ML20196F131
| ML20196F131 | |
| Person / Time | |
|---|---|
| Issue date: | 11/10/1988 |
| From: | Baer R, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20196F120 | List: |
| References | |
| CON-NRC-31-83-667, REF-QA-99990004-881202 99990004-88-26, NUDOCS 8812120205 | |
| Download: ML20196F131 (14) | |
Text
3 APPENDIX U.S. NUCLEAR REGULATORY COMMISSION REGION IV Performance appraisal for the NRC/ State of Arkansas Environmental Monitoring Cooperative Agreement NRC-31-83-667 Facility Name:
State of Arkansas Department of Health (ADH)
Appraisal At:
Little Rock, Arkansas Appraisal Conducted: October 13-14, 1988 Appraisal Period: January 1, 1985, through December 31, 1987 rp Appraiser:
ph d[d, n/9//r
- 8. Nicholar, Senior Radiation Specialist Date F cilities Radiological Protection Section Approved:
/jf 8d
. E. Baer, Chi
Facilities Radiological Date Protection 5 don j
A;fraisal Summary Appraisal Conducted October _13-14, 1988 (Report 39990004/88-26)
Areas Appraised:
Adherence to tbc requirements of the cooperative agreement including:
organization and mariagement support, sample collection and acAlytica', procedures, far,ilities, counting instrumentation, staffing and qualifications, laboratory quality assurance, and followsp corrective action tikon or, previously identified deficiencies.
j I
Results:
The state's overall perfomance did not fully satisfy all the requiremerits of the cooperative agreetent regarding sample analyses.
Sever &l deficiencies were identified and are sur-arized in paragraph 3.
Based on the state's upcate of laboratory equipment and covnitments to improve the performance of the laboratory, it is recommended that the cooperative agreement be cont.inued.
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DETAILS 1.
Persons Contacted A.D_H
- F. Dobbins, Assistant Director, Bureau of Environmental Health
- B. Bevill, Health Physics (HP) Supcevisor, Nuclear & Environmental Safety Section
- G. Dieus, Director, Division of Radiatior Control & Emergency Management "G. Dilbeck, Chemistry Sepervisor, Radiochemistry Laboratory
- R.
Horn, Director, Division of Public Health Laboratories D. Thomas, Radiochemist, Radiochemistry Laboratory D. Tran, Radiochemist, Radiochemistry Laboratory
- Denotes those present during the exit interview on October 14, 1988.
2.
General The purpose of this appraisal was to evaluate the state of Arkansas' compliance with the cooperative agreement conditions and to review corrective 3ctions on areas of concern reported in the previous appraisal conducted January 15-17, 1986.
The appraisal effort was devoted to reviewing the 1935, 1986, and 1987 environmental monitoring program around the Arkansas Nuclear One (ANO) station.
The thermoluminescent dosimeter (TLD) program and environmental sampling and analyses program were implemented in January 1980.
3.
Appraisal _Findines The state's effort, since the previous appraisal conducted in Jat.uary 1986, had shown some improvement during 1986: however, the state's performance during 1387 in completing sample analyses indicated several deficiencies, the NRC appraiser's findings identified during this appraisal are summarized below:
a.
The technical staff in the radiochemistry laboratory and the Nuclear and Environmental Safety Section staff, who administer the cooperative agreement, had experienced a 100 percent turnover since January 1986.
See paragraph 6.
b.
The present technical staff in the radiochemistry laboratory have had limited on-the-job training before assuming their present positions and responsibilities.
See paragraph 7.
c.
Procedures for the radiochemistry laboratory have not been updated to include current laboratory techniques and instrumentation.
See paragraph 9.
3 d.
Calibration standards for the air particulate filter quarterly composite, vegetation / food prcducts, and fish need to be established.
See paragraph 10.
e.
Airborne samples were not collected at the ANO weather station several weeks during 1985.
See paragraph 11.a.1.
f.
The state's charcoal cartridge radiciodine analyses during 1987 were not completed in a timely manner for iodine-131 analysis.
See paragraph 11.a.3(b) and 11.a.3(c).
g.
Gamma isotopic res;1ts were not reported for the air particulate filter quarterly composites in 1987.
See paragraph 11.a.3(d).
h.
The state's surface water gamma isotopic analyses during 1987 were not completed in a timely manner for iodine-131 analysis.
See paragraph 11.b.3(a).
1.
The surface water tritium results for 1987 reported as actual measured values were less than the state's reported lower limit of detection (LLD) for tritium.
See paragraph 11.b.3(b).
J.
The radiciodine LLD for milk was not met in 1985, 1986, and 1987.
See paragraph 11.e.
k.
The state's milk gamma isotopic analyses during 1987 were not completed in a timely manner to analyze for all required isotopes.
See paragraph 11.c.3(a).
1.
Fish samples :ollected in 1987 had not been analyzed prior to the issuance of the 1987 anrual report.
See paragraph 11.c.3.
m.
One vegetation rample for 1996 was not split with the licensee so no comparative analytical results re-e available.
See caragraph 11.4.2(a).
n.
Vegetation sampics collectea in 1937 had not been analyzed prior to the issuance of the 1987 annual report.
See paragraph 11.e.3.
o.
Shoreline sediment samplo collecced in 1987 had not been analyzed prior to the issuance of the 1937 annual "eport.
See paragraph 11.f.3.
p.
The state's LLO values for all sample media and isotopes appeared to be lower than achievable for par.4ent sample sizes and analytical techniques.
Sie paragraph 11.h.
q.
The state had not issued a supplementary report for missing data in the original 1987 annual report.
See paragraph 12.
i t
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4.
Management Support-l The state of Arkansas has an environt,. ental monitoring program in addition to the samples and analyses required by the cooperative agreement.
The i
environmental monitoring program is conducted by the Division of Radiation Control and Emergency Management with the support of the Division of L
Public Health Laboratories.
The state's environmental ronitoring program i
and the NRC cooperative agreement are administered by qualified personnel who have experience in radiation control and environmental monitoring.
The 2 tate's environmental monitoring program and radiochemistry laboratory were funded during the appraisal period with adequate budgets to support and accomplish the sampling and analyses requirements throughout the state and around AND and to maintain the radiochemistry laboratory equipment and I
supplies.
(
5.
Organizational Structure The NRC appraiser reviewed the state of Arkansas' Bureau of Environmental
(
Health Services organizational structure. The organizational structure and reporting sequence for the Division of Radiation Control and Emergency Management and the Division of Public Health Laboratories has remained the same as previously reported in the NRC Appraisal Report No. 99990004/86-02 with one exception:
the Licensing and Environmental Surveillance. Section, which admiitisters the NRC cooperative agreement, has been reorganized and named the Nuclear and Environmental Safety Section (NESS).
6.
Staffing P
The NRC appraiser reviewed the staff responsible for the requirements of the cooperative agreement.
There has been a 100 percent change of staff in the radiochemistry laboratory and the NESS since the previout appraissi in January 1986.
The present staffing consist of the radiochemistry laboratory supervisor, George A. Oilbeck; the two laboratory rad <ochemists, Donne L. Thomas and Ovyan T. Tran; the NESS HP supervisor, i
Bernard R. Bevill; and the NESS health physicist, Lee Gershner.
7.
,T_ra i n i n g l
The NRC appraiser
- reviewed the offsite and on-the-jcb training received by f
the technical staff since the previous appraital conoucted Jaruary 1986.
No formal offsite training had been attended by any of the present i
technical staff in support of the cooperative agreement.
The NRC appraiser determinec that the only training received by the technical staff to perform the requirements of the NRC cooperative agreement had been on-the-job training while in their present positions of responsibility.
The NESS HP supervisor, B. R. Bev111, who adminis'.or$ the cooperative agreement, has been in his present position since December 1986 without prior knowledge of the cooperative agreement requirements. The NESS health physicist, L. Gershner, who assists in the coordination of the environmental sampling, has been in his present position since July 1987.
The rsdiochemistry laboratory supervisor,
5 G.A. Dilbeck, received on-the-job training in the radiochemistry laboratory for 7 months before assuming the position of supervisor in January 1988.
The two laboratory radiochemists had no prior radiochei.;istry experience before being assigned to their present positions in June and October 1988.
The NRC appraiser noted that on-the-job training records had not been established which would document that supervision had reviewed and accepted employee proficiency for performing specific sampling and analytical tasks.
Ti.e NRC appraiser indicated that a specific program should be established for the on-the-job training.
The technical staff should be encouragu
.c attend specific job related short courses and workshops to maintain e appropriate level of technical competence to perform the requirements of the NRC cooperative agreement.
These items were discussed at the exit interview and the ADH management agreed that specific training related to *.e requirements of the cooperative agreement is valuable and will be approved whenever possible.
8.
Facilities and Equipment l
The NRC appraiser reviewed NESS and radiochemistry laboratory equipment and facilities. There had been no changes in the laboratory facilities.
The NRC appraiser noted that the NESS had purchased a new Harshaw TLD system in July 1986. The NESS had also purchased four air samplers since the previous appraisal in January 1986 to replace the old air samplers which were dif ficult to keep operatio' al.
The NRC appraiser reviewed the radiochemistry laboratory counting instrumentation upgrades.
It was determined that a new lia.id scintillation spectrometer system had been purchased in October 19 M and a new gamma spectroscopy system had been purfhared in Decemb.r 1987 to reMa:e out-dated equipment and eliminate a very high cercentage of instrument down-time.
The NRC appraiser discusse, at the exit interview, the possibility of adding a high-purity r
~
germanium detecter t. the gamma spectroscopy system to increase the efficiency of cample gamma isotopic araiyses.
The ACH management agreed to evaluate the purchase of this additianal detector.
9.
Procedures The hRC ap?rsisSr reviewed the state's progress in oeveloping envircrmental Mor,itoring prcgram and radiochemistry laboratory procedures for:
sampla collecticn, control, preparation, and analyses; calibration of laboratory counting instruments, TLD system. and air sampling equipment; and quality control (QC) of analytical instrumentation.
The NRC appraiter reviewed tne NESS environmental monitoring progre procedures for sample collection, sample centrol, field exchange of environmental TLDs, calibration and QC of the TLD system, and calibration of the environmental low volume air samplers.
The NESS had assembled all of the environmental monitoring prograr procedures into a section procedures manual which included a title page indicating who prepared and reviewed the procedures, when the procedures had been issued and revised, and who authorized approval for official use.
The NRC a v aiser noted
6 that the calibration procedure for the environmental low volume air samplers did not specify a recalibration frequency. The NRC appraiser reviewed the radiochemistry laboratory procedures manual and noted that all radiochemistry laboratory procedures for sample control, preparation, and analyses; and calibration, operation, and QC of analytical instrumentation had been approved for official laboratory use.
The NRC appraiser noted that many of the analytical procedures had been taken from Enviroamental Protection Agency (EPA) documents or the Health and Safety Laborawry Procedures Manual, HASL-300.
These procedures were found to be in need of revision to incorporate current laboratory techniques and instrumentation.
The NRC appraiser noted that the procedures manual did not have operating and calibration p.aocedures for the new liquid scincillation spectrometer and the new gamma spectroscopy system. The NRC appraiser observed little change or improvement in the radiochemistry laboratory procedures since the previous appraisal conducted in January 1986.
The effort to improve the radiochemistry laboratory program needs to receive a high priority especially in the area of program documentation so as to maintain quality analytical results and program continuity.
The NRC appraiser discussed, at the u it interview, the need for radiochemistry procedure revisions and upgrading to present laboratory techniques and instrumentation.
The ADH management agreed that efforts would be made to upgrade and develop required procedures as time permits.
- 10. Quality Assurance Projram The NRC appraiser reviewed the state's OC program for the radiochemistry counting instruments.
The state participates in the EFA cross-cneck pregram. The state's performance during 1985, 1936, and 1987 was reviewed and found acceptable within the EPA acceptance criteria. A summary of the EPA cross-check program risults for the re pective years was included in each of the 1985, 1986, and 1987 annual reports as required by the cooperative agreement.
The state's raciochemistry Idoratory also partorms an internal OC program.
This proq*an censists of performance checks and calibrations of the counting instruments.
The adiochemistry laboratory had not written detailtd procedures to document the methods for conducting the counting instrum.entation calibratien and QC programs.
The NRC appraiser reviewed selected calibration data and QC data for the radiochemistry laboratory counting instrumehts over the appraisal period which nad been performed with radioactive standards traceable to the National Bureau of Standards.
Performance checks were being performed on the counting instruments routinely.
QC charts were being used to determine and trend instrument performance.
It apoeared that the state was performing adequate QC tests to verify the performance of the radicanalytical counting instruments.
However, a review of calibration dsta for the Packard Tri-Carb liquid scintillat
- system indicated that the system had not been calibrated since the oal installation in October 1987.
The calibration data for the Nuclear ata gamma spectroscopy system indicated that an air particulate filter composite standard for 13 filters had not been prepared for the quarterly composite requirement. Calibration standards
a 7
spe:ifically for fish and vegetation samples had not been prepared.
The Nuclear Data gamma spectroscopy system should be reca11brated using properly prepared standards in accordance with written approved procedures to meet the cooperative agreement requirements for analysis of water, milk, air, sediment, fish, and vegetation.
The state's m;nimun, detectable activities for required nuclides in all sample media shoulo be reestablished to reflect current analysis sensitivities.
- 11. Cooperative Agreement Required Sample Collections and Analyses The NRC appraiser reviewed the sample collections and sample analyses performed for the period January 1, 1985, through December 31, 1987, to determine agreement with Attachment 1 to the cooperative ~ agreement.
The NRC licensee, Arkansas Power & Light Company (AP&L), conducts its own environmental sampling and analysis program in cooperation with the state.
State personnel performed routine sampling and sample splitting with che licensee as required by the cooperative agreement.
State personnel performed all sample preparation and analyses for their samples in the state's radiochemistry laboratory.
The state's TL0s were also processed by state personnel. State personnel exchanged the TL0s 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 cgreement samplinj areas wrre evaluated and several observailons and ueficiencies were noted:
a.
Airborne - Particulate and Radioicdine The cooperat!ve sgreement requires two r.ontinuous air samplers:
one air sampler in close croximity to tne licensee's air sampler in a high calculated X/Q direction from the plant and another <ir sampler at a control location in close proximity to the licensse's air i
sampler.
The state and the licensee have air samplers located about O 7 m'.les east of the plant at tns ANO meteorological tower.
The state's and licersee's control sample station is located about 21 miles soutnwest of the plant at the AP&L substation in Danville, Arkansas.
Gross 'Jeti analysis of the air pa*ticulate $45010$ is I
required follouin; each weekij f' ster change.ad the filters composited by location for a nonthly gacma isotopic analysis in 1965 and a quarterly gamaa isotopic anaiysis in 1980 and 1937.
The weekly radiciodine charcoal cartridge samples are required to be analyzed der iodine-131 following each cartridge exchange.
Airborne pirticulate and radioiodine samples were collected weekly at the state's two air sampler locetions.
Gross beta, gamma isotopic, and iodine-131 analyses were performed at the required frequencies in the state radiochemistry laboratory.
The results reported by the state in the 1935, 1986, and 1987 annual reports are summarized below:
8 (1) 1985 Annual Report State airborne samples were not collected at the ANO weather station during t.e time period January through March 1985 due to operater error and also not collected in November 1985 due to lack of repl' cement charcoal cartridges.
(2) 1956 Annual Report The state and licensee reported monthly gamma itotcpic data for the air particulate fiiter composites during the first quarter and switched to reporting quarterly gamma isotopic data for the air particulate 111ter composites for the secorid, third, and fourth quarters as per the cooperative agreement requirements.
(3) 1987 Annual Report (a) The state's and licensee's air particulate filter data should be reported in the same format for ease of comparing data.
(b) The state's weekly charcoal cartridge radiviodine analyses for the time period June 10 through September 15, 1987, were not completed in a timely manner for iodine-131 analysis.
Too many half-lives for iodine-131 had transpired wher tr inalyses were completeu making the results of the analy.ws useless.
(c) The state's weekly charcoal cartridge radioicdine analyses for the time period September 22 through December 29, 1987, had not been performcd when the report was issued in May 1988 making these samples useless.
The state representatives stated to the NRC appraiser that the old gamma spectroscopy system was not working during much of jr this time period causing delays in the analysis of the samples.
(d) The state had not cor..pleted the gamma isotopic analyses on the air particulate filter quarterly composites when the report was issued in May 1985 due to the numerous malfunctions of the old gamma spectrosccpy system and lack of a calibration standard for the filter compcsite, b.
Surface Water The cooperative agreement requires two surface water samples to be collected monthly:
one sample downs'. ream of t'e plant in the immediate area of the plant discharge and another sample upstream of I*.
the plant at a control location.
The cooperative agreement requires a gamma isotopic analysis on a monthly frequency and a tritium l
9 analysis on a quarterly composite by location of the monthly samples.
The state and licensee collected monthly samples from the lake into which the plant discharge flows and from an upstream control location at Big Piney Creek.
The samples were split between the state and licensee. Gamma isotcpic and tritium 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 are summarized below:
(1) 1985 Annual Report The surface water results reported by the state in the 1985 annual report met the requirements of the cooperative agreement.
(2) 1986 Annual Report The quarterly tritium results for the Big Piney Creek samples were reported with an unusually large standard deviation for the corresponding tritium result.
(3) 1987 Annual Report (a) The state's monthly gamma isotopic analyses for the time period April 14 through November 9, 1987, were not completed in a timely manner for iodine-131 analysis.
Too many half-lives for iodine-131 had transpired when the analyses were completed.
The state representatives stated to the NRC appraiser that the old gamma spectroscopy system was not working during much of this time period causing delays in the analysis of the samples. This data is essentially useless.
(b) The quarterly tritium results reported by the state as actual measured values were below the state's *eported LLD for tritium. The low reported tritium results had large corresponding standard deviations.
c.
Milk The cooperative agreement requires one monthly sample of an of' dairy or milk supply located in the highest X/Q location ava' The cooperative agreement requires a gamma isotopic analysi'.
specific iodine-131 analysis on a monthly frequency.
This sm location had been determined to be the Arkansas Technical University Dairy which is located about 5 miles east of the plant.
The state collected monthly samples which were split with tne licensee. Gamma isotopic analysis including radiciodine were performed at the required frequencies in the state radiochemistry laboratory.
)
l
i 10 The results reported by the state in the 1985, 1986, and 1987 annual reports are summarized below:
(1) 1985 Annual Report The state's monthly iodine-131 results were reported as below LLD.
The state's LLD for iodine-131 in milk according to of the annual report was 0.1 pCi/ liter.
The NRC appraiser determined that the state had not performed a specific low level radioiodine analysis of the milk samples; ther& fore, the state was unable to achieve the reported LLD.
The radiochemistry laboratory supervisor informed the NRC appraiser that he was not aware of the requirement to perform a specific low level radioiodine analysis on the monthly milk sample.
(2) 5 Annual Report state's monthly iodine-131 results were reported as below The state's LLD for iodine-131 in milk according to tachment 1 of the annual report was 0.1 pCi/ liter. The NRC oppraiser determined that the state had not performed a specific low level radioiodine analysis of the milk samples; therefore, the state was unable to achieve the reported LLO.
The radiochemistry laboratory supervisor informed the NRC appraiser that he was not aware of the requirement to perform a specific low level radioioline analysis on the monthly milk sample.
a (3) 19e7 Annual Report ta) The state's monthly gamma isotopic analyses for the time a
period May 18 through September 9, 1988, were not completed in a timely manner to analyze for all required isotopes.
Too many half-lives for barium-140 had transpired when the analyses were completed, j
The state representatives indicated the analyzes were delayed due te LSs old gamma spectroscopy system not l
working durint nach of this time period causing delays in the analysis of the samples.
This data is esse,t4 ally j
useless.
(b) The state's monthly iodine-131 were reported as below LLD for the time period January 22 through March 24, 1987.
The state's LLD for iodine-131 in milk according to of the annual report was 0.1 pCi/ liter.
The NRC appraiser determined that the state had not performed a specific low level radiciodine analysis of the milk
- l samples; therefore, the state was unable to achieve the 4
i
+
11 reported LLO.
The radiochemistry laboratory supervisor informed the NRC appraiser that he was not aware of the requirement to perform a specific low level radioiodine analysis on the monthly milk sample.
t (c) The state's monthly iodine-131 analyses performed by bulk i
gamma isotopic analysis for the time period April 22 i
through Cecember 9, 1987, were not completed in a time?y j
manner for iodine-131 analysis. Too many half-lives for iodine-131 had transpired when the analyses were completed.
The state representatives indicated that the analyses were i
i delayed due to the old gamma spectroscopy system not working during much of this time period causing delays in the analysis of the samples.
This data is essentially useless.
l d.
Fish l
The cooperative agreement requires one sample of. commercic'iy 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 state collected semiannual fish samples from the plant discharge canal.
Fish from the catch were split between the licensee and the state for analysis.
The gamma isotopic analyses of the state samples were performed in the state radiochemistry laboratory.
The results reported by the state in the 1985, 1986, and 1987 annual reports are summarized below:
(1) 1985 Annual Report The ru ults reported by the state in the 19?5 annual report met the requirements of the cooperative agreement. The isotopic results reported for cesium-137 by the state and licensee were in goou' yreeeent.
(2) 1986 Annual Repcrt Tne resultt, reported by the state in the 1086 annual report met the requirements of the cooperative agreement.
The isotopic results reported for cesium-134 and cesium-137 by the state and licensee were in good agreement.
( 3,'
1987 Annual Report The state had not analyzed the fish samples collected un April 30 med October 15, 1987, when the report was issued in May 1988.
12 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 or farm in the immediate area of the plant. Gamma isotopic analyses including radioiodine of the edible portions are required.
The sample location had been determined to be at the C. Stewart residence garden which was located about 1 mile southeast of the plant.
The state and licensee collected and split samples from the garden at the time of hsrvest. The gamma isotopic analyses of the state samples including radiciodine were performed in the state radiochemistry laboratory.
t The results reported by the state in the 1985, 1986, and 1987 annual reports are summarized below:
(1) 1985 Annual Report The results reported in the 1985 innual report met the requirements of the cooperative agreement.
(2) 1986 Annual Report (a) One of the vegetation samples was not split with the licensee because it was a nonedible sample.
(b) The licensee's reported cesium-137 result of 31.9 pCi/kg was less than the licensee's LLD of 50 pCi/kg for cesium-137 in a vegetation sample as reported in 4 of the report.
l (3) 1987 Annual Report l
t l
The state had not analyzed the vegetat'on samples collected on l
1 June 17 and September 15, 1987, when tM report was issued in May 1987.
These samples are considered useless, f.
Sediment From Shoreline The cooperative agreement requires one annual split with the licensee for gamma isotopic analysis of shoreline sediment along a body of water into which plant discharge flows.
The licensae collected and spilt a sample frvm the lake into which the plant discharge canal flows about 0.25 miles below the mouth of the ANO discharge canal.
The gamma isotopic analysis of the state sample was performed in the state radiochemistry laboratory.
l The results reported by the stat in the 1935, 1936, and 1987 annual reports are summarized below:
)
i
i 13 (1) 1985 Annual Report Tne state and licensee identified cobalt-60, cesium-134, and cesium-137 in the split sample collected on March 2, 1985. The reported results were in good agreement between the state and licensee for cobalt-60 and cesium-134; however, the cesium-137 result reported by the state was one order of magnitude greater than the cesium-137 result reported by the licensee.
(2) 1986 Annual Report The state and licensee identified manganese-54, cobalt-55, cobalt-60, cesium-134, and cesium-137 in the split sample collected on July 12, 1986.
The reported results were in good agreement between the state and licensee.
(3) 1987 Annual Report The state had not analyzed the shoreline sediment samples collected on March 7 and August 14, 1987, when the report was issued in flay 1988.
These samples are considered useless.
g.
Direct Radiation Levels The state has established a TLD direct radiation monitoring network of 52 locations around the ANO site in conjunction with the licensee and the 40 location NRC TLD network established in December 1979.
Sixteen of the licensee's TLD sites and seventeen of the state's TLD sites are colocated with the NRC.
The cooperative agreement requires J
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, h.
LLO The NRC aporaiser reviewed the state's and licensee's LLO tables included in the 1985, 1936, and 1987 annual reports tabulating the LLDs for each environmental sample media and analysis type required by the cooperative agreement. The LL0s reported for both the state and licensee met the requirements of the cooperative agreement.
However, it was noted that the state's LLD for iodine-131 in water and milk was reported as 0.1 pCi/ liter.
This is an order of magnitude less than the LLD for iodine-131 in water and milk of i
1.0 pC1/ liter as required by the cooperative agreement.
This reported iodine-1,1 LLO is impossible to obtain even if a specific low level radiotodina analytical procedure is performed on the water and milk samples.
It was determined that the state had not performed a low level radiciodine analysis on any water or milk samples and a review of sample gamma isotopic analyses of water and milk indicated 1
I
___7
'6 O*
14 an LLD for iodine-131 of approximately 4-5 pCi/ liter. The NRC appraiser also noted that the LLD values reported for all the other isotopes and sample media appeared to be lower than what would be expected for the sample size and analysis techniques used by the state radiochemistry laboratory, These observations were discussed during the exit interview on OC ober 14, 1988. The state representatives agreed te e>:alua:e the state's LLD values reported in the annual reports and 'ev synlit A and document a new LLD table using current labor
.g
.aiyi13 urocedures.
12.
Reports The 1985, 1986, ar.d 198 t
. d rev.
were submitted bv the state in accordance with the requ.
' nts 4/'
cooperative agreement.
- However, as noted above many of th, u tysei
samples collected in 1987 were either not completed or com, 'ted o a delayed schedule wnich rendered most of the data useless for evaparison purposes with the licensee's analysis results.
As per paragraph IV, "Reporting," of Attachment A. "Statement of Work," to 4
the NRC cooperative agreement, missing results in the originally submitted annual report must be noted and reasons for the missing results explained.
In addition, the NRC cooperative agreement requires that the missing data be submitted in a supplementary report as soon as possible. At the time of the appraisal, the state had not completed analyzing all of the 1987 samples which had been collected.
Therefore, a supplemtntal repott had not been issued.
This item was discussed at the exit interview and the 1
state representatives agreed to sspoly a suppiementary report as soon as possible containing the analytical results of samples which were indicated not analyzed at the time of the initial report.
13.
Exit Interview At the conclusion of the appraisal on October 14, 1988, the NRC appraiser discussed the scope and findings of the appraisal with the individuals denoted in paragraph 1.
The NRC appraiser discussed those observations and findings which did not meet the conditions of the cooperative agreement as outlined in paragraph 3 of this report. The state representatives agreed to review the NRC appraiser's observations and findings and implement the necessary program improvements in order to comply with all conditions of the cooperative agreement.