ML20055A042
| ML20055A042 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 06/17/1982 |
| From: | Cunningham A, Montgomery D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20055A036 | List: |
| References | |
| 70-1113-82-06, 70-1113-82-6, NUDOCS 8207150420 | |
| Download: ML20055A042 (10) | |
Text
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'o UNITED STATES
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8' NUCLEAR REGULATORY COMMISSIGN n
.E REGION 11 o
101 MARIETTA ST., N W., SUITE 3100 ATLANTA, GEORGI A 30303
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Report tio. 70-1113/82-06 Licensee:
General Electric Company P. O. Box 780 Wilmington, IJC 28402
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Facility flame: Wilmington Manufacturing Division Docket tio. 70-1113 License rio. Stim-1097 Inspection at Wilmingt,o,44crth Carolina Inspector:
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A. L. Cunningham 7
' Dats Signed Accompanying Personnel:
E. Y. Shum (March 10-11,1982)
Approved by:
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- 0. M. Mont'gomery, Se t on Chief Bate Signed Division of Emergenc Preparedness and Operational Support
SUMMARY
Inspection on March 10-11 and April 26, 1982 Areas inspected This special, unannounced inspection involved 27 inspector-hours on site in the area of ground water environmental monitoring including:
review of sampling and analysis data compiled by licensee; collection of ground water samples for confirmatory analyses; review of licensee contractor reports.
Results Of the three areas inspected, no violations or deviations were identified.
8207150420 820618 PDR ADOCK 07001113 C
________a
REPORT DETAILS 1.
Persons Contacted Licensee Employees
- W. J. Hendry, Manager, Regulatory Compliance
- C. M. Vaughan, Acting Manager, Licensing and Compliance Audits
- W. B. Smalley, Engineer, Environmental Protection D. Narine, Engineer, Environmental Protection
- E. A. Lees, Manager, Quality Assurance
- B. F. Bently, Manager, Fuel Chemistry Operation
- P. E. Younghans, Manager, Materials Operation
- G. W. McKenzic, for J. Harmon, Manager Manufacturing Technology and Engineering Operations
- J. Bergman, Manager Fuel Manufacturing
- Attended exit interview on April 26, 1982
- Attended exit interviews on March 11 and April 26, 1982 2.
Exit Interview The inspection scope was summarized on March 11 and April 26, 1982, with those persons indicated in paragraph 1 above. The inspector informed licensee representatives that ground water samples collected by the NRC would be submitted for the following analyses, viz.:
total nitrate, fluoride, gross alpha, and isotopic uranium (where so indicated by gross alpha analysis).
The inspector also informed licensee representatives that results of the above cited analyses would be summarized in the inspection report.
3.
Licensee Action on Previous Inspection Findings Within the scope of this inspection, no previous inspection findings were outstanding.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Purpose Inspection was conducted in response to the NRC concerns regarding possible intrusion and migration of radioactive and associated non-radioactive contaminants into ground water sources (IE Inspection Report No.
70-1113/80-20). Accordingly, ground water samples were taken from selected (nsite monitoring wells for confirmatory analyses of nitrate, fluoride and isotopic uranium.
2 6.
Site Inspection a.
Inspection included the following items:
(1) a detailed site tour confirming general site topography and the location of monitoring and supply wells with reference to the waste treatment and final process lagoons, and process waste storage areas, viz., zirconium sludge and calcium fluoride; (2) review of ground water data and analytical summaries compiled by the licensee during calendar years 1972 through 1981, and the period January 1 through March 11, 1982, regarding groundwater nitrate, fluoride and uranium concentrations in wells monitoring the above cited waste treatment facilities and storage areas; (3) selection and sampling of monitoring wells, based upon licensee data summaries for wells which indicated either periodic or consistent nitrate concentrations substantially in excess of the assigned drinking water limit of 44.3 parts per million (40 CFR 141.11.b); (4) review of licensee contractor reports regarding site hydrogeology and the impact of process wastes on identified ground water sources during calendar years 1978 through 1981.
b.
The inspector conducted a detailed review of ground water monitoring and chemical analytical data compiled by the licensee during the period, January,1972 through March 11, 1982, to provide the following:
(1) an overview of the extent and frequency of radioactive and asso-ciated nonradioactive chemical contamination of onsite ground water sources traceable to process waste treatment and storage; (2) a basis for selection of ground water samples by the NRC for confirmatory measurements of nitrate, fluoride and uranium contaminants.
The licensee provided annual summaries of sampling and analytical data for all ground water monitoring wells, with the exception of the MW series wells which monitor the three ground water sources within the areas of the waste treatment lagoons, zirconium sludge storage, and sewerage treatement plant.
The latter data and contractor reports were made available to the inspector during the followup inspection conducted on April 26,1982.
Review of the findings are summarized below.
(1) Zirconium sludge storage monitoring wells ZB, ZC and ZE consis-tently indicated high nitrate concentrations durir.g the period 1978 through 1982 (e.g., maximum values of 5200 ppm (9/6/79), 1990 ppm (4/18/79), and 2095 ppm (2/9/82), respectively, were recorded). During the above period, uranium concentrations were consistently recorded at or below 0.01 mg/1.
Similarly, fluoride concentrations were low throughout the subject period. The inspector collected two aliquots each (500 ml and 1.0 liter) from monitoring wells ZC and ZE.
Well ZB was dry and Well ZB-2 yielded less than 75 ml.
(2) Waste treatment wells (WT series wells monitor the waste treatment facility including the primary nitrate lagoons) WT-1 and WT-4 consistently indicated mean annual nitrate concentrations in excess of 44.3 ppm during the period 1972 through 1981.
In the case of WT-1, a maximum nitrate concentration of 1495 ppm was recorded in 1973 with a corresponding annual average of 280 ppm.
i
A 3
In the case of monitoring well WT-4, an annual average nitrate concentration of 397 ppm was recorded in 1978.
In 1981, the annual average nitrate concentrations for the above wells were 82 ppm and 119 ppm respectively. Waste treatment well WT-7 indicated elevated nitrate during the period 1973 through 1979, exhibiting a maximum value of 1900 ppm with a corresponding annual average value of 837 ppm for 1973. Waste treatement monitoring wells WT-2 and WT-9 indicated periodic excursions above the assigned 44.3 ppm nitrate limit during calendar years 1974 through 1978. The inspector obtained two aliquots each (500 ml and 1.0 liter) from waste treatment wells WT-1, WT-2, WT-3, WT-4, WT-7, and WT-9 for analysis.
(3) Review of monitoring and analytical data compiled by the licensee on final process lagoons monitoring wells (PL series wells) disclosed no nitrate concentrations in excess of the assigned limit during the period 1973 through 1981. These were not sampled.
(4) Since neither monitoring nor analytical data compiled by the licensee on the MW series wells was made available to the inspector during the initial inspection (March 10-11,1982),
ground water samples were collected from monitoring wells MW-2A, B and C, MW-3A, B and C, and MW-4A, B and C based upon the proximity of the wells to the general areas of the waste treatment facility and zirconium sludge storage. As discussed above, the MW series wells monitor the three groundwater sources, including the deep aquifer, within the area surrounding the waste treatment lagoons and the zirconium sludge storage area.
It should be noted that the licensee also extracted water samples from all wells selected and sampled by NRC as cited above.
It should be further empha-sized that all wells were sampled concurrently by NRC and GE.
Such sampling should neither be considered nor confused with accepted state-of-the-art split sampling.
7.
Preparation and Analysis of Ground Water Samples a.
All samples collected by NRC for nitrate analysis (500 ml aliquots) were fixed with concentrated sulphuric acid at a concentration of one i
milliliter per liter of sample. The samples were maintained at an average temperature of 6 C and submitted to the EPA Regional Research Laboratory in Athens, Georgia, for nitrate and fluoride analyses. The one liter aliquot ground water samples were forwarded to the Department of Energy Radiological and Environmental Sciences Laboratory, Idaho Falls, Idaho, for gross alpha analysis and selective gamma isotopic analyses based upon the indicated level of gross alpha activity.
b.
Nitrate analysis of NRC samples was conducted by EPA employing the copper-cadmium (Cu-Cd) reduction method (EPA Method 353.2). Nitrate analyses were reported as nitrate-nitrogen; however, as shown in Table 1, the reported results were converted to total nitrate. The
4 licensee used the Brucine analytical method for nitrate analysis of well water samples and reported the results as total nitrate, also shown in Table 1.
Analyses of the following parameters were also included:
fluoride, gross alpha, total and isotopic uranium (U-238, U-235,U-234/233).
In addition to the analyses cited above, the licensee included ammonia and pH. The parameters of immediate interest are listed in Tables 1 and 2, and include fluoride, nitrate, gross alpha, gross beta, total and isotopic uranium.
c.
The analytical data summarized in Table 1 for total nitrate in WT series wells sampled on March 11, 1982, show no elevated values (i.e.,
no values in excess of the previously referenced maximum contaminant level of 44.3 ppm).
The fluoride content of all samples summarized is consistently low, i.e. significantly less than the 10 ppm limit assigned by the licensee. Table 1 discloses that nitrates in ground water sampled from wells ZC and ZE by NRC are elevated and appear to be consistent with analytical data compiled by the licensee during the period 1980 through February 9,1982.
Licensee results for samples taken on March 11, 1982, show high nitrate in Well ZE only.
In view of the sampling method previously discussed, it is difficult to assess the large disparity between the two sets of data for well ZC; however the results generally support evidence of continued local intrusion of nitrates into ground water from the zirconium sludge storage area.
d.
Table 2 summarizes the radiological analyses conducted by NRC and the licensee on ground water samples collected March 11, 1982. The only gross alpha activity and corresponding isotopic analyses indicating evidence of intrusion and retention of uranium in localized ground water zones was disclosed for waste treatment well WT-1.
The well is located north of the waste treatment facility and lies within the zone between the subject facility and the waste treatment lagoon complex.
8.
Inspection Findings a.
Review of ground water sampling and analytical data compiled by the licensee during the period January 1,1972 through February 9,1982, and review of analyses of samples collected by NRC and the licensee en March 11, 1982, regarding intrusion of process wastes into site ground water sources disclosed the findings detailed below.
(1) The waste treatment wells are located around the waste treatment facility including the waste treatment lagoons. Waste treatment well WT-1 (located in zone between waste treatment building and waste treatment lagoons) consistently showed average annual nitrate concentrations in excess of the assigned maximum contam-inant level during cale:idar years 1972 through 1981. Wells WT-2 and WT-7 (located east and north, respectively of the waste treatment lagoons) showed annual average nitrate concentrations above the assigned limit during calendar years 1973 through 1978, while wells WT-3, W-5 and WT-8 (located SE, NE and SW, respec-tively, of the waste treatment lagoons) showed no excursions l
[
5 above the assigned limit during calendar years 1972 throuth 1981.
It was noted, however, that well WT-8 was destroyed in 1978 and was supplemented by Well ZE of another series but located within the same general area. Well ZE indicated no nitrate concen-trations in excess of the limit during 1979 and 1980. Wells WT-4 and WT-6 (located NW and north, respectively, of the waste treatment lagoons) exhibited annual average nitrate concentrations in excess of the assigned limit during calendar years 1978 through 1981 in the case of WT-4, and 1973, 1974 and 1976 in the case of WT-6.
Well WT-9 (located S-SE of the subject lagoons and east of the zirconium sludge storage area) exhibited annual average concen-trations exceeding the assigned maximum level during 1974 through 1978. None of the WT-Series well sampled on March 11, 1982 indi-cated excursions above the referenced maximum contaminant level for nitrate. During calendar years 1972 through 1981, the subject series consistently showed uranium concentrations less than 0.01 ppm; however, analyses of ground water sampled from WT-1 on March 11, 1982, indicated intrusion and retention of uranium as j
shown in Table 2.
(2) MW-Series Wells which monitor ground waters (including perched water stratum, shallow and deep aquifers) within the areas surrounding the waste treatement process lagoons and zirconium sludge storage exhibited nitrate concentrations significantly l
below the maximum contaminant level of 44.3 ppm (40 CFR 141.11.b).
l Similarly, inspection also disclosed that both site supply and j
observation wells sampled during the period January 1,1972 through February 9, 1982 were within the assigned nitrate con-taminant level referenced above. Ground water uranium concen-trations for the well series were within the 0.01 to 0.02 ppm range during the referenced period.
Fluoride concentrations for the subject series, during the same period, were below the licensee assigned limit of 10 ppm.
(3) Z-Series wells surround the zirconium sludge storage area which is located south-southwest of the waste treatment lagoons.
Review of licensee annual ground water sampling and analysis data compiled during 1978 through 1981, and analysis of samples collected on February 9, 1982, disclosed that in the case of well ZC, (located north-northeast of the storage area) of 39 groundwater samples collected, 30 exhibited nitrate concentrations in excess of the maximum contaminant level. The highest nitrate concentration of 1990 ppm was recorded April 18, 1979. All ZC samples collected in 1980 (with the exception of three samples), exceeded the limit, with concentrations ranging from 108 ppm to 610 ppm. All ZC samples collected during 1981, and February 9,1982 (with the exception of one sample) exceeded the limit, and showed concen-trations ranging frcm 350 ppm to 1320 ppm.
Nitrate analyses of Well ZC samples collected on March 11, 1982, by the licensee and NRC were reported as 12 ppm and 514 ppm, respectively, as shown in Table 1.
Well ZE demonstrated a trend consistent with the elevated nitrate concentrations cited for well ZC.
Nitrate analysis of ZE sample collected on February 9, 1982 was reported l
]
6 as 2095 ppm. Nitrate analyses of ground samples from Well ZE on 1
March 11, 1982 were reported as 824 ppm by the licensee and 567 ppm by NRC, as shown in the previously referenced Table. Samples taken from Well ZB (located north-northwest of the storage area) consistently exhibited nitrate concentrations in excess of the t
referenced maximum contaminant level for nitrates.
During the period February 5,1979 through May 6,1980, a maximum nitrate concentration of 5200 ppm was recorded on September 6, 1979. The subject well remained essentially dry during the period June 2, i
1980 through December 8, 1981. The remaining Z-series wells (viz., ZD, ZF, ZG) exhibited ground water nitrate concentrations l
below the the assigned maximum contaminant level during their j
entire sampling history (July 6,1978 through February 9,1982).
l All Z-series well samples exhibited less than 0.01 ppm uranium during the referenced sampling period.
Similarly, all Z-series well samples exhibited fluoride concentrations below the licensee 1
assigned limit of 10 ppm during the subject sampling period.
i (4)
Intrusion of process wastes into ground water appears to be i
confined to the specific onsite locations discussed above; viz.,
sectors of the zirconium sludge storage area immediately south of the waste treatment lagoons (wells ZB, ZC, ZE) in the case of nitrates, and intrusion and retention of uranium within the localized ground water zone monitored by waste treatement well WT-1.
(5)
Inspection included a review the licensee's hydrogeological consultant's (Law Engineering Testing Company (LETC0) Marietta, Georgia) project reports published during the period March 3, 1978 3
through February 4,1982. The consultant conducted basic studies and related projects identifying onsite ground water sources and i
j conditions, location and placement of monitering wells, and impact assessment of process waste intrusion on ground water quality.
The consultant's report dated January 7,1982, for Project No.
MH-9326.5, provided an overview of site ground water conditions l
and apparent trends regarding nitrate intrusion into such water.
The significant discussions and findings summarized in the report are listed below.
Details regarding onsite hydrogeological characteristics are not included in the summary given herein.
i (a) Elevated nitrate concentration in WT-Series wells during 1972 and early 1975 appear to be consistent with process waste transfer line and primary nitrate lagoon liner leakage known to have occurred during the subject time period.
(b) Trend toward decreased nitrate concentration in WT-Series wells was noted during 1976, with the exception of well WT-1.
4 As stated in the report, WT-1 had the highest groundwater elevation in the vicinity of the process lagoons, and changes between long term trends in the WT series could not be explained on the basis of existing data compiled.
It was postulated that changes between trends could relate to any of the following:
(1) anistropic properties of the shallow i
l 7
aquifer within the subject area; (2) localized sources of nitrate from past leakage; (3) weil construction and/or depth.
(c) Nitrate concentrations in Z-Series wells fluctuate to greater extremes than those in WT-series. Upward trends in Z wells nitrate concentration indicate an active form of leakage.
(d) Short term fluctuation in WT series wells appear to be related to heavy rainfall.
(e)
In the area of the process lagoons and zirconium sludge storage, there appears to be a significant diffcrence in projected ground water elevations in the principal aquifer (deep aquifer) as compared with those of the upper sand aquifer. Such changes suggest that some form of confining layer is present beneath most of the process lagoons and zirconium storage area.
Further, project findings show that flow in the shallow aquifer is predominantly toward the drainage ditch (i.e., the site east-west drainage ditch which outfalls to the northeast Cape Fear River).
l l
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TABLE 1
^
SUMMARY
/ COMPARISON OF ANALYTICAL DATA COMPILED FOR GROUND WATER SAMPLES (COLLECTED 3/11/82)
NliUEPA GE-Wilmington Ippm)
(ppm)
_ _ _ _ _. SAMPLE #
NO F
NO F
3 3
N WT-1 25.7 1.10 23.6 0.90 WT-2 18.6 0.15 20.8 0.10 WT-3 0.22 0.16 0.79 0.10 WT-4 36.7 0.44 37 0.54 WT-7 3.67 0.13 21 0.10 WT-9 14.42 0.10 20 0.10 ZB-2 0.22 0.10 0.42 0.15 ZC 514 0.20 12 0.18 ZE C67 0.10 824 0.10 MW2A 0.22 0.10 13.00 0.10 2B 0.22 t,.14 0.20 0.11 2C 0.22 0.15 1.40 0.10 MW3A 10.36 0.12 10.20 0.10 3B 4.51 0.10 4.50 0.10 3C 3.23 0.21 25.00 0.13 MW4A 20.9 0.10 21.10 C.10 4B 11.54 0.10 16.00 0.10 4C 0.22 0.14 0.13 0.10 a
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