ML20207T229

Insp Rept 50-160/87-02 on 870217-23.Violations Noted:Failure to Have Operating Procedures for Sampling of Liquid Waste Tanks & Failure to Follow Health Physics & Surveillance Procedures

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: ML20207T216 ML20207T225 ML20207T229
References
50-160-87-02, 50-160-87-2, NUDOCS 8703230329
Download: ML20207T229 (7)

See also: IR 05000160/1987002

Text

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Report No.:- 50-160/87-02- ,

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Licensee:- Georgia-InstituteofTechnojogy /

225 North Avenue-

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' 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: Olr4 @ bf 3 b1 NN

G. B. Kbzo

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(i Date Signed

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Approved by: -

'D 7/3 /d 7

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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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 j

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 l

Analysis, 7/17/81, the inspector noted that the coolant sample line is ]

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. TS 6.4.b(6) and TS 6.4.b(7)

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

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necessary if compliance with 10 CFR 20 Appendix B limits was to be

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

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that.although :the TS required samples were collected prior to and

,' .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-

F (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

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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

scintillation counting equipment. Licensee representatives stated

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that the major contaminants found in the waste tank was tritium  !

(soluble) and Co-60 (particulate) and believed the procedure to be

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adequate for release of soluble material to the sanitary sewer

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system. - To verify the adequacy of the -licensee methodology, the

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).

L 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

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regarding the potential for release of the insoluble radioactive

particulate materials in the waste tank to the sanitary sewer system

j 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

stated that the high turbidity of water in the waste tanks introduced

! 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

i- and only found on infrequent occasions during normal discharge

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 .

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

n is . released; and determination of _ suction discharge intake ' level in

, the . waste . tanks. The licensee agreed to provide _ plans 'to address

these issues.

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The . inspector _ discussed procedural methodology to ensure adequate '

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detection limits for material released to the sanitary sewer. -

Detection limits - based on the sample size, counting time, and

detector efficiency, should be evaluated - for each radioisotope

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analysis methodology utilized. In addition, the inspector noted that

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

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counting analysis was being conducted. Failure to follow the

approved procedure for liquid scintillation tritium analyses was

L 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

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records. The' inspector noted and discussed inconsistencies between

times' for the collection, analyses and _ termination of the release.

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l The inspector infonned licensee personnel that all samples should be

collected prior to _and during discharge of the waste tank contents.

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Furthermore, all radiological analyses should be completed prior to

4 termination of the release. Licensee representatives stated that all

samples were collected as required ' by TS; however, not all

radiological analyses. were completed prior to termination of the

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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

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

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not exceed TS nor 10 CFR 20 Appendix B, Table II limits. In general,

concentrations of H-3 and gross beta-gama activity in liquid

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effluents were approximately 1 E-4 uC1/ml and 1 E-7 to 1 E-8 uCi/ml,

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) '

a.. Allegation (2870020003)'

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' Tampering;with a liquid waste tank- sample having 'a high tritium

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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.

All sample 'results were evaluated. and: detemined to . be within

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regulatory compliance limits. In addition, the inspector reviewed - -

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-

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

l procedures detailing sample collection . methodology (Paragraph 5.a).

l 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

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particulate contamination in the tanks. TS requirement 3.5.a(5)

j. required two independent samples of a tank to be taken,_one prior to

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release and one during release; and an independent sample to be taken

, 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

l' 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

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each ' discharge.' . Review of this issue resulted 1n the violation

concerning failure to-have procedures for waste tank releases.

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