ML20028G358
| ML20028G358 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 12/30/1982 |
| From: | Bidinger G, Crow W, Shum E NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20028G351 | List: |
| References | |
| NUDOCS 8302080477 | |
| Download: ML20028G358 (8) | |
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DEC 3 01982 Docket No.:
70-1113 Licensee:
General Electric Company Wilmington, North Carolina, Facility
Subject:
SAFETY EVALUATION REPORT, RENEWAL OF SNM-1097 FOR A ONE-YEAR PERIOD
Background
The renewal application for the Wilmington flanufacturing Department (WMD) facility at Wilmington, North Carolina, was subraitted on May 4,1981.
Significant revision of this application is needed. To provide GE with time to make revisions, the existing license is being amended to revise the expiration date and add certain environmental monitoring requirenents conditions of the license.
Discussion of Amendments Since the license was renewed in 1976, there have been twenty-seven amendments.
The disposition of these amendments in the renewed license is as follows:
Anendment No.1 (nitrate-bearing liquids disposal) was superseded by Amendment No. 6.
Amendment No. 2 (waste incineration) was superseded by Amendment No. 25.
Amendment No. 3 (deconmissioning) was superseded by Amendment No. 22.
Amendment No. 4 uill be included in the license as Items 6E, 7E and 8E.
The application dated March 3,1978 is referenced in Condition No. 9.
Amendment No. 5 (application dated May 4,1978) will be incorporated into the license as Item (e) of Condition No.10.
Anendment No. 6 will be incorporated into the license as a revised Condition No.16. The amendment which expired May 31, 1981, is being reinstated without an expiration date.
Araendment No. 7 (application dated April 18, 1977) will be included in the license by reference in Condition No. 9.
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2 Amendment No. 8 has been superseded by Amendment No. 24.
Anendment No. 9 has been superseded hy Anendment No. 22.
Amendment No.10 (application dated October 3,1979) will be incorporated into tha license hy reference in Condition No. 9.
Amendment Ho.11 (order to implement 40 CFR 190) will be included as Condition 18.
(Note that Amendment No. 14 modified Anendment Ho. 11.)
Amendment No.12 will be included in the license as Items 6F, 7F and 8F.
The application dated January 17, 1980, is referenced in Condition No. 9.
Amendment No.13 has been superseded by Amendment No. 22.
Amendment No.14 (which modified Amendment No.11) will be included in Condition No.18.
Amendment No.15 (application dated June 11,1980) will be included in Condition No.10 (a) and referenced in Condition Ho. 9.
Amendment No.16 (application dated Decenber 16,1980) will be included by reference in Condition No. 9.
Amendment No.17 (application dated December 30,1930) will be included by reference in Condition No. 9.
Anendment No.18 (application dated April 3,1981) will be included as Items 6G, 7G and 8G, and by reference in Condition No. 9.
Anendment No.19 was rescinded by Amendment No. 21.
Amendment No. 20 (application dated June 18,1981) will be incorporated into Item 8.C and referenced in Condition No. 9.
Amendment No. 21 (application dated December 21, 1979 and supplements dated Hovember 17, 1980, and June 1,1981) authorized operation of the GECO conversion lines in Building D.
This amendment, as modified hy Amendment No. 25, will be included as new Condition No. 20.
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3 Amendment No. 22 will be included in the license as Condition No.19.
Amendment No. 23 was superseded by Amendment No. 24 Anendment flo. 24 will be included in the license as revised Condition No.13.
Amendment No. 25 (application dated December 27, 1979, and supplements dated December 4,1981, March 8,1981, and March 30,1981) authorized incineration.
The anendment will be included in the renewed license as Condition No. 17.
Anendment No. 26 (application dated July 8,1982) authorized disposal of 800,000 gallons of uraniw1-bearing zirconium sludge.
The anendment will be included in the renewed license as Condition No. 24.
Anendment No. 27 (application dated September 1,1981, and supplenent dated August 13,1982) authorized use of neutron absorber systems.
The anendment will be included in the renewed license as Condition No 25.
Discussion of Other Changes in License Conditions License Condition No.12 has been reworded to reflect changes in Part 20 on use of respiratory protection devices.
License Condition No.14 has been revised to incorporate a new Annex, dated July 1982.
License Conditions 21-23 have been added to include requirements for er vironmental nonitoring. Justification for these conditions follow.
EVALUATION OF GE'S EFFLUElli AND ENVIRONMENTAL HONITORING PROGRAM OF GE'S FUEL FABRICATION PLANT, WILHINGTON, NORTH CAROLINA I.
Background
On December 21, 1979, GE submitted a license amendment application for the expansion of plant conversion capacity. The submittal contained an effluent and environmental monitoring progran covering radiological and non-radiological paraneters.
On September 1,1981 GE submitted a revised effluent and environmental monitoring program.
In this revised progran, GE deleted the following items:
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1.
All the non-radiological parameters previously specified in the December 21, 1979 submittal.
2.
Monitoring wells No. WT-1, WT-2, WT-3, WT-4, WT-8 and WT-9 around the waste treatment lagoon.
3.
Monitoring wells No. PL-2, PL-4, PL-6, PL-7, PL-9, PL-10, PL-11 and PL-12 around the final discharge lagoons.
4.
All four wells around the calcium fluoride filter cake storage area.
5.
All six wells around the zirconium sludge area.
6.
All four wells around the sanitary treatment facility.
7.
Some of the surface water nonitoring stations.
II. Discussion Re Iten 1, GE stated that the nnn-radiological monitoring progran is conducted in accordance with State and EPA permit requirements. The staff is particularly concerned about potential leakage in the lagoon and waste storage areas.. The detection of non-radiological constituents, such as nitrate and fluoride, in groundwater is essential since it would provide HRC with an early warning of any substantial leakage in these storage areas; thereafter, remedial action should be taken immediately before it results in an adverse impact to the envirorunent.
The NRC staff has coordinated with the State and by letter from the State to GE, dated October 22, 1982, the State has assumed the responsi-bility and had imposed a groundwater conitoring program on GE under the State's authority in the NPDES permit.
In regard to the stack monitoring of fluoride, the NRC staff has reservations en the use of Whatman #41 filter paper impregnated with calcium carbonate to collect total fluoride, e.g., UO F and HF which is a corrosive gas. During the collection perio$ $f one week, the integrity and the efficiency of the filter paper may deteriorate.
The stack monitoring data from GE indicate that the release rate of total fluoride is about 20 gm per day. Based on our experience with fluoride releases in similar facilities this number is substantially lower than other fu21 fabrication plants.
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5 The staff has to use a valid source term to assess the environmental impact from the release of fluoride on GE's next license renewal action. Based on GE's lett?r to NRC, dated Decenber 27, 1979, it was estimated in Table 1 ' hat maximum air emission quantities of NH F 4
from the proposed incinerator operation alone would be 120 lbs/nr.
Although GE is not incinerating this type of naterial at the present time, monitoring of stack effluent is necessary if future operation covers this type of materials.
In addition, discussion with GE staff indicated that there may be other sources of fluoride releases from SE operations not related to GE's SNH license activity. Under the NEPA Act, the NRC staff has to evaluate the cumulative impact to the environment from the total fluoride releaset from other nearby activities.
Therefore, the staff recommends that GE conduct a study on the environ-mental inpact associated with the release of fluorides from the GE operations. The data obtained will be reviewed by the State and NRC to determine if further action is necessary. The data must be submitted along with other environmental infnrmation with GE's-next license renewal application. We believe that an adequate environmental monitoring program should include stack nonitoring, anblent air and vegetation monitoring.
In Item 2, the staff finds no justification for GE to delete the wells which are already installed around the lagoon areas.
In addition, some of these wells were found to have high nitrate and uranium concentrations in past and current nonitoring data. This indicates that these wells are in strategic locations for detection of seepage. Therefore, except for well WT-8, which was destroyed, all the existing monitoring wells around the lagoons should be included.
According to GE (letter to NRC dated March 31,1982), the results of the contaminated wells were returring to normal; however, recent results have shown increased concentration. An effort is underway by GE to deteraine if this is an anomaly or if there is a new source.
Therefore the staff is concerned that the past groundwater contamination in the wells may have destroyed their effectiveness for detection of new leakage and GE should consider the installation of a double liner and leak detection system in the lagoons to eliminate thf s problem.
GE should also continue to monitor other existing wells and use available on-site hydrogeologic data to evaluate the potential environ-mental impact resulting from past lagoon leaks. The assessnent should provide an estimate of the quantities of nitrates and radionuclides.
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which have escaped from the lagoons, the poter*.ial environnental impact, particularly on the nearby GE's potable water supply wells located along the direction of the contaninated plume and the remedial action to be taken (if eny) fron past leakages.
In addition, there may be Tc-99 (a beta enitter) present in the lagoon liquid waste because of the use of recycled uranium in the enrichnent facilities, and it is required that isotopic analysis shall be performed to identify the major beta enittireg nuclides if the gross beta concentration in the well water exceeds 50 pCi/1.
It Iten 3, the staff has evaluated the past manitoring data and found that rione of these wells had been contaminated in ti.e past.
Consultation with the State indicated that the use of PL wells #1, 3, 5, 8 and 11 should be adeqt, ate to detect leakage.
In Items 4 and 5, the staff also finds no justification for GE to I
delete all the radiological monitoring on wells which are already l
installed and monitored around the waste storage areas. However, GE included radiological as well as non-radiological monitoring under the State's groundwater monitoring requirement. Since this is an area of common interest, the NRC staf f requires that GE shall include the monitoring of these wells with groundwater colla Con on 'a l
quarterly basis and analysis for gross cipha and.. with action levels as specified in the licensee's letter dated September 1,198i.
In Item 6, discussion with the State indicated that potential contamination with radionuclides in groundwater from the waste treatment facility is remote and no monitoring is required.
In Item 7, the staff finds that donitoring of surface water by collecting grab samples of water upstream and downstream of the GE facility is adequate because the expected concentration of radionuclides is low and the radiation dose through this Tiquid pathway is insignificant.
The licensee is continuously nonitoring the liquid release points to surface water to determine the quantity of uranium nuclides released.
L However, because of the possibility of Tc-99 being present in the liquid wastes, the staff requires GE to include semi-annual analysis of composite samples for Tc-99 in the liquid discharges from the chenical lagoons.
For other minor modifications of the licensee's revised program, the staff requires that the licensee improve their detection limit of gross-alpha and gross-beta in water samples to 5 pC1/1 and 20 pCi/1, respectively, since the staff expects that the background levels on omcc>
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7 gross alpha and beta la groundwater would be much lower than GE's proposed detection linit of 30 pC1/1 and 50 pC1/1 for gross alpha and gross beta respectively. This is also consistent with GE's proposed action level for 3 tines background on gross alpha in groundwater; otherwise the action levels for ground 4ater would be 90 90 pC1/1 for gross alpha. The staff considers this concentration too high because if the ground water is contaminated to such level, a largn amount of
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non-radiological chemicals would have leached out from the lagoors and a large amount of subsurface soil could be contaminated or saturated with radionuclides.
III. Conclusion The staff has evaluated GE's effluent and environmental monitoring programs. Pised on the above discussion and operation with the State, the staff proposes the following conditions for effluent and environmental monitoring for renewal of GE's license:
21.
The licensee shall conduct an effluent and environmental radiological monitoring program as sprcified in the licensee's letter dated September 1,1981, with the following modifications:
The detection 11 shall be 5 x 10 git of gross alpha in well water samples a.
p Ci/ml (5 pC1/l), or lower.
If tha-concentration of water exceeds 15 pC1/1, isotopic analysis shall be performed at least once to identify the major alpha emicting nuclides.
be 2 x 10~fon limit of gross beta in well water samples shall b.
The detect y C1/ml (20 pCi/1), or lower.
If the concentration of water exceeds 50 pCi/1, isotopic analysis shall be performed at least onc. to identify the major beta emitting nuclides. -
c.
Water samples from all of the existing monitoring wells around the waste treatment facility,(Wil,WT2,WT3,WT4, WTS, WT6, WT7 and WT9) as identified in Exhibit 4 of the licensee's letter dated Itarch.31,1982, shall be sampled monthly and analyzed for gross alpha and gross beta, with action levels as specified for WT wells in the licensee's letter dated Septenttr 1, 1981.
r d.
Water samples from the monitoring wells arou3d the final discharge lagoons (PL1, PL3, PLS, PL8 and PL11), as identified in Exhibit 4 of the licensee's letter dated March 31, 1982, shall be sanfled quarterly and analyzed for gross alpha and gross beta with action level as specified for PL wells in the licensee's letter dated September 1,1981.
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e.
Water samples from the four wells around the calcium fluoride filter cake area and the six wells around the zirconiun sludge area, as identified in Exhibit 4 of the licensee's letter dated March 3?,, 1982, shall be collected from these wells on a quarterly basis and analyzed for gross alpha and gross beta, with action level as specified in the licensee's letter dated September 1, 1981.
- 22. The licensee shall include semi-annual analyses of composite sanples for Tc-99 in the liquid discharges from chemic.I'lagoo,'s as identified in item (2), Figure 3 of the licensee's letter dated September 1, 1981.
23.
The licensee shall notify the 141C Regional Administrator within 10 days of any violation of the NPDES permit.
Oricinaz Cicnna by q*0 80 LI. BidID8cI-G. H. Bidinger Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS
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C. Y. Sbwn E. Y. Shum Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and origina1 cicned by:
Material Safety. H!iSS W. T. Crow Approved by:
W. T. Crow, Section Leader
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