Safety Light Corporation (Commonwealth of Pennsylvania)
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1.0 Site Identification
|Type of Site:||Complex Decommissioning Site|
|License No.:||37-00030-02; 37-00030-08|
|Docket No.:||030-05980; 030-05982|
2.0 Site Status Summary
Safety Light Corporation (SLC) holds an expired license (License No. 37-00030-08), formerly for the manufacture of tritium exit signs, and for site characterization and decommissioning activities (License No. 37-00030-02). Contamination at the site is from the manufacturing operations of self-luminous watch and instrument dials and other items involving Ra-226, Cs-137, Sr-90, and Am-241. Radioactive waste was disposed on site in three primary locations: silos, lagoons, and a waste dump. Primary soil contaminates include Ra-226 and Cs-137 with small amounts of Am-241. The onsite ground water is also contaminated with H-3, Sr-90, and Cs-137.
In October and December 2000, SLC submitted a DP to NRC which called for a "task by task" approach to decommissioning because of limited funding availability. The DP presents decommissioning activities which will make the site suitable for unrestricted release. This approach was approved by NRC in December 2001, and on August 15, 2002, NRC amended the SLC license to approve the work plan for processing and sorting waste that was removed from two underground silos in the fall of 1999.
An EPA Administrative Order of Consent with SLC for the sorting, characterization, and re-packaging of the drums of mixed waste and radioactive waste that were removed from the onsite silos, became effective on February 3, 2003. Under the EPA Emergency Removal Action, three shipments of radioactive material to an offsite disposal facility were completed by November 15, 2004. Disposal costs are expected to exceed the licensee's decommissioning funds, so EPA is expected to propose a unilateral Order and use EPA emergency removal funds to complete disposal of the underground silo waste. On September 23, 2004, EPA proposed adding SLC to the National Priority List (NPL). Two public meetings were held on Novemeber 4 in Bloomsburg, PA to inform the public of the proposal and to answer questions. SLC was added to the NPL in an April 27, 2005 rulemaking (70 FR 21644).
Remedial investigation studies for groundwater, buildings and soil were initiated in October 2004, January 2006 and May 2006, respectively. As of March 2007, EPA and EPA contractors completed shipment of 167 drums of silo waste, to WCS (Texas) for temporary storage, that had been stored at SLC. Approximately 50 drums and several B-25 boxes containing silo waste remain in storage at the SLC site. Activities associated with preparations to dismantle various buildings are ongoing.
The licensee estimates the cost of decommissioning to be approximately $29 million. An NRC analysis of the licensee's Decommissioning Cost Estimate concluded that the decommissioning cost for unrestricted release of the site by the licensee was estimated to be between $94 and $120 million, and to be $50 million to $78 million for restricted release.
The first use of radioactive material at the Bloomsburg site occurred in 1948, following the relocation of U.S. Radium operation from Brooklyn to Bloomsburg and disposal of radium at Bloomsburg. Multiple licenses were held at this site. Manufacturing activities involved luminous items such as military dials/gauge faces, deck markers, and paint. Initially, radionuclides included radium, Sr-90 and Cs-137, but as of 1979, only H3 was used in manufacturing.
Between 1948 and 1951, U.S. Radium constructed one or two underground silos for disposal of radioactive waste. A 1953 AEC inspection report described how ordinary liquid chemical wastes, as well as liquid wastes containing both naturally-occurring radioactivity and Commission-distributed activity, were discharged into a dry well. A 1959 AEC inspection report described how liquid radioactive wastes were released into the canal on site and subsequently drained through the ground into the Susquehanna River. It is likely that this disposal method resulted in contamination of the soil under and around the canal.
The new tritium operations facility was built in 1968-69 and License No. 37-00030-08 was issued in 1969. That same year, License No. 37-00030-02 was renewed for 1 year, allowing only decommissioning activities. In June 1977, U.S. Radium began the process to renew License No. 37-00030-02. The NRC required greater detail regarding U.S. Radium's plans and a schedule for carrying out these decontamination activities. The renewed license contains both a requirement to perform specified activities and to provide the NRC with a schedule for future activities.
In May of 1980, U.S. Radium began a period of corporate restructuring, which resulted in the transformation of its Nuclear Division, first into a wholly owned subsidiary corporation and then, following a sale, into an independent company with separate management (Safety Light Corporation). The NRC was unaware of the restructuring until 1983, when this matter was discussed during a routine inspection. No notification of the restructuring or the sale was made to the NRC by U.S. Radium or Safety Light Corporation, although the NRC was informed of an apparently simple name change to Safety Light Corporation in 1981.
During the period from 1980 through the 1990s, various special and routine inspections and licensing actions occurred for the decommissioning activities under the -02 license, and for manufacturing under the -08 license. The site's major activity was the manufacture of exit signs and aircraft signs containing tritium, which included the filling of the tubes used in the signs. Tube filling operations ceased around 1994, which drastically reduced the environmental releases of tritium from the site. Manufacture of tritium foils ceased in mid-2007, and the receipt of returned signs for recycling ceased on October 31, 2007. All activities ceased on December 31, 2007.
In October and December 2000, SLC submitted a decommissioning plan (DP) to NRC which called for a "task by task" approach to decommissioning because of limited funding availability. The DP presented decommissioning activities which were intended to make the site suitable for unrestricted release. This approach was approved by NRC in December 2001. Additionally, on August 15, 2002, NRC amended the SLC license to approve a work plan for processing and sorting the waste that had previously been exhumed from the two underground silos and containerized in the fall of 1999. The licensee estimated the cost of decommissioning to be approximately $29 million. An NRC analysis of the licensee's Decommissioning Cost Estimate concluded that the decommissioning cost for unrestricted release of the site by the licensee was estimated to be between $94 and $120 million, and to be $50 million to $78 million for restricted release. These values are expressed in year-2000 dollars.
Shortly after the silo waste was exhumed, EPA entered into an Administrative Order of Consent with SLC for the implementation of a Non-Time Critical Emergency Removal Action involving the sorting, characterization, re-packaging and disposal of the ex-silo waste. This order became effective on February 3, 2003. Under the EPA Emergency Removal Action, three shipments of radioactive material to an offsite disposal facility were completed by November 15, 2004. Disposal costs exhausted the licensee's decommissioning funds, so EPA issued a unilateral Order and used EPA emergency removal funds to complete disposal of the ex-silo waste. On September 23, 2004, EPA proposed adding SLC to the National Priority List (NPL).
Two public meetings were held on November 4 in Bloomsburg, PA to inform the public of the proposal and to answer questions. SLC was added to the NPL in an April 27, 2005 rulemaking (70 FR 21644). Remedial investigation studies for groundwater, buildings and soil were initiated in October 2004, January 2006 and May 2006, respectively. The EPA, via an inter-agency agreement, obtained the assistance of the U.S. Army Corps of Engineers to remove, sort, the characterized ex-silo waste from the site. As of March 2007, 167 drums of the ex-silo waste had been shipped to Waste Control Specialists (WCS) in Andrews, Texas for temporary storage. Additional waste shipments were subsequently made to EnergySolutions in Clive, Utah. As of July 2010, one drum containing radium remains on the site in a shielded area awaiting disposition. In 2012, WCS received authorization from Texas to permanently dispose of the ex-silo waste at the Andrews, Texas facility.
In 2008-2009, U.S. Army Corps of Engineers removed seven of the most dilapidated buildings from the site along with the temporary silo waste building. The building demolition debris was shipped to a U.S. Ecology RCRA "C"; landfill in Idaho. The debris was exempted from regulation as radioactive waste by the Commonwealth of Pennsylvania. In 2011 the Susquehanna River level rose to historic levels as a result of tropical storm Lee partially flooding the SLC site. Post-flood sampling revealed the presence of low levels of site contamination on the adjacent downstream residential property. The off-site contamination was found immediately downstream from the site's "West Dump." In 2013 EPA removed contaminated soil from the adjacent property and consolidated that soil with the contaminated soil and debris in the West Dump. The West Dump was shaped and covered with gravel and soil to limit future erosion.
In 2012, in response to concerns about the deteriorating condition of the SLC Main Building, EPA performed a structural evaluation of the building. This study revealed numerous structural deficiencies that threatened to cause partial collapse of the building. EPA implemented a plan to strengthen and preserve the building and to remove large quantities of debris from the building to reduce excessive weight and fire loading.