ML20154Q581

Insp Rept 50-322/86-03 on 860127-0214.Concerns Re Mgt & QC of Radiochemistry Program Noted.Deficiencies Noted During May & June 1985 Audit Still Exist

ML20154Q581
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/14/1986
From:	Kister H, Pasciak W, Strosnider J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20154Q579	List: ML20154Q575 ML20154Q581
References
50-322-86-03, 50-322-86-3, NUDOCS 8603210198
Download: ML20154Q581 (25)

See also: IR 05000322/1986003

Text

_ -- ._ _ _ _ _ _ - - - - _. .

.

!

'

.

-

.

J

. U. S. Nuclear Regulatory Commission

Region I

!

Report No. 50-322/86-03

i Docket No. 50-322

i

License No. NP;-36

. Licensee: Long Island Lighting Company

P. O. Box 618

Shoreham Nuclear Power Station

Wading River, New York 11792

,

j Inspection At: Wading River, New York

i Inspection Conducted: January 27 - February 14, 1986

Inspectors: James J. Kottan, Laboratory Specialist

John A. Berry, Senior Resident Inspector

Karen L. Rabatin, Radiation Specialist

Clay C. Warren, Resident Inspector

1

Reviewed: - ----  ::d@-- --- -

6

! J. R. Strosnider, Chief, Reactor Date Signed ,

rojects Section 18, Division of

4

Reactor Projects

8:-J. -- ------ ------ -2 Y-

W. J. Pasciak, Chief, E fluents Date Signed

Radiation Protection Section, Division of

Ra i tion Saf y n Safeguards

'

Approved: ------- -- -- - -- - ------- -

Harry B. ister, Chief, Projects Date Signed

Branch No. 1, Division of Reactor Projects

i

'

Summary: The results of this special inspection raise serious concerns regard-

ing the management and quality control of the Radiochemistry program

at Shoreham, specifically as it relates to the training and qualifi-

cation of personnel, and laboratory QA and practices. The NRC inspec-

tion found that the deficiencies identified during the May and _ June,

1985, LILCO audit of the Radiochemistry Division still existed in

February,1986 and that little progress in implementing effective

fixes had been made. Even after the Corrective Action Request from '

<

, 8603210198 860314

i PDR ADOCK 05000322

O PDR

- .- . - - - . - -- .-_ .- - . - - . - - , . - _ _

.

QCD was issued, a serious step which is only one level less severe

than a Stop Work Order, the issue was still not promptly and effec-

tively addressed by the Radiological Controls Division. The Qualit /

Controls Division and Quality Assurance Department's handling of t',e

results of QCD Audit 85-05 brings into question the timeliness anr

effectiveness of their handling of identified potentially seriou-

problems. Similarly, management awareness of, and response to, the

results of the QCD Audit was not indicative of a responsive attitude.

Problems with training and qualification of Radiochemistry section

personnel indicate a lack of plant and training department management

involvement in the training activities of the section. This issue

had been brought to the attention of supervisory personnel by techni-

cians on a number of occasions, and was clearly identified by the

QCD Audit. The Training Department appears to have had no involvement

in the training and qualification of radiochemistry technicians.

Training records kept by the training department were found to be

incomplete and erroneous in many respects. No formal training for

technicians was offered, nor was training review of qualification

records evident. Training department management did not conduct

adequate reviews of qualification records and were not sufficiently

involved in the implementation and/or audit of the training program

being run by the Radiochemistry section, to identify that a poten-

tially serious problem existed. Additionally, although QCD Audit

Report No. 85-05 identified findings that were clearly related to

training, no one in the training division or i!uclear Operations

Support Department was on distribution for the Audit Report.

Problems in laboratory practices and laboratory QA relate directly to

the issue of management attention to Radiochemistry activities,

training and aualification. The problems noted appear to be a direct

result of inadequate training and inadequate management guidance and

support from their superiors. At times when issues were raised by

technicians, they apparently were not properly addressed by super-

visory personnel. Some of the problems noted with the improper use

of control charts and graphs appear not to be due to a deliberate

attempt by technicians and foreman to ignore trends or indicators,

but rather indicate that they in fact were unaware of the purpose of

these graphs and charts. These problems indicate a failure of higher

level supervisory personnel to involve themselves in the activities

of the section on a regular basis.

- -_-

.

.

1. Review of the LILC0 Quality Assurance Audit of the Radiochemistry Section

The inspectors reviewed LILCO Quality Control Division Audit Report No.

85-05, Shoreham Plant Staff-Radwaste/ Radiochemistry. This audit was con-

ducted during the period May 20, 1985 to June 25, 1985. The audit was

conducted in accordance with QA procedures to verify compliance with and

determine the effectiveness of station procedures for the Radwaste and

Radiochemistry Divisions.

The audit report detailed specific " findings" of noncompliance. The

report also detailed " observations". Observations differ from findings

in that an observation details a suggestion for a non-mandatory change in

an area which is in compliance, and findings detail failures to comply

with a commitment or conform to an established regulation, industry stan-

dard, license condition, or internal procedure.

The findings in this audit report concerned the following general areas.

. Inability to provide documentation to show that the Radiochemistry

Engineer had completed required surveillances of Radiochemistry

Section activities.

Inability to produce logs or work activity schedules to show that

required semi-annual split sample analyses were being performed.

. Inadequate and conflicting documentation between Radiochemistry

Section and Training section training folders.

.

The fact that numerous instances were found where individuals had

been certified as technicians without having completed the required

initial training program.

.

The certification of numerous individuals in certain aspects of the

training program without their having completed all training tasks

required for such certification.

.

Failure to implement or document a requalification program in analyti-

cal techniques for technicians as required.

. Failure to properly complete chemistry data sheets in that no reasons

were given for out of specification chemistry conditions.

.

Failure to properly label reagent solutions with appropriate expira-

tion dates, and the presence of out of date solutions in the labora-

tory work areas.

,

The observations in this audit report concerned the following general

areas:

~

s

m

. . . . ~ . - - ._ .-_a

i

,

'

2

i

. The failure to properly store or label a chemical solution. This

observation had been identified as a finding during a previous QCD

audit.

. Numerous examples of improper completion of the Radiochemistry Log

,

Book, Radwaste Log Book, Radiation Monitoring System Log Book and

Offsite Analysis Log Book.

,

The audit report findings and observations were sent to the Radiochemistry

Organization on July 15, 1985 for response. QCD required that these re-

, sponses be returned by August 15, 1985. The Radiochemistry Engineer re-

j sponded to QCD in late October 1985 and proposed corrective actions to be

implemented. Radiochemistry committed to corrective actions and indicated

that these actions would be completed by specific due dates. All due

] dates, with the exception of one, committed to completion of corrective

, action on or before December 31, 1985. The one exception to this involved

4

the failure to implement a requalification program for technicians in

j analytical methods. The Radiochemistry Section committed to complete

corrective action on this item by March 31, 1986.

j The QCD Lead Auditor responded promptly to the proposed corrective actions

q and commitment dates, approving Radiochemistry's actions. QCD initially

) rejected the March 31, 1986 completion date for the requalification

i finding as unacceptable, and requested additional information as to what

, interim actions would be implemented by Radiochemistry as remedial steps.

J Radiochemistry responded that the March 31, 1986 completion date was based

upon all technicians completing required sample analyses. The extended

'

time frame for this completion was the result of shift scheduling con-

straints. QCD accepted this response.

QCD scheduled followup audits on each of the findings in Audit Report 85-05

to verify that Radiochemistry had properly implemented their proposed cor-

, rective actions. During the week of January 13, 1986 a followup inspection

was performed to verify implementation of corrective actions for audit

finding 85-05-43. This finding had involveu the fact that technicians had

not completed all phases of the required initial training program. Radio-

chemistry had committed to resolution of this item by December 31, 1985.

i

This follow-up audit identified that corrective actions had not been com-

pleted. On January 17, 1986, QCD management and the Quality Assurance

Department Manager met with the Radiological Controls Division Manager and

Radiochemistry Supervision to inform them of the lack of completion of the

audit finding commitments. QCD was prepared to issue a Stop Work Order

to Radiochemistry, but agreed to a Corrective Action _ Request instead based

upon Radiochemistry's commitment to immediately institute short term cor-

rective actions to allow work to continue. Raciochemistry and QCD per-

sonnel worked that night, and over the weekend, to ensure that enough

'

technicians were properly cualified to allow work to continue, and a re-

'

view of all personnel qualifications was initiated. The Quality Controls

Division formally issued the Corrective Action Request on January 27, 1986

n e,c,---g,- +-<c,,--- w ,.~-mm,, . - - - - , , - n , - --n----v,,--s

a , - - - , . , ,, . + , - , - ,,w .-.na -

g a,,- .+-.4 -a

._ _ - - _ _ _ _ . . _ _ . . _ _ . - _ _ _ _ _ _ _ _ _ _ - _ .. -

b *

i

-

i

. 3

to the Radiological Controls Division Manager. The Radiological Controls

! Division response to the Corrective Action Request was due to QCD on

l

February 28, 1986 and therefore was not available at the time of this

inspection.

,

, 2. Organization and Qualification of Radiochemistry Section

I The inspectors reviewed the licensees chemistry organization with respect

4 to structure and staffing. The inspectors also reviewed the qualifica-

j tions of the supervisory and professional personnel in the licensee's

1

chemistry organization. These reviews were performed using the criteria

contained in Section 6.2, Organization; and Section 6.3, Unit Staff

Qualification, of the Technical Specifications and ANSI Standard N18.1-1971,

j " Selection and Training of Nuclear Power Plant Personnel".

i

The licensee appears to have an effective organizational structure for the

management of the station chemistry program. The responsibilities and

. authorities of management positions, as well as position interfaces, are

!

clearly defined. The licensee is using the selection criteria contained

in Procedure SP No. 71.002.01, Radiochemistry Section Policy and Objec-

tive, for staffing the organization. The selection criteria in this pro-

i

^ cedure are the selection criteria in the FSAR Section 13.1.3. and ANSI /

ANS-3.1-1979 which meets and exceeds the criteria of ANSI Standard

N18.1-1971. Beginning with and including the radiochemistry engineer, the

I

licensee's staff includes 9 professional or supervisory positions with a

total of 11 individuals. All individuals in the current organization meet

the selection criteria with the exception of one individual; a foreman.

The licensee stated that documentation could be supplied to demonstrate

the qualifications of this individual for the foreman position.

_'

Subsequent review of the documentation by the inspector determined that

the qualifications of this individual still remain in doubt as to whether

, he meets the experience requirement of four years specified by Procedure

i

SP No. 71.002.01. Procedure SP No. 71.002.01 implements the requirements

<

of Section 6.3 of the licensee's Technical Specifications. Until more

detailed information regarding this individuals previous experience can

j be supplied this item is considered unresolved. (50-322/86-03-01)

>

i The inspector also noted that of the 11 individuals in the organization

four were contractor personnel. The licensee stated that attempts were

, being made to recruit qualified individuals so that the organization would

be staffed with company personnel. In addition, the inspector further

'

' noted that the individual occupying the radiochemistry engineer position

is acting in that position. The acting radiochemistry engineer has been

j

^

absent from work recently due to illness and, therefore, both the radio-

chemistry supervisor and radiochemistry support supervisor have been acting

for the acting radiocheraistry engineer. The inspector discussed the

i temporary staffing situation with the licensee. The licensee stated deci-

i

sions would be made regarding _these staffing matters in the near future.

, The inspector stated that this area would be reviewed during a subsequent

j inspection. (50-322/86-03-02)

.

'

4

-, -

, .. . . - - , , - - . . . - , . . - - - . - - - - , , - - . . _ _ , - , . _ - - . . , _ - - , . . - - , . ---.-.,-_ -,

. -- - _ _ - . . . . .

.

.

4

2

o

In reviewing the selection criteria used for the radiochemistry supervisor

'

position the inspector noted that the criteria were the same as that for

the foreman position. The licensee stated that the selection criteria in

Procedure SP No. 71.002.01 for the radiochemistry supervisor would be

upgraded to the same criteria used for the radiochemistry support super-

visor position. The inspector stated that this area would be reviewed

during a subsequent inspection. (50-322/86-03-03)

3. Technician Selection, Training and Qualification

,

The inspector reviewed the licensee's program for the selection, training,

j

and qualification of Radiochemistry Technicians. The review was performed

using the criteria contained in Section 6.4, Training, of the Technical

l Specifications and ANSI N18.1-1971, " Selecting and Training of Nuclear

Power Plant Personnel". The licensee's program in this area is detailed

in Procedure SP No. 71.006.01, Radiochemistry Technician Selection,

Training and Qualification Program.

The licensee's technician selection and training program as detailed in

Procedure SP No. 71.006.01 meets the requirement of ANSI N18.1-1971. In

addition, procedure SP No. 71.006.01 contains provisions for technician

qualification on specific procedures or tasks as well as requalification

and retraining. The inspectors reviewed licensee selection and qualifi-

cation records and held aiscussions with chemistry technicians with respect

i

to implementation of Procedure SP No. 71.006.01. The licensee's procedure

requires that the individual technician demonstrate practical abilities,

procedural and technical knowledge, and the skills necessary to perform a

i

task. Either procedure checkout guidelines or technician task evaluation

guides are to be used to qualify technicians. Contrary to these require-

ments, however, the licensee qualified the chemistry technicians on proce-

dures by giving open book exams to the technicians. The technicians were

given the examination, which consisted of approximately three to five

questions on each specific procedure, and copies of the applicable proce-

dures and instructed to take the examination. Interviews with technicians

indicated that actual task evaluations were not performed, although quali-

fication records reviewed show signoffs for these task evaluations.

The inspector also noted that the licensee had qualified seven chemistry ,

technicians on the radiation monitoring system (RMS) procedures using the

required task evaluation guide, but that all the technicians were quali-

fled on the same date. Again discussions with chemistry technicians in-

dicated that individual procedure qualifications had not been performed

as required. The licensee stated that the RMS task evaluation guides were '

all signed on the same date by a chemistry foreman based on the judgement

of the foreman that the chemistry technicians were qualified. The

inspector noted that Seciton 6.4 of the Technical Specifications requires

a training program that meets or exceeds the recuirements of ANSI

I

N18.1-1971. Procedure SP No. 71.006.01 written cursuant to the requirements

of Section 6.4 of the Tecnaical Specifications requires task evaluations

as part of the training prcgram. However, as the above examples indicate,

!

.__ .

-

_ _ . _ .

_ . _ _ , _ _ _ _ _ _ _ _ . . . , . , . , _ . _ _ . _ . _ _ , _ . ~ . . . _ - - _ , , _ _ . - - . . . , .

.

.

5

the licensee failed to perform the task evaluations as required by the

procedure. The inspector stated that the failure to follow Procedure

SP No. 71.006.01 was a failure to meet the training requirements of

ANSI N18.1-1971 and, therefore, a violation of Section 6.4 of the

Technical Specifications. (50-322/86-03-04)

Interviews with chemistry technicians further indicated that laboratory

QA was not included in any training given by the Chemistry Department.

Chemistry technicians did not appear to be aware of the basis for a lab-

oratory QA/QC program; eg, why the technicians perform control measure-

ments and how to evaluate them; and the concept that the QA/QC programs

and associated analyses are part of the overall analytical methodology.

This lack of training has had an adverse effect on the laboratory QA

program as discussed in Section 5.

4. Procedures

The inspector reviewed the licensee's procedures for sampling, instrument

calibration, operation and maintenance, radiochemical and non-radiochemical

analyses, and laboratory quality control. The inspector noted that the

above procedures were reviewed and approved as required by Section 6.8,

Administrative Controls-Procedures and Programs, of the Technical Specifi-

cations and conform to standard industrial practices.

The inspector observed the analyses of the NRC standard chloride solutions

(See Section 7). The licensee used procedure SP78.011.38, Rev. 2,

" Chloride Analysis, Specific Ion Electrode Method". This procedure states

that two check standards with concentrations of 20 ppb and 50 ppb chloride

will be prepared, analyzed, and results plotted on a control chart. If

the results of these licensee check standards fall within two sigma error

limits, the existing chloride calibration curve is considered acceptable

to use for the analysas. Tha insnector noted that the check standards

were prepared and analyzed, but the results were not plotted since no

control charts exist. The inspector further noted that 6.8.la of the

Technical Specifications requires that procedures be established, imple-

mented, and maintained covering the activities referenced in Appendix A

of Regulatory Guide 1.33, Revision 2, February 1978. This includes

chemical and radiochemical control procedures. Procedure SP 78.011.38

was written pursuant to the requirement of Section 6.8.1.a of the

Technical Specifications. The inspector stated that the failure tc use

control charts as required by Procedure SP 78.011.38 for the period

'

November, 1985 through February, 1986 was a violation of Section 6.8.1 of

the Technical Specifications. (50-322/86-03-05)

The licensee stated that no control charts are generated for the chloride

check standards because the same respective miliivolt (MV) readings are

obtained each time 20 ppb and 50 ppb standards are analyzed. These

measurements result in a mean millivolt (or pob) value with a standard

deviation of zero.

. _ - .

-. . - - -. _ . . . . .. . . . . . - - -.

.

!

6

t

i

5. Laboratory Quality Assurance (QA)

The inspector reviewed the licensee's program for the quality assurance

'

of analytical measurements. This program is addressed in Procedure SP

71.018.01, " General Laboratory Operation". The inspector noted that con-

trol charts were implemented for all of the laboratory radioanalytical

instrumentation. However, the inspector further noted that the licensee

did not appear to be using the control charts as intended. Several months

data for both the gamma spectrometry and gama well counting systems were

commonly on one side of mean, yet no corrective actions were taken.

. Standard guidance is that no more than eight consecutive data points

i should fall on the same side of the mean without some action to maintain

! instrument statistical control. One of the licensee's control charts was

found to have thirty consecutive biased data points. Control charts for

the liquid scintillation counter were present for quenched background and

quenched standard samples. The mean values and warning limits for these

I charts were determined from the previous months data which is a recommend-

ed practice. The inspector identified that all of the previous months

data prints are not used to calculate the control chart parameters; in-

,

stead, a minimum of fifteen data points are randomly chosen. This method

may lead to an improper evaluation of the warning limits.

The inspector also discussed the calibration of micropipettes with the

licensee since the pipettes are used for Technical Specifications related

analyses. The licensee stated that the micropipettes are calibrated rou-

tinely, but could produce no data to substantiate these calibrations.

, Discussions with chemistry technicians indicated that pipettes calibra-

tions were not performed routinely.

i

~

As previously mentioned the licensee does not use a statistical curve

fitting method for chemical calibration curves. The inspector discussed

i

curve fitting with the licensee and stated although curve fitting is not

i a quality parameter, it may improve analytical results because of better

interpolation of the area between data points. The inspector pointed out

'

that not curve fitti,g calibration data points is a deviation from good,

commonly accepted lat oratory practice. On the other hand, the licensee's

software for the gammi spectrometry system statistically fits the cali-

bration curves for the gamma system geometry. Again, the inspector

pointed out that good laboratory practice would include plotting the

actual calibration data as a visual check for anomalous results.

'

The inspector noted that the above items are generally accepted laboratory

practice. The lack of their implementation appears to be related to a

lack of attention to detail by the licensee and raises concerns regarding

the reliability of chemical analyses. These areas will be reviewed

during a subsequent inspection. (50-322/86-03-C6)

i

. , . - _ , ., ._ - . _ . _ _ . . _ . . - . . - , _ . . , _ . _ _ . , . _ ~-.,,m, , . . , , . . . . , - , . . , . _ . . . ~ . _ -

_ _ _ . _ . . _ . _ . _ _ . __ . _ . . _ _ . _ . . .

t

.

7

i

1

f 6. Laboratory Tour

.

! The inspectors conducted a tour of the Radiochemistry Lab to observe con-

l ditions, level of cleanliness, and general laboratory practice. The in-

spectors noted standards that were available for use had expiration dates

that were past due. The inspectors also noted instruments available for

use which had past due calibration dates.

i The inspector also noted several conditions in the laboratory that were

j not in accordance with good housekeeping practices. The inspector noted

'

broken glassware in the chemical storage room, chemical deposits on

workbenches, numerous empty chemical bottles being stored under sinks and

in fume hoods, glassware available for use without being free of mineral

deposits and a general state of clutter and disarray in portions of the

laboratory. '

7. Measurement Capability Test Standards '

, During the inspection test standards were submitted to the licensee in

] order to evaluate the licensee's capability to measure radioactivity in

effluents and chloride concentration in the reactor coolant system. The

radioactivity standards were prepared by the NRC reference laboratory, DOE

'

Radiological and Environmental Sciences Laboratory (RESL), and duplicated

the types of samples and nuclides that the licensee would encounter during

i,

operation. The standard chloride solutions were prepared by Brookhaven

National Laboratory (BNL) Safety and Environmental Protection Division,

'

for the NRC Region I. All test standards were analyzed by the licensee's

chemistry technicians using routine methods and equipment.

w.

The results of the radioactive standards comparison indicated that all of

the radioactivity measurements were in agreement based on the criteria for

intercomparing results. (See Attachment 1). The results of the comoari-

'

son are listed in Table 1. The results of the chemical standard comparison

also indicated that the chloride measurements were in agreement based on

the criteria for intercomparing results. (See Attachment 2). Standards

of 10, 30 and 70 ppb concentrations were submitted to licensee and all

i were analyzed in triplicate. The results and comparisons are listed in

3 Table 2. Although the results of the radioactive and chemical standard.

comparisons were satisfactory, the problems in laboratory procedures and

j QA; noted in Sections 3, 4, 5, and 6; raise concerns regarding the.

reliability of the chemical analysis program. l

i 1

8. Technician Interviews Concerning Training and Knowledge and

Performance of Duties

.

t The inspectors interviewed Radiochemistry section technicians to determine

,

the adequacy of on the job training, to confirm implementation of the

qualification process and to evaluate the quality of formal classroom

-

training. The following are the results of those interviews.

i

!

!

,

,

, , _ y . _ , - . . _ , ._....,,,,,_._,,.,__,,m , . _ . _ , , , , , . - , , . _ , , , , . . , .,, , , y,_ , , , . . . , . . , , . . .,,,r.,... - , . . . . , , , . , . , . .

.- . - . .- - _ _ -

- - - - _ _ ..-

.

i

8

i

! -

The inspectors determined that technicians routinely perform both

preventive and corrective maintenance on electronic equipment in the

Radiation Monitoring System, including safety related equipmsnt, with

no electronics training or previous electronics background other than

. on the job training. This is an apparent violation of ANSI 18.1-1971

] which requires a minimum of three years working experience in their

specialty, which the licensee has committed to in Technical Specif1-

cation 6.3.1 (50-322/86-03-07).

-

Technician qualification cards have a performance section which must

be completed prior to a technician qualifying as an on-shift techni-

j cian. The inspectors determined that, contrary to Station Procedure

71.006.01, a number of the technicians have been qualified as shift

~

technicians, without ever performing tasks under supervision.

-

Prior to qualification as a shift technician, an individual spends

I six months in on-the-job training. The inspector determined that in

! many cases only the last 2 to 4 weeks of this six months were spent

1 in actual on-the-job training and, no formal or structured training

i program was established. In these cases approximately five and one-

half months of the six month period were spent working on activities

other than the areas to be qualified in. It was determined that, in-

adequate time was provided to allow technicians to complete perfor-

mance elements as required by Station Procedure 71.006.01.

-

The inspectors determined that the testing process for qualification  !

I

was not being conducted in accordance with S.P.71.006.01 in that the

licensee administers procecural based exams with the procedures

j available to the trainee instead of requiring performance of

i

procedures under supervision. (See Section 3)

The last three of the above observations are additional examples of

the apparent violation of. Section 6.4, Training, of the Technical

Specifications (50-322/86-03-04) stated in Section 3. The findings

presented above indicate that serious deficiencies exist in the

Radiochemistry training program. As indicated in Section 1, similar

deficiencies had been noted during the LILCO QA audit conducted

during May and June of 1985. In addition, the inspectors found that

many of these training and qualification problems had been brought

to the attention of higher level management by technicians in the

Radiochemistry Department. The lack of a timely resolution of

identified problems indicates an absence of management involvement

in the department's activities.

9. Exit Meeting

'

On February 14, 1986 the inspectors discussed the findings of this inspec-

tion with station management. Based on NRC Region I review of this report

and discussions held with licensee representatives, it was determined that

this report does not contain information subject to 10 CFR 2,790  !

i

restrictions.

!

J

'

,

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ - - - _ _ - - - - - - - - - - - - - - -

w , n

.

.

l

l

ATTACHMENT 1

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

program.

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 = NRC REFERENCE VALUE RATIO = LICENSEE VALUE

REFERENCE VALUE UNCERTAINTY NRC REFERENCE VALUE

Resolution Agreement

<3 0.4 - 2.4

4-7 0.5 - 2.0

8 - 15 0.6 - 1.66

16 - 50 0.75 - 1.33

51 - 200 0.80 - 1.25

> 200 0.85 - 1.18

_

1

I

i

- - - ------

- _ ._.,

?

.

,

Table 1

Radiological Capability Test Results

Sample ISOTOPE NRC VALUE LICENSEE VALUE COMPARISON

Results in Total Microcuries

Spiked Ba-133 (3.96 0 .04)E-2 (3.79 Agreement

0.05)E-2

Charcoal

Cartridge

Detector 2

Geometry 12

Spiked Ba-133 (3.96 0.04)E-2 (4.22 0.06)E-2 Agreement

Charcoal

Cartridge

Detector 1

Geometry 12

(1) Spiked Ba-133 (3.96 0.04)E-2 (4.26 Agreement

Charcoal

0.06)E-2

Cartridge

Detector 1

Geometry 12

(2) Spiked Ba-133 (3.96 0.04)E-2 (4.62 Agreement

Charcoal

0.06)E-2

Cartridge

Detector 1

Geometry 12

(1) Cartridge analyzed by different technicians

(2) Cartridge rotated 80 degrees.

Spiked Cd-109 2.21 0.11 2.72 t 0.08 Agreement

Particulate Ce-139 (7.4 0.3)E-2 (8.87 0.07)E-2 Agreement

Filter

Detector 2

Geometry 16 Co-57 (3.8 0.2)E-2 (4.56 0.03)E-2 Agreement

Co-60 (9.9 0.5)E-2 (1.14 Agreement

0.01)E-1

Cs-137 (9.5 0.41)E-2 (1.13 0.01)E-1 Agreement

Sn-113 (1.61 0.07)E-1 (1.87 0.02)E-1 Agreement

Y-88 (2.49 0.11)E-1 (2.86 Agreement

0.03)E-1

_ _ _ _ _ _ _ _ _ - _ - _ _

. . . . .__

, ..: :

_

.

Table 1 (Continued)

Radiological Capability Test Results

Sample ISOTOPE NRC VALUE LICENSEE VALUE COMPARISON

Results in Total Microcuries

Spiked Cd-109 2.21 0.11 (2.72 0.08) Agreement

Particulate

Filter Ce-139 (7.4 0.3)E-2 (7.9 0.2)E-2 Agreement

Detector 1

Geometry 17 Co-57 (3.8 0.2)E-2 (4.03 0.10)E-2 Agreement

Co-60 (9.9 0.5)E-2 (1.02 0.02)E-1 Agreement

Cs-137 (9.5 0.4)E-2 (9.98 0.16)E-2 Agreement

Sn-113 (1.61 0.07)E-1 (1.72 0.06)E-1 Agreement

Y-88 (2.47 0.11)E-1 (2.43 0.09)E-1 Agreement

Sample E(Kev) NRC Value Licensee Value Comparison

Results Gammas Per Second

Simulated 186 231 5 233 8 Agreement.

Offgas Vial

Detector 1 242 496 10 481 10 Agreement

Geometry 9 295 1230 30 1294 15 Agreement

352 2360 50 2263 20 Agreement

609 2970 60 2699 30 Agreement

--, ,-

9 .

l

.

Attachment 2

Criteria for Comparing Analytical Measurements

This attachment provides criteria for comparing results of capability tests.

In these criteria the judgement limits are based on the uncertainty of the l

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 NRC value is computed

Licensee Value

(ratio = NRC Value );

(2) The uncertainty of the ratio is propagated.

If the absolute value of one minus the ratio is less than or equal to twice

the ratio uncertainty, the results are in agreement. (ll-ratio [s_2x

uncertainty)

SL S' S*

j[ = 5 , then Z = x + y

Y

J_^ x^ y2

(From: Bevington, P.R., Data Reduction and Error Analysis for the Physical

Sciences, McGraw-Hill, New York, 1969)

.. . . .. -.- . . - - - - - - , - . . . - . - - - - . . . , -

n

- -

-__. . .g

3 .

h

Table 2

Chloride Capability Test Results

NRC Vai"e Licensee Value Ratio (Lic./NRC) Comparison

Results in Parts Per Billion (ppb)

j 10.3 0.7 < 20 --

- No Comparison -

4

28 -3 33 3 1.2 0.2 Agreement

70 3 68 6 0.97 0.10 Agreement

.

_, - , , --g- - wn Y *