ML20244D830
| ML20244D830 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 05/25/1989 |
| From: | Kahle J, Stoddart P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20244D828 | List: |
| References | |
| 70-1113-89-04, NUDOCS 8906190276 | |
| Download: ML20244D830 (9) | |
Text
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' UNITED STATES :
l fER MG NUCLEAR REGULATORY COMMISSION
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- ch 101 M RIE ST EET, N.W.
ATLANTA, GEORGIA 30323 i
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t % Y Ps 5 M Report No.: 70-1113/89-04 i
Licensee: General Electric Company Wilmington, NC 28401 j
1 Docket No.: 1113 License No.: SNM-1097 Facility Name: -General Electric Company Inspection Conducted: April 24-28,1989
' Inspector:
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5-6'8f
.j P. G. Stoddart-Date Signed-1 Approved by: h4[hdU P/b[f <
J. B. Kahle, Chief Date Signed Radiological Effluents and. Chemistry Section l
Emergency Preparedness and Radiological 3
1 Protection Branch Division of Radiation Safety and Safeguards
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SUMMARY
Scope:
This routine, unannounced inspection was. in.the areasiof, radioactive waste -
management; radioactive effluent sampling, monitoring, and. analysis; and '
radiological environmental monitoring.
Results:
Review of logs and sampling data indicated adequate treatment: and' control-of radioactive liquid and gaseous effluents.
The licensee had made good progress-toward : incineration of a-large backlog of wooden radioactive. waste storage -
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boxes and had reduced the.. inventory from. 776 boxes,: as of September 1988, to -
only 40 boxes-as 'of this inspection..The remaining 40 boxes were proje'cted' to-l be processed within four to five weeks of the' time of this inspection..
A computer-based : heating, ventilating,. and ~ air conditioning. (HVAC)l system -
status monitoring and control. system had been placed in' operation-in the fuel manufacturing area.
The' system was.-designed to improve building: air balance conditions, provide for monitoring and control ~of hoods and process: enclosures, and to monitor flow and pressure'-drop in.high efficiency. particulate air (HEPA)-
filter installations.
The' inspector also reviewed information to be included in the ' licensee's~ forthcoming Environmental ' Report.
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One non-cited violation (NCV) was identified for failure to meet a license condition for sensitivity of isotopic uranium radioactivity analyses.
No deviations were identified.
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REPORT DETAILS 1.
Persons Contacted i.icensee Employees J. Bradberry, Jr., Manager, Emergency Preparedness and Security
- W. Cameron, Supervisor, Shop Operations
- T. Crawford, Engineer, Environmental Protection D. Hassler, Manufacturing Engineer, HVAC Systems
- P. Stansbury, Senior Engineer, Nuclear Safety H. Strickler, Senior Project Manager, Environmental Protection
- R. Torres, Manager, Radiation Protection
'C. Vaughan, Manager, Regulatory Compliance P. Winslow, Manager, Licensing and Nuclear Materials Management Other licensee employees contacted during this inspection included engineers, operators, technicians, and office personnel.
- Attended exit interview 2.
Liquid Radioactive and Chemical Waste Management (88035)
All liquid process streams of radioactive and nonradioactive nature were collected in the several plant waste treatment systems.
After chemical treatment and processing, the streams entered a series of process and discharge lagoons.
The outfall of each of two discharges was continuously sampled on a basis proportional to the volumetric rate of outflow.
Samplers captured a fixed small volume sample for each 1,000 gallons of discharge and composited the aliquots in a container. Composited samples were callected daily, with the exceptions of weekends and holidays.
Daily composites were analyzed for total uranium content and reported in terms of parts per million (ppm, by weight).
Aliquots from daily composite samples were used to produce weekly composited samples, which were analyzed for gross alpha and beta radioactivity.
A third composited sample was prepared for each 6-month period (semiannual) and was analyzed for l
1 No violations or deviations were identified.
3.
Environmental Monitoring (88045) l All site drainage, including the outfalls of the treatment lagoons and storm drains, passed through a site dam prior to discharging to the Northeast Cape Fear River.
A daily grab sample was collected at the dam discharge and analyzed for totcl uranium in ppm.
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The inspector noted the presence'of' active small minnows in the stream of water at the site dam-outfall.
This appeared to confirm that the licensee's treatment of chemical wastes had made~the effluent.sufficiently J
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d pure to support small fish population.
It was1 also noted that the vegetation in and around the stream appeared to be green and healthy.:
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The inspector reviewed logs of. analyses. of. samples' from the process lagoons, -site _ dam, railroad _ bridge, boat landing (Castle Hayne),- and General Electric dock for calendar year 1988.
The highest observed -
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uranium values were' from the process lagoon. outfalls for the. month of -
L January 1988, and ranged from 0.02 ppm' to 0.21 ppm,'with.an average of q
about 0.05 ppm for the month..These values were consistent with or.below q
values seen in previous years.
Maximum permissible concentration-(MPC)-
J for the estimated annual enrichment value was calculated to be'21.6 ppm.
On this basis, the highest release. value, prior to dilution in the sited drainage system and in the_ Northeast Cape Fear River, was approximately; 1 percent (%) of MPC,- with average daily concentrations at about 0.25%
MPC.
Concentrations measured at-the site dam for the same period were a.
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l maximum _of 0.13 ppm and average daily concentrations, based on grab sample-data, were about 0.02 to 0.04 ppm, or less than 1% of MPC.
The inspector revieued records of weekly composite sample results from the l
Federal Paper Corporation process lagoons at Riegelwood, NC.
All sample i
results were a small fraction of the MPC limits of.10 CFR Part 20,
- I Appendix B, Table II, Column 2.
Samples appeared to'have.been collected i
and analyzed in accordance with license conditions.
The inspector reviewed results of analyses of samples of ~ sludge from'the licensee's onsite sanitary waste treate nt system. Results appeared to be.
adequate and radioactivity content wau Kwer than observed in previous-inspections (Inspection Report No. 70-1113/88-06).
Sanitary sewage" treatment sludge was stcred onsite.by spreading ~ it on a former sanitary waste lagoon as authorized by the license.
No violations or deviations were identified.
4.
Heating, Ventilation, and Air Conditioning (HVAC) System (88035)
- O The inspector examined the licensee's recently installed system for the-
'j status monitoring and operational control of the HVAC system for the fuel'-
1 manufacturing facility and discussed the system installation, design, and j
operating experience with licensee representatives.
This was a computer-based system which tracked such parameters as temperature, filter pressure drop, differential air pressures between areas and rooms, motor 1
power consumption in amperes, air velocity, chiller water flow, damper l
position, humidity, time, date, elapsed or run time, and static pressure at points in.the system.
At the time of this inspection,100% of all-j gaseous (air) exhaust systemt and all recirculating systems and from 50%
to 60% of radioactive hoocs and process enclosures in the fuel _
1 manufacturing area had been incorporated into the system with 100%
coverage of all radioactive hoods and process enclosures expected to be l
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3 completed within the next several months.
Consideration was being given to extending the system to HVAC systems of other site facilities.
It was l
noted that the system had the capacity and capability to include other environmental factors, such as radiation levels, radioactivity concentrations in air or effluent paths, fire detection and industrial hygiene through the use of a variety of existing detection modules.
While the monitoring and control system would not eliminate the need for in-person monitoring and observation of the various conditions of the HVAC system, it would provide continuous monitoring of essential factors and conditions and provide for instantaneous detection and alarm in the event of upset or trouble anywhere in the HVAC system or subsystems.
The monitoring and control system was conceived, designed, and constructed over approximately the last two years by licensee personnel, utilizing primarily off-the-shelf components or modules. Computer software programs were also conceived and developed by onsite licensee personnel.
The demonstrated onsite capability of developing such a system in-house, coupled with the necessary management support and funding, was considered by the inspector to be a licensee strength.
No violations or deviations were identified.
5.
Radioactive Gaseous Effluent Monitoring and Environmental Monitoring (88035,88045)
The inspector reviewed plant radioactive gaseous stack effluent sampling and analysis results for the fourth quarter of calendar year 1988.
Average weekly concentrations of gross alpha activity varied between 1E-13 uCi/cc to IE-15 uCi/cc.
Such concentrations of effluents represented less than 50% of MPC (10 CFR 20, Appendix B Table II, Column 2) at the point of discharge to the atmosphere without further consideration. of the atmospheric dispersion and diffusion characteristics of the plant site.
Section 5.2.1.2 of the License Application provided for sampling of air downwind of the fuel manufacturing facility in the N, S, SW and NE directions. Samples were to be collected continuously and, in addition to analysis for gross alpha in week-long samples activity, the samples from-each location were to be composited and analyzed on a monthly basis for uranium isotopes with an analytical sensitivity of at least E-16 uti/ml.
The inspector reviewed the results of the analyses for the above samples for calendar year 1988.
Results of the gross alpha analyses of weekly-samples ranged from 20E-16 uCi/ml to 70E-16 uCi/ml and the observed values appeared to be consistent with results from prior years. However, in the inspector's review of the isotopic uranium analysis results of the monthly composited samples for the same period, it was observed that beginning with the analyses for the month of June (1988), the data appeared to be erratic by factors greater than could be accounted for by statistical errors alone.
For the months of October through December, the results were extremely erratic. The vendor's analysis report for the October 1988
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4 samples noted:
"7hese samples were analyzed twice; both times the yields were low, resulting in higher LLDs and higher positive results than normal.
The positive results are not considered to be very reliable."
The vendor's data included statistical error (two sigma) values as much as a factor of 100 or more greater than were shown in the analyses of composite samples for the first nine months of the year.
The vendor reported the isotopic uranium results in terms of uCi/ft3 for U-234, U-235 and U-238.
For reporting purposes, the licensee converted the vendor results to units of 10E-05 pCi/m3 When the inspector re-evaluated the licensee's data conversion, it was determined that the 1
reported results were actually in units of IE-05 pCi/m3 In units of uCi/ml, the NRC's preferred form, the results had been expressed in terms of IE-17 uCi/ml.
When the alpha isotopic results were expressed in units of E-16 uCi/mi, several items became more apparent.
First, the 2-sigma values and "less than" values were of such magnitude as to show that more than half of the analyses did not meet the specified analytical sensitivity of "at least" E-16 uCi/ml.
Second, and as previously noted, the numerical values of radioactivity ascribed to the 3 ruclides reported were highly erratic.
Third, since the licensee's process feed material had an average U-235 enrichment of approximately 2.5%, the ratio of U-234 alpha activity to that of U-238 should have been approximately 6.5:1; calculated ratios varied from 0.3:1 to 21:1, with only one of 15 calculated ratios coming within 20% of the expected value.
When this matter was discussed with licensee representatives during the l
inspection and again during telephone conversations on May 4,1989, and l
May 9, 1989, it was stated that the licensee's control procedures had been-keyed to the results of the weekly gross alpha analyses rather than to the 3
monthly alpha isotopic analyses and that the erratic isotopic measurements i
I and failure to meet the analytical sensitivity criteria for uranium isotopes had not been recognized as such.
A licensee representative stated that discussions had been opened with the vendor to fully ascertain the reasons for the poor chemical dissolution yield and high background counts, which the vendor acknowledged were the apparent cause of the:
erratic results and high statistical errors, and the reasons why no j
appropriate remedial action had been taken through the vendor's quality assurance program. A licensee representative stated that the licensee had initiated procedural and quality assurance measures to prevent a future recurrence.
The licensee was informed on May 9, 1989, that the failure to meet the criterion in Section 5.2.12 of the License Application was a violation of License Condition number 9, which requires that licensed material be used in accordance with the statements, representatives, and conditions of Part I of the licensee's application.
The licensee's corrective actions
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were determined to be adequate; therefore, the violation is not being cited because the criteria specified in Section V.A. of the Enforcement Policy were satisfied and no Notice of Violation was issued.
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follow-up review in subsequent inspections, this matter was entered in the Region 11 tracking system as noted below.
4 The inspector reviewed a recent licensee audit of the vendor providing the l
analyses discussed above.
The audit was identified as IP 89-01, dated March 28, 1989, and was conducted March 20, 1989.
No findings were identified in the audit and there were no findings listed for previous I
audits of the same vendor.
The ' inspector' noted that the auditor apparently did not identify or discuss with the vendor the discrepancies detailed in the above discussion of alpha isotopic analyses for the period of June-December 1988.
l In discussions with licensee representatives and as a result of the i
I inspector's review of the audit described above, it was apparent that, while several members of the licensee's staff, including the cognizant licensee representatives and the audit staff, had reviewed the. isotopic uranium analysis data, the licensee staff had not previously recognized l
the discrepancies noted in the alpha isotopic analyses and had not recognized that requirements of the license had not been met.
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The inspector concluded that this appeared to be an example of weakness on l
the part of the licensee staff in the areas of procedural completeness, j
quality assurance, and technical expertise. in low-level radiological I
measurements.
l (0pened) NCV 70-1113/89-04-01:
Review corrective measures to assure that l
isotopic uranium analyses of air samples meet the sensitivity requirement 1
l of E-16 uCi/ml as required by the license, l
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OtherActivities(88035,88045)
The inspector, at the request of the licensee, reviewed information to be l
included in the Environmental Report, which was to be submitted at a later date as part of the facility license renewal.
A number of typographical i
errors were noted and certain anomalies were pointed out.
The inspector l
l also suggested re-formatting of a small number of charts and tables for i
purposes of consistency.
The reviewed material was considered to be proprietary in nature.
On April 27, 1989, the licensee's Manager of Emergency Preparedness and Security contacted the inspector relative to the discovery and recovery of a quantity of scrap zircalloy fuel rod pieces on the evening of the previous day.
The material consisted primarily of zircalloy castings for fuel rod end pieces.
Some of the material had been machined, some partially machined, while some parts had never been machined.
There was no visual evidence to indicate that any of the material had ever been welded to a fuel tube and, therefore, no reason to assume that the material had ever been in contact with fuel pellets or had ever been part of a used (irradiated) fuel assembly.
All pieces had been surveyed with portable alpha survey instrumentation and no radioactivity was detected.
The material weighed about 50 pounds and occupied a space equivalent to l
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two gallons of water in a 5-gallon plastic pail._ The niaterial had been found by a scavenger in a creek bed below a bridge:in an area where stolen property or material was frequently disposed of.
Based on a preliminary
-l investigation, a licensee representative stated that the material :had probably been.taken from a -scrap bin.1ocated at the' rear' of the fuel-components manufacturing area in the belief that the material' was stainless-steel.
It was postulated that when the material was found to be j
not. salable, it was disposed of.by dumping it in the creek..A sheriff's-R deputy, called ' to the site by _ the scavenger,.who _had also recovered.
.i electronic equipment marked as property 'of-a local school district, identified the zircalloy pieces as. originating from the licensee's q
facility and notified facility Security.
No violations or deviations were identified.
7.
WasteBoxes(88035)
.j The inspector, through discussions with licensee representatives, and a tour of the staging areas for storing wooden boxes of radioactively.
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contaminated waste, determined that the backlog of boxes has been reduced.
to approximately 40 boxes. In September of 1988, the backlog inventory was' 776 boxes.
Reduction in the outside storage of this large backlog of waste boxes is definitely a strength in the licensee's safety program.
No violations or deviations were identified.
8.
Exit Interview q
The inspection scope and results were summarized on April 28, 1989, with those persons indicated in Paragraph 1.
The inspector described the areas inspected and discussed in detail the inspection results listed above.
Although proprietary information was reviewed during this inspection,'none h
is contained in this report.
Dissenting comments were'not received from the licensee.
Concerns regarding the sensitivity of isotopic uranium radioactivity analyses were discussed with licensee representatives on May 4 and 9, 1989.
Logs and sampling data indicated adequate treatment and control' of radioactive liquid and gaseous effluents..The licensee had made good progress.toward incineration of a large backlog of wooden radioactive I
waste storage boxes and had reduced the inventory from 776 boxes, as 'of.
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September 1988, to only 40 boxes as of this inspection. The remaining 40 boxes were projected to be processed within four to five weeks of the time of this inspection.
1 A computer-based HVAC system status monitoring and control system had been placed in operation in the fuel manufacturing area.
The system was-designed to improve building air balance conditions, provide for i
monitoring and control of hoods and process enclosures, and to monitor flow and pressure-drop in (HEPA filter installations. 'The inspector also j
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informally reviewed a draft of the licensee's forthcoming Environmental Report.
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One NCV was identified for failure to meet license requirements for j
sensitivity of isotopic uranium radioactivity analyses.
No deviations were identified.
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