ML20028D141
| ML20028D141 | |
| Person / Time | |
|---|---|
| Issue date: | 12/28/1982 |
| From: | Oestmann M, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20028D138 | List: |
| References | |
| CON-NRC-05-80-275, CON-NRC-5-80-275 99990003-82-01, 99990003-82-1, NUDOCS 8301170140 | |
| Download: ML20028D141 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION III Performance Appraisal for the NRC/ State of Wisconsin Environmental Monitoring Contract Report No. 9999-0003/82-01 Contract No. NRC-05-80-275 a
Docket No. 9999-0003 Facility: State of Wisconsin Division of 1:ealth Appraisal At: Madison, WI l
Appraisal Conducted: November 22-24, 1982 Appraisal Period: July 1980 through November 1982 ff <, hWWW thkW Appraisal Team Members:
M.
. Destmann
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p M. C. Schumacher
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M Approved By:
M. C. Schumacher, Chief Independent Measurements and Environmental Protection Section
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Appraisal Summary i
Appraisal Conducted on November 22-24, 1982 (Report No. 9999-0003/82-01(DEPOS))
Areas Appraised:
Adherence to requirements of the contract; organizational structure and management support; policies and standards; technical staffing and training; facilities, analytical equipment, and counting instrumentation; analytical procedures and laboratory performance; quality assurance; reports, and communications.
Results: The State's performance related to this contract is satisfactory and much improved since the previous appraisal.
State support for continuing the i
program is strong. Minor discrepancies were noted related to sample splitting, missing report items, and to not fully completed analytical procedures.
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DETAILS 1.
Persons Contacted
- L.
McDonnell, Chief, Section of Radiation Protection (SRP), Bureau of Environmental Health, Division of Health (DOH), Department of Health and Social Services (DHSS), State of Wisconsin.
D. Hendrickse, Radiation Consultant, SRP, Bureau of Environmental Health, DOH, DHSS, WI.
- T. Johnson, Acting Director, Bureau of Environmental Health, DOH, DHSS, WI 2 R. Laessig, Ph.D., Director, State Laboratory of Hygiene (SLH), University of Wisconsin.
2 D. Hassemer, Assistant Chief of Clinical Chemistry, SLH R. McElmurry, Chemist, SLH L. West, Chemist, SLH J. Edison, Chemist, SLH 1Attended exit interview on November 24, 1982 at the State of Wisconsin, SRP office.
2 Attended exit interview on November 24, 1982, at the University of Wisconsin SLH.
2.
General This appraisal was conducted to review the performance by the State of Wisconsin of work under NRC/ State of Wisconsin Environmental Monitoring Contract No. NRC-05-80-275.
Under the contract the State performs environmental monitoring and TLD exchange in the vicinity of the Point Beach Nuclear Power Plant, the Kewaunee Nuclear Power Plant and the Lacrosse Boiling Water Reactor. The contract serves to compare and verify the programs conducted by the three licensees. The State's program is somewhat more extensive than required by the contract.
In addition, the State performs environmental monitoring not covered by the contract in Wisconsin in the vicinity of the Zion Nuclear Power Plant located in Illinois and the Prairie Island Nuclear Power Plant located in Minnesota.
The appraisal consisted of a review with members of the Section of Radiation Protection (SRP) of the Department of Health and Social Services (DHSS) at their office in Madison, Wisconsin, and with members of the State Laboratory of Hygiene (SLH) on the University of Wisconsin Madison campus. The review covered the period July 1980 through November 1982.
3.
Summary und Recommendations Based on its review, the appraisal team recommends renewal of the contract with the State of Wisconsin. Overall, the State's performance has satisfied the objectives and conditions of the contract and current performance is regarded as good.
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f Significant improvements were made since the previous NRC appraisal (July 1980), in the areas of:
a.
Communications between SRP and SLH b.
Training and qualifications of SLH personnel c.
Sample collection, analysis, and data reporting d.
Quality assurance and quality control, and e.
Management support.
Several deficiencies needing improvement were noted, including:
a.
Laboratory procedures not in final form and approved by management, b.
Incomplete recalibration of redrifted Geli detector, c.
Missing items in the annual reports such as explanations of missing data and of differences with licensee data, description of lower limits of detection (LLD) achieved, and description of EPA cross check program participation, and d.
Minor discrepancies between contract sampling requirements and performance.
The appraisal team also observed that laboratory space, although improved, is still somewhat crowded and that the GeLi spectroscopy system currently used is somewhat antiquated by present standards and should be considered for eventual replacement.
4.
Organization The current contract is with the State of Wisconsin, Department of Health and Social Services (DHSS), Division of Health. Administration of the contract is the responsibility of the Chief of the Section of Radiation Protection (SRP) within the Bureau of Environmental Health.
SRP collects or arranges through subcontract for sample collection and maintains liaison with the State Laboratory of Hygiene (SLH) which performs the sample analyses under subcontract.
This arrangement is based on a Memorandum of Understanding (revised and updated February 1982) between SLH and DHSS.
SLH is a part of, and is located on the campus of the University of Wisconsin in Madison.
Its work related to this contract is a very small part of its overall responsibility.
The following diagrams show the organizational structures and the present incumbents.
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DIAGRAM 1 State of Wisconsin, Department of Health and Social Services Ggvernor l Donald Percy,, Secretary, DHSSI
' K. Rentmeister, Administrator Division of Health L. Riddle, Director, Bureat) of Environmental Health L. McDonnell, Chief, Sectior of Radiation Protection lID.Hendrickse, RadiationConsultantf 4
DIAGRAM 2 State Laboratory of Hygiene University of Wisconsid fStateLaboratory.ofHygieneBoard}
(R. II. Laessig, Ph.D., Director, SLHI g-7 i
'D.
Hassemer, Assistant Chief of Clinical Chemistry' I
l R. McElmurry
,L. West J. Edison l
Chemist j
Chemist
( Chemist, l
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5 Liaison between SRP and SLH appears to be effective. SRH was involved in the development of analytical procedures and in the training of the chemists. A representative of SRP visits the laboratory frequently and is available for consultation on problems. He also reviews the finished data forwarded weekly by the laboratory.
In addition to the organization described above, a Radiation Protection i
Council consisting of ten members appointed by the Governor and the legislature serves to advise the Governor and the DHSS on radiation j
matters.
5 Management Support Management commitment and support were discussed with the Chief, SRP, i
and his supervisor, the Acting Director of the Bureau of Environmental Health and with the Director, SLH, and the Assistant Chief of Clinical Chemistry, SLH.
1 It was indicated that the State remains firmly committed to continuing the program. State funding for it continues to exceed the NRC's.
The presence of three chemists in the SLH radiological unit gives an improved backup capability. Two of the three are largely involved with this program; the third is concerned mainly with the EPA Drinking Water Program.
6.
Policies and Standards i
The appraisal team reviewed State policies and standards relating to environmental monitoring. These are presented in the revised Wisconsin Administrative Code HSS 157 published September 1982. Under this code, i
the State incorporated the same standards for protection against i
radiation as in 10 CFR Part 20.
Except for Section HSS 157.16, " Radio-activity in Community Water Systems", radiological environmental 1
I monitoring is not directly addressed. However, the State follows the general Radiological Environmental Monitoring Program (REMP) described in the NRC's Radiological Assessment Branch Technical Position, l
Revision 1, November 1979.
I The appraisal team reviewed selected SLH procedures including those for operation of the Nuclear Data ND130 gamma spectrometer, gross i
alpha and beta radioactivity in drinking water, analyses of iodine and strontium in milk and water and other procedures relating to i
l analyses of soil, fish, and vegetation. Most of the procedures are based on standard references but not all have been put into the standard laboratory format. Only one, that for drinking water, was fully complete in final form and approved by the Assistant Chief of j
Clinical Chemistry. The others appeared to be close to completion and had been entered into the laboratory computer system. The ND 130 procedure appeared to be in need of updating to reflect current practices. Laboratory management recognized the need for completing l
the procedures and stated that effort would be devoted to this over the next six months.
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i In discussion with SRP and SLH representatives, it was also agreed to i
include levels requiring non-routine action such as expedited notification and/or reanalysis in the laboratory procedures.
The appraisal team also reviewed the laboratory system for tracking samples from receipt to the entering of analytical results on data sheets. Good records are kept. Copies of data sheets are sent weekly to SRP for routine review.
7.
Staffing The appraisal team reviewed the background and experience of the staff that implements the contract.
L. McDonnell, Section Chief, SRP, has a M.S.
in Physics and about 24 years experience in engineering physics and allied disciplines. The past 14 years have been related to radiation effects and radiation protection, including four years as a Radiation Consultant in SRP prior to appointment to his present position in 1974.
Mr. McDonnell also is a member of a task force for the NBS Radiation Measurements Program and Chairman of the Environmental Nuclear Council of the Radiation Program in the states. He has been responsible for administration of the contract since its inception.
D. Hendriske, Radiation Consultant, SRP, has a B.S. In Chemistry and about eight years experience in radiochemical analysis for SRP prior to his present appointment.
Mr. Hendriske was involved in the training of the chemists and is available to provide consultation.
j He visits the laboratory regularly and reviews the analytical data on a weekly basis.
David Hassemer, Assistant Chief of Clinical Chemistry, SLH, has a M.S.
in Chemistry and has been employed with the SLH for 11 years previously I
involved in blood chemistry. He has been in his present position since 1977 and has been directly involved in daily administration of the l
radiation protection laboratory for the past two years.
I R. McElmurry, Chemist, SLH, has a B.S.
in Chemistry and taught high school chemistry before joining SLH in the fall of 1979.
Mr. McElmurry is responsible for most of the daily ccunting work in the i
laboratory.
L. West, Chemist, SLH, has a B.S. in Chemistry and has been with SLH l
since November 1980.
Ms. West performs chemical separations and counting for the strontium and iodine analyses in milk and water.
l L. Edison, Chemist, SLH, has a B.S. In Chemistry and was employed by Commonwealth Edison for about one year before joining SLH in December 1980.
Ms. Edison performs analyses for radium in drinking water and i
is knowledgeable in the operation of gamma spectroscopy systems using Nal and GeLi detectors.
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Training 4
Between August 1980 and February 1982, the Section of Radiation Protection (SRP) had its office at the laboratory to assist SLH in developing its capabilities for radiological analyses. SRP gave on-the-job training to involved SLH personnel and helped in development i
of analytical methods. This effort, together with continued stability in staffing at SLH appears to have contributed significantly to the capability observed by the appraisal team.
f The laboratory has also employed Professor D. Showalter of the University of Wisconsin, Stevens Point, during summers to provide consulting service in radiochemistry, primarily for guidance in I
equipment calibration and operation of new equipment.
Offsite training within the past two years has included a one week radiochemistry course at the NRC Reference Laboratory in Idaho attended by Hendriske (Oct 80) and McElmurry (Feb 81), a three day environmental radiation workshop at Argonne National Laboratory attended by Edison (Apr 81), a consultation visit to Argonne on radium analysis techniques by Hendriske and Edison, and to the University of Wisconsin, Lacrosse, on strontium and iodine analyses in milk by West.
Laboratory management recognizes the value of such training, but budget restrictions limit its availability, 4
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Facilities and Equipment The appraisal team visited the SLH 1aboratory. Space devoted to sample preparation and analysis is somewhat improved since the last appraisal but still quite limited. The area used for sample preparation is in a l
laboratory shared with another SLH group. There is no fume hood i
dedicated to the radiological work except for the last stages of the l
strontium and lodine in water preparations which are done in a hood in a general laboratory on another floor. Normal laboratory facilities i
such as drying ovens, centrifuges, and analytical balances are present.
l The nature of the facilities necessarily restricts SLH to low level radiological work.
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The counting room facilities are basically unchanged since the last l
appraisal.
It consists of two rooms with a total of about 275 square feet of floor area. One contains two gamma spectroscopy systems including shields, detectors and other associated equipment. The other contains a Tennelec LB 5100 gas flow proportional counter used l
for gross alpha and beta counting, a Beckman LS 100C liquid scintil-lation counter used for tritium in water, and a Beckman Wide Beta II used for analysis of strontium 89-90 and iodine in milk and water.
The gamma spectroscopy systems are somewhat antiquated. They include I
a Nuclear Data ND-130 512 Channel MCA with IBM typewriter printout used with a four inch NaI (TI) detector, and a Tracor Northern 1024 MCA l
with teletype output, normally used with a GeLi detector. The latter MCA has been inoperative and a loaned Canberra Series 40 MCA was being used.
None of the systems were computer based and all data l
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reduction is done by hand from hardcopy printout, a time consuming and inefficient procedure. The Director, SLH, indicated that a new MCA was first on the list for capital equipment replacement assuming funds are available. Computer based data reduction capability is desired and systems allowing interface to the laboratory PDP 11 computer system are being considered.
The GeLi detector required redrifting in September 1982. While it was out of service, a rented detector was used. The GeLi detector is back in service and in the process of being recalibrated. Laboratory per-sonnel said it suffered essentially no loss of resolution.
SLH is considering getting an intrinsic germanium detector.
The laboratory relies mainly on certified standards obtained from USEPA, NBS and Amersham. They appeared generally adequate for instrument cali-bration.
The iodine on charcoal cartridge calibration is done with a spiked cartridge prepared in the laboratory.
10.
Quality Assurance Laboratory quality assurance appeared generally good. Analytical procedures provide for routine replicate analyses to verify methods and instrument operation. Counters are calibrated regularly with traceabic sources and daily performance checks are made between calibrations.
Quality control charts are maintained on the counters. The current one for the gas counter showed some drifting out of the predicted control limits which appeared to be related to gas bottle changes.
It was suggested that these limits be recalculated when bottles are changed rather than after a fixed time interval as is currently done.
SLH participates in the EPA interlaboratory crosscheck comparison program for radioactivity in water, milk, food, and air (particulate filter geometry).
The laboratory has performed well in these comparisons.
The EPA program does not provide a crosscheck on iodine in charcoal cartridges. Calibration for this gecmetry is obtained using a cartridge spiked by SLH using an EPA furnished radiciodine standard.
It was agreed that an independent check would be made for this geometry using a com-mercia11y prepared spiked charcoal cartridge owned by SRP.
I SRP performs an essential quality assurance function through review of the weekly data submittals from the laboratory. The reviewer is familiar with the sample collection program and is experienced in the performance of the analytical work done by the SLH 1aboratory.
In addition, the Laboratory's performance in the EPA crosscheck program is followed.
11.
Communications Annual reports containing the results of the monitoring program are routinely distributed to the NRC, the power plant licensees and to 9
other state agencies including Agriculture, Natural Resources, and the Public Service Commission. There were no nonroutine events reported during the period of this appraisal.
Some upgrading in the reports is needed to effect complete congruity with requirements.
In particular, the reports should include explana-tions of all missing data, of significant differences between licensee and State results, a description of EPA crosscheck program results, and a table showing the lower limits of detection (LLD) achieved by the State in its analyses. An LLD table was included in the 1981 report for Lacrosse but not for Point Beach or Kewaunee. The appraisal team-discussed the State's LLD for the various media. Certain LLD's in the current contract appeared to be overly restrictive and will be revised when the contract is renewed in January 1983.
12.
Performance 4
Adherence to the contract was reviewed by examination of sampling and analysis records, the State's annual reports and discussion with in-volved state personnel. Overall, performance has improved significantly, owing largely to the fact that laboratory analyses were able to keep pace with sample collection. This was a problem before 1981.
Generally, results reported by the State and the licensees were below the contract specified lower limits of detection (LLD). When results were above the LLD's, for the most part they were comparable. Some exceptions were noted for reported gross beta activity on weekly air particulates. The activities were always low, generally in the range of IE-15 to IE-12 pCi/cc and there was no coordination between the 1
State and licensees to assure that delay intervals before counting were the same.
Minor discrepancies were noted in that edible vegation samples and fish sampics (Kewaunee and Pt.
Beach) are not true splits with the j
licensee in that the two parties sample at different times and places.
Also sediment samples are not being taken for the Point Beach plant l
although they are for nearby Kewaunee.
SRP representatives indicated there were sometimes difficulties in coordinating with the licensees for sampling and/or analysis. They indicated these matters would be addressed with the licensees.
13.
Exit Interview The appraisal team discussed the scope and findings of the appraisal at the conclusion of the appraisal on November 24, 1982.
Separate meetings were held with the management of the State Laboratory of Hygiene and the Division of Health at their respective locations.
The appraisal team noted the State's generally good performance and, in particular, the significant improvement in the quality of laboratory work since the NRC appraisal in 1980.
Additional work is needed to complete and approve laboratory procedures. The SHL representative stated that this would be emphasized during the next year.
In addition, SRP agreed to provide nonroutine action levels in the various media for inclusion in the SLH procedures.
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4 The appraisal team also noted the important quality assurance role played by both groups - (1) SLH by incorporation of replicate analysis into routine analytical practices; and (2) SRP by routine review of finished data.
It was agreed that the use of spiked QC samples would be a desireable improve-ment and the SRP representatives agreed to consider the feasibility of providing the SLH with such samples. The SRP also agreed to include a statement in the annual report regarding results of participation of the r
SLH in the EPA cross check program, 3
i SRP also agreed to try to better coordinate sampling to assure that more of the samples are split with licensees.
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