ML20211A270
| ML20211A270 | |
| Person / Time | |
|---|---|
| Issue date: | 08/18/1994 |
| From: | Axelson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Borello C AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20210U181 | List:
|
| References | |
| FOIA-98-341 NUDOCS 9908240012 | |
| Download: ML20211A270 (4) | |
Text
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i UNITED STATES g
- g NUCLEAR REGULATORY COMMISSION y
REGION IH t
801 WARRENVILLE ROAD LISLE, ILUNOIS 60532-4351 AUG 161994 4
Ms. Christine Borello.
AMS N0. RIII-94-A-0026 itesident - Concerned (,$tizens
-[
Dear fis. Borellok l
This is in response to your letter received April 12, 1994, and your letter dated July 20, 1994, in which you indicated that radioactive material may have been disposed at the Uniontown Landfill. You also addressed possible wrongdoing by various Federal and State agencies involved with the site.
In addition, this letter addresses your July 25, 1994, letter regarding communication issues you believe occurred between you and members of my staff.
Thank you for bringing these concerns to our attention and as a result, my staff has done the following:
1.
The concern regarding wrongdoing was referred to the U.S. Environmental Protection Agency (EPA) Office of Inspector General on May 18, 1994. At your request, a copy of the referral letter was provided to you under separate cover.
2.
The concern regarding the dumping of radioactive material was reviewed by my staff. Their review included the following:
a.
A file search was conducted of expired and terminated Atomic Energy Commission (AEC) and Nuclear Regulatory Commission (NRC) licenses for the period 1970-1985 for lost sources or disposals at this landfill. The file search did not identify any documents which would indicate that a former AEC or NRC licensee disposed of licensable radioactive material at the landfill during the above l
time frame.
b.
A review was conducted of the EPA's Science Advisory Board (SAB)
" draft" report dated June 14, 1994, regarding this same issue.
The Board reviewed radioanalytical data, disposal records and landfill records. Our review of the board's draft report did not identify any information which would lead the NRC to belleve licensable radioactive materials were disposed of at the landfill.
c.
An evaluation of the radioanalytical reports from the Ohio Department of Health and EPA contractors which you mailed to my staff, revealed the following:
Information in this record was deleted 99o824oo12 990017 n accordance with the Freedom of Inform:0 10 PDR FOIA A8%.
REED 98-341 PDR g
- 3 11 ]
EIENPT FR0 ISCLOSURE 10 CFB 2.7 0 NFORMATIOR
790 8 2-7oo / z_
Ms. Christine Borello 2
AUG 161994 (1)
Most of the data stamped "INVAllDATED," with exceptfonally high results, was later explained by the EPA and its contractors to be due to laboratory procedural errors.
As an example, water samples taken from a " Residential Well" during June 1991, showed a tritium concentration of 1,069,337 picocuries/ liter (pCi/1) [39,565 becquerels / liter (Bq/l}]. Due to the questionable high results, the well was later re-sampled during October 1991, and the results showed less than 500 pC1/1 [19 Bq/l]. This later value is below the minimum detectable concentration for the instrumentation used and cannot be distinguished from background tritium conrentrations. Discussions with EPA staff on August 8, 1994 and August 10, 1994, indicated that the June 1991 sample result was invalidated due to laboratory procedural error. Also, this well was subsequently sampled by the Ohio EPA in December of 1991 and by the U.S. EPA and the Ohio EPA from May 1992 through March 1993 (quarterly samples collected) and was found to be less than 500 pCi/l [19 Bq/l], which is.significantly less than the U.S. EPA drinking water limit of 20,000 pC1/1 [740 Bq/l] for tritium.
(2)
Also noted were radioanalytical results of filters used to filter ground water samples collected in September 1992, which indicated the presence of plutonium-238 and plutonium-239. These results were determined to be statistically insignificant, since the measurements were below the minimum detectable activity, that is, the results were so low that the analytical instrumentation could not discriminate the results from background radionuclide values.
(3)
In addition, a soil sample collected in January 1992 from a 91 feet deep bore hole was reported to have concentrations of 0.016 i0.013 pCi/g [0.59 i0.48 Bq/Kg] for plutonium-238 and 0.09610.027 pCi/g [3.6 il.0 Bq/Kg] for plutonium-239.
The EPA reanalyzed these samples in November 1992 and determined the concentrations for plutonium-238 to.be 0.004 iO.0li pCi/g [0.15 id.41 Bq/Kg] and for plutonium-239 to be 0.007 0.008 pCi/g [0.26 i0.30 Bq/Kg]. These concentrations are statistically insignificant, that is, the results were so low that the analytical instrumentation used could not discriminate the results from background radionuclide values.
j d.
On August 4 and 11, 1994, NRC staff evaluated radioanalytical reports from sampling done by the U.S. EPA. This sampling period (quarterly samples collected) was from May 1992 to March 1993.
1 Our review of the EPA, data revealed only the presence of naturally occurring radionuclides at envi onmental levels and did not reveal any man-made radionuclides.
EEMPT FROM JLOSs.J i10 CFR 2.790 ORMATION
Ms. Christine Borello 3
AUG 161%4
)
)
In addition to the above,-an interagency agreement between the NRC and'the EPA (draft, " Federal Radiological Emergency Plan" (FRERP)) has established new guidelines for designating the Lead Federal Agency (LFA) for different types of radiological or potentially radiological incidents. The NRC and EPA have agreed that the EPA will be the LFA for radiological incidents at sites not licensed, owned, or operated by a Federal agency or an Agreement State. This would include scrap yards, railroad sites and landfills. The Uniontown landfill would fit into this category.
Since characterization and/or remediation of this site has been delegated to the U.S. EPA, the remaining technical issues you asked about regarding previous radiological water sampling results, soil core sampling, and questions you have regarding procedures for collection and analysis of environmental samples, will be referred to the U.S. EPA's Region V office.
In summary, based upon our review of your concerns regarding possible radioactive contamination in and around the Uniontown Landfill, we have determined that there is no evidence that NRC licensed material was dumped at the landfill.
Regarding the issues raised in your July 25, 1994 letter, I will attempt to address your concerns as follows:
Concern:
You stated that you were concerned and distressed by the fact that the NRC continues to focus on you as the " alleger" instead of referring to you as a representative of a concerned citizens group.
Response
Please accept our apology for using this term.
I can assure you that this will not happen again. Further, I have_ directed my staff to recognize you as.a representative of the Concerned Citizens of Lake Township when communicating with you.
j Concern:
You indicated that the NRC identified you (directly or indirectly) during an interview with a local reporter as the " alleger" when I
the NRC was asked questions reganiing the actions that it has taken reganting your concerns with the EPA.
Response
My staff is unaware of intentionally disclosing your nam 5 as the individual that provided information to the NRC. We have reviewed this matter and cautioned the staff regarding conversatioits involving concerns from the public.
Concern:
You stated that'you were told by an NRC official that it was his professional judgment that he believed and had recommended that the NRC should take over th!5 site ani do casplete, " full-blown field studies" that included core samples, stream testing and gas analysis for radiation.
EID4PT FROM 3 CLOSURE 20 CTR 2.7 NFORMATION
1 Ms. Christine Borello 4
AUG 161C94
Response
On March 2,1994. Mr. Wiedeman contacted you to gather additional information regarding the Uniontown Landfill concerns. The intent was to ensure that we had properly characterized the issues.
During this conversation, you asked questions regarding how the NRC would or could resolve the potential environmental contamination issues involving radioactive material. Mr. Wiedeman explained to you several options that were being considered.
It was not Mr. Wiedeman's intent to suggest that the NRC should assume respunsibility for evaluation of the site.
' Should you have any questions regarding the above, please do not hesitate to contact me at (708) 829-9800 or Mr. Mike McCann of my staff at (708) 829-9856.
J Sincerely, I
l W. L.
xelson, Direc or Division of Radiation Safety and Safeguards
)
cc:
H. J. Miller, RIII A ;E!! funk, RIIII j
L. J. Norton, OIG i
J I
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EIEMPT FROM ISCLOSURE 10 CFR 2.7 0 RMATION
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