ML20135B813
| ML20135B813 | |
| Person / Time | |
|---|---|
| Issue date: | 08/30/1995 |
| From: | Weber M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20135B362 | List:
|
| References | |
| FOIA-96-529 NUDOCS 9703030209 | |
| Download: ML20135B813 (1) | |
Text
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1 From:
Michael F. Weber
( MFW ) / El./ /-
To:
TW4 :ilMS 1 : HMS 3 : Cli1 : CH 2 :WGS MJN6/// E/
I Date:
Wednesday. August 30. 1995 6:26 pm
Subject:
Engelhard -Forwarded -Reply 1
Thanks for-the clarification.
In short, your message is that NRC is involved in both Engelhard and Chevron.
That is important E
because we have jurisdiction for source material under the Atomic Energy Act.
I agree with the view that we might excercise 1
discretion and not get involved if the contamination were <
j 0.05%, but that needs to be a conscious decision by NRC.
In our review, fit sounded as if we were simply deferring to the State, i
even though they lacked jurisdiction (Ohio is not yet an L
Agreement State).
If I have bolixed something in my summary, please clarify.
Mike I
I J
From:
William G.
Snell (WGS) i To:
CH1:HMS3:llMS1:TW4:TW7:MFW r
Date:
Thursday, August 31. 1995 7:39 em
Subject:
Engelhard -Forwarded -Reply -Reply 4
Mike.
i Your understanding is correct.
4 Bill l
9703030209 970221 PDR FOIA BABCOCK 96-529 PDR
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Septemb'r 28, 1995 e
Chevron Chemical Company Environmental & Health Protection ATTN: Mr. R. William Potter Senior Environmental Projects Engineer 6001 Bollinger Canyon Road P,0. Box 5047 i
San Ramon, CA 94583 i
SUBJECT:
RADIATION PROTECTION INSPECTION ON SEPTEMBER 7, 1995
Dear Mr. Potter:
This refers to the special inspection conducted by Messrs. Raymant Glinski and John House of this office on September 7,1995; and to the telephone conversation between Mr. Joe Davis of Foster Wheeler Environmental Corporation and Mr. William Snell of this office on September 11, 1995. This inspection included a review of the activities involving the remediation of former Harshaw Chenical Building Plant C at 1000 Harvard Avenue, Cleveland, Ohio. At the conclusion of the inspection, aspects of the inspection were discussed with members of the onsite contractor personnel.
The areas examined during this inspection are identified in the enclosed report. Within these areas, the inspection consisted of interviews with personnel, selective examination of representative records, assessment of radiation protection training, and observation of decontamination and radiation protection practices. The inspectors also toured the Plant "C" building.
No violations of NRC requirements were identified during the course of this inspection.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC Public Document Room.
We will gladly discuss any questions you have concerning this inspection.
Sincerely, O ttt w l 5 % c}
W'.
c'Co larh, Chief Decommissioning Section Project Code: 687
Enclosure:
Inspection Report
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DATE 09/d/95 09h.h5 k2f/95 09/zs/95 O(fOOO [OQy
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l U.S. NUCLEAR REGULATORY COMMISSION REGION III.
Project Code: 687 Docket No. None j
License No. None 4
Owner:
Chevron Chemical Company 4
Inspection At:
Former Harshaw Chemical Building Plant C 1000 Harvard Avenue i
Cleveland, Ohio Onsite Inspection Conducted: September 7, 1995 Inspection By:
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[-" M M Rayinant L. Glinski Date Radiation Specialist l
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Senior Radiation Specialist 4.
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,43/,e Approved By:
J. W.
McCormick-B#ger, Chief Dite DecommissioningSfetion Insoection Summary
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j Insoection on September 7. 1995 Areas Insoected: This was a special inspection to assess the radiation protection training and practices conducted for the decommissioning activities i
at the former Harshaw Chemical Building Plant C.
The inspectors also observed decontamination activities and examined instrument calibration records.
Results: All aspects of radiation protection and calibration were determined to be in compliance with NRC regulations and the NRC approved Decommissioning Plan.
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DETAILS
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Persons Contacted 1.
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- Rick Storey, Foster Wheeler Field Operations Leader
'SJoe Davis, Site Health and Safety Coordinator 9 Individual present during th'e telephone conversations.on July 20 and.
September 11, 1995.
- Individual present during the inspection on September 7,1995.
2.
Backaround Natural uranium was used in the prod'Jction of uranium hexafluoride for 4
the Manhattan Engineering District and Atomic Energy Commission (AEC) in the 1940's and 1950's at this site. Building C was the main-processing building, and is made of brick & concrete with one, two and three-story 1
sections, of 66,500 ft".
Building C was decommissioned by the Harshaw Chemical Company and released from AEC control in 1960. Currently, the Engelhard Corporation owns the entire site except for Building C, which is owned by the Chevron Chemical Company.
From 1976' through 1972, surveys of this site were conducted by Argonne National Laboratory for the Department of Energy (DOE). These surveys identified residual uranium contamination in excess of NRC release limits within Building C.
In 1992, Chemical Waste Management conducted additional surveys of Building C for Chevron and confirmed the existence of considerable uranium contamination in excess of NRC release limits.
t Because DOE determined that they had no further responsibility for the site, Chevron assumed responsibility for the'remediation of Building C.
In June 1995, the. Decommissioning Plan for Building C was approved, with work beginning in July 1995.
3.
Trainina.
The inspectors interviewed the Field Operations Lead and determined that his past training and experience in radiation protection as a senior i
health physics technician were adequate to fulfill the duties of his current position.
q The inspectors examined the radiation protection training manual distributed to the radiation workers and were informed that this course involved six hours of classroom work. The content of this training i
appeared adequate to meet the training requirements specified by the
" Radiological Health and Safety Plan for the Building i
Decontamination / Decommissioning at the Harshaw Chemical Site Plant-C".
In addition, the workers received two hours of training on the Health and Safety Plan.
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Discussions with the Health and Safety Coordinator indicated that he had i
the authority to determine the level of training for site personnel.
Depending on the scope of work to be performed, he could waive the six hour formal training course. A review of the Health and Safety Plan
-confirmed-that he had this authority. The Health and Safety Plan also stated that training for all field personnel, including subcontractors, 1
would be provided to specifically address their activities.
No violations of NRC requirements were identified.
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Radiation Protection Practices c
i The inspectors interviewed the Field Operations Lead and other staff l
about the site-specific radiatia protection practices and the Radiation Work Permits (RWP) under which the laborers were working. The following information was obtained during the interviews:
o A urine sample for bicassay had been obtained from each worker before starting work at the site, and arrangements were available to collect and analyze urine samples from workers after a suspectesi intake of contamination.
The current RWP required a hard hat, safety glasses, coveralls,-
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shoe covers, and gloves. Rubber gloves were required for working with wet material.
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The floor areas and equipment being decontaminated were kept wet o
i to inhibit the generation of airborne contamination.
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o Hoods and respirators were' required for specialized decontamination activities.
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The entire Building C was considered a Radiation Control Area (RCA).
o Workers were required to sign-in and sign-out on the RWP log sheet each time they entered and exited the RCA. A review of several of the log sheets indicated that logs for August 5-6, 1995 appeared
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missing.
It was subsequently determined that new sheets had i
inadvertently not been posted for the weekend of August 5-6, 1995.
As a result, workers signing in over the weekend had signed in on the Friday, August 4, 1995, sign-in log. The Health and Safety i
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Coordinator indicated he would be more diligent in ensuring new log sheets we,re posted in the future.
Workers conducted whole body frisks prior to removal of protective o
clothing (PC), and after removal of PC a hand and foot frisk was conducted.
The inspectors observed that the radiation protection practices were being adequately implemented by the workers,
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The two RWPs written to date were reviewed.and they appeared to be i
sufficient for the radiological' condition of the RCA. The inspectors discussed with the staff the need to issue another RWP if the e
decommissioning work resulted in increased removable or airborne radioactivity.
Radw'aste was being temporarily stored in marked bags within the RCA.
No violations of NRC requirements were identified.
5.
Instrument Calibration 'and Checks The inspectors noted that the radiation detection instruments were in calibration and that daily performance checks were being conducted. The certificates for the check sources and the daily source check logs were examined and found to be sufficient.
No violations of NRC requirements were identified.
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Exit Meetina 3
An exit meeting was conducted on September 7,1995, with the individuals -
specified in Section 1 of this report. The preliminary results of the inspection were discussed. The licensee did not identify any
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information as, proprietary.
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