ML20149F924

Insp Rept 70-1151/97-04 on 970623-25.No Violations or Deviations Noted.Major Areas Inspected:Observation & Evaluation of Licensee Radioactive Waste Mgt & Environ Protection Program

ML20149F924
Person / Time
Site:	Westinghouse
Issue date:	07/11/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20149F922	List: ML20149F919 ML20149F924
References
70-1151-97-04, 70-1151-97-4, NUDOCS 9707220368
Download: ML20149F924 (17)

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U.S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.: 70 1151 License No.: SNM 1107 Report No.: 70 1151/97 04 Licensee: Westinghouse Electric Corporation Facility: Commercial -Nuclear Fuel Division -

Location: Columbia, SC 29250 Inspection Conducted: June 23 25, 1997 Inspector: W. Gloersen Senior Radiation Specialist O

Approved by: E. McAlpine, Chief Fuel Facilities Branch Division of Nuclear Materials Safety I

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Enclosure 9707220368 970711 ~

PEWt ADDCK 07001151 )

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~ EXECUTIVE

SUMMARY

Commercial Nuclear Fuel ~ Division NRC Inspection Report 70-1151/97-04 The primary focus of this unannounced inspection was the observation and evaluation of the licensee's radioactive effluent waste management and environmental protection programs. The report includes the inspection efforts of one regional inspector. The inspection identified the following aspects of

-the licensee programs _as outlined below:

WASTE MANAGEMENT e: The annual offsite dose due to liquid and gaseous effluent releases in 1996 for individual members of the public was significantly below ten

. percent of the limit specified in 10 CFR 20.1301 indicating that the licensee's releases of radioactive material in effluents were ALARA.

e Stack sample delivery line concerns were noted.

, o Documentation of the corrective actions taken or planned to be taken for

. exceeding the control concentration limit for gaseous effluents had improved.

ENVI'RONMENTAL PROTECTION

. e Analytical results from the various environmental samples collected indicated that there was no radioactive material from plant operations accumulating or concentrating at the sample location.

e Comparison of environmental sample results indicated that the licensee's and NRC's results detected only background levels of uranium.

e Staffing levels were adequate to support ongoing licensed activities in the areas of environmental protection and effluent waste management.

e A revised ground water sample collection and preparation procedure appeared to provide more representative analytical results, however high gross beta concentrations were noted in the onsite ground water samples J

- for the third and fourth quarters 1996.

Attachment:

Persons Contacted and Exit Meeting List of Items Opened. Closed, and Discussed

' List of Acronyms J

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Report Details

1. Summary of Plant Status Effective July 1,1997, the Division General Manager, Mr. Ron Koga will retire. Mr. Jim Fici was recently appointed the Division General Manager which will also be effective on July 1. Mr. Fici's replacement as the Plant Manager, Columbia Fuel Fabrication Facility, will be named later.

During the periods of inspection, normal fuel production activities were being conducted, including uranium recovery and waste processing operations.

On June 23 at 23:34, the licensee reported under NRC Bulletin 91 01 the loss of one of two contingencies associated with nuclear criticality safety in the hopper of the granulator in line 1. The safety 1 significance was low for the exiting condition due to the lack of moderator in the system.

The granulator hopper was in a part of the process between powder blending and Jelletizing. The licensee's process used a roll com) actor to increase t1e density of the blended powder which falls into a lopper that feeds the granulator. The granulator hopper was of a decreasing rectangular cross section (more resembling a frustum of a rectangular

. ayramid) topped by a rectangular section. The total volume of the lopper was approximately 43 liters. The Licensee's criticality safety evaluation assigned favorable volume to the granulator hopper in error.

The actual volume was about 4 liters greater than geometrically favorable for the maximum plant enrichment of 5.0 percent U 235.

The licensee detected the lack of favorable volume through a reanalysis of the system following a blockage in the hoaper where 165 kilogram of U02 powder accumulated in the hopper. The floor operators at Westinghouse had expected to remove one container of material from the granulator every seven to nine minutes. When that did not occur, the operators suspected a blockage had occurred.

When the licensee realized that they did not have favorable volume hoppers, the pellet lines were shutdown and the licensee initiated installation of stainless steel wedges in the hoppers to reduce the volume to a more favorable geometry. The licensee restarted lines 1 through 3 on the morning of June 24. The wedge was installed in line 4 on the afternoon of June 24, 1997. The licensee alans to install the wedge in line 5 (which does not get as much use) 3efore restarting it.

The moderation contingency was maintained. The roll compactor received material from the blenders and the material was analyzed and confirmed to be dry before it went into the blender. The roll compaction and granulation process was within an enclosure that had no water sources, thus maintaining moisture control. It should be noted that in the blending process,1700 kilograms of U0, powder at the same level of moderation was determined to be safe J

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, for the system to be about 0.985 under Westinghouse calculated the following conditions: as the k,f'ound geometry, optimum moderation, inch of water reflection. Moderation was not optimum, it was dry.

Therefore, the as found k,,, would have been much lower.

2. Environmental Protection (R2) (88045)

a. Organization (1) Insoection Scope The inspector reviewed the licensee's Regulatory Engineering and Operations organization, including staffing levels with regard to the programs for environmental safety and radiological effluents management.

(2) Observations and Findinos The inspector noted that the structure of the organization had not changed significantly since the last inspection of this program area. The licensee basically had assigned one Senior Regulatory Engineer, one Environmental Technician, and one Laboratory Technician.

(3) Conclusion During the onsite inspection, the inspector did not identify any concerns with the organization or responsibilities of the Regulatory Engineering and Operations staff. Based on discussions with licensee representatives and observation of activities, the inspector noted at the time of the inspection that staffing levels appeared adequate to support ongoing licensed activities in the areas of environmental protection and effluent waste management.

b. Monitoring Program Implementation (1) Inspection Scope Safety Condition S 1 of Materials License No. SNM 1107 authorized the use of licensed materials in accordance with statements, representations, and conditions contained in the License Application dated April 30, 1995, and approved supplements thereto.

Chapter 10. Section 10.4.1 of the License Application specified the minimum sampling and analytical requirements for the licensee's environmental monitoring program, Referenced tables and figures specified which media were to be sampled, sampling locations, sampling frequency, types of analysis, and analytical sensitivities.

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- (2)I -Observations and Findinas p

The inspector reviewed the changes to the following procedures since the last inspection:

o R0P 06 006, Collection of Routine Weekly and Monthly j Environmental Samples, Rev. 7, December 17, 1996 o R0 06 007 Two Inch Well Sampling, Rev. 6,

.i December 17, 1996 o RA 401, Environmental Control Requirements Mandated by i l.. 10 CFR 20 and EPA 40 CFR 61, Rev. 8, February 13, 1997 During the last inspection of this' program area, the

, inspector observed the practice of using the same sampling i equipment for the collection of the ground water samples could lead to a cross contamination problem. During this j: inspection, the inspector noted that the licensee had.

4 revised its groundwater sample collection and preparation procedure (R0 06 007). The licensee revised the procedure L to use well specific specialized PVC bailers. The procedure

specified that three one liter ground water samples be .

collected from each well. One liter was to be acidified

with two milliliters of H SO 2 and 4 labeled for ammonia i .o analysis. The second liter was to be analyzed for e fluoride, and conductivity and not to be acidified.pH.The -

j- third liter was also not to be acidified and prepared for

. shipment to a vendor laboratory for radioactivity analysis.

The sample request form to the vendor specified additional L analysis requirements. Specifically, for all samples with a i gross alpha concentration greater than 15 picocuries per

, liter (pCi/ liter), an isotopic uranium analysis was e required. In addition, for all samples with a gross beta

concentration greater than 50 pCi/ liter, an isotopic beta

analysis was required.

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! The inspector determined that the changes in the procedures i

did not decrease the effectiveness of implementing the environmental monitoring program and that the procedures had adequate provisions for collecting and analyzing the environmental sam)les at the frequencies and locations specified in the icense Application.

3-(3) Conclusions 4

L, Based on the above reviews, it was concluded that the licensee had effectively implemented the required l_ environmental monitoring program.

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c. Monitoring Program Results

] (1) Insoection'Scooe Chapter 10 Section 10.4.1 of the License Application

,' specified that action levels will be established by-arocedure for environmental samples. Figure 10 1 of the

_icense Application specified gross alpha and beta .

concentration action levels for ground-water and gross alpha

' concentration action levels for vegetation samples.

Procedure RA 215 Unusual Incidents, Rev. 9, dated February 22, 1996, specified an action level for p environmental air samples.

'(2) Observations and Findinas -

! -The inspector reviewed the analytical results for 1996 of 4

selected environmental sampling media, including: ambient i air particulate samples: vegetation samples: soil samples; i sediment samples; and fish samples. The inspector L determined that the environmental samples had been collected i and analyzed in accordance with the applicable procedures.

L The analytical results indicated background levels of

' radioactivity in the environment. There were no concentrations of radioactivity in the environmental samples

[. that were above the licensee's action levels.

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1 1 The inspector also reviewed 22 onsite ground water sample results.for the third and fourth quarters 1996. The

! inspector noted that during the fourth quarter, the licensee

[ had revised the groundwater sample collection and sample

. preparation procedure to minimize the potential for cross contamination between the samples and to avoid the analysis of dissolved solids in the water which could bias the

. results high and thus not be representative of the ground t

water quality. During the third quarter, gross alpha concentrations ranged from less than 2 pCi/l to 171 pCi/1, i- Gross beta concentrations ranged from less thar 3 pC1/1 to P

297 pC1/l. During the fourth quarter, the gross alpha

concentrations in the ground water samples dropped i dramatically. Gross alpha concentrations in all the wells 3-except one ranged from less than 2 pCi/l to 5 pCi/1. The

, gross alpha concentration in the one well was 33 pC1/1. The inspector noted, however, that.the gross beta concentrations during the fourth quarter ranged from less than 3 pCi/l to

713 pC1/l. The licensee was in the process of investigating i y- the cause of the elevated concentrations.

The inspector also discussed with the licensee any unusual environmental events during the period ~ January 1 to June 23,

1997. The licensee indicated that no unusual events were ,

reported, however, two minor occurrences were noted:

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i. '(a) On February 5, 1997, a solution was observed in one of ,

i.' the drainage ditches. Approximately 25 gallons of solution was removed. No contamination was found in ,

i the drainage ditch nor the main environmental control  !

, valve.

J t (b). On March 16,1997, approximately 5000 gallons of lime slurry was spilled on to a concrete )ad. The slurry i was contained on the pad. Most- of t1e slurry was

> umped backLto the holding tank. The remainder was  ;

losed off. to the east lagoon. The spill was caused by '

the failure of the seals on pump 1109 A.

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(3) Conclusions -

1 In general, .the analytical results from the various '

environmental samples collected indicated that there was no radioactive material from plant operations accumulating or concentrating at'the sample location. The licensee had  ;

revised the ground water sample collection and preparation procedure which appeared to provide more representative analytical results .for gross alpha concentrations. No conclusions could be reached with regard to the high gross beta concentrations.noted in the onsite ground water samples for the third and fourth quarters 1996.

d. Management Audits ,

(1) Insoection Scooe I Chapter 3. Section 3.6 of the License Application specified the requirements for licensee audits and self assessments.

This portion of the inspection involved a review of audits in the areas of environmental protection and radioactive i emissions in liquid and gaseous effluents.

(2) Observations and Findinas The inspector reviewed two of the most recent audits pertaining to the subject program area. The audits were ,

performed by the Senior Regulatory Engineer who has responsibility for the environmental protection and radioactive effluents programs. In addition to this type of I self assessment, the licensee should consider having this i program area audited by someone who does not have direct' responsibility for the program area. The first audit

)ertained to the environmental program and was completed in kcember 1996. There were no significant issues identified.

The second audit pertained to radioactive effluent program, and likewise, there were no issues identified. The inspector noted that neither the purpose of the audit was specified in the audit reports nor was the audit report addressed and/or copied to senior management.

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6 (3) Conclusions Although the audits were performed in a timely manner, the purpose of the audit and the addressee (s) were not specified. In addition, it was noted that these program areas were audited by the regulatory engineer who had direct responsibility for the areas being audited.

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e. Quality Control of Analytical Measurements (1) Inspection Scope In an effort to evaluate the licensee's analytical capabilities for environmental samples, the inspector- '

reviewed a comparison of split sample results between the State of South Carolina and the licensee.

(2) Observations and Findinas The ins >ector reviewed the 1995 State of South Carolina Annual Environmental Report, dated March 29, 1995. The report was prepared for the NRC under Contract No. 29 83 624 by the State of South Carolina. The report provided a summary of independent analyses of environmental samples collected in the vicinity of NRC reactor and fuel facility licensees in South Carolina. The inspector reviewed the split sample results of the following samples collected around the Westinghouse facility: (1) surface water: (2) ground water from Well No. 4: (3) Congaree River sediment:

(4) soil: (5) vegetation: (6) fish: and (7) co-located stationary continuous environmental air sample. Basically, the results were in agreemen: that background levels of radioactivity were measured. The inspector did note that the licensee's environmental air sample result was biased high when compared to the State's result. The 1996 Annual re) ort was not available at the time of this inspection to mace similar comparisons.

The inspector determined that the licensee had acquired the services of another contract laboratory since the last inspection. Section 10.5 of the license application specified the Regulatory Component will perform a biennial evaluation of vendors used to analyze environmental samples.

In addition, Section 10.5 specified that the evaluations '

will consider the need for " spike" and " replicate" sample submittals. During the review, the inspector did not note the use of spike or replicate sample submittals. >

7 (3) Conclusions The results.of split environmental samples analyzed by the

' State of South Carolina and the licensee in-1995 were in.

-agreement. The quality assurance program for environmental measurements was adequate, but there was no indication that-the licensee considered the_need for ' spike or . replicate sample submittals.

f. Monitoring Program Reports (1) Insoection Scooe The inspector reviewed discussions nf environmental and effluent trends in the licensee's 1996 Annual ALARA Report.

' Section 5.1.3 of the license application specifies the contents of the Annual ALARA Report which is submitted to -

the Plant Manager.

(2) Observations and Findinas The inspector noted that the 1996 Annual ALARA Re: ort included appropriate discussions and graphs of am)ient environmental airborne radioactivity concentrations, vegetation, soil, fish, and Congaree River sediment data as -

. required by Section 5.1.3 of the License ivplication.

However, the inspector noted that a summary of groundwater-data was not provided in the report. The' licensee indicated that these data would be reviewed so that an appropriate summary could be considered in the next report.

(3) C2nclusions The 1996 Annual ALARA Report included acceptable discussions of - environmental and effluent' trends. The report did lack acceptable review and summary of data for the onsite groundwater monitoring program,

g. Inspection Followup (92701)

(1) Summary of Issue IFI 70 1151/96 03 02: Compare analytical results-of a split

. wet weather stream. sediment sample and a Congaree River sediment sample.

(2) Observations and Findinas In an effort to evaluate the licensee's analytical capabilities and effectiveness of the program, during the inspection as documented in Inspection Report (IR) 96 03, the inspector' requested that a wet weather stream sediment sample (from the storm drain near environmental air sampling J

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station number 3) and a Congaree River sediment sample be collected and analyzed for radionuclide concentrations, as appropriate, by the licensee and split with the NRC for confirmatory measurements purposes. The NRC's samples were analyzed by the Oak Ridge Institute for Science and Education (0 RISE). ORISE performed a gamma isotopic l analysis. Since the gamma isotopic analysis provided sufficient confirmatory measurements, it was determined that neither a gross alpha / beta analysis nor an isotopic uranium analysis would be necessary. The licensee's samples were analyzed by their contractor laboratory for gross alpha and beta concentrations. A summary of the analytical results are provided in the table below: 3 i

Table 1: Comparison of Environmental Sample Analyses Between NRC and Licensee Westinghouse (pC1/gm) NRC 0 RISE (pC1/ gram)

Sample Gross Gross Uranium 238 Uranium 235 Alpha Beta Congaree River 1.1 0.6 1.9 +/ 1.4 < 0.3 Sediment Wet Weather 0.4 0.2 0.7 +/ 0.5 < 0.2

, Stream Sediment After reviewing the data, it was concluded that both sample analyses were in agreement and that the results indicated that only background levels of uranium were detected.

(3) Conclusion This item is considered closed.

3. Waste Management (88035)

a. Liquid Effluent Monitoring Results (1) Insoection Scoce Chapter 10. Section 10.2 of the License Application specified that a liquid waste treatment facility was provided and maintained to permit the holdup of liquid wastes for treatment, sampling, and analysis, and to permit their disposal in accordance with the provisions of 10 CFR Part 20.

(2) Observations and Findinos The liquid effluent released to the Congaree River from the WTF was required to be sampled continuously by a flow rate promrtional sam)le collector. R0P 06-001, NPDES Daily, Weecly, and Mont11y Effluent Sample Collection, Rev.12.

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9 l April 21, 1994, specified the liquid effluent sample collection requirements. . The licensee discharged aaproximately 130,000 gallons of liquid effluent per day.

T1e licensee collected daily samples from the proportional sampler to monitor for NPDES chemical parameters and to be analyzed for gross alpha activity, gross beta activity, and isotopic uranium. The licensee used a vendor laboratory to perform the required analyses for the monthly composite 1 samples.

The inspector reviewed the Semi Annual Radiological Effluent Discharge Reports for January through December 1996. The reports were submitted within the required time frame. The i inspector noted that the licensee used the guidance specified in Regulatory Guide 4.16, Monitoring and Reporting

' Radioactivity in Releases of Radioactive Materials in Liquid and Gaseous Effluents From Nuclear Fuel Processing and

' Fabrication Plants and Uranium Hexafluoride Production Plants, Rev. 1. December 1985.

The quantities of radionuclides released in liquid effluents

to unrestricted areas presented in Table 2 were derived from previous and present licensee semienual effluent release reports.

Table 2: Summary of Li i WestinghouseColumbia, quid Effluent S.C.Releases Facility for the Total Radioactivity Released (millicuries (mci))

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) Year Liouid Effluents

! 1985 246.2 1986 111.2 1987 57.2 1988- 34.5 1989 53.9 1990 24.3 1991 38.0 1992 18.6 1993 36.0 1994 53.6 1995 47.0 1996 46.8 An insignificant decrease of uranium in the liquid effluent discharged to the Congaree River was noted in 1996 compared to the quantity discharged in 1995. During the years 1992-1994, there was an apparent increasing trend identified.

The licensee indicated that in 1994, a shift in the manufacturing operations which basically ceased the direct UF to U0 powder conversion process and increased the use of,the Adu conversion process. The ADU conversion process

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, generated more liquid waste. The inspector reviewed the i records of liquid waste discharges for the first three months of 1997, and noted that the monthly average

discharges (before dilution) for gross alpha concentrations j'. were significantly greater than the unrestricted' release limit (URL). The licensce attributed these increases to a i

i decrease in the pH in the East Lagoon- thus driving the uranium back into solution and discharged. The licensee was 4 i

investigating this problem and was considering improved i i

monitoring the'pH of the liquid waste before it .is discharged into the lagoon system.

10 CFR 20.1302 allowed the' licensee to demonstrate compliance with the annual dose limit for individual members-of the public specified in 10 CFR 20.1301 by calculating the

' total effective dose equivalentf(TEDE) to the individual- <

likely to receive the highest dose from the licensed

operation. The licensee calculated the TEDE due to radioactive material released in liquid effluents to be less i than 0.002 millirem per year for 1996. The licensee based 4

this calculation on the method used by an NRC radiological e dose assessment performed in 1979, which used the guidance in Regulatory Guide 1.109.-

(3) Conclusions There were no apparent problems noted with the licensee's liquid sampling and analysis program. In addition, the annual offsite dose due to liquid effluent releases in 1996 for individual members of the public was significantly below ten percent of the limit specified in 10 CFR 20.1301 indicating that the licensee's releases of radioactive material in liquid effluents were ALARA.

b. Airborne Effluent Monitoring Results (1) Inspection Scope Chapter 10. Section 10.1 of the License Application specified the sampling and analytical requirements for gaseous effluents. Continuous sampling was required during production omrations for those operations which could result in ex1austing radioactive materials to unrestricted -

areas. ' Collection and analysis of those samples was required to be performed on a daily basis during production operations. The adequacy of the gaseous effluent controls was required to be determined by representative stack sampling to. demonstrate compliance with applicable regulations. In addition, if the radioactivity in the plant

. gaseous effluents exceeded 1500 microcuries per calendar quarter, a report was required-to be submitted to the NRC which identified the cause for exceeding the limit and the corrective actions to be taken to reduce release rates.

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[ 11 (2) Observations and Findinas b The inspector reviewed procedure R0P 06 002, Roof Effluent Air Sam) ling and Counting, Rev. 11. December 17,.1996, and

t i noted t1at it included provisions for the daily collection 2

of air particulate samples from 45 sampling locations and -

l analysis after a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> decay period and specified an action-level (or control concentration limit) of -

3 4E 12 pCi/ml. Procedure RA 401, Environmental Control e Requirements Mandated by 10 CFR Part 20 and EPA 40 CFR Part 61, Rev. 8. February 13, 1997, specified the. actions to take i 2- in the event a stack sample exceeded the control concentration limit specified in R0P 06 002. q 1 .1 The inspector accompanied a technician during the collection of the daily stack sample collection activity and noted no

, problems with the method used to collect the samples. .

j However, using the guidance in ANSI N13.1 Guide to Samaling

- Airborne Radioactive Materials in Nuclear Facilities, t1e

inspector noted the following stack sampling concerns

I o -The sample delivery lines on the ammonie fume .

scrubbers (Nos. 44 and 45) had at least two '

unnecessary 90 degree bends.

. o The sample _ delivery line on the Chemical Area exhaust appeared to be damaged.

o The sample probe location on the Development Lab exhaust (No.1) was at the-top of the stack.  ;

o Approximately half of the sampling systems used tygon tubing-for sample delivery lines which were subjected to harsh environments and the eventual degradation of ,

the sample delivery line.

. The inspector reviewed weekly gaseous effluent discharge reports for the period January 1 to May 30, 1997. The inspector noted that on several occasions the gaseous effluent control concentration limit was exceeded. It appeared that the appropriate actions were taken as requ' ired ,

by RA 401, and the inspector noted that the documentation of the corrective actions taken or planned to be taken was  :

improved when compared to the last inspection of this area.

In addition, the inspector reviewed the Semi Annual Radiological Effluent Discharge Reports for January through December 1996. During the. time period between January -

December 1996..the gaseous effluents at the point of discharge from the stacks represented an average discharge 1 concentration of approximately 1.65E 13 pC1/ml. This concentration was approximately 275 percent of the 10 CFR Part 20, Appendix B. Table 2, Column 2 unrestricted release i

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12 limit for Class "Y" material. However, it should be noted that this concentration would be diluted by a factor of at least 1000 at the site boundary using ground level diffusion factors.

The quantities of radionuclides released in gaseous effluents to unrestricted areas presented in Table 3 were derived from previous and present licensee semiannual effluent release reports.

Table 3: Summary of Gaseous Effluent Releases for the Westinghouse- Columbia, S.C. Facility Total R6dioactivity Released (millicuries (mC1))

Year Gaseous Effluents 1985 1.54 1986 1.51 1987 1.40 1988 1.44 1989 1.23 1990 1.23 1991 1.16 1992 0.99 o 1993 0.91 1994 0.48 1995 0.50 1996 0.48 The total gaseous radioactivity discharged during 1996. was I 0.48 mci of uranium, compared with 0.50 mci during 1995. i Since 1988 gaseous effluent discharges have indicated a i continued decreasing trend. This decreasing level of q gaseous effluent discharges had resulted from upgrading HP '

counting l methods. procedures As indicatedand in using Tablerevised sampling 3 above, and counting the annual totals l for gaseous effluents since 1987 were significantly less i than the license application limit of 1500 Ci per calendar )

quarter. j The inspector also reviewed the licensee's calculations and  ;

input parameters to calculate offsite doses to the maximally I exposed individual due to gaseous effluent releases using l the EPA's COMPLY computer code. The COMPLY computer code was used for calculating the offsite TEDE to the individual likely to receive the highest dose from licensed operation to demonstrate compliance with 10 CFR 20.1301 and 20.1302  :

and with the National Emission Standards for Hazardous Air Pollutants (NESHAPS) in 40 CFR Part 61, Subpart I. The total effective dose equivalent (TEDE) for 1996 due to a total stack discharge of 484.9 microcuries (pC1) was less than 0.6 millirem per year (mrem /yr) to an exposed j

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13 individual living at the site boundary. The calculated TEDE was significantly less than the new 10 CFR 20.1101 dose constraint of 10 mrem /yr.

(3) Conclusions Documentation of the corrective actions taken or planned to be taken for exceeding the control concentration limit for gaseous effluents had improved. In addition, stack sample delivery line concerns were r.oted. The licensee agreed to evaluate the noted concerns. The annual offsite dose due to gaseous effluent releases in 1996 for individual members of the public was significantly below ten percent of the dose '

constraint specified in 10 CFR 20.1101 indicating that the i licensee's releases of radioactive material in gaseous i effluents were ALARA.  !

4. Information Notices and Administrative Letters (92701) )

a. Insoection Scope The inspector reviewed the following NRC Information Notices (ins) l and Administrative Letter (AL) to determine if the information had  ;

been received by the licensee: )

- e AL 96 05: Compliance With The Rule " Timeliness In ,

Decommissioning Of Material Facilities" 1 (November 5, 1996) e IN 97 04: Implementation Of A New Ccnstraint On Radioactive Air Effluents (February 24, 1997) ,

e IN 97-20: Identification Of Certain Uranium Hexafluoride Cylinders That Do Not Comply With ANSI N14.1 Fabrication Standards (April 17, 1997) e IN 97 24: Failure of Packing Nuts On One Inch Uranium Hexafluoride Cylinder Valves (May 8,1997)

b. Observations and Findinas The inspector determined that the Information Notices and Administrative Letter had been received by the licensee, reviewed for applicability, distributed to appro)riate personnel, and that action, as appropriate was taken or scleduled.

c. Conclusion The licensee's actions i e appropriate.

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5. Inspection Followup (92701)

a. Summary of Issue Failure to comply with the terms and conditions of the NRC License, certificate, or other approval, as ap)licable, and other applicable requirements of Subparts A, G, and K of 10 CFR 71.

b. Observations and Findinos I The inspector reviewed a 10 CFR 71.95(a) report submitted to the NRC dated May 22, 1997, pertaining to a situation in which the  :

conditions of approval in the NRC Certificate of Compliance (CoC)

No. 9239. Rev. 4 were not observed in making a shipment.

10 CFR 71.12(c)(2) requires the licensee to comply with the terms i and conditions of the NRC License, certificate, or other approval. -i as applicable, and other applicable requirements of Subparts A (general provisions), G (operating controls and procedures), and H (quality assurance) of 10 CFR 71. Condition No. 5(a)(3) of the 1 NRC CoC No. 9239 specified that the packaging was constructed in '

accordance with Westinghouse Electric Corporation Drawing No. MCCL301, Sheets 1, 2, and 3. Rev. 4.

On or about April 24, 1997, during a pre shipment inspection, the o

licensee determined that certain Model MCC 3 shipping containers had been used for fuel shipments which did not reflect the minimum weld pattern on the container shell as described in license i drawing MCCL301. The different weld configuration was determined  !

to be a violation of the NRC CoC. Specifically, the drawing  !

called for skip welds to be made in 16 locations on the external rollover angle bars on the bottom half of the container shells.

The licensee discovered that approximately 80 out of 255 MCC 3 containers in use had the skip welds in only 12 locations.

This discrepancy was not detected by the supplier (who was also

[ the designer of the container shell assembly) during the quality control inspection, nor by the licensee during the receipt inspection. The licensee obtained in writing from the supplier that the 12 weld configuration did not decrease the margin of safety of the shipping containers. The licensee's engineers agreed with that assessment.

The licensee's explanation of the reasons for the violation, the immediate actions taken and the results achieved, and the actions taken to prevent recurrence, as documented in the letter to the NRC noted above, was acceptable.

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c. Conclusion A violation of 10 CFR 71.12(c)(2) requirements was identified.

However, this violation will not be subject to enforcement action because the licensee's efforts in identifying and correcting the violation met the criteria specified in Section VII.B of the NRC Enforcement Policy (NCV: 70-1151/97-04 01).

6. Exit Interview The inspection scope and results were summarized on June 25, 1997, with those persons indicated in the Attachment. The inspector described the.

areas examined and discussed the inspection results, including the non-cited violation and the likely informational content of the inspection report with regard to documents and/or processes reviewed during the inspection. Although proprietary documents and processes were occasionally reviewed during this inspection, the proprietary nature of these documents or processes has been deleted from this report, o

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ATTACHMENT

1. PERSONS CONTACTED Licensee Personnel

• J. Bush, Manager, Manufacturing (Acting Plant Manager)

• R. Fischer, Senior Engineer S. Gantt, Senior Regulatory Engineer

• D. Goldbach, Manager, IFBA and ADU Rod Manufacturing

• W. Goodwin, Manager, Regulatory Affairs

• J. Heath, Manager, Regulatory Engineering and Operations

-J. Hooper, Senior Regulatory Engineer

• E. Keelen, Manager, Product Assurance N. Kent, ~ Criticality Safety Engineer, Regulatory Affairs

• E. Reitler, Fellow Engineer

• T. Ross, Manager, Transportation T. Shannon, Technician, Regulatory Affairs Other licensee employees contacted included engineers, technicians, production staff, security, and office personnel.

• Denotes those present at the exit meeting on June 25, 1997

2. INSPECTION PROCEDURES USED IP 88035 Radioactive Waste Management IP 88045 Environmental Protection IP 92701 Inspection Followup

3. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Status Description 70 1151/96 03 02 Closed IFI: Com)are analytical results of a split wet weatler stream sediment sample and a Congaree River sediment sample for gross alpha / beta and/or radionuclide concentrations as appropriate.

70-1151/97 04 01 Closed NCV: Failure to comply with the terms and conditions of the NRC License, certificate, or other approval, as applicable, and other applicable requirements of Subparts A, G, and H of 10 CFR Part 71.

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4. LIST 0F ACRONYMS AL Administrative Letter ALARA As Low as is Reasonably Achievable ADU Ammonium Diuranate CoC Certificate of Compliance DHEC Division Heali i and Environmental Control '

- IN Information Notice IR Inspection Report K effective K}/ml 8 microcurie per milliliter mci millicuries i mrem millirem NESHAPS National Emission-Standards for Hazardous Air Pollutants  ;

NCV Non Cited Violation NHSS Nuclear Material Safety and Safeguards NRC Nuclear Regulatory Commission o ORISE Oak Ridge Institute for Science and Education i pCi/g picocurie per gram  !

pCi/l 31cocurie per liter RG 1egulatory Guide SC South Carolina i TEDE Total Effective Dose Equivalent i Uranium Hexafluoride UF[

UR Unrestricted Release Limit i o URRS- Uranium Recycle and Recovery Services l WWTF Waste Water Treatment Facility j 1

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