ML20247D179

Insp Rept 70-0824/89-03 on 890410-12.No Violations or Deviations Noted.Major Areas Inspected:Radioactive Effluent Radiological Environ Monitoring & QC

ML20247D179
Person / Time
Site:	07000824
Issue date:	05/05/1989
From:	Kahle J, Marston R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20247D178	List: ML20247D177 ML20247D179
References
70-0824-89-03, 70-824-89-3, NUDOCS 8905250213
Download: ML20247D179 (9)

Text

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. . A FE UNITED STATES T [f ,00g'og

• NUCLEAR REGULATORY COMMMSION

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-j 101 MARIETTA STREET,N.W.

R ATLANTA, GEORGI A 30323 4

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MAY 11155 Report No.: 70-824/89-03 Licensee: Babcock and Wilcox Company Naval Nuclear Fuel Division - Research Laboratory Lynchburg, VA 24505 Docket No.: 70-824 License No.: SNM-778

' Facility Name: NNFD'Research Laboratory .

Inspection Condu tee: April 10-12,1989 Inspectpr: .. [c~[Ae S[M/7 f R. M rs n Date Signed Approved by: .

J. B'. Jahle, Chief d( .i~o/79

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Date Signed -l Radio)'ogicalEffluentsandChemistrySection I Emergency Preparedness and Radiation' Protection l

-Branch Division of Radiation Safety and Safeguards I

SUMMARY

Scope This routine. ' unannounced inspection was conducted in the areas of radioactive

. effluents, radiological environmental monitoring, and quality control.

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

The licensee's programs continued .to be well-managed with a stable Health

' Physics staff able to anticipate and respond to the demands of a changing research program. In the comparisons of sample analysis discussed in Paragraph 6, all were in agreement.

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REPORT DETAILS

1. Persons l Contacted Licensee Employees

• R. Bennett, Manager, Safety and Licensing

• C. Boyd, Jr. Licensing Administrator K. Doran, Research Chemist

) '*S. Schilthelm, Health and Safety Supervisor

• L. Trent, Manager Safety and Safeguards Other licensee employees contacted during this inspection included technician and administrative personnel.

• Attended exit interview

2. Audits (88035, 88045, 84844)

The inspector reviewed' the Monthly Health and Safety Audit Reports .for May 1988 through . March 1989. The audit consisted. of a walk-through of specif.ied plant areas and reviews of specified items; such as incomplete-work orders,- review cf frisking instrument . calibrations, contamination, and. proper posting of controlled areas. Each audit included a section on status sof findings included in .the report (several were corrected on-the-spot), and a section on the status of findings from previous reports.

-The . inspector reviewed the latest Safety Audit Subcommittee (SAS) Audit-Report, dated- September 27, 1988. The audit had been conducted August 30-31, 1988. The audit consisted of a procedure review, a review of: personnel exposure records, verification that routine activities were conducted and documented in accordance with procedure, 'and followup of items from the previous SAS Audits. This audit included recommendations for improvement.

1 No violations or deviations were identified.

3. Procedures (88035, 88045, 84844)

The inspector reviewed selected Area Operating Procedures in the Health Physics (HP) area, and reviewed selected Nuclea'r Chemistry Laboratory Procedures. The inspector also reviewed selected Technical Procedures within the scope of this inspection, concentrating primarily on those which had been- revised since the last inspection (70-824/88-03) in this area.

The existing procedures appeared to be adequate; however, there were still some to be implemented to provide complete coverage of the program.

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No violations or deviations were identified.

4. Liquid and Airborne Effluents (88035)

The inspector reviewed procedures, facilities, sampling and analytical equipment, and resulting data produced in the program. During a tour of the facility, the inspector determined the status of the sampling equipment and provisions for obtaining representative samples.

a. Liquid Effluent Program The inspector reviewed Technical Procedures pertinent to the program, toured the plant and examined components of the system, discussed the program with licensee representatives, and reviewed liquid effluent sampling and analysis records.

Sampling and analysis records were found in the HP Lab notebooks.

The inspector reviewed the results for the LRC Pond, the NNFD Pond, the Dirt Coffin Basin, Silo Draintile, the Liquid Waste Disposa'l Pit (LWDP) Tank 10K-2, and the NNFD Composite for the period from May 4, 1988 to March 2, 1989. Sampling was done at the frequency specified in the license application, and effluent concentrations were within the limit stated in the license.

b. Airborne Effluent Program The inspector reviewed Technical Procedures pertinent to the program, toured the plant, examined components of the system, and discussed the program with licensee representatives. The inspector reviewed Area Air Sample Data logs for the period from May 4,1988 to April 3, 1989. The samples were counted for gross alpha and gross beta, and percent of MPC was calculated and displayed. Concentrations were generally on the order of a few hundredths of a percent. Sampling and analysis were conducted in accordance with the license application. While analysis appeared to be adequate, a procedure had not yet been formally implemented (IFI 89-03-01, Paragraph 8, of this report).

The inspector verified that weekly checks were made of the pressure differential across HEPA filter banks through review of the HP Weekly Operation Checklists for the period from January 4, 1988 through December 27, 1988. The inspector verified that final HEPA filter banks were leak tested annually or after replacement by review of the DOP Testing Log for the period f rom June 9,1988 through February 21, 1989.

No violations or deviations were identified.

5. Environmental Monitoring Program The inspector and a licensee representative toured the plant grounds and examined environmental sample locations and equipment. The inspector reviewed environmental sampling and analysis records for Calendar Year

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3 (CY) 1988, including analyses of river silt and vegetation performed by a vendor. Results of these analyses showed that the environmental parameters were within action levels.

The inspector examined the results of the analyses of the ground water sampling well samples for CY 1988. A licensee representative stated that wells 6 and 7 were added in early February 1989, and pumps were installed on the wells in April 1988. The wells were sampled monthly, even though sampling was required quarterly. Due to the change in sampling methods, from grab sampling to pumping, the readings were higher for the first three months of the year. The highest average gross beta for the year was 10.83 picocuries per liter for Well #01, and the highest average gross alpha was 2.76 picocuries per liter for Well #04.

The inspector reviewed the results of the latest Annual LRC Hillside and Railroad Survey which was conducted on November 9,1988. Background on this program and the results of the previous survey were discussed in Inspection Report No. 70-824/88-02, Paragraph 8.b.

The survey was performed annually and consisted of direct surveys inside the culverts and the area of property directly adjoining the inlets and outlets of the culverts. The micro-R meter used for the surveys was held three feet above the ground for those surveys outside the culverts, and placed on a metal sled which was drawn through the culverts by ropes to survey the interior of the culverts. Following is a summary of the results of the current survey:

Average Range

, Location (Micro-R per hour) (Micro-R per hour)

1. LRC side of NNFD 22.1 19-30 spurline, railroad property

2. NNFD spurline culvert, 19.5 13-28 railroad property

3. Middle section of railroad 18.7 15-24 property (between spurline and mainline

4. Mainline culvert, 11.4 9-15 railroad property

5. Lower side (north of mainline), 13.9 11-7 railroad property

6. Creek from mainline to NNFD 21.3 10-42 canal, B&W property

7. NNFD canal, 12.8 7-26 B&W property

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l The results were generally comparable to those from.the previous survey.

One change from previous surveys was the 'use of a PRM-7 for surveys over i

the _ ground. The RSS-111 was still used for the survey inside the

culverts. The previous survey was conducted using the RSS-111 for all measurements.

No violations or deviations were identified.

6. Changes.in Program (88035, 88045, 84844)

The inspector discussed changes in the program with licensee representatives.

Since the last inspection (70-824/88-03) at this facility, the licensee-implemented a . method to check for isokinetic flow in the ' stack sampler during the semiannual stack flow measurement. This was done in response to IFI 88-08-03. The measurements done so far showed that flow was isokinetic.

The HP Lab was expanded. The Stack and Meteorological ~ Monitoring rack, the cold hood, the hot hood, the three proportional counters and Metier Balance were moved into a room adjacent to the old lab. This expansion lessened.the crowding found in the old lab. In addition, the underground storage. facility. for high 1evel. radioactive waste storage (generally.

spent fuel ' remnants from the hot cells) was completed and operational.

-No violations or deviations were identified.

7. Quality Control and Confirmatory Measurements (84844)

-The inspector reviewed calibration records and quality control data, including control charts for the Radiochemistry Groups gamma spectroscopy system and the HP Group's Sharp Low Beta and Beckman Wide Beta Systems.

The inspector also examined the instruments located in the fan room of the 50 meter exhaust stack and reviewed the calibration records for the stack monitor and stack flow rates meter. All system were found to be in current calibration and applicable control charts were current.

At the inspector's request (70-824/88-03), the licensee sent to Region II an airborne effluent filter and a liquid radwaste sample with the corresponding analyses for gross alpha and gross beta. The NRC had these samples analyzed and conducted a comparison (Attachment 1) in accordance with the criteria shown in Attachment 2. All comparisons were in agreement. J I

.No violations or deviations were identified. j

8. Action on Previous Inspection Findings (2701, 92702)

(Closed) Inspector Followup Item (IFI) 70-824/87-02-01: Develop and implement procedures for reading delta-P across HEPA filters and

5 calculating activity in airborne samples. The delta-P was checked as part of the Weekly Operations Checklist which was proceduralized as part of Technical Procedure RL-TP-157, Weekly Operations Checklist. This item will be closed and the remainder tracked as IFI 70-824/89-03-01.

(0 pen) IFI 70-824/89-03-01: Develop and implement procedure for ca,lculating activity in airborne samples.

(Closed) IFI 88-RL-01: Review circumstances' of apparent leak from Research Laboratory Spent Fuel Pool and licensee's corrective actions.

The inspector discussed the incident with licensee representatives and reviewed the letter dated November 11, 1988, on the subject that the licensee sent to the NRC.

The Pool was surrounded with overflow gutters which were precast concrete structures mortared in place and to each other. Drain lines ran from the i gutters to a holding tank in the Primary Equipment Cell. On October 12, 1988, the Pool was inadvertently filled to the lip of the gutters. The following morning, the pool level was found to have decreased to about-four inches below the lip of the gutters, and had stopped by the morning of October 13, 1988.

Investigation revealed. that _the pool water had leaked through cracks in the seams into the gutters, then into the gutter drain lines. .The drain lines - leaked the water onto the soil beneath the. floor of the Cask Handling Area. The leakage continued until the Pool level reached the i lower seam of the gutters. Little if any of the water reached the holding tank in the Primary Equipment Cell.

It was determined that approximately 515 gallons of water was lost, and estimated that 748 microcuries of gamma-emmiting radionuclides (primarily Mn-54, Co-60, and Cs-134 and 137) and 64 microcuries of non gamma emitting radionuclides were lost. There was no evidence any of this' water reached the boundary of the restricted area.

The drain lines have been temporarily plugged, and will be permanently plugged when feasible. A steel sump will be constructed on the pool wall at a level that will prevent pool water from exceeding the level of the floor of the gutters. A pump will then pump the water to the holding tank.

(Closed)-IFI 70-824/88-03-01: provide effluent filter and liquid radwaste sample and analysis to Region II. The licensee sent the samples and .

analyses to Region II.  ;

(Closed) IFI 70-824/88-08-03: Review test results of stack sampling following vent duct modifications. The inspector verified that sampling  ;

of the stack was isokinetic. l i

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(Closed) Information Notice 88-IN-22: Disposal of sludge from onsite sewage treatment facilities. A licensee representative stated that the Research Lab's sewage was sent to NNFD for treatment.

9. Exit Interview The inspection scope and results were summarized on April 12, 1989, with those persons indicated in Paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results. Proprietary information is not contained in this report. Dissenting comments were not received from the licensee.

The inspector discussed the open items that were closed during this inspection and encouraged the licensee to continue to upgrade the Technical Procedures.

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ATTACHMENT 1

'.0:lFIRMATORY MEASUREMENT COMPARISONS OF GROSS ALPHA AND GROSS BETA FC NNFD RESEARCH LAB ON LIQUID WASTE AND GASEOUS EFFLUENT SAMPLES Licensee NRC Ratio (sci /ml) (uCi/ml) Resolution (Licensee /WRC) Comparison Liquid Gross Alpha 9.34E-08 (3.6 0.7) E-08 5.14 2.6 Agreement Gross Beta 2.21E-06 (2.04i0.10) E-06 20.4 1.08 Agreement Filter (uCi) -(uCi)

Gross Alpha 7.24E-07 (1.7 0.2) E-06 8.5 0.43 Agreement Gross Beta 1.98E-04 (3.69 0.12) E-04 30.75 0.54 Agreement

. *V ATTACHMENT 2 CRITERIA FOR COMPARISCd5 0F ANALYTICAL MEASUREMENTS

- This attachment provides the NRC's criteria for the comparison of results of analytical radioactivity measurements. These criteria are based on empirical relationships which combines . prior experience in comparing radioactivity analyses, the measurement of the statistically random process of radioactive emission, and levels of agreement in radioactivity measurements acceptable to the NRC.

. In these criteria, the " Comparison Ratio Limits"2 denoting agreement or .

disagreement between licensee and NRC results are variable. This variability l is a function of the ratio of the NRC's analytical value relative to its associated statistical and analytical uncertainty, referred to in this program as " Resolution"2 As the numerical value of " Resolution" increases, the range of acceptable variations or differences between the NRC and licensee analytical becomes smaller or more restrictive. Conversely, as the value of " Resolution" decreases, a wider and less restrictive y < ation or difference between the NRC and licensee analytical values is considt <a acceptable.

For comparison purposes, a ratio between the licensee's analytical value and the NRC's analytical value is computed for each radionuclides present in a given sample. The computed ratios are then evaluated for agreement or disagreement based on " Resolution." The corresponding values for " Resolution" and the

" Comparison Ratio Limits" are listed in the Table below. Ratio values which are either above or below the " Comparison Ratio Limits" are considered to be in disagreement, while ratio values within or encompassed by the " Comparison Ratio Limits" are considered to be in agreement.

TABLE NRC Confirmatory Measurements Acceptance Criteria Resolution vs. Comparison Ratio Limits Comparison Ratio Limits Resolution for Agreement

<3 No Comparison 4-7 0.5 - 3.0 8 - 15 0.4 - 2.5 16 - 50 0.5 - 2.0 51 - 200 0.6 - 1.66 -

>200 0.75 - 1.33 2 Comparison Ratio = Licensee Value NRC Reference Value 2 Resolution = NRC Reference Value Associated Uncertainty

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