ML20149D991
| ML20149D991 | |
| Person / Time | |
|---|---|
| Issue date: | 12/24/1987 |
| From: | Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20149D966 | List: |
| References | |
| 99990004-87-03, 99990004-87-3, NUDOCS 8801130185 | |
| Download: ML20149D991 (6) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION REGION IV Performance appraisal for the NRC/ State of Texas Environmental Monitoring Cooperative Agreement NRC-31-83-671 Licensee:
Texas Department of Health (TOH)
Appraisal At: Austin, Texas Appraisal Conducted: November 2-3, 1987 Appraisal Period: January 1 through December 31, 1986 Inspector-d f4A b[A&M/
/ 2&W 7 J. Blair Nicholas, Sen/or Radiation Specialist Dafe Facilities Radiological Protection Section
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k Approved:
Bla~ine'Muday, Chief,igilitiesRadiological Dafe
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j Protection Section Inspection Summarv, Appraisal Conducted November 2-3, 1987 (Report 99990004/87-03)
Areas Appraised:
Routine, announced performance appraisal of the state's adherence to the requirements of the cooperative agreement including:
management support, organization, facilities and equipment, procedures, quality assurunce program, and followup corrective actions taken on previously identified deficiencies.
Results: The state's overall performance satisfied the general requirements of the cooperative agreement regarding sample collection and analyses. On October 28, 1987, the Texas Department of Health requested, in writing, to terminate NRC Contract No. 31-83-071 on December 31, 1987, due to reorganization and loss of resources in the Texas Bureau of Radiation Control.
Based on discussions with the Texas Bareau of Radiation Control (BRC) personnel, the NRC/ State of Texas Environmental Monitoring Cooperative Agreement NRC-31-83-671, after December 31, 1987, will be modified to delete the requirements for collection and analysis of environmental samples and to retain only the responsibility to maintain the NRC TLD direct radiation monitoring networks around the Comanche Peak S+.eam Electric Station (CPSES) and i
the South Texas Project (STP) reactor sites, l
8801130185 880106 IE GA999 ESGTX 99990004
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. DETAILS 1
1.
Persons Contacted IDH "D. K. Lacker, Chief, BRC
- R. A. Ratliff, Director, Division of Compliance'and Inspection,.BRC D. E. Brown, Unit Chief, Radiation Chemistry Section, Bureau of Laboratories (BL)
R. A. Cripps, Health Program Specialist, Primary Health Care Services Program J. M. Drosche, Assistant Unit Chief, Radiation Chemistry Section, BL J. R. Haygood, Administrator, Radioactive Materials Branch, BRC
- C. R. Meyer, program Manager, Uranium Special Inspections and Environmental Surveillance Section, BRC
- Denotes those present during the exit interview on November 3, 1987, 2.
General The purpose of this appraisal was to evaluate the state of Texas' compliance with the cooperative agreement conditions, to review corrective actions on the deficiencies reported in the performance appraisal conducted May 27-29, 1986, and to discuss the state's request to terminate the cooperative agreement on December 31, 1987. Most of the appraisal effort was devoted to reviewing the 1986 environmental monitoring programs concerning the CPSES and STP reactor sites.
The interim preoperational environmental monitoring programs at CPSES and STP involve a f
thermoluminescent dosimeter (TLD) network and environmental sampling program of soil, vegetation, food products, and surface water. The NRC 4
TLD and environmental sampling programs around CPSES were initiated in 1983 with the current interim preoperational environmental monitoring program agreed to in September 1985.
The STP interim preoperational environmental monitoring program was initiated in August 1985 followed by the establishment of the NRC TLD network in October 1986.
Elements of the 7
NRC cooperative agreement program which were not fully implemented at either reactor site in 1986 during this interim program included the following:
air, milk, fish, sediment, and surface water samples. These samples were collected and analy7ed on a quarterly. frequency rather than monthly.
Starting January 1, 1987, the NRC environmental monitoring i
program was established as described in the NRC Cooperative Agreement NRC-31-83-671.
However, the interim preoperational environmental monitoring program at the CPSES reactor site remains in effect throughout 1987.
Discussions were held with Texas Bureau of Radiation Control personnel concerning their written request to terminate the NRC/ State of Texas Environmental Monitoring Cooperative Agreement NRC-31-83-671 on December 31, 1987. Their reason for the request to, terminate the i
.. responsibilities of cooperative agreement are due to a reorganization within the TDH and the loss of resources including 18 personnel and the Division of Environmental Programs in the BRC which was administering and managing the NRC cooperative agreement.
Based on these discussions, it was agreed that the state of Texas, BRC, will not continue to collect and analyze environmental samples in accordance with the cooperative agreement but will continue to maintain the NRC TLD direct radiation monitoring networks around CPSES and STP reactor sites. The current NRC/ State of Texas Environmental Monitoring Cooperative Agreement NRC-31-83-671 will be modified as of January 1,1988, to reflect these changes.
3.
Management Support The state has an environmental monitoring program at CPSES and STP in addition to the samples and analyses required by the cooperative agreement. The state is currently implementing an interim preoperational program at each of the nuclear power facilities as described in paragraph 2.
The environmental monitoring programs are conducted by the Bureau of Radiation Control with assistance from the Bureau of Laboratories.
The state's environmental monitoring program is administered by qualified personnel who have experience in environmental monitoring and who take a concerned interest in the performance of the environmental monitoring program and the cooperative agreement.
4.
Organizational Structure The NRC appraiser reviewed the BRC and BL staff assignments and responsibilities. The organizational structure and reporting sequence underwent a reorganization in September 1987 causing a loss of 18 positions and dissolution of the Division of Environmental Programs which adtrinistered the NRC cooperative agreement.
The NRC cooperative agreement responsibilities have now been shifted to the BRC's Division of Compliance and Inspection.
5.
Facilities and Equipment The NRC appraiser reviewed the BRC and radiochemistry laboratory facilities and equipment utilized in the performance of the cooperative agreement. There have been no sigr.ificant changes in the facilities and equipment since the appraisal conducted in July 1984.
6.
Procedur;g The NRC appraiser reviewed the state's current environmental monitoring program procedures for sample c.ollection, control, preparation, and analysis, calibration of counting instruments, quality control of analytical counting instrumentation and air sampling equipment, and preparation methods and documentation of radioactive calibration standards. The NRC appraiser noted that progress was being made in the area of procedure development.
The BRC had written sampling procedures for all environmental media, sample handling and control, and procedures
. for the calibration, operation, and quality control of the TLD reader.
The BRC was establishing a procedures manual.
The radiochemistry laboratory had written a laboratory procedures manual which provides instructions for conducting radiochemistry laboratory activities.
The technical staff at both the BRC and BL expressed their desire to improve the environmental program and will continue efforts to make procedure improvements as time permits.
7.
Quality Assurance Program The NRC appraiser reviewed the state's quality control program in conjunction with the laboratory analytical counting instruments.
The state participates in the Environmental Protection Agency (EPA) cross-check program.
The state's performance during 1986 and 1987 was reviewed and found to be within the EPA acceptance criteria. A summary of the EPA cross-check program results was included in the 1986 annual report as required by the cooperative agreement.
The state's radiochemistry laboratory performs an internal quality control program in conjunction with the laboratory counting instruments. The NRC appraiser reviewed the calibration data and quality control data for the I
radiochemistry laboratory counting instruments for year 1987. The NRC i
appraiser noted that recalibration frequencies had been established for the radiochemistry counting instruments and acceptance criteria had been established for the routine quality control checks.
8.
Cooperative Agreement Required Sample Collection and Analyses The NRC appraiser reviewed the sample collection and analyses for the period January 1 through December 31, 1986, to determine agreement with to the cooperative agreement and the interim preoperational program started in September 1985. The licensee's, Texas Utilities Electric Company and Houston Lighting and Power, conduct their environmental monitoring programs in cooperation with the state.
State personnel performed routine environmental sampling and sample splitting with the licensees.
State personnel performed all sample preparations and analyses of their samples in the state radiochemistry laboratories.
The state's TLDs were also processed by state personnel. State personnel exchanged the TLDs associated with the NRC TLD direct radiation measurements network and submitted them for processing to the NRC Region I on a quarterly er. change frequency.
The following cooperative agreement sampling areas were examined and the various deficiencies noted:
a.
Surface Water The interim preoperational environmental monitoring program requires at least two surface water samples to be collected and analyzed quarterly at each reactor site:
one sample from an immediate area of l
plant discharge and one sample from an upstream control location.
The quarterly gamma isotopic and tritium analyses of the state sample were performed in the state's radiochemistry laboratory by state personnel.
The results reported by the state in the 1986 annual report met the requirements of the interim preoperational environmental monitoring
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program; however, the surface water samples were not split with the licensees in all cases.
Therefore, licensee comparative analysis results were not reported.
b.
Soil The interim preoperational environmental monitoring program requires at least four soil samples to be collected and analyzed quarterly at each reactor site.
The quarterly gamma isotopic analyses of the state samples were performed in the state's radiochemistry laboratory by state personnel.
The results reported by the state in the 1986 annual report met the requirements of the interim preoperational environmental monitoring program; however, the soil samples were not split with the licensees.
Therefore, no licensee comparative analysis results were available.
c, Vegetation The interim preoperational environmental monitoring program requires at least four vegetation samples to be collected and analyzed quarterly at each reactor site.
The quarterly gamma isotopic analyses of the state samples were performed in the state's radiochemistry laboratory by state personnel.
The results reported by the state in the 1986 annual report met the requirements of the interim preoperational environmental monitoring program; however, the vegetation samples were not split with the licensees.
Therefore, no licensee comparative analysis results were available.
d.
Food Products The interim preoperational environmental monitoring program requires at least one food product sample to be collected and analyzed semiannually at each reactor site.
The semiannual gamma isotopic analyses of the state sampics were performed in the state's radiochemistry laboratory by state personnel.
The results reported by the state in the 1986 annual report met the requirements of the interim preoperational environmental monitoring program; however, some food sample from CPSES were spoiled upon
)
. receipt and could not be analyzed and the food product samples were not split with the licensee.
Therefore, no licensee comparative analysis results were available, e.
Direct Radiation Levels The state has established a TLD direct radiation monitoring network around both reactor sites. At CPSES the state has 45 TLD locations in conjunction with the licensee and the 47 locations NRC TLD network established in March 1983.
Twenty-two of the licensee's TLD sites and 18 of the state's TLD sites are collocated with the NRC. At STP the state has 15 TLD locations in conjunction with the licensee and the 46 locations NRC TLD network established in October 1986.
Twenty-seven of the licensee's TLD sites and 14 of the state's TLD sites are collocated with the NRC.
The cooperative agreement requires the state personnel to exchange the NRC TLDs quarterly and send them for analysis by NRC Region I personriel.
The results reported in the 1986 annual report for CPSES met the requirements of the cooperative agreement, j
f.
Lower Limits of Detection The NRC appraiser reviewed the state's lower limits of detections (LLDs) reported in the 1986 annual report. The LLDs reported by the state met the requirements of the cooperative agreement.
9.
Reports The 1986 annual report was submitted by the state to the NRC Region IV office within the time period specified in the cooperative agreement.
10.
Exit Interview At the conclusion of the appraisal on November 3, 1987, the NRC appraiser discussed the scope and findings of the appraisal with the individuals i
denoted in paragraph 1.
The NRC appraiser discussed the terms of the new cooperative agreement to delete the requirements for environmental sampling and analyses and retain the requirements to maintain the NRC TLD t
networks around CPSES and STP reactor sites.
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