ML20215N000
| ML20215N000 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 10/09/1986 |
| From: | Adamovitz S, Dan Collins, Gloersen W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20215M993 | List: |
| References | |
| 70-1151-86-11, NUDOCS 8611040156 | |
| Download: ML20215N000 (10) | |
Text
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NUCLEAR REGULATORY COMMisslON
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101 MARIETTA STREET N.W.
t-ATLANTA, GEORGI A 30323
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OCT 2 31986 Report No.: 70-1151/86-11 Licensee: Westinghouse Electric Corporation Nuclear Fuel Division Columbia, SC 29250 Docket No.:
70-1151 (Fuel Division)
License No.: SNM-1107 Facility Name: Westinghouse Electric Corporation Inspection ~ Conducted: July 28, 1986 - August 11, 1986 Inspectors:
4 E
/MM hN W. B. Gloersen Date Signed
) m m / h n; w s;
/d-9-fL' S. S. Adamovitz V-Date Signed Approved by:
/d - f-26 D.
M.- Collins, Branch Chief Date Signed Division of Radiation Safety and Safeguards SU!HARY Scope:
This routine, unannounced inspection covered the following areas:
counting room quality control and confirmatory measurements; radioactive waste management; and environmental monitoring.
Results:
One violation was identified Failure to have an adequate calibration procedure to-determine counter efficiency for the Tennelec LB 5100 alpha / beta proportional counter. The failure to.take. corrective action as committed to in a response to Violation 70-1151/84-11-03 was also identified.
8611040156 861023 PDR ADOCK 07001151 C
2 REPORT DETAILS 1.
Persons Contacted Licensee Employees
- W. J. Hartnett, Acting Plant Manager
- W. L. Goodwin, Manager, Regulatory Affairs
- E. E. Keelen, Manager, Manufacturing
- E. K. Reitler, Technical Coordinator, R&E Engineering
- J. W. Heath, Manager, Health Physics Operations R. E. Fischer, Senior R&E Engineer D. L. Colwell,- Measurement Control Coordinator Other licensee employees contacted included one technician.
- Attended exit interview 2.
Exit Interview The inspection. scope and findings were summarized on August 1,1986, with those persons indicated in Paragraph 1.
A previous violation (see Inspection Report No. 70-1151/84-11-03) involving failure to meet if cense The condition HEPA filter differential pressure setpoints remain open.
inspectors also informed licensee representatives that failure to have approved procedures for-efficiency determinations and p'erformance checks of laboratory alpha counting equipment (Paragraph 5.c) would be considered an Unresolved Item
- pending further review by Region II management.
During a telephone conversation on August 11, 1986, between USNRC RII management and C. F. Sanders (Westinghouse, NFD), the licensee was informed that the Unresolved Item would be considered a violation (Paragraph 5.c).
One new Inspector Followup Item concerning split sample analyses.(Paragraph 9.b) was Licensee representatives acknowledged the violation and.the identified.
The licensee did not identify as proprietary any of inspectors' comments.
the material provided to or reviewed by the inspectors during this inspection.
3.
Licensee Action on Previous Enforcement Matters (Closed) 70-1151/83-01-01:
(VIO) Failure to follow Health Physics (HP)
Operating Procedure 06-002 pertaining to gaseous effluent stack sampling and HP Procedure 06-002 required routine inspection of stack monitoring.
- An unresolved item is a matter about.which more information is required to determine whether it is acceptable or may involve a violation or deviation.
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deficiencies observed. and ~
stations, corrections of any sampling notification of the responsible Radiological and Environmental.. Engineer of Procedure 05-056. " Air Sample Systems Integrity-any problems encountered. Verification," was written and implemented to assure, on a Health Physics each stack sampling station was operating correctly.
responsibility sheets were used to assure that this inspection was performed each time the stack samples were changed. This item is considered closed.
(Closed) 70-1151/84-11-02:
(VIO) Failure to have written calibration The inspectors reviewed In-Vivo procedures for the in-vivo counting system.and revised In-Vivo Procedure 9, Rev.1, Procedure 9, Rev. 0,. 2/11/85The procedure provided generalized instructions intended for March 4, 1986.
Regulatory Affairs - professionals to - perform the calibration of the whole-body counter; however, detailed self-explanatory instructions appeared to be omitted. This item-is considered closed.~
(Closed) 70-1151/84-11-04:
(VIO)FailuretonotifyNRCRegionII.withinten days of changes -to NPDES permit.'
Corrective administrative actions by
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included verbal counseling and. informal memos to licensee personnel responsible individuals.
The requirement to notify NRC of NPDES permit The licensee changes has'since been _ removed from the license conditions.has also This item is documents new requirements and the responsive individual..
considered closed.
(VIO) Failure to meet HEPA filter differential (0 pen) 70-1151/84-11-03:
Pressure limits were observed to be-within prescribed pressure limits.. limits, but the licensee had not completed corrective action in that the procedure governing surveillance on the system had not been approved.
4.
Audits;(88035,88045)
In-house, informal audits of the radiation control program, including analytical results, measurements and effluent releases, were conducted a.
routinely by management. The inspectors noted..however, that there was no formal. mechanism for data. review, problem identification and The inspectors reviewed-the following audit reports:
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resolution.
1.
REE-RDM-85-067 Program Audit, Shipping / Receiving of UF6, December 22, 1985 REE-REF-85-067 Effluent Audit Program, November 27, 1985 2.
Summary Effluent and Environmental Monthly Monitoring Reports, 3.
January 1985 - April 1986 4.
Columbia Plant Audit Report:
July 1, 1985 - December 31, 1985; dated March 31, 1985,Section V, Effluent and Environmental Monitoring
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Westinghouse Audit of the Vendor:
Controls for Environmental Pollution, May 15, 1984 The inspectors discussed audit results and followup actions with cognizant' licensee representatives.
Anomalous environmental data were reported to management via the monthly Summary Effluent and Environmental Monitoring Report.
The Columbia Plant Audit Report:
July 1, 1985 - December 31, 1985, provided annual dose estimates to the nearest resident, summarized radioactive liquid and gaseous effluents, and identified developing trends.
A corporate audit of the Radiation Protection Program was conducted in May 1984, and was reviewed during a previous ' inspection (70-1151/84-11)..No significant items or adverse trends regarding the present inspection areas.were identified in the audit reports.
b.
The inspectors discussed the Westinghouse audit of the vendor:
Controls for Environmental Pollution.
The inspectors noted that an audit was conducted in May 1984, and inquired if a current audit had been conducted.
Licensee representatives indicated a Westinghouse corporate audit of the vendor had been conducted during the first half of 1986, but that the formal ' report had not yet been issued.
Licensee representatives indicated they would review the corporate audit to determine if the audit satisfied waste management and environmental program requirements. No violations or deviations were identified.
5.
Procedures (88035, 88045) a.
License Application Section 3.2.1 states that written procedures describing general radiation protection requirements for selected surveillance activities will be maintained.
The inspectors reviewed selected portions of the following procedures:
(1) RA-101 Records. Management Program, Rev. 2, May 1, 1984 (2) RA-204 Bioassay Program, Rev. 2, February 8, 1984 (3) RA-209 Low-Level Radioactive Waste Audit Plan, Rev. 4, July 14, 1986 (4) RA-210 Radioactivity Airborne Investigations, Rev. 3, March 28, 1985 (5) RA-211 Low-Level Radioactive Waste Responsibilities, Rev. 3, October 14, 1985 (6) RA-216 Low-Level Radioactive Waste Releases.to Wooden Boxes, Rev. O, April 8, 1985 (7) RA-400 NPDES Permit Program, Rev. 2, April 25, 1984 (8) RA-401 Environmental Control Requirements Mandated by 10 CFR 20, Rev. 1, April 25, 1984 (9) RA-404 PCB Handling and Disposal, Rev. 2, April 25, 1984 (10) RC-405 Hazardous Waste Management, Rev. 1, July 24, 1981 (11)05-001 Preparation and Analysis of Inplant Air Samples, Rev. 3, February 5, 1986 (12)05-002 Obtcining Removable Alpha Activity By Means of Smear, Rev. 2, September 26, 1983
5 (13)05-003 Analysis and Release of Uranium Solutions, Rev. 5, March 10, 1986 (14) ~05-004-A Determining Alpha Activity of a Water Sample (Any Sample
.in Liquid State), Rev. 3, February 26, 1986 (15 05-016A Weekly Measured Discards Report, Rev.'3, January 14, 1986 (16 05-037 HEPA Filter System Leak Test, Rev. 1, March 3, 1981 05-048 Routine Responsibility Checklists, Rev. 1, March 11, 1985 (17 (18)05-053 Proper Use of Measurement Standards, Rev.1. August 23, 1985 (19)~05-056 Air Sample Systems Integrity Verification, Rev. 2, February 15, 1986 (20)06-001 NPDES Daily, Weekly, and Monthly Effluent Sample Collection, Rev. 7, March 18, 1985 (21)06-002 Roof Effluent Air Sampling and Counting, Rev. 5, April 13, 1984 l
(22)06-003 Ambient Environmental Air Monitoring for Radioactivity, Rev. 3, February 18, 1986 (23)06-006' Collection of Routine Weekly and Monthly Environmental
~ Samples, Rev. 3, May 23, 1983 (24) NMM-470 Control Chart Limits ' Determination and Data Evaluation, Rev. 5, June 26, 1985 (25)01-024 Operation of Tennelec Counter Model LB5100, Rev. 1, March 10, 1986 (26)'HP-01-025 Tennelec LB5100 Calibration Procedure, Rev. 0, January.17, 1983 (27) Invivo Procedure 9, Invivo Calibration, Rev. 1, August-4, 1986 Isotopic Uranium in Water (Diethylether (28).CEP Procedure extraction), no date (29) CEP Procedure - Determination of Gross Alpha and Gross Beta in
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Water, no date (30) CEP Procedure - Procedure for Fluorometric Determination of Uranium in Urine, Rev. 2, December 15, 1983 (31) FP-328, Air Effluent - and' Sintering Furnace Exhaust Systems Preventive Maintenance. Program, Rev.1, June 29,1979 4
(32) FP-330 Changing Absolute (HEPA)-Filters, Rev. 2, August 6, 1984 The inspectors.noted that procedures were being reviewed and approved by licensee representatives.
Inspectors' concerns regarding specific procedures were discussed with cognizant licensee representatives as noted in Paragraphs 5.b and 5.c.
The inspectors reviewed Procedure FP-330 " Changing Absolute (HEPA) b.
Filters."
This review was conducted to verify the licensee's.
corrective actions to the ' Notice of Violation (N0V), regarding failure to meet HEPA filter differential pressure limits for effluent process streams (70-1151/84-11-03), were being implemented. - The inspection disclosed that Procedure FP-330 had been modified but not approved until -the last day of the onsite inspection (August 1,1986).
The inspectors noted that the effective date of this procedure was August 4, 1986.
The licensee's response dated February 19, 1985, to the NOV (70-1151/84-11-03) stated that the maintenance procedure for
6 the filter systems would be modified to include daily review of filter pressure drop readings and that full compliance would be achieved by March 15,1985.. The inspectors determined that the daily review was Failure to performed but not according to an approved procedure.
approve the modified procedure for the filter systems maintenance by results in the violation remaining open.
The failure March 15, 1985, to approve the' modified procedure for filter system maintenance by March 19, 1985, is considered a failure on the part of the licensee to take full corrective action on Violation 70-1151/84-11-03.
Strong This violation management attention should be directed to this matter.
remains open pending licensee action.
c.
The inspectors reviewed Procedure HP-01-025 "Tennelec LB5100 Calibration Procedure," Rev. O, January 17, 1983, and noted this procedure covered the determination of alpha and/or beta plateaus but did not include an efficiency determination. The inspectors also noted the licensee did not have a procedure to cover background and of the alpha counting equipment.
License performance checks Condition 2.1 of Safeguards Amendment No. SG-2 to Special Nuclear Materials License No. SNM-1107 requires the licensee to follow
-Chapters 1.0 through 8.0 of the current Fundamental Nuclear Material Control (FNMC) Plan.
Section 4.1.2 of the FNMC Plan states the of measurements of nuclear material are measurement and control detailed in written procedures which include calibrating chemical analysis equipment.
Section 3.4, A-7 of the FNMC Plan defines the radiometric analysis method as the measurement system for gaseous 10 CFR 70.57(a)(8)-
effluents to be released to the environment.
defines calibration to mean the process of determining the numerical relationship between the observed output of a measurement system and-the value, based upon reference standards, of the characteristics being From discussions with cognizant licensee representatives, measured.
the inspectors determined that the.Tennelec LB5100s were being used for i
gaseous effluent accountability since air particulate filters were these detectors.
The inspectors. informed licensee counted on representatives during the August 1,1986, exit interview that this L
issue would be considered an unresolved item pending review by
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Following review by NRC Region II management and Region II management.
by Nuclear Materials Safety and Safeguards, this issue was determined l
to be a violation (Severity ) Level V) of license conditions identified above and 10 CFR 70.57(a)(8.
The inspectors informed licensee representatives by telephone on August 11, 1986, that failure to provide adequate written procedures for calibration and performance checks of alpha counting equipment was a violation (70-1151/86-11-02).
One violation and one continuing violation were identified in this program area.
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6.
Records (88035,-88045)
The inspectors reviewed selected portions of the following records:
a.
(1) Gaseous Effluent Weekly Summary Report, January 1985 - May 1986 (2) Liquid Waste Analyses from Vendor - (CEP - Controls for Environmental Pollution) January 1985 - June 1986 (a) Gross alpha (b) Gross beta (c) Isotopic uranium (d) Gamma (3) Air Sample System Integrity Checks, January 6,1986 - July 14, 1986 (4) Daily (HEPA) Filter Pressure Drop Readings (per FP-328),
January 2, 1986 - July.31, 1986 (5) HEPA Filter Leak Test Results, January 1986 - July 1986 (6) Tennelec's #2 and #4 Data Sheets (Background and Performance Checks) January 1986 - July 1986 (7) Well Water Radiological Summary for Wells #1, 2, 3, and. 4, 1982-1983 (8) Surface Water Radiological Summary for Road, Spillway, Causeway, Entrance, and Exit, 1982-1983
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(9) Congaree River Surface Water Summary for Locations #1, 2, 3, 4, 5, and 6, 1983 (10) Soil Analysis Summary for Locations #1, 2, 3, and 4,1981-1983 (11) Vegetation Analysis. Summary for Locations #1, 2, 3, and 4, 1981-1983 Results of the record review were discussed with cognizant. licensee representatives as noted in Paragraph 6.b.
The inspectors noted that QC data for laboratory instrumentation were b.
trended as indicated in a -previous inspection report still not (70-1151/84-11). Licensee representatives indicated they'are currently automating count room data transfer via a new computer system and plan to initiate data trending by the end of the calendar year.
No violations or deviations were identified.
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7.
Radioactive Waste Management (88035)-
The inspectors and a licensee representative examined various areas of the plant-facility involving radioactive liquid waste generation, treatment, and disposal.
The principal areas inspected included process conversion, scrap recovery,- and the Waste-Treatment Facility including the quarantine tanks, 2-process and storage. lagoons.
The inspectors also reviewed liquid effluent release records (see Paragraph 6) compiled during January 1986 to June 1986, i
and noted that the licensee was in compliance with 10 CFR-20.106(a).
Inspect 1on 'of the airborne ' effluent program consisted of a review of.
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facility ventilation systems with major emphasis directed toward required i
processing (scrubbing and filtration), monitoring and controlling releases of'. gaseous effluents via. process stacks -located on the manufacturing building roof..The inspectors accompanied licensee representatives on a tour of the process stacks dedicated to vent specific process areas within i
the facility.
The inspection of the manufacturing building effluent exhausts also included the - five calciner combustion gas exhaust - vents.
Gaseous products from the combustion;of natural gas in the calciner heating chambers' are vented to the atmosphere without HEPA filtration.
Generally, combustion gas products do not come into contact with the. reaction gases 4
within the calciner tube and thus rarely exceed licensee administrative action limits. Occasionally, minor ventilation problems occurred within the immediate vicinity of thd calciners.
The licensee had a corrective-action program in place in cases when the administrative limits were exceeded. The-inspectors noted that in.RA-401, " Environmental Control Requirements Mandated by 10 CFR 20," that if a stack exceeded the administrative limits j'
(set below the concentrations listed in 10 CFR 20, Appendix B, Table II) for-more than four consecutive samples,. the affected operation would. be i
terminated until the problem could be determined and evaluated.
The inspectors also conducted a review of the HEPA filter test logs for D0P
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- leak test results and -differential pressure checks across the HEPA filter bank compiled during. January 2,1986 - July 30,1986.
The licensee is required to replace the HEPA filter when the differential pressure across
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'the' HEPA filter is greater than eight inches of water for negative. pressure systems.
From a review of selected records cited above, it was determined that the filter systems were-maintained as required.
No violations or deviations were identified.
8.
Effluent Release Report (88035)
-10 CFR 70.59 requires the licensee to submit a report to the NRC Region II Office within 60 days after January 1 and July 1 of each year specifying the quantity of each of the principal radionuclides released to unrestricted areas in liquid and gaseous effluents during -the previous six months of operation.
The ' inspectors' reviewed the semiannual effluent release reports for the periods covering January 1,1985 - June 30,1985 (dated August 7, 1985) and July 1, 1985 - December 31, 1985 ( ated February 17,1986). Based on data contained in the 1984 effluent reports, the total amount of uranium
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9 176,200 uCi and in gaseous effluents was released in liquid effluents was 1915 uC1.
In 1985, the total amount of uranium released in liquid effluents was 246,200 uC1, while the releases in gaseous effluents totaled 1536 uCf.
Gaseous results were obtained from point source analysis (gross alpha) of effluent.
Liquid results were obtained by compositing stack gas The proportional samples prior to the discharge to the Congaree River.
licensee uses a vendor laboratory to analyze the 30-day composite samples The inspectors noted for gross alpha, gross beta, and isotopic uranium.
that the licensee estimated the 1985 annual lung dose to an infant at the The lung dose at the site nearest residence to be approximately 2.7 mrem.
boundary was estimated to be 5.3 mrem.
No violations or deviations were identified.
9.
Environmental Program (88045)
The inspectors reviewed selected procedures, analytical results, and a.
licensee representatives and counting room records with cognizant determined that the organizational structure and program management had not changed since the previous radioactive waste and environmental inspection (70-1151/84-11).
The inspectors noted that the procedures were in place to document responsibilities and coordinate sampling for the environmental program.
The inspectors also noted and expressed concern that the QC program implementation did not meet the general guidance of Regulatory Guide 4.15 " Quality Assurance for Radiological Monitoring Programs."
Licensee representatives agreed to ovaluate the use of Regulatory Guide 4.15 for the QC program.
The inspectors discussed the collection of samples to be split between b.
the licensee and NRC laboratories to evaluate the licensee's capability to measure accurately radionuclides in plant liquid and gaseous effluent process streams.
Licensee representatives collected a particulate filter and split liquid effluent samples and agreed to send The the analytical results to the Region II office in a timely manner.
inspectors informed licensee representatives that comparison of licensee and NRC results from these split sample analyses will be reviewed during a subsequent inspectfon.
(0pened) 70-1151/86-11-03 (IFI) Compare results of NRC and licensee analyses of split samples.
No violations or deviations were identified.
Licensee Action on Previously Identified Inspector Followup Items (92701) 10.
(Closed) 70-1151/84-03-02 (IFI): Calciner Exhaust Vent Problems. This item dealt with administrative action limits being periodically exceeded byThe
~Calciner Units 2 and 5 exhaust vents during the final quarter of 1984.
elevated activities appeared to be attributed to periodic calciner discharge leaks and minor ventilation problems within the immediate vicinity of the calciners.
The inspectors reviewed a memo dated December 14, 1984,
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" Corrective Actions to Reduce HP Results on Calciner Combustion Gas Effluent."
Some of the corrective actions included:
(1) the use of dust control tents when process equipment was breached near the calciner; (2) the replacement of broken port hole plugs with new ones; (3) the replacement of flimsy. burlap seals with better-tighter fit seals; (4) the monitoring of daily count sheets and correlating activities in the area with counts; and (5) the addition of mechanical dampers to the vent systems so as to reduce the magnitude of the negative pressure in the system. The inspectors noted that four out of a total of five calciner combustion gas effluent lines had the modifications.
Based on a selective review of gaseous effluent weekly summaries, the problem appeared to have been controlled.
This item is considered closed.
(Closed) 70-1151/84-11-01 (IFI):
Update and Review of Radiation Protection Procedures.
Procedure 05-003 " Analysis and Release of UNH Samples," was revised to include performance checks and recalibration of the NaI detector.
Other procedures had not been revised to include control limits for plant radiation protection instrumentation and analyses. -However, this item is being tracked by FRP Inspection Report 70-1151/86-12.
This item is considered closed.
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