ML20246D980
| ML20246D980 | |
| Person / Time | |
|---|---|
| Issue date: | 06/29/1989 |
| From: | Holtzman R, House J, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20246D977 | List: |
| References | |
| REF-QA-99990003-890705 99990003-89-03, 99990003-89-3, NUDOCS 8907120057 | |
| Download: ML20246D980 (6) | |
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U. 'S : NUCLEAR REGULATORY COMMISSION REGIONLIII Performance Appraisal for the.NRC/ State of Ohio Environmental Monitoring Cooperative Agreement.
Report No. 9999-0003/89003 Cooperative Agreement No. NRC-30-646-Docket No. 9999-0003 Facility: . Bureau.of Environmental Health, and Ohio Department of Health Laboratories Appraisal: At: ' Columbus,: Ohio Appraisal Conducted: June 13-14, 1989 (Onsite)
June 20, 1989 (Telephone Conversation)
Appraisal Team Members: . Holt an ' $ d 9 -89, Date Az T.liouse d- A-T- 1ri Date
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' Approved By: -M. C.:Schumacher, Chief Radiological Controls and 6-4 /#9 Date --
Chemistry Section
, . Appraisal' Summary Ap3raisal Conducted on June 13 and 14, 1989 (Report No. 999-0003/89003(DRSS)
(I) 80721)).
- Areas Appraised: Adherence to the requirements of the cooperative agreement; organization structure and management support; technical staffing and training; facilities,' analytical equipment and counting instrumentation; sampling and' analytical procedures and laboratory performance;. quality assurance / quality control; data storage and assessment; reports (IP 80721).
Results: Since the previous; report in this area, the program has been expanded
.from monitoring of the environmental program of the Davis-Besse Nuclear Power Station to include that of the Perry Nuclear Power Plant in Perry, Ohio. The ]
Annual Report was last submitted to the NRC for 1986. The State's performance j
.related to this cooperative agreement was. satisfactory, although management's support for the program. appears to be somewhat weakened. Due to loss of L
personnel in the Program, the data have not been extensively assessed nor
-have the Annual Reports for both 1987 an 1988 been completed. The samples
-have been analyzed for these periods and the results have been stored in a computer. While some weaknesses were noted, the laboratory capabilities in radiochemical analysis appear to be satisfactory and improving.
8907120057 89o705 0 REG 3 QA999 ESGOH P 99990003
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DETAILS
, 1. ~ Persons' Contacted
-Ohio' Department of Health 2R. Suppes Director,l Bureau of Environmental Health (BEH)
-2,2D. Steva, Health Physicist II, Radiological. Health Program (RHP), BEH 2G. . Davidson,. Director, Ohio Department of Health Laboratories (0DHL) 1J... Green,. Supervisor, Environmental Chemistry, ODHL 1E. Clark, Supervisor, Radiochemistry Unit, ODHL 2N..Tidwell' ,.Analyst, ODHL 2C. Eddy, Quality Assurance Officer, OHDL' 2 Attended exit-interview on: June 14, 1989.
2 Telephone discussion held on June 20, 1989.
2.. General-(IP80721)
This appraisal was conducted to review the performance.by the. State of Ohio of the. environmental monitoring program under the NRC/ State of Ohio Cooperative l agreement (NRC-30-646). The State performs environmental monitoring and exchanges of the NRC TLDs in..the vicinities of the
, Davis-Besse Nuclear Power Station (DBNPS) and the Perry Nuclear Power Plant (PNPP). This program serves to compare and verify the results of the programs conducted by the two licensees.
This appraisal consisted 'of interviews with staff members of. the Ohio Department of Health (ODH) Bureau of Environmental Health and the ODH Laboratories in~ Columbus, Ohio. The review covered the period of January 1985 through June 1989.
- 3. Summary and Recommendations Based on its review, the appraisal team recommends continuation of the existing' cooperative agreement between the NRC and the State of Ohio.
This recommendation is contingent upon the State's submittal of Annual Reports for 1987 and 1988. Overall, while the State's performance has had
'some deficiencies; they have agreed to correct them.
Several improvements have been made since the previous Appraisal,
- including: expansion of the program to include the Perry Nuclear Power Plant; completion ~of the 1986 Annual Report; and development of a procedure to' analyze I-131 in milk at an LLD level of one pCi/ liter, as )
required by the Agreement and by the licensee monitoring programs.
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Several deficiencies were also noted, including: not implementing the ;
above I-131 analytical procedure; weaknesses in the QA/QC . program in the laboratory; and unresolved differences between the ODH results and those of the licensees. 1
- 4. Organization and Staffing While the organization is unchanged since the previous appraisal,3 management personnel change have been extensive. The Cooperative Agreement is administered by the Program Administrator of the Radiological Health Program (RHP) who reports to the Chief of the Bureau of Environmental Health (BEH) who, in turn, reports to the Director of the Department of Health. Because the Administrator position is vacant, R. Suppes, Chief of the BEH is presently the Acting Program Administrator. The environmental campling effort in the RHP is under the Environmental Surveillance Section (D. Steva) and the TLD exchange work is under the Radioactive Materials Inspection Program (B. Wilmoth).
Samples are collected by the Ottawa County Health Department in the vicinity of the DBNPS and by the Lake County Health Department for
'the PNPP. The samples are shipped to the ODH Laboratories for analysis.
For the ODH Laboratories, the Director reports to the Chief of the Bureau of Support Services. The analytical work is directed by the Supervisor, Radiochemistry, who reports to the Environmental Chemistry Supervisor.
The staff is knowledgeable about the work, and the technicians have done well, as shown by their tests with EPA performance samples. However, the technicians are presently hired only on a temporary basis, which may limit their proficiencies and limit laboratory improvements.
The RHP and laboratory personnel have good qualifications.
- 5. Management Support Management appears to be committed to continuing the program, although it has reduced the priority of this program relative to others in the BEH due to loss of personnel in the RHP, and the resulting additional workload of other activities, such as a survey of radon in houses and the monitoring of nuclear fuel facilities.
- 6. Ohio Annual Environmental Monitoring Reports Pursuant to the Cooperative Agreement, the ODH is required to submit an annual report within 120 days of the end of the calendar year (by May 1 of the following year). This report is to include a summary of the 1 Region III Appraisal Report No. 9999-0003/85-03(DRSS) 3 1
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J analytical results in comparison with those of the licensees (DBNPS and PNPP), sampling and analytical procedures, and evaluations of any '!
significant differences between the results of.the ODH and those of the plants. The report should also include explanations of all missing -l j
data, a description of the ODH results for the EPA crosscheck, and a table of ODH Laboratories' lower limits of detection (LLD). The report is to be distributed to State and Federal Agencies, as well as to the I licensees.
The team members reviewed the latest Annual Report (1986). It was i generally good and it appeared to fulfill the requirements of the '
Agreement for the 1986 period. The reviewers noted some suggestions for changes to be incorporated into future reports. The I-131 LLD for milk was still substantially greater than the 1 pCi/ liter requirement of the Agreement. The ODH representative was aware of this problem and noted that the laboratory has developed a procedure to increase the sensitivity by chemical separation. However, they are in the process of hiring the additional help needed to validate the method. The LLDs for tritium were in conformance with the Agreement, but somewhat higher (1200 pCi/ liter) than those of the licensees (330 pCi/ liter at DBHPS). Laboratory personnel noted that they were revising their procedure to reach the lower level. Further, the present. procedure uses only two ml af sample in a standard 22-ml LS vial compared to 10 mi samples that could be mixed with some scintillator. Such a replacement would not actually
. impact on thir operations, since the present scintillator must be replaced I a environmental safety reascos.
The reviewers noted that it is difficult to compare results between the laboratories with the split sample data because the results for plant contamination are almost always less than the LLDs. However, in some cases, such as with fish and milk, there is substantial K-40 activity in the samples, which can provide direct comparisons. Thus, in the DBNPS samples, the milk data show good agreements between the laboratories, but in the fish samples (p. 33, Annual Report), the ODH values were substantially lower by 20-40L The milk results show that the calibrations of the counting systems are similar, but the fish results indicate that the samples were treated dif ferently in the two laboratories, e.g. , one laboratory may let the samples dry more, or water added to the sample for homogenization may have been included in the sample weight. The ODH representatives are attempting to resolve this problem. Finally, it was noted that some unlikely nuclides were reported, some of which could have been from the licensee's plants (Annual Report, pp. 31, 35, 36 and 55).
These appear to be artifacts and were probably not actually present.
Careful and detailed assessments of the data would show that most of them were artifacts caused by statistical fluctuations in counter background peaks, slight shifts in the apparent energies of small peaks, and amplification of small peaks due to large radioactive decay corrections.
If they can not be eliminated as artifacts, a footnote should give an explanation of the significance.
One serious consideration is that the reports for 1987 and 1988 have not been completed, due to the changes in ODH priorities. However, the ODH has collected and analyzed the samples, and the data are stored in computer 4
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files _for processing. The results have not been assessed nor correlated with those of the licensee. -The Bureau of Environmental Health-representative stated that the^ reports would be completed and sent to
.the NRC. Region'III office.by October 1, 1989. They will do them. separately'
'and' submit them'to the Region as tney are completed. The submission of the 1987 and 1988 Annual-Reports to the NRC by the. committed time will-be-followed'under Open Item No. 9999-0003/89003-01.
- 7. Facilitie.s and Equipment
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The appraisal team visited the radiochemistry laboratory and counting room at the ODH Laboratories. The facilities are about the same as previously reported.2 The radiochemistry laboratory is well-equipped with adequate bench space.and a fume hood. A hood in an adjacent laboratory is used for evaporations, which is needed for the gross beta-analyses.
In the counting room, the Intrinsic Ge. detector has recently been replaced.
'It is in a lead shield and connected to the ND 66 analyzer. The gross alpha / gross beta. counting is done in a Tennelec Model 1500 Series II Automatic Low Background Alpha / Beta counter and the tritium counting
'is done in a Beckman Model LS-233 Liquid Scintillation Counter. The charcoal cartridges are counted on a shielded NaI(T1) counter. A new alpha spectrometer system in the laboratory is not yet operational.
The laboratory facilities appear to be adequate for the analyses required for this program.
- 8. Quality Assurance / Quality Control in the Laboratory The QA/QC program in the laboratory appears to be adequate. The laboratory.
is. certified by the EPA for environmental analyses, so that much of this program is mandated by EPA procedures. The. technicians are required to do various blind and other performance samples prior to and during the analysis of a set of samples. Periodically, they also analyze EPA interlaboratory samples with mixtures of nuclides. Control charts are.also maintained on performance check sources and backgrounds on some However, for of the counter ( sp)ch as the the Ge detectorssy tem,-the checks were made, and entered into the Tennelec alpha / beta counter.
instrument log, but not plotted. The check source charts had control limits of two standard deviations (SD) and the background charts a fixed limit, such as 0.1 count / min on the alpha counter. The sample tracking program appeared to be good.
The reviewers noted some concerns about QA/QC program in the counting room. These were mainly that the Ge detector had no control charts, and that the statistics of the charts (mean and SD values) were determined only infrequently. These appeared to be based on about 20 pieces of data taken at the beginning of the year. The statistics should be calculated l
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.at more frequent intervals,. such as monthly or quarterly, and the
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calculated parametersitested to note changes using statistical tests, such as-Student's t-test (for-'mean-values) and the variance ratio test-(F test) for variances-(SD2),
The reviewers also. suggested some possible changes in the procedures that might-improve efficiency of.the operations and accuracy'of.the results.
The. background charts should be setup in a manner similar to that of the
.' source check charts with a mean and SD-based control-limits. If the' background count _ rates-are stable (as shown.'by the control charts), this would reduce the number of. background. measurements needed,;give more accurate ~and precise background values, and consequently more accurate-and precise estimates of. net ~ counts. This would also result in lower LLDs. While this modification may not satisfy the EPA requirements of-equal sample and background counting times, it could be used for.other samples,.and the EPA might consider modifying'it. It was also suggested -
that the check. sources may have somewhat low-counting rates, so that the the control charts. reflect-mainly the statistical variability of the radioactive decay, rather than that of the instrument, i.e., the. check source should-have about 10,000 counts, so that the relative standard deviation of the radioactive decay is about 11L Presently the performance check results are entered on the' charts only weekly; to give a timely picture of instrument operation, the results should be entered at the time of measurement.
The QA/QC programs appeareto need some" development, but with the extensive checks on the analyses, they appear to ensure reasonable results.
- 9. . Exit Interview The appraisal team members discussed the scope and findings of the appraisal at the conclusion of the appraisal on June 14, 1989. Possible
, improvements in the upcoming Annual Reports were' discussed (Section 6).
ODH representatives stated that the 1987 and:1988 reports would be completed by October 1, 1989. In a subsequent telephone conversation a representative agreed to submit separate reports for each year and to submit the first when completed. The laboratory program appears to be satisfactory, but the team noted some deficiencies-in the QA/QC program and that the lack of continuity of employment of the technicians, as discussed in Sections 3 and 8. The laboratory director noted that they were, working on the technician problem.
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