ML20135B857
| ML20135B857 | |
| Person / Time | |
|---|---|
| Issue date: | 10/19/1995 |
| From: | Mccormick NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Kopas A ENGELHARD CORP. |
| Shared Package | |
| ML20135B362 | List: |
| References | |
| FOIA-96-529 NUDOCS 9703030241 | |
| Download: ML20135B857 (1) | |
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- October 19, 1995 ,
l Engelhard Corporation Chemical Catalysts Group .
l ATTN: Mr. A. G. Kopas, Manager Environmental Services !
120 Pine Street P.O. Box 4017 ,
i Elyria, OH 44036-2017 i
SUBJECT:
. SITE CHARACTERIZATION PLAN (PHASE II) REVIEW ,
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Dear Mr. Kopas:
We have completed our review of your Site Characterization Plan (Phase II) submitted to us by letter dated October 6,1995, for your site at 1000 Harvard Avenue, Cleveland, Ohio. Mr. William Snell of my staff discussed the Plan {
with Mr. Ted Adams from B. Koh & Associates on October 17, 1995. We found the Plan acceptabic and have no additional questions.
If you have any questions or comments, please contact me at (708) 829-9872 or William Snell at (708) 829-9871.
1 Sincerely, l
, Original-Signed By l
J. W. McCormick-Barger, Chief Decommissioning Branch cc: M. Weber, NMSS/DWM/LLDP i
R. Vandegrift, Ohio Department of Health '
i DOCUMENT NAME: A:\ENGLHARD.II h
OFFICE RIII O RIII M O-NAME Snell 8 McBarger DATE 10/18/95 10/#/95 0FFICIAL RECORD COPY 9703030241 970221 PDR FOIA
,, BABCOCK 96-529 PDR
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i' November 13, 1995
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! Chevron Chemical Company Environmental & Health Protection ATTN: Mr. R. William Potter. 1 Senior Environmental Projects Engineer l 6001 Bollinger Canyon, Road P.O. Box 5047 San Ramon, CA 94583 -
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SUBJECT:
RADIATION PROTECTION INSPECTION OF THE RENEDIATION OF FORMER l HARSHAW CHEMICAL BUILDING PLANT.C IN CLEVELAND, OHIO (CHEVRON i SITE) l
Dear Mr. Potter:
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This refers to the spe'clal inspection conducted by Messrs. William Snell and John House of this office on October 24-25, 1995. This inspection included a !
review of the_ activities involving the remediation of former Harshaw Chemical Building Plant C at 1000 Harvard Avenue, Cleveland, Ohio. At the conclusion ;
of the inspection, aspects of the inspection were discussed with members of j the onsite contractor personnel from Foster' Wheeler Environmental Corporation. t
- *; The areas examined during this inspection are identified in the enclosed report. Within these areas, the inspection consisted of interviews.wH' l personnel, examination of representative records, and observation of '
decontamination and radiation protection practicer The inspectors r N .
toured the Plant C building. ;
During the course of this inspection, it was detemined that an aspect of the radiation protection program was not being implemented consistent with the requirements of 10 CFR Part 19.13(e). Specifically, an actual or estimated !
record of radiological exposure was not provided to an employee upon request when the employee was terminated. Because you or your contractor, Foster Wheeler Environmental Corporation, are not NRC licensees, this is not considered a violation of NRC requirements. However, we are concerned about this issue. j Although it has been the NRC's policy to agt require non-licensed site owners 1 or their contractors to possess an NRC license to conduct decommissioning '
l work, we do expect that the radiological controls program will implement and
!t comply with the NRC's regulatory requirements in 10 CFR Parts'19 and 20. ;
. Therefore, please provide a written response withi.n 45 days from the date of l this letter as to what actions will be taken to ensure exposure records, if ;
requested, will be provided upon the temination of an employee.
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i Chevron Chemical Company ;
e In accordance with 10 CFR 2.790 of the Commissicn's regulations, a copy of ;
this letter and the enclosed inspection report will be placed in the NRC ,
Public Document Room.
l We will gladly discuss any questions you have concerning this inspection.
Sincerely, l Original Signed By '
J. W. McCormick-Barger, Chief ~
Decommissioning Branch !
Project Code: 687
Enclosure:
Inspect ~ ion Report cc w/ enc 1: R. Vandegrift, Ohio Department of Health ,
J. Davis, Foster Wheeler Environmental Corporation ,
bec w/ encl: M. Weber, NMSS :
P. Goldberg, NMSS l i
PUBLIC (IE07) a -.
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DOCUMENT NAME: A:\CHEYCHEM.DNM c - c , . c ,. am g
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0FFICE RIII C RIII snf RIII@ff) b NAME Snell/ca# House M McBaker l DATE 11/> /95 11/cff95 11/g/95 0FFICIAL RECORD COPY l
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l U.S. NUCLEAR REGULATORY COMMISSION i
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REGION III-
- Project Code: 687 !
i Docket No. None License No. None
-Owner: Chevron Chemical Company .!
Inspection At: Former Harshaw Chemical Building Plant C !
1000 Harvard Avenue i Cleveland', Ohio Onsite Inspection Conducted: October 24-25, 1995 --
- 1 Inspection By: '
W 8 ohn E. Honse ' D' ate !
pSeniorRadiationSpecialist l
1 l b 001 C.C- Ok u /3}9f Wfiliam G. Snell Date Senior Radiation Specialist N
Approved By: IN. bA 18 /t 3/15-(fl. W. McComick-B'argerf Chief 'Date Decommissioning Branch Inspection Summary '
Inspection on October 24-25. 1995 Areas Inspected: This was a routine inspection to assess the radiation protection program and practices conducted for the decommissioning activities at the former Harshaw Chemical Building Plant C. The inspectors also observed decontamination activities and examined radiation protection program records.
Results: In general, the radiation protection program and practices were determined to be acceptable. However, two issues were identified that require action. The first involved the failure to provide an actual or estimated record of radiological exposure to an employee upor, request when the employee was teminated as is required by 10 CFR Part 19.13(e). The second issue involved an inconsistency in the Health and Safety Plan as to when urinalyses
, are required.
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! DETAILS l i ;
'1. Persons Contacted l
Joe Dav'is, Health and Safety Coordinator, Foster Wheeler Environmental' ;
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_ Corporation '
Ferdinand Rock, Midwest Remediation Manager, Foster Wheeler . ;
Environmental Corporation '
. Rick Story, Field Operations Leader / Operator, Foster Wheeler Environmental Corporation :
Frank Talbot, Health Physicist, Ohio Department of Health .
The'above individuals were present during the inspection on I October 24-25, 1995. >
- 2. Backaround -
Natural uranium was used in the productio'i of uranium hexafluoride for ;
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 sections, of 66,500 ft'. Building C was decommissioned by the Harshaw l Chemical Company and released from AEC control in 1960. Surveys i conducted during the 1970's and 1990's determined that Building C, as ,
well as other areas of the site, were still contaminated in excess of l NRC regulatory limits. Currently, the Engelhard Corporation owns the entire site except for Building C, which is owned by the Chevron .
3 Chemical Company.- l 1
In' June 1995, Chevron's Decommissioning Plan for the decontamination and j demolition of Butiding C was approved by the'NRC, and remediation.
activities began in July 1995.
- 3. Current Status To date, the facility has been characterized, with the extent of contamination greater in scope then originally anticipated. The primary area of additional contamination discovered was where a one to two inch concrete floor was poured over an existing floor. Between these two layers of concrete considerable loose contamination has been found.
At the time of the inspection, almost all overhead pipes and wiring had been taken down. These materials were being stored within the building until a formal procedure for surveying the material for release was developed.
The inspectors were able to observe initial testing of a steel shot scabbling machine that had been acquired for decontamination efforts.
The system could support up to five scabbling hoses operating simultaneously.
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.e l 4. Radiation Protection Practices The inspectors interviewed the contractor individuals identified in Section 1 about the site-specific radiation protection practices, radiological surveys, and the control and free release of contaminated i equipment and materials. In addition, records and documentation of
- surveys, instrument calibrations, air monitor samples, and Radiation Work Permit (RWP) sign-in sheets were reviewed. A tour of the facility was also conducted. The following information was obtained during the j tour, records review, and interviews
The access control point was clean and well organized with two i portable survey instruments available for frisking. Sufficient i
' supplies for suiting out in personal protective clothing as !
required (e.g., booties, gloves, tape,.etc.) were available. RWPs I
were posted and sign-in sheets indicated personnel were signing in i as required. NRC Form 3, #ctice to Workers, was also --
l conspicuously posted adjacent to the RWPs.
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.The tour of the building indicated that contamination was being adequately identified and controlled. An onsite laundry had been l l
established with all water being filtered and reused or stored l
pending authorization from the Northeast Ohio Regional Sewer District that it could be released to the sewer.
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A review of survey records indicated that surveys are being
- conducted as required and more. . Records for the access control l point indicated surveys were being conducted two to three times a
, week on average, although required only weekly. !
. - The only material that had been free released from the site had i been no-longer needed tools / equipment, and items with salvage i value such as old lockers and some scrap metal. A rtview of survey records indicated all these items had been ' surveyed, F decontaminated where necessary, and ~ resurveyed, prior to release.
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During a September 7, 1995 inspection, a concern was identified )
i regarding workers signing the sign-in and sign-out RWP log sheet each time they entered and exited the RCA. This was primarily due i
!. to the failure of having the appropriate log sheets posted for !
use. A review of the log sheets indicated that personnel had been ;
} signing in and out as required since that time. i A review of the air monitoring reports indicated that background
, varied from 0.26 counts per minute (cpm) to 0.89 cps, based on a
- daily calculation. The minimum detectable activity (MDA) of the l detector, also detemined daily, was calculated to be 0.26 to 0.30 ;
- cpm. Because the MDA was within the range of the background !
i measured, the inspectors questioned the appropriateness of the '
1 detector or the length of the count times. The contractor stated :
- that he would look into the issue.
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A review of. instrument calibration re.:ords indicated that e calibrations were current and instruments were source checked as :
. required.
. All workers observed during the tour of the facility appeared to .:
be wearing the proper personal protective clothing for the work 4 they were performing.
~5 . Urinalysis and Dose Records The Health and Safety Plan provided conflicting information on the requirements for urinalysis. Section 6.10, Radiation E'xposure Records, i states that personnel Bay be required to complete urinalysis testing at '
the start and completion of the project. However, Section 8.3.5, l Urinalysis, states urinalysis shall be performed )rior to the start of l site activities and upon termination of work in tie Exclusion Zone. The Health and Safety coordinator indicated that he could have urinalysis i performed on an as-needed basis, but in fact they had performed them on -i all personnel. This inconsistency in the Health and Safety Plan should ,
be corrected. j A review was made of dose records to verify if personnel who had been )
terminated had received their dose record. 10 CFR Part 19.13(e) j requires that an act'ual or estimated record of radiological exposure is l provided to an employee, upon request, when the employee is terminated. l The contractor stated that they had one employee who was terminated request a copy of his dose record. The contractor believed he had 30 days with which to provide the information. Because the contractor, Foster Wheeler Environmental Corporation, is not an NRC licensee, this is not considered a violation of NRC requirements..
- 6. Exit Meetina An exit meeti,ng was conducted on October 25, 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 information as proprietary.
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