ML20127J968
| ML20127J968 | |
| Person / Time | |
|---|---|
| Issue date: | 01/20/1993 |
| From: | Bouwens M, Kinneman J, Roberts M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20127J967 | List: |
| References | |
| REF-QA-99990001-930120 99990001-92-29, NUDOCS 9301260010 | |
| Download: ML20127J968 (10) | |
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' U.S. NUCLEAR REGULATORY COMMISSION REGION I Repon No.
99990001/92-022 License No.
None Non-Licensee:
United Technologies Pratt &_Whilo;.y Aircraft Road Middletown. Connecticut Facility Name:
Pratt & Whitney Inspection At:
Building 450 hiiddletown. Connectitui Inspection Conducted: November 16 and 17.1992 Inspectors:
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Mark C. Roberts date Senior Health Physicist
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w-Mark R.- Bou' wens date Health Physicist Approved by:
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l-to -h oh D. Kinneman, Chief date es rch, Development and Decommissioning Section Inspection Summary: Routine. unannounced safety inspection conducted November 16 and 17.
1992 (Inspect!on No. 99990001/92-029)
Amas Inspected: Follow-up on open items from August 24, 1992 inspection; organization, scope and status of decommissioning activities; training and instructions to workers; facilities and equipment; personnel radiation protection - external; personnel radiation pmtection -
internal; radioactive effluents; contamination contml and area surveys; postine snd labeling; waste storage, shipping and disposal; surveys of other site buildings.
Results: No violations were identified.
9301260010 930120 PDR GA999 EMVUNTE 99990001 PDR' T~FICIAL RECORD COPY i m n w a ul ro IE:o"'
REG 10ill
4 DETAILS 1.
Persons Contacted
- John Engle, Plant Engineer - hianufacturing Operations, Pratt & Whitney _
- William Everett, Supervisor Facility Engineering, Pratt & Whitney
- David Alberghini, Plant Safety Engineer, Pmtt & Whitney
- K. Paul Steinmeyer, President, Radiation Safety Associates, Inc.
- Jeffrey Adams, Project hianager, Environmental Sciences, hiiddletown Site, C.T. hiain John Dowling, Project Engineer - Building 450 Constmetion, Pratt & Whitney Paul R. Steinmeyer, Health Physics Supervisor, Radiation Safety Associates, Inc.
John Rotchford, IIealth Physics Supervisor, Radiation Safety _ Associates, Inc.
Paul Suroviak, Senior Heahh Physics Technician, Bartlett Nuclear hiark Jones, Sub-contractor Supervisor, Jones Demolition, Inc.
Dennis Galloway, State of Connecticut, Department of Environmental Protection (via telephone)
- Denotes those present at exit interview.
===2.
Background===
Pratt & Whitney Corporation has operated the site in hiiddletown, Connecticut since 1957. Originally the site was owned by the government and operated under contract, but was purchased by the company in 1966 from the Govemment Services Agency. The site was originally used for research and development activities with radioactive material, but more mcently for manufacturing multi-curie cesium 137 (Cs 137) and cobalt-60 (Co-60)-
sources. This latter activity was authorized under an Atomic Energy Commission (AEC) license issued in 1966 and terminated in 1971. When the license was terminated, residual Cs-137 and Co-60 contamination remained in Building 450. This building, located at the far northern end of the site, houses a series of seven hot cells that were used for research and development and source manufacturing. While a few'other site buildings were authonzed locations of use on the AEC license and many other buildings were used or potentir.lly used in the earlier mscarch and development activities, this inspection primarily concemed the decommissioning of Building _450.
A detailed survey of Building 450 was performed in June 1992 by Pratt & Whitney's radiological contractor, Radiation Safety Associates, Inc. (RSA), A copy of this report and a decommissioning plan prepared by RSA were submitted to Regie: I. Region I reviewed the plan and Pratt & Whitney modified the plan in response to NRC comments.
Although no NRC license now covers Building 450, Pratt & Whitney and their contractor agreed to conduct the decommissioning of the facility in accontance with applicable regulations in 10 CFR 19 and 20 and the written decommissioning plan. Pratt &
Whitney a'so agreed to conduct radiological surveys of other site buildings that may have
- been contaminated with radioactive materials from past licensed operations and msearch and development operations conducted during the time peried that the facility:was operated under contmet.
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Pratt & _ Whitney plans to partially demolish Building 450 and use the structural steel r.ame of the building to construct a new warehouse. Pratt & Whitney is conducting the decommissioning of this building in accordance with the facility decommissioning plan submitted to the NRC on July 8,1992 and additional information received on July 14, 1992. The plan was also amended to incorporate-a procedure for the removal of contaminated discharge piping leading from Building _450 to a remote valve pit and to incorporate the partial demolition of the walls of the hot cells to facilitate removal of contaminated pipes and contaminated steel plates that were not accessible by routine decontamination. The decommissioning activities were previously inspected on August 24,1992.
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Follow-up on open items fmm August 24.1992 Inspection (Closed) Inspection No. 99990001/92-020, posting of NRC Fonn 3 and the notice required by 10 CFR 19.11 (b) in the vicinity of the Building 450 decontamination activities. Pratt & Whitney had agreed to post the above referenced documents and had 4
provided telephone conGnnation that the documents had been posted. However, the inspector had not visually connrmed the posting of the documents prior to exitig the site due to the remote location of Building 450. During this current inspection, the impcctors confirmed the posting of the referenced documents.
(Closed) Inspection No. 99990001/92 020, documentation of air efuuent measurement methodology.
INring the August 24, 1992 inspection, the inspector reviewed the -
effluent measurement technique and found the method actually followed acceptable; however, the method was not completely documented in the written. pmcedure.
Following the August 24,1992 inspection, Pratt & Whitney sent an updated procedure that suf0ciently documented the methodology that was being employed.
(Closed) Inspection No. 99990001/92-020, contaminated pipe removal plan. During the.
decontamination of isolated spots of contamination in the waste tanks outside Building 450, small amounts of contamination were measured on the discharge piping leading-from the tanks to a distant valve pit. The original decommissioning plan did not address t
removal, survey and decontamination of contaminated piping found outside the building.
During the August 24,1992 inspection, the inspector examined the locatious where the.
piping was located and requested that Pratt & Whitney sene an addendum to the i
decommissioning plan that addressed the removal, monitoring and decontamination of this piping. This information was subsequently sent to Region I on September 9,1992.
' die NRC found the informatica acceptable.
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-Organization. Scoce and Status of Decommissioning Activities The overall decommissioning of Building 450 and the survey of other buildings where radioactive material was previously used is administratively supervisxt by individuals from the Pratt & Whitney engineering staff. These individuals ensure that the contractor has the necessary site resources to complete the project. The primary contractor, Radiation Safety Associates, Inc.-(RSA), provides the technical management and supervision for the decontamination project.
The staff of _ RSA' prepared 'the decommissioning plan and subsequent addenda to the plan. In support of the project, RSA has written health physics procedures and provided training to workers. Personnel from RS A provide project supervision and some of the necessary health physics services.
Various subcontractors provide additional health physics support and demolition services for the project.
During the decontamination and removal of the waste tanks in the pit on the east side of-Building 450, radioactive contamination surveys indicated residual fixed contamination in the piping leaving the tanks. This contamination was not identified in the initial chameterization since the waste tanks were still in place.
During the inspection conducted August 24, 1992, the inspector requested that Pratt & Whitney submit an addendum to their decommissioning plan to address the removal, survey and decontamination of this piping. On September 9,1992, Pratt & Whitney transmitted an acceptable addendum to the plan. The addendum discussed removal of approximately 1,000 feet of pipe, cutting and splitting the pipe into pieces small enough to be surveyed and decontamination of the pieces that did not meet the release criteria. At the time of this inspection, approximately 1,200 feet of piping has been removed. Contamination found has been very small (maximum of a few hundred counts per minute with a GM survey meter), very spotty and fixed on the inside surfaces of the pipe. Approximately twenty per cent of the pipe has some contamination. Suiveys performed during the pipe 4
excavation do not indicate any contamination of soil in the areas where pipe has been removed.
A subcontractor has been decontaminating the walls, ceilings and floors of the hot cells with various pellet blasting techniques and hand-operated, air-powered decontamination-tools. These decontamination methods have been effective for accessible areas within the cells. However, radiological surveys identified contamination within small diameter penetrations in the cell walls and on the back of the steel plates lining the lower portion-of each of the cell walls. The techniques described have not been able to remove this fixed contamination. In order to complete decontamination of the inaccessible areas, Pratt & Whitney requested that they be able to demolish the walls of the hot cells with heavy equipment and segregate contaminated objects for decontamination or disposal.
Region I staff concurred with the need to remove the walls to make the contaminated-i areas accessible and requested that Pratt & Whitney submit an addendum _ to the decommissioning plan that_would describe the methodology to be used. On October 2, 1992, Pratt & Whitney submitted their plan for removing the walls. The plan included
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identifying contaminated or potentially contaminated steel plate and pipes with spray paint; knock.ing down small sections of the walls; recovering any contaminated pieces; and surveying the remaining mbble to ensure contaminated material was not inadvenently disposed as clean waste. Region I found the plan acceptable.
At the time of the inspection, the north, south and east walls of the hot cells had been demolished and the debris surveyed and removed or stockpiled for decontamination.
Contaminated pieces of metal were surveyed to identify the location of surface contamination and decontaminated prior to disposal as clean waste.
The west wall, a long wall common to all of the hot cells, is not able to be removed at this time since this wall, which is constmeted of reinforced concrete, provides support for the stmetural steel of the second floor and roof. In order to remove this wall and thus remove the contamination present in penetrations and steel liner plates, temporary support columns need to be constructed to suppon the second floor and roof. In order to suppon the temporary columns, concrete must be poured into the pit areas of each of the hot cells. Pratt & Whitney provided preliminary surveys for the pit areas for three of the seven cells (cells 1,2 and 7) and requested that Region I release these areas for unrestricted use. The results indicate that there are small spots of fixed contamination 2
in the base of the cells exceeding 5,000 dpm/100 cm, however, the results do not exceed 5,000 dpm/100 cm when averaged over one square meter. The inspector informed the 2
Pratt & Whitney personnel that the areas could be filled, but the data provided should be eventually included in a summary report for the decommissioning of the entire building. The Pratt & Whitney staff intends to send survey data to Region I for the remaining cells so that these cells may also be released for unrestricted use.
The large shield blocks from the roof of each cell were removed by means of a cane and laid down on plastic sheeting on the floor of the building. The roof blocks were to be moved to a decontamination tent under construction adjacent to the Building 450. The blocks have very low levels of find contamination and no removable contamination.
Hand-held scabbling devices are being used to decontaminate the block surfaces.
No safety concems were identified.
5.
Training and Instructions to Workers During the August 24,1992 inspectica, routine training and instmetions to workers were reviewed and found to be acceptable. During this inspection, the inspectors specifically examined the training and instmetions provided to the workers employed by the demolition subcontractor Due to their limited involvement with radioactive materials, the demolition workers were given a shoner orientation lecture that included, but was not limited to: biological effects of radiation exposure, radiation detection, contamination control, radioactive waste and exposure control. These workers were not required to take the radiation worker examination. Continuous health physics coverage was provided l
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6 for activities perfonned by these workers.with radioactive materials.
The work performed by the demolition subcontractor was limited to operating heavy equipment to -
knock down the walls of the hot cell and removing the clean concrete mbble and metal scrap. - Materials were surveyed by health physics personnel prior to release, disposal as radioactive waste or stockpiling for future decontamination. The inspectors reviewed the training outline for these workers and detennined that the infonnation presented was appropriate and sufficient to allow directly supervised work with radioactive materiais.
The inspectors discussed the training received by the demolition workers with the supervisor of these workers and concluded that the training was adequate preparation for the work being perfonned. The demolition supervisor stated that he and his workers had numerous questions prior to the start of this project, but the health physics staff has been able to appropriately answer all their questions and make them feel comfortable with the work that they were doing.
No safety concerns were identined.
6.
Eacilities and Eauipment Facilities and equipment are appropriate for the project. Sufficient numbers of calibrated poitable radiation survey meters are available for contamination and radiation measurements. Three survey meters were selected at mndom (3 Ludlum Model 19 Micro R-meters, Serial Nos. 95509, 95406 and 32873) to check each instrument's operability and calibration reconis. The instmments appeared to be properly operational and the calibration records were complete. The designated calibration frequency for the instruments were intervals not to exceed twelve months. The oldest calibration date for any of the instruments was Febmary 21,1992, approximately nine months prior to the inspection. Appropriate calibration stickers were affixed to the instmments, Tempomry trailers are used as an ofGce for project coordination and health physics measurements, waste storage, decontamination and stockpiling of materials for decontamination. All trailers are locked when not actively being used. A calibrated scaler / detector (Bicron FRISK-TECH) is used in the health physics trailer for counting smears and air samples. This device is used to count the smears for the final release surveys for each of the cells.
The instrument was initially calibrated by the manufacturer. Sources traceable to NIST (NationalInstitute for Science and Technology) are used daily to check the instrument perfonnance. The measured efGciency for the device is approximately 16 per cent. Background counts are perfonned daily. The inspectors reviewed selected records for this instrument and found all information to be complete and confinned the accuracy of the efGciency calculations.
r Decontamination of metal scrap is conducted in a tmiler that has been speciGcally set op for decontamination operations. Prior to commencing decontamination activities, the L
inside of the trailer was covered with plastic sheets to protect the wooden interior.
Separate areas were set up in the trailer for performing cutting, surveying and d
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M-7 decontamination. Decontamination of metal pieces is conducted with grinding tools in one of two hoods. Air is exhausted from the hoods through HEPA Hitration systems.
HEPA filtered vacuum cleaners are used to collect paniculates generated from the grinding operations.
No safety concerns were identified.
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Personnel Radiation Protection - External Personnel monitoring is conducted using thennoluminescent dosimeters (TLD's) from Teledyne Isotopes (Model PB-5), a NVLAP certified dosimetry supplier. Workers were observed to be wearing assigned dosimetry. Badges are scheduled to be exchanged at -
three-rnonth intervals. Results from the first monitoring period indicated all exposures were less than the minimal detectable level of 10 millirem.
No safety concems were identified.
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Personnel Radiation Pny;clion - Internal Prior to starting work on the project, individuals were given a pre-employment whole body count. Whole body counting was perfonned for the contractor at the Connecticut Yankee nuclear power station which is not far from the Pratt & Whitney site. Whole body counts are reviewed by the contractor. The inspector examined selected whole body count records and all showed only typical amounts of naturally occurring potassium-40. Post-project whole body counts are also performed on personnel. A review of selected post-project repons also indicate only naturally occurring potassium-40.
Activities requiring the use of respirators have not been perfonned recently. Workers perfonning surface decontamination on steel plates and piping perform their work in a hood that exhausts through a HEPA filter system. Work areas are periodically cleaned with a HEPA filtered vacuum cleaner. Air samples taken in the work area have not indicated the need for respiratory protection during decontamination o}xmtions.
No safety concerns were identified.
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Radioactive Effluents Dust and particulate contamination generated during the decontamination processes uc controlled close to the source to prevent exposure of workers and prevent the release of material to the environment. Air samples taken in the geneml area of the effluent from the vacuum cleaners have not indicated any release of radioactive particulates.
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8 Radioactive effluents from the abmsive decontamination activities in the decontamination trailer are controlled by exhausting the inside air through a llEPA filter system.
3 Available !! EPA Gltration systems include a 5,000 ft'/ min unit, a 500 ft / min unit and two 750 ft / min units. Effluents are evaluated by collecting air samples a few feet 2
downstream of the HEPA filter exhaust. Air samples are typically collected and analyzed at least once each shift. Results obtained thus far do not indicate any significant release of radiological particulates. General area smears taken approximately twice per week include locations near the IIEPA fdter exhaust. The results from these smear samples have not indicated contamination around the llEPA filter exhaust.
The efnuent monitoring method is completely documented in the written sun'cy procedure.
No safety concerns were identified.
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ContamiJ1atian ConJmlamLArealvmys Entry to the decontamination trailer is controlled by a step-off-pad and a radiation rope boundary. Protective clothing requirements for da:ontamination work include coveralls, hats, boots, face shields and double gloves. Air sampling is perfonned to detennine the need for respiratory protection, however, airborne activities have been are sufficiently low enoegh to preclude the need for respiratory protection. Since only small amounts of fixed contamination remain in the hot cells, contamination control measures are only required when direct contact of the areas is likely.
Contamination and mdiation surveys are conducted daily in areas where work is perfonned. General area surveys are conducted twice per week. Sun'eys are also conducted on the large constmetion equipment used in the demolition of the walls. The results obtained thus far do not indicate the sp:ead of contamination outside marked areas. The results of all surveys, calibrations and perfomiance checks are reviewed on a weekly basis by a second health physicist as a quality check.
No safety concems were identified.
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Emling and Labeling Entry to the waste storage trailers and the decontamination tmiler are properly posted with Caution, Radioactive Ma'erials signs.
Fomi NRC-3 and an appropriate note indicating where documents recuired by 10 CFR 19.11 could be found were both posted in the health physics trailer.
No safety concerns were identined.
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Waste Storage. Shio. ping and Disposal Radioactive waste generated thus far is stored in standard 7.5 ft' dmms in a locked trailer. Fifty-eight drums were filled and sealed and awaiting shipping for disposal. The contractor estimated that the remaining radioactive wastes on site would fill another twenty drums. All waste is expected to be shipped to the U. S. Rology facility in Richland, Washington for disposal in late December 1992.
Concrete rubble genented as a result of the demolition of the walls in Building 450 is surveyed prior to release for unrestricted disposal. This material is presently being-recycled by a local concrete company. Clean steel plate, piping and reinforcing bars are sent to a steel recycling facility. The demolition company, Jones Destniction, Inc.,
retains some of the stmetumi steel, copper and miscellaneous metals for future recycling.
All of these materials are surveyed by health physics technicians prior to release.
Records are not kept for clean material that is released. Records are retained for materials that have been decontaminated. The decontamination technique employed for the steel and other recyclable materials and other debris has been appropriate for the material removed so far. Fixed contamination is readily removed by means of electrical hand tools and the loose contamination is collected in a HEPA-filtered vacuum cleaner.
Protective clothing for this project is supplied by INS in Springfield, Massachusetts, Used clothing is generally _ uncontaminated, but does require laundering. The used protective clothing is shipped in standard 7.5 ft' dnims as Low Specific Activity, N.O.S.
waste to the laundry facility. The shipment is placarded as Radioactive. The contractor has made five laundry shipments thus far.
No safety concerns were identified.
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Surveys of Other Site Buildings In previous discussions with the NRC, Pratt & Whitney had agreed to survey the buildings on the site that may have been previously used for research and development activities with radioactive materials. Twenty-two buildings on site were identified as having been in use during the time period when esearch and development activities were being conducted. At the time of the August 24, 1992 inspection, nineteen of these-buildings had been surveyed. Buildings 310 and 330 have been surveyed since the previous inspection and no radiation levels in excess of normal background were i
identified. Building 340 had not yet been surveyed at the time of this inspection.
l No safety concerns were identified.
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10 14, Exit Interview The results of the inspection were discussed with the licensee representatives identified in Section 1 of this report. A representative from the State of Connecticut was contacted by telephone to discuss the results of the sun'ey.
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