ML20045H297

Insp Rept 70-0033/93-01 on 930602.No Violations Noted. Major Areas Inspected:Radiological Survey of Portions of Onsite Excavated Area Following Remediation by License

ML20045H297
Person / Time
Site:	07000033
Issue date:	07/01/1993
From:	Pasciak W, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20045H290	List: ML20045H289 ML20045H297
References
70-0033-93-01, 70-33-93-1, NUDOCS 9307200060
Download: ML20045H297 (17)

Text

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U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No.: 70-33/93-01 Docket No.: 70-33 License No.: SNM-23 Priority _L Category IIHEE Licensee:

Texas Instruments. Incoroorated 34 Forest Street Attleboro. Massachusetts 02702 Facility Name:

IIFIR Project Inspection At:

Attleboro. Massachusetts Inspection Conducted:

June 2.1993 7///03 Inspector:

J J. Rotil/ Project Engineer

. Date Facilities Radiation Protection Section (FRPS)

Facilities Radiological Safety and Safeguards Branch (FRSSB)

Division of Radiation Safety and Safeguards Approved by:

/d-M a2b 7-I-93 W.'Pasciak, Chief Date FRPS,FRSSB Division of Radiation Safety and Safeguards Areas inspected: Special, announced inspection by a region-based inspector to perform a radiological survey of portions of the onsite excavated area following remediation by the licensee.

Results: Preliminary results of the survey indicated that the licensee appeared to have completed remediation of the excavated area in an appropriate manner. No safety concerns or violations of regulatory requirements were identified.

9307200060 930707 PDR ADOCK 07000033 C

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4 Ettalls 1.0 IfJllylduals Contacted M. J. Elliott, Manager, Environmental Engineering M. Griffin, Project Manager W. A. Lorenzen, Health Physicist F. F. McWilliams, Health Physicist W. Schuele, Attleboro Site Manager F. J. Veale, Jr., Manager, Environmental Engineering / Industrial Hygiene Other licensee representatives, employees and remediation contractor employees were also interviewed during this inspection.

2.0 Backaround On December 14-16,1992, the NRC contractor, the Oak Ridge Institute for Science and Education (ORISE), performed a verification survey of the remediated area of the Attleboro site. During that survey, it was determined from radiation levels (ranging from 2% to 40 times background) on the walls of the excavation that radioactive material remained that was above the 30 picoeuries total uranium per gram of soil guidance value contained in the NRC-approved Remediation Plan. In addition, analysis of soil samples taken by ORISE indicated that there were two locations on the bottom of the excavation that exceeded the NRC guidance value. Results of the ORISE survey are provided in.

As a result, the licensee was requested by the inspector to perform additional remediation activities.

Since the December,1992 NRC-survey the licensee has performed additional onsite remediation, drained the groundwater out of the excavated area, and verified that the excavated area met the NRC guidance value of 30 picoeuries total uranium per gram of soil.

Since, according to a May 25, 1993 letter to the NRC (Attachment 2), the licensee intended to backfill the excavation as soon as the final survey was completed, a special inspection was conducted on June 2,1993 in order to verify that the bottom of the excavation met the NRC guidance value indicated above.

3.0 Conduct of the Verification Survey The inspector performed the verification survey discussed in Paragraph 2.0. Surfaces j

adjacent to, in and on the walls of the excavation were scanned using a gamma scintillation detector. Micro-R readings were taken at one meter above the surface at random locations, soil samples were taken from the two remediated areas on the bottom of the excavation and from two locations that exhibited elevated radiation readings during the scanning. The two elevated areas were remediated by the licensee prior to sampling by the inspector.

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4.0 Preliminary Survey Results 4.1 Walkover Survey A walkover survey was conducted in the excavated area by the inspector using a Ludlum Model 16 Analyzer equipped with a 1 inch sodium iodide scintillation detector. Prior to the survey, the instrument background was determined to be about 2500 counts per minute. Radiation levels in the excavated area were found to be between one and one and one-half times background except in two elevated areas (grid location 185N X 157E, three times background; grid location 177.5N X 122E, two times background). Both elevated areas were immediately remediated by the licensee. Subsequent to remediation, the radiation levels in these two areas was reduced to one to one and one-half times background.

4.2 One-Meter Gamma Survey The inspector performed gamma radiation measurements at one-meter above the surface using a Ludlum Micro-R Meter. The measurements were made in the following locations.

Results Results Grid Location (Micro-R/hr)

Grid Location (Micro-R/hr) 185N 157E 14 165N 130E 13.5 1775.N 122E 15 170N 130E 14 180N 120E 14 175N 130E 13 175N-125E 14 182N 140E 12 170N-125E 12.5 180N 130E 13.5 190N - 160E 12.5 190N 140E 11 4.3 Soil Samples Soil samples were obtained by the inspector for the two elevated grid locations identined by the inspector in paragraph 4.1 and from the two grid locations l

identified in the ORISE survey report discussed in paragraph 2.0.

Preliminary Sample Result Sample Identification (picoeuries total uranium / cram soil) 185N 157E 22 177.5N 122E 58 162N 130E 16 182N 132E 36

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The preliminary sample analysis results were obtained by alpha counting in the licensee's laboratory. This technique has been shown to be conservative (higher) when compared to the analytical results obtained in the ORISE laboratories as indicated in Attachment 3. The samples will be sent to the ORISE laboratories for verification analyses and the results will be provided in a subsequent inspection report.

5.0 Additional Actions Recuired 5.1 Licensee Upon completion of the additional remediation activities, the licensee is expected to resurvey the excavated areas and provide the NRC with a revised final survey report. The expected schedule for completion of these activities is provided in.

5.2 NR_C Following receipt of the licensee's final survey report, the NRC contractor will visit the site, resurvey the applicable areas and will perform final confirmatory surveys on the surface of the remediated area.

6.0 Exit Interview The inspector met with the licensee representatives denoted in Paragraph 1.0 at the conclusion of the inspection on June 2,1993. The scope of the inspection and the findings were discussed with the individuals present.

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y ORISE OAK frnDGE INiterufE FOR SCIE NC E AND E DUC ATION f f 4 pr.;y/r f Jy*DNMl Ni " Y ?ill M S CMVI IDN January 25, 1993 Mr. Jerry Roth Region 1 Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19400 1

SUlU ECT:

INTERIM RADIOLOGICAL SURVEY LETTER REPORT FOR TIIE TEXAS INSTRUMENTS, INCORPORATED BURIALSITE, ATTLEHORO, M ASSACIIUSETTS

Dear Mr. Roth:

The Environmental Survey and Site Assessment Program (ESSAP) of the Oak Ridge Institute for Science and Education (ORISE) performed a confirmatory radiological survey of the Texas Instruments Burial Site in Attleboro, Massachusetts, on December 15-16, 1993.

Survey activities included gamma surface scans and collection of soil samples. ESSAP offers the following interim survey data for your review.

SURFACE SCANS Gamma surface scans were performed at the boundary of the excavated area. Several locations of elevated direct radiation were identified (Figure 1). At a number of these locations, the elevated activity was associated with small pieces of metal debris. A similar piece of material was identified while scanning around the overburden piles at grid block location 220N,145E.

Remedial activities by Creative Pollution Solutions (CPS), a contractor for Texas Instruments, were not effective. Furthermore, during these remedial activities, a relatively larger piece of scrap metal with elevated activity was excavated from the west side of the burial site, adjacent to the parking area.

SOll. S AMPLING Ten soil samples were collected from the bottom of the excavated area and six samples were collected from the overburden piles. ESSAP has analyzed all samples by gamma spectrometry.

The analytical results are presented in Table 1, and sample locations are shown in Figure 2. The total uranium concentrations for samples taken from the overburden piles ranged from 1.5 to 50 pCi/g. The total uranium concentrations for samples taken from the bottom of the excavation P O BOX 117, OAK RIDGE. TENNESSEE 378310117 Mamged and operated by Oak Rdge Assoucied Universities for the U S Department of Ene<gy

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Mr. Roth 2

January 25,1993 ranged from 3 to 400 pCi/g. The sample with a total uranium concentration of 400 pCi/g was taken at grid coordinate 185N,125E. A second sample, taken by the licensee at approximately the same location, was analyzed by ESSAP and contained 85 pCi/g of total uranium.

The soil concentration guideline, for enriched uranium, is 30 pCi/g.

The total uranium concentration at a number of locations in the excavated area exceeds this limit. Furthermore, based on the survey fhidings, it is ESSAP's opinion that the full extent of the burial site, particularly on the west side, adjacent to Building 11 parking area, has not been determined.

If there are any questions or you need additional information, please do not hesitate to contact me at (615) 576-3355 or Michele Landis at (615) 576-2908.

Sincerely, 4

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y Armin Jaberaboansari Project Leader Environmental Survey and i

Site Assessment Program AJ:mkp cc:

J. Parrott, NRC/6H3 D. Tiktinsky, NRC/6E6 T. Mo, NRC/6H3 J. Swift /F. Brown, NRC/6H3 J. Kinneman, NRC/ Region 1 NRC/PMDA, 6E6 J. Berger, ORISE/ESSAP M. Landis, ORISE/ESSAP File /205

TABLE 1 URANIUA1 CONCENTRATIONS IN SOIL SAMPLES TEXAS INSTRUMENTS, INC.

ATTLEBORO, MASSACIIUSETFS l

Uranium Concentrations

• Sampic Location U-235 U-238 Total Uranium' m

Excavated Area' 200N,165E 0.7 0.1 10.5 i 2.2 27 185N,125E, Sample 1 15.1 2.0 48.5 7.2 400 185N,125E, Sample 2d 1.7 0.3 45.7 i 6.7 85 j

185N,150E 0.2 0.1 5.3 1.3 10 j

180N,130E 1.9 0.3 30.0 4.5 74 170N,190E 0.1 i 0.1 0.5 i 0.6 2.8 I

165N,125E 0.3 0.1 3.7 1.2 11 160N,135E 1.3 0.1 54.3 2.2 84 160N,130E 2.1 0.3 89 13 140 155N,11SE 0.1 0.I 1.2 0.7 3.5 150N,139E 0.6 i 0.1 56.1 2.4 70 Overburden Piles' 230N 155E 1.0 0.2 27.1 i 4.2 50 220N,155E 0.2 0.1 4.4 i 1.1 9.0 220N,140E 0.9 i 0.2 15.9 2.6 37 210N,145E 0.1 0.1 0.8 i 0.7 1.5 13FP1, Sample l' l.1 0.2 24.5 4.0 50 BFPl. Sample 2 1.0 0.2 16.8 2.8 40 Uncertainties represent the 95% confidence level based only on cour. ting statistics.

6 Total uranium concentrations are calculated based on a U-234 to U-215 activity ratio of 22:1.

See Figure 2.

d This sample was provided to ESSAP by the licensee.

Exact locations for soil samples from the overburden piles are not indicated on Figure

2. Approximate grid coordinates or a general description is provided.

" Backfill Pile 1" (BFP1) is located to the west of the excavated area across from the parking area. Samples 1 and 2 were taken from the southwest and northeast corner of BFP1, respectively.

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TEXAS INSIMUMENTS

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May 25,1993 Mr. Jerome Roth Project Engineer - Fuel Facilities UNITED STATES NUCLEAR REGULATORY COMMISSION REGION 1 475 AllendaleRoad King of Prussia, PA 19406 Re: Texas Instruments Incorporated, S.N.M. License No. 23 Docket No. 70-33

Dear Mr. Roth:

This letter will serve to document certain information that was conveyed to you orally during telephone conversations on May 5 and May 20,1993. As requested, Texas Instruments incorporated (TI) is submitting information concerning the status and schedule of the remaining activities to remediate the fonner Low Level Radioactive Waste (LLRW) burial site located on its Attleboro property.

Beginning August 31,1992, and continuing through January 25,1993, TI completed the excavation, processing, packaging, transportation, and disposal of approximately 62000 cu.ft. of LLRW contaminated soil and debris in accordance with its Remediation Plan (dated July 30,1992). Remaining activities involve " Backfill and Restoration" activities. These include dewatering groundwater that infiltrated the excavation, removing a very small quantity of LLRW contaminated sediment, backfilling the excavation, restoring the site to original conditions, and submitting a final report to the NRC.

As of this writing, " Backfill and Restoration" activities are undenvay. After receipt of an appmved " NPDES Permit Requirements Exclusion" from the EPA, dewatering operations commenced on May 14. Since then, contractors and resources have been scheduled to complete the remaining phases in a timely and efficient manner. Likewise, the site population has been notified of scheduled times and durations of parking lot closures and other inconveniences to their nonnal activities.

TEXAS INST RUMENTS INCORPORATE D + 34 FOREST STREET

• ATTLEBORO, MA 02703

%ft OW 3000

• T ELE K 210801

• CABLE TE WINS

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USNRC.

Attn: J. Roth -

Page 2 May 25,1993 j

This past weekend, May 19 and 20, TI's Health Physics contractor performed radiological surveys in the excavation to more accurately define the sediments requiring removal. Subsequent activities will adhere as closely as possible to the following schedule:

e All dates are for 1993 Sediment Removal May 26 to May 29 Soil Sampling and Analysis May 28 to June 2 Gross Alpha Counting will occur simultaneously with " Sediment Removal."

Samples will be collected according to the sampling grid pattern described in the Remediation Plan.

Gamma Spec Analysis will be performed to verify the Gross Alpha results on a few l

selected samples.

Backfill Operation June 2 to June 9 Final Walkover Survey June 10 to June 16 Restoration and Landscaping June 17 to July 1 Submit Final Report August 20 Please feel fme to contact me if you have any questions concerning the above information or any other related matter.

Sincerely, i

MATERIALS AND CONTROLS GROUP ENVIRONMENTAL, SAFETY, AND HEALTH DEPARTMENI' m)l,LLuL.}n LU, j d'l f 0

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Michael J. Elliott Engineering Manager MJE:bys cc: Mr. Daniel V. Bartosh Jr., TI-Dallas Mr. John O'Donnell, T1-Dallas Mr. Richard L. Joosten Jr., TI - Dallas Mr. Francis J. Veale Jr., TI - Dallas a

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ORISE OAK PlDGE IN5ilTUTE F OR SCIE NC F AND E DUCATION

( N) MG (/ T,.IV* C.*NMI N I '. Y T I f M ', Div1?,EM A February 4,1993 j

Mr. Jerry Roth Region 1 Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19400 SUfUECT:

CONFIRMATORY ANALYSIS, GAMMA SPECTROMETRY AND ALPHA SCREENING, TEXAS INSTRUMENTS INCORPORATED, ATTLEBORO, MASSACHUSETTS

Dear Mr. Roth:

At the request of the Nuclear Regulatory Commission (NRC), the Texas Instruments incorporated provided the linvironmental Survey and Site Assessment Program (ESSAP) of the Oak Ridge Institute for Science and Education (ORISE) with several soil samples for the purpose of evaluating the analytical results reported by the licensee. ESSAP has completed the gamma spectrometry analysis of these samples and offers the following data for your review.

The results of the ESSAP gamma spectrometry analysis are presented in Table 1. The results of the licensee's gamma spectrometry and alpha screening analyses are presented in Table 2, and are plotted in Figures 1 and 2. Based on a pair-wise comparison t-test, there are no statistically significant differences (P > 0.6) between the licensce's and the ESS AP gamma spectrometry data.

In addition, for samples with a total uranium concentration of >20 pCi/g, the licensee's alpha screening data are statistically identical (p > 0.8) to ESSAP's gamma spectrometry data.

How ever, for samples with a total uranium concentration of < 20 pCi/g, the alpha screening data are statistically different (p<0.001) from ESSAP's gamma spectrometry analysis. This fact should not be a concern because the alpha screening analysis appears to provide a more conservative estimate.

However, it should be noted that according to the licensee, the alpha screening data presented here are based on an average of 5 to 10 samples which tends to mask any significant variation among the individual samples. Therefore, because only single measurements are taken in the actual field surveys, reproducibility may still be a concern unless data to the contrary are presented. The uncertainties associated with these measurements, including those of gamma P O. BOX 117, CAK RIDGE. TENNESSEE 37831 0117 Monoged and opermed by Cok R4dge Assmioned Univers*es for the U S. Department of Energy l

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Mr. Roth IWiary 4,1993 spectrometry, may be rather high and cannot be accurately estimated. The method of statistical analysis utilized here does not take into account the level of uncertainty associated with individual measurements.

t if there are any questions or you need additional information, please do not hesitate to contact me at (615) 576-3355 or Michele Landis at (615) 576-2908.

1 Sincerely, N

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Armin Jaberdboansari Health Physicist / Project Leader Environmental Survey and Site Assessment Program cc:

J. Parrott,.NRC/NMSS T. Mo, NRC/NMSS.

i D. Tiktinsky, NRC/NMSS J. Swift /F. Brown, NRC/NMSS J. Kinneman, NRC/ Region I M. Landis, ORISE J. Berger, ORISE PM DA, 6E6 File /205 l

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TABLE 1 ESSAP GAMMA SPECTROMETRY ANALYSIS OF SOIL SAMPLES TEX AS INSTRUMENTS, INC., ATTLEllORO, MASSACllUSETTS Uranium Concentrations (pCi/gf Sample Identification

• U-235 U-238 Total Uraniunf-134N, ll8E 0.1 0.1 3.0 0.9 5.3 MP4 0.2 0.1 5.0 1.0 9.6 MP5 0.2 i 0.1 6.0 i 1.0 11 235N,156E 0.4 0.1 4.0 1.0 13 M P l-2 0.3 i 0.1 8.0 i 1.0 15 138N,113E 0.3 0.1 8.0 1.0 15 Rock Pile 0.7 0.1 12.0 2.0 28 11FP I 0.8 0.1 18.0 i 3.0 36 RS 410-411 1.7 0.2 36.0 i 5.0 75 RS 414 1.3 i 0.2 47.0 7.0 77

' Sample identifications were provided by the Texas Instruments, Inc.

• Uncertainties represent the 95% confidence level based only on counting statistics.

• Total uranium concentrations are calculated based on a U-234 to U-235 activity ratio of 22:1.

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-i TAllLE 2 COMPAltlSON OF URANIUM CONCENTRATIONS IN SOIL SAMPLES AS DETERMINED IW ESSAP AND Tile TEXAS INSTitUMENTS, INC.

Total Uraninm Concentration (pCi/g)"

l Sample Identification Gamma Spectrometry Alpha Screening ESSAP TI A

TIA 134N,118E 5.3 4.7 12.8 MP4 9.6 21.8 14.2 MP5 11 7.1 16.0 235N,156E 13 12.5 19.0 M P 1-2 15 11.7 19.2 138N,113E 15 1.3 21.4 Rock Pile 28 27.0 25.8 BFPI 36 36.8 29.9 RS 410-411 75 57.0 75.3

[ RS 414 77 90.8 85.0

• Total uranium concentrations are calculated based on a U-234 to U-235 activity ratio of 22:1.

6 Texas Instruments, Inc., Attleboro, Massachusetts i

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