ML20235H068
| ML20235H068 | |
| Person / Time | |
|---|---|
| Issue date: | 09/21/1987 |
| From: | Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20235H033 | List: |
| References | |
| 99990004-87-02, 99990004-87-2, NUDOCS 8709300350 | |
| Download: ML20235H068 (9) | |
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APPENDIX l l
U.S. NUCLEAR REGULATORY COMMISSION- 1 REGION IV I l
Performance Appraisal for the NRC/ State of Colorado Environmental Monitoring Cooperative Agreement NRC-31-83-668 Facility Name: Colorado State Department of Health Radiation Control Division Appraisal At: Denver, Colorado Appraisal Conducted: August 17-19, 1987 Appraisal Period: January 1, 1985, through December 31, 1986 i
Appraiser: M td'&/ k[/ [
O J. B. Nichola~s, Seni r Radiation Specialist Date '
g Facilities Radiologic (al Protection Section TJ Approved: ) (f h ){jf(0/0 BVWurray, Chief, Fa ties Radiological lh Protection Section Date /
Appraisal Summary Appraisal Conducted on August 17-19, 1987 (Report 99990004/87-02)
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 did not fully satisfy all of the requirements of the cooperative agreement regarding sample collection and analysis. Several deficiencies were identified and are discussed in paragraph 3. Based on the state's commitments to improve their performance, it is recommended that the cooperative agreement be continued.
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8709300350 PDR GA999 99990004 PR
i a 2 DETAIL 1
- 1. Persons Contacted Colorado Department of Health
- A. Hazle, Director, Radiation Control Division (RCD)
D. Gamewell, Principal Health Physicist, Technical Services Unit (TSU) !
- M. Hanrahan, Principal Health Physicist, Regulatory Unit Q. Nguyen, Senior Electronic Specialist
- R. Terry, Health Physicist T. Toledo, Senior Electronic Specialist K. Weaver, Senior Health Physicist
- Denotes those present during the exit briefing on August 19, 1987.
- 2. General The purpose of this appraisal was to evaluate the state of Colorado's compliance with the cooperative agreement conditions and to review corrective actions on deficiencies reported in the performance appraisal conducted January 8-10, 1986. The appraisal effort was devoted to reviewing the results of the 1985 and 1986 environmental monitoring program around the Fort St. Vrain Station (FSV). The cooperative agreement was initiated in 1981.
- 3. Summary and Conclusions The state's effort, since the previous appraisal conducted in January 1986, has shown improvement. However, several deficiencies still exist. These include: j
- a. The state was not using an industry standard 47 millimeter diameter i air particulate filter and charcoal cartridge. See paragraph 7 for details.
- b. Written procedures have not been completed and approved for: sample collection and control, response tests, calibration, operation and quality control of all radiation counting facility (RCF) 1 instrumentation, and preparation methods and documentation for ]
radioactive calibration standards. See paragraph 9 for details,
- c. The state has not fully implemented the use of control charts for )
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quality control of RCF instrumentation. See paragraph 10 for detai1s.
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- d. Counting geometries and/or calibration standards for the air particulate filter quarterly composite, charcoal cartridge, fish, and vegetation / food products need to be improved. See paragraph 10 for details. l 1
- e. Gross beta air particulate lower limit of detection (LLD) was not met l in 1985'and 1986. See paragraph 11.a.(1)(a) and 11.a.(2)(a). 'j
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- f. The radiciodine LLD for surface water was not met in 1985 and 1986. ]
See paragraph 11.b.(1)(a) and 11.b.(2)(a).
- g. Gamma isotopic results were not reported for upstream surface water i samples for January, March, and July 1985. See paragraph 11.b.(1)(b).
- h. Gamma isotopic resultr were not reported for the downstream surface water sample for January 1985. See paragraph 11.b.(1)(c).
- i. The radioiodine LLD for milk was not met in 1985 and 1986. See .,
paragraph 11.c.
- j. Shoreline sediment sample for 1986 was not split with the licensee so as to compare analytical results. See paragraph 11.f.(2).
Even though several minor deficiencies still need to be corrected, it is recommended that the cooperative agreement be continued.
- 4. Management Support !
The state maintains a comprehensive environmental monitoring program in addition to the samples and analyses required by the cooperative agreement. The environmental monitoring program is conducted by the RCD with the support of the Division of Laboratories within the Colorado State Department _of Health. The program is administered by qualified personnel who have experience in environmental monitoring and take a concerned interest in the performance of the program. The program is funded with a limited budget to accomplish the present workload and to maintain present radiochemistry laboratory and RCF equipment and supplies.
- 5. Organizational The NRC appraiser reviewed the State of Colorado's RCD regarding responsibilities for the management cooperative agreement. The ;
organizational structure and reporting sequence had undergone a reorganization in the spring of 1987 and the cooperative agreement is now administered and conducted under the TSU.
- 6. Staffing The NRC appraiser reviewed staffing regarding personnel responsible for implementing the requirements of the cooperative agreement. There have been no changes in the technical staff since the performance appraisal
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l . conducted in November 1982. The NRC appraiser noted that the RCF appeared l to be understaffed to perform the required sampling and analysis duties, to manage'the cooperative agreement, and to conduct the expanding state j environmental monitoring program.
- 7. Facilities and Equipment The NRC appraiser reviewed the RCF and equipment utilized in the-performance of the cooperative agreement requirements. There have been no changes in the facilities since the previous appraisal in January 1986.
The RCF had added, in the last 2 years, a second ND66 terminal and DSD880 disc drive to the Nuclear Data multichannel analyzer system. The NRC appraiser determined through discussions with the RCF staff that budget requests have been made to add a second high. purity germanium detector to the Nuclear Data system and to replace the Beckman Model LS100C liquid-scintillation system with a new state-of-the-art liquid scintillation system.
The cooperative agreement required LLD for air particulate gross beta analysis was not being met using the present sampling and analytical equipment. The NRC appaiser noted that the RCF air sampling equipment was using a 4-inch particulate filter and charcoal. cartridge. The air particulate filter was being analyzed for gross beta using a manual counting system. During discussions between the NRC appraiser and the RCF technical staff, it was determined that the standard 47 millimeter diameter air particulate filter and charcoal cartridge would possibly provide the necessary sampling and analysis capability to meet the cooperative agreement gross beta LLD for the air particulate gross beta analysis and also allow the gross beta analysis to be performed on the automatic Tennelec LB 5510 gross alpha / beta counting system. This item ;
was discussed at the exit briefing and the RCD management stated that the use of the 47 millimeter air particulate filter and charcoal cartridge would be evaluated.
- 8. Training The NRC appraiser reviewed the offsite and on-the-job training received by the RCF technical staff since the previous appraisal conducted in January 1986. It was determined that none of the RCF technical staff had attended any offsite training during the appraisal period. This item was discussed at the exit briefing and the RCD management agreed that offsite training is valuable and will be approved whenever possible.
- 9. Procedures The NRC appraiser reviewed the state's current environmental monitoring program procedures for sample collection, control, preparation, and analysis; calibration of counting instruments; and quality control of analytical counting instrumentation and air sampling equipment. The NRC appraiser noted that very little progress had been made in developing i
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program procedures since the previous appraisal. A review of the existing i procedures in the " Quality. Assurance Program for the Colorado Department of Health - Radiation Control Division" indicated that all the proposed procedures were either not written or completed and that those which had been drafted were not written in a standard laboratory format to include a title page indicating procedure title, author, procedure number, revision number, date of issuance, and approval. This item was discussed at the exit briefing and RCD management stated that efforts would be made to develop the required procedures. -
- 10. Quality Assurance Program The NRC appraiser reviewed the state's quality control program for the i RCF counting instruments. The state participates in the Environmental Protection Agency (EPA) cross-check program. The state's performance during 1985 and 1986 was reviewed and found acceptable.
The RCF also porforms an internal quality control program. This program consists mainly of performance checks and calibrations of the counting instruments. The RCF has not written procedures to document the i instrumentation calibration and quality control program. The NRC appraiser reviewed the quality control data and calibration data for the RCF counting instruments. Performance checks were being performed on the counting instruments routinely and the results were tabulated. The RCF was not using quality control charts to determine and trend instrument performance. The review of calibration data for the Nuclear Data multichannel analyzer system indicated the last calibration was performed in October 1984. The review also determined that an air particulate filter composite standard for 12-13 filters had not been prepared for the quarterly composite requirement, a charcoal cartridge standard had not been prepared and that the single particulate filter geometry was being used to assume a face-loaded charcoal cartridge counting geometry, and that the 3.5 liter Marinelli beaker water counting geometry was being used to analyze fish and vegetation samples. Accurate radioactive standards traceable to the National Bureau of Standards had not been prepared for each sample media to specifications which will meet the LLD and analysis requirements of the cooperative agreement. The Nuclear Data gamma spectroscopy system had not been recalibrates using properly prepared standards in accordance with approved written procedures to meet the l cooperative agreement requirements for analysis of 1988 samples.
- 11. Cooperative Agreement Required Sample Collections and Analyses I The NRC appraiser reviewed the sample collections and sample analyses performed for the period January 1, 1985, through December 31, 1986, to determine agreement with Attachment 1 to the cooperative agreement. The licensee, Public Service Company of Colorado, by contract with an independent laboratory, conducts its own radiological environmental !
monitoring program in cooperation with the state. State personnel performed routine environmental sampling and sample splitting with the licensee as required by the cooperative agreement. State personnel
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performed all sample preparations'and analyses,of their samples in the state laboratories except for TLD direct radiation measurements. ~ State personnel exchanged the'TLDs associated with the NRC.TLD direct radiation. ,
measurements network and submitted them for processing to~the NRC Region I !
'of.fice on a quarterly exchange frequency.
The following cooperative agreement sampling areas were evaluated and the various deficiencies noted:
- a. Airborne - Particulate and Radiciodine ;
The cooperative agreement requires two continuous air samplers: 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 st a control; location in close proximity to the licensee's air sampler.
The state and licensee.:have air samplers located about 0.8 miles south.of the plant.at a farm building. The state's and licensee's control air sampling station is located about~10.5 miles north of the plant in Johnst:wn . Colorado. The state operates two additional. air sampling stations not required by the cooperative agreement. The cooperative agreement requires continuous air sampling with airborne particulate:and radioiodine samples- collected weekly at two. locations 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 radioiodine charcoal cartridge samples were.
required to be analyzed for 1311 following each cartridge change.
Airborne particulate and radiciodine samples were collected weekly by state personnel at their four sample locations. Gross beta,~ gamma isotopic', and 132I analyses were performed at the required frequencies in the RCF by state personnel.
The results reported by the state in the 1985 and 1986 annual reports met most of the specific requirements of the cooperative agreement; however,-the NRC appraiser noted the following observations and deficiencies:
(1) 1985 Annual Report (a) The gross beta air particulate required LLD of 0.01 pCi/Ms was not met.
(b) The state's gross beta data were consistently at least a factor of 10 greater than the licensee's gross beta results. This is due to the difference in the LLD for the gross beta analysis at the two laboratories.
(c) The charcoal cartridge 2311 required LLD of 0.07 pCi/Ma was i not met on several analyses. j j
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(2) .1986 Annual Report
-(a) The gross beta air particulate required LLD of 0.01 pCi/M 3 was not met.
(b) The state'.s gross beta data were consistently at least a factor of 10 greater than the licensee's gross beta results. This.is'due.to the difference in the LLD for the gross beta analysis at'the two laboratories.
- b. Surface Water The cooperative agreement requiresitwo surface water samples'to be collected. monthly: one sample downstream of the plant ~in;the.
immediate area of the plant discharge and another sample upstream of the plant at a cont'rol location. The state and licensee collected-
-monthly. samples:at an upstream location about 1.5 miles west-southwest.'of the plant and at a downstream location about 1.4 miles north-northeast.of the plant. The cooperative agreement >
requires gamma isotopic and tritium analyses to^be performed on the monthly samples. The gamma isotopic and tritium analyses of the state samples were performed in the RCF by' state per.sonnel. The licensee-did not report a 181I result on the surface water samples.
The results reported in the 1985 and 1986 annual reports met most of the specific requirements of the cooperative agreement; however, the NRC appraiser noted the following observations and deficiencies:
(1) 1985 Annual Report (a) The 181I required LLD of 1.0 pCi/l was=not met.
(b) Gamma isotopic results were not reported for the upstream control water sample for January, March, and July.
(c) Gamma isotopic results were not reported for the downstream water sample for January.
(2) 1986 Annual Report (a) The 1811 required LLD of 1.0 pCi/l was not met.
(b) The tritium result for the downstream wat$r sample in June was incorrectly reported as 1611395 pCi/1. The correct value is 30,3611395 pCi/1.
(c) The NRC appraiser noted significant differences in the comparative results for the tritium analyses between the ,
-state and the licensee on the upstream control water '
samples for April and June.
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- c. Milk
[ 'The cooperative agreement requires.one monthly sample of an offsite l'
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r located in the highest X/Q direction from the plant. This sample. location has been determined to be at Station F-44 which.is-
- located approximately:1.1 miles east of.the plant. The monthly sample is collected by the licensee and split with the state. The monthly gamma ~ isotopic and low level radioiodine analyses were performed in the RCF by state personnel.
The results reported in the 1985 and 1986 met most of the specific requirements of the cooperative agreement; however, the following deficiency was noted in both reports. The LLD for radioiodine in milk did not meet the criteria of 1.0 pCi/ liter as specified in Attachment 2 of the cooperative agreement.
- 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 licensee collected' semiannual fish samples from an upstream location in the ' spring and from a downstream location in the fall. Fish were split between the licensee and the state for. analysis. The gamma isotopic analyses ,
were performed in the RCF by state personnel. I The results reported in the 1985 and 1986 annual reports met the requirements of the cooperative agreement. The NRC appraiser noted that the downstream sample location identification was in error. The location is described as R-10, South Platte at bridge and Colorado
~ Highway 66 which should be Colorado Highway 60.
- e. Food Products The cooperative agreement requires two samples 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 i plant discharge flows, or green leafy vegetables grown in a private f garden or farm in the immediate area'of the plant. Gamma isotopic analysis including radiciodine of the edible portions is required.
The state and licensee collected and split the required food product samples. The results reported in the;1985 and 1986 annual reports 1 met the specific requirements of the cooperative agreement. j
- f. Sediment from Shoreline The cooperative agreement requires one annual sample to be split between the state and the licensee for gamma isotopic analysis of shoreline sediment along a body of water into which plant discharge flows.
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9 The results reported by the state in the 1985 and 1986 annual reports met most of the specific requirements of the cooperative agreement; however, the NRC appraiser noted the following observation and deficiency: {
(1) The NRC appraiser noted in both the 1985 and 1986 annual reports
.that the downstream sample location identification was.in error.
The location is described as R-10, South Platte at bridge and Colorado Highway 66 which should be Colorado Highway 60.
(2) The results reported by the state in the 1986 annual report were-for a sample collected on August 16, 1986,.which did not compare to the licensee's samples collected on July 14 and October 18, 1986. The criteria of splitting the shoreline sediment sample ,
was not met. The state representative stated the original split ;
sample data was lost by the state and a substitute sample was '
analyzed and the results reported.
- g. Direct Radiation Levels The state has established a TLD direct radiation monitoring network.
of eight locations around the Fort St. Vrain station site in conjunction with the licensee and the NRC TLD 49 location network established in January 1981. Thirteen of the licensee's TLD sites and six 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 and 1986 annual reports met the requirements of the cooperative agreement.
- 12. Reports The 1985 and 1986 annual reports were submitted by the state within the time period specified in the cooperative agreement.
- 13. Exit Briefing At the conclusion of the appraisal on August 19, 1987, 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 meet the conditions of the cooperative agreement as outlined in paragraph 3. The state personnel agreed to review the NRC appraiser's findings and implement the necessary program improvements in order to comply with all aspects of the cooperative agreement.
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