ML20246Q051

Forwards Trip Rept of 890328 Visit to Safety Light Facility in Bloomsburg,Pa Re Observations & Recommendations Resulting from Insp of Facility

ML20246Q051
Person / Time
Issue date:	05/10/1989
From:	Pittiglio C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Bell M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
REF-WM-3 NUDOCS 8905220349
Download: ML20246Q051 (28)

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LLRB r/f LPittiglio TJohnson MBell JGreeves RBangart JSurmeier PLohaus 'JJoyner, RI MKnapp, RI FCostello, RI RCunningham- =PDR Yes /T7 F / or CF Only / / PDR No / / Category: Proprietary ACNW Yes /I"7 'No / / SUBJECT ABSTRACT: ~TNSPECTION OF SXTETY LIGHT FACILITY MEMORANDUM FOR: liichael J. Bell, Chief td'hBranch g3 g 9 THRU: Timothy C. Johnson, Section Leader Regulatory Branch LLWM, NMSS FROM: - Clayton L. Pittiglio, Jr., P.E. Regulatory Branch LLWM, NMSS

SUBJECT:

INSPECTION OF SAFETY LIGHT FACILITIES In response to the April 19, 1989 request from Region I, to assist in the evaluationofDemandforInformation(DFI)'issuedonMarch 16, 1989 to Safety Light Corporation, Tim Johnson and I visited the Safety Light facility in Bloomsburg, Pennsylvania on March 28,.1989. I have attached a trip report that lists the attendees at the meeting along with several observations,and recommendations resulting from the inspection of the facility. Originiiigifeiby Clayton L. Pittiglio, Jr., P.E. Regulatory Branch LLWM, HMSS i

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t T-SAFETY LIGHT FACILITY MEETING L DATE: April-28, 1989 LOCATION: Safety Light Corporation, Bloomsburg, Pennsylvania ATTENDEES: Jim Joyner, NRC, RI Frank Costello,.NRC, RI Tim Johnson, NRC, LLWMD-Larry Pittiglio, NRC, LLWMD Jack Miller, President Safety Light Corp. Michael O'Donoghue, Attorney Safety Light Corp. Allen Mandelbaum, Attorney Safety Light Corp.' PURPOSE: TO INSPECT THE FACILITY AND TO DISCUSS THE DFI AND THE STATUS OF THE REQUIRED RESPONSE DISCUSSION: The meeting opened with a discussion of the facility, a brief historical review of the site and a review of the facility site plan. The Safety Light facility is situated on.an 11 acre site adjacent to a residential area and the rear boundary of the site adjoins the Susquehanna River. The discussion of the site plan focused on areas not i released for unrestrictive. release and its impact on workers and the public. Safety Light discussed a plan for securing these areas by fencing. Safety Light also stated that the corporation hired IT Corporation to recommend i access restrictions as well as prepare a proposal for characterizing the site. i Next, Safety Light presented a brief historical review of L the site since its initial operations in the early 50's when U.S. Radium Corporation used the site to manufacture self-illuminating watches and instrument dials. During this time, the site was.used for disposal of some radioactive materials. Records of the amount and extent of j buried waste do not exist. At that time the company also made Sr, Co, Cs sources. In addition, U.S. Radium Corporation increased use of tritum in the 1960's and 1970's as radium use declined. Today, Safety Light Corporation uses tritum exclusively in the manufacture of self-illuminating exit signs and other light sources. I

, 0 ) Safety Light discussed its insurance coverage. Miller stated that Safety Light and its predecessors had insurance policies with 18 differcnt companies. These companies { have been contacted and given notice that a claim may be forthcoming. He also stated most of those policies had no pollution exclusions. The attorneys also discussed a New Jersey case and stated that their belief was that the insurance companies would be financially responsible for the claims. In closing, other topics were discussed including Safety Light restating their excellent current worker safety record since 1981. NRC reemphasized the significance of responding in a timely manner to the Demand for Information (DF1). Jim Joyner stated that NRC was looking for a detailed Site Characterization Plan as well as a proposal for cleaning-up the site and reemphasized the need for information required in the DFI. It was also pointed out to Safety Light that the tax information and site characterization plan were due to NRC by April 30, 1989. (Enclosure A provides a summary of the NRC DFI). SITE TOUR: NRC then spent the next 2-3 hours inspecting the facility. OBSERVATIONS: The grounds and building, excluding the Processing Building where Safety Light currently conducts business, are in extremely deteriorated conditions. Enclosure B shows the different levels of contamination associated with each area of the grounds and adjacent buildings. Several of the buildings are in such an extreme state of deterioration that temporary shoring has been installed to support the roofs. It is my opinion, as a registered Structural Engineer, if these areas receive an abnormal snowfall, several roofs may not be able to support the load. Since these buildings are contaminated, it is important that structural integrity be maintained. RECOMMENDATIONS: In addition to the required responses for the DFI, Safety Light should conduct a structural inspection of the deteriorated structures and make necessary improvements to secure these buildings. This action needs to be done in the immediate future.

I g.. Enclosure A i SAFETY LIGHT _0RDER FOLLOWUP I. DEMAND FOR INFORMATION - DUE DATE: APRIL 15 A. Requirement: Describe the extent to which the decontamination of the Bloomsburg facility was considered, if at all, and by whom, in determining the nature of.the reorganizations and transfers discussed in this Order. Action: P.eview to determine extent to which the response impacts on compliance with 10 CFR 30.34(b) and whether or not noncompliance was intentional. Reviewer: J. Gutierrez, RI Due Date: May 19, 1989 B. Requirement: Copies of all contracts, agreements, deeds, or other instruments of conveyance, between any of the Corporations or individuals concerning responsibility for cleanup of the Bloomsburg site. Action: Review to determine extent to which the response impacts on compliance with 10 CFR 30.34(b) and whether or not noncompliance was intentional. Reviewer: J. Gutierrez, RI Due Date: May 19, 1989 1 C. Requirement: For each Corporation, copies of all annual financial statements, including but not limited to, balance sheets showing all assets and liabilities and profit and loss statements, for the three years prior to this Order. Action: Review to assist in assessing the licensee's financial status and ability to satisfy terms of the Order. In particular, for Safsty Light, evaluate the profitability of the tritium sign business to deterulne whether permitting continued operation (to provide funds for site cleanup) Review J. Gutierrez, RI M. Bell, MMSS Due te: May 19, 1989 1 ATTACHMENT 1

i D. Requirement: For each Corporation, copies of all quarterly financial statements, including but not limited to, balance sheets showing all assets and liabilities and profit and loss statements, for the three ] years prior to this Order. Action: Review to assist in assessing the licensee's financial status and ability to satisfy terms of the Order. In particular, 1 for Safety Light, evaluate the profitability of the tritium si business to determine whether permitting continued operation (gn to providefundsforgt* cleanup)isjustified. Reviewer. J. Gutierrez, M. Bell, NMSS Due Da : May 19, 1 E. Requirement: For each Corporation, copies of all annual Federal tax 1 returns for the three tax years prior to this Order. l Action: Review to assist in assessing the licensee's financial status and ability to satisfy terms of the Order. In particular, for Safety Light, evaluate the profitability of the tritium sign business to determine whether permitting continued operation (to provide funds for si'e-anup) is justified. N Review J. Gutierrez, RI M. Bell,IMSS Due ate: May 19, 1989 F. Requireuerr;.: A1a ng of the names of all individuals or corporations owning at least 10% of the stock in any Corporation, indicating each owner's address, the number of shares owned, and the total number of shares outstanding. Action: Review to assist in determining the extent of joint ownership of the various companies and the extent of each such individual's financial involvement and whether or not others previously unknown c held liable for the clean-up. _D Reviewers: J. Gutierrez, RI M. Bell, NMSS Due Date: May 19, 1989

i II. SITE CHARACTERIZATION PLAN - DUE DATE: APRIL 30 A. Requirement: All Corporations shall jointly submit, to the Regional Administrator, NRC, Region I, for his review and approval, a joint plan to characterize the radioactivity at the Bloomsburg site. The. plan shall describe in detail how a complete radiological and. geohydrological survey surface and subsurface.of all facilities and of the surrounding soil and groundwater will be conducted in. order to fully determine the radionuclides concentrations and their lateral and depth profiles water and soil. The survey,s shall be sufficient to develop aas we complete plan for decontamination / removal operations necessary to permit unrestricted access to the site.. The plan shall include, but not be limited to, provisions to address the issues contained in the 1988 NRC Environmental Evaluation of the Safety Light Corporation Site, Bloomsburg, Pennsylvania. Particular attention shall be given to identifying areas of the site that should be given priority in the site decontamination activities. The joint plan shall provide a schedule, with milestones, for completion of the site characterize-tions within 180 days. Action: Review the characterization plan to determine whether implementation would provide adequate assessment of the extent of radioactivity at the site. Particular attention should be paid to the way the plan addresses the specific points called out in the Order (seeabove). To the extent possible, develop estimate of the cost of cleanup. Guidance as to the acceptability of the licensee's plan and the cost of cleanup can be obtained in the following references: 1. Monitoring for Compliance with Decommission 1nc Termination survey criteria, RUREE/CR-2082, oat Ridge Nat' onal LaboraGry for U.S. Nuclear Regulatory Commission, June 1981. 2. Technology. Safety and Costs of Decossissioning Reference l i Mon-Fuel Cycle Nuclear Facilities. NURE6/CR-1754, Pacific' northwest Laboratory for U.S. Nuclear Regulatory Commission, February 1981. 3. " Guidance for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source or Special Nuclear Material," U.S. Nuclear Regulatory Connission, May 1987 Reviewers: J. Kinneman, RI M. Weber, letSS E. Shum, NMSS Due Date: June 2, 1989 l

I 4 B. Requirement: The plan shall specify the amount of funds that each of the Corporations is to provide for implementation of the plan. Any corporation that does not agree with the joint plan may submit an individual plan, with a statement explaining the reasons for disagreement with the joint plan. A corporate officer, not lower than the President, for each of the Corporations shall certify, under oath or affirmation, to the accuracy of the information contained in the site characterization plan and to the intent on behalf of the corporation to implement the plan. Action: Review to confirm that appropriate certifications have been provided. Comptre estimate of decontamination costs developed from II.A. above with funds specified as being provided. Consider course of action if insufficient funds available. Reviewe J. Gutierrez, R M. Bell, 255 Due Dat : June 2, 1989 III. ACCESS C0llTROL A aITE - u DATE: JUNE 14 i Requirement: Within 90 days from the date of this Order, Safety Light Corporation shall post the premises as required by 10 CFR Part 20 and shall control access to all contaminated areas at the Bloomsburg facility by a fence or other suitable means so as to create a restricted area, as defined in 10 CFR Part 20. q Action: Conduct inspection by May 5,1989 to detennine status of corrective actions. If necessary, conduct inspection no later than June 20, 1989, to evaluate compliance with this element of the Order. Reviewer: J. Kinneman, RI Due Dates: May 5 and June 20, 1989 i i 1 1 L _- _-- -

Document Name: ACTION PLAN CHART l Requestor's ID: LEPRE Author's Name: JIM JOYNER I Document Comments: l CHART FOR ACTION PLAN Destination Name: LEPRE Distribution Name: NRCRI_ CONNIE _0060 Addressee: Janet Lepre, 5 F23 Date Sent: 04/19/89 Time Sent: 14:51 Message: JANET: LAST ONE! THIS IS A CHART AND IS SIDEWAYS THANKS A LOT!!! CONNIE, REGION I 346-5274

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iI Enclocure B ENVIRONMENTAL EVALUATION OF THE SAF C LIGHT CORPORATION SITE, BLOOMSBURG, PENNSYLVANIA 1. Introduction Since activities began in the late 1940is, disposal of effluents and wastes at the U.S. Radium Corporation site near Bloomsburg, Pennsylvania, has caused radio-active contamination. Available monitoring data indicate that soils beneath the site have been contaminated with Ra-226 and Cs-137, and shallow groundwater has been contaminated with H 3 and Sr-90. Decontamination of the sita, which is now owned by Safety Light Cogoration and Metreal Corporation, is licensed by the U.S. Nuclear Regulatory Commission (NRC) under license number 37-00030-02t The purpose of this report is to (1) complie relevant information etioet the radicar.tive contaminant 6n of the site (2) assass hazards to nearb posed by the contamination based on available information, and (3)y residents establish priorities for cleanup of the contaminattun. The report will be used by NRC to support its evaluation and enforcement of ifcense number 37-00030-02. After a brief description of the site and its location, the report identifies and assesses sources'of contamination, describes the extent of radioactive contamination based on available information, assesses exposure of off-site and on-site resi-dents, and presents priorities for cleanup of existing contamination. 2. Location and General Description The Safety Light Corporation site is located in central Pennsylvania approxi-mately 1 km (0.63 mile) east of Almedia, Pennsylvania, in South Centre Township along Old Berwick Road. Larger population centers nearby include Bloomsburg abcat 4 km (2.5 mile) west and Berwick about 5 km (3.1 mile) east of the site. At an elevation of 163 m (490 feet) above mean sea level, the site is located on an old terrace and floodplain on the north bank of the Susquehanna River. Before occupation by U.S. Radium Corporation, the 1,ite was used to manufacture wooden toys during World War II. After the war. U.S. Radium Corporation pur-chased the site and began manufacturing self-illuminating watch and instrument dials and other articles containing radioactive materials. Consistent with the l name of the company, most of the early activities at the site involved the use of radium. Except for radium operations, U.S. Radium co moration was licensed by the Atomic Energy Commission (AEC) to use and distribute products containing a wide variety of radionuclides including C-14, Fe-55, Co-60, Ni-63, In-CS, p Sr-90, Cs-137, Po-210, Np-237, U-238, and An-241. In additien, U.S. Radium Corporation increased the use of tritium as radium use ceclined in the 1960's and 1970's. Today, Safety Light Corporation uses tritium exclusively in the raanufacture of self-illbeinating exit signs and other light sources. 3. Contaminant Sources Disposal of radioactive wastes and effluents generated on site has been a liciensing issue since operations began in the 1950's. Various approaches were used for waste disposal at the site, including injection into a dry well, open dumping, disposal in underground silos, oischarge to the sanitary sewer,

dilution and discharge to the Susquehanna River, and disposal at licensed disposat facilities off site. The company made repeated changes in its waste disposal practices in response to directives from the AEC. U.S. Radium Cor-poration even proposed to dispose of its radioactive waste at abandoned mines, but was declined authority by the AEC. After diverse uses of radionuclides had terminated in the late 1960's, the AEC licensed U.S. Radium Corporation to decontaminate the site and prepare it for eventual release for unrestricted use. By the late 1970's, however, little ) progress had been made in the decontamination effort. In 1978, U.S. Radium Corporation identified more than 32 contaminated areas on sita and proposed a decontamination program to sitigate the contamination (8cown, 1974). The pro-gram, however, has not been fully implemented. A considerable portion of the site is still contaminated with radioactive materials. In addition, only lieited survey information is available to determine the extent of contamination. For example, a test pit excavated in the old canal area between the manufacturing area and the river exposed radioactive materials, " oily" wastes, and wooden debris from 42.7 cm (17 inches) to 2.3 m (7 feet) below the surface (Meiser and Earl,1979). Therefore, detailed surveys of the site may identify more exten-sive contamination by radiological and non-radiological constituents. Table 1 categorizes sources of contamination into high, moderate, and low poteri-tial sources of contamination at the site. The sources were assessed based on information compiled in the docket and on experiences with sources of radiolog-ical and non-radiological contamination at other sites. For each source, the table describes radionuclides that may be released from the source and the path-ways most affected by the release. The table also identifies whether the source i is active or inactive. For this listing, sources are considered " inactive" if they are not currently releasing significant amounts of radionuclides to environ-mentel media. The locations of the sources listed in the table are illustrated in Figure 1. In additior, to sources of contamination located on site, sources of radiological contamination may exist off site, i.e., soil contaminated with Cs-137 on the property immediately east of the Safety Light property. Soil contaminated with Cs-137 was detected by the licensee in the backyard of the property east of the site. Much of the contamination was removed from this property and dumped on site. However, recent gamma surveys on the adjacent property still indicate residual Cs-137 contamination of the soil. i o' 2

i i Table _1. Sources of radiological contamination at the Safety Light Corporation site, Bloomsburg, Pennsylvania. \\ Radionuclides I Name* Ra Cs Sr H Pathway

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High Potential Sources: Disposal pits (17) X X GW, S X Cs-137 fon exchange hut with tank (20) X GW, S X Well in personnel building (25) X GW, S X Well in well house (19) X GW, S X Drain lines (32) X X X X GW, 5 X Carpenter shop (19) X D X Drainage canals X X X X GW, 5, SW X Moderate Potential Sources: Waste building (7) X X X X GW, 5 X Utility building)(9) X X X X GW, S X Radium vault (10 X S X Contaminated soils X X X X GW, S X (3,12-16) Loading dock (21) X X X X 5, D X Sewer grate (22) X X X X S X Plant dumps (26,27,29) X X X X GW, S X Etching building (30) X X GW, S D X Low Potential Sources: Former garage (2) X GW, 5 X Storage silo (4) X X X X D X Waste building (5) X X X X S, D Old house (6) X X X X S, D X 8x8 building (8) X X X X D X Lagoons (18 & 28) X X X X GW, S, SW X Application area (23A) X X D X Main building)(238) X X X X 0, S. GW r. Sidewalks (24 X D, S X Former exit sign assembly area (31) X X D X

• Numbers correspond with area numbers used by Safety Light Corporation
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4. Extent of C, contamination Available monitoring data indicate that the soils beneath the site have been contaminated with Cs-137 and Ra-226. The data also indicate that shallow alluvial groundwater has been contaminated with Sr-90 and H-3 (0RAU,1982). The current extent of soil and groundwater contamination is illustrated in Figures 2-7. Substantial uncertainties exist about the extent of contamination and its rate of environmental transport because of the complexity of the site, inadequacies of sampling and analytical programs, and the lack of a detailed, comprehensive survey of the site. In addition, studies to date have not assessed the extent of non-radiological contamination that may accompany the radiological contamination. Despite these limitations, available sampling data can be used to indicate the approximate location of contaminated areas and conduct prelie-inary assessments of the risks associated with the contamination. Oak Ridge Associated Universities (0RAU,1982) also concluded that samples of surface water and vegetation collected on and off site do not contain elevated concen-trations of radionuclides. Therefore, preliminary assessments indicate that disposal activities at the site have contaminated soil and shallow groundwater, but have not significantly contaminated surface water and vegetation off site. Figures 2 and 3 depict the approximate distribution of Cs-137 and Ra-226, respectively, in surface soil at the site (i.e., upper 5 cm). Background con

• centrations for Cs-137 and Ra-226 range from 0.04 to 0.74 pCi/g and from 0.44 to 0.74 pCi/g, respectively (0RAU, 1982).

With the exception of an isolated area in the northwestern corner of the site, the contamination is limited to the area between the manufacturing buildings and the Susquehanna River. The highest concentrations are clustered around (1) the liquid waste discharge canals near B45 and B46, (2) former plant dump sites near B41, and (3) the abandoned canal that paralleled the river near B43. The source of the elevated concentra-tions in the northwestern corner of the site near B40 has not been determined. In addition, the soil sampling data indicate elevated concentrations along the eastern property line between locations 10 and 39. These elevated levels may be associated with the Cs-137 contamination that was excavated from the adjacent property and dumped near location 10. Limited sampling at depth by ORAU has indicated deeper contamination of the soil in the same general locations as indicated by the surface samples. Sampling to date has not been sufficient to determine the extent and distribu-tion of Sr-90 contamination in soil. Figure 4 depicts the distribution based on available surface sampling data. For comparison, the only background concentration of Sr-90 in surface soil was 0.63 pti/g. Thus, the soil sampling indicates contamination of the soil with Sr-90 up to mere then 10 times the background concentration. The concentrations of tritium and other radiological and non-radiological con-stituentshavenotyetpendeterminedinsurfaceorsubsurfacesamples. Groundwater sampling performed by the licensee and others, including NRC, has indicated on-and off-site contamination. In a study for the licensee, Meiser and Earl (1979) confirmed the presence of shallow, unconfined groundwater in a highly conductive, alluvial aquifer beneath the site. The aquifer consists of gravsls, sands, and silts deposited by glacial-fluvial and fluvial processes during the Quaternary Period. Water level measurements indicate a relatively flat hydraulic gradient from north to south beneath the site toward the river. However, the measurements also indicated river bank storage and groundwater 5

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nounding in the. area immediately south of the disposal pits and lagoons near wells 1 nnd 4. These transient variations in the water table elevation may divert grounbeter flourbeneath the site toward the east or west. In addition, the fil' ed-in canal and other artificial modifications to the aquifer (e.g., disposal pits) any affect the direction of groundwater flow and transport between the river and the manufacturing area. Further, on-site injection of effluent contaminated with Sr-90 and other radionuclides, as well as off-site pumping may have complicated the directions of groundwater flow and transport. Therefore, although the general hydraulic gradient in the alluvial aquifer is directed toward the river, off-site transport of contaminants to the east or west is reasonably likely. Off-site transport of contamination is reflected in available groundwater mont-toring data for tritium in borihole 14 and the Vance/Walton private well located off site east of the property. Figure 5 depicts the temporal variation of the tritium concentrations in both wells. Although there is considerable variation in the concentration data, the concentrations in these two wells appear to cor-relate after November 1935. Much of the " noise" in these data may have been caused by sampling or analytical interferences (e.g., cross-contamination via sampling). Tritium concentrations in background groundwater samples range from below detection limit to approximately 2000 pC1/1 (0RAU, 1982). Thus, the ele-vated concentrations detected in the Vance/Walton well appear to be caused by transport of cf.ntaminated groundwater off site. Additional information is i necessary to assess the extent and rate of the off-site trarsport. Figure 6 depicts the spatial distribution of tritium in groundwater samples (ORAU,1982). Most of the elevated concentrations occur along the trend of the abandoned canal from well 21 to well 23 across the back of the site. The high-est concentration detected was 72,200 pCi/1 et well 21. However, the contamina-tion is spread over a larger area than was seen previously for the distribution of Cs-137 and Ra-226 in surface soils. Figure 7 depicts the spatial distribution of Sr-90 in groundwater samples (0RAU, 1982). Sampling programs to date have not been sufficient to characterize the extent and rates of Sr-00 transport in the alluvial aquifer beneath tha site. Available data, however, indicate that shallow groundwater has been significantly contaminated with Sr-90. The data also show widespread distribution of Sr-90 in the groundwater ranging from 3.4 to 62,100 pCi/1. The highest concentration reported is 62.100 pCi/1 in well number 1, which is located immediately adjacent to the disposal pits. According to licensee staff, one of the disposal pits was used during the 1950's to dispose of equipment and wastes contaminated with Sr-90. Thus, the source of the Sr-90 contamination observed in wells 1 and 4 may be leaching and transport of Sr-90 from vaste within the dispose 1 pits. According to M61ser and Earl'(1979), the bottom portions of the disposal pits extend below the water table. Besides the disposal pib and other on-site activities, Sr-90 was also discharged into the groundwater directly by injection into a dry well on site. Frazier (1953) reports that U.S. Radium injected liquid chemical and radioactive wastes in a dry well. Although the location of the dry well is uncertain, the licensee reported that a well in the basement of the former personnel building (contant-nated area number 25) was used for waste storage and disposal. Each month during the early 1950's, approximately 15 to 20 microcuries of Sr-90 were disposed in the well at concentrations around 1 microcurie per liter (Frazier,1953). Such injections could have caused substantial groundwater contamination in the shallow 9

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aquifer beneath the site and may account for the widespread distribution of Sr-90 in the gr~oundwater. Available sampling data for Cs-137 and Ra-226 indicate that concentrations of these constituents in shallow backgroured values (0RAU,1982) groundwater are generally within the range of Exceptions to this generalization are wells 1, 4, 12, and 13 for Cs-137 and well 5 for Ra-226. Sampling and analysis has not been performed to determine the distribution of other radionuclides and non-radiological hazardous constituents in the shallow groundwater. 5. Exposure Analysis Although available sampling and e vironmental information at the Safety Light Corporation site is inadequat? 's cenduct a complete environmental assessment of the contamination, it may b ved to develop preliminary estimates of human exposure to the contamination. Ti,a following section estimates doses to humans resulting from ingestion, inhalation, and direct radiation pathways. These estimates have been developed using conservative calculations that tend to overestimate doses to humans. They should be revised as new information about the transport and fate of contamination on and off site becomes available. 5.1 Direct radiation Gamma radiatiofi levels measured at 1 m above the surface in accessible areas on the property show that exposure rates at the property boundary range fros 7 to 33 micro R/hr (0RAU,1982); two generally elevated areas were noted near the boundary -- one near the northwest corner (18 micro R/hr) and another along the southeast perimeter (133 micro R/hr). Background exposure rates in the Blooms-burg area range from 6-10 micro R/hr. Higher direct radiation rates were detected around the lagoon areas. The maximum direct radiation measured at 1 e above the surface was 133 micro R/hr, south and southeast of the East Lagoon. The only elevated exposure rate off site was detected in the area of the Cs-137 soil contamination, which was since been partially cleaned up. With the preliminary survey data from ORAU, it is estimated that a worker on site exposed outside the plant area for 4 hr/ day and 240 day /yr would receive an average annual whole body dose of approximately 25 mres/yr including back-ground radiation. The highest direct gamma radiation is around the lagoon areas with an average exposure rate of about 100 micro R/hr at 1 m above the ground surface. The exposure rate is more than 10 times above background level. Assuming 75% occupancy time for a permanent resident in this area and a shielding factor of 0.5, the annual whole body dose for this resident is esti-mated to be M0 area /yr. The only elevated exposure rate off site was detected in the area of the Cs-137 soil contamination, which has since been partially cleaned up. All other exposure rates detected along the property line approxi-mate background rates (0SAU, 1982). Therefore, direct radiation exposure will only affect on-site restdents. 5.2 Exposure to Contaminated Soil In addition to direct radiation, an individual may be exposed to contaminated soil via ingestion and inhalation pathways. Preliminary data from soil sampling and analysis at the site show an elevated level of Ra-226, Cs-137, and Sr-90 in 13

surface and subsurface soil. To assess the radiological impact free espc-sure to' contaminated soil, the staff use the average soil concentration from the ORAM survey (0RAU, 1982) including randos and bias sample data which tend to be conservative in dose assessment. tion of Sr-90, Cs-137, and Ra-226 of the site. Table 2 summarizes the soil concentra-Table 2. Radionuclides concentration in contaminated soil Maximum cAid:Utration Radionuclides concentration (pC1/g) 3r-90 15.4 3.5 Cs-137 631 20.1 Ra-226 672 14.3 A resident or worker on site may inhale contamination soil that is resuspended I in the air or radon gas emanated from the soil. Using the average concentra-tions listed in Table 2 assuming a worker exposed outside the p ant area for 4-hdday and 240-day /yr,, and assuming a loading factor of 200 micrograms soil - or cubic meter, the annual doses for a worker are listed in Table 3. Table 3. Annual dose to worker from inhalation Organ Dose (mres) Lung 1.3 x 10-' Bone 1.1 x 10 1 Effective Whole-Body 2.0 x 10 8 Dose conversion factors for the above estimates are derived using the Task Group Lung Models (ICRP-1966) and summarized in NRC's NUREG/CR-0150. Vol. 3 (NRC,1981). As shown in Table 3, the doses to the workers from inhalation of particulate are small compared with the direct gamma radiation on site. The radon emanation rate is estimated to be about 14.3/m8-sec (EPA, 1983). Assuming average wind speed of about 4 m/sec in this area (FSAR, 1984), the resulting t air concentration would be 3.6 x 10 3 pCi/1, which is insignificant compared with the unrestrictive maximum permissible concentration (MPC) of 3 pCi/1 as specified in 10 CFR Part 20 Table II. Indoor radon level is estimated by assuming a. residential house built on the site. The indoor radon is estimated l to be about 0.029 WL (NRC, 1981a). For 75% occupancy, this is equivalent to 0.54 working level month (WLM) or about 540 ares /yr effective whole body dose equivalent (ICRP, 1981). In addition to direct r diation and inhalation, an individual could receive dose from ingestion of food products if the land is released and used for agri-cultural purposes. At present, the land is committed for industrial purposes. Assuming that 50X of annual food products (vegetation, beef, silk) for a resi-dont is consumed from food products grown on site, the doses from ingestion are calculated using/CR-0150, Vol. 3 (NRC, 1981).NRC Regulatory Guide 1.109 ( factors in NUREG Table 4 summarizes the total annual doses from the ingestion of contaminated food products. ____ _ _____ _-_- ____.__ M

I.able 4. Total annual dose from the ingestion of contaminated food products l. Organ Dose (ares) Bone 27.3 Effactive Whole-Bo @

1. 5 Equivalent 5.3 Exposure to Contaminated Groundwater Available groundwater monitoring data indicate that the Safety Ligitt Corporation site has degraded shallow, alluvial groundwater on and off site by increasing radionuclides concentrations (0RAU, 1982).

concer.trations detected in groundwater beneath the site areMaximum and average radi isted in Table 5. These data are generally consistent with tritium concentrations' determined by the licensee and confirmed by the NRC. Table 5 Concentration of radionuclides in groundwater Maxian Average concentration concentration Radionuclides (pC1/1) (pCi/1) H-3 72200 9790 Ra-226 9.1 1.1 Sr-90 62100 10800 Cs-137 57 31.3 Radionuclides concentrations in the contaminated groundwater exceed Maximum Con-taminant Levels (MCLs) prescribed by the U.S. Environmental Protection Agency (EPA) for drinking water from public supplies. Maximum concentrations exceed l the MCLs by up to 3.6 times for H-3,1.8 times for Ra-226, and 7760 times for St-90. Cs-137 concentrations have not been detected in excess of EPA's MCL, which is 160 pCi/1. Clearly Sr-90 contamination in the groundwater poses the largest exposure hazard to on-site residents who say consume groundwater. Con-sumption of 2 liters per day for one year of groundwater at the average concen-tration of 10000 pC1/1 would result in an annual bone dose of 5.4 ren or 0.4 rem effective whole bo # equfvalent. Currently on-site groundwater is not used for human consumption; however, this could occur if the site is released for unrestricted ~use. With the exception of tritium, radionuclides have not beeni detected at elevated concentrations in groundwater off site. Monitoring data reported by the licensee indicates that the concentration of tritium in groundwater in the VanceNalton .well east of the site has exceeded or come close to exceeding EPA's MCL for tritium (20,000 pC1/1) on occasion (see Figure 5). Because of variations in the direction of the hydraulic gradient and limitations of previous sampling programs, it is unknown whether Sr-90 and other radionuclides besides tritium have also been transported off site in groundwater. 15

5. 4 Exposure to contaminated Surface Water The Susquehanna River is the only natural surface water body on or adjacent to the Safety Li t Corporation site.

Because of the large average flow rate of the river (7.@5E61/d) at the site, discharge of contaminated probably not significantly degrade the quality of river water by increasing radionuclides concentrations. Assuming a hydraulic conductivity value of 0.3 m/d, hydraulic gradient of 0.01 m/s, and a cross-sectional area of a potential contaminant plume of 120 e8, the estimated discharge rate of contaminated ground-4 water to the river would be approximately 366 1/d. If the Sr-90 concentration of this water was equal to the maximum detected concentration (62,100 pCi/1) and if the discharge completely mixed with the river water within several hun-dred meters downgradient of the discharge area, the estimated diluted concentra-tion of Sr-90 in the river would be about 3 pCi/1, which is less than EPA's MCL ) for Sr-90 of 8 pCi/1. This diluted concentration is a conservative estimate of the effect of contaminated groundwater discharge on river water quality because (1) the hydraulic conductivity value selected is two orders of magnitude more conservative tsan the conductivity value determined by Meiser and Earl (1979) in alluvius ad,4 cant to the river

2) the assumed area of the plume is con-siderably largar than plumes prese,n(tly detected on site, and (3) Sr-90 co trations are significantly less than 62.100 pC1/1 in groundwater adjacent to the river.

The conservative of the diluted concentration is confirmed by ground

• water, surface water sediment, and aquatic biota monitoring.

Therefore, it is unlikely that discharge of contaminated groundwater to the river will cause significant increases above background levels of radionuclides concentrations l in surface water. 6. Priorities foi contamination Cleanup Although substantial uncertainties currently exist about the extent and signift-cance of radiological and hazardous non-radiological contamination at the Safety Light Corporation site, available information indicates that radionuclides are being transported off site in groundwater and that radionuclides concentrations in groundwater and soil on site preclude release of the site for unrestricted use. In addition transport of the radiological contamination is actively occurring as a res, ult of ongoing leaching of contaminant sources and continued transport of contaminants that were discharged to groundwater by previous dis-posal practices. Therefore, decontamination of portions of the site is warranted to (1) prevent excessive exposures of nearby residents to con-tamination in groundwater off-site and (2) mitigate additional transport of contaminants to minimize the volume of contamination that will ultimately need to be disposed of. Further, additional information is necessary to characterize the extent,of the contamination, to assess risks to nearby residents and to support i@ lamentation of an effective decontamination program. Given limited resources to conduct the decontamination and characterization programs, this section identifies activ.ities that should be given priority consideration as part of the decontamination program. 6.1 Decontamination Priorities Two types of contamination should be cleaned up before other contaminant sources: sources that are actively releasing contaminants to the environment and sources that are causing off-site transport of contaminants. Contaminant sources that are actively releasing contaminants into environmental media should 16

r I i be mitigated or eliminated to reduce. additional contamination at the site. Based orthe di_stribution of radiological contaminants in soil and groundwater at the site, it appears-that the disposal silos, contaminated soil areas, and dump sites are actively releasing contaminants to soil and groundwater. There-fore, the decontamination program should assign first priority to cleanu control of the disposal silos, dump sites, and contaminated soil areas. p and Although the lagoons and drainage canals may be releasing contaminants to soil and groundwater, these sources either have been or are being used for discharge of non-contaminated effluents. It is unknown whether their continued use will further exacerbate contamination at the site. The characterization progras described in the next section should assess the extent to which these sources are actively releasing contaminants to the environment. Other sources of contamination, although significant from the standpoint of dose to on-site residents, do not appear to warrant immediate decontamination. Continued release of contaminants from these sources appears to be occurring at very low rates or not at all. For example, these is no evidence that the con-taminated wall in the carpenter's shop is releasing radionuclides to the environ-The contaminated wall may pose a direct exposure hazard to on-site workers, ment. but exposure may be limited by restricting access, and the radiological hazard is expected to decrease with time without resulting in more widespread contasid-ation. As another example, the well used for injecting contaminated liquid wastes is no longer being used. Although it may have been the most significant source of contamination to the groundwater at one time, it does not appear that the well or the contaminated soils adjacent to the well (if they exist) are actively releasing radionuclides at a sufficient rate to warrant immediate decon-tamination. Except for tritium, radiological contamination of soil and groundwater does not appear to pose immediate hazards for residents off site. Tritium has been detected in off-site groundwater at concentrations in excess of EPA's MCL for drinking water. However, the source of the tritium contamination in the groundwater is presently unknown. Therefore, decontamination of the source of tritium contamination in groundwater should be deferred until after the site has been sufficiently characterized to identify the source and determine how best to dispose of it. The off-site VanceNalton well used for drinking water should be monitored closely. Water samples should be collected at least monthly and analyzed for tritium, Cs-137, Ra-226 and Sr-90. Data should be submitted to NRC and the State for evaluation and for potential remedial action.

6. 2 Characterization Program Prior to initiating decontamination of the sources, additional site characterize-ation information should.be collected and assessed to (1) identify active sources, (2) determine the extent *of contamination associated with the sources, (3) identify other sources that should be given priority consideration for decontamination, and (4) optimize the design of the decontamination activities.

Additional inform-ation needs may be categorized into several topical areas, including source term characterization, contaminant transport assessment, and risk assessment. 17

.s Source tem ch4racterization and contaminant transport assessment should be eghasired prior te selection and design of decontamination activities. The characterization program should place special emphasis on determining the extent and significance of Sr-90 contamination in groundwater. In addition, the source term characterization should include a detailed surface and sub-surface radiological survey to ensure that all contaminated areas are properly identified before the initiation of decontamination. 7. Summary Disposal of radioactive wastes at the Safety Light Corporation site near Blooms-burg, Pennsylvania, has caused extensive contan' nation of groundwater on and off site and soil on site. Current decontamination efforts should focus on cleanup i and control of the disposal silos, open dumps, and contaminated soils to minimize further contamination of the soil and groundwater. Additional information is necessary to characterize the sources of contamination, transport characteristics of the site, and hazards posed to nearby residents by both radiological and j non-radiological hazardous constituents. 8. References I Brown, T., 1978. Letter to F. Combs, October 23, U.S. Radium. Corporation. EPA, 1983. Draft Environmental Impact Statement for Standards for the i Control of 8yproduct Materials from Uranius Ore Processing (40 CFR 192) EPA 520/1-82-022. Frazier, P., 1953. Memorandum to RS8 Files, September 28, U.S. Atomic Energy Commission. i FSAR, 1984. Final Safety Analysis Report - Susquehanna Steam Electric Station, July, 1984, Docket No. 50-387. ICRP, 1966. Task Group on Lung Dynamics, " Deposition and Retention Models for Internal Dosimetry of the Human Respiratory Tract," Health Phys. 12, 173-207, 1966. ICRP, 1981. Limits for Inhalation of Radon Daughters by Workers. International Commission on Radiological Protection, Publication 32, March 1981. Meiser, E., and "Hydrogeologic Investigation of Alluvial Groundwater System, T. Earl, 1979. U.S. Radium Corporation, Bloomsburg, Pennsylvania," Meiser & Earl Hydrogeologists. { NRC, 1981. NUREG/CR-0150, Vol. 3, Estimates of Internal Dose Equivalent l l to 22 Target Organs for Radionuclides occuring in Routine Releases from Nuclear Fuel + Cycle Facility, 1981. ( NRC, 1981a. Disposal or Onsite Storage of Residual Thorium or Uranium (Either as Natural Ores or Without Daughters Present) from Past Operations SECY-81-576, October 5,1981.}}