ML20052D916
| ML20052D916 | |
| Person / Time | |
|---|---|
| Issue date: | 03/26/1982 |
| From: | Murray B, Nichols J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20052D909 | List: |
| References | |
| CON-NRC-05-76-379, CON-NRC-5-76-379 99990004-82-01, 99990004-82-1, NUDOCS 8205070315 | |
| Download: ML20052D916 (13) | |
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APPENDIX U. S. NUCLEAR REGULATORY COMMISSION REGION IV Performance appraisal for the NRC/ State of Arkansas Environmental Monitoring Contract No. NRC-05-76-379 Facility:
State of Arkansas Department of Health Appraisal At:
Little Rock, Arkansas Appraisal Conducted:
February 17-19, 1982 Appraisal Period: January 1,1979 - December 31, 1981 Inspector:
3/As-/rz yBlairNichola6,RadiationSpecialist Dhte' Approved by:
dML DMM k8d!81 Blaine Murray, Chief, facilities Radiation Protection
'Date '
Section Ayoraisal Summary Appraisal Conducted on February 17-19,1982 (Report:
99990004/82-01)
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.
Results:
The State's overall performance satisfies the general requirements of the contract regarding' sample collection and analyses.
However, certain contract specifics were not met during 1979.
Deficiencies were noted in the areas of written procedures, staff training, missing data, and lower limits of detection.on certain sample types.
See paragraph 3.
8205070315 820402 IE GA999 ESCAR 99990004 PDR
2 DETAILS 1.
Persons Contacted (Arkansas Department of Health)
- B. Saltzman, M. D., Director, Arkansas Department of Health
- F. Wilson, Director, Division of Environmental Health Protection
- M. Tull, Chief, Emergency Preparedness and Environmental Analysis Programs
- J. Henry, Chief Radiochemist E. White, Health Physicist
- Attended exit interview.
2.
General The purpose of this appraisal was to review the performance of the State of Arkansas (State) concerning the NRC/ State of Arkansas Environmental Monitoring Contract No. NRC-05-76-379.
The independent measurements performed under the contract are associated with Arkansas Power and Light's Arkansas Nuclear One power reactor located near Russellville, Arkansas.
The contract serves as a means of comparison and verification of the environmental monitoring program. conducted by the Arkansas Power and Light Company (Licensee).
The appraisal consisted of a tour of various sample stations including TLD, air, milk, water, and vegetation.
During the tour the appraisal team observed state personnel during the collection of air and water samples.
The remainder of the inspection was spent reviewing with State personnel at the Arkansas Health Department offices at the reactor site and in Little Rock such items as procedures, sample analysis results, laboratory facilities, counting instrumentation, and organization.
It should be noted that the State of Arkansas currently conducts a more extensive environmental monitoring program than required by the contract.
3.
Summary and Conclusions The State's overall effort during the period from January 1, 1979 -
December 31, 1981, satisfied the conditions of the contract.
- However, several identified deficiencies exist.
These include:
a.
Written procedures have not been completed and approved by management for use in the radiochemistry laboratory.
See paragraphs 5 and 10.
b.
No formal training or training outside the State Health Laboratories for the technical staff, other than one course attended by the chief radicchemist in 1980, has occurred since the last appraisal in August 1979.
See paragraph 8.
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c.
The Canberra Scorpio Multi-Channel Analyzer System was out-of-service for several months causing a backlog of gamma isotopic analyses i
.and not allowing.for short-lived radionuclides to be analyzed on a timely basis.
See paragraph 9.
d.
Very little, if any, comparable licensee's data was included in the 1979 annual report.
Comparable licensec's data should be tabulated beside the State's results in accordance with the format illustrated in Attachment No. 3 to the contract.
See paragraphs 13.a., 13.b.,
13.c., and 13.d.
e.
Data for some State water samples were not included in the report No explanation was noted.
See paragraph 13.c.
89 90 f.
No data were reported by the State for 5r and Sr analyses in milk.
See paragraph 13.d.
g.
Vegetable samples were not analyzed per the contract.
See paragraph 13.f.
131 h.
The State's lower limits of detection for I in water and milk do not meet contract requirements.
See paragraph 14.
i.
The State did not submit a 1980 annual report in the time period l
specified in the contract.
See paragraph 15.
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4.
Organization The appraisal team evaluated the following areas associated with the contract:
a.
Management support ~
b.
Organizational structure i
c.
Staffing d.
Training e.
Facilities and equipment t
f.
Procedures g.
Quality Assurance The status of the above items is detailed in the following paragraphs.
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4 5.
Management Support The State has an established environmental monitoring program in addition to the samples and analyses required by the contract. The environmental monitoring program is conducted by the Division of Environmental Health Protection with the support of the Division of Public Health Laboratories. The program is administered by qualified personnel who take a concerned interest in the performance of the program. However, it was noted that considerable time has been required to review and approve a draft copy of the Radiochemistry Laboratory Users Manual. The program is funded with a workable budget to accomplish the present workload and to adequately maintain laboratory equipment and supplies.
6.
Organizational Structure The appraisal team reviewed the State of Arkansas' Bureau of Environmental Health Services and Division of Enviromental Health Protection staff assignments and responsibilities.
The following diagram shows the present structure and assigned individuals.
B. Saltzman, M. D.
Director-Arkansas Department of Health I
J. Hill Director - Bureau of Environmental Health Services
.I F. Wilson F. Horn Director - Division of Environmental Director - Division Health Protection of Public Health Laboratories I
M. "ull J. Henry Chief - Emergency Preparedness Chief Radiochemist and Environmental Analysis I
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I E. White F. Balding L. Floyd Health Physicist Radiochemist Lab. Tech.
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Staffing The appraisal team reviewed the educational backgrounds and j
qualifications of the technical staff.
M. Tull - B.S. in physics' f
Mr. Tull directs the emergency preparedness and environmental programs and is responsible for the administration of the contract.
He has attended the 10-week health physics course offered at Oak Ridge and various ~ other emergency preparedness I
courses.
He has been employed by the State for 6 years and has been working with the environmental program for 2 years.
E. White - B.S. in preveterinary science l
Mr. White lives in Russellville and conducts his job i
requirements from a State office approximately h mile from the plant site.
He does all the environmental sampling for the plant and the State which includes the spliting of samples for the contract.
Mr. White exchanges all the NRC TLDs and monitors that program as well as conducting the State TLD network which includes reading the State's TLDs and tabulating the data.
Approximately 10% of his time is spent on items directly related to the requirements of the contract.
He has attended the 10-week health physics course offered at Oak Ridge and various other emergency preparedness courses.
Mr. White has been employed by the State for.2 years in his present capacity.
l J. Henry - B.S. in chemistry and a M.A. in public health Mr. Henry directs the radiochemistry laboratory operation and is knowledgeable in the radiochemistry laboratory procedures and operation of all the laboratory counting equipment.
He has 3
been employed by the State for 15 years.
F. Balding - B.S. in chemistry Mr. Balding prepares many of the samples that require chemical-separations.
He is knowledgeabla in the operation of the various counting instruments.
He does all of the counting and data collection.
He has been employed by the State for 1
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-year.
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4 L. Floyd - Ms. Floyd has no formal degree in the sciences.
She performs most of the record keeping for the laboratory and data tabulation for reports.
She does some sample counting if required.
She has been employed by the State for 1 years.
The present staff is adequate to perform the analytical workload in a timely manner as long as the analytical instrumentation is performing properly.
8.
Training Offsite' training for laboratory personnel is at a premium because of budget restrictions.
Laboratory personnel indicated that they were aware of various course offerings for state personnel, such as the radiochemistry course given at Radiological and Environmental Sciences Laboratory (RESL) in Idaho Falls, Idaho, but management did not show much interest or encouragement in staff participation.
The chief radiochemist attended, in i
1980, the 2-week course on the Canberra Scorpio system.
Up to the present time, most of the laboratory staff training has been strictly as needed on-the-job.
9.
Facilities and Equipment 1
The, appraisal team toured the laboratory and instrument counting facilities and reviewed the equipment and instruments used to perform the ansTyses required by.the contract.
The laboratories and counting room complex approximates 4000 square feet.' Office space for the chief radiochemist is provided in the corner of the counting room.
Desk space for the radiochemist and laboratory technician is provided as part of the l
laboratory area.
The combined laboratory areas are equipped with radioactive material qualified fume hoods, sinks, utilities and
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approximately 500 square feet of laboratory bench space.
Since the last appraisal a new laboratory area has been constructed adjacent to the j
counting room.
This laboratory is equipped with two fume hoods, utilities, and sinks.
It is currently used for storage.
The following types of laboratory and counting equipment are available:
a.
Refrigerator and freezer for preservation of perishable reag'nts and samples b.
Drying oven for sample preparation c.
Large centrifuge d.
Analytical balance e.
Triple beam balance
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4 f.
Canberra Scorpio, Model 3000, Multi-Channel Analyzer System linked to a PDP-11 minicomputer and associated electronics and used to support a high resolution Ge(Li) detector-The Scorpio system uses a Dec-Writer II as a I/O device along with the MCA console.
As an output hardcopy device, the system is linked to a Centronics line printer.
g.
4"x4" Nal detector inside a thick lead and steel shield linked to a Nuclear Data ND-180 512 channel analyzer gamma ray spectroscopy system used for gamma ray analysis.
h.
Canberra Low Background Alpha-Beta System, Model 2200, gas flow proportional counter with manual sample changers in a four detector array used for beta measurements of planchet samples only.
i.
Canberra low Background Alpha-Beta System, Model 2201, thin-window gas flow proportional counter with a 100 sample automatic sample changer used for alpha and beta measurements on planchet samples of air particulate and water.
The beta background is less than 2 cpm and the alpha background is less than 0.08 cpm.
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Packard Tri-Carb, Model 3320, Liquid Scintillation System used for low-energy beta and tritium analyses.
The system has a 200 sample capacity and stores and counts the samples in a refrigerated environment.
k.
Transnuclear Low Background Beta Counter, Model CLL-4, thin-window gas flow geiger counter used for beta measurements.
1.
Victoreen, Model 2800, Thermoluminescent Dosimeter Reader used for analysis of direct environmental radiation measurements.
The State presently maintains 51 TLD locations around Arkansas Nuclear One.
m.
Air samplers for particulate and air radioiodine sampling are maintained at two locations.
These sites are located at the plant meteorological tower and at the AP&L Danville electrical substation location.
It is the desire of the laboratory to acquire a "back up" Ge(Li) detector multi-channel analyzer system to eliminate the problems of timely sample 4
analysis in the event of long down time on the existing Canberra Scropio system.
This problem has been the experience in the past due to lack of a service contract on the system and the fact that the multi-channel analyzer system is not entirely composed of Canberra equipment.
During 1981 down time of 2-3 months was experienced because of several electronic component problems which had to be trouble shot and repaired without a field service call.
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8 10.
Procedures
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The appraisal team rehiewed existing procedures in the following areas:
sample collection,' sample control, sample preparation, sample analysis, operation of countingiinstruments,-response tests for counting instruments, calibration of counting. instruments, and quality control of analytical counting instrumentation;
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In the areas of sample collection,and sample, control written procedures have been established.
Many an'alytical procedures used by the laboratory are taken directly from published documents but not put into a standard State laboratory format.
The appraisal team noted that written
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procedures to cover many of the labt ory instrument operations and sample analyses have been written ano re included in a draft copy of the Radiochemistry Laboratory Users Mar.ual which had not been approved for use by the Director, Division of Laboratories.
However, some of these procedures were found to be in need of updating and. revision to current practices and instrumentation.
The State commented that they planned to devote an effort during'1982 to establish approved procedures.
11.
Quality Assurance Program The appraisal team reviewed the State's quality control program in conjunction with the laboratory counting instruments.
The State participates in the EPA Cross Check Program.
The EPA provides interlaboratory comparisons of analytical results of spiked radioactive samples.
The EPA Cross Check Program provides sample types of sample media required by the contract except for fish, vegetation, river sediment, and charcoal cartridge.
The State's performance in the program was reviewed and found to be generally acceptable within EPA criteria.
i The State also performs periodic internal quality control measurements on the laboratory counting instruments.
This program consists mainly of response tests and calibrations of the various counting instruments.
These tests and calibrations are performed with radioacti"e sources traceable to the National Bureau of Standards. Written detailed proccdures are not available to document the response tests and calibration results.
However, data from these tests are routinely recorded.
12.
Site Tour of Environmental Sample Stations The appraisal team visited several of the contract sample stations with State personnel on February 18, 1982.
During the tour the appraisal team observed the State personnel collecting air particulate, air radioiodine, and water samples.
Specific sample stations visited include:
a.
NRC TLD Site No. 47 and air control station at Arkansas Power and Light's
-Danville substation.
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b.
NRC TLD Site No. 9 and onsite air sample station at the ANO meteorological tower located 0.1 mile east of the plant.
c.
NRC TLD Site No. 40 located across the road from the Moore National Guard Armory on Highway 28 south of Dardanelle.
d.
NRC TLD Site No. 39 located on telephone pole No. 28 in front of the Russellville High School.
e.
ANO discharge canal water sample station located at the site boundary on the shore of the lake southwest of the plant.
f.
Milk and vegetation sample stations located at the Arkansas Tech. Dairy Farm.
The TLD sites were located with the aid of an area map marked with the TLD site identifications and a written description of their locations.
13.
Contract Required Sample Collection and Analyses l
The appraisal team reviewed the sample analyses for the period January 1, 1979 - December 31, 1979, to determine agreement with Attachment No. 1 to the contract.
The licensee, Arkansas Power and Light, conduct their own environmental sampling and analysis program in cooperatio". with the State.
State personnel perform all routine environmental sampling for the licensee and the State and do all sample splitting required by the contract. _ State personnel perform-all sample preparations and counting in the State laboratories.
The State's TLDs are also processed by State personnel.
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The following contract items were'noted:
a.
Airborne (1) Particulates
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The' State's plant site. sample station is located about 0.7 mile east of_the plant at the ANO meteorological tower.
The State's control sample station is located approximately 21 miles southwest of the plant at the AP&L substation in Danville. The State's air samples'are positioned in close proximity to the licensee's air samples.
(2) Radiciodine Radioiodine charcoal-cartridge samples are collected at the same locations noted above.
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10 The particulate and radioiodine samples are collected weekly.
The air samplers are Eberline Model RAS-2 outfitted with a particulate filter holder preceding a " waffle iron" style charcoal cartridge holder for radioiodine collection.
The' particulate filter presently in use is a 47 mm Gelman loaded filter and the charcoal cartridge is an Eberline Model 10-1 manufactured by Scott Health and Safety Products.
Calibration on the air samplers is performed by state personnel on a 6 month interval.
The gross beta, gamma isotopic, 1317, 895r, and Sr analyses are.
90 performed in the State Health Laboratories by state personnel.
The results reported by the State meet the requirements of the contract.
The appraisal team noted that no licensee data for airborne particulate or radioiodine were included in the report for comparison purposes as required by the format in Attachment No. 3 to the contract.
b.
Direct Radiation Levels In 1979 the State placed LiF TLDs at five locations aro'und the ANG site.
Exposures were read quarterly by the State using-a Victoreen, Model 2800, Thermoluminescent Dosimeter Reader.
At the~present time the State has a TLD network of 51 locations around the plant site.
The State maintains a control TLD at the-State Health Department in Little Rock.
For the data reported for the first and second quarters of 1979, the State results indicated a quarterly average dose of 13 mrem.
The appraisal team noted that the State supplied no data for the third and fourth quarters of 1979.
The explanation offered by the State was that the TLD reader was inoperative during that time.
No comparable licensee data for TLD direct radition measurements was included in the report as per
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Attachment No. 3 to the contract.
During the time' period covered by.this appraisal, the NRC TLD network had not been established.
The initial placement of the NRC TLDs for environmental monitoring was performed during the period December 5-7, 1979.
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Surface Water The State collects a monthly sample from the lake into which the' plant discharge canal flows.
This sample is split with the y,
licensee.
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The contract requires one composite quarterly sample.
Ths contract
.v. does not specify if a single sample constitutes a quarterly i.
composite or that the intent is a :omposite c.f several individual
, - samples such as monthly or weekly.
The contract does not require a' control upstream water sample., This should be considered in future contract proposals and more definitive sampling requirements written.
,The gamma isotopic, tritium, 89Sr, and Sr analyses are performed in 90
\\the State Health Laboratories by state personnel.
The results reported by the State meet the requirements of the contract; however, the following deficieni:ies were noted by the appraisal team:
(1)Liffo data was reported by the State for tritium and strontium
. analyses. for.tne months 'of January 1979.- May 1979 and October 1979.
No explanation is noted in the report; j
s (2) Water sample data for all required analyses is not r'eported for October 1979 and.no explanation is noted in the report.
Apparently no sample was collected.
(3) No comparable licensees data for gamma. isotopic analysis nor-monthly tritium and strontium data which could be directly compared to the State's results were. included in the: report as i
per Attachment No. 3 to the contract.
i d.
' Milk 1-t The State collects monthly milk samples from the following dairies i
and splits these samples with the licensee:
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Arkansas-Tech. Dairy-located 5 miles;fromplantag99 l
0.MeyersDairy-located 8milesfromplantat29Q R. Young Dairy - located 12 miles from plant at 73 The contract requires one quarterly sample at an offsite dairy located in the highest X/Ql direction from the plant.
The gamma isotopic and radiciodine analyses are performed in the i
State Health Laboratories by state personnel.
The following deficiencies were noted by the cppraisal team:
09 90 (1) NodatawerereportedbyftheStatefor Sr and Sr analyses
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[4 for the reporting period from January 1, 1979 - December 31, J
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'3 1979.
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(2) 'TheState's LLD for radioiodine in milk was reported at <5.0 pCi/ liter which does not meet the criteria of <0.4 pCi/ liter as 7
specified in Attachment No. 2 to the contract.
(3),.No-comparable 1icensee's data for gamma isotopic, radioiodine, j
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and strontium analyses were included in the report as per N
Attachment No. 3 to the contract.
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Fish The State collects semiannual, fish samples from the plant intake
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catial and the plant discharge canal.
Individual fish from the catch
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s ar6 divided between the State and the~ licensee for analysis.
f; The contract requires one sample in the vicinity of the discharge point of the plant semiannually or in season.
The contract does not require a control upstream sample.
This should be considered in future contract proposals since this area is a highly fished recreational area and many people fish routinely in both the plant intake and discharge canals.
The gamma isotopic analysis was performed in the State Health Laboratories by state personnel.
The results reported by the State meet the requirements of the contract.
f.
Fruits or Vegetables The State collected a sample of gregn leafy vegetables from the J.
Taylor garden located 1 mile at 135 from the plant site and split the sample with the licensee.
However, no gamma isotopic analysis i
was performed by the State and no licensee's data was included in the report.
14.
Lower Limits of Detection (LLD)
The appraisal team reviewed the State's LLDs for the various sample types to determine agreement with Attachment No. 2 to the contract.
A State representative and the published numbers in the 1979 contract report indicate that the following contract LLD's could not be achieved:
Analysis Sample Contract LLD State LLD 131 1
water 0.4 pCi/l 5.0 pCi/1 l
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milk 0.4 pCi/l 5.0 pCi/l f
131 It is suggested by the appraisal team that future reports include f
LLD tables for all sample media and sample analyses reported to meet the requirements of the contract.
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Audits and Reports A State representative stated that activities performed under the contract are periodically reviewed by supervisory personnel.
- Formal, written audit reports regarding these reviews are not normally prepared.
At the time of the appraisal, the State had not submitted their annual report for 1980 or 1981.
A State representative stated that the 1980 overdue report would be prepared and submitted by March 31, 1982.
The 1981 annual report was in the process of being assembled and would be submitted within the time period specified in the contract.
16.
Exit Interview At the conclusion of the appraisal on February 19, 1982, the appraisal team discussed the scope and findings of the appraisal with the i
individuals denoted in paragraph 1.
The appraisal team expressed concern I
regarding those iteins that did not meet the conditions of the contract.
The State representatives stated that in the future more attention will be devoted to the contract requirements in order to carry out a high quality program.
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