ML20136A792
| ML20136A792 | |
| Person / Time | |
|---|---|
| Site: | 02700039 |
| Issue date: | 04/04/1979 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20126A746 | List: |
| References | |
| FOIA-92-71 27-0039-79-02, NUDOCS 7906140158 | |
| Download: ML20136A792 (13) | |
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U. S. NUC1. EAR REC.ULATORY COHKISSION OTTICE OF INSPECTION AND ENTORCDENT
- RECION 111 Report No. 27-39/79-02 Docket No. 27-39 License No. 13-10042-01 Licensee Nuclear Engineering Company, Inc.
9200 Shelbyville Fosd Suite 526 P. O. Box 7746 Louisville, KY 40407 Tacility Name Nuclear Engineering Sheffield, IL Burial Facility I
inspection Att Sheffield IL Inspection Conducted: March 9,16, 21, 22, 23, and 29,1979 Inspectors: A. B. v1 Neh9and16) ff/7/
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23 and 29) ' '
C. J. Pap riello (Karch 29) if Y 2 Y Approved By:
QGY A. B. Davis, Chief 'f/y /7 f Fuel Tacility and Materials /
Safety Branch Ins pe c t ion Sununa rf Inspection on March 9.16, 21, 22. 2 3. and 29,1979 (Report No. 27-39/79-02)'
Areas Inspected: Special, announced inspection to ' determine status of the site, includsagt radiation surveys, physica4 toer of the site, radioactive euterial status, site security, enviroinneatal monitoring, and records of licensed activities required by reg $4tiene. The inspection involved i,8 inspector-hours on site by Nuo MC inspectors.
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Re sult s t Of the six areas inspected, six apparent items of noncompliance l vith NRC regulations were identified, all inf ractions. (License :
Condition 8. site security, integrity of fence - Paragraph 7a) t (License Condition 8 - sump monitoring - Paragraph 0) (License '
Condition 8 - surface water runof f sampling -- Paragraph 8) (License -
Condition 8 - security personnel not employed - Paragraph 7b)
) ;, - .. g (10 CFR 30.52(b) - svailability of records - Paragraph 9)
', t (10 CTR 30.$2(a) - access to site - Paragraph 10).
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- e DETAILS
- 1. Persons Contacted T. Eser Vice President Nuclear Engineering Company (KECO)
R. Moore, Site Manager, NECO. Shef field l j
J. Blackburn,1111oots Department of Public Health (March 9 '
1979 portion of inspection only)
A. Amburst, Radiation Safety Officer, NECO, Sheffield Site
- 2. General The inspection was conducted in several parts. The first part ',
was conducted on March 9 and the second part was conducted on March 16,1979. The purpose of the inspection was to (1) determine the present status of the Shef field Lov Level Radioactive Waste Disposal Site relative to the requirements of License No. 1 3-20042-01 (2) conduct radiation surveys of facilities and buildings which were stated by the licensee to have been decontaminated, and (3) determine if all non-buried radioactive waste had been removed from the facility. This special inspection was conducted at this time because Nuclear Engineering Company (NECO) in a letter to KRC dated March 8, 1979, had stated their unilateral intention to terminate the license.
On March 21, 22, 23 and 29, inspections were conducted to determine licenace actions and changes in actions in response to an NRC Order to Show Cause issued on March 20, 1979, an interim compromise with the State of Illinois reached 'during a State Court Hearing on March 22, 1979, and a PreliminaryInjunction issued on Furchby27,the Circuit Court for the 13tle Judicial Circuit of Illinois 1979.
- 3. Licensee Action on Previous Inspection Findings Not Inspected.
- 4. Radiation Surveys l
Independent radiation surveys were conducted by the inspectors.
Direct radiation ocasurements were taken using NRC survey instruments Eberline E500B,_ Sr 322. Eberline E-530, Sr 507, and a Victoreen Thyac III calibrated on January 23,1979. March 3, 1979, and February 10, 1979, _respectively._ In addition, smear samples were taken in various locations of these buildings to assess the degree of removable contaminscion. .The emear samples were analyzed at the NRC-Region III Laboratory. One sample was also analyzed at the Argonne Nationti Laboratory (ANL).
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The acceptance critaris for these measurements vere the dendnimus criteria provided in Draf t Guidelines for Decontamination of Tacilities and Equipment Prior to Release for Unrustricted tlse ,
or Termination of 1,1 cense for Byproduct, Source or Special Nuclear Material dated December 1973.
On March 9,1979, dirtet radiation measurements were made in the Vaste Solidification Building Truck Bay, and Maintenance Shop / Change Room. (The Of fice Building, which is located outside ef the restricted area, was not surveyed.) Direct radiation levels wre also measured at selected locations in the equipment yard and at trenches where sink holes wrs observed (Paragraph 3).
Padiation levels at all areas except the sink holes were '
approximately 0.02 mR/hr. The radiation surveys of the sink holes wra performed at distances ranging f rom ground surface (i.e., at the " mouth" of the hole) to approximately four feet below the ground surface, the location depending on the accessibility of the sink hole. Radiation levels ranged f rom 0.02 mR/hr to 0.3 mR/hr the latter being measured at the
" mouth" of the sink hole near Trench 23.
The smear sample results are shown in Attachment 1.
On March 21, a radiation survey at the bottom of a sink hoia at the east and of Trench 24 showed a radiation level of 1$ mR/hr.
A survey made at the bottom of a sink hole on Trench 23 shoved no levels over background (( 0.02 mR/hr).
On March 23, a radiation survey at the bottom of a sink hole over Trench 14A showed 50 mR/hr as measured with the licensee's Teletector which was calibrated on 2/20/79. A measurement made over an exposed drum in a aink hole over Trench 7 showed a radiation level of 1 mR/hr.
On March 29, radiation surveys of the sink holes observed over
< Trenches 14A and 7A showed radiation levels less than 0.03 mPa/hr.
With the exceptions noted above, all other radiation measurements
- showed levels at background ( v 0.02 - 0.03 mR/hr).
No items of noncompliance or deviations were identified.
$. Tour of the Twenty Acre Burial Site
- a. March 9 and 16, 1979 The inspectors toured the burial site on.ptch 9 and 16,-
1979.
In the burial trench area sink hohs (eettlements) were found at several locations. Thehparea_variedin 4
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ei 8 sire, with the smallest being about 3 f t. x 5 f t. and the largest being about 10 f t. square. The depth of the holes ranged from about 2 to 4 ft. Holes vere found in the following locations:
(1) Trench 23, east end (1 hole)
(2) between trenches 14 and 14A (3 holes spaced along the length of the trenches)
(3) Trench 6 north edge (1 hole)
The Site Operations Kanua? for 1,ov-Level Rad-Vaste Disposal at Shef field, Illinois (Site Operations Manus 1), states that maintenance vill be performed to repair the trenches when veather conditions make such repair practicable.
Practicable conditions did not exist as of March 16, 1979.
Monthly Trench Inspection records show the last inspection of trench condition was performed by the licensee on Tebruary 27, 1979, and the last trench maintenance was pe r f o rme d on De cember 19, 1978.
- b. >b rch 21. 19 79 On March 21, 1979, an NRC inspector toured the burial site.
At this tLme, a new sink hole was observed in an area over Trench 24. This hole was not observed by NRC inspectors on March 9 and 16 and was directly over an area on which the NRC inupector valked on March 16. The hole was about 8 f t. x 12 ft. in area and 10 ft. deep.
- c. March 2 3.1979 On March 23, 1979, an NRC inspector toured the burial site with State of* Illinois representatives. The inspector I
observed licensee employees filling in sink holes. The inspector also observed that repair work had been performed
! on the perimeter fence.
The inspector took smear samples f rom the plastid lined pond inside the Burial Site discussed in Paragraph 6. The 1
inspector split samples with the State of Illinois and I
the licensee of water taken f rom sumps on Trenches 14A and 25C. The results of the analysis of these samples will be reported in a subsequent inspection report.
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The inspector and licaneet personnel made radiation surveys of sink holes over Trenches 14A and 25C prior to the licensee filling these holes.
- d. March 29 1979 Two NRC inspectors toured the burial area to observe conditions and licensee activities on March 29. The inspectors noted that previously observed sink holes had been filled.
The inspectors observed that a sink hole on Trench 14A and two over Trench 7A had reopened af ter being filled.
This had probably occurred the day of the inspection since there was heavy rain the night before and it was raining during the inspection.
The inspectors made radiation measurements over the holes and about 2 ft. into the holes but observed no radiation levels over background (Paragraph 4).
The inspectors observed no activity on the site during the inspection.
No items of noncompliance or deviations were identified.
- 6. Radioactive Material _ Status Visual observations and direct radiation surveys discussed in Section 4 of this report indicated that all radioactive material to be buried or processed had been removed from the facility. Several exempt instrument check sources are still located in the store room. In addition, the plastic lined pond inside the Burial Site, which had been used to store ice with tritium concentrations above the 2 nC1/1 reporting level, still exists.
The inspectors reviewed the following rticords to corroborate this findings
- a. The 1979 Liquid Shipment Los i'
- b. The two latest Radioactive Shipment Records (RSR's)
The Liquid Shipment Log showed all liquids received had been solidified and shipped from the site. The last receipt and
, shipment had occurred on March 7,1979.
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The RSR's did not contain running inventory so they could not be used to corroborate that all solid material had been i shipped from the site.
No items of noncompliance or deviations were identified.
- 7. Site Security
- a. Security Fence Integrity On Karch 9, the inspectors observed damage to the sia foot chain link fence which surrounds the burial site. An area of the fence vest of the parking lot and areas on the east side of the burial site along a road built to the U. S.
Geological Survey funnel showed damage. The fence chain ,
link material was separated from its upper support resulting in gaps of 2 to 3 feet in height. The upper supporc was disengaged in two locations. Strands of barbed wire were missing f rom the fence top at one location.
Section 4.1.1 of the Site Operations Manual states that principsi perimeter security of the burial site is neintained by a continuous six foot chain link fence topped with three strands of btrbed wire. It further states that the integrity of this perimeter fence must be maintained at all times.
The condition of the fence was not in conformance with this Manual requirement and is, therefore, in noncompliance with License No. 13-10042-01, Condition 8.
l By March 21, repair of the ' security fence was undervsy and i
' on March 29, inspectors observed no portion of the fence in need of repairs and observed several locations where new fencing had been installed.
- b. Other Security Measures By contact with the County Sheriff, observation, discussion l vith a licensee representative, and review of records, the inspectors determined the following relative to security (1) The County Sheriff makes periodic checks of the f acility during non-business hours. During the March 16 inspection, an *Illinois State Policeman stopped at the site.
(2) The licensee has not employed security personnel from private agencies and is not conducting periodic patrols of the Burial Site restricted ares as required by Saction 4.3 of the Site Operations Manual. Therefore, the licensee is in noncompliance with License No.
13-10042-01, Condition 8.
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(3) The NECO industrial security program is in effect.
Since the burial site is within NICO property, this site benefits f rom the industrial security program.
(4) NECO personnel have continued checking to assure burial site gates are closed and locked. The stated reason for this check is that there is soon NICO owned property inside the burial site fence.
($) Licensee personnel intend to notify appropriate authorities of any security or energency problema relative to the burial site should any occur. They would act as responsible citizens in this regard.
(6) The licensee is continuing to maintain the Af ter Shif t and Weekend Log, which includes a security check. Since March 8,1979, six entries have been entered into this log indicating licensee personnel presence at the site during weekend or non day shift hours.
- c. Site Security Audits Section 4.0 of the Radiological Control and Safety Manual states that the Chief Radiological Control and Safety Of ficer will be directly responsible for the implementation of an audit program and an in depth audit of specific areas of Radiological Control and Safety will be conducted qua r t e rly. As part of this audit, the burial site security is reviewed. According to a licensee representative, this audit was conducted on March 8,1979.
The report for this audit has not yet been written. It vill be reviewed during a future inspection.
In addition, the licens3e conducts an administrative audit on a quarterly basis by persons appointed by a member of corporate managemant which includes a review of site security. Records of these audits were reviewed during this inspection. The last audit was performed February 9,1979.
Ivo items of noncompliance vere identified.
- 8. Environmental Monitoring Program The environmental monitoring program for trenthes 14 and 14A, which is required by Condition No. 8 of License No. 13-10042-01, Amendment No.11, was examined. The program, %ich is ' conducted according to Procedure SI.002 of the Site Operatipos Manual, requires permanent sump, surface run-of f, well, and air sampling.
In addition, operational portable grab air samples and aqueous i
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e intrusion veter samples are required, when there are open trenches. Racords were reviewed for the period of January 1978 through February 27, 1979. nis review and discussion with licensee representatives verified that sample coilsetton and analyses have been performed as required through that date and that action levels have not been exceeded. However, the weekly monitoring of Trench 14 and 14A sumps has not been performed as required by Procedure S1.002, Section 6.1.1. nis constitutes noncompliance with License Condition No. 8.
In addition, surface runoff samples have not been collected for the weeks of b r:h 5 and 12 as required by Procedure S1.002, Section 6.1.2. This constitutes noncompliance with License Condition No. 8.
The licensee samples ground and surface water, soil, and vegetation on a quarterly basis, onsite and offsite. ne samples are analyzed for gross alpha, gross beta and tritium.
D e inspectors reviewed these sample results for calendar year 1978 and no problem areas or anomalous results were noted.
Two itema of noncompliance vere identified.
- 9. Availability of 1,teensee Records On March 21, the inspector asked the Site knager several questions and asked to see several licensee records. Dese are as follows:
- a. Does NECO intend to honor the NRC " Order to Show Cause" and meet its requirements as a licensee?
- b. Are there any records to indicate that NECO has met the measurements of soil density requirements outlined in a letter to Licensing dated May 10, 1967, and in the Site Operations knual as referenced in Amendment 11 to the license dated January 1977. If no records exist or are available, how did NECO determine the requirements we re met ?
- c. Will NECO connait to the repair of the damaged security fence noted during the inspections on March 9 and 16, 19797
- d. Will NECO repair the sink holes neted in several areas on the site?
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- e. Is NECO performing the required monitoring of the trench
, sumps and collectirB the water runof f samples as requiredt
- f. Will NECO assume the functions of a guard force as required in Section 4.3 of the Site Operations Manual until a contract guard force can be obtained?
- g. Does NICO have records to show that Trenches 14 and 14A were constructed in accordance with the application f or lic e nse ame ndment ?
Af ter calling the NYC0 Corporate Office, the Site Manager told the inspector that the above qctstions would have to be raised with NECO's Corporate legal Counsel.
On March 22, 1979, the inspector asked the Site Manager several que stions. These vere as follows:
- a. Has there been any monitorint of the trench sumps or have any water runof f samples been taken in accordance with Section 6.1.1 and 6.1.2 of the Site Operations Manual since the NRC " Order to Show Cause" was issued?
- b. Has the licensee started security patrols of the area in accordance with Section 4.3 of the Site Operations Manual?
- c. Mas the licensee been repairing the fence since the Order was issued?
With respect to the first two questions, the Site Manager told the inspector that this matter would have to be raised by the NRC with the licensee's attorney. With respect to question c., the Site Manager told the inspector that some of the fence has been and is being repaired.
On March 29, 1979, two NRC inspectors asked the same questions as were asked on March 21, 1979. In addition, the NRC inspectors asked to see personnel exposure records required by 10 CTR 20.401, personnel bionssay records required by the license and records of airborne monitoring required by the license.
Af ter calling the KECO Corporate Office, the Site Manager i
told the inspectors that any request for these records should be made to the corporate attorney.
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' Failure to make available to the Commission for inspection,
- records kept as required by the regulations and his License, is an item of noncompliance with respect to 10 C7130.52(b), '
10 CTR 40.62(b) and 10 CFR 70.55(b).
One item of noncompliance was identified.
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) 10. Access to the site on Nrch 29, 1979, at about 11:30 a.m., the W3C inepectors stated that they wanted access to the burial area. The $1te knager stated that he needed permission from the Corporate Office to open the gate to the burial area. N Site Manager. '
af ter calling the Corporate Office, told the inspectors that the legal staf f who could give permission were at lunch. At about 1845 p.m., the Site knager told the fuspectors since his key was a duplicate of the key possessed by the State of ;
Illinois, the inspectors vould be allowed on site if permission of the State was obtained. The NRC inspectors called the ,
State and obtained their permission since the inspectors believed it important to directly observe current conditions on the site. At 2:00 p.m., the licensee's Radiation Safety Of ficer opened the gate and allowed the inspectors to tour the burial area.
The f ailure of the licensee to grant Consnission inspectora oc: ass ts the burial area is an item of noncompliance with 10 CTR 30.52(a),10 CTR 40.62(a), and 10 CTR 70.5$(a).
One item of noncompliance was identified.
- 11. h.it Int e rview The inspectors met with licensee representativas (denoted in Paragraph 1) at the conclusion of all parts of this inspection.
On March 9 and 16,1979, the following items were discussed:
- a. The item of noncompliance relative to the condition of the security fence. (Paragraph 7.a)~
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- b. Other security measures and audits. (Paragraph 7.b and 7.c)
- c. The item of noncompliance relative to the failure to perform weekly sampling of Trenches 14 and 14 A sumps and.
surface runoff water. (Paragraph 8)
- d. The status of smear sample results and the possibility that iodine-125 levels at two locations exceeded the dominimus criteria.
NOTE: In a telephone conversation on h rch .\9, 1979, the Site Manager was informed of. the results reported in Section 4 of this report and agreed to further decontaminate the areas with high iodine-125 surf ace contamination levels.
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- e. ne condition of the trenches, perticularly with respect to the sink holes, the licensee's intentions relative to trench maintenance, and the inspector's finding that trench maintenance was not yet practicable due to ground conditions but soon would be. ne licensee stated that trench maintenance is no longer a NECO responsibility,
- f. ne licensee audio taped the exit interview and other discussions during the inspection. He agreed to provide the inspectors with a transcript of the informa-tion taped.
he inspection findings were discussed at the site on March 23 and 29, 1979, with the Site Hansger. In addition, the items of noncompliance identified during all phases of the inspection were discussed in a telephone conversation between Hr. A. B. Davis, NRC, and Mr. T. Bae r, Vice President of NECO on March M,1979.
At t a chte n t 1 Attachment 1 2269 280
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ATTACMMINT 1
, Result Alpha Beta Location (drs/100 cm2) Idpe/100 cm2)
, 1 Maint. bay - shop ares (1 0 south end, near door 2 Store room source 0 7 3 Drum in storage area (1 0 4 North vs11 2 25 5 rioor east vall 2 0 6 East vall 3 16 7 S.E. floor 5 0 8 S.W. corner floor (1 0 9 Vest vall* h 5 125 10 West floor center N (1 13 11 N.V. corner floor o (1 0 12 Inside washing machine C g 3 0 13 Under clothes dryer U 2 0 14 Floor N.E. corner 9 g 3 8 15 Shelf east vall E 6 6 16 Shelf west vall y 5 17 17 Sump cover inside vail C (1 11 center of room j 18 Floor - between center of 2 4 5 vall door and drain 19 Floor - between center of N 2 (1 vall and drain 20 Floor - center of N vall 3 0 21 Change room 0 18 i . *These results exceed the dominimus criteria for iodine-125; therefore;
, additional decontamination vill be required.
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