ML20210E742

Informs That on 990206,NRC Was Notified of an Issue Involving Interstate Nuclear Svc in Springfield,Ma.Info Was Transmitted on 990217

ML20210E742
Person / Time
Issue date:	02/23/1999
From:	Duane White NRC
To:	Hallisey R MASSACHUSETTS, COMMONWEALTH OF
Shared Package
ML20210E685	List: ML20210E680 ML20210E701 ML20210E716 ML20210E742 ML20210E756 ML20210E767 ML20210E806 ML20210E812 ML20210E822
References
FOIA-99-279 NUDOCS 9907290022
Download: ML20210E742 (16)

Text

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• n' Febnary 23, 1999 Robert M. Hallisey, Director Radiation Control Program Department of Public Health 174 Portland Street, 5* floor Boston, MA 02114

Subject:

Referral of Matter Received by the NRC Regarding Interstate Nuclear Services

Dear Mr. Hallisey:

On February 6,1999, the NRC was notified of an issue involving Interstate Nuclear .

Services in Springfield, Massachusetts as noted in the enclosure to this letter. This information was also transmitted to Mr. Robert Gallagher of your staff on February 17, 1999.

Since this matter is not within NRC jurisdiction, but rather appears to be within your jurisdiction, this matter is being referred to you for whatever action you deem appropriate.

Since this matter was .eceived by the NRC anonymously, no response to this letter is requested.

Your cooperation with us is appreciated. I will gladly discuss any questions you may have concerning tins information.

Sincerely, Original Signed By:

Duncan White State Agreements Officer

Enclosure:

As Stated l

9907290022 990723

PDR FOIA ROBERTS99-279 PDR CERTIFIED MAIL RETURN RECEIPT REQUESTED

! t 9 % 7 2 S e 4 7-0FFICIAL RECORD COPY Q

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c Mr. R. M. Hallisey 2 RI-99-A-0015 Distribution:

Allegation File No. RI-99-A-0015 -

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DOCUMENT NAME: g:\alleg\referra!\9915ref.wpd To receive e copy of this document, indicete in the box: 'C' = Copy without ottachment/ enclosure *E' = Copy with attachment / enclosure 'N' = No copy  ;

OFFICE ORA: SAC G DNMS:SR/) .

NAME DVito/adw/slj &I DWhite[&/at.

DATE O2/ 2 /99 ( O2/ $/99 //

OFFICIAL RECORD COPY

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i The NRC has received information that the Interstate Nuclear Services (INS) facility in Springfield, Massachusetts has 1) not repaired major damage to its waste water system that allows leakage into the ground water; 2) installed additional equipment in a manner that would cause rapid release of contaminated water in the event of a failure; 3) not performed routine analyses to insure that discharges comply with regulations by containing no soluble materials; 4) routinely discharged radioactive sludge into the City of Springfield sanitary sewer system; 5) designed the location of the routine sampling point and the holding tank mixers to conceal and facilitate the discharge of sludge; and 6) taken action with INS management's knowledge to conceal the presence and discharge of the sludge.

A copy of the concerns received by the NRC is enclosed.

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• L OmCIAL RECORD COPY .

INTRODUCTION This repon documents problems with the Interstate Nuclear Sersices (INS) wastewater pretreatment system and potential violations of the Code of Federal Regulations, Title 10, Part 20 (10CFR20).

INS, a subsidiary of the Unifirst Corp., located at 295 Parker Street in Springfield, Ntassachusetts,is an industrial laundry that washes radioactively contaminated clothing worn at nuclear power plants, government nuclear facilities, universities, and other manufactures of nuclear products. The wastewater generated by this laundering process is discharged into the City of Springfield sewer system.

DESCRIPTION OF THE WASTE WATER SYSTEM The water from each washer dumps into a trough. This trough drains into two tanks in an unlined below ground pit. Niany years ago the tanks overflowed into the pit. In an ill conceived effort to recover from the overflow, the tanks were pumped empty prior to removing the water from the pit. The empty tanks tioated in the full pit and broke loose from the connecting pipes. Rather than fix this serious problem, INS elected to continue operating with the pit as the collection point and let the tanks remain in position. The level detectors were moved outside of the tanks and hung haphazardly on the side of the pit. This most likely accounts for sporadic and inaccurate indication of the water level in the pit. The drain on one of the tanks has become plugged and so it remains full and over flows continuously The other tank drains continuously through the break in the pipe. I.arge amounts of sludge collect in the bottom of this pit be:ause the mixers that were in the original tanks hase been removed or corroded and would not mix the ]

pit esen if they were operational.

When the pit becomes full, water is pumped through a mechanical shaking screen, This screen was  ;

recently added when INS was experiencing clogging of their sand tilters This tank and screen were placed outside of a flood control dam that contains all of the other original tiltration tanks and piping. A leak in  ;

this screen,its tank. or discharge pump would quickly run across the floor of the facility and out of the i building which is at or abose grade. The water entering this screen has not been tiltered and therefore represents the most contaminated water that INS handles The shaking screen collection tank is pumped into an equalization tank in preparation for tiltration. This tank contains a large mixer to keep solid material in suspension.

The attached Figure I is a simplitied drawing of the collection process as described above When water is to be tiltered it is pumped from the Equalization tank through one of four sand tilters. A continuos sample collects in a small deep-sink when water is beirg tiltered The discharge from the sand tilters collects in one of four sampling tanks When the sample tanks are full. a technician scoops a sample from the deep-sink. This sample is analyzed for radioactivity and ifit is below radioactivity limits specified in 10CFR20 appendix B table 3. it is pumped into two holding tanks in a dammed ponion of the Unifirst building When Unifirst wastewater operations allow. the INS water is blended with Unifirst water before it is discharged into the sewer system Figure 2 is a simplitied drawing of the tiltration. sampling. and discharge portion of the process described abose 1

OfflCIAL RECORD COPY

PROBLEMS AND POTENTIAL VIOLATIONS

1. -The pit that contains the broken pipes and useless tanks was not designed or intended to be used as a tank itself. It can, and has, overflowed to adjacent abandoned pits and building materials. It is almost certain that slow leakage occurs and allows contaminated water into the ground below. No attempt has ever been made to identify or quantify this leakage.

2. Due to the uncontained location of the shaking screen, any failure or leakage could result in rapid flooding and release of the most highly contaminated water to the environment and adjacent buildings.

3. Inadequate and improper sampling of the facility discharge does not insure compliance with regulations. 10CFR20 2003 Disoosal by release into sanitarv sewerage states in part:

(a) A licensee may discharge licensed material into sanitary sewerage if each of the following conditions is satisfied:

(!) The material is readily soluble (or readily dispersible biological material) in water, and (2) The quantity oflicensed or other radioactive material that the licensee releases into the sewer...does not exceed the concentration listed in table 3 of appendix B to part 20..

While INS is diligent about insuring that each sample tank complies with condition number 2, it does no other analysis. INS has wdtten its own dennition of"readily soluble", but does not sample each tank to insure compliance with its own definition. In addition it samples the waste stream at the wrong location. i i

Although listed as problem 43. this is the most serious violation and there is reproducible evidence to show that the inadequate and improper sampling conceals the discharge ofinsoluble sludge to the Spring 6 eld sewer system.

SOLUBILITY ISSUE INS performed its own study and detennined that soluble means that the wastewater should contain no panicles greater than 20 microns in size. It then performed a one time analysis to insure that the water being discharged from the sand 61ters contained no particles greater than 20 microns and declared itselfin compliance with the solubility requirement for all future discharges from the facility Webster's Dictionarv de6nes soluble as " capable of entering into solution or of being dissolved" To dissolse is denned as "to consert from a solid to a liquid state by merging with a liquid. to make a solution of as, to dissake sugar in water" By specifying a particle size. INS is admitting the material exits as a solid, not a liquid. In addition. there are chemical, electncal, physical, and biological reactions occurring down stream of the sample point that INS is aware of but does not fully understand.

The water in each sampling tank is allowed to settle before being mosed to the holding tanks. This may be for seseral hours. while the technician performs the radioactivity analysis, or up to several days ifleR over a weekend before being discharged Esen if the 61ters always operate perfectly and there are never any particles greater than 20 microns passing through. after being sampled the particles combine. grow, or 2

OfflCIAL RECORD COPY

F react chemically with each other to form sludge that settles to the bottom of each sample tank. This sludge is visible as a " bath tub ring" at the top of each tank, visible material on the sides of each tank, and a sticky sludge on the cables and floats that make up the level detection equipment in each tank. It is not visible at the bottom of the tank because the water is opaque with suspended solid material and the tanks are not completely drained during a discharge. If properly sampled the sludge is collectable and it is obviously not soluble.

INS management is aware of this sludge, and has infrequently ordered plant personnel to enter and clean out the sample tanks to avoid its discovery by regulators. Six inches of black material resembling wet mud has to be removed. When the 2 holding tanks were installed in the Unifirst building they were equipped with large mixers (see Figure 2) to keep this sludge in suspension until it was pumped to the sewer. Mixers would not be necessary if the materials were soluble.

The conditions for release of radioactive materials into sanitary sewage apply at the point of discharge.

INS has sampled the water-

1. prior to settling in sample tanks,

2. prior to agitation in holding tanks, and

3. prior to blending with another waste stream.

Further chemical, electrical, physical, and biological reactions certainly occur when INS water is mixed with the water from Unifirst. The Unifirst water contains many unidentified contaminants and the resulting mixture is not sampled before being sent to the sewer. Because the radioactive material is not soluble, it settles and plates out quickly in the sewer line and causes elevated radiation levels above the manhole in the middle of Parker Street. INS Management is aware of the elevated radiation levels and claims no responsibility for clean up or monitoring because "all discharges have been within the regulations" as they hase interpreted them I

REPRODUCIBLE SUPPORTING EVIDENCE #

Esidence to support this report can easily be obtained by the following actions:

1. Perform a sisualinspection of the INS Sample tanks The " bathtub ring". sertical plate-out, and level instrument fouling are clearly visible.

Draw samples from the bottom of the sample tanks using a level specitic sampler. A suitable sampler can be lowered in the open position and tripped with a trigger The closed sampler can then be withdrawn without diluting the sludge sample with surface water.

3 Measure radiation dose rates abose and in the manholes in the street in front of the building at 295 Parker Street with appropriately sensitise detection equipment.

Note These actions must be taken without prior notice to INS Tank cleaning will temporarily concea; most of this esidence INS has presiously cleaned the tanks for this purpose.

3 0FFICIAL RECORD COPY

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i CONCLUSIONS i l

1. INS has not repaired major damage to its waste water system that may allow leakage into ground water.

2. INS has installed additional equipment (the shakmg screen) in a manner that could cause rapid release of contaminated water in the event of a failure.

3. There are no routine analysis performed to insure that discharges comply with regulations by containing no insoluble materials.

4 INS routinely discharges radioactive sludge to the City of Springfield sanitary sewer system.

5. The location of the routine sample point and the Holding Tank Mixers are designed features of the I

wastewater system that function to conceal and facilitate the discharge of this sludge.

6. INS Management has taken action to conceal the presence of the sludge and to continue to discharge it.

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0FFICIAL RECORD COP't L

COLLECTION PORTION OF INS WASTEWATER .

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TRANSMIT T0: LT A-3 M LOCATION: M FAXNO.'(bO) Odl-SO9k FROM: Nh TITLE /0FFICE:

NUMBER OF PAGES (INCLUDING COVER SHEET): .

RETURN TELEPHONE N0. (610) 337-SlE i RETURN FAX NO. (610) 337-5208 DATE AND TIME SENT: h'M-hh

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REMARKS:

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- **::c:::c.c:::cr.::::m:0 -COMM. JOURNAL- ******************** DATE FEB-17-1999 ***** T I ME 16: 05 *** P. 01 l

MODE = TRANSMISSION START =FEB-17 16:03 END=FEB-17 16:05 NO. COM ABBR /NTlJK STATION NAME/ PAGES PRG.NO. PROGRAM NAME I TELEPHONE NO.

1 001 OK s 86177272098 007 d -

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l l,[1] The pit that contains the broken pipes and useless tanks was not designed i

or intended to be used as a tank itself. It can, and has, overflowed to ,

adjacent abandoned pits and building materials. It is almost certain that slow leakage occurs and allows contaminated water into the ground below. No

! atternpt has ever been made to identify or quantify this leakage. In summary, l INS has not repaired major damage to its waste water system that may allow leakage into ground water.

[2] Due to the uncontained location of the shaking screen, any failure or leakage could result in rapid flooding and release of the most highly contaminated water to the environment and adjacent buildings. In addition, INS routinely discharges radioactive sludge to the City of Springfield sanitary sewer system.

l [3] Inadequate and improper sampling of the facility discharge does not insure compliance with 10 CFR 20.2003(a) (1). INS has written its own definition of "readily soluble" but does not sample each tank to insure compliance with its own definition. In addition, it samples the waste stream at the wrong l l location. There is reproducible evidence to show that the inadequate and l improper sampling conceals the discharge of insoluble sludge to the i Springfield sewer system.

l

[4] INS management is aware that they generate radioactive sludge, and has frequently crdered plant personnel to enter and clean out the sample tanks to avoid its discovery by regulators. In addition, the location of the routine i sample point and the Holding Tank Mixers are designed features of the I wastewater system that function to conceal and facilitate the discharge of I this sludge. INS management has taken action to conceal the presence of the sludge anci to continue to discharge it.

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V-INTROD11CTION This report. documents problems with the Interstate Nuclear Services (INS) wastewater pretreatment system and potential violations of the Code of Federal Regulations, Title 10, Part 20 (10CFR20).

[NS, a subsidiary of the Unifirst Corp , located at 295 Parker Street in Springfield, Massachusetts, is an I industrial laundry that washes radioactively coritaminated clothing worn at nuclear power plants, I

government nuclear facilities, universities, and other manufactures of nuclear products. The wastewater l

generated by this laundering process is discharged into the City of Springfield sewer system.

. DESCRIPTION OF THE WASTE WATER SYSTEM The water from each washer dumps into a trough. This trough drains into two tanks in an unlined below l

ground pit. Many years ago the tanks overflowed into the pit. In an ill conceived effort to recover from L

the overflow, the tanks were pumped empty prior to removing the water from the pit. The empty tanks floated in the full pit and broke loose from the connecting pipes. Rather than fix this serious problem, INS l elected to continue operating with the pit as the collection point and let the tanks remain in position. The level detectors were moved outside of the tanks and hung haphazardly on the side of the pit This most likely accounts for sporadic and inaccurate indication of the water level in the pit. The drain on one of the tanks has become plugged and so it remains full and over flows continuously. The other tank drams continuously through the break in the pipe. Large amounts of sludge collect in the bottom of this pit because the mixers that were in the original tanks base been removed or corroded and would not mix the pit esen if they were operational.

l When the pit becomes full, water is pumped through a mechanical shaking screen. This screen was recently added when INS was experiencing c!ogging of their sand titters. This tank and screen were placed outside of a tlood control dam that contains all of the other original 61tration tanks and piping. A leak in this screen. its rank. or discharge pump would quickly run across the tloor of the facility and out of the building which is at or abose grade. The water entering this screen has not been 6itered and therefore represents the most contaminated water that INS handles The shaking screen collection tank is pumped into an equalization tank in preparation for tiltration. This tank contains a large mixer to keep solid material in suspension The attached Figure l is a simpiided drawing of the collection process as desenbed abase When water is to be 6itered it is pumped from the Equalization tank through one of tbur sand diters. A continuos sample collects in a small deep-sink when water is being tiltered The discharge from the sand tilters collects in one of four sampling tanks When the sample tanks are full, a technician scoops a sample from the deep-sink. This sample is analyzed for radioactisity and ifit is below radioactisity limits specified in 10CFR20 appendix B table 3. it is pumped into two holding tanks in a dammed portion of the Unifirst building. When Unidrst wastewater operations allow. the [NS water is blended with Unidrst water before it is discharged into the sewer system Figure 2 is a simpli6ed drawing of the 6ltration. sampling. and discharge portion of the process described abose 1

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PROBLEals AND POTENTLAL VIOLATIONS 3 1

1. The pit that contains the broken pipes and useless tanks was not designed or intended to be used as a tank itself. It can, and has, overflowed to adjacent abandoned pits and building materials. It is almost l certain that slow leakage occurs and allows contaminated water into the ground below. No attempt has j l

l ever been made to identify or quantify this leakage.

l 2. Due to the uncontained location of the shaking screen, any failure or leakage cculd result in rapid ,

flooding and release of the most highly contaminated water to the environment and adjacent buildings.  !

3. Inadequate and improper sampling of the facility uischarge does not insure compliance with j regulations. 10CFR20 2003 Discosal bv release into sanitarv sewerage states in part:

l (a) A licensee may discharge licensed material into sanitarf sewerage if each of the following conditions is satisfied:

(I) The material is readily soluble (or readily dispersible biological material) in water, and l (2) The quantity oflicensed or other radioactive material that the licensee releases into the sewer...does not exceed the concentration listed in table 3 of appendix B to part 20..

i While INS is diligent about insuring that each sample tank complies with condition number 2, it does no other analysis. INS has written its own de6nition of"readily soluble", but does not sample each tank to insure compliance with its own dednition. In addition. it samples the waste stream at the wrong location.

Although listed as problem 23. this is the most serious violation and there is reproducible evidence to show that the inadequate and improper sampling conceals the discharge ofinsoluble sludge to the Spring 6 eld sewer system.

SOLUBILITY ISSUE

[NS performed its own study and determined that soluble means that the wastewater should contain no panic!es greater than 20 microns in size. It then pen'ormed a one time analysis to insure that the water being discharged from the sand diters contained no panicles greater than 20 microns 2nd declared itselfin compliance with the solubdity requirement for all future discharges from the facility Webster's Dictionarf de6nes soluble as "capabie of entering into solution or of being dissolsed" To i dissolse is denned as "to consen from a solid to a liquid state by merging with a liquid to make a solution l of, as to dissoke sugar in water" By specifying a particle size. INS is admitting the material exits as a solid. not a liquid. In addition, there are chemical. electrical, physical. and biological reactions occurring down stream of the sample point that INS is aware of but does not fully understand The water in each sampling tank is allowed to settle before being mosed to the holding tanks This may be for seseral hours. while the technician performs the radioactisity analysis. or up to seseral days ifleft oser a weekend before being discharged Esen if the 61ters always operate perfectly and there are neser any particles greater than 20 microns passing through. ader being sampled the panicles combine, grow, or 2

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react chemically with each other to form sludge that settles to the bottom of each sample tank. This sludge is visible as a " bath tub ring" at the top of each tank, visible material on the sides of each tank, and a sticky sludge on the cables and floats that make up the level detection equipment in each tank. It is not visible at the bottom of the tank because the water is opaque with suspended solid material and the tanks are not completely drained during a discharge. If properly sampled the s!udge is collectable and it is obviously not s:luble.

INS management is aware of this sludge, and has infrequently ordered plant personnel to enter and clean

! out the sample tanks to avoid its discovery by regulators. Six inches of black material resembling wet mud I has to be removed. When the 2 holding tanks were installed in the Unifirst building they were equipped j with large mixers (see Figure 2) to keep this sludge in suspension until it was pumped to the sewer. Mixers I

would not be necessary if the materials were soluble. l The conditions for release of radioactive materials into sanitary sewage apply at the point of discharge.

INS has sampled the water- l

1. prior to settling in sample tanks,  !

2. prior to agitation in holding tanks, and 3 prior to blending with another waste stream.

Funher chemical, electrical, physical, and biological reactions certainly occur when INS water is mixed with the water from Unifirst. The Unifirst water contains many unidentified contaminants and the resulting mixture is not sampled before being sent to the sewer. Because the radioactive materialis not soluble,it settles and plates out quickly in the sewer line and causes elesated radiation levels above the manhole in the I

middle of Parker Street. INS Nianagement is aware of the elevated radiation levels and claims no responsibilitv for clean up or monitoring because "all discharges have been within the regulations" as they hase interpreted them REPRODUCIBLE SUPPORTING EVIDENCE i Evidence to suppen this repon can easily be obtained by the following actions-1 Perform a sisual inspection of the INS Sample tanks The " bathtub ring", senical plate-out, and lese! instrument fouling are clearly visible

Draw samples from the bottom of the sample tanks using a lesel specitic sampler. A suitable sampler can be lowered in the open position and tripped with a trigger The closed sampler can then be withdrawn without diluting the sludge sample with surface water 3 Measure radiation dose rates abose and in the manholes in the street in front of the building at 295 Parker Street with appropriately sensitise detection equipment.

Note These actions must be taken without prior notice to INS Tank cleaning will temporarily conceal most of this esidence INS has presiously cleaned the tanks for this purpose I

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1 CONCLUSIONS i

1. INS has not repaired major damage to its waste water system that may allow leakage into ground water.

l 2. INS has installed additional equipment (the shaking screen) in a manner that could cause rapid release of contaminated water in the event of a failure.

3. There are no routine analysis performed to insure that discharges comply with regulations by containing no insoluble materials.

4. INS routinely discharges radioactive sludge to the City of Springfield sanitary sewer system.

5. The location of the routine sample point and the Holding Tank Mixers are designed features of the wastewater system that function to conceal and facilitate the discharge of this sludge.

6. INS Management has taken action to conceal the presence of the sludge and to continue to discharge it.

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COLLECTION PORTION OF INS WASTEWATER i

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