of management attention to training has produced weaknesses in RES Department technician and supervisory knowledge. Inspection ques-tioning of these individuals found them to be weak in Health Physics theoretical knowledge and the technical bases for the activities they perform. The additional RES staffing being proposed for the 1988 budget should bring about improvements in this are Relative to technician staffing during outages, the inspector found that excessive technician overtime was being used. In general, technicians averaged approximately 400-600 hours of overtime during a recent ninety-seven (97) day outage. However, at least one tech-nician was allowed to work sixty-eight (68) consecutive days at twelve (12) hours per day (totaling 830 hours0.00961 days <br />0.231 hours <br />0.00137 weeks <br />3.15815e-4 months <br /> of 0.T.). Plant Standing Order No. 26, " Overtime Policy," Rev. 4, states that radi-ation protection personnel "should not be permitted to work more than j ... seventy-two (72) hours in any seven (7) day period." This policy

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was waived for RES technicians during the recent outage, with many

, technicians routinely exceeding the NRC established guidelines.

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During inspector discussions with the Resident Manager, he indicated l that this poor practice would not be continued in the future, At the time of this appraisal, the licensee had eleven (11) more l professional / supervisory staff than during the last appraisal, bringing the total to thirteen (13). Two (2) of these individuals are Senior Reactor Operators (SRO) qualified, and provide integrated plant operating experience to the Radiation Protection Program. In addition, broad Health Physics technical knowledge is readily ;

available within the Department, as the RES Superintendent and !

Radiological Engineer are both Certified Health Physicists. It was noted by the inspector, however, that radiation protection super-visory resources for outage conditions appeared to be very limite '

! Specifically, only two full-time individuals, knowledgeable and experienced in plant systems and radiological hazards, are available to supervise outage radiological control activities. The licensee

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has attempted to supplement these supervisors through the use of '

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contractor and corporate personnel assigned as Assistant Radiation Protection Supervisor:. However, these individuals were not brought on-site early enough to provide them with sufficient time to become knowledgeable of plant specific systems, programs and personnel.

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This weakness was discussed with licensee management, who indicated

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that they would evaluate the need for more Radiation Protection Supervisors and/or lead time for temporary personnel to ensure adequate oversight of the Radiation Safety Program during outag , Inspector review of " Exempt Position Descriptions" for station RES l l professional / supervisory staff found them to be of good quality, with a concise listing of " principle accountabilities." Two exceptions to this were the descriptions for the Assistant Emergency Plan Coordinator and the Radiation Protection Supervisor (RPS). Position descriptions for these individuals were not accurate reflections of their responsibilitie For example, the position description for i

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the RPS did not include such items as Respiratory Protection, Radio-active Material Shipping and Radwaste (i.e.,10 CFR 61 classification i of waste), all of which are part of routine RPS responsibilities.

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descriptions and make appropriate changes to the principle account-abilities sectio As indicated in section 1.1, corporate staff is frequently involved )

with plant activitie Two specific corporate groups, Radiological I i Health and Chemistry and Operational Appraisal, are routinely l

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involved to provide support to and oversight of the Radiation Safety Program. The composition and function of these groups is described below.

, The Radiological Health and Chemistry group functions as a technical l resource for the plan Research and investigation into complex l chemical or radiological problems are conducted as well as project t

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management for assigned tasks. Staffing of the group is composed of ,

Nuclear Engineers, Chemical Engineers, Radiological Engineers and j Radiological Specialists. During the week of the appraisal, the inspector observed that one of the radiological engineers was onsite, involved in a HVAC project.

l The Operational Appraisal group ,rovides oversight and evaluation of {

the Radiation Safety Program. Their function includes not only

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compliance to regulatory requirements, but also includes industry i standards and good practices to improve the program. Staffing of !

this group includes: 1 Chemistry, 1 Environmental and 1 Radiological j Appraisal Specialist. However, there has been staffing problems relative to maintaining a qualified individual in the position of Radiation Appraisal Specialis Through a lack of timely and aggressive action to fill this position, it'has remained vacant for approximately the last six (6) months. Furthermore, additional investigation by the inspector determined that this position has only been filled approximately one-half of the time since it

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. 10 was establishe Inspector discussions with licensee corporate and station staff could not identify any problems which prevented this position from being filled in a more timely manner.

l Summary Staffing at the RES technician and supervisory level for routine and outage conditions is very limite This has resulted in the use of excessive overtime, specifically to support outage activities. As a result of these staffing problems, RES technician progress in the Apprenticeship Program has not been at the rate expected. Inspector questioning of technicians and supervisors found them to be weak in theoretical health physics knowledge and their knowledge of the technical bases for the activities they perform. Corporate staff involvement with the program is excellent, with the exception of the Sr. Appraisal Specialist - Radiological, whose position has remained vacant for extended periods of time because of lack of timely and aggressive action by management to fill i .0 Personnel Selection, Qualification, and Training 2.1 Selection Criteria

, Technical Specification 6.3 requires that the plant staff meet or I

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exceed the minimum qualifications of ANSI N18.1-1971 for comparable position Each staff position in the RES department has an Exempt Position Description which incorporates the ANSI training and experience requirements. The Position Descriptions retain the ANSI l requirement for 5 years of experience but enhance the training

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requirement to include a bachelor degree. However, the college '

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degree requirement is frequently waived for staff members such that only the minimum ANSI requirements are met in practic i The Exempt Position Descriptions provide a thorough and clear description of the responsibilities for most position Most were issued in 1982 and continue to be valid since no reorganization has ,

occurred. Candidates for open positions are initially screened by the Human Resources Department using the requirements stated in the position description. The final decision rests with the hiring superviso For the past several years, it appears that most open positions have been internally filled by promoting technicians or !

reassignment of site personne .2 Qualification Criteria There is an extensive qualification program for RES technicians which is referred to as the " Apprentice Program." Progress in this program is tracked via signatures on a " Qualification Card" which is broken down into six sections:

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Specialty Items A few hundred signatures by various instructors are required to J complete this card. Each line item on the Qualification Card has an associated " Qualification Standard" which specifies the detailed knowledge required to satisfy the requiremen '

This program was initiated in 1984 and was invoked as a requirement for all existing as well as recently hired technician The class-room training and testing has been scheduled over a four year period, j All technicians attend one week of instruction each six work week j Although senior technicians on staff in 1984 must participate in this program, many of the qualification requirements were grandfathered or waived for this group. However, they must attend the classes and pass the quizzes.

l l There is no formal qualification program for RES supervisors. In l 1986 a training program (Indoctrination and Training Procedure - ITP

1. 11) was developed for the entire plant supervisory staff. A four week session was planned to acquaint the supervisors with general plant systems and operations. The program, published in February 1987, has not been offered nor has a firm schedule been se l The training department has also identified specific training needs '

for each supervisor based on job task analysis. Like ITP #11, this i program has not been implemente An on-site Quality Assurance department has been conducting annual audits of staff qualifications in accordance with Technical Speci-fication 6.5.2.8. Previously, the audit only included the RES Superintendent. At NRC request, the audit was expanded to the entire RES staff in 198 .3 Training Programs There is a full-time training staff with a training manager on-sit The classrooms and particularly the training laboratories are very well equipped. The two course coordinators who provide most_of the training for RES personnel are well qualified. Student handout material was extensive and of excellent qualit Training programs such as those discussed in section 2.2 appear to be well structured and controlled. Comprehensive records are maintained of both on site and off site training although summary lists

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, 12 for various individuals were not up to date - a clerical oversigh The training department appears to be equipped to identify and also to satisfy the training needs of the RES department. The response to an NRC request to shorten the site access training for NRC inspectors resulted in a revised ccurse content that was developed in a few days. Accreditation from INPO for all training programs is in proces The effectiveness of the training programs is negatively impacted by delays and postponements. Schedules are often affected by plant outages and the unavailability of personnel to be trained. A further weakness is the availability of a " waiver" option to station manage-ment that is used to grant ANSI status to contractor technicians and to grandfather senior technicians in the Apprentice progra Retraining or in-service training of RES supervisors is controlled by the RES Superintendent. Attendance at off-site training is uneve One supervisor received training in 1986 while several others have not attended any contractor sponsored training. Two supervisors are enrolled in the Georgia Tech home study program in health physic I The on-site training appears to be generic for all supervisors. The '

lack of a formal retraining program for the technical supervisors in the RES department represents a programmatic weakness in this are !

A review of internal correspondence indicates that management has been aware of this weakness since May 1986.

l NRC interviews with selected technicians and first line supervisors found a lack of knowledge regarding fundamental radiation protection concepts as discussed in section The appraisal team concluded that delays in implementing the supervisor retraining program and waiving training for house technicians may be a contributing factor to this proble .4 Document Reviewed James A. FitzPatrick Nuclear Power Plant (JAFNPP) Qualification

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Card and Standard for Radiological and Environmental Technician, l Rev. 1

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JAFNPP Radiation Protection Manual Chapter 3, " Organization and l Responsibilities" l

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JAFNPP Indoctrination and Training Procedures ITP-11, " Training for Technical Staff and Managers," Rev. 2 l

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Power Authority of the State of New York, Exempt Position Description, (various titles), Radiological and Environmental Services Department - JAFNPP

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Review of personnel training records for G. Vargo, K. Szeluga, J. Solini, M. McMahon, J. McCarty, T. Bergene and E. Mulcahey i

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Memo J. C. Brons to L. W. Sinclair, " Training, Monthly Report for August," dated 9/6/85 i

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Memo G. Smith to D. Simpson, " Training Records Audit," dated 9/20/85

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Memo to File - G. Smith, "Non-Licensed Operator Training

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Memo J. S. Coppolino to R. Converse,"INPO Mid-Cycle Audit,"

dated 5/13/86

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Memo D. F. Simpson to E. Mulcahey., et al, " Technical Staff and Manager Training Program," dated 4/16/87 3.0 Exposure Control 3.1 External Exposure Control 3. Dosimetry Program Licensee strengths were found in the quality and adminis-tration of the dosimetry program _ The licensee uses a Panasonic dosimetry system and the Model 812 AS dosimeter for routine meqitoring of deep and shallow exposures due to beta and gamma radiation. A vendor supplied film (NTA)

badge with a polycarbonate chip was used for monitoring neutron doses when entries are made into containment at power, or near neutron sources. However, neutron survey measurements and stay times were used to assign neutron doses of record.

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Extremity dosimetry was provided with single chip finger band The licensee performed a study of the density thickness of their protective clothing (PCs) extremity equipment (i.e., cotton liners and rubber gloves) and determined that these layers of extremity PCs would effectively shield out the range of beta energies encountered at their facility. Therefore, all extremity doses are evaluated as deep dose onl The licensee had a dedicated building for processing the TLDs, and for maintaining dosimetry records and personnel exposure files. There was ample space for processing dosimetry, storage of extra dosimetry, feeding the data into personnel exposure tracking systems, and performing the necessary data review to assure quality of dosimetry data. Computers were used to collect raw data, process the data into doses, and assign doses to workers.

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l Dosimetry personnel interviewed appeared competent and knowledgeable in their assigned responsibilitie ,

Positions were clearly defined. Appropriate training and I retraining was provided to personnel, such as the University of Michigan dosimetry course, and the Annual ]

Panasonic User's Group meetings. The Radiological Engineer '

had recently attended a course on current skin exposure problem )

There is a dedicated exposure records clerk and assistants j to maintain all plant exposure record Records review indicated that exposure information was kept accurately and up to date. Personnel files contained all information 4 related to previous exposure histories, whole body counts, I physical and psychological qualification for respirator use, and termination reports for individuals who left the i sit f 3.1.2 Exposure Review and Assessment Exposure review was performed daily by dosimetry personnel with the aid of a computer program for trackir.g and trending data. The licensee used a computer program for comparing the TLD results to the accumulated direct. reading !

dosimeter (DRD) results and flagging anomalous data for investigatio Review of data was provided by the dosimetry superviso !

l An active quality control program, including frequent

! reader QC checks and cleaning, and using spiked badges with I personnel dosimetry processing runs assured the quality of I the data being generated by processing. Criteria are established to investigate data that was out of bounds for l this tes The licensee als.o continued to use University l of Michigan for their quality assurance program for TLD l performanc An area of weakness was identified with respect to dose j assessment of skin due to generalized contamination and hot '

particle contamination. A procedure was established to i

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evaluate and assess skin dose due to these types of

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contamination, but the procedure did not contain complete l information to perform the calculation The licensee

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stated that the procedure was under development and the appropriate information was being compiled for incorpora-tion into the procedure.

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There was a clearly established and well-written Radiation Protection Manual which provided all administrative limits and regulatory limits to limit personnel exposure. The ,

ALARA concept was used liberally throughout the document, '

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as wel Procedures followed the guidelines of the l

Radiation Protection Manual, and established the necessary steps to ensure that personnel exposures were well controlled. The procedures were readily available for l reference at the Health Physics control poin l A tour of the reactor building, turbine hall, and radwaste building indicated that postings were conservative and accurate. Access into high radiation areas was locked and maintained. Discussions with one of the radiation protec-tion supervisors indicated that he periodically accompanied technicians in the field and sensitized them to potential problems and procedural infractions. Written reports were maintained of the results of each tou .2 Internal Exposure Controls Although the licensee had a whole body counting system for in vivo l analysis of internal uptakes, no in vitro program existed for deter-mining and quantifying uptakes from radioisotopes that cannot be j detected by whole body counting equipment. This was identified as a !

. weakness in the internal exposure controls program. The licensee i stated that although an opportunity never occurred for them to need j an in vitro bioassay program, they would establish a procedure for collecting urine and feces, arranging for analyses, and assessing the dose in the event of positive result I

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4.1 Program Responsibility '

The primary responsibility for liquid and gaseous waste management is assigned to the Operations Department. The Waste Management General i Superviscr reports to the Assistant Operations Superintenden j Management oversight of this area was adequate. Discharges of liquid radioactive wastes are performed with the approval of Radiological and Environmental Services, which also tracks all . liquid and gaseous radioactive release .2 Waste Processing Systems The liquid and gaseous waste systems meet Appendix I design '

objective Technical Specifications require operation of the liquid radwaste system to reduce the amount of radioactivity in effluents when the projected dose from untreated liquid releases would exceed a pre-established limit. The licensee takes a more conservative approach, however, in that all of its liquid-waste is

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, 16 treated prior to release. The Offgas Treatment System is required to be operational virtually at all times the plant is operatin Although neither the liquid nor gaseous systems have redundant backups, alternate methods exist for processing wastes within the ,

systems, and are used as needed. The radwaste supervisor stated that '

operation of the liquid radwaste processing system for discharge of effluents is accomplished by treating the liquid waste, followed by sampling; if the waste meets the regulatory limits, it is then l l discharged. If not, further processing and sampling is done until i the waste water meets the limits. The licensee does not have a  !

specific formal program for establishing and tracking decontamination factors for various parts of the liquid waste processing syste Gaseous wastes from the Standby Gas Treatment System and the Main Control Room Ventilation System are required by Technical Specifi-  !

cations to be treated continuously by passing them through filter i systems prior to discharge. These filter systems are tested at f six-month intervals to ensure that they meet the minimum Technical Specification requirements for removal of radioactive particulate and iodines. During a recent inspection of this area, it was deter-mined that the licensee met the Technical Specification requirements for filter testing.

l The licensee has adequate procedures for handling and dischar.ging l liquid and gaseous effluents. Procedures address, as appropriate, valve line-ups, sampling and analysis, alarm and isolation setpoints, and tracking of releases to ensure compliance with technical speci-  !

fication 11mits. Completed procedures are reviewed and approve l During a recent inspection of this area, the inspector determined that effluent monitors were calibrated and tested in accordance with procedurally established methods, and that frequency requirements were being me In response to self-identified concerris, the licensee has initiated a program of improvements to its Offsite Dose Calculation Manual (ODCM)

and certain related procedures to better address the Radiological Effluent Technical Specifications. An improved version of the computerized offsite dose tracking program is also being develope Discharge Permits The licensee's method for issuing liquid discharge permits was 1 generally goo However, there is no method of ensuring th?.t minimum )

tank recirculation times (which are required by procedure prior to d sampling) are met. The licensee stated that chemistry technicians observe the strip chart which tracks tank level versus elapsed time, and that they will not take the sample unless the minimum recircula-tion time is met. The radwaste operator log generally includes the I

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I time at which tank recirculation was begun, but does not indicate when the sample was take The licensee should develop a method to document that minimum recirculation times were met for each type of tank released, j

4.3 Radiochemistry DC Program Although the radiochemistry quality control program was generally good, the following concerns were noted: An off site vendor labora-tory has been contracted for analysis of liquid samples for certain radionuclides such as Sr-89, Sr-90, Fe-55, and H-3, which the licen-see is not able to analyze in its own laboratory. As a QC check on the ability of this laboratory to make accurate analyses, samples are obtained from a vendor and sent to the contractor laborator The results of the analyses are compared to the known values by the QC laboratory, and accepted or rejected according to its criteri These QC samples are sent to the contractor laboratory on a quarterly basis. Very few disagreements were noted. However, the licensee had not investigated the reasons for disagreements which occurred during the second quarter of 1986. The licensee also did not document the bases for the criteria used for determining whether results are or are not in agreement, although the criteria were given in a letter to the licensee from the QC laboratory as being those used by the NRC for its confirmatory measurements program. The licensee personnel who have the responsibility to investigate and resolve disagreements should be aware of the bases for the criteri .0 ALARA Program 5.1 Program Establishment The ALARA program at the FitzPatrick station is well organize There is a full-time ALARA Supervisor with a dedicated staff of three technicians who report to the Radiological Engineer. Although the ALARA group is a line function, there is evidence of good upper management support and involvement in the progra A corporate based radiological engineering group supplements the site program by maintaining contact with industry-wide associations and various vendors. The station owner (NYPA) joined EPRI in July 1987 which increases the amount of data available to the ALARA groups. A

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review of Radiation Safety Committee minutes indicates an active interest and participation in ALARA developments. There are frequent visits to the site by corporate personnel to exchange informatio Corporate procedure NGP #19, " Preparation and Review of Modification Packages," requires an ALARA review of modification (mod) packages by the design engineers. A corporate HP is usually assigned to assist the design engineer during the conceptual design phase at the request of the Director of Project Engineering. A one day course in

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1 ALARA was provided to corporate engineers in 1985. However, a review of a few mod packages did not produce eny records that clearly docu-ment the ALARA considerations by the design engineer. Also, there is no group dedicated only to ALARA at the corporate level nor is there an ALARA manua The on-site ALARA group reviews all work in advance to ensure that ALARA concepts are applie This includes screening all RWP requests 1 and attendance at daily and weekly work planning meetings. The )

chrter for this group is found in site Radiological Engineering '

Procedures and Chapter 9 of the Radiation Protection Manual. A Plant ALARA Review Committee chaired by the Superintendent of Power meets periodically to review ALARA issue Minutes of meeting and deci-sions of the committee are issued by the ALARA Superviso An Annual Radiological Program Report is issued by the Radiological Engineer which contains extensive and detailed information regarding ALARA ectivities on site during the year, i

5.2 Facilities and Equipment Various mock-ups are available for training of workers including an unused control rod drive, limitorque valve and a recently acquired  ;

Recirc Pump seal cavity. There is no undervessel mock-up. Cr.ews must i l be trained off-site for undervessel wor Extensive use is made of video monitors and two-way radios to control work in high radiation areas of the drywell. Alarming dosimeters as well as teledosimeters are frequently used to closely monitor worker exposure ]

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l The ALARA group is responsible for erecting contamination contain- )

ments (glove bags, tents, etc.) when required. Standard components are used and there are no custom prefa,bricated covers for components such as the reactor hea The station has offered to be a host for an EPRI project to evaluate the use of robots for routine radiation surveys. An automatic con-trol rod drive removal mechanism is under evaluation for potential i purchase. There is an effective ongoing program to identify hot spots for decontamination or shielding installatio The drywell has been completely photographed with data stored on laser discs that allows workers and supervisors to search for equipment without entering radiation area ,

5.3 Integration With the Radiation Protection Program

l Cooperation and coordination between the ALARA group and other site departments appears to be very good. However, the full responsi-bility still rests with the ALARA group without the proactive participation of the other work groups.

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I Prejob and post-job reviews are thorough with extensive detail. This has allowed the ALARA group to optimize the performance of routine { )

outage wor The annual cumulative person-rem performance has been close to industry-wide BWR averages. Although the person-rem have decreased since 1980, the trend has matched the general decrease in the industr FitzPatrick station performance has therefore remained average relative to the industr A major project to chemically decontaminate the reactor recirculation system is scheduled for the 1988 refueling outage. This is projected to save more than 300 person-rem and significantly reduce station exposures in the long term. Additional water shields, cobalt reduc-tion, and hot spot fixes are also being considere .4 Summary The previous appraisal found that an ALARA program was lacking. This has been corrected. A well organized ALARA program exists at the

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site and at corporate. A program weakness to be addressed concerns the need for active participation in the program by work groups and design engineer Although management at the highest levels are intimately involved in the program, the performance goals that are established are not

challenging or aggressive. Management appears to accept average

! performance and is willing to accept postponements. No long range plan for significant exposure reductions was evident The well '

organized and capable ALARA staffs are generally underutilize .5 Documents Reviewed Radiation Protection Manual Chapter 9, "ALARA Program" Procedure REP-1, "ALARA Review" Procedure REP-2, "ALARA and Radiological Program Reports" Procedure REP-3, " Containment Selection and Use" Procedure REP-4, " Selection and Use of Temporary Shielding"

Procedure REP-5, " Plant ALARA Review Committee" ,

l Memo JRES-87-232, " Annual Radiological Program Report," dated l 6/15/87 l

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. Memo JCB 87-02, "1987 Goals," dated 3/2/87  ! Memo to the Trustees from John C. Brons (JCB 87-165), i

" Radiological Untrol Performance Indicators," dated 5/13/87

! Memo REB-87-017, " Nuclear Support Division 1987 Goals," dated l 5/21/87 Memo JSG-87-22, " Minutes of JAF Chemical Decontamination Meeting," dated 6/4/87

AIF Conference paper, "The Pursuit of Excellence in Radiation i Protection Programs," by J. J. Kelley, dated 10/8/86

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20 Memo MEDA-SM-23-86, "IP3 and JAF Nuclear Power Plants Low Cobalt Alloys for Hardfacing Applications," dated 6/10/86 Sixteen trip reports by corporate radiological engineers for ALARA purposes 6.0 Facilities and Equipment 6.1 Counting Room and Sample Screening Area The licensee's capability to adequately process the various samples collected in support of the Health Physics program was reviewe Samples are routinely screened by the technicians in the hallway outside the Chemistry la Seven counter / scalers with GM detectors and one unit with a Nai detector allow for e quick determination of a potential problem and the ability to prioritize samples sent to the Counting Roo The counting lab, located within the Chemistry lab, consists of four germanium detectors for gamma spectroscopy, one NaI well detector for gross gamma analysis, and four proportional counters - one automatic and three manual Adequate equipment is available for beta / gamma counting for both outage and non-outage conditions, although any significant increase in alpha counting may exceed current counting capabilit The purchase of a new computer system for gamma spectroscopy will increase throughput and should be ready for operation by July 1, 198 ;

6.2 Calibration Facility and Survey Instruments

, The current calibration facility is located in a small room situated

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at the bottom of a stairwell . The room is used to store instruments tagged out-of-service, those to be placed into service, the Eberline 10008 calibrator, and general administrative facilities. One technician is assigned the main respon.sibility of operating the 1 day-to-day operations. Although an adequate number of survey instru-ments were on-hand, the inspector noted that 789s of the Eberline R0-5s and 65?s of the Victoreen 740-Fs, the licensee's two major ion  !

chamber instruments, were out-of-service. In addition, 70?s of the l extendable probe instruments were out-of-service. During the prev- l ious outage, the licensee stated that some health physics technicians '

had to borrow instruments from other individuals. More efficient turnaround of equipment would place the licensee in a condition to better handle unexpected increases in survey requirement The inspector noted that the licensee has purchased two portable and l one fixed alpha scintillation counters, although none were currently in service. The two portable survey instruments are the licensee's only means for fixed alpha determination ;

6.3 Whole Body Counting Facility l

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A closed geometry chair and newly purchased computer system are located in a room near the access control point. Due to the nature of the system geometry, additional precautions in both subject and detector positioning are necessary. The facility is adequate to evaluate most uptakes to be encountered. The current location, however, does not allow the licensee the flexibility of processing individuals outside of the RCA and may become ineffective due to high backgrounds during a major releas .4 Respirator Cleaning Facility The licensee has established a separate building, outside of the reactor complex, for the processing of respiratory equipment. State-of-the-art equipment for the cleaning and testing of both masks and filter cartridges is available. A dedicated air compressor for main-taining SCBAs has been installed and the licensee performs tests to certify breathing qualit The inspector noted that ample spare parts were available for most maintenance requirements. A computer program is currently under development to assist in surveillance testing, mask history and accountability, The licensee's dedication to maintaining quality respiratory equipment is demonstrated in this facilit .5 Access Control Point - Health Physics Office A single access control point is used for entrance to both the reactor and turbine builciings with the Health Physics Office located

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at the junction of the " clean" and controlled areas. Monitoring of i all personnel is performed solely by GM tube friskers. Although a !

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portal monitor is also in service, it is neither calibrated nor source checked. The licensee has purchased several state-of-the-art ,

whole body friskers but has yet to place them into operation. In light of the licensee's history of hot particles, the presently available monitoring equipment is not effective for properly detect-ing hot particle The licensee should expedite the installation of the new frisker .6 Instrument Issue Window

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The licensee has established a dedicated area for the issue of finger rings, dosimeters, survey instruments, air samplers' and respiratory '

equipment. All survey instruments are source checked at the begin-ning of each day. Individuals being issued instruments have avail-able a check source for some instruments, but the inspector did not observe it being used after a device was issued. This practice is not effective in identifying faulty instruments prior to their use and could result in unsafe health physics operations and invalid survey results. This practice is not consistent with ANSI standard recommendations.

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The qualifications of an individual to wear a particular respirator is checked at the job site against the RWP access sheet. Individuals receiving respiratory equipment are not checked at issue time as recommended in NUREG-0041 As an additional precaution, this would prevent workers not respi-ratory protection qualified, from wearing such equipmen .7 Engineering Controls and Air Sampling Instruments The inspector noted that an adequate number of portable HEPA filters l of various capacities were on-hand. The Respiratory Protection Group l maintains a log for accountability and surveillance purposes.

i Periodic DOP tests are performed to insure operability on deman Lead blankets are the primary tool for temporary shielding. Prior to their installation, an ALARA review, pre-surveys and engineering evaluations are performed as required. Post-installation surveys are also performed to document shielding adequac Logs are maintained for location and blanket accountability. During a tour of the facility, the inspector noted a large number of shielded areas. The licensee stated that plans are being undertaken for the next outage to decontaminate and reduce the number of temporary shields currently l required.

l The licensee has purchased several new continuous air monitors which are used for trending purposes only (filters not routinely counted).

Approximately six units (two for iodine) are awaiting initial set-up and calibration. Eight units are presently in us Portable air sampling equipment is adequate in both quantity and typ Flow rates are routinely calibrated in-house, with the calibration unit in turn calibrated by the manufacture .8 Decontamination Facilities , j Personnel decon is performed at the access control point. A dedi-cated shower, sink, frisker and associated supplies are available within view of the Health Physics offic Equipment decontamination is performed utilizing a large washdown area (" carwash"), a freon glove box and a bead-blasting unit. During a tour of the facilities, the inspector noted that the bead-blasting unit contained a HEPA filter unit. Conversations with the licensee indicated that the HEPA filter was not on a routine surveillance by either the Respiratory Protection Group or the Maintenance Grou This oversight indicates that a better method of catching surveil-lance requirements for incoming equipment should be considered, s

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6.9 Surveillance Program l

The plant radiological surveillance program is documented in several

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procedures and consists of checks and surveys performed at specified frequencies. Monitoring areas have been selected and assigned a monitoring interval based upon access requirements (i.e.,

self-monitors), occupancy factors and the potential for change in radiological conditions. Daily checks for radiation and contamin-ation are performed at access points, high traffic areas, and areas where radioactive material is routinely handle Checks are also performed to ensure proper posting and high radiation area control More detailed surveys (radiation, contamination, and airborne) are performed weekly or as require Responsibilities for various facets of the surveillance program appeared to be somewhat fragmente The majority of the program rested with the health physics technician The Respiratory Pro-tection Group had responsibility for the daily surveillance of l operational HEPAs, Continuous Air Monitors, and the monthly low l

l volume air samples.

l l Procedural guidance for the RES technicians for the performance of ,

the various types of surveys was somewhat weak. Table I to RPOP-5, {

the plant radiological surveillance schedule, noted when neutron '

surveys should be performed, but did not give any further specific j guidance when addressing radiation, contamination or airborne survey A review of records by the inspector noted that when a routine airborne analysis indicated gross alpha activities as high as 68% of MPC, no follow-up analysis was performed to document that the ,

activity was due to radon / thoron daughters rather than transurani ;

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In addition, calculational errors were not always detected by the j reviewing supervisor. This indicates that a more indepth technical '

review by both the supervisor and performing technician may be warrante '

Discussions with the licensee revealed that procedures for the hot particle program have not yet been formalized. As stated earlier, l whole body friskers have been purchased, but for an effective pro-

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gram, special contarrination survey techniques should be available to help identify possible sources of these particle . Chemistry Program During this inspection the licensee's chemistry program was appraise This appraisal consisted of a review of the licensee's organization and staffing and facilities and equipment as well as the submission of chemical and radiochemical standards to the licensee for analysis.

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24 1 7.1 Organization and Staffing The licensee's chemistry organization is part of the Radiological and Environmental Services (RES) organizatio The chemistry organization within RES consists of a chemistry general supervisor, an environmental supervisor, a chemistry supervisor, and ten technicians plus one environmental technician. The chemistry general supervisor reports to the RES superintendent. The licensee is i currently expanding the chemistry organization with the addition of j these supervisory / professional positions: a chemical engineer, an environmental engineer and an additional chemistry superviso Current staffing appears adequate, and the addition of the super-visory/ professional personnel will strengthen the technical capabilities of the licensee's chemistry organizatio .2 Facilities and Equipment The licensee's chemistry facilities and equipment, including inline l

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chemical monitoring instrumentation and sampling systems, are ade-quate to support current Technical Specification requirements. State of the art instrumentation such as an ion chromatograph (IC), induc-tively coupled plasma spectrophotometer (ICP), and computer based gamma spectrometer coupled to germanium detectors were present in the chemistry laboratory and counting room. Other laboratory supplies

! and equipment such as reagents, glassware, fume hoods, etc., were in !

l adequate suppl .3 Chemical Standards Results  !

During the inspection, standard chemical solutions were submitted to ,

the licensee for analysis by the inspector. The standard solutions were prepared by Brookhaven National Laboratory (BNL) for the NRC ] l Region I, and were analyzed by the licensee using normal methods and equipment. The analysis of standards .is used to verify the licensee's capability to monitor chemical parameters in various plant systems with respect to Technical Specification and other regulatory  ;

requirement In addition, the analysis of standards is used to l evaluate the licensee's analytical procedures with respect to accurracy and precision,

The results of the standards measurements comparison indicated that l five of the 18 measurements were in disagreement under the criteria l used for comparing results. (See Attachment 1.) i The initial chloride disagreements were due to a combination of a ,

leaking suppresor column, a potentially fouled separator column, and ,

problems with the integrator. When these problems were corrected, only one chloride value was in disagreement. Initially all the copper results were in disagreement; these were due to insufficient warm up of the AA lamp. Reanalysis with sufficient icmp warm up

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I resulted in two of the three copper results still being in disagreement. However, none of the disagreements were greater than 15 percent. The licensee also analyzed the iron, copper, nickel, and )

chromium standards using the ICP although this instrument was not yet i in routine use. All of these results were in agreemen These data are presented in Table '

The inspector noted that licensee technicians demonstrated both practical and theoretical knowledge of IC operation when resolving .

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the disagreements initially obtained in comparing the chloride standards. In addition, the inspector noted the accurate results of the metals analyses obtained with the ICP, and discussed with the licensee when the procedure for the instrument would be completed so that the ICP would be put into service for routine use. The licensee stated that the ICP will be put into routine service as soon as practicable. The inspector had no further questions in this area 7.4 Radiochemical Standards Results During the inspection, radioactivity standards were submitted to the licensee by the inspector for analysis. The standards are used to evaluate the licensee's capability to measure radioactivity in both l effluent and inplant samples as required by Technical Specification requirements. The standards duplicated the types of samples and nuclides that the licensee would encounter during normal operation.

l The licensee used routine methods and equipment for the analysis of l the standards.

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The results of the standards measurements comparison indicated that all of the measurements were in agreement under the criteria used for comparing results (see Attachment 2) with the exception of the Cs-137 on charcoal. The inspector submitted charcoal cartridges containing radioactivity distributed both uniformly and on the face of the cartridge. The licensee calibrates with a face loaded charcoal cartridge only and the results of the uniform distribution cartridge l were, therefore, biased low with the Cs-137 being in disagreemen l In discussing this with the licensee the insepctor noted that the 1 licensee only encountered face load cartridges from actual samples; I but licensee personnel were aware that other distributions of radio- I activity on charcoal cartridges were possible and other calibration l standards were available but not routinely used. These data are presented in Table I . Whole Body Counting Program l During this insepetion the licensee's capability to adequately perform radiological bioassay using a whole body counting system was reviewed. An ,

NRC whole body counting phantom containing radioactive sources traceable 5 to the National Bureau of Standard (NBS) was submitted to the licensee for analysis. The phantom duplicated the nuclides and the organ burdens that the licensee might encounter during normal operhtion. The phantom was ,

analyzed using the licensee's normal methods and equipmen i

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8.1 Comparison of Results The licensee's whole body counter consists of a chair containing i three sodium iodide detectors: a 5" x 4" for the torso, a 4" x 4" for the lung, and a 1!s" x 2" for the thyroi The detectors are ,

coupled to r multichannel analyzer which is interfaced to a compute ]

The system software is supplied by a vendor. The NRC phantom was l counted for 300 seconds. The results of the comparisons are listed {

in Table III. The lung results are based on an average of five

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measurements and the GI tract results are based on an average of two measurements. Based on these results, no discrepancies were identified in this are .2 Procedures and Data j The licensee's procedure, PDP10, "Whole Body Counter Operation and Calibration" was reviewed. The procedure requires daily gain and background checks, weekly source checks with acceptance criteria, and annual calibrations. The inspector reviewed the calibration data for q 1985, 1986 and 1987 and noted that NBS traceable standards were used ]

and the calibration data were relatively consistent from year to year. The inspector also reviewed selected 1987 QC dat The licensee plots the results of the QC checks on control charts in order to note any trends in QC dat .0 Exit Meeting The inspectors met with licensee representatives at the conclusion of the inspection on June 19, 1987. The team leader summarized the performance scope and findings of the inspection which were acknowledged by the licensee in a positive manne ;

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Chemical Capability Test Results Chemical NRC Licensee Value Ratio Parameter Value (method) (Lic./NRC) Comparison i i

ResultsinPartsperMillion(pg j l

Nickel 5.09 0.26 5.88 0.25 (AA) 1.16 0.08 Agreement 1 .3 11.46 0.44 1.12 i 0.05 Disagreement 1 .4 15.95 1 0.13 1,04 1 0.03 Agreement Chromium .3 5.50 0.25 (AA) 1.08 0.08 Agreement 9.41 .71 0.50 1.14 0.06 Disagreement 1 .8 13.97 2.01 0.98 1 0.15 Agreement Iron 4.89 0.35 5.02 0.62 ( AA) 1.03 0.15 Agreement 9.55 1 0.34 9.37 0.41 0.98 0.06 Agreement 1 .4 1 .31 0.99 0.04 Agreement I Copper 4.68 0.24 2.98 0.61 ( AA) 0.64 0.14 Disagreement 9.66 0.49 5.31 1.05 0.55 0.11 Disagreement 1 .6 1 .3 0.81 0.04 Disagreement Copper 2 4.68 0.24 5.37 0 (AA) 1.15 0.06 Disagreement ;

9.66 0.49 10.92 0.15 1.13 0.06 Disagreement '

1 .6 16.02 0.16 1.10 0.05 Agreement Nickel 5.09 0.26 5.18 0.18(ICP) 1.02 0.06 Agreement 1 .3 10.09 0.20 0.99 0.03 Agreement 1 .4 15.96 0.42 1.04 0.04 Agreement Chromium .3 4.84 0.12(ICP) 0.95 0.06 Agreement i 9.41 .48 0.23 1.01 0.04 Agreement 14.3 1 .15 0.26 1.06 1 0.06 Agreeemnt Iron 4.89 0.35 5.11 0.14 (ICP) 1.04 1 0.08 Agreement 9.55 0.34 9.81 0.31 1.03 1 0.05 Agreement 1 .4 14.93 0.14 1.02 0.03 Agreement Copper 4.68 0.24 4.72 t 0.11 (ICP) 1.01 0.06 Agreement 9.66 0.49 9.45 i 0.07 0.98 0.05 Agreement 1 .6 15.57 0.35 1.07 0.05 Agreement

Reanalysis, See Paragraph 10.3

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Table 1 Chemical Capability Test Results Chemical NRC Licensee Value Ratio Parameter Value (method) (Lic./NRC) Comparison Results in Parts per Billion (ppb)

Chloride 2 .1 1 .1 (IC) 0.59 0.12 Disagreement 3 .2 2 .6 0.67 1 0.04 Disagreement 8 .2 4 .0 0.59 0.02 Disagreement Sulfate 2 .9 2 .6 (IC) 1.00 0.06 Agreement 4 .4 4 .9 1.00 0.06 Agreement 80.8 1 .3 .97 0.04 Agreement Chloride 2 2 .1 2 .3 (IC) 0.86 0.11 Agreement 3 .2 4 .5 1.13 0.04 Disagreement 80.5 1 .07 0.05 Agreement i

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Table II Radiological Capability Test Results i

1 SAMPLE ISOTOPE NRC VALUE LICENSEE VALUE COMPARISON Result in Total Microcuries Particulate Ce-144 ( .5) E-2 ( .0) E-2 Agreement Filter Cs-137 ( .2) E-2 (1.52 0.04) E-2 Agreement Mn-54 ( .2) E-2 ( .4) E-2 Agreement Co-60 ( .2) E-2 (2.75 0.08) E-2 Agreement Uniformly Loaded Co-57 ( .2) E-2 (3.05 0.12) E-2 Agreement Charcoal Cartridge Cs-137 ( .4) E-2 (6.97 0.07) E-2 Disagreement Co-60 (1.02 0.05) E-2 (7.95 0.12) E-2 Agreement Face Loaded Co-57 ( .2) E-2 (3.70 0.14) E-2 Agreement Charloal Cartridge Cs-137 (1.02 0.05) E-2 (8.59 0.09) E-2 Agreement l C0-60 (1.06 0.05) E-1 (9.51 0.13) E-2 Agreement i

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Table III )

Results* of Phantom Data Licensee Result I Isotoqe Organ NRC Known Value Licensee Result NRC Value Co-60 Lung 65 9 85 8 1.31 0.22 Cs-137 Lung 92 12 158 7 1.72 i 0.24 Co-60 GI 59 1 8 140 4 2.37 0.05 Cs-137 GI 83 11 263 9 3.17 i 0.43 l

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ATTACHMENT 1 l

Criteria For Comparing Analytical Measurements l

l This attachment provides criteria for comparing results of capability test In these criteria the judgement limits are based on the uncertainty of the

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ratio of the licensee's value to the NRC value. The following steps are performed:

(1) the ratio of the licensee's value to the NT+RC value is computed License.9 Value (ratio = NRC Value );

(2) the uncertainty of the ratio is propagate If the absolute value of one minus the ratio is less than or equal to twice the j ratio uncertainly, the results are in agreement. (ll-ratio l s 2 uncertainty)

Z = X, then Sz2 = Sx2 + Sy 2 Y 27~ X2 y2  !

l (From: Bevington, P.R., Data Reduction and Error Analysis for the Physical Sciences, McGraw-Hill, New York 1969)

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ATTACHMENT 2

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CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS This attachment provides criteria for comparing results of capability tests and verification measurements The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this progra In these criteria, the judgement limits are variable in relation to the comparison of the NRC Reference Laboratory's value to its associated uncertainty. As that ratio, referred to in this program as " Resolution",

increases the acceptability of a licensee's measurement should be more selective. Conversely, poorer agreement must be considered acceptable as the resolution decreases.

Resolution 2 Ratio For Agreement 2

<3 0.4 - .5 - .6 - 1.66 16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25

>200 0.85 - 1.18 1 Resolution = (NRC Reference Value/ Reference Value Uncertainty)

2 Ratio = (License Value/NRC Reference Value)

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