IR 05000054/1990080
| ML20012D683 | |
| Person / Time | |
|---|---|
| Site: | 05000054, 07000687 |
| Issue date: | 03/19/1990 |
| From: | Ronald Bellamy, Bores R, Carrasco J, Jang J, Kelly P, Knapp M, Kottan J, Mcnamara N, Ross F, Starmer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20012D677 | List: |
| References | |
| 50-054-90-80, 70-0687-90-80, 70-687-90-80, NUDOCS 9003280234 | |
| Preceding documents: |
|
| Download: ML20012D683 (38) | |
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.n _ - , U. S. NUCLEAR REGULATORY COMMISSION . REGION I- [ l Report Nos. 50 54/90-80 70-687/90-80 , . Docket Nos.1(E14 i '70-687 , License Nos. B-61 , SNM-639 Priority 1 Category UHBR-t Licensee: Cintichem. Incorocrated a , P. O; Box 816 . Tuxedo. New York 10987 , a Facility Name: Reactor and Hot I.aboratory
Inspection At: Tuxedo. New York l -
Inspection' Conducted: February 916 and February 26.1990 k-dM I C;IN O ( ~ Inspectors: R} R. Bellamy, Chief, FacilTes Radiological date d Safety and Safeguards Branch (FRS&SB), M[ Division'of Radiation Safety and Safeguards (DRSS) ! 3/l5li$ i R. J. Bs6s, Chief, Effluents Radiation date ! Protection Sec RPS), FRS&SB,'DRSS < , Wb 7-17-90 . J. J. Kottan, laboratory Specialist dat7 F PS, FRS&SB, DRSS f. O')& S d6-fc) ' JL.
L /C. Jang, Senior Radiatiordspecialist date L ERPS, FRS&SB, DRSS l-L ha tmh SI:5ho ' N. T. M9Namara, Laboratory Assistant date ' ERPS, FRS&SB, DRSS I 9003280234 900319
PDR ADOCK 05000054 J.d I .Q PDC
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<.. ,. 6; > d f/M/d 3-/6-fd J. Nrasco, Reactor Engineer date . Materials and Process Section, Engineering . Branch, Division of Reactor Safety (DRS) kk u JOU9$ P. W. Kellef Resident Inspector, Indian Point 2 ' date Projects Branch 1, Division of Reactor Projects (DRP) l V WIS/99 f R. J. Staf(ner, Technical Branch, Division date-l // of Low Level Waste Management & Decommissioning (LLTB), Nuclear Materials Safety and Safeguards (NMSS) f & WW/?4 kF. W. Roh, Hydrologist, LLTB, NMSS date
Y 9I/O Approved by: e , Malcolm R. Knapp, Dire (taf / ate' l d Division of Radiation Safety and Safeguards Inspection Summary: Special Inspection on February 9-16 and February 26.1990 Combined Inspection Renort Nos. 50-54/90-80: 70-687/90-80 Areas Inspected: Special team inspection by NRC personnel from Region I and Headquarters - .
(NMSS) of the events surrounding the discovery of radioactivity in the storm drain system in ' November,1989 and in response to the leaks in the reactor pool system on February 9,1990 and following. - Areas inspected included the circumstances surrounding the pool system leaks; l the licensee's radiological measurement capability; the control of liquid releases from the site; ! the short term actions and longer term mitigation of ground water contamination resulting I ' from the ventilation duct from the hot cells; the hydrogeological studies being conducted by the licensee; and the management organization and resources applied to identifying and' correcting the contamination problems.
Results: The inspection indicated that with one exception, the licensee's response to the events '
on February 9 and following were timely and appropriate. The exception was the release of contaminated effluents from the onsite holding pond to the Indian Kill Reservoir during the early hours of February 9,1990. This was identified as a violation (Section 3.2.4). The licensee's efforts to obtain expert assistance, as necessary, to identify, mitigate and correct the leaks; to provide the hydrologic site characterization; and to effect longer range corrective actions were, in general, timely and aggressive. Section 5.1 discusses an unresolved item relative to the collection efficiency of the main filter bank.
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u;.; Table of Contents
Page 1.0 Principal Individuals Contacted......................... Details 1.1 Licensee Representatives....................... -. De t ails 1.2 Licensee Consultants and Contractors...........,,... Details 1.3 New York State Representatives..................
1.4 - NRC Representatives.......................... 3 2.0 Purpose of Inspection...............................
3.0 Reactor Pool System leaks and Chronology of Events........
3.1 Syste m Description............................ 4 3.2 Activities of February 8,1990, Preceeding the Leak.....
3.2.1 Onsite Water Management Prior to February 9, ..
1990 3.2.2 Discovery of Contamination in the Holding Pond on February 9,1990...................... 5 3.2.3 Determination of Source of Leak............., 6 3.2.4 Management of the Contaminated Water On Site.
3.2.5 Further Leaks Identified...................
3.2.6 NRC Concerns..........................
4.0 Inspection Activities in the Gamma Pit and HUT,.........
r 4.1 The G amma Pit..............................
] 4.1.1 Mortar Activity..........................
- 4.1.2 Grouting Activity........................
4.1.3 Nondestructive Examination of Concrete.........14 Structures 4.2 The Hold-Up Tank (HUT)......................
4.3 Previous Inspection Activities..................... 16 5,0 - Contamination in Storm Drain S-5......................
_ 5.1 Ventilation System Filtration.....................
5.2 Long Range Corrective Actions...................
- 6.0 Confirmatory Measurements..........................
7.0 Hydrogeological Studies.............................
8.0 Licensee Organization and Management.................. 20 9.0 Exit In terview.................................... 20 Attachments - Attachment 1, Figure 1, Diagram of the Reactor Pool Systems Attachment 1, Figure 2, Simplified Diagram of the Reactor Pool System - Attachment 2, Sequence of Events for Pool System Leakage Attachment 3, Site Diagram Indicating the Sampling Points for Runoff Water Attachment 4, Confirmatory Action Letter, dated February 23, 1990 _ Attachment 5, Letter _ dated February 13, 1990, Order Modifying License Attachment 5, Figure 2, Order Modifying License Attachment 6, Cintichem Verification Test Results Attachment 7, Hydrogeologic Inspection at Cintichem Attachment 7, Appendix A, Letter dated January 12,1990 from N. G. Kaul - to J. J. McGovern Attachment 7, Figure 1, Proposed Monitoring Well Locations _ m
--. .- .... , .,; e- ' DETAILS 1.0 - Principal Individuals Contacted ' 1.1 Licensee Representatives D. Gallagher, Vice President-Operations, Medi-Physics, Inc.
- D. Grogan, Manager, Radiochemical Production
'J. Guenther, Staff Health Physicist .l M. Johnson, Reactor Supervisor
- J. McGovern, Plant Manager
- F. Morse, Manager, Engineering and Technology Sales
- T. Rice, Health Physics Tech. III (Env. Iab)
- W. Ruzicka, Manager, Nuclear Operations
- T. Springer, Director, Materials Management, Medi Physics, Inc.
J. Stewart, Supervisor, Health Physics R. Strack, Nuclear Projects Engineer '
- L. Thelin, Staff Health Physicist
- T. Vaughn, Manager, Health, Safety and Environmental Affairs 1.2 Licensee Consultants and Contractors W. Fecych, Consultant Burns and Roe. Inc.
J. Vri, Engineer . Leggette. Brashears and Graham. Inc. (LB&G) L F. Getchell, Project Manager l D. Terry, Field Supervisor
l ' Olson Wricht NDT&E. Inc.
L Olson, Principal Engineer y l Structural Preservation Systems. Inc.
J. Gallagher, Concrete Repair Contractor A. Stock, Concrete Repair Contractor _ _ - - - - - - -
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1.3 New York State Representatives New York Department of Environmental Conservation (NYDECT J. Jones, Hydrologist, Bureau of Radiation, NYDEC
- W. _Varcasio, Environmental Radiation Specialist I, Bureau of Radiation B. Youngberg, Environmental Radiation Specialist III, Bureau of Radiation S. Zobel,' Environmental Radiation Specialist II, Bureau of Radiation New York State Department of Labor (NYDOL)
.. B. Kothari, Associate Radiophysicist, Division of Safety and Health 1.4 NRC Representatives
- M. A.- Austin, Radiation Specialist, ERPS, FRS&SB, DRSS, Region I
- R. R. Bellamy, Chief, FRS&SB, DRSS, Region I
- R. J. Bores, Chief, ERPS, FRS&SB, DRSS, Region I
'J. E. Carrasco, Reactor Engineer, MPS, Engr. Br., DRS, Region I G. C. Comfort, Project Licensing Manager, Fuel Cycle Safety Branch, Division of Industrial and Medical Nuclear Safety, NMSS, HQ
- J. C. Jang, Senior Radiation Specialist, ERPS, FRS&SB, DRSS, Region I P. W. Kelley, Resident Inspector, Indian Point 2, Division of Reactor Projects (DRP), Region I J. J. Kottan, Laboratory Specialist, ERPS, FRS&SB, DRSS, Region I
- N. T. McNamara, Laboratory Assistant, ERPS, FRS&SB, DRSS, Region I
- F. W. Ross, Hydrologist, LLTB, NMSS, HQ L W. Rossbach, Senior Resident Inspector, Indian Point 3, DRP, Region I R. J. Starmer, Section Leader, LLTB, NMSS, HO
- Denotes attendance at NRC exit on February 15,1990 2.0 Puroose of Inspection This special inspection was conducted primarily in response to the reactor pool system leaks discovered on February 9,1990, and the resulting contamination of the water in
the onsite holding pond. The inspection team also reviewed the licensee's ongoing efforts to identify, repair and mitigate the contamination in a storm drain system identified in October / November,1989, believed to be due to exhaust leakage from the underground ventilation duct that leads from the hot cells to the main filter bank.
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3.0 Reactor Pool System Leaks and Chronolony of Events 3.1 System Description As used in this report, the reactor pool system refers to the reactor water storage tank, the hold-up tank (HUT), the pool and stall, the transfer canal and the gamma pit. The reactor water storage tank is an above ground aluminum structure which has a capacity of 100,000 gallons. The stall and pool are concrete structures with a metalliner sandwiched between two layers of concrete. As shown in Attachment 1, Figures 1 and 2, the transfer canal and gamma pit are connected to the pool. The transfer canal can be isolated from-the pool and gamma pit by a gate at each end with inflatable seals to form water-tight barriers. The transfer canal and gamma pit are concrete structures without liners and according to construction drawings may have been poured against bedrock. The hold-up tank is a concrete box resting on bedrock at an elevation below the reactor. It provides for decay of nitrogen-16 from the reactor prior to the coolant going through heat exchangers and returning to the reactor pool. The HUT, like the transfer canal and gamma pit, are unlined concrete structures. The reactor is licensed by the NRC to operate at powers up to 5 megawatts for irradiation of targets used in the production of radionuclides for use in radiopharmaceuticals.
3.2 Activities of February 8.1990. Preceeding the Leak At about 0700 hr on February 8,1990, the licensee pumped water from the pool, stall, transfer canal and gamma pit to the storage tank in order to drain the gamma pit. After the gamma pit was emptied, it was isolated from the transfer canal. Subsequently, the pool, stall and transfer canal were reflooded to normal water level. The gamma pit was then cleaned with high pressure water spray.
At approximately 1815 hr, the gate between the transfer canal and gamma pit was opened to allow the gamma pit to refill. By about 1900 hr, the pool and primary water system had been refilled to normal level. (See Attachment 2 for a partial sequence of events beginning on February 8,1990.)
3.2.1 Onsite Water Management Prior to February 9.1990 The licensee had previously reported to the NRC in a letter dated December 14,1989, the discovery of radioactive contamination in a storm drain discharge outfall (S-5) and at an upstream manhole in the parking lot (S-4). The S-5 outfall discharges into an onsite holding pond, the far end of which passed through an earthen berm via two side-by-side i
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5 culverts. The discharge side of the culverts was referred to as S-1 and S-2, respectively, for sampling and radioanalysis. This discharge traveled approximately 60 to 100 meters downgrade to the Indian Kill Reservoir.
A sampling point just prior to the reservoir was designated S-6. (See Attachment 3 for details of sampling locations).
As a result of increased activity levels of iodine 131 (I-131) measured at S-j 5, the licensee installed a deionizing system at S-4 on January 4,1990 to- ' reduce the I-131 concentration to less than the maximum permissible concentration in water (MPCw) at S 5. No detectable levels were > measured in the holding pond. On January 5,1990 the NRC requested that Cintichem close the gate at the holding pond berm, preventing the holding pond from discharging.through S-1 and S-2. The licensee was - further requested to sample and analyze the water in the holding pond (S-12) prior to any further releases to the Indian Kill Reservoir. The licensee agreed to take these actions as well as to increase the sampling and analyses of the water at S-1, S-6, S-4 and the other potential release , points. This was the situation as of February 8,1990.
3.2.2 -Discovery of Contamination in the Holdina Pond on Februarv 9.1990 l: Due to the heavy rains on February 8, the storm drain system and surface water runoff filled the holding pond much more rapidly than normal.
< Records indicate that the holding pond was sampled and discharged eight times on February 8. The last discharge was at 2116 hr. Records of the i analyses indicated that no activity above background had been detected in any of the above samples.
At about 0900 hr on February 9,1990, licensee management was informed by the onsite environmental laboratory that a sample collected from the - l holding pond (S-12) at 0030 hr that morning revealed the following i activities.
l- 'I-131 3.28 E-7 uCi/mi L Mo-99 3.59 E-7 uCi/ml l Na 24 1.18 E-5 uCi/ml I-133 2.76 E-7 uCi/ml ' The licensee immediately took action to ensure that no further water was L released from the holding pond to the reservoir, and started pumping the water from the holding pond to onsite tanks, where it could be held, sampled, analyzed and released, or processed and released as necessary.
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- r A _ waste processing contractor.was brought on site to process the water through a deionization / filtration system. S-12 was resampled and analyzed by the licensee's environmental laboratory. The results of a sample.
collected at S-12 at 0902 hr on February 9,1990 had the following ' activities.
I-131 6.40 E-7 uCi/ml Mo-99 4.66 E-7 uCi/ml , Na-24 1.16 E-5 uCi/ml I133 4.35 E-7 uCi/ml i After obtaining the preliminary results of the 0902 hr sample from S 12,- the licensee notified the NRC and the NYDEC.
The licensee continued to pump the water from the holding pond to tanks and to process that water to a second tank for sampling and analysis.
The licensee also sampled and analyzed the possible sources of contamination to the holding pond. Analytical results revealed the contamination was coming from the discharge (S-3) of the storm drain, which includes any drainage of the reactor pool, transfer canal and-gamma pit system. The discharge of S-3 was pumped directly to storage tanks beginning at 1000 hr on February 9. Analyses confirmed that the discharge contained activity levels nearly equivalent to that in the reactor pool system. The licensee further reported that the temperature of the discharge was only slightly less than the pool water.
3.2.3 Determination of Source of Leak L The licensee attempted to determine the specific source of the leak. With ! the reactor shut down, the pool water storage tank was inspected and no evidence of leakage was found. The water in the pool system was equalized across the pool, transfer canal and gamma pit to measure rates
. of loss after isolation. Based on the correlation between water level in ' L the gamma pit and rate of flow at S-3, and on the slightly better correlated radioisotopic match between the gamma pit and the S-3 l discharge, the licensee deduced that the gamma pit was the most likely source of the leak. The gamma pit was drained during the evening hours of February 9 and the flow at S-3 was observed to be greatly reduced.
Heavy rains during the night again boosted the flow in S-3 by about two orders of magnitude. Visual inspections of the gamma pit on February 10,1990, identified a primary possible source of leakage and several suspect areas. These findings subsequently were confirmed by a l I! I
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~ contractor utilized by the licensee to inspect and repair the reactor pool-system. (See Section 4 for additional details).
3.2.4 Management of the Contaminated Water On Site
' During the day and evening hours of February 9,1990, the licensee ' continued to pump water from the holding pond to the onsite tanks for
. processing and analysis prior to discharge to the 001 discharge point,' which is located downstream from the reservoir. The licensee's available.
spare water storage capacity rapidly decreased as rains continued. The - licensee took action to minimize the addition of unnecessary water to the holding pond by eliminating noncontact process water.
The licensee's radioanalytical capability was such that the analysis of a sample required about 3 to 4 hours in order to reach an adequate sensitivity. This was due to the 250 ml bottle geometry employed at that
time by the licensee. After the NRC Mobile Radiological Measurements Laboratory arrived on site about 2130 hr on February 9, samples were analyzed in that laboratory to assist the licensee's environmental j laboratory in providing a more rapid sample turnaround (about 40 minutes) using a one-liter Marinelli beaker counting configuration. NRC . analyses were used to independently assess activity levels in various liquid streams, verify the licensee's analytical measurements and to assist in trending changes in activity as a function of time. The NRC also assisted. the licensee in calibrating the licensee's four detectors for the Marinelli geometry and verifying the results of those calibrations. (See Section 6.0) By Saturday morning, February 10, the licensee had essentially run out of spare storage capacity for water and the holding pond had filled to near the top of the berm. Concern increased that the berm might fail or that the holding pond would overflow. Analyses by the licensee and verification by the NRC revealed that the radioactivity levels in the holding pond had been reduced, primarily from dilution by incoming-surface water, to less than the appropriate MPCw for discharge at the 001.
discharge point. The NRC then concurred with the licensee's request to pump directly from the holding pond to the 001 discharge. The licensee and NRC continued to sample and analyze the holding pond at S-~12 to L ensure that the radioactivity levels continued to decline and no new ,
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sources of radioactivity appeared. Following the emptying of the holding pond to the 001 discharge and the subsidence of the influent to the - holding pond, the licensee agreed to operate the holding pond in a batch > process mode. That is, before pumping the holding pond to the 001 , discharge, the licensee agreed to sample and analyze the holding pond at S-12. No more discharges were to be made to the Indian Kill Reservoir.
The licensee continued to process the water from the filled tanks, $ analyzing each batch prior to release to the 001 discharge. ' Water from S - ', 3 was pumped to tanks; water from.S-4 was processed through a deionizer prior to release to the holding pond. Samples were taken by the licensee-at least daily at S-1 to monitor leakage from the holding pond through the berm.
. On February 20,1990, the licensee informed the NRC during telephone discussions that, on February 9,1990, the holding pond had been released ' three times to the reservoir prior to completion of the analyses. These releases were made at 0030 hr,0410 hr, and 0657 hr, after the samples ' were taken but before the analyses were completed. The licensee stated - that it had been raining hard and the holding pond filled more rapidly than the licensee could sample and analyze the samples. At that time it , took the licensee over three hours to analyze a sample with the counting
geometry (250 ml bottle) in use. Consequently, the licensee reported, the l holding pond was discharged prior to completion of analyses to keep the pond from overflowing the berm or causing the berm to fail.
Furthermore, the licensee stated that, prior to that time, no detectable activity had been identified in any S-12 samples. The licensee estimated that the three early morning discharges on February 9,1990 totaled about 30,000 gallons.
The analytical results for the 0030 hr samples became available at about ' 0900 hr on February 9,1990. As stated above, all subsequent discharges of the holding pond were halted as of that time.
The licensee's records indicate the following results for the last S-12 sample on February 8 and for the next three S-12 samples on February 9, 1990. The holding pond was discharged each time to the reservoir, y L i .- , m
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Time of Sample and , , - Start of Discharge - Nuclide Activity uCi/ml Time Analyses Completed
2/8/90 2116 hr No detectable activity 2/9S01038 hr .2/9/90 0030 hr I-131 (3.28i19.1%*) E-7' 2/9/90 0859 hr Mo-99 (3.59*10.f,4%) E-7 I133 (2.76*33.53%) E-7 Na 24 (1.18i2.56%) E-5 . 2/9/90. 0400 hr I-131 (4.13i43.94%) E-7 2/9/901007 hr Mo-99 (3.11*21.93%) E-7 , Na 24 (8.9712.55%) E-6 l-2/9/90 0657 hr I 131 (5.15i17.38%) E-7 2/9/90 1122 hr Na 24 (1.32c3.94%) E-5
2/9/90 0902 hr I131 (6.40i28.67%) E-7 2/9/90 1247 hr .-> Holding Pond Mo 99 (4.65i22.91%) E-7 not released I-133 (4.35i47.40%) E-7 to reservoir Na-24 (1.16*3.28%) E-5 ,
- Two standard deviation uncertainty The release of radioactivity from the site to the reservoir, rather than to the 001 discharge point as required by Sections 3.9.3(1), (2) and (3) of the Technical Specifications, for Reactor License No. R-81, and Sections 5.1.3.a., b. and c. of Part 1 of the application for the SNM-639 license, L
respectively, is a violation. (50-54/90-80-01; 70-687/90-80-01) It is noted that the appropriate MPCs from 10 CFR 20, Appendix B, L Table II, Column 2 for the released radionuclides are as follows.
1131 3 E-7 uCi/ml I-133 1 E-6 uCi/ml Mo-99 2 E-4 uCi/ml Na-24 2 E-4 uCi/ml
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' Water samples have been collected daily by the licensee at the water company's pumping station (S 13) since February 9, and periodically by L the NRC, the New York Department of Health, and the water company y for independent analyses. Review of available data for water collected at l S.13 since the release through February 26,1990, had indicated no E detectable radioactivity in the reservoir above natural background.
Following telephone discussions with Cintichem on February 20, the NRC L issued a Confirmatory Action I.etter (CAL 190-005) on February 23,1990 .; L to confirm the methodology and procedures for any subsequent discharges - ! from the site. (See Attachment 4). The CAL prohibits any further , intentional discharges to the reservoir, defines the sampling and analytical ' program for discharges from the site, and establishes notification i requirements relative to defined off normal discharge conditions, During the early morning hours on February 24,1990, the licensee notified the NRC that, because'of the heavy rains and surface water run-
- off, the holding pond had to be pumped to the 001 discharge prior to
completion of the analyses in order to prevent overflow or breach of the
f berm. Subsequent completion of the analyses revealed measurable levels ' of I 131 in the holding pond at the time of this discharge, but below the appropriate MPCw for discharge to 001. The licensee identified the contamination source as S-3 and took action to install a larger pump at S-3 to prevent any overflow from discharging to the holding pond.
. On February 26,1990, the inspector reviewed the licensee's action relative to the CAL; observed the larger capacity pump at S 3, the piping from S-3 to an onsite tank, and the modifications to S-1 to pump leakage back to the holding pond; and reviewed the draft procedure used to ensure that all practical efforts were made to prevent any discharge of unmonitored water, and to prevent any water from the holding pond from being released to the reservoir. The inspector determined that the licensee had taken all actions as expected from the CAL and, in addition, made additional modifications to minimize any further occurrence of the above events. The inspector had no further questions with regard to the discharge on February 24,1990.
, 3.2.5 Further Leaks identified The HUT is a rectangular structure constructed of concrete with the approximate dimensions of 30 ft (L) x 15 ft (W) x 10 ft (H). There is a concrete divider wall running lengthwise in the HUT for a distance of about 25 ft, one end of which is attached to the end of the HUT. During . . - - - - - - - -
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normra reactor operations, the coolant enters the HUT on one side of the -) wall and exits the HUT on the other side of the wall. Total travel time in > the HUT is about ten minutes. This delay time allows the N-16 in the-coolant to decay prior to the coolant leaving the HUT. Upon leaving the l-HUT, the coolant is pumped through a heat exchanger and then returns to the pool. During operations, the normal HUT level is between 3 and 7 ft and the HUT is kept in a slight vacuum by drawing air through the vent line. The HUT level is recorded once per day. A tygon tube attached to the HUT is used to measure level. Elevation markings are located next to the tygon tube and the readings are estimated to the nearest inch.
L After the identification of the leaks in the gamma pit, the licensee began a series of tests on February 10 and 11,1990, to determine if other pool system components also had leaks. The primary means of testing involved raising the water level in the pool, transfer canal and hold up tank, isolating the transfer canal and measuring any changes in the water level !- over time. Additionally, the licensee increased surveillance of radioactivity.
L and flow rates in the various storm drain systems.
l A pool, canal and gamma pit water loss rate test had been performed from December 22-29,1989. Based on level changes and the amount of make-up water added to the system, it was determined that a total of 12 gph (.2 gpm) of water was being lost. Analysis indicated that the loss was due to evaporation from the pool system surfaces, $ During the February 10-11 tests, the hold up tank, which is at a lower > - elevation than the pool, was filled to a level even with the top of the , pool. This was done by allowing the HUT water to enter the HUT vent i ' line, which rises above the pool. The pool and HUT were in communication with each other via the normally open core exit butterfly valve and connecting piping. The transfer canal was isolated from the reactor pool. The gamma pit was drained at the time. From pool level [ l.
measurements, it was determined that a 344 gph (5.7 gpm) leak existed either in the pool, HUT, or connecting piping. The HUT was then ' isolated from the pool by closing the butterfly valve and the HUT was pumped down to an elevation of seven feet. It was noted that the pool and HUT level then remained constant. The licensee concluded that a leak existed in the HUT above the 7-foot elevation. The licensee estimated that about 4000 gallons of water were lost durirg the test.
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L-;w . " i . No increase in storm drain flow nor radioactivity was detected. The , licensee then inspected and sampled all accessible areas surrounding the HUT. On February 13, the licensee drilled through the external wall of - - the pump room near the floor adjacent to the HUT. A large quantity of contaminated water was found behind the wall. The licensee began ' pumping this water to onsite tanks for processing. Although about 4000 gallons of water were estimated to have leaked from the HUT during the i February 10-11 tests, the licensee had pumped nearly 50,000 gallons from this area 'as of February 26. This corresponds with the dilution of leaked. water by outside surface and ground water as determined by tritium ' measurements of both pool water and recovered water on February 13, 1990.. Those samples had indicated about a factor of 7 dilution, Inspection of the HUT by the licensee revealed several areas of possible e ._ leakage. (See also Sections 4.2 and 4.3) 3.2.6. NRC Concerns 'Because of the generally similar construction of the HUT, gamma pit and transfer canal, and the several identified leaks and suspect areas, the NRC , expressed concern that other leaks or weak areas may exist in these structures. Concern was also expressed that one or more of these structures may not be structurally sound to ensure their integrity during continued operation. Even though the licensee had voluntarily shut the reactor down at about 1500 hr on February 9, the NRC was concerned g about the potential risks to the public from uncontrolled releases of radioactively contaminated materials from the facility. As a result, the NRC issued an Order Modifying License on February 13,1990 (Attachment 5). The Order in effect requires that the reactor remain.
shutdown until the licensee submits a plan to the NRC indicating how it will identify all leaks, fix them and develop a system to ensure the rapid < identification and correction of any future leaks.
The licensee initiated a search for qualified vendors to test the entire surface area of the gamma pit, transfer canal and hold up tank using sophisticated ultrasonic tests. The licensee also employed Construction Testing Laboratories, Inc. to perform analyses of the concrete structures and concrete cores taken from these structures to determine the failure mechanism (s) of these structures, ascertain the material properties of the concrete, determine the structural soundness of the pool system and
! recommend corrective actions. As of February 26,1990, the ultrasonic L testing of the HUT was completed, and testing of the gamma pit was to be finished that day. The transfer canal had yet to be started, as had the
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concrete core sampling and analyses. (See Sections 4.0,4.1 and 4.2 for more details relative to the testing and examination of the gamma pit and HUT through February 16, 1990).
4.0 Inspection-Activities in the Gamma Pit and HUT During the team inspection from February 9 through 16,1990, subsequent to the , identification of the leaks and suspect areas in the gamma pit and HUT, the inspectors ' closely followed the licensee's actions relative to identification and repair of unsound , and suspect concrete.
4.1 The Gamma Pit The initial leak site in the gamma pit was located on the north wall inside the pit, about 20 feet from the face of the gate that connects the gamma pit with the transfer canal and about 5 inches above the shelf at the bottom of the pit.
Drawings indicate that concrete for this north wall may have been poured against the bedrock. According to the drawings, the wall is one foot thick and has two layers of vertical and horizontal rebar. The wall thickness and rebar arrangement are typical for each side of the gamma pit.
The repairs for the north wall were initiated on Monday, February 12,1990.
This repair work was donc by an outside contractor (Structural Preservation Systems, Inc.). The inspector reviewed the characteristics of the materials used in the repair. The procedures used were also observed and repairs were monitored.
4.1.1 - Mortar Activity The material used for patching the cavity was polymer-modified portland cement, screed mortar called Sika Top 111. This two-component, fast-setting, free flow mortar selflevels and moves easily into hard to-get-at places with little, if any, tooling. The screed mortar Sika Top 111 has several advantages, such as superior abrasion resistance, over conventional portland cement mortar; its bond strength ensures superior adhesion, increased resistance to deicing salts, high early strengths, good freeze and thaw' resistance; and is not flammable.
The inspector also reviewed the strength characteristics data for this material as a function of curing time, including the compressive, flexural, splitting tensile and bond strength, and found these characteristics adequate for this particular application. Procedures reviewed and observed by the inspector for installation included surface preparation,
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mortar mixing and application, finish and curing. All these activities were done in accordance with written procedures from Sika Corporation, the supplier of the screed mortar.
4.1.2. Grouting Activity In addition to the mortar, chemical grout Scotch seal 5610 (Gel) was used - to fill and tightly seal internal cracks with an impermeable, tough flexible mass. It also fills and seals any existing void spaces in and behind a leaking structure. Chemical Grout 5610 penetrates and consolidates the mortar as well as the existing concrete around the cavity in question. This grout is a low viscosity liquid which reacts with water (still or active) in a predictable, controlled manner to form expansive, resilient, adhesive solids in density and strengths appropriate to this task.
Grout 5610 is injected under pressure into a leaking structure to form a water barrier, or can be mixed with contaminated water or toxic water to form a permanent encapsulating solid. Based on its properties and intended application, the inspector determined that Grout 5610 was suitable for the task. Grout 5610's preparation was done in accordance with the product supplier's recommendations.
To effect the repair of the identified hole in the gamma pit, the Grout 5610 was applied through pre-drilled holes on both sides of the cavity already filled with mortar. The Grout 5610 was pumped under 100 psi pressure, in accordance with the manufacturer's recommendation. The ~ inspector found the grout installation acceptable. - Nevertheless, during_the - pumping of the grout, some of the grout resurfaced at other locations, along the north wall of the gamma pit, giving the indication that honeycomb and internal crevices existed in this reinforced concrete wall.
This incident triggered new NRC concerns about the leak barrier and structural integrity of the gamma pit. The inspector expressed this concern to the licensee who agreed to perform nondestructive examination. of the gamma pit and the other concrete structures of similar construction, including the hold-up tank and transfer canal.
4.1.3 Nondestructive Examination of Concrete Structures-The licensee contracted a concrete nondestructive testing and evaluation company, Olson Wright NDT&E, Inc., to perform impact echo (IE) testing for evaluation of the gamma pit and other structures in question.
Flaws such as voids, honeycombing, cracking and delamination can be detected by this technique.
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The IE test involves impacting the concrete at a point on the exposed surface of the wall. A surface receiver measures the vibration displacement of the concrete to the impact. - A signal analyzer performs fast Fourier transforms operations on the time domain signal from the receiver and produces a plot of displacement versus frequency. Analysis of this plot provides information on the condition of the concrete immediately beneath the point tested. An area of flawed concrete can generally be identified immediately.
The inspector observed preliminary activities and some of the actual testing. At the time of the completion of the inspection, the licensee had collected preliminary results from ten pre-selected sample surfaces. The results indicated that concrete at these points displayed a honeycomb texture and structural weaknesses. Tests will be conducted throughout the gamma pit on a one foot square grid basis. For this task, extensive surface _ preparations had to be made. In addition to this nondestructive testing (NDT) technique, destructive tests will be conducted on concrete cores to correlate the NDT results for further evaluation of the present condition of the gamma pit and other associated concrete structures of similar construction. Construction Technology Laboratories, Inc. of Skokie, Illinois was seleued to perform these tests.
Based on preliminary review of the NDT techniques, the inspector concluded that the IE testing can be a valuable supplement to aid the licensee in evaluating the soundness of the concrete structures.
4.2 The Hold-up Tank (HUT) Following the identification of the leak from the HUT, the tank was drained.
Along with licensee personnel, the inspector entered the drained HUT on February 15,1990. The internal walls and ceilings were coated with at least two layers of different colored paints in various stages of cracking and peeling. An HP technician pointed out several locations on one wall that had been previously patched with grout material in 1987. The repaired areas were about 3-4 ft above the floor and covered about 3 square feet of wall surface. - At three locations where the paint had peeled from the wall the inspector was able to gouge away the concrete with his gloved fingers. The concrete crumbled from the wall. In several areas, pits about three inches in diameter and about 1/2 ' inch deep were seen about three feet above the floor.
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4.3 Previous Inspection Activities The licensee reported entering the HUT at least annually since 1987 to perform visual inspections. Tests similar to those done on February 11-12, 1990, had also been performed to check for inventory loss. The licensee did not use a formalized, written procedure to perform these tests; however, the test data were recorded. The Manager, Nuclear Operations stated that a test procedure was not required since making major water level changes is allowed per the licensee's , Regulations Manual (RM) - 05, Reactor Shutdown. Senior Operators are1 allowed by procedure to direct major water level changes. The inspector verified that RM-05 kilowed this operation. The inspector indicated to the Manager, Nuclear Operations and the Nuclear Safeguards Committee (NSC) Chairman that a written test procedure, reviewed by the NSC for 10 CFR 50.59 applicability, may prevent operating errors, and would provide a means of repeating the test under the same conditions.
The inspector reviewed Technical Specifications, Final Hazards Summary Report (November 1960), and NUREG 1059, Safety Evaluation Report for Renewal of License, to determine if the licensee was in compliance with leak detection requirements. The inspector.was unab!e to locate any requirements with regards to primary system leakage detection (requirements exist for maintaining a-specified reactor pool level). Currently, operators use changes in HUT level and the amount of makeup water added to the pool as an indication of a large inventory loss. A small or slow loss of inventory would not be readily detectable by this method.
5.0 Contamination in Storm Drain S-5 In a letter to the NRC dated December 14,1989, the licensee described contamination of storm drain S-5 and efforts to find the source of this contamination. In subsequent correspondence to the NRC, the licensee described the sampling at upstream sample point S-4, a manhole in the parking lot; the use of a deionizer on the effluent of the drain and results achieved; the identification of leaks in the underground hot cell exhaust duct between the hot cells and the polishing filter bank; and apparent success in minimizing additional contamination of the S-5 storm drain system. The licensee suspected that some hot cell exhaust was able to bypass the main filter bank because of leakage in the underground exhaust ducts both upstream and downstream of the filter bank.
A portion of the underground ductwork apparently rests on bedrock and appears s to leak into a cavity which communicated across the pressure drop of the main filter bed, providing the bypass pathway. The licensee opened the underground cavity to atmospheric pressure upstream and downstream of the main filter bank and repaired visible defects in the ventilation ducts. With the cavity pressure _ _ - _ - _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ . _ _ _ _ _ _ _ _
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' -increased to atmospheric, any additional leakage should result in outside air being drawn into the duct, rather than exhaust air drawn out and past the filters.
The licensee hypothesized that the hot cell exhaust air bypassing the filters contacted water in the cavity and resulted in the contamination seen at S-4 and S-5.
v Subsequent to the opening of the duct cavity to atmospheric pressure, the levels of ' contamination have fallen steadily. During this inspection the inspector reviewed the radioanalytical data from S-4. The inspector noted that the activity of I-131 increased with an increase of the water flow rate until January 27,1990. Subsequent to that date,_ there appeared to be no relationship between the I-131 activity and the flow rate. : The inspector was informed by licensee representatives that the ventilation duct leaks were repaired about January 27, at which time the cavity had been opened to atmospheric
pressure. As a result of these observations, the inspector requested the licensee to > perform a statistical analysis using the linear regression method to examine any
relationship between the I-131 activity and the flow rates before and after January 27, 1990< The relationship between I 131 activity and the flow rate before repair of the duct was about four times higher than that observed after the repair.
The decrease in_ the contamination levels at S-4 since January 27,1990, appeared to follow that based on radioactive decay of I-131. Continuation of this pattern would i indicate that no additional contamination'is entering this ground water transport system.
As of February 26,1990, the I-131 concentration at S-4 was less than 1 E-6 uCi/ml; down from as high as 6 E-4 uCi/ml on January 26,1990. As noted earlier (Section -< 3.2.4), the MPCw for I-131 is 3 E-7 uCi/ml. As also described in the same section, water from S-4 was being processed through a deionizer before release to the holding pond.
5.1 Ventilation System Filtration Section 3.2.2 of Part 1 of the application for the SNM-639 license requires that the iodine collection efficiency of the charcoal beds be determined quarterly and L that the minimum collection efficiency of the system be 99.5%. While the p licensee performed the filter efficiency determination more frequently than L required (monthly vs. quarterly), if exhaust gases bypassed the filter bank as discussed in Section 5.0, the results of the iodine collection efficiency tests would not be valid. The inspector noted~that the method of determination of the
l: iodine collection efficiency for the charcoal beds was identified as an unresolved item during an inspection conducted October 23-27,1989 (70-687/89-80-13). The L circumstances of the filter bypass and impact on filter collection efficiency will be L considered as part of that unresolved item (70-687/90-80-02).
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5.2 lancer Rance Corrective Actions During the inspection on February 14,1990, the licensee and a representative of Burns and Roe discussed the licensee's plans and conceptual drawings for
replacement of the underground exhaust duct from the hot cells to the main
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filter bank. The licensee stated that the construction drawings would be q completed within about two weeks and submitted to the NRC and New York State. Because of the change to the facility design, both the NRC and New York State must approve the modification. The licensee indicated that the construction effort would likely take about a month. The proposed modification would prevent the hot cell exhaust from having any possible contact with water upstream of the main filter bank. Discussions included consideration of duct size and shielding, connection with the hot cells and severance of current connections with the old duct, seismic and support considerations, individual hot cell flow control, and appropriate _ instrumentation ports for measuring various parameters.
, The licensee stated that comments received would be considered in the
construction drawings.
. 6.0 Confirmatory Measurements As discussed in Section 3.2.4, the NRC: Region I Mobile Radiological Measurements Laboratory responded to the site on February 9,1990, to perform independent assessments of radiological samples, assist the licensee in making analyses and'to confirm the licensee's capability for making accurate measurements. The inspector also reviewed the licensee's analytical facilities and equipment.
, Through discussions with the licensee and observations by the inspector, it was
determined that the licensee analyzes environmental samples using four germanium detectors, interfaced with a computer-based multichannel analyzer, located in the environmental counting laboratory. The licensee had calibrated the four detectors for a 250 ml polyethylene bottle counting geometry. Due to this counting geometry, the licensee needed to count the samples for a relatively long count time (approximately three hours) in order to achieve the required detection limits.
' t The inspector discussed with the licensee the possibility of improving the detection limit, thereby reducing the required counting time, through the use of Marinelli beakers designed to fit directly ever the detectors. This modification would allow the licensee to achieve similar detection capabilities in about 1/5 of the counting time. The licensee-informed the inspector that a NIST (National Institute of Standards and Technology) traceable standard in a one liter Marinelli beaker had been recently purchased, however, due to time constraints they had not been able to calibrate their detectors for this geometry. As a result, on February 10 and 11, the inspector assisted the licensee by analyzing samples for trending purposes while the licensee took the needed time to m . - - m -. . -m.
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U calibrate the detectors for a one-liter Marinelli beaker counting geometry. Once the . licensee had calibrated the detectors for this geometry, and could analyze samples at a much faster rate, the NRC once again compared analyses of samples in order to verify the licensee's capability to measure radioactivity using the new geometry. The results of . these sample measurement comparisons indicated that all measurements were in - agreement (for all four detectors) in accordance with the criteria for comparing results.
l , ! (See Attachment 6. The results of the comparisons are listed in Table I of Attachment ' 6 and the criteria are provided as Attachment 1 to Table 1).
. , - 7.0 Hydrogeological Studies During this inspection, the NRC reviewed the scope and' nature of the licensee's hydrogeological studies to characterize the site. This portion of the inspection is described in Attachment 7 to this report and will not be repeated here. This portion of the inspection included a site tour; tour of the reactor and hot cell facilities; meetings with the licensee and licensee's consultants and with New York DEC representatives; review of the licensee's hydrogeological investigation work plan; and the qualifications of the licensee's consultants. The conclusions based on this inspection and the current knowledge of the situation on site are: 1) that the hydrogeological investigation work plan is reasonable and should produce sufficient basis data on the aquifer characteristics, flow and direction and water quality to assess the potential for offsite releases of contaminated groundwater related to contamination at S-3 and S-4; 2) the-licensee's consultant hydrogeologists are knowledgeable and well prepared to conduct L the investigation; and 3) the investigation activities are in accordance with the work plan and following written procedures.
On February 26,1990, during the site inspection, the licensee _ stated that the planned _ monitoring wells had been completed. The licensee further indicated that because their hydrogeological consultant believes there are two layers of water flow from the hill near .; Building 2 (one deep and one shallow), one additional shallow well will be installed adjacent to the northern-most w:ll, MW2, on the hill.
The licensee also reported on February 26 that the excavation in the roadway in front of Building 2 in accordance with the licensee's commitment had not yet been completed u because of the cold weather and other schedule conflicts. The licensee expected this to be completed by March 9,1990. (See Attachment 7, p. ATT 7-5 for details).
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8.0 Licensee Organization and Management Thr. inspector reviewed the licensee's organization and management for responding to the ventilation system and reactor pool system contamination events. The review included a determination of the level of management involvement and the amount of effort devoted to the identifiution and resolution of the sources of contamination.
Through discussions with the licensee and consultants, the inspector determined that the licensee had the commitments of the company president and that aggressive actions were being directed by the Plant Manager and the Vice President for Operations, Medi.
Physics. The latter had been on site several days a week since January 2,1990 and essentially full time since January 15,1990. The Manager, Engineering and Manager, Health, Safety and Environmental Affairs were fully involved with the Plant Manager in carrying out identification, mitigation and corrective actions. Subordinate managers were assigned to ensure normal plant activities did not suffer from the diversion of management activities to the recent events. The licensee stated that only engineering related to new activities would be delayed.
The inspector determined that licensee management was providing appropriate direction and oversight to the identifled leakage problems, has been responsive to NRC concerns, and has undertaken a broad approach to upgrading facilities and equipment. The inspector had no further questions in this area at this time.
The licensee has brought in consultants and corporate support to complement and supplement the plant staff. Subsequent to the leaks on February 9,1990, the licensee, through industry contacts, aggressively pursued qualified vendors who could perform expert evaluations of the reactor pool systems and to provide recommendations for permanent repairs.
9.0 Exit interview On February 15,1990, the inspector discussed with the licensee representatives identified in Section 1.0, the scope and findings of the inspection. The licensee acknowledged the findings and stated their commitment to respond to all actions as required by the NRC Order dated February 13,1990.
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Figure 2 , SIMPLIFIED DIAGRAM OF THE REACTOR POOL SYSTEMS i i
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. . ATTACHMENT 2 =, .w , -. t ' , ! ! Sequence of Events * for Pool System Leakage , ' Time Line of Events Date Time Comments 2/8/90 Heavy rains at times during 2/8/90 0610 hr Reactor shutdown ! 0700 Pumping water to storage tank 0739 Stopped pumping water to storage tank 0750 Bringing water back to pool, stall and canal 0830 Pool level returned to normal 1030 Cooling tower basin drained . 1145 Cooling tower basin cleaned; start refilling basin 1500 Gamma pit cleaned
1815 Pumping hold-up tank to pool 1815 Returning water from storage tank; gamma pit gate open 1816 Cooling tower basin filled 1855 Pool level and primary water system returned to normal 2033 Reactor critical 2/9/90 0030 Sampled water in S-12; analytical results reported 0859 0900 Stopped releases from holding pond; set up to pump to storage tanks 0906 ' Sampled water in S-3; analytical results reported 1536 1000 Began pumping S-3 to storage tanks 1100 Began pumping from holding p;od to storage tanks 1220 NRCnotifiedofproblem(NYDECcalled,leftmessage) 1300 Inspected water storage tank 1506 Voluntary shutdan of reactor d 1530 Told NYDEC of problem 1700 Chem Nuclear water deionizing system started up 1940 Shut down waste evaporator; cooling line drained , 2000 NRC arrived on site 2030 Orange County (NY) Health arrived on site 2037 Pool, canal, & gamma pit at normal water level 2050 Equalized pool water level with hold-up tank (HUT) 2055 Gamma pit test 2120 Pool, canal, & gamma pit water level lowered to 6-foot level in canal 2130 S-3 flow rate 3.0 gallons / minute 2130 NRC Mobile Radiological Measurements Laboratory on site 2208 Pool, canal, & gamma pit water level lowered to 4-foot level in canal 2208 Equalized pool water level with hold-up tank
2239 S-3 flow rate 2,2 gallons / minute
- Most of the events and times were provided by Cintichem, with the terminology generally taken from Cintichem logs of activities.
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2/10/90 0100 hr Pumping from gama pit to pool 0215 Hold-up tank at six feet 0400 Gamma pit water level at upper gama pit shelf (12 feet down) ' 0430 S-3 flow rate at 0.35 gallons / minute 0500 Moderately heavy rain , 0520 S-3 flow rate at 5.5 gallons / minute 0520 S-3 flow test aborted because of rain dilution 0615 Visual inspection of gamma pit 0730 Hold-up tank steady at 6 feet; further tests delayed i because of rain 1100 Ordered backup vessel from Chem Nuclear
1115 Started pumping pond to 001 discharge 1400 Repaired leak in holding pond 1545 Met with NRC and NY DEC, and told them the gamma pit was leaking 2/11/90 1000 Diverted S-3 to North 10K tank 1000 SPS inspected gamma pit 1140 Commencing pool and hold-up tank leak check 1234 Leak test start for third time (first 2 aborted) 1300 Emptied holding pond and covered bottom with bentonite 1530 Aborted leak test - air purge on 1630 Leak test started for fourth time 1855 Butterfly valve closed 1900 Leaks around grouted area of hold-up tank stopped 2048 Open butterfly-valvo - (1500 gpm to 0 gpm) 2120 Stopped test 2335 Leak test started for fifth time 2/12/90 0005 Pool equalized with HUT , 0520 Stopped test 0530 7 feet of water in HUT 0530 Leak test started; butterfly valve closed-0900 NSC meeting on grouting 1230 Hold-up tank level still 7 feet; storage tank pressure gauge 20.5 feet 1245 Began grouting in gamma pit 1338 Level and pressure same as at 1230; water pumped out of hold-up tank 1400 Set up pillow tank 1500 Marinelli beaker counting geometry use began at Environmental Lab 1500 Pumping hold-up tank water to pool 1600 Pool level higher than canal after pumping 1845 Equalized pool and canal levels 1900 Inspection of hold-up tank , 2230 Water returned from storage tank line to hold-up tank 2/13/90 0840 NYD0L on site 0845 Announced leak in hold-up tank 1022 Sample water in boiler house and Bldg 4 service pits 1550 Drilled hole outside of hold-up tank 1600 Sent samples to Roche for tritium analysis 1641 Received Order " preventing startup" from NRC
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2/14/90 0900 hr NOT testing firm arrived 1000 Pumping Bldg 5 service pit to mall tank r 1515 Pumping pump room wall water to storage tank 1930 Open meeting with NRC and Tuxedo Town Board ! 2/15/90 1000 NRC exit meeting ' 1130 Met with NRC re: the filter bank 1545 Called CTL structural consulting firm ^ 1600 Met NOT. group to discuss results of inspection g' 1700-Installed sump pump at pool end of canal and began pumping back to canal 2000 Began NOT testing 2/20/90 1830 NRC learns of discharges to reservoir on 2/9/90 e 2/23/90 NRC issues CAL on sampling, analyses, discharges and ~ notification 2/24/90 0100 Cintichem notifies NRC of implementation of CAL , and provisions on radioactivity in holding pond and 0447 pumping to 001 y . ! ,. - _ _ ... - - -
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. S-2 Left Drain at 002 Outfall $ S;3 Storm Drain Outfall at Visitors Parking tot , $ 5-4 Building 3 Storm Drain Catch Basin e S-5 Building 3 Storm Drain Outfall fi S-6 Runoff Stream, 20 ft from Indian Kill Reservoir ~ S-7 Building 4/ Cooling Tower Storm Drain Outfall k ' .. . 5-12 Holding Pond Inside Cem S-13 Raw Mater from Mater Corepany Pumning Station s /,- , - ' ' y
p , I ATTACHMENT 6 e . ,- ! I - ' . Table 1
Cintichem Verification Test Results l SAMPLE ISOTOPE NRC VALUE QCENSRR VALUE COMPARISON j , Resul s in Microcuries Per Milliliter t i S4 I131 (5.32:0.10) E-6 (5.9t2.14%) E-6 Agreement 2/14S0 0950 hrs Detector #1 ' S3 I131 (3.2:0.4) E-7 (3.2i30%) E-7 Agreement 2/14/90 t 0950 hrs Detector #2 Pump I131 (1.13t0.06) E-6 (1.15*13%) E-6 Agreement Room, South j Wall, End of IlUT 2/13/90 1550 hrs Detector #3 ' S4 1131 (7.0040.11) E-6 (7.38t2%) E-6 Agreement 2/14/90 1515 hrs Detector #4 , The NRC results are reported with a one standard deviation uncertainty and the licensee , results are reported with a two standard deviation uncertainty.
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. A'ITACHMENT 1 to TABLE I
CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS This attachment provides criteria for comparing results of capability tests and , verification measurements. The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this program.
In these criteria, the judgement limits are variable in relation to the comparison of the NRC Reference Laboratory's value to its associated uncertainty. As that ratio, referred to in this program as " Resolution", increases the acceptability of a licensee's measurement should be more selective. Conversely, poorer agreement must be considered acceptable as the resolution decreases.
Resolution 1 Ratio For Agreement: P <3 No Comparison
0.5 - 2.0 8 - 15 0.6 1.66 16 50 0.75 1.33 51 - 200 0.80 1.25 > 200 0.85 1.18 1 Resolution = (NRC Reference Value/ Reference Value Uncertainty) 2 Ratio = (Licensee Value/NRC Reference Value) !
. , l " ' ATTACHMENT 7 , ' e , . HYDROGEOLOGIC INSPECTION AT CINTICHEM F. W. Ross, Hydrologist i Nuclear Material Safety and Safeguards
Backaround During the period of February 12-15, 1990, I participated in an , ' NRC Region I inspection of Cintichem, Inc., Tuxedo, New York.
The inspection was prompted by reported radiological contamination measured in storm water runoff from sampling point S-4 on January 2, 1990, and the January 12, 1990 New York State Department of Environmental Conservation (NYDEC) order for site hydrogeologic characterization that was issued in response to this contamination (Appendix A).
The contamination measured at S-4 is suspected to have emanated from the contact of groundwater , with soil contaminated by air leaks in underground portions of the hot cell ventilation system in Building 2.
The weekend prior to the inspection, radiological contamination was also found in storm water runoff sampled at location S-3.
This contamination is attributed to water leaks from the gamma pit, based on similar gamma pit and discharge water isotopic signatures, a higher than normal discharge water temperature, and an apparent relationship between a decline in surface water discharge with reductions in t gamma pit water levels.
The contamination consisted of fission products such as iodine-131 and other short half-life gamma
emitting radionuclides.
My inspection activities were directed at evaluating the hydrogeologic investigation already under way at the Cintichem site.
, My evaluation considered: 1) whether the hydrogeologic
investigation is likely to provide basic hydrogeologic data sufficient to determine the potential for offsite radiological contaminant migration in groundwater from sources such as the hold-up tank, gamma pit, and hot cell ventilation system; and 2) whether Cintichem's hydrogeologic investigation work plan satisfies the NYDEC January 12, 1990 order for site groundwater characterization.
The hydrogeologic inspection consisted of the ' following activities: 1) a site walkover; 2) tour of the reactor and hot cell buildings; 3) meetings with Cintichem personnel, hydrogeologic and environmental consultants to cintichem Inc, and representatives of the NYDEC; and 4) review of Cintichem's hydrogeologic investigation work plan and credentials of their hydrogeologic consultants.
Site Walkover I conducted a site walkover to become acquainted with the site, and the monitoring and emergency activities being conducted on site.
During the walkover, I observed the relationships among the terrain, site buildings, surface drainage features and the Indian Kill Reservoir.
I observed and photographed well drilling activities, storm runoff monitoring locations, the hot cell ventilation duct, rock outcrops, swampy areas below the site and the storm runoff holding lagoon, Indian Kill Reservoir, and , ' - - - - . . . .
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l . ATT 7 -2 Indian Kill Creek and the SPDES discharge outlet to the creek.
I observed that the facility was constructed on the steep eastern slope of Hogback Mountain, and rests in part upon a rocky rubble ' backfill accumulated during construction blasting of the bedrock.
The hold-up tank, reactor pool, transfer canal, and gamma pit t (Buildings 1 and 2) are built in niches and holes cut into the bed rock.
The bedrock consists of fractured Pre-Cambrian granite gneiss.
As of the conclusion of the inspection, three of six wells scheduled to be drilled into the rubble were completed (MW . 5, 7 & 8).
Two additional wells (MW 1 and 2) are planned for
completion into bedrock (Figure 1).
Reactor and Hot Cell Buildina Tour ! On the morning of February 14, I was given a tour of the reactor
building (Building 1) and hot cells (Building 2).
I observed the l work underway to analyze and repair the leaky concrete that forms i the gamma pit and hold-up tank walls.
In the hot cell building, ' I observed the floor excavations in the vicinity of the underground portions of the hot cell ventilation system.
The excavations were created on either side of the air filter bank to ' equalize air pressure beneath the building between the ventilation ducts and surrounding rock rubble.
Thus, contaminated air is mostly prevented from exiting the duct work ' and bypassing the filter bank through cavities in the backfill.
Although the top of the soil beneath the building appeared to be dry, Cintichem personnel believe that water contacting soil contaminated in this fashion resulted in the iodine-131 concentrations detected in storm water runoff from sampling point , S-4.
Cintichen Inc. is presently considering designs for ' i l replacing underground portions of the current hot cell - ventilation system with overhead ventilation.
Review of Site Hydroceoloaic Investication Work Plan , I reviewed the Hydrogeologic Investigation Work Plan for the Cintichem site prepared by Leggette, Brashears and Graham, Inc.
(LB&G), hydrogeologic consultants to cintichem, Inc.
The work plan was developed in response to the January 12, 1990 NYDEC order requiring Cintichem, Inc. to take subsurface borings sufficient to define groundwater flow and the extent of groundwater contamination related to the iodine-131 l concentrations found in surface water samples collected from I monitoring point S-4 on January 2, 1990.
The work plan is l designed to provide a preliminary characterization of groundwater l flow at the site and to delineate the extent of iodine-131 and . associated radioisotopes in groundwater in the vicinity of ' Building 2 and downgradient areas.
The plan is also designed to evaluate the potential of offsite contaminant migration.
Results of the investigation will be used to determine if subsequent investigations and/or remedial actions are necessary.
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. . _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ .. ' ! .- l , ATT 7-3 + The work plan calls for construction of eight monitor wells, six completed into the saturated portions of unconsolidated rubble material and two that will penetrate saturated portions of the underlying fractured crystalline bedrock.
Split-spoon samples of unconsolidated rock and soil materials are to be collected at , ' five-foot intervals.
However, during the inspection, I learned that wells drilled so far have encountered mostly bedrock rubble
material that is impossible to collect by the split spoon
technique.
Groundwater samples are being collected during well development and one round of samples will be collected from each monitor well within 3 to 5 days after development.
Two , subsequent rounds of samples will be collected at two-day intervals following the initial round.
Aquifer characteristics ' will be evaluated at each well using rising head and falling head slug test methodologies.
A licensed surveyor will be contracted to determine the locations and elevations of completed monitor ' wells and related features, and the surveyor will complete an accurate base map of the site.
At the conclusion of the ' investigation, LB&G will prepare a summary report to include monitor well boring logs, well completion drawings, site plans with groundwater elevations, computations of groundwater flow direction and rate, and soil and groundwater quality data. The report will summarize the hydrogeologic conditions encountered at , the facility as well as the impact on the subsurface environment resulting from leakage of radioisotopes from the facility.
The lateral and vertical extent of encountered subsurface materials l will be mapped.
Air photos will be evaluated and possible ' environmental impacts as well as petential receptors will be identified.
Based on data provided by the current investigation, the report will make recommendations for additional study.
Sample analyses will be coordinated by Cintichem and follow Cintichem's QA/QC program for radiological environmental monitoring.
LB&G anticipates five weeks to complete the proposed work, however, well drilling through the rubble has been somewhat more difficult than anticipated and some delay in completing the investigation is expected.
I conclude that, given current knowledge of the situation at Cintichem, Inc., the hydrogeologic investigation work plan is reasonable.
This conclusion is based on my review of the work plan, discussions with the LB&G project manager and field supervisor, and the NYDEC hydrogeologist, who indicated that the hydrogeologic investigation work plan appears to fulfill the requirements imposed on Cintichem by the January 12, 1990 NYDEC order (see Hydrogeology Meeting below).
Because the work plan was conceived to address only the radiological contamination observed at sampling point S-4, it will not provide " complete" hydrogeologic characterization of the site.
However, it is likely to produce sufficient basic hydrogeologic data on aquifer characteristics (hydraulic conductivity and specific storage), flow magnitude and direction, and water quality to assess the .. -. ..
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i i . ATT 7-4 ' potentici for off-site releases of radiologically contaminated groundwater related to the contamination at S-3 as well as S-4.
The work plan does include specific detailed procedures for well installation, groundwater sampling, conducting slug tests, and the environmental radiological monitoring.
In addition, adequate health and safety practices and procedures are described.
j Review of Hydroceolocist's Credentials i I reviewed the credentials of the hydrogeologists conducting the i groundwater investigation at the site.
This information is provided in cintichem's January 22, 1990 submittal to the NRC.
The principal investigators are employed by Leggette, Brashears and Graham, Inc., a nationally known groundwater consulting firm with several offices located throughout the country.
The project manager for the investigation is Mr. Frank Getchell.
Mr.
Getchell has a Bachelor of Science in mathematics from the University.of Scranton and a Master of Science in geology from Syracuse University.
Mr. Getchell has also completed a number of j advanced continuing education courses in hydrogeology and related subjects.
He is a certified professional geologist with the American Institute of Professional Geologists and is licensed in - the State of North Carolina.
Mr. Getchell has ten years demonstrated experience in hydrognology and has worked on more than twenty projects throughout the Northeast.
l l Supervision of field activities is being provided by Mr. David Terry.
Mr. Terry has a Bachelor of Science in geology from Syracuse University and a Master of Arts in geological sciences from the SUNY at Binghamton, New York.
Mr. Terry is a licensed geologist in the state of North Carolina and has more than eight years demonstrated experience in geology and hydrogeology.
Based on my review of the hydrogeologist's credentials and from on site discussions with the investigators, I conclude that the hydrogeologists are knowledgeable and well prepared to conduct the site hydrogeologic investigation.
l Hydroceoloav Meetina At 2:00 PM February 14, 1990, I held a meeting with the NYDEC hydrogeologist, and representatives of Cintichem, Inc. and their hydrogeologic and environmental consultants.
The purpose of the meeting was to discuss the adequacy of the hydrogeologic investigation with respect to NRC regulatory concerns and the i January 12, 1990 NYDEC order.
Based on current understanding of l the radiological contamination problem, the NYDEC hydrogeologist ! and I agreed that the hydrogeologic investigation, including the additional excavation discussed below, is adequate as planned and ' i _ _
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ATT 7 -5 should continue to focus on circumstances surrounding the contamination observed at S-4.
The investigation need not be
expanded in response to the more recent radiological releases observed at S-3, however, additional well drilling was not ruled , out should data generated from the current investigation suggest ' that more drilling is necessary.
The hydrogeologists from LB&G, Inc. stated that reasonable evidence exists (e.g., groundwater mounding at southwest corner of Building 3) to suggest that the radiological contamination i observed at S-4 traveled principally through building foundation drains and storm runoff system feeding S-4 and not directly through the. groundwater flow system.
They suggested that ' contaminated water may have collected in old foundation drains underlying the hot cell building (Building 2) and intercepted a ] buried water line running between the hot cell building and , ! Building 3.
From there, the contaminated water may have entered foundation drains feeding the storm runoff system monitored at S-4.
LB&G recommended that a portion of the roadway in front of Building 2 be excavated at the confluence of the old building foundation drains and the buried water line.
Stand pipes could ) then be installed to measure water levels and take water samples ' during storm runoff events.
The state hydrogeologist and I strongly recommended to Cintichem that'this work be undertaken as soon as possible.
Cintichem officials recognized the worthiness of this endeavor, but expressed concern that excavating upper portions of roadway while the well drilling and water control activities are occurring on the lower roadway would seriously disrupt important facility shipping operations.
Cintichem stated that they would consider how to schedule this activity to meet our concerns and minimize further disruption of the facility, and would provide an answer at the inspection closeout meeting.
At the closecut meeting, Cintichem committed to begin work on roadway excavation by Monday or Tuesday of the week of February 19, 1990.
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ATTACHMENT 7 , APPENDIX A .* e New York State Department of Environmental Conservation to WeH Road, Mbany. New York 12238 i ... Thames C. Jorane
Commissioner , January 12, 1990 . i ! ' . . ' Mr. James J. McGovern . l Cintichen, Incorporated ' P.O. sex 816 i Tuxedo, New York 10947 I ' > Dear Mr. McGovernt Circumstances at the Cintichen f acility that have recen'tly l been brought more clearly to light give rise to serious concern by - While the initiation of enforcenent action is . the purpose of this letter is to confira l this Department.
under consideration, recent, telephone conversations between my staf f and representatives of Cintichem in which the circumstances requiring ! the identified remedial action have been brought to Cintichen' sin part, by t The context of these concerns is defined, l 6 NYCRR Part 360 and the September it, 1976 Consent order, DEC attention.
i ' l 43-0335.
I on January 2, 1990, the Department collected surface. water samples at the facility near the areas marked 8-1 and 3-4 on the . ' The analyses of the samples conducted by the New . York State Department of Nealth indicate that the enclosed map.
i tion
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.the maximum permissible concentration pursuant to 4 NYCAR 5ec Monitoring points 5-1 and 3-4 are located up-gradient and
in line with the flow to the Indian Kill reservoir, which is being { .38e.9.
The used as a drinking water supply for nearby residents.
- distance between the 8-4 location and the reservoir isThe release approximately 600 feet.
the site to the ground and surface water appear to be a violation of New York's water pollution control laws, specifically including L 17-0501, and may be in violation of BCL i l~ but not limited to ECL 17-0701, 17-0803 and 6 NYCRR Section 380.4(b).
, , In order to ensure protection of the environment and to i identify all measures necessary to comply with the law, Cintichen must immediately take the following remedial actions: Continue operating the ion exchange water treatment system at s-4 to remove radioactive materials from the interce - 1.
groundwater until the Department directs otherwise.
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. Provide an initial characterization of the vertical and 2.
horizontal extent of surface and groundwater contamination at and .. emanating f rom the site, including but not limited to the followings a.
Conduct tracer tests to verify the origin of radionuclides detected at 5-4.
First, a colormetric tracer must be introduced into the borehole in the basement of the Radioactive ! Materials baboratory (Duilding 2).
In the event of positive results, this is to be followed by an additional tracer test, e.g., using bromides, to determine the dilution f actor between It is Building 2 and s-4 as indicated on the enclosed map.
23, 1990, expected that this action will be completed by January and a report identifying and discussing the results shall be
submitted to the Department by February 9,1990.
The protocol for I the test must be submitted to the Department for approval at least l ( one business day prior to undertaking the test.
l
b.
Take subsurface borings sufficient to define Sample and provide split samples to the groundwater flow.
Department of these borings, surface water and groundwater to
It is expected that this l define the extent of contamination.
12, 1990, and a report t action will be completed by February ' identifying and discussing the results shall be submitted to the , Department by March 1, 1990.
l obtain grab samples of groundwater from S-4, at ( ' the water is treated, and c.- f 24-hour intervals, both before and after analyse those samples.
A report on this ongoing effort is expected weekly.
d.
Obtain aquatic biota samples (including plankton, fish, and benthic rooted aquatic vegetation, invertebrates,from the Indian Kill reservoir and ha l organisms) for radioactive content.
A report identifying and discussing the results shall be submitted to the Department by February 12, 1990.
Obtain grab samples at the drinking water intake e.
structure in the Indian Kill reservoir at 24 hour intervals and A report identifying and discussing the analyse those samples.
, , results on this ongoing effort shall be submitted to the l Department daily.
f.
All samples shall be sent to an indepindently owned e laboratory, approved by the Department, for antlysis of , radioactive content.
submit to the Department within 45 calender days of the 3.
, date of this letter a plan which shall include but is not limited I to the following: . Descriptions of all measures to be taken in a.
accordance with 1 and 2 above; ! , t, ,-w-g---- ,---,-__.v---- - - -, -______m.,- m m ,,__._____m__ m --
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l i b.
Identification of measures to be taken to identify i the full vertical and horizontal extent of contamination and to - provide for ongoing monitoring of the quality of all groundwater . and surface water at and emanating from the facility, including . the installation of permanent groundwater nonitoring wells; .I A program of sampling and analysis of the quality of c.
in the Indian Kill reservoir sufficient to identify any i water contamination emanating or which may emanate f rom the f acility / , ' (via air, water or earth); d.
A program of sampling and analysis of the quality of water entering the drinking water intake structure in the Indian E111 reservoir water company to identify any contamination from the f acility which may be present in such water; , A program for determining the source (s) of ground , e.
and surface water contamination at the facility; and - f.
A schedule for implementation of all requirements in this directive.
,
The company shall pctmit Department employees to enter the site at any reascnable time to determine compliance with this letter.
If you have ony questions, please contact Dr. Paul J. Merges at: NYS Department of Environmental Conservation
Division of Hazardous substances Regulation Bureau of Radiation ' 50 Wolf Road - Room 510 12233-7255 Albany,)New York or (518 457-2225.
i ' $1ncerely, ' W"L' / ' N. G. Kaul, P.E.
Director Division of Hasardous i Substances Regulation '
L cci r. Bradley, NYSDOL L J. McGrath, USNRC Enclosure l.
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i - Yg' k UNITED sTAfss L- NUCLEAR REGULATORY COMMISSION ! I: Rat 4ON 1 i f ~
476 ALLaNOAL.E ROAD
tono OF PRUSSIA. Pl.NNSYLVANIA 1s404 Docket Nos. 50 54 F EB 23 1990 License Nos. R-81 70-687 SNM 639 l CAL No.190-005 i.
' Cintichem, Incorporated j! " NITN: Mr. James J. McGovern l Plant Manager l P. O. Box 816 ! ' Tuxedo, New York 10987 i Gentlemen: I This letter is to confirm our understanding of your commitments made during telephone i discussions with Dr. Robert Bores of this office on February 23,1990, i Based on those discussions, we understand that, until further notice, you are taking the ! following actions.
{
1.
Release no water intentionally from the onsite holding pond to the Indian j Kill Reservoir.
2.
Eliminate, to the extent possible, any leakage / seepage from the holding pond , to the reservoir through the S 1 gate at the sampling point.
' To the extent that such leakage cannot be eliminated, sample - the leakage with a composite sampler and analyze these .; sampka on at least a 12 hour basis. If the composite sampler r becomes inoperable, take and analyze grab samples taken at . no more than 6-hour intervals.
l
3.
Make all discharges from the holding pond in a batch mode to the 001 discharge point to the Indian Kill Creek downstream of the reservoir, in accordance with an established written procedure, following sampling and gamma spectral analyses to ensure that the radioactive content is below the applicable maximum permissible concentrations (MPCs).
. In the event that heavy rains or surface run-off to the holding - pond requires that, to preserve its integrity, the holding pond be emptied or lowered prior to the completion of the analyses , on a batch basis, pumping to the 001 discharge point may be ! begun. In that case, sampling and analysis of the holding pond L.
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. _. - .' I .,.. FEB 2 81990 ATT 4-2 l . , shall be done on an hourly basis until the batch release process can be re-established.
4.
Inunediately (within one hour of detection) notify the NRC, Region I, through the NRC Operations Office (3019510550) should any radioactisity be measured above background levels in the holding pond or at S 1, or, , should any unanalyzed release from the holding pond occur.
, For purposes of this notification the sensitivity of analyses shall i - be such that at least 0.1 times the applicable MPCs can be detected.
! If our understanding of your actions, as described above, is not in accordance with your actual plans and actions, please contact this office within twenty four (24) hours of receipt
of this letter.
Your cooperation with us is appreciated.
Sincerely, i . /Y 7/ Malcolm R. Knapp, Director Disision of Radiation Safety and Safeguards ec: W. G. Ruzicka, Manager, Nuclear Operations D. D. Grogan, Manager, Radiochemical Production T. Vaughn, Manager, Health, Safety and Emironmental Affairs A. Dorozynski, Supenisor, Town of Tuxedo Public Document Room (PDR) Nuclear Safety Information _ Center (NSIC) l State of New York l l l l:
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ATTACHllENT 5 f**%.k - ^
, UNITED $TATES [ NUCLEAR REGULATORY COMMISSION ' ' r.
. W A SHING TON, D. C. 20665 %, ..... FEB 181990 Docket No.
50 54 70-687 License No. R-81 SNM-639 ~ EA 90-033 i Cintiches, Incorporated ATTN Mr. James J. McGovern ! Plant Manager P. 0. Box 816 Tuxedo. New York 10987
Gentlemen: l
l Subject: ORDERMODIFYINGLICENSE(EFFECTIVEIMEDIATELY) Enclosed is an Order Modifying License, effective imediately.
This Order requires that the facility remain shutdown until you have identified and fixed existing leaks at your facility that have resulted in the release of radioactivity to an onsite retention pond.
We recognize that suspension of your NRC licensed activities may impact the
delivery of medical care.
Therefore, please keep the Regional Administrator, Region 1, informed of the impact of this Order on the ability of the medical
, community to obtain radioisotopes.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," Part 2 Title 10, Code of Federal Regulations, a copy of this letter and the enclosed Order will be placed in the NRC's Public Document Room.
The responses directed by the accompanying Order are not subject to the clearance procedures of the Office of Management and Budget, as required by . the Paperwork Reduction Act of 1980, PL 96-511.
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Sincerely, i Hug L. Thompso/7) fry Jr.
O p ty Executiv Di c r for Nu lear Materials ty, Safeguards, and Operations Support Enclosure: Confirmatory Order . CERTIFIEDMAiL RETURN RECEIPT REQUESTED n n,,, A,1, /_tL.G
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Cintichem Incorporated ATT 5 - 2 ,
' cc w/ enc 1: , T. Vaughn, Manager, Health Safety and Environmental Affairs
M. D. Johnson, Reactor Supervisor D. D. Grogan, Manager, Radiochemical Production ' W. G. Ruzicka, Nuclear Operations Manager , Dr. William Vernetson, Director of Nuclear facilities,
. ' University of Florida Pubite Document Room (PDR) . Nuclear Safety Information Center (NSIC) ' State of New York , !
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ATTACHMENT b i'.,< Figure 2 C'
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. UNITED STATES NUCLEAR REGULATORY COMMISSION Cintichem, Incorporated Docket Nos.
50-54 P. O. Box 816 70-687 Tuxedo, New York 10987 License Nos. R-81 SNM-639 EA 90-033 ORDER MODIFYING LICENSE (EFFECTIVEIt94EDIATELY) I Cintichem, Incorporated (the" Licensee").istheholderofLicenseNos.R-81and SNM-639. License No. R-81 and License No. SNM-639 authorize the Licensee to produce and process radioisotopes. License No. R-81 was issued by the Nuclear Regulatory Commission (the "Ccunission" or "NRC") on September 7,1961, was most recently amended on March 14, 1989, and is due to expire on June 30, 2000.
License No. SNM-639 was most recently renewed by the NRC on October 19, 1984, was most recently amended on May 17, 1989, and is currently under timely renewal.
Other activities involving radioactive byproduct material are conducted at this site under the authority of the State of New York.
t . !! - On February 9,1990, the Licensee reported to the NRC Region I office the identification of an unmonitored release of radioactively contaminat3d water from the facility's reactor building to an onsite retention pond.
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' ATT,5/2 -2 i . i The rapid and unexpected buildup of radioactivity in the retention pond, , combined with the increase in the pond level due to rainfall the night of February 9 and the morning of February 10, indicates a significant ! i - potential for radioactive releases in excess of regulatory limits. An NRC inspection team was dispatched to the facility, and arrived at the facility t on the evening of February 9,1990. Subsequently, the team was informed i that the uncontrolled release of radioactivity to the pond apparently resulted from a failure of part of the concrete wall of the gamma pit.
(The gamma pit is a wa'ter-filled pool which is used for the temporary storage of radioactive e material.)
Subsequently, on February 12 the Licensee informed the NRC inspection team . that another concrete vessel on site, namely, the holdup tank (which is located in the reactor bulloing and which is used to allow the decay of short-lived isotopes in the reactor coolant), also apparently had developed a leak.
The-foregoing relates to matters subject to the NRC's jurisdictior.. .- !!! The concurrent identification, within a very short time period, of the failure of two concrete vessels, resulting in the uncontrolled release of radioactively i l l l c l . y , --,.,-y---. r-y-,, w , - -,
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l contaminated water to the site environs, demonstrates that the Licensee cannot presently provide reasonable assurance that continued operation under its licenses will be in compliance with Comission requirements.
Therefore, continued operation of the facility without additional action is inconsistent ) with the Commission's requirements.
In view of the potential risks to the public from uncontrolled releases of I radioactively contaminated materials from the facility. I have determined, , pursuant to 10 CFR 2.204, that public health, safety and interest requires that this Order be made immediately effective.
! IV > Accordingly, pursuant to Sections 57, 104, 161b., 161 c., 1611., and 1610., 182, and 186 of the Atomic Energy Act of 1954, as amended, and the Connission's . regul6tions in 10 CFR 2.204 and 10 CFR Parts 50 and 70 IT IS HEREBY ORDERED, , THAT LICENSE N05. R-81 AND Snit-639 ARE MODiflED, EFFECTIVELY IMMEDIATELY, AS FOLLOWS: .. A.
The reactor remain shut down until such time as the Licensee: 1.
Submits to the NRC, for its review and approval, a plan to: i - -- -- - - - --
r- , ., Irl*
.. <- - i ATT 5/2 -4 - , Promptly identify, by inspection, existing locations of leaks a.
of radioactively contaminated material from the facility; . b.
Promptly repair all existing Iraks, and assure their effectivent.ss; Establish and implement a monitoring program to assure the c.
prompt identification of future leaks of radioactively . ' contaminated material from the facility; 2.
Implement the plan; and
, 3.
Notify the NRC, in writing under oath or affirmation, that the plan has been completed, and the Regional Administrator, Region I,
authorizes restart of the reactor.
! B.
Following authorization for restart pursuant to paragraph A 3 above, , the Licensee shall implement the monitoring program approved pursuant ~ to paragraph A.1.c.
, C.
Within 90 days of the date of this Order, the Licensee shall submit to the Regional Administrator, Region I, for review and approval, a detailed , plan for identification of the root causes of the undetected and uncontrolled leaks of radioactive material, as well as any structural deterioration of the structures, systems, and components.
The plan shall include a schedule with appropriate milestones.
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ATT 5/2 -5 , , D.
Upon completion of the plan set forth in Section IV.C a report shall be ., submitted to the Regional Administrator, Region I, which describes the results obtained, and corrective actions taken or planned (with milestones) to address the identified problems.
The Regional Administrator, Region ! may in writing relax or terminate all portions of the Order for good cause shown.
. Y , The Licensee, or any person who is adversely affected by this Order, may t request a hearing within 30 days of the date of this Order. A request for hearing should be clearly marked as a "R(: quest for Hearing" and shall-be submitted to the Secretary, U.S. Nuclear Regulatory Comission, Washington, , l D.C.
20555, Attention: Chief, Docketing and Service Section.
Copies of the hehring request also shall be sent to the Director, Office of Enforcement.
U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, to the Assistant General Counsel for Hearings and Enforcement at the same address, and to the Regional Administrator, Region I, 475 Allendale Road, King of Prussia, Pennsylvania 19406.
' If a person other than the licensee requests a hearing, that person shall set forth with particularity the manner in which his interest i is adversely affected by this Order and shall address the criteria set forth in10CFR2.714(d).
In the absence of any request for a hearing within the specified time, this Order shall be final without further Order or proceedings.
A REQUEST FOR HEARING SHALL NOT STAY THE IMMEDIATE EFFECTIVENESS . -.. - - -- -- - - . ~ - - - - , .e - -~nr -
i.. Y .. ,, o i ' . , ATT 5/2 -6 , If a hearing is requested, by the Licensee or a person whose interest is adversely affected, the Comission will issue an Order designating the time and place of any hearing.
If a hearing is held, the issue to be considered at such hearing shall be whether this Order should be sustained.
' ,
i f FOR THE NUCLEAR REGULATORY COP 9tISSION - , v' W \\ ' Hugh. Thompson, r.
- ' Dep Executive Dire r for Nuclear Materials Safety, Safeguards, , and Operations Support Dated at Rockville, Maryland this y day of February 1990 i ,
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