ML20133D907

Insp Rept 70-1113/85-05 on 850415-19 & 0524.No Violation or Deviation Noted.Major Areas Inspected:Radwaste Mgt,Environ Protection,Confirmatory Measurements,Bioassay & Independent Insp Effort

ML20133D907
Person / Time
Site:	07001113
Issue date:	06/13/1985
From:	Dan Collins, Gloersen W, Montgomery D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20133D893	List: ML20133D889 ML20133D907
References
70-1113-85-05, 70-1113-85-5, NUDOCS 8508070512
Download: ML20133D907 (11)

Text

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1. Ceog, UNITED $7ATES

- 3 'o NUCLEAR REGULATORY COMMISSION

, [N ' ' ,'o REGION 11

! g j 101 MARIETTA STREET.N.W.

• 'c AT LANTA, GEORGI A 30323

..... Jul. 011995 l

Report No.: 70-1113/85-05 Licensee: General Electric Company Wilmington, NC 28401 FaciHty: General Electric Wilmington Facility Docket No.: 70-1113 License No.: SNM-1097 i Inspection Conducted: April 15 - 19, and May 24, 1985 Inspectors: _b ,/k N z wuz 3 4t d"/6 .97 W. B. Gloe'rsen j [ Date Signed i

h A Yk bG;xu, ~ &/o-S (

D. C Montgo W ryg ~ / ~liate Signed

Accompanying Personnel

D. M. Collins D. Sly l Approved by: *M' # Ir-/5 - 85 1 D. M. Collins, Chief Date Signed i Emergency Preparedness and Radiological i Protection Branch Division of Radiation Safety and Safeguards i >

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SUMMARY

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j Scope: This routine unannounced inspection involved 60 inspector-hours on site t in the areas of radioactive waste management, environmental protection,

confirmatory measurements, bioassay, and independent inspection effort.

j Results: No violations or deviations were identified, i i

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{BS"MEIkM3 I L i

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REPORT DETAILS

1. Licensee Employees Contacted

• J. Bergman, Manager, Fuel Manufacturing

• W. McMahon, Manager, Quality Assurance

• R. Hawk, Manager, Oper/stional Planning

• C. Vaughan, Manager, Regulatory Compliance

• W. Smalley, Manager, Environmental Protection

• R. Pace, Manager, Fuel Support

• P. Winslow, Manager, CHEMET Laboratory R. Torres, Manager, Radiation Protection

• P. Stansbury, Senior Nuclear Safety Engineer

• S. Murray, Senior Nuclear Safety Engineer

• T. Crawford, Environmental Protection Engineer

• B. Dunn, Licensing Administrator B. Beane, Senior Engineer, Fuels Fabrication A. Shaefer, Senior Engineer A. Cameron, Day Shift Foreman l

• Attended exit interview

2. Exit Interview 1

! The inspection scope and findings were summarized on April 19, 1985, with l those persons indicated in Paragraph 1. The inspectors described the areas l inspected and discussed the inspection findings. One unresolved item

• was l identified in the area .of operation and maintenance of ventilation systems l (Paragraph 10). An inspector followup item in the area of effluent sample

analysis comparisons between NRC and the licensee (Paragraph 7) was l identified. Licensee representatives acknowledged the inspectors' findings.

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3. Procedures (88035, 88045) l Chapter 2.7 to Part I of the license application requires written procedures to be established, implemented, and maintained covering various areas including Radiation Safety, Radiation Protection and Environmental i

I l a Unresolved items are matters about which more information is required to l determine whether they are acceptable or may involve violations or deviations.

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Protection functions. The inspector reviewed selected portions of the following Environmental Protection Instructions (EPIs), Nuclear Safety Instructions (NSIs), and other procedures:

EPI 0-1.0, Operation of Final Process Effluent Control Stream, Rev. 2, June 1, 1984 EPI 0-2.0, Environmental Sampling of the Final Process Lagoon System and Site Dam, Rev. 4, January 7, 1985 EPI 0-4.0, Sample Collection and Analysis of Aeration Basin Monitoring Wells, Rev. 1, June 1, 1984 EPI 0-6.0, Stack Sampling Program, Rev. 8, October 9, 1984 EPI 0-7.0, Soil and State Split Sampling Programs, Rev. 6, February 12, 1985 EPI 0-8.0, Sample Collection from Monitoring Wells, Rev. 9, February 12, 1985 EPI 0-9.0, Environmental Ambient Air Sampling Stations, Rev. 1, June 1, 1984 NSI 0-4.0, Nuclear Safety Engineering Radiation Protection Instru-mentation, Rev. 20, August 24, 1984 ATM 4.1.21.2, Determination of Uranium in Water by X-ray Fluorescence, Rev. 7, March 4, 1985 ATM 1.2.21.10, Measurement of Uranium in Urine using the Scintrex UA-3 Analyzer Method, October 6, 1982 The inspector noted that the procedures were being reviewed, updated, and approved by appropriate staff and management as required by administrative requirements.

No violations or deviations were identified.

4. Records (88035, 88045)

The inspector reviewed selected portions of the following records:

(1) Sampling and analysis results of the Environmental Radiological Monitoring Program described in Table 5.1 of Part I of the license application, June 1984 - March 1985.

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3 (2) Stack sampler particulate filter sampling and analysis results for the following stacks:

CHMS0546 - Exhaust for Main Chemical Area (FMO)

CHMSFOX - Exhaust for Main Chemical Area (FM0X)

UPSE000 - Uranium Processing System Exhaust INEXBURN - Incinerator Exhaust (3) In-vivo Lung Counter Records, 1/3/84 - 4/17/85 Daily Performance Checks Background Checks (4) Results of spiked analysis of urine samples 3/6/85 - 4/17/85 (5) Quality Notice - Qualification for the use of the Scintrex UA-3 Analyzer, June 29, 1982 (6) Calibration recoras and performance checks for the following instruments, July 1984 - March 1985:

Harshaw TASC-12 Alpha / Beta Counting System Liquid Uranium Monitor Fluorimeter No violations or deviations were identified.

5. Licensee Audits The inspector reviewed the licensee's external and internal audit program as related to the radioactive waste management and environmental protection programs. The external audits were conducted by the Quality Assurance and Reliability Operation (QA&RO) Group which was part of the licensee's corporate structure but independent of the Wilmington Manufacturing Department. External audit findings were documented either as Corrective Action Requests (CARS) or Advisories. CARS required a formal committed corrective action and committed prevention actions from the responsible area manager. A tracking system was maintained to followup on CARS. Advisories did not require a formal response to the QA&RO, however, they were normally re-examined during the next audit. Environmental Protection Internal Audits were also referred to as " Regulatory Compliance Audits." Personnel under the direction of the Manager of the Environmental Protection function performed the environmental protection audits, however, they did not report to the production organization and had no direct responsibility for the function and area being audited. Audit findings were documented and communicated to the Area Manager who was responsible for corrective action commitments. Corrective action items were tracked until their closure.

The inspector reviewed QA&R0 Audit Report No. 84-02 (dated 6/14/84) conducted May 7-31, 1984. There were no corrective action requests identified in the areas of environmental protection or waste management.

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Approximately five advisories were identified in the areas of records management, documentation, quality assurance, and sample analysis reporting.

Audit results were reviewed by management and appropriate followup actions were taken. The inspector also reviewed Environmental Protection (EP) Audit 8405, EP Audit 8406, and EP Audit 8501. The inspector noted that appropriate management initiated corrective action on the " areas of concern" identified in the audits.

No violations or deviations were identified.

6. Environmental Protection (88045)

a. The inspector reviewed the licensee's environmental protection program with respect to the requirements of Chapter 5 to Part I of the licensee's application. The environmental protection program had been changed since the last inspection due to the issuance of the renewed license dated June 29, 1984. Basically, the new program added additional sampling analysis, and other requirements. The inspector determined that procedures were in place which established criteria for meeting requirements for sampling, data recording and storage, reporting of results, calibration, measurements and analysis, and actions to be taken in the event analysis results exceed or deviate from established limits. The inspector examined and reviewed selected records of the environmental sampling and analysis program for the period July 1984 to March 1985. The review included an examination of air monitoring, surface water, nitrate waste stream, groundwater, soil and vegetation sampling records. The inspector noted that the licensee had identified an item in this program requiring corrective action which had been accomplished.

No violations or deviations were identified.

b. During the record review process, the inspector also observed that the groundwater WT-4 series well was dry throughout 1984. The inspector noted that the licensee took the appropriate corrective actions as required by Section 5.2.4.2 of Chapter 5 to Part I of the license application (effective June 29, 1984) which requires the licensee to initiate an investigation within 14 working days after the end of three consecutive dry sampling periods and to initiate a corrective action program resulting in the renewal of sampling. On December 12, 1984, a new WT-4 well was installed. The licensee experienced no problems with the new well from December 12, 1984, to March 1985. All records of investigations and corrective action programs were in order.

No violations or deviations were identified.

c. Section 5.2.1.2 of Chapter 5 to Part I of the license application requires installation and operation of ambient air sampling stations in the prevailing wind directions downwind of the principal point of effluent release, near the fenced property line. The inspector and a licensee representative examined and observed the operation of the four

5 ambient air sampling stations located in the south, southwest, northeast, and southeast quadrants as described in Figure 5.3.

No violations or deviations were identified.

7. Quality Control of Analytical Measurements (88045, 84844)

The inspector determined that no substantial changes had been made in the program for quality control of radioactivity measurements. The licensee's program had the capability to identify deviations or deficiencies in the analysis of environmental and effluent samples by automatically checking each determination, running standard yield determinations between sample counts and checking counter background on each shift. Counter data was automatically entered into a computer logging system programmed to identify deviations. Analyses which either exceeded or deviated from established boundary values were repeated for verification. The inspector determined that radioactivity counting standards used by the licensee were traceable to the National Bureau of Standards (NBS). NBS traceable certificates for the standards were available on-site.

The licensee used several laboratories to perform the radiological analyses for the environmental radiological monitoring program. Isotopic analyses on the particulate filters from the ambient air monitoring stations were performed by a vendor. The gross alpha and gross beta analyses for the various liquid samples were performed by a laboratory that is part of the licensee's corporate structure. Gross alpha and beta analyses of stack samples of airborne discharges were performed on-site. Other environmental samples were analyzed in the CHEMET environmental laboratory for uranium content. Samples with trace levels of uranium were analyzed by fluorimetry.

The inspector reviewed the fluorimeter calibration curve and QC data log for January-March 1985. Samples with higher levels of uranium were analyzed by using a Liquid Uranium Monitor (LUM) which basically uses an X-ray fluorescence process for uranium content analysis. Spiked samples with known amounts of uranium were run daily on the LUM and an average recovery of the spike was determined.

During this inspection samples were collected for confirmatory measurements to evaluate the licensee's capability for measuring radioactivity in the various effluent streams as required by license conditions. Three liquid samples from the waste treatment facility were collected and split with the licensee on April 18, 1985 (V-108 in, V-108 out, V-104 out). Additionally, two stack sampler particulate filters (CHMS0546 - 4/14-15/85, UPSE000 -

4/12-13/85) that had been analyzed recently by the licensee were collected.

These samples will be analyzed by the U.S. Department of Energy's Radio-logical and Environmental Sciences Laboratory (RESL) for the NRC. The inspectors requested the licensee to provide the results of their analyses to the NRC. The results will be reviewed during a subsequent inspection (70-1113/85-05-01).

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8. Bioassay Program (92706)

The inspector reviewed the quality assurance program for the lung counting system and analysis of uranium in urine (urinalysis program). The inspector a reviewed operating procedures for calibration and routine operations. The inspector noted that the lung counter was calibrated annually by the company contracted to operate the system. Periodical performance checks and background counts were made to ensure the operability and verify calibration status. The inspector noted that the urinalysis program did not include the analysis of spiked, " blind" samples and/or replicate analyses as part of the

quality control program. Although the licensee periodically analyzed urine samples spiked with known quantities, the program had not been incorporated into plant procedures and no formal review of the data was apparent. The inspector noted that there were no specific license requirements regarding quality control in this area. A licensee representative stated that similar

. findings had been identified in QA&R0 Audit Report No. 84-02 and that this area was being reviewed.

The inspector reviewed records associated with the testing of the Scintrex UA-3 Analyzer and discussed the operational history with CHEMET Laboratory staff including the manager. Prior to procurement of the analyzer, a licensee representative visited a commercial laboratory that was using the Scintrex UA-3 for analysis of uranium in urine and determined that the instrument was acceptable. Following procurement of the Scintrex UA-3 Analyzer, the instrument and chemical procedure for analysis of uranium in j urine was tested. Although initial testing at a General Electric Laboratory

! in Schenectady, NY was not successful, subsequent testing at the licensee's facility demonstrated the instrument's capability to make accurate measurements in urine. The licensee's testing of this method and instrument was consistent with good laboratory practice. A Quality Notice,

" Qualification for the use of the Scintrex Analyzer" was issued on June 29, 1982, prior to its use for bioassay analyses. This notice documented the testing and acceptability of the instrument for measuring uranium in urine at an acceptable lower limit of detection.

The inspector provided three spiked, " blind" urine samples and a blank urine sample to the licensee for analysis. These samples were prepared by the U.S. Department of Energy's Radiological and Environmental Sciences i Laboratory (RESL). These samples were analyzed'for uranium by the licensee using the licensee's approved procedure which utilized a Scintrex UA-3 Analyzer. The results were erratic and, with the exception of sample #1, were higher than the known values by as much as a factor of 40. The licensee reported a value of 56 pgm/L compared to a known value of 70 pgm/L for sample #1. Since a review of licensee quality control data did not show similar problems, it appeared that the storage and/or preservation of the spiked samples may have resulted in interferences that were not normally I

present in fresh urine samples. The spiked urine samples were approximately seven days old and preserved with hydrochloric acid while the licensee normally holds urine samples for less than one day prior to analysis with no preservative. Additional unknown aqueous solutions spiked with uranium were j sent to the licensee for analysis using the same techniques as used for the i

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7 analysis of urine samples. The licensee results for these samples were as follows:

Concentration, pom/ liter Sample Known GE* Ratio GE/Known Blank -

<1 1

1. 1 14 15 1.07

1. 2 70 77 1.10

1. 3 31 32 1.03

1. 4 70 82 1.17

• Average of three determinations Although there were no official NRC acceptance criteria for bioassay analysis, the results were considered acceptable for this type of analysis.

The results met the draft American National Standards Institute (ANSI) criteria for bioassay measurements. The results appeared to show a systematic high bias. This would be conservative with respect to worker protection.

No violations or deviations were identified.

9. Liquid and Airborne Effluent Monitoring Instrumentation (88035)

The inspector reviewed the radioactive liquid and airborne effluent monitoring programs established to meet the requirements of 10 CFR 20.106, 10 CFR 20.203, 40 CFR 190, and the sections of Chapter 5 to Part I of the license application. The inspector reviewed the licensee's procedures and methods of sampling and analysis and the licensee's procedures and records for calibration of the following counting instruments (covering the period July 1984 - March 1985):

Harshaw TASC-12 Alpha / Beta Counting System Liquid Uranium Monitor Fluorimeter No violations or deviations were identified.

10. CHEMET Laboratory Tour The inspector toured the CHEMET Laboratory area and observed various laboratory operations in progress. The inspector noted that fume hood air velocities appeared to be lower than normally encountered. At the inspector's request, a licensee representative arranged for the measurement of the air flow for several fume hoods in the CHEMET Laboratory. The inspector observed a licensee representative perform the air flow

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measurements. The average air flow for hood #5 was approximately 55 linear feet per minute (ifpm) compared to the licensee's action point of an air flow of 80 lfpm. Although other fume hoods met the licensee's action point, the flow rates were lower than normal.

Subsequent to the inspector's observations, the licensee determined that the main ventilation system had been changed from the east bank to the west bank in order to calibrate the air flow monitors associated with the east bank.

Either the east or west banks can be used to provide ventilation for the fume hoods and process areas. The air flow was normally controlled automatically by process instrumentation; however, the west bank was in the manual operation mode when the switchover was made. The manual flow settings were not adequate to provide the normal flow requirements. A licensee representative stated that this condition lasted for 20 to 30 minutes before normal air flow was achieved. The inspector informed the licensee that this matter would be considered as an unresolved item pending NRC review of the procedures for operation and maintenance of the venti-lation systems and air monitoring data collected during this period.

(70-1113/85-05-02)

One unresolved item was identified.

11. Radioactive Gaseous Effluents (88035)

a. The licensee was required by 10 CFR 20.106 to limit the amount of radioactivity in effluents to unrestricted areas. Chapter 5 to Part I of the license application required the licensee to process, monitor, and control radioactive gaseous effluents to meet the applicable regulatory requirements.

The inspector reviewed sampling and analysis logs of the stack sampler particulate filters for each principal radioactive effluent, release point, representing an approximately two-month period since the last inspection. The inspector noted that records were completed, and that the required sampling and analysis of stack filters had been performed in all cases that were analyzed. All sample analysis results reviewed by the inspector were less than action guide limits.

No violations or deviations were identified.

b. The inspector reviewed the Semiannual Effluent Reports pertaining to gaseous effluents for January-June 1984 and for July-December 1984 which were submitted to meet the requirements of 10 CFR 70.57. The inspector did not observe anomalous measurement results, trends, or missing data.

No violations or deviations were identified.

c. The inspector reviewed the high efficiency particulate air (HEPA) filtration systems. The licensee did not perform in place D0P leak testing of the HEPA filter systems since license conditions do not

9 specify in place leak testing requirements. The manufacturer of the HEPA filters provides certified D0P testing documentation on each filter by serial number. The licensee regularly monitored the differential pressure (AP) across the filter banks. Filters are replaced with AP values exceeded the manufacturer's ratings for the filter. Assurance of system integrity was based on quality control during filter procurement, training of plant personnel in correct methods of filter installation, and on effluent sampling and analysis.

This filtration system reduced the potential for exposure to airborne contamination to personnel changing the filter banks. A number of conventional systems had been replaced with this system. Gaseous effluents were sampled continuously downstream of the HEPA filter banks. Samples were removed at daily or weekly intervals, depending on the potential for concentrations of particulate material in the effluents, and were analyzed on site for gross alpha activity.

No violations or deviations were identified.

12. Radioactive Liquid Effluents (88035)

a. The licensee was required by 10 CFR 20.106 to limit the amount of radioactivity in effluents to unrestricted areas. Chapter 5 to Part I of the license application required the licensee to process, monitor, and control radioactive liquid effluents to meet the applicable regulatory requirements.

The inspector selectively reviewed the NPDES Liquid Waste Release Self-Monitoring Reports for the period June 1984 to March 1985. In addition, the inspector selectively reviewed the periodic sampling and analysis records of continuous releases from the holding lagoons and nitrate waste streams for the same period noted above representing approximately three months of operation. On the basis of this selective records review, the inspector determined that the required samples and analyses had been performed. Liquid waste release records reviewed by the inspector showed uranium concentrations less than the action levels for uranium in liquid effluents.

No violations or deviations were identified.

b. The inspector reviewed the Semiannual Effluent Reports pertaining to liquid effluents for January-June 1984 and July-December 1984 which were submitted to satisfy the requirements of 10 CFR 70.57. The inspector did not observe anomolous measurement results, trends, or missing data.

No violations or deviations were identified.

c. The licensee monitored liquid effluents by periodically collecting and analyzing composite samples of continuous releases from the holding (final process) lagoons to the Northeast Cape Fear River. Control of c

10 releases was afforded by pre-release sampling and analysis of batch inputs from the quarantine tank control system to the holding lagoons which provided a degree of control over the soluble uranium input to the lagoons.

No violations or deviations were identified.

13. Radioactive Solid Waste (88035)

The licensee was required by 10 CFR 20.203, 10 CFR 20.301, and 10 CFR 20.401 to use caution signs and other controls to limit access to radiation areas (as related to solid wastes), to follow general requirements for waste disposal, and to maintain records of waste disposal, respectively.

Section 1.7.5 of Part I to the license application authorized the licensee to treat, store, and dispose of solid wastes pursuant to 10 CFR 20.302 and 10 CFR 20.304. Section 5.1.3 of Part I to Lne license application required the licensee to monitor, assay, observe action limits and report activity data on each solid waste shipment.

The inspector examined the licensee's incineration facility used to oxidize combustible solids and liquids. The ash product was processed for uranium recovery with the unusable portion of the ash being transported to a licensed burial ground. At the time of this inspection, the incinerator was not operating. Solid wastes generated in the fuel manufacturing operation (FMO) were packaged in boxes. These boxes were assigned to controlled access holding areas where they awaited processing through a decontamination facility. The decontamination operation provided the licensee a means to receive uranium for recycle, to separate wastes into combustible and noncombustible categories, and to decontaminate material for reuse. After separation in the decontamination facility, the combustible wastes were packaged into 4' X 4' X 4' plywood boxes for subsequent burning in the incineration facility. The noncombustible wastes were packaged into 4' X 4'x 3'1' metal boxes for shipment to the Barnwell facility for disposal. The metal boxes were D0T-approved for retrievable storage. The boxes were j

labelled appropriately in accordance with 10 CFR 20.203 and each box was marked with an identification code and number. All waste boxes, whether the combustible boxes for on-site incineration or the metal boxes for off-site shipment, were stored in on-site outdoor storage areas for not less than 60 days prior to incineration or off-site shipment. After that time, each box was taken to a special analytical facility where sensitive radiation spectrometry was used to determine the uranium-235 content. The storage areas were appropriately fenced and marked with caution signs.

The inspector reviewed selective records of radioactive solid waste interim storage, incineration, and shipments off-site to the Barnwell facility representing approximately a two-month period since the last inspection.

No violations or deviations were identified.

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