ML20246A511

Insp Rept 70-1151/89-04 on 890530-0602.No Violations or Deviations Noted.Major Areas Inspected:Liquid & Gaseous Effluents,Environ Monitoring & Confirmatory Measurements

ML20246A511
Person / Time
Site:	Westinghouse
Issue date:	06/20/1989
From:	Adamovitz S, Dan Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20246A501	List: ML20246A499 ML20246A511
References
70-1151-89-04, 70-1151-89-4, NUDOCS 8907070011
Download: ML20246A511 (13)

Text

_

. t

. . UNITED STATES g SErg'o NUCLEAR REGULATORY COMMISslON

.7ff" ' ' #

REGION il

.g g 101 MARIETTA STREET, N.W.

• - g ATI.ANTA, GEORGI A 30323 4

9 " " * ,o JUN 2 21989 Report No.: 70-1151/89-04 Licensee: Westinghouse Electric Corporation Commercial Nuclear Fuel Division Columbia, SC 29250 Docket No.: 70-1151 License No.: SNM-1107 Facility Name: Commercial Nuclear Fuel Division c l

Inspection Conducted: May 30 - June 2, 1989 Inspector: hms // O?RMW .6 'O  ?

S. 5. Adamovitz V D&te Signed Approved by: MM.br c) 4/2dP/M D. M. Collins, Acting Chief Tate ' Signed Radiological Effluents and Chemistry Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards

SUMMARY

Scope:

This routine, unannounced inspection was conducted in the areas of liquid and gaseous effluents, environmental monitoring, and confirmatory measurements.

Results:

In the areas inspected, violations or deviations were not identified.

The licensee's commitment to effective control of radioactive effluents was {

evidenced by the continuing decrease in liquid effluent activity (Paragraph 5). )

Liquid effluents had decreased by almost an order of magnitude from 1985 to 1988, and gaseous effluents remained constant even though the facility was processing material with a higher percent enrichment.

Additional management review of HEPA filter test results (Paragraph 4) had been implemented in response to a problem identified in Inspection Report No. 88-06.

In that previous inspection, DOP test results of 0.4 percent were identified as passing.

1 The licensee had improved data management for the laboratory (Paragraph 6).

Software upgrading provided automatic transfer of effluent air filter counts from the Tennelec counters to a computer for activity calculations and data 8907070021 PDR 890622 C ADOCK 07001151 PDC

JUN 221989 L

l storage. A second upgrade tracked Tennelec performance checks, identified i trends, and actions to be taken.

The results of the confirmatory measurements for a gaseous effluent sample were found to be in agreement-(Paragraph 8). Aninspectorfollow-upitem(IFI)was closed concerning this measurement.

One IFI was identified concerning the review of test results for possible alpha self-absorption by effluent filter wetting (Paragraph 3.b).

The licensee had applied to the State for a mixing zone which would allow variances from specified groundwater quality standards in a subsurface zone (Paragraph 7.b).

The February 1989. incident concerning 25 dead deer found on adjacent property near the Congaree River was discussed (Paragraph 7.c). Preliminary evidence indicated the deaths were probably due to a virus and not attributable to the facility.

t l ,

l' . .

(

l l REPORT DETAILS

1. Persons Contacted Licensee Enployees K. Bartsch, Technician A, Regulatory Operations

• R. Fischer, Senior Engineer, Regulatory Affairs

• W. Goodwin, Manager, Regulatory Affairs

• J. Heath, Manager, Regulatory Operations

• E. Keelen, Manager, Manufacturing

• P. Loch, Plant Manager

• E. Reitler, Manager, Regulatory Engineering Function

• Attended exit interview

2. Audit (88035, 88045)

Licensee Application, Section 3.1.2.3, Item (7), states the specific responsibilities of the Radiation Protection Component shall include audits of license activities for compliance with applicable State and Federal regulations, licenses, permits, and documentation of these audits to facilitate corrective actions. License Application, Section 3.1.4.5, states .that the Radiation Protection Component shall perform quarterly data audits of environmental quality to assure that chemical and radiological effluents and environmental concentrations are within license and permit conditions. Licensee Application, Section 3.2.1.2(7), states that the Radiation Protection Component shall perform an evaluation every two years of vendors used to analyze environmental or bioassay samples.

The inspector reviewed the monthly " Summary Effluent and Environmental Monitoring Reports" for September 1988 to March 1989. The levels of gross alpha radioactivity in the liquid effluent discharged to the Congaree River ranged from 0.38 to 1.36 percent ("I,) maximum permissible concentration (MPC). Monthly averages for gaseous effluents from the pellet area furnace air exhausts and the chemical process air exhausts were reported as less than the unrestricted area MPC. These reports satisfied the required data audit specift in Section 3.1.4.5 of the License Application.

The licensee conducted three vendor audits during December 1988. One vendor laboratory performed NPDES compliance analyses for Westinghouse on a routine basis. Two other laboratories were used for chemical and radiochemical analyses of environmental samples. The audits concluded  !

that the vendors were acceptable to perform specified environmental sample analyses.

The inspector also reviewed two in-house audits conducted during December 1988 which covered the effluent and environmental programs. The inspector

- _ - _ _ - _ - _ _ - _ _ _ _ _ - _ - - a

v 4 -

noted that 'the programs were audited against applicable regulatory requirements and license conditions. Liquid and gaseous effluents were evaluated against regulatory limitations and the ALARA philosophy.

No violations or deviations were identified.

3. Procedures (88035, 88045, 84844)

a. License Application, Section 3.2.1.1, states that written procedures describing general radiation protection requirements shall be maintained and followed. The inspector reviewed selected parts of the following procedures concentrating on procedures that had been revised since the last inspection:

(1)01-025, Calibration of Tennelec LB5100 Automatic Sample Counters, Revision 3, March 22, 1989 (2)01-026, Tennelec Background and Efficiency Operation, Revision 0, August 25, 1986 (3)05-003, Analysis and Release of Uranium Solutions, Revision 6, July 11,1988 (4) 05-004-A, Determining Alpha Activity of a Water Sample (Any Sample in a Liquid State), Revision 5, December 16, 1988 (5)05-056, Air Sample Systems Integrity Verification, Revishn 4, i July 11,1988 l (6)05-062, Gamma Survey of Ventilation Eauipment, Revision 3, January 17, 1989 (7)06-001, NPOES Daily, Weekly, and Monthly Effluent Sample Collection, Revision 10, May 19, 1989 (8)06-002, Roof Effluent Air Sampling and Counting, Revision 6, May 19, 1989 (9)06-003, Ambient Environmental Air Monitoring for Radioactivity, Revision 4, May 19, 1989 (10)06-006, Collection of Routine Weekly and Monthly Environmental Samples, Revision 4, May 19, 1989 (11)06-007, Two Inch Well Sampling, Revision 2, May 19, 1989 (12)06-008, Air Sampling Representativeness, Revision 1, May 19, 3989 (13) RA-401 Environmental Control Requirements Mandated by 10 CFR 20, Revision 2, April 25, 1989 l

a 3

The inspector noted that several procedures had been recently revised due to organizational name changes. All revised procedures were approved by licensee management.

b. Procedure 06-002, " Roof Effluent Air Sampling and Counting,"

Revision 6, May 19,1989, stated that any wet filters were to be dried prior to counting. The filters were then counted face-up in an alpha-beta proportional counter subsequent to a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> holding time after collection. The inspector inquired whether filter wetting was a constant problem and if the licensee had considered corrective actions for detecting alpha emitting activity that possibly soaked through the wet filter paper. The licensee indicated filter wetting was typically not a problem and that some informal tests had been done in previous years but the documentation was not available. The inspector examined a series of daily effluent filters and did not observe any obviously wet filters. The licensee agreed to perform a series of tests where selected effluent filters would first be counted per the normal procedure. The filters would then be digested in a nitric acid solution in order to leach any alpha emitting isotopes and the residue from the acid solution would be counted for alpha activity. Comparison of the gross alpha activity determined by normal procedure and by nitric acid digestion would indicate any problems with alpha self-absorption. The inspector informed licensee representatives that review of the test results would be considered an inspector follow-up item (IFI).

IFI 70-1151/89-04-01: Review the results of tests for possible alpha self-absorption by filter wetting.

No violations or deviations were identified.

4. Records (88035,88045,84844)

a. The inspector reviewed selected portions of the following records:

(1) Filter System Pressure Status, January-April 1989 (2) In-Place HEPA Filter Test D0P Log, December 1988 - May 1989 (3) Tennelec Performance Checks, January-May 1989 for Tennelec Nos. 1, 3, 4, 5, and 6 (4) Tennelec Calibration Data, January-May 1989 for Tennelec Nos.1, 2, 3, 4, and 6 (5) ALARA Reports, January 1 - June 30,1988, July 1 - December 31, 1988 (6) NPDES Discharge Reports - January-April 1989

4 (7) Ambient Environmental Air Monitoring Data Summary Log, September 1988 - May 1989 (8) Summary Effluent and Environmental Monitoring Reports, September 1988 - March 1989 i 1

(9) Seven Day Effluent Air Summary, January - March 1989 (10) Controls for Environmental Pollution Analytical Results for Effluent and Environmental Samples, August 1988 - March 1989 The results of the records reviewed were discussed with licensee representatives as noted in Paragraph 4.b. I

b. The inspector noted that the licensee had implemented additional steps to improve review and control of HEPA filter test results.

During a previous inspection (70-1151/88-06) conducted April 1988,  ;

the inspector reviewed the In-Place HEPA Filter Test (DOP) log and  ;

noted that the December 16, 1987 test results for the incinerator mill system were documented as 0.4?; and passing. At the time, procedure HP-05-037 "HEPA Filter System Leak Test," Revision 1, March 3,1981, specified that a filter must pass a 0.05?J leak test using a DOP smoke detector. Since that inspection, the licensee had initiated weekly management review of the test results and had modified the form for the filter test log to include the pass / fail criteria.

No violations or deviations were identified.

5. Effluent Release Reports (88035) 10 CFR 70.59 requires the licensee to submit a report te the NRC Region II office within 60 days after Jar,uary 1 ana July I cf each year specifying the cuantity of each o/ the principle radionuclides released to unrestricted arcas in liquid and gaseous effluer.ts during the previous six months of operations. 10 CFR 20.106(p) requires licensees engaged in uranium fuci cycle operations to be subject to 40 CFR 190 which limits the annual wSolr; body don to any memoer of the pthlic to 25 millirem (mrem).

The inspector rev'.ewed the ef fluent and ALARA reports for 1988, and discussed the reports with licensee representatives. The effluent information presented in Table A was obtained from current and previous etfluent and ALARA reports.

L ,

5 TABLE A EFFLUENT

SUMMARY

FOR WESTINGHOUSE ACTIVITY RELEASED (MICR0 CURIES) 1985 1986 1987 1988 Gaseous Effluents 1,536 1,505 1,399 1,442 Liquid Effluents 246,200 111,171 57,164 34,544 Lung Dose to the Nearest Resident Infant (mrem) 2.5 2.7 2.5 2.6 The annual lung dose to the nearest resident showed little change over the past four years and remained at approximately 10 percent of the 25 mrem federal dose limit.

Gaseous effluents remained essentially constant during that time period even though the facility was processing material with a higher percent enrichment. Liquid effluents continued to decrease showing a reduction of almost an order of magnitude since 1985. The licensee attributed the continuing decline in liquid releases to increased awareness throughout the facility for proper segregation and recycling of the wastes. Also during 1988, mop water from equipment and floor cleaning was routed to the advanced waste water treatment facility for processing. Prior to 1988, the mop water flowed directly to contaminated holding tanks and little processing was done.

No violations or deviations were identified.

6. Radioactive Waste Management (38035)

The inspector and a licensee representative discussed waste management and toured selected portions of the plant. During 1988, the licensee hed begun replacing Cuno filters for liquid process streans with bag f *11ers or filter presses. The licensee previously had expcrianced problems with the Cuno filters which did not incinerate completely and formed a nylon sludge in the bottom of the incinerator. This sludge hampered recovery of uranium product and reduced the efficiency of the incinerator. The new bag filters or filter papers used in the presses were essentially ashless and allowed easy uranium recovery. 1 The inspector also examined various gaseous effluent release points and discussed system operability. The licensee currently maintains 38 release stacks for gaseous ef fluents. During 1988, the air compressor and boiler room stacks were deleted and an exhaust stack for the decontamination room was added. Also the furnace exhaust standby system was replaced with a new system which eliminated one of two stacks.

r L'

l .

6 In reviewing the Seven Day Effluent air Summaries for January-March 1989, the inspector noted that the U308 Hi '" rip exhaust routinely exceeded MPC limits for gaseous effluents. The licensee had investigated the cause of the higher gaseous activity and determined that the HEPA filters were not securely seated due to a defective clanp. The clamp was repaired and the problem resolved by April 26, 1989.

The inspettor also reviewed the HEPA filter test logs for DOP leak test results and differential pressure checks across the HEPA filter bank conducted during December 1988 to May 1989. The licensee was required to replace the pre- and/or HEPA filter when the differential pressure across i the filter bank exceeded 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.

The inspector toured the licensee's count room and reviewed calibration records and performance checks for the Tennelec alpha-beta proportional counters for January-May 1989. The licensee maintained seven counters for in plant, effluent, and environmental air samples. The licensee had initiated computer software upgrades during 1988 to improve data management for the laboratory. Tennelec performance counts, which were previously logged and checked manually, were now entered on a computer.

The computer data base automatically compared the counts to control limits, identified a trend or out-of-specification limit, and indicated the actions to be taken. A second software upgrade transferred daily effluent air filter counts from the Tennelec counters to a computer for activity calculations and data storage. This upgrade expedited data trending and the identification of problems for gaseous releases from the facility's stacks.

No violations or deviations were identified.

7. Enviror mental Monitoring Program (88045)

a. The inspector reviewed selected procadures, analyticel results, and count room records with licensee representatives ar.d determined that the organizational structure and program management had not changed since the previous inspection (70-1151/88-12). The inspector toured several envirchmental sampling stations including air, surface water, and well water. The inspector noted that all air sampling stations were operational and calibrated.

b. During 1988, the licensee had applied for a groundwater mixing zone from the State of South Carolina, The mixing zone would allow variances from specified groundwater quality standards in a subsurface zone, and the l'icensee's request was prompted by a groundwater contamination problem which occurred prior to 1980.

Groundwater contamination was first identified in April 1980. The licensee had detected elevated levels of fluoride and ammonia in a man-made pond on plant property and determined that the source of the pond contamination was an underground spring that discharged into the

1 1 .

l 7 1

pond. -Several. possible sources of contamination for the spring were identified which included leaks or spills from above ground storage tanks in the waste water (WW) treatment area, leaks from below ground piping in the WW treatment area, and leakage through liners in the process waste lagoons. The licensee installed 28 monitoring wells during 1980 to assess groundwater conditions. The remedial actions by the licensee to prevent further leakage into the ground water included:

l (1) Replacement of buried piping networks with above ground piping (2) Replacement of liners for all process lagoons-(3) Construction of dikes for storage tank areas and floor drains to recycle any spills (4) Establishment of a quarterly groundwater monitoring program l- (5) Establishment of a program to routinely monitor diking systems l- (6) Installation of a pumping facility at the facility's man-made i pond to pump water back to the WW plant in order to minimize overflow into Sunset Lake.

The licensee indicated that in general, chemical and radioactive contaminants in the monitoring wells had slowly decreased over the past nine years. The inspector reviewed the quarterly well sample results for the past 12 months and noted elevated levels of gross alpha and beta activity in wells No.18 and No. 29. with typical values of 200 to 400 pCi/1. Well No. 18 was located at the edge of the South Lagoon and Well No. 29 was located near the North Lagoon.

The inspector additionally reviewed grapned results of alpha and beta activities for well No.18 during 1985-1987. Alpha values ranged from 40 to 650 pC1/1 and beta values from 10 to 560 pCi/l with no identifiable trend in either esse. Well No. 7 also maintained elevated levels of fluoride (80-150 mg/1) and ammonia (200-900 mg/1) from 1980-1987.

The State would allow the mixing zcne if the following conditions were met:

(1) Reasonable measures had been taken to minimize the ingress of additional contaminants into the groundwater and to control the migration of contaminants already present in the groundwater.

(2) The contaminated groundwater was confined to the uppermost aquifer which had little or no possibility of being used as a j drinking water source. '

(3) If the contaminated groundwater discharged to a surface water, ,

the surface water quality standards would not be exceeded. l i

l

_ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ __ ___ _ _ J

i 8

1 i

1 (4) The contaminated water occurred on the applicant's property with minimum potential for contaminants to flow offsite.

(5) The contaminants or any combination were not dangerously toxic, mobile, or persistent. f i

The licensee indicated that the affected groundwater was not used for drinking water or industrial applications. Also there was no known pumpage of the groundwater on properties immediately adjacent to the plant property. At the time of the inspection, the licensee had not received approval from the State for a groundwater mixing zone. The Environmental Protection Agency (EPA) had chosen the Westinghouse site for a hazardous materials study and the licensee had not yet received the final EPA report. The State had halted implementatiori of the mixing zone request until the results of the EPA study were published.

c. During February 1989, the State of South Carolina notified the NRC that approximately 25 dead deer had been found near the Congaree River downstream from the Westinghouse plant on adjacent property.

The deer had been discovered over a two week period and the State contracted with the University of Georgia to determine the cause of the deaths. No other wildlife had been affected and preliminary evidence indicated the possibility of a virus. The licensee performed a property search the week of February 27, 1989, and found no additional carcasses. Routine analyses of effluent and environmental samples indicated no unusual levels of radioactivity or chemicals in the facility's effluents or surrounding environment.

The licensee also collected an additional sample from a drainage ditch but again found nothina uausual . The University of Georgia performed autopsies and cellected bicpsy samples from several carcasses but indicated that, due to the time span between death and sample collection, determination of the cause of death would be cifficult if not impossible. As of the date of this inspection, the licensee had not received final word as to the results of the University of Georgia's investigation. However, preliminary evidence indicated that the deaths were not attributable to the plant.

On June 14, 1989, the licensee provided the inspector a copy of a letter frch the South Carolina Wildlife and Marine Resources Department dated June 12, 1989. The letter stated that as of that date, the State did not have any conclusive evidence as to the cause of the deaths and that there was currently no evidence to link Westinghouse to the deaths of the animals.

No violations or deviations were identified.

8. Confirmatory Measurements (84844)

The results of the analyses of the effluent air filter collected during the previous inspection (70-1151/88-12) were discussed with licensee

9 representatives (see Attachment 1). The sample results were determined to be in agreement with the NRC value for gross alpha activity.

No violations or deviations were identified.

9. Inspector Follow-up Item (92701)

(Closed) IFI 70-1151/88-12-01: Compare results of NRC and licensee analyses of gas effluent sample. The results were compared and discussed with licensee representatives (Paragraph 8). This item is considered closed.

10. Exit Interview The inspection scope and results were summarized on June 2,1989, with those persons indicated in Paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results listed below.

The licensee's ' commitment to effective control of radioactive effluents I was evidenced by the continuing decrease in liquid effluent activity.

(Paragraph 5). Liquid effluents had decreased by almost an order of magnitude from 1985 to 1988, and gaseous effiuents remained constant even though the facility was processing material with a higher percent enrichment.

Additional management review of HEPA filter test results (Paragraph 4) had been identified in Inspection Report No. 88-06. In the previous inspection DOP test results of 0.4% were -identified as passing.

The licensee had improved data management for the laborato ry (Paragraph 6). Software upgrades provided automatic transfer of effluent air filter counts from the Tennelec counters to a computer for activity calculations and data storage. A second upgrade tracked Tennelec performance checks, identified trends, and actions to be taken.

The results of the confirmatory measurements for a gaseous effluent sample were found to be in agreement (Paragraph 8). An IFI was cicsed concerning this measurement.

One IFI was identified concerning the review of test results for possible i alpha self-absorption by effluent filter wetting (Paragraph 3.b).

The inspector and licensee discussed documentation of the ground water contamination which occurred prior to 1980, subsequent corrective actions, and the mixing zone request from the State (Paragraph 7.b). Additionally, the February 1989 incident concerning 25 dead deer was discussed (Paragraph 7.c).

_ a e p e

_ m r

_ o g C A C

R N

o/

ie 2 ts 8 an Re 0 c

i L

K C

A T 9 S 8 n 9 o A 1 i t

F Y u 9 O A l -

M o N s O - e S R IRT REN ATA 1 PLL MIP T OF N C A E EI M TTB s H NAM i C ELU s A MUL T ECO ly t T RI C ai 5 A UT nn -

SR- Au E AA /

EPE ei 5 M S eC 3 U su .

Y O n 4 R H e O G c T N i A I L

M T R S l E F

N W

O C

8 s 8 i

5 9 st - 1 yi E l

n 6 r au e n/ 0 b Ai 1 o C 3 t CU c R 5 O N

d e

t e c t e a l l l u a o ic hp c t l s r a a a w P: s e rs e lp ctr keo l p

g al g m a ti a j Sf S I

.c I

~

{

i l

ATTACHMENT 2 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS i

This enclosure provides criteria for comparing results of capability tests and j verification measurements. The criteria are based on an empirical relationship '

which combines prior experience and the accuracy needs of this program.

~

l In this criteria, the judgement limits denoting agreement or disagreement between licensee and NRC results are variable. This variability is a function of 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 licensee values must be considered acceptable as the resolution decreases.

For comparison purposes, a ratio 8 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.

Resolution = NRC Reference Value Associated Uncertainty for the Value 8

Comparison Ratio = licensee Value NRC Reference Value TABLE 1 i

Confirmatory Measurements Acceptance Criteria For Gross Beta and f* css Alpha Measurements Resolutions vs. Comparison Ratio Comparison Ratio for Resolution Agreement

! <4 no comparison 4-7 0.3 - 3.0 8-15 D.4 - 2.5 16-50 0.5 - 2.0 51-200 0.6 - 1.66

>200 0.75 - 1.33

-