ML20153F448
| ML20153F448 | |
| Person / Time | |
|---|---|
| Issue date: | 04/28/1988 |
| From: | Baer R, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20153F444 | List: |
| References | |
| REF-QA-99990004-880503 99990004-88-20, NUDOCS 8805100333 | |
| Download: ML20153F448 (13) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMISSION REGION IV
.i Performance appeaisal for the NRC/ State of Nebraska Environmental Monitoring Cooperative Agreement NRC-31-86-330 Facility:
Scate of Nebraska Department of Health (NDH)-
Division of Radiological Health (DRH)
Division of Laboratory Services (DLS)
Appraisal At:
Lincoln, Nebraska i
Appraisal Conducted:
March 30 through April 1, 1988 Appraisal Period:
January 1,1986, through December 31, 1987
. Appraiser:
//28[dB J.'B.
Nicholas, Senior Radiation Specialist Date Facilities Radiological Protection Section L
Approved:
//lo[48
. Baer, Acting Chief, Facilities Date Radiological Protection Section Appraisal Summary Appraisal Conducted March 30 through April 1, 1988 (Report 99990004/88-20)
Areas Appraised:
Routine, announced performance appraisal of the state's
. adherence to the requirements of the cooperative agreement including:
management support, organization, staffing, facilities.and equipment, training; procedures, quality assurance program, and followup corrective actions taken on previously identified deficiencies.
Results:
The state's overall performance satisfied most of the requirements of
'the cooperative agreement regarding sample collection and analysis.
Several minor deficiencies and observations are identified in paragraph 3.
Based on the state's past performance and their commitments to continue to improve the program, it is recommended that the cooperative agreement be continued.
8805100333 880503 PDR QA999 ESGNE 99990004 DCD L
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2 DETAILS j
1.
Persons Contacted ~
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NDH
- A. Cota, Deputy Director, Programs
- J.-Balk, Radiochemist, DLS
- J. Blosser, Director, DLS
- H. Borchert, Director, DRH
- B. Casari, Director, Bureau of Health Protection
- J. DeFrain, Health Physicist, DRH
- C, Horn, Chemistry Supervisor, DLS
- H.' Smith, Laboratory Supervisor, DLS
- Denotes those.present du' ring the exit briefing on April l',
1988.
2.
General The purpose of this appraisal was to evaluate the state of Nebraska's i
compliance with the cooperative agreement conditions and to review corrective actions on areas of concern reported in the initial acceptance appraisal conducted October 17-18, 1985.
The appraisal effort was devoted to reviewing the 1986 and 1987 environmental monitoring programs around the Fort Calhoun Nuclear Station (FCS) and the Cooper Nuclear Station (CNS).
The thermoluminescent dosimeter (TLD) programs around FCS and CNS were initiated in October 1980 and the environmental sampling and analyses programs were implemented in January 1986.
3.
Observations and Conclusions-The state's effort, since the initial appraisal conducted in October 1985, has shown improvement.
However, several deficiencies and observations are identified below:
a.
The state may wish to include in future equipment budgets several i
instrument upgrades in the DLS radiochemistry laboratory.
See paragraph 8.
b.
Written procedures have not been completed and approved for:
sample collection and control, sample analyses, and instrument operation, calibration, and quality control (QC).
See paragraph 9.
l c.
Gamma isotopic data for weekly analysis of charcoal cartridges should be reported as a separate' sample type and analysis.
See paragraphs 11.a(1) and 11.a(2).
d.
Charcoal cartridge 1811 lower limit of detection (LLD) was not met in 1987.
See paragraphs 11.a(1) and 11.a(2).
3 e.
The radioiodine LLD for surface water was not met in 1986.
See paragraphs 11.b(1) and 11.b(2).
f.
The state did not report a surface water composite tritium result for the first quarter of 1986.
See paragraphs 11.b(1) and 11.b(2).
g.
The state reported measured tritium results less than the reported LLD for several quarters in 1986 and 1987.
See paragraphs 11.b(1) and 11.b(2).
h.
The radioiodine LLD for milk was not met in 1986.
See paragraph 11.c.
i.
The state's and licensees' results for fish, food products, and shoreline sediment should be reported in the same units for ease of data comparison.
See paragraphs 11.d, 11.e, and 11.f.
j.
The gamma isotopic results for fish were not directly comparable because the state and licensees did not process the fish samples the same.
See paragraph 11.d(1).
k.
Fish samples were received unsuitable for analyses from the licensee.
See paragraph 11.d(2).
1.
The gamma isotopic results for broadleaf vegetation were not directly comparable because the state and licensee did not process the vegetation samples the same.
See paragraph 11.e(2).
Even though several minor program deficiencies need to be corrected, the state's overall performance was acceptable and it is recommended that the cooperative agreement be continued.
4.
Management Support The state currently does not conduct a separate state environmental monitoring program around FCS and CNS other than the samples and analyses required by the cooperative agreement.
However, the state does maintain independent TLD monitoring networks around the nuclear power stations in Nebraska.
The state's environmental monitoring program described by the cooperative agreement is conducted by the DRH with the support of the OLS within the NDH.
The program is administered by qualified personnel who have experience in environmental monitoring.
The program appeared to be funded in 1986 and 1987 with adequate budgets to support and accomplish the sampling and analysis work load around FCS and CNS and to maintain radiochemistry laboratory equipment and supplies.
5.
Organizational Structure The NRC appraiser reviewed the state of Nebraska's ORH and OLS staff acsignments regarding responsibilities for the management and ir.plementation of the cooperative agreement.
The organizational structure
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and reporting sequence were nearly the same as previously described in the NRC Appraisal Report 99990004/85-10 conducted in October 1985, with one exception, the Director, Bureau of Health Protection and the Director, Laboratory ~ Services, now report to the same Deputy Director.
This organizational structure establishes a single direct line of authority and control _ over the administration of the cooperative agreement by the DRH and the analytiel laboratory services provided by the DLS.
There had F
been one personnel change in the management structure since the previous appraisal.
This change was the assignment of Arturo Coto as Deputy Director of Health Services.
6.
Staffing The NRC appraiser reviewed staffing regarding personnel responsible for implementing the requirements of the cooperative agreement.
There have been no staff changes in the DRH and DLS since the previous appraisal conducted in October 1985.
7.
Training l
The NRC appraiser reviewed the offsite and on-the-job training received by
.the DRH and DLS technical staff since the previous appraisal conducted in October 1985.
The NRC appraiser determined that the laboratory technician had received on-the-job training in radiochemistry laboratory techniques.
No offsite training had been received during the appraisal period. The NRC appraiser noted that training records had not been established which l
would document that supervision had reviewed and accepted employee i
proficiency for specific analytical procedures.
The NRC appraiser indicated that a specific program should be established for the on-the-job training of DRH and DLS personnel.
DRH and DLS personnel should be encouraged to attend specific job related short courses and workshops to 4
maintain an appropriate level of technical competence.
This item was 1
discussed at the exit briefing and the NDH management agreed that offsite training is valuable and will be approved whenever possible.
8.
Facilities and Equipment The NRC appraiser reviewed the DLS radiochemistry laboratory facilities l
and equipment utilized in the performance of the cooperative agreement.
There have been no changes in the facilities and equipmant since the l
previous appraisal in October 1985.
However, the NRC appraiser noted that i
the DRH had purchased three new low volume environmental air samplers.
The NRC appraiser noted that the liquid scintillation counting system is j
over 10 years old and service and parts are becoming more difficult to i
obtain in a timely manner.
The NRC appraiser discussed at the exit i
briefing the possibility of replacing the old liquid scintillation system with a state-of-the-art liquid scintillation system and also addiiig a i
second high purity germanium detector to the Nuclear Data 6700 multichannel analyzer system to increase the efficiency and number of gamma isotopic 6
j analyses.
The NDH management agreed to evaluate the purchase of these j
laboratory instrument upgrades.
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t 9.
Procedures The NRC appraiser reviewed the state's progress in developing environmental monitoring program procedures for:
sample collection, control, preparation, and analyses; calibration of counting instruments, TLD reader, and air sampling equipment; and QC of analytical-counting instrumentation.
The NRC appraiser noted that good-progress was being made in the area of procedure development.
The DRH had drafted procedures for air sampling and exchange of the TLDs.
The radiochemistry laboratory had written laboratory procedures which provide instructions for the operation of the various radiochemistry counting instruments and the performance of sample analyses.
However, it was noted that a complete review of these procedures needed to be performed and the procedures approved for use.
The NRC appraiser discussed at the exit briefing the lack of procedures for the calibration of the environmental air samplers -
and calibration and QC procedures for the TLD program instrumentation.
The NDH management stated that efforts would be made to develop required procedures and complete the reviews and approvals on the existing procedures.
radiochemistry laboratory counting instruments.
The State participates in the Environmental Protection Agency (EPA) cross-check programs.
The state's performance during 1986 and 1987 was reviewed and found acceptaole within the EPA acceptance criteria.
The state's radiochemistry laboratory also performs an internal QC program.
This program consists mainly of performance checks and calibrations of the counting instruments.
The DLS radiochemistry laboratory has written procedures to document the instrumentation calibration and QC program.
The NRC appraiser reviewed the calibration data and the QC data for the radiochemistry laboratory counting instruments over the appraisal period which had been performed with radioactive standards traceable to the National Bureau of Standards.
Calibrations and performance checks were being performed on the counting instruments routinely and the results were tabulated.
QC charts were being used to determine and trend instrument performance.
It appeared that the state was performing the required calibrations and adequate QC tests to verify the performance of the radioanalytical counting instruments.
A review of the calibration data for the Nuclear Data multichannel analyzer system indicated that all environmental sample media and counting geometrics had been calibrated during the appraisal period.
11.
Cooperative Agreement Required Sample Collections and Analyses The NRC appraiser reviewed the sample collection and analyses performed for the period January 1, 1986, through December 31, 1987, to determine agreement with Attachment 1 to the cooperative agreement.
6 The two NRC licensees, Omaha Public Power District and Nebraska Public Power District, by contracts with independent laboratories, conduct their own radiological environmental monitoring programs in cooperation with the state.
State personnel and personnel from each of the licensees performed routine environmental sampling and sample splitting as required by the cooperative agreement.
State personnel performed all sample preparations and analyses of their samples in the DLS radiochemistry laboratory.
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 office on a quarterly exchange frequency.
The following cooperative agreement sampling areas were evaluated and several observations and deficiencies were noted:
a.
Airborne - Particulate and Radiciodine The cooperative agreement requires two continuous air samplers at each nuclear power station:
one air sampler in close proximity to the licensee's air sampler in the highest calculated X/Q area from the plant and another air sampler at a control location in close proximity to the licensee's air sampler.
The state operates two additional air sampling stations near FCS and one additional air sampling station near CNS which are not required by the cooperative agreement.
The cooperative agreement requires continuous air sampling with airborne particulate and radioiodine samples weekly at two locations for each nuclear power station as described above.
Gross beta analysis of the air particulate samples was required following each weekly filter change and the filters were composited by location for a quarterly gamma isotopic analysis.
The weekly radiciodine charcoal cartridge samples were required to be analyzed for 1311 following each cartridge exchange.
Airborne particulate and radioiodine samples were collected weekly by state contracted personnel at the state's sample locations.
Gross beta, gamma isotopic, and 1311 analyses were performed at the required frequencies in the DLS radiochemistry laboratory by state personnel, t
The results reported by the state in the 1986 and 1987 annual reports for the two licensees met most of the specific requirements of the cooperative agreement; however, the NRC appraiser noted the following observations and deficiencies:
(1) FCS (a) 1986 Annual Report 1)
The state's quarterly air particulate composite isotopic data was not reported for the first quarter of 1986.
The weekly air particulate filters were not composited for analysis.
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2)
The licensee reported gamma isotopic results for the i
air particulate filters on a monthly composite rather than on a quarterly composite; therefore, a direct comparison with the state's quarterly composite analytical results could not be made.
3)
The charcoal cartridge weekly gamma isotopic data should be reported as an independent sample type and analysis.
(b) 1987 Annual Report 1)
The licensee reported gamma isotopic results for the air particulate filters on a monthly composite rather than on a quarterly composite; therefore, a direct comparison with the state's quarterly composite analytical results could not be made.
2)
The charcoal cartridge weekly gamma isotopic data should be reported as an independent sample type and analysis.
3)
The charcoal cartridge 1811 required LLD of 0.07 pCi/m3 was not met by the state on several analyses.
(2) CNS (a) 1986 Annual Report 1)
The state's quarterly air particulate composite f
isotopic data was not reported for the first quarter of 1986.
The weekly air particulate filters were not composited for analysis.
2)
The charcoal cartridge weekly gamma isotopic data should be reported as an independent sample type and analysis.
(b) 1987 Annual Report 1)
The charcoal cartridge weekly gamma isotopic data should be reported as an independent sample type and analysis.
2)
The charcoal cartridge 1811 required LLD of 3
0.67 pCi/m was not met by the state on several analyses.
8.
b.
Surface Water The' cooperative agreement requires two surface water samples to be collected monthly at each nuclear power station:
one sample downstream of the plant in the immediate area of the plant discharge and another sample upstream of the plant at a control location. The cooperative agreement requires a gamma isotopic analysis on a monthly frequency and a tritium analysis on a quarterly composite by location of the monthly samples.
The required samples were collected and split between the state and the licensees monthly, Gamma isotopic and tritium analyses were performed at the required frequencies in the DLS radiochemistry laboratory by state personnel.
The results reported by the state in the 1986 and 1987 annual reports for the two licensees met most of the specific requirements of the cooperative agreement; however, the NRC appraiser noted the following observations and deficiencies:
(1) FCS (a) 1986 Annual Report 1)
The state's quarterly surface water composite tritium data was not reported for the first quarter of 1986.
The monthly surface water samples were not composited for analysis.
2)
The licensee reported tritium results for the surface water samples on a monthly sample rather than on a quarterly composite; therefore, a direct comparison with the state's quarterly composite analytical results could not be made.
3)
The licensee did not report isotopic results for 131I on monthly surface water samples.
4)
The surface water 131I LLD of 1.0 pCi/ liter for a i
drinking water source, such as the Missouri River, was not met by the licensee.
5)
The state did not implement in 1986 an analytical procedure which met the required surface water 131I LLD of 1.0 pCi/ liter.
6)
The state reported measured tritium results less than the analytical procedure reported LLD for the second and fourth quarters of 1986.
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9 (b) 1987 Annual Report 1)
The state reported measured tritium results less than the analytical procedure reported LLD for the third and fourth quarters of 1987.
2)
The licensee reported tritium results for the surface water samples on a monthly sample rather than on a quarterly composite; therefore, a direct comparison with the state's quarterly composite analytical results could not be made.
3)
The licensee did not report isotopic results for 1811 on monthly surface water samples.
4)
The surface water 181I LLD of 1.0 pCi/ liter for a drinking water source, such as the Missouri River, was not met by the licensee.
(2) CNS (a) 1986 Annual Report 1)
The state's quarterly surface water composite tritium data was not reported for the first quarter of 1986.
The monthly surface water samples were not composited for analysis.
i 2)
The licensee reported gamma isotopic results for the surface water samples on a quarterly sample rather than on monthly samples; therefore, a direct comparison with the state's monthly gamma isotopic results could not be made.
3)
The state did not implement in 1986 an analytical procedure which met the required surface water 1311 LLD of 1.0 pCi/ liter.
4)
The state reported measured tritium results less than the analytical procedure LLD for the second and fourth quarters of 1986.
(b) 1987 Annual Report 1)
The state did not report gamma isotopic results for surface water samples for the months of February and March.
The samples were not received by the state laboratory from CNS.
10 2)
The state's quarterly surface water composite tritium was not reported for the first quarter of 1986 since the samples for February and March were not received.
3)
The state reported measured tritium results less than the analytical procedure LLD for the third and fourth quarters of 1987.
4)
The state implemented in April 1987, an analytical procedure which met the required surface water 1311 LLD of 1.0 pCi/ liter.
c.
Milk The cooperative agreement requires one monthly sample of an offsite dairy located in the highest X/Q location.
Thecoogerativeareement 1 1I analys s on a requires a gamma isotopic analysis and a specific monthly frequency.
The samples were collected and split between the state and the licensees monthly.
Gamma isotopic and radioiodine analyses were performed at the required frequencies in the DLS radiochemistry laboratory by state personnel.
The results reported by the state in the 1986 and 1987 annual reports for the two licensees met most of the specific requirements of the cooperative agreement; however, the NRC appraiser noted the following deficiency in both reports.
The state did not implement, during the period January 1986 through April 1987, an analytical procedure which met the required milk 1311 LLD of 1.0 pCi/ liter as specified in of the u operative agreement.
Since May 1987, the state's analysis of 131I in milk has met the cooperative agreement LLD requirement.
d.
Fish The cooperative agreement requires one sample of a commercially or recreationally important species in the vicinity of the plant discharge to be sampled semiannually or in season.
Gamma isotopic analysis of the edible portions is required.
The results reported by the state in the 1986 and 1987 annual reports for the two licensees met, in part, the specific requirements of the ccoperative agreement; however, the NRC appraiser noted the following observations and deficiencies:
(1) FCS (a) 1986 Annual Report 1)
The licensee only collects fish samples annually rather than semiannually as specified in the cooperative agreement, t
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The licensee reported _gama isotopic results according to species and sampling-location while the state composited all fish samples and reported the composite results.
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The state's gama isotopic results were reported in units of pCi/kg wet rather than pCi/gm wet as i
. indicated in the report.
The state's and licensee's E
data should be reported in the same units for ease of 2
data comparison.
(b) 1987 Annual Report
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The same observations were made for the 1987 annual report as-indicated above for the 1986 annual report.
(2) CNS (a) 1986 Annual Report 1)
The fish sample collected in June 1986 was-received unsuitable for analyses in the state laboratory.
No analysis was performed.
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The state's gama isotopic results were reported in units of pCi/kg wet rather than pCi/gm wet as indicated in the report.
The state's and licensee's data should be reported in the same units for ease of i
i data comparison.
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(b) 1987 Annual Report I
The state's gama isotopic results were reported in units i
of pCi/kg wet and the licensee's gamma isotopic results 1
were reported in units of pCi/gm dry.
The state's and i
licensee's data should be reported in the same units for ease of data comparison.
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e.
Foo_d Products i
4 The cooperative agreement requires two samples 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 discharge flows, or green leafy vegetables grown in a private garden or farm in the imediate area of the plant to be split between the state and the l
licensee at the time of harvest.
Gama isotopic analysis including radiotodine of the edible portions is required.
The state and i
licensees collected and split the required food product samples.
Gama isotopic analyses including radiofodine were performed in the p
DLS radiochemistry laboratory by state personnel.
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12 The results reported by the state in the 1986 and 1987 annual reports for the two licensees met the requirements of the cooperative agreement; however, the NRC appraiser noted the following observations:
(1) FCS The licensee is not required by their Technical Specifications to sample food products; therefore, no food product samples wcre collected and analyzed by the licensee.
As a result, no food product samples were split with the state.
(2) CNS (a) 1986 Annual Report The licensee's gamma isotopic results were reported in units of pCi/gm wet rather than pCi/kg wet as indicated in l
the ro9 ort.
The state's and licensee s data should be reported in the same units for ease of data comparison.
(b) 1987 Annual Report 1)
The licensee reported gamma isotopic results for individual broadleaf samples while the state composited all broadleaf samples and reported the composite results.
2)
The state's gamma isotopic results were reported in units of pCi/kg wet while the licensee's gamma isotopic results were reported in units of pCi/gm wet.
The state's and licensee's data should be reported in the same units for ease of data comparison.
f.
Sediment from Shoreline The cooperative agreement requires one annual sample of shoreline sediment along a body of water into which plant discharge flows to be split between the state and licensee for gamma isotopic analysis.
The state and licensees collected and split the required sediment samples.
Gamma isotopic analyses were performed on the samples in the DLS radiochemistry laboratory by state personnel.
The results reported by the state in the 1986 and 1987 annual reports for the two licensees met the requirements of the cooperative agreement.
g.
Direct Radiation Levels The state has established a TLD direct radiation monitoring network of 12 locations around the FCS. site in conjunction with the licensee
13 and the NRC TLD 42 location network established in October 1980.
Three of the licensee's TLD sites and six of the state's TLD sites are collocated with the NRC.
The state has 10 TLD locations around the CNS site in conjunction with the licensee and the NRC TLD 43 location network established in October 1980.
Ten of the licensee's TLD sites and eight 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 personnel.
The results reported in the 1986 and 1987 annual reports met the requirements of the cooperative agreement.
12.
Reports The 1986 and 1987 annual reports for the two licensees were submitted by the state within the time period specified in the cooperative agreement.
13.
Exit Briefing At the conclusion of the appraisal on April 1, 1988, the NRC appraiser discussed the scope and findings of the appraisal with the individuals denoted in paragraph 1.
The NRC appraiser discussed those items which did not fully meet the conditions of the cooperative agreement and observations for program improvement as outlined in paragraph 3.
The state personnel agreed to review the NRC appraiser's findings and implement the necessary program improvements.
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