ML20042F620

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Forwards Procedure Describing General Soil Excavation & Sorting Process During Removal from Impacted Areas
ML20042F620
Person / Time
Site: 07000925
Issue date: 04/30/1990
From: Stauter J
CIMARRON CORP.
To: Haughney C
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 9005090158
Download: ML20042F620 (4)


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Cthi4RROWC0@0RAn0N V

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ro unrm, e ensaw owous n,n April 30, 1990 1

l CFRTIFIED MAIL IUmRN RFEEllet RHOUR3THD Charles'Haughney, Chief

  • uel Cycle Safety Branch 91 vision of Puel Cycle,. Medical, Academic and Commercial Use Safety U.S. Nuclear Regulatory Commission Washington, D.C.

20555 RE: License SHM-928; Docket 70-925

. Amendment itequest: On-Site Deposition of Uranium Containing Soils Meeti.19 NRC Branch

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Technical Position Option 2 Criteria Dear Mr. Haughney Mr. Davis Hurt of your staff requested that we submit a description of our present The t

procedure for sorting soils removed from the Uranium Plant impacted areas.

attached procedure describes the general soil excavation and sorting process which we will use for de remainder of the project.

Previous submittals relating to this topic are superseded by the attached document.

questions concerning this matter, please contact me at your If you have any earliest con'venience.

Sincerely, C

J.C. Stauter, Director Environmental Affairs JCS gw Attachttwent

'I N0b5?$$$$$$y5 PDC A SUBSIDIARY OF Kf3WPArmafrcarateild V

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CIMARR0N FACILITY Soil Sorting Method The primary method used to sort so::s for the purposes of appropriate Branch Technical Position option disposal at the Cimarron Facility relies on the collection and analysis of soil s ample s for uranium content.

Cimarron Corporation has used a gamma pulse height analysis system for soil assays at the Cimarron Facility for several years.

This system has been demonstrated to be satisf actory for the analysis of soil samples for uranium content and sorting of these soils in

,accordance with NRC's Branch Technical Position (46 FR

205, pp 52061-52063, October 23, 1981 Disposal or Onsite Storage of Thorium or Uranium Wastes From Past Operations).

In addition to the gamma pulse height method, Cimarron Corporation till continue to use other radiation detection instrumentation such as sodium iodide detectors / count rate meters to aid in the sorting process.

.Although these instruments will not be used to quantify soil uranium concentrations or for final sorting of soils, the instruments will be used for gross screening and initial sorting of soils as the excavation is in progress.

Final sorting and determination of the final disposition of facility soil will be based on soil sampling and t

gamma pulse height analysis.

The general approach to the excavation and appropriate disposal designation process will proceed as follows:

1..

A walkover gamma radiation survey (may include surface scan l

or probing) is performed to' identify any gross ~ contamination which is easily distinguishable above typical background l evel s.

These areas are identified for additional evaluation.

If the levels are such that removal is obvious, l

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cleanup of this soil may begin wi t ho'u t collection of samples.

However, if the requirement for removal or i

disposition (off site versus onsite disposal) is questionable, soll sampling and analysis will be done.

The analysis results will be reviewed and appropriate removal and disposal actions taken, o

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2.

As an excavation progresses, soil samples will 'be collected to determine when adequate soil removal is complete.

Option o

1 and 2 criteria contained in the Branch Technical Position will be applied as follows:

a.

Between the ground surface and four feet deep, soil with uranium concentrations greater than 30 pCi/g will be removed and buried in a designated area, provided the soluble and insoluble uranium concentrations are less than 100 and 250 pCi/g, respectively.

b.

At depths greater than four

feet, soil with uranium concentrations greater than 100 pCi/g- (soluble uranium) and 250 pCi/g (insoluble uranium) will be removed for.

offsite disposal at a commercial LLRW site.

Material between 30 pCi/g and the 100-250 pCi/g soluble / insoluble will be lef t in place.

l 3.

Soil stockpiled for onsite disposal at the Cimarron Facility i

or for of fsite disposal at a commercial low level radioactive dis'osal facility will be sampled and analyzed for l

-waste p

L uranium content.

The data for each stockpile will be

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l evaluated to insure proper classification of the soil.

Cimarron Corporation has demonstrated that the facility gamma pulse l-height analysis system is appropriate for uranium analysis and sorting of soils at the Cimarron Facility at the levels of concern.

Oak Ridge i APR 1990

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Associated Universities in a

lettei from Mr.

James D.

Berger, Director, Environmental Survey and Site Assessment program, ORAV to Mr.

Davis Hurt, NRC-NHSS dated August 31, 1989 reported that "the Kerr-McGee analytical procedure can provide an acceptably accurate t-measurement of enriched uranium in soil within the range of Option 1 and Option 2 concentrations...".

Cimarron Corporation will continue to analyze approximately ten percent (10%) of the soil samples by radiochemical ( al pha p*.l se hei ght i-method) analysis techniques to evaluate the facility gamma pulse height system for QA/QC purposes.

We welcome the review of this data by HRC during routine inspections of our program.

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0332s

APR 1990

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