ML20203J530
| ML20203J530 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 02/13/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20203J511 | List: |
| References | |
| 70-1151-98-01, 70-1151-98-1, NUDOCS 9803040173 | |
| Download: ML20203J530 (27) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION !!
I Docket No.: 70 1151 i
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' License No.: SNM 1107 Report No.: 70-1151/98 01 !
i Licensee: Westinghouse Electric Corporation '
t Facility Name:
Commercial Nuclear Fuel Division Date: January 12 16, 1998 Inspectors: S. Chotoo. Environmental Engineer W. Gloersen Senior Fuel Facility Inspector
-A. Gooden, Radiation Specialist Approved by: E. J. McAlpine, Chief Fuel Facilities Branch - ;
. Division of Nu:: lear Materials Safety -
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P A kO ff51 _ Enclosure C pon _
Executive Summarv Commercial Nuclear Fuel Division NRC Inspection Report 70 1151/98 01 The primary focus of this unannounced inspection was the observation of work activities and evaluation of the licensee's radiation protection, environmental protection, and radioactive waste management programs. The ,
report includes inspection efforts of two regional based inspectors and a headquarters licensing engineer. The inspection identified the following aspects of the licensee programs as outlined below: !
RADIATION PROTECTION l
- The licensee's manual system for tracking radiation protection instruments lacked details regarding instrument locations and was tedious, but functional (Paragraph 2.b.).
- The licensee's external and internal Exposure control programs were adequate for evaluating, and monitoring personnel exposures: and the-controls were in place to maintain exposures less than 10 CFR Part 20 limits (Paragraphs 2.c. and 2.d.),
- IM maximum assigned total effective dose equivalent (TEDE) for calendar ye e (CY) 97 (3.04 rem) was less than CY 96 (3.49 rem); and the reduction was attributed to the combination of various engineering controls, equipment modifications, and reduced material throughput (Paragraph 2.c.).
- The occupational exposure in 1997 (187.6 rem) based on estimated fourth quarter thermoluminescent dosimeter (TLD) data and annual internal results was significantly less than the 1996 results of 276 person rem (Paragraph 2.c.).
- The licensee's program for controlling dose to an embryo / fetus was adequate and met the intent of 10 CFR 20.1003 regarding a woman voluntarily declaring her pregnancy (Paragraph 2.c.).
- The respiratory rotection training video still re This was initially idhntified by NRC in September 1996 fuires updatin?).
Paragraph 2.e .
+ Housekeepin improvements were necessary as evidenced by the discovery of improper stored used shoe covers and full face respirators (Paragraph .f.). i ENVIRONMENTAL PROTECTION
- A violation of minor environmental concern was noted for the failure to establish action levels by procedure for certain environmental samples (Paragraph 3 b.3).
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- Analytical results from the various environmental samples collected indicated that there was no radioactive material from accumulating or concentrating at the sample location Paragraph(plant operations3.c.3).
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- The licensee's decommissioning recorde and files were well organized, j maintained, end detailed (Paragraph 3.e.3).
I WASTE MANAGEMENT l
- The licensee had enerienced higher than normal gross alpha !
concentrations in tie liquid-effluent discharges which were attributed l to a decrease in the pH in the East Lagoon, thus driving the uranium
- back into solution and discharged (Paragraph 4.a.3). )
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- The-licensee's notification of the liquid effluent line break event to the onsite--inspector was timely and the action plan developed by the ;
j licensee _was appropriate (Paragraph 4.b.3).
- Stack sample delivery line concerns were noted (Paragraph 4.c.3),
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- The licensee was proactive-in planninq for a capital project to replace
- the filtering ~ system associated U 0cHF strip exhaust with a more j efficient system (Paragraph 4.c.33.
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Attachment:
4-Persons Contacted and Exit Interview List of items Opened. Closed, and Discussed
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4 Reoort Details t
- 1. Summary of Plant Status
.This report covered a one week period. There were no unusual plant operational occurrences during the onsite inspection.
- 2. RadiationProtection(83822)(R1)
- a. Radiation Protection Proaram Procedures (R1.02)
(1) Insoection Scone l
Procedure changes were reviewed to determine the effectiveness on the program, and verify that changes met license conditions and requirements in 10 CFR 20.
(2) Observations and Findinas Several procedures that were revised since the last inspection (February 1997) were reviewed, and no concerns were identified. Changes included the addition of shoes and shoe covers to the periodic contamination surveys: the procedure for personnel conducting surveys on radiation producing machines was clarified regarding the appropriate survey instruments to utilize: and the frequency for a respirator medical exam was changed for consistency with the federal guidance.
(3) Conclusions The selected procedural' revisions were considered as procedural enhancements and continued to implement the radiation protection program in a manner consistent with the license and regulations,
- b. Radiation Protection Proaram Eauioment (R1.03)
(1) Insoection Scoce calibration, and The inspector maintenance reviewed of equipment the operability,f to determine i equipment was adequately maintained and reliable to perform the intended
-safety function.
(2) Observations and Findinas A random number of fixed air sampling locations were observed and samplers were found operational and ficw rates were within set points. Instruments were checked for
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operability, current calibration-sticker.-and battery status at the following locations: main step-off pad men's change
2 room, chem lab, and the rad protection counting area. The inspector observed technicians performing operability checks on frisking cquipment and a scintillation alpha counter (SAC) using a radioactive source to verify that the equipment responded properly. In addition, the audible alarm capability of the frisking instruments was verified as operational. With one exception, all equiynent responded properly. The exception involved a hand-leld survey instrument that required battery replacement.- Docuxentation was reviewed for three different types of instruments used
- to evaluate dose and/or contamination levels to verify W t equipment was reliable, and checks were performed in accordance with procedures. No problems were noted, based-on results for 1995 and 1996, operability checks were performed consistent with procedural frequency for such checks and no concerns were noted regarding the reliability of equipment.
The inspector questioned the licensee regarding the existence of a system which identified all instruments and tracked the due date as well as last date for calibration and/or maintenance. In response, the inspector was informed-that the current methodology was a manual rather than computer based system 'The inspector was provided for review a notebook containing data sheets with instrument model number, serial number, and the date for last calibration and due date for next calibration. To ascertain the accuracy of calibration details and equipment identity and location, the inspector provided the licensee with serial numbers and model numbers taken from instruments during the facility tours. No problems were noted with details associated with the calibration data. However, the licensee's tracking system was unable to' identify the equipment location (step-off cad, chem lab, etc.).
(3) Conclusions Based on the location of-selected' equipment and the intended riate equipment was available and operational.use, The licensee the inspector deterreined that
-for tracking instruments lacked details regarding instrument locations and was tedious, but-functional,
- c. External Exoosure Control (R1.04)
(1) Insoection Scoce The inspector reviewed licensee procedures to determine if controls were in place to monitor occupational doses, and verify that administrative limits were established to control occupational dose as low as reasonably Lchievable (ALARA). The inspector reviewed personnel exposure data
3 based on the results from three ouarters of TLD data and estimated results for CO 9er thr ugh December 1997, to determine if expos, cc.- ere in comr11ance with 10 CFR Part 20 limits.
(2) Observations and Findinas The inspector reviewed radiation prote: tion orocedures, and discussed with licensee representatives the personnel monitoring requirements based on documentation from the licensee's evaluation of dosimetry requirements for 1997.
The inspector determined that the licensee's monitoring program was consistent with requirements in 10 CFR Part 20.
The inspector reviewed documentation from TLD data and discussed with a licensee representative personnel exposures for 1996 and 1997. External exposures as obtained via TLDs disclosed the maximum deep dose equivalent (DDE) was 0.516 rem in 1996 and the maximum assigned dose as of October 1997 with estimated fourth quarter data was 0.325 rem. The '
maximum exposed individual in 1996 was a worker in the fuel ,
bundle final assembly area. As of October 1997, the maximum exposed was a pellet operator. The maximum TEDE for 1996 wa 3.41 rem and assi conversion employee. gned For 1997to(based an ammonium diuranate on estimated fourth (ADU) quarter TLD data and annual air sampling data), the maximum TEDE was 3.038 rem assi-ned to a conversion area operator.
The inspector noted that the maximum assigned TEDE (3.038 rem) exceeded the licensee's ALARA goal of 2 rem / year.
During CY 1996. 26 workers exceeded the ALARA goal. Based on estimated data for the fourth quarter CY 97.18 employees were projected to exceed the 2 rem / year ALARA goal.
Regarding extremity exposures, the maximum exposure was 20 rem in 1996 and 12.73 rem as of October 1997 assigned to a pellet operator. The top ten exposures in CY 97 ranged from 8.83 - 12.73 rem.
The collective dose for 1996 was 276 3erson-rem and 187.6 person-rem TEDE as of October 1997. T1e significant reduction in occ.upational exposures from CY 96 to CY 97 was attributed to various engineering controls and equipment modification along with reduced material throughput. The inspector questioned the licensee regarding documentation for any planned exposures or declared pregnancies, and was informed that there were no planned special exposures:
however, one worker declared pregnancy status during 1997.
In response, the inspector reviewed the licensee's declared pregnancy policy which was an inspector follow-up item (IFI) from a previous inspection and is discussed elsewhere in this report (see Section 2.g.). Further. the inspector examined the licensee's procedure (RA-225 " Control Of
4 Radiation Dore and Chemical Exposure To The Embryo / Fetus",
Rev. 0, datea November 20. 1997) governing declared pregnancies and noted that exposure estimates and actions taken to protect and restrict the employee from exposures were consistent with the procedure.
(3) Conclusions Based on the exrsosure records review and interviews, the inspector determined that the licensee's external exposure control program was adequate for evaluating and monitoring personnel exposures. The annual assessment of exposure data was adequate for identifying which em)loyees or categories of workers required monitoring, and t1e ex)osure controls were in place to maintain exposures less tlan 10 CFR Part 20 limits. When administrative action limits were exceeded and required investigation into causal factor, the investigation was thorough and extensive in attempts to determine the cause. The licensee's program for controlling dose to an embryo / fetus was adequate and met the intent of 10 CFR 20.1003 regarding a woman voluntarily declaring her pregnancy rather than beinc coerced or required by the licensee,
- d. Internal Exoosure (RI.05)
(1) Insoection Scoce The inspector reviewed licensee procedures for assessing internal exposure to determine if controls were in place to monitor occupational doses, and verify that the administrative limits were established to control occupational dose ALARA. Exposure data based on air sampling results for the period ending December 1997 was reviewed to determine if exposures were in compliance with 10 CFR Part 20 limits.
(2) Observations and Findinas TR licensee's primary method cf assigning internal exposures to personnel was based on fixed air sample results. In addition to the air sampling program, employees that were assigned to potentially contaminated and/or airborne areas participated in the bioassay program for exposure verification. The inspector reviewed the results for 1997 based on data for January through December 1997.
The maximum committed effective dose equivalent (CEDE) in 1997 was ?.73 rem and 3.09 rem for 1996. The top ten exposures in CY 97 ranged from 2.16 to 2.73 rem. The maximum assigned CEDE was to an ADV conversion employee.
. The inspector and licensee discussed and examined equipment and/or design changes (e.g. HEPA-filtered ventilation I
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5 system) to reduce one exposures during a tour of the conversion area.
The licensee conducted an evaluation of bioassay and air sampling data to determine which employees were expected to exceed the internal monitoring threshold of 0.5 rem (500 mrem) CEDE during 1997. The determination was based on data (airborne and bioassay) for the period January 1 through December 31. 1996.
(3) Conclusions Based on the interviews and exposure records reviewed, the inspector determined that the licensee's internal exposure ccntrol program was adequate for evaluating and monitoring personnel exposures. The procedures and system for tracking exposures provided management with results for trending occu)ational exposures. Administrative dose limits were esta)lished and all assigned exposures were well below the regulatory limits. The annual assessment of exposure data was adequate for identifying which employees or categories of workers required monitoring.
- e. Resniratory Protection (R1.06)
(1) Insoection Scone The re viratory protection training and equipment maintenance program were reviewed to determine if activities were in compliance with procedures and license conditions.
(2) Observations and Findinos The inspector reviewed the procedure governing respiratory
)rotection training (RA-205 entitled Respiratory
)rotection), and training records were reviewed for 14 individuals assigned to the controlled area. No problems were noted. The traiaing for randomly selected individuals was reviewed and considered current and up to date. During a previous review of the res)iratory protection training video, the inspector noted tlat certain details associated with the video required an update for consistency with the current policy (see inspection report (IR) 70-1151/96-03).
When questioned regarding the status of the update, the licensee indicated that the video had not been updated at this time. In response, the licensee assigned a commitment i action item to the commitment tracking system (CTS No. 617) to complete the video update by September 1. 1998.
The inspector toured the face masks cleaning and laundering facility and noted that the full-face cartridge respirators were cleaned and properly stored. The inspector observed a
6 technician performing the required surveys and inspections on respirators (used on a 3revious shift and cleaned) prior to releasing for reuse. T1e inspector noted that the respirator laundering and handling procedures were adequate for segregating the cleaned from the dirty masks. The performance of mask surveys by a respiratory protection technician was observed and no action limits were exceeded.
No problems were noted involving the maintenance of equipment. However, during a chemical area tour, the inspector noted poor house-keeping practices involving used respirators. Workers were using respirators but not depositing the used respiratore in designated receptacles.
Several examples were noted where respirators were left on equipment, tool boxes and/or work area rather than returning to the receptacle for used respirators. The licensee took immediate action to discuss this matter with all shift personnel qualified for respirator use. In the aftermath of the licensee's meeting with shift personnel, no additional examples were observed.
Regarding respirator usage, document' tion was provided to i show tnt during a six year period (1991 - 1997). the maximum use was 43.000 in CY 95 with a steady downward trend to 30.000 in CY 97.
(3) Conclusions Based on the review of records, interviews, and observation of activities in progress, the inspector determined that the training for those individuals selected was current and consi-tent with procedural requirements. During the inspection period, the respiratory cleaning facility was organized and respirators were properly stored such that sanitized and unsanitized equipment would not become mixed.
The licensee took immediate actions in response to the inspectors' observations and comments regarding respirator housekeeping in the chemical area,
- f. Surveys (R1.08)
(1) Insoection Scooe The contamination control survey program was reviewed to determine if surveys were effective in the identification of contamination and performed in accordance with procedures.
(2) Observations and Findinas The inspector accompanied a Rad Control Technician during the performance of contamination surveys, and observed the collection of smear samples from the following: furnace area hallway, chem lab, and Manufacturing Automation Project
7 (MAP) functional area. During the plant tour, the inspector requested the licensee obtain smear samples independent from those locations required by procedure for verification that action limits were not exceeded. No problems were noted, the independent smear samples were less than the aC. ion limits requiring clean up.
In addition to the anove observations, documentation in support of periodic :.orveys were reviewed as follows:
. Weekly surveys for the period October 28. 1997 to December 16. 1997 covering conversion equtpment and the 100 men's change room.
. Bi-weekly surveys for the period May 26, 1997 to December 7. 1997 covering water fountains.
. Monthly surveys for the period May 19. 1997 to December 9. 1997 covering the cafeteria, dock 11. and cafeteria eating tables / vendor tables.
The documentation for randomly selected areas disclosed that the surveys were performed at the required frequency in accordance with procedures. Further in the event area smear results exceeded the action limits. actions were taken to decontaminate area of the smear to acceptable limits.
During the performance of surveys discussed above, the inspector did not identify any significant weaknesses in the licensee's 3rogram to maintain and control radioactive materials, iowever, the inspector observed two items of concern requiring licensee attention:
. During the MAP tour, the inspector noted several used sets of orphan shoe covers t1at were incorrectly stored inside shoe bins rather than the contaminated shoe cover rece)tacle. The inspector informed the licensee that t11s practice was an examale of improvements needed in housekeeping. T1e licensee took immediate action to remove the shoe covers for disposal.
During the observation of health physics coverage associated with maintenance activity on lines 1 and 4 the inspector noted that maintenance worker trainin may be weak in contamination control fundamentals. g Maintenance personnel were observed without a respirator extending over and/or under the barrier tape posted as " respirator required." Personnel was consulting with an individual performing the actual maintenance. In response to the inspectors
- observations, the licensee discussed with workers adherence to barrier controls and posting for controlling contamination and exposure to workers.
8 (3) Cowlusions No concerns were noted with the surveys. The observed surveys were consistent with procedures, and personnel performing surveys were attentive to details and activities associated with area operations and the associated ALARA concerns.
- g. Followun on Previous 1v Identified Issues (R1.12)
(1) Insoection Scooe The inspector reviewed actions taken by the licensee to cor* t previous issues to verify that the corrective act...is were adequate and had been completed.
(2) Qblervations and Findinas (Closed) IFI 70-1151/97-01-01: Review licensee actions in response to declared pregnant woman (DPW) policy.
l The licensee's policy statement was reviewed and
! revised for consistency with the definition of DPW as l discussed in 10 CFR 20.1003. The previous wording stated that an employee mult notify the licensee and provide medical documentation confirming pregnancy.
The revised policy stated that "an employee who becomes pregnant should notify the Medical Department, her manager, and Human Resources immediately upon medical confirmation by her physician of her aregnancy. The employee should also furnish the iedical Department with a statement from her physician which also states her ex)ected date of delivery, approval to continue wor ( and expected date of retu n to work." The revised policy was issued on May 2.
1997 to Plant Managers and Team Managers via a Work Place Meeting Script requesting that the revised policy be reviewed with each em)loyee no later than Ma3 15, 1997. At the time of t1e inspection, the Employee Handbook nor the Regulatory Training Manual had been updated to reflect the revised policy. The inspector was informed that the revisions to the Regulatory Training Manual would be completed Seatember 1. 1998: and the Employee Handbook was scleduled for update late CY 98 or early CY 99.
(Closed) V10 70-1151/97-01-02: Failure to follow Procedure RA-203 (General HP Rules and Recommendations).
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By letter dated March 27. 1997, the licensee disputed the violation and arovided the basis for the denial.
In response, the NRC acknowledgment letter (dated June 3, 1997) informed the licensee that the violation occurred as stated and the licensee's corrective actions to prevent recurrence was acceptable. Consequently, the-inspector verified that the licensee had completed corrective actions as
' indicated in the letter dated March 27, 1997. No problems were noted. During the period of the inspection, the inspector did not observe workers
. chewing gum or food products in the chemical area.
4 (3) Conclusions Based on the licensee's actions, the above items are considered closed.
- 3. Environmental Protection (88045) (R2)
- a. Oraanization (R2.01) 4 (1) Insoection Scoce The inspector reviewed the licensee's Regulatory Engineering ,
and Operations (RE0) orJanization, including staffing levels with regard to the programs for environmental safety and radiological effluents management.
4' (2) Observations and Findinas 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 r- Senior Regulatory Engineer -one Environmental Technician, and one Laboratory Technician. The inspector noted that the stability and experience of the staff was good. The staffing levels appeared adequate to handle the existing e work load.
(3) Conclusion During the onsite inspection, the inspector did not identify any concerns with the organization or responsibilities of the RE0 staff. Based on discussions with licensee representatives and observation of activities, the inspector noted at the time of the inspection that staffing levels a?peared adequate to support ongoing licensed activities in tie areas of environmental protection and effluent waste '
management.
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- b. Monitorina Proaram Imolementation (R2.01)
(1) Intoection Scone 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.
(2) Observations and Findinas The ins)ector reviewed selected procedures to note changes since tie last inspection of this program and to determine if the procedures implemented the requirements of 10 CFR 20 and the license application.
. R0P-06-003. Ambient Environmental Air Monitoring for Radioactivity. Rev. 7. issue date Narch 14. 1996 This procedure required the technician to write down the flow rate during sampling. However, the licensec had installed new air sampling equipment that maintained a constant flow rate. Hence. 2.0 cubic feet per minute (cfm) was always used. The ins)ector accompanied the technician during sampling of tie ambient environmental air sampling statioris and verified that the flow-rate was essentially 2.0 cfm.
. R0P-06-006. Collection of Routine Weekly and Monthly Environmental Samples. Rev. 7. issue date December 17.
1996 This procedure was limited to the routine collection of weekly and monthly environmental samples, however it did not specify the quarterly and annual collection of certain environmental samples specified in the license application. The licensee indicated + hat the collection of quarterly and annual samples was handled on an internal " tickler" file system.
The inspector determined that there were no significant changes in the procedures since the last inspection and therefore did not decrease the effectiveness of implementing
e 11 the environmental monitoring program. The inspector noted that the procedures reviewed were generally consistent with the requirements of the license application and 10 CFR Part 20.
However. contrary to Section 10.4.1 of the license application, which requires that action levels will be established by procedure for environmental samples, the inspectors noted that there were no action levels established by procedure for surface water, river water, sediment, soil, and fish samples. During the inspection, the licensee made a comitment to establish these action levels and develop a procedure incorporating these action levels by March 30, 1998. '?.1e inspector identifieo this issue as a violation of Safety Condition S-1. Section 10.4.1 of the license application for the failure to establish i action levels by procedure for certain environmental samples. However, this failure constitutes a violation of minor environmental concern and is being treated as a l
non-cited violation (NCV) consistent with Section IV of the l NRC Enforcement Policy and therefore will not be subject to formal enforcement action (NCV: 70-1151/98-01-01: Failure to establish action levels by procedure for certain environmental samples).
(3) Conclusions Based on the above reviews. it was concluded that the licensee had acceptable procedures to implement the environmental monitoring program. However, a violation of minor environmental concern was noted for the failure to establish action levels by procedure for certain environmental samples.
- c. Monitorina Procram Results (R2.02)
(1) Insoection Scooe Chapter 10. Section 10.4.1 of the License Application specified that action levels will be established by
)rocedure for environmental samples. Figure 10-1 of the
.icense Applicatioi specified gross alpha and beta concentration action levels for ground water and gross alpha concentri. tion action levels for vegetation samples.
Procedure RA-215. Unusual Incidents. Revision 9. dated February 22, 1996, specified the action level for environmental air samples, s
12 (2) Observations and Findings The inspector reviewed the arialytical results for 1997 of selected environmental sampling media, including: ambient air particulate samples, soil samples: surface water samples: and river water samples. The inspector determined that the environmental sa":ples had been collected and analyzed in accordance with the applicable rocedures and license application requirements. The anal tical results for the soil sam concentrations. ples Theindicated inspectoruranium noted an at overall b ckground increase of the gross alpha concentration in the soil samples collected in 1997 when compared to the 1996 data. These discrepancies may be due to the licensee changing its vendor laboratory performing analytical services between 1996 and M97.
During the onsite inspection, a routine soil v.mple was collected at the environmental stationary air st.mple station location #4 by the licensee and split with the NRC for confirmatory measurement purposes. The inspector indicated to the licensee that the comparison of the analytical results would be tracked as an inspector follow-up item l
' (IFI 70-1151/98-01-02: Coc3are analytical results of a split soil samp#4).le from environmiatal stationary air sample station location 1
The inspector also reviewed monthly surface water results l for 1997 which were collecteC at che locations specified in l
I Section 10 of the license application. The inspector noted that gross alpha concentrations at the " Roadway" location (water ditch, southwest of the manufacturing areas) ranged from approximately 3 to 52 3C1/ liter. However, the inspector also noted that tie gross 61pha concentrations at the " entrance" location (creek into U Upstream at the facility fence line) pper Sunset ranged fromLake approximately <1 to 45 pC1/ liter. These samples were considered to contain background levels of gross alpha activity. A comparison of'the gross alpha concentrations at the two locations is presented in the graph on Figure 1.
The licensee had no explanation for the variability in the surface water background results or the slightly elevated Roadway sample results. Further, as noted above, the licensee had not established any action levels for surface water sample results. The inspector indicated that a review of the licensee's determination for the wide variability and slightly elevated surface water sample results for the roadway and entrance locations would be tracked as an IFI (IFI 70-1151/98-01-03: Review licensee's determination for the wirte variability and slightly elevated surface water sample gross alpha results).
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i 3 4 s a r e e se it Mene h 1997 Figure 1: 1997 Ourface Water Sampling Data for Background and Roadway locations The inspector also reviewed the river water sample results for 1997 and roted that no concentrations were above the background. lie insr ~t,r also reviewed the 0A/0C report from the vendor labc aory and noted that the laboratory's performance was within acceptable parameters for gross alpha and beta analyses according to Environmental Protect "a Agency (EPA) comparison tests.
In addition, weekly ambient air sampling data for 1997 were reviewedandshowejonlyoneslightexceecenceoftheaction level of 5.0 x 10 pCi/ml. The exceedence occurred at stationary air sample station #2"with a measured a gross aipha concentration of 5.12 x 10' C1/ml. The licensee took the ap)ropriate action required by procedure which was to nctify tie cognizant regulatory engineer.
The in.nector also reviewed 22 onsite ground water sample results or the first through the third quarters 1997. The i license upplication specifies quarterly sampling of selected
14 wells. In addition, the following action levels were ,
specified in the license:
o gross alpha 15 pCi/ liter perform isotopic analysis e gross beta 50 pC1/ liter perform isotopic analysis e total uranium 30 pCi/ liter notify licensee management /NRC The inspector verified that the licensee had-performed the quarterly sampling as required by the license application.
At the time of this inspection, the fourth quarter data were not available for review. A summary of the action levels exceeded is provided in the table below:
Table 1: Number of Wells Exceeding the Action Limits in 1997_
Quarter Gross Alpha Gross Beta- Total Uranium 1 2 7 1
-2 1 6 1 3 4 7 1 The inspector noted that when the action levels were excer.ced that the appropriate isotopic analysis was performed. The inspector also noted consistently elevated gross beta results in all three quarters. The licensee was in the process of making an evaluation. The inspector indicated that an IFI would be tracked to review the licensee's evaluation and assessment (IFI 70-1151/98-01-04:
Review the licensee's determination for the elevated gross beta ground water sample results noted in the first--three quarters of 1997).
~(3) Conclusions 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. No determination could be made for the wide variability and slightly elevated surface water sample gross alpha results. Similarly, no-conclusions could be reached with regard to the high gross beta concentrations noted in the onsite ground water samples for the first three quarters of 1997. These issues were being evaluated by the licensee.
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- d. Unusual Incidents (88035. 88045) (R2.08)
(1) Insoection Scooe The inspector reviewed unusual events pertaining to I environmental issues that occurred in 1997 Procedure l RA-215. Unusual Incidents. Revision 9. dated February C2. I 1996, specified the actions to take for unusual incidents. '
(2) Observations and Findinas
. The inspector reviewed the licensee's unusual incident
] reporting records and discussed with the licensee any n unusual environmental events that occurred during 1997, The LJ inspector discussed the following incidents in the records:
(a) On February 3.1997 a small, short duration UF, puff from the local transmitter on the Line 4 vaporizer equipment was observed.
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6 (b) On February 5. 1997, solution was observed in one of the drainage ditches. Approximately 25 gallons of solution was removed. No contamination was found in the drainage ditch nor the main environmental control valve.
(c) On March 16. 1997, approximately 5000 gallons of lime slurry was spilled on to a concrete sad. The slurry was contained on the pad. Most of tie slurry was aumped back to 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.
(d) On April 30, 1997, a small, short duration UF, puff occurred from the blind flange on the oxygen column on Conversion Line #1. The release was contained.
(e) On September 9,1997, a small, short duration UF, puff occurred from a Johnson valve on Line 2.
(f) On November 22. 1997, an outdoor tank leaked ap3roximately 35 gallons of uranyl nitrate in to a diced area.
The inspector noted that the licensee took the appropriate action as necessary for the incidents indicated a)ove.
(3) Conclusion The inspector concluded that the occurrences noted above were minor in that there was no significant impact to the environment.
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- e. Decommissionina Records (88104) (R2.07)
(1) Insoection Scooe The inspector reviewed the licensee's decommissioning records to ensure com)liance with the record keeping requirements of 10 CFR 70.25(g). 10 CFR 70.25(g) specifies that each licensee keep records of information important to decommissioning of a facility in an identified location until the site is released for unrestricted use. 10 CFR 70.25(g)(3) recuires that a list contained in a single document be upcated every two years that contains decommissioning related information as specified in 10 CFR 70.25(g)(3)(I) through (iv).
(2) Observations and Findinas The inspector observed that the licensee implemented via the commitment trackin system a method to ensure compliance with 10 CFR 70.25( ) by updating at least annually the decommissioning fi es and documenting the review on a
" review sheet." The review sheet is sent to the Manager, Regulatory Operations and Engineering to verify the following:
. spills of radioactive materials not totally cleaned up
. potent ally contaminated materials buried onsite e areas decontaminated that were formerly used for radioactive materials e any other events, pertinent information.
The inspector verified that the self-imposed annual review was performed in July 1996 and 1997.
The inspet. ' Iso reviewed the licensee's decommissioning files. In a , sort by a contractor dated June 1980 on a fish kill in a facility pond, a reference was made to an
" abandoned filter cake landfill." The maps in the "eport did not indicate the location of the landfill or provide any further details. The licensee was questioned on the subject and indicated that to their know' edge no such laadfill exists. The contractor may have oeen referring to an area whert. calcium fluoride wa,s temporarily stored while a pond liner was repaired. The licensee indicated that the subject would be investigated further.
17 (3) Conclusion The inspector concluded that the licensee's decommissioning records and files wers well organized, maintained, and detailed.
- 4. Waste Manaaement (88035) (R3)
- a. Liouid Effluent Monitorina Results (R3.02)
(1) Insoection Scooe
'] 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 20.
(2) Observations and Findinas The licuid effluent released to the Congaree River from the Waste kater Treatment Facility (WWTF) was required to be sampled continuously by a flow rate proportional sample collector. R0P-06-001. National Pollution Discharge and Elimination System (NPDES) Daily. Weekly, and Monthly Effluent Sample Collection. Rev.12. April 21,1994 specified the liquid effluent sample collection requirements. The licensee discharged approximately 130.000 gallons of liquid effluent per day. The licensee collected daily samples from the proportional sam)ler to monitor for NPDES chemical parameters and gross alpia activity. 30-day com)osite samples were required to be analyzed for gross alpia activity gross beta activity, and isotopic uranium.
The licensee used a vendor laboratory to perform the required analyses for the monthly composite samples.
The inspector reviewed monthly sampling and analysis data from Janucr y through October 1997. The inspector noted that the running annual average gross alpha concentration through October 19E ' was approximately 420 pC1/ liter, which was greater than the unrestricted release limit (URL) of 300 pCi/ liter. It should be noted that 10 CFR 20.1302 allowed the licensee to demonstrate compliance with the annual dose limit for individual members of the ]ublic specified in 10 CFR 20.1301 by calculating the TEDE to the individual likely to receive the highest dose from the licensed operation. The licensee will be calculating the TEDE when the November and December liquid effluent sampling results are received from the vendor laboratory. The licensee attributed these increases to a decrease in the pH in the East Lagoon, thus driving the uranium back into l
18 solution and discharged. The licensee was investigating this problem and was considering improved monitoring of the pH in the liquid waste before it is discharged into the lagoon system. Procedure RA-401. Environmental Control Requirements Mandated by 10 CFR 20. Revision 8. February 13, 1997. Step 7.1.2 specifies that an investigation will be performed if the annual average gross alpha concentration exceeds 300 pCilliter. The inspector noted that the licensee had initiated a liquid effluent action plan realizing that the annual average through December 1997 would more than likely be above the action level specified in RA-401 The licensee indicated that the action plan would be placed in the Regulatory Engineering tracking system. The inspector indicated that the proposed actions were appropriate, however, a review of the action plan would not be made until it was finalized.
(3) Dnclusions There were no apparent uroblems noted with the licensee's liquid sampling and cr.dlysis program. The licensee had experienced higher than normal gross alpha concentrations in the liquid effluent discharges. These increases were
' attributed to a decrease in the pH in the East Lagoon, thus driving the uranium back into solution and discharged. The licensee war developin address this problem, g a liquid effluent action plan to
- b. Unusual Events (R3.12)
(1) Insoection Scooe The inspector reviewed an event that was identified on January 14, 1998 involving a break in the liquid effluent discharge line at the Congaree River near the diffuser.
(2) Observations and Findinos On January 14, 1998. the licensee was inspecting the newly installed river diffuser and identified a slow underground leak at the edge of the Congaree River. The licensee terminated the liquid effluent discharges at 10:00 am on January 14 and notified the cognizant regulatory engineering staff. The inspector was notified shortly thereafter. The inspector and a licensee representative examined the area around the pipe break. The licensee collected a soil / sediment sample at the centerline of the pipe on January 14. On January 15. the State of South Carolina Division Health and Environmental Control (DHEC) was notified by the licensee. Repair efforts were initiated on January 15, 1998.
19 The licensee had developed a response plan to include the following:
Characterize the contamination in the soil and collect ,
additional samples as needed, l Document the volume discharged since the last pipe inspection.
+ Document the range of activity in the liquid effluent.
Establish ownership of the affected property.
Follow up with engineering and operations to verify l completion of the repair.
The inspector indicated that the action plan may involve cleanup activities and/or placement of this event in the facility decommissioning files. The inspector also indicated that the com be tracked as an IFI (pletion of the action plan IFI 70-1151/98-01-05: items would Review the licensee's completion of the action plan items for the river discharge line break at the Congaree River near the diffuser).
(3) Conclusion The licensee's notification of the event to the onsite inspector was timely. The action plan developed by the licensee was appropriate.
- c. Airborne Effluent Monitorina Results (R3.04)
(1) Insoection Scoce Chapter 10. Section 10.1 of the License Application specified the sampling and analytical requirements for gaseous effluents. Continuous sampling was required during production o)erations for those operations which could result in ex1austing radioactive materials to unrestricted areas. Collection and analysis o' those samples was required to be performed on a dat basis during production operations. The adequacy of the goeous 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.
20 (2) Observations and Findinas The inspector reviewed procedure R0P-06-002. Roof Effluent Air Samaling and Counting. Rev. 11. December 17, 1996, and noted tlat it included provisions for the daily collection of air particulate samples from 45 sampling locations and analysis after a 24-hour decay period and specified an action level (or control concentration limit) of 4E-12 gCi/ml. Procedure RA-401. Environmental Control Requirements Mandated by 10 CFR 20 and EPA 40 CFR 61.
Rev. 8. February 13, 1997 specified the actions to take in the event a stack sam)le exceeded the coctrol concentration limit specified in RO)-06-002.
The inspector accompanied a technician during the collection of the daily stack sample collection activity and noted no 3roblems with the method used to collect the samples.
lowever, using the guidance in American National Standards Institute (ANSI) N13.1 Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities, the inspector noted "3 following stack sampling concerns:
. The calciner off gas Line 2 had excessive moisture in the flowmeter
. The ADU on line scrubber samale probe was located within one duct diameter of Jend in the duct.
. The Scrap Recovery lines 2A and 28 had (1) moisture in the delivery line: (2) used excessive lengths of tygon tubing for sample delivery lines which were subjected to harsh environments and the eventual degradation of the sample delivery line: and (3) sharp bend in the tygon tubing at the sample probe exit.
The inspector reviewed weekly gaseous effluent discharge reports for the period January 1 to December 19, 1997. The inspector noted several exceedences of the control concentration limit specified in RA-401. Of the 43 exceedences of the control concentration. 29 or 63% of them were at stack location 1237 (U3 0,-HF strip exhaust). The licensee indicated that this location had been identified for a capital project to replace the filtering system with a more efficient system. the inspector also verified that the appropriate actions were taken as required by RA-401, for exceedences of the control concentration limit. All exceedences of the control concentration limit were recorded on Form R0F-0 122-1, which included the reganse action taken.
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l 21 (3) Conclusions Documentation of the corrective actions taken or planned to be taken for exceeding the control concentration limit for gaseous effluents had improved. The licensee was proactive in planning for a capital p' ect to replace the filtering system associated with the , -HF strip exhaust with a more efficient system. In a ition, stack sample delivery line concerns were noted. The licensee agreed to evaluate the noted concerns.
5.- Exit Interview The inspection scope and results were summarized on January 16, 1998, with those persons indicated in the Attachment. The inspector described the areas inspected and discussed the inspection results including the issue involving the failure to establish action levels by procedure for certain environmental sam)les, and the likely informational content of the inspection report witi 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. Dissenting comments were not received from the licensee.
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ATTACHMENT
- 1. PERSONS CONTACTED Licensee Personnel
- J. Allen, Plant Manager
- W, Dougherty, Manager, Respirator Team
- R, Fischer Senior Engineer, Regulatory Engineering and Operations S. Gantt, Engineer, Regulatory Engineering and Operations
- D, Goldbach, Manager, Chemical Operations
- W Goodwin, Manager, Regulatory Affairs
- J. Heath, Manager, Regulatory Engineering and Operations R. Jacobs, Team Manager, Chemical Conversion
- A, Kaminsky, Manager, Human Resources
- G. LaBruyere, Manager, Mechanical Manufacturing
- R. Likes, Senior Regulatory Engineer
- D. Matthews, Manager Ins)ection and Analytical Services
- S, Mcdonald, Manager, Tec1nical Services
- N. Parr, Manager, Chemical Process Engineering
- C, Perkins, Manager, Maintenance
- E. Reitler, Fellow Engineer
- T. Shannon, Re ulatory Affairs Technician
- R, Williams, R ulatory Affairs Advisory Engineer Other licensee employees contacted included engineers, technicians, production staff, security, and office personnel.
- Denotes those present at the exit meeting on January 16, 1998,
- 2. INSPECTION PROCEDURES USED IP 83822 Radiation Protection IP 88035 Radioactive Waste Management IP 88045 Environmental Protection IP 88104 Decommissioning Inspection Procedure for Fuel Cycle Facilities
- 3. LIST OF ITEMS OPENED CLOSED, AND DISCUSSED Item Number Stat.qs. Descriotion 70-1151/97-01-01 Closed IFI -Review licensee actions in response to DPW policy (Paragraph 2.g.).
70-1151/97-01-02 Closed VIO - Failure to follow procedure RA-203 (Paragraph 2.g.).
2 70-1151/98 01-01 Closed NCV: Failure to establish action levels'by procedure for certain environmental samples (Paragraph 3.b 2). l 70-1151/98 01-02 Opened IFI: . Compare analytical results of a split soil sample from environmental stationary air. sample station location #4 (Paragraph 3.c.2).
70-1151/98-01-03 Opened IFI: Review l icensee's l
determinatier. for the wide variability and slightly elevated surface water sam]le gross alpha l results (Paragrap1 3.c.2).
70-1151/98-01 Opened IFI: Review the licensee's determination for the elevated gross beta ground water sample results-noted in the first three quarters of 1997 (Paragraph'3.c.2).
70-1151/98 01-05 Opened IFI: -Review the licensee's completion of the action plan items-for the river discharge-line break at the Congaree River near the diffuser (Paragraph-4 b 2).
4.- LIST OF ACRONYMS M. ARA As low as-is' Reasonably Achievable Alk) Ammonium Diuranate ANSI- -American National Star.dards Institute CEDE Committed Effective Dose Equivalent cfm Cubic Feet per Minute-
'CY Calendar Year-DDE - Deep Dose Equivalent DHEC Division Health and Environmental Control DPW Declared Pregnant Woman EPA Environmental Protection Agency IFI Inspector Follow-up Item IR Inspection Report MAP Manufacturing Automation Project pC1/ml microcurie per milliliter mci millicuries t
mrem millirem NCV- Non-Cited Violation NPDES National Pollution Discharge and Elimination System
'NMSS Nuclear Material Safety and Safeguards NRC Nuclear Regulatory Commission pC1/g picocurie per gram
3 pC1/1 picocurie p,r liter RE0 Regulatory Ea31neering and Operations TEDE Total Effective Dose Equivalent TLD Thermoluminescent Dosimeter Uranium Hexafluoride UF[
UR Unrestricted Release Limit WWTF Waste Water Treatment Facility VIO Violation E