Re: radwaste scaling factors

[Emil <kerrembaev@YAHOO.COM>]

Bill,



Although, your recommends are correct however are

they reasonable? 



What do I mean?



I mean the TIME.



1. TIME.



Time is the money, right?



In the theory, of course we would like to have as

many as possible batches of the waste streams to

be characterized. And they are normally get

analyzed as parts of the effluents program.



In the reality, you have to use the scaling

because of the time it takes for the "Hard to

Detect" isotopes to get analyzed, some time it

takes more than a quarter to get the results in

the main time you may have to run out of the

space to keep rad waste or other operational

issues are forcing to ship the waste out...



You brought out an interesting issue.



I do not know what has exactly happend in Cooper,

I can only SPECULATE.



2. SPECULATIONS:



May be there was a falier to update radwaste

shipments/inventory in the annual reports, when

the "hard to detect radionuclides" analysis came

back from the vendor laboratory and "significant"

underestimations in the total activities were

discovered.



I do not see for the NRC resident to be so much

"unreasonable" to issue a violation for the

scaling was used because of the timing delays in

obtaining the Part 61. 

Probably, there were other problems and the

official notice of violation was issued as a

notice to indicate that there were problems in

the total amounts of the activities of the

radwaste in the annual report.



Emil.





You wrote:

>>>

I would recommend that you:  (1) avoid using 

rolling averages,  (2) be

sure to investigate any scaling factor shifts of 

more than an order of

magnitude, and (3) consider sampling and 

laboratory analysis for each

batch of low volume, high specific activity waste



streams, such as (for

a BWR) RWCU and FPCCU resins.

>>>











>>>>

Date: Fri, 06 Sep 2002 13:23:25 -0400

From: William V Lipton <liptonw@DTEENERGY.COM>

Subject: radwaste scaling factors



This message is directed to my fellow power 

reactor radwaste people.  My

concern is the calculation of scaling factors for



our various waste

streams.



I noticed the following in an inspection report 

for Cooper (NRC

Inspection Report 50-298/01-06, dated November 

19, 2001, available from

the NRC web page):

page 13:  "A noncited violation ... was 

identified for failure to

properly classify and manifest radioactive waste 

shipments in 1999,

2000, and 2001.  On August 21, 2001, the 

inspectors identified that the

licensee had incorrect shipping manifests and had



underreported isotopic

and total shipment radioactivity.  The licensee 

had utilized

nonconservative 3-year average waste stream 

analysis scaling factors in

each waste stream...Various isotopic scaling 

factors were low by a

factor of between 10 and 100..."



Although I have not talked with anyone at Cooper 

about this, I suspect

that this may have resulted from using software 

that uses rolling

averages for waste classification.  Even if 

that's not the case, here,

this is a potential problem if you use such 

software. While rolling

averages  may be good for smoothing out random 

fluctuations resulting

from the imprecision of the sampling and analysis



processes, it may also

mask a significant shift in the radioisotopics of



plant waste streams.

This creates the potential for nonconservative 

characterization and

classification.



I would recommend that you:  (1) avoid using 

rolling averages,  (2) be

sure to investigate any scaling factor shifts of 

more than an order of

magnitude, and (3) consider sampling and 

laboratory analysis for each

batch of low volume, high specific activity waste



streams, such as (for

a BWR) RWCU and FPCCU resins.



The opinions expressed are strictly mine.

It's not about dose, it's about trust.

Curies forever.



Bill Lipton

liptonw@dteenergy.com







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