ML20247M207

Insp Rept 70-1201/89-02 on 890412-14 & 0504-05.No Violations or Deviations Noted.Major Areas Inspected:Radiological Liquid & Gaseous Effluents,Radiological Environ Monitoring & Radiological Confirmatory Measurement

ML20247M207
Person / Time
Site:	07001201
Issue date:	05/12/1989
From:	Kahle J, Marston R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20247M205	List: ML20247M199 ML20247M207
References
70-1201-89-02, 70-1201-89-2, IEIN-88-022, IEIN-88-22, NUDOCS 8906020389
Download: ML20247M207 (8)

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UNITED STATES

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MAY'151989

. Report.No.: 70-1201'/89-02 Licetisee: B&W Fuel Company Connercial Nuclear Fuel Plant.

Lynchburg,-VA 24505 Docket No.: 70-1201 License No.: SNM-1168 Facility Name: Commercial Nuclear Fuel Plant Inspection Cor. ducted: April 14 and ay 4-5, 1989 Inspector: I2 [

R. R. Murst n Dat igned Approved by:_ / [9 Af J..K Kahle,. Chief. /Dade Signed I/ 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 radiological liquid and gaseous effluents, radiological' environmental monitoring,. and ,

radiological confirmatory measurements.

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

. was managing a safe facility from a Health Physics radiological effluents and environmental) standpoint. The evaporation of liquid radwaste appears to be an adequate method to minimize the quantity of radioactivity released to the environment.

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L l REPORT DETAILS

1. Persons Contacted

• W. Engelke, Manager,-Quality and Safety

• D. Ferree, Manager of Manufacturing

~*J._ Ford, Manager, Fuel Manufacturing

• K. Shy, Health Physicist '

• C. Speight, Manager, Facilities and Services

• Attended exit interview

2. Audits'(88035,88045,84844)

.The inspector reviewed Quarterly Health Physics Audit Reports HS-88-2, conducted May 20, 1988; HS-88-3, conducted September 9, 1988; and HS-88-4, conducted December 6, 1988.

The audits were conducted by an independent auditor (from B&W, Naval Nuclear Fuel Division). The inspector also reviewed the licensee's responses to audit findings and follow-up to corrective actions.

The inspector- reviewed the weekly Health-Safety Audits for the period from May 20. 1988, through April 7,1989. These weekly audits consisted primarily of physical facility inspections. During the period evaluated, findings appeared in the reports in two instances. Corrective action was completed by the following week in the first case. In the second case, sufficient time had not elapsed at the time of the inspection for the licensee to take final corrective action.

No violations or deviations were identified.

3. Procedures (88035,88045,84844)

The inspector reviewed Health-Safety Procedures applicable to the scope of the inspection. Most of these procedures had been revised since the previous inspection (70-1201/88-06).

The most significant change was in Procedure AS-1104, Waste Water Effluent Control, Revision 12, dated June 20, 1988. The change reflected the changes in disposal of liquid industrial waste. The radioactive liquid waste (controlled area hand-wash sink, showers, and mop water) was evaporated rather than released through the retention tanks as previously dor.e . The evaporator was installed approximately one year ago.

The procedures appeared to have been prepared, revised, and maintained in accordance with the license application.

No violations or deviations were identified.

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4. Liquid Effluent Program (88035)

During a tour of the plant, the inspector examined components of the liquid effluent handling, processing, .'and ' monitoring system. The 1 effluents program was discused with licensee representatives and applicable records were reviewed. i 1

' Licensee representatives stated that spent acid solutions and sanitary "

sewage was sent to the Naval Nuclear Fuel Div.ision (NNFD) facility for' treatment. Non-contact cooling water was transferred to the fish pond -

which provided a steady flow to the wet weather stream.

Industrial Waste Water was handled according to the potential content.

Water from the controlled area hand washing sink, showers, and mop water was collected in a holding tank located in the controlled area change room, then was pumped up to a secondary holding tank located on the.

mezzanine above. The effluent was gravity fed to an evaporator, where the.

water was evaporated, with the vapor then passing through the controlled area gaseous' effluent HEPA filtration system.

l Other industrial waste liquids containing acids, caustics, and trichlorethylene (TCE) were generated in the parts cleaning room, the demineralized room, and the metallurgy laboratory.- Any water with potential TCE was filtered through two filters containing activated carbon., The liquid was then transferred to the retention tanks, where it was sampled, and pH-adjusted and defoamed, as required, before release to the environment.

The inspector selectively reviewed the Liquid Effluent Release Records for the period from May 12, 1988 through March 31, 1989. There were 171 releases during the period. The inspector also reviewed the Waste Water Evaporating System Sludge -Inspection Record for the period from August 3, 1988 through - March 27,' 1989. This was a monthly record describing inspections of the primary holding tank, the secondary holding tank, and the evaporator for sludge levels. All inspections were recorded at less than one inch.

The Annual ALARA Report for October 1987 through September 1988 listed effluents by month, totals for the year, then gave monthly and daily averages. No significant trends were identified in these releases.

No violations or deviations were identified.

5. Airborne Effluents (88035)

The inspector examined the air cleaning equipment during a tour of the plant. The inspector reviewed the Gaseous Effluent Discharge Reports for the second quarter of 1988 through the first quarter of 1989. The reports gave total activity per quarter, average concentration, and total volume released per quarter. The total and average releases were summarized in the ALARA Report for Fiscal Year 1988. No significant trends were identified in these releases.

3 The inspector reviewed the Manomecer/Magnehelic Audit Records for pressure drop across HEPA filter and the Controlled Area Negative Pressure Audit 17, 1988 through April .3,1989. All filters reed less than four.

for inches May(water gauge) and the Controlled Area was at negative pressure with respect to surrounding areas.

No violations or deviations were identified.

6. Environmental Monitoring Program (88045)

The . inspector- reviewed the environmental sample collection and analyses records for those environmental samples collected in calendar year-1988 and for the first quarter of 1989. The inspector determined that the program appeared to have been conducted in accordance with requirements.

The inspector also reviewed the licensee's graphs of the results of the program.

No violations or deviations were identified.

7. Instrumentation and FJality Control (88035, 88045, 84844)

The inspector reviewed the equipment located in the Radiation Control and First Aid Room and discussed the equipment and its use with licensee representatives.

There were alarm system indicators for:

Sump pit full; Retention tanks full; and Criticality monitoring.

Several counting systems were also set up in the room:

NMC PCC-11T and PC-4 proportional counters (dedicated for environmental samples);

NMC Automatic Countin work station samples)g; System (ACS) proportional counter (count most Eberline BC-4 Beta Counter (count beta smears); and Ludlum Model 1000 with alpha scintillation detector (alpha smears).

Licensee representatives stated that there was a Ludlum Model 20A alpha scintillation ounter located in the controlled area.

The following calibration records were reviewed:

a. Automatic Counting System (ACS) Alpha efficiencies and plateaus were calculated on July 5, August 11, October 6, October 10, 1988, and l January 2, 1989.

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b. NMC PC-4 Alpha efficiencies were determined on June 9, June 20, July 7. July 8, and December 14, 1988; and January 2 and April 4, l

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1989. B6ta efficiencies were determined on June 20 and July 7, 1988.

An alpha plateau was determined on' July 7, 1988.

c.- NMC PCC-11T Alpha' efficiencies were determined on July 7, August 10,

. September 22, 1988, and January 6, 1989; alpha plateaus determined on July 7, 1988 and January 6,.1989, and beta efficiencies determined on July: 7, and September 22, 1988,- and January 6, 1989.

d. Ludlum' Model 1000 Alpha efficiencies were~ determined on July 5 and; November. 11, 1988, .and January 3, 1989.

e.. Ludlum Model 20A' Alpha efficiencies were ' determined on JulyL1, '1988, and January 3, 1989.

f. Eberline BC-4 Beta efficiencies were determined- on August 26, August 30, September 20, and October 24, 1988, and ' January 3, LJanuary 9, January 10, February 15, and February 16, 1989.

. The Linspector reviewed the _ daily checks, background checks, and control chartsLfor each of the laboratory instruments. The instruments. appeared to be relatively stable with very little drift.

During a previous inspection (70-1201/88-06), the inspector requested that

- the licensee send a . retention tank sample and an air sample ; filter to

' Region II1with the licensee's analyses of those samples. The licensee sent the samples and cr.alyses on June 3,1988.- Region'II compared the.

results. of the licensee's analyses with the NRC's analyses. This comparison -is provided in Attachment 1. Attachment 2 explains the criteria for comparing analytical measurements. Both the measurements were in agreement according to the comparison.

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- During the same inspection (70-1201/88-06), the-inspector collected six

soil samples from the licensee's "G" sample area near the " wet weather stream" to where the contents'of the retention tanks were released. The samples were analyzed by'the NRC contract laboratory to determine uranium concentrations (gross alpha) in the soil. The results of these analyses are l ' presented in the followin9 table.

Table Sample Result Location (pCi/g)

L G2 11.9 G4 83.3 l G6 3.2 G8 38.5 G9 79.5 G10 3.7

A 5

The NRC results were consistently higher than the values obtained by the licensee during a period of five quarters. This situation was discussed with licensee representatives on May 4 and 5, 1989. Agreement was reached to split soil samples at a later date to determine if biases exist in the soil analysis.

No violations or deviations were identified.

8. Action on Previous Inspection Findings (92701, 92702)

(Closed) Information Notice 88-IN-22: Disposal of sludge from onsite sewage treatment facilities. Raw sewage was pumped from this facility to l the NNFD for treatment. The Information Notice was not applicable to '

the facility since no onsite treatment was used.

(Closed) Inspector Follow-up Item 88-06-01: Provide effluent filter and liquid radwaste sample and analyses to Region II. The licensee provided the requested items (see Paragraph 7 of this report).

9. Exi t' I nterview The inspection scope and results were summarized on April 14, 1989, with those persons indicated in Paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results listed below.

Proprietary information is not contained in this report. Dissenting comments were not received from the licensee.

Tne -inspector discussed the areas evaluated and the two items that were closed out.

On May 4 and 5,1989, telephone conversations were held with licensee representatives to discuss the fact that NRC results of soil samples were consistently higher than licensee results and the need to split soil samples. Arrangements will be made at a later date for splitting soil samples.

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G l ATTACHMENT 2 CRITERIA FOR COMPARISONS OF 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 agreenient or disagreement between licensee and NRC results are variable. This variability 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 variation or difference between the NRC 1; and licensee analytical valucs is considered 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 r4tios 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 l 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 0.3 - 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 3 Resolution = NRC Reference Value Associated Uncertainty