ML20237J974

Insp Rept 70-1151/87-13 on 870803-07.No Violations or Deviations Noted.Major Areas Inspected:Counting Room QC & Confirmatory Measurements,Radwaste Mgt & Environ Monitoring. Related Info Encl

ML20237J974
Person / Time
Site:	Westinghouse
Issue date:	08/20/1987
From:	Kahle J, Marston R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20237J935	List: ML20237J932 ML20237J974
References
70-1151-87-13, NUDOCS 8709040147
Download: ML20237J974 (11)

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-[ 'o UNITED STATES 8" "" 7, NUCLEAR REGULATORY COMMISSIONS

$ nE FIEGION 11 o, f 101 MARIETTA ST., N.W., SUITE 3100 oD ATLANTA, GEORGtA 30303 fiUG 2 81987 Report No.: 70-1151/87-13 Licensee: Westinghouse Electric Corporation Nuclear Fuel Division Columbia, SC 29250 Docket No.: 70-1151 License No.: SNM 1107 Facility Name: Columbia Plant Inspection Conducted: August 3-7, 1987 Inspector: - -

• Y 77 Date Signed

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R. R. Marston Approved by: d b N8M p d J. B. Kahle', Section Chief 67 YN<T7 Date Signed Division of Radiation Safety and Safeguards

SUMMARY

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

1 Results: No violations or deviations were identified.

I 8709040147 870828 PDR L ADOCK 07001151 PDR

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REPORT DETAILS

( 1. Persons Contacted

• W. L. Goodwin, Manager, Regulatory Affairs

• J. Heath, Manager, Health Physics Operations

• E. R. Reitler, Manager, Radiological and Environmental Engineering

• R. E. Fischer, Senior Engineer, Radiological and Environmental Engineering

• Attended exit interview

2. Exit Interview l

l The inspection scope and findings were summarized on August 7, 1987, with those persons indicated in Paragraph I above. The inspector described the areas inspected and discussed in detail the inspection findings listed below. No dissenting comments were received from the licensee. 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 (Closed) (VIO) 70-1151/84-11-03: Failure to meet HEPA filter differential pressure limits. Section 2.2.5 of the license application states that the maximum differential pressure permitted across a HEPA filter will be 8" H20. On numerous occasions during the month of September 1984 daily HEPA filter pressure drop readings for Air Effluent Exhaust System 1A exceeded 8.0". P ocedure FP-330, " Changing Absolute HEPA Filters," and 4 Procedure FP-328, " Air Effluent and Sintering Furnace Exhaust Systems )

Preventive Maintenance Program," reflect this requirement and require supervisory review of the daily pressure drop inspection. Licensee representatives stated that these procedures had been implemented. The inspector reviewed a sample of the filter inspection / records for the year to date and noted that filters were changed prior to reaching a pressure drop of 8" H 20. This item is closed.

4. Audits (88035, 88045)

a. In-house, informal audits of the effluent program and the environmental program were conducted by management. The inspector  ;

reviewed the following audit reports:

(1) Audit of Effluent Program, December 28, 1986 (2) Audit of Environmental Program, December 29, 1986.

The inspector noted that the audit of the effluent program was conducted for compliance to NRC regulatory requirements, 40 CFR 190, license application requirements and license conditions. No

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discrepancies were noted by the auditor, and trending of the effluent program was provided for the period from 1977 through the first half of 1986.

The audit of the environmental program was conducted for compliance to NRC regulatory requirements, 40 CFR 190, license requirements and Plant Health Physics Procedures. No discrepancies were identified.

The inspector noted that there was no formal requirement for followup of audit findings.

b. The licensee conducted audits of vendor participation in the licensee's effluent and environmental program. The following audits were reviewed:

(1) Audit of Controls for Environmental Pollution (CEP), December 16 and 17, 1986.

(2) Audit of Eberline Thermo Analytical, Inc. , December 16, 1986.

The above audits had not yet been formally written up, but the auditor's notes were reviewed. The notes included copies of the vendors' applicable procedures as well as vendor qualifications, certifications, and QA programs. Eberline has sampled and analyzed Congaree River water quarterly at three locations specified in the license application, Paragraph 2.7.1 and Figure 2.7.1, in addition to three other points. These samples were taken upstream and downstream of the plant discharge point and were analyzed for gross alpha and gross beta.

CEP performed analyses of urine samples as well as environmental samples collected by Westinghouse, including: fish, toil, sediment, vegetation, water and a monthly liquid effluent composite. Copies of the vendors' analytical procedures had been obtained by the auditor and were reviewed by the inspector. No adverse findings were noted by the auditor in either audit.

No violations or deviations were identified.

5. Procedures (88035, 88045, 84844)

License Application, Section 3.2.1, states that written procedures describing general radiation protection requirements sha'1 be maintained and followed. The inspector reviewed selected parts of procedures from the following areas:

a. Health Physics Operating Procedures;

b. Regulatory Affairs; and

c. Nuclear Materials Management Procedures.

g . .

3 A listing of the specific procedures reviewed is provided in Attachment 1.

The inspector concentrated primarily on those procedures which had been revised since the last inspection.

The inspector also reviewed the following Facilities Engineering Plant Procedures:

'FP-328, Air Effluent and Sintering Furnace Exhaust Systems Preventive-Maintenance Program, Revision 2, December 8, 1986.

FP-330, Changing Absolute HEPA Filters, Revision 3, August 4,-1986. j Procedure FP-328 provided criteria for changing prefilters, . intermediate filters, and HEPA filters. The 1,ystems using these filters were also identified. This procedure also provided for a daily inspection of the filters, including recording the pressure drop. Procedure FP-330 provided the instructions for these filters. Section 5.1 of FP-330 required that, "HEPA filters on negative pressure systems will be changed at or prior to an 8" H2 O pressure drop. Positive pressure systems will be changed at or prior to 4" H O 2 pressure drop."

The. inspector noted that procedures were being reviewed and approved by licensee representatives. The procedures appeared to adequately. implement NRC requirements and the license application and license conditions.

No violations or deviations were identified.

6. Records (88035,88045)

The inspector reviewed selected parts of the following records:

a. Seven Day Effluent Air Summary from December 29, 1986, through June 14, 1987

b. Chemistry Sample Log, from January 2, 1986, through August 5, 1987

c. Tennelec #1, 4, and 6, Monthly Plateau Determinations from July 1986 J through June 1987 l

d. Pu-239 Calibration Source Certifications

e. Congaree River Surface Water Summary for Locations 1,2,3,4,5,6 (by Eberline) from July 1986 through March 1987.

f. Liquid Effluent Monitor Monthly Composites (by CEP) from July 1986 through May 1987 (1) gross alpha ,

(2) gross beta (3) isotopic uranium (4) gamma spectroscopy l

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g. Ambient Environmental Air Analyses, from four locations for gross alpha from June 25, 1986, through June 19, 1987

h. Vegetation Analyses (by CEP), four samples each for gross alpha, +

gross beta, and fluorides; for May 1986 and September 1986

i. Soil Analyses (by CEP), four samples each, for gross alpha, gross beta, total uranium, and fluorides; for May 1386 and September 1986 i

j. Sediment Analysis (by CEP); for gross alpha, gross beta, fluorides, '

and isotopic uranium; for December 1986

k. Fish Analyses (by CEP); for gross alpha, gross beta, and isotopic .

uranium; for November 1986

1. Well and Surface Water Analyses (by CEP), for gross alpha, gross beta, and nitrate; from July 19861hrough May 1987

m. Special Ground Water Chemical Report, for gross alpha, gross beta, and nitrates (by CEP); and pH, fluorides, ammonia, and conductivity (by licensee); for samples taken September 12, 1986, December 18, 1986, and March 31, 1987

n. In-Pla 2 HEPA Filter Test (DOP), for the period from December 12, 1986, through August 3, 1987

o. Daily Filter Pressure Drop Readings, from January 4,1987, through August 6, 1987 ..

p. Air Sample System Integrity Checks, for the period from June 10, 1987, through August 4, 1987.

The inspector's review of these records indicated that the. licensee's effluent and environmental programs were conducted in accordance with NRC regulatory requirements, 40 CFR 190, license requirements, and licensee procedural requirements. 5 No violations or deviations were identified.

7. 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 inspector reviewed effluent reports for the periods covering January 1, 1986-June 30, 1986 (dated August 27, 1986) and July 1, 1986-December 31, 1986 (dated February 12, 1987). Attachment 2 to this report shows a comparison between the annual releases for 1984, 1985, and

. 5 1986. Gaseous results were obtained from point source analysis (gross

! alpha) of. stack- gas effluent, and liquid values were obtained by L compositing proportional samples prior to discharge to the Congaree River.

The licensee estimated the 1985 annual lung dose to an infant at the nearest residence to be approximately 2.7 mrem, and the lung dose to an infant at the site boundary was estimated to be 5.3 mrem. By comparison, the . licensee estimated the 1986 annual lung dose to an infant at the nearest residence to be approximately 2.7 mrem, and the infant lung dose at the site boundary was estimated to be 5.1 mrem. A licensee representative stated that there was a significant decrease -in gaseous effluent in the second half of 1986 due to improved process ventilation control. There was also a decrease in liquid effluent in the second half of 1986 due to improved filtration for processing contaminated waste.

No violations or deviations were identified.

8. Radioactive Waste Management (88035)

The inspector and a licensee representative examined various areas of the plant facility involved .in generation, treatment, and disposal of liquid radioactive waste.- The primary areas . inspected included process conversion, scrap recovery, and the Waste Treatment Facility. Licensee representatives stated that there had been no significant changes to the waste management program since the previous inspection (70-1151/86-11).

Regulatory Affairs Procedure, RA-401, " Environmental Control Requirements Mandated by 10 CFR 20," described the effluent environmental control requirements of 10 CFR 20 as they pertain to liquid and gaseous radiological discharges. Process waste liquid was monitored by an online sodium iodide monitor system. The system was set to alarm at 0.8 MPC (10 CFR'20, Appendix B, Table II, Column 2), and at 1.2 MPC, diverted flow to diversion tanks.

The process ventilation stacks were sampled continuously with filter media change every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Procedure RA-401 required that if a stack exceeded MPC (10 CFR 20, Appendix B, Table II, Column 1) for four consecutive samples, the source operation would be shut down.

The inspector also conducted a review of the HEPA filter test logs for DOP leak test results and differential pressure checks across the HEPA filter banks (see Paragraphs 6.n and 6.0). The licensee is required to replace the HEPA filter when _the differential pressure across 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.

9. Environmental Program (88045)

The inspector reviewed selected procedures, analytical results, and count room records with cognizant licensee representatives and determined that the organizational structure and program management had not changed since the previous inspection (70-1151/86-11). The inspector noted that

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procedures were in place to document responsibilities and coordinate sampling for the environmental program. The inspector and a cognizant licensee representative toured the owner-controlled area surrounding the plant and inspected a selection of the designated environmental sampling '

points and sampling equipment. The inspector concluded that the environmental monitoring program was conducted in accordance with Section 2.7 of the license application.

No violations or deviations were identified.

10. Confirmatory Measurements (84844)

The results of the analyses of the split samples collected during the previous inspection (70-1151/86-11) were discussed with licensee representatives (see Attachment 3). It was noted that the licensee's air filter was higher than the NRC results by 47%; but the liquid effluent analysis results were consistently lower than the NRC results:

Gross alpha -

48% of NRC results Gross beta -

26% of NRC results U-234 -

28% of NRC results U-235 -

21% of NRC results U-238 -

38% of NRC results A comparison of the data (see Attachment 3) shows agreement for the gross alpha analyses of the air sample and the gross alpha analysis of the liquid sample. However, the gross beta and isotopic analyses showed disagreement or no comparison. The comparison methodology is provided in Attachment 4.

The inspector discussed the collection of samples to be split between the licensee and NRC laboratories to evaluate the licensee's capability to accurately measure radionuclides in plant liquid and gaseous effluent process streams. Licensee representatives agreed to collect a particulate filter air sample and split liquid effluent samples. After analysis, the air sample filter and the liquid split samples, with the analytical results, would be sent to the Region II office in a timely manner. The inspector informed ~ licensee representatives that comparison of licensee and NRC results from these split sample analyses will be reviewed and discussed with the licensee representatives in the future.

(0pened) 70-1151/87-13-01 (IFI) Compare results of NRC and licensee analyses of split samples.

No violations or deviations were identified.

l l 11. Followup Items (92701)

(Closed) IF1 70-1151/86-11-03: Compare results of NRC and licensae cnalyses of split samples. The results were compared and discussed (see Paragraph 10, this report). This item is closed.

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ATTACHMENT 1 Procedures Reviewed by Inspector j

Health Physics Operations Procedures HP-01-024, Operation of Tennelec Counter Model LB 5100, Revision 1, j March 18, 1986 HP-01-025, Tennelec LB 5100 Calibration Procedure, Revision 0, January 17,

'1983

'HP-01-026, Tennelec Background and Efficiency Operation, Revision 0, August- 22, 1986 -l HP-05-048, Routine Responsibility Checklists, Revision 2, February 4, 1987 HP-05-056, Air Sample Systems Integrity Verification, Revision 3, January 14, 1987 HP-06-001, NPDES Daily -Weekly, and Monthly , Effluent Sample Collection, .

Revision 9, July 21,1987

• HP-06-008, Air Sampling Representativeness, Revision 0, January 2,1987 Regulatory Affairs Procedures i RA-204. Bioassay Program, Revision 3, December 16, 1986 RA-211, Low-Level Radioactive Waste Responsibilities, Revision 4, 4 March 30, 1987 Nuclear Materials Management Procedures

• NMM-CP-475, Control Chart Limits, Determination, Data Evaluation, and Response Actions, Revision 1, July 27,1987 Facilities Engineering Plant Procedures FP-328, Air Effluent and Sintering Furnace Exhaust Systems Preventive Maintenance Program, Revision 2, December 8,1986 FP-330, Changing Absolute HEPA Filters, Revision 3, August 4, 1986

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l ATTACHMENT 2 Comparison of Effluents Released Year 1984 1985 1986 Gaseous Effluents (microcuries) 1,915 1,536 1,505 Liquid Effluents (microcuries) 176,200 246,200 111,171 j

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t ATTACHMENT 4

-Criteria for Comparing Analytical Measurements )

This' enclosure provides criteria for comparing results of capability tests

and verification measurements. The criteria

are based on' an empirical relationship which combines prior experience and the accuracy needs of this- )

program.  !

1 L In this criteria, the judgement limits' denoting agreement or disagreement' l between licensee and NRC results are variable. .This variability is a-functioniof the NRC's value relative to its associated uncertainty. As the ratio of the NRC value to its associated uncertainty referred to in this program as " Resolution"2 increases, the range of acceptable differences between the NRC and licensee values should be more restrictive. Conversely',

poorer agreement between NRC and ' licensee values must be considered acceptable.as the resolution decreases.

H For. comparison purposes, a ratio 2 of the licensee value to the NRC value is computed. This . ratio is then evaluated for agreement based on . the ,

calculated ' resolution. The corresponding resolution. and calculated ratios '

which denote agreement are listed in Table 1 below. Values outside of the agreement ratios are considered in disagreement.

2 Resolution = NRC Reference Value Associated Uncertainty for the Value

]

2 Comparison Ratic = Licensee Value NRC Reference Value TABLE 1 1 Confirmatory Measurements Acceptance Criteria For Gross Beta and Gross Alpha Measurements Resolutions vs. Comparison Ratio Comparison Ratio for Resolution Agreement

< 4 no comparison 4- 7 0.3 - 3.0 i 8- 12 0.4 - 2.5 ')

16 - 50 0.5 - 2.0 51 - 200 0.6 - 1.66 r- >200 0.75 - 1.33 j i

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