ML20035G214
| ML20035G214 | |
| Person / Time | |
|---|---|
| Site: | 07000903 |
| Issue date: | 04/20/1993 |
| From: | Joseph Austin NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Wolff J CHEVRON U.S.A., INC. |
| Shared Package | |
| ML20035G215 | List: |
| References | |
| NUDOCS 9304270009 | |
| Download: ML20035G214 (6) | |
Text
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o UNITED STATES
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NUCLEAR REGULATORY COMMISSION 7.
j WASHINGTON. D. C. 20555
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APR 1 0 BBS Mr. John D. Wolff Superfund and Waste Management Specialist Chevron Research and Technology Co.
Point Richmond Technical Center 1003 West Cutting Blvd. #260 P.O. Box 4054 Richmond, CA 94804-0054
SUBJECT:
DECOMMISSIONING PLAN FOR PLUT0NIUM FACILITY AND MULTIPLE FAILU BUILDINGS & FINAL RELEASE SURVEY PLAN, PAWLING SITE, NEW YORK
Dear Mr. Wolff:
This is in response to your letters dated February 17, 1993 and March 18, 1993 in which you requested approval of the following documents:
1.
Decomissioning Plan for the Plutonium Facility and Multiple Failure Building of the National Park Service Property located near Pawling, New York, February 1993 (February 1993 Decomissioning Plan) 2.
Final Release Survey Plan of the National Park Service Property located near Pawling, New York, March 1993 (March 1993 Final Release Survey P1an)
These documents were prepared for the Chevron Corporation by Integrated Environmental Services (IES), a division of the Nuclear Energy Services (NES).
As indicated in our letter (dated December 11,1992) approving the soil remediation work plan, the 1988 ORAU report will be used only as information for identifying the general locations of contamination in soils and buildings.
Our understanding is that the same IES team, with appropriate qualifications and experience, identified in our December 11, 1992 letter, will be performing the tasks indicated in the two documents referred above.
The specific comments on the building decomissioning plan and the final I
release survey plan are included as Enclosures A and B, respectively.
In addition, comments from the State of New York (Department of Environmental Conservation /DEC) are enclosed.
Primarily, as mentioned in the enclosure, the i
shipping and manifesting of wastes should be performed in compliance with.
DEC's 6NYCRR Part 381 Low-Level Radioactive Waste Transporter Permit and Manifest System. For completion of your plans, we would appreciate incorporating your intentions with respect to the State of New York's requirements for shipping wastes. With respect to the computer modeling of the site, the Nuclear Regulatory Comission will perform a dose assessment h]
using the Department of Energy's computer code, "RESRAD". Data from the decomissioning program will be used for the "RESRAD" analysis.
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i ENCLOSURE A Comments on Decommissionina Plan for the Plutonium Facility and Multiole Failure Buildina of the National Park Service Property. Pawlina. New York (February 1993) 1.
Paae 1. Paraaraoh 2 It should be noted that the ORAU survey was not intended to
" characterize" the residual contamination at the site or to provide sufficient detail to design a remedial action plan. The results of the ORAU survey should be regarded as qualitative with respect to the horizontal and vertical boundaries of the contamination.
It is, therefore, important to understand the limitations of the ORAU data with respect to its application to remediation planning.
The Decommissioning Plan refers to removing isolated " hot spots" as identified in the ORAU radiological. report. As discussed above, because the ORAU survey was a limited radiological survey rather than a
" characterization" survey, it is uncertain whether the " hot spots" identified are actually isolated, or rather, indications of more wide-spread subsurface contamination. The plan should identify the approach to be taken to supplement the ORAU survey.
Figures, which indicate the areas of contamination, should be' included.
2.
Paae 1. Paraaraoh 3 Surface scans for alpha, beta, and gamma activity should be included as part of the initial building survey.
3.
Pace 1. Paraaraoh 5 The guideline reference is incorrect. The appropriate reference is, 3
" Guidelines 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. NRC, August 1987".
4.
Pace 2.Section III A.2 We understand that NES has a license for performing decontamination activities.
Is it your intent that the NES proposed decontamination work will be performed under this license?
5.
Paae 2.Section III B.1 Please clarify the phrase "the initial radiological survey".
6.
hgp E. Paraaraohs 2 and 3 Describe the survey methods to be used for personnel and materials leaving the controlled area either in this document or in the Health and Safety Plan.
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7.
Paae 5. Paraaraoh 4 What types of personnel air sampling will be used - breathing zone or
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general? Provide information relative to environmental air sampling.
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8.
Paae 5. ParaaraDh 7 (VIII RELEASE CRITERIA)
Please provide soil contamination release criteria.
9.
Pace 5. Paraaraoh 7 Please see Comment 3.
10.
Paae 6. Paraaraoh 3 Please see Comment 3.
11.
Pace 6. Paraaraoh 4 Provide a reference for the QAPP or include it as an attachment.
12.
Paae 7. Task 4 This Section should include a description of the methods to be used to adequately characterize the areas.
How will samples be analyzed?
13.
Paae 7. Task 5 What information will be used to determine the boundaries of the radiologically controlled areas?
14.
Pace 8. Paraaraoh 2 (TASK 6)
What kind of tests will the filters be subjected to assure high efficiency cleaning of air?
15.
Paae 10. Task IQ In addition to the items indicated, please provide a thorough description of analytical and survey data manipulation, figures, i
I photographs obtained under Tasks 3 and 9, and chain-of-custody documents.
16.
Paae 11.Section XII. Item A (2)
Will liquid wastes be generated?
If so, how will the liquid wastes be l
handled?
l 17.
Pace 11.Section XII. Item B(2)
Waste shipments should also be made to comply with all disposal site license requirements.
2
ENCLOSURE B Comments on Final Release Survey Plan of the National Park Service Property.
Pawlina. New York (March 1993) 1.
Pace 1. Introduction The Plan indicates that the survey is consistent with the recommendations of NUREG/CR-5849; however, the Plan does not address the use of " survey units" or describe the method for evaluating and statistically testing the data to assure that the associated conditions, i.e. 95% overall confidence level, have been satisfied.
2.
Although the Plan indicates that structure measurements will be taken at 1 m intervals (per NUREG/CR-5849), several of the sample forms in Appendix A are designed for or make reference to the survey method of averaging 5 measurements within each grid block.
It is not clear whether different record forms will be used for the 1 m interval measurements and averaging calculation.
3.
Paaes 1 and 6 Specific plutonium isotopes of concern and their relative activity ratios at this site should be identified.
4.
Paae 1. Paraaraoh 3 The Plan states that the final release survey will include both buildings and grounds.
Information on grounds areas to be surveyed, soil gridding intervals, soil surface scanning, and soils guidelines are provided in this Plan; however, there is no mention of the subsurface sampling plan, sampling techniques, or detailed analytical procedures to be used for the survey of grounds areas.
5.
The possibility of subfloor contamination in the Plutonium Facility should be given consideration.
Floor cores should be obtained to test subfloor soil and building footer contamination.
6.
Paae 1. Paraoraoh 4. Pace 2. Paraaraoh 1. Paae 8. Paraoraoh 1. and Pace
- 10. Item 5 There are references to Regulatory Guide 1.86.
This document is specifically intended for nuclear reactors and that the appropriate reference for other categories of facilities is " Guidelines 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. NRC, August 1987".
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7.
The Plan indicates that the Plutonium Facility will be surveyed, but specific portions of that building to be surveyed are'not identified.
I The ORISE survey identified only 5 rooms in that building, with contamination above current guidelines.
If other areas are to be surveyed, it should be indicated whether they will be considered as "affected" or " unaffected" areas.
8.
Pace 3. Last Paraaraoh The gridding of upper wall and ceiling surfaces in several rooms of the Plutonium Facility will be required, based on data from the earlier ATCOR Survey (" Final Survey Results After Decontamination, Gulf United Nuclear Fuel Corporation Plant Facility", Pawling, New York, ATCOR Inc.,
January 1974).
9.
Paae 4. First Paraaraoh Although a pancake GM probe can detect alpha activity, the high background, small surface area, and low efficiency, relative to an alpha -
detector (ZnS scintillation or gas proportional) would seem to make this a questionable choice for alpha scanning. The detection sensitivity-of the GM pancake detector for Pu-239 is probably well above the guideline value.
i 10.
Paae 4. Last Paraaraoh You indicate that elevated activity areas will be evaluated by taking 5 L
additional measurements within _the grid but outside the elevated activity area. When evaluating eleva measurementsshouldbetakenipa1m}edactivityareas, additional area contiguous to the elevated-l area.
In some cases, this I m area might not be the gridded area, but might be an area that extends into other grids.
i 11.
Pace 5. Last Paraaraoh Exposure rates should be in gR/h, not in yrem/h as indicated on the sample form in Appendix A.
i 12.
Paae 6. Item V. Survey Instrumentation How will the instruments be calibrated? What standard sources will be i
used?
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Mr. John D. Wolff 2
If you have any questions, please contact Sam Nalluswami of my staff on 301-504-2502.
0.4201 Srgs gy John H. Austin, Chief Decommissioning and Regulatory Issues Branch Division of Low-Level Waste Management and Decommissioning, NMSS Encls: As stated cc: Mr. John Byrne, NPS Dr. Paul Merges, State of NY Mr. F. Trejo, IES/NES Mr. James Berger, ORISE DISTRIBUTION:
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YES N0 g Path & Name of File:s:\\llwmtype\\cecilia\\pawgrem2.smn ENCLOSURE A:s:\\llwmtype\\cecilia\\pawdeblg.smn ENCLOSURE B:s:\\llwmtype\\cecilia\\pawsurvy.smn