ML20237H896
| ML20237H896 | |
| Person / Time | |
|---|---|
| Issue date: | 08/17/1987 |
| From: | Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20237H854 | List: |
| References | |
| CON-NRC-31-83-669 99990004-87-01, 99990004-87-1, NUDOCS 8709030424 | |
| Download: ML20237H896 (11) | |
Text
1 APPENDIX 4
U.S. NUCLEAR REGULATORY COMMISSION REGION IV Performance Appraisal for the NRC/ State of Louisiana Environmental Monitoring Cooperative Agreement NRC-31-83-669 Facility Name:
Louisiana Department of Environmental Quality Office of Air Quality and Nuclear Energy Appraisal At:
Baton Rouge, Louisiana l
Appraisal Conducted:
July 13-15, 1987 Appraisal Period:
January 1,1985, through December 31, 1986 Appraiser;
$4 FIy/pr
// Facilities Radiological Protection Section
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Approved:
/ f[ 46 k)///dM/d
[/7[h Blaine Murrsy, Chief, Facilities Radiological cate' Protection Sect # n l
Appraisal Summary Appraisal Conducted on July 13-15, 1987 (Report 99990004/87-01) l Areas Appraised:
Routine, announced performance appraisal of the state's adherence to the requirements of the cooperative agreement including:
i 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 and the timely submittal of the annual report.
Several deficiencies were identified and are discussed in paragraph 3.
Based on the state's commitments to improve the performance of the laboratory, it is recommended that the cooperative agreement be continued.
8709030424 070901 IE GA999 ESCLA 99990004 PT 1
. DETAILS 1.
Persons Contacted Louisiana Department of Environmental Quality
- M. A. Madden, Secretary, Department of Environmental Quality (DEQ)
- G. Von Bodungen, Assistant Secretary, Office of Air Quality and Neclear Energy
- W. H. Spell, Administrator, Nuclear Energy Division (NED) l
- J. M. Schlenker, Radiation Protection Laboratory Specialist
- Denotes those present during the exit briefing on July 15, 1987.
2.
General The purpose of this appraisal was to evaluate the state of Louisiana's compliance with the cooperative agreement conditions and to review correctiv9 actions on the deficiencies reported in the performance appraisal conducted August 5-8, 1985.
The appraisal effort was devoted to reviewing the 1985 and 1986 environmental monitoring programs concerning I
the Waterford-3 Station (WFS) and River Bend Station (RBS).
The Thermo Luminescent Dosimeter (TLD) and environmental sampling programs around WFS were initiated in 1983 and the RBS TLD program was started in. April 1984 followed by the implementation of the environmental sampling program in January 1985.
3.
Summary and Conclusions The state's effort, since the nrevious appraisal conducted August 1985, has shown some improvement; however, several deficiencies still exist.
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These inciude:
a.
Written procedures have not been completed and approved for:
sample collection and control, sample analysis, and laboratory counting instrumentation operation, calibration, and quality control.
See paragraph 9 for details.
b.
Gross beta data from RBS was reported as an average over the reported time period.
See paragraph 11.a.1(c) for details.
c.
Gamma isotopic analyses of quarterly composites of air particulate samples were not performed.
See paragraphs 11.a.1(d) and 11.a.2(b) for details.
d.
Surface water samples were not collected at RBS during the first quarter of 1985.
See paragraph 11.b.1(a) for details.
=
. e.
Monthly milk samples were not collected and split between the licensee and the state for several months.
See paragraph 11.c.1(a) for details.
f.
Monthly radiciodine analyses were not performed on several monthly milk samples.
See paragraph 11.c.2 for details.
g.
Fish samples were not collected and analyzed in 198:
See paragraphs 11.d.1 and 11.d.2 for details.
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h.
Shoreline sediment sample was not collected and analyzed in 1985.
See paragraph 11.f.2 for details.
i.
The 1985 and 1986 annual reports were not submitted as required by the cooperative agreement.
See paragraph 12 for details.
Even though several deficiencies still need to be corrected, it is recommended that the cooperative agreement be continued.
4.
Management Support The state no longer conducts a separate state environmental monitoring program around WFS and RBS that would be in addition to the samples and-analyses required by the cooperative agreement.
However, the state does collect and analyze several air and water samples in the vicinity of the Grand Gulf Nuclear Station not required by the cooperative agreement.
The state has not maintained an independent TLD monitoring network around the l
nuclear power stations in Louisiana since 1984.
The state's environmental monitoring program described by the cooperative agreement is conducted by the DEQ Office of Air Quality and Nuclear Energy.
The program is administered by qualified personnel who have experience in environmental monitoring.
The program appeared to be funded in 1985 and 1986 with adequate budgets to support and accomplish the sampling and analysis work j
load around WFS and RBS and to maintain radiochemistry laboratory j
equipment and supplies.
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i 5.
Organizational Structure i
i The NRC appraiser reviewed the state of Louisiana's DEQ, Office of Air Quality and Nuclear Energy, and NED staff assignments and responsibilities.
The organizational structure and reporting sequence were nearly the same as previously described in the NRC Appraisal Report i
99990004/84-28 conducted in October 1984.
The only change noted was that the NED had been reorganized and the cooperative agreement was now administered and conducted under the Inspection and Enforcement Section (I&ES). There had been three personnel changes in the management i
structure since the previous appraisal.
The following personnel assignments were made:
Martha A. Madden, Secretary, DEQ; Gustove Von Bodungen, Assistant Secretary, Office of Air Quality and Nuclear Energy; and Ronnie L. Wascom, Program Manager, I&ES.
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D
. 1 6.
Staffing The NRC appraiser reviewed staffing regarding personnel responsible for implementing the requirements of the cooperative agreement. There was one staff change in the NED laboratory since the previous appraisal conducted in August 1985.
As a result of the NED reorganization, S. A. Woods is no longer performing routine duties in the radiochemistry laboratory.
This leaves only two Radiation Protection Laboratory Spec #.alists working full time in the laboratory.
The NRC appraiser noted that the laboratory appeared to be understaffed to perform the requirec' sampling and analysis duties to manage the cooperative agreement and conduct the environmental monitoring programs around three nuclear power stations.
7.
Facilities and Equipment The NRC appraiser reviewed the NED radiochemistry laboratory facilities and equipment utilized in the performance of the cooperative agreement.
There have been no changes in the facilities since the previous appraisal.
The NED radiochemistry laboratory had added in the last 2 years a high purity germanium detector to the Canberra Series 90 multichannel analyzer system giving the system a total of four state-of-the-art detectors.
Also, the laboratory had purchased a Canberra 2400 alpha / beta / gamma automatic counting system, a Beckman Model 3801 Liquid Scintillation 4
system, and three new air samplers.
8.
Training i
I The NRC appraiser reviewed the offsite and on-the-job training received by the technical laboratory staff since the previous appraisal conducted in August 1945.
The NRC appraiser determined that the laboratory technician had received on-the-job training in sampling and analysis techniques.
No offsite training had been received.
This item was discussed at the exit briefing and the DEQ management stated that offsite training 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 pregress had been made in developing program procedures since the previour, appraisal.
The existirg procedures were not written in a standard laboratory format which should include a title page indicating procedure title, author, procedure number, revision number, date of issuance, and authorizing approval for laboratory use.
This item was discussed at the exit briefing and the NRC appraiser indicated that formal documentation of the radiochemistry laboratory program is still lacking.
The DEQ management stated that efforts would be made to develop required procedures using the NED word processing system to assist the technical staff in preparing and updating procedures.
. 10.
Quality Assurance Program The NRC appraiser reviewed the state's quality control program in conjunction with the laboratory counting instruments.
The I&ES has not I
written procedures to document the instrumentation quality control l
program.
Performance checks are performed on the counting instruments i
routinely, but the results are not officially recorded.
The laboratory was not using quality control charts to determine and trend instrument I
performance.
The state participates in the Environmental Protection l
Agency cross-check program.
The state's performance during 1985 and 1986 was reviewed and found acceptable.
l 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, 1986, to determine agreement with Attachment 1 to the cooperative agreement.
The two utility licensees, Louisiana Power and Light and Gulf States Utilities, conduct their own environmental monitoring programs in cooperation with the state.
State personnel performed routine environmental sampling and sample splitting with each of the licensees as required by the cooperative agreement.
State personnel performed all sample preparations and analyses of their samples in the NED I
radiochemistry laboratory.
State personnel exchanged the TLDs associated i
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 state had not submitted the 1986 annual reports for the two nuclear power stations at the time of the appraisal; however, the following cooperative agreement sampling areas were examined and the various deficiencies noted.
I a.
Airborne - Particulate and Radiciodine The cooperative agreement requires two continuous air samplers at each nuclear power station:
one air sampler in close proximity to l
the licensee's air sampler in the highest calculated X/Q area from j
the plant and another air sampler at a control location in close 1
proximity to the licensee's air sampler.
The cooperative agreement l
requires continuous air sampling with airborne particulate and radiciodine samples weekly at two locations for each nuclear power station 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 131I following each cartridge change.
Airborne particulate and radiciodine samples were collected weekly by state personnel at the four sample locations.
Gross beta, gamma isotopic, and 1311 analyses were performed at the required frequencies in the NED radiochemistry laboratory by state personnel.
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l The results reported by the state in the 1985 annual reports for the two licensees met most of the specific requirements of the I
cooperative agreement; however, the NRC appraiser noted the following deficiencies:
1 (1) River Bend Station 1
(a) The River Bend Energy Center air sampling station (API) was not operational until the end of June 1985.
(b) The River Bend control air sampling station (AGS) located at the Gulf States Utilities Service Center in Zachary, Louisiana, was not operational until the end of September 1985.
(c) The licensee's gross beta data was reported as an average over the reported time period rather than on a weekly basis; therefore, a direct comparison of analytical results could not be made.
(d) The quarterly air particulate composite isotopic data were only reported for the third and fourth quarters of 1985 for station API and only for the fourth quarter of 1985 for station AGS because air samplers were not operational before third quarter, 1985.
(2) Waterford-3 (a) The Waterford-3 air sampling station (APG-01)-located at the secondary meteorological tower was not operational until July 1985.
(b) The quarterly air particulate composite isotopic data was not reported for the first and second quarters of 1985 for station APG-01 because the air sampler was not operational until July 1985.
i b.
Surface Water I
The cooperative agreement requires two surface water samples to be l
collected monthly at each nucleur power station:
one sample j
downstream of the plant in the immediate area of the plant discharge and another sample upstream of the plant at a control location.
The i
cooperative agreement requires a gamma isotopic analysis on a monthly frequency and a tritium analysis on a quarterly composite by location i
of the monthly samples.
The samples were collected and split between I
the state and the licensees monthly.
Gamma isotopic and tritium analyses were performed at the required frequencies in the NED l
radiochemistry laboratory by state personnel.
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. s The results reported 'ay'the state in the 1985 annual reports for the two licensees met most bl the specific requirements of the cooperative agreement; however, the NRC appraiser noted the following deficiencies:
i (1) River Bend (a) Surface water sample; were not collected for the first l
quarter of 1985.
Splitting of surface water samples was l
not implemented until April 1985; therefore, the state did not report any g6ma isotopic or tritiurt results for the i
first quarter of 1985.
(b) The licensee did not report 1311 results.
(2) Waterford-3 No deficiencies noted.
c.
Milk The cooperative agreement Inquires one monthly sample of an offsite dairy located in the highest X/Q location.
The cooperative agreement requires a gamma isotopic analysis and a specific 131I analysis on a monthly frequency.
The samples were collected and split between the state and the licensees monthly.
Gamma isotopic and radiciodine analyses were performed at the required frec,uencies in the NED radiochemistry laboratory by state personnel.
The results reported by the state in the 1985 annual reports for the two licensees met mostf of the specific requirements of the 3
cooperative agreement; however, the NRC appraiser noted the following deficiencies:
(1) River Bend (a) Samples web not split or analyzed by the state and licensee for the months of February, March, June, and July in 1985.
State representatives offered no explanation as to the missing samples.
(b) The state and licensee are currently not collecting and splitting milk samples at the River Bend Station since the McKowen Dairy has gone out-of-business.
1 (2) Waterford-3
(
State 131I data for the months of January, April, May, June, and July ist 1985 yre not included in the 1985 annual report.
State representatives offered no explanation as to the missing samples results.
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. 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 results reported by the state in the 1985 annual reports for the two licersees met, in part, the specific requirements of the cooperative agreement, however, the NRC appraiser noted the following l
deficiencies-(1) River Bend No #ish samples were collected and split with the lictisee during 1985.
State representatives offered no explanation as to the missed samples.
(2) Waterford-3 Two fish samples were collected and split between the state and th+ licensee, but they were not collected at the required se.1iannual time frequency.
e.
Food Products The cooperative agreement requires two samples to be split between the state and the licensee of principal food products grown near a point having the highest X/Q, or grown in an area irrigated by water into wh kh the plant discharge flows, or green leafy vegetables grown in a private garden or farm in the immediate area of the plant.
Gamma isotopic analysis including radioiodine of the edible portions is required.
The state and licensees collected and split the required food product samples.
The results reported in the 1985 annual reports for the two licensees met the specific requirements of tiie cooperative agreement.
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 intc which plant discharge flows.
The results reported by the state in the 1985 annual reports fo-the j
two licensees met, in part, the specific requirements of the l
comparative agreement; however, the NRC appraiser noted the following deficiencies:
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(1) River Bend No deficiencies noted.
(2) Waterford
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No sediment sample was collected and split between the state and the licensee during 1985.
State representatives offered no 1
explanation as to the missed sample.
g.
Direct Radiation Levels The NRC established in July 1982 a TLD network of 36 locations t.round the Waterford-3 Station site.
Thirteen of the licensee's TLD sites are collocated with the NRC.
The NRC established in March 1984 a TLD
]
network of 44 locations around the River Bend Station site.
The licensee has 14 ~iLD sites which are collocated with the NRC.
The state does not maintain a TLD network around either nuclear power station.
The cooperative agreement requires the state personnel to exchange i
the NRC TLDs quarterly and send them for analysis by NRC Region I personnel.
The results reporte.d in the 1985 annual reports fer the two licensees met the requirements of the cooperative agreement.
h.
Lower Limit of Detection (LLD)
The NRC appraiser reviewed the states LLDs reported in the 1985 annual reports for the two licensees.
The LLDs reported by the state met the requirements of the cooperative agreement.
I 12.
Reports 1
The cooperative agreement "equires an annual report of state analysis results with comparisons of duplicate or split sample analysis results by the licensee within 120 days af ter January 1 of each calendar year.
The j
1986 annual report for each of the two licensees had not been submitted to
{
the NRC Region IV office at the time of the appraisal.
Late submission of i
the annual reports has been an ongoing problem since the initial implementation of this cooperative agreement.
The following table illustrates that fact.
Licensee Year Due Date Received Date River Bend 1985 4/30/86 4/9/87 River Bend 1986 4/30/87 Not received by 7/15/87 Waterford-3 1984 4/30/85 10/20/85 Waterford-3 1985 4/30/86 10/28/86 Waterford-3 1986 4/30/87 Not received by 7/15/87 L
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This issue of late reports was discussed with state representatives during the exit briefing.
State personnel committed during the exit briefing to have the 1986 annual reports submitted to the NRC Region IV office by September 1, 1987.
13.
Exit Briefing At the conclusion of the appraisal on July 15, 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 5.
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.
The state representatives committed to submitting the 1986 annual reports to the NRC Region IV office by September 1,1987.
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