ML20028G144
| ML20028G144 | |
| Person / Time | |
|---|---|
| Issue date: | 01/27/1983 |
| From: | Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20028G139 | List: |
| References | |
| 99990004-82-07, 99990004-82-7, NUDOCS 8302070450 | |
| Download: ML20028G144 (11) | |
Text
- _ _ _ _
APPENDIX U.S. NUCLEAR REGULATORY COMMISSION REGION IV Followup performance appraisal for the NRC/ State of. Colorado Environmental Monitoring Contract No NRC-05-80-267 -
Facility: State of Colorado Department of Health Appraisal at: Denver, Colorado Appraisal conducted:
November 18-19, 1982 Appraisal period:
January 1,1982 - October 31, 1982 Appraiser:
MI
/dd/ps Blair Nichol(s, Radiation Specialist Date NDL d'A
/[O7/B3 Approved by:
i BlaineMurray, Chief,FgcilitiesRadiation D#te Protection Section Appraisal Summary:
Appraisal conducted on November 18-19, 1982 (Report: 99990004/82-07)
Areas Appraised: Adherence to requirements of the contract; organization and management support; sample collection and analytical procedures; facilities and counting instrumentation; technical staffing and training; laboratory quality assurance; and followup on corrective action taken on previous deficiencies.
The appraisal involved a total of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> onsite by one NRC appraiser.
Resul t's - The State's overall performance concerning the general requirements of the contract regarding sample collection and sample analyses was generally acceptable. A review of the 1981 annual report noted several deficiencies in meeting contract specifics.
See Section 3.
Corrective action was in progress in the deficient areas of written procedures, instrument calibration, and program quality assurance.
8302070450 830131 PDR STPRG ESGCO
2 DETAILS 1.
Persons Contacted (Colorado Department of Health)
A. Hazle, Director, Division of Radiation Control M. Hanrahan, Sr. Health Physicist R. Terry, Health Physicist Public Service Company of Colorado F. J. Borst, Manager, Radiation Protection V. J. McGaffic, Radiochemistry Supervisor Colorado State University J. Johnson, Licensee Environmental Contractor 2.
General The purpose of this followup appraisal was to review the content of the 1981 annual report with the State of Colorado and review the corrective action taken on the deficiencies reported in the previous performance appraisal conducted on February 22-24, 1982.
The proposed NRC/ State of Colorado Environmental Monitoring Contract for the period 1983-1985 was reviewed in detail to ensure that sample types and frequencies and analysis types and frequencies were consistent and comparable with the licensee's Radiological Environmental Technical Specifications.
.3.
Sunnary and Conclusion The State's effort, since the previous appraisal conducted in February 1982, has shown improvement. However, several identified deficiencies still exist. These include:
a.
Written procedures have not been completed and approved for sample collection and control, for response tests, calibration, operation, and quality control of all radiation counting facility counting instrumentation, and for preparation methods and documentation for radioactive calibration standards.
See Section 9 for details.
b.
The State's and licensee's control air sample locations were not in close proximity to each other.
See Section 11 for details.
c.
Some data included in the 1981 annual report were not directly comparable. The State's contract and the licensee's Environmental Technical Specification sampling and analysis frequencies were not always identical allowing direct comparison of results.
See Sections 11.a,11.c,11.d, and 11.f for details.
v 3
d.
The State did not report any of their own TLD data or the licensee's TLD data in the 1981 annual report.- See Section 11.b.
gS0 data ygge reported in the 1981 annual report by the State for e.
Ba -
La in milk.
See Section 11.d.
j f.
Fish or invertebrate samples were not collected o analyzed in 1981, as per-Attachment 1 to the ontract.
See Section 11.e.
g.
Vegetable samples collected by the. State in 1981 were not split with the licensee for comparative analysis as per Attachment 1 to the contract. See Section 11.f.
h.
}gy State's lower limits of detection (LLD) for tritium in water and I in water did not meet contract requirements.
See Section 12 for details.
4.
Management Support The State has an established environmental monitoring program to monitor activities at Rock Flats Laboratory and other radioactive material handling areas.in the state in addition to the sampics and analyses required by the contract in the vicinity of Ft. St. Vrain nuclear power generating' station.
The environmental monitoring program is conducted by the Division of Radiation Control with the support of the Division of Laboratories within the Colorado State Department of Health. The program is administered by l
qualified personnel who have experience in environmental monitoring and take a concerned interest in the performance of the program. The State's general fund supports the staff salaries, but very little funding is available for technical equipment support or purchase of new instrumentation.
i 5.
Organizational Structure The NRC appraiser reviewed the State of Colorado's Office of Health Protection, Division of Laboratories, and Division of Radiation Control staff assignments and responsibilities. The following diagram shows the present structure and assigned individuals.
i
4 F. Traylor~, M. D.
~
Executive Director - Colorado Department of Health I
l I
I D. Rice R. Arnott, Ph.D.
Assoc. Director - Colurado Asst. Dir. - Office of Dept. of Health Health Protection l
D. McGuire, M. D.
A. Hazie.
Director - Division of Laboratories Director - Division of Radiation Control B. Dunn
.M. Hanrahan Chief Chemist Senior Health Physicist E. Kray R. Terry T. Toledo Q. Nguyen Radiochemist Health Physicist Sr. Elec.
Sr. Elec.
Specialist Specialist 6.
Staffing There has been one change in the technical staff 'since the previous appraisal conducted in February 1982.
D. Mauer is no longer employed by 4
the Colorado State. Department of Health.
-R. Terry has been transferred to the Division of Radiation Control and has assumed the responsibilities of the health physicist position. Mr. Terry's educational background, qualifications, and responsibilities are as follows:
R. Terry - B.S. in Biology / Biochemistry Mr. Terry is responsible for most of the gamma -isotopic analysis work performed in the radiation counting facility using the Ortec, Model 7040, Multi-Channel Analyzer System. He.is knowledgeable in the counting facility procedures and operation of all the counting equipment. He performs most of the counting instrument quality assurance work and is responsible for revising and writing program implementing procedures for f
the radiation counting facility. He has taken the Radiological Emergency Response Operations Training Course in Las Vegas, Nevada; the Radiochemistry Course for state personnel in Idaho Falls, Idaho; the Uranium Licensing and Compliance Course in Bethesda, Maryland; and 1 year of graduate school.
l Mr. Terry has been employed by the State for 5 years as a chemist previously working in the areas of air and water polution specializing in radiochemistry.
7.
Training Since the previous appraisal in February 1982, the laboratory radiochemist attended the radiochemistry course offered for state personnel at the
5 Radiological and Environmental Sciences Laboratory (RESL) in Idaho Falls, Idaho, and the senior health physicist attended the FEMA course on Dose Calculations offered at Hanford, Washington. All other training for the radiation counting facility technical staff has been on-the-job as needed.
8.
Facilities and Equipment Since the previous appraisal in February 1982, the 4" x 5" NaI detector had been replaced with a second 3" x 3" NaI detector for gamma ray analyses.
It was housed inside a lead and steel shield and linked to the Nuclear Data, Model ND-66, Multi-Channel Analyzer System. Also, the old Ge-Li detector had been replaced with a 12 percent intrinsic Germanium detector for high resolution gamma spectroscopy analyses using the Ortec, Model 7040, Multi-Channel Analyzer System.
The Tennelic, Model LB-5110, low background alpha-beta gas flow proportional counter is currently calibrated for gross alpha and gross beta measurements on planchet samples of water.
The operating problems with the Ortec, Model 7040, Multi-Channel Analyzer System have been resolved enabling the system to be reliable for high resolution gamma spectroscopy analyses of environmental radiation level samples.
All other equipment and facilities remain the same since the previous appraisal.
9.
Procedures The NRC appraiser reviewed the State's progress in developing program procedures, which were lacking or in need of revision from the previous appraisal conducted in February 1982, to determine the adequacy and. status of approved procedures.
Documents Reviewed S-1, " Sample Management" Yet to be written 5-6, " Sample Collection-Soil" Draft S-9, " Sample Collection-Milk" Yet to be written E-10, " Proportional Counter-Air Particulate-Alpha" Yet to be written E-14, " Gamma Spectrometry-Nal-3" x 3" 6/7/82 E-16, " Annealing TLD's" 10/30/79 E-22, "Tennelic LB-5100 Gross Alpha and Beta in Water" 10/15/82 QC-17, "Tennelic LB-5100" 10/1/82
6 The NRC appraiser noted that several previously deficient procedures had been revised or developed since the last appraisal indicating that the technical staff was concerned with improving the radiation counting facility program. A considerable amount of time and effort over the last several months had been directed toward writing operating and calibration procedures for the Tennelic, Model LB-5110.
The NRC' appraiser reviewed the calibration results of the Tennelic system and the two NaI detectors linked to the Nuclear Data, Model ND-66, Multi-Channel Analyzer System. The Tennelic, Model LB-5110, low background alpha-beta gas flow proportional counter was found to be fully calibrated for gross alpha and gross beta measurements on evaporated water samples.
The two Nal detectors were found housed _inside their respective lead and steel shields and recently calibrated for the various sample counting geometries including: 3.5 liter Marinelli beaker,1.0 liter Marinelli beaker, 4-inch diameter air filter, 8 x 10-inch Hi-Vol air filter, and 4 ounce specimen cup.
The NRC appraiser is still concerned that formal documentation as to counting instrument calibration, counting instrument response tests, and radioactive standard's preparation is still greatly lacking.
The State's conscientious effort to improve the radiation counting facility program needs to continue.
- 10. Quality Assurance Program The NRC appraiser reviewed the State's quality control in conjunction with the radiation counting facility instruments. As noted in Section 9, detailed written procedures were lacking to demonstrate an implemented QC program.
The State participates in the Environmental Protection Agency (EPA) Cross Check Program. The EPA provides interlaboratory comparisons of analytical results of spiked radioactive samples. The State's performance in the program during 1982 was reviewed and found acceptable within the EPA criteria.
A sunmary of the EPA Cross Check Program results was included in the'1981 annual report as required by the contract. The State's most consistent performance was in analyzing gross alpha and gross beta in water, gross alpha and gross beta in air particulate, and tritium in water.
Radionuclide ganma emitting nuclide analysis of water and milk showed definite need for improvement.
- 11. Contract Required Sample Collection and Analyses The NRC appraiser reviewed the sample analyses reported in the 1981 annual report to determine agreement with Attachment 1 to the contract. The licensee, Public Service Company of Colorado, by contract with an independent laboratory, conduct their own environmental sampling and analysis program in cooperation with the State.
State personnel performed all sample prepara-tion and analyses in the State laboratories except for low level radiciodine in milk and TLD direct radiation measurements.
i 7
i The following contract areas were examined in the review of the 1981 annual report and the various deficiencies-noted:
a.
Airborne (1) Particulates The State's plant site sample sic. tion was located about 0.8 mile south of the plant at a farm building. The licensee's air sampler was colocated in close proximity to the State's air sampler. The State's control sample station was located 10 miles south-southeast of the plant at the Colorado highway maintenance yard in Fort Lupton, Colorado.
The licensee's control air sampler was located about 3.5 miles south-southwest of the plant.
Therefore,
.the licensee's control air sampler and the State's control air sampler were not located in close proximity to each other as required by the contract.
(2) Radioiodine Radiciodine charcoal cartridge samples were collected at the same locations noted above for particulates.
Airborne particulate and radioiadine samples were collected yggkly at the locations defined. The gross beta, gamma isotopic, and I analyses were performed in the State Radiation Counting Facility by State personnel.
The results reported by the State in the 1981 annual report met some of the specific requirements'of the contract; however,_the NRC appraiser noted the following deficiencies:
(1) The State's and licensee's control air sampler locations were not in close proximity to each other as required by the contract; therefore, the results reported for the control locations were not directly comparable. The State has agreed to install an additional air sampler at the licensee's control location in 1982.
(2) The licensee's gamma isotopic results for air particulate were 3
J not reported in the annual report as required by Attachment 3 to the contract. The explanation offered by the State was that the data were not directly comparable with the State's results because the licensee performed the analysis weekly rather than quarterly and analyzed a composite of all air sample locations rather than individual sample analysis by location. Adoption of new standardized Environmental Technical Specifications in 1982 by the licensee should eliminate this problem by providing data which will be directly comparable to the data required by the State contract.
-l 8
b.
Direct Radiation Levels In 1981 the State maintained a TLD network of locations around the Ft. St. Vrain station along with the NRC TLD network established in 1980.
Several of the State locations were colocated with the NRC and licensee locations.
The NRC appraiser noted that no TLD data were reported in the 1981 annual report as per Attachnent 3 to the contract.
In future reports, data for the State-NRC-Licensee colocated locations should be tabulated for comparison purposes.
c.
Surface Water In 1981 the State collected an effluent water sample and a control upstream water sample each month which were split with the licensee.
The contract required a gamma isotopic analysis monthly and a tritium analysis quarterly on each sample. The gamma isotopic and tritium analyses were performed in the State Radiation Counting Facility by State personnel.
The results reported in the 1981 annual report met those specific requirements of the contract; however, the NRC appraiser noted the following deficiencies:
(1) Only three isotopic results from the monthly gamma isotopic analyses performed by the licensee, which could be directly compared to the State's results, were included in the 1981 annual report. Adoption of new standardized Environmental Technical Specifications by the licensee in 1982 should eliminate this problem.
(2) The State composited by location the monthly water samples for quarterly tritium analysis as per Attachment 1 to the contract.
However, the licensee analyzed the water samples for tritium on a monthly frequency as required by the licensee's Environmental Technical Specifications. The different sample treatment and tritium analysis frequency produced no comparable analytical results. Adoption of new standardized Environmental Technical Specifications by the licensee in 1982 and changes to the State contract should provide ana'.ysis results which will be directly comparable between the State and the licensee.
d.
Milk In 1981 the State collected a monthly milk sample fro.. station F-44 located about 1.1 miles east of the plant and split the sample with the licensee.
The contract required only one monthly sample from an offsite dairy located in the highest X/Q direction from the plant.
The monthly gamma isotopic analyses were performed in the State Radiat{ggCountingFacilitybyStatepersonnelandthemonthlylow level I analyses were performed by a commercial laboratory.
'l 9
The results reported in the 1981 annual report met the requirements of the contract except for the following deficiencies-noted by the NRC
-appraiser:
140Ba 140La analysis in-(1) No data was reported by the State for milk for the entire year.
No explanation was noted in the report.
(2) Only one.' isotopic result, 137Cs, from the monthly gamma isotopic-analyses performed _ by the licensee, which could be directly compared to the State's results, was included in the 1981 annual report. Natural occurring potassium or radioactivity should not be reported. Adoption of new standardized Environmental Technical Specifications by the licensee in 1982 should eliminate this problem.
e.
Fish The contract required one sample of a commercially or recreationally important species in the vicinity of the plant discharge to be sampled semiannually or in season.
Fish and/or invertebrate samples were not collected during 1981. The explanation noted in the report was that game fish or commercial fish were not available.
f.
Food Products In 1981 the State collected potatoes from a site about 1.0 mile south of the plant and corn and beet tops from a site about 0.5 mile southeast of the plant. The samples were not split with the licensee as required by Attachment 1 to the contract.
The results reported in the.1981 annual report had the following deficiency:
(1) The food product samples collected by the State were not split with the licensee; therefore, no corrparable gamma isotopic data were available for the report as per Attachment 3 to the contract.
g.
Sediment from Shoreline The contract required one annual sample split with the licensee for gamma isotopic analysis of shoreline sediment along a body of water into which the plant discharge flows. A sediment sample from location E-38 located about 1.3 miles north-northeast of the plant on the shore of Goosequill pond was taken in March 1981 and analyzed by both the State and the licensee.
134 137 The results reported by the State indicated that Cs and Cs isotopic activities were below the lower level of detectability gits. The licensee's lower level of detectability limit for Cs was reported at approximately an order of magnitude higher than the State.
10
- 12. Lower Limits of' Detection The NRC appraiser reviewed the State's LLD's for the various types of samples to determine compliance with Attachment 2 to the contract. The LLD's published in the 1981 annual report met the limits established in to the contract except for the following cases:
Analysis Sample Contract LLD State LLD Tritium water 330 pCi/l 350 pCi/1
~131 1
water 0.4 pCi/l 10 pCi/l The LLD's proposed in the 1983 environmental contract' should help eliminate thisanalysissensitiv{3yproblem. The proposed LLD for' tritium in water is 2000 pCi/1 and for I in water is 1.0 pCi/1.
It is suggested by the NRC appraiser that fut' re reports include an LLD u
table for each sample media and sample analysis reported for both the State's and licensee's results.
f
- 13. New Contract review The NRC appraiser met with representatives from the State and the licensee to familiarize all parties involved with the sampling and analysis requirements of the new contract. The following items were discussed:
(1)
A. review of all sample media, number of samples, frequency of collection, frequency and type of analysis, and sampling location was performed.
The contract sampling and analysis requirements were modified to coin-cide with the licensee's ' proposed Environmental Technical Specifications so that comparable data between the State and the licensee would be available for the annual report.
(2)
It was agreed that a quarterly exchange of data would be made on the split samples between the State and the licensee to facilitate the timeliness of reporting.
4 (3)
It was agreed that TLD data would be normalized to a 90-day quarter and reported in terms of mR/90-day quarter per site for direct comoarison between the State, licensee and NRC.
(4)
It was agreed that the annual report compiled by the State as a contract requirement would be submitted to the licensee for a 10-day comment period prior to submittal to the NRC Region IV office.
4-3
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