ML20137U341

Acceptance Appraisal Rept 99990004/85-10 on 851017-18.Major Areas Discussed & Appraised:Terms of Environ Monitoring Cooperative Agreement,Mgt Support,Organizational Structure & Facilities

ML20137U341
Person / Time
Issue date:	11/22/1985
From:	Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
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ML20137U317	List: ML20137U313 ML20137U341
References
99990004-85-10, NUDOCS 8512090270
Download: ML20137U341 (10)

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{{#Wiki_filter:- w.. - jy ':. m G 43 e. V ,h- ? 4 < a. s a APPENDIX ~ I .S.-iNUCLEAR REGOLATORY COW 4ISSION . REGION ~IV a x Acceptance appraisal.for..the NRC/ State of Nebraska Environmental Monitoring Cooperative Agreement Facility: State ofl Nebraska Department of Health Division-of Radiological Health Division of Health Laboratories-- .. Appraisal At: 1 Lincoln, Nebraska -Appraisal ' Conducted: October 17-18, 1985 } Appraiser: //!L2/rf dh Blair Nicholas,lSenior Radiation Specialist .Date .'86cilitiesgadiological: ProtectionSection; 4 IApproved: .b b /i/.t.t /pr' Blpfne Murray, Chief,' Facilities Radiological Date y Wrotection Section Appraisal Summary. Inspection Conducted October 17_10u,981 (Report 99990004/85-10) l 3 Appraisal-Purpose: To perform t preagreement" review to determine the capabili-ty.of:the State of Nebraska to provide services of the quality necessary for conducting an environmental nonitaring program for the NRC around the Fort'Calhoun Nuclear Station and Cooper Nuclear Station. 4 b S re'a's Discussed'and Appraised: Terms of the environmental ~ monitoring coopera-A ?- ' tive agreement,. management.suppcrt, or;j nizational structure, technical imple-- J. mentation ~ procedures, counting 'instreaentation, laboratory instrumentation, and facilitiesc The' appraisal involved c totas of 28-hours onsite by one NRC appraiser andethe' Chief, Facilities Rad M ogical Protection Section. ~ a 8515090270 851203 -i-IE GA999 ESGNE 9990004 PDR r } 5, 4 f e + n , w

g ,~ii ; - ~ a ^ a 2 ~Results: 'The state is presently conducting a limited environme tal~ monitoring n program around Fort Calhoun Nuclear Station and Cooper Nuclear Station.- Some .of the' sampling.and analyses requirements specified in the proposed NRC/ State 1 C - of Nebraska ~ Environmental Monitoring Cooperative Agreement are currently being performed by the' state.- The state is presently under' contract with the NRC to exchange the TLDs associated with the NRC's TLD direct' radiation monitoring

networks established around Fort Calhoun Nuclear Station and Cooper Nuclear Station. The; state should be able to accomplish the work.specified in'the-

. proposed cooperative agreement-with only a few additional samples to their

present; program such as milk, food products', fish,fand shoreline sediment.

It is recommended that the necessary actions be completed in order'to implement -the proposed cooperative agreement effective January 1,1986. I l b 6' e, _e s 4 -'? 1 T \\ d . s, W g --t* e 4 L E \\ P

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<~ y, ^ L 4 + ,y 3 r. e 3,, 1 y ,asc 1 1 ^ JJ DETAILS 5 W q c : 1 7 t g 4 ,+. .a gbI '[ , Persons Contacted ' f ENeb' ras'ka.' State Departhent'of Health (NDH) ?'

• R[ Beck, Deputy Director. Administration,;NDH

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• B.-Macy,-Deputy' Director -? Programs, NDH r

'*J. Balk,; Radiochemist, Health Laboratories f ' '*J. Blosser, Director,. Division of Health Laboratorios s

• H.-Borchert,' Director,1 Division of Radiological Health 1r

• B.

Casari, Director, Bureau of Health Protection ~ .J.'DeFraine,-Radiation Health Specialist-4

• C.. Horn,'ChiefLChemi,st, Health Laboratories C

C.; Rogers,' Health Physicist

• E. Simmons,' Radiological Health
• M. Smith, Laboratory Supervisor, Health Laboratories

. 'Others ~*B.'Murray, Ch.ief, Facilities Radiological Protection Section, v - U.S. Nuclear Regulatory Commission, Region IV j ~.

• Denotes.those present during the exit briefing on Octobar 18,.1985.

~~ 2. General '4 ..The purpose of this apprai. sal was toireview the capability of the State-of =- Nebraska to enter into=an. Environmental Monitoring Cooperative Agreement .with theJNRC and discuss the' terms and conditions of the cooperative 1 agreement.W The environmental' independent measurements performed under.the f 1 cooperati.ve agreement:are to be associated with the Fort Calhoun Nuclear -Station'and: Cooper Nuclear' Station located near Fort Calhoun, Nebraska, 'and Brownville, Nebraska, respectively. - -The discussion and ensuing. appraisal included history'and purpose of the 4 -NRC environmental monitoring! program, explanation of the terms and condi-tions of the proposed cooperative agreement,'and a review of~the technical staffing, staff training and experience, organizational structure, manage-

rial support,I procedures, technical-instrumentation, and laboratory facilities.'

~ g P ~ a.7 -It should be'noted that the State of-Nebraska, Division of Radiological N Health, with the' support of;the' Division of Laboratories presently con-' . ducts a limited environmental monitoring program around Fort Calhoun-a Nucle'ar Station 'and Cooper Nuclear Station sites. Some of the sampling --,J. and analyses requirements specified in the proposed NRC/ State of Nebraska. . ~ [' f q',', s E t <l Qt _ { + v. ~ s s 7 ,nu s. -l E.X m

p,. _ g p". = r 4 .4' ^ w W, . Environmental. Monitoring Cooperative' Agreement are currently being per-Lformed by~the state. -The state is presently under contract with the NRC to exchange the_TLDs' associated'with the;NRC's TLD direct radiation imonitoring ' networks established around Fort Calhoun Nuclear Station and' ~ TCooper Nuclear Station. 1 l3; ? Summary-and Conclusion' s t .;In; general' the state has the capability to. satisfy the conditions of the - 6 proposed cooperative' agreement. However, the NRC appraisal team identi-g". - (

fied the following items which require'the state's attention:

p a. The state appeared to need an additional technician to support the-1 professional personnelLin order'to satisfy the requirements of,the t proposed cooperative agreement. See. paragraph 8 for details. J g .b. 'The state does not currently have an established,' comprehensive-1 environmental monitoring program around the two nuclear power facili ' ^, ties'. 3See paragraph-10,for details. ce - c.: The state had not completed all>prccedures regarding the environmen-

tal/ radiological monitoring program.

See paragraph 12 for details. t d. .The' state had not completed ' calibration of the' gamma spectroscopy-system for al_1_ sample media and counting geometries required by the-proposed cooperative agreement. See'. paragraph 13 for details. e. .The state had not. verified all* lower levels of detectability for radionuclides in allfenvironmentalisample media against;the require-ments of'the proposed cooperative agreement. See paragraph 14 for + details. , ~ x.

The NRC appraisal-teamtfound the state's laboratory equipment,Lnuclear counting. instrumentation, and facilities ~ adequate to meet tne requirements of the proposed" cooperative ' agreement.; Howe'ver,- several ' items of concern J

O were identified and'listedfabove which require _the state's attention. The NRCfappraisal. team feels'that.most of these items of concern can be , resolved by December:1985., Accordingly,.the NRC appraisal team recommends. ~ that an Environmental Monitorin'g Cooperative Agreement be negotiated and .put 'in force'with the State of. Nebraska etfective January 1,1986. ~ 4 4..

Areas Evaluated.

b N The NRC appraisal' team' evaluated the following areas which would affect h 1 'the performancs'of the proposed cooperative agreement specifications: s C (a. Management Support n. w '1,- v . j [ r , If ' th s 'SL (__

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w g n;g > ;_ ' f.; ! sEnvironmental Monitoring Experience- .,y a w ~_

g. m Facilities and' Equipment

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Lower Limits of Detection ~ ,~ 3 m ~ v. ' f' LThe. status'of}the;aboveitems.isdetailedin-thefollowingparagraphs.

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,4 ,' 5 '.* ' I Management Support u I' ~ ,,f,, ,MR

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+ @ hThe stite. currently has'a' limited environmenta1' monitoring-program around c JJ

thettwo nuclear powerfstationsDlocated in Nebraska.4 Discussions with the

~ 5 i.;NDH~ management indicated that'there was a strong' interest in initiating an c ' environmental 7 monitoring program as. proposed ~1n th'e cooperative agreement ~ / < a'nd'that the,DivisionLof Radiological)Hea1th'with'the;supportfof'the Division of Health 'L'aboratories was : ready to' administer and conduct such'.a f tu a.. S 1 cooperative 1 agreement by providing personnel,Lfacilities,2and budget.,. n m a# g .,.i." 3 e 4r p,;4 __ e "y e

c. 6.., iOrganizational Structure, s.g y;

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f. 4x t ' i.The NRC.appraisd, team reviewed the current;NDH itaff as'sigrinentsian'd f -

[R i e responsibilities;aC to.how they would relateito-parforming the' proposed 7' i X c ecooperative agreement. The,following.; diagram shows;the present structure, i. and assigned individuals: & s?,

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R.' Beck, ' Deputy Director

B. Macy, Deputy Director; PV Administration Prog rams 'J ..'J. Blosser, Director,.., , 8.-Casari, Director "3 Division ~of Health' Laboratories Bureau of Health Protection ,7 s s- ~M. Smith-s H. Borchert, Director. Laboratory Supervisor c Division of Radiological: Health i t . -C. Horn

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-C. Rogers. L, Chief ' Chemist -, Health Physicist t

J. Balk J. DeFraine o

~ Radiochemist Radiation Health Specialist ~ r in-h' T. Jones. s g Laboratory Technician 6.: The NRC appraisal team determined that the~ organizational lines of author >e g ity.were such that the contracting officer, the Director of Health, had direct control over the4 administration of the cooperative agreement and'- y the analytical laboratory and field personnel. 7. 3 Budaet JT'e NRC" appraisal team ' discussed the state's budget-as it relates to h ~ fund.ing a s~ampling and analysis program for environmental monitoring. The . stateris currently funding administrative personnel and two. laboratory "c ' -.c staff in~ radiochemistry..The budget supports the current activities of I s d 4 3 .i_

3 37 y [ '- th 7 .the, limited environmental monitoring program including sampling, radio-chemistry, laboratory equipment, and instrument support. m '- The cooper $tive' agreement is'not intended to provide full cost recovery to ~ .the state and the. state informed the-NRC appraisal team that state re-sources would=be made available.to accomplish the requirements of the k ' cooperative 'ag'reement. L ,. U 8,' .StaffinoL 4 /, 4 TheNRCippraisal'teamreviewedtheeducationalbackgroundsandqualifi-( a n . cations of the~ technical. staff. The Division of Radiological Health and i b. thel Division of Laboratories should have sufficient personnel so that. the ' requirements of-the cooperative agreement do not degrade the efficiency of o the radiological health staff or radiochemistry laboratory. The laborato- . ry should have at least one full time professional radiochemist supported by'one technician working full time on sample preparation and radio- . chemistry analyses and at least one technician working part time coordi- 'nating sample collection and sample receipt. It is considered satisfactory to have the environmental samples collected by a local individual near the respective reactor sites or the licensee provided the sample collectors receive sufficient training in collecting representative samples. The laboratory personnel. who will be performing the analytical require-L

ments of the cooperative agreement should have experience in conventional chemistry, radiochemistry, and radiation measurements, particularly gamma spectroscopy. The professional staff r'esponsible for the analyses re-quired by the cooperative" agreement should have a minimum of five years experience'in chemistry, of which a minimum of one year should be in

radiochemistry..The NRC' appraisal team found that the present radio-n chemistry laboratory professional-staff-met the qualification criteria, but was limited in ' technician support to adequately perform the analytical workload required by the proposed cooperative agreement.

.a k 19. Training The NRC appraisal team reviewed training activities that would be associ- =ated with the cooperated agreement. The state stated that offsite train-ing: for' laboratory personnel is encouraged, but dictated by budget and h u. availability of applicable courses. The NRC appraisal team noted that Jim L Balk.had completed the " Radiochemistry Course for State Regulatory Person- nel". offered by the NRC at the Radiological and' Environmental Sciences Laboratory in Idaho Falls, Idaho. The NRC appre.isal team recommended that' the. radiological health' staff involved in supoorting the requirements of the proposed cooperative agreement be encouraged to attend the above course. Most of.the onsite training has been self motivated and strictly 'on-the-job as needed. Training records had not been maintained that would V 6 m

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10. ; Environmental'Monitorina Experience' i-3 y a..

s.. 1-,- ~ s% m l1 \\', T jThe NRC app.. isal.. team ; reviewed = thetstate's experience in performing an ' '. W* J 4 ra environmental monitoring program and radiochemical analyses on environ- ~ f:mentalisamples. The state'has conducted'a limited statewide' surveillance- .,E:n Jprogram for theLpurpose of, determining the concentrations of radioactivity r RQ. ~ g in'the environment'for the;past 15 years.. The state has monitored the '< environment surrounding the decommissioned Hallam Nuclear Power Plant sitel "~ M for: the past:15 years by taking direct radiation measurements and analyz-! Ting well water samples' from !the; surrounding area. Since 1974,-the Divi- - 1~ .C, 6 ith'e areas around' Fort Calhoun Nuclear Station and Cooper Nuclear. Station.' < -sion of, Radiological Health has been taking independent air samples from f 'In July.1985T the. Division. of Radiological Health initiated.a' split ' J ~ w sampling: program with the Fort Calhoun' Station environmental group includ-s >Cc" ting samplesLof* air, milk, fish, surface. water, food products, and shore 3 ,e ~ b*r, k line sediment :The Division of Radiological Health was currently working W}y. p. f: twith the Cooper. Nuclear Station environmental group to establish-a similar y , ; sampling program., H w e III T 'lli Facilities and Equips'ent. i f N .sv n. Li'~ 1 ' _ ThefNRC-appraisal team appraised the radiochemisty laborat'ory and radia- ? S tion counting. facilities; located in thelState Department = of Health 'Labora-q ' M.. m-> . tory;and reviewed:the.' equipment and instruments which would be used to . [

perform;the' work' required by the proposed; cooperative agreement.

The

3., gradiochemistry; facility is located inLthe basement of. the laboratory Jbuildingland is' divided into'two roomsh One room is designed as.the 1'%

instrumenticountingiroom and the'other room-is equipped to be used as the f . radiochemistry 1aboratory for sample' preparation and"analysic, record ';' istorage,'and' personnel office' space.' The. instrument counting room is " ' approximately-150~ square feet and is equipped with' regulated electrical ~ -service... humidity control, and a_ir conditioning. The laboratory' area.is gM !approximately 400 square feet?and equipped:with-a; sink,: utilities, approx- ~ - imately 100 squ'areffeetiof laboratoryibench space; and a fume hood to- ' N kp ha'dle; radioactive mater,ials. n a o-Y SThe NRC appraisal. team (found that theJ1aboratory equipment, facilities, s 1 %b (and counting.roomLinstruments appearedtto be> adequate to perform the ^' 'A; ' req'uirements of the cooperative agreement. Service' agreements were in ^ ' force on all the' nucleartcounting' instrumentation.' v - u s-a p +$ [ 9 i s s M f 4 a 8 fN,, f b r 7 y e q '.{ Y' k 3 jyl 3 f s( f 1

W ~ + [. : g ed / i 4 k [E 112. Procedures:

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,f The[NRC ' appraisal' team reviewed existing procedures in the following ^ ~ v ' areas:. sample collection,' sample control, sample preparation, sample - analysis, counting' instrument operation and calibration,' and quality ( control.:of' counting instrumentation. The NRC app'aisal team note'd that-good progress had been made in the area r s of procedure, development. However, it was noted that the p ocedures reviewed were not written in a format which included for cacii procedure a title ~ page indicating title, ' author, procedure number, revision number, date:of issuance, and supervision authorizing approval; for use. / ~ 1 R. s Y 13. Quality Assurance Program. r[ Qf iThe?NRC; appraisal. team reviewed the state's quality control program ~ Q;r

associated with the

radiochemistry laboratory instrumentation.

The state. ~ t,s V J. ris a participant.in'the Environmental Protection Agency (EPA). cross-check 'f ~Ifprogram;..The state's performance during 1984 and 1985 was reviewed and 7~ t ; '._;f 4 ifound' acceptable ~ within the EPL acceptance criteria; ~ ~~ e [7 Thefskathlalso:performsanintsrnalqualitycontro,1 program. This program g" - consists.mainlyjof' calibration and performance checks of the various , counting instruments. The calibrations, and performance checks have been performed with radioactive = sot rces ' traceable to~the National Bureau of (Standards.,The NRC appraisal. team reviewed the quality. control data and^ y calibration data for the radiachemistry_ laboratory counting instruments. -e 'It appeared thatethe state:w4s performing adequate quality control tests ~ to verify'the' performance o'(the radioanalytical counting instruments.; 1 JHowever, the' review ~of' cal' oration: data for the Nuclear Data gamma ~ spec-6troscopy system, indicated that anjair particulate filter composite stan-c dard' of 12-13 filters' had. not' been prepared for the quarterly composite 3 a , requirement, a fish or meat calibration ~ standard had not been prepared, V 4 and;a vegetation / food products' calibration standard had notibeen ~ prepared. .J w 4 3 ,e LThese;calibrationistandards must be= prepared to' specifications'which will-, meet,the' lower limits'of'detectability (LLD) and analysis. requirements of + " Q +; P the. proposed cooperative agreement and the' Nuclear Data gamma spectroscopy / ,,f. system'calibratedforallrequiredcountinggeometries. J ? 14. LLO< 7 jL W ~The'NRC appraisal team reviewed the LLDs the state had established for-the- .various analyses of the environmental sample media.to determine the-i state's' capability in meeting the requirements.in Attachment 2 to the proposed cooperative agreement. The LLDs which were reviewed met most of f ,m / the required limits. The NRC appraisal team informed the laboratory staff be A< ^t f s . i 4 s 6 j_

4 .c '10 Z '.[ that they shoul'd verify that.all the required LLDs proposed in the coop- . erative;agteement are being met and for those not being met analytical

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{ .: procedures should be. modified to meet the required LLDs, >15..-Exit BAiefino At=the conclusion of the appraisal on October,18, 1985, the NRC appraisal team discussed the scope and findings of the; appraisal with the-individuals denoted in paragraph 1. The NRC appraisal team expressed concern regarding - those items which did not meet the conditions of-the proposed cooperative + ~agreement.as outlined in paragraph.3'of this report; y ? N N i ,1:g ?. i . s. ? .J, ~ ( i (; b n t ~ s i i. o ,] .1 .M 3 4 I m-4 a ' A T. ' ' 4 A ?

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