ML20207T229
| ML20207T229 | |
| Person / Time | |
|---|---|
| Site: | Neely Research Reactor |
| Issue date: | 03/03/1987 |
| From: | Hosey C, Kuzo G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20207T217 | List: |
| References | |
| 50-160-87-02, 50-160-87-2, NUDOCS 8703230329 | |
| Download: ML20207T229 (7) | |
See also: IR 05000160/1987002
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Report No.:- 50-160/87-02-
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Licensee:- Georgia-InstituteofTechnojogy
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225 North Avenue-
' Atlanta, GA 30332
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Docket No.: 50-160
License No.: R-97
Facility Name: Georgia Institute of Technology Research Reactor (GTRR)
Inspection Conducted: February 17-23, 1987
Inspector:
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G. B. Kbzo
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Date Signed
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Approved by:
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C. M. Hosey? 5ectiot Chi _ef
Date Sig~ned
Division _of Radiatipn Safety-and Safeguards
SUMMARY
Scope: Th'is routine unannounced inspection involved onsite review in'the areas
of radiation control and environmental protection for the Georgia Institute of
Technology Research. Reactor facility.
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Results: Two violations were identified - failure to have operating. procedures
for sampling of the liquid waste tanks; and failure to follow health physics
cnd surveillance procedures.
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8703230329 870'309
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- R. A. Karam, Director, Nuclear Research Center
- L. D. McDowell, Reactor Supervisor
W. H. Downs, Reactor Operator
~*R. M. Boyd, Radiation Safety Officer
- S. N. Millspaugh, Deputy Radiological Safety Officer
Other licensee employees contacted included technicians and office
personnel.
Nuclear Regulatory Commission
- D. Verrelli, Chief, Reactor Projects Branch 2
- A. Herdt, Chief, Engineering Branch
- S. Vias, Project Engineer
- Attended exit interview
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-2.
Exit Interview
The inspection scope and findings were summarized on February 23, 1987,.
with those persons indicated in Paragraph 1 above.
Two potential
violations concerning failure to have procedures for liquid waste effluent
sampling (Paragraph 5.a) and failure to follow procedures (Paragraphs 4
and 5.b) were discussed.
Licensee representatives acknowledged the
inspector's convrents and expressed no contrary opinions. The licensee did
not identify as proprietary any of the material provided to or reviewed by
the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters
.This subject was not addressed in the inspection.
4.
Radiation Control (837438)
The inspector discussed with licensee representatives sources of
radioactive contamination at the facility which could be present in the
liquid waste tanks.
Potential sources included fission and activation
products from reactor operations and/or contamination from material
brought into the facility for testing and research purposes.
Licensee
representatives stated that the prevalent radioactive contaminants
introduced into the facility were H-3 and Co-60.
The primary system
radionuclides identified in the monthly coolant analyses required by
Technical Specification (TS) 4.4.c were reviewed.
Major isotopes
identified in the coolant included H-3, Ar-41, Na-24, Mg-27, Mn-54 and
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Co-60. The inspector noted that the potential radioactive contaminants at
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the GTRR facility indicated the need for additional evaluation of liquid
radiological measurement capabilities (Paragraph 5.b).
From review of Instrument and Surveillance Procedure 7200, Radionuclide
Analysis, 7/17/81, the inspector noted that the coolant sample line is
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required to- be secured (isolated) except during monthly surveillance
activities.
From discussion with licensee representatives and during a
tour of the sampling area the inspector verified that the line constantly
remained in a recirculating (non-isolated) condition. The inspector noted
that isolation of the line as required by procedure would lessen the
potential for accidental contamination.
required written procedures to be provided and utilized for radiation and
radioactive contamination, and surveillance and testing requirements.
Failure to follow procedures to secure the primary coolant sample line was
identified as an apparent violation of Technical Specifications
(50-160/87-02-01).
5.
Environmental Protection Liquid Effluents (837438)
Technical Specification (TS) 3.5.a(1) specified that the concentration of
gross radioactivity, excluding tritium and background, in liquid effluents
released to the sewer system from the reactor building shall not exceed
3 E-6 microcuries per milliliter (uCi/ml) unless the discharge was
controlled on a radionuclide basis in accordance with the limits specified
in 10 CFR 20 Appendix B, Table II.
TS 3.5.a(2) specified that the
concentration of tritium released to the sewer system shall not exceed
l'E'1'uti/ml.
The ' inspector dhcussed and reviewed with cognizant licensee
representatives procedures and records regarding collection, analysis and
discharge of liquid wastes to the sanitary sewer system.
The following
items were discussed in detail during the inspection.
a.
.0perations did not have written procedures concerning sampling of the
liquid waste tanks.
Operations personnel indicated the 5,000 gallon
liquid waste tank utilized for releases to the sewer system was not
mechanically mixed nor recirculated prior to release. The inspector
noted that thorough mixing of the waste tank contents would be
necessary if compliance with 10 CFR 20 Appendix B limits was to be
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demonstrated using a single homogeneous sample prior to release. The
inability to properly mix the tank contents required adequate
sampling prior to and during effluent discharge, and the timely
completion of radiological analyses for the collected samples.
TS 3.5.a(5) required that during release of liquid radioactive
effluents two independent samples of each tank be taken, one prior to
release and one during release; and that an additional independent
sample be taken from the discharge line during release.
Following
discussion of TS 3.5.a(5) intent with licensee representatives, the
inspector noted that to ensure proper monitoring and compliance with
release limits, waste tank samples should be systematically sampled
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and analyzed prior. to termination of the release. ' Review of 'the
- process release records. from January 1986- to February 1987 indicated
that.although :the TS required samples were collected prior to and
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.during'each waste tank discharge, numerous radiological analyses were-
completed subsequent _ to termination of the release.
The-inspector-
informed licensee representatives that .TS 6.4.b(6) 'and 6.4.b(7)-
required written procedures to b.e provided and utilized for radiation
- and radioactive contamination control,' and isurv'eillance and> testing
-activities. . Failure to have procedures for sampling of the low level
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liquid was.te tank - prior to and during effluent releases was
identified as an apparent violation of Technical Specifications
(50-160/87-02-02).
b.
The- inspector reviewed procedures and discussed TS required
radiological analyses of liquid effluent samples. . Health Physics-
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(HP) Procedure 9025, Liquid Waste Tank Analysis, August 29, 1985,
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-required a 500 ml liquid waste tank sample.to be filtered through a
0.45 micrometer (um) filter.
The- filter was then analyzed for gross
beta-gamma activity by proportional. counting and the filtrate
analyzed for tritium by liquid scintillation methodology.
The
~ ' inspector discussed the adequacy of this procedure with cognizant
licensee representatives and noted. that,. if present, soluble
radioactive contaminants could pass through the filter and possibly
be excluded from the beta-gamma analyses.. Furthermore, any soluble
contaminant could increase the values reported for tritium and/or not
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be' detected as a result of the energy window settings of the liquid
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scintillation counting equipment.
Licensee representatives stated
that the major contaminants found in the waste tank was tritium
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(soluble) and Co-60 (particulate) and believed the procedure to be
adequate for release of soluble material to the sanitary sewer
system. - To verify the adequacy of the -licensee methodology, the
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inspector requested the licensee to collect and split three waste
tank samples with the NRC Region II laboratory.- Standard procedures
for radionuclide analyses will be completed and the results compared
between the-licensee and the NRC. The inspector noted that this item
will be reviewed during a subsequent inspection (50-160/87-02-03).
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10 CFR 20.303 required licensed material discharged to the sanitary
sewerage system to (a) be readily soluble or dispersible in water and
(b) not exceed the quantities specified in this section.
Concerns
regarding the potential for release of the insoluble radioactive
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particulate materials in the waste tank to the sanitary sewer system
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were discussed during the inspection and during a subsequent -
teleconference on March 3,1987, between Dr. R. A. Karam, Director,
Nuclear Research Center and NRC Region II personnel.
The licensee
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stated that the high turbidity of water in the waste tanks introduced
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from the building sump prevented the practical use of the liquid
waste filter system prior to release to the sanitary sewer.
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Furthermore, the particulate contamination in the tanks was minimal
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and only found on infrequent occasions during normal discharge
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sampling. NRC representatives noted that without continual filtering
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or control of relea'ses to avoid draining! heavier particulate. material
into discharge suction at the tank bottom, potential releases of
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radioactive. particulates could occur. _NRC personnel reviewed the
following issues : with licensee ' representatives; evaluation of the
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particulate contamination in.the waste. tanks;; review of mechanisms,-
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either mechanical and/or procedural,- to ensure:only soluble material
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is . released; and determination of _ suction discharge intake ' level in
the . waste . tanks.
The licensee agreed to provide _ plans 'to address
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these issues.
The . inspector _ discussed procedural methodology to ensure adequate
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detection limits for material released to the sanitary sewer. -
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Detection limits - based on the sample size, counting time, and
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detector efficiency, should be evaluated - for each radioisotope
analysis methodology utilized.
In addition, the inspector noted that
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for each liquid waste tank sample tritium analysis, Procedure 9025,
required five useparate- one-minute counts; however, a review of
records .and discussion with technicians performing the analyses
indicated that only a- single five-minute '. liquid scintillation
counting analysis was being conducted.
Failure to follow the
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approved procedure for liquid scintillation tritium analyses was
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identified as an additional example of a -violation for failure to
follow procedures (50-160/87-02-01).
c.
The inspector reviewed liquid effluent discharge log books and
records.
The' inspector noted and discussed inconsistencies between
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times' for the collection, analyses and _ termination of the release.
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The inspector infonned licensee personnel that all samples should be
collected prior to _and during discharge of the waste tank contents.
Furthermore, all radiological analyses should be completed prior to
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termination of the release.
Licensee representatives stated that all
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samples were collected as required ' by TS; however, not all
radiological analyses. were completed prior to termination of the
release.-
Inspection determined that approved procedures did not
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address details of sampling; including sample representativeness,
sequence of sampling times, and timeliness of radiological analyses
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for each release.
This issue is addressed in details regarding
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rocedures for liquid waste tank sampling and analysis
p(Paragraph 5.a).
The inspector reviewed the records of liquid releases during
January 1986 to February 1987, and verified that concentrations of
radionuclides in liquid effluents released to the sewer system did
not exceed TS nor 10 CFR 20 Appendix B, Table II limits.
In general,
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concentrations of H-3 and gross beta-gama activity in liquid
effluents were approximately 1 E-4 uC1/ml and 1 E-7 to 1 E-8 uCi/ml,
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respectively.
The inspector noted that the licensee's evaluation of
anomolous results and computational corrections were adequate.
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- 6.
-All'egation Followup (99024)
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Allegation (2870020003)'
' Tampering;with a liquid waste tank- sample having 'a high tritium
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content.
Discussion and Finding.
From discussion with cognizant licensee -personnel - and . review of
applicable- . records, _ the . inspector - concluded 'that , tritium
concentrations measured _ for waste tank liquids have remained
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relatively. consistent since January 1986, approximately 1. E-4 uCi/ml.
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.All sample 'results were evaluated. and: detemined to . be within
regulatory compliance limits.
In addition, the inspector reviewed -
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mathematical corrections regarding data -on the waste tank sample
sheets and log books. All corrections appeared to be valid.
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The allegation concerning tampering with a liquid-waste tank sample -
having elevated H-3 concentrations was not substantiated.
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b.
Allegation _(2870020004)
Improper mixing of the_ waste tanks and failure to collect samples at-
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midpoint of the release.
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Disc'ussion and Finding
The inspector discussed liquid waste tank sample collection with
licensee representatives.
Operations did - not have approved
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procedures detailing sample collection . methodology (Paragraph 5.a).
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The 5,000 gallon tank utilized for releases does not have mechanical
- agitators to ensure homogeneous mixing of the tank contents prior to
discharge.
Furthermore, mechanical agitation could increase the
activity released to the sewer as a result of. resuspending known
particulate contamination in the tanks.
TS requirement 3.5.a(5)
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required two independent samples of a tank to be taken,_one prior to
release and one during release; and an independent sample to be taken
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from the discharge _ line durina the release.
If collected and
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analyzed in a systematic and timely manner, these samples could be
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used to demonstrate compliance with TS and -10 CFR 20, Appendix B
requirements.
Inspection revealed that radiological analyses of
samples collected during the discharge were not always completed
prior to termination of the release. A review of all sample results
indicated consistent tritium and gross beta-gamma concentrations
among the three samples collected during each discharge from the
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waste tank.
The allegation was partially substantiated in that thorough mixing of
the waste tank was not conducted and samples were not systematically
collected and analyzed to meet the intent of TS 3.5.a(5).
However,
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the -licensee-'was not required to collect a midpoint sample- during
each ' discharge.'
. Review of this issue resulted 1n the violation
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concerning failure to-have procedures for waste tank releases.
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