ML20154N623

Insp Rept 70-1113/88-06 on 880411-15.No Violations or Deviations Noted.Major Areas Inspected:Radwaste Mgt & Radiological Environ Monitoring

ML20154N623
Person / Time
Site:	07001113
Issue date:	05/18/1988
From:	Kahle J, Stoddart P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20154N610	List: ML20154N604 ML20154N623
References
70-1113-88-06, 70-1113-88-6, NUDOCS 8806030021
Download: ML20154N623 (11)

Text

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MAY 191988 Report No.: 70-1113/88-06 Licensee: General Electric Company Wilmington, NC 28401 Docket.No.: 70-1113 License No.: SNM-1097 Facility Name: General Electric Company Inspection Conduc ed: A % 1 11-15, 1988 _

In'spector: hO M/

Date Signed P. V.qoYdW Approved by:

J. shle, Section Chief Mhdb '

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D/te61gned Di on of Radiation Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection was conducted in the areas of radioactive waste management and radiological environmental monitoring.

Results: No violations or deviations were identified.

I 880603o021 ADOCK 0700 880519 3

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REPORT DETAILS

.l. Persons Contacted _

Licensee Employees

• B. Bentley, Manager, Fuel Production W. Cameron, Supervisor, Shop Operations

• T. Crawford, Engineer, Environmental Protection R. Foleck, Senior Specialist, Licensing Engineering D. Hassler, Manufacturing Engineer, HVAC Systems S. Murray, Senior Engineer, Nuclear Safety

• C Vaughan, Manager, Regulatory Compliance

• P. Winslow, Manager, Licensing and Nuclear Materials Managemer Other licensee employees contacted included engineers, t< inicians, security force members, and office personnel.

Other Organizations M. White, Federal Paper Corp., Riegelwood (N.C.) Facility

• Attended exit interview

2. Exit Interview The inspection scope and findings were summarized on Apr'l 15, 1988, with those persons indicated in Paragraph 1 above. The inspe: tor described the areas inspected and discussed in detail the inspection findings listed below. No dissenting comments were received from the licensee.

The origin of the high radioactivity level found in the sanitary waste treatment sludge in the sample of August 1987 could not be positively identified; subsequent monthly samples were at normal levels. The combustible radioactive waste incinerator was operating satisfactorily and good progress had been made in reducing the inventory of waste stored on site. An increase in plant liquid effluent radioactivity for July-December 1987 was attributed to cleanout of the uranium waste recovery system lines. The environmental monitoring program was reviewed and the inspector, accompanied by licensee personnel, toured the Federal Paper Corporation waste treatment facility at Riegelwood, N.C.

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.

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4. Sanitary Sewage Sludge Sampling and Analysis (88035, 88045)

The inspector and licensee representatives discussed sampling and analysis of the plant sanitary sewage sludge. In the original site construction, the priraipal sanitary treatment system was a sewage lagoon. In 1974, the .

present packaged aerator treatment plant was installed and the use~ of the lagoon as the primary sanitary waste treatment facility was discontinued.

Sludge accumulations from the aerator treatment plant have been spread on the former waste treatment lagoon since 1974. In inspection report No. 70-1113/87-12, a summary of sludge analyses for 1987 was presented.

In that report, the value given for the August sample was abnormally high

-- 1.3 ppm U in the wet sludge and 278 ppm V in the dried material. The licensee resampled the sludge in September but the sample's radioactivity level was in the normally occurring range. The licensee could not offer an explanation for the high value. It was noted that the time period coincided with the cleanout of the uranium recovery system lines (see Section 6 for discussion) but no definite correlation could be made.

Analyses of samples taken since August 1987, are tabulated below, with the earlier 1987 results also shown for reference.

Table 1 i Sanitary Sludge Sample Analysis Results Date of Sample Wet Sludge (ppm V) Dried Material (ppm U)*

March 14, 1988 0.01 2.82 March 2, 1988 0.06 10.36 January 21, 1988 0.02 6.33 December 10, 1987 0.16 23.20 October 19, 1987 0.24 64.10 September 30, 1987 0.21 39.00 August 6, 1987 1.30 278.00 July 2,1987 0.05 10.2 June 4, 1987 0.06 20.0

• Note: At an average enrichment of 2.5% (U-235),1 ppm of uranium equates to approximately 1.57 pCi/g.

The sludge spreading area was visited by the inspector in the company of a licensee representative. The conditions at the sludge spreading area appeared to be similar to those observed during the August 1987 inspection. There was an estimated six inches of water standing in the i

low spots at one end, vegetation was in good condition and several small

wading birds were seen actively utilizing the area. The area is enclosed I

by a six to eight foot high earthen berm on all sides.

l The licensee representative stated that no samples of the accumulated material (dried sludge) had been taken or analyzed over the past several years. In view of the NRC's concern over the reconcentration effects l

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3 detected in the sewage treatment facilities at other plants, the licensee representatives and the inspector discussed the benefits of collecting and analyzing a representative sampling of - the accumulated material for -

uranium content. At the exit meeting, licensee representatives committed to sample and analyze the gross alpha activity and uranium content of at

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least three sludge samples taken at random from the sludge spreading area.

The sample analyses will be reviewed during a future inspection.

(0pened) Inspector Followup Item (IFI): 70-1113/88-06-01: Review results of analyses of samples from sludge spreading area.

No violations or deviations were identified.

5. Incinerativ., of Combustible Radioactive Waste and Reduction of Volume of On-Site Storage of Radioactive Waste (88035)

The inspector and licensee representatives discussed the licensee's operational experience with the combustible radioactive waste incinerator since the August 1987 inspection. From August 1,1987 through March 31, 1988, the incinerator was out of service for approximately four weeks:

one and one-half weeks for replacement of bag filters with a new type bag filter and a total of about two and one-half weeks in two segments for maintenance involving re-working of the water injection distributor. For the remainder of the period, the facility was operated on a 24-hour per day, five days a week schedule.

For CY 1987, 2,071 boxes were incinerated out of a scheduled 2,105 boxes.

For the first three months of CY 1988, 491 boxes were incinerated. During CY 1987, 538 boxes of waste were generated, which was 350 boxes less than estimated at the start of CY 1987, largely as a result of improved procedures in the consolidation and packaging of waste and an intensive waste reduction program.

The difference between CY 1987 figures of 2,071 boxes incinerated while only 538 boxes were generated, represented an overall reduction of 1,533 boxes in the inventory of boxes of waste stored onsite. As of January 1, 1988, the backlog of stored boxes was 1,626. As of April 10, 1988, that number had been reduced to 1,254. At the rate of incineration experienced since January 1, 1988, a licensee representative calculated that the existing backlog of stored boxes could be eliminated by the year's end and that only current generation boxes less than 3-months old would remain.

The inspector and licensee represtatatives also toured the waste box storage pads. The inspector noted that the boxes which had been in the worst condition at the time of the last inspection had been taken for incineration and that while a small number of boxes exhibited visible evidence of deterioration, the overall conditions were substantially improved.

No violations or deviations were identified.

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6. Review of Radioactive Effluent Release Report (88045)

The inspector reviewed the licensee's semi-annual Radiological Effluent Release Report for July - December 1987, and discussed the report with licensee representatives. The report appeared to be complete and was re:ponsive to the requirements of 10 CFR Part 70.59 and of the License Application.

In comparing the report data with previous reports, the inspector noted that the July-December 1987 liquid effluent release values were higher than values listed in the five previous semi-annual reports (a factor of 2.6 times the 6-month average, January 1985 through Jene 1987, and a factor of 4.8 times the January -

June 1987 releases). Licensee representatives stated that the increase had been attributed to maintenance cleanout operations involving a clogged process drain line from the uranium waste recovery system (formerly referred to as "U-Pump")

in late July and early August 1987, during the scheduled annual plant shutJuwn. The inspector noted that while the release rates were above an administrative action level and were above normal operational release rates, the relesses were within regulatory limits.

Paragraph 5.1.2.3, "Action Levels for Liquid Effluents," of Chapter 5, Part I, of the license application specified action levels for chemical uranium concentration in effluents from the final process layouts at two parts per mi' lion (2 ppm) daily average for a month and five parts per million (5 p;m) for any one daily sample. Action level on radioactivity concentratien was specified as 3E-05 uCi/ml gross alpha activity for a weekly comp; site. Paragraph 5.1.2.3 also noted that 2 ppm of uranium at a typical en ichment would equate to approximately 10% of the 10 CFR Part 20 value of P,E-05 uCi/mi annual average for release to an unrestricted area.

The licensee records for monthly averages of daily uranium analyses showed 0.973 parts per million U for July 1987 and 0.889 parts per million U for August 1987. Based on the soove, the July and August monthly averages equated to less than 5% of the 10 CFR Part 20 value for release to an unrestricted area.

When the daily action levels for uranium content were exceeded, licensee actions included tracing the source of the activity to the uranium waste recovery system cleanout operations and to treatment to neutralize the residual acid-bearing stream to minimize the soluble uranium content of fluids entering the final treatment lagoon.

No violations or deviations were identified.

7. Inspector Visit to Riegelwood Facility of Federal Paper Company (88045)

The inspector, accompanied by two licensee representatives, toured the biological waste treatment facility at the Riegelwood, North Carolina plant of the Federal Paper Company on April 14, 1988. Piragraph 5.1.4.2, of Chapter 5, Part I, of the license application "Treatrd Nitrate Waste,"

authorized the licensee to transfer nitrate solutionr from the onsite

5 nitrate lagoons, by means of tank truck, to the biological waste treatment facility of the Federal Paper Company, Nitrate bearing liquid waste was produced at the licensee's facility as a result of the treatment of metal finishing operation solutions and nitrate wastes from uranium processing operations. These wastes were pumped two or more times daily from the nitrate lagoon into a semi-trailer tank truck. ' A grab sample was taken from each shipment and analyzed for uranium content before approving release of each shipment from the licensee's site. A composite of grab samples from each day's shipments was prepared for additional uranium analysis and a weekly composite was analyzed for gross alpha activity. Action levels and administrative actions were as follows:

Sample Type Action Level Action Each truck >25 ppm U Investigate cause Each truck >50 ppm U Stop shipment Daily Composite >3 ppm U Investigate 30 Day Composite of Daily Composites >3 ppm U Investigate Individual truck samples were analyzed prior to shipment for uranium with a LLD of 10 ppm U and action levels of 25 ppm and 50 ppm. A more precise analysis was made on daily composites with a LLD of 0.02 ppm. The LLD for gross alpha analysis of weekly composite samples was SE-09 uCi/ml.

The inspector and the two licensee representatives were accompanied by Mr. M. White of Federal Paper on a tour of the biological waste treatment system at the Riegelwood, North Carolina, facility of the Federal Paper Company. The tour included the truck unloading connection to the plant canal leading to the waste treatment system, the primary treatment clarifier pand, the "New Bay" lagoon, the "North Basin" lagoon, and the outfall to the Cape Fear River. The lagoons, in total, had a surface area of approximately 200 acres and were estimated to contain on the order of 750 million gallons of water.

The licensee's environmental monitoring program included the Federal Paper Company's waste treatment facility, where water and sludge samples were collected quarterly. Water samples were analyzed for gross alpha activity and for gross beta activity. Sludge samples were analyzed for gross alpha activity, gross beta activity, and for total uranium. Sludge samples for 1987, were analyzed at 0.2 ppm to 1.6 ppm total uranium. LLD for total uranium was given as 0.02 ppm and action level as 5 ppm. No pattern was evident in dried sludge samples, with values of 0.6 to 1.6 ppm being seen from one area (April 1.4 ppm V, July 0.6 ppm V, and October 1.6 ppm V).

Radioactivity concentrations for gross alpha activity in sludge ranged from less than 6 pC1/g to 23117 pCi/g and beta activity ranged from 6!3 pCi/g to 24 8 pCi/g. Typical levels of alpha and beta activity from naturally occurring environmental uranium and thorium in soil are on the order of 10 to 30 pCi/g.

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No violations or deviations were identified.

8. Audits (88045)

Paragraph 2.8.2, "Environmental Protection Internal Audits" of Chapter 5, Part I, of the license application provides for. annual internal audits of the environmental protection function to ensure that the operational activities conform to documented environmental requirements. Radiation safety programs were audited at two year intervals by an "appropriate function outside of the WMD organization." Waste management and environmental monitoring were considered to be part of radiation safety programs.

-No external audits had been performed in the waste management area since the data of the previous inspection of August 1987.

Internal audits within the scope of this inspection included an audit of the licensee's contract analytical laboratory, Teledyne Isotopes, on March 25, 1987, and reported in an audit report dated April 8,1987. No adverse findings or concerns were reported.

Audit report EP8701, dated December 23, 1987, was an internal audit report covering the packaging of radioactive waste boxes and drums, and the segregation of hazardous and low level radwaste. No findings were reported.

The audits appeared to be thorough and of adequate depth. In that no findings were reported, no assessment was made of management response to audit findings, No violations or deviations were identified.

9. Environmental Monitoring Program (88045)

The inspector reviewed the licensee's environmental monitoring program and discussed the results of the sampling and analysis program with licensee representatives. It was noted that the individual tho had served as the environmental program manager for several years had retired as of January 1988, and that a staff engineer had been assigned temporary responsibility for the program. A senior staff representative informed the inspector that a permanent appointment would be made soon from a list of qualified persons.

In reviewing program records and reports, the inspector noted that the licensee had initiated an atmospheric contamination particle sizing program. The program was triggered by Paragraph 5.2.1.2, "Sampling and Measurement," of Chapter 5, Part I, of the license application, which provided that if the results of the ambient air sampling station program indicated a quarterly airborne uranium concentration of greater than 3.45 E-15 uC1/ml, that within 30 days af ter receiving the analytical results, an air sampling program would be instituted at the site boundary in the

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7 direction of the nearest resident to determine the particle size distribution of radioactive material with a cascade impactor of multiple stages covering respirable and nonrespirable particle size ranges. Over the December 1987 to January 1988 time frame, "running" quarterly airborne uranium concentration values approached, but did not exceed 3.45 E-15 uCi/ml; in that the trend for January was apparently increasing, the licensee initiated the sampling program as a precaution. Results as of the date of this inspection were inconclusive and sampling was being continued.

All required soil, air, surface water, sludge, nitrate waste stream, and groundwater samples appeared to have been taken in accordance with the program set forth in Table 5.1 of Chapter 5, Part I, of the License Application. In cases where certain samples exceeded action levels, appropriate actions appeared to have been taken.

Certain aspects of the environmental monitoring program were discussed in detail in other sections of this inspection report (See Sections'4, 6, 7, 4 and 8).

No violations or deviations were identified.

10. Confirmatory Measurements (84844, 88045)

During the inspection of August 24-27, 1987, (70-1113/87-12), the inspector requested the licensee to submit split samples representing two effluent stack air sampler filters and two liquid process effluent samples. Samples were received by NRC on or about September 15, 1987, and were forwarded to NRC's contract laboratory for analysis. Sample analyses were completed October 16, 1987.

The samples, as analyzed by both the licensee and by the NRC contract laboratory, contained extremely low radioactivity values. Two air samples, identified as CHMSX and CHMN, initially contained both airborne particulate uranium and radon decay particulates. The licensee analyses were performed approximately 12 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after completion of sampling.

The 'NRC contract laboratory analyzed the samples approximately 60 days later. The licensee also submitted three liquid samples.

In that all of the sample analyses by both laboratories showed quantities I of uranium or of gross alpha activity at near-background levels, the statistical criteria normally employed by the NRC for comparisons of gamma i

emitters by gamma spectrometry were not considered applicable, devertheless, criteria of NRC Module 847118, issued March 31, 1976, were utilized as a rough measure of comparability. The relative data are provided in Attachment 1, with the criteria of NRC Module 84711B provided in Attachment 2.

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8 l It was noted that while using a table of criteria not recognized as l applicable to chemical uranium and gross alpha determinations, the  !

licensee was in agreement with the NRC laboratory in 3 out of 5 measurements. In the case of Uranium Air Sample CHMSX, the decay time of two months was considered more than sufficient to produce the factor of 5 differential between the licensee and NRC lab results; therefore, the NRC does not consider a disagreement determination to have been made on a valid statistical basis and no comparison was made. The Uranium Liquid-Outlet Lab sample was analyzed by the licensee at a lower limit of detection (LLD) of 1 ppm, whereas the NRC contract lab analyzed at a LLD of 0.07 ppm; no comparison was made because of differences in the analytical techniques employed.

On the basis of the above discussion, the licensee's laboratory analyse's of the five samples submitted were considered acceptable.

(Closed) Inspector Followup Item (IFI) 70-1113/87-12-01, Compare analytical results of split sample analyses by GE and by NRC contract lab and inform licensee of correlation of results. On the basis of the above discussion, this matter is considered closed.

No violations or deviations were identified.

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ATTACHMENT 2 Criteria For Accepting the Licensee's Measurements

Reference:

NRC Procedure Module 84711 B, Issue Date March 31, 1976 l l

I This attachment provides criteria for comparing results of capability tests and I verification measurements. The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this program. '

In these criteria, the judgement limits denoting agreement or disagreement between licensee and NRC results are variable. This vtriability is a function of the NRC's value relative to its associated uncertainty, referred to in this program as "Resolution" increases, the range of acceptable's differences between the NRC and licensee values should be more restrictive. Conversely, poor agreement between NRC and licensee values must be considered acceptable as the resolution decreases.

For comparison purposes, a ratio of the licensee value to the NRC value for.

each individual nuclide is computed. This ratio is then evaluated for agreement based on the calculated resolution. The corresponding resolution and calculated ratios which denote agreement are listed in Table 1 below. Values outside of the agreement ratios for a selected nuclide are considered in disagreement.

Resolution = NRC Reference Value for a Particular Nuclide

-Associated uncertainty for the Value Comparison Ratio = Licensee Value NRC Reference Value TABLE 1 Confirmatory Measurements Acceptance Criteria Resolutions vs. Comparison Ratio These criteria are applicable to gross beta measurements where samples are counted on the same date using the same reference nuclide.

Comparison Ratio Resolution for Agreement

<4 No comparison 4-7 0.3 - 3.0 8 - 15 0.4 - 2.5 16 - 50 0.5 - 2.0 i 51 - 200 0.6 - 1,66

>200 0.75 - 1.33 i

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