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Home My WebLink AboutDRC-2018-004827 - 0901a0688081e9c1INSPECTION REPORT FOR: EnergySolutions DATE OF INSPECTION: April 13,2018 FACILITY ADDRESS: Clive, Utah (40.698602, -l I3.I07504) FACILITY CONTACT: Robert Sobocinski, PG, Groundwater Program Manager, Direct 801.303.01 87, Cell 801.201.1561 APPLICABLE REQUIREMENTS: Radioactive Material License UT 2300249 Appendix M dated Jruly 22,2014. R3 1 3/R3 I 5 or applicable license/permit requirements TYPE OF INSPECTION: Environmental Monitoring Report for Second half of 2017. PARTICIPAIITS: Bill Craig, Robert Sobocinski. WEATHER CONDITIONS: Not applicable TIME IN: Self-explanatory TIME OUT: Not applicable. REPORT PREPARED BY: Bill Craig FACILITY DESCRIPTION: CREDENTIALS, PURPOSE AND SCOPE: Not Applicable. MANAGEMENT ACTIVITES: NARRATIVE: The report was reviewed and compared with prior results to evaluate trends and compliance. ISSUES: Prior versions of the EMP required fence line samples quarterly and annual radial samples. Because the radial samples were taken during the same period that the fence line samples were taken, the quality control samples taken were allowed to cover both events. Now the radial soil samples are a separate event and need to have quality control samples processed in accordance with EMP. The Division is still concerned about the abnormally large difference between the spiked values and the analytical results for the gamma detector quality control checks. The Division acknowledges the licensee's efforts to correct the deficiency and will monitor the future results. COMPLIANCE STATUS: In the Environmental Monitoring Plan (EMP) dated July 22,2014, section 6.5 Soil Sampling Quality Control Requirements states "Four of the routine soil samples from each sampling event will be split." Additionally, it requires four soil samples to be collected twice as simultaneous blind field replicates. Contrary to this, the second half semi-annual environmental report did not include any results for these two requirements. RECOMMENDATIONS: No other deficiencies were noted during this inspection. The minor deficiencies listed above may lead to more significant problems if not corrected. Because of the minor nature of these findings it is recommended that enforcement discretion is exercised. SIGNATURE: Uid,e.--.-, 0,*1 DIVISION OF WASTE MANAGEMENT & RADIATION CONTROL INSPECTION MODULE SEMIAI\INUAL REPORT REVIEW Environmental Monitoring Program License Number AT 2300249 Appendix M Serniannual Report: 2"dHalf 2017 2.0 Reviewed by:Bill Craig Radioactive Material License Condition 29 The Licensee shall submit the following reports to the Executive Secretary: 1.0 Has the licensee submified the semiannual results from the Environmental Monitoring Program within 3 months after the last day of each monitoring period? Yes NoX Violation Comments: Received late on March 30,2018 Airborne Particulate Sampline Location - Does the semiannual report provide results for the following 14 stations: A-10, A-11, A-13, A-16, A-17, A-18, A-19, A-22, A-28, A'29, A-30, A-35, A- 36, and VTD (if operated)?Yes X No Violation Analvsis - Did the licensee analyze the air filters for gross alpha and gross beta concentrations after a minimum of 7 days?Yes X No Violation Comments: 2.2 Was a semiannual average alpha air particulate concentration calculated for each monitored location? Comments: Highest average alpha concentration for a Point of Compliance Station was 2.5 E- 15 at A-35. It was 2.9%o of the action level. 2.1 Yes X No Violation 2.3 Was a semiannual average beta air particulate concentration calculated for each monitored location? Yes X No Violation Comments: Highest average beta concentration for a Point of Compliance Station was 2.5 E- 14 at A-28 This was 1.2% of the action level. 3.0 Greater than Action Level - For samples with net alpha concentrations greater than the action level of l.4E-13 prCi/ml, did the licensee analyze the filter by Gamma spectrometry within 3 days after the gross alpha analysis? yes No NA X Violation Comments: No samples exceeded alpha action levels. 3.1. For samples with gtoss beta concentrations above background greater than the action level for Pb-210 (Concentration - bkgd(station 4-16) : greater than 2.lE-12 pCilml) did the licensee analyze the filter by garnma spectroscopy within 3 days after the gross beta analysis? Yes No NA X Violation Comments: No samples exceeded beta action levels. 3.1.1. Was additional radiochemical analyses performed when an individual filter has a net alpha concentration above 3E-12 uCi/ml or net beta concentration above 5E-11 uCi/ml, unless gamma spectroscopy associates at least 50 percent of the net alpha or net beta activity present on the filter with gztrnma- emitting radionuclides? Yes No NA X Violation Comments: No individual samples exceeded limits. No additional analysis required. 4.0. Semiannual Composite Analvsis - Did the licensee analyze on a semiannual basis, composite samples, consisting of all samples from each specific POC station dwing the quarter, by gamma spectometry. These composite samples will also be analyzed specifically for U-238, -234, and -235,Th-228, -230, and -232,Ra-226, Pb-210, and Po-210.Yes X No Violation Comments: None of the results exceeded ECL's. 4.1 Additional Analvsis - Was additional radiochemical analyses performed for those radionuclides that could reasonably be expected to contribute more than five percent of the aggregate CEDE over the 5.0 period?Yes X No Violation Comments:Pl-239,1J-234,U-Dep, Arn-z{l,Ra-226, U-Nat, Pu-238, U-238,Pu-240, Th-Nat, Th-232, Co-60, Cm-243, andTh-230 identified in report as radionuclides requiring additional analvsis. Accuracv of Tests - Are MDA's for alpha and beta screening at least 7E-14 pCi/ml. Yes X No Violation Comments: Minimum Detectable Concentrations MDC) - Are the MDCs for gamma spectral analysis of semiannual airborne particulate samples less than 10 percent of the ECL's? Yes X No Violation Comments: Spot checks on U-238, Ra-226 and Co-60 showed MDC's well below 50 % criteria. U-238 maximum MDA:5.3E-16 pCi/ml and limit of 7.2E-13 pCi/ml. Ra-226 maximum MDA = l.5E-16 pCilml and limit of 6E-13 pCi/ml, Co-60 manimum MDA :3.8E-16 uCi/ml and limit of 5E-11 pCi/ml. Radon in Outdoor Air (section 4.2 and 5.2) 6.0 Location - Does the semiannual report provide results for the following l5 stations: A-10, A-11, A-13, A- 16, A-17,A-18, A-19, A-22, A-27, A-28, A-29,A-30, A-35, A-36,andB-2? Yes X No Violation Comments: Averase Rn Concentration - are the net average concentrations for Radon below the ECL? (4.9 pCr/l,respectively) Yes X No Violation 5.1 6.1 Site average uncorrected concentration of 0.04 pCilL. Highest concentration without occupancy factor was 0.4 pCilL at A-17 for 4th quarter. Gamma Radiation Dose (4.3) 7.0 Location - Are gamma doses measured at the following 13 stations: A-10, A-l l, A-13, A-16, A-17, A- 18, A-19, A-22, A-28, A-29, A-30, A-35, and ,4.-36Yes X No Violation Comments: Highest Semiannual Dose was 60.3 mrem/Q at A-28 without occupancy factor. Max dose for POC last 2 periods with occupancy factor was 14.9 rnrem at A-28. 7.2. Known dose - Were four dosimeters given a known dose each period, analyzed and reported in the semiannual Environmental Report? Yes X Comments: Average dosimeter difference was -24.5%o for 17Q3 and 8.8% for 17Q4. Mar dosimeter difference was -32.0Yo. 7 .3 Were four radon monitoring devices sent to be exposed, analyzed and reported in the semiannual Environmental Report? Yes X No No Violation Violation Comments: Ma:r difference is7.7%. Average difference is 6.3 %. 8.1 Soit Sampling (4.4) Gamma Spectroscoov Analysis - Are gamma spectroscopy results reported for the following 24 locations on an annual basis: B-2, S-19, S-22,5-24,5-26,5-27, S-28, S-29, S-36, S-37, S-39, S-40, S- 56, S-57, S-59, 5-64, 5-65, 5-66, S-71,5-72, S-73, S-74, S-77, SA-18? Yes X No Violation 9.1. Special Analvsis Requirements - Is the soil collected from Stations: A-36,B-2,5-22, 5-26, S-28, S-39, 5-56, S-59, 5-65, 5-66, S-72,5-74, and SA-18 analyzed for thorium 230 and232in first half year report? Yes NoX Violation Comments: Not required for second half semi-annual report. 10.0 Concentration results - Are all reported naturally-occtrring nuclide concentrations, other than Potassium-40 below 5 pCi/gram? Yes No X Violation X Comments: Highest U-238 concentration was 2.5 pCrlg at North 1200. Average concentration 1.3 pCilg. 10.1 Concentration results - Are all reported concentration values for Cesium-I37, below 3 pCi/gram? Yes X No Violation Comments: Highest concentration was 0.8 pCilg at West 1200. Average concentration is 0.3 pCilg. 10.2 Concentration results - Are all reported man-made nuclide concentration values, below 2pClgram? Yes X No Violation Comments: Highest concentration was 0.3 pCi/gm at west 300. Average was 0.1 pCi/gm. 11.0 Split Soil Samples - Did the licensee split samples at four stations and report the replicate error ratios (RER) values? If RER exceeded 2 andthe activity was less than 5 times the isotope's detection limit, was the sample rearnlyzed? Yes No X Violation Comments: No soil split samples included in report. f 1.1 Duplicate Soil Samples - Did the licensee collect and analyze four soil samples twice as simultaneous blind field replicates (duplicates)? Was one sample analyzed for Thorium 228,230, and232. If RER exceeded 2 and the activity was less than 5 times the isotope's detection limit, was the sample reanalyzed? Yes No X Violation Comments: No Thorium analysis included in report. ll.2 Soil Samples - Did the licensee's analysis have an MDC less than or equal to 1.5 pCilg except when the uncertainty is less than 50% of the measured activity? Yes X No Violation Comments: lJ-238 samples met requirement. Highest MDC was 1.49 pClg. Dose Limitsl2,l Total Effective Dose Equivalent (TEDE) [R313-15-3011 - Is TEDE for last two periods less than 100 millirem? Yes X No Violation ? Comments: Highest annual TEDE was reported to be 3l mrem at A-35 12.2 ALARA Constraint [R313-15-01(4)l - Is CEDE for last two periods less than 10 millirem? Yes X No Violation Comments: Highest annual CEDE 0.31 mrem/year was at station A-18. 12.3 Radioactive Material Releases [R313-25-191 - Is CDE for last two periods less than 25 millirem? Yes X No Violation Comments: Highest annual CDE was 0.043 Inrem at A- 10 and A-22. Sample Analysis (5.0) 15.0 Certified Laboratorv - Are outside analytical results and analysis used for dose determination for comparison to standards performed by a Utah Certified Laboratory? Go to http://health.utah.govAab/labimpAabcert/LabsCertified CWA.xls for listing. Yes X No Violation Comments: GEL laboratorv.