ML20207M946
| ML20207M946 | |
| Person / Time | |
|---|---|
| Issue date: | 10/03/1988 |
| From: | Block S, North H, Tenbrook W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20207M851 | List: |
| References | |
| CON-NRC-32-83-684 NUDOCS 8810180429 | |
| Download: ML20207M946 (5) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION V a,
Performance Appraisal Report No. NRC-32-83-684/88-01 Contract: NRC-32-83-684 Contractor: State of California Health and Welfare Agency Department of Health Services
- 714/744 P Street '
Sacramento, California 95814 ,
' Appraisal at: State of California Sanitation and Radiation. Laboratory (SRL)
Berkeley, California ',- ,
State of California Department of Health Service's '.
Environmental Management Branch (EMB) '
it.
Sacramento, California -
i Appraisal Conducted: August 31, 1988 and September 19, 1988 ,
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. Appraisal by: 8 /0/h/ h __
W. K. TenBrook, Project Officer Date/ Signed' '
Facilities Radiological Protection Section
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Si Block, Health Physicist Date' Signed Emergency Preparedness and Radiological Pro ction Branch .
Approved by: V /olJ/ff'__
H. S. N(rth, Acting Chief Da'te' Si gned l Facilities Radiological Protection Section Summa ry:
- Areas Appraised
- Management Support, Organization, Staffing, Factlities, Quality Assurance, Reports. NRC Inspection Manual Chapter 1415 criteria and !
guidance were used.
Results: Overall program status is adequate, but on a declining trend, principally due to increased State radioanalytical workload without concomitant improvements in laboratory staffing and faci .itia; (Sections 2, 4 and 6). Items to be resolved were ident,1fied in laboratory QA/QC and the annual report (Sections 4, 5 and 8).
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DETAILS
- 1. Perr.ons Contacted W. Bean, Chemist, SRL J. Hickman, Associate Health Physicist, EMB R. McKinley, Health Physicist, EllB D. Speed, Health Physicist, EMB E. Squibb, Laboratory Assistant, SRL *
- 8. Tamplin, Chief SRL G. Uyesugi, Research Radiochemist, SRL D. Womeldorf, Chief, EMB J. Wong, Health Physicist, EMB
- 2. Changes and Improvements The State has reassigned radiological environmental monitoring from the Radiological Health B=anch to the Environmental Management Branch. EMB contemplated several initiatives to improve the program during 1989 and beyond, including efforts to attain more uniformity in State / Utility sampling and analytical methods, arrange more timely receipt of Utility and SRL data, improve the presentation of the annual report, and expand the routine environmental monitoring program at nuclear power facilities. No outstanding changes were noted in the conduct of the program to date, and no significant change to the annual report format was planned by EMB prior to 1989.
The Sanitation and Radiation Laboratory had purchased an additional liquid scintillation counter for low-background analysir, and was seeking to reconfigure shielding for low-background gamma analysis so as to make better use of NRC-supplied instrumentation. One additional chemist was to be hired in 1739. Two additional hires dedicated to the Californic low-level waste compact site. survey were planned following 1989.
4 The chaages in the State's activities pursuant to the contract were considered adequate to maintain contract performance to date, and did not have a detrimental effect.
- 3. Organization, Staffing and Training The State employed three EMB field agents, stationed in Los Ange16s, Berkeley and Sacramento, to perform split and parallel environmental sampling with reactor licensees, send the samples to SRL, and perform field exchange of State and NRC environments) dosimeters. An additional EMB Health Physicist managed the resuits returned by SRL and the Utifity, and was designated to draft the 1988 annual report. One section head manages the State environmental surveillance program, including the NRC contract program.
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'h SRL personnel prepared and analyzed the NRC contract samples-among the samples received from many State agencies. The radiological laboratory was overseen by-one Research Radiochemist, with two chemists and a; Laboratory. Assistant at his disposal. One Chemist was on extended leave at the time of the onsite appraisal. The laboratory staff has excellent experience, and participates in ongoing training in the fcrm of technical meetings, seminars, and analytical training by instrument
'vendo rs .
! 'The organizational structure and quality of personnel involved in the NRC contract effort were appropriate to per. form the requirements of the cooperative agreement. However, laboratory employee mora'e was low, and it appeared that laboratory staf f levels had nnt kept pace with
. increasing workload. Laboratory personnel stated that occasional 4
backlogs of perishable environmental sample media had occurred, and the
! - samples had spoiled prior to preparation. The laboratory staffing situatien-could affect parformance of NRC contract requirements as the State laboratory mission continues to expand.
- 4. Facilities, Methods and Quality Assurance
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The physical layout of the State's laboratory facilities was essentially unchanged since the initiation of the cooperative agreement. However, space has become very limited due to added instrumentation and the storage of' documents and supplies. A small
. radiochemistry lab 1has been provided in an adjacent building to
- ' separate tasks involving higher specific activ*ty radioactive material from environmental measurements.
1 The types of instrumentation necessary to perform the required analyses i were present. However, in some cases the State had 1ot committed sufficient funds to provide vendor maintenance for critical instrumentation, delaying analyses until sufficient funding could be ,
obtained.
j SRL's performance in the EPA quality assurance program has been excellent, indicating proper calf oration and analytical methods are in ,
use. However, SRL has declined to parti;!pate in the EPA cross-check
! for food products, which is a sample media included in the cooperative agreement. Quality control checks on instrumentation were routinely performed, but action criteria were not established for these checks.
- The control dosimeters for the NRC TLD network were ?.tored in the EMB i offices. The dosimeters were kept in their lead cask, as required.
The appraiser distributed NRC records of TLD locations for correction and revision by state field personnel.
The' State's facilities were adequate to perform the routine
' measurements required by the cooperative agrsement, given that the 3 State considers the NRC contract measurements an outstanding priority.
However, restricted space, difficulti"s in obtaining maintenance services, and backlogs due to unusual radiological incidents indicatad that the SRL facilities, and the resources dedicated to them, are 3
becoming inadequate for their overall tasks. This situation could 1
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affect the State's prformance e under the cooperative agreement, and will be monitored by the NRC Project Officer.
- 5. Annual Report The 1987 annual report to NRC was received within the required time, and was. reviewed by the NRC appraisers. The appraisers identified the following:
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The State cited' radon da'ughter decay as the principal reason for a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> delay prior'to air particulate sample analysis. The appraisers disagreed, stating that radon daughters would be essentially absent well within one day. The State and the appraisers agreed that the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> was generally estabitshed among environmental programs to provide a reasonable time for sample transit and consistent decay for gross radioactivity measurements, while incidentally allowing decay of ,
.short-lived radionuclides.
Somo instances of unavailable or missed saeples were reported by the State. These included sediments from Diablo Canyon, silt from Rancho Seco,' and the substitution of animal feed vegetution for human food product at Rancho Seco. The appraiser interviewed the field agents responsible for obtaining split and parallel samples, and no outstanding or recent problems were identified in obtaining the required samples.
Utility measurements of milk products and produce were reported both as wet weight and dry viight, while the State measurements were consistently reported as dry weight. These inconsistencies made measurement intercomparisons difficult. Although botn methods are appropriate under certain circumstances, the State and the Appeaisers agreed that consistency was desirable to fulfill the confirmatory measurement function of the contract. EM8 representatives stated that they would consult the Utilities to better coordinate measurement units in JY1989.
State measurements of air particulate beta activity from Chernobyl fallout were typically one order of magnitude higher than the Utility measurements. Although there were differences in sampling frequency between the State and Utilities during the fallout period, the appraisers and the State could not identify any conc!usive reason for the discrepancy. The NRC Project Officer stated that he would continue
' to consult with the State in order to reco1ve this discrepancy.
Finally, the State did not include gamma isotopic measurements of quarterly air particulate filter cumposites in the annual report.
These analyses are a contract requiremeat. The appraisers located the analytical data for these measurements during an onsite visit to SRL.
When informed of the omission, EMS repiesentatives stated that the data would be submitted to NRC in a supplet.4 ental report.
The St3te's annual report was not considered fully acceptable in that
, it did not contain one set of data required by the cooperative l
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agreement. Submittal'of a supplementary report was considered a
. satisfactory remedy for this deficiency.
n 6. Management Support-F The appraisal of the status of laboratory ; facilities and staffing revealed a lack of commitment on the part of' management to adequately support the radiological laboratory program. The responsibilities of the State laboratory have expanded greatly, including evaluation'and qualification of outside laboratories, and additional analytical activities pursuant to federal and State programs and initiativns, of which the NRC cooperative agreement is a part. Management has not provided funding, facilities and staffing proportional to these
, expanded responsibilities.
- 7. Debriefina The appraisers met with State representatives at the conclusion of each onsite visit to present the findings of the appraisal. The appraisers and the State also discussed actions-to resolve specific deficiencies identified in the_ appraisal.
I' Summar'; and Recommendations 8.-
- l. The State's performance under the cooperative agreement nas been adequate, but on a declining trend, principally due to increased State i radioanalytical work 1_oad'without concomitant improvements in laboratory staffing and facilities, and the omission'of some. required data from the 1987 annual report to NRC. New hiring at SRL and the initiatives put forth by EMB are first: steps teward averting this decline.
No NRC action concerning the terms and conditions of the cooperative agreerrent is contemplated. , Pursuant to the cooperative agreement and
< the findings of'the appraisal, it was agreed that the following actions I would be taken prior to the next annual appraisal:
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- 1. SRL participation in the EPA radiological cross-check for food products.
- 2. Establish quantitative action points for quality control of SRL instrumentation used in contract analyses.
- 3. Submit a supplement to the 1987 annual report coritaining State and Utility gamma isotopic analyses of quarterly air particulate l filter composites dating from 1986.
- 4. In the absence of uniform analytical technique among the Utilities
] covered by the contract, insure that State eeasurements are reported in units that are suitable for comparison with each respective Utility measurement.
The NRC Project Officer wi;1 verify completion of these actions through consultations with the State.