ML20154P466

Insp Rept 70-1151/88-06 on 880425-29.No Violations or Deviations Noted.Major Areas Inspected:Counting Room QC & Confirmatory Measurements,Radwaste Mgt & Environ Monitoring

ML20154P466
Person / Time
Site:	Westinghouse
Issue date:	05/20/1988
From:	Adamovitz S, Kahle J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20154P464	List: ML20154P459 ML20154P466
References
70-1151-88-06, 70-1151-88-6, NUDOCS 8806030343
Download: ML20154P466 (10)

Text

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UfJITED STATES

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%, ...../ NAY 2 01988 Report No.: 70-1151/88-06 Licensee: Westinghouse Electric Corporation Commercial Nuclear Fuel Division Columbia, SC 29250 Docket No.: 70-1151 (Fuel Division) License No.: SNM-1107 Facility Name: Westinghouse Electric Corporation Inspection Conducted: April 25-29, 1988 Inspector:C [c/Ut 6 V8

<v S.,4. Adamovitz Date Sfgne~d Approved b : W j(dli 9M7 J. B. (ahle, Section Chief Date Sfgned Div on of Radiation Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection was conducted in the areas of counting room quality control and confirmatory measurements, radioactive waste management, and environmental monitoring Results: No violations or deviations were identified.

8806030343 880520 PDR ADOCK 07001151 C DCD

i REPORT DETAILS

1. Persons Contacted -

Licensee Employees K. R. Bartsch, Health Physics Technician

• R. E. Fischer, Senior Engineer, Radiological and Environmental Engineering

• W. L. Goodwin, Manager Regulatory Af f airs

• J. W. Heath, Manager, Health Physics Operations

• E. E. Keelin, Manager Manufacturing

• E. P. Loch, Plant Manager R. D. Montgomery, Regulatory Engineer, Criticality Safety E. R. Reitler, Manager., Radiological and Environmental Engineering R. D. Young, Supervisor, Instrument Department

• Attended exit interview

2. Exit Interview The inspection scope and findings were summarized on April 29, 1988, with those persons indicated in Paragraph I above. The inspector described the areas inspected and discussed in detail the inspection findings. No dissenting comments were received from the licensee. The licensee identified the material provided to or received by the inspector which was proprietary.

3. Audit (88035, 88045)

License Application, Section 3.1.2.3 Item 7, states that the Radiation Protection Component shall be responsible for audits of licensed activities for compliance with applicable State and Federal regulations, licenses and permits and documentation of these audits to facilitate corrective actions. The inspector reviewed the following in-house audit reports:

1) Audit of Environmental Program, December 29, 1987

2) Audit of Effluent Program December 30, 1987 The inspector noted that significant plant modifications were documented.

Audit findings were identified and resolved, though informally documented and tracked. The licensee conducted biannual audits of vendor laboratories. The last vendor audits were performed in December 1986, and were documented in a previous inspection report (70-1151/87-13).

No violations or deviations were identified.

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4. - Procedures-(88035,-88045,84844)

License Application, Section 3.2.1, states that written procedures describing general radiation protection requirements shall be maintained and followed. The inspector _ reviewed selected parts of the following procedures:

a. RA-211 Low-Level Radioactive Waste Responsibilities, Rev. 4, March 30, 1987

b. RA-401 Environmental Control Requirements Mandated by 10 CFR 20, Rev. 1, April 25, 1984

c. HP-05-004-A Determining Alpha Activity of a Water Sample (Any Sample in Liquid State) Rev. 3, February 26, 1986

d. HP-05-037 HEPA Filter System Leak Test, Rev.1, March 3,1981

e. HP-05-056 Air Sample Systems . Integrity Verification, Rev. 3, January 14, 1987

f. HP-01-026 Tennelec Background and Ef ficiency Operation, Rev. O, August 22, 1986

g. HP-06-002 Roof Effluent Air Sampling and Counting, Rev 5, April 13, 1984

h. HP-06-003 Ambient Environmental Air Monitoring for Radioactivity, Rev. 3, February 18, 1986

1. HP-06-006 Collection of Routine Weekly and Monthly Environmental Samples, Rev. 3, May 23, 1983

j. HP-05-001 Preparation and Analysis of Inplant Air Samples, Rev. 6, I September 9, 1987  :

k. HP-01-025 Calibration of Tennelec LB5100 Automatic Sample Cou>ters, Rev. 1, August 22, 1986

1. MCP-202035 On-Line Monitor Calibration, Rev. O, March 11, 1988 The inspector noted that procedures were being reviewed and approved by l licensee management.

L No violations or deviations were identified. l l

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5. Records (88035, 88045, 84844)

a. The inspector reviewed selected parts of the following recordt:

1) Summary Effluent and Environmental Monitoring Reports, January 1987 - January 1988

2) Filtration System Pressure Status, January - April 1988

3) Controls for Environmental Pollution (CEP) Analytical Results for Environmental and Effluent Samples, January 1987 -

March 1988

4) In-Place HEPA Filter Test (DOP), June 1987 - April 1988

5) Tennelec Data Sheet for Counters 1-6, Daily Source Checks, January 1987 - April 1988

6) Columbia Plant ALARA Reports, January 1 - June 30,1987, and July 1 - December 31, 1987 Results of the record review were discussed with cognizant licensee representatives as noted in Paragraph 5.b.

b. In reviewing the In-Place HEPA Filter Test (DOP) log, the inspector noted that the December 16, 1987 test results for the incinerator mill system were documented as 0.4% and passing. Procedure HP-05-037 HEPA Filter System Leak Test, Rev. 1, March 3, 1981, specified that a filter must pass a 0.05% leak test using a DOP smoke detector. The inspector also examined the original work order for this system and noted that the D0P test results were recorded as 0.4%. Discussions with cognizant licensee representatives indicated that the system was an in plant recirculating exhaust system and not an effluent system.  !

The system had subsequently been tested eleven times since the December 16, 1987, measurement and all results were within acceptance j criteria. Licensee representatives also interviewed the technician 1 that performed the December 16 measurement, and indicated that the j technician was aware of the correct acceptance margin. The inspector '

reviewed the past twelve months of data for the in place HEPA filter tests and found no other discrepancies. The inspector discussed current management review and data control with licensee representatives. The licensee agreed to evaluate and implement additional controls for data management.

No violations or deviations were identified.

6. Effluent Release Reports (88035)

a. 10 CFR 70.59 requires the licensee to submit a report to the NRC Region II office within 60 days af ter January 1 and July 1 of each year specifying the quantity of each of the principle radionuclides

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4 released to unrestricted areas in liquid and gaseous effluents during the previous six months of operation. 10 CFR 20.106 G requires licensees engaged in uranium fuel cycle operations to be subject to 4

40 CFR 190 which limits the annual whole body dose to any member of the public to 25 millirem.

The inspector reviewed the effluent reports for the periods covering January 1 - June 30, 1987 (dated Aegust 18, 1987) and~ July 1 -

December 31, 1987 (dated February 16, 1988). The table below summarizes 1985 - 1987 effluent data and annual air doses to the nearest resident. The dose summaries were extracted from plant ALARA reports.

Effluent Summary for Westinghouse Activity Released (microcuries)  ;

1985 1986 1987 I Gaseous Effluents 1536 1505 1399 j Liquid Effluents 246,200 111,171 57,164 Lung Dose to the Nearest Resident Infant (millirem) 2.5 2.7 2.5 From 1985-1987, the annual lung dose to the nearest resident averaged

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4 2.56 mrem which was 10.3% of the 25 mrem federal dose limit. In reviewing the liquid effluent data the inspector noted that the microcurie qJantity peaked in 1985, and had been steadily declining  :

since then. Licensee representatives attributed the higher 1985 i liquid effluents and subsequent decrease to several factors.  !

Westinghouse's highest production year was 1985, and the increased .

production would have resulted in higher discharges. The licensee  !

also began an investigation in early 1986, to evaluate the processing .

of the contaminated waste streams and determined that small amounts l of liquid waste were not being reprocessed in the advanced wastewater treatment system. The licensee management checked various onsite laboratories and operations groups and emphasized the importance of recycling all liquid wastes in order to minimize effluents. Liquid effluents were also decreased by installation of .a 30,000 callon holding tank for liquid waste treatment during the latter ...lf of i 1985. The new tank, which replaced a 10,000 gallon tank, utilized an improved Cuno filter, and the increased capacity and better filter performance improved waste processing. A third factor that

contributed to the decrease in liouid effluents was that the waste

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flow pattern was modified to incluue an additional lagoon, the East Lagoon, rather than direct discharge. The licensee also began reprocessing liquid effluents from the molybdenum boat decontamination process and in 1986, initiated offsite boat decontamination by a vendor.

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b. The inspector calculated the uranium enrichment for liquid effluents and noted an apparent discrepancy for the 1983 data. Typical enrichment values ranged from 2.6 to 5.6% with the exception of the -

1983 data which was calculated to be 14.6%. Licensee. representatives indicated that the microcurie quantity of U-238 was incorrettly reported in the January - June 1983, semiannual report due to a ,

typographical error. The reported value was 3178 uCi U-238 but the  ;

correct value was 11731 uCi: Utilizing the new data, the effective  ;

enrichment was calculated to be 4.43%, which was in the range of other values. The inspector discussed submitting a corrected semiannual report-with licensee representatives. The licensee agreed to submit the corrected values with the next routine semiannual report, and the inspector emphasized the importance of notifying the NRC of erroneous data in a timely manner.

No violations or deviations were identified.

7. Radioactive Waste Management (88035)

The inspector and a licensee representative discussed waste management and

! toured the liquid waste treatment facility. Prior to exiting the plant, radioactive liquid waste was held in a series of quarantine tanks, and an ,

online monitor was set to alarm at 0.8 MPC (10 CFR 20, Appendix B, Table II, Column 2), and divert flow at 1.2 MPC. Liquid wastes from the ammonium diuranate (ADU) process and the manufacturing automation process (MAP) were then routed to the advanced wastewater treatment system where uranium was removed to levels less than 1 ppm. The recovered uranium was ,

routed back to the plant for manufacturing purposes. A small amount of -

a sludge (approximately one 55 gallon drum per month) was generated by the advanced treatment process, and this sludge was packaged as radioactive  !

waste mater'.al and sent for burial at a licensed facility. Upon exiting '

the advanced wastewater treatment plant, the liquid waste was treated with calcium hydroxide to increase pH and form an insoluble precipitate, calcium fluoride (CaF2 ). Amm nia was removed from the liquid waste by distillation and routed back to the ADU process stream. The slurry bottoms, insoluble calcium fluoride, from the distillation process were  !

routed to lagoons for settling of the solids. The liquid supernate, after pH adjustment, chlorination and aeration, was discharged to the Congaree l River. Disposal of the calcium fluoride sludge had been handled by several different methods over the past years. Prior to 1981, and i installation of the advanced wastewater treatment system, the calcium  !

1 fluoride, contaminated with uranium, was fixed with a cement-like binder

and buried at a low-level radioactive waste burial site. After the 3

advanced wastewater treatment was installed, which decreased the uranium concentration in the sludge to less than 30 pCi/ gram, the licensee

obtained a license amendment (dated January 29, 1982) which allowed disposal of the CaF sludge ir a chemical or sanitary landfill. The 2

inspector reviewed state-issuec' permits which indicated that the licensee i had made two shipments of CaF 2 sludge to a chemical landfill--one shipment j j in 1982, another in 1985. Af.er two shipments to the chemical landfill, j the licensee obtained another licensee amendment (dated April 24, 1987) to '

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6 allow distribution of the calcium fluoride as a product material to a briquetting company.

The inspector and a licensee representatives ~also examined various gaseous  ;

effluent release points and discussed-system maintenance. The plant had a ,

total of 38 release stacks and radioactivity in gaseous effluents was -

controlled primarily by the use of HEPA filters. Some ventilation systems

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also used pre-filters and-intermediate filters in conjunction with the HEPA filters. _ Gaseous effluent sampling was accomplished by an isokinetic probe in each release stack, which continuously drew a sample through a fiberglass filter paper. The papers were changed on a 24-hour basis and counted for gross alpha. Any system that exceeded MPC (10- CFR 20, Appendix B, Table II, Column 1) for four consecutive samples, the source operation was required to be shut down and the cause of the increased effluent activity identified.

No violations or deviations were identified.

8. Followup on Licensee Incident Reports (88035)

In a letter dated November 24, 1987, to the NRC Region II, the licensee d

described the failure of the incinerator exhaust fan on November 21, 1987.  :

The fan failure resulted in metal fragments piercing the fan housing and external ductwork damage. The inspector discussed the incident and subsequent corrective actions with licensee representatives. Since the ,

incinerator exhaust HEPA filters were not damaged, there' was no significant release of radioactive material to the environment. The licensee determined that the cause of the fan failure was stress corrosion of the 304 stainless steel alloy by acidic vapor. The damaged fan was replaced with the original carbon steel fan and a new carbon steel epoxy-coated fan was ordered.

The licensee expected to install the  ;

1 epoxy-coated fan by the summer 1988. Following installation of the new

fan, a protective shroud was to be erected around the fan housing to shield metal fragments in case of a second fan failure.

No violations or deviations were identified.

9. Environmental Program (88045)

The inspector reviewed selected procedures, analytical results, and count room records with cognizant licensee representative and determined that the organizational structure and program management had not changed since the previous inspection (70-1151/87-13). Environmental sample collection  ;

was primarily the responsibility of Health Physics Operations with the 1 exception of monthly surface water samples which were collected and analyzed by a vendor. Other environmental samples were shipped to a

, second vendor for analysis.

The inspector toured several environmental sampling stations including air, surface water, well water and fallout stations. The inspector noted i i

4 all air sampling stations were operational and calibrated. ,

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7 No. violations or daviations were identified. ,

10. Confirmatory Measurements (84844)

The results of the analyses of the split -samples collected during the -

previous inspection (70-1151/87-13) were discussed with licensee representatives (see -Attachment 1). It was noted that the licensee's gross alpha results for the stack particulate filters were consistently higher than the NRC'results. The licensee and the NRC counted the same -

filter paper sample and often one to two months' transit time elapsed prior to the NRC analysis. The NRC's consistently lower analytical results could be partially attributed to isotopic decay. Analytical results for the liquid effluent sample were all in agreement with the -

exception of U-234. Since the liquid and gaseous effluent ' samples contained such small amounts of radioactivity, the licensee agreed to  :

split a single liquid process sample which would contain higher _ levels of '

radioactivity. The liquid process sample would be taken _ near the quarantine tanks and analyzed for gross alpha, gross beta, and isotopic uranium. The licensee agreed to provide the NRC RII office with the analytical results in a timely manner. The inspector informed licensee -

representatives that comparison of the licensee /NRC analytical results 1 would be considered a followup item and_ reviewed in a future inspection. '

(0pened) 70-1151/88-06-01 (IFI) Compare NRC/ licensee analytical results for a split process sample.

11. Followup Items (92701)

(Closed) IFI 87-13-01: Compare results of NRC and licensee analyses of split samples. The results were compared and discussed with licensee representatives (Paragraph 10). This item is considered closed.

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l ATTACHMENT 1 l CONflRMA10RY MEASUREMENT COMPARISONS Of STACK .

I PARTICULATE flLTER AND LIQUID EFFLUENT SAMPLES WESTINCHOUSE - COLUMBIA PLANT - APRIL 1988 l

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l . Ratio SQmpp NRC Analysis Licensee Analysis Resolution Licensee /NRC Compa ri so3 Stock Particulate uCi/ unit uCi/ unit I f i l te r:

gross a lpha 8.811.8 E-7 6.53 E-6 5 7.4 No compa ri son Liquid Effluent gross a lpha 9.911,7 [-7 3.04 E-7 6 0.31 Ag reement gross beta 7.910.5 E-7 5.08 E-7 16 0.64 Agreement U-234 7.110.4 E-7 2.18 E-7 18 0.31 Di sag reement 4-235 2.911.5 E-8 8 E-9 2 0.28 No comparison U-238 1.40f0.14 E-7 7 E-8 10 0.50 Ag reement

1. Samples were collected September 1987

A ATTACHMENT 2 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS

,i This enclosure provides criteria for comparing results of capability testE and verification measurements. The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this program.

In this criteria, the judgement limits denoting agreement or disagreement .

between licensee and NRC results are variable. This variability is a function '

of the NRC's value to its associated uncertainty referred to in this program as "Resolution"1 increases, the range of acceptable differences between the NRC and licensee values should be more restrictive. Conversely, poorer agreement i.

between NRC and licensee values must be considered acceptable as the resolution decreases.

l For comparison purposes, a ratio 2 of the licensee value to the NRC value is i computed. This ration 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 are considered in disagreement.

' 2 Resolution = NRC Reference Value Assoc 1Efid Uncertainty for the Value

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2 Comparison Ratio = Licensee Value NRC Reference"Vilue TABLE 1 Confirmatory Measurements Acceptance Criteria For Gross Beta 'and Gross Alpha Measurements Resolutions vs. Camparison Ratio 1

Comparison Ratio for Resolution Agreement >

< 4 no comparison 1 4- 7 0.3 - 3.0

) 8- 12 0.4 -

2.5

! 16 - 50 0.5 -

2.0

, 51 - 200 0.6 -

1.66

>200 0.75 - 1.33 e

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