ML20235F414

Insp Rept 70-1113/87-12 on 870824-28.No Violations or Deviations Noted.Major Areas Inspected:Radwaste Mgt,Environ Monitoring & Confirmatory Measurements

ML20235F414
Person / Time
Site:	07001113
Issue date:	09/18/1987
From:	Kahle J, Stoddart P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20235F412	List: ML20235F409 ML20235F414
References
70-1113-87-12, NUDOCS 8709290097
Download: ML20235F414 (11)

Text

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UNITED STATES

- [p Rf og ,

o NUCLEAR REGULATORY COMMISSION y's '

g. REGION 11

< 0 101 MARIETTA STREET, N.W.

I* *- f ATLANTA, GEORGI A 30323 4 o 9'"**g SEP 2 2 537 Report No.: 70 .1.113/87-12 Licensee: General Electric Company Wilmington, NC 28401 Docket No.: 70-1113 License No.: SNM-1097 Facility Name: Nuclear Fuel and Component Manufacturing Inspection Conducted g August 24-28 1987 Inspector: A '

GdAo 9// [ f 7 v P. G. 5 ~dd'rt DatfSig'ned Approved by:

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J. BAa le, Section Chief '

[c 1.t 9[/f/77 Date/ Signed '

Divisi6 of Radiation Safety and Safeguards

SUMMARY

Scope: This routine unannounced inspection was in the areas of radioactive waste management, environmental monitoring and confirmatory measurements.

Results: No violations or deviations were identified.

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REPORT DETAILS ,

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1. Persons Contacted Licensee Employees

• C. Vaughan, Manager, Regulatory Compliance

• G. Bowman, Senior Program Manager

• W. B. Smalley, Senior Program Manager

• T. P. Winslow, Manager, Licensing and Nuclear Materials Management

• E. A. Schaefer, Senior Engineer, Chemet Labs

• P. Stansbury, Senior Nuclear Safety Engineer

• R. L'. Torres, Manager, Radiation Protection

• T. R. Crawford, Engineer, Environmental Protection

• B. F. Bentley, Manager, Fuel Production

• R. H. Foleck, Senior Specialist, Licensing Engineering

• S. P. Murray, Senior Nuclear Safety Engineer '!

• B. J. Beane, Manager, HVAC Systems

• B. S. Dunn, Specialist, Licensing Support

• Attended exit interview

2. Exit Interview The inspection scope and findings were summarized on August 28, 1987, with l those persons indicated in Paragraph 1 above. The licensee did not identify as- proprietary any of the materials provided to or reviewed by the inspector during this inspection.

3. Licensee Action on Previous Enforcement Matters (Closed) Violation 86-01-01: Improper installation of HEPA filters resulting in release of particulate material on January 22, 1986. The inspector reviewed procedure revisions for installation and for quality control of installation of HEPA filters ir. primary and secondary effluent treatment filter systems. Required training for filter change personnel was reviewed and determined to be adequate. The licensee's actions were appropriate and adequate to preclude repetition of circumstances which led  ;

to the release of January 22, 1986. This matter is considered closed.

4. Radioactive Waste Management (88035)

All liquid process waste streams were collected in the waste treatment systems. After treatment and being diluted with uncontaminated water the l streams entered a series of process and discharge lagoons. The outfall of l each of two discharges was sampled continuously on a basis proportional to j the rate of outflew. The sampler captured a fixed small volume sample for j each 1,000 gallons of discharge and collected the aliquots in a bottle.

With outflow running at approximately 300 to 500 gallons a minute, a '

sample was added to the composite every two to three minutes. Composites l

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2 were collected daily, except for weekends and holidays. Daily composites were analyzed for uranium content. An additional weekly composite was made from samples collected during the week and was analyzed for gross alpha and beta activity. A third composite was prepared for each 6 month period (semi-annual) and was analyzed for technecium-99.

In addition to the discharge lagoon outfall sampler, all site drainage, including discharge lagoon outf all and storm drains, passed through the spillway of a site dam prior to reaching the North East Cape Fear River.

~A daily grab sample was collected and analyzed for uranium.

The inspector reviewed 1986 grab sample analysis results of water from the site dam outflow to the North East Cape Fear River. Maximum uranium concentration observed was 0.96 ppm. This equates to approximately 5% of MPC for uranium at the enrichment used by the licensee.

The inspector and licensee representatives discussed the question of concentration of radioactive materials in sanitary sewage treatment plants. The licensee has an onsite sewage treatment system.

Periodically, sludge was removed from the treatment facility and was spread over the area of a former process settling pond (area of approximately 2 acres). The inspector, accompanied by a licensee representative, toured the sanitary sewage treatment plant and observed the sludge spreading area. As a result of recent heavy rainfall, an undetermined shallow depth of water covered about one-third of the 2 acre area. Vegetation in the spreading area was in good condition and waterfowl and wading birds were observed using the area.

The inspector reviewed analyses of sludge samples collected in the current year. Analysis results were: J Type of Analysis Date Sampled l l'

6/4/87 7/2/87 8/6/87 Trace uranium in sludge, as received 0.06 ppm U 0.05 ppm U 1.30 ppm U Trace uranium in dried material 20 ppm U 10.2 ppm U 278 ppm U Total solids content 3,140 ppm 5,300 ppm 4,800 ppm (0.31 w/o) (0.53 w/o) (0.48 w/o)

Licensee representatives recognized the elevated August result and plan to  !

evaluate further after the September analyses are completed.

Offsite shipments of liquid ammonium nitrate solutions were made one or more times daily to the Federal Paperboard Company at Riegelwood, NC for use in their waste treatment system. Uranium concentrations were determined from samples frem each batch and a weekly composite was counted i

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for gross alpha and beta radioactivity. Uranium analyses were performed on the Scintrex-UA-3 analyzer.

No violations or deviations were identified.

5. Gaseous Radioactive Waste Management (88075)

All plant gaseous effluent streams with known potential for release of radioactive materials to the environment were prefiltered and then final filtered through either one or two levels of high efficiency particulate air (HEPA) filters prior to release. All radioactive or potentially radioactive effluent release points were monitored by continuous particulate filtration sampling devices and laboratory analysis of the collected samples.

The inspector reviewed revised procedure 340-FME-85-70, "HEPA Filter Change and Certification," Rev.3, issued February 25, 1987. Changes in the procedure responsive to Violation 70-1113/86-01-01 included: addition of "one-over-one" signature by the filter , installer and the HVAC Supervisor to assure proper positioning of each filter, proper operation of damping devices, and adequate sealing of the filter gaskets; addition of the review of stack emission trends by the FME Manager, HVAC Systems Engineer, and the HVAC Supervisors; and a requirement for training and qualification of FME filter change personnel with retraining ' and requalification required every two years. Based on the inspector's review of the procedure and on discussions with licensee representatives, the procedural changes were adequate to minimize the potential for a recurrence of improper HEPA filter installations.

Licensee representatives informed the inspector of pending revisions to HVAC control systems which would substantially improve control of building airflow and air balance and was expected to result in improved system performance and decreased radioactive emissions. It was noted however, that a " tightening-up" program initiated after the January 1986 release had resulted in an approximate factor of two improvement in control of releases and that further improvement would likely not be of a dramatic nature. The initial phase of the pending revisions was anticipated to be completed by the end of CY 1988.

No violations or deviations were identified, i

6. Solid Radioactive Waste Management (88035)

The inspector and licensee representatives discussed the operation of the licensee's incineration facility for oxidation of combustible solid wastes. After shutdowns in 1986 and early 1987 to install new refactory material, a modified scrubber and a new " bag house" for dust collection, the incinerator had a capacity for approximately five 4'x4'x4' boxes of combustibles each eight hour shift.

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4 As of January 1,1987, the licensee had a backlog.of 3,1414'x4'x4' wooden boxes of contaminated solid combustible waste, stored on-site on three

" pads". ,

As originally conceived, the boxes were to have been stored for approximately 60-days to permit uranium decay products to build to

-equilibrium, at which. time each box was to have been moved to a sensitive gamma radiation detection array for analysis of the uranium 235 content.

After analysis, the boxes. were to be transferred to the incinerator I facility.,

Failure of the original incinerator facility in 1976, combined with delays in replacing the incinerator led to the accumulation of several thousand boxes, all of which were stored outdoors with little or no protection from the weather. The new incinerator did not meet its intended capacity and was not ribl e to do much more than " break-even" with plant waste generation. In a typical year, approximately 700 to 800 boxes of

-combustible waste were generated. The incinerator was able to handle only 1,029 boxes in 1985 and 924 boxes in 1986, operation on a 3-shift, 5-day week schedule. With the modifications made in late 1986 and early 1987, the incinerator capacity was increased to approximately five boxes per shift and as of August 24, 1987, 1,298 boxes had oeen processed while 440 new boxes had been generated to date in 1987. This represented a " gain" of 858 boxes in reducing stored inventory. Barring breakdown of the incinerator, the backlog of stored boxes was expected to be cleared out by the end of calendar year 1988.

Licensee representatives informed the inspector that as of July 1,1987, a >

new type of storage box, made principally of waterproofed reinforced j cardboard, had been used in place of the plywood storage boxes previously esed. Tests of the cardboard boxes demonstrated resistance to weathering f for the anticipated 60-day storage period while the box construction j materials permitted a shorter incineration period, which was expected to l increase incinerator output. Until more data on weathering characteristics are obtained and reviewed, the cardboard boxes were to be incinerated promptly after the end of the 60-day storage period.

7. Environmental Protection (88045)

The licensee's environmental radioactivity monitoring program was based principally on plant effluent sampling and analysis and used sampling of the offsite environment as a means of confirming the licensee's )

projectiles of minimal environmental impact. Analyses of samples 1 collected from gaseous effluent stacks, from liquid outfalls, and from groundwater monitoring wells formed the principal bases of the program.  ;

The program was backed-up or confirmed by measurements made by sampling l and analyzing environmental water and soil, from offsite locations. The physical makeup of plant releases, e.g., soluble and insoluble forms of j low-enriched uranium, were such as to be essentially identical to known naturally occurring radioactive components present in air, soils, biota and in common fertilizers. The projected or calculated concentrations and

5 accumulations of plant effluents in the environment were small and generally indistinguishable from natural background. Sampling and analysis of effluents at the point of release, i .e., prior to dispersion and dilution in the environment, permitted calculation of the environmental effects of. plant effluents at levels below that which could be determined from evaluation of results of analysis of samples collected in the plant environs.

Each identified point of release of gaseous effluents was sampled continuously and analyzed for uranium content. Samples from most gaseous release points were analyzed monthly, while certain release point samples identified on the basis of past analysis records, were collected and analyzed weekly.

The inspector reviewed analysis data from 1986 and 1987 (to date) gaseous effluent stack samples. The only observed anomaly of significance was the result for the effluent stack sample involved in the January 1986 event in which gaseous effluent from a GEC0 " flameout" escaped through a filter system in which HEPA filters had been improperly installed (see Violation 86-01-01). Maximum effluent concentrations (with the above-noted exception) were in the range of 0.01 to 5.0 E-12 microcuries per millileter (gross alpha activity). The annual average MPC for continuous offsite exposure to insoluble uranium-234 was 4.0 E-12 microcuries per milliliter.

Four ambient air samplers were located near the site boundary at points downward of the principal effluent release points. These locations were selected on the basis of historical meteorological data, fence line proximity, and general offsite population distribution.

Results of analyses of 1986 and 1987 air samples from the four ambient air sampling stations located near the plant fence lines were in the range of 10 to 25 E-16 microcuries per milliliter, with the exception of one sample collected during the release of January 1986 (see above discussion) which indicated 4.4 E-14 microcuries per milliliter for the week of January l 22-29, 1986. To put these values in perspective, the MPC of 10 CFR Part l 20, Appendix B, Table II, Column 1, for continuous exposure to of fsite populations, was 4.0 E-12 microcuries per milliliter. The release of January 22-29, 1986, was at a level of approximately 1% of MPC, while the remaining analyses were orders of magnitude less.

Water samples were collected monthly at points on the North East Cape Fear River both upstream and downstream of the plant outfall. These samples were analyzed for uranium content. No radioactivity attributable to plant operations was detected in the upstream and downstream samples.

Groundwater monitoring wells provided data on potential groundwater transport of radioactive contaminants from the site. Some 30 wells were provided and all were located inside the plant property. Potable water and plant process water were also obtained from 15 site wells; these wells were deeper than the groundwater monitoring wells but were also regularly sampled and analyzed for radioactivity content. Historically, the water

6 supply wells have never shown any uranium activity. Among the groundwater monitoring wells, Waste Treatment Well #1 had radioactivity levels consistently above the reporting limits of 15 picoeuries per liter (alpha) and 50 picocuries per liter (beta). This well was located immediately adjacent to the Waste Treatment area and reflected known leaks of radioactive material from the period 1975-1980.

The inspector reviewed monitor well groundwater samples "or the period 1985 and 1986. During the review, it was noted that asphe activity was measured in wells 1A, 20, and 21 during the period of Septenber 1985 to June 1986. The wells were located in a drainage ditch servicing the solid waste storage pads. The licensee's investigation concluded that the contamination originated from leakage of material from deteriorated wooden radioactive waste storage boxes on the solid waste storage pads. A small but unquantified amount of low-enriched uranium apparently was washed out of one or more of the deteriorated boxes and was carried into the ditch area by rain and rain runoff water.

The licensee's remedial actions included removing approximately two inches of contaminated marl and gravel from the surface of the storage pads and shipping the material to an offsite disposal facility, regrading of the pads to assure control of runoff and to divert runoff to the site dam, adding a six-inch-high berm at the south side of each storage pad to prevent runoff water from escaping offsite, re packaging the contents of the seriously deteriorated wooden boxqs, and adding a 6 mil thickness polyethylene plastic cap on each box to retard weathering and deteriorations of the wooden boxes. In addition, the Regulatory Compliance and Radiation Protection groups were required to conduct weekly inspections of the storage pad areas (See Paragraph 6 of this Inspection Report).

No violations or deviations were identified.

8. Semi-Annual Effluent Release Reports (88045)

The inspector reviewed the licensee's Semi-Annual Effluent Release Reports for calendar years 1985 and 1986 and also for the first six-month period of 1987. The data presented indicate that the licensee was within discharge limits of the license and was in compliance with 10 CFR 20.106 for release of radioactive matericis to the environment.

A table of the licensee's effluent data for January 1985 through June 1987 was prepared to show trends. The table appears as an Attachment to this Report. In January of 1986, the licensee had a release of uranium particulate aerosol (gaseous release) which was attributed to improper installation of HEPA filters. As a result of that release, the licensee t instituted a program for the reduction of particulate releases. This L program involved improved quality control on installations and maintenance of HEPA filters and improved control of processes having potential f or generations of particulate aerosols. in approximately the same time (

period, the licensee revised liquid process treatment systems to provide J

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for better _ recovery of n uranium content previously discharged to the settling : lagoons and from which some uranium was discharged to the North East' Cape Fear River. Comparing' releases for the first six months of 1985 and . of ' 1987, gaseous effluents showed 'a reduction - of a: factor .of approximately three while liquid effluents were reduced by a factor.of approximately two.

J No violations or. deviations were identified.

l  : 9. ~ Bioassay Quality Assurance Program (84844 and 92706) u The inspector and ' a licensee representative. discussed the quality assurance program _ for RMC-Canberra system for in-vivo ccunting o f-insoluble uranium in the lungs of plant personnel. Contractor reports for 1986 were reviewed by the inspector. The inspector observed that the system was calibrated annually by the contractor (RMC-Canberra) using a -

sources either obtained directly from the National Bureau of Standards-(NBS) or from suppliers participating in quality assurance programs with-the NBS. Periodic performance checks and background determinations were m made to ensure the operability of the system and to verify calibration status. Contractor and licensee records indicated that 1,802 analyses had l been made of facility personnel in the period from January-1, 1985 through h March 31, 1937. Approximately 63% of all analyses showed that body / lung burdens were lower than the minimum detectable levels (MDL) of approximately 50 micrograms U-235. Approximately 36% of all analyses showed lung burdens ranging 'from MDL to 150 micrograms U-235. Less than 1% of all analyses were in the range from 150 to less than 200 micrograms U-235. Based on the calibration and quality assurance programs conducted by the contractor, the. inspector concluded that the quality assurance program was adequate and that the lung burden results should be considered val i d.,

The inspector reviewed records of the laboratory quality assurance program and quality controls for the operation calibration and maintenance of the Scintrex UA-3 Analyzer used in the licensee's urinalysis program for determination of soluble uranium. Unknown or " spiked" samples were analyzed at least once during each operating shift on which urinalyses were being performed. A review of spiked sample analytical results for 1986 and the first seven months of 1987 indicated that at low

• concentrations of uranium in urine, results averaged about 6.2% high (106.2% recovery). Results at medium concentrations averaged approximately 11% low (88.8% recovery), while at high known concentrations, results averaged about 24% low (76% recovery). The above values were based on 49 spikes at high concentrations, 170 at medium concentrations, and 148 at low concentrations.

While there were no official NRC Acceptance criteria for bioassay urine analyses, the results were considered acceptable for this type of analysis ,

when related to the draft American National Standards Institute (ANSI) {

criteria for bioassay measurements. It should be noted that the i

" standards" proposed in the draf t ANSI criteria and used by the licensee J i

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are .. prepared in an artificial': urine solution and .that no fully

. sati sf actory H artificial urine has. been developed,. the use. of which satisfactorily correlates to analyses of spiked human urine.

11 0 . Confirmat'ory Measurements and Quality Assurance in - Laboratory Analyses (84844).

The . inspector and licensee representatives. discussed - results of confirmatory measurement samples split between the licensee and NRC during a 1985 inspection. Results of four samples showed good agreement; however, the results of a fifth liquid sample having a - very low concentration of soluble uranium were in disagreement by - a factor of approximately 50. . Regarding this :last sample which was analyzed by a

x-ray fluorescence method by both the licensee . and' by the NRC contract laboratory, licensee. representatives stated that as a consequence of

. repeated occurrence of high values of standard deviation, the x-ray fluorescence instrument was replaced, shortly after the 1985 inspection,'

by a 'Scintrex UA-3 Analyzer.and by .an Inductively Coupled. Plasma (ICP) spectrometer. The UA-3 was utilized in the range from 1 ppb to 10 ppm of uranium, while the ICp was utilized in the range from above 1 ppm of uranium.

At . the - inspector's request, the licensee agreed to provide NRC Region II

-(RJI) with split . samples representing two effluent stack air sampler filters and aliquots of two liquid process effluent samples. In the case of the air sample filters, the complete filters were to be supplied to RII

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after completion of routine analyses. In the case of the liquid samples, the original samples were to be well mixed and two aliquots-of each sample

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were to- be prepared, one of which would be retained for analysis by the licensee, while .the other would be sent to 'RII, at which point the RII samples would be trans-shipped to the NRC Contract Laboratory for analysis. Results of analyses made by the licensee were to be sent to RII, after which the licensee would be apprisad of the NRC Cont'ract

' Laboratory analysis results.

The inspector reviewed records of the laboratory quality assurance program and quality controls for the operation, calibration and maintenance of the UA-3 Analyzer and the ICP spectrometer used in the liquid process and effluent radioactivity analysis programs. The inspector also observed laboratory personnel making a calibration run on the UA-3 Analyzer using uranium standard solutions traceable to the National Bureau of Standards.

s - Licensee representatives stated that for both the UA-3 Analyter and the ICP Spectrometer, calibrations were performed prior to, and af ter, each sample analysis; the inspector's review of licensee records confirmed that the stated calibrations were being performed. In the UA-3 calibration the inspector observed, the accuracy of the analysis of a 2.0 ppb standard was such that there was no discernible error in the meter needle's indication at 2.0 ppb. '

Measurements of dissolved uranium in process waste water was accomplished in the laboratory with the Scintrex UA-3 Analyzer and with an Y_____ _-_ _

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e inductively-compled plasma (ICP) spectrometer (Instruments S. A. , Model ,

JY38). Concentrations ranging f rom approximately 1 ppb to about 10 ppm e.~' .

were measured using the Scintrex UA-3 Analyzer while concentrations above l

10 ppm were made with the ICP Spectrometer.

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The Scintrex UA-3 utilized a nitrogen laser v supplied a monochromatic ultraviolet light. Uranium atoms absorbing tt. .aser's ultra-violet light ,)

energy emitted a green luminescence which was cetected and measured by a photomultiplier (p.m.) tube. The addition of a buffered pyro phosphate -

enhanced the luminescent yield of uranium by a factor of about 80. s In the ICP spectrometer, the liquid to be analyzed for uranium content was "

acidified, mixed with argon gas to form an aerosol, and injected into an argon plasma operating at greater than 5,000 K, where the aerosol was -

ionized. As uranium ions diffused into cooler areas of the plasma, they emitted electromagnetic radiations in the ultraviolet to infrared regions of the optical spectrum. The electromagnetic radiations were analyzed and quantitatively evaluated by a scanning diffraction spectrometer. both the ,

Scintrex UA-3 Analyzer and the ICP Spectrometer were calibrated prior to  ;'

and subsequent to each determination.

Based on the above discurtions, the inspector concluded that the licensee's provi; ions for confirmatory measurements and quality assurance in laboratory analyses were adequate.

(Closed) 70-1113/85-01-01, IFI: -

Review split sample analysis results between GE and RESL. The 1985 split sample results were discussed with licensee personnel. A discrepancy '

between GE and RESL results on one sample of low uranium c:nce.1tration was a moot point since the licensee had recognized the basic problem with the analytical device in question and had replaced it shortly after the 1985 inspection. This matter is considered closed.

(0pened) 70-113/87-13-01, IFI:

The licensee submit samples to compare analytical results with NRC contract lab. ,

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