ML20010J210
| ML20010J210 | |
| Person / Time | |
|---|---|
| Site: | 02700039 |
| Issue date: | 09/24/1981 |
| From: | Grant W, Paperiello C, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20010J201 | List: |
| References | |
| 27-0039-81-01, 27-39-81-1, NUDOCS 8109290708 | |
| Download: ML20010J210 (8) | |
Text
,
w U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III Report No. 27-39/81-01 Docket No. 27-39 License No. 13-10014-01 Licensee:
U.S. Ecology, Inc.
Post Office Box 7246 Louisville, KY 40207 Facility Name:
U.S. Ecology, Inc.
Inspection At: Sheffield, Illinois Inspection Conducted: September 8 and 9, 1981 Wh Yu1MMklO 9)g,,/,j Inspectors:
M. C. Schumacher
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W. B. Grant J Y V
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Approved By:
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Inspection Summary Inspection on September 8 and 9, 1981 (Report No. 27-39/81-01)
Areas Inspected: Routine Unannounced inspection of radiological and envian-mental protection including: Organizational changes; audits; security; instruments; training, retraining, and instruction to workers; personnel radiation protection - external; internal; air sample program; permanent sample station and environmental monitoring; trench inspection and water erosion and independent measurements. The inspection involved 22 inspector-hours onsite by two NRC inspectors.
Results: One apparent item of noncompliance for failure to sample surface water runoff was identified.
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DETAILS 1.
Persons Contacted
- R. Moore, Site Manager A. Armbrust, Site Radiological Control and Safety Officer
- Denotes those present at exit interview.
2.
General The purpose of this inspection was to determine if the licensee is conducting their Environmental protection and Radiological Safety Programs in accordance with their license requirements and to observe water erosion condition onsite.
3.
Scope of Operations The records indicate that the last date of waste burial was in Trench 14-A on April 8, 1978. No radioactive waste had been buried at the Sheffield, Illinois facility since that time. The licensee has not received any radioactive material at the Sheffield site since March 8, 1979. The licensee is performing caretaker functions.
4.
Organization A license amendment changing the name of the licensee from Nuclear Engineering Company (NECO) to U.S. Ecology Inc. was issued in December 1980. The Licensee's organizational structure and its re-sponsibilities pertaining to the Sheffield, Illinois site remain as defined in the Radiological Controls and Safety for Burial Sites Manual (RCS) and the Site Operations Manual for Low Level RAD Waste Disposal at Sheffield, Illinois (SOM). These manuals were incorporated into the license by Amendment No.11, dated January 6,1977.
The following organization changes have been made since the inspection conducted in April 1980.
Mr. J. J. Scoville is President of the Corpora-tion.
Mr. Roger Carter is Vice President, Marketing and Mr. Ken Walle.r is Deputy Radiological Control and Safety Officer.
No items of noncompliance were identified.
5.
Audits a.
Quarterly Audit The licensee's quarterly audits as described in Section 4 of the RCS and Section 2 of the SOM are being implemented and records of these audits were reviewed. The audits consist of a review of:
) _
i (1) Dosimetry Program; (2) Radiological Control and Safety Training; (3) Emergency Drills and Equipment; (4) Working Procedures / Performance and Personnel Decon.;
(5) Radiological Survey and Posting; (6) Radiation Instrumentation; (7) Environmental Monitoring; (8) Security, and General Condition of Burial Site.
b.
Site Inspections The licensee's quarterly site inspection requirements as described in the RCS and SOM were reviewed.
Section 2.2.5 of the RCS requires that the Chief Radiological Control and Safety Officer spend a minimum of one to three days of every calendar quarter at the burial facility.
These inspections were performed as required since the last inspection.37 No items of noncompliance were identified.
6.
Security Program The licensee conducts a security program in accordance with Section 4.0 of the SOM except for those changes that were negotiated between NRC and NECO and documented in an agreement between both parties, dated April 23, 1979. The "After Shift and Weekend Log" was reviewed. The results of this review indicated the security program is being implemented.
No items of noncompliance were identified.
7.
Instruments A review of the licensee's records showed the licensee's radiation survey instruments, which are used to perform sutveys in accordance with the licensee's survey procedures (SI-004), are calibrated at approximately six month intervals as required. The instrumentation on hand includes alpha, beta and gamma survey instruments.
Gamma instruments have ranges capable of detecting ambient background up to tens of R per hour.
No items of noncompliance were identified.
8.
Training, Retraining, and Instruction to Workers The licensee's training, retraining, and instruction to workers are described in the RCS and SOM as are all forms required for signature with eference to instructions and tests. Radiation worker's requal-ification tests were reviewed since the last inspection. The three truck drivers and the Site Radiological Control Officer were requal-ified in 1981. The Site Manager is currently taking requalification training.
No items of noncompliance were identified.
1]
IE Inspection Report No. 02700039/80-01..
9.
Personnel Radiation Protection - External The licensee's personnel radiation monitoring program as outlined in the RCS was reviewed during this inspection. The licensee uses monthly film badges for monitoring external whcie body exposures to persons actively engaged in the program. There are currently only five individuals badged.
The film badges are supplied by R. S. Landauer Company. The licensee maintains copies of Form NRC-5, NRC-4, State of Illinois form RMA-1, and the reports from the film badge supplier. These records wer eviewed for e
1980 and the first two quarters of 1981. Whole body exposures were minimal.
Areviewgecordsofthelicensee'sdirectsurveysmadesincethelastin-spection-indicated that daily surveys are made of the maintenance shop, office, lunch room, and change room areas. The records showed no radiation levels above 100 counts per minute above background.
No items of noncompliance were identified.
10.
Personnel Radiation Protection - Internal The licencee's bioassay program consists of performing urinalyses of all radiation workers on a quarterly frequency. This program includes gamma isotopic, uranium, and tritium analyses.
In 1980 the licensee also had whole body counts done on all radiation workers and intends to have counts performed on the personnel in 1981 as soon as that can be arranged. No problems were noted.
No items of noncompliance were identified.
11.
Air Sample Program The licensee takes weekly air samples of the yard outside the main build-3 ing by drawing air through a sample tube at a rate of 5 ft / minute using a stationary pump inside the building. The results of these samples were reviewed and indicated concentrations below 10 CFR Part 20, Appendix B Limits.
No items of noncompliance were identified.
12.
Permanent Sample Stations Weekly and quarterly records of trench water level surveillance for the period April 1980 through August 1981 were reviewed. The records in-dicated no standing water in these sumps except for trench 18 where the level varied from 2.3 to 4 feet above the bottom over the period. This trench is periodically sampled by the license for the State of Illinois.
Licensee representatives onsite did not have the results of the State's analysis.
Preliminary analysis of a sample collected by the inspectors indicated approximately 500 nanocuries per liter tritium and approximately SE t uCi/ml Co-60 in the trench 18 sump. The sarple has been forwarded t the NRC reference laboratory for detailed analysis.
2/
Ibid. - -
T 4
Radiological Work Procedure SI-002 referenced by Condition No. 8 -Y License Amendment No. 11 of January 6, 1977 requires weekly monitoring of onsite surface water runoff sample station "S."
There are two such stations:
"S1" in the runoff path to the northwest and "S2" in the runoff path to the southeast. Although records Indicated the stations were checked weekly, no samples had been collected during the period May 1980 through August 1981 owing to the sample stations filling with silt during periods of runoff. The inspectors verified that both stations were filled with silt and that no sample was available.
- However, standing water from the most recent runoff was available nearby and the inspectors collected water for analysis by the NRC reference laboratory.
In the September 9,1981 exit interview, the licensee agreed to take standing water samples, if available, when a sample cannot be taken from the designated samplers.
Licensee representatives were notified by telephone on September 17, 1981 that failure to monitor surface runoff was considered to be noncompliance with the above referenced license condition.
- 13. Environmental Monitoring Program The licensee's environmental monitoring program includes quarterly sampling of surface and ground water, soil, and vegetation onsite and offsite. The samples are analysed by a contractor, Radiation Management Corporation, for gross alpha, gross beta, and tritium. The inspectors reviewed the records for the second half of 1980 and the first half of 1981 for evidence of migration of waterborne radioactivity from the burial trenches. There appeared to be no positive evidence of migration cular sample. However, as noted in an earlier seen in these partj/ tritium concentrations in sample collected from inspection report,-
USGS wells onsite near the trenches have indicated that tritium movement has occurred. This was confirmed by water samples taken during the 4
previous inspection-/ from USGS Wells No. 523 and No. 528; licensee Well G, and from surface runoff near Well G.
(See Attachment 1.) Tritium results (below) were all within the unrestricted area limit of 3000 nCi/ liter.
USGS Well 523 97 nCi/ liter USGS Well 528 8.3 nCi/ liter Licensee Well G 0.4 nCi/ liter Surface runoff 0.2 nCi/ liter During this inspection, the inspectors collected additional surface and ground water samples from locations north and south of the burial trenches and from one offsite location.
(Paragraph 16)
No items of noncompliance or deviations were identified.
- 14. Trench Inspection Inspection of the closed trenches for erosion shrinkage or settlement is required quarterly; however, the licensee has chosen to inspect at monthly intervals. The inspectors reviewed the records of the results 3/
IE Inspection Report No. 027-0039/78-01.
{/
IE Inspection Report No. 027-0039/80-01..
of these inspections. Holes, ruts or cracks in the trench caps were recorded on a site map with location, size and possible cause indicated.
Inspections were done on a monthly basis. Handwritten notes on the maps indicate that corrective actions have been timely.
No items of noncompliance were identified.
- 15. Site Tour The inspectors toured the burial site and observed that there appeared to be a good growth of vegetation over most of the site. A few fresh holes (
1 ft) and some cracks 6" - l' were noted in the trench caps.
Licensee representatives assured the inspectors these would be filled as soon as possible to prevent further erosion of this areas. Some areas of erosion away from the trench caps was also noted. The most serious of these was on the south side of Trench No. 11 where most of the surface water leaving the site to tl.ie south travels. Large gullies 1 to 5 f t, deep have formed in an area about 15 f t. across and 30 f t.
long leading to the south east corner of the site. The erosion starts about 25-30 ft. from the edge of Trench No. 11. There seems to be no immediate threat to the integrity of the trench. This problem was noted in licensee audits for 1981. Licensee representatives stated that because of heavy rainwater runoff this year, remedial action to date has not been very effective. They have asked Corporate IIeadquarters to do an engineering study for a permanent fix of the problem. These items will be reviewed for corrective action during the next inspection.
No item of noncompliance were identified.
16.
Independent Measurements Water samples were taken from USGS' Well Nos. 552, 559 and 528.
U.S.
Ecology's Well Nos. TA-9 and G, the creek SE of the burial site, the weir in the south runoff, Trench No. 18 end sump, and surface water near surface runoff sample site S-1.
The samples were sent to the Radiological and Environmental Sciences Laboratory, Idaho Falls, Idaho for analysis. The results will be transmitted in an addendum to this report.
Direct radiation measurements were performed during the tour of the burial site using Eberline G-M Instrument Model E500B NRC No. 000704.
No readings appreciably different from background were observed.
- 17. Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on September 9, 1981. The purpose scope and findings of the inspection were discussed.
Licensee representatives indicated that erosion conditions near Trench 11 would be closely foilowed and that permanent corrective actions would be._
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undertaken when 'he engineering study is completed. Licensee representa-c tives also agreed to sample surface water representative of runoff, if available, when liquid cannot be obtained from the designated samplers.
Licensee representatives were notified by telephone on September 17, 1981 that failure to sample surface runoff was considered to be a violation of Procedure S1-002 and therefore of their license, i
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