ML20149M213

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 99990004/87-02

ML20149M213
Person / Time
Issue date:	02/22/1988
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Hazel A COLORADO, STATE OF
References
REF-QA-99990004-880222 NUDOCS 8802250414
Download: ML20149M213 (2)

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FEB 2 21988

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In Reply Refer To:

Report: 99990004/87-02 Colorado Department of Health ATTN: Albert J. Hazel, Director Radiation Control Division 4210 East lith Avenue Denver, Colorado 80220 Gentlemen:

Thank you for your letter of December 31, 1987, in response to our performance appraisal and concerns dated September 25, 1987. We have reviewed your reply t,nd find it responsive to the concerns raised in the performance appraisal. We will review the implementation of your corrective actions during a future performance appraisal to determine full compliance with the terms of the cooperative agreement.

Sincerely, 04tGINAL SIGNED BY ROBERT D. MARTIN Robert D. Martin Regional Administrator cc v/ State's letter:

Richard Gamewell, Principal Health Physicist Radiation Control Division Technical Services 'Jnit 4210 East lith Avenue Denver, Colorado 80220 Public Service Company of Colorado ATTN: Robert 0. Williams, Jr.

Vice President, Nuclear Operations P. O. Box 840 Denver, Colorado 80201-0840 (cc continued next page)

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Colorado Department of Health Frank J. Congel, Director Division of Radiation Protection and Emergency Preparedness, HQ Edna T. Knox, Contract Administrative Officer Division of Contracts, AR 2223 Robert J. Doda, Chief State and Government Affairs Staff, RIV bcc w/ State's letter:

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R. D. Mar, tin R. L. Bangart R. E. Hall L. A. Yandell B. Murray D. ti. Meyer J. B. Nicholas RSTS MIS RIV Eiles RPSB i

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S-A--_ Or._ CO.iO.MJO COLORADO DEPARTMENT OF HEALTH 4210 East lith Avenue y

Denser, Colorado 80220 Phone (303) 320 8333 z

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Roy Romer Zowernor Thomas M. Vemon, M.D.

Isecutrwe Direr. tor December 31, 1987 g

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Region IV j-611 Ryan Plaza Drive, Suite 1000

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Arlington, TX 76011 RE: NRC/ State Ft. St. Vrain Environmental Monitoring Performance Appraisal (Refer to Appraisal Report 99990004/87-02)

Dear Mr. Martin:

The enclosed responds to your concerns regarding items which did not fully satisfy the conditions of the NRC/ State of Colorado Environmental Monitoring Cooperative Agreement for the Fort St. Vrain Station, based on the per formance appraisal conducted in August 1987 by Dr. J. B. Nicholas.

This response conforms to timing agreed by telephone with Dr. Nicholas at our request. We look forward to any further comments you may have.

Respectfully )

D, A ert J. Hazie,. Director Radiation Control Division AJH/KKLW/ cf cc: R. O. Williame, Jr., PSC Frank J. Congel, NRC HQ Merle L. Dorsey, NRC Region IV Robert J. Doda, NRC Region IV J. B. Nicholas, NRC Region IV l

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FSV Appraisal Response December 31,.1987 Page l' of 3 RESPONSE TO DEFICIENCIES i

IDENTIFIED IN THE AUGUST 1987 PERFORMANCE APPRAISAL OF THE NRC/ STATE OF COLORADO ENVIRONMENTALHONITORING COOPERATIVE AGREEME Use of 47mm Filter to Achieve LLD for Air Particulate Gross Beta Analysis a.

Comment:

The State was not using an industry standard 47 millimeter diameter air particulate filter and charcoal cartridge.

Response

As stated at the exit briefing by RCD management, the use of the 47mm (nominal 2") air particulate filter and charcoal cartridge is desirable and has been evaluated for implementation.

7 The RCD intends to make this changeover in calendar year 1988.

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Sampling, Calibration and QC/QA Written Procedures Commen t :

Written procedures have not been completed and approved for.

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sample collection and control, response tests, calibration, operation and

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quality control of all radiation counting facility (RCF) instrumentation, and preparation methods and documentation for radioactive calibration l

scandards. See paragraph 9 for details.

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Response

The RCD will complete in a standardized format title page, (to include a indicating procedure title, author, procedure number, revision number, date of issuance, and approval) all previously incomplete 5

procedures:

for sample collection, control, preparation, and analysis; calibration of counting instruments; and quality ccntrol of ana'iytical counting instrumentation and air sampling equipment.

This work on documentation will be meshed with the priorities placed on analysis in the i

kadiation Counting Facility.

Special attention will be given to procedures revision as required equipmemt upgrades are made.

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QC Control Charts i

Commen t :

The State has not fully implemented the use of control charts for quality control of RCF instrumentation.

See paragraph 10 for details.

Response

The Radiation Counting Facility tabulates quality control and performance data daily for all equipment used for radioactive measurements.

Technicians verify tt.at the data is consistant with normal equipment as required. equipment operating ranges and when outside the normal NRC's interpretation of the cooperative agreement,For the purpose of dem Facility personnel will tabulate the data graphically commencing inRadiation Countingi January 1988.

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FSV Appraisal Response December 31,- 1987 Page 2 of 3'

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Proper and Traceable Comparison Standards Comment: Counting geometries and/or calibration standards for the air particulate filter quarterly composite, charcoal cartridge, fish, and vegetation / food products need to be improved.

Response: Calibration standards for all samples analyzed by the Radiation Counting Facility are adequate and appropriate. The frequency of efficiency calibrations need to be increasedi, these calibrations will be performed semi-annually if the necessary additional funds (roughly $1,000) can be found. This is a very high priority for the Radiation Counting Facility.

NRC assistance in obtaining replacement standards, as discussed in the exit interview, in geometries optimal for comparison to data from other stations may be requested. The efforts to standardize counting geometries using traceable comparators will be tailored to the RCD equipment, particularly in recalibrating the Nuclear Data gansna spectrocopy system _ to meet the cooperative agreement requirements for analysis of 1988 samples.

1985 and 1986 Gross Beta Air Particulate LLD Not Het e.

Comment: Gross beta air particulate lower limit of detection (LLD) was not mE in 1985 and 1986. See paragraph ll.a.(1)(a) and ll.a.(2)(a).

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Remonse: As stated in responce to comment a., the RCD is examining a number of options in order to reduce the discrepancies between the State and licensee results. This discrepancy is due to the State's exceeding the gross bets LLD of 0.01 pCi/M,

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1985 and 1986 Radioiodine LLD for Surface Water Not Het Comment: The radioiodine LLD for surface water was not met in 1985 and 1986. See paragraph ll.b.(1)(a) and 11.b.(2)(a).

Re spons e,:

The RCD will attempt in 1988 to tighten procedures in order to meet the radioiodine LLD of 1.0 pCi/L for surface waters as specified in of the Cooparative Agreement.

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Missing Gamma Isotopic Results for Upstream Surface Water Comment: Gamma isotopic results were not reported for apstream surface water samples for January, March, and July 1985. See paragraph 11.b. (1 )(b ).

Response: The RCD will continue, as it has since the missing data problem in early 1985, to obtain 100% completeness of gama isotopic analysis.

These samples are obtained from a split collected by the licensee; in the instances in question, no s' ample was provided to the RCD by the licensee's contractor. The RCD is thus not in control of such missing data. Since 1985, the RCD data has been timely received and analyzed; no future problems in this regard are anticipated.

FSV Appraisal Response December 31, 1987 Page 3 of 3

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Missing Gamma Isotopic Results for Downstream Surface Water

,s Comments:

The RCD will continue, as it has since the missing data problem in early 1985, to obtain 100% completeness of gamma isotopic analysis.

These samples are obta'ned from a split collected by the licensee; in the instances in question, no sample was provided to the RCD by the licensee's contractor.

The RCD is thus not in control of such missing data. Since 1985, the RCD data has been timely. received and analyzed; no future problems in this regard are anticipted.

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LLD for Radioiodine in Milk Not Met Comment:

The radiciodine LLD for milk was not met in 1985 and 1986.

See paragraph 11.c.

Response

The RCD is examining several alternative methods of analysis, particularly in emphasizing sample preparation, and will achieve the LLD of 1.0 pCi/L specified in Attachment 2 of the cooperative agreement.

j. Missing Sediment Sample Comment:

Shoreline sediment sample for 1986 was not split with the licensee so as to compare analytical results. See paragraph 11. f.(2).

Response: These samples are obtained from a split collected by the licensee; in the instances in question, no sample was provided to the RCD by the licensee's contractor. The RCD is thus not in control of such missing data. Since 1985, the RCD data has been timely received and analyzed; no future problems in this regard are anticipated. A special effort will be made in 1988 to ensure that the shoreline sediment sampling is fully in accord with the requirements of the cooperative agreement.

Again, this will be an item of special emphasis.

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