ML20099E024

Special Rept:On 840927,discovered That Contaminated Oil Shipped to Lee Steam Station for Disposal by Incineration. Caused by Misinterpretation of Regulations.Shipments of Contaminated Oil Halted

ML20099E024
Person / Time
Site:	Oconee
Issue date:	10/24/1984
From:	Tucker H DUKE POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8411210062
Download: ML20099E024 (7)

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m lMrsTJsaes:P.(O'Reilly.: Regional ~ Administrator 1g .

D iU.$S.; Nuclear Regulatory Commission

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/ ' [Re:' Oconee[Nucijar?St'a' tion, ; Units *1,12,K;and 3 '

1 Docket' Nos.E50-269,[ -270 7 -287 * '

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Dear:

Mr.LO'Reilly:' ,

Please ' find . attached als'pecial report' concerning 'the burning lof contaminatied ;

oiliat! Lee Steam Station which had been-shipped from Oconee Nuclear Station.~1

'Th'is report describes'an-incident whichiis' considered to"b'e of:no. significance..

with respect to its effect on the' health and safety of.the public. .

Very truly yours,-

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.Ha1 B. Tucker RFH:slb.

. Attachment cc: Document' Control Desk American Nuclear Insurers

.-U. S. Nuclear Regulatory Commission c/o.Dottie'Sherman, ANI Library'.

Washington, D.C. 20555 The Exchange, Suite 245 270.Farmington Avenue INPO Records Center Farmington,'CT 06032

-Suite 1500 1100 Circle 75 Parkway M & M Nuclear Consultants Atlanta, Georgia 30339 1221 Avenue of the Americas New York, New York 10020 Mr. J. C. Bryant NRC Resident Inspector. ,

Oconee Nuclear Station

-Ms. Helen Nicolaras Office of Nuclear Reactor Regulation .

U. S. Nuclear Regulatory Commission.

Washington, D. C. -20555 OFFICIAL COPY

'84112100'62 841024

'PDR ADOCK 05000269 7{'

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Duke Power Company-

_0conee Nuclear Station

- Special Report- .l

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' Shipments of.. Contaminated Oil to;

Lee, Steam' Station for Disposal By. Incineration . ,

~

Introduction:

~

On September ' 27, - 198'4', Oconee station peisonnel determinedsthat slightlyL Jcontaminated oil'had been shipped to Lee Steam Station for burning, ; contrary to..

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an NRC Region II- interpretation of " exempt quantity". 'Approximately119,000 gallons - of- this ~ contaminated : oil:were burned - at Lee tduring the period September. -

11981_to July 1984. LThe last contaminated oil: shipment; occurred in June 1984.

- Prior. to an NRC Region II interpretation of 10CFR30.18 on March 20, 1984,' Duke ihad interpreted the regulation as allowing . disposal' of exempt quantities of; ra'dioactive materials. _ The . NRC ' Region II interpretation of 10CFR30.18,' which -

pertained to. McGuire Nuclear Station' sludge samples, . stated that there are- no exempt quantities of radioactive materials for disposal purposes.

Immediate corrective action consisted of.ensuringLthat=all contaminated.oili. .

4' shipments were halted. Henceforth, all contaminated oil generated onsite will~- ~

be burned in the' onsite auxiliary boiler or alternately solidified as waste.

i Descriptions of Occurrence:

In the latter part of 1978,.the need existed at Oconee Nuclear Station ~(ONS) to

. find a faster and more efficient method of disposal -for secondary side spent oil. Some of the oil contained minute quantities of certain radioisotopes and the oil was accumulating ~ rapidly enough so that storage was-impractical. A i'

decision was made,that the very slight amounts of activity present in the oil-

! could be categorized as " exempt quantities", defined in 10CFR30.18. As such,

the. oil could be shipped to and burned at Lee Scean Station. Due to the very L small activities involved, this disposal method was not considered hazardous to the health and safety of the public. A station directive =was, generated and approved, in August 1981, describing the waste oil program for ONS. Primary side oil and secondary side oil with activity greater than 50% of the 10CFR30.70 and 30.71 allowance was required by the directive to be burned onsite. Uncon-1 taminated oil and secondary side oil possessing an activity less than 50% of the allowance could be burned at Lee according to the directive. Shipment of 4 the contaminated oil commenced in September 1981 and a total of eight shipments were made by June 1984, amounting to 18,635 gallons.

Dis ussions were held between the NRC Region II and Duke regarding the term

" exempt quantity" in connection with McGuire Nuclear Station in February 1984; i the NRC indicated at' that time that their interpretation allowed non-routine

, . shipments of concaminated substances for laboratory analysis only. A written clarification followed on March 20, 1984 which specifically stated that no 4

" exempt quantities" are recognized for disposal purposes. A period of time elapsed between the issuing of the clarification by NRC and the realization by i Duke that the interpretation applied as well to the Oconee contaminated oil

shipments to Lee. Shipments were halted immediately, once the situation became

clear.

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t , Cause of' Occurrence:

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The . burning 'of the contaminated oil at Lee ' Steam Station occurred as a result.

.of. Duke personne1' interpreting the intent of,10CFR30.18, as applyin;_to_the

disposal of.very slightly contaminated materials'. The term " exempt quantities" was not. perceived as applying -to ' a'small sample (e.g. , for laboratory analy-

' sis). _ No : written. interpretation which clarified ' 10CFR30.18 had -been provided :

by the NRC at the. time Duke'made'the-judgement concerning;the contaminated oil.

The connection'between the,NRC Region II' clarification of March:20, 1984,and 1the'. shipping of contaminated oil:to Lee.for-burning was not immediately.recog-nized. However, a'more prompt recognition _that:the disposal method wasLin:

Leonflict'with the NRC Region II interpretation would have resulted in only a-redu'ction'of the total volume of contaminated oil burned at Lee. The cause for:,

jthe delay:in recognizing _the conflict was an oversight by the personnel'in-volved in the handling of the March ~ 20,'1984 letter.

Analysis of Occurrence:

.The original decision to ship and burn.the_ contaminated oilsat Lee was based on

- the fact that the ' concentration of' radioisotopes were very low. Duke elected

'to restrict-even further.(relative to 10CFR30.70 and 30.71) the activity levels of oil to'be burned; the levels were required to be less than 50% of the exempt levels specified by 10CFR30.70 and 30.71, for shipment to Lee.

Following the suspension of shipments to Lee, a decision was made to reanalyze all data related to the oil that had been shipped for: burning. The. analysis sought to determine, with at least 95% certainty,_shether the shipments indeed contained radioisotopes. Analysis of,the data, taking.into account background readings,Tindicated that Cesium-137,was present in a. number.of~ waste oil' samples, but with a concentration which was at~or just above the lower' limit of detectability.

Summarizing the~above information, it is seen that the original plan'to_ burn

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i the oil at Lee' stipulated that very low levels of contamination (less than half the perceived limit of 10CFR30.70'and 30.71) could not be' exceeded. Addition-ally a confirmatory analysis proved that the radioisotope concentration in i samples of oil already burned was very low. Attachment 1 provides the radio-n logical assessment of the impact that this incident had on the health and safety of the public and employees of Lee Steam Station. On this basis,' Duke i submits that this occurrence was of no significance with respect to' the health l and safety of the public.

1.

! Corrective Action:

The immediate corrective action taken was to halt all shipments of contaminated oil to Lee Steam Station. In the future, contaminated oil will be burned onsite in the auxiliary boiler or alternately solidified as waste material.

p .The station directive covering the waste oil program will be revised to remove

l. all reference to the term " exempt quantities". The deficiencies in handling NRC clarifications have been recognized and appropriate corrective actions are ~

being evaluated to assure proper handling in the future.

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Attachment:

1' Radiological Environmental Impact.

-Burning Low-Level Contaminated Oil at Lee Steam Station.

. Study Period: '1982 - 1984-Waste. Description Spent Oils from Oconee Nuclear Station Waste Volume s Activity

. Year- Volume (gal). Radionuclide ~ Total' Activity 1984 -3020 -Cs-137 0.16 2250- Cs-137 2.35 5270. 2.51 1983 7'300 Cs-137 2.19-1350 Cs-137 0.44 8650 2.63 1982- 715 Cs-137 6.34

-Cr-51 1.18 4000 Cs-137 2.05 4715 .cs-137 8.39 Cr-51 1.18 Dose Calculations:

1) Effluent dose '- Inhalation Pathway (Assume 100% release through stack)

-D = 3.17 E-8 I Rg [WQg ]

I ,

where:

3.17E-08 = The inverse of the number of seconds in a year. '

D*.=Thereleaseofradioiodines,radioactivematerialsinparticulate form and radionuclides other than noble gases in gaseous effluents,

'i', in pCi. Releases shall be cumulative over the calendar.

quarter or year as appropriate.

W= The annual average dispersion or deposition parameter for t

estimating the dose to an individual at the controlling location. ,

W = (X/Q) for the inhalation pathway, in sec/ms ,

W - (@) for the food and ground plane pathways, in meters-2, l-l

O R.

• = The dose factor for each identified radionuclide, 'i', in m2 (mrem /yr) per pCi/see or mrem /yr per pCi/m3 , for each pathway.

(Tables 3.1-12 + 3.1-30) 1.1 For adult f/Q = 2.10E-07 Cs-137 R.. = 4.27E+5 (WB)

R[ = 6.20E+5 (Liver)

Cr-51 R. = 9.99E+1 (WB)

R['=5.94E+4(Lung)-

D

= (3.17E-8)(4.27E+5)(2.10E-7)(A) = mrem /yr.

-D"bgy = (3.17E-8)(6.20E+5)(2.10E-7)(A) = mrem /yr.

1984 A = 2.51pCi D = 7.13E-9 mrem /yr.

b

. Dliver = 1.04E-8 mrem /yr.

1983 A = 2.63pCi D = 7.40E-9 mrem /yr.

wb D li er = 1.08E-8 mrem /yr.

~

1982 A = 8.39pCi D wb = 2.38E-8 mrem /yr.

(Cs-137) D liver = 3.46E-8 mrem /yr.

A = 1.18pci D = 7.85E-13 mrem /yr. -

wb (Cr-51) Dliver = 4.67E-10 mremfyr.

D TOTAL = 2.38E-8 mrem /yr.

D = 3.46E-8 mrem /yr.

liver D = 4.67E-10 mrem /yr.

lung Infant doses would be less than those for an adult.

2) Effluent dose - Ground-food Pathway 2.1 For adult where D/Q = 3.0E-10 Cs-137 R = 5.94E+9 (WB) ,

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Rg = 9.07E+9 (Liver)

Cr-51 Rg = 4.58E+4 (WB)

Rg = 1.15E+7 (GI) 1984 A = 2.51pci D ub = 1.42E-7 mrem /yr. "

D liver = 2.16E-7 mrem /yr.

1983 A = 2.63pci D = 1.53E-7 mrem /yr.

wb D liver = 2.27E-7 mrem /yr.

1982 ACs = 8.39pCi Dwb = 4.73E-7 mrem /yr.

D liver = 7.23E-7 mrem /yr.

ACr = 1.18pCi Dy3 = 5.14E-13 mrem /yr. ~

D = 1.29E-10 mrem /yr.

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'2.2 For infant where D/Q = 3.0E-10 CS-137 Rg = 3.22E+9 (WB)

R = 4.54E+10 (bone) f Cr-51 .R = 1.34E+5-(WB) f Rg = 3.91E+6 (GI) 1984 A = 2.51pCi D = 7.69E-8 mrem /yr.

b D igy = 1.08E-6 mrem /yr.

1983 A = 2.63pCi D = 8.05E-8 mrem /yr.

wb Dliver = 1.14E-6 mrem /yr.

1982 ACs = 8.39pCi . Dub = 2.56E-7 mrem /yr.

Dliver = 3.62E-6 mrem /yr.

A Cr = 1.18pCi Dwb = 1.50E-12 mrem /yr.

D igy = 4.39E-11 mrem /yr.

D b TOTAL = 2.35E-7 mrem /yr.

EXPOSURE DOSES

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'. feed rate of oil 5.4 gal / min. or 324 gal /hr.

feed rate of coal 67 tons /hr. = 134,000 lbs'./hr.

-0.12 ash content total oil volume = 18,635 gal.

1984 5,270 gal.

1983 8,650 gal.

1982 4,715 gal.

total hours burhing oil 1984 16.3 hrs.

1983 26.7 hrs.

1982 14.6 hrs. .

Ash volume generated - (134000//)(.12x) hrs.

1984 262,104 lbs.

[

1983 429,336 lbs.

1982 234,768 lbs.

Total ash generated by Lee = 1.8E+8 lbs/yr.

Radioactivity in Ash -

total act/ ash volume 1984 Cs-137 -

3.07E-5 pCi/gm.

1983 Cs-137 -

3.22E-5 pCi/gm.

1982 Cs-137 -

1.03E-4 pCi/gm.

J Cr-51 -

1.45E-5 pCi/gm.

3) Dose Rate on Surface of Semi-infinite Source ,

dis.

D = \IA.i x 5g (2.22 i" I i

PCi-min)x(60 "hr)x(1.602 x 10-8 *#S)x(100 MeV ergs /g-rad)

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-w 1[WhiriD slDisa rata:et surfaca in: Rad /hr.

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~~RD '

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A.=Radionuclide'i!EconcentrationinICOgal l' #

A

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1 (E =Radi$riuclide~'i'leffective,~ energy liniMev?

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Di s's6 = 2.65E-8"arads/hr. _

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DDisas!= 2j78E-8'arads/hr.

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e 1. ~ jD is's2,= 8.89E-8 arads/hr.t

_lCs-137L

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?4.64E-10 meads /hr.  : Cr-51~ ~

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+ 51982 TOTAL'=8.94E-8'arads/hr. ~

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b If an~ individual' stood in. ash for;1; year, his. dose would be less thin

.0.001.arad.1 Since - the'. ash is- placed :ia a pond!with ~ at .least 1 fcot

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p # :of water covering the; ash and the: ash further~ diluted by.the' pond-ashi ~J

capacity, the doseLto thel individual is evenlless. , Assume (11 foot;of

! 0.00005 water 2will mrad; provide 4,HVL of

attenuation,:then dose will be less than'

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Conclusions:

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Based on the calculations above,.the effluent' dos'es.ttrough the: inhalation-

. pathway will be:

.,- JADULT.& INFANT' 3 1984.- 7.13E-9 mrem /yr WB' 1.04E-8. mrem /yr Live'- r 1983' 17.40E-9 mrem /yr WB. 1.08E-8 mrem /yr Liver.

-1982- 2.38E-8 mrem /yr WB 3.46E-8 mrem /yr Liver ~

l

} ..and through the food pathway _will be:

ADULT INFANT

.1984 --2.16E-7. mrem /yr Liver- .

i 1.08E-6' mrem /yr Liver 1983- 2.27E-7 mrem /yr Liver 1.14E-6 mrem /yr Liver 1982 7.23E-7 mrem /yr Liver .

3.62E-6 mrem /yr Liver-

> ' Compare these numbers with the radiological impact caused by atmospheric

. emmissions of natural radioactive material - coal-fired rural power station maximum individual dose rate:

Lung - 2.1 mrem /yr.

. Bone -:16.0 mrem /yr. *See Footnote 1

'LThe exposure rate to stand in ash continuously is < 0.001 mead /yr . and' F

when covered with water is < 0.00005-mrads/yr.

p i.

As can be seen from comparison of dose rates, the effects of burning _

[ the. oil'sent to Lee Steam Station were virtually insignificant.

h

- The health,and ' safety of.the public and employees cf Lee were not--

affected.

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~ 1['ederalRegister/Vol.-44,No.-249/ December 27,1979/p. 76743, Table 2 L_ .

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