ML20057B562
| ML20057B562 | |
| Person / Time | |
|---|---|
| Site: | 07000903 |
| Issue date: | 09/13/1993 |
| From: | Joseph Austin NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Wolff J CHEVRON U.S.A., INC. |
| References | |
| NUDOCS 9309220233 | |
| Download: ML20057B562 (5) | |
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Chevron Research and Technology Co.
Attn: Mr. John D. Wolff SEP 131993 Senior Superfund Specialist Point Richmond Technical Center 1003 West Cutting Blvd #260 P.0. Box 4054 Richmond, California 94804-0054
Dear Mr. Wolff:
SUBJECT:
COMMENTS ON THE FINAL PROJECT REPORT FOR THE DECONTAMINATION AND DECOMMISSIONING OF THE PLUT0NIUM FACILITY AND MULTIPLE BUILDING AT-NUCLEAR LAKE SITE, PAWLING, NEW YORK The Nuclear Regulatory Commission staff reviewed the " Final Project Report for the Decontamination and Decommissioning of the Plutonium Facility and Multiple i
Failure Building, Nuclear Lake, Pawling, New York", dated August 1993, prepared and submitted on August 31, 1993, by NES, Inc./IES. The Oak Ridge Institute for Science and Education (0 RISE) also reviewed and provided comments.
The review comments are enclosed and if you have any questions, please contact -
Sam Nalluswami of my staff at (301) 504-2502.
OrbirdStoedBy John H. Austin, Chief Decommissioning and Regulatory Issues Branch Division of Low-Level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards
Enclosures:
As stated cc:
Timothy J. Vitkus, ORISE Patrick J. LaFrate, NES/IES TICKET: D-930053 DISTRIBUTION: Central File LLWM r/f JGreeves PLohaus JRoth MBell JSurmeier NMSS r/f LLDR t/f MWeber LBell Nhk Sm 11'LB'oxesHniConcilfrenceiB16sk!toTDafineCDistritiu' ion /CopFLPFsfeFsnce; t
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Comments y Pawlina Final Survey Repy_t SEP 131993
- 1. Executive Summary. 3rd Para..
D.
1 This section indicates that waste will be disposed at the Barnwell facility. Has all the waste been shipped for disposal or does waste remain on-site?
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- 2. General There were several inconsistencies noted between the Final Survey Plan and the Final Project Report. These are summarized below.
- a. The Final Survey Plan (Section IV, p. 6) stated that the upper walls and f.eiling of the Plutonium Facility will be gridded. The Final Survey Report indicates that only two rooms of the facility were gridded in this manner.
Please provide a rationale for this change.
- b. The Final Release Survey Plan (Section IV, p. 9) stated that exposure rate measurements would be made at each exterior soil sampling location.
These data were not provided in the Final Report.
Please provide these data.
- c. The Final Survey Plan (Section IV, p. 6) stated that direct measurements would be obtained at floor drains, sumps, and drain lines. However, -
other than the results from one residue sample, it is unclear whether these data were collected.
- 3. General Following the initiation of the final survey, were areas ' identified that required further remediation? A discussion of this subject is important because it helps to understand the effectiveness of the remediation activities before the final survey was initiated, and, therefore, helps us develop the confirmatory survey plan.
- 4. Section 1. D.
1 Soil contamination levels are not listed in Reference 1.
- 5. Section 2. o. 1 Suggest referring to the approved final survey plan in this section.
- 6. Section 2. o. 1 Exposure rates are measured at a height of 1 meter.
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- 7. Section 5. o. 5 Suggest that a statement be included to indicate that the release criteria were approved in the decommissioning work plan reviews.
The date of the guidelines is August 1987.
Please delete the words.. draft Regulatory Guide.
after the word USNRC in paragraph 1.
- 8. Section 7.2.2.
p.
13 Maps were not provided that indicate the characterization soil sampling locations. Therefore, the reader is unable to determine the specific locations where soil samples contained elevated radionuclide levels.
It is unclear to the reader whether soil was excavated from any of the identified " hot spots." Please describe the remediation activities pertaining to elevated soil levels.
- 9. Section 7.2.2. Last Para.. o. 15 A statement is made that the alpha spectroscopy data supporting the Am-241 to Plutonium ratio is provided in Attachment 1.
However, in Attachment 1, under "QA Results," only one data sheet showing the alpha spectroscopy results for Sample 500-215 is provided. Are these the only alpha spectroscopy data available? Please provide the data from the other samples.
10.
Table 2. o.16 o
A grid number of E-9 is given for one of the Plutonium. Building, Room 2 walls.
Is this the correct wall grid identification?
Is this the expansion joint contamination location referred to in Section 7.57 11.
Table 3.
p.
17 Is G-ll a correct grid number? Data in the Attachment 2 are provided through grid number G-9.
12.
Table 7. o.19 This table presents data from a wall in Room 15 of the Plutonium Building.
To which wall are these data applicable?
13.
Table 9.
p.
20 Was the exterior floor drain in Room 4 of the Plutonium Building (8.17 pCi/gm of Am-241) removed? What about the other drains?
The data sheets for bulk sample 500-214 in Attachment 1 indicate an activity of 0.00 pCi/gm.
Is there a transcription error in reporting the activity for this sample?
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14.
Section 7.5. First Para.. o. 22 When the contaminated expansion joint in Room 2 was remediated, how far did.
the contamination extend under the floor? Where were soil samples taken in this area?
t 15.
Section 8.
p.
23 Suggest referring to the NRC approval of the final survey plan in this section.
16.
Section 8.1.4. o. 26 A discussion of how the background exposure rates were determined should be provided. When you state that exposure rates ranged from 8-11 uRem/hr, do these exposure rates include background? Note that the release criteria is 5 uR/hr above background at I meter.
17.
Tables 12-15. o. 30 Do the exposure rate values include background? Note that the exposure rate data in these tables range from 6-12 uRem/hr. This appears to be inconsistent with the statement in Section 8.1.4 that exposure rates ranged from 8-11 uRem/hr.
18.
Section 8.4.3.1. o. 36 A statement is made that soil grid and sample locations are presented in.
Under the "95% Confidence" section in Attachment I some of these locations are presented. However, the specific 1.ocations of many of the soil, subfloor soil, and bulk sample collection points are not presented.
Please provide diagrams showing the locations of these samples.
Were soil samples collected in the vicinity of the contaminated drain line found in Room 4 of the Plutonium Building?
19.
Table 18.
p.
36 The data sheets in Attachment I for samples S00-251 and SD0-255 show two Cs-137 entries that are added together. We assume that only one of the entries is applicable.
Please confirm our assumption so that futJre confusion may be prevented.
20.
Table 22.
p.
38 Note that the "QA Results" section shows a Cs-137 concentration for sample SD0-224 of 0.327 pCi/gm. This table, however, shows no detectable activity.
Shouldn't a concentration of 0.327 pCi/gm be detectable?
21.
Tables 18-24. op. 36-39 We suggest that a footnote be added to these tables that indicates the minimum detectable activity level for each radionuclide.
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22.
0A Results Section. Attachment 1 A gamma spectrometry results summary is provided for a sample identified as Client Sample ID #3. Where was this sample taken from and does it correlate with one of the other "SD0" sample identifications?
23.
95% Confidence Section. Attachment 1 The soil averaging calculations average all the soil samples from a survey unit together. Average soil sample computations, however, should be performed for each depth that sanples are taken.
For example, surface samples should be averaged separately from samples taken at the 15 cm - 2 foot depth.
In checking the confidence calculations for the Plutonium building soils, we were unable to verify average concentration value that you obtained for the 58 samples given in Tables 18 - 21. We assume you treated the non-detectable values using the LLD value of 0.24 pCi/gm.
Please reverify this computation.
i 24.
Plutonium Buildina Data Sheets. Rooms 6. 7. 8. 11. 12. and 17 In the exposure rate data sheets, the background is not provided. What are the background exposure rates for these rooms?
- 25.. Air Samoles Why is the conversion factor for alpha 6.76E-77 This conversion factor was not used in the alpha MDC calculations.
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