ML19345D125

IE Insp Rept 70-1257/80-07 on 800812-15.No Noncompliance Noted.Major Areas Inspected:Licensee Use of Lagoons for Storage & Evaporation of Liquid Process Wastes,Lagoon Monitoring & Possible Environ Impact

ML19345D125
Person / Time
Site:	Framatome ANP Richland
Issue date:	10/14/1980
From:	Book H, Cooley W, Thomas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML19345D122	List: ML19345D121 ML19345D125
References
70-1257-80-07, 70-1257-80-7, NUDOCS 8012090143
Download: ML19345D125 (12)

Text

(3 U. S. ;UCLEAR REGULATORY CC:OtISSIO 1 0FFICE OF I :SFECTIO!! A!!D E:iFORCEME!;T REGION V Report ::o. 70-1257/30-07 I

Docket !!o. 70-1257 License No.

SilM-1227 Safeguards Group Licensee:

Exxon fluclear Company 2101 Horn Rapid Road Richland, UA 99352 FacilityTame:

Richland Facility Inspection at:

Richland, Washington Inspection conducted:

August 12-15, 1980 Inspectors:

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Luoley, hidi rac1,(1Lles inspector Date Signea il Date Signeo

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Approved by:

ii. u., incmas, Cgief, Materials Radiological Protection ' Da(c S igned

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Section Approved 2y:

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rid H. E. Book, Chief, Fuel Facility and fiaterials Safety Ddte Signed Branch S u==a ry :

Inspection on August 12-15,1980 (Report flo. 70-1257/80-OH Areas Inspected:

Licensee's use of the lagoons for the storage and evaporation of liquid process wastes; lagoon monitoring and possible environmental impact; organization; internal review and audit; safety committee activities; employee training; operations review; and radiation protection. The inspection involved 25-inspector hours onsite by one flRC inspector.

Resul ts :

flo items of noncompliance or deviations were identified within the scope of this inspection.

I RV Form 219 (2) 8012090 g

l DETAILS 1.

Persons Contacted

• D. L. Cornell, Panager, Manufacturing

• H. P. Estey, t'anacer, Licensing and Compliance, Operating Facilities

• C. O. Brown, Senior Licensing Engineer R. H. Schutt, formerly Specialist, Criticality Safety

• D. E. Clark, Senior Engineering Assistant

• T. C. Probasco, Engineer, tuclear and Industrial Safety R. L. Miles, Supervisor, Radiological Safety

• E. L. Foster, Technical Specialist, Radiological Safety R. A. Schneider, Senior Specialist, Special fluclear Safeguards

• E. R. Herz, Engineer, Special fluclear Safeguards L. E. Hansen, Senior Specialist, Criticality Safety and Physical Security

• Denotes those attending the exit interview.

2.

Lacoon Liouid Storace and Evaooration Systen Figure 1 attached to this report identifies four existing chemical storage lagoons, their orientation, and 13 test wells used to monitor those lagoons for leaks. That figure also indicates the location of two additional proposed test wells and the ground water elevation in the vicinity of the lagcons.

The dates given in parentheses indicate the first use of each test well which corresponds with the first use of the nearby lagoons.

The ground water elevation indicates that the direction of flow of ground water is to the north past Test Uell 9 from where it is presumed to turn to the % th east.

The proposed additional test wells in the north east corner of Figure 1 are to further determine the ground water direction as well as monitor any plures in the ground water originating from the lagoons. Test Well 8 has been used as a background sampling station.

Another well has been four.d on the Exxon property by the licensee located approximately 1/2 mile west of the lagoons. That well will be used in the future as a background sampling station.

The general ground water flcu in this area is to the south east toward the Columbia River as determined by the Pacific ?!orthwest Laboratories studies.

The specific ground water flow to the north and then east at the Exxon lagoons appears to be a local anomaly.

The depth of the Exxon wells is approximately 25 feet.

The bases of the lagoons are about 6 to 8 feet above the ground water level.

Drinking water for the City of Richland is obtained from the Columbia River at a point approximately four miles to the south east of the Exxon site.

Auxiliary drinking water is sometimes supplied to the city from wells located approximately five miles due south of the Exxon facility.

Ground water flow rate in the vicinity has been estimated at by Pacific florthwest Laboratories at 15 feet per day. This rate has been questioned by Exxon in view of the anomalous direction of flow of ground water at its site.

a e

3.

History of the Storace and Evanoration Lanoon Usaae J

The licensee placed lagoons 1 and 2 into service at the beginning of operations approximately October,1971. At that time Test Wells 1, 2, 3 and 4 were used to monitor for leaks in lagoons 1 and 2.

Lagoons 1 and 2 were lined with petromat.(a composition-type of material) and covered with asphalt.

The licensee established a test well monitoring program in which he monitored the wells for nitrate, fluoride, sulfate, and uranium.

Lagoon leak action guides were established and presented at page I-5.15 (among other places) of the license application.

Within a short time of the beginning of operations *(July 1973) fluoride ion i

was detected at about twenty ppm in Well fiumber 2.

It did not appear in Wells 1, 3, and 4.

At the same time nitrate ion appeared in Wells 1 and 2 at concentrations ranging from 50 to 300 ppm. The nitrate ion did not appear statistically significant in Wells 3 and 4 at that time.

Sulfate ion appeared in Well fiumber 2. in July 1973 at a concentration of about 700 ppm.

The sulfate ion did not appear statistically significant in Wells 1, 3 and 4 at that time.

flo uranium concentration in excess of 0.1 ppm was found in any of the well samples.

The levels of ionic content discovered in the wells indicated a leak in lagoon number 1 and were'of such a magnitude as to require an investigation on the part of the licensee. The matter came to the attention of IIRC Region V in August 1973 (flRC report flumber 70-1257/73-04). The matter had been reported to the State of Washington, Department of Ecology by the licensee at that time. Lagoon flumber 1 had been drained into lagoon llumber 2; inspected for lining defects; and patched and resurfaced by the licensee by August 16, 1973.

The ion levels in the wells designated above remained at about the same level and perhaps decreased a little as operations went into the Spring of 1975.

a f!RC Inspection Report 70-1257/75-03 dated April, 1975 notes that residual ionic content was still detectable but decreasing.

It notes that in February 1975 Well flumber 4 indicated a spike of sulfate ion.

In the interim the licensee maintained the lagoons in the investigative mode attempting to account for the source of ions in the wells; checking the accuracy of analytical work; and attempting to better define the direction s

j of ground water flow..The matter was complicated in that high sulfate i

concentrations observed in Wells f! umber 1, 2 and 4 could be accounted for l

by the fact that an underground stainless' steel transfer pipe which carried uncontaninateri sulphuric acid had developed a leak. That event occurred in the Spring of 1975.

flevertheless, the licensee continued to detect elevated i

ion concentrations in those three wells and began planning on again refurbishing the north lagoon (flRC Inspection Report flo. 70-1257/76-04).

flRC Inspection Report 70-1257/76-07 relates that nitrate and sulfate ion concentrations in Wells 1 and 2 were again becoming more elevated.

Additionally the licensee measured liquid level drop rates in lagoon i

numbers 1 and 2'which indicated a possible leak in lagoon number 1.

The licensee was at that time preparing to inspect and refurbish both lagoons 1 and 2.

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_3 f!RC report 70-1257/77-04 relates that the licensee had emptied lagoon number 1 and found no leaks at its bottom although nany small leaks were found and repaired along the slopes of the lagcen. Underground chemical pipe leaks were found and repaired which leaks could have accounted for the high nitrate and high fluoride ions observed in the nonitoring wells around the lagoons.

Those wells continued to indicate less than 0.1 ppm uranien in all samples obtained. The services of Pacific f orthwest Laboratories were obtained to help in the evaluation of the situation and to obtain and analyze w;11 samples for uranion at sensitivities in the ppb range and also to determine the enrichment of any uraniun found at those levels.

Ground water samples indicated parts per billion of uranien of average enrichment 2.0%.

flRC Reoort fiumber 70-1257/77-06 relates that a comorehensive study of test well productivity, ground uater gradient, well loca' tion, and relative value of stagnant versus dynamic well sampling had been conducted by the licensee in cooperation with Pacific florthwest Laboratories.

That study resulted in plans to reolace certain wells and to drill additional wells for monitoring purposes.

(October 1977) flRC Inspection Report flo. 70-1257/78-01 indicates that iagoon number 1 had been surveyed and leaks were found in the lagoon liner and the lagoon relined.

The licensee at this tire had determined that he would completely reline lacoons numoer 1, 2 and 3.

Lagoon number 3 had been placed in operation about August 1974.

flRC Report fiumber 70-1257/79-06 indicates that the licensee was continuing refurbishing and expanding the chemical liquid waste lagoor.s.

Lagoon number 4 was beinq constructed at the time.

Lagoon number 1 had been drained and a double lining of Hyperlon had been placed in that lagoon.

A layer of sand had been placed between the the Hyperion liners and a sampling system of polyvinyl chloride tubing had been placed in the sand layer to permit sampling for leakage.

The licensee had drilled approximately 10 cores in the base of lagoon number 1 to determine the uranium content in the base of the lagoon due to leakage.

The licensee planned on similar double lining and leak samping systems for all four lagoons.

The licensee planned on providing 13 test wells around the lagoons and believed that he now knew the ground water flow direction.

Those wells and lagoons were planned for ccmpletion in 1979 and the information on the attached figure 1 is current to the end of 1979.

flRC Inspection Peport flumber 70-1257/80-04 indicates that the analysis of the core drillings at the base of lagoon number 1 indicated the possibility that 70 kilograms of low enriched uranium had been embedded in the base of that lagoon. A similar but less quantitative analysis of the soil under the lagoon number 3 indicated that about 540 kilograms of low enriched uranium nay have become embedded in the base of lagoon number 3.

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4-Pacific florthwest Laboratories analytical work for uranium in well water on the Exxon site indicated parts per billion of uranium of approximately 2 percent enrichment. A question arises as to why the uranium appears to be held up in the soil whereas the anions proceed through readily.

An Exxon representative theorizes that a calcium compound named Caliche underlies the Columbia Valley floor and that it readily exchanges its calcium for any available uranium. During the drilling of the proposed wells indicated in the flortheast corner of Figure 1, search will be made for the Caliche layer.

4.

Present Status of the Chemical Waste Lagoon System The licensee is presently operating four chemical waste lagoons as identified in the attached Figure 1.

All four of those lagoons have been furnished with a double layer of Hyper 1on. The two layers of Hyperlon are separated by four inches of sand.

Embedded within the four inches of sand in each of the four lagoons is a liquid detection system which is connected to a manifold system and can be samoled by pumping.

Those leak detection systems provide for the detection of leaks in the upper of the two Hyperlon

'iners.

La;oons numbers 1 and 3 are additionaly equipped with leak detection probes located underneath the lower of the two Hyperlon layers.

They are also available for sampling to determine leakage of the lower Hyperlon layer. The licensee has evaluated that second system and believes it is of limited value in determining leakage of the lower Hyperlon layer because the leakage prober may be easily sealed off from their surroundings due to the weight of Hyperion liner and water lying above it.

In the construction of lagoon number 4 the licensee sloped that lagoon to the north and provided three drains running to east to west and terminating in dryuells at the edge of the lagoon.

That drainage system is intended to provide leak testing of the bottom Hyperlon liner.

At the time of this inspection pumping on the leak detection system of lagoon 2 indicated the possibility of continuing leakage or the pumping of residual liquids from previous leaks. The licensee is evaluating that situation.

The lagoon system is presently monitored by 13 test wells with two oroposed additional test wells presently being drilled.

Throughout the test well analytical work uranium concentrations never exceeded 0.1 parts per million. The fluoride, nitrate and sulfate ions were found with certainty only in test wells numbers 1, 2 and 9 although some evidence of leakage was found in lagoon number 3, also. That circumstance leads the license to infer that the ground water flow is sharply to the north at the site of the lagoons so that test wells 3 through 7 have not been affected.

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l Since the najor effort in relining the lagoons began in early 1978 there has been a steady decrease in the ionic content detected in wells number 1, 2 and 9.

The fluoride concentration is presently indicated as about 15 parts per nillion (above the investigation level). The nitrate ion is presently indicated at about 200 parts per million (above the investigation level).

The sulfate ion concentration is presently indicated at about 200 parts per million (below the investication level).

Additional details of liquid chenical waste stortae lacoon system experience has been presented by the licensee in his document Jft-14 Add.4 Anolicant's Environmental Pecort Uranium 0xide Fuel Plant Expansion (Phase 3) dated August 1977 and in his document Jii-14 Add. 6 Applicant's Environmental Report dated April 1979.

5.

Oroanization R. H. Schutt. Criticaly Specialist, transferred to the fleutronic Engineering Section at Exxon. His reolacement has been approvea. The licensee is naking more use of the facilities of Pacific !!orthwest Laboratories for both first and second party reviews of criticality analytical work.

6.

Internal Review and Audit This inspection included a review of radiation safety audits conducted fron January through July,1980.

During that time 12 audits were performed.

Special reviews were included along with the routine audits.

Special reviews included studies made of the frequency of respiratory protective eauipment use; environmental surveillance; sources of airborne activity; and caseous effluents with respect to the limit of 50 nicrocuries activity release per quarter.

Routine audits and reviews noted the existence of visible contamination in the UO-2 building, improper use of protective clothing and inproper location of a personnel survey instrument. Action on recentendations was acccmplished either at the time of the review or as the result of correspondence with facilities management.

7.

Safety Conmittee Activity This inspection included a review of the minutes of the licensee's Health and Safety Council meetings conducted between April and July 1980.

Subjects considered by the Council included possible adverse effects of volcanic ash fallout and resulted in a prelininary action plan for ash fallout.

Other subjects included planning for video tace training sessions in the areas of enrichnent control and radiation safety.

8.

Employee Traininn Employee traininq is furnished by personnel of the Radiological Safety and l'anufacturing Operations groups.

Shortly after hiring new employees are given formal instruction in radiation and criticality safety.

Lecture outlines are available and are used as handouts.

Approximately five hours of lecture time is devoted to that phase of training.

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A continual program of retraining is conducted by Operations Management according to a predetermined schedule.

General information and industrial safety is addressed monthly to operations employees. The subjects of safeguards accountability, enrichment control, criticality safety, radiological safety, emergency procedures and contaminatan control are addressed at quarterly meetings with manufacturing personnel. Those latter sessions extend to about I hour of discussion time.

Records of new-hire training are maintained in Auxiliary Operations personnel redical and dosimetry files. Those records include the subjects covered, films or film strips presented, training aids used, and handout materials used. They include date of training, length of meeting, signature of trainee and instructors name.

Similar records of Manufacturing Operations training sessions are maintained in the Manufacturing Department. Those records similarly, include the name of instructor, date of instruction, specific subject covered, and name and signature of attendees.

Copies of the Manufacturing Onerations training session records are furnished to Radiological Safety for incorporation in the employees medical and dosimetry files.

Radiology Safety retains those duplicates although only those sessions on criticality safety; radiological safety and emergency procedures are folded into the medical and dosimetry file. Records on sessions other than those are maintained in separate files.

A review of Manufacturing Operations training sessions for the period April through July,1980 indicated that approximately 40 training sessions had been conducted and that the aid of personnel from Auxiliary Operations had been furnished in several of those sessions.

9.

Radiation protection This inspection included a review of the results of the licensee's uranium urine bioassay and uranium in vivo results for the year 1979 and for the period January 1980 through the date of this inspection.

A maximum uranium urine bicassay result for 1979 was 215 ug/l which occurred approximately July 1, 1979.

A resampling on July 6,1979 indicated less than 10 ug/1, the limit of sensitivity of the measurement. The maximum uranium urine bicassay result for the year 1980 was 113 ug/l which occurred in January 31, 1980 and had decayed to less than 10 ug/l by February 1,1980.

The individual who had indicated the 113 ug/l result was subsequently sampled on 16 occasions through July 29, 1980. On 13 of those occasions the urine bicassay results was less than the licensee actions level of 25 ug/1.

On three occasions the result was in excess of 25 microgram per liter to a maxinum of 101 ug/1.

The review of in vivo counting results for the year 1979 indicated that approximately 276 persons were lung counted and that the results of those lung counts were recorded for each individual according to the area in which he worked. The maximum individual positive result was 92 microgram uranium 235.

In the year 1980 to date the licensee had acquired 128 in vivo counts on 123 persons. Thirty-three positive results were experienced in that group and the maximum lung burden indicated was 97 micrograms uranium-235.

10.

Fixed Air Samoler Relocation Study The licensee plans the relocation of a number of fixed air samplers in the U0-2 manufacturing plant.

Many, if not most of these samplers are presently located at the point of highest airborne concentration experienced rather that at the breathing zone of the acerator. The puroose of the relocation study is to determine the breathing zone area to be sampled and to relocate and to add fixed air stations as made be required to sample the breathing zone.

At the time of this inspection the licensee had completed a eview of air sample locations in the U0-2 plant.

He had categorized those fixed stations as Equipment (those measuring maximum concentrations developed by station equipment), Representative (those sample stations representative of the-breathing zone concentration of employees), and Background (those measuring the general background in operating areas).

Additionally, the licensee had identified those sampling stations which were to be relocated or recositioned.

The study had resulted in the discontinuance as well as the addition of some fixed air samole stations.

A result of the study was an increase of approximately 12 new samoling locations.

The licensee's plans are to discuss the location cnanges with operations personnel; arrange for the physical relocation; obtain air samples and experience witn the new system; and extend the study to other Exxon facilities at Richland.

11. Manacement Interview The scope and results of this inspection were discussed with licensee representatives at the conclusion of the inspection on August 15, 1980. Those persons were informed that no items of noncompliance with flRC requirements were observed within the scope of the inspection.

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