ML19341C925
| ML19341C925 | |
| Person / Time | |
|---|---|
| Site: | Wood River Junction |
| Issue date: | 12/23/1980 |
| From: | Crocker H, Kinney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19341C923 | List: |
| References | |
| 70-0820-80-14, 70-820-80-14, NUDOCS 8103040534 | |
| Download: ML19341C925 (14) | |
Text
o.
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
70-820/80-14 Docket No.70-820 License No. SNM-777 Priority 1
~ Category up Licensee:
United. Nuclear Corporation UNC Recovery Systems Wood River Junction, Rhode Island 02894 Facility Name:
Fuel Recovery Operation Inspection at: Wood River Junction, Rhode Island Inspection conducted:
ugust 18-19, 1980 Inspectors:
//f//
Am J2 P [D m < W.' Mnney/, Projept inspector
/date/ signed date -signed date signed Approved by L M
H. W. CrockeK Chief, Fuel Facility datd signed
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Project Section, FF&MS Branch Inspection Summary:
Inspection on August 18-19, 1980 (Report No. 70-820/80-14)
Areas Inspected:
Routine, unannounced inspection by a region-based inspector of:
burial of contaminated vermiculite; presence of radionuclides in test well samples; presence of fission products in test well sartples; and presence of radium-228 in test well samples.
The inspection involved 10 inspector-hours onsite by one NRC region-based inspector.
i Resul ts : Of the four areas inspected; no items of noncompliance or deviations were identified in three areas; one apparent item of noncompliance (Infraction -
failure to discontinue receipt and processing of slightly irradiated uranium scrap after July 16, 1976, paragraph 4) was identified in one area.
Region I Form 12 (Rev. April 77) 8103040536 9
- - - -e-w g
DETAILS 1.
Persons Contacted
- C. E. Bowers, President
- D. M. Schultz, Compliance Manager J. L'Heureux, Nuclear Materials Control Manager
- K. A. Helgeson, Nuclear and Industrial Safety Manager
~
- denotes personnel present at exit interview.
2.
Burial of Contaminated Vermiculite The inspector examined the available records and the site where radioactive material was buried by the licensee in 1967 and 1968.
In an interoffice memorandum dated October 26, 1967, from R. P. Smith to D.
F. Cronin permission to dispose of sampled and assayed vermiculite, which had been removed from old scrap drums, by burial on UNC property was requested.
I,1 a reply dated November 7,1967, Mr. Cronin gave permission to bury the sampled vermiculite on UNC property in accordance with 10 CFR 20.304, since the vermiculite contained less than the permissible amount of radioactivity.
This reply also outlined the practices to be followed in burial of waste on UNC property.
In a memorandum dated December 28, 1967, from E. Barton to R. P. Smith, the following information was listed; total volume of vermi-culite-46 yards or 9200 gallons; total amount of U-235-0.74 grams; total amount uranium in uCi-0.4 uCi U-234 and 46 uCi of U-235.
According to licensee records, the marker found at the burial site stated:
UNCFRP Benchmark Burial Log No. 67-1 Volume:
46 Yards U235:
0.74 Grams U235:
46.0 Microcuries U234:
0.4 Microcuries The only record located by the licensee which pertained to the 1968 burial was the August 1968 monthly report from E. Barton to L. J. Swallow.
In this report it was stated that clean-up of the south yard was completed with removal and burial of vermiculite.
According to licensee records, the marker found at the burial site stated:
UNCFRP Marker Burial Log No. 68-1 Volume:
30 Yards U235:
0.48 Grams U235:
30.0 Microcuries U234:
0.3 Microcuries
J l
3 i
The inspector reviewed the licensee's records concerning the removal of the vermiculite from the burial locations and packaging'of the dug-up material in 55 gallon barrels for shipment to the Barnwell, South Carolina burial site during 1979.
The waste was dug up from the soil on July 17 and 18, 1979.
The licensee removed the four feet of overburden; cleaned out the vermiculite and hauled it to their physically protected area; and filled the hole with the removed overburden and other soil.
According to the supervisor's log, the vermiculite and soil removed from the ground was
~
loaded into 55 gallon barrels from July 20 until July 27, 1979.
According to the Drum Seal Log, 260 drums were sealed and shipped to Barnwe'.1 from July 31, until August 21, 1979.
According to the records and markers, 76 cubic yards or 15,352 gallons of vermiculite were buried, and 260 55 gallon drums or 14,300 gallons were sent to Barnwell, South Carolina, for burial.
According to the licensee, they have searched their records and have made inquiries with all their employees and former. employees concerning any burials of radioactive material other than that sent to licensed burial grounds such as the Barnwell site.
There were no other burials according to any records or recollections.
The licensee had buried some nonradio-active trash in an old building foundation on UNC property.
They dug this material out of this location and stored it in their yard, where it is presently located.
The licensee apparently met the requirements of 10 CFR 20.304 when they buried the radioactive material in 1967 and 1968.
The licensee was acting in a responsible manner when they removed the material from the burial site and sent the material to the Barnwell burial site for disposal.
3.
Presence of Radionuclides in Test Well Samples The presence of radionuclides, especially strontium 90, in ground water samples has caused public concern.
The inspector searched inspection reports and old licenses for information concerning the liquid waste hand-ling system for pertinent information.
a.
Liquid Waste Handling System Aqueous process wastes which contained low concentrations of uranium were neutralized using lime, and the resultant slurry was pumped to a lagoon system.
In the lagoon system the solids settled out.
The supernatant liquid was supposed to be discharged to the Pawcatuck River after samples showed the radioactive concentrations were within NRC (AEC) regulatory limits given in Appendix B to 10 CFR 20.
When the facillity was started up in 1964, there was one 36 by 72 foot lagoon to receive the liquid waste.
The lagoon had a plastic lining.
This lagoon, Lagoon A, was filled during plant operations so that a new lagoon, Lagoon B, was needed.
Lagoon B was placed in service in
l 4
February 1966.
This lagoon also had a 6 mil plastic lining.
The lagoons were arranged so the liquid waste entered new Lagoon B and was to overflow into Lagoon A after Lagoon B was filled.
It was estimated that it would take about 6 months for Lagoon B to fill to the overflow level.
It was also reported that 12,195 gallons of liquid were dis-charged from Lagoon A to the Pawcatuck River during 1966.
In 1967 it was reported that the liner in Lagoon B had ruptured, and in mid 1967 the licensee had to discharge 10,000 gallons of water from Lagoon A to the Pawcatuck River and from Lagoon B to Lagoon A for repair of the liner.
(The rupture of the liner had to be up on the side of the lagoon near the top for the removal of 10,000 gallons of liquid to lower the level enough for any repairs.)
In late 1969 it was reported that the liquid levels in the lagoons had not reached the level which required discharge of the supernatant liquid to the river.
No discharges from the lagoons to the river had been made for two years.
The reason given was the water was leaving the lagoon by evaporation or seepage.
According to an October 23, 1974 report from Dr. William E. Kelley, Consultant Hydrogeologist to United Nuclear Corporation, precipitation estimated from records at Kingston, six miles to the east in the upper Pawcatuck River Basin, averages about 45 inches per year.
A table of evaporation data taken at Kingston in Dr. Kelly's report showed that from 1963 through 1972, excluding 1964, the average yearly evaporation was 27.2 inches.
Therefore, the liquid level in a lagoon would rise about 17 inches a year from unevaporated precipitation.
Of course, the addition of process liquid waste would fill the lagoon more quickly.
From the above discussion, it is evident that:
- 1) the lagoon system was leaking; and 2) Lagoon B was probably the leaking lagoon.
In a report for an inspection made in late October 1970, the inspectors reported that the liquid level in the lagoons remained constant.
The inspector made the point to the licensee that test wells to determine i
seepage from the lagoons were needed.
The licensee was in agreement l
with the philosophy of an enlarged environmental program, but did not have any definitive plans for obtaining additional data.
In a report for an inspecton in early January 1972, the inspectors reported that test wells were being sunk around the liquid waste lagoons.
l According to inspection reports for inspections made in January and July 1973, accumulated solids were removed from Lagoon A during August l
5 through October 1972.
Licensee records showed that 2,150 f~fty-five gallon drums of sludge were shipped off-site for burial.
According to the licensee, there was no visible evidence that Lagoon A had leaked.
j The renewed Lagoon A was fitted with a polyvinyl chloride bottom liner l
and a polyethylene top liner as part of the renewal operation.
The l
renewed Lagoon A was put into operation on December 16, 1972.
The
, lagoon dimensions were 110 by 90 feet, and the lagoon was eight feet deep.
In the same inspection reports discussed in the previous paragraph, it was mentioned that seven test wells had been driven and samples taken during 1972 indicated the presence of radioactivity in the wells.
The depth of the wells ranged from 18 to 35 feet.
The samples from Well No. 3 (located just west of Lagoons A and B) averaged about 350 dpm/ liter in alpha activity and about 500 dpm in beta activity.
The samples from the other wells averaged 50 dpm/ liter in alpha activity and 30 l
dpm/ liter in beta activity. The activity present in the liquid waste and the ground water are discussed in another section of this report.
The licensee continued to use the reneweo Lagoon A and Lagoon B until early 1977.
the licensee would transfer supernatant liquid from Lagoon A to Lagoon B, thereby keeping the level in Lagoon A down.
The licensee did not discharge any liquid to the Pawcatuck River.
Evidently, the leakage ar.d evaporation from the lagoon system was sufficient to keep the liquid level below the overflow level.
According to Inspection Report No. 77-08, in early 1977 the licensee attempted to increase the capacity of Lagoon A by placing sandbags and plastic lining to build up the sides.
This was not satisfactory, and the licensee dug a lagoon extension and lined its walls with plastic.
The lagoon extension was placed in service on April 15, 1977.
The licensee also obtained two above ground pools for contingency use on April 13. The licensee indicated that the solids in Lagoon B would be placed in Lagoon A, and Lagoon B would be replaced.
In Inspection Report No. 77-09, it was reported the licensee had replaced Lagoon B with 5 lagoons designated as C, D, E, F, and G.
Process waste was to enter lagoon C and cascade to D, E, and F as necessary.
Lagoon G was not completely installed in mid July 1977.
The replacement of Lagoon B probably ended the major source of leakage to the ground water.
In Inspection Report No. 78-09, it was reported that the licensee representatives stated that improvements in the lagoon system would result in the subsidence of traces of activity found by test well sampling.
It was also reported that covers had been placed on the waste lagoons and snow, ice, and rain water had collected on the covers.
The licensee intended to sample the precipitation and dis-charge it to unrestricted areas if it met 10 CFR 20 limits.
6 In Inspection Report No. 78-13 it was reported that plastic covers put over the lagoon to separate the rain water from lagoon water were torn and there was no plastic interface between the lagoon process waste and the rain water.
The licensee indicated they would remove and dispose of the torn plastic covers.
In Inspection No. 78-18 it was reported that the lagoon covers remained in the lagoons.
It was also reported that the ifcensee was using pumps and preforated hoses to wet down the sunny slope of a lagoon to increase evaporation of the liquid.
It was also reported that a liner failure in Lagoon C resulted in no more than 5,000 gallons of lagoon water being lost to the ground.
The evaluation by the licensee of this unusual event pointed out that the concentrations of radio-nuclide
'he lagoon were within 10 CFR 20 limits for release to unres' areas.
In Inspection Report No. 78-28 the leak testing of the licensee's 500,000 gallon nominal capacity covered " Plasti Steel" tank was reported.
The licensee found two leaks by the leak detection system.
The licensee then pumped air into the leak detection pipe and the location of the leaks in the plastic line was observed by the air bubbles through the leak in the liner.
The licensee repaired the leaks.
In Inspection Report No. 79-04 for a February 12-15, 1979 inspection it was noted that the licensee had started collecting waste in the new storage tank.
In Inspection Report No. 79-12 for a May 21-25, 1979 inspection, it was reported that 5 of the 6 lagoons had been covered by an air filled plastic dome to facilitate evaporation and exclude rain water.
In Inspection Report No. 79-16 for an August 27-31, 1979 inspection, it was reported that the licensee was going to use filtration and drying to get rid of the lagoon sludge.
In summary, the information in the inspection reports indicates that Lagoon 8 did leak.
Lagoon B was in service from February 1966 through 1976.
Lagoon B was replaced by Lagoons C, D, E, F and G in early 1977.
b.
Test Well Sample Results As was indicated in the previous section of this report, seven test wells were driven and samples taken during 1972.
These samples showed alpha and beta radioactivity in the samples. One well, Well No. 3, had average activities of 350 dpm/ liter alpha activity and 500 dpm/ liter beta activity.
The samples from the other wells had alpha activity averaging about 50 dpm/ liter and beta activity averaging about 30 dpm/ liter.
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7 In Inspection Report Numbers 73-04, 74-07, 75-16, 77-08, 77-10, 77-14, 78-09, 78-18, 78-27, 79-06, 79-18, and 80-05 the sampling of the water from the test wells and the results were discussed.
In all of these reports it was concluded that there was radioactivity in the ground water.
In these reports the inspectors also assumed that the radio-activity present was uranium-235.
The concentrations of the radio-activityinthegroundwaterwerewellwithinthe10CFR20limitsfgg release of uranium-235 in liquid to unrestricted areas which is 3x10 uCi/ml (66,000 dpm/ liter).
On December 27, 1978, the Division of Fuel Cycle and Material Safety of the Office of Nuclear Material Safety and Safeguards of the NRC issued Amendment No. 5 to License No. SNM-777.
This amendment author-ized the use of the new 500,000 gallon " Plasti Steel" tank for contain-ing process liquid wastes under additional conditions.
One of these additional conditions was that the licensee must collect water samples on a monthly basis at me monitoring wells and analyze the sample for gross alpha and gross beta radioactivity.
If the gross alpha and gross beta exceed 15 picrocuries/ liter and 50 picocuries/ liter, respec-tively, the licensee had to identify the major nuclides and determine their concentratic6s.
The licensee implemented the above license condition in February 1979.
The licensee received the first results of the identification and concentration of the radionuclides from their contracted laboratory in August 1979.
Since that time, the licensee has:
sampled the test wells; analyzed the samples for gross alpha and gross beta activity; and sent samples to their contract laboratory for identification of the major radionuclides and determination of the concentrations of these nuclides.
(The licensee was cited for not sending all samples required to their contractor for analyses in Inspection No. 70-820/80-05.)
The inspector examined the licensee's gross beta analyses of the well samples for the period from January 1978 through August 1980.
Mean gross beta values for the wells were determined.
These mean values are shown in Figure 1.
The sample well identification numbers and the depths of the wells are shown in Figure 2.
The gross beta concentra-tions versus the sample dates were plotted for those wells with mean gross beta concentrations above 100 dpm per liter.
These graphs are shown in the exhibits section of this report.
These graphs are analyzed later in this report.
The inspector reviewed the sample result reports from the samples sent to the contracted laboratory for the months of February through October 1979.
Special attention was paid to the concentrations of the radio-nuclides compared to the 10 CFR 20 Appendix B concentration limits for release of water to unrestricted areas.
This review showed that the
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Mean Gross Beta Values for January 1978 through August 1980
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Figure 2.
Identification and Depths of Test Wells
10 concentrations of the radionuclides were within the 10 CFR 20 Appendix B limits; however, the concentrations of radium-228 and strontium-90 were relatively high in some well samples.
The NRC collected samples from the lagoons and test wells on UNC property in July 1980.
The analyses of these samples confirmed the presence of strontium-90 and radium-228 in the ground water.
The analyseg of water samples fgom wells T-2 and T-3 had values of 8.3 +
1.7x10 and 4.36 + 1.4x10 uCi/ml for radium-228.
The concentration limitforwatertobereleasedtoungestrictedareasgiveninAppendix B of Part 20 for radium-228 is 3x10 uCi/ml.
c.
Discussion of Test Well Results Review of the graphs of gross beta concentration in the different wells versus time for the period of January 1978 through August 1980 (Exhibits 1-12) discloses that the gross beta concentration in the ground water during that time period in general has remained relatively constant.
Only wells T-2, T-4, and 76U have shown a significant downward trend in the beta concentration over that period of time.
4.
Presence of Fission Products in Test Well Samples From the previous discussion, it is apparent that Lagoon B, which was in service from the beginning of 1966 through the end of 1976, leaked and radionuclides entered the ground water beneath the lagoons.
The radio-nuclides included strontium-90 and cesium-137 which are fission products.
The source of the fission products in the lagoon materials is discussed below.
In Amendment No. 19 to License No. SNM-777 dated May 5, 1966, United Nuclear Corporation was authorized to recover 6.233 kilograms of uranium-235 from uranium-aluminumfuelelementspreviouslyusedinlgwpowercriticality experiments. The licensee calculated that 0.385x10 milligriesoffission products per gram of uranium-235 and a maximum of 7.45x10 grams of plutonium per gram of uranium-235 were present in the fuel elements.
These values were well within the 10 CFR 50.2(a)(3)(fi) values for facilities exempt from the requirements of 10 CFR 50.
(Any facility designed or used for the separation of isotopes of uranium or the isotopes of plutonium, i.e., spent fuel reprocessing facilities, are licensed under 10 CFR 50.)
11 In Amendment No. 33 to License No. SNM-777 dated June 15, 1967, the licensee was authorized to recover the uranium from other fuel elements similar to those authorized to be prggessed by Amendment No. 19.
The amount of plu-tonium was less than 1x10 gram per gram U-235 and the amount of fission products was less than 0.25 millicuries per gram U-235.
Therefore, the exemption limits of 10 CFR 50.2(a)(3)(ii) applied.
Amendment No. 43 to License No. SNM-777 dated June 17, 1968, authorized a revised Section 100 to License No. SNM-777.
Under Section 103, Summary of
~
Activities, it was stated, "The maximum quantity of slightly irradiated material at any one time.will be less than 2 percent of the total allowable SNM.
The maximum radiation levels acceptable will be 10 mr/hr at one foot".
Also it was stated in 103.1, Recovery Operations, "Only unirradiated n.aterial, except as exempted by 10 CFR 50 will be processed 10 W 50.2.3.
-6 ii...the material to be processed contains not more than 10 grams of plutonium per gram of U-235 and has fission product activity not in excess of 0.25 millicuries of fission product per gram of U-235."
During the review of the renewal application for License No. SNM-777, in an enclosure to letter dated March 31, 1972, Licensing asked for the following information.
" 1.
In support of your request, in Subsection 103, dated March 6, 1972, to process slightly irradiated fuel, you should either submit an analysis which establishes that non particulates could not consti-tute a significant portion of your effluent releases or describe the appro-priate modifications to your effluent monitoring and waste treatment systems."
In a reply of May 22, 1972, the licensee noted that they deleted their request to process slightly irradiated uranium.
The revised Subsection 103 dated May 22, 1972, which superseded the issue of March 6, 1972, had no reference to the processing of slightly irradiated material.
When License No. SNM-777 was renewed in its entirety on July 16, 1976, Subsection 103, with an issue date of May 22, 1972, was included as an effective page of the license.
From the above, it is apparent that from May 5, 1966, until July 16, 1976, the licensee was authorized to receive and process slightly irradiated uranium.
It is also apparent that the licensee decided not to process slightly irradiated material once their license was renewed in its entirety.
Most of the uranium scrap received by UNC Recovery Systems for recovery of i
the U-235 comes from the Naval Reactor program.
A good part of the scrap recovered came from the Knolls Atomic Power Laboratory (KAPL) and the Bettis Atomic Power Laboratory (BAPL) Naval Reactor Programs.
In accordance with Department of Energy (DOE) procedures, scrap nuclear material from the Naval Reactor program was reported to the Oak Ridge Central Scrap Management Office (OR-CSMO) for evaluation and disposition.
The Department of Energy supplied information to the NRC concerning the i
Naval Reactors program scrap which the Oak Ridge Central Scrap Management l
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12 Office contracted with United Nuclear Corporation for the recovery of the U-235.
(Exhibits 1, 2, and 3)
Critical Facility Fuel Development Fuel Upper Limit (Slightly Irradiated)
(Not Irradiated)
For SR-90 Content Year
- grams U-235 -
arams U-235 -
- millicuries -
1964 0
742 1965 0
0 1966 0
1,262 1967.
68,173 55,790 1.8 1968 0
164,581 1969 0
0 1970 0
0 1971 0
210,654 1972 243,987 36,236 4.7 1973 18,500 48,013 0.5 1974 35,781 39,115 0.5 1975 37,044 79,277
- 0. 5 4
1976 0
36,648 1977 0
22,706 1978 32,826 42,866 0.8 1979 9,662 5,178 0.1 1980 351,092 8,431 9.4 797,065 781,499 15'.3 From the above table, during the period from 1966 through 1976, the licensee processed 403,485 grams of U-235 which was slightly irradiated.
As was stated previously, the licensee was authorized by the NRC to process this material.
As indicated in Section 3.a. of this report the period 1966 through 1976 is the time when Lagoon 8 was in service, and Lagoon 8 was probably the leaking lagoon.
From the table it is also evident that UNC Recovery Systems processed scrap containing slightly irradiated uranium in 1978, 1979, and 1980 even though their license did not authorize such processing after the license renewal date of July 16, 1976.
There was another example of slightly irradiated material being processed by UNC after July 16, 1976.
In January 1977, UNC Fuel Recovery Operations received 5 fuel plates from Michigan Technological University.
These fuel plates contained about 557 grams of uranium enriched to contain about 20 percent U-235.
Conversation with a professor at Michigan Techno bgical University disclosed that the University received these fuel plates along with 10 other plates from Argonne National Laboratory.
The fuel elements were used in the low power Argonaut Reactor probably from 1957 to 1959.
The pro-fessor estimated that the fuel plates were irradiated in the reactor at an average of 100 watts power for 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per week, 50 weeks per year for 3 years.
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The surface readings of the fuel plates was about 2 to 3 mres/hr.
The l
professor stated that the cesium-137 peak can still be detected by a gamma scan of the fuel plates still in the custody of the University.
(Exhibit 4) 2 There has been discussion as to the definition of irradiated and unirradiated scrap.
In thair letter to Region I dated November 13, 1980, Oak Ridge Operations of the Department of Energy pointed out that, " critical fuel materials have been handled both within the Naval Reactors complex and ORO as unirradiated in accordance with DOE policy which provides that for recovery purposes, slightly irradiated (less than 100 millires/ hour on contact) scrap can be considered as unirradiated."
In this letter it was i
also pointed out that, "The personnel directly associated with the enriched uranium recovery contracting efforts here in Oak Ridge were not aware of the fact that the UNC license did not allow the processing of material containing microcurie quantities of fission products.
DOE's contracts with UNC required the contractor to have all necessary licenses to possess and process the material.
Most parties to enriched uranium recovery efforts are aware of the less than 100 millirem threshold and routinely treat this material as unitradiated."
From this discussion it is apparent that DOE considers the slightly irradiated j
material to be unirradiated.
The information discussed previously in this report demonstrates that both the NRC and UNC considered the slightly irradiated material to be irradiated with minute quantities of fission products being present in the effluents as a result of processing such material.
During i.he licensing renewal activity in 1972, the NRC did not deny UNC the authority to continue to receive and process ~ scrap containing slightly irradiated material.
As was previously discussed, the NRC requested that in support of the request to process sightly irradiated uranium the licensee should either submit an analysis which establishes that non particulates (fission products in solution) could not constitute a significant portion of the effluent releases or describe the appropriate modifications to the effluent monitoring and waste treatment systems. Apparently, rather than either submit this analysis or describe these appropriate modifications, the licensee decided to forego the authority to receive and process the slightly irradiated uranium-bearing scrap.
The processing of the slightly irradiated scrap after July 16, 1976, is an item of noncompliance.
5.
Presence of Radium-228 in Test Well Samples Radium-228 is a daughter of thorium.
The licensee recovered much uranium-235 from uranium-thorium material. This thorium was probably the source of the radium-228 present in the test well samples.
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14 6.
Exit Interview The inspector met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the onsite inspection on August 19, 1980.
The inspector presented the scope and findings of the inspection.
The point of whether or not the licensee had processed irradiated material after their license renewal date of July 16, 1976, was discussed.
The inspector noted that Region I was attempting to learn when irradiated material had been processed at UNC Recovery Systems.
The inspector noted that if it was determined that irradiated material had been processed after the license renewal date, the licensee would be cited with an item of noncompliance.
The licensee noted that there were questions concerning what constituted irradiated and unirradiated fuel.
In a telephone conversation on December 12, 1980, the inspector informed Mr. R. J. Gregg, Plant Manager, that the processing of irradiated material after July 16, 1976, was an item of noncompliance.
7.
Exhibits Exhibits 1, 2, and 3 are correspondence between Region I and Department of Energy Schenectady Naval Reactors Office and Oak Ridge Operations Office.
Exhibit 4 is a letter to Region I from Michigan Technological University.
These exhibits contain information concerning the slight irradiation of uranium-bearing scrap sent to UNC Recovery Systems for processing after July 16, 1976.
i
-Exhibits 5 through 16 are graphs showing beta and strontium-90 concentrations in test well which had a mean gross beta value over 100 for the period from January 1978 through August 1980.