ML20034H187
| ML20034H187 | |
| Person / Time | |
|---|---|
| Issue date: | 03/12/1993 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-93-062, SECY-93-62, NUDOCS 9303160144 | |
| Download: ML20034H187 (10) | |
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March 12, 1993 SECY-93-062 (Informat. ion)
FOR:
The Commissioners FROM:
James M. Taylor, Executive Director for Operations
SUBJECT:
REMOVAL OF BUDD COMPANY FROM SITE DECOMMISSIONING MANAGEMENT PLAN PURPOSE:
To notify the Commission that remedial action has been completed on the Budd Company (Budd) site in Philadelphia, Pennsylvania, and that the staff plans to release the site for unrestricted use, terminate the license and remove the site from the Site Decommissioning Management Plan (SDMP).
SUMMARY
From 1956 through 1967, the Budd Company operated a hot cell facility to manufacture sealed sources for use in industrial radiography..In 1967, Budd terminated source manufacturing operations and conducted-limited decommissioning of the facility. Remediation activities resumed in July 1991 and were completed in May 1992. Based on the actions taken by the licensee, staff review of the surveys performed and the results of an NRC confirmatory survey, staff concludes that decommissioning activities are complete and the I
site is ready to be released for unrestricted use.
BACKGROUND:
In SECY-90-121, the original SDMP, and in subsequent revisions to the SDMP (SECY-91-096 and SECY-92-200), the staff identified approximately 40 sites where remedial action was required due to the presence of residual
Contact:
M. Roberts, RI NOTE:
TO BE MADE PUBLICLY AVAILABLE (215) 337-5094 IN 10 WORKING DAYS FROM THE DATE OF THIS PAPER M. Harvey, NMSS (301) 504-2522 4
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contaminated material.
One of these sites is the Budd Company facility in Philadelphia, Pennsylvania.
The site is now ready for release for unrestricted use and removal from the SDMP list of sites requiring remedial action.
SITE HISTORY:
The Budd Company operated a hot cell facility at 2950 Roberts Avenue in Philadelphia, Pennsylvania from 1956 through 1967.
Budd was licensed to manufacture sealed iridium-192 (Ir-192), thulium-170 (Tm-170) and cobalt-60 (Co-60) sources for use in industrial radiography. A small amount of unsealed cesium-137 (Cs-137) was also used for a brief time at the facility.
The hot cell is an "L-shaped" structure of approximately 20 square meters (200 square feet) attached to an outside corner of a larger building (the X-ray Building).
The walls and roof of the hot cell are composed of reinforced concrete from 0.9 to 1.2 meters (three to four feet) thick.
Penetrations included an access door, ventilation and exhaust ports, a shielded window for observation, and ports for the manipulators used to remotely perform operations inside the hot cell.
Licensed material was stored at the bottom of two 1.2 meter (four-foot) deep storage wells in the floor of the hot cell, opposite the window.
A 75 centimeter (thirty-inch) deep stainless steel lined pit (the " cesium pit"), located between the two storage wells, was used to store other objects.
In 1967 Budd terminated source manufacturing operations and began limited decommissioning of the facility. At that time, large amounts of equipment and licensed material were removed from the cell and properly disposed or transferred.
The interior of the hot cell was cleaned, but not completely remediated.
The walls of the hot cell were painted to stabilize loose contamination.
Since the hot cell had not undergone complete remediation, the window and door openings were sealed with 40 centimeter (16-inch) thick concrete block and structural steel. All other openings to the cell were also sealed to maintain the integrity of the cell.
At the time of facility shutdown, the quantity of Co-60 in the hot cell was estimated to be approximately 5 curies. All Ir-192 and Tm-170 remaining decayed to insignificant levels due to the long entombment period (25 years) and the relatively short half-lives of Ir-192 (74 days) and Tm-170 (129 days). The interior of the cells was maintained as a restricted area until remediation began in July 1991.
Budd performed periodic surveillance to ensure that the integrity of the cell was maintained.
In December 1988 the licensee requested renewal of its NRC license authorizing storage of the contaminated hot cell and equipment for decay. This request for renewal was deemed to be filed in a timely manner. However, in May 1990, j
Region 1 informed the licensee that the NRC was unwilling to renew the license to permit continued storage of the contaminated material and requested that a plan for characterization of the radiological status of the facility be submitted for NRC approval. Once the characterization plan was approved and l
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implemented, the licensee was to submit a decommissioning plan for the facility and a schedule for performing the decommissioning.
CHARACTERIZATION:
The licensee contracted with Westinghouse Scientific Ecology Group, Inc. (SEG) to perform both the characterization and remediation tasks.
In November 1990 the licensee submitted a characterization plan.
Region I approved the plan and the licensee's contractor performed the characterization in December 1990.
Characterization of the bot cell was accomplished by drilling four five-centimeter (two-inch) holes through the exterior walls of the cell.
Based on the results of direct measurements made through the holes and the analysis of the concrete cores and smears obtained from inside the cell, a remediation plan was prepared by the contractor and submitted to Region I in April 1991.
The decommissioning plan was approved in late April 1991.
REMEDIATION:
Remediation was conducted from July 1991 through May 1992 and included a final radiological survey of the facility.
Since there was limited information concerning the condition of the hot cell at the time of its entombment, conservative precautions were used for the initial opening of the hot cell including operation of a high efficiency particulate air (HEPA) filter system to capture airborne contamination generated as a result of decommissioning operations.
Contaminated equipment, including portions of the original ventilation system, lighting fixtures and a small overhead crane and crane rail were found at the entrance to the cell.
This contaminated equipment was removed from the cell and discarded as radioactive waste.
Radiation exposure rates in the cell were generally less than 5 milliroentgens/ hour; however, higher exposure rates were measured above the source storage wells and the cesium pit.
A layer of concrete and lead sheets covering this area limited the exposure rate in this location to approximately 20 milliroentgens/ hour.
After removal of the concrete and lead shielding, exposure rates ranging from 80 to 300 milliroentgens/ hour were measured on contact with the source storage wells and cesium pit.
Due to elevated exposure rates and the uncertainties in the amount of shielding in the wells, the amount of radioactivity remaining in the storage wells and cesium pit could not be accurately estimated.
Therefore, the licensee revised the decommissioning plan to include additional radiation safety controls necessary for handling larger amounts of radioactivity than originally anticipated. The storage wells were removed by cutting out a concrete core around each steel well and hoisting each well out of the cell with a large crane. Based on direct measurements, one of the wells was estimated to contain up to 800 millicuries of Co-60 at the time of removal.
Transportation and disposal of this source well necessitated the use of a special transportation liner and cask. The second source well and the cesium pit contained significantly less activity and did not require extraordinary measures for removal. All three objects were shipped to the SEG facility in Tennessee for processing and disposal.
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After removing the higher activity material from the hot cell, contaminated i
surfaces of the concrete floor, ceiling, and walls were removed with scabbling devices.
Small amounts of contamination fixed in the concrete on the floor and walls outside the hot cell were also removed. Areas inside the X-ray Building above the hot cell including electrical cables and a cat walk were also surveyed and remediated as necessary.
Region I inspected the characterization and remediation activities on at least five separate occasions.
SURVEYS AND LIMITS:
Surveys provided by the licensee show that all floor, ceiling and wall surfaces now meet the criteria for acceptable surface contamination found in the NRC's " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source or Special Nuclear Material," May 1987. ThecriteriaforCo-p0and/ orcs-137 are no more than p,(000 disintegrations per minute (dpm)/100 cm (average)pnd 15,000 dpm/100 cm maximum) for total contamination and 1,000 dpm/100 cm for removable contamination.
The licensee surveyed 100% of the interior of the hot cell using 100 square centimeter gas-flow proportional detectors.
Average and maximum values were tabulated for each wall, ceiling, and floor surface. Average total 2
contaminationva]uesfortheinteriorsurfacesrangedfrom310dpm/100cm to 2
1,100 dpm/100 cm. Maximum values ranged from 1,700 dpm/100 cm to 2
8,500 dpm/100 cm for these areas.
Nearly 5,000 direct measurements were made inside the cell.
Removable contamination was assessed by taking smears and counting them with a shielded GM detector and scaler. 2Results of the 635 smearstakenjnsidethehotcellaveraged16dpm/100cm with a maximum of 143 dpm/100cm.
Surveys were conducted outside the hot cell with larger area probes (300 or 550 square centimeters) and similar results were obtained.
Contaminated concrete and a small amount of contaminated soil were excavated from the area beneath and surrounding the two source wells and the cesium pit.
No other locations were found to have radioactive contamination distributed throughout soil or concrete.
The residual concentrations of Co-60 in soil samples from beneath the cesium pit, taken and analyzed by the contractor, averaged 2 picocuries (pCi)/ gram. The concentration of Cs-137 was less than the detection limit in all samples.
Separate soil samples taken during an NRC confirmatory survey of the facility averaged 6.1 pCi/ gram for Co-60 and 0.1 pCi/ gram for Cs-137. This difference in Co-60 concentrations is not significant due to the small number of samples analyzed and typical variation in environmental sampling.
In the original decommissioning plan, the licensee had not proposed criteria for residual radioactive contamination in soil. On a case-by-case basis, the staff has developed or provided criteria for release of property whose soil shows evidence of radioactive contamination.
Values previously used for Co-60 and Cs-137 are 8 pCi/ gram and 15 pCi/ gram, respectively. Where more than one t
radionuclide is present, the sum of the ratios of the individual concentrations to their respective concentration limits normally may not
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exceed unity.
These specific criteria have previously been presented in the
" Order Establishing Criteria and Schedule for Decommissioning the Bloomsburg Site" (57 8 6136-6141) and in a May 6, 1987, memorandum from J. Hickey, Office of Nuclear Material Safety and Safeguards to W. Cline, RII, providing an evaluation of acceptability of proposed decommissioning activities for a hot cell facility at Fort McClellan, Alabama. This latter memorandum indicates that the primary pathway for exposure to individuals for these nuclides is by direct radiation and that the concentration limits were developed by assuming that gamma exposure rates should not exceed 10 microroentgens/ hour above background for an area of greater than about 9 meters by 9 meters (30ft x 30ft) and should not exceed 20 microroentgens/ hour above background for discrete areas.
Exposure rate measurements in the Budd hot cell average about 3 microroentgens/ hour above background following remediation.
The measured exposure rates in the excavated area of the hot cell are the same as the remainder of the cell and, thus, do not indicate any discrete areas of contamination. After review of the soil sample data and the exposure rates for the excavated area, the staff concludes that the facility meets these guidelines for residual soil contamination since the residual soil concentrations for Co-60 and Cs-137 are less than 8 pCi/ gram and 15 pCi/ gram, respectively, the sum of the ratios of the individual radionuclide concentrations to the respective concentration limits are less than unity, and the exposure rate basis for the concentration values is met.
Surveys conducted outside the building indicated exposure rates indistinguishable from background (8-10 microroentgens/ hour). Measurements on the roofs of the hot cell and the X-ray Building were also indistinguishable from background.
Exposure rate measurements made inside the X-ray Building, in a small room outside, but adjacent to the hot cell, indicate elevated exposure rates ranging from 19.5 to 37 microroentgens/ hour (background included).
Examination of the surface scan data did not indicate the presence of superficial contamination. Analysis of samples of the concrete block wall indicated elevated concentrations of naturally occurring uranium-238 (U-238) and thorium-232 (Th-232) (and their radioactive decay products) in the concrete.
Calculations by the Region I staff using the data from the sample analyses, the actual dimensions of the room and assuming a homogenous distribution of the naturally occurring radioactive materials in the walls show that the measured exposure rate is completely attributable to the sum of the natural background exposure rate and the exposure rate contribution from the walls of the room. The staff concludes that the facility meets the exposure rate criteria (exposure rates not to exceed 5 microroentgen/ hour above natural background) identified in the " Action Plan to Ensure Timely Cleanup of Site Decommissioning Management Plan Sites" (57 813389-13392).
The contamination found in the soil does not indicate any potential for groundwater contamination because the manufacture of the sealed sources did not involve the use of water or other liquid solvent that could have carried the contamination down to groundwater. The contaminated soil was covered by a building, which prevented rain water from infiltrating and leaching the residually contaminated soil and transporting contamination to the water table. The contaminated soil, removed from below the cesium pit, was confined to a small area.
For these reasons, and the fact that the highest level of
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contamination was found to be just below the cesium pit's stainless steel liner, it is highly unlikely that contamination moved to the groundwater.
As a check against potential groundwater impact from the residual contamination remaining onsite, the Department of Energy's RESRAD radiological dose assessment code was run, assuming a highly conservative family farm scenario, using site-specific information, where available, and conservative or default values when the information was unknown.
A maximum dose equivalent of less than 0.1 millirem per year was calculated for the groundwater pathway and less than 1.0 millirem per year for all pathways. These calculated values are a small fraction of current (500 millirem per year) and new Part 20 (100 millirem per year) dose limits for individual members of the public.
All radioactive waste generated at the facility was removed by SEG and transported to SEG's Oak Ridge, Tennessee facility for volume reduction and eventual disposal at a licensed low-level waste burial site.
After completion of the remediation activities in May 1992, the licensee's contractor performed an extensive survey of the remediated areas and adjacent areas where no remediation was performed.
NRC staff reviewed the draft data and performed a confirmatory survey and inspection on May 10 and 11 while the contractor was still at the site.
Staff reviewed the licensee's final report of the closecut survey after it was received on September 26, 1992, and concludes that the licensee's survey accurately describes the condition of the facility.
Region I also reviewed previous Budd Company licenses for the Philadelphia site and certain licenses of Budd Company's successor, Automation Industries, Inc.
Staff conducted this review to determine if there is any historical information concerning spills, lost sources, releases of material, or other information which would indicate the need for additional remediation or investigation at the site.
Based on this review, staff concludes that licensed sealed sources were properly disposed and the decommissioning activities and surveys conducted by Budd's contractor addressed all appropriate areas.
CONCLUSIONS:
Based on the remedial activities detailed above, staff review of the licensee's closecut report, the results of NRC's confirmatory survey, and staff's review of historical information about the site, staff concludes that decommissioning has been completed in a satisfactory manner.
Staff plans to formally notify the licensee, by letter, that the Nuclear Regulatory Commission " plans no further action on this site".
Region I will terminate the current license for decommissioning as requested by the licensee in a letter dated September 24, 1992. Drafts of the letter to be sent to the licensee and the amendment terminating License No. 37-05680-04 are enclosed.
The site will also be removed from the SDMP.
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Region I transmitted a copy of the final inspection report and confirmatory survey to the Commonwealth of Pennsylvania, Department of Environmental Resources and discussed the results with the Commonwealth.
Pennsylvania representatives indicated by letter, dated January 25, 1993, that they have no unresolved concerns regarding the radiological issues at the site.
Staff also sent a letter to the Environmental Protection Agency on February 9,1993, informing them of NRC's intent to terminate the license and remove the site from the SDMP.
COORDINATION:
The Offices of Congressional Affairs and Public Affairs have reviewed this paper and concurred. The Office of the General Counsel has reviewed this paper and has no legal objection.
d <y es H. Tay)tr
- ecutiveDirector for Operations
Enclosures:
1.
Draft letter to The Budd Company 2.
Draft Amendment Terminating License No. 37-05680-04 DISTRIBUTION:
Cocunissioners OGC OCAA OIG OPA OPP ICEGION I EDO ACNW SECY
- 4 DRAFT License No. 37-05680-04 Docket No. 030-19963 Control No. 117340 The Budd Company ATrN: Richard Lemke Counsel 3155 West Big Beaver Road Troy, Michigan 48084
Dear Mr. Lemke:
SUBJECT:
THE BUDD COMPANY HOT CELL FACILITY IN PHILADELPHIA, PENNSYLVANIA This refers to your Radiological Remediation Report dated September 24,1992 regarding the Budd Company hc.t cell facility at 2950 Roberts Avenue, Philadelphia, Pennsylvania and to your request that License No. 37-05680-04 be terminated. Based on this report, we understand that Budd believes that the site has been adequately remediated to allow unrestricted use.
The results of the surveys and analyses performed indicate that all areas of the facility meet the criteria found in the NRC's " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source or Special Nuclear Material", May 1987 and also meet the current soil contamination criteria developed by the NRC staff and applied on a case-by-case basis.
After reviewing your reports and surveys of this property and conducting our own survey, we conclude that further remedial action is not required. Therefore, the NRC no longer has any regulatory concern with regard to this property. The facility at 2950 Roberts Avenue, Philadelphia, Pennsylvania is hereby released for unrestricted use. Amendment No. 03 terminating License No. 37-05680-04 is enclosed.
As noted in the Action Plan (57 ER 13389), this is the final action of the Commission on the referenced license. The NRC will not require any additional decommissioning in response to future NRC criteria or standards, except in the event that additional contamination, or i
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noncompliance with the Decommissioning Plan approved by NRC in April 1991, is found indicating a significant threat to public health and safety. Noncompliance would occur when a licensee does not comply with the approved Decommissioning Plan, or provides false information.
Thank you for your cooperation in this matter. Please contact me at (215) 337-5252 if you have any questions.
Sincerely, John D. Kinneman, Chief Research, Development and Decommissioning Section Division of Radiation Safety and Safeguards
Enclosure:
Amendment No. 03 bec:
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