ML20138H458

Performance Appraisal Insp Rept 99990004/85-09 on 851015-16. Overall Performance Satisfies Agreement Requirements.Minor Deficiencies Noted.Major Areas Inspected:Adherence to Requirements of Cooperative Agreement

ML20138H458
Person / Time
Issue date:	12/02/1985
From:	Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20138H443	List: ML20138H437 ML20138H458
References
99990004-85-09, 99990004-85-9, NUDOCS 8512170199
Download: ML20138H458 (10)

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t APPENDIX ,

U.S.NUCLEARREGULATORYCOMMISSION REGION IV l Performance Appraisal for the'NRC/ State of Kansas Environmental Monitoring Cooperative Agreement NRC-31-84-502 Facility Name: Kansas Department of Health and Environment (KDHE)

App'raisal At: Topeka, Kansas Appraisal Conducted: October 15-16, 1985 Appraisal Period: July 1 through December 31, 1984 n/t/ps' Appraiser: _ Blair Nicholas! Senior Radiation Specialist Dafe-Facilities Radiological- Protection Section l

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Blaine'Murray, Chief,facilitiesRadiological Date Protection Section Appraisal S'ummary' Appraisal Conducted on October 15-16 1985 (Report: 99990004/85-09)

Areas' Appraised: ' Adherence to the' requirements of the cooperative agreement including: organization and management support, sample collection and analytical procedures,. facilities, instrumentation, staffing and qualifications, quality assurance program, and followup corrective actions taken on previously identified deficiencies. The appraisal involved 15 appraiser-hours by one NRC. appraiser.

Results: The' state's overall performance satisfies the general requirements of the cooperative' agreement regarding sample collection and analyses. Several

. minor deficiencies are-discussed-in paragraph 3. Based on the state's performance, it is recommended that the cooperative agreement be continued.

8512170199 851211 IE GA999 ES9KS 99990004 PDR

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2 DETAILS

1. Persons Contacted KDHE'

• C. V.- Hamm, Special Assistant to the Secretary, KDHE

• D. J. Romano, Manager, Bureau of Air Quality and Radiation Control

• R. Carlson, Director, Laboratory Services and Research '

S. T. Masih, Radiation Contro1' Inspector

• H. L. Spiker, Chief, Surveillance and Emergency Planning Section D. To, Chief, Radiation Chemistry Laboratory Others-

• B. Murray, Ch'ief, Facilities Radiological Protection Section, U.S.N.R.C.,

Region IV-

• Denotes those present'during'the exit b'riefi~ng on October 16, 1985.

2 .- General The purpose of this appraisal was to e. valuate the State of Kansas' compliance with the cooperative agreement conditions and review corrective actions on the deficiencies reported in the initial appraisal conducted August 8-9, 1983.

-3. Summary and Conclusion The state's effort,-since the previous appraisal conducted in August 1983, has shown significant improvement; however,'several deficiencies still exist. .These include:

a. Procedures have been written, but not approved by management, for use in the field 'and in the radiochemistry laboratory. See paragraph 9.

for details.

Lb. Counting geometries and/or calibration standards for the air particulate filter quarterly composite, soil, vegetation / food products,_and fish need to be improved. See paragraph 10 for details.

c. Gross beta analyses of weekly air particulate filters were performed at different decayLtimes'than the licensee causing problems in comparing data. 'See paragraph'11.a(2) for details.

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Ld. Gamma. isotopic analyses of-quarterly composites of air particulate samples were not performed. See paragraph 11.a(3) for details,

e. The lower limits of detection (LLD) for 2 2 2I in milk were not met.

See paragraph 11.c(3) for details.

f. :The state's and licensee's LLDs were not included in the 1984 annual report. Seeparagraphs11.a(4),11.b,11.c(2),1}.d,and11.h.

Even.though several minor deficiencies still need to be corrected, it is recommended that the cooperative agre'ement be continued.

4. Management Support

'The state has 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 Bureau of Air Quality and Radiation Control, Division of Environment', with assistance from Laboratory Services and Research. 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 was funded in 1984 with a workable budget to. support and accomplish the

-present workload and to maintain present laboratory equipment and supplies.

5. Organizational Structure The NRC appraiser reviewed the state of Kansas' Department of Health and Environment, Division of Environment, and Bureau of Air Quality and Radiation Control staff assignments and responsibilities. The organizational structure and reporting sequence are the same as reported in the-NRC Appraisal Report 99990004/83-03 conducted in August 1983 with one, exception, the Chief, Radiation. Chemistry now reports directly to the

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Director, Laboratory Services and Research.- There had been two personnel changes in the muagemt:nt structure since the previous appraisal. These changes were S. V. Bhatia to assume the responsibilities.of Director, Division of Environment on October 18, 1985, and David J. Romano becoming the Manager,: Bureau of Air Quality and Radiation Control.

6. Staffing The NRC appraiser reviewed the. staff responsible for the requirements of

-the cooperative agreement. There.were two staff changes in the

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Surveillance and Emergency Planning Section (S&EPS) since the previous appraisal in August 1983. These changes involved the addition of C. A. Schwartz, Radiation-Control Inspector, and A. E. Smith,

. Environmental Technician,.to the S&EPS.

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-7. Training, The NRC appraise,r reviewed the offsite and on-the-job training received by the-technical: staff since the previous appraisal conducted in August 1983.

The NRC appraiser? determined that H. Cogliergin had completed the

.._ . " Radiochemistry Course for State Regulatory Personnel". offered by the NRC at the Radiologica'l and Environmental' Sciences Laboratory (RESL), in Idaho' Falls,' Idaho, and S. T. Masih had completed the 5 week basic

' radiological health course at Oak Ridge Associated Universities,

.0ak Ridge,. Tennessee.

The NRC' appraiser not'ed that staff training is conducted on-the-job as

. required. Training records.are not maintained that would indicate that supervision.had' reviewed and accepted employee proficiency for specific.

sampling and analytical _ tasks. The NRC appra.iser recommended that the two radiation control inspectors and environmental technician be scheduled to take the radiochemistry course at RESL, Idaho Falls, Idaho, as.soon as it becomes_'available again.

8 .~ . Facilities'and Equipment The NRC appraiser reviewed the S&EPS and radiochemistry laboratory equipment and facilities. There had been no changes in the laboratory

-facilities. The NRC' appraiser noted that the S&EPS had purchased three-new low volume environmental air samplers bringing the air sampler inventory to nine air samplers which service six air sampling locations.

The_NRC appraiser also noted that the gross beta counting system was over 10 years ~old and experiencing variations in.the quality control data causing'it to be out-of-specification limits.on numerous occasions. :The

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, chief of. radiation chemistry had requested in the 1984 budget funding for a new gross alpha / beta cou.nting system but the request had been denied.

.This equipment upgrade was discussed in the exit-' briefing and the Director, Laboratory Services and Research, . informed the NRC appraiser

'that a state-of-the-art gross' alpha / beta counting system will be given

. highest priority:when_ funding equipment procurement'in the next fiscal year budget.

- 9 .- Procedures The NRC appraiser reviewed the state's progress in developing environmental monitoring program procedures for sample collection and control,. sample preparation,. sample analysis, calibration and quality control of analytical counting instrumentation, and preparation methods for radioactive calibration standards to determine the adequacy and status ofjapproved procedures.

The NRC appraiser noted'that good progress was being made in the area of

. procedure development. -The S&EPS had written sampling procedures for all

5 environmental media and had established a'section procedure manual. The radiation chemistry ~ laboratory had written a laboratory procedures manual which provides instructions' for conducting radiochemistry laboratory activities. However, it was noted that the procedures reviewed were not written-in a format which included for each procedure a title page indicating title,_ author, procedure number, revision number, date of issuance, and authorizing approval for laboratory use. The technical staff . express'ed their desire for improving the program and will continue efforts to deve. lop procedure improvements as time permits.

10. Quality Assurance Program The NRC appraiser reviewed the state's quality control program in conjunction with the laboratory counting instruments. The state participates in the Environmental Protection Agency (EPA) cross ~-check program. The state's performance during.1984 was reviewed and found acceptable within the EPA acceptance criteria.

The state's radiochemistry laboratory also performs an internal quality control program. This program consists mainly of performance checks and calibrations of the counting instruments. The laboratory staff also perform periodic analyses on spiked blind samples. The NRC appraiser reviewed the quality control data and calibration data for the radiochemistry laboratory counting instruments over the appraisal period which had been performed with radioactive standards traceable to the National Bureau.of Standards. The laboratory was developing computer software to document the quality control program. It appeared that the state was performing adequate quality control tests to verify the performance of the radioanalytical counting instruments. However, the review of calibration data for the Nuclear. Data gamma spectroscopy sys W .

indicated that an air particulate filter composite standard for 12-13-filters had not been' prepared for'the quarterly composite require-ment, the small soil standard of 75 grams in a petri dish was not large enough to meet sample isotopic LLD requirements, the small vegetation / food products standard of 50 grams in a petri dish was not large enough to meet sample ~ isotopic LLD requirements, and no fish geometry calibration standard had been prepared. These standards must be prepared to specifications which will meet the LLD and analysis requirements of the cooperative agreement. The Nuclear Data system must be recalibrated using properly prepared standards to meet the cooperative agreement requirements as soon as possible and before the analysis of any 1985 samples.

11. Cooperative Agreement Required Sample Collection and Analyses The NRC appraiser reviewed the sample collection and analyses for the period July.1:through December 31, 1984, to determine agreement with Attachment I to the cooperative agreement. The licensee, Kansas Gas and Electric Company, by contract with an independent laboratory, conducts its

6 own environmental monitoring program. State personnel. performed all sample preparations and analyses in the. state radiochemis'try' laboratory.

The state's TLDs were also processed by state personnel. State personnel exchanged the TLDs associated with the NRC TLD monitoring network and sent them for processing of direct radiation measurements which were performed by NRC Region I personnel.

The following cooperative agreement. sampling areas were evaluated and several observations and deficiencies were noted:

a. Airborne - Particulate and Radioiodine The cooperative agreement required two continuous air samplers: one sampler in'close proximity to the licensee's sampler in a high calculated X/Q direction and one at a control. location in close proximity to the_ licensee's sampler. .The state and licensee have air

. samplers located about 2.8 miles north of the plant in the community of Sharpe, Kansas. The state's and licensee's control sample station is located about 15 miles west-northwest of the plant in the town of Hartford, Kansas.

Airborne particulate and radioiodine samples were collected weekly by the state at its two sample locations. Gross beta, gamma isotopic, and I-131 analyses were performed in the state radiochemistry laboratory by state personnel.

The results reported by the state in the-1984 annual report met most of.the specific requirements of the cooperative agreement; however, the NRC appraiser noted the following observations and deficiencies:

(1) The state and licensee gross beta results should be expressed in the same units and format to facilitate comparison.of data.

(2) The state's' gross beta results were consistently at least a

= factor of 10 greater than the licensee's gross beta results.

This may be due to the fact that the state analyzes their samples after 29 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br /> of decay from time of sampling while the licensee's contractor may allow greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of decay.

between sampling and analysis. The difference in activities may be due to lack of decay of natural occurring radioactivity deposited on the particulate filters. An experiment performed

in the state-laboratory of gross beta analysis of a p' articulate filter after 29 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br /> of decay and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of decay after sampling verified the observed difference in gross beta results.

The state is taking corrective action to analyze the air particulate samples allowing the same sample decay time as the licensee's contractor.

7 (3) The state performed gamma isotopic analyses on monthly composites of air particulate filters rather than quarterly composites as required by the cooperative agreement. Therefore, the state's data .is not directly comparable ~to the licensee's data representing quarterly composites. This item is being corrected in the state laboratory.

(4) The gamma isotopic and radi6 iodine results were reported to be

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below detection limits; however, no LLD limits were included in the report for either the state or licensee.

b. Surface Water The cooperative agreement required two surface water samples to be collected monthly: one from an immediate area of plant discharge and one from an upstream control location. These samples were to be split with the licensee for analysis. A gamma isotopic analysis was required on a monthly frequency and a tritium analysis on a quarterly composite by location of the monthly samples. The state and licensee collected monthly samples from the lake into which the plant discharge flows and from an upstream control location at the John.Redmond reservoir. The samples were split between the state and the licensee. The gamma isotopic and tritium analyses were performed in the state radiochemistry laboratory by state personnel.

The results reported by the state in the 1984 annual report met the specific requirements of the cooperative agreement. The gamma isotopic results were reported to be below detection limits; however, no LLD limits were included in the report for either the state or licensee. The monthly sample dates should be recorded in the report.

c. Milk The cooperative agreement required one monthly sample of an offsite dairy located in the highest X/Q direction from the plant. This sample location had been determined to be at the Redding Dairy which was located about 5 miles northeast of the plant. The state and licensee collected duplicate monthly samples. The gamma isotopic and low level radioiodine analyses were performed in the state radiochemistry laboratory by state personnel.

The results reported by the state in the 1984 annus' report met, in part, the specific requirements of the cooperative agreement; however, the NRC appraiser noted the following observations and deficiencies:

(1) The monthly sample dates were not recorded in the report.

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'(2) The gamma isotopic and radioiodine results were reported to be

~below detection limits; however, no LLD limits were included in the' report.for either the state or licensee.

_(3) :The NRC appraiser noted.that.the state radiochemistry laboratory had used.a gamma scan of 2.0 liters of sample for the radioiodine analysis. The.LLD for radioiodine in milk using

-this method and an eight hour counting time is reported as 5.pCi/ liter in the " Radiation Laboratory Procedure Manual" which does not meet the criteria of.'1.0 pCi/ liter as specified in Attachment 2 of the cooperative agreement. It is required by the cooperative ag~reem.ent that the state use a wet chemistry analysis for radiciodine in milk which meets the LLD requirement.

The NRC. appraiser determined the Redding Dairy had gone out of business in June.1985 and. milk samples were no longer being obtained

-from that location. Possible alternate sampling locations were discussed with the state and licensee. It was decided that due to the scarcity of milk producing animals in the vicinity of the plant

'that the state.would start collecting monthly samples from the licensee's control location.

d. Fish

.The~ cooperative agreement required one sample of a commercially or i recreationally important species in the vicinity of the plant discharge semiannually or in season. Gamma isotopic analysis of the edible portions was required. The licensee collected semiannual fish samples from the lake into which the plant discharge flows. Fish

'from the catch were split between the licensee and the state for analysis. The gamma isotopic analysis.was performed in the state radiochemistry laboratory.by state personnel .

'The results reported by the state in the 1984 annual report met the specific requirements of the cooperative agreeme'nt. The gamma isotopic results were reported to be below detection limits; however, .

no LLD limits were included in the report for either the state or licensee.

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e. -Food Products The cooperative agreement required two samples at the time of harvest to be 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 plant discharges waste, or green leafy vegetables at-a private garden or' farm in the immediate area of the plant. . Gamma isotopic' analysis of the edible portions was required. The sample location had been determined to be at the Hermon resident garden which was located about Ifmile . north of the plant. The state and licensee collected and split samples from the garden at the time of

. harvest. The gamma isotopic analysis was performed in the state radiochemistry laboratory by state personnel . The results reported in.the 1984 annual report met the requirements of the cooperative

. agreement,

f. ~ Sediment from Shoreline The cooperative agreement required o'ne annual sample split with the licensee fcr gamma isotopic ~ analysis of shoreline sediment along-a body'of water into which plant discharge flows. The state and licensee collected a duplicate sample from the Wolf Creek discharge cove about 0.5 miles. northwest of the plant. The gamma isotopic analysis was performed in the state radiochemistry laboratory by .

state-personnel. The results of the analysis were omitted from the 1984 annual report but were supplied to the NRC appraiser for review'

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during the appraisal. The results of the analysis met the requirements of the cooperative agreement and were reported to be below detection limits. The state will be providing the NRC with the missing data as soon as possible in a supplementary report in accordance with the reporting requirements of the cooperative agreement.

g. Direct Radiation Levels The state has established a TLD direct radiation monitoring network-of 21 locations ~ around the. Wolf Creek Generating Station site in

' conjunction with'the licensee and the NRC TLD 47 location network established in September 1983. Six of the licensee's TLD sites and twelve of the state's TLD sites are colocated with the NRC. The cooperative agreement required the state personnel to exchange.the NRC TLDs quarterly and send them for analysis by NRC Region I personnel. The results reported in the 1984 annual report met the requirements of the cooperative agreement.

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h. .LLD The NRC appraiser requested that future reports include an LLD table for each sample media and sample analysis reported for both the state's results and the licensee's results. Inclusion of these

-tables in future reports will. assist in determining compliance with the cooperative agreement.

12. Reports The 1984. annual report was submitted by the state to the NRC Region IV office within the time period specified in the cooperative agreement.

13. Exit Briefing At the. conclusion of the~ appraisal on October 16, 1985, the NRC appraiser discussed the scope and findings of the appraisal with the individuals denoted in paragraph 1. The NRC. appraiser expressed concern regarding those items which did not meet the conditions of the coo' perative agreement as outlined in paragraph 3 of this report.

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