ML20199C706
| ML20199C706 | |
| Person / Time | |
|---|---|
| Issue date: | 12/26/1995 |
| From: | Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20198L898 | List: |
| References | |
| 99990004-95-05, 99990004-95-5, SSD, NUDOCS 9901190083 | |
| Download: ML20199C706 (7) | |
Text
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ENCLOSURE 2 i
U.S. NUCLEAR REGULATORY COMMJSSION REGION IV.
Inspection Report:
999-90004/95-05 License: General License (10 CFR 31.5)
Licensee:
City and County of Honolulu Department of Wastewater Management Division of Treatment and Disposal 1350 Sand Island Parkway Honolulu, Hawaii 96819 Facility Name: Waimanalo Wastewater Treatment Plant Inspection At: Honolulu, Hawaii Inspection Conducted: November 13 and 16, 1995 Inspector: 'Emilio M. Garcia l
Approved: 0$M&b/// k w iaan Jn 9bfk5
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fFr&nk A.' Wensl&Wski, Chigf' jV Date Materials Branch Inspection Summary Areas Inspected: Special, announced inspection to review the circumstances surrounding the improper disposal of a 139 microcurie cesium 137 sealed source contained in a electronic compensating cell.
Results:
The inspection confirmed that a 139 microcurie cesium 137 source was improperly disposed in the Kaapa landfill at the Island of Oahu, State of Hawaii sometime'after January:1992 but prior to April 1993. The inspection also established that five additional generally licensed sources were properly transferred to the manufacturer, although the
-licensee failed to report these transfers to the NRC as required. These two items were identified as Severity Level IV violations.
Summary of Inspection Findinos:
Violation (999-90004/9505-01) was opened and closed involving the improper ~ disposal of licensed material (Section 2).
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Violation (999-90004/9505-02) was opened and closed involving the
. failure to report to NRC the. transfer of generally licensed sources l
(Section 2).
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Attachment:
j Persons Contacted and Exit Meeting.:
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- l DETAILS 1 BACKGROUND AND CHRON0 LOGY The City and County of Honolulu operates a' system of wastewater treatment facilities throughout the Island of Oahu.
In the late sixties or early seventies the Waimanalo Wastewater Treatment Plant (WTP), one of these L
facilities, was built for the State of Hawaii by Honolulu Iron Works. At the time of construction Honolulu Iron Works purchased and installed an Ohmart l
series ASR-4 sludge density gauge at WWTP, Serial No. S-909. The Ohmart series ASR-4 sludge density gauge includes two generally licensed cesium 137 sources, a principal source of 1000 millicuries for measuring the sludge density and a 250 microcurie source in the compensating cell that is part of the ASR control system.
The plant, including the Ohmart ASR gauge and sources, was turned over to the State of Hawaii after completion of construction sometime in early 1972.
WWlP has been owned and funded by the State of Hawaii since construction.
'On April 24, 1972, the Department of Public Works and the City and County of Honolulu entered into an agreement with the State of Hawaii to operate and maintain WTP. This agreement is documented in a April 18, 1972, letter from Mr. Sunao Kido, Chairman and Member of the Department of Land and Natural Resources, State of Hawaii, to Mr. Edward Y. Hirata, Director and Chief Engineer, Department of Public Works, City and County of Honolulu.
In January 1992,- as part of an upgrade to WTP, the ASR-4 control panel, including the 250 microcuries cesium 137 source in the compensating cell, was removed and placed in storage at WTP awaiting disposal. The sludge density gauge had not been working for a number of years.
Sometime before April 1993 the control panel, including the 25C microcurie cesium 137 source in the compensating cell, was placed in a trash bin by the then WTP supervisor. He recalls having been told by a technician that this particular control panel did not have a radioactive source. Not all Ohmart sludge der.dty gauge control panels had a compensating cell with a radioactive source.
In_ April 1993, the ASR-4 gauge with the 1000 millicurie source was removed and subsequently returned to Ohmart Corporation for proper disposal. At that time, some of the city and county staff suspected that the compensating cell l.
L with the radioactive source had been lost but they did not realize that they needed to report it to the NR'..
On July 1,1993, as part of a reorganization of the City and County of Honolulu, the operation and maintenance of WWTP was reassigned to the new Department of Wastewater Management and specifically to the Division of Treatment and Disposal (DTD).
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In' early July 1995, as a result of a review of some documents that had been I
transferred to DTD and discussions with a consultant and an official from the 1
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l State of Hawaii Department c: Health, Noise and Radiation Branch, the licensee became aware that the 250 microcuries cesium 137 source in the compensating cell had not been properly disposed and that the NRC needed to be notified.
On July 11, 1995, the licensee telephoned the NRC Walnut Creek Field Office l
(WCF0) to inform NRC of the missing source. Subsequent to this call an
-initial written notification dated July 24, 1995, an interim report dated August 3,1995, and a consultant's report of October 9,1995, were submitted to NRC.
On July 31, 1995, the Department of Public Works, who operates the Kapaa landfill, was informed by the Department of Wastewater Management of the possible disposal of the source in the Kapaa landfill.
2 SOURCE DISPOSAL The inspector reviewed the licensee's and consultant's reports and interviewed DTD personnel to determine the facts surrounding the source disposal.
In January 1992 a contractor for the Department of Public Works removed the entire electronic housing associated with the Ohmart ASR-4 gauge from the Motor Control Center and relocated it to the Blower Building at WWTP.
The housing was being kept because the contractor and the staff at WWTP believed that it contained a radiation source and therefore could not be disposed as normal trash. Accr.rding to the then WWTP supervisor, he repeatedly asked the office of plant engineering at the Department of Public Works to arrange for the disposal of the housing that contained the source but his requests were not acted upon.
Some months later, a telemetry technician employed by the City and County of Honolulu told the then WWTP supervisor that the particular model of sludge gauge that they had at WWTP did not have a radioactive source in the electronic housing. Not all Ohmart electronic housings associate:I with radioactive sludge density gauges have compensating cells with radioactive sources. The telemetry technician does not recall this conversation with the former WWTP supervisor.
Based on this information, the former WWTP supervisor personally placed the electronic housing in a trash bin. All trash from WWTP eventually gets disposed at the Kapaa landfill.
Based on a initial activity of 250 microcuries on May 1967, the calculated activity on JarcJary 15, 1992, was 139 microcuries.
10 CFR 31.5(c)(8) requires, in part, that any person who acquires, receives, possesses, uses or transfers byproduct material in a device pursuant to a general license shall, with exceptions not applicable here, transfer or i
dispose of the device containing byproduct material only by transfer to persons holding a specific license pursuant to 10 CFR Parts 30 and 32 or from l
an Agreement State.
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[(' o. A v Contrary to the above, sometime after January 1992 but before April 1993, the' City and County of Honolulu disposed of an Ohmart Corporation compensating cell in.the PC-6 housing of the ASR density gauge system containing 139 microcuries of cesium 137 and this disposal was not made to a person
- holding a specific license pursuant to 10 CFR Parts 30 and 32 or from an Agreement State. Specifically, the device was disposed of in the Kaapa l
l landfill, an unlicensed facility-(999-90004/9505-01).
1In April 1993, the ASR-4' gauge with the 1000 millicurie source was removed.
On June 23, 1993, this source together with four other cesium 137 sources from other wastewater treatment facilities operated by the City and County of Honolulu were leak tested and returned to Ohmart Corporation for proper disposal. These sources were:
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misima Activm unsra remarment runt oftiIcuries LOCATim ASA-4-A-2102 5 909 1000 Waimenato FD 6 6562 5
S and FD-6 65625 500-Sand iatand SDG-30 1476-0/10 48186 1000 Kallus Proper receipt of these sources was acknowledged by Ohmart Corporation in a letter dated August 11, 1993. The-licensee had not reported.the transfer to i
.NRC as required by 10 CFR 31.5(c)(8).
- 10 CFR 31.5(c)(8) also requires, in part, that any person who transfers byproduct material. in a device pursuant to a general license shall within 30 days-after transfer of a' device to a specific licensee, furnish the Director of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, a report containing identification of the device by manufacturer's name and model number and the name and address of the person receiving the device.
l Contrary to the above, on June 23, 1993, the City and County of Honolulu l
transferred.five Ohmart Corporation source holders, each originally containing between 500 and 1000 mil 11 curies of cesium 137, and a report of these
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transfers was not made to the Director of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission (999-90004/9505-02).
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On December 6, 1995, during'a telephone conversation.with the inspector, the plant engineer agreed to~ submit the required report.
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3 'DOSINETRY o
The City and County of Honolulu hired a consultant to evaluate the consequences to members of the public from the improper disposal and to prepare'the r c ort to NRC required by 10 CFR 20.2201. The City and County of Honolulu submitted a timely interim report on August 3,1995, and a final consultant's report on October 9, 1995.
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The inspector reviewed and evaluated the consultant's report and calculations.
The consultant to the City and County of Honolulu estimates a deep dose u
i equivalent of less than 0.1 millirem to an'y individuals involved with the.
removal 'and disposal, and a committed dose equivalent to members of the public of.4.7x10-' millirem per year from drinking contaminated ground water. The first estimate appears reasonable, the second estimate appears extremely conservative in view that the source is encapsulated and in a ceramic form that is not readily soluble.
4 FUTURE USE OF LICENSED MATERIAL
'With the transfer of sources on June 23, 1993, DTD ceased possession of any 1
NRC licensed material.- At the time of the inspection, DTD possessed a compensator cell with a radium 226 source but radium is not licensed by the i
NRC and this compensator cell.was scheduled to be shipped back to the l
manufacturer.
L The plant engineer stated that DTD did not plan or intend to possess any NRC licensed material in the future.
L 5 CONCLUSION l
The~ City and County of Honolulu improperly disposed of a generally licensed 139 microcurie cesium 137 sealed source in the Kepaa landfill in the Island of Oahu.
i The City and County of Honolulu failed to inform the Director of the Office of Nuclear Material Safety and Safeguards of the transfer of generally licensed sources to the original manufactt.rer.
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-The Division of Treatment and Disposal does not currently possess and does not l
intend to possess any NRC licensed material.
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ATTACHMENT
- 1. PERSONS ~ CONTACTED
~1.1 City and County of Honolulu Personnel
- Mike Nunn, Plant Engineer II Earl Ng, Technical Services Mike Dao, Supervisor Waimanalo Wastewater Treatment Plant-Ivan Hawkins, Former Supervisor Waimanalo Wastewater Treatment Plant 1.2 Gamma Corporation - Consultant to the City and County of Honolulu Philip J. Manly, President
- Denotes individuals who participated in the exit briefing on November 16, 1995.
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2 EXIT MEETING The inspection findings as noted on the report were discussed with j
Mr. Mike Nunn during an exit briefing conducted on November 16, 1995, at the Division of Treatment and Disposal offices at 1350 Sand Island Parkway, Honolulu, Hawaii. Mr. Nunn was infonned of the violations contained in the report via telephone on December 6, 1995.
No dissenting comments were presented by Mr. Nunn.
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