ML20206S860
| ML20206S860 | |
| Person / Time | |
|---|---|
| Issue date: | 09/17/1986 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Lacker D TEXAS, STATE OF |
| References | |
| NUDOCS 8609230012 | |
| Download: ML20206S860 (2) | |
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SEP 171986 Texas Department of Health-ATTN:
David K. Lacker, Chief Bureau of Radiation Control 1100 West 49th Street
-Austin, Texas 78756-3189 Gentlemen:
Thank you for. your letter of August 26, 1986, in response to our performance appraisal and concerns dated July 10, 1986. We have reviewed your reply and 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, Original signe41irf.
Robert D. Martin Robert D. Martin Regional Administrator cc w/ state's letter:
James Taylor, Director Division of Reactor Programs, HQ Sharon Stewart, Contract Administrator Technical Contracts Branch Division of Contracts, ADM Texas Department of Health ATTN:
M. J. Boyer, Jr., Supervisor Environmental Chemistry Branch Bureau of Laboratories 1100 West 49th Street Austin, Texas 78756-3189 (cc continued next page)
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Texas Departrnent of Health Robert Bernstein, M.D., F.A.C.P.
1100 West 49th Street Robert A. MacLean, M.D.
Commissioner Austin, Texas 78756-3189 Deputy Commissioner (512) 458-7111
- Professional Services Hermas L Miller Radiation Control Deputy Commissioner (512)835-7000 Managementand Administration August 26, 1986 s
Mr. Robert D. Martin U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011
Dear Mr. Martin:
This letter refers to the performance appraisal conducted by Dr. J. Blair Nicholas of your office during May 27-29, 1986, for the U.S. Nuclear Regulatory Commission (NRC)/ State of Texas Environmental Monitoring Cooperative Agreement No. NRC-31-83-671 and responds to items indicated in the appraisal report, dated July 1, 19 8 6.~~~
Item 1 Please note the following corrections in Texas Department of Health staff and titles:
M. J. Boyer, Jr., Supervisor, Environmental Chemistry Branch, Bureau of Laboratories; R. A. Cripps, Chief, Field Operations Program, Facility Surveillance Branch, Bureau of Radiation Control; and R. S. Garcia, Geologist I, Field Operations Program, Facility Surveillance Branch, Bureau of Radiation Control.
Item 3a Procedure development and revision in the Bureau of Radiation Control (ERC), Division of Environmental Programs, is an ongoing process with revisions as needed. The format for revision of procedures is in the form of a memo through supervisory chain for approval to all staff members from the author of the revised or new procedures. Relevant data, such as title, author, purpose of revision or issuance, and date of issuance are indicated on the memo attached to the procedure. The Facility Surveillance Branch has developed procedures that are concerned with in-house, routine daily activities such as sample processing, vaste disposition, and sample log maintenance.
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August 26, 1986 Page 2 addition, procedures' have been developed that are concerned with field operations and are included in the Environmental Surveillance Handbook. This Handbook is issued to members of the BRC at the main office in Austin and in Regional offices.
The Handbook is currently being revised and updated. Sample collection procedures are being revised and developed and will be included in conjunction with the Handbook revision.
The Texas Department of Health Bureau of Laboratories has also a laboratory procedures manual written for the radiochemistry laboratory. This manual provides instructions for conduct'ing radiochemistry laboratory activities. The format for the manual has been_ changed to include a title page indicating title, author, procedure number, date of issuance, and approval.
Item 3b The Facility Surveillance Branch, as part of the ongoing development of its quality assurance program, is currently developing a computerized list of instruments requiring calibration. This list will contain for.each instrument identified by State property number 4
and serial number, the date of last calibration and the date of the i
next calibration. The implementation of this listing and the l-development of written procedures have been delayed due to lack of staff. Air sampler calibration, operational, and maintenance procedures will be developed in the near future and will be put in the Environmental Surveillance Handbook which is currently being updated and revised. The two low volume air samplers, Radeco Model HD-288, serial #1763 and #1764, that were used to monitor the air at the Comanche Peak Steam Electric Station (CPSES) were calibrated on October 29, 1982, by Radeco and put in place at CPSES in early 1983.
Prior to the termination of the State's interim pre-operational environments 1 monitoring program, approximately three months before the projected date for issuing an operating license, and resumption of the NRC environmental monitoring program as described in the NRC cooperative agreement NRC-31-83-671, these air samplers will be l
calibrated according to instrument calibration schedules and procedures that will be in effect in the near future.
l.
The Texas Department of Health Bureau of Laboratories, in response to the deficiencies in calibration data for the radiochemistry laboratory counting instruments, has increased the number of calibration standards and geometries for the various sample matrices. Routine scheduling of the recalibration of counting instruments was not carried out in the past as long as the daily quality control data fell within control limits. Acceptance criteria for the quality control data is now clearly documented and recalibration will be conducted on an annual basis, or more frequently, if necessary.
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Mr. Robert D. Martin August 26, 1986 Page 3 Item 3e Several airborne sample data were missing from the 198'4 annual report.
Regional personnel were unable to exchange air filters on February 15, July 17, and December 25 due to general meetings in Austin and a State holiday. Exchange of filters was made the following week. Airborne sample data were missing from the 1985 annual report from the meteorological tower location for the period of May 28 through August 26, 1985, and from the Chalk Mountain location for ehe period of July 16 through August 27, 1985. Sample data were not reported due to pump malfunction at both locations. Air sampler exchange was delayed until personnel were available to bring the air samplers to Austin for exchange and repair. These samples were deleted in the interim pre-operational environmental monitoring program effective September 1,1985. The implementation, in the near future, of operational and maintenance procedures for air sampling instrumentation will include procedures for exchange of air samplers that will ensure expeditious replacement of malfunctioning air samplers with minimal loss of air sampling data.
Item 3d i
Licensee tritium data for the upstream control were not reported in the 1984 annual report for the third and fourth quarters.
The third quarter tritium datum was < 2000 pCi/1. The fourth quarter datum was not reported because the upstream control location was changed from Lake Cranbury Marina to the Brazos River in December 1985, and split samples were not taken for the entire fourth quarter at this location.
Item 3e l
l The Texas Department of Health Bureau of Laboratories did not meet the L
lower limit of detection (LLD) for radioiodine in surface water and milk because of procedural problems. The LLD requirement for radioiodine in water, approved in 1986, is now being met.
The LLD for radioiodine in milk was not met in 1984 but has been met since then.
Two gallons of milk are collected monthly so that sufficient sample is I
available for prompt performance of both radioiodine and gamma isotopic analysis. This new procedure for milk collection should prevent recurrence of deficiencies in gamma isotopic data for milk as noted by the appraiser.
l Item 6 i
Mr. Russell S. Garcia, Geologist I, was transferred temporarily from l
the Environmental Assessments Branch to the Facility Surveillance Branch on July 22, 1985, due to the loss of an Environmental Quality Technician V staff position in 1985.
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Mr. Robert D. Martin August 26, 1986 Page 4 Item 7 The Texas Department of Health Bureau of Laboratories has available workbooks which show an analyst's proficiency at specific tasks and annual performance evaluation reports. Annual training records have been begun for each employee within the section. Also, a record is now being maintained on each individual showing their performance on U.S. Environmental Protection Agency (EPA) collaborative testing samples.
s We hope that the identified concerns have been addressed to your satisfaction. Our Bureau will continue to fulfill our obligation to meet all the conditions of the cooperative agreement. Should you have any questions concerning this response, please contact Raymond Cripps Ph.D. or Marilyn Preusse, Ph.D. of the Division of Environmental Programs.
Your truly,
.=e2L David K. Lacker, Chief Bureau of Radiation Control M N> -