ML19276F171
| ML19276F171 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 02/16/1979 |
| From: | Gibson A, Millsap W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19276F155 | List: |
| References | |
| 70-1201-79-02, 70-1201-79-2, NUDOCS 7903270437 | |
| Download: ML19276F171 (11) | |
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION o
REGION il 8
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101 MARIETTA STREET, N.W.
I ATLANT A, GEORGI A 30303 o
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Report No..
70-1201/79-02 Licensee:
Babcock and Wilcox Commercial Nuclear Fuel Plant P. O. Box 1260 Lynchburg, Virginia 24505 Facility Name: Commercial Nuclear Fuel Plant Docket No.
70-1201 License No. : SNM-1168 Inspection at: Lynchburg, Virginia Inspector:
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/(, f4 '77 W. J. Mil sa,R tion Specta fist Date Signed Approved by:
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/ 7 '? ~1 A. F. Gibson, Section Chief, FFMS Branch Date Signed
SUMMARY
Inspection on January 15-19, 1979 Areas Inspected This routine, unannounced inspection involved 37.5 inspector-hours onsite in the areas of radioactive liquid effluents, radioactive airborne ef fluents, procedures for controlling release of effluents, air flows internal to the facility, effluent reports, laboratory counting instruments, and radioactive solid wastes.
Results Of the 7 areas inspected, no apparent items of noncompliance or deviations were found in 5 areas; 2 apparent items of noncompliance were found in 2 areas (Inf raction - Failure to isokinetically sample the pelletizing recir-culation system paragraph 6; Deficiency - Failure to include one source of airborne ef fluent in semi-annual report paragraph 6).
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DETAILS 1.
Persons Contacted Licensee Employees
- E. J. Silk, Plant Manager
- D. W. Zeff, Manager, Safety, Licensing, and Safeguards C. W. Speight, Works Industrial Engineer
- R. L. Vinton, Health Physicist
- K. E. Shy, Supervisor, Health and Safety P. A. Cure, Health Physicist P. Schonfeld, Facility Engineer J. P. Watters, Licensing Engineer Other licensee employees contacted during this inspection included 3 technicians.
- Attended exit interview.
2.
Exit Interview The inspection scope and findings were summarized on January 19, 1979, with those persons indicated in Paragraph I above.
The licensee was informed of the apparent items of noncompliance discussed in paragraph 6 and committed to certain corrective actions also discussed in paragraph 6.
The licensee stated that further details of his corrective actions would be discussed in his response to this inspection report.
3.
Licensee Action on Previous Inspection Findings (0 pen) Unresolved Item (70-1201/77-2/2) Radioactive Liquid Releases to Unrestricted Areas. This item was previously discussed in RII Rpt. Nos.
70-1201/77-2 and 70-1201/78-3. At the time of the inspection, this item was discussed with a licensee representative who stated that, baring unforeseen dif ficulties, the liquid filtration system should be installed and operating by May 1,1979.
4.
Unresolved Items Unresolved items were not identified during this inspection.
. 5.
Radioactive Liquid Effluent a.
Tour of the Facility The inspector discussed with a licensee representative the source terms for liquid radioactive waste and dilution liquids as well as the plant's practices in handling this waste. The inspector then visited the liquid radioactive waste retention tank facility and discussed its operation with a licensee representative. At the request of the inspector, a licensee representative operated the air sparging system used to mix the contents of the tanks prior to sampling and demonstrated the vigorous mixing that this system pro-vides. These discussions, and this demonstration, demonstrated that the licensee was apparently in compliance with License Condition 8.1.2 which requires, in part, that potentially contaminated liquid effluents be controlled through a retention tank system with dilution and mixing capabilities and that the liquids be evaluated for compliance with 10 CFR 20, Appendix B limits prior to release to unrestricted areas.
b.
Radioactive Liquid Effluent Records The inspector reviewed the records of the releases of liquid radio-active materials to unrestricted areas, entitled Liquid Effluent Record, for the time period from 1/4/78 to 12/21/78. The inspector noted only one case (Release #80 on 6/30/78) of liquid waste for which uranium concentration exceeded the "75% of unrestricted area MPC" action point described in License Condition 8.1.2; this condition prohibits discharge and requires further treatment or disposal by burial.
The inspector determined by discussions with a licensee representative and review of applicable records that the liquid waste had been further diluted prior to discharge to unrestricted areas, and that the release had been authorized by the plant manager's designated alternate and an investigation had been conducted to determine the cause of high concentrations. This fulfilled all the requirements of License Condition 8.1.2 and the inspector had no further questions concerning this matter.
The inspector also chose two examples (Release No. 83 on 7/11/78, and Release No. 102 on 9/5/78) of liquid releases whose concentration exceeded 21% but not 75% of unrestricted area MPC and determined that the requirements of License Condition 8.1.2 had been met. The inspector had no further questions concerning this matter.
The inspector noticed that each time a retention tank is discharged the technician notes in his records if an accumulation of sludge is present in the tank.
This practice fulfills License Condition 8.1.2(a) which requires the retention tanks to be inspected monthly for sludge accumulation.
. c.
Calibration of the Liquid Waste Retention Tanks The inspector questioned a licensee representative concerning his method of determining the total volume of liquid effluent discharged from a given retention tank which is needed to calculate the total releases of radioactive material to unrestricted areas. The licensee representative stated that a flow integrator had been used to fill the tank and calibrate a dipstick to volume of liquid in the tank; "before" and "af ter" measurements are used to determine the total volume discharged. The inspector asked to see the data supporting this calibration and, while reviewing it, noticed that it was inconsistent with similar data given in Procedure No. AS-1104 (Contaminated Liquid Effluent Control). The inspector questioned a licensee representative concerning this matter and was informed that the data that the inspector had in hand was from a later and better calibration of the retention tanks.
The inspector stated that the licensee's best information should be incorporated into this procedure in order to determine, as accurately as possible, the amount of releases of radioactive materials to unrestricted areas. The licensee representative agreed with the inspector and stated this data would be incorporated into Procedure No. AS-1104.
This is an open item pending the inspector's review of the updated procedure (79-02-01).
6.
Radioactive Airborne Effluents a.
Tour of the Facility The inspector toured the facility and discussed with a licensee representative the general design of the plants ventillation systems used to handle contaminated effluents from the pelletizing area, as well as the design and installation of three separate air stream sampling arrangements.
The results of these efforts are given below:
(1)
Clean Area Retort Stack Sampling The inspector examined the sampling system on this stack and noted several problems. The inspector noted that the sampling probe, actually a pitot tube, was oriented perpendicular to the air flow in the duct and that the sample was being drawn through the static pressure tap rather than through the inner tubing and out the total pressure tap.
This was true even though the air flow rate in the probe for isokinetic conditions was apparently being calculated on the basis of drawing the sample through the inner tubing. Furthermore, once the sampling probe was removed and the line from the probe through filter housing to the rotometer blocked, the rotometer continued to show a steady air flow when it should have indicated a sudden drop in flow rate.
This difficulty was traced to the filter housing which, lacking the proper gasket, proved impossible to seal. The licensee representatives corrected these difficulties within a short period of time. The inspector noted that there was no regulatory requirement for sampling this stack.
(2) Pelletizing Area Stack Sampling The inspector examined the flow straightener and sampling system on this stack and discussed with a licensee represen-tative the method used to ensure that the sample taken is isokinetic as required by License Condition 8.1.l(b), as well as the means used to determine the total flow rate out of the stack.
The licensee's responses to all questions were satis-factory and the inspector had no further questions concerning this sampling system.
(3) Pelletizing Recirculation Syster Sampling The inspector examined the sampling system on this duct and noted several problems. First, the pitot tube, mounted between two sampling probes, used to determine the proper flow rate through the sampling probe for isokinetic conditions, was oriented perpendicular to the air flow in the duct and was therefore giving erroneous information; this observation was later confirmed by the licensee's measurements.
This probe had apparently been misoriented since it was installed in November 1978. Secondly, the probe being used at that time to collect a sample was oriented at an angle of approximately 45 to the airflow. Thirdly, neither the sampling probe nor the pitot tube were firmly fixed into the duct since both could be easily moved by hand. These conditions constitute anisokinetic sampling.
Licensee representatives were informed that this was in noncompliance with License Condition 8.2.1 which states, in part, that " Daily isokinetic samples of recirculated air shall be collected in the pelletizing area when the facilities are in operational status" (79-02-02). A licensee representative, in the inspector's presence, promptly corrected the deficiencies in this sampling system. At the time of the exit interview, a licensee representative stated that, in order to prevent this situation from developing in the future, the sampling systems would, at a minimum, be placed under some sort of routine surveillance to verify the probe placements.
. b.
Pelletizing Recirculation System The inspector discussed the functioning of this system with a licensee representative and determined that, under certain conditions of plant ventilation, a damper on the recirculation effluent air is discharged to the rod handling area.
During operation, potentially contaminated air passes through system components in the following order:
HEPA filtration, the sampling system, the damper, a total flow measuring device and then discharge into the pelletizing area.
On certain occasions, automatically determined, air is removed from outside the plant and directed into the pelletizing area; when this occurs, in order to maintain the pelletizing area at a negative pressure to lesser contaminated areas as required by License Condition 8.2.1, the recirculation system damper is automatically open. The inspector asked a licensee representative if the radioactive material discharged through this damper is included in the semi-annual effluent reports required by 10 CFR 70.59 and, also, when the damper was installed on this recirculation system. The licensee representative stated that this damper was installed in April 1976 and that the radioactive material discharged through it had never been included in the semi-annual effluent reports.
Licensee representatives were informed that failure to include this radioactive material in the effluent reports was apparent noncompliance with 10 CFR 70.59 (79-02-03). At the time of the exit interview, this situation was reviewed with licensee representatives and it was agreed that since the air flow rate and concentration of radioactive material out of the damper could be determined with existing equipment, the only requirements remaining were some means of determining the total time the damper is open.
A licensee representative stated that this means would be obtained and installed by March 31, 1979, and in the meantime, conservative estimates of the amount of radioactive material disciarged through this damper would be made.
c.
Quarterly Verification of Isokinetic Sampling The inspector examined the records, entitled Isokinetic Aj Sampling Rate Meter Calculations, of the licensee's quarterly ef forts to assure isokinetic sampling of the pelletizing stack and pelletizing recirculation system. The records for each quarter of 1978 were present; a more detailed consideration of the actual conditions of sampling is contained in paragraph 6.a of this report.
The inspector had no further questions concerning this matter.
. d.
Records of Pelletizing Stack Effluents The inspcetor examined the records, entitled Area Air Effluent Records for the Controlled Area Effluent, of the releases of racio-active materials out the pelletizing stack for the time period from January 3 to December 22, 1978. The inspector noted no case where the concentration of radioactive materials exceeded 75% of the un-rectricted area MPC which constitutes compliance with the limits set by 10 CFR 20.106 and the most restrictive case set by License Condition 8.1.1.
The inspector had no further questions concerning these records.
e.
Records of Concentrations of Airborne Radioactive Materials in the Pelletizing Recirculation System The inspector examined the records, entitled Area Air Effluent Records, of the concentrations of airborne radioactive materials in the pelletizing recirculation system for the time period from 1/3/78 to 12/22/78 and noted no case when the concentrations exceeded the limits set by 10 CFR 20.106. The inspector had no further questions concerning these records.
f.
Records of Weekly Checks of HEPA Filter Differential Pressure Gauges The licensee is required by License Condition 8.1.1(a) to weekly check the differential pressure gauges monitoring HEPA filters and to replace the filters when the differential pressure exceeds four inches of water.
The inspector reviewed the records, entitled Magnahelic Readings, of these checks for the time period from 1/4/78 to 12/19/78.
The inspector noted that the records were present and noted that the records were present and noted no case where the differential pressure exceeded four inches of water. The inspector had no further questions concerning these records.
7.
Procedures For Controlling the Release of Effluents The inspector reviewed the procedures for controlling the release of effluents and discussed with a licensee representative the items listed below:
a.
Procedure No. AS-1104 Rev. 2 - Contaminated Liquid Ef fluent Control (1) The inspector noted that this procedure neither calls for mixing the retention tanks prior to sampling as required by License Condition 8.1.2 nor specifies the mixing time necessary to obtain a representative sample. The inspector discussed this with a licensee representative who stated that the tech-nicians routinely mix the tanks for approximately ten minutes
-1 prior to sampling. The inspector asked the licensee represen-tative if a study had been performed to determine the mixing time necessary to obtain a proper sample.
The licensee representative stated that a study had not been performed but that he felt that ten minutes of mixing was adequate; the inspector agreed.
The inspector stated that the licensee's procedures should reflect his practice; the licensee represen-tative agreed.
The licensee representative stated that the procedure would be revised to instruct the technicians to mix the tanks for either ten minutes or a mixing period determined by a study prior to sampling.
This is an open itera pending the inspector's review of the licensee's action (79-02-04).
(2) The inspector noted that this procedure did not specify that once the concentration of radioactive material in the effluent reached a certain action level specified by License Condition 8.1.2 that an investigation to determine the probable cause and techniques for elimination required by License Condition 8.1.2 should be performed. The inspector determined by record review and discussions that the licensee was performing the required investigations; however, the inspector stated that the licensee's procedure should reflect his practice.
The licensee representative agreed. The licensee representative stated that the procedure would be revised to reflect this license condition. This is an open item pending the inspector's review of the licensee's action (79-02-05).
b.
Procedure No. AS-1103, Rev 3 - Airborne Radioactive Materials Control The inspector noted and stated to a licensee representative, that now that the damper on the pelletizing recirculation system is considered a point of release to uncontrolled areas (see paragraph 6.b of this report), it thould come ander the controls required by License Condition 8.1.l(c) and that these controls should be procedur-alized.
The licensee representative acknowledged the inspector's comments and agreed to take the matter under consideration. This is an open item pending the inspector's review of the licensee's action (79-02-06).
c.
Procedure No. AS-1110, Rev. 4 - Solid Waste Control The inspector noted that although this procedure contained License Condition 8.1.3(a-d), which defines the upper limits of contamination for which waste materials and equipment may be disposed of in a routine industrial f shion, it did not include License Condition 8.1.3(e) which states, essentially, that if an item cannot, for some reason, be thoroughly surveyed, it will be treated as contami-nated and, when possible and practical, reasonable attempts will be
. made to decontaminate all items with detectable contamination to non-detectable levels. The inspector discussed this with a licensee representative who stated that these practices were being followed and that the procedure would be revised to include them. This is an open item pending the inspector's review of the licensee's action (79-02-07).
8.
Airflows Internal to the Facility License Condition 8.2.1 states, in part, that " General area exhaust units will be operated to maintain areas of greater contamination at a slight negative pressure with respect to lesser contaminated areas".
a.
Negative Pressure Audits As a means of insuring compliance with this license condition, the licensee requires, by means of Procedure No. AS-1103, that weekly visible smoke tests and checks of fixed pressure dif ference indicators be performed. The inspector reviewed the records of these tests and checks, entitled Negative Pressure Audits, for the time period from January 5, 1978, to December 10, 1978.
In all cases, the records were present and the results of the tests and checks appeared to be adequate. The inspector had no further questions concerning these records, b.
Independent Check of Air Flows At the request of, and in the presence of, the inspector a licensee representative perfo rmed visible smoke tests to determine the direction of air flow at the following points:
door between the vault and the pelletizing area; equipment door between the outside and the pelletizing area; door between the change room and the pelletizing area; and the door between the rod handling area and the change room. In all cases, the flow was from the lesser to the more contaminated areas.
The inspector had no further questions concerning these tests.
9.
Semi-Annual Effluent Report The inspector reviewed the semi-annual effluent report for the first six months of 1978 transmitted to Region II in a letter dated August 8, 1978, as required by 10 CFR 70.59.
This regulation requires that the report be submitted within 60 days of July 1, 1978, and that it contain the quantity of each principle radionuclide released to unrestricted areas in liquid and gaseous effluents during the previous six months of operation. The inspector noted that the report was submitted within the required time frame and that it listed the principle radionuclides to be expected.
As a check on the total amount of utonium reported by the
_9 licensee to have been released to unrestricted areas in liquid effluents, the inspector, using the licensee's release records independently totaled the individual release records to dete rmine the total amount of of uranium released in the liquid effluents; the inspector's total agreed with the licensee's amount.
The inspector had no further questions concerning the report of liquid effluents. An apparent item of noncom-pliance concerning the reporting of airborne effluents is discussed in paragraph 6 of this report.
10.
Laboratory Counting Instruments a.
Instrument Calibration and Checks The inspector reviewed the records of the monthly calibrations and daily checks of the NMC PCC-11T proportional counter, which is used to count all liquid and airborne effluent samples, for the year 1978. All records were present and the calibration method appeared adequate.
The inspector had no further questions concerning the calibration of this instrument.
b.
Source Check of the NMC PCC-11T Proportional Counter At the request of the inspector, a licensee representative counted on the NMC PCC-11T Proportional Counter a Th-230 alpha standard provided by the inspector and provided the inspector with his assessment of the activity present on the standard. The licensee's assessment and the actual amount of activity present on the standard were in goc < agreement.
The licensee representative was informed of this and the inspector had no further questions.
c.
Instrument Sensitivity License Condition 8.3.2 states that the analytical capability for evaluation of effluent samples shall be such that instrument sensi-tivity and sample preparation techniques allow:
a.
0.5% of the appropriate MPC for liquids; b.
10.0% of the appropriate MPC for airborne effluents.
The inspector discussed with a licensee representative his method of satisfying this license condition and was info rmed that the method used was taken from NBS Handbook 80, "A Manual of Radioactivity Procedures".
The inspector reviewed the licensee's calculations and they appeared to be in order.
The inspector had no further questions concerning this matter.
. 11.
Radioactive Solid Waste The inspector toured the pelletizing area and observed the manner in which contaminated waste is controlled and packaged and discussed with a technician his work practices in controlling this waste; the inspector also toured the LSA storage facility and observed the condition of packages stored there. Procedure AS-1110, Rev. 4, Paragraph 7.5 requires that these packages be surveyed for removable alpha contamination and the beta-gamma dose equivalent rate at three feet before removal from the controlled area; if the removable alpha contamination exceeds 2
220 dpm/100 cm or if the beta gamma dose equivalent rate at three feet exceeds 10 mrem /hr, the package must be decontaminated to levels below these limits or repackaged. While at the licensee's LSA storage facility, the inspector recorded identifying information from two packages awaiting shipment and later checked the licensee's records to see if the records of the transfer of the packages were on file; they were. The inspector reviewed the records entitled LSA Container Survey for the time period from 10/4/78 to 12/22/78 to see if the LSA packages met the above limits before being removed from the controlled area. The inspector noted no case where the limits were exceeded and had no further questions concerning solid radioactive waste.
.