ML20057C708

Forwards Response to NRC Review & Comments Re Final Project Rept for Decontamination & Decommissioning on Pu Facility & Multiple Failure Bldg at Nuclear Lake Site,Pawling Ny,

ML20057C708
Person / Time
Site:	07000903
Issue date:	09/17/1993
From:	Lafrate P NUCLEAR ENERGY SERVICES, INC.
To:	Nalluswami S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
ESR-5052, NUDOCS 9309290286
Download: ML20057C708 (25)

Text

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-. INTEGRATED ENVIRONAfENTAL SERVICES b

A DIVISION OF nG5 44 SHELTER ROCK R04D 0$$N?lb'**

I September 17, 1993 1

s ESR-5052 Mr. Sam Nalluswami Nuclear Regulatory Commission Division of Low-Level Waste Management and Decommissioning 11555 Rockville Pike Rockville, MD 20852

Subject:

Responses to USNRC Review of Nuclear Lake Site Final Project Report

Reference:

(1)

USNRC Comments on the Final Project Report for the Decontamination and Decommissioning on the Plutonium Facility and Multiple Failure Building at Nuclear Lake Site, Pawling, New York l

dated Sept. 13, 1993 (2)

Final Project Report for the Decontamination and Decommissioning on the Plutonium Facility and Multiple Failure Building at Nuclear Lake 3

Site, Pawling, New York dated August,1993 l

(3)

Decommissioning Plan for the Plutonium Facility and Multiple Failure

- i Building of the National Park Service Located Near Pawling, New York, dated February,1993 i

Dear Mr. Nalluswami:

This letter provides NES/IES' response to the USNRC's review and comments pertaining to the subject Nuclear Lake site documents.

' The following NES/IES responses of enclosure A are keyed to the USNRC comments of Reference (2) above. All NES/IES responses have been incorporated in the referenced plans.

Enclosure B includes the addendum to Reference (3) above which incorporates the Decontamination and Decommissioning of the Waste Disposal Building (WDB) at the Nuclear Lake Site.

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e Please don't hesitate to call me at 203/796-5080 if you have any more questions.

Sincerely yours, Patrick LaFrate Project Manager Nuclear 12ke Project NES/IES Enclosures pjl cc:

John Wolff, Chevron Timothy Vitkus, ORISE t

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Enclosure A 1)

Comment 1

[

r Executive Summary. 3rd Para.. o.1 This section indicates that waste will be disposed at the Barnwell facility. Ilas all the waste been shipped for disposal or does waste remain on-site?

NES/IES Response Radioactive waste, consisting of two (2) B-25 boxes were shipped to the Barnwell on 8/26/93 (Refer to Attachment II of the report for shipment documentation). Because of the decontamination effort of the WDB, there will be additional waste generated t

(approximately (1) 55 gal. dmm) which will remain on-site until the end of phase II of the project (building demolition).

2)

Comment 2 General There were several inconsistencies noted between the Final Survey Plan and the Final Protect Repon. These are summarized below..

a)

The Final Survey Plan (Section IV, p. 6) stated that the upper walls and ceiling 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 the rationale for this change.

j NES/IES Response Section IV, p. 6 states.. "The upper walls and the ceilings will not be gridded unless 1

there is evidence that these surfaces are contaminated (the upper walls and ceilings of the Plutonium Facility will be gridded based on the positive survey results from the carlier ATCOR survey..." The ATCOR survey report summarized in " Nuclear Lake

- A Resource in Question, January, 18,1982" states.. "The USAEC confirms that J

ATCOR Inc., ' carried out all work necessary to reduce contamination levels to below j

those specified in the Guidelines for Decommissioning of Facilities and Equipment Prior to release for Unrestricted Use or Termination of License for By-praduct, Source or Special Nuclear Material,s issued by the Directorate of Licensing...

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Therefore, NES/IES, using NUREG/CR-5849 as a guide, determined that only the Alpha Lab and Alpha Utility Room of the Plutonium Facility warranted upper wall I

and ceiling grids because of contamination on the lower walls found in these areas during the final release survey l

Comment 2 (continued) j b.

The Final Release Survey Plan (Section IV, p. 9) stated that the exposure rate l

measurements would be made at each exterior soil sampling location. These data were not provided in the Final Report. Please provide these data.

f NES/IES Response Refer to Attachment 1 of this enclosure for exposure rate measurements that were.

j made at each exterior soil sampling location. These data will be incorporated into the l

Final Report Addendum.

Comment 2 (continued) c.

The Final Survey Plan (Section IV, p. 6) stated that direct measurements wculd be obtained at the floor drains, sumps, and drain lines. However, other than the results from one residue sample, it is unclear whether these data were collected, i

NES/IES Resoonse Refer to Attachment 1 of this enclosure for direct measurements that were obtained at the floor drains, sump and drain lines. These data will be incorporated into the Final Report Addendum.

3)

Comment 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 heips to understand i

the effectiveness of the remediation activities before the final survey was initiated, and, therefore helps up develop the confirmatory plan, i

NES/IES Response i

Following the initiation of the final survey, areas identified by the survey to require additional remediation were as follows.

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ROOM AREAS MAX. READING BOX STORAGE /DECON Several small spots on floor 15,000 dpn' dy 2

(approx. 3 in )

CAVE AREA Several small spots on floor 10,000 dpm #7 2

(approx. 3 in )

i a

ALPIIA LAB Upper walls (above 2 1,000 dpm a meters)

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i ALPIIA LAB Several small spots on floor 500 dpm a 2

(approx. 3 in )

i CIIANGE ROOM /DECON Several small spots on floor 500 dpm a 2

(approx. 3 in )

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4)

Comment 4 Section 1. p.1 i

Soil contamination levels are not listed in Reference 1.

N_ES/IES Response The statement will be rewritten to read.. "Specifically, building surface cor,tamination levels comply with the ' Guidelines for Decontamination of Facilities and Equipment i

Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct,-

Source or Special Nuclear Material,' U.S. NRC, August 1987 (Ref.1). Soil

'I contamination levels comply with USNRC negotiated limits of 25 pCi/g total for plutonium isotopes including Am-241 and 15 pCi/g for Cs-137." This revision will be i

incorporated into the Final Report Addendum.

j 5)

Comment 5 Section 2. o 1 Suggest referring to the approved final nrrvey plan in this section.

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• 9 N_ES/IES Response t

Concur. This revision will be incorporated into the Final Report Addendum.

6)

Comment 6 Section 2. n.1 Exposure rates are measured at a height of 1 meter.

NES/IES Response l

Concur. This revision will be incorporated into the Final Report Addendum.

l 7)

Comment 7 S'ection 5 p.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 i

Guide. after the word USNRC in paragraph I.

1 NES/IES Response i

Concur. These revisions will be incorporated into the Final Report Addendum.

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8)

Comment 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 radionuclide 1 vels.

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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.

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NES/IES Response

)

i NES/IES will provide a map indicating the characterization soil sampling locations in

]

the Final Report Addendum.

1 Soil remediation activities included removal of approximately 130 ft of contaminated 3

soil by backhoe from the area south of the WDB. A small area of soil (approximately-.

I ft') was removed by shovel from the area south of the Shield Mock Up Building.

Soil sampling and analysis was performed until concentration levels of the contaminant (Cs-137) was below 15 pCi/g.

9)

Comment 9 Section 7.2.2. Last Para.. n.15 i

A statement is made that the alpha spectroscopy data supporting the Am-241 to

~

Plutonium ratio is provided in Attachment 1. Ilowever, in Attachment 1, under "QA l

Results," only one data sheet showing the alpha spectroscopy results for sample SDO-215 is provided. Are these the only alpha spectroscopy data available? Please j

provide the data from the other samples.

l i

NES/IES Response l

Refer to Attachment 2 of this enclosure for the additional data. These data will be i

incorporated into the Final Repor,t Addendum.

l 10)

Comment 10

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Table 2. p.16 i

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 7.5?

NES/IES Response This is the expansion joint. Grid E-9 was used to locate the area because wall grids l

were not laid out at this point in the project. Measured activity was the result of the j

activity from the expansion joint and is not the wall. This clarification will be incorporated into the Final Report Addendum.

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11)

Comment 11 l

Table 3. p.17 l

. Is G-11 a correct grid number? Data in the Attachment 2 are provided through grid number G-9.

NES/IES Response This is an error. G-9 is the correct grid number. This clarification will be incorporated into the Final Report Addendum.

i 12)

Comment 12 i

Table 7. n.19 This table presents data from a wall in Room 15 of the Plutonium Building. To which wall are these data applicable?

t 6

NES/IES Response L

Table 2, p.16 and Table 7, should be replaced by the following:

Table 2: Plutonium Building Room 2 East Wall Grid Number Direct p-y Direct a Removable p-y, a t

E-9 1,211,232 168

< MDA Note: Activity results are in dpm/] 00 cm' Table 7: Plutonium Building Room 15 East Wall Grid Number Direct p-y Direct a Removable p-y, a A-5 29,600 154

< MDA i

Note: Activity results are in dpm/100 cm' This clarification will be incorporated into the Final Report Addendum.

13)

Comment 13 Table 9. n.20 Was the exterior floor drain in Room 4 of the Plutonium Building (8.17 pCi/g of Am-241) removed? What about the other drains?

The data sheets for the bulk sample SDO-214 in Attachment 1 indicate an activity of 0.00 pCi/g. Is there a transcription error in reporting the activity for this sample?

NES/IES Response The plutonium was decontaminated during the remediation/ decontamination phase of the project to 0.00 pCi/g.

All other drains in the Pu Facility were surveyed. Attachment 1 of this enclosure contains the survey documentation.

This clarification will be incorporated into the Final Report Addendum.

7

t r

The reported activity is incorrect (5.23 pCi/g).- It should have been reported as 5.38 pCi/g. This sample was quantified before the isotope library for the Canberra l

Spectran-AT software was updated. The concentration was determined by using the

" peaks not used" section of the print out of SDO-214 of 59.87 kev for Am-241. The software library for Am-241 was updated on the 5th of August,1993:

Activi ty 'T pC1 2. 22 dpm, 6 0 s ec,gggg g g,g,gy

x Specific Activity =

1 min

% Yield y das t

4.88 Y sec 1pC2 60sec /70 (grams)

5. 38 pCi/g =

x x

0.35 ' Y, 2.22dpm 1 min dis 1

This clarification will be incorporated into the ~ Final Report Addendum.

L 14)

Comment 14 Section 7.5. first para. n.22 l-.

When the contaminated expansion joint in Room 2 was remediated, how far did the

(

l contamination extend under the floor? Where were soil samples taken in this area?

j i

NES/IES Response l

The contamination extended approximately 18 inches under the floor. All I

contaminated material was removed. Subfloor sample SDO-310 (Attachment 1 of the l

Final Report) confirmed the results of the remediation.

I 15)

Comment 15 Section 8. n.23 l

Suggest referring to the NRC approval of the final survey plan in this section.

NES/IES Resnonse Concur. This revision will be incorporated into the Final Report Addendum.

8

I 16)

Comment 16 1'

L Section 8.1.4. n. 26 A discussion of how the background exposure rates were determined should be provided. When you state that the exposure rates ranged from 8-11 pRem/hr, do these exposure rates include background? Note that the release criteria is 5 pRem/hr l'

above background at I meter.

NES Response Indoor background exposure rates were determined by entering the unaffected-buildings on site and recording background measurements at 1 meter from any surface. Background exposure rates had a range of 8 - 12 pRem/hr with the mean l'

calculated at 9 pRem/hr. This is recorded on some exposure rate documentation.

Outdoor background exposure rates were determined by surveying outside all buildings on site and recording background measurements at 1 meter from any surface. Background exposure rates had a range of 8 - 12 pRem/hr with the mean calculated at 9 pRem/hr.

l-This revision will be clarified and incorporated into the Final Report Addendum.

17)

Comment 17 l

Tables 12-15. n.30 Do the exposure rates include background? Note that the exposure rate data in these tables range from 6-12 gRem/hr. This appears to be inconsistent with the statement in 8.1.4 that exposure rates ranged from 8-11 Rem /hr.

NES Response Exposure rates do include background. Exposure rates recorded less that 8 pRem/hr should have been recorded as < 8 pRem/hr. The statement in Section 8.1.4 that states.." exposure rates ranged from 8-11pRem/hr." will be changed to 8-12 l

pRem/hr.

This revision will be clarified and incorporated into the Final Report Addendum.

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18)

Comment 18 Section 8.4.3.1. n. 36 -

A statement is made that soil grid and sample locations are presented in Attachment

1. Under "95% Confidence" section in Attachment I some of these locations are presented. Ilowever, the specific locations of many of the soil, subfloor, and bulk q

sample collection points are not presented. Please provide diagrams showing the locations of these samples. Were soil samples collected in the vicinity of the r

contaminated drain line found in Room 4 of the Plutonium Building?

NES/IES Response Subfloor samples were collected in Room 2 directly underneath the expansion joint f

area, Room 3 in the North East Corner and Room 5 along the south wall. Diagrams of the exact locations will be provided in the Addendum of the Final Report.

Soil samples were collected in the vicinity of the contaminated drain line found in Room 4 of the Plutonium building (SDO-305, SDO-306 and SDO-307) and are found

. i in the soil sample section of Attachment 1 of the final report.

19)

Comment 19 Table 18. n.36 l

The data sheets in Attachment I for samples SDO-251 and SDO-255 show two Cs-137 entries that are added together. We assume that only one of the entries is

.j applicable. Please confirm our assumption so that future confusion may be prevented.

NES/IES Response Your assumption is correct. The Spectran-AT software library incorrectly contains two entries Cs-137 and Csl37 without the hyphen This results in both being 7

calculated and the total activity being addea. We ve corrected the problem.

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i 20)

Comment 20 i

Table 22. n.38 Note the "QA Results" section shows a Cs-137 concentration for sample SDO-224 of 0.327 pCi/g. This table, however, shows no detectable activity. Shouldn't a concentration of 0.327 pCilg be detectable?

I 10

NES/IES Response Concur. The result should have been reponed as 0.327 pCi/g.

This will be clarified and incorporated into the Final Report Addendum.

21)

Comment 21 Tables 18-24. pp. 36-39 We suggest a footnote be added to these tables that indicates the minimum detectable activity level for each radionuclide.

t NES/IES Response Concur. MDAs for each radionuclide will be added as a footnote to each table in the Final Report A' dendum.

d 22)

Comment 22 OA Results Section. Attachment 1 A gamma spectroscopy 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 "SDO" sample identifications?

NES/IES Response The sample was taken at the Waste Disposal Building soil area waste pile and correlates to SDO-234.

23)

Comment 23 95% Con 0dence 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 the samples are taken. For example, surface samples should be averaged separately from samples taken at the 15 cm - 2 foot depth.

11

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In check.ing the confidence calculations for the Plutonium Building soils, we were unable to verify average concentration value you obtained for the 58 samples given in

l Tables 18 - 21. We assume you treated the non-detectable values using the LLD value i

of 0.24 pCi/g. Please reverify this computation.

NES/IES Response l

NES/IES did use the LLD of 0.24 pCi/g for this calculation. The computation will be l

re-evaluated and the results reported in the Final Report Addendum.

24)

Comment 24 j

Plutonium Buildine Data Sheets. Rooms 6. 7. 8. I1.12. and 17 t

In the exposure rate data sheets, the background is not provided. What are the background exposure rates for these rooms?

t NES/IES Response

[

The background exposure rate for the Pu Building range from 8 - 12 Rem /hr. The mean background exposure rate was 9 pRem/hr. 9 pRem/hr will be reported as background for each of these rooms.

l This will be clarified and incorporated into the Final Report Addendum.

25)

Comment 25

!. Air Samples j

Why is the conversion factor for alpha 6.7E-7? This conversion factor was not used in the alpha MDC calculations.

NES/IES Response This conversion factor is provided for alpha particle self/ filter attenuation. It should have been used.

j This error will be corrected and incorporated into the Final Report Addendum.

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• ISOTOPIC PLUTONIUM RESULTS SU2cdJuly Lab Name.: Analytical Technologies, Inc.

Date Collected: 07/24/93 Client Name: IES Division of NES Date Analyzed:

08/13/93 Client Project ID Nuclear Lake Decomm.

Sample Matrix:

Soil Lab Workorder Number. 93-08-013 Count Duration: 1000 Min.

Client Lab Pu-239 Pu-238 Sample ID Sample ID (pCi/g)

(pCi/g)

1. 1 08-013-01 2.32 0.41 0.16 0.09 s

1. 2 08-013-02 0.10 0.06 0.22 0.10

1. 3 08-013-03 0.07 0.02 0.02 3

1. 5 08-013-04 0.19 0.04 0.02

1. 6 08-013-05 0.10 0.03 0.03 0.02 Blank 08-013-B1 0.01 0.01 Duplicate 08-013-D1 0.07 0.02 0.02 Remarks:

Sample 93-08-013-D1 is a duplicate of 93-08-013-03.

= Below Detection Limit; see method for DL determination 1

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