ML20138J840
| ML20138J840 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 04/18/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20138J832 | List: |
| References | |
| 70-1113-97-03, 70-1113-97-3, NUDOCS 9705090057 | |
| Download: ML20138J840 (19) | |
Text
..... -. - - -
~
r U.S. NUCLEAR REGULATORY COMMISSION REGION II l
Docket No.:
70-1113 l
l l
License No.:
SNM 1097 i
Report No :
70-1113/97 03 l
Licensee:
General Electric Company i
Wilmington, NC 28402 l
l Facility Name:
Nuclear Energy Production l
[
Dates:
March 23 27, 1997 l
Inspector:
W. Gloersen, Senior Radiation Specialist l
l t
Approved by:
E. J. McAlpine, Chief Fuel Facilities Branch l
Division of Nuclear Materials Safety l
Enclosure 9705090057 970418
"~
PDR ADOCK 07001113 C
pm
l L
Executive Summary l
General Electric Nuclear Energy Production i
l NRC Inspection Report 70-1113/97 03 l
The primary focus of this routine unannounced inspection was the observation and evaluation of the licensee's environmental protection and waste management programs.
In addition, the status of the new Dry Conversion Facility (DCF) l was reviewed with respect to radiation protection, radioactive effluent waste management and functional testing of sampling systems. The report covered a one week period and included the results of inspection efforts of one regional fuel facility inspector.
Based upon the results of this inspection, the licensee's environmental protection and waste management programs were acceptable. Within the scope of i
the inspection, one non cited violation was identified for the failure to collect and analyze a vegetation sample as required by the license application. There was one new inspector follow up item being tracked aertaining to reviewing the licensee's internal dose assessment of the CaF 2
3asin excavation equipment operators.
4 RADIATION PROTECTION Installation and functional testing of the stationary air sampling e
equipment associated with the Dry Conversion Facility had not been completed and therefore the licensee could not demonstrate air sampling representativeness.
Radiation protection posting and access control requirements had not e
i been completed for the Dry Conversion Facility.
A high volume air sample indicated elevated gross alpha airborne e
concentrations in the vicinity CaF, excavation of the south basin.
ENVIRONMENTAL PROTECTION Analytical results from the various surface environmental samples e
collected indicated that there was no radioactive material from plant l
operations accumulating or concentrating at the sample location.
One isolated example for the failure to collect a vegetation sample e
l during the second half of 1996 was identified.
Elevated concentrations of uranium in certain samples from groundwater e
wells in the vicinity of the CaF pits was identified.
2 e
The 1996 external audit of the environmental 3rotection function was thorough, however, the audit was lacking in tlat it provided no assessment of performance for the licensee, s
c.
WASTE MANAGEMENT The licensee had effectively implemented the required stack sampling e
- program, Total quantities of radioactive liquid and gaseous emissions from the e
facility have been decreasing since 1994.
Equipment installation, functional testing, and procedure development e
for the collection and analysis of gaseous and liquid samples associated with the Dry Ccnversion Facility were not ready to support operation of the facility.
Attachments:
Partial List of Persons Contacted Inspection Procedures Used List of Items Opened, Closed, and Discussed List of Acronyms
~
l l
l l
l l
I l
l l
1 l
-~,
1 Report Details j
I. Introduction A.
Inspection Overview 1.
Purpose This inspection was conducted to determine the adequacy of the licensee's environmental protection and waste manaoement programs. This routine inspection was conducted through a review of selected records, interviews with personnel, and direct observation of work activities in the areas of facility operations, environmental protection, and waste management.
2.
Ma.ior Areas of Emohasis l
Areas inspected included:
e Environmental Protection Program Implementation e
Effluent Waste Management Program e
DCF Operational Readiness in the areas of Radiological Protection and Radiological Effluent Controls B.
Sunnary of Plant Status This report covered a one week period. There were no unusual plant operational occurrences during the onsite inspection. Construction and testing activities for the DCF were progressing.
II. Radiolooical Controls A.
Radiation Protection (83822) 1.
Radiation Protection Proaram Eauipment a.
Insoection Scope The inspector examined the stationary air sampling system and other radiation protection equipment necessary to support operations in the new DCF.
b.
8bservations and Findinas
)
Dur!ng tours of the DCF, the inspector noted that most of the stationary air samplers (SAS) had been installed, however, it was also noted that several air sampling heads were missing: the system had not been functionally tested; and the final locations 1
l i
2 for air samplers had not been determined (see Inspection Report No. 70 1113/97 02). The licensee indicated that at DCF startup.
25%-50% of the workers will be issued lapel air samplers to evaluate personnel exposures.
l The inspector also noted that the licensee had established a DCF radiation protection action item checklist, which required that the action items be closed before DCF startup. The completion of the installation, testing, and procedures for the SAS was included on the action item list.
In addition, the action item list included the establishment of a radiation protection work area in the DCF with necessary counting equipment and instrumentation:
adequate respiratory protection equipment and supalies of protective clothing: and adequate supplies of hig1 volume, low volume, and lapel air samplers.
c.
Conclusions Installation and functional testing of the stationary air sampler (SAS) equipment had not been completed and therefore the licensee could not demonstrate air sampling representativeness. The licensee's radiation protection action item list to support DCF l
operations was acceptable.
l 2.
Internal Exposure Controls j
a.
Insoection ScoDe The ' inspector examined work activities associated with the CaF, Basin source removal and relocation project to determine if l
adequate radiation protection controls were in place.
l l
b.
Observations and Findinas l
During a tour of the CaF Basin source removal and relocation projectonMarch25,199h,theinspectorobservedexcavation activities of the south basin (Basin #1). The excavation activities involved the removal of the CaF using heavy machinery.
2 During dry conditions, the potential for dusty conditions existed.
The inspector noted that the heavy equipment operator was not wearing a lapel air sampler, nor was a lapel air sampler required
)
by the arocedure. CaF Project Health and Safety Plan, Revision l
g 1, Marc 1 11, 1997, indicated that personnel radiation exposure is monitored by (1) thermoluminescent dosimeters (TLDs): (2) in-vitro bioassays: and (3) area radiation monitoring. After the observation by the inspector, the licensee requested that a high i
volume air sample be collected.
The high volume air sample result was 0.96E 11 yC1/ml. The inspector discussed the result with licensee representatives who indicated that the excavators will be i
l t
3 issued lapel air samplers so that any potential internal exposure l
l could be evaluated. The inspector indicated that the results of the internal exposure assessment will be tracked as an inspector i
followup item (IFI 70-1113/97 03 01).
c.
Conclusions By collecting a high volume air sample, the licensee detected l
elevated gross alpha airborne concentrations in the vicinity CaF, excavation of the south basin. No conclusions can be made until l
more data are collected and assessed.
3.
Postinas. Labelina. Access Control a.
Inspection ScoDe The inspector examined DCF to determine if adequate postings and access control measures were in place to support operations in the new Dry Conversion Facility.
b.
Observations and Findinas During tours of the DCF, the inspector noted that the facility was in the final construction stages and therefore the necessary radiation protection mstings and radiation control area access had not been establisled. As noted above, the licensee had i
established a DCF radiation protection action item checklist. DCF posting and access control requirements were included on the action item checklist.
c.
Conclusions l
Although the necessary radiation protection posting and access control requirements had not been completed, the licensee's system for tracking these items for completion before DCF startup was acceptable.
l B.
Environmental Protection (88045) 1.
Monitorina Proaram Results a.
Insoection ScoDe i
The inspector reviewed the licensee's environmental protection program with respect to program implementation. Table 5.1 of Chapter 5 of the License Application specifies sampling frequency, parameters analyzed, action levels, minimum detectable concentrations (MDCs), and sampling types collected.
Figures 5.3, 5.4, 5.5, 5.6, and 5.7 of the same cha)ter contained maps showing the locations of sampling sites throug1out the area.
i 1
l 4
b.
Observations and Findinas The environmental monitoring program 3rovided representative i
measurements of radioactivity in the lighest potential exposure l
pathways and verification of the accuracy of the effluent monitoring program of environmental exposure pathways.
Accumulation of radioactivity in the environment can thereby be measured; trends assessed, to determine whether the radioactivity resulted from plant operations: projections mcde of potential dose to off site populations based on the cumulative measurements of any plant-originated radioactivity; and detection of unanticipated pathways for the transport of radionuclides through the environment. The program was designed to detect the effects, if any, of plant operation on environmental radiation levels by monitoring radiation pathways in the area surrounding the plant site.
It also verified that the measurable concentrations of radioactive materials and levels of radiation were not higher than expected on the basis of the effluent measurements.
The inspector reviewed selected sampling results from weekly environmental stationary air samples; and surface water, sediment, and soil samples collected quarterly in 1996 as part of the licensee's routine environmental monitoring 3rogram. Most of the sampling locations around the facility were >elow the appropriate action level specified in Table 5.1 of the Application. The l
inspector did note that, in the first, second and fourth quarters 1996, a few onsite and offsite soil samale locations had slightly elevated total uranium concentrations t1at exceeded the licensee's i
action level of 0.7 ppm as specified in Table 5.1.
In those l
cases, the licensee issued an Environmental Action Level (EAL) l investigation. The inspector reviewed selected EAL investigations that documented elevated soil sample results that occurred in 1996. The EAL investigations were adequately documented and part of the licensee's followup action was to watch the trend. The inspector indicated that additional appropriate actions might l
include a review of sampling procedures and techniques and a review of the analytical procedures used in the CHEMET laboratory where the environmental samples were analyzed. The licensee acknowledged the inspector's comments.
During the review process, the inspector noted that the results for the vegetation samples scheduled for collection in Fall 1996 were not available.
Table 5.1 of the license application recuires j
the licensee to collect vegetation samples twice per year anc to be analyzed for fluorides. By the end of the onsite inspection.
the licensee was still in the process of locating the sample results.
In a subsequent telephone call on April 7, 1997, the licensee informed the inspector that the vegetation sample was not collected in the Fall 1996. Apparently the sample was inadvertently missed and it was not included on the licensee's overcheck list.
In addition, Table 5.1 did not specify an action level for vegetation samples. The corrective actions included the l
l
5 issuance of an Action Level Investigation Form, collection of a vegetation sample and the analysis (in addition to the first half 1997 sample), and update the overcheck list to include vegetation sampling. The licensee was informed on April 15, 1997 that the failure to collect the vegetation sample was a violation of Safety Condition S-1, Sections 5.2.2.3 and Table 5.1 of the Application.
However, this violation will not be subject to enforcement action I
because the violation was of minor environmental concern, the licensee's efforts in correcting the violation were prompt, and the violation met the criteria specified in Section IV of the NRC Enforcement Policy for a Non Cited Violation (NCV 70-1113/97 03-02).
The inspector also reviewed the results of the licensee's groundwater monitoring 3rogram. Table 5.1 of the license application specified t1e sampling locations, collection l
frequencies, analytical parameters, and action levels.
In 1996, most of the groundwater monitoring results were below the license j
application action level. However, the inspector noted that i
groundwater sample results for total uranium from the wells i
l installed downgradient from the CaF pi from approximately 2 to 3181 pCi/ liker.t relocation project ranged l
The maximum concentrations occurred during the excavation activities. The licensee met with representatives of the State of North Carolina's Department of Environment, Health and Natural Resources (DHENR) on i
December 19, 1996 to discuss the results of the CaF Well 2
monitoring data.
The State DHENR representatives noted that since the groundwater sample results were in excess of State groundwater quality standards, the licensee was required to fully assess the vertical and horizontal extent of the affected groundwater and propose a corrective action to restore the groundwater. _In a letter dated March 3,1997 from the licensee to the State of North Carolina, the licensee transmitted a schedule for actions to l
address the issues raised by the DHENR. The inspector indicated l
that further review of the licensee's progress in addressing the groundwater issues will be made during subsequent inspections.
i The inspector also noted that groundwater sample results from Well PL 11A, which was installed east of the NE CaF basin and became operational on January 30, 1995, rangedfrom4bto 21,600 pCi/ liter during the period January 30, 1995 to j
February 17, 1997. The sam le result collected on February 17, 1997 was approximately 920 i/ liter. The licensee believed that this well may have been dri led into a vein of CaF,t from PL 11A.
sludge. The licensee installed two additional wells downgradien To date, the sample results from those wells indicated background levels.
c.
Conclusions j
In general, the analytical results from the various surface environmental samples collected indicated that there was no l
l
6 concu' *ating at the sample location. There was one isolated exame.e for the failure to collect a vegetation sample during the j
secoad half of 1996. The licensee had detected elevated l
concentrations of total uranium in certain groundwater wells in 1
l the vicinity of the CaF pits. The elevated activity was most 2
l likely due to the excavation of the CaF during the source term 2
l relocationprojectin1996.
i I
2.
Manaaement Audits. Inspections. and Controls l
l a.
Inspection Scope 1
The inspector reviewed the licensee's environmental protection l
audit program and results. The requirements of the environmental l
protection internal audits were specified in Section 2.8.2 of the license application. The requirements for external audits were I
l specified in Section 2.8.3 of the application.
1 b.
Observations and Findinas The inspector randomly examined records of both internal and external environmental protection audits. The last external audit was conducted the week of September 23 27, 1996 by the licensee's cross business unit. The audit covered management and organization, operating permits, air emissions, waste water, waste management, radiation protection, soil and groundwater contamination, and procedures. The audit was com)rehensive, however, a heavy emphasis was placed on OSHA and EPA regulatory l
compliance. The audit findings were formally tracked, including l
the corrective actions and issue date: assigned to a person or organization for closure action; identified an action completion date; and identified the closure status. The inspector did note, however, that the external audit provided no assessment of l
licensee performance in the environmental protection area.
l The inspector also reviewed the quarterly internal audits conducted in 1996. Each of these audits focused on a ) articular aspect of the Health and Safety program, including, tie environmental protection function, training, waste storage, and radiological protection. The last quarterly environmental audit was conducted during the first quarter 1996. There were no audit findings identified. The inspector noted that for the other quarterly audits conducted in 1996, there was no apparent formalized tracking system for audit findings.
c.
Conclusions The 1996 external audit of the environmental protection function was thorough, the audit findings were tracked, and the. assignment of responsibility for closure was acceptable. However, the audit I
7 was lacking in that it provided no assessment of performance for the licensee.
In addition, a more formalized system to track internal audit findings was noted as an area for improvement.
3.
Decommissionino Activities-CaF, Relocation Pro.iect a.
Inspection Scope i
The inspector reviewed the licensee's progress in evaluating the l
residual radioactivity remaining in the burial trenches of the northwest CaF storage area after relocation of the material to an l
2 above ground storage facility in the Controlled Access Area (CAA).
In addition, the inspector reviewed the progress in removing the CaF from three basin areas.
2 i
b.
Observations and Findinas l
As of the end of July 1996, the licensee had essentially completed the excavation and relocation of the CaF from the northwest 2
storage area. The licensee was in the process of implementing the l
Final Status Survey and Release Plan for the Northwest CaF,ity Area l
(FSS Plan) in order to demonstrate that residual radioactiv l
concentrations at the northwest CaF storage area satisfied the 2
NRC criteria for future use without licensing restrictions and radiological controls. The inspector indicated to the licensee that a representative number of samples should be split.
preserved, and stored for possible future NRC analysis for l
confirmatory measurement purposes.
l The inspector also noted that the licensee had initiated the CaF, removal from the South Basin (or Basin # 1) and relocation to an above ground storage facility. The licensee estimated that 29,970 l
cubic feet (ft ) of CaF was in the basin.
In addition, the 2
l licensee had planned to remove CaF in both the North Basin '9asin 2
- 2 37.690 ft ) and the Outer Basin (Basin #3-34,280 ft ).
Although the licensee's goal was to remove the CaF source term, 2
the licensee had not planned to release these areas without licensing restrictions and radiological controls due to their proximity to the operating site process lagoon system. The licensee's request to delay " free release" of the CaF, basin area was still being reviewed by the NRC.
c.
Conclusions The licensee had completed excavation of the CaF in the Northwest 2
Storage Area well with in the schedule and was progressing acceptably toward implementation of the Final Status Survey and Release Plan.
8 C.
Waste Management (88035) l 1.
Monitorina Proaram Results a.
Inspection Scope The inspector reviewed and assessed records and reports of gaseous and liquid effluent discharges from the facility 4" ring the last calendar year and compared those discharges to diicharges from l
previous years.
]
10 CFR 70.59 requires the licensee to submit a report to the NRC Region II office, within 60 days after January 1 and July 1 of each year, specifying the quantity of each the of the principal l
radionuclides released to unrestricted areas in liquid and gaseous l
effluents during the previous six months of oper,ation.
If the quantities of radioactive materials released dur'ing the reportir.g periods are significantly above the licensee's design objectives previously reviewed as part of the licensing process, the report shall cover this specifically.
b.
Observations and Findinas l
i i
The inspector reviewed the Semiannual Effluent Release Reports for l
the period January 1, 1996 through December 31, 1996, and verified that they were submitted within the required time frame. During i
the onsite inspection, the inspector noted that the report for the second half of 1996, dated February 25, 1997, incorrectly made l
reference to the first half of 1996. The inspector verified the data were representative of the second half of 1996. The licensee immediately corrected the typographical error and resubmitted the second half 1997 semi annual effluent release report in a letter to the NRC dated March 24, 1997. Although the minimum reporting requirements of 10 CFR 70.59 were met, the inspector observed that the licensee used only selected portions of the report format guidance sxcified in Regulatory Guide 4.16, Monitoring and Reporting ladioactivity in Releases of Radioactive Materials in l
Liquid and Gaseous Effluents From Nuclear Fuel Processing and Fabrication Plants and Uranium Hexafluoride Production Plants, Rev. 1. December 1985.
Subsequent semi-annual reports will be reviewed against the reporting format guidance in Regulatory Guide 4.16.
The inspector compared the total quantities of liquid and gaseous effluent discharges in 1996 with previous years. The data are summarized in Table 1 below.
m..
me-
9 Table 1:
Effluent Summary for General Electric Company Nuclear Energy Production (1993 1996) l Quantity Released (microcuries. pCi) l Effluent Nuclide 1993 1994 1995 1996 Gaseous U 234 7.31E+01 1.04E+02 9.56E+01 9.42E+01 U 235 2.85E+00 4.06E+00 3.84E+00 3.71E+00 l
U 236 2.54E 02 3.69E 02 1.84E-02 1.21E-01 U 238 1.16E+01 1.65E+01 1.60E+01 1.44E+01 Total 8.76E+01 1.25E+02 1.15E+02 1.12E+02 Liquid U-234 8.19E+04 7.19E+04 6.51E+04 4.97E+04 U-235 3.19E+03 2.81E+03 2.61E+03 1.96E+03 U-236 2.89E+01 2.54E+01 1.21E+01 6.42E+01 U-238 1.30E+04 1.14E+04 1.11E+04 7.60E+03 l
Total 9.81E+04 8.61E+04 7.88E+04 5.93E+04 i
l The total quantity of uranium discharged in gaseous effluents in 1996 was 112 yCi. Since 1994, there has been a slight decrease in the total quantity of uranium discharged in gaseous effluents. By l
using the USEPA's COMPLY code, the licensee estimated an offsite dose of approximately 0.? mrem. The estimated dose was based on the total quantity of gaseous effluents released from the facility l
in 1996 to a maximally ex>osed receptor. This estimated dose was l
significantly less than t1e NRC's new dose constraint of 10 mrem for air emissions, as specified in 10 CFR 20.1101(d).
l The total quantity of uranium discharged in liquid effluents in 1996 was 5.93E+04 pCi. Since 1993, there has been a decrease in l
the total quantity of uranium discharged in liquid effluents. The licensee did not calculate a dose based on the total quantity of liquid effluents released from the facility in 1996.
c.
Conclusions Total quantities of radioactive liquid and gaseous emissions from the facility have been decreasing since 1994.
In 1996, the estimated dose to a maximally exposed offsite receptor was less l
than 10% of the 10 CFR 20.1101(d) dose constraint which indicated that the licensee's gaseous releases were ALARA.
2.
Effluent Controls. Procedures. and Instrumentation a.
Inspection Scope The inspector reviewed the licensee's controls and procedures for sampling and analyzir.g liquid and gaseous discharges from the facility.
In addition, the inspector reviewed the licensee's readiness for samp' sing and analyzing effluent discharges from the DCF uhich was currently in the final stages of construction.
l
I i
10 The licensee was required to sample and analyze discharges via the gaseous and liquid pathways in accordance with Chapter 5. Part I of the license application. Specifically, Section 5.1.1 outlined l
airborne effluents and exhaust systems from the uranium processing areas.
Each exhaust stack from uranium processing areas was required to be continuously sampled from a )oint between the final l'
Application specified the collection frequency, parameters of HEPA filter and the discharge to the atmosplere. Table 5.1 of the interest, action levels, and detection limits. Depending on the particular stack, the filters in the stack samplers were required l
to be collected at least daily or weekly and measured for gross l
alpha and beta activity. Additionally, Section 5.1.2 of the l
Application described the treatment process, sampling and analytical controls for treated process liquid waste.
b.
Observations and Findinos (1)
Fuel Manufacturing Operations (FM0) l The inspector reviewed selected procedures and verified that the l
action levels and provisions for collecting and analyzing liquid l
and gaseous effluent samples were in accordance with the license application.
In addition, the inspector reviewed selected weekly composited analytical results from January 1996 to February 1997 for discharged liquid effluent from the final process lagoons, aeration basin and the site dam. The inspector noted that total uranium, gross al)ha, and gross beta concentrations in the samples were well below t1e specified action levels.
l The inspector selectively reviewed weekly stack program re3 orts I
covering the period from September 1996 February 1997.
3ased l
upon the records reviewed, the inspector noted that the specified action level had been exceeded during the 3eriod January 1016, 1997 on the stack associated with the new Jecontamination and Volume Reduction Facility (DVRF). The weekly average sample l
result for the DVRF stack was 9.73E 10 Ci/cc which exceeded the licensee's weekly average action level of 3.0E-12 pCi/cc. The high activity was probably due to the disturbance of the settled material in the ductwork during system startup. The material in the ductwork had settled due to the long period of inactivity.
The licensee's corrective actions were acceptable.
l In addition, the inspector reviewed the quarterly quantities of gaseous waste effluents released in 1996 and the first quarter of 1997. The inspector verified that the gaseous release quantities were less than the license application limit of 1250 pC1/ quarter.
In 1996, the maximum quarterly quantity release was 34.1 pCi which occurred during the third quarter. The total quantity of uranium i
l l
l 11 l
l released during the first quarter of 1997 was 36.1 pC1.
From the data above, it was apparent that the licensee was well below the license application's quarterly limit.
l (2)
Dry Conversion Facility (DCF)
In addition, the inspector toured the DCF to determine if adequate gaseous and liquid sampling ecuipment and procedures were l
installed, functionally testec, and operationally ready for startup.
The inspector noted that there will be three gaseous release aoints from the DCF:
(1) HVAC discharge from the DCF main j
l auilding (uranium and HF samples): (2) discharge from the washing column (uranium and HF samples); and (3) discharge from the emergency scrubber (HF sam)le).
The DCF HVAC system exhausts building air to the atmosplere through a single stack mounted along the side and roof of the building. The stack did not penetrate the roof of the building due to the potential concerns for water intrusion. Air is passed through two sets of high efficiency particulate air (HEPA) filter banks before it is exhausted to the atmosphere. The four foot diameter stack was designed to carry 28,645 cubic feet per minute (cfm) of air. The sampling points for HF and particulate matter (uranium) were located in the horizontal section of the duct and approximately 20 l
feet -(ft) downstream of the 90 degree bend where the duct l
penetrated the DCF building wall. The licensee indicated that a l
single point sampling probe located in the center of the duct for the collection of particulate matter should be sufficient for obtaining a representative sample due to the turbulent flow in the duct. The inspector reviewed the licensee's evaluation, which l
made appropriate references to applicable ANSI standards and use of chemical engineering references. Based on the assumptions of the rated efficiencies of HEPA filters for the removal of particles, the average size of the ) articles remaining in the exhi,at stream after passing throug1 the HEPA filters should be much smaller than five microns. Assuming that the inertial l
effects for particles less than five microns will be negligible.
l the particulate matter in the air stream may be considered as a l
gas. The licensee also predicted that the exhaust air in the l
stack will be turbulent and therefore the particulate matter containing the uranium is expected to be evenly distributed across the stack diameter. The ins)ector verified the licensee's calculation of the Reynolds iumber which predicted the turbulent flow. Although, collecting a sample from a horizontal section of a duct is not ideal, the licensee's analysis justifying the sample probe location appeared to be acceptable.
While tracing the sam)le delivery line from the HVAC discharge back to the DCF main Juilding, the inspector noted at least three 90 degree bends that could have been avoided. The licensee made note of the observation and indicated that the problem would be l
1
l I
i l
12 corrected.
From discussions with a licensee HVAC specialist, the inspector noted that the velocity profile measurements across the duct diameter had not been completed and the air flow probes had l
not been installed.
In addition, the ins)ector noted that Dwyer rotameters had been installed, however, t1e licensee's rotameter calibration equipment was only compatible with Wallace rotameters.
The HVAC specialist indicated that the Dwyer rotameters would have to be replaced with equipment compatible with the licensee's calibration equipment.
In addition, the licensee had not completed revision to the surveillance, sampling and analysis procedures for the DCF.
The inspector also traced the sample delivery line associated with the discharge from the washing column. Although unnecessary 90 degree bends were not observed, the inspector did note similar concerns as discussed above for the HVAC discharge.
The inspector also toured the hydrofluoric acid tank system facility and noted that installation of the liquid sampling equipment had not been completed.
In addition, sampling and analysis procedures were still in the development process. The licensee was also evaluating what modifications to make for transporting ten percent HF acid solutions to the Waste Water Treatment Facility.
c.
Conclusions Releases of gaseous radioactive materials from the facility were significantly less than the license a) plication quarterly limit.
In addition, total uranium, gross alpla, and gross beta concentrations in liquid effluent samples were well below the specified action levels.
Both of these parameters indicated that licensee *s effluent control program was effective.
Equipment installation, functional testing, and procedure development for the collection and analysis of gaseous and liquid sa':.ples associated with the DCF were not ready to support operation of the facility.
3.
Information Notices (92701) a.
Insoection Scope The inspector reviewed the following Information Notice (IN) to determine if the information had been received by the licensee:
l e
Implementation of a New Constraint on Radioactive Air Effluents, dated February 24, 1997.
l 13 b.
Observations and Findinas The inspector determined that Information Notice 97-04 had been received by the licensee, reviewed for applicability, distributed to appropriate personnel, and that action, as appropriate, was taken or scheduled.
i l
C.
Conclusion l
l The licensee's actions were appropriate.
4.
Followuo on Previously Identified Issues (92701) a.
Inspection Scope The inspector reviewed the following unresolved item (URI):
70 1113/96 07-01: Determine whether or not the strong tight container identified as D0T 128-30 satisfied the packaging recuirements s>ecified in 49 CFR 173.410 and 173.411 for an incustrial paccage Type 1.
b.
Observations and Findinas The inspector reviewed the licensee's evaluation of the Jackaging requirements.
It was determined that the DOT 128-30 paccage l
conformed to 49 CFR 173.410 requirements. The container in question was equivalent to a 4G container. The 12B 30 container was made from fiberboard that incorporated an inner container l
consisting of a one gallon metal can. The shipment in question involved a limited quantity of radioactive material. Therefore.
the packaging requirements for limited quantity shipments were not I
required to be transported via IP-1 classified containers (49 CFR l
173.411), but were required to be shipped in accordance with 49 i
CFR 173.410.
c.
Conclusions The licensee's analysis was acceptable. This item is closed.
l 4
14 i
III. Manaoement Meetinas A.
Exit Interview 1
l The inspection scope and results were summarized on March 27, 1997, with those persons indicated in the Attachment. The inspector described the areas inspected and discussed the inspection results, including the likely informational content of the inspection report with regard to documents and/or processes reviewed during the inspection. Although proprietary documents and processes were occasionally reviewed during this inspection, the proprietary nature of these documents or processes has been deleted from this report.
Dissenting comments were not l
received from the licensee.
l During a telephone conversation on April 7,1997, the licensee informed the inspector that a vegetation sample required by the license application to be collected semi-annually was not collected in November i
1996. The licensee was contacted telephonically on April 15, 1997, and informed that the failure to collect and analyze the vegetation sample would be identified as a non-cited violation of license application requirements.
i l
l l
1 l
l t
i
I 15 i
ATTACHMENT 1.
PERSONS CONTACTED
)
Licensee Personnel
- D. Brown, Team Leader, Environmental Project
- T. Crawford, Senior Environmental Engineer
- D. Dowker, Team Leader, Environmental Process Team
- R. Foleck, Senior Licensing Specialist G. Fornasiero, Engineer, Packing and Transportation
- A. Maary, Principal Nuclear Safety Engineer
- C. Monetta, Manager, GENE Environmental Health and Safety (EH&S)
- L. Paulson, Manager Nuclear Safety
- L. Quintana, Manager, Fabrication Product Line R. Reda, Manager Fuels and Facility Licensing
- G. Sbrocco, EH&S Engineer
- H. Shaver Nuclear Safety Engineer
- H. Strickler, Manager, Site EH&S
- K. Theriault, Manager Quality Assurance and Chemet Laboratory C. Vaughan, Project Manager EH&S New Facility Licensing / Safety ~
1 Other licensee employees contacted included engineers, technicians, production staff, security, and office personnel.
- Denotes those present at the exit meeting on March 27, 1997 2.
INSPECTION PROCEDURES USED IP 83822 Radiation Protection IP 88035 Radioactive Waste Management IP 88045 Environmental Protection IP 92701 Followup 3.
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED l
Item Number Status Descriotion l
70 1113/96 07-01 Closed URI Determine whether or not the strong l
l tight container identified as D0T 12B30 I
satisfied the packaging requirements specified in 49 CFR 173.410 and 173.411 for an industrial package Type 1.
i
l 16 70 1113/97-03-01 Open IFI Review licensee's internal dose assessment of the CaF equipment operators., basin excavation 70 1113/97-03 02 Closed NCV - Failure to collect a vegetation sample in accordance with Sections 5.2.2.3 and Table 5.1 of the Application.
4.
LIST OF ACRONYMS c
CAA Controlled Access Area l
CaF Calcium Fluoride 2
l-cfm cubic feet per minute DCF Dry Conversion Facility DHENR Department of Health. Environment, and Natural Resources DVRF Decontamination and Volume Reduction Facility j
EAL Environmental Action Level EH&S Environment, Health & Safety j
EPA Environmental Protection Agency l
FM0 Fuel Manufacturing Operations FSS Final Status Survey GE NE General Electric Nuclear Energy GE-NEP General Electric Nuclear Energy Production l
HF Hydrofluoric Acid HVAC Heating, Ventilation, and Air Conditioning IFI Inspector Follow up Item IP Industrial Package IR Inspection Report MDC Minimum Detectable Concentration NCV Non Cited Violation l
OSHA Occupational Safety and Health Administration ppm parts per million SAS Stationary Air Sampler URI Unresolved Item I
l i
l