ML20057G026
| ML20057G026 | |
| Person / Time | |
|---|---|
| Issue date: | 10/07/1993 |
| From: | Mccann G, Wiedeman D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20057G021 | List: |
| References | |
| REF-QA-99990003-931013 99990003-93-22, NUDOCS 9310200099 | |
| Download: ML20057G026 (9) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
(
REGION III Report No. 99990003/93022(DRSS)
Docket No. 999-90003 Facility:
Elkem Metals Company Non-Licensee P. O. Box 299 Marietta, OH 45750-0299 Union Carbide Corporation License No. SMB-933 Mining and Metals Division Docket No. 040-07708 l
Grand Junction, Colorado (Terminated)
Inspection At: Marietta, Ohio Inspection Conducted: August 26-27 1993 Inspector:
. ep
/4-7 N D. G. Wiedeman Date nior Health Phys'cist Approved:
[
~
G16rgef.McCann, Chief
.@U) Acs Date Fbel Facilities and Decommissioning to/7[cf3 Section Inspection Summary Inspection on August 26-27. 1993 (Recort No. 99990003/93022(DRSS)1 Areas Inspected: This was a routine inspection which included a review of the activities associated with the decontamination and remediation in and around Simplex Storage Building A, a.k.a Building 78. This inspection included a review of the former licensee's subsidiary (Umetco) and sub-contractor's (IT Corporation) training programs, radiologic survey procedures and results, personnel monitoring, bioassay results, and air monitoring during the decontamination activities in and around Simplex Storage Building A.
This inspection also included independent radiation measurements.
Results:
No violations or deviations from the NRC approved plan titled l
" Project Plans for Remedial Action at Elkem Metals Company dated December 11, 1992," were identified. The NRC inspector's confirmatory direct radiation surveys { beta + gamma} of the areas in and around the rail road tracks North and Northeast of Building 78 indicate that these areas were successfully decontaminated. Two additional areas of low level contamination were identified outside Building 78, these areas were posted and the area is now restricted until a plan is developed to remediate the contamination.
9310200099 931013 REC 3 GA999 EMVELKMC 99990003 PDR
DETAILS 1.
Persons Contacted
- John Hughes, Environmental Supervisor, Elkem Metals, Marietta, Ohio
@* Jay Davis, Project Manager, Umetco Reclamation Corporation (Umetco)
Jack Boberg, Site Health and Safety, IT Corporation Harry Coleman, Radiological Technician, IT Corporation Chuck Crawford, Radiological Technician, IT Corporation Steven Duce, Site Radiation Safety Officer, IT Corporation Jim McAlpine, Site Foreman / Operator, IT Corporation Bill Simpson, Operations Supervisor. IT Corporation Michael Uniatowski, Environmental Technician, IT Corporation Steven Wisniewski, Cost Administrator, IT Corporation David Lightbody, Environmental Technician, IT Corporation Edward Wayne, Environmental Technician, IT Corporation W. Ladie, Project Manager, IT Corporation
@Rodney Dement, Environmental Engineer, Elkem Metals
- Attended the exit meeting conducted on August 27, 1993.
@ Telephone conference call conducted on September 27, 1993 to discuss bioassay results.
- Exit meeting on August 26, 1993.
2.
Backaround During the early 1960's, Union Carbide Corporation processed tin slags at this facility for the production of tantalum-columbian metals.
This activity was conducted under NRC Source Material License SMB-933.
Process residues containing thorium and uranium were retained and stored onsite.
In the early 1970's, operations were terminated. This license was terminated on July 8, 1985, based upon surveys conducted by the former licensee's (Union Carbide Corporation) consultant and confirmatory surveys by Oak Ridge Associated Universities (0RAU), an NRC contractor.
The records from Union Carbide's terminated license file (License No. SMB-933) indicate that radioactive residues were disposed of by transfer to a commercial burial site and equipment was removed and buildings were decontaminated. A review of these records indicate that only one building was decontaminated (Building 77, also known as Simplex Storage Building B); however, there were no indications that the building that was used to process this material was ever decontaminated (Simplex Storage Building A). This building was last used for processing thorium ores by the former licensee, Union Carbide in the early 1970's and has been used for storage of supplies by the current owner, Elkem Metals since they purchased the property in the 1980's.
In early 1992, an employee from Elkem Metals conducted a direct radiation survey of Simplex Storage Building A, in preparation for raising the building and noted radiation levels higher than ambient background inside the building and notified the NRC Region III office of his findings.
An on-site inspection was conducted on January 30, 1992 2
(see Report No. 99990003/92901(DRSS)). During this inspection, it was determined that residual radioactive contamination existed inside the building which was in excess of the NRC release criteria. On February 6,1992 the NRC issued a Confirmatory Action Letter (CAL) which confirmed that the following actions would be taken:
(1) the building would be posted and access to the building would be restricted, and (2) within 30 days provide the NRC with a characterization plan and schedule for remediation of the radioactive contamination.
Union Carbide Corporation (UCC) assumed responsibility for the characterization and decommissioning of the building and surrounding affected areas. UCC's subsidiary and contractor, Umetco Minerals Corporation and IT Corporation, submitted a Project Plan and Remediation Plan for NRC approval in December 1992. These plans were approved by the NRC on May 27, 1993. This inspection included a review and compliance with this approved plan. At the time of this inspection sixteen workers were involved with the implementation of the deuntamination and decommissioning plan. However, only nine of the sixteen workers are actually involved in remediation activities and the remaining seven individuals provide management oversight and audit functions.
No violations of NRC requirements were identified.
3.
Descriotion of Radiolooic Hazard This site poses no immediate threat to the public as it is in an industrial site with controlled access. At the time of the inspection, all areas suspected of being contaminated and Simplex Storage Building A were posted with signs stating " Caution Radioactive Material" and/or
" Caution-Potentially contaminated soils. Do not enter this area without prior authorization." All areas of potential contamination and work areas were roped off with yellow caution tape.
No violations of NRC requirements were identified.
4.
Air Monitorino a.
Preliminary Samplina Prior to work in high dust areas, a sample of nuisance dust was collected on August 19, 1993, to determine compliance with Occupational Safety and Health Administration (OSHA) requirements and to determine the efficiency of their personnel air monitoring collection systems.
This sample was collected for 376 minutes at a flow rate of 3.5 liters / minute (1/m). The results of nuisance dust of 2.2 mil]igrams/ meter}his sample show a maximum 3
(mg/m ).
This is below the 5 (respirable) and 10 mg/m (total dust) limits stated in 29 CFR and Appendix D limits of the American Conference of Governmental Industrial Hygienists (ACGIH).
3
b.
Personnel Air Samplers Four individuals working inside a high dust area were monitored for airborne respirable nuclides with lapel air samplers.
The samplers were turned on when working in high dust areas then shut off when the work was completed and the individual exits the working area.
These samples were counted on a Eberline ESP-1 alpha counting system for 1 bour, 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> then 3 days. The results of the 1 and 5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> sample are used to determine personnel exposure to short lived nuclides, e.g, radon-222.
The inspectors review of the data indicates that the maximum intake for one individual was less than 15 Derived Air Concentration-hour (DAC-hour) and the remaining individuals were < 1 DAC-ho personnel airborne exposure results were less than lx10"gr. To date all pCi/ml. This is below the NRC approved action level of 1x10"2 pCi/ml and is less than the limits specified in 10 CFR 20.1204, Appendix B, Table 1, Column 3.
Monitored breathing zones have been established inside Building 78 during activities that may produce high airborne dust and all individuals that vark in these areas have been fit tested for respirators and have been medically certified and approved for use of a respirator.
c.
Environmental Air Samplina Prior to any remediation work a continuous air sample was taken for a 3 day period. The results indicated a maximum of 2.0x10"' pCi/ml. At the start of remediation work to date, two continuous air samplers operate 24-hours a day in areas near Building 78 that are up-wind and down-wind from the prevailing winds. The sample filter is changed every Tuesday and Friday. The sample is counted for 60 minutes in the Eberline ESP-1 alpha counting system; however, a new Tennelec Model LB 5100 alpha / beta system will replace the former counting system.
The NRC inspector's review of the environmental monitoring data indicates that the gross alpha / beta analysis from August 6 to August 13, 1993 has not increased above the initial sample results that were taken prior to the start of the remediation work. IT Cor environmental action limit of 2.9x10"goration has established an pCi/ml which is a summation of the nuclides thorium-232, thorium-230, thorium-228 and radium-226 as required in 10 CFR 20.1302, Appendix B, Table 2 (Class W).
No violations of NRC requirements were identified.
5.
Radiation Protection All workers involved in the decontamination and decommissioning activities are issued wholebody thermoluminescent dosimeters (TLDs) for determining wholebody exposures to radiation. The badges are returned to their vendor for processing every month. At the time of the inspection the initially issued badges were still being worn, therefore, the results were not available at this time.
Each worker directly involved in remediation activities is required to have a urinalysis initially (baseline sample) and a bi-weekly sample thereafter. Threshold action levels for re-sampling, evaluation and work restrictions have been 4
established. All urine samples are tested for natural uranium, thorium-232, thorium-230 and radium-226.
During the first two-weeks of August 1993, 12 workers provided urine samples for analysis. The NRC inspector's review of the bioassay records on September 27, 1993, indicate that none of these individuals exceeded the established threshold action levels for natural uranium, thorium-230 or thorium-232.
However, seven workers exceeded the action limits for radium-226. These individuals were resampled on August 23, September 7 and September 16, 1993. The results were not available at the time of this inspection and will be reviewed during the next inspection along with Umetco's evaluation of the elevated radium-226 bioassay results.
No violations of NRC requirements were identified.
6.
Trainina Each individual that enters a restricted area or conducts remediation activities in contaminated areas is required to attend an 8-hour training session conducted by IT Corporation. The NRC inspector's review of training records indicate that twelve individuals received the required training on July 23, 1993, and four additional workers received the required training between August 2-24, 1993. All training records for the sixteen individuals working at the site were complete.
A form NRC-3 was posted in the office trailer and all individual workers that were interviewed appeared to have a good understanding of their procedures and the NRC rules and regulations.
No violations of NRC requirements were identified.
7.
Independent Measurements The inspector toured the site in and around Simplex Storage Building A with representatives from Umetco and IT Corporation and reviewed the remediation activities that had taken place.
During the tour, the inspector conducted independent radiation surveys with a Victoreen Model 190 survey instrument with a Model RP-1 pancake probe, NRC Tag No.
042444 calibrated on January 22, 1993, and a Ludlum Model 19 microR meter, NRC Tag No. 014809, calibrated on June 27, 1993. An instrument response check was conducted with the Victoreen Model 190 in a low background area with a.006 microcurie (sci) {222 Bq} thorium-230 check source. This instrument response check indicated 2,900 counts / minute (cpm) which equates to 600-700 microrads/ hour (grad /h) { beta + gamma} and ambient background radiation levels were 40-60 cpm.
Background
radiation measured with the Ludlum Model 19 indicated 8-20 #R/h {2.0-5.0 nC/kg/h} gamma.
A side-by-side comparison of portable survey instruments was performed by the NRC inspector with a known thorium check source. Both portable survey instruments (NRC & IT, Corporation) were within 10 percent agreement with each other.
Review of the radiation surveys conducted near the railroad tracks North 5
of Building 78 showed that prior to the remediation of the contaminated soil the average radiation level was 20-60 pR/h {5.0-15.0 nC/kg/h} which is in excess of the natural background levels. After remediation activities, average background level dropped back to < 20pR/h {< 5.0 nC/kg/h}).
Confirmatory radiation surveys conducted by the NRC inspector indicated that the contaminated soil around building 78 had been successfully remediated (see Attachment A for survey results and locations surveyed).
Several areas of elevated radiation levels were identified by Umetco and IT Corporation that were unexpected. These areas are approximately 300 feet (91 meters) East and Southeast from Simplex Storage Building A and may not be associated with the former licensed activities due to the higher alpha / gamma ratios than the contamination in Building 78.
Currently, these areas are being evaluated by Umetco and IT Corporation to determine the origin of the material and the appropriate method for remediation. Subsequent to the on-site inspection, personnel from IT Corporation remediated the removable contamination, posted the areas wi+h caution signs and restricted the areas.
No violations of NRC requirements were identified.
8.
Exit Meetina The NRC inspector met with the individuals identified in Section 1 of this report and summarized the findings of the inspection.
The inspector indicated that the inspection showed that the radiation levels found along the railroad tracks North of Simplex Storage Building A and adjacent to the East side of the building were now at background levels and could be back filled. Subsequent to the inspection, Region III was informed that due to contractual disagreements between Union Carbide Corporation (UCC) and IT Corporation, UCC suspended all work activities at the site (see Attachment B). On September 27, 1993 Region III was informed that meetings were scheduled for October 1 and 7, 1993, between UCC and IT, Corp. to resolve these contractual disagreements.
No proprietary information was discussed during the exit meetings.
Attachment A:
Survey locations and results Attachment B:
Letter to NRC dated September 20, 1993 6
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Surgey results include background Survey by-D. G. Wiedeman Elkem Metals Compor Marietta, OH.
ATTACHMENT A PAGE.)-of hAGES
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, SENT SY:Xerex Telecepier 7020 : E-20-93 : B:09AM :
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17067505605;# 2 Umetco Minerals Corporation P.O.BO X 1029
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GRAND JUNCTICN. COL OAADO B1502 W (303) 945-3700 i
i September 20, 1993 Mr. Darrel Wiedeman U.S. Nuclear Regulatory Commission, Region III i
Nuclear Materials Safety Section No.1 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Wiedeman:
Re: Former Union Carbide Corporation Mariotta, Ohio Facility License No. SMB-933 l
Due to a contract disagreement with IT Corporation, the remedial action contractor at the Elkem site, Union Carbide Corporation has temporarily l
suspended work at this site. Union Carbide is committed to completing the remedial action at this site pursuant to the plans approved by the NRC as soon as practicable.
I am traveling to the Elkem site today (September 20,1993) to verify that appropriate posting and other health physics controls are left in place during l
this work interruption.
I apologize for any inconvenience this work interruption may cause you. Union l
Carbide is working diligently to resume the remedial action and I will keep you t
l informed of the project status.
If you have any questions or require further information, please contact me.
While I am traveling today, please contact Jim Moon at (614) 374-5777.
j Sincerely,
<d.
l Jay. Davis i
Project Manager JWD/sw via FAX 708-790-5665 cc: Jim Moon, UCC Jack Frost, Umetco John Hamrick, Umetco Curt Sealy, Umetco Rod Dement, Elkem Richard Brown, U.S. Ecology ATTACHMENT B PAGE_/_ of_!_ PAGES