ML20150B111
| ML20150B111 | |
| Person / Time | |
|---|---|
| Site: | 07000824 |
| Issue date: | 03/02/1988 |
| From: | Kahle J, Marston R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20150B070 | List: |
| References | |
| 70-0824-88-02, 70-824-88-2, NUDOCS 8803160170 | |
| Download: ML20150B111 (9) | |
Text
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MAR 0 21988 Report No.:
70-824/88-02 Licensee:
Babcock and Wilcox Company Naval Nucleaa Fuel Division Lynchburg, VA 24505 Docket No.:
70-824 License No.:
$NM-778
[
1 Facility Name: Naval Nuclear Fuel Division Research Laboratory Inspection Conducted:
F bruary 8-10, 198 3
/
Inspector:
R. R. Marston Date Signed Accompanying Personnel:
C. Hughey D. Sl.y, ONMSS W. Pennington, ONMSS Rgrovencher,ONMSS Approved by:
Y
.b M
3 //, fY J. B. V%1e, Section'Ctfief Date Signed p
Division of Radiation Safety and Safeguards a
SUMMARY
l Scope:
This routine, unannounced inspection involved onsite review of liquid and gaseous waste m:nagement and envi onmental monitoring Results:
No violatie.ns or deviations were identified.
1 1
l l
8803160170 880302 PDR ADOCH 07000824 C
REPORT DETAILS 1.
Licensee Employees Contacted
- R. Bennett, Manager Safety and Licensing, NNFD-RL
- D. Harris, Health Physics Sr. Technician, NNFD-RL -
- A. Olsen, Sr. License Administrator, NNFD-RL
- S. Schilthelm, Supervisor, Health and Safety, NNFD-RL
- L. Trent, Manager, Regulatory Relations, NNFD
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on February 10l, 1988, with those persons indicated in Paragraph 1
.bove.
The inspector described the areas inspected and discussed in detail the inspection findings listed below. The licensee acknowledged the inspector's comments and expressed no contrary opinions.
The licensee did not identify as proprietary any of-the material provided to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.
4.
Audits (88035,88045)
Chapter 2, Paragraph 2.8.2 of the license application requires that the Supervisor, Health and Safety, or his. designated alternate conduct internal audits once a month for the purpose of evaluating the health physics aspects of operations.
Further, it requires that the License Administrator be responsible for assuring the appropriate corrective actions are taken to address the audit findings.
Chapter 2, Paragraph 2.8.3 of the license application requires the Safety Audit Subcommittee (SAS) to perform an audit of general safety and compliance of l
the Health and Safety group at least annually. Further, it requires the I
License Administrator to be responsible for assuring that the appropriate corrective actions are taken to address the audit findings.
The inspector reviewed the Health and Safety Audit Reports for the period July 1987 through January 1988.
The audits included status af findings from previous audits.
The audits addressed health physics practices, occupational health, and general housekeeping. The inspector reviewed the quarterly SAS audits for the third and fourth quarters of 1987.
The audits discussed the scope of the audi* items requiring corrective action.
l status of previous findings, and details of the audit.
The audits appeared to be thorough and comprehensive.
v No violations or deviations were identified.
2 5.
Procedures (88035,88045)
Chapter 2, Paragraph 2.7.2.1 of the license application describes the requirements for establishment, review, approval, and implementation of technical procedures.
The inspector reviewed a selection of technical procedures.
The procedures had been reviewed, updated, and approved as required.
A licensee representative stated that the procedure development program discussed in the previous report (Report No. 70-824/87-02, Paragraph 5) was still in progress.
No violations or deviations were identified.
6.
Records (88035,88045)
The inspector selectively reviewed the following records:
HEPA Filter DOP Testing Logs from May 27, 1987 through November 4, 1987.
Daily Operations Checklist from January 4 through February 10, 1988.
Weekly Operations Checklist from July 2, IEB7 through February 8, 1988 l includes HEPA filter pressure different'al checks).
Results cf annual survey and samples from contaminated railroad property, culverts, stream, and canal.
Background (Environmental) air Sample logs ar July 1, 1987 through r
January 27, 1988.
NNFD Liquid Waste Pumping Record / Batch Ri l er,e Analysis (liquid effluent) for August 4, 1987 through Februa.y 3, 1988.
Health Physics Log Book (Analyses of Wi a Tanks, River, LRC Pond, NNFD Pond, Dirt Cof fin Basin, Rain an c. Crmposites from August 27, 19E7 through January 5, 1988).
Air Sample Analyses (stacks, radiochemistry lab, and hot cells) for July 1,1987 through January 20, 1988.
Environmental Reports from TMA Eberline provided radiochemical analyses of sediment and vegetation samples for the second and third quarters of 1987.
Stack monitor calibrations:
particulate monitor on September 24, 1987, and gas monitor on October 20, 1987.
3 Beckman Widebeta II alpha and beta efficiencies and plateaus on December 10, 1987, standards and background for August 1987 through January 11, 1988, and control charts.
Sharp Low Beta efficiencies and plateaus on October 14, 1987, and control charts for July 1987 through December 7, 1987.
Radiochemistry Logsheets for Secondary Source Preparation for sources 138, 140, 146, 147, and 148.
Gamma Spec. Systems calibrations for January through February 1988.
Liquid Scintillation system daily standard test, backgrounds and control charts for August 1987 to February 1988.
The inspector determined from review of the above records that regulatory and procedural requirements appeared to have been met.
A licensee representative stated that scheduled HEPA filter testing had been conducted the previous day, but the results had not yet been entered in the log.
No violations or deviations were identified.
7.
Liquid and Airborne Effluent Sampling and Analysis (88035)
The inspector reviewed facilit'.es, procedures, sampling and analytical equipment and methods, and resulting data produced by the program. During a tour of the facility, the inspector noted the status of the sempling equipment and provisions for obtaining representative samples, a.
Liquid Effluent Program Low level liquid waste was transferred from process areas to tanks in the Liquid Waste Building, then on to the B&W Naval Nuclear Fuel Division (NNFD) liquid waste system.
Prior to release to NNFD, the contents of the tank were mixed and sampled for radioactive content and pH.
When the contents were above specified release limits or outside the acceptable pH range, the contents were diluted to meet the concentration limits or neutralized to the allowable pH range.
Housekeeping appeared to be good in the Liquid Waste Building and no leaks were observed.
No violations or deviations were identified, b.
Gaseous Effluent Program Potentially contaminated exhaust air from hot cells, hoods, and glove boxes was discharged from the 50 meter high stack. Backup power was provided for the stack exhaust fan.
Areas where the exhaust might contain radioactive material were passed through HEPA filters prior to exhaust to the roof or stack. The inspector noted that the stack
d 4
gaseous and particulate monitors were in current calibration and housekeeping appeared to be good in the area of the stack and its monitors.
No violations or deviations were identified.
8.
Environmental Monitoring (88045) a.
Environmental Monitoring Program The inspector reviewed the licensee's environmental monitoring program with respect to Chapter 5, Paragraph 5.2 of the license application. The inspector and a cognizant licensee representative toured the plant grounds and examined representativi sample locations and equipment.
Counting equipment in the Health Physics Laboratory and the Radiochemistry Counting Room were examined. Records reviewed by the inspector indicated that calibrations were current and that the licensee had performed all required sampling and analyses.
b.
LRC Hillside Contamination In
- 1969, a pipe which carried contaminated water from a demineralizer, used in connection with the LRC test reactor, to the Liquid Waste Disposal Facility burst, resulting in leakage into a storm sewer. The sewer line emptied down a hillside behind the solid waste storage building, resulting in contamination of the hillside and a marshy area at the base of the hill. A restricted area was fenced in and posted.
Measurements conducted during the summer of 1980 showed that Cobalt-60 contamination had migrated northward to extend 20 feet within the railroad right-of-way.
The extended boundary was fenced to restrict access to the area, and LRC, later in the year, submitted a plan for decontaminating the soil so that the area could be released for unrestricted use.
The plan called for removal of contaminated soil and disposal or storage, depending on degree of contamination.
A.
additional restricted area was established north of the railroad right-of-way, characterized by a small creek that crossed the property and terminated in the NNFD canal.
It was determined to be impractical to remove the railroad tracks in order to replace the contaminated culverts running under the roadbed and carry out other extensive decontamination within the right-of way.
License conditions were proposed and included in the license which required that:
Condition 22:
An annual survey shall be made of direct radiation of water channel (culverts passing under Chesapeake & Ohio Railroad spur and main line) passing through the railroad right-of-way to assure that radioactivity is not migrating
5 from the LRC restricted area (hillside) or the culverts.
Condition 23 An annual direct radiation survey shall be made at the east end of the canal to detect migration of activity to the canal via the creek.
Condition 24 Accumulated water in the retention basin shall be sampled at least annually and if its activity exceeds 10*4 of the concentration specified in Appeadix B, Table 2, Column 2 of 10 CFR Part 20, the collected water shall be pumped to the liquid waste retention basins for disposal as low level radioactive wastes.
Condition 25 A restricted zone shall be established on the area north of the Chesapeake & Ohio main line right-of-way with a fence line based on radiation levels not exceeding an exposure' dose rate of 500 mR/yr.
The licensee's current survey program to implement License Conditions 22, 23, and 25 was implemented by Technical Procedure LRC-TP-273, Babcock & Wilcox Lynchburg Research Center Hillside Survey.
The survey was performed annually and consisted of direct surveys inside the culverts and the area of property directly adjoining the inlets and outlets of the culverts. The micro-R meter used for the surveys was placed on a tripod three feet above the ground for those surveys outside the culverts, and placed on a metal sled which was drawn through the culver"s by ropes to survey the interior of the culverts.
The most recent survey was conducted in November 1987.
Following is a summary of the results of the survey:
Range of Readings Location (Micro-R per Hour) 1.
LRC side of NNFD spurline, 12.0 - 16.5 railroad property 2.
NNFD spurline culvert, 13.3 - 30.5 railroad property 3.
Middle section of railroad 7.5 - 16.8 property (between spurline and mainline) 4.
Mainline culvert, 9.0 - 16.0 railroad property 5.
Lower side (north) of mainline, 9.7 - 13.9 railroad property
- e 6
6.
Creek from mainline to NNFD 9.5 - 49.0 canal, B&W property 7.
NNFD canal 6.0 - 25.8 B&W property Soil samples were taken from four of the above areas (locations 2, 3, 5 and 6 in above Table) and analyzed by gamma-ray specteoscopy by the LRC Radio-Analytical Chemistry Group. The results indicated that the highest concentrations of Uranium-234 and
- 235, Thorium-232, Radium-226, and Cesium-137 were in the area between the spurline and main line of the railroad (Location 3, in above Table); while the highest concentration of Cobalt-60 was found in the creek to the canal (Location 6, in above Table).
Uranium-238 was not detected; however, the Lower Limits of Detection (LLD) for this nuclide in these samples was rather high, ranging from 11.0 to 38.9 picocuries per gram (dry) of soil.
No violations or deviations were identified.
9.
Confirmatory Measurements (84844)
During the inspection in August 1987 (Report 87-02), the licensee agreed to compare results of liquid radwaste sample and an effluent particulate sample with the NRC.
The sample and the filter were collected, analyzed and sent to Region II in September 1987, along with the analytical results. The results of the comparison are provided as Attachment 1.
The criteria for comparison are provided as Attachment 2.
These comparisons were discussed with the licensee during the inspection.
No violations or deviations were identified.
10.
Inspector Followup (92701) a.
(0 pen) Inspector Followup Item (IFI) 87-02-01: Develop and implement procedures for reading pressure differential across HEPA filters and calculating activity in airborne samples. The inspector noted that, while the required calculations and measurements were being done, the procedures had not yet been completed (reference Paragraph 5, this report).
b.
(Closed) IFI 87-02-02:
Provide effluent samples and analysis for comparison. The samples and analyses were provided (see Paragraph 9, this report).
O ATTACHMENT 2 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS This attachment provides criteria for comparing results of capability tests and verification measurements. The cr teria are based on an empirical relationship i
which combines prior experience and the accuracy needs of this program.
In this criteria, the judgement limits are variable in relation to the comparison of the NRC Reference Laboratory's value to its associated uncertainty.
As that ratio, referred to in this program as "Resolution,"
increases, the acceptability of a licensee's measurement should be more selective. Conversely, poorer agreement must be considered acceptable as the resolution decreases.
RATIO =
LICENSEE VALUE NRC REFERENCE VALUE Resolution Agreement
<3 No Comparison 4-7 0.3 - 3.0 8 - 15 0.4 - 2.5 16 - 50 0.5 - 2.0 51 - 200 0.6 - 1.66
>200 0.75 - 1.33 i
AT T ACitMEN T 1
.NitQ (icergee Ratdo Re so l u t i o.r!
Qomparison (uci)
(oCi)
Liconsee/NRC filter Gross Alpha 7.5 t 1.4 E-7 2.25 E-7 0.3 5.36 Ag reement cross ticta 3.59 i 0.12 E-4 2.27 E-4 0.63 29.92 Ag reement IJquid (uci/mi)
(uci/mi)
Gross Alpha 1.9 t 0.3 E-7 2.60 E-7 1.37 6.33 Agreement Cror,s Beta 1.16 t 0.05 E-6 1.12 E-6 0.97 23.20 Ag reemen t i
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