ML20154L760
| ML20154L760 | |
| Person / Time | |
|---|---|
| Issue date: | 09/02/1988 |
| From: | Baer R, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20154L740 | List: |
| References | |
| REF-QA-99990004-880915 99990004-88-23, NUDOCS 8809260283 | |
| Download: ML20154L760 (8) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION REGION IV Performance Appraisal for the NRC/ State of Kansas Environmental Monitoring Cooperative Agreement NRC-31-84-502 Facility Name:
Kansas Department of Health and Environment (KOHE)
Appraisal At:
Topeka, Kansas Appraisal Conducted:
August 8-10, 1988 Appraisal Period:
January 1, 1985, through December 31, 1987 f/2/I'[
Appraiser:
D h.B. Nicholas,SeniorRadiationSpecialist Date Facilities Radiological Protection Section f/2/86 Approved:
4 W
R.' E. Baer, Chief, Facilities Radiological Date Protection Section Appraisal Summary Appraisal Conducted August 8-10, 1988 (Report 99990004/88-23)
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 on corrective actions taken on previously identified deficiencies.
Results:
The state's overall performance satisfied the requirements of the cooperative agreement regarding sample collection and analyses.
Several observations for program improvement are outlined in paragraph 3.
Based on the state's performance, it is recommended that the cooperative agreement be continued.
8809260283 000915 RE04 GA999 ESGKS 99990004 PNV
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2 DETAILS 1.
Persons Contacted KDHE
- 80. H. Traster, General Counsel "J. A. Power, Jr., Director, Division of Environment
- J. C. Irwin, Acting Director, Bureau of Air Quality and Radiation Control
- E. L. Jeffords, Health Physicist
- S. T. Hasih, Radiation Control Inspector A. E. Smith, Environmental Technician H. L. Spiker, Chief, Surveillance and Emergency Planning Section
- 0. To, Chief, Radiation Chemistry Laboratory
- Denotes those present during the exit interview on August 10, 1988.
2.
General The purpose of this appraisal was to evaluate the state of Kansas' compliance with the cooperative agreement conditions and to review corrective actions on areas of concern reported in the previous appraisal conducted October 15-16, 1985.
The appraisal effort was devoted to j
reviewing the 1985, 1986, and 1987 environmental monitoring programs around the Wolf Creek Generating Station (WCGS).
The i
thermoluminescent (TLD) program and the environmental sampling and j
analyses program were implemented in January 1984.
3.
Observations and Conclusions The state's effort, since the previous appraisal conducted in October 1985, has shown improvement.
However, several observations for program improvement are identified below:
a.
The state may wish to include in future equipment budgets several equipment upgrades.
See paragraph 8.
b.
Written procedures have not been written or approved for all aspects of the environmental monitoring program.
See paragraph 9.
c.
Surface water tritium results were reported at different frequencies
.y the state and licensee.
See paragraph 11.b.
4.
Management Support The state has an environmental monitoring program in addition to the samples and analyses required by the cooperative agreement.
The environmental monitoring program is conducted by the Bureau of Air Quality and Radiation Control, Division of Environment, with assistance from the
3 Division of Laboratories.
The program is administered by qualified i
personnel who have experience in environmental monitoring.
The environmental monitoring program was funded during the appraisal period l
with an adequate budget to support and accomplish the sampling and analysis work load around WCGS and to maintain radiochemistry laboratory f
equipment and supplies.
5.
Organizational Structure l
The NRC appraiser reviewed the state of Kansas' Department of Health and Environment, Division of Environment, and Bureau of Air Quality and Radiation Control staff assignments and responsibilities.
The organizational structure and reporting sequence are the same as reported 2
in the NRC Appraisal Report 99990004/85-09 conducted in October 1985.
There have been two personnel changes in the management structure since the previous appraisal.
These changes were James A. Power, Jr.. Director, l
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Division of Environment and John C. Irwin, Acting Director, Bureau of Air Quality and Radiation Control.
6.
Staffing The NRC appraiser reviewed the staff responsible for the requirements of the cooperative agreement.
There was one staff change in the Surveillance and Emergency Planning Section (S&EPS) since the previous appraisal in October 1985.
This change involved the addition of E. L. Jeffords, Health Physicist, to the S&EPS.
7.
Training i
The HRC appraiser reviewed the offsite and on-the-job training received by L
the technical staff since the previous appraisal conducted in October 1985.
The NRC appraiser determined that E. L. Jeffords and A. E.
Smith had completed the "Radiological Emergency Response Course" offered l
by the NRC in Las Vegas, Nevada, and S. T. Masih had completed the "Radiation Protection Engineering Course" offered at Oak Ridge, Tennessee.
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The NRC appraiser noted that on-the-job training is conducted as required, l
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Training records had not been established which would document that supervision had reviewed and accepted employee proficiency for specific
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j sampling and analytical tasks.
The NRC appraiser indicated that a
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j specific program should be established for the on-the-job training.
l Technical staff should be encouraged to attend specific job related short i
courses and workshops to maintain an appropriate level of technical competence.
These items were discussed at the exit interview, and the KOHE i
management agreed that offsite training is valuable and will be approved I
whenever possible.
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8.
Facilities and Equipment l
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The NRC appraiser reviewed the S&EPS and radiochemistry laboratory t
equipment and facilities.
There have been no changes in the laboratory l
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4 facilities.
The NRC appraiser determined that the laboratory was expecting delivery of a new gross alpha / beta counting system in October 1988.
The NRC appraiser discussed, at the exit interview, the possibility of adding three new air samplers to the inventory and a second high purity germanium detector to the multichannel analyzer system to increase the efficiency of sample analyses.
The KOHE management agreed to evaluate the purchase of this equipment.
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 quality control (QC) of i
analytical instrumentation.
The NRC appraiser noted that some progress had been made in the area of procedure development.
The S&EPS had written sampling procedures for all environmental media and was establishing a section procedures manual.
Procedures to maintain and calibrate the air samplers had been written and approved.
Procedures for calibration and operation of the TLD reader were not written.
The radiochemistry j
laboratory was revising its laboratory procedures manual which provided instructions for operating laboratory instrumentation and performing laboratory analyses.
However, it was noted that the procedures reviewed were not written in a format which included for each procedure a title page including title, author, procedure number, revision number, date of issuance, and authorizing approval for use.
The NRC appraiser discussed, at the exit interview, the lack of procedures for the calibration and QC l
of the TLD instrumentation.
The KOHE management stated that efforts would l
be made to develop required procedures as time permits.
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- 10. Quality Assurance Program i
The NRC appraiser reviewed the state's QC program for the radiochemistry laboratory counting instruments.
The state participates in the Environmental Protection Agency (EPA) cross-check program.
The state's performance during 1985, 1986, and 1987 was reviewed and found acceptable within the EPA acceptance criteria.
1 The state's radiochemistry laboratory also performs an internal QC progrim.
This program consists of performance checks and calibrations of the counting instruments.
The radiochemistry laboratory has written procedures to document the instrumentation calibration and QC programs.
The NRC appraiser reviewed the calibration data and QC data for the radiochemistry laboratory counting instruments over the appraisal period I
which had been performed with radinactive standards traceable to the National Bureau of Standards.
Calibrations and performance checks were I
being performed on t'e counting instruments routinely.
QC charts were j
being used to detennine and trend instrument performance.
It appeared that the state was performing the required calibrations and adequate QC i
tests to verify the performance of the radioanalytical counting l
i ns t rume nts,.
A review of the calibration data for the Nuclear Data i
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5 multichannel analyzer system indicated that all environmental sample media and counting geometries 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 1
for the period January 1, 1985, through December 31, 1987, to determine agreement with Attachment I to the cooperative agreement.
The NRC l
licensee, Wolf Creek Nuclear Operating Company, by contract with an independent laboratory, conducts its own environmental monitoring program.
State personnel performed all routine environmental sampling, sample splitting with the licensee, and sample preparation and analyses.
The state's TLDs were also processed by state personnel.
State personnel exchanged the TLDs associated with the NRC TLD monitoring network and submitted them for processing to the NRC, Region I office on a quarterly i
exchange frequency.
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The following cooperative agreement sampling areas were evaluated-a.
Airborne - Particulate and Radiciodine The cooperative agreement requires two continuous air samplers:
one 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 four additional air sampling stations near WCGS which are not required by the cooperative agreement.
Tha state and i
licensee have air samplers located about 2.8 miles north of the plant in the community of Sharpe, Kansas.
The state's and licensee's control air sample station is located about 15 miles west-northwest of the plant in the town of Hartford, Kansas.
Gross beta analysis of the air particulate samples is required following each weekly filter i
change and the filters were composited by location for a quarterly gamma isotopic analysis.
The weekly radioiodine charcoal cartridge i
samples are required to be analyzed for iodine-131 following each i
cartridge exchange.
Airborne particulate and radioiodine samples were collected weekly at f
the state's air sampler locations.
Gross beta, gamma isotopic, and i
iodine-131 analyses were performed at the required frequencies in the i
state radiochemistry laboratory.
The results reported by the state in the 1985, 1986, and 1987 annual reports met the specific requirements of the cooperative agreement.
b.
Surface Water I
l The cooperative agreement requires two surface water samples to be
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collected monthly:
one sample downstream of the plant in the imrtediate area of the plant discharge and another sample upstream of L
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the plant at a control location.
The cooperative agreement requires j
a gama isotopic analysis on a monthly frequency and a tritium j
analysis on a quarterly composite by location of the monthly samples.
The state and licensee collected monthly samples from the plant I
discharge cove and from an upstream control location at the
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John Redmond reservoir.
The samples were split between state and i
licensee.
Gama isotopic and tritium analyses were performed at the required frequencies in the state radiochemistry laboratory.
l The results reported by the state in the 1985, 1986, and 1987 annual reports met the specific requirements of the cooperative agreement.
l However, it was noted that the licensee's tritium results were reported monthly in the 1987 report rather than quarterly making it difficult to directly compare analysis results.
The state personnel informed the NRC appraiser that the state implemented monthly tritium analyses of surface water samples in 1988 to conform to the analysis i
frequency requirements of the licensee.
I c.
Milk 3
The cooperative agreement requires one monthly sample of an offsite i
dairy or milk supply located in the highest X/Q location available.
The cooperative agreement requires a gamma isotopic analysis and a specific iodine-131 analysis on a monthly frequency.
The sample location had been determined to be at the Redding Dairy which was located about 5 miles northeast of the plant.
The Redding Dairy went l
out of business in July 1985 and milk samples were restarted from the t
Skillman residence near Hartford, Kansas, in October 1985.
The state and licensee collected duplicate monthly samples.
Gama isotopic and low level radioiodine analyses were performed at the required frequencies in the state radiochemistry laboratory.
The results reported by the state in the 1985, 1986, and 1987 annual reports met the specific requirements of the cooperative agreement, d.
Fish The cooperative agreement requires one sample of a comercially 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 licensee collected I
semiannual fish samples from the lake into which the plant discharge i
flows.
Fish from the catches were split b9 tween the licensee and the j
state for analysis.
Gama isotopic analyses were performed in the j
state radiochemistry laboratory.
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i The results reported by the state in the 1985, 1986, and 1987 annual I
reports met the specific requirements of the cooperative agreement.
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7 e.
Food Products The cooperative agreement requires two samples at the time of harvest 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 or farm in the immediate area of the plant.
Gamma isotopic analysis including radioiodine of the eligible portions is required. The sample location has been determined to be at the Hermon residence garden located about 1 mile north of the plant.
The state ano licensee collected and split samples from the garden at the time of harvest.
Gamma isotopic analyses including radioiodine were performed in the state radiochemistry laboratory.
The results reported by the state in the 1985, 1986, and 1987 annual reports met the specific requirements of the cooperative agreement, 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.
The state and licensee collected a duplicate sample from the plant discharge cove about 0.5 miles northwest of the plant.
The gama isotopic analysis was performed in the state radiochemistry laboratory.
The results reported by the state in the 1985, 1986, and 1987 annual reports met the requirements of the cooperative agreement, g.
Direct Radiation Levels The state has established a TLD direct radiation monitoring network of 21 locations around WCGS in conjunction with the licensee and the NRC TLD 47 location network established in September 1983.
Six of the licensee's TLD sites and twelve 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 1985, 1986, and 1987 annual reports met the requirements of the cooperative agreement.
12.
Reports The 1985, 1986, and 1987 annual reports were submitted by the state in accordance with the requirements of the cooperative agreement.
13.
ExitIntervb At the conclusion of the appraisal on August 10, 1988, the NRC appraiser discussed the scope and findings of the appraisal with the individuals
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denoted in paragraph 1.
The NRC appraiser discussed the observations for program improvement as outlined in paragraph 3.
The KOHE management L,
agreed to review the NRC appraiser's observations and implement the necessary program improvements.
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