ML20138F390
| ML20138F390 | |
| Person / Time | |
|---|---|
| Issue date: | 09/05/1985 |
| From: | Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20138F334 | List: |
| References | |
| CON-NRC-31-83-669 99990004-85-08, 99990004-85-8, NUDOCS 8510250255 | |
| Download: ML20138F390 (9) | |
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APPENDIX U. S. NUCLEAR REGULATORY COMMISSION REGION IV Performance Appraisal for the NRC/ State of Louisiana Environmental Monitoring Cooperative Agreement NRC-31-83-669 Facility Name': Louisiana Department of Environmental Quality Office of Air Quality and Nuclear Energy Appraisal At:
Baton Rouge, Louisiana Appraisal Conducted: August 5-8, 1985 Appraisal Period: January 1,1984, through December 31, 1984 Appraiser:
4 7 / <_/ d M 9/s/pr 4fBlairNicholai,SeniorRadiationSpecialist Date '
Pacilities Radiological Protection Section Approved:
lbbit&
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/$5 BlatieMurray, Chief,FacflitiesRadiological D4te '
Protection Section Appraisal Summary Appraisal Conducted on August 5-8, 1985 (Report 99990004/85-08)
Areas Appraised: Adherence to the requirements of the cooperative agreement including: organization and management support; sample collection and analytical procedures; facilities; instrumentation; staffing and qualifications; quality assurance program, and followup corrective actions taken on previously identified deficiencies.
The appraisal involved 30 appraiser-hours by one NRC appraiser.
Results: The state's overall performance did not fully satisfy all the requirements of the cooperative agreement regarding sample collection and analyses. Several deficiencies were identified and are discussed in paragraph 3.
Based on the state's update of analytical equipment, staff changes within the laboratory organization, and commitments to improve the performance of the laboratory, it is recommended that the cooperative agreement be continued.
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2 DETAILS 1.
Persons Contacted Louisiana Department of Environmental Quality
- G. J. Gasperecz, Assistant Secretary, Office of Air Quality and Nuclear Energy
- W. H. Spell, Administrator, Nuclear Energy Division (NED)
- S. C. Collins, Program Manager, Nuclear Projects Section (NPS)
- D. M. Dement, Environmental Program Specialist
- J. M. Schlenker, Environmental Program Specialist
- S. A. Woods, Environmental Program Specialist
- Der.otes those present during the exit briefing on August 7, 1985.
- Denotes those present during the exit briefing on August 8,1985.
Louisiana Power and Licht (LP&L)
M. Marler, Senior Health Physics Technician Gulf States Utilities (GSU)
M. Reed, Environmental Technician 2.
General The purpose of this appraisal was to evaluate the state of Louisiana's compliance with the cooperative agreement conditions and to review corrective actions on the deficiencies reported in the annual appraisal conducted on October 3-5, 1984. Most of the appraisal effort was devoted to reviewing the 1984 monitoring program concerning the Waterford-3 Station; however, the appraiser also reviewed portions of the River Bend monitoring program.
The River Bend activities involve the TLD program initiated in April 1984, and the biota sampling and analyses program initiated on January 1, 1985. The TLD and biota programs concerning Waterford-3 were initiated in 1983.
3.
Summary and Conclusions The state's effort, since the previous appraisal conducted October 1984, has shown some improvement; however, several deficiencies still exist.
These include:
a.
The NED laboratory does not currently have operating and calibrated instrumentation to perform gross beta measurements in accordance with the requirements of the cooperative agreement.
See paragraph 7 for details.
3 b.
Written procedures have not been completed and approved for:
sample collection and control, sample analyses, and laboratory counting instrumentation operation, calibration, and quality control.
See paragraph 9 for details.
c.
Onsite air sampler location at Waterford-3 station was not established in 1984. See paragraph 11.a for details.
d.
Gross beta analyses of weekly air particulate samples were not performed.
See paragraph 11.a(1) for details, e.
Gamma isotopic analyses of quarterly composites of air particulate samples were not performed. See paragraph 11.a(2) for details.
f.
Quarterly tritium analyses of surface water samples were not performed on quarterly composites of monthly samples.
See paragraph 11.b for details, g.
Monthly radiciodine analyses were not performed on samples collected from the offsite dairy located in the highest X/Q direction from the station.
See paragraph 11.c for details.
h.
The 1984 annual report was not submitted as required by the cooperative agreement.
See paragraph 12 for details.
4.
Management Support In addition to the limited environmental monitoring program described in the cooperative agreement, the state has their separate environmental monitoring program around the Waterford-3 and River Bend Stations. The state's environmental monitoring program is conducted by the Department of Environmental Quality, Office of Air Quality and Nuclear Energy. The program is administered by qualified personnel who have experience in environmental monitoring. The program was funded in 1984 with a workable budget to accomplish the workload around the Waterford-3 station and maintain laboratory equipment and supplies. The cooperative agreement was expanded to include the River Bend station during 1985 which has required additional funds and personnel to support the program.
5.
Organizational Structure The NRC appraiser reviewed the state of Louisiana's Department of Environmental Quality, NED and NPS staff assignments and responsibilities.
The organization structure and reporting sequence are the same as reported in the NRC Appraisal Report 99990004/84-28 conducted in October 1984.
There had been two personnel changes in the management structure since the previous appraisal. These changes were Greg J. Gasperecz assuming the responsibilities of Assistant Secretary for the Office of Air and Nuclear
4 Energy and L. Hall Bohlinger becoming the Assistant Administrator of the NED.
6.
Staffing The NRC appraiser reviewed the staff responsible for the requirements of the cooperative agreement. There was one staff change in the NPS since the previous appraisal conducted in October 1984.
This change involved the addition of D. M. Dement, Environmental Program Specialist, to the NPS.
7.
Facilities and Equipment The NPS radiochemistry laboratory facility had added a low-energy high purity germanium detector to the Canberra Series 90 multichannel analyzer system. The Canberra 2400 automatic alpha / beta / gamma system had been received and installed. Due to detector problems and lack of certified calibration standards, the Canberra 2400 system had not been put into service. This left the radiochemistry counting facility without the capability of gross alpha / beta measures since December 1983 when the Beckman Wide Beta II was declared inoperable. A state representative indicated that the instrument manufacturer had recently corrected the Canberra 2400 system detector problems and that certified calibration standards had been received-The technical staff assured the NRC appraiser that the Canberra 2400 system would be calibration and put into routine service as soon as possible. All other equipment and facilities remain the same since the previous appraisal.
8.
Training Since the previous NRC appraisal conducted in October 1984, M. Schlenker and S. Woods have completed the Canberra RSX-11 system manager's course and S. Woods has completed the Federal Emergency Management Agency
. sponsored dose assessment course. At the time of the appraisal, D. Dement had been employed with the NPS about two weeks and was undergoing on-the-job training including sampling and analytical techniques.
9.
Procedures The NRC appraiser reviewed the state's progress in developing NPS program procedures for sample collection and control, sample analyses, and for counting instrumentation operation, calibration, and response testing.
The NRC appraiser noted that some progress was being made in this area.
The technical staff were revising and updating existing procedures to reflect current laboratory equipment and analytical techniques. The procedures were not written in a standard laboratory format which should include title page indicating procedure title, author, procedure number, revision number, date of issuance, and authorizing approval for laboratory usage.
The existing NPS program procedures were currently being entered
5 into the NED laboratory electronic word processing system to assist the technical staff in updating and formalizing the procedures. However, the NRC appraiser indicated that formal documentation of the NPS program is still lacking. The technical staff expressed their desire for improving the program and will continue efforts to develop and implement procedures as time permits.
- 10. Quality Assuranca Program The NRC appraiser reviewed the state's quality control program in conjunction with the laboratory counting instruments.
The NPS has not written procedures to document the instrumentation quality control program. Performance checks are performed on the counting instruments routinely but results are not officially recorded.
The state participates in the Environmental Protection Agency cross-check program. The state's performance during 1984 was reviewed and found acceptable.
- 11. Cooperative Agreement Reauired Sample Collection and Analyses The NRC appraiser reviewed the sample collection and analyses for the period January 1, 1984, through December 31, 1984, to determine agreement with Attachment I to the cooperative agreement.
The licensee, Lp&L, by contract with an independent laboratory, conducts its own environmental sampling and analysis program in cooperation with the state.
State personnel performed all sample preparations and analyses in the NED laboratory except for the TLD direct radiation measurements which were performed by NRC Region I personnel.
The state had not submitted the 1984 annual report at the time of the appraisal; however, the following sample media data were examined and the various deficiencies noted:
a.
Airborne - Particulate and Radioiodine The cooperative agreement requires two continuous' air samplers:
one sampler in close proximity to the licensee's sampler in a high calculated X/Q direction and one at a control location in close proximity to the licensee's sampler.
During the appraisal period the state maintained only one air sampler in close proximity to the licensee's control station located approximately 30 miles east of the station on the roof of the LP&L general office building.
The state did not meet the requirements of the cooperative agreement by not installing an air sampler in close proximity to the licensee's location in a high calculated X/Q direction until July 1985.
The state's reasons for not installing air samplers as required were that numerous equipment failures and budget restrictions had precluded having a sufficient number of _ operable air samplers.
The state purchased four new air samplers in November 1984 and since that time
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6 established the second air sampler location at Waterford-3 and one air sampler at the River Bend station in close proximity to the licensee's sampler in a high calculated X/Q direction. State person-nel committed to installing a second air sampler in close proximity to the licensee's control location at the GSU service office in Zacharey, Louisiana, by September 30, 1985.
State personnel also committed to writing purchase requisitions for a minimum of three new air samplers by October 1,1985, to use as backup support and i
replacement for in-service units.
The cooperative agreement requires continuous air sampling with airborne particulate and radiciodine samples collected weekly at two locations as described above. Gross beta analysis of the air particulate samples was required following each filter change and the filters were to be composited by location for gamma isotopic analysis quarterly.
The radiciodine charcoal cartridge samples were required to be analyzed for 1811 isotopic analysis following each cartridge change.
Airborne particulate and radioiodine charcoal cartridge samples were' collected weekly by the state at its one location.
1811 analyses t
were performed weekly in the NED laboratory by state personnel as required by the cooperative agreement.
However, the state's results l
indicated that the airborne sample analysis requirements of the cooperative agreement were not met for the following reasons:
(1) Gross beta analysis was not performed on the weekly air participate samples because no operating and calibrated instrument in the laboratory was available to perform this analysis. The Beckman Wide Beta II had been out-of-service since December 1983 and the new Canberra 2400 system had not been calibrated and put into operation since it was received in November 1984 due to detector problems and lack of certified calibration standards.
(2) Gamma isotopic analyses of quarterly composites of the air particulate samples were not performed.
This was due to an oversight of the cooperative agreement requirements, b.
Surface Water The cooperative agreement requires two surface water samples to be collected and composited weekly:
one from a downstream location and one from an upstream control location. A gamma isotopic analysis was required on a monthly frequency and a tritium analysis on a quarterly composite by location of monthly samples. The licensee utilizes automatic samplers for collection.
Sample flow rates are checked weekly and samples are taken biweekly and split monthly with the state. The gamma isotopic and tritium analyses were performed in the NED laboratory by state personnel.
i
m 7
The state results for 1984 met, in part, those specific requirements of the cooperative agreement; however, the NRC appraiser noted that the quarterly tritium analyses were performed on one sample per quarter rather than on the quarterly composite by location of monthly samples. Therefore, the state's data is not directly comparable to the licensee's data.
c.
Milk The cooperative,greement requires one monthly sample of an offsite dairy located in the highest X/Q direction from the station. This sample location had been determined to be at Weber's farm which is located approximately 5 miles northwest of the Waterford-3 station.
Gamma isotopic and radiciodine analyses were required on a monthly frequency. The licensee collected samples monthly which were split with the state. The state personnel performed monthly gamma isotopic analyses in the NED laboratory.
The state results for 1984 met, in part, the specific requirements of the cooperative agreement; however, the NRC appraiser noted that the specific analyses for radioiodine were not performed.
State personnel stated that not enough sample had been collected to perform the specific radiciodine separation analysis.
The state personnel have corrected this problem in 1985.
The NRC appraiser determined that the state had met all the specific analysis requirements of the cooperative agreement on milk samples taken from the licensee's control location at the Louisiana State University dairy where sufficient milk samples were obtained.
d.
Fish The cooperative agreement requires one sample of a commercially or recreationally important species in the vicinity of the plant discharge semiannually or in season.
Gamma isotopic analysis of the edible portions was required.
The state results for 1984 were reviewed and were found to meet the requirements of the cooperative agreement.
e.
Food Products The cooperative agreement requires two samples to be split with the licensee of principal food products grown near a point having the highest X/Q, or grown in an area irrigated by water into which the plant discharges waste, or green leafy vegetables at a private garden l
or farm in the immediate area of the plant.
Gamma isotopic analyses including radiciodine of the edible portions were required. The l
state results for 1984 were reviewed and found to meet the l
requirements of the cooperative agreement.
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8 f.
Sediment from Shoreline The cooperative agreement requires one annual sample split with the licensee for gamma isotopic analysis of shoreline sediment along a body of water into which plant discharge flows. A sediment sample was collected and analyzed by the state and the licensee for 1984.
However, due to the problems associated with the multichannel analyzer system at the time of the analysis, analytical results were not stored and cannot be recovered.
g.
Direct Radiation Levels The state has established a TLD direct radiation monitoring network of 15 locations around the Waterford-3 station in conjunction with the NRC TLD 36 location network established in 1982.
Fourteen of the licensee's TLD sites and eight of the state's TLD sites are collocated with the NRC. The NRC established in March 1984 a TLD network of 44 locations around the River Bend station. The licensee, GSU, has 14 TLD sites which are collocated with the NRC. The state had not established a TLD network around the River Bend station at the time of the appraisal. The cooperative agreement required the state personnel to exchange the NRC TLDs quarterly and send them for analysis by NRC Region I personnel.
The state TLDs had not been evaluated quarterly during 1984.
At the time of the appraisal, the licensee's TLD results and the i
NRC's TLD results had not been tabulated; therefore, no comparison of results could be made.
h.
Lower Limit of Detection (LLD)
The NRC appraiser requested that the annual report include LLD values for each sample media and sample analysis reported for both the state's results and the licensee's results.
[
12.
Reports l
The cooperative agreement requires an annual report of all state analyses results with comparisons of duplicate or split sample analysis results by the licensee within 120 days after January 1 of each calendar year. The annual report for 1984.had not been submitted to the NRC Region IV office l
at the time of the appraisal.
State personnel committed during the exit briefing to have the 1984 annual report submitted to the NRC Region IV l
office by September 30, 1985.
l l
State representatives stated that the delay in submission of the 1984 annual report was due in part to some data having not been received from the licensee in a timely manner. The NRC appraiser recommended to the state that some arrangement should be made_with the licensee to coordinate an exchange of analytical results for comparative samples and to discuss l
potential problems on a quarterly basis.
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- 13. Exit Briefing At the conclusion of the appraisal, the NRC appraiser discussed the scope and findings of the appraisal with the individuals denoted in paragraph 1.
The NRC appraiser expressed concern regarding those items which did not meet the conditions of the cooperative agreement.
The state representatives agreed that in the future more attention will be devoted to the cooperative agreement requirements in order to carry out a high quality program.
The NED administrator committed to the following items:
a.
The state will establish an air sampler location in close proximity to the GSU control air sampler location at the GSU service office in Zacharey, Louisiana, by September 30, 1985.
b.
The NED will write purchase requisitions for a minimum of three new air sampiers by October 1, 1985, to be used as backup support. and replacements for inservice units.
c.
The NED will submit the 1984 annual report to the NRC Region IV office by September 30, 1985.
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